ML20217F450
| ML20217F450 | |
| Person / Time | |
|---|---|
| Issue date: | 09/16/1999 |
| From: | NRC |
| To: | |
| References | |
| REF-10CFR9.7 ASB-300-921, NUDOCS 9910200324 | |
| Download: ML20217F450 (221) | |
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( . OFFICIAL TRANSCRIPT OF PROCEEDINGS UNITED STATES OF AMERICA l NUCLEAR REGCLATORY COMMISSION 1
Title:
RELEASE OF RADIOACTIVE MA'l ERIAL WORKSIIOP l
i 9 .
Case No.:
O Werk Order No.: ASB-300-921 7
tv LOCATION: San Francisco, CA b
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DATE: Thursday, September 16,1999 PAGES: 240 - 411 s.
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i 240 i 1 UNITED STATES OF AMERICA
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( , . 2 NUCLEAR' REGULATORY COMMISSION 3
j 3 ;
l
- 4. ***
)
i 5
I 6 RELEASE OF RADIOACTIVE MATERIAL WORKSHOP 7
8' 9
10 1 I
11 Radisson Miyako Hotel I 12 1625 Post Street ;
4 13 San Francisco, California
,_ 14:
s- 15 16 Thursday, September 16, 1999 17 18 19 -
20 21 The workshop commenced, pursuant to notice, at 22 8:30 a.m.
23 l
24 '
25 i
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241 ,
i 1 P_R O C E E D I N G S 2
[8:30 a.m.]
3' 4 MR. CAMERON: I hope you all had a good night last 5 night. And we bant to thank you again for all of the good 6 discussion and attention yesterday. I think we feel that we 7 had a'really good first day of the meeting, and we expect 8' that to continue today.
9 I just wanted to run through what I anticipate the l
\
10 agenda being and get any feedback from you before we go on.
I' Ray Turner has kindly consented to give us a little primer, 12 so to speak, on recycling. And we're going -- we're going 13 to start off with him as soon as I'm done talking here.
,, 14 And I have a strike through through health impacts (s / 15 because we pretty much finished it yesterday, but if there's 16 anything remaining that people want to say on that we can --
17 we'll go to that first.
18- We have Giorgio Gnugnoli from the NRC staff who is l l
19 going to do a presentation on economic impacts. The lasc i
.20 presentation is Tony Huffort, and it's basically 21 implementation issues. And implementation issues came up so 22 . many times yesterday, and we tried to keep track of them on 23- those rather unartful flip charts over there in the paddock.
24 .But I'think that an important session for us today is what 25 we're calling " Don's shoes." And Mark started us off ANN RILEY & ASSOCIATES, LTD.
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a 242 11 yesterday with " Mark shoes," but we're going to do a " Don A
s- 2 shoes" today, and this is' Don Cool, who is responsible for
'3 this -- this project. Juxi I won't say anything more than 4- this. project.
5 But what would -- what would you do if you were in 6 Don's shoes in terms of going forward with this from a 7 project standpoint and from a substantive standpoint. And 8 this will be our sort of integrating summary discussion to 9 try to' tie together a lot of the things that we heard 10 yesterday and will hear this morning. So, I'm sort of 11 excited about getting to this -- to this point. I don't 12 -think that we'll take the whole day to do all of this, so an 13 added benefit may be that we'll break a little bit early and 14 give you some additional time.
15 I do want to just before we go make sure that we
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16 run through some of these paddock issues, because I think a ,
i 17 lot of them will have been covered by the time we get there, 18 but if there is anything that hasn't been covered, if 19 anything -- anybody wants to add anything on these, we'll go 20 to that.
21 So, when we're talking today, when you're 22: listening to other people talk, keep in mind Don's shoes, 23 okay, for that discussion. What would you do? ,
24 Before we go to Ray is there anything that anybody 25 wants to say about the agenda or wants to ask? Any ANN RILEY & ASSOCIATES, LTD.
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143 l-L 1 questions before we get started?
) 2 All' right. Well, Ray, thank you for doing this.
3 And I'm just going to. turn it over to you, Okay?
4 MR. TURNER: Okay. I think it's important -- can 5 you. hear me okay?
6 I think it's important when we start talking about 7 rule making and things of this nature and -- radioactive 8 materials, that we get a little bit better understanding of 9 what's going to happen as we recycle, primari2y the carbon 10 steels and also some of the other products, the nickels, 11 coppers, aluminums and things like that. What's going to 12 happen downstream from the gate, from the scrap collection 13 point, be that a scrap dealer or be that a steel mill. Some 14 steels are sold, some scraps are sold directly into steel 15 mills.
16 I'd like to start, just kind of give you a brief !
17 scenario of each type of operation. First we'll start with 18 a torching operation. Primarily done outside with either 11 9 natural gas or plasma or propane torches or possibly mount 20 gas and oxygen. Just somebody standing there holding a 21 torch, usually about three, three to four feet long, and 22 he's standing on top of the material to torch the material. ,
23 Protective gear that he wears would include like a 99 d.ust 24 fold respirator for dust and fumes and mist.
L25' The drippings, as he cuts at the torching table or
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- I he cuts the material, the drippings usually will fall to the
) 2 ' ground. Some of those drippings will be -- you'll be able 3 to remove them with a magnet as he removes the material 4 that's been prepared and cut. But a lot of the material 5 will just be in the -- the drippings will be in the form of 6 slags, and they'll form a base on which that employee is 7 going to be standing and working from then on. So, if he 8 cuts a lot of the material just bear in mind that he's going 9 to be standing on the torch drippings and working on top of i
10 those. They can be shoveled up and disposed of. Typically, 11 they are disposed of at a landfill somewhere. I don't know 12 if that would be a RCRA landfill or probably could be, if 13 it's not -- if it's not contaminating material, just an 14 industrial landfill.
O
\m / 15 The railing plate, if there's any rail involved or 16 steel beams or plate, a lot of this material, if they're in 17 pretty good shape, the web is actually cut out of the inside 18 of the plate, as we discussed yesterday, and that material 19 is either sold as reusable plate or as rerollable plate.
20 hit's never melted again, it's just reused in it's current 21 form. They just reshape the dimensions, the width, the 22 length, and it's reused in its current form. Again, that i 23 would come from the torching operation as well.
24 Usually, that type of material runs anywhere from ;
25 about 50 to 70 pounds a cubic foot in its prepared state, i j
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l 1 once it's been prepared to go to the steel mill.
l l \ 2 The next process would be a shear. Just like a
'3 huge scissors. It can either be a stationary sheer or it 4- can be-a mobile shear that's operated on rubber tires or on 5 track -- a track crawler. Primarily, again, it's done 16 outside. Almost all of this scarp processing is done 7 outside. There's a few locations in the northern part of 8 .the country where they have some inside oper tionr. but for 9 the most part I'd say probably 95 percent of them are going i l
10 to be done outside in the open.
11 Just use standard protective gear when they're l 12 operating a shear. They don't use any kind of a respirator, 13 but they do use -- they'll have leather gloves. They may 14 have some protective clothing in the event that they have j 15 some material that's a little bit too heavy to shear, 16 they'll torch gut that material, and of course they'll have 17 steel-toed shoes.
18 The only -- the biggest position of concern 19 probably at a shear, if you're going to be sheering, and you 20 can sheer materials at, you know, all the way up to maybe 21 six or eight inches. Typically, when they're running the 22 shear we're just going to be talking about plate, structural 23 beams. They're not going to be shearing rails because ,it
-24 . tears your shear up too badly. They'll shear a lot of the 25 sheet iron, a lot of the piping and stuff like that, and the l
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p 246 1 shear just kind of eats that up like cutting through butter l 2 with a knife.
3 What happens at a shear at the mouth of the shear 4 as a scrap comes up, a scrap comes down to a shaker table 5 and it actually shakes down on a grate. And the scales or 6 some of the coatings like the galvanizer zinc coatings will 7 be on some of the piping, some of the rust and things like 8 that will collect right below the mouth of the shear. And 9 periodically, and it usually happens probably about once a 10 week, they'll put some workers in there just with shovels.
11 Same protective gear that we mentioned, but no respirators.
12 And they'll just shovel those sludges and scales up. That 13 material is typically disposed of at a RCRA landfill, p_ 14 That material, once it's prepared, runs about 35 ksl 15 to 55 pounds per cubic foot. It's usually sheared in, for 16 the most part, in two links. Either three foot long or five 17 foot long material by about two feet wide. In the event 18 it's sheared for a foundry then it will be sheared one to 19 three feet long, but most of it will be either three or five 20 foot long with probably 50 or 60 percent of that being five ,
i 21 foot material. jl 22 The third type of operation would be a shredder.
I 23 And this one, a little bit different from a shredder that I
24 would shred vegetables or slaw. A shredder is a -- it's I l
25 like a huge box than you can feed maybe two or three I
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, : . ._ j 247 1 automobiles into at one time. It has a very large cylinder 2 that has some' manganese, high manganese -- I think 11 to 15 3 percent manganese hammers, probably about this big, maybe 18
- 4 inches long and probably 14 inches wide, that are uitting on 5 pins around this rotator shaft. And this rot uor shaft 6- spins about'anywhere from 650 to 1,000 rpms. And these 7 hammers, they call them shredder hammers, actually pivot and 8 swing on'the shafts,.and they're all around this, the 9 shredder shaft. Usually just beat and tear the automobile 10 or the sheet iron or piping and things like, just literally 11 just. tear it to pieces.
.12 You're primarily talking about the thinner 13 . materials that will.be going through a shredder. They ge .
14 wouldn't be shredding large structural beams. It wouldn't 15 _ be' shredding heavy. shafts because it would -- it will I
16 literally tear the shredder apart. So, you're talking about 17 material that's probably a quarter of an inch thick and
~ 18 under for the most part. It can take some heavier materials 19 and obviously does because some automobile parts are thicker 20 than that.
21 'Same, just normal protective gear. No respirators 22 are used around shredders. They have some employees on the 23 stacker belts as the material comes off of shredders -.
24 well, let me back up just a moment. As the steel or the
- 25 iron or the ferrous material is shredder it falls down onto 1
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248 1 a conveyor belt. It runs up from that conveyor belt where l )- 2 it's picked up with a series of either one, two or three 1
3 magnets, and roll over onto a second conveyor belt. And 4 what this does is separate the ferrous material from the !
5 non-metallic or non-ferrous material which goes off on l
'6 another conveyor belt and is stacked into bins. It 7 separates the copper, it separates the aluminum,' and then it i 8 separates what's called shredder fluff. The aluminum 9 material is what -- copper and aluminum is what we call :
10 residue, and that's sold on the open market to copper and 1 11 aluminum producers for whatever is made out of copper 12 aluminum products. o 1
13 All of the material in almost every process is I 14 stored on the ground once it's processed until it goes to
( 15 the-steel mill where it 'is again stored on the ground out in 16 the open until it's melted.
17 The -- in -- both the shear and the shredder kind 18 of destroy themselves. They self-destruct. So, if you i
19 -operate a shear or a shredder, especially a shredder, for l
20 about eight hours, you're going to have maintain or perform !
21 maintenance on-it for another four to eight hours in the 22 evening or at night.
23 In some cases it's a one-on-one. You operate, l 24 eight hours and if somebody overshreds it you're going to 25 maintain it for the next eight, which means that you're
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L 249 TN going to have a lot of welding going on inside the shredding 5t_) 2 chamber around the shredder shaft and the hammers, and 3 you're going to put some employees down inside the shredder
'4 box underneath the rotor, because a lot of the scales and 5 things that fall off, like in the shear, some of the scales 6 are not going to go on into the conveyor system, they're 7 going to-fall down and' collect'inside the shredder box.
8 So, at the end of the day and especially at the 9 end of the week you've got some employees that are down 10 under the roter with some shovels and have to just shovel 11 that stuff out.
12 That material, in its prepared form -- oh, the 13 shredder fluff, by the way, which is like your fabrics or
,_ 14 cloth or whatever would come off of a wire. Anything that's s
15 non-metallic goes to a RCRA permitted landfill, either on j
^
l 16- site -- most of them are offsite, but some facilities have 4
l 17 an cn1 sight landfill, permitted landfill.
18 Material in its prepared state runs anywhere from 19 60 to 90 pounds per cubic foot, and if we're talking about 20 sheet iron we're probably talking about something that will 21 be about 65 pounds per cubic foot in its prepared state. ;
22 It's either -- all of the material will either be 23 magged, or picked up with a magnet, or it will be picke.d up 24 with a grapple and dropped into a truck or a rail car or 25 loaded into a barge. Some shredders have conveyor systems !
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' 1 4 1 that they can actually just convey right out into a barge or
- 2 into.a rail car as it's being prepared, so then it will be 3 handled by a magnet or a grapple when it gets to the mill.
<4 The next category will be a baler. And this is 5 nothing more than just a big squeeze box. It squeezes cheet 6 iron and just makes various size cubes or bales or you may l-7 hear theta called, referred to as bundles, number one or 8 number two bundles. The material is just squeezed very 9 tight, usually about 90 pounds per cubic foot in its 10 finished state.
11 Again, repair is quite a bit of welding on the 12 equipment because of the abrasion and materials that goes
- 13. through the baler, but probably a lot less personal contact 14 .there than what you would see in a torching or a shredding O
\w / 15 operation. A baler kind of destroys itself too. Most c; 16 those are in the areas of hydraulics and things like that.
17 Smelting. In the event that some of the 18 components have rather large percentages, substantial 19 percentages of aluminum, then they may be subjected to an 20 aluminum sweat furnace. These are primarily electric 21 induction type furnace. Not induction, just electric, I 22 guess, convection type furnaces where it -- the aluminum 23 will actually be melted away from steel. You can take,,for <
24 example,-an automobile transmission or some kind of a i
25 transmission, and put it in these sweat furnaces and it will
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l 251 1 melt away the aluminum. You end up with a little bit of f )\
)%, 2 dross and you'end up with the iron or steel components.
3 The dross that comes from the sweat furnaces, I 4 believe, is usually disposed of at a RCRA title landfill.
5 Some of that material now is being recycled back to the 6 steel industry to use for a deoxidation material. You have 7 to use a lot of de-ox in the steel industry on every heat of l 8 steel that they make or every batch of steel that they make. {
9 So, some experimentation is taking place this year trying to 10 use some of the aluminum drosses back into the steel 11 industry again. Again, you're talking about just standard 12 safety equipment.
13 Some of the material, if it's in a prepared state, 14 can be taken direct to a steel mill where it will either be
\- 15 magged or grappled into a charging bucket and dropped l 16 primarily into electric arc furnaces is where most of this 17 type of material would go. And there's several reasons for
- 18. that I won't go into right now. But that's the type furnace 19 you're going to be talking about, primarily, is electric arc 20 furnaces.
21 Electric arc furnaces produce about 50 percent '#
22 the steel that's produced in the United States. That's 23i where most of your recycled metal goes. It operates .
24- primarily on 100 percent recycled materials, for the most 25 part. And.the reason I say for the most part, there are
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- p. 1- some. materials that are iron' based, virgin iron-based
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( 2 materials like hot brigaded iron is made from iron ore fines ;
3 that's also used in electric arc furnaces, or some pig iron 4' may be.used.in addition to the recycled materials.
5- In the melting process in electric arc furnace, 6 depending on how aggressive the steel mill is with their 7 oxygen blowing practice, and they all blow oxygen, 100 8- percent.of them blow oxygen into the steel, into the bath,
- 9. to refine the steel. During the blowing of that c,rygen, 10 that's primarily where most of your bag house dust is !
11 generated. And depending on the aggressiveness of the 12 oxygen blowing practice it will generate anywhere from 20 to 13 40 pounds of bag house dust for tone of steel charged.
14' That material also -- it's called a KO 61 dust.
15 It's characteristically hazard because of things like 16 cadmium and zine has some lead that's in there already.
17 So, whatever goes to the bag house, whatever is la burned off and goes into the bag house, which is early in 19 the melting stage, is going to end up in the bag house dust, 20 .If it's a substantial amount, then you're talking about 21 mixed-waste material. If you're talking about something
- 22. that's enough to contaminate a bag house, above permissible 23 limits. From what I've heard I don't think we're talking 24 about those levels on this material. I think we're talking 25 about levels that may even be undetectable by the currently ANN RILEY & ASSOCIATES, LTD.
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253 1 ' deployed systems that are at steel mills and at scrap yards.
() 2 I wouldn't anticipate that being a problem, but I'm not the 3- expert,-you're the experts here. So, just to give you an 4 idea of what happens there.
5 In addition to the bag house dust they are also 6 going to generate anywhere from three to five percent of 7 slag. That number can vary, it can be as much as six or 8' seven percent slag, depending on how much lime the steel 9 mill has to add to achieve the properties they want to 10 achieve. For example, if they're looking for low 11 phosphorous or low sulphur, they're going to add more 12 calcium or more lime, either dolomitic lime or calcine lime, 13 into the furnace, on top of the bath, and that will all go 14 into the solution with the slag that comes out of the 15 metals. So, it can be anywhere from three to about five, 16 normally about three to five percent of the melt ends up in 17 slag.
18 The slag usually goes through rock crushers that 19 are onsite at most mills, and most electric arc furnaces 20 have their onsite slag hammers and rock crushers. It's 21 crushed and sized and used for things like roadbed, fills, 22 driveways, the -- what do you call the material on the rail, 23 the railroad ballast for building railroad beds and things l
24 ,like that. It's also used for things like the sewer drain 25 fields. I. forget what you call those things. But anyway, l
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, 1 the drain fields for sewers and things of that nature.
{
l) '2 The balance of the material ends up in the steel 3 matrix. And when that material is run through what's called i
4 a' continuous casting machine, they actually melt it in the 5 furnace then they pour it in a ladle. Then that ladle sits i 6 on the casting machine over the top of another very large 7' trough that has some nozzles or refractory nozzles or slide 8 gates on the bottom of that which actually open up and let l 9 the steel then flow into the molds.
10 As it flows into the molds of course it's in a 11 molten state now. They have to chill it very, very quickly.
l j 12 And the molds are open top to bottom and they're continually 13 moving. When the billet comes out of the bottom of the mold 14 it's in a -- it's a very soft state, but a solid form. It's 15 no longer liquid. The internal structure of the billet or i
16 the slab will be liquid, but then as it goes down through a 17 bin section it's flooded with just a tremendous amount of i
18 water. And by the time it gets to the shear, or most of 19 them are torch cut off now, it's formed about one or one and i 20 half percent scale, which is called mill scale, on top of ,
21 the billet or on top of the slab or beam or whatever it may 2:2 be.,
P ,
23 That mill scale is collected in the mill scal.e l 24 pits, and the primary use for mill scale is probably in l 25 cement plants. Some of it is also sold back to the big 1
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,7 . . _ , .
i I 255 l 1L integrated steel mills, where it's mixed with some other
(~){
is ,/. 2: materials, iron ore fines and what we call red ore, and it !
3 goes to a centering plant to give them a product. It's 4- primarily FE 203 and F304'. It can go back into an l . 5 integrated steel mill where they will recover most of the j 6 iron from that material. I don't know what the percentage 7 is but it :an go either place. It can go back to an 8 integrated steel mill and become part of the iron again or 9 it can go to a cement manufacturer where it's, you know, 10 cement manufacturers buy a lot of mill scale, that's a lot i
11 .of our.
12 And the only other thing that I have here would be 13 some of the material -- some of the material can be sold off l 1
14 and used on things like farms to make farm gates in the l> 15 event that it's piping and things like that. Typically, you !
16 know, for the most part in the scrap industry that's not ]
17 done. Usually when it goes to a scrap yard it's either 18 sheared and processed and cut up. They don't let it lay j 1
19 around and collect and wait on a farmer to come and see if !
i 20 he can use any of it. It's usually chopped up, cut up and I 21 sent right out as quick as they can get it out the door to a 22 steel mill. You don't see scrap yards carrying huge 23 stockpiles of scrap like they used to years ago. Usually, 24 he'll have more than -- no more than just a couple of days 25 or a few days supply of scrap on the ground at any one time, l
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4 256 1 then it goes out the door. They -- the economics of the g_) 2 scrap.' industry today'are such that you just can't afford to 1
3 hold'it around and speculate on the market. They're going I
4 to get rid'of'it'just about as fast as they process it.
5 That's -- as far as economic impact on the carbon 6 ' steel grades, with the quantities we're talking about here, I 7 I don't see an economic impact whatsoever. None. I mean, 8 we're talking about approximately 100 million tons a year of 9 carbon steel that's recycled just in the United States. And 10 out of 100 million tons a year we're talking about maybe 11 20,000 tons or so a year of this material being recycled, on 12 an average, or 300,000 or so tons over the next 30 to 40 13 years. That's not a drop in the bucket, I can tell you. It
_ 14 is not going to create an economic impact from the carbon
(/ 15 steel segment..
16 The nickels and the coppers, if there are large 17 stockpiles of those on the other hand, could create some 18 economic impact on the nickel suppliers, nickel alloy .
19 suppliers and the copper alloy suppliers. Those -- those 20 type -- well, if it's copper wire, for example, it's going 21 to be stripped and the chopped in a real fine, probably one 22 eighth inch long to maybe a quarter inch long copper chop, 23 and the same thing with aluminum. The aluminum may be 24 remelted then into what they call sows or small pigs, which 25 will then subsequently be remelted either in an aluminum
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-1 furnIace, or a lot of the aluminum, then, is sold back to the t)
\ ,j- 2 steel industry where it's used for deoxidation materials, i l
3 remove the oxygen. After it's tapped out into the ladle you I 4 have to remove the oxygen from the steel bath to get rid of 5 the inclusions. A lot of this aluminum is used back into 6 the steel industry then. That's pretty much it in a 7 nutshell.
8 MR. CAMERON: Well, that's great, Ray. It also i l
9 ' serves as a useful introduction to Giorgio's topic. But 10 let's go out for questions or comments to Ray. And if Jim 11- Turner or Phil want to tell us more about your processes 12 that would be illuminating too. Any questions or -- Paul l
13 Genoa
, 14 MR. GENOA: I don't want to let anyone down. Paul V 15 Genoa, NEI. I 16 Ray, that was great. You just went through an 4
17 entire industrial process with the visir>n of someone who is i 18 concerned about the workers, and potentially the public, l 19 from any contaminants that may be associated with the 20 process.
21 So, that was a really beautiful step-by-step i
22 environmental health analysis of your field. And I was l l 23 drawn immediately to the parallels between the trace amounts 24 of hazardous material associated with that process that 25 concentrate in various parts of the process and have ben !
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,x 1 identified and separated out for specific disposal ;
[( ,)
2 requirements, because we learned that that's'how the process 3 ~ works. And the similarities with' radioactive contamination 4 are' identical.
5 Some of the' material that contaminates the steel l
6 scrapLis just' naturally included in the steel matrix one way !
i or the.other. Other is perhaps the coating on the wiring, 8 maybe lead connectors that are used in the wiring or 9 whatever. .There are parts that you added to the product 10 that was then separated in some fashion. So, there's sort 11 of, you'could almost say, natural. analogues, between natural 12 radioactivity and manmade radioactivity. Sort of that 13 Lanalysis is following through the scraps systems. And 14 you're -- and it's concentrating and being separated and its
(_,f 15 potentially. exposing workers at different steps along the i
-16 way. And it's been analyzed and it's been identified that l 17 it needs to be controlled in a certain way, and at certain 181 points'in the process that material is collected and sent
-19' off to RCRA facilities to isolate it. But we all know that
'20 it doesn't get every atom of that material. As a matter of 21 fact, there are di minimis standards below which you don't 22^ have to worry about some of that stuff. So, some of it 23_ stays with the steel all the way through the process and j 24 other is Feparated out.
l 25 So, there is a very clear and analogous situation g
l O
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259 1 to radioactive material that may be associated with it, I
2 -although because radioactive materials have other properties 3' than the hazardous materials have, they expose different 4 risks to the workers and to the public at different stages, 5 and of course it would have to be fully analyzed.
6 But anyway, I was just drawn by the comparison and 7 I think it's worth considering. But you certainly wouldn't 8 want to recycle steel with high levels of contaminants. I'm 9 sure that you separate the batteries from the automobiles 10 before they go through a shredder.
- 11. MR. TURNER: Absolutely.
12 MR. GENOA: You shouldn't put significant 13 radioactive contaminated metal into the front end of a 14 process like that either because it becomes unmanageable.
('N
\sl 15 The reality, though, is that there is probably some metal 16- that has very small amounts that probably could go through 17 the process without harm. It probably is today. And I 18 think you point out correctly at the levels we're talking 19 about and below you would never be able to detect it, you 20 could only calculate it. Thanks.
21 MR. TURNER: One thing -- two things. Let me 22 address the bag house dust problem once again because I 23 don't think I quite took that into completion. .
24 Bag house dust, as several years ago, can no 25 longer bear a -- can't~ bear a mixed waste. Much of the bag
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1 260 l 1 house. dust, or most of the bag house dust, from electric arc
' () 2 furnaces go to a subsequent process where they reclaim the 3 zinc from that dust. There is at least one, maybe a couple 4 of. processes now to claim some of the other metals, but for 5 the most part they're just looking for the zine that comes 1
6 out of the bag house dust.
]
7 In the case of cesium 137, in mills that have had 8 contaminating events, most of the cesium 137 ends up in the 9 bag house dust, so that creates a mixed waste. However, i
10 when it goes through the'derzincing process we've run a lot j 11 of tests on the zinc pigs, and it -- Jim's mill, for 12 example, ran'a to'of tests on the zinc pigs, and they have
-13 found no cesium 137 that carried over into the zine pigs 14 once it's remelted and they make large sows or pigs out of j 15 their zinc. It pretty much stays with the dust, then the 16 - dust is disposed of'at a - .I don't know, industrial or RCRA 17 landf111. ~~
f c. -
18 Your point about melting some high-level 19 radioactive material. In some cases that's done if you want 20 to use the material for_ things like shielding blocks where 21 the material is going to become irradiated again anyway. ;
i 22: You may want to melt some higher level radioactive material.
l l
23 You know it's going to -- is still going to be controlled 24 - and become shielding blocks or something for -- in some 25 other kind of irradiater. Any other questions?
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1- HMR . CAMERON: Phil?
. ,r\
Jj 2 .MR. GIANUTSOS: I just want to -- our facility 3 does'not melt scrap with the intent of producing a clean 4 . product in that there is no volumetric standard that we can l 5 look to right not. Hopefully that will change in the not 6 too distant future. We do produce contaminated blocks. One 7 of the applications right now is for use in shielding an 8 application where there's a significant neutron fluence. So 9 the blocks will become activated whether they are clean to i
10 begin with or.not. That's an excellent application for ll 11 recycling the steel in that we can take low-level materials 12 and even high-level materials and blend them to produce a i
13 block that's easily handled, will be subsequently activated l 14 anyway, and really divert that from the otherwise clean n(_/ 15 . waste stream. .
16 I should also add that we've taken all of the 17 processes that you've described and moved them indoors and 18 really done extensive air sampling for both radioactive and 19 non-rad constituents, and find, for the most part, with the 20 levels that we've set up to accept, the overriding concern 21 is nuisance dust during cutting operations, so we're wearing 22 respiratory protection for that, and it provides more than 23' adequate protection of the workers from the radioactive.
24 materials that'are generating.
25 The process itself does inherently separate a lot I
r y 4
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262 1- of' materials. The NUREG draft contains some of those
-Q
(_j 2 . partitioning factors. They're very significant and really 3 need to be looked at as a process in the future. Cesium, as 4 you noted, does essentially leave the bath, as do some of 5 theJother more volatile materials. Tritiated materials 6 .certainly are going to be cleaned up in the process.
7 Iodines, some zincs, works pretty well. Other materihls 8 will preferentially.go to the slag. So, we really need some 9 biometric standards to look at this process for more than 10 just producing contaminated blocks. There's a lot of 11' potential for it there.
12 Now, we run an induction furnace, so the 13 atmosphere is relatively well controlled in the building.
('N 14 We have no effective release. And that's a couple of things k_s) 15 that I look at in the NUREG. The assumptions are bag house 16 'only, for example, where our bag house is treated 17' additionally with a paper filtration. We sample the 18 effluence. They're much lower than what would be 19 anticipated from a normal facility. That's just some of the 20 comments I wanted to add forth.
21 MR. CAMERON: Okay. Thank you very much, Phil. I 22 think Dr. Lull, in the back, might.
23 MR. LULL: Just a point of clarification. At the 24 end of your comments you mentioned the volume of potentially 25 contaminated material to be recycled versus a total amount
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263 N
1 that's being'done and recycled, and that this is a pittance.
~( /^j 2- Does that mean, then, that one really can't make a strong 3 ' economic argument that there is'-- that we have an 4 obligation as environmentally attuned people to recycle this 5 material, that;it really doesn 4t make much difference 6 whether we recycle this contaminated stuff or'not, and the 7 big picture of steel being_ recycled. And does that take 8 'away an argument from us.in terms of that this is a good 9 thing to do?
z ..
10 MR. TURNER: In terms of the carbon steel, let me
{
11 clarify myself here. The 20,000 tons or so a year, which is 12 primarily carbon steel, is a drop in the. bucket compared to 13 'the overall scheme of things. And I can tell you in the 14 scrap businesses I do there is absolutely no impact to O
b 15 20,000 tons of steel hitting the market. No economical 16 impact there at all.
17 Let me again clarify. When I say there is no 18 economic impact, I am talking about to the scrap industry.
'19 It's not going to compete with other grades of recycled 20 scrap metals that are non-radioactive or non-hazardous. It 21 will not compete with the scrap industry. Twenty-thousand 22 tons is not going to make that much difference.
23- In the steel mill the point that Jim is making is !
24 if'it was contaminated highly enough to contaminate that j ' .2 5 mill then it certainly would be an economic impact on that I
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264 1 individual mill if they.had to shut down and do a i f 2 decontamination on the mill.
3' MR. KARNAK: Yeah. EPA did our economic analysis.
4 We found exactly that, that there was not enough material-
~5 that it would impact the industry, wouldn't really make much 6 of an impact on mining new steel, primarily -- I had learned i 7 a lot about economics in the process of looking at this --
8 primarily because it's'a matter of trade off. If this 9' material were not available there might be other recyclable l 10'- material with only slightly higher cost that would go into -
11 the stream. We couldn't do it one for one against new 12 steel. And _ the -- at one tenth of one percent of the flo /
13 of recycled steel it really didn't amount to enough to cause i 14 a significant impact.
/~'%
V 15- MR. CAMERON: Dr. Lull again.
16 MR. LULL: I guess, then. you could end up then 17 talking about sort of a~ specialized recycling of material 18 like was described where you're taking stuff, and if it's 19 very expensive to dispose of this material in specialized 20 low-level rad'ioactive landfills or some FUSRAP type of 21 facility, presumably recycling it around again, like you're 22 describing with your specialized process, might make 23 economic sense within that economic realm. Although it, 24 doesn't impact the total steel industry in a way or the 25 economics of mining, it still makes a lot of sense for
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.w 265 1 society to be recycling this into a use where it's just D) i 2 going to get recontaminated again rather than contaminating 3 brand new steel and having to dispose of more stuff.
4 MR. CAMERON: You know -- oh, go ahead. I'm 5 sorry, Ray.
6 MR. TURNER: Another point that I'd like to make 7 here'is that one of the processes I mentioned earlier this 8- morning is a mobile shear, both stationary and mobile 9 shears. A mobile shear can really be loaded onto a low bed 10 type of truck and transported to a DOE facility, for 11 example. And the material can actually be sheared on site 12 a t the facility without any fear of then contaminating 13 somebody else's scrap yard with the scales or whatever. All 14 the scales or whatever falls off would remain there at the 15 facility and could be cleaned up at the facility.
16- MR. CAMERON: Okay. And Paul.
17 MR. GENOA: Yeah, to follow that thread. And 18 that's exactly why we need a standard that's at that very i
19 low level that would allow you to say that once that shear 20 came on we know conceptually, absolutely, that there will be 21 some contamination from using the shear on the DOE site.
22 Not how much, very little. Have to have a way to say that 23 that shear can come off the site now when it's done. Not 24 that the shear is ever going to hurt anybody from whatever 25 little bit of the contamination it may have picked up doing
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266 1 that job, but there's got to be a way to say it came in and G
i, ,) 2 now it can go out safely. That's what we're here about.
3 We're not here about trying to set levels where we can ship 4 radioactive caterial into the pub]ic domain.
5 MR. CAMERON: Okay.
6 MR. TURNER: It's not extremely difficult to 7 decontaminate *2 shear. I've gone through some exercises 8 where we were actually shearing some bales looking for some 9 sealed sources that were lost and encapsulated inside of 10 some steel bales. And I worked with the company that lost
~
11 the sources, and that's what we -- we literally took a 12 mobile sheer on site to the steel mill and sheered about 13 1,900 tons of steel bales. The company that provided the 14 health physicist and the radiological workers, all done on 15 very careful scrutiny. Also provided a decontamination
't 6 process in the event that the sheer became contaminated 17- worse case. And even worse case wasn't extremely difficult 18 to contaminate -- decontaminate the sheer. Unfortunately, 19 we never found the sources. They weren't there.
20 MR. CAMERON: Bill Kennedy.
21 MR. GIANUTSOS: I just wanted to elaborate a 22 little on what Paul said. Relative to equipment being 23 cleared, that's a good example. There are pieces of 24 equipment that could be used that cannot be cleared with 25 present technology. A good example would be anything with a I') 10M RILEY & ASSOCIATES, LTD.
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i 267 1 hydraulic system with oily film on it, alpha emitters can't
() 2 be monitored. The current requirements are that surface 3 contamination monitoring be performed. There's many 4 inaccessible surfaces. You drop stripping, electric motors 5 with ventilation holes in them, et cetera, and generate a 6 large amount of waste, not because it's actually 7 contaminated but because we can't prove that it isn't.
8 The assumption has to be this is, in fact, a 9 contaminated piece of equipment. We don't have any tools 10 right now that will allow us to do either a volumetric or a 11 mass based survey and release those items.
12 So, there are some pieces of equipment that either 13 will not be used or processes that will be abandoned as a 14 result of the cecondary waste cost.
15 MR. CAMERON: Okay. Great. Thanks a lot, Phil.
16 Bill Kennedy.
17 MR. KENNEDY: From yesterday's conversation I 18 . understand -- I think I understand that, historically, when 19 sources have been dropped and gone through the mills that 20 you had to do extensive decontamination, shutting down the 21 plants and attempting to collect as much of the material as 22 possible.
23 MR. TURNER: 1 Exty-five times to date.
24 MR. KENNEDY: Sixty-five times to date. What are 25 the clean up levels that you use as targets?
C'\f
+
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- . w .r 268 1 '
1 MR. TURNER: Initially, there was no acceptable 13 i 2 s j level of cesium. We'll just address cesium. Cesium and 3 cobalt have been two of the bigger ones. Initially there 4 was no acceptable level of cesium. If you found it in the 5 bag house dust or in the steel mill in the slag, it had to 6 be disposed of. It had to be removed.
7 That being the case made it an impossibility to 3 melt steel in the United States because all of the bag house 9 dust in the United States has trace amounts of cesium, even 10 in mills that have never had a contaminating event. Just 11 from fall out. All of the materials they use that are 12 refractor materials. Even in the lime, believe it or not, 13 has trace amount of cesium. The zirconium sands that they 14 use in a lot of the mills and refractory sands have trace 15 amounts of cesium. I went to work with -- not for -- but 16 helped some steel mills try to establish a level or a clean 17 up standard, which is what it's asking for, cesium and 18 cobalt in bag house dust.
19 The level -- the clean up level today is two 20 picocuries per gram. Well, it was two picocuries per gram.
21 I think that was raised about a year ago now two. It was 22 100 or 130 picocuries per gram. The material could go to a 23 landfill. Jim could -- Jim Turner.
24 MR. TURNER: At the facility itself, the clean 25- up -- the removal standard is two picocuries per gram for (N
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269 1 the dust, and I think soil is five.
.p And then when you have
( ,/ 2 to cleaned up and you want to dispose of it, if it's up to 3 130 picocuries per gram it can be treated for the hazardous 4 constituents and sent to a subtitle C landfill if you can 5 find one that will accept it. And above that has to go to 6 Envirocare or be divested and sent to a low-level 7- radioactive waste site.
8 MR. TURNER: The other thing that has to be 9 cleaned is the duct work. The bag house, the tags have to 10 be changed and disposed of. And the dust work, these might 11 be 15 or 20 foot diameter vacuum tubes or ducts that come 12 from the top of the steel mill and run to the bag house.
13 Those literally have to be scraped down, washed, and then 14 your standard 5,000 fix, 1,000 removal criteria take over k-- 15 inside the structure.
16 MR. CAMERON: Okay. Let's -- I want to thank you, 17 Ray,-for taking the time to -- to inform us of this, and 18 'also thank Phil and Jim Turner for their comments. It's a 19 great introduction for Giorgio for his presentation. And 20 let's go to Giorgio'and then we'll continue this discussion 21 of economic impacts.
- 22. And I guess we -- we need to thank Giorgio for 23 doing the Powerpoint for all'the presentations, and now he's 24 going to entrust it to Alan Summorville from my ICF. Okay.
'25 MR. GNUGNOLI: I'm sure that Bill Gates 0)
(,
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270 l' ! appreciates the commercial for Powerpoint,'even though,we're
- 2 using Corel' Presentation.
3 The other side of the equation, if you will, in-4 . terms of looking at'~ impacts, is trying to give some sort of
'5' value to compare them.
6 The first question is basically _why do we consider 7 -the economic and cost benefit. I'm.sure that.I'm preaching L 8 to the choir in many.of'these things. But'there's basically
.9- an Executive order that was-signed by President-Reagan that
. 10 said that, in'effect, federal agencies have to consider 11 this. The wording is pretty stringent in that-federal 12 agencies must consider cost benefit in their evaluations of
' 13- alternatives for major rules or regulatory actions.
14 But one of the main. points out of that.particular 15' ' order that has impressed me is that it directs executive 16- . agencies to prepare a regulatory impact analysis.for all of
- 17. these actions, and it'.s.important that these actions should
. 18 .not be: undertaken unless they resulted in a positive net 19 .value to: society. So, already we're sort of put in terms of
.an evaluation' role in terms of considering the impacts of 21- -t.he various' alternatives.
- t -
.22 . The NRC has sort of coalesced these -- this 23 Lparticular executive. order's impact in terms of its own 24 regulations and its own practices and policies And in i
25- 'effect what the BR0058 is is it tells you, okay, this is how :
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,: ... a 271
- 1- we have to do this, this is what we have to consider.
Pi g 2 If we could'go on to the next slide. While it --
3 what are these economic impacts? And we've talked about 4 this pretty much all'of yesterday and beginning today is 5 that if we have to do radiologic surveys to verify 6 permissible levels, this is a cost. This is something we --
7 that depending on what the alternative it is and'how 8 stringent or how unstringent it is, it effects the amount of 9 cost outlay to confirm the fact that you are operating in a 10 safe manner.
11 The next bullet talks about the economic impact on 12 scrap metal and other industries. And I guess Ray's done a l
13 pretty good job in terms of laying all that process out.
- 14- And so certainly you have manufacturing process surveys of l
15 both, I guess, incoming and outgoing, to some degree. And l 16 the last point or last sub-bullet is this false alarm 17 aspect. It behooves the organization to have to verify-18 that, okay, is this a false clarm or do I really have
.19 something-in here like a seal source to worry about. And 20 the impact there is that particular mill facility has to 21 then stop operations and then has to deal with its 22 particular loss of income associated with stopping things 23 and such. .
24 The last point is on the replacement. Obviously 25 Ray pointed out that it isn't a big deal in carbon steal, ANN RILEY-& ASSOCIATES, LTD.
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l' 272 1 but for other metals it might be worthwhile to recycle the
! ( ,) 2 materials. And so it does present a fact -- or a 3 perspective from benefits and costs in terms of seeing -- if 4 we can get this in without having to go out and process box 5 side to get that aluminum if there is enough of a value to 6 just melting and reusing it. l 7 Continuing on the costs. The disposal costs, 8 again, have been mentioned before. If you have the j 9 possibility of sending it to a public landfill or solid 10 waste landfill I guess it would be per volume, possibly less 11 than if you had to send it to a low-level waste facility.
12 So, there is some benefit in terms of whether it's 13 recyclable or the material can be cleared to a great extent.
14 I believe we mentioned it before, but the next (m-) 15 item is sort of the incidental industries, the ones that i 16 really basically you feel that didn't have much of a stake 17 about recycler clearance, all of a sudden they're going to 18 be effected by the products coming out. And certainly the 19 film industry and the electronics industry. So, they're 20 effected here in almost -- you could almost call them 21 commercial victims.
22 The next item is the possibility for buildup. We 23 really aren't too sure about exactly how to handle this.. We 24 will sort of have to be looking into the future trying to 25 see, well, is there a buildup or could it be the other way l
r-( ,x)
'~'
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273 1' that there's enough dilution. If you look at the numbers
[ n..
i 2' ~ that were cited before about the quantity of material that's 3 contaminated in the carbon steel sector, you sort of wonder 4 if you'd even notice it~if you really uniformly melted the l 5 stuff and such.
l 6 The next item is the socioeconomic impacts, and l l
7 any sort of evaluation of impacts from major regulatory 8 actions, you have_to look at how communities may be 9 effected, jobs lost, jobs' gained, et cetera. And we need to l
10 factor this~in when we do this evaluation of alternatives.
11 The other thing is that this is not, by any means, 12 a totally inclusive list. So, there are other things to be 13 concerned about. And again, as I mentioned yesterday, this i 14 is not your typical NRC cost benefit analysis. We're sort V 15 of going to have to do things a little bit different in the !
l l 16 case of recycle and release and clear the materials going 17 'out to the general use. !
18 Next slide. 'This is sort of a no-brainer here in 19 terms of what's really' involved fundamentally in a cost !
l '20 benefit analysis. We evaluate the potential health and i 21 safety environmental' impacts and then against the cost 22 required to achieve them or preserve them, depending on what 23 the impacts are, whether good or bad.
24 We look at all the benefits of each alternative.
25 Next. point we look at the detriments, including the costs ;
~
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i 274 i ,-
I from each alternative, and then we have to sort of weigh
( ) 2 them. It's almost sort of like a righteous final point on 3 this, but in effect we go back to the-initial Executive 4 Order. It says we have to have a net value to society, and 5 that's really the bottom ~line. It doesn't have to be 6 totally quantitative in effect. There are other aspects we 7 consider. As I mentioned yesterday, the environmental 8 justice aspect. And we even look at aesthetic effects when 9 we're doing a cost benefit analysis in terms of a regulatory 10 action. So, that's pretty much it.
11 The thing we're looking for here now is not just 12 comments about how -- how to assign costs or value, but 13 really now we're at the point where we're ready to start 14- this evaluation. We're going to look at each alternative.
) 15 What are the advantages. What are the disadvantages. And 1b- again, to sort of reassure you, number one is the protection 17 of public health' safety and the environment. That's above 18 all the most important thing. And secondly is, in terms of 19 cost benefit analysis, we're not trying to make a moral '
20 judgement. We're trying to use this as a tool to help us :
21 make a decision. And in this use of the tool we're not 22 going to be assigning a value in sort of a moral arrogance ;
23 in terms of whether a particular item is more important than l 24 another one or the value of a human life is only this or 25 that. lit's just a tool to help us make a decision tc i
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l 275 1 distinguish the results of these alternatives. And so we (n) v 2 need this. It will help us make the alternatives different 3 so that we can evaluate and judge them.
4 So, with that, we'd like to hear from you.
5 MR. CAMERON: Thanks, Giorgio. And it might be a 6 good place to start to see if we have identified all of the 7 different types of economic costs. And let me just through 8 one thing in from the paddock that Terry brought up 9 yesterday, which is we had a bullet up there that talked 10 about sensitive industries, I think was the description.
11 The film industry. Whatever. Terry's point from yesterday 12 was the potential economic impact on the steel industry from 13 public perception, I think was the way it was phrased, of l
14 these prodtats are -- may have radioactivity, may be
( f 15 defective. Terry, do you want to say anything more about 16 that at all?
17 MR. CIVIC: That's basically it. You have to 18 remember -- people have to remember that the steel gets used 4
19 in a wide variety of applications, including food. Tin 20 cans. So, you start looking at that market as, well, I 21 don't want to buy anything in tin cans, we'll buy stuff in >
l 22 plastic or some other kinu of can, aluminum or something.
I 23 But some of the food stuffs can't be packaged in anythi.ng i 24 other than steel cans. So, it 'recomes a consideration for !
1 25 the NRC. !
l
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276 1 but." CAMERON: Okay. Thank you, Terry. How about
-2 other -~~other' types of. costs'that we might not have n( }
- 3- ~ identified? "Ed?
4' MR. BAILEY: Luckily, I've only been involved in
~
5 one ofothese meltings, but-this particular company, and I 161 . don't knowLwhether'it would be an industry practice or not, 7 basically there.was a loss of income to the company, but f8 there was a-very dramatic loss of income to the employees of 9i that mill. They essentially did not get paid for ,-- the 10 bulk of the work force did not get paid during the time the 11 -mill was shut down.
12-- The company's primary product was water pipe.
13 Luckily,'I_ guess,-for them, it never really became a 14 widespread issue, but I imagine had a lot of the people
() 15 buying water pipe realized that this -- this mill had been 16' contaminated,- they would have had a hard time selling it.
17 ~Directly across the driveway was a bulb farm that was )
l 1 18 f - growing bulbs for, you know, to sell for flowers. It could '
19 just have' easily had been a farm of some kind. We did a 20" minimal amount of sampling in the bulb' farm, but if that had 21 heen a -- that particular year they.had been growing lettuce 22- -there,.we would have done a whole lot of sampling and it
~ ^
23L -would have been hard-to convince anybody that the cesiu.m 24 .that we found in theisoil wasn't from that accident, I 25 think.
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277 l n
1 So, those are the-kinds of impacts that probably
() 2. . will be hard to quantify,'but I guess the main one is -- is
- 3. again the individual workers'that really lost a lot during l 4 .that week or two that-the mill was down.
5 MR. CAMERON: Okay. And that, I take it, was from 6 an accidental smelting of a radioactive source that got out 7 in commerce of some kind. And Don may want to mention later i 8 on how that issue is being addressed at the NRC. It's a 9- 'related issue. Do you want to -- do you want to talk about 10- it now? That's good. Great, i
11 MR. COOL: Well, we can go ahead and talk about 12 that just a minute. One of the things that the Commission 13 and the states has been putting a lot more attention to is 14 the whole issue of sources and the control of sources and ID 15
\s,/ maintaining accountability of the sources. Because there 16 are a large number of cesium, cobalt and moresium sources 17 which are out there in industry mostly as gauging devices, 18 thickness gauges, for a variety of things. Tney could be 19 used in the steel mills, gauging the thicknesses of the 20 mills. .You'll see them in paper. A variety of different 21 kinds of gauging and measuring types of applications.
22 And as the mills observed, as we've already talked 23 about here, there have been instances where those sources 24 have no longer been where they're supposed to be. They may 25 have dismantled. They may have remodeled the facility.
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I 278 1 Owners may have changed over the course of time. And the I 2 licensing structure that's currently in place for most of 3 these sources is one of the things that we've in fact put up 4 there, a general license, which means that all of the 5 requirements are in the regulations, but there'is not a lot, 6 or in fact very.little or not communication back and forth 7 on a routine basis between the regulatory agency, either the 8 NRC or a-state, and the particular owner.
9 So, as you might expect, all of us, you could 10 actually sort of forget that it's out there. You may even 11 have people marketing here's the straight thing little 12 measurement for you, put it up for 20 years and forget about 13 it. Well, that sort of -- you sort of tend to do just that. l 14 So, we in fact have a proposed rule, it's f,,,T
(_/ 15 currently in the formal proposed rule stage, which is 16 examining and posing a number of additional requirements 17 which will amount to registration of these devices. It 18 would impose some additional information for the vendors to 19 provide to the regulatory agency, provide some additional 20 requirements in terms of tracking that through the process, 21- and would, for the first time, institute a process where 22 there is a -- we're proposing yearly contact back and forth 23 where the owner of the license would get a little card.or a 24 sheet or a letter from me that says, "I think you have the 25 following one, two, three, however many devices, please
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- 4 279 1 , verify that you have. one, two, three devices, that they are 1
2 the serial numbers we think they are, that you still know 3 where they are, you've seen them, you've checked them,
=4 they're still labeled properly, and send me your check for 5 $400.00 or so to keep the whole process going."
6 Now, a little bit of a monetary incentive because 7 that tends to help a little bit, not really unlike what you 8 do with your car and your driver's license. You get the l 9 little registration card, you fill it out, you send it back ;
10 in, yeah, you send them a check.
'11 And so the Commission is in the process of putting 12 in place, that some of the states, in fact, are out in front 13 of us there, have been doing this for several years trying 14 to learn from their experience in this process to try and 15 reduce the number of sources that get out into the commerce 16 in this possibility.
17 MR. CAMERON: Okay. Thanks, Don, and I just would 18 mention for people's information that the NRC is going to 19 hold a workshop on October 1st in Washington, D.C. that's ,
20 going to use a roundtable of the vendors of these devices to 21 discuss implementation issues related to the proposed rule 22 that Don mentioned, and if anybody is interested in that 23 workshop just please talk to either Don or me.
24 Andy, do you have something on another type of 25 economic cost?
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280 1 MR. WALLO: I think you covered it. I just wanted j
[)
\ / 2 to stress the difference between the economic impacts l
{
1 3 associated with melting of source versus economic impacts l 4 with implementing a standard, _and I think that --
-5 MR. CAMERON: Good. Good. Yeah. It's good that 6 we clarified that. John, I've got one here for you.
7 MR. KARNAK: I just wanted to add the point that i
8 EPA did a preliminary economic analysis and it is available I 9 on our website if anybody is interested in taking a look at 10 that: epa. gov / radiation /cleanmetals. And you'l?. find it i 11 there. Okay. Epa. gov / radiation /cleanmetals. And if you 12 just -- if you forget that, just go to radiation and go down )
13 the left side. There's -- there are -- you can hotlink on 14 the thing.
i 15 MR. CAMERON: Yeah, I think that is a pretty 16- important eference for people to look at because I imagine 17 it has all sorts of information and data on it. i l
18 MR. KARNAK: Just bear in mind the data is about 19 three years old now.
20 MR. CAMERON: Thank you. David?
21 MR. BELK: David Belk, University of California. l 22 I'd like to change the subject a little bit, actually, to 23 pull up something on the screen, the disposal costs and the 24 relationship to dis $osal facilities.
25 When you do your analysis, make sure that you do )
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281 l' more than just look at the use of the facility. How much
(_j 2 does'it' cost to send something to a disposal facility. The 3 example I'd like to give you is some of you -- excuse me --
4 some of you from California may know that the University of 5 California was recently charged with running a commission or 6 a committee to look at the alternatives to the dispose -- to 7 the Ward Valley facility. Well, setting up such a 8 commission is not free. Dealing with the public when it 9 .comes to trees is not free, as was referenced yesterday.
10 So, there's cost to the public relations when it comes to 11 disposal and handling of materials that may not necessarily 12 be automatically included when you analyze low-level 11 3 radioactive waste or public landfill facilities.
14 So, just to bring that up, that there's additional l
[..h
\s / 15 costs that appear to be hidden, but they're real.
16- MR. CAMERON: Yeah, and I think that's sort of a 17 good. thing for the NRC to keep in -- in mind generally, not 18 just with disposal costs, but there may be indirect costs, 19 derivative costs that flow out of these. And Giorgio, go 20 ahead.
21 MR. GNUGNOLI: Before we continue in that, I just 22 want to thank again Don and Ed for bringing up the point about'these sources and things getting out.
~
23 And maybe,one 24 of the things that might be helpful from the group gathered
'25 here is perhaps some advice to us about how we can deal with r^s
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r-282 1 the fact that we do -- we do run into these situations. I
('~'N
%./ l
\ 2 think a number of people feel that no matter what regulation 3 level you may choose, whether it -- if we do put a rule in 4 place that's .1 millirem per year or one or two, that these 5 kinds of things can still happen. Someone makes a mistake 6 or it's poor quality control.
7 It would be helpful for us to hear that what, 8 besides choosing a number, let's say a millirem or a set of 9 concentrations or whatever, would help us in terms of 10 providing a degree of confidence or assurance that maybe --
11 that we would have almost a commensurate drop in terms of 12 incidence of this loss of control. I don't know if that's 13 even a possibility, but that might be something worth 14 investigating.
15 MR. CAMERON: And that -- that is, I think, 16 probably legitimately discussed under -- under 17 implementation. Some alternatives may obviously have less 18 of a -- some alternatives may deal with that problem more 19 adequately than other alternatives.
20 Let's hear from Heather.
21 MS. WESTRA: Okay. Well, my -- my comment is 22 related to the -- to the previous one, the costs of assuring 23 the.public, you know. Will there be increased monitoring 24 costs, sampling costs at the mills, et cetera? Increased 25 costs to protect workers, public relations, all of those l
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233 c
1 things, I think, need to be considered in the -- in the
( 2 final analysis.
3 MR. CAMERON: Okay. Thanks, Heather. Can we 4 follow -- are there some follow ups to Heather's point?
5 Jim.
6 .MR. TURNER: -Yeah, I would agree with that.
7- There's a -- you're going to be required to train your 8 personnel, you'll have to do exposure monitoring, I would 9 imagine, and the only other one I would add -- and I don't 10 know how likely it is that -- and I think this opens up a 11 potential for sabotage or illegal disposal of a source in a, 12 say, a car of -- that's known to contain radioactive scrap.
13 That would be a good place to hide one. Or maybe the person 14 would think, well, it's going to -- it's radioactive i
_ 115 already, so what could this hurt.
16 MR. CAMERON: Okay. Thank you, Jim. Paul, you 17 were registering some -- do you have anything to say about 18 ~ follow up on this?. I would give you the mic.
19 MR. GENOA: Yeah. Follow up to the monitoring. I 20 hope we don't get to a point where we're going to allow 21 radioactive. material out to the public that's going to 1
22 require your workers to be monitored. That would be wrong. I 23- Okay. So, that's how I feel about that. It shouldn't 24 happen.
- .25 What I do believe about what I heard is that there
-m
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284 l 1 should be a standard that allows you to evenly and uniformly
(,,) 2 determine whether material that needs to be controlled is 3 being controlled. I think that will help the sealed source 4 issue. IVo, I think you need to have clear regulations that 5 control those sources and you'd have clear communications as 6 to what the obligations of those source users are, and then 7 you need punitive controls to punish people who don't 8 control properly, because this is a huge impact on public 9 health. And that's what you need to do with sealed sources.
10 But let's not confuse that discussion with this. This 1
11 discussion should be focussed on what is a safe level, as 12 low as reasonably achievable, for controlling radioactive l 13 material where it is, ensuring that material that could harm 1
7, 14 somecne doesn't get out. I mean, that -- I hope that's
( )
\_ ' 15 where we're going to get this discussion. l 16 MR. CAMERON: Yeah, we -- we are going to end up 17 there. I think that we still need to make sure that there 1
18 are no other comments on types of costs. And I think that l 19 we may want to get into a discussion of people's l
20 perspectives on the relative importance of some of these 21 costs. Rob Lull, in reference to Ray's presentation, was l 22 talking about the replacement costs, and he sort of -- for 23 the metals. And he -- he framed that issue in terms of is 24 it important to have a -- to recycle this type of material l
25 because of replacement costs. But let me make sure that we l
,o
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285 1 got all types of costs.out. Trish.
(q)\ 2 MS. HOLAHAN: Trish Holahan. I just, I guess.
'3 want to ask and go back to a number of alternatives were 4' raised yesterday, and'whether or not folks think that there i
5 are perhaps unique costs that need to be considered for some 6 of the other alternatives.
7 'MR. CAMERON: Okay. Let's -- let's think about 8 that, and while we're thinking about that particular issue 9 let's go to -- to Rob Lull.
10 MR. LULL: I would -- I would really support these 11 comments, last comments, about the political costs and the 12 costs of dealing with individuals and peoples, I've seen 13 the process in California develop -- trying to develop a 14 low-level waste. disposal facility escalate for years, and I 15 many organizations have sprung up whose people -- who -- who 16 are people -- were salaried people, lots of legal people 17 have made huge amounts of money, and all of this has gone to i 18 increase the cost of disposal at the facility where it used 19 to cost people $40.00 a cubic-foot for disposing of 20 low-level radioactive waste, which we're talking about a 21 higher level of waste than what we're d'scussing at this 22 . meeting. The costs now are escalated up to five, six, seven 23 hundred dollars a cubic foot, by some projections. And,the 24 longer the delay goes on, the higher that is, which leads to
- 25. another point, and that is when you talk on -- maybe a
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286 h 1
~ subset. point.onto the low-level waste disposal facility
\p . 2 because it's obvious that some of the people who aren't in
.. 3 attendance in this meeting will use political pressures to 4 try and drive all of this material into a low-level waste 5- . disposal-facility, rather than the ability to go through a 6 less expensive' recycling process. And one side'effect will 7 be'that those who are low volume users of the low-level 8 ~ waste facility where the total cost depends on the total i
9; -volume coming in.will actually.perhaps benefit from that 10 measure after everything is forced into the volume. The 11 total volume going to a low-level waste facility would 12 significantly increase, and thereby the unit volume cost 13 would decrease. So, there actually may be a benefit for 14 .some of the low-level waste disposal people, and that would 15 be'another force that one would have to take into account in 16 terms of the economie pressures on a proposed system here.
17 I certainly think.that's not a good way of using society's 18 scarce' physical resourcer, but that certainly might be a 19 direction that might flow out of the economic realities
-20 here.
-21 MR. CAMERON: Okay. Thank you. ' Terry.
22 MR. CIVIC: There may be another economic impact )
23 here that we ought to consider. And I'll use Proposition 65 24' as an example.
25 MR. CAMERON: If you could just make sure l
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I 287 t
l .
1 everybody knows what that is? '
(~N
(,,/ - 2 MR. CIVIC: Oh, California published ~a rule a L 3' couple of years ago now, indicating that there were -- the i
4 State of California determined that there we.te certain 5 chemicals that could cause cancer or have reproductive 6 effects, and that if a material had that, any of these 7 listed chemicals, you.had to put warning labels on 8 everything. From the steel' industry's perspective we were 9 swamped with any customer that bought steel indicating that 10 we had to put certifications that we met Proposition 65. We 11 looked at trying to do risk assessments associated with the 12 steel, et cetera. So, there was horrendous cost associated i 13 with responding to customer inquiries, developing 14 certifications, that type of thing.
/~% 1 ks/ 15 In this scenario you'll have a public that will 16 obviously be concerned about radioactive activity in steel.
17 They will cause the manufacturers of the products to come to 18 us and say, " Certify to us that your steel doesn't coatain 19 radiation above natural background." And we will havia to do 20 that. .They -- there are -- so,.there are costs associated 21 ,with actions by governmental agencies that effect us.
22 The steel industry will probably go to the 23 suppliers of the scrap and say, "Tell us, certify to us that 24 you don't have any -- that you're not giving us any 25 radioactive. steel that came from DOE facilities or nuclear i
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...a 288 1 power plants or whatever."
f So, there's -- there is going to
(%j 2 be a trickle down effect associated with then evaluating, 3 finding out where the steel came from, where the scrap came 4 from, and significant cost associated with that.
f
-5 MR. CAMERON: Okay. Good. Good point, Terry, for 6 us to consider. And we do -- I do want to get to Trish's
'7 issue for the group. But Bill, do you have something on 8 types of cost or?
9 MR. KENNEDY: The previous cost -- this is Bill 10 Kennedy again. The previous cost is a little difficult for oil me to grasp'because currently steel does contain radioactive 12 materials. So, if the blanket question is certify to me 13 that the steel does not contain any radioactive
' 14 contaminants, then you can't make that statement. What's 15 missing is a standard against which you judge the trivial 16 concentrations that you' encounter. And to me that's the 17 central part of this whole discussion. The same thing with 18- hazardous chemicals. You can't say there are no harardous 19 chemicals in something, pesticides or whatever, but you have 20 safe levels identified against which you measure and can UL answer the question honestly that the material has been 22- deemed safe by a given standard. SO, to me it's a matter of
- 23. dagree. .
24 The steel already has radioactive materials
- 25 inherent in'it because of life since World War II. The (Oj ANN RILEY & ASSOCIATES, LTD.
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289 1 question is are those levels acceptable against a given
( ) 2 standard, and that's what missing is the standard.
3 MR. CAMERON: Great.
4 MR. TURNER: I'd like to respond to that one if I 5 can.
6 MR. CAMERON: That centers us again, I think. And 7 Jaz, you want to amplify on that?
8 MR. DEVGUN: Yeah. Jaz Devgun. And I want to add 9 on to Bill's comments, also, a question for Ray that since 10 in the steel trade, it's open trade, I mean, there's 11 international steel coming into the country on a routine 12 basis and probably vice versa. How do you take into account 13 like the difference in their standards may be, and if there 14 are requirements like the gentleman just mentioned here, how im
(,) 15 do you ensure that that steel does not have any higher 16 radioactivity than ours?
17 And as a side question to that is you mentioned if 18 they take two picoeuries per gram as the -- factor standard, 19 I guess in the bag house dust maybe. But even if you take 20 five picocuries per gram there are standards in other 21 countries, like in Germany, which would be 0.6 becquerels 22= per gram, which comes to about 14 picocuries per gram. So, 23 what if they release the steel or any material with that 24 higher level, how do -- how does that connect?
25 MR. TURNER: I don't know if we have any atheists l-l ANN RILEY & ASSOCIATES, LTD.
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I 290 1 .here or not, but atheists in a suit in a casket is like i) 2 somebody all' dressed up and no place to go. Just need to be 3 careful that when we make some regulation here that you 4 don't make a rule that's not going to go anywhere. The l
5 mills are going to have to accept it. And even though some i 6 of the European countries may be adopting some higher j 7 concentrations in the steel products I can tell you that if 8 it sets of a detector at the export yard in European 9 countries it's going to be rejected at that yard. It's not 10 going to be accepted there. There may be a rule that says l l
11 you can have higher concentrations, but if it rings a bell 12 and these things get more and more sensitive, they won't 13 accept it.
14 The gentleman mentioned something about hackground
\_./ 15 radiation, and I think we're talking abcut no radiation 16 above natural uackground in the steel. We know tr :e is 17 some radioactive material in just -- in everything. But if 18 it does not. increase the background radiation or doesn't 19 increase the signal enough to make the bell go off, then 20 typically the mills consider that as radioactive free, 21- radiation free material. I think it's important here to 22 address what is background, how background is measured in 23 scrap and steel facilities. And when we think of a 24 background, typically we think of it's five or 10 microrems 25 per hour in natural background just right outside the a
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L 291 1 building with a hand held survey meter, that may be the N ,/ . 2 case. But when you are monitoring you have portamonitors in 3 steel mills, you have a fixed monitor on both sides of a 4 scale and sometimes over top of the scale. And either --
5 most of them are plastic scintillator base systems now. A
)
6 few of them are still sodium iodine, but almost all of them 7 are plastic scintillator systems.
8 When you. pull a truck or a rail car, that 10 9 microrems per hour background disappears. There's no more j i
10 air between those detectors and it may drop down to two l I
11 microcrems per hour. And these systems are constantly )
i 12 monitoring and changing, you know, sometimes up to 50 times 13 per second. And they typically are set at three standard 14 deviations above that newly adjusted background. So, (D
k/ 15 although your background radiation level -- long story short 16 impossible at this time -- may be 10 microrems per hour, 17 these systems alarm at-four microrems per hour, after the 18 truck goes through. So, we're talking about extremely low, l 19 extremely low sensitivities. And they're not going to get 20 any less sensitive. The reason they're not. going to get any l 21 less sensitive is we've run some tests and we're going to 22 . run another test the latter part of next month on some newer 23 systems. What we've found is that beyond certain level,s in 24 shredder scrap, or in scrap that has density greater than l 25 about 50 or 55 pounds per cubic foot in a truck, not a rail p/
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292 1 car but just a truck, when you get 22 inches and beyond I^N
( ,/ 2 inside that load, no commercially developed system today can 3 see it, not even fixed gate. They don't see it today.
4 So, the systems are not going to get any less 5 sensitive, they're going to get more sensitive and more 6 sophisticated.
7 MR. CAMERON: Okay. Let's keep fo? lowing that. I 8 think John Karnak from EPA has something. John Karnak.
9 MR. KARNAK: Yeah. I want to go back a couple of 10 years to when EPA first started looking at the possibility 11 of -- looking at the technical aspects associated with 12 release of this kind of material.
13 When this came to the attention of some of the p_ 14 environmental groups they were at our doorstep immediately, kI 15 and we said, "Well, look, guys, you know that there's some 16 material that's going out of these facilities now." And 17 they said, "We didn't know that. Go get it and bring it 18 back."
19 Putting a standard like this out is going to alert 20 everybody that something is happening. And, you know, 21 before three years ago a lot of these groups didn't know it 22 was happening. And I think this is the point that Terry was 23 making is that now we've brought it to everybody's attention 24 and now you've got people that are going to start getting 25- excited about things.
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293 l' So,.the fact that there's radiation in material n
( j_ 2- today,-the' fact we're recycling stuff from DOE facilities
-3 today and NRC facilities is all just fine. The more 4 attention you bring to it, the more people get excited.
5 MR. CAMERON: That's a nice optimistic on that,
, 6 John. But let me just -- since Trish has brought up the 7 aspect, the whole issue of alternatives and looking at the 8 alternativos from yesterday that the NRC put up, the 9 alternatives that all of you developed and looking at any 10- unique economic costs associated with any of those, this is 11 an alternative th'at we have to make sure is considered, that 12 I don't know if we did or not. But bring it all back. Get 13 it. Okay. I think that we've heard from that. So, let's
- 14. make sure that that is an' alternative that's on the record
(. 15 that was sort of indirectly offered by John Karnak from EPA.
16_ I mean, you told us about it here. I'm not trying to put i 17 the onus on you for that.
18' MR. TURNER: Chip, I'd like to respond to one
~19 other statement. Ray Turner.
20- MR. CAMERON: Oh. Sorry, Ray.
21 MR. TURNER: I'd like to respond to one other 22 statement that was made ea'rlier today by'Giorgio, and that's 23- about false positives causing work stoppages or causing 24 steel' mills to have to shut down and wait until the material 25 :is removed.
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There's only three steel mills, electric arc type
() 2 steel mills that I'm aware of in the United States that has 3 a system where that would be the case, and these are three 4 what were called comsteel pra tices. One of them is owned 5 by Jim's company that Jim works with, and two others are 6 owned -- one is built and operating right now in South 7 Carolina, the other one is in construction, where the scrap 8 actually f] oats across a conveyor and directly into the 9 furnace.
10 Aside from those three, two which are operating 11 and one is being built now, at least two of those mills have 12 already stated that they don't want any of this material 13 whatsoever, so that brings it down to one mill in the U.S.
14 that has a comsteel type practice.
O
(_,/ 15 If you have a false positive on scrap that comes 16 into a steel mill, it really doesn't effect the melt shop 17 because this is something that occurs at the gate, at the 18 monitor, outside. And the impetus here is to prevent it 19 from ever getting to the melt shop so you don't have that 20 work stoppage. It really doesn't create a work stoppage in 21 the melt shop itself. It just requires some time on the 22 part of the RSO or people that are doing the cleanup of that 23 shipment and'having that.
24 MR. CAMERON: Okay. Thanks, Ray. I think it just 25 underscores the need to carefully explore these costs,
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[ 295 1 because it may look on the surface that there's a cost, but (O) 2 when you really get into it, it may not be.
3 What I'd like to do,.at least start to do, before 4 we take a break, is let's run -- let's go to Trish's 5 question and let's run through these alternatives. And she 6
used . the word " unique" cost, but I think maybe we should say 7 notable cost that anybody wants to tag on to these 8 alternatives. And perhaps the best way to do it is just do 9 it systematically. And continue current practice 10 alternative up there. Anybody want to offer a -- any 11 information on what they think is a notable economic cost 12 associated with that? Okay. Phil.
13 MR. GIANUTSOS: Ray noted the increasing 14 sensitivity of these gate monitors. Right now it's quite --
O
(,,/ 15 quite easy to release materials under the current practices,
- 16 end up with a roll off material or a large truckload of that 17 material and have it rejected. That is a real cost and it's 18 increasing as more of these monitors get out there. The 19 generators at that point are blending the material, shipping 20 it in smaller loads, taking steps to get through the gate 21 monitor. This material is, in fact, released under 22 acceptable standards, it's just the gate monitors themselves 23 do not have an alarm set point that's anything other than a 24 fluctuation in background. That's -- that's really 25 unacceptable and will get worse.
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296 1 MR. CAMERON: Okay. Thank you, Phil. Acceptable
(]n 2 dose levels. Brian has a comment on that.
3 MR. HEARTY: This is Brian Hearty. One of the 4 things that I saw yesterday when we were trying to balance 5 health impacts, and what is brought up in the issue paper in 6- several places is that NRC currently has limits on air and 7- liquid-effluent releases, and those are set up based on 50 8 millirem each, adding up to the public dose limit of 100 9 millirem.
10 I guess what I see ic when we see this there is --
-11 this is another dose, another type of effluent, another type i
1 12 of release that is going to start a public dose. So, when 13 we're setting a dose level, I guess one of the things I was
! 14 looking at is that going to be balanced with the 50 and 50 15 millirem for air and liquid so that we end up with still 100 l l
16 total. And then if it comes to be cost beneficial to .
17 possibly reduce the air and gaseous levels where it would be 18 more beneficial to do that than to maybe set lower levels 19 for solid release, and if those can be balanced somehow in 20 an analysis.
21 MR. CAMERON: That's an interesting point. Does 22 anybody want to talk to that point, either from the NRC or 23 from.the -- our participants? Bill Kennedy, do you wan,t to ;
24 say something on that?
25 MR. KENNEDY: This is Bill Kennedy. Although the ANN RILEY & ASSOCIATES, LTD.,
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MPCs in the tables that are in 10 CFR 20 are calculated at 2 50, remember the practice is that level plus alara.
3 Also remember that for air there are separate 4
regulations under EPA where you have to certify an operating 5 plant at a much lower level than 50 millirem. Also remember l 6 that other regulations apply.
7' So, if you take all of that into account and the 8 plus alara consideration, I think it's possible to set a L 9 clearance level in terms of a dose standard with a plus 10 alara and not have the sum of the three types of effluents 11 even approach the 100 millirem.
12 14R . CAMERON: And I see Debra McBaugh at least is 13 agreeing with Bill. Since Bill made the last comment, why 14 don't'we -- anything on adopting the ANSI standard, any 15' unique or notable economic costs associated with that?
16 Okay. How about restrictions limiting release of 17 solid materials to certain authorized areas? Anybody have a 18 comment, anything they think is notable in terms of an 19 economic cost associated with that? Bill?
20 MR.. KENNEDY: I don't say it quite in jest, but 21 back to number one, part of the cost of adopting the ANSI 22 standard might be a cost savings to the government for 23 having to develop a numerical standard. You know, you..still 24 have to go through a regulatory prccess, but you wouldn't 25 have to apply costs for the development of the standard.
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l 1 So, it's kind of a negative cost. It might be a savings.
A l ( )- 2 MR. CAMERON: I think that's a legitimate point to 3 make. Paul Genoa.
4 MR. GENOA: Yeah, on number two. Again, this is 5 just conceptual, but if you were to come up with a threshold 6 for sorting safe material from material that needs to be 7 controlled and then you were to postulate a series of 8 restricted applications that would isolate this material 9 from the general public but allow other alternatives than a 10 low-level waste disposal site, you would have to set up a 1 l
11 regulatory program for that. You have to do analysis. You )
12 may choose to license'certain activities. Or you may just 13 allow it to continue within existi'ng licenses, like the GTS
,_s 14 Duratech facility or others. But -- but it's possible that
(_s 15 there might be some licensing and rule making activities in j l
16 , the' future that would allow or set a stage to allow 17 restricted release applications. ;
18 MR. CAMERON: Okay. Thank you, Paul. That's 19 following along in the same vein of Bill Kennedy's comment.
- 20. And let's just go freeform, I guess, here on this 21 alternatives and notable costs. Brian?
22 MR. HEARTY: .This is just a quick comment on Bill.
23 I know that we have alara still in the paddock. I don'.t 24 think.that that's been totally resolved that alara is part 25- of, you know, what's going to end up in the dough standard.
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299 1 MR. CAMERON: Okay. Thanks for reminding us of (q / 2 that. And we do need to -- we had a little bit of a 3 discussion connected to Mark's point yesterday about sort of l
4 a self-generated alara concept, but we still need to go back 5 and address that specifically. Frank Cardile?
6 MR. CARDILE: I wonder if we could follow a little
.7 further with.the restricted use cost. I wanted to ask a 8 questionop.the, I guess, the industry. I guess the license ;
i 9 industry and the steel industry. All the different 10 industries that are out here. I think the point I was just 11 making, how far would this licensing of perhaps scrap yard i
12 owners or steel manufacturers have to go to make a l 13 restricted use work? And what cost would that include?
14 MR. CAMERON: Okay. There's a question for you.
N_) 15 Debra, do you have a comment on that?
16 MS. MCBAUGH: Just a feeling from looking at it 17 from the State's perspective, the restrictive use is sort of 18 an uncomfortable area for us because it really appears that 19 we would be spending more time and money, our resources, 20 having to track that, because I can't see that we would just 21 let ,it go. And even if NRC was to license it, we're an 22 agreement state, but even if -- I mean, some things are done 23 under NRC that we don't have a lot of jurisdiction in, but I l
24 think we would be very concerned about what was happening if 25- a restricted use happened. So, I think there would be a lot ANN RILEY & ASSOCIATES, LTD.
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- m 300 i 1 of money involved there for the scates.
!a.
LJ 1 2 MR. CAMERON: So, it would be this continuous 3 monitoring cost for people. We have some follow-ups.on 4' that? Okay. Ed, and then we'll go to Jim Turner. l 5 MR. BAILEY: Back years ago we licensed a facility 6 that had phosphogypsum to incorporate phosphogypsum into 7 roadbeds, bridge abutments, pipeline bedding and those kinds 8 of activities. And we did a dose assessment and all this !
9 other great stuff only to learn that we didn't really know l 10 how roads were built, we really didn't understand how 11 pipeline bedding worked. And this stuff -- stuff kept I 12 appearing in public and school yards or parking lots and on 13 and on and on. And we ultimately decided that that was 14 really a stupid thing we had done because we were eaten i
/T t 15 alive by complaints, by actually having to go out and see ,
s ,/ j 16 how the secondary user actually used this material, because 17 you could buy it and do what you wanted to with it.
18- I also remember a case where Exxon had a light 19 hydrocarbon plant. And for those of you who are not 20 familiar with a -- with the oil and gas business, they did 21 an analysis and found out that, hey, natural gas has some 22 naturally occurring radioactive materials in it. And when 23 they sold th'at to a plastic plant, the MSDS, the materi,als 24 data whatever you call it sheet, had a cryptic note on it
! 25 that this gas contained, among other things, a naturally l
A \
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301 1 occurring radioactive material. So, they were selling it to
(,.-/) 2 a place that used the plastic to make diapers. And you talk 3 about one atom of radioactive material. The company that 4 was making that did not want to use that natural gas from 5 that plant which had that identified.
6 I think the labeling cost, too, could be quite i
7 extensive. Thorium coman gas lantern mantles. I think all 8 of us realize that at least up until a point they contain 9 thorium. If you look at one bought in California it says, 10 "This product contains material known to cause cancer in 11 humans." And that labeling goes on there regardless of what 12 NRC regulations say about that being an exempt product.
13 So, I can see some states, some jurisdictions, 14 '
coming up and making you label it whether you said you
(_,/ i 15 wanted it labeled or not. So, that could be additional j 16 cost. i 17 MR. CAMERON: Okay. Jim, do you have a similar 18 comment on that? We'll keep going with this one.
19 MR. TURNER: No , I just wanted to follow up on the 20 lady's comments while we're here. We maintain, for certain 21 purposes, traceability of out steel, and that's a rather 22 expensive process. And all it does is as you go out if a 23 building collapses or something and our steel is in it,. we 24 can trace it back and find out where it came from, when it 25 was made and so on and so forth. And what you're talking (7 ,3 ANN RILEY & ASSOCIATES, LTD.
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302 1 about, I think, is probably more expensive because now (D 2 you're talking about tracing where it goes.
V- And, you know, 3' a bridge might be out'there for 30 years. You have to have 4 a program in effect that's going to track that bridge for 30 5 years. I don't know how you go about that.
l But I think {
6 there's probably a significant program development cost in 7 there.
8 MR. CAMERON: Okay. As a -- in juxtaposition to 9 the point that I think that Paul Genoa and Bill Kennedy have 10 made, that an unrestricted release based on a standard that 11' has basically been sent as a safe standards that material 12 would no longer be considered to be called radioactive at 13 all. Is that -- I just wanted to make sure that that's what 14 you were saying, right Paul'?
15 MR. GENOA: Yes. )
16 MR. TURNER: Chip, I'd also like to respond.
17 MR. CAMERON: Go ahead, Ray.
18 MR. TURNER: If I understood your comment 19- correctly, were you asking what would be the economic impact I
, 20 or how much would it cost to retrofit or to build facilities !
l 21 that would capture these emissions, how much would it cust 22- to modify a_ mill? Was that your question?
23 MR. CAMERON: And are you talking to -- who are 24 you talking to?
25 MR. TURNER: Tri.sh.
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303 1 MS. HOLAHAN: It was more are there specific
.g k _)
s 2 considerations that we should take into account for certain 3- alternatives, that we, for example, at what point --
for 4 which a3ternatives might we need to take those into Ii 5 consideration.
J 6 MR. TURNER: In response to that-comment, the 7 general electric arc furnace steel mill in the U.S., we've 8 got mills now that are being built today, most of them are 9 on the order of about one and half to maybe 2.2 -- maybe 2.4 10 million ton per year melting facilities. They're generating 11 ' huge volumes of dust because -- simply because of the amount 12 of steel that they are producing. They are not in a captive 13 environment. It would be really economically infeasible to
-- 14 place that type operation, a captive environment such as you 5- / 15' would have at GTS Duratech. You're talking about a much, 16 much larger scale in the general steel industry today. I 17 don't believe it would be economically feasible to do that.
18 MR. CAMERON: Okay. Thank you, Ray. How about --
.19 - I guess that we'll call this alternative here the " Mark 20 shoes alternative" from yesterday. Anybody -- anybody want 21 to say anything about costs associated 9 .td1 that? Including 22 mark, .do you want to offer anything or. that beyond what you 23 said yesterday? Mike Glesnick has the microphone if yo.u 24 want to make a comment. No? Okay. Paul, though, I guess.
- 25. And Eric -- Eric, go ahead.
l t
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- . MR. GOLDINi
-l' o I'll make a quick comment. That j-s
()p 2 alternative, one of the costs that would have to be 1
]
)
3 considered is the fact that you would have vastly larger i
4 . quantities of low-level waste, and the prospect of low-level !
5 . waste facilities in this country does not look too good. i 6 So, the cost of storage or whatever could be pretty steep.
7 MR. CAMERON: Is this alternative the one that 8 would really -- the notable implication of this is that ;
9- there would be a lot and-question mark of low-level waste 10 that would have.to be disposed of? I mean, what is that --
11 what is that amount of low-level waste if you adopted 12 something like this that would -- that would be generated?
13 Let's go to Paul on that and then we're going to 14 go to Rob Lull in the back. Paul?
15 MR. GENOA: Paul Genoa, NEl. I don't have a 16 number for you, but I think, you know, that's written as if i 17 these are stagnant facilities and you walk into the 18- facility, it's like walking into your living room and your 19 couch and your coffee table and your bookshelf. Because 20 it's a nuclear facility, it's going to be low-level waste.
21 And that's one way to look at it. And that would be a huge 22 cost, and it would be hard to justify because they may or 23 may not be -- have licensed material, and they certainly 24 wouldn't, or in many cases, wouldn't have health risk. So, 25 I'm not sure about your authority as well.
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305 l
- j. 1 But beyond'that, that's not really how these 1'
.(,o)- 2 facilities work. You have materials moving in and out of 3
th3se facilities constantly. And all of those materials.
4 How could you say that the fixed materials have to stay, but 5s the mobile raterials don't? That would be disingenuous.
l 6 So, then you're saying, "Well, anything that comes in has to 7 stay in forever." The end result of that is, you know, you 8 can't -- the technology goes away. You can't operate an 9 industry in that fashion.
10 Also, you're disingenuous because you seem to be l
11 ignoring the people. You know, the people who go in there
! 12 breathe the air, incorporate some minute amount of
'13 radioactivity into their bodies, have it on their skin.
14 They can't. leave either. You seem to just very easily 15 ignore the people, you know, because it would be too hard to l 16 deal with. But you're saying, you know, they're radioactive 17 waste, too. They've got to go be buried at Barnwell. I 18 mean, that's what you're saying.
19 ,
[ Laughter.)
l
'20 So, I mean, carried to extreme, it becomes an 21 absurd approach.
22 MR. CAMERON: There's a bus that's going to be l
23 leaving for Barnwell outside if -- Dr. Lull. .
l 24 MR. LULL: Yeah, I agree. I think that we need to
~25 rewrite that alternative, That alternative, as it stands, i
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7 306 1 is really ridiculous. First of all, you would be at least A
' ( ,) 2 surveying things to prove whether or not they have any
'3 radioactivity on them. And things that are not radioactive 4 would not need to be kept. I mean, that's -- it's crazy to 5 do that.
6 The other thing that it doesn't take into account 7 is when you-take radioactive sources and move them into some 8 other place, like industrial radiographers who are taking 9 radioactive sources and radiating buildings for building 10 reconstruction or remodeling. Are you going to make the 11 whole building, now, a low-level waste disposal because it 12 had radiation use there? As this is written, that's what it 13' would stand. So, we need to rewrite this. As it's written 14 it doesn't take'into account the simple act of doing a 15 survey to prove that nothing has -- no contamination has 16 been placed on the materihl that's come in or been in an 17' area where there's radioactive use going on. And the-other 18 ching is it doesn't take into account that you take 19 radioactive sources into other places, and that you don't 20 leave contamination behind, that you can measure that.
21 And so the measurement by survey ought to be 22 included in this, and that would reduce the amount, even 23 though -- even so, making everv;hing that has any small 24 trace amount of radioactive contamination on it going -- and 25 forcing that to go and be defined as low-level waste, no
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307 1 matter how low the level, would be tremendously expensive
() 2 and would create a real problem because, as you've heard, we 3 are having major problems. establishing low-level waste 4 disposal capacity in this country. And the cost of disposal 5 at what's available is very, very difficult. This would 6' create a -- really major problems and major costs. So, I 7 recommend that we reword that as an alternative. j 8 MR. CAMERON: Okay. Thanks for that 9 recommendation. And I think that let's -- let's have one or 10 two more comments and then let's take a break and I think 11 we'll come back and do implementation. There are other 12 alternatives that you generated yesterday. Anybody have 13 anything on those or -- Eric, go ahead.
14 MR. GOLDIN: Just one last quick comment regarding 15 .this no release that -- of materials that have been in a 16 radioactive material area. I know that the focus of the 17 meeting has'been on nuclear power plants, because that's a 18~ focus of a lot of the environmental activists, but there are 19 -lots of facilities. I work across the hall, on occasion, 20 from a biomedical laboratory that uses unsealed carbon 14 21 and tritium labeled compounds, and everything in that lab, 22 which is half the size of this room, would then be subject 23 to that same restriction, which means glassware and all {
l 24 ~ kinds of chemicals and all kinds of stuff. And it would l
25 basically stop biomedical and microbiological research. !
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51 308 1 MR. CAMERON: Okay, A final comment on this, Ray?
(3'
( ,/ - -2. MR. TURNER: I think we could go on a brainstorm 3 all. afternoon, but I think there are huge implications here 4 when we're. talking about material that has been in the area, 5 radioactive material not being able to leave that area. A 6 new process that I've been working on for several years, for 7 example, with a company right here in California, which 8 we've now developed and are offering commercially,-actur' y 9 radiates scrap using neutron generators on a conveyor system 10 so that we can tell the exact chemistry of that scrap before 11 it goes into an electric arc furnace or any type of furnace
. 12 or any other vehicle. We can look at manganese, chrome, 13 nickel. We can look at carbon, I think. Things like that.
14 So, we know the exact physical chemistry of that scrap heap
(~
(- ) 15 before it's ever melted. That could no longer -- that type j 16 of technology could no-longer exist. i 17 . And I would have really been ticked off last night 18- if I couldn't have finished my beer that finishes that level 19 that, by some Amerasian gauge, and tops it off at a certain 20 level. If'I couldn't drink that beer, I really would have 21 been ticked off last night.
22 [ Laughter.]
23 MR. CAMERON: I guess now we're getting to the i
l 24 bottom line, right? This is it.
- 25 Any final comment on some of these other l
O
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n- . ...o 309 p
1 alternatives? I think we've -- we've heard enough about the
( ,\)
s .
2 " Mark shoes alternative." Any -- anybody have anything to 3; say?- 'Okay. Craig from Envirocare.
4 MR. THORLEY: I was.just going to say, based on I
5 what Paul said, maybe you could change the name of that from j 6 " Mark-she,,, alternative" to the " Hotel California option."
7- MR. CAMERON: Okay. Thank you. Thank you'. All 8 right. Okay. Well, let's -- let's take a break and come 9 back at 10:45.
I 10 (Off the record from 10:30 to 11:00 o' clock a.m.)
11 MR. CAMERON: NRC is a fee recovery agency. What 12 are the implications of the various alternatives for fee 13- recovery in terms of assessing licensee costs? And I know !
14 that that's one that I haven't heard any discussion about I f-~g !
%- l 15' from -- from the staff, and I would just like to see if we 16 get any commentary on that from any of you out there.
17 And does someone from the NRC staff want to say 18 anything about that? And I'm looking at Don. Don doesn't 19 want to -- do you have anything to say on that fee recovery?
20 But it is -- I mean, it is something that is a potential 21 cost that should be considered. Anybody have anything on 22 the fee recovery issue?' I mean, you can -- you can imagine 23 that under different alternatives there could be more c.osts 24' .that the NRC would have to. recover because it would involve 25 more regulatory time. Debra.
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r 310 1 MS. MCBAUGH: Well,.I would just have to ditto
() 2L that. We are a fee recovery as well and we get absolutely j 3 no state funds for any of our programs. So, everything has 4 to come from licensee fees, which is why restricted use is 5 more of a problem for us, because we have no funds to pay I 6 for something that isn't directly related to a licensee.
7 MR. CAMERON: So,'you'd have to figure out how you 8 would assess that sort of continuous monitoring. ;
9 Scott, am I in your way or do you have something I 10 to say? All right. Yes, Eric.
11 MR. GOLDIN: Yeah. Eric Goldin. This may be --
)
.12 should have brought up ao an alternative, but I suppose one l 23 fof the options is for -- for material that is known to be 14 very slightly contaminated and would not be released into I
N .
H15 the public domain, one of the options that I described as 16 , waste management yesterday is to apply for a 2002 exemption j 17 or the state equivalent. And in that case, again, there is 18 no fee recovery process that I'm aware of for either the NRC 19 in a non-agreement state, or the state agency, to do the 20 work to make those exemptions occur.
21 MR. CAMERON: Okay. Thank you very much, Eric.
22 Well, let's -- let's go to Tony for a presentation, for his
- 23 presentation, how should control solid material be assured 24- under various alternatives. And Barbara, are -- signing at i.
L 25 me. What.is' going on?
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I 311 1 .
BARBARA: I'm passing out two documents that --
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(_ ,/ 2 i
1 one was referred to yesterday. And actually, maybe Tom ;
i
- 3. would be willing to give a brief orientation to the health !
4 physics considerations. And it's an EPS waste information. i 5 . Sort of a graph approach, I think. And Tom could tell you 6 more about that.
l 7' MR. MADDEN: Yeah. I mentioned this yesterday.
8 It's what we in NNR use for 2002 review -- 20.2000 reviews, 9 the methodology or the overall approach. Several of you 10 have expressed interest in the -- in this. I had it faxed 11 'to me and this is -- thic is a copy of it. It doesn't 12 really go into any detail as far as the methods that are 13 used for the staff to analyze. It gives some examples of 14 materials that have been -- that have been approved for 15 disposal. It's not really an exemption to our regulations. l 16 It's an authorized path that's prescribed in part 20. An !
17 alternative means. And -- I'm sorry. I'm sorry. It is not 18 really an exemption, as was just characterized. It is an l l
19 . authorized method in part 20. And the other -- the other 20 probably more detailed discussion of it as Bob Nelson 21 referred yesterday to NUREG 1101. But I just wanted you to ,
22- have this. Several have expressed interest. And so now you 2 3 '- have it. . !
24 MR. CAMERON: And if you do have any questions on
'25- - it, get together with Tom during one of the breaks, too.
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,w 1 Thanks, Tom. And Thanks, Barbara. And Tony, if you're
). 2 ready to go, why don't you take it away?
3 MR. HUFFORT: Thank you, Chip. The title of this 4 is, "How should controls be assured under various 5 alternatives?" We've already discussed implementation and 6 . restrictions.
7 Sure. Not a very sensitive mic.
8 We've already discussed implementation and 9 restricted use to a certain extent already. During this 10 session maybe we can focus on how these concepts would be 11 contained in a draft regulatory guide if we were to develop 12 .a draft regulation.
13 And before we discuss what future controls should 14 be. considered, I'd like to review what controls are in place
\ 15 right now during -- with our existing regulations.
16 Our existing regulations require licensees to make 17 surveys of solid materials to evaluate the potential 18 radiological hazard, as we discussed yesterday. And as part 19 of the licensees rad safety program they develop procedures 20 for controlling solid materials, which includes radiation o-21 56nitoring, to evaluate any materials before they are 22 released. And presently there are some issues related to 23 the existing' survey programs. Not a licensees use the.same 24 survey instruments and procedures to monitor solid 25 materials. This can lead to variations in detection
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313 1 sensitivities in different equipment being used to measure
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( ,) 2 the radioactivity present. This, in turn, can lead to 3_ differing levels of control, which in turn results in l
4 non-uniform levels of protection.
5 Another issue _is that existing guidance on !
l 6 conducting surveys is really geared towards surface l
7 contamination. It is not geared toward volumetric releases.
8 As Pnil from GTS Duratech had pointed out earlier today, 9 some equipment may have small amounts of radioactivity 10 present in cracks or holes of the equipment, and it's very
- 11. difficult to do a surface survey and assess where or how 12 much that material is in the internal parts of this. If we 13 don't have a volumetric release standard, it is very
,, 14 difficult to make that type of assessment.
~
15 There are also some physical limitations.for 16 measuring volumetric contamination. Because it is simply j 17 very difficult to measure certain types of radioactivity 18_ 'that's contained in a solid object, especially when using 19 the typical hand held survey instruments that are present at 20 most licensed facilities.
21 The overall consideration here in controlling 22' these materials is how to detect or measure radioactivity in 23 the material itself and'then compare it to a predetermined 24 level, either a dose level or a concentration level.
I 25 And it's likely -- can I have the next slide, 1
A i
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314 1 Giorgio? It's likely that this survey method that will be l 2' chosen for controi'ing solid materials is going to be 3 dependant on the alternative that we eventually choose.
4 Currently, we're considering a range of 5 alternatives, and this requires the NRC staff to technically 6 evaluate a variety of survey approaches. Because the 7 alternative that's chosen in fact determines the survey 8 method that's used it follows that if we have a dose 9_ criterion that's very low or zero above background, we might 10 have to consider using very sensitive survey instruments and 11 methods. And when we're shifting to these types of newer 12 survey methods or equipment, there are associated costs and 13L practicalities;when we decide to use that.
t ,
14 Certainly, as we discussed this morning, 15 monitoring costs might be increased, and the staff is 16 : planning ~to evaluate that.
17 Another consideration in controlling colid
- 18. materials is restricting a release to only certain J 19 authorized uses. For example, the future use of the 20 material could be restricted to only industrial purposes, as 21 we've already discussed, where the potential for public j i
22 exposure would be perhaps smaller.
23 For a restricted use I'd like to discuss what are ;
l 24 some of the controls that are needed and some of the options
)
25 that-are currently on the table. Should we consider
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l 315 1- licensing the first user and the processor of these
. gS.
ty ,) 2 materials? For example, we've already talked about these 3 materials being-used for bridge supports, railroad tracks, 4 shielding blocks, and I've heard, prior to this session, 1 i
5 also the discussion of radioactive material being contained 6 in tank treads for military purposes.
7 If we decide to use restricted use, what kind of 8 process-should we have for public review and involvement?
9 As Andy Wallo had stated previously from the DOE, they have {
l l
10- public interest groups that they're aware of and they ,
)
11 interface with at their sites. Should this be appropriate 12 for us? And as far as the length of the time for restricted 13 solid materials, what is the appropriate length of time? ;
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14 Should it be tied to the radioactive half-life of the k_,T) 15 material? Some radioactive materials have relatively short 16 half-lives. They decay quickly. Should it be based on the 17 radioactive half-life? Should there be a cut-off? Or 18 .should it be tied to the lifetime of the equipment? If you 19 build a bridge and the bridge lasts 50 years, let's say, 20 during the first use would we be considering some types of 21' controls over that bridge? Would we have NRC inspectors go 22 out to take a look at it? Should there be labels on this 23 bridge support? Should there be a stamping of some type on 24 the metal that's used in the bridge. support? ;
l 25 '
And I'd like to open it up, just open it up, Chip.
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What other options should be considered that we already have
.O i V. 2* not discussed?
'3 MR. CAMERON: .Okay. Thanks, Tony. Tony talked 4 about surveys and he talked about restricted use and noted S that there hacsalready been some discussion-on this.
6 . Besides th'ose two topics I think that there were some 7- . implementations' brought up yesterday that we can pull back 8 .in'at-the end. But Tony, does it make sense to sort of
- 9. let's/ focus on survey, the' survey issue first?
10 MR. HUFFORT: Especially if we could think about 11 how surveys would be incorporated into a new draft. rad guide 12 'if one were developed, that might be helpful.
13 MR. CAMERON: Okay. That's a good -- good 14 question. Let's talk on the survey issue and what sort of 15' guidance.would be needed. Who wants to start us off on 16 .that? I know there were some comments yesterday that dealt 17 with this issue of surveys and detectability.
18- MR. HUFFORT: Yeah. One of the questions that I
- 19' 'had'from the discussion'this morning was the issue of NRC 20 having.their licensees conduct surveys prior to it being 21 released, but it also appears that some of the scrap metal 22 facilities have very sensitive detectors.already in place.
23 If we have'these'.very sensitive instruments out there ,
24 already, is that more or less setting a standard already for
- 25. us, a'de facto standard for measurability?- And what would ANN'RILEY & ASSOCIATES, LTD.
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, 1- be the correlation between the surveys at a licensee's
()
,-m 2 ' facilities and.that of a scrap metal dealer, for example?
3 Would there be inconsistencies?
4 MR. CAMERON: Good - good question. And we'll 5 . start with Ray.
l6 MR. TURNER: Ray Turner. Is this on?
7 There have been significant changes just over the 8 last five or six years -- just over the last three or four 9 . years -- in the sensitivity:of the systems that are there 10- today. And some of the tests'that my company has been 11 involved in -- in conducting -- show that in the very short 12 distance inside a truck, as I discussed, I think-I discussed 13- earlier this morning, you still can't see a-gauge. I know 7_ _
14' we're not talking about gauges-here, but you still can't see
( i
(/ 15 a gauge when it's more than 21 inches or 22 inches inside a 16 truck and is shielded by a scrap that's 55 pounds a cubic l l
17 foot or more. Most of the scrap that's going out by rail, 18 for example, is going to run 70 or 80 pounds a cubic foot by 19 the time they pack it down into the rail cart and maximize 20 on the freight advantage.
- 21. So, I'think -- I'm confident, in fact, I'm sure 22 that the application of the systems, the sensitivity of the 5
23 -systems is not going to get any less, it's going'to get.
'24 greater than it is today. So, implying that what we have l 25 today is being extremely sensitive be the standard, we're l
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. .u .,cr 318 1 talking'about material that's going 'to be released over 30
( r-'s
() '2 or 40 years, and I think-we'd have a standard that would be 3 very short lived.
4 MR. CAMERON: If you based that standard on 5 current technology detectability.
6 Debra, do you -- do you want to say something?
7 All right.
8 MS. MCBAUGH: I guess I just want to clarify 9 'whether in this -- I'm reading back through it again.
10 Whether we're really only talking about metals and scrap. 'I ;
11 mean, we talk about several other materials in the document, 12 b'ut it seems to me we've been focussed on recycle and reuse
-13 of metals only. And I have other concerns, but I don't know
(
14 if those are something we really want to deal with, but we i O
\_/ 15 have the issues of just normal trash, how it gets surveyed.
16 This happens at Hanford as well as licensees. But how that
- 17 normal trash gets surveyed and then released to, say, a 18 landfill. And that seems to me that this is something that ,
I 19 we would use for that as guidance. But I'm not sure if this ]
20 is the place to talk about that.
I 21 MR. HUFFORT: I -- I think it is. Is this on? I H22 think it is because one of the things we're trying to assess
^
23 in this process is what is the scope of the rule. We're 24 currently looking at, as we discussed yesterday, metals, 25 concrete and soils, and it was brought up yesterday that we l 5(") ,
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'l need something possibly more encompassing. At least that's r~s. ,
1
() 2 one of the comments I heard, that we need-to look at l
3 everything, including trash. So, althcugh I'd agree with 4 you that the discussion, especially today, is kind of 5 focussed on' metals, we need to look beyond that because the 6 . comments that we're hearing, atlleast today, are that we -- I 7 we need possibly a broader scope than what we thought of. q 8 So, certainly, from our standpoint, at least now, 9 we're looking at soils and concrete in addition to metals.
10 But if we're going to broaden'to other materials, then I 11 'think your point -- your point is well taken in any regard.
12 MS, MCBAUGH: Then -- because there are processes 13 that have been put into place for doing trash. I know we 14 have methods that have been set into place. What kind of 1
/'s '
k_s) 15 surveys and how frequently you survey and equipment to use.
16 And it is also being used at laundries for surveying out the 17- protective clothing once they've washed it. So, there are i 18 methods out there that we could include.
19 MR. KENNEDY: Yes. Bill Kennedy. Obviously, 20 during the development of this ANSI standard we have looked
'21 at a lot of implementation issues, and the Health Physics 22- Society and ANSI Committee N13 are currently committed to 23 the development of a second standard that would deal with 24 implementation issues, and it would be far beyond metal 25 recycle. As we know, there are a lot of things impacted by v .
s . e-
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'1' this potential rule making.
y}.
l 2 If you think in parallel to how surveys are
.3 conducted, I'll hit a few highpoints. We talked yesterday 4 briefly about process knowledge. If currently licensees 5 know something or don't have a reason to suspect it's 6 radioactive, a lot of times they will either not survey or 7 minimize the survey requirements on those items. And that 8 '. is a -- a cost effective way of screening when you would do 9 a survey.
10 There are a lot of issues dealing with 11 instrumentation selection which have to be tied to any
.12 numerical standard that you're looking at for the matrix, 13 the' geometry, the type of material involved. We heard the 14 examples about the plastic simulator detectors at scrap
'/
(/) 15 metal yards, but you can multiply that by every different 16 geometry or type of material that you would have. In other 17- words, very carefully selected, specific procedures.
- 18. You touched briefly on surface versus volumetric 19 measurements, and how the size or shape of a material might 20 be involved, the density of the material and what it is you 21 need to again monitor against.
22 Other options a e like concentration averaging.
l 23 Even using reg guide 186 there are -- it is recognized,that 24 materials may contain hot spots, and where the average 25 concentration of the material, of the residual radioactive ANN RILEY & ASSOCIATES, LTD.
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~1 -material, is less than the hot spot. There needs to be some 2 ' consideration about what is a hot spot and how dces it 3 influence a~ decision. making process.
4 You know, we look at things like summing fractions because it's likely not cost effective to try to identify
~
5
- 6. every radionuclide that's there, but to use known isotopic 7 ratios and to be able to use, perhaps, a sum of fractions 8: :(phonetic) approach at' deriving the total activity 9 associated with an item or material.
10 We looked at, again, the debate about removable 11 contamination levels versus fixed, but I think the standard 12 .has'come down on a single standard that is the combination 13 .of both. However, there may be situations where measuring
,, 14 the removable amount may. serve as a surrogate for 15 : determining the total activity present on an' item.
16 ' Variability of background we talked about. If 17 indeed you set a standard that is either not distinguishable q 18- .above background or_in the. lower dose ranges less than 10 19 millirem a year, fluctuations ~in background become very 20 important, and statistical measures would have to be put in 21 place to determine when a reading is significant or not, 22 since radiation is a random event. You would have 23- fluctuations'over' time. ,
24 How to get representative samples. And in a QA 25 sphere you might look at testing the null hypothesis as a Q(~3 ANN RILEY &~ ASSOCIATES, LTD.
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! 322 1 question here. And, you know, there may be direct or
- M a t+- 2 indirect sampling or scanning measures that would be 3 appropriate, depending on the situation encountered.
4 I think what's happened in che industry is often 5 times lthough attempts are given to provide guidance, it's 6 the challenge to licensees to develop specific monitoring, 7 trainings, record keeping programs, quality assurance 8 programs, in a manner that convinces the NRC that they have 9 a credible quality program for operating their facility.
10 And I think release of materials falls under that blanket as 11 well.
li MR. CAMERON: Thanks a lot, Bill, and thanks for 13 bringing that issue from the'jaddock and thac Mark raised 14 yesterday about when do you not have to do a -- a survey.
15 Okay. Bob Meck.
16 MR. MECK: One of the things that we've touched on 17 is the reuse of equipment, and I think most people vould 19 think that tearing down equipment given certain operational
- 19. knowledge doesn't make a lot of sense. And so past history 20 or process knowledge seems to be an important factor, as 21 well as what the equipment is going to be used for, you 22 know, say a pompers (phonetic), and so on.
23 And so -- and Bill also touched on this, the 24 question to air, I think, a bit, is how can the NRC, you 25 know, incorporate common sense with the requirements for D)
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,, 1 surveys in terms of process knowledge for equipment and so OV ~2 on? Thank you. Bob Meck.
3 MR. CAMERON: Okay. Thanks, Bob, for putting that 4 ' out. Any comments? Let's go to Andy, and then we'll got o 5 Ray-Turner. Andy Wallo.
6 MR. WALLO: Andy Wallo, DOE. I guess I wanted to 1
7 comment a little bit-as we're trying-to resolve the 8 difference between the way we would survey for clearance 9 versus somebody receiving this material either at a mill or 10 at a waste dump, and the -- the gamma devices they have 11 there.
12 The problem is the difference, particularly at the 13 steel mills, is they're trying to find sources that might 14 cause problems for them, and so they -- they have this rO 15 self-shielding problem. They have to look at alternatives 16 in how to dehl with that. And frankly, if you look at the 17 physics, ultimately, the only.way they're going to solve 18 that problem.is by reducing the self-shielding. You're not 19 going to get the-instruments any better to detect something
- 20. that!s buried in three feet of steel. That's what we use to 21 shield the radioactivity, so if you're going to try to find 22 a source, you have to remove the shield.
23- Now, we do a lot of -- of release surveys and have 24 a' lot of automated systems at the DOE facilities. Some of
'25 the green is clean programs where they survey everything ANN RILEY & ASSOCIATES, LTD.
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. j-1 that goes.out to a landfill to make sure that it's not j 7 c2 contaminated involved conveyor belts and some of the large j 3 scintillators that you all use at the plants. And we do 4 find problems with those in terms of unusual things getting 5- into regular garbage. We closed down a system because 6 somebody cleaned their boots that was uncontaminated mud 7 .that got into a regular trash system that shut down the 8 system because the radioactivity in the mud was higher than t
9 we'd allow to go to our trash dumps, based on the way the 10 alarm system was set up.
11 And that's the same thing that's going to happen 12 here. When we do a sur"ay to release something, we'Le i 13 releasing with hand held, we're checking all of the 14 material. The way the systems are currently set up at the 15 mills is they're looking for a differential. They look for I 16_ any alarm that sees a little change in activity, rather than 17 a total volume of activity. And recounting that on, for I 18 instance, DOE non-reactor scrap metal, probably 95 percent 19 of our carbon steel is uranium related material. Of that 95 20 percent of the scrap that we're dealing with, I would say 80 l 21 percent is clean. There in nothing can be detected on it.
22 Of the 20 percent that you might find something on, most of 23 it is spotty.I And the spotty stuff is easily removed down l 1
24 to current release levels, and would be easily removed down l 25 .to what 1 imagine might be proposed as a result of a i.
- /"% \
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l 325' ]
1- standard. But the result is that when you remove that you ;
) '2 spill have some residual spotty contamination.
3' When you put it through these detectors at the 4 ' mill, that spot, if it's on the surface right next to the )
5 scintillator, is a differential inactivity. So, when it --
i 6 the truck scans through, it measures a very low background, 7 it gets a very low activity spot, but it is a differential.
8 And that difference alarms. j 9 And the problem between how we survey for 10 clearance and how you cervey to ensure a source isn't coming .
11 into a facility, is something that's not going to be easy to 12 resolve, and it's something that needs to be thought about. ;
I 13 And we see this, as I say, as we have automated systems 14 versus hand held surveys that we'get these kind of alarms.
- 15. I'm not sure -- the -- the other thing is I'm kind
- l l
16 of surprised that the steel mills aren't seeing more other i 17 materials that we've said several times here that over the 18 past 50 years there's radioactivity getting into the steel.
'19 .Well, actually, if we look at the amount of material that we
- 20 have in our stream now,. Ray mentioned that it's a small 21 fraction of what's recycled every year. But what we ,
22 released _over the past 50 years is even a smaller fraction 23 of what's in the recycle system now.
24 But'as I noted, most of our material has uranium i 25 on it. The surveys I've done at phosphate mills, the g ANN RILEY & ASSOCIATES, LTD.
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L n 326 l l .1 ' surveys I've done at vanadium mills, at non-uranium mills,
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T 2- copper ore mills, iron ore mills, have the same levels of 3' uranium that we're talking about here, and higher, 4' sometimes, than what we would release. It surprises me that 5 if -- if we have a concern with the release standards we're 6 proposing here, why som i of the recycled steel from 7 phosphate industries, from the copper industries, from the 8- ferrous are industries, why they aren't alarming at the 9 mills as well. And I think it's something that we ought to 10 'look into.
11 -Again, we talked about the fact that this is not 12 just 50 years of nuclear industry radioactivity, this is 200 13 years of industry. These industries have been around. They
'14 concentrate materials and they concentrate uranium and (G) 15- radium which, by and large, are what's in the fuel cycle 16 materials that we're surveying out.
17- MR. CAMERON: Thanks, Andy. And I guess on that I 18 would see if Tony and Bob have anything to say on that 19 before we'go to Ray. But on your last point do you think 20 that the -- the NRC's presentation on this issue, whatever 21 the ultimate outcome is, do you think there should be more 22 _ attention paid to giving, perhaps, a broader overall 23 -perspective to the public on the nature of this problem by 24 talking about some of the things that you were mentioning?
25 MR. WALLO: I think that's probably of some 1
j
'O ANN RILEY & ASSOCIATES, LTD.
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j'- 1 l-327 1 benefit, though I'm not sure the folks that are interested r"y l ( ) 2 in not allowing release are that concern with that fraction. .
3 But I think it's for the general public probably important.
4 But what might be more important is to recognize that these 5 industries-have to be aware that there may be some fallout 6 from these rositions on the nuclear industry as well.
7 It I take.a chance to comment on a federal 8 guidance that EPA attempted to issue back in '97, I guess, 9 or was-it '96? The federal guidance, John. John can 10 correct me. I think it was December of '96. Basically 11 adopting 100 millirem standard across the board. The 12 comments didn't come in obviously from the nuclear industry 13 opposing it. The people that commented were the oil 14 industry, the phosphate industries, many of the normal ore
( 15 processing industries that said this 100 millirem standard 16 is obscene, it will cost us billions of dollars to implement 17 and you can't do'it.
18 .Now, if we take that another step further and ;
19 somebody looks that's saying, "Well, gee, if you're 20 controlling radioactivity from the nuclear industry at these 21 levels, are you going to have fallout and force us to j 22 control it in the t-norm industries as well?" That's 23 something that -- that I think is maybe one of the costs or 24 benefits you have to consider, is their fallout from a 25 standard.
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328 1 MR. CAMERON: That's -- and you're using fallout
,r-(NJ' 2 in terms of something bad that results?' Okay. So that 3 people don't think there's actually radiation that comes 4 from a standard. But -- okay, may be good, not bad.
5 And just to -- we sort of touched en the issue 6 that David brought up'about an implementation issue, this 7 whole idea of what sort of educational efforts go with a ]
8 standard.
9 Before we go to -- to Ray, Bob or Tony, do you 10 have anything to say with regard to what -- the points Andy 11 raised?
12 13 MR. HUFFORT: Other than they're all valid points, 14 I thought. j
~ f~'\
(_,) 15 MR. CAMERON: Okay. Thank you. Ray.
16 MR. TURNER: Ray Turner again. In response to I 17 Andy's comment and also to the lady over here, probably 18_ there is enough sweeping data and information and discussion '
19 that could tale place in each area, be it soles or concrete 20 or recyclable scrap metals, probably enough to justify 21 separate meetings for each one of those. We've been talking 22 primarily about recycled scrap metalc for the most part in 23 this whole meeting, and it's taken up the whole meeting.
24 But in response to Andy's comment, a couple of 25 things. We do see, every day, other elements coming in I
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! 329 t
1 besides-gauges and besides norm pipe. In fact, the concrete (xj 2 we're talking about will set off the radiation detectors 3 when it comes in. If you send a shipment of concrete -- not .
4 a shipment, but just a few pieces of concrete or a football .
5 sized piece of concrete let up against the side of a rail 6 car, that will set one of.these detectors off.
7 In addition, if the rail car or the truck trailer 8 has been welded with thoriated welding rods, that will set 9 them off as well. So, a lot of times trucks -- they won't 10 allow certain trucks to come into steel mills because 11 they've used nickel thorium welding rods for the welds, and 12 that sets off the detectors. Bauxite ore from aluminum 13 plants. Zirconium sand. The white sand on the beaches down 14 in Florida. Just that sand alone will set them off when it O
k ,/
m 15 comes through. Phosphate. Thorium.
16 Dirt build-up in the bottom of a rail car. It 17 gets six or eight inches deep in the bottom of rail cars. l 18 Our company also has the largest private fleet of gondola ,
i 19 cara in the country, and we're constantly having to clean j 20 .out the bottom of those cars because just the dirt build-up 21 in the bottom of the cars will set off the detectors. And i
22 in addition to'that, the air filters on the trucks pick up 23 enough thorium and stuff that they'll set off the detec. tors.
24 So, we are seeing a lot of other things come through.
1 25 MR. CAMERON:
~
I thank you. Thank you, Ray. Paul.
i
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1
- 330 1 MR. GENOA
- Yeah. Paul Genoa, NEI. This whole
- 'T 2 discussion'is really the crux of the matter, the difficulty.
I(G 3 And I think you asked a question -- you asked a question 4 that I wanted to address, which is is there something about 5 how the NRC should communicate what they're trying to 6 accomplish here that will influence the outcome, and I think l
7 the answer is yes, absolutely. And I think it's a touchy l 8 thing. It's difficult. But I think you really need to
- 9. think about how this'whole thing is presented.
.10- From my perspective, you're trying to solve a 11 problem. And the problem you're trying to solve is how --
12 recognizing that materials flow in and out of nuclear i
13 facilities every day, and recognizing that there are all of j 14 these natural radioactive materials in the environment and
/N
- ( ) 15 'all of these detection sensitivity issues, how do you set a l
16 level that assures the public that you are safely 17 controlling those activities so they won't be harmed. And 18 your technical dilemma is how do I set a level. You seem to 19 have packaged this as how much radiation is okay to go out.
- 20. That's not how you need to package this. There is no level 21 that the public thinks is okay to go out. It's how strong 22 controls do I impose to ensure that stuff doesn't get out, 23 recognizing the technical limitations. .
24 So, you're on the backward side of this whole --
25 the whole issue, and I think it's scaring people for a lot I
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y 331 i
1 of reasons. And I don't know how to help you. I'm trying
! [) 2 to think of it because it --
i \_/
3 MR. CAMERON: Paul,_even -- you know, even that is 4 helpful. And Tet's -- let's explore that issue. David.
5: MR. BllLK: Yeah, I just wanted to add that we're
- 6. not just talking about, quote, " nuclear facilities." We're
~
7 talking about universities, high tech areas, biotech. So, 8 don't just focus on thac. And I think that term, although I 9 understood what you -- what you meant -- needs to be very 10 carefully handled. It gets back to this whole thing about 11 how you present -- present these issues, because they're 12 much broader scope than metals, sand, that kind of stuff.
I 13 It's much, much broader scope.
14 MR. CAMERON: Okay. Thank you, David. Frank,~do r~g i
_Q 15 you want to ask a question?
16 MR. CARDILE: I just wanted to go back to the I 17 question or the points that you were raising at Ray. If NRC 18 proceeded and set a standard like, say for example, one 19 millirem as the -- as the dose standard that we had in the 20 regulation, and the licensee surveyed all the material that 21 he might have at a particular time and then put the material 22 in a truck, as far as the NRC is concerned, at least for 23 that. licensee, the process is over. I mean, the materi.a1 24 has been certified, surveyed to a level that was safe H25 according to the regulation. But as you point out, a number fG ANN RILEY & ASSOCIATES, LTD.
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1 of different things will set off alarms.
2 So, I'm not -- I don't know what question I'm
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3 asking, but it seems like weive got a -- a dichotomy or a )
4 disconnect where NRC may be setting a standard for its 1
5 licensees to survey at to demonstrate, you know, for sure 6 that the atandard has been met, and yet other factors are
{
7 going on at your facility, your steel facilities, setting 8 off alarms or -- or that would have an effect on whatever i
9 standard we have.
10 I'm not sure what question I'm asking, but it 11 seems like we're trying to proceed to set a standard for our 12 licensees, I think, as Tony mentioned, to survey that 13 material, and yet, when it gets to your facilities, all 14 kinds of other things are going on in other radioactive (n) 15 materials, like norm from the oil and gas industry are I 16 perhaps coming in, setting off alarms. And perhaps a 17 truckload comes in from a nuclear power plant that sets off 18 alarm for no reason related to the material from the 19 facility. But I'm just curious how you and, I guess, how 20 Paul sees that kind of situation.
21 MR. TURNER: Probably the right term again --
22 probably with the exception of the refractories that line 23 the vessels inside the steel mills, all these other ite.ms 24 are being rejected when they set off the detectors. They
~25 don't just go in the mill and stay. If it rings the bell,
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t' 333 i 1 it's going to go back out. It's not something that's going 1
' 2. .to stay there.
. %J l 3 Now, the difficulty that I see in working with the 4 concrete issue, for example, is if the NRC says, "Okay.
5 We've cleaned it to a certain level, now, and it's okay." )
6 It's going to start off.a detector -- I don't know if I 7 care, but how do I know if it's the licensable NRC material i
8 that hadn't been cleaned out low enough, or how do I know l l
9 where to draw the line when it's the natural radioactivity l 10 setting off that detector in the area of concrete? And i 11 that's why I said earlier there's a lot of issues here that 12 could spawn subsequent meetings or meetings within 13 themselves just to discuss concrete. I don't know how you 14 address that problem or that issue. I
-( 15 If I'm running a concrete plant and you send me a 16 shipment and say, "Well, thia is clean. It meets all the i
17 release standards." It's going to -- it's going to ring my 18 bell, how do I know what I've got?
19 MR. CAMERON: Jim, do you want to tie on to that?
20 MR. TURNER: I think so. Yeah, I see -- for the 21 general public and so forth, I think the way you're talking 22 about controlling the material may be all right. But from a ;
23 paranoid redycler, I guess it would be, that's been bit, I 24 think that this also goes back to the cost. There might be 25 a cost in providing an assurance to the steel mill that --
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334
- 1 that this material-has been controlled from the time you
, ,m a
d' 2 surveyed it out until it gets to the mill, until it gets to 3= the furnace. And'I think you would want that from your 4 standpoint as well, because although you surveyed it and 5' certified that it's empty, what if another load of scrap got 6 in with the source and in that same heap. Now, you're going 7 to say.it.wasn't yours, but the mill manager is going to say l
8 something different. 1 9 MR. CAMERON: That's an important implementation 10 ' problem. Paul, do you want to comment on that or'-- !
11 MR. GENOA: Well, I did. I guess -- I mean, I see 12 two different problems. If -- if you're setting levels that 13 are as low as reasonably achievable, they're not going to be i 14 setting off your detectors that you're setting up any more
-15 frequently.than natural background materials are. And I
-16 guess I don't understand, Ray, when you set the detector 17 off, I guess you're just rejecting the load and-sending it 18 away. You're not actually going in and trying to find the 19 source that may be in there, because you're trying to solve 20 the. problem. You're trying to find orphan sources. You're 21 not trying to find radiation, you're trying to find orphan 22 sources that could damage your facility. That's sort of a 23 different problem. , j 24- MR. TURNER: We're talking not just about orphan 25 discreet sources but we're also talking about contaminated
'h v
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335 1 metals.like steel that may be contaminated with cobalt, for (n.)
i 2 example, that can also set off the detector.
3 In response to your first statement, in most mills 4 or in many mills they do call some body in or they call the '
5 state or they have their RS will go out and sort through the I
6 shipment and sort through the load and determine what is 7 setting of" the detector and remove that one component.
13- Then the requirement is that the responsibility 9 they caused to the disposal of that component goes back to 10 the shipper of that shipment of scrap or that load of scrap.
11 Along with that goes a cost that average anywhere from about 12 $250 to $450 per truckload of material for the crane time, )
i 13 for the personnel time that it takes to do that. j 14 But in some cases they are being sorted out. In 15 other cases, where mills have had one or two contaminating 16 events and have spent.$12 or $15 million and have been shut 17 down for three weeks, I can guarantee you that they're not 18 even going to sort through it. They don't want it on the 19 property. They're going to send it out and let it be dealt 20 with at point B, which may be the scrap recycler the ship 21 had begin with, (nr it may be another location that it will 22 be decontaminated.
23 MR. MECK: Ray -- Ray, are you saying that the 24 properly cleared material has -- that you've had problems 25 with material that's been properly cleared, shipped to your
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336 1 facility and set off an alarm and you had to do something
,em
. (] 2 with it, or'are you talking about improperly cleared j .' 3 material that's gotten into a shipment and you've had to
~'4 find it and send it back to waste, or is it -- is it both?
5 MR. TURNER: I'm talking about any material that 6- comes in and sets off the alarm in the mill. You cannot 7 assume that you do not have a nuclear device or a discrete 8 cesium or.a cobalt source buried in that shipment. You have 9 to verify that, okay, yeah, this is -- nickel, for example.
10 Thorium nickel.
11 MR. MECK: Let's -- let's exclude the source 12 question here. Are there a large number of occurrences
- 13. where you've received contaminated steel, not from a source 14 but just contaminated steel that has resulted from an bV 15 improperly cleared supplier?
16 MR. TURNER: Yes, there have been. There's one 17 being cleaned up right now in Lexington, Kentucky. There 18 have been several places. One in Ohio that had to be 19 cleaned up.
20 'MR. MECK: It's just not inadvertent sources, that 21- - it is in fact material that's been improperly cleared by a 22 licensed facility that has come into your way, come into
.23 your feed stream?
'24 MR. TURNER: No, not by a licensed facility, but 25 by somebody that held a licensed device at some point in
\
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337 L 1 time and let that device get out of hand somewhere, and it
>(3
'1 j 2 'was erroneously melted into a heat of steel and contaminated l
v 3 heat steel.
4 MR. MECK: Okay. I'm just trying to separate the 5' source problem from other contaminated material. I'm trying 6 to get an idea of the significance of one versus the other,
- 7. MR. CAMERON: Okay. Let 's -- Jim, do you have i
8 something to say on -.to try to help Bob with that
]
-9 clarification? And we have Scott and I think Paul. But 10 ~ let's make sure that Bob has the answer.
11 MR. MECK: We have two issues, here. We have a
-12 separate issue'of improperly controlled sources, and that's 13 an issue we're trying to handle separately from the 14 clearance effort. Where we're looking at clearance is
( )' 15 trying t'o--- in my mind, anyway, is determining whether we 16 have a problem with material that's being released that 17 shouldn't have been. released in the first place, aside from 18 the source problem.
19 MR. CAMERON: Let's focus on that second aspect 20 that Bob brought up. So, if we could have Jim say something 21 about that, and Scott, I don't know if you can -- and Paul, 22 you wanted to address that issue also? Do you have some 23 _information on that? And perhaps Ray and Ed. Let's address 24 that. Go ahead, Jim.
25 MR. TURNER: That isn't what I was going to i
l
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1 338 1 address.
. ,m f) 2 MR. CAMERON: Well, give the mic to Ed Bailey for
'31 a second.
4 MR. BAILEY: The problem, as I see it, is -- and 5- we've had both gauges detected and also just contaminated 6 material' such as -- zus wall fill (phonetic) piping, and then
- 7. in one case a rail. car that was made with contaminated 8- steel, setting off alarms.
9 The problem is that when that appears at that 10 steel mill, they don't know the difference. And so what it 11 means is -- and we've been involved in doing this -- is you 12 literally.take each piece of material off and you survey 13 each piece of material. And if you're real unlucky you get 14- down to where the car is empty and there's dirt or -- it's O)
!q_ '15 been used_to hall fertilizer, and the fertilizer that's 16 accumulated in the bottom of the facility or the car is 1
17' 'actually what has set the alarm off.
- 18. There is one agreement state located very close to
-19 us that has a policy of not going out. They just turn the 20 car around. I mean, they tell the mill send it -- send it 21 back.~ They don't go out and survey it. The mill doesn't 1
22 have anybody come-in and survey it.
23 The Conference of Radiation Control Program ,
I l
24 Directors has a -- authority from USDOT to sort of exempt ,
25 the shipments.from all of the normal radiation shipments.
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! 1 l- l 339 Every time they ship one of those back the cost from this 1
() 2' state'is about $5,000 for that return trip just right up 3 front. That shipment, one of them came back to Sacramento, l:
4- surveyed out, loaded.onto another car, the same waste went 5 'right-back. So, there's about $10,000 extra cost on that
'6 one shipment which didn't contain a gauge, and it didn't 7 contain contaminated material.
8 MR. CAMERON: John, do you have something to add 1
9 to that? i 10 MR. KARNAK: I think the thing to keep in mind --
11 _ John Karnak -- is that we all, most folks here are 12 technically trained and we no statistics and we no 13 probability and we no uncertainty. I 14 Bear in mind that any system -- and I think this
( 15 is what Ray Turner was coming to -- any system has the i
16 possibility of failure. And if that alarm goes off at Ray's
'17 or-at a scrap yard, they don't know and they don't care 18 whether there's a source in there,.whether there's dirt at
-19 the bottom of the car or something else in many cases, there i 20- is;a problem-and there's a problem that's going to cost them 21 time and money'at this point.
22 And that's, you know, you can't separate the
' 2 35 source. It's true, there may not be a source in there,,but 24 you.can't separate it. It doesn't make a difference. It
. :25 doesn't' appear that way to the guy that's trying to solve '
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n 340 1 his problem because now he's got a load of stuff there that f
!(m 2 he can't do something with. .And,-you know, what -- nobody l
3 knows whether the guy forgot to put the batteries or turn on
! 4 the alarm.or kick the switch on the plastic scintillation ;
[ 5 detectors as they went through the scrap yard or whatever. !
6 Something may.have~ happened, and there's a dozen or two 7 dozen or 500 things that could have happened. They don't 8 know and they don't care. 1 9 MR. TURNER: I understand that the end result is 10- the same, what I'm trying to determine is what's the source l 11- of the problem. l 12 MR. HUFFORT: Can I offer a suggestion? An 13 observation? l 14 MR. CAMERON: All right. Go ahead, Tony.
rN
(,) 15 MR. HUFFORT: I think one of the sources of the ;
16 problem is identification or signature of the radionuclides.
17 Much of the equipment -- and please help me out here, Ray --
- 18. is that they're' going by gross counts, that it's simply a 19 gross count rate that they're seeing at background when the 20 truck comes into the detector area, as you mentioned before, 21 it drops down and then if there's an increase in the gross 22 counts, they say there's radioactive material here. They 23 don't say what it is. They don't say is it natural, is, it 24 from the oil and gas industry, is it from a nuclear power 25 . plant, is it a source that is shielded that has been
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341 1 unfortunately released improperly. We don't have a
()
~
2 signature on this material.
3 Also, Ray, you mentioned before that there are new 4 studies that are going to be performed and that the future
.5 of these material, these detectors, are evolving. What I'd 1
6 like to throw out here is would signature capability be 7 helpful to identify the material itself? For example, 8 coming from a nuclear facility, if you have a certain number 9 of radionuclides that that facility owned, possessed or 10 used, and then it was released and surveyed, it would only 11 have those materials in that load. If you had the ability 12 at the scrap monitoring facility to cetermine what 13 radionuclide was present, you could say yes, this is 14 naturally occurring soil, this is fertilizer, but this over j
( 15 here is from a nuclear power plant. Would that be helpful?
16 MR. CAMERON: Okay. Thanks for putting that on.
17 And let's get a response from Ray and Paul -- we'll go to 18 Paul next, and Scott needs to say something over here.
19 MR. TURNER: Ray Turner. In some cases it would 20 be helpful, it would be probably more helpful to the states 21 I that have to spend $5,000 per response. I don't know why it 22 would be that much. I think you're overpaid. Oh, the cost 23 of the freight. Oh, I apologize.
24 MR. CAMERON: Still wants to --
25 MR. TURNER: In terms of a signature, you're I
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l L
342 1 talking about something like a gammaspec that would identify r~N l
() 2 the radionuclide that's inside. In some cases it would be 3 useful in the event it was, say, thorium or radium, 4 naturally occurring norm material -- norm material. It l 5 would help to identify what you've got and a little bit more 6 about what to look for. It doesn't mean the steal mill is 7 going to accept it. They probably won't. But it's my 8 understanding t hat a portion or a large portion or some 9 portion of the traterial that we're talking about releasing 10 here is cesium and_is cobalt, and those are the main 11 contaminators of steel mills, and they're not going to let 12 those pass. If they see cesium on the signature or cobalt, l
13 it's not going to pass. In some cases it would, but not 14 cesium and cobalt.
p)
(, 15 MR. CAMERON: Paul Genoa.
I 16 MR. GENOA: Well, I was trying -- Paul Genoa, NEI.
17 I was trying to do the same thing that Bob was trying to do, 18 separate the two issues. And I guess the linkage is that, 19 you know, my approach would be that if you set these levels 20 low enough that it doesn't matter, it doesn't effect your 21 issue. The only way it could, I guess, is that it perhaps 22 raises this background and makes your job of finding a 23 source, which is the problem, harder. And so I guess t.here 24 is an impact there, potentially. But that's where I was 25 trying to separate out.
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343 1 If your clearance levels are set low enough, there
[Yh- 2 should be no effect upon your actions or activities at all, 3 because this has been going on for 30 yeava or 50 years, and 4 you've already, you know, you're already dealing with it.
5 There shouldn't be any net change in material coming out to 6 you if this thing is done right, in my opinion anyway.
7 -MR. CAMERON: Okay. Thank you. Scott.
8 MR. PETERSON: I wanted to -- Scott Peterson from 9 NEI. I wanted to digress a little bit back to the 10 communications issue and really second David's point a
'11 couple minutes ago that I think it is important in how we 12 discuss this issue to talk about the large community of 13 industry, education, medical uses that this rule potentially 14 could benefit.
() 15 And, you know, we've heard from the recycling 16 committee on the impact on the steel mills when you 17 potentially recycle this material. But I think it would be
-18 beneficial to, at some point in these meetings, to hear from 19 folks like Dave or from Bob who represent biotech medicine, 20 university research, that community on what this would mean 21 to their programs going forward, whether it's clearance of 22 this material to disposal facilities and the potential 23 impact it would have on their storage issues, particula,rly 24 with the lack of low-level waste disposal facilities.
25 MR. CAMERON: Good. And we'll try to integrate
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344 y 1 that into the discussion that we've been calling " Don
()
,w 2 shoes," because I think it fits in with some of the s-. t 3 questions that Don.is going to pose to you right after we 4 come back from lunch for our final discussion. Jaz.
5 MR. DEVGUN: Jaz.Devgun. I have a quick 6 suggestion. I think as we are seeing so far, the discussion 7 .has, at least'today, focussed on the recycled metals. And 8- I'm a little bit disturbed about that because I think in 9 planning for the future meetings, perhaps you could some 10 kind of -- have some kind of allocation to other materials, I
11 too. Because they are of great concern to the industry.
l 12 And as I think Debra pointed out and some other. Not to --
13- not to discourage discussion from one issue which is really 14 important -- recyclable material and metals is very )
/N i
(_,) ' 15 important -- but to be able to also talk about concrete and 16 other materials, as we kind of mentioned yesterday. And --
17 and because there are significant issues there also.
18 I -- metal, of course it's important because it 19 can -- it has no barriers. It can go in from household 20 products to'anywhere else. But for concrete, for example, I 21 may have a limited scenario where I just simply want to use 22 these large amounts of concrete cleared for a local landfill 23 or quarry fill or something of that nature. And when Bob 24 Meck drives his -- the standard from those bear standard
'25 could be the same, whether it's one millirem per year or
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r 345 1 anything else. But by the time we drive it to the guideline
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2 value in terms of the materials, whether it's sulphurous 3 based or volumetric based, it's going to be different, for 4 metals different, for concrete it's going to be different 5 and how we apply it. I think we need to talk about that.
6 And this is a suggestion for you that as we -- the 7 discussion in terms of threads is really excellent because 8 there's a. continuity to it, but some kind of mechanism to 9 switch,to other materials. Thank you. 1 10 MR. CAMERON: Okay. Thanks for that suggestion, 11 Jaz. That will -- we'll try to incorporate that into future 12 agenda plannings, to not just exclusively talk about metals 13 but to also deal with concrete.
14 Let's take two more comments here and then get Bob
() 15 Meck and also Craig and Bill up so that we can break for 16- lunch and come back.
17 Let's -- let's take Jim right now and then we'll 18 go to Mark.
19 MR. TURNER: This will be quick. I just want to 20 clarify my earlier point about there maybe being a gap in 21 the control between the time the scrap was released from the iML . facility to the time that it reached the steel mill. I 23' Th'e problem wouldn't be so much in setting of.f the 24 alarm, because we never melt a source that sets off the l 25 alarm, it's the ones that -- so, assuming that your material i.
1 i
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p 346 l
! I got'through, assuming there was a source put in it or p) .2 assuming that some other material got through with a source lin it and they wound up in the same melt, that's a -- that's
~
'3 4 where'I see we need to have some type of control, other than 5 release'maybe, between the time that it's released from the 6 facility or the time you're talking about releasing it from i
- 7. . the licensed facility to the time it reaches the recycle !
8 -facility, whatever the recycle facility is. )
- 9. MR. CAMERON: Is.that clear to Bob and Tony?
10 MR. HUFFORT: No, it's not clear to me. I'm 11 not - I don't understand why, if a licensee surveyed their j l
12 material' properly and properly cleared the material, what 13 additional control would be required on that material before 14 it.came to your facility.
15 Now, the scenario I see is that after that 16 licensee's material is released it might get mixed with a 17 broker or somebody with some other material that was no la properly cleared, but then the problem stems back to the 19 individual, the. single individual who released the material, 20 not the licensee who did it right, the licensee who did it 1'
21 wrong. But it's still the control at the release point that 22 I see as-critical. If it's released properly, it's released 23 properly. There shouldn't, in my mind, have to be anything ;
24 .else that happens downstream.
25 MR. TURNER: How does he know that it was released i ANN RILEY & ASSOCIATES, LTD.
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347 1 properly?
.4 ~
- j, ) 2 MR. HUFFORT
- I guess -- I -- I don't know. I 3 can't answer the. question other than the fact that the 4 licensee- has done the job right. Paul?
5 MR GENOA: Well, I guess that I'm trying to get 6 back to that point because things are released today and 7 they come to you, and they don't give you a problem unless j l
8 they incorporate a source, and that's something that is 9 outside this discussion. Now, the only linkage I can see is
-10 if somehow the material being cleared somehow increases the 11 background around your detector and limits your sensitivity 12 .to detect the source, which is the problem. But if the 13 levels are right, you don't care whether this stuff comes to 14 you.
\_,/ 15 MR. CAMERON: Can I make a suggestion here?
16 Let's -- Debra may be able to shed some light on this, but 17 perhaps if you could do a little caucus during lunch and try 18 to square this away and maybe give us a little report about 19 whether it's been squared away or whatever so that -- do 20 this sort of offline and we'll come back with it.
21 So, we can -- we'll get Debra on and then we'll 22 finish'off with M' ark, who I'think has another point to make. 1 23 Debra. ,
l 24 MS. MCBAUGH: Well,.we've had examples of L 25 licensees that have done the proper procedure and have I l'
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348 1 surveyed, and still_you can have something that shows up,
[nJ 2 And I:think it's because we can't survey.100 percent of 3 anything. And when we set up a procedure that is a free
'4 release procedure, it says, "This is how many surveys you do 5 and-this is the percentage thac you look at and you look at 6 the history of the item and you say, okay, this is how much 7 you survey." And so you aren't going to have 100 percent 8- assurance that there isn't something that is going to get 9' out there that gets caught. And -- and I don't think it's 10 because -- it'isn't because the licensee hasn't done the 11 proper procedure.
12 MR. CAMERON: Okay. Thanks. That's a useful end 13 point to that, perhaps. Mark.
14 MR. CARVER: I thought Tony asked a question that
.(_c) 15 was very important to me in this elide here. NUREG 1640, by 16~ my reading, necessarily sets very le acceptance criteria 17 for these surveys. If I follow the methodology of the NUREG 18 _it postulates that surfacially contaminated metal will end 19 up being transported by a driver of a truck, and in order to 20 keep his exposure less than one millirem a year, the surface 21 contamination levels are very low. And my reading of the 22 tables in the NUREG produces numbers that are so low 23 necessarily that I don't think I have instruments at my 24 power plant that can detect those levels of radicactivity in 25 certain circumstances. And the reason that -- you already l l
1
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l 349 1 know that.
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! 2 The reason I wanted to speak up again is to 3 underscore a point that I think Paul and Mark Somerville 4 made yesterday-and again'today. We're not just talking (
l 5 about scrap metal. We're not just talking about 1 6 ' decommissioned facilities. We're talking about very large
-7. nuclear facilities, like nuclear power plants, that operate l 8 every day by moving trucks of material in and out of the l
9 plant. Today it's very difficult for us to do. We're ;
i 10 : spending lots of money with lots of people and lots of '
11 equipment, as you know, to screen and survey the things that 12 go in and out of our plant necessarily. My reading of 1640 13 makes that job almost impossible with the -- with the 14 materials and people that we have today. And I'm not n
() 15 criticizing the report. It has to derive numbers that low ,
l 16 because we need to keep the dose to the truck driver less 17 than a millirem as he does trucks in and out. You know, 18 these conservatisms produce these very low numbers.
- 19. But you've asked a very good point. How do we do
- 2 0.. those surveys with these numbers? And my reading is I 21 can't. So -- so, some people may think that means, "Well, 22 that means you can't decommission your power plant. Too 23 bad." -Well, no , that means I can't operate my power pl, ant, 24 and that's -- and that's important to me.
25 MR. CAMERON: Good. That's a great introduction
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r 350 1 to get Bob Meck up here for his five minutes, but it's also h
I A _/
2 a nice ststGmsnt from your perspective about what the nature 3 of~the problem and the need here is, which is also 4' somet.hi tig, that's what we want to focus on, one of the 5 things we want to focus on when we come back after lunch for 6 our final discussion.
7 Bob, could you do a short presentation on 1640 and 8 then I'm going to let Craig from Envirocare -- and I keep 9 stumbling over your last name, sorry -- and Bill Kennedy 10 from Health Physics Society say something. We'll close out 11 for lunch and come back.
12 MR. MECK: Okay. I've got the clock running and 13 it's only 15 minutes? Hurry up. Hurry up. Hurry up.
14 Know your audience. How many folks here have
() 15 spent more than two hours looking through 1640? Okay. A 16 good majority. How many have no idea what this document is 17 about, more or less.
18 [ Laughter) 19 That's right. That's right. Andy has a way about 20 him, you know. He's always got a different twist on things.
21 The position that the Commission is in is if there 22 were a net benefit, as we've talked about, a net benefit to 23 1"aving a change in the regulation, it's to weigh what the 24 risk would be that would be acceptable for that net benefit.
25 And so there's no point in taking on a risk unless there's
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351 l' some perceived potential for getting a benefit of it. And O 2 we've been talking about there are some in the audience who V l i
3 think that -- that there is a benefit likely and we need'to !
)
4 draw the line someplace..
5 And so the challenge the Commission has is if we 6 . were to draw such a line, where would we do it and how would 7 we go about doing that. And the line is a risk line. What !
1 8 kind of a risk would we have and what principles would we
.9 have.
10 Yesterday, I talked about how 1640 is oriented I 11 toward the individual. What kind of risk from radiation l 12 alone would an individual get? Well, we're talking about a 13 broad spectrum of materials and we're talking about a 14 complex society where materials get used in many different 15 ways. And'we're talking about a large number of 16 radionuclides. So, how -- how did we go about that, saying, 17 well, what can an individual get.
18 So, the philosophy overall is if we can identify 19 the group of people who would generally get the most :
20- radiation from -- from clearing material, from just letting i 1
21 it go out into the commerce, what -- what would that person !
22 get? And that's what NUREG 1640 is about. Now, there's a !
23 follow on, E document that's going to be produced to talk 24 about the collective does, and we talked about that 25 yesterday and got into a pretty active discussion, and I'll 1
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p 352 I
1 ; mention that later.
<y '
(wJ i- 2 But suppose -- I'm going to take a specific 1
3 exhmple for the illustration of what 1640 is, but basically 4 we looked at what are the -- in terms of bulk and mass, what 5 are the likely kinds of materials that would come out of our 6 licensed facility, and that would hare some potential for j i
7 tracking where it would go? And we choose ferrous metals, I f
8 copper, aluminum and concrete to analyze. Okay. So, I'm 9 going to take one of these. And the radionuclides that we 10 used we choose from manifests. We looked at manifests that 11 go to low-level wastes and say what radionuclides are in 12 there? We also looked at those that the EPA analyzed. And i
13 we also looked at the European Union and what what were of '
14 interest in that. And we analyzed, for each radionuclide, t'
(h,/ 15 all of those radionuclides.
16 And so I've got one minute? Okay.
1 17 So, what did we do? We say, "Okay. A consumer l 18 product would have this kind of a dose, and there would be a i 19 distribution of how, you know, how -- what kind of doses 20 that somebody from a consumer product would get." A slag 21 worker from the release of this may get this kind of a dose.
22 And out here someplace the transportation worker may get 23 this kind of dose.
24 And so we looked at 89 scenarios across all these 25 materials, and this is what we would say is a critical l -
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L
E 353 1 group. This person gets the most or this group of people
~A g 2 get the most dose. And so what NUREG 1640 does is to 3 identify all of these scenarios, but also it's aimed at l 4 finding out where the critical group is and what kind of a 5 dose it is.. It does not set a limit. Okay. It says if for 6 a unit of. radioactivity in the -- in the material or in the 7 scrap that's released from the facility, what would be the 8 dose to the critical group per unit. But we have not -- we l 9 have not set whether that is going to be any unit at all or 10 some range of units.
l 11 I'd be happy to answer questions.
12 MR. CAMERON: Great. Well, I think what we will i 1
13 do is Bob will be'available to discuss any questions that 14 you might have on the document during lunch and after the l 15 meeting.today. And are you going to tell us about your 16 summer vacation?
17 MR. MECK: We went to eastern Oregon and it was 18 .Very lonesome.' l 19 On the follow on work, as part of the process of i 20 enhancing participation, we've got a contractor meeting and 21 we've. decided to open up the -- the development of the 22 technical basis when we are meeting with contractors so that 23 the process can be more visible to people and will also open
'24- up a certain portion of that.for public comment. That 25 meeting will occur next week in Washington, D.C. in our ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034 l
I
)
354 1 Rockville offices September 23rd and 24th. On Wednesday it
[\_/ ) 2 came out in the Federal Register. I just wanted to alert 3 people here. I've got more details if you want them.
4 MR. CAMERON: Okay. Thank you very much. We all l 5 like to kid Bob, but he did a tremendous job on this, and if 6 you do have questions for him, please talk to him.
7 We're going to also go quickly to Bill Kennedy 8 from the Health Physics Society and also to Craig. Does it 9 matter which one -- Craig, do you want to come up? Okay. j 1
10 Go to that mic, please. '
11 MR. THORLEY: I didn't want Paul to think that
-12 this was just his mic. Craig Thorley from Envirocare. I 13 just want to state for the record, to start off with, that 14 my two oldest kids have braces, so I'm -- hopefully we can r~s. !
( ,) 15 be in a situation where I'm not getting beat up on all j l
16 sides, which is what we often feel like at Envirocare. '
17 I can empathize with the situation that the power 18 plants are in with the regulators, with the steel companies. !
1 19 I know that this is a tough issue because you've got a lot l
20 of competing considerations. We are going to be submitting 21 written comments, but we, as Envirocare, we support the 22 idea, understand that there has got to be some level at 23 which you draw the line. But as you might expect, we would 24 support very strict standards for release or for clearance.
25 The reason for that, if I can give you just a
[s \
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r- 1 355 1 little. bit of history about my company, we are a licensee of
'i 2 the Nuclear Regulatory Commission for 11E2 disposal uranium 3 mill tailings (phonetic.) That process took us four years to 4 go through and cost us millions of dollars. The first thing 5 -- the first issue on that license was do we have to do an 6 environmental impact statement, because the DOE had just 7 done probably the most comprehensive environmental impact 6 stat ement process ever done for the vitro tailing site which 9 is right at our location. The NRC came back to us and said, 10 "No, .that's not good enough. That was on the other side of 11 the fence. You've got to do your own, completely new i 12 environmental impact statement."
13 And so we-went through that process from 1989 to 14 1993. We were licensed by the State of Utah for low-level, 15 norm and mixed-waste disposal at similar levels of scrutiny 16 for our low-level disposal. For example, anthronorm 17 -disposal, we were required to submit our application in --
18 in accordance with NUREG 1199. It was reviewed under NUREG 19 1200. That means that we were licensed as if we were going .
. 2 0. to be a full fledged class A, B and C low-level radioactive 21 waste disposal facility, as if we were going to be taking 22 millions of curies of waste. In the 12 years'we've been 23 operating, we have taken less than 1,000 curies. It's 24 .probably in the range of 700.
- 25. So, we were held to a very high standard compared i
h'\
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!~ 356 1- to the operation that we have. Not just in the licensing of i jN O
2 .our facility,.but in terms of the operation of our facility.
i 3 We are. held to very strict standards. We get violations for 4 things that I'm sure folks from the power industry would --
5- could tell you some similar kinds of stories. But I want to 6 tell-you about just a couple.so that you understand the 7 -level of scrutiny-that we have and the costs that are 8 imposed on us'that we have to incur in order to meet those 9 compliance standards.
10 We've had violations in the past for on a form 11 where a question was not applicable drawing a line at that, 12 'at that blank, rather than putting n/a down, as the
- 13. regulation said you had to put n/a down. Our operations 14' manual, which had been approved by the State, said you could
/
( 15 . draw a line through it. So, that was a violation.
- 16. MR. CAMERON: Is this a therapy session for you or
'17 does this have some connection to clearance? All right.
18 MR. THORLEY: This has a good connection to it, in 19 my opinion, anyway.
20 The -- I mean, I could go on and on with those 21 kinds of stories, but what I'm trying to tell you is it's 22 expensive to run our facility. It's not expensive as 23- Barnwell. Hopefully not as expensive as Wip or Yucca 24 Mountain would be. But you get what you pay for when it 25 comes to waste disposal industry. You could take your trash
/ '\ ANN RILEY & ASSOCIATES, LTD.
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F 357 j f 1 and dump it out in your backyard, but that's not what we do.
Os 2 We send it to a municipal landfill, hopefully. And you
,V '
l 3 could take your hazardous waste and dump it in the municipal' I
4 landfill,.but that's not what we do. And the same thing
- 5. with' low-level waste, supposedly. i 6 The reason I've told you all of that is because we 7 have been held to very strict standards by the NRC and my 8~ perception of the trend, I would generally be in favor ot 9 what you're proposing to do, but the trend, it seems to me 10 in the last few years from NRC, has been towards a 11 deregulatory trend, and that troubles me, number one, and 12 number two, it makes me skeptical about.what you're trying j 13 to.do.
14 And the -- and on the issue of the deregulation, A
Q 15 for example, first of all, Caveara Mining was allowed, and 16 Mr. Treby knows a lot about this, they were allowed to amend 17 their license so they could take 11E2 in commercially. And 18 they were not held to the same standards that Envirocare was 19 in order to get into the business. But that didn't last 20 long because they were quickly undercut by NRC who then 21 suddenly determined that any 11E2 which had been generated 22 before 1978 was magically no longer subject to UNTRCA. And
~
23 so now that waste is going to other places, like Button 24 Willow and Envirosource. These are RCRA landfills. And 25 that's what the Corps of Engineers is doing. And I don't D ANN RILEY & ASSOCIATES, LTD.
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p o.
358 IL ' blame these guys. That's their job. Their job is to clean py.
( 1- 2' up., meet minimum standards at minimum cost, and they're 3: going to do that if they're allowed to.
4 The cesium 137 is another situation that -- that I 5 thought was interesting. Mt. Turner and Mr. Turner know 6 'about that. The -- when the branch technical position catae 7- out from NRC the justification for it was -- there were a 8 couple of justifications. One was that the NRC had not 9 . adequately controlled sources. The other was that it -- the
~10 steel. companies thought-it cost too much to send it to 11 Envirocare. And that was news, I'm sure, to the more than 12 half of universe of waste that had already come to 13 .Envirocare. But that's-just another issue on the
_14 deregulatory trend.
O(s/- 15 The next one is this unimportant quantities of 16 . source material, and under 10 CFR 40.13, and that's why the 17 Corps asked about that, because they are sending waste to 18 waste control specialists'today under that, essentially an 19 exemption which was never intended to be a clearance
-20 standard cn a standard, a regulatory standard for waste 21 materials, as the State of_ Texas through a fit in a letter
'22 in March 18th, 1999'to the NRC on that issue after the NRC 23 gave it the green light, and then it was elevated to NRC 24 Commission and-they said, "No big deal. Go ahead."
25 And so that's -- that's what's going on to date.
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ro 359 1
I
,m.
That - -that is -- it makes these kind of issues that you're t
'/ 2 talking about fairly innocuous compared to some of this !
3 other waste _that is going out.
4 And then,' lastly, a letter from Greta Diakis i
5 '(phonetic) to John Dingle (phonetic) a few weeks ago that !
6 basically said, "We think that for lots of hits stuff, that 7 RCRA landfills are just as good as low-level landfills."
8 Well, that was news to me after the scrutiny that we had to 9 go through to get out license and then to have an NRC j 10 commissioner saying RCRA's just as good as a low-level, we 11 haven't really done any studies on it, but we think that 12 that's the case.
13 And then finally, with DOE sending some of 11E2 to 14 International Uranium Company for recycling, they spent $2 l's million to' send it to them. The company says, "We're doing 16 this to recycle $50,000 worth of uranium out of it." And i
17 the NRC is willing t o accept that at face value that they're 18 really doing that for recycling purposes rather than taking 19 the $2 million to dispose of the waste material.
20 Those are some of the reasons why I am troubled I 21 about the trend at NRC, and I'm skeptical about what's going l 22 on because it seems like it is, in a sense, a return to the i 23 BRC which Congress ordered the NRC to withdraw those policy 24 statements. And if you've -- if you know about the .
l 25 withdrawal of the policy statement, it said, "Well, we're f(n)
' d ANN RILEY & ASSOCIATES, LTD.
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360 1 going to withdraw it because Congress ordered us to, but we
() 2 don't really -- it doesn't make any difference because we 3 can do whatever we want under the Atomic Energy Act anyway.
'4 MR. CAMERON: Okay. Can we -- thank you very 5 much, Craig. And --
6 MR.. THORLEX: Well, I'm not --
7 MR. CAMERON: -- I think you raised the issue of 8 consistency, and I hate to -- to cut you off just right now.
9 MR. THORLEY: Just one more minute and then I'll 10 be done.
11 MR. CAMERON: Okay. One more minute.
12 MR. THORLEY: Okay. On the issue of competition.
13 If ' you J ower the standards then that 's one way to increase 14 competition, but that's not the way to go about it. In the A
( ,) 15' same way that the -- if the -- if the Major League baseball 16 thought, well, we saw what Sosa and Maguire did, that was 17 great, why don't we move in the fences 100 feet and then l
18 everyone will have a 70 home run hitter and we can pack the 19 stands. That's not what would happen. That would ruin the 20 game of baseball, Just if you lower the standards here too 21 much is what I see you're doing is lowering the standards in 22 the industry that I'm in. Holding me to the high standard, 23 but telling everybody else that they don't have to meet. it.
24 MR. CAMERON: Okay.
25 MR. THORLEY: So, that's, you know, we'll submit I\ - ANN RILEY & ASSOCIATES, LTD.
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361 1 written comments, but those are the reasons why we're r's
.( ) 2 concerned.
13 Okay.
MR. CAMERON: We'll look forward to those 4 written comments. And just let me clarify for the record, l 5 is the NRC is not setting anything here today. We're 6 gathering information on wnat course of action the NRC 7 should take in regard to the releasr of materials.
8 Let's finish up the morning session with brief 9 remarks from Bill Kennedy, Health Physics Society.
10 MR. KENNEDY: Thank you. I have a prepared 11 statement from Health Physics Society that I've turned over 12 to the meeting organizers that will appear in your handouts 13 at the end, I've been assured. I will hit a couple of high 14 . points, but I won't read it into the record. Has it been A
(,) 15 passed out? I didn't get it. Okay. I think she's about to 16 pass it out.
17 Well, just a couple of high points. As you know,
'18 the Health Physics Society represents about 6,000 dedicated 19 professionals focusing on radiation safety issues. The 20 Society believes that the definition of clearance level is 21 an important part of the standards process to provide for 22 the safe handling.use and disposal of radioactive materials.
23 In previous society position statements we, number one,. have
- 24. supported regulations for radiation protection that are 25' based on the National Council of Radiation Protection and b
\~ '
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362 1
Measurements. recommendations for dose limits to individual
[~h 2 members of the public.
\s ,/ '
3 Item two is that we recommend that constraints be 4 applied to all regulated, non-medical, non-occupational 5 sources of radiation exposure to the general public, 6 excluding indoor radon, such that no individual member of 7 the public will receive in any one year a total effective 8 . doue equivalent exceeding 100 millirem or one millicevert 9 from all of the sources combined, and we recommend that the 10 dose limits be applied only to individual members of the 11 public, not to collective dose from population groups.
12 We further recommend that the regulations for 13 radiation protection be based on consensus standards of the 14 American National Standards Institute, or ANSI, issued by
() 15 the Health Physics Society standards committee, in keeping 16 with the intent of public law, 104-113, National Technology 17 and Transfer Act of 1995, and the OWB circular A-119, 18 " Federal Participation in the Development and Use of 19 Voluntary Consensus Standards."
20 We recommend that the primary radiation protection 21 standards be an all pathway total effective dose equivalent 22 standard, with screening levels related to quantities that 23 could be measured, such that compliance with these levels 24 will result in the primary dose standards being met for all 25 reasonable and likely scenarios.
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l; 363 1- We recommend that.the screening levels be derived
['\_/) 2 . consistent with the principles of alara or as well as 3 reasonably achievable.
4 And the Society supports the adoption of the ANSI 5 standard, N1312, issued in 1999 entitled, " Surface and 6 Volume Radioactivity Standards for Clearance." And that 7 that standard is consistent with the previously mentioned 8 positions oC the Society. 1 9 As I mentioned earlier in the meeting, the final 10 clearance standard was approved by ANSI in August of 1999.
11 This standard provides both the individual dose criteria of 12 one millirem per year for clearance, and derives screening i
13 levels for groups of similar radionuclides, l 14' The standard also allows for clearance when
() 15 justified on a case-by-case basis at higher dose levels when 16 it can be assured that the exposure sources, including those j 17 not covered by the standard, will be maintained alara and 18 will provide an adequate margin of safety below the public
- 19. dose limit of 100 millirem per year, total effective dose 20 equivalent.
21 Now, we recognize that there will be several '
22 complex issues that make it difficult to fully implement the 23 standard, an'd as a result, some of those things were ,
24 excluded from the standard. They included naturally 25 occurring radioactive materials, radioactive materials in or I~N ANN RILEY & ASSOCIATES, LTD.
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l 364 L 1 on persons, release of licensed or regulated sites or
) 2 facilities for unrestricted use, radioactive materials on or
-3 in food stuffs, release of land or soil intended for 4 agricultural purposes. Materials related to national 5 security and process gasses or liquids.
6 The full position paper, I guess you'll have an 7 opportunity to read at your leisure following the meeting.
8 Thank you very much.
9 MR. CAMERON: That's great. And thank you, Bill.
10 And thank all of you for.your patience and attention for 11 this morning. When we come back we're going to go to the-12 " Don shoes' issues, and I'm going to have Don set that up. l 13 And it basically is going to try to do integration of all 14 the things that we're talking about. And for -- in terms of O)
(, 15 your schedule, we'll start at 1:30. We will be done by 16 3:00. It's possible that we'll -- we could end earlier than 17 that, but at the outside, we'll stop at 3:00 so that you can i 18 schedule around that. Okay. All right. Thank you,
.19 [Whereupor, at 12:21 p.m., the worksh'ap was 20 recessed, to reconvene at 1:45 p.m., this same day.]
i' 21 22 23 .
)
24 ,
25-i
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n.
365
-1 AFTERNOON SESSION
-(3 2
() [1:45 p.m.]
3 MR. CAMERON: Welcome back to the final push on .
4 this meeting. And this session should be a lot of fun for 5 us.
6 And before we get started, let me just -- John 7 Karnak wanted to make sure that some material that was given ,
8- to you was understandable.
9 MR. KARNAK: Okay. Barbara passed out this 10 morning this document that says, " EPA's mixed waste 11 regulations." The two rules. So, I'm not directly 12 responsible with them, but I put my name and phone number on l 13 the back, and I'll make sure that you get the name of the 14 folk that you need to talk to about those two. And it talks O'
q,j/ 15 a little bit about the one under RCRA and the one under AEA 16 that we're working on.
l 17 T'ae other thing I wanted to mention is that we 18 have some extra copies of the work that we did and the 19 reports we published in 1997. And if you'd like to get 20 copies, either technical or the economic reports, just give 21 me your card and write " reports" on the back and I'll make 22 sure you get them.
23 MR. CAMERON: Okay. Thanks, John. And I guess 24 ~Debra McBaugh has been suffering some anxiety over the lunch 25 hour about something that she said, so we're going to let h)
/
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366 1 her get rid of that anxiety. j 2 MS. MCBAUGH: And boy, does that make it sound (mv}
3 exciting.
4 I was just a little bit concerned, and I sort of 5 was right when I said it, but when I made the statement that 6 licensees can do all of the right procedures and still end 7 up with something that can get out, I wanted to make that 8 very clear that we have never seen anything get out that is 9 a hazardous problem. We've only seen things get out that 10 were an annoyance because an alarm could go off. But we're 11 not letting things get out that are -- that are a health 12 risk. So, I just -- yeah, sure. So, I did want to make 13 that clear that it was an annoyance level thing, not, 14 MR. CAMERON: All right. This discussion that rm
( 15 we're going to have is meant to try to integrate the various
%s) 16 pieces that we've talked about over the past two days and 17 give you an opportunity to give us opinions on this whole 18 business. And Don is going to talk a little bit more to set 19 this up for you. But think about being in his shoes. And 20 he has some questions here about what do you see as the need 21 to take action? In what time frame should action be taken?
22 What additional information is necessary? And what action 23 would you take? And you can sort of wrap all these together 24 and make a statement on it. You can address one particular 25 issue and we'll try to -- to follow some discussion threads
/
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F 367 1 there, too. But I'm going to turn it over to Don to amplify
[w/ 2 1 on this.
3 MR. COOL: Okay. Thank you, Chip. I don't know 4 whether this is on enough for you to hear me or not, so I'll b
5 just try and talk a little but louder into it. And Giorgio, 6 you can take the " Don shoes" off of the top of the slide.
7 To answer what are probably the obvious questions, they're 8 nine wides. They're wingtips. They're Rockports, so that 9 you can still do a lot of running and walking in them l
10 because you have to be fast and quick on your feet. This
~
11 issue over the last few days has clearly indicated that ,
12 !
there is a fair amount of legwork -- pardon the continued i l
13 analogy -- that has to be done.
14 but in thinking about how to try and, at this
/O i, j 15 point after a day and a half with lots if very good 16 discussions with a whole variety of things that have been 17 laid out, with additional alternatives that have been put up 18 on the table and other things, try to find a way to 19 summarize and pull together some of that information because 20 some of the next steps are with this meeting and then the 21 Atlanta meeting and the Washington meeting, to sit back and I i
22 analyze, see what we have learned, determine if there are !
l 23 some common threads, to use Chip's term, that sort of pull i 24 together the information that we've received out of those 25 three meetings.
I I
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r; 368 1 All'the information, the things that are in the j .
2 transcript, are going to be put into a database and sorted 3 and categorized to see what we have here so that we can then 4 go to the Commission, both to tell them what all we've heard 5 and to'give them some recommendations, next steps and more 6 details in terms of the schedule activities.
7 Operating in parallel with that will have to C. continue to be all of the technical development work that 9 you've heard referenced to throughout the course of the 10 meeting, and that will be proceeding along on a parallel 11 track.
12 And having a little analogy yesterday -- and I 13 guess it was Mark's shoes -- and having done this once 14 before I don't even remember which set of workshops it was,
<m
(
) 15. .got to thinking in terms of, all right, maybe it would be 16 interesting at this point to give you an opportunity to say 17 if you were now in charge of this rule, if you were now 18 responsible to go back to your office and do something, a 19 rule, not a rr.2e, make a recommendation, what would that 20 recommendation look like, based on all the things that 21 you've heard, all of the interactions that you've had back 22 and forth, all the thingo that your fellow participants have 23 been saying over the last day and a half.
24 And I thought of a few questions. You might have
'25 some others. But to stimulate some thought. What's the ANN RILEY & ASSOCIATES, LTD.
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e4 Ih 369 1 need to take the action? You know, what particular drivers l () 2 do you see as important to less important in this process 3 that should weigh into the decision making process? What 4 kind of time frame? Are there issues? And the second and 5 the third are sort of linked together. Are there specific 6f additional pieces of information that you would feel like 7 you needed to have that you haven't heard here being 8 referenced or available or otherwise that you would find
'9 important in order to believe.that you had come up with a l 10 good recommendation? And then the sort of question of all 11 questions, the real bottom line, what kind of action would 12 you take? If you had the Commission sitting in front of 13' you, what would you suggest on the basis of these 14 discussions that they do? Would you recommend that they do
() 15 a rule, would you recommend they not do a rule? Would you 16 recommend additional guidance documents? The whole suite of 17 different things. What kind of level might you pick?
18 That's a lot of questions, but that's to amplify this.
19 And what I was in hopes was that a number of you 20 might be able to sort of pull together in your own mind 21 those thoughts, because I think that would be very 22 interesting. I know it would certainly be interesting to me 23 because, in' fact, when I walk out of here I will have t.o be 24 in my shoes. And while to some extent I can say, well, it 25 will actually be Bob's shoes and Trish's shoes and Frank's ANN RILEY & ASSOCIATES, LTD.
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- a
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. 1 shoes and Tony's shoes and everything, in the end it does 1.
p; V
2 boil down to we have to'go back and we have some things that 3 we're going to have to do. And so what I would like over 4 this last hour or so is to hear from you on the basis of all 5 these discussions as a way of summarizing. What would you 6 do?
7 MR. CAMERON: And let me just add one thing to --
8 to what. Don asked you to do is that like the NRC we're 9 -gathering information to decide what should be done. There 10 has not been a decision. You may not have a recommendation 11 on terms of what should be done, rule, no rule, whatever.
12 Like-the NRC, you may need further information. There may 13 be additions to the process to bring new information from a 14' varied sort of interests into the decision making time
[^)\
s, 15 frame. And Don did not mean to exclude that.
16 So, with that --
17 MR. COOL: But of course if you send in written 18 comments I guess I'd prefer that you not entitle them " Don's 19 shoes." Just as a matter of appearance.
20 MR. CAMERON: Let's put a human face on this 21 federal bureaucracy, though. I like Don's shoes. You know, 22 we could just spend the rest of the time making jokes about 23 you. That would be relaxing, at any rate.
24 Does anybody want to kick this off and address 25 all, part, whatever? Let's go to Heather Westra.
O
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a a l
371 l 1 MS. WESTRA: Well, one of the questions that's r^N
( j) 2 been on my mind is why are you doing this? What is the
]
- 3. need? You'know, under NEPA you have to -- if you're going 4 to take an action you have to describe the purpose and need 5 for that action. And in my mind I don't think that's been 6 ' clearly articulated. So, perhaps I could hear back from the 7 NRC as to what is the need for this action?
8 MR. CAMERON: Juld maybe it would be useful to hear 9- from others, too, what their opinion is on that, that first 10- .very important issue. Don.
11 MR. COOL: Okay. I will give you a little bit of 12 an answer, but, in fact, what I'm hoping is to hear from you 13 whether or not you see a need. I 14 The Commission believes that there is a need, that p.-
\sl 15. there is an arena where we are not acting in a systematic 16~ ' manner, where we need to take a hard evaluation in terms of 17 . applying the appropriate controls to assure that materials 18 that don't get out, don't get out. And a number of other 19 things that are going on nationally and internationally 20 which are playing along the same lines of -- for which we
]
21- believe we need to participate.
22 I've heard a lot of things today which perhaps l l l l 23 could be construed as need, but if that -- those are the 24 fundamental issues that we see being present. A part of my
~25 reason for tossing out the question was, in fact, to see if i
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372 1 you could reflect back what you see is the need or, as I
?l e) 2 .think1you've just suggested, is there the need, and N- 3- articulate that.
E 4 MR. CAMERON: Okay. Let's have some other views 5 on Heather's question. No? Anybody want to talk to -- I 6- mean, we_do have things on the record, obviously, that i 7 people talked about, scattered throughout on need. But does 8 someone want to put an emphasis on why they see a need for 9 ' action to be taken? Paul?
10 MR.' GENOA: Paul Genoa, NEI. I guess the basis --
11 the basic conclusion is that, you know, sound, effective, 12 efficient public policy requires clarity, consistency and 13- predictability, and these are qualities, frankly, that are 14 lacking in the current situation. And that has actually (A,) 15 recently spawned Congressional interest in why there isn't a 16 national standard to handle these things. So, from that and 17 the practicality, the practical reality that materials move
- 18. .in and out of here and they're judge on a different and 19 inconsistent basis, as well as the international j l
20 implications of an inconsistent basis, I believe requires ;
21 that action be taken.
22 MR. CAMERON: All right. Anybody else? Debra, do 23 you want to talk to the need? Okay. Let's go to you a.nd 24 then we'll go back to Robert Hull.
25 MS. MCBAUGH: I guess from a State perspective ANN RILEY & ASSOCIATES, LTD.
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i 373
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1 when we try to deal with things that have unintentionally (ts 2 gotten somewhere and we get an alarm, it would be helpful to 3 have guidance in the form of a standard that was there that l
4 would help us to evaluate, instead of doing a case-by-case.
5 So, I do see a need from that perspective. I'm a little )
6 worried by opening Pandora's box. I guess that is a concern 7 I have. Because it seems to work as we do it now. It's j 8 just not very comfortable. And I don't like being 9 inconsistent in using reg guide 1.86 or that sort of l 10 approach when everything else we're trying to do is l
11 dose-based and trying to sort of deal with the health risk. j 12 And so, trying to explain that to the public is a little 13 iffy, I think.
1 14 So, I guess I see -- basically, I do see a need 1
, ~ ,
k 15 for it. I do have some concerns on how it was done,
{} j 16 actually. And as I've been listening the last couple of 17 days, you were sort of asking what -- I haven't quite I 18 formulated what I'm going to go back and recommend, but I !
19 have some interesting questions that I didn't think I would 20 have before. And one of them is I'm looking more and more 21 to wanting to go with the one millirem rather than with a 22 higher number because it would be much easier to justify 23 that in anything that we have to go out. And we have t.o get 24 public comment anytime we adopt a rule, an NRC rule into our 25 regs. We have to go through a full process as well.
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b i N l 374 1- And I also -- I'm thinking really strongly about l Yg )L ~2 whether we do restricted use, whether we would -- I'm hoping I
3: that that wouldn't be a matter of compatibility, that we {
L 4 would be able to make our own decision on whether we wanted 5 ft.o'go with the restricted use, because I'm certainly going l 6 to take back a lot of questions to everyone to discuss on 7 that issue.
1 8 And I guess I'm also looking -- one other question l 9 that.came to my mind during this whole process is do -- I l 10 had always thought that it would be something we would 11 address all -- everything,.like I had brought up with the i
12 landfill, and just that it would address anything. But 13 there is a possibility it could be a limited scope and only
.14 address certain issues, which is kind of a restricted thing o
() 15 in that way. So, that's something I'm going to discuss when 16 we get back.
17 MR. CAMERON: Good. That was a good -- a good 18 summary of your thoughts on that, and it did raise an issue 19 that we haven't talked about is what's the proper breakdown 20 of authority between the NRC and the agreement states on 21 this issue in terms of compatibility? Should agreement 22 states be allowed to set more stringent levels, for example?
l 23- Do they need to adopt every part of the rule uniformly?, But L 24 we may come -- we may want to come back to that. I want to 25 go to Robert Holden,.now.
l l
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l l 375 1 MR. HOLDEN: Just beginning on that point in terms
( )~ 2 of requirements,. regulatory authority and standards. You
'w' 3: know, a few years ago in San Diego, outside of San Diego, a 4 reservation had sought to serve as a host for solid waste 5 repository for the City of San Diego, and there was a huge 6 outcry from -- from citizens in the state legislature in 7 California regarding their effort. It was just primarily 8 economic development motives. But, you know, the outcry 9 ranged from, you know, what's wrong with this picture, the !
10 Indians are supposed to be environmentalists, and -- and
.11 there's a -- there's nothing to prevent them from accepting 12 hazard waste, radioactive waste, or for that matter, it's 13 going to be highly unregulated.
14 A friend of mine that was an attorney was working (7,/ 15 with a tribe and he spent many hours talking to legislatures 16 and citizens of communities, and by and large what came out 17 of this was that people learned that the standards that the 18 tribes were going to set were much higher than California,
'19 which were certainly not. lax. But it was just one of those 20 nuances where, you know, tribes had to respond to. But, I 21 mean, I don't know what the analogy is, but I guess, you 22 know, familiar with certain variances and the things that 23 tribes have to go through to get special regulations or 24 special efforts made to allow them to do what they 25 ordinarily have a right to do because, you know, beginning I\ ANN RILEY & ASSOCIATES, LTD. '
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376 1 remarks I made before, certain communities regarding
-~g i I
y 2 emergency. preparedness and regulatory authority throughout 3 the United States and just state the fact they used to be --
4 this is former police and fire jurisdiction for Indian 5 nations of Indian nations. 1 i
6 But having said that, I guess I'm not -- what I'm 7 not sure of is, you know, in setting a standard, the j 8 standard is.what it is now on a case-by-case basis. I mean,
{
9 Hi s that not good enough? 'I mean, from what I'm hearing, the 10 ' scope and magnitude of -- of these products, of this 11 material, it's -- is it to the volume that much time and l
12 business should be spent on pursuing this by the folks that i 13 I work with. I mean, we have to, because of the importance 14 and because of the potential, the potential harm. I say 15 . potential harm because, you know, for one thing, they don't 16 know. But if something is allowed into the environment, as
.17- I spoke of the incidence yesterday, that we've come across 18 this in so many. instances. And that was just one instance.
19 So many industries, so many businesses have dropped, so left 20 or defrauded tribal governments and tribal people out of not 21 only dollars but of dangerous products left in their midst.
22 You know, I won't go into the litany of things -- of 23 instances this has happened. But it's just something t. hat 24 we'need to think about.
25 But also, when I think about terms of time and
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377 )
1 response that the Nuclear Regulatory Commission will need to
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I' 2 put.forth to give notice, communication to tribal ,
1 i
governments, because as was noted, you know, there is an 1
3-4 Executive Order that -- from Ronald Reagan, that calls for 5 this cost benefit analysis to be done.
6 There's also an Executive Order in place that 7 calls for consultation with tribal governments. And in that !
l 8 Executive Order it enumerates many things that should be 9 done and have to be done to apprise Indian country as to j 10 what these actions mean, who's involved in them, and what 11 the, you know, what the potential liabilities are, as well 12 as benefits.
l 13 So, I'm not sure. I mean, this is probably more I 14 in the way of a comment than -- than any answers. I'm not tO V .15 sure.
16 MR. CAMERON: Thank you, Robert. Let's hear from 17 terry, since we're right here, and then we're going to go i
18 over to Ed Bailey. l 19 MR. CIVIC: That's why I grabbed the microphone, 20 and so it was right here.
21 I could possibly address what action would you 22 take. I, like Debra, would like to go back and mull through 23 my notes and all this material and look at what was ,
1 i
24 . discussed here. I think we all should do that, and l
l 25 particularly the NRC people.
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378 1 I think one action that you must take is to
[; 2 eliminate the perception of a bias. And your bias is v
3 evident with 1640. It's one MR free release of material.
4 And there is -- hasn't been anything else looked at or 5 evaluated in -- in this context.
6 So, as a member of the AISI and the steel industry 7 and the metals industry, we oppose the free release of 8 steel, and I think you need to look at that strongly from 9 the perception standpoint, from the impact on our business 10 as well as what you want to do with the other materials.
11 And we laid out a lot of different options, and I 12 think you need to look at the various options and -- and 13 maybe before the next meeting come back with a different set 14 of framework of discussions, as opposed to trying to go back (3 15 down the same road again.
, (_,/ Because I would imagine that most 16 of the people in this room are going to be at the other ,
1 17 sessions. Maybe a few other people. So, why beat a dead 18 horse? That's all I have to say. 1 l
19 MR. CAMERON: Okay. Thank you. Thank you, Terry.
20 And I think that the caution about eliminating biases could 21 be more broadly applied than just to 1640, perhaps.
22 MR. BAILEY: Is this working? It is?
23 MR. CAMERON: Yeah. ,
24 MR. BAILEY: Okay. I'm sorry.
25 When we did introductions yesterday, one of the --
O
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I'didn't mention that I'm also the chairman elect of the
/'N
.i) 2 Organization of Agreement States. And why -- why -- whereas 3 we are not here officially representing them, I can tell you 4 that there are going to be some questions that are ra.4 sed by 5- the agreement states. And two of them I'm just tossing out 6 so that perhaps you can look into them.
7 One is whether or not if you had a policy adopted, 8 whether or not this would be a carte blanche to a licensee 9 to develop their own procedures and just go do it, or 10 whether it would require pre-approval of those procedures 11 prior to implementation of this. I have my own preference, 12 I think, that it would have to be a pre-approved process, 13 that there has been some review of how it was going to be 14 done.
(]_,7 15 The other one is going to what Debra said. What's 16 the compatibility level? I think that there will be states, 17 and I'think California may be one of them, that may have 18 difficulty politically adopting an identical rule. And then 19 that begs the question, if -- if California or some other 20 state cannot adopt the rule for political reasons, does that 21 set up a possibility of Diablo Canyon or Saul (phonetic) 22 shipping stuff to Oregon, which has adopted the rule, and 23 clearing it out to that second state? I mean, they create a 24 company. I mean, we've got a company here in California 25 'that decoms reactor equipment. There wouldn't be any reason
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380 l 1 why that company couldn't decom down to whatever level was
[T c) 2 required in their particular jurisdiction and release it.
I
)
3 And those -- I don't expect any kind of answers to 4 those today, but I think those are some of the issues that 5 will come up with he agreement states in looking at adopting 6 the rule, presuming that you all adopt one.
7 MR. CAMERON: Okay. Thanks, Ed, and that -- that 8' parhaps need or the issue for the need for national 9 uniformity also influences what type of compatibility level 10 -
was set by the Commission in the rule. Bil' 11 MR. KENNEDY: Bill Kennedy. Thank you. I think 12 what Paul said in terms of he credibility, the consistency, 13 I think that's kind of the motivation I look at. I look at 14 when reg guide 1.86 was developed it was for surface 15 contamination only, it was for decommissioning only. That 16 particular reg guide contained a lot of things beyond the 17 surface contamination numbers. It looked at options for 18 decommissioning. It looks at certain license termination.
19 Kind of conditions well beyond what has been applied for 20 primarily, and that is the surface contamination guidelines 21'- that are in there. j 22 It didn't contain volume contamination criteria, 23 nor did it contain things that would help ease the spec,ial 24' case situations, you know. I always tell this story. When
'25 I was in college I went to calculus class and they taught O- ANN RILEY & ASSOCIATES, LTD.
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E 381 1 you how to differentiate. And they taught you all the lh' V'
2 . general' rules. And when you took the test, it was on all 3 the exceptions. It wasn't on the general rules you learned, 4 it.was the special cases.
5 But in reality, everything isn't a special case, 6 and there needs to be a framework within which decisions are 7- made that have' credibility, have consistency, and can, 8I across the board, be applied to the majority of situations.
9 There will always be special cases, no matter what rule is 10 applied, but what you want is something that has credibility 11 for all of the other situations that can be handled in a 12 good. manner.
13 I think that -- that we're not just talking about 14 recycle of steel or the potential contamination of consumer
( ) 15 products, we're talking about every day operations at 16- licensed facilities, ultimately by implication we'll be 17- talking about DOE facilities as well, and those go far 18 beyond contaminated metals. And I think that to me there is 19' a crying need for consistency to.have a regulation in place.
20 There is also a crying need because you take the situation-21- of agreement states where there will be loopholes and ways 22 around by sending materials to other states. Potentially, 23 internationa'lly, the same thing could be happening. ,
24 If you think about the U.S. role in a global 25 economy where some countries can clear materials at given
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382 1 levels, and if you look at how people will attempt to make a
. ,m 2 profit by their activities, there may be incentives for lV) 3 people to do things away from this country, not just from 4 one state to the other, to achieve a positive economic 5 result for themselves. And so to leave it unregulated and 6 with an' inconsistent program that's handled on a special 7 case basis I think simply, you know, leaves the framework 8 open for a lot of misuse in ways that perhaps today we 9 haven't experienced but may be very real coming down the 10 road.
11 So, I just, I say I think there's a very real 12 need. The time frame was 40 years ago this should have 13 happened. It didn't, but it's not too late to fix it today.
14 MR. CAMERON: And when you say four years ago,
(/N) 15 you're talking about the EPA?
16 MR. KENNEDY: Forty years ago.
17 MR. CAMERON: Oh , 40. Forty years. I was trying 18 to get you involved in this, but you don't want to get 19 involved. All right. How about some other -- other 20 perspectives? Not that the perspectives that you've already 21 given in the last day and a half aren't noted, but.
22 MR. MASCHKA: Paul Maschka from General Atomics.
23 One of the problems that I have seen here is I really do not 24 understand what the standards are that you're going to 25 release to. Unless you can make these into a nice clear 1
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383 1 table that's easily measurable by my health physics
!Le%. I
() 2 technicians that I_can easily evaluate, I'm not going to
{
3- send anything out unless I can really say it meets that i 4 ,
3 value. If I have to do a calculation or an estimation of a 5 dose rate that's going to occur to some body down the road, 6 and that can be opened to question, I'm not going to approve 7 anything going to landfill, going to recycle. It's all 8 going to go to low-level waste.
9 So, one of the things that really needs to be done 10 is a. nice, clear values numbers that can be easily measured l 11 and can be shown to be true.
l 12 MR. CAMERON: Okay. Thanks, Paul. Jim. l 13' MR. TURNER: I would just say that -- if you want l
, I'N 14 a recommendation, what I would say to do when you got back Aq-).
15 would be I would suggest that you identify all the possible 16 outlets for these materials, whether it be paper, steel,
-17 glass. I guess we're talking metals, concrete and dirt.
18- And then perhaps meet with groups of those outlets and see 19 what it would take for them to -- what it would take -- what i 20 you would have to do to get them to take it.
21 MR. CAMERON: Okay. Thank you. Ray.
22 MR. TURNER: Just in response to Debra's comment-a- ~~
~
23 while'ago about the certificate, that it would help to have l
24 a certificate in terms of responding to a detection, 25 assuming a detector'went off somewhere. And I think that's ANN RILEY & ASSOCIATES, LTD.
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I what you're saying would help you identify where that l (3) 2 material came from and what level it had been surveyed or
- 3. cleaned to, 4 MR. CAMERON: Let's get some clarification on 5 that. Debra, do you know what Ray is talking about?
6' MS. MCBAUGH: No.
_7 .MR. CAMERON: Okay. No.
8 MS. MCBAUGH: Were you referring to my statement I 9 just made right after lunch? Okay. Yeah, I think - T 10 don't recall saying anything about certification. Al '. :
- 11. tried to say was that when a licensee uses a procedure to ,
1
-12 clean -- to' release something, and if something gets l
13 released it's not a health risk that gets released, it's an 14 annoyance. So, it will be something that could set off an f).
q, 15 alarm at your facility, but if we went -- when we go to look 16 at it, it's not a health concern.
17 MR. CAMERON: Do you want to say anything about 18 certificates?
19 MS. MCBAUGH: Yeah. Okay.
20 MR. CAMERON: Okay. We'll come back to you for 21 some compatibility discussions. Okay. Here you are, Ray.
22 MR. TURNER: I understand. I think I understand i 23 what.you're saying. I think -- still think we're saying the i 24 same thing here. We have to continue to bear in mind that 25 when this material goes for recycling purposes. It may go 4 ANN RILEY & ASSOCIATES, LTD.
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385 1 to a scrap dealer or it may go to a steel mill. And if it
[Q T 2- goes to a steel mill, that very well might be true, it might 3 be more of an annoyance thing. But if it goes to a scrap 4 facility somewhere and it's commingled with other processed 5 scrap, I'm -- I've heard two stories here now. One says the :
i 6 levels are going to be so low, you won't be able to detect 4 7 them.
8 But I've heard another one that says there may be I 9 some hot spots, and if those hot spots are right against the 10 side of a truck or a rail car, they'll set off the 11 detectors. And if that hot spot is cesium or cobalt and it's 12 been commingled with other material from a scrap facility, 13 then that's a problem.
14 You can't loose sight of the fact that once it b'T (j 15' goes through the detector or once it's out your gate it's
- 16. out of sight and out of mind.
=17 MR. CAMERON: Let me ask Paul Genoa a question 1
18 related to that. Paul and several others have advanced the 19 proposition that set a clear dose level for this material 20 and below that it's not going to be considered radioactive 21 material. It's still going to set off Ray's alarms.
22 MR. GENOA: So does concrete and dirt.
23 MR. TURNER: Concrete and dirt --
it's not cesium 24 and cobalt. l l
25 MR. GENOA: What's the difference? l l
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L 386 1 MR. CAMERON: Do you -- does that give you -- what 7-~s
(
mJ
) 2 would you do -- what would you do in a situation like that?
3 It sets up'your alarms but it's below the standard and 4 'someone says, "Well, .it's.not' radioactive material. i It's 5 below the standard." l 6- MR. TURNER: Okay. I don't disagree with what j 7 .you're saying, but what I'm saying is you cannot assume that 8 it's not a gauge that's been commingled with thi-t shipment.
9 What I'm saying is you can't assume that it's a nuisance 10 alarm coming from a hot spot on this material that may not 11- be a radiological concern. It's just a nuisance alarm, But 12 if it's been commingled with other scrap materials, we're 13 not talking about radium or thorium or dirt, something 14' that's going to be in the bottom of the car, you're still b
(_f .15 going to have to go through that rail car and sort out. And 16 as Ed Bailey pointed out earlier, you're going to have to 17 look at every piece of scrap that comes out of that car to 18 determine that it, in fact, is not a nuisance alarm and 19 ensure that it's going to be safe to melt.
20 MR GENOA: And I acknowledge that and I'm 21 sympathetic to the challenge you have of trying to detect 22 sources that could come in, or perhaps contaminated metal 23 from abroad, that would set off your detector, which is, 24 really based on trying to protect your furnace from a 25 source. So, I'm sympathetic.
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I-387 1 1 My problem is I don't think -- you've got that
).
2 problem today, and if this clearance rule goes through 3 properly, it shouldn't change the problem you already have 4 today. And I'm sympathetic to that, and I don't think --
1 5 and I don't-know how to solve the problem.
{
6 But -- but if I could follow up on essentially 7 what your proposition was.
8 MR. CAMERON: Okay.
l 9 MR. CENOA: The proposal. '
1 10 MR. CAMERON: And then we'll go to Giorgio. Go 11 ahead, Paul. Follow up on it.
12 MR. GENOA: I think what we've heard for the last 13 couple -- the last couple days. It feels like a couple of l
14 days. What we've heard is that we have a regulatory I ) 15 structure in place that tends to identify what is an
\~/
16 acceptable level of safety for the public from radioactive 17 materials, man made, and that's around 100 millirem, and 18 that you're_considering some kind of standard, some kind of 19 controls that people should impose on the clearance of 20 material coming and going from facilities, and that is a 21 problem that needs to be addressed. And you've articulated 22 that that level ought to be well below any health risk.
23 Some small draction of that standard. And we've heard.of 24 all the difficulties with natural background and all of 25 that. And potential impacts on certain communities and
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388 1 nations and people and all that, and I appreciate all that.
A
, ' (\_/) 2 But what we've heard is that, one, that we're 3 probably not talking about a level that's a health risk, 4 we're talking about sort of what's a public acceptable risk 5 and what's a politically acceptable path forward. And I 6 think what we're really dealing with here, we've heard that 7 the steel industry and the recycle -- the public does not 8 want radioactive material put into their consumer products, 9 - and the nuclear industry doesn't want to release radioactive 10 materials into general commerce that ends up in the public 11 domain. And I guess -- so the question is but we still need 12 to clear materials from our facilities, and we understand 13 the challenge that you're faced with is how do you set a 14 criteria that we can all agree is safe and essentially N
I 15 clean, with those little quotes around it, so that we know 16 that the public is protected, so that we can guarantee that 17 the material that is not clean is not going to enter the 18 public domain and be recycled, and how do you implement 19 that?
20 And I propose that you implement it on a 21 consistent standard. I think we've heard about the rea on 22 for a health-based standard, a dose-based standard. I 23_ believe that you should promulgate such a rule. I beli, eve 24 that you'll have to go ahead and put together regulatory j 25 guidance to help implement the rule, because this is a ,
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1 complex issue. And I agree that.we need numerical values
.k [ 2. that are-crystal clear that you can compare. I don't think !
! 3 they should be in the rule because that takes a lot to 4' change and we may want to change those values over time, so 5' it ought to be in guidance. And I think you ought to really 6 give due consideration to an ANSI standard, that I haven't 7 ' read yet, but I believe, knowing the scrutiny those 8 standards go through,'and the length of time that they've j 1
9 been developed, that they probably have a pretty good 10 technical basis, so I would encourage you to look at that as 11 perhaps some sort of an_ implementation.
12 But the number you pick is a policy decision, what i
13 is acceptable to the public. My belief if it ought to be as 14 low as reasonably achievable. The level ought to be as low j 15 as is practical for us to implement. But please recognize 16 there are practical limitations to what we can implement.
17 So, I guess that's what I'm trying to say here.
18 MR. CAMERON: Okay. And we may go back to you for 19 those practical limitations on what you can do. Giorgio?
20 MR. GNUGNOLI: This is -- this is just a question 21 on clarification. On the third bullet there we have the 22 identifiable possible outlets. Jim Turner, I think, brought 23 that up. I want to make sure what we talked about was.
'24 outlets in terms of release points, intermediate points 1
25 where the material may change ownership, or are you talking I (~h
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390 1- about-first user or end user or all of those? Just a i
, .m I I 2 clarification point.
(/
i
.3 MR. TURNER: I was talking the recyclers.
4 MR. GNUGNOLI: Okay.
5 MR. TURNER: Or the next user.
6 MR. CAMERON: Heather. Thanks for the 7 clarification, Jim. Did you want to say something else?
8 Okay. We'll be back to you.
9 MS. WESTRA: Okay. I don't mean to be beating a 10 dead herse, but just going back to one with regard to 11 purpose and need, I think Paul just said it is that the need 12 is to clear materials from facilities. And I think that if 13 you're going to be working with the pub'.ic you need to state 14 that, and that the purpose is to provi'Je clarity, 15 consistency, et cetera. But the nee 6, I think, has, as it's 16 been stated, is to clear materia 1F from facilities. And you 17 need to describe what you're talking about in terms of the 18 magnitude of the problem. How many tons of materials are 19 out there that could be potentially cleared and released. I 20 don't think that that's been part of the discussion yet as )
21 far as quantifying what we're talking about in terms of tons 22 or whatever it might be.
23 MR. CAMERON: Okay. Thank you, Heather. Mark, do 24 you want to -- do you have a comment on what Heather just 25 said? All right.
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391 1 MR. LEWIS: It seems like the debate is kind of 2 being framed in a way that sounds like the industry -- and
[v}
3 I'll only speak for power plants -- seem to be trying to 4 figure out an outlet to get rid of some of their excess 5 activity or some of their contaminated materials, and pass 6 it off somewhere else. And I don't see that as the issue.
'7 What I see is we're trying to find a level that 8 defines clean, and we all kind define that for ourselves.
9 And if something is above clean then we'll send it to Phil 10 or somebody like Phil. Phil appreciates that.
11 MR. GIANUTSOS: Or Envirocare.
12 MR. LEWIS: Or Envirocare.
13 MR. GIANUTSOS: Is this a contract?
14 MR. LEWIS: Yes, it is, as a matter of fact.
l f'%
i
) 15 But if it's below that level then we 'll release l
16 it and we won't worry about being second guessed. And the i 17 thing that keeps kind of popping into my mind is that 18 -there's work that's been done in the NCRP. There's work 19 that's been done in the NUREG that sort of de fines what's 20 out there.in the environment, from bomb testing or from life i
21 as we'know it as far as concentrations of activity. 1 22 And years ago in the Health Physics Newsletter 23 there was the concept of defining a new unit called 24 , background. And it's almost useful to go back to that
'i 25 concept and say if we're in the background range, if what we ANN RILEY & ASSOCIATES, LTD.
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392 11 have is indistinguishable from an activity standpoint from
-( sJ s
12_ the natural radiological environment, then obviously we're 3 not changing anything.
4 ,
So, that's kind of the way we're looking at it is 5 we're not:looking_for.a way to save money, as Dan Hursch li said, by not having to deal'with the activity by giving it 7 to consumers. All we're trying-to do is say above what 8 level should we send it to Phil, and below what level should 9 we go ahead and -- and be reasonably assured that it's 10 clean.
11 MR. CAMERON: That's an interesting -- I think 12' that's a very important issue, tieing it back into the 13 letter that we received from various citizen groups. And I 14 think that Heather, the intent of what you were saying was
() 15 _the more the proper perspective and context is placed around 16' this issue, the more we get away from attributing motives to 17 the NRC for acting in.this area.
18 Would it make people more comfortable if the 1
- L9 utilities' donated all of.the money into some conservation 20 . fund? I mean, if.we want to think outside the box. And
, 21 - I'll just-stop right there because it's probably too far 22 outside the box, but there you are. Ray. Can we -- why 23 - don't you -- we seem to be having a little trouble with 24 that. Why don't you just take this guy.
'25 MR. TURNER: I'll just offer up one scenario that l
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m 393 1 can fit, I believe can fit, and I've said it a number of 2 times, and it would fit not only in the steel recycling 3 industry but in the soles, the dirt, the concrete.
4 Whichever industry we're talking.about releasing this 5 material to be a restricted or a free release, and that's 6 the way.with all the what ifs except one.
7 What if I've got a steel mill and I am agreeable 8 to take this material and do a control melt and nothing but 9 this material, without commingling it with any other 10 material, and if the NRC/ DOE or whoever the federal agency 11 may be is so confident that it is not going to be a problem 12 in my industry, in my plant, then why not belly up to the 13 bar and say, "You do a control melt and melt this 2,000 tons 14 a month, or whatever it's going to be, and if it does cause
() 15 a problem, I'll decontaminate your plant and hold you 16 harmless for all the loss production that it may have caused 17 you"? That will solve your problem.
18 I'm talking about on a real time basis. If you're 19 confident that it's going to work and you really trust your 20 numbers,.then guarantee me that if it contaminates my steel 21 mill you'll pay for the decontamination-and lost business I 22 and lost production. And I'll guarantee you the steel mills i 23 will melt it down if you'll do that. ,
24 MR. CAMERON: I think we're still outside the box.
25 That's good. That's good. Dave.
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n 394 j i
1 MR. BELK: Oh, yeah. Dave Belk, University of
?'N
}y
) 2 California. Once'again, I'd.like to bring it back to, hey, 3 we're not a steel mill, okay. Usually, when I go to public 4 meetings or talk to people I tell people just about anything 5 in industry, the University of California does at some scale 6 somewhere within the state of California. But now I'm not 7 sure we have a steel mill anywhere. We may have a small one 8 on a bench top.
9 But in any case, to get back to that issue but 10 also to the issues mentioned before, from the nonrecycling I
11 point of view, we are concerned with how clean is clean or, i 12 in this case, what is clean. That's the issue that I would 13 be looking at. What is clean? And that's, I think, a 1
14 fairly simple thing, I would assume, for you guys to .
. ("~'\
( ,/ 15 determine. What is clean? Ignoring a -- nothing personal 16 against you -- ignoring issues when it comes to 17 manufacturing. What is clean? If you -- if you can tell us 18 what clean is, then all these other issues, I would think, 19 would fall away.
20 MR. CAMERON: Okay. Thanks, Dave. Paul, go 21 ahead, then we'll go to Brian.
.22 MR. GENOA: Yeah. Paul Genoa. Again, I think we 23 need to get the issue back to clearance, which is why we're 24 here, and I think that if we do with clearance, just as this 25 gentleman has pointed out, you ought to be willing to belly O
\~ /
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395 1 up to the bar and guarantee to him that it won't effect his (q ). 2 facility, because it won't, you know. And if you can't 3 guarantee that, you can't go forward. You need to be able 4 to accept levels that are acceptable and clean from a public 5 health and safety point of view, and that they aren't going 6 to cause residual problems, like out in the environment.
7 And think:you can't, and I think the numbers prove it out.
8 MR. . CAMERON: Okay. Let's go to Brian.
9 MR. HEARTY: Brian Hearty. Basically, just to 10 reiterate again, we need a level, we need some type of 11' promulgatedi regulation that we can use when we're releasing 12 solid material from sites. And realize that not just 13 licensed facilities, but that when federal regulations are 14 promulgated, they.can also be used under CRCLA at sites that 15 might not contain licensed material-but is relevant and 16 appropriate for setting clean up levels or determining how 1 17- ' clean is clean. l 18 The other. point I want to make is the guidance 19 .that has to come. with this, if you do a dose-base rule. Now 20 it just has to-set maybe the concentration levels. But the 21 big; thing is how'to implement, how to measure it, what i
22 statistical basis do you use to prove it. I'm talking i 23 something similar to like the marsium for -- that's for i
24 surfaces for doing some type of guidance for clearance of 25 - the materials. j l
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p l 396 1 MR. CAMERON: Okay. Thanks, Brian. Let's --
2 let's go over here to Jaz.
l()
3 MR. DEVGUN: Yeah. Jaz Devgun. I want to go back 1< ,
4- to the question that do we have a consensus that for any l l
5 clearance, for any numbers to be derived and used in forms 1 i
6 or tables, do we start with a dose criteria of one millirem? l l
7 Have we guidance consistency on that, have a consensus on
]
8 that, basically? Because form what I have seen, I have 1
9 conducted how clean is a clean workshop, our waste manual ;
1 10 for six, seven years. Every year once a year we get --
11 usually get an industry government representative, sometimes 12 overseas, l
13 There isn't a consensus per se, but we all know 14 that one millirem is a very -- it's negligible, I mean, as
( 15 compared to any other risks, any other like we have had.
- 16. How do they know. When like a flight across New York to 17 L.A. would have given you a full millirem.
18 So, we are talking, really, extremely low dose.
19 We all agree with that. But is there a consensus, is there 20 something there which you can refer to and st. art from there?
21 We need a mile marker, saying, well, this is going to be our 22 tritadium, and then we'll go ahead and then develop the
.23 methodology, whether it's 1640 or anything else and dri,ve 24 those numbers which we can use in the field.
25 MR. CAMERON: Let me explore that in the context 1
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p r
i 397 l 1-of a. question to Paul Genoa that Paul, you were talking
() 2 about levels before and you said there at e practical 3 limitations on what we can do. Can you or would you put 4 that'in the context of -- would you explain that a little 5 bit more? My -- it raised in my mind, well, what levels 6 cause what *.ypes of practical limitations? And I don't want 7 to put you on the spot if you -- if you, you know.
8 MR. GENOA: 'Well, I mean, I think we spoke today.
9 'I think we're -- we adhere at the practical limitations of 10 the steel mill, you know, that they have a detection system l
-11 set up to capture radioactive material that could enter the 1 L '
12 facility and injure it by contaminating it, but there are 13 limitations on it, that routine, uncontaminated concrete, i
14 contaminated only with natural radioactive material sets off 15 their detector if it's in a certain configuration. That 16 dirt in the bottom of their container sets it off in a 17 certain' configuration. I 18 In fact, I understand that even if the steel is l 19 stacked up the wrong way that that would set it off, you 20- know, because'of the difference in densities and background 21 and all that.
l 22 So, there are limitations on how hard you can 23' practically look to detern3ne that there is no radioactive
~
24 material. And it's a ridiculous game because everything has 25 radioactive material in it at some level. So, you have to L
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398 ,
1 just' accept that the world is radioactive. I mean, that's A'
(s.j 2 how it war; born. That's how it's always going to be.
3 So, then you get into, well, let's se up a safety, 4 a health basis. And you've already done that. You've 5 'already said 100 millirems is safe. But the public is not 6 going to accept 100 millirem from this activity, so you 7 apportion some small amount of 100 millirem. Well, pick a 8 number, I don't care, you know, but there comes that 9 implementation. How do you measure that? And I mean at a 10 nuclear power plant. I mean, I worked at the Crystal River 11 Plant in Florida. We set our detectors so that people come 12 and people go, and their equipment comes and goes through 13 the facility.
14 In the morning at that power plant we had four
() 15 fossil plants nearby. If we had a damp morning or a cold 16 weather with inversion, we have the wind blowing the wrong 17 way, the radioactive material being emitted by the coal 18 plants comes over and sends off our detectors. That's a 19 fact of like. It's kind of like Ray trying to, you know, 20 measure the stuff coming into his facility. So, here we're 21 trying to operate a nuclear plant and those ccal plants are 22 giving us trouble next door. Well, it's natural material, 23 you know,.you just have to accept it. .
24 So, there are limitations to what you can do with 25 detection, particularly if you drive it down to levels that
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L 399 1 .are so far below a health risk and so far down into some ]
( 2 portion of the natural fluctuation and background that it
~3 becomes indistinguishable from background, and an 4- implementation nightmare.
5 MR.' CAMERON: Okay. Thank you. Let's go to Don 6 and then over to Bob Nelson. Don?
7' MR.. COOL: I just wanted to reflect back a little 8 bit on - on what'was'said. I guess from where I'm sitting 9 at the moment, I don't see a single view yet. I've heard 10 this view. I've heard some other people support that. I've heard what I think is a very different approach, although it 1
11 i
12 might: end up being the same number. I don't know, at the l 13 moment. And that's part of what we're trying to do here, in ,
i 14 fact, is to see what are the ways to go about it.
,m
( ,) 15 A perfect, wonderful outcome of all of this would 16 be that Bob's modeling and Ray's detectors would come to the ,
17 same place. Now,'I probably should be taken off for a four 18 cause drug test for even thinking that, but that's part of 19 the exploration process that we're in.
20 MR. CAMERON: He thinks that this hasn't been ,
21- talked about by the staff before, unrelated to your 22' statement. But go ahead, Bob.
23 MR. NELSON: I had the same point that Don ma,de, ,
24- that we haven't reached a consensus on any standard at this '
25- point. That's why we're having these workshops. Those need i
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F 400 1 to continue. And we won't be there for a while.
./ 3 l ( ,) 2 MR. CAMERON: Okay. Bill.
3 MR. KENNEDY: Yes. Bill Kennedy. In developing 4 the ANSI standard we wrestled with this very issue about how 5 -do you set a dose limit and then do a back check to see if 6 you've just now driven technology to wear it likely might 7 not have gone'normally because you set limits that were not 8 detectable.
9 As we all know, detectability is a function of how 10 hard you look, how long you count, how much you invest in 11 training and instrumentation. We looked at generally 12 available instrumentation and we found that at one millirem 13 a year the doses would be detectable with field 14 instrumentation for the majority of radionuclides. For the 15 special case radionuclides often times it's not the only 16 radionuclide you're looking at, it's one of a mixture. So, 17 you can use isotopic ratios to -- to detect what or to 18 estimate what's there for the things that may be 19 non-detectable. But certainly a good survey program would 20 have to establish those isotopic ratios and have a quality 21 assurance kind of level of protection there. Much below {
l 22 - about a millirem a year you don't -- you run into real j l
23 detectability problems for most materials. j 1
24 If you think about one millirem a year and you 25 think about a 2,000 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> work year as the basis of the I
l 1
l -s
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l 401 i
n i calculation, if my. mouth is right we're talking about a half
() 2 a micro R-and hour differential in dose rates. For an j 3- external pathway for a photon only dose. And I believe, if 4 I remember the detectability of the smelters, you were 5 talking a change of--- I'm not sure if you said two or three 6 micro R an hour difference, given a background of 10.
7 Right. And so, I believe this further supports 8 Paul's contention that at the kind of levels that logically 9 come out.of this discussion, using today's technology, you 10 -likely wouldn't ever see an alarm unless a mistake was made 11 and somebody through in more material than they should have, 12 and in that case you should be seeing an alarm.
13 So, I offer those things for consideration.
14 MR. CAMERON: Okay. Thanks, Bill. Rich, you A
(_,[ 15 haven't said much, so.
16 MR. BURKUN: Yes. I don't want to endorse the 17 ANSI standard at this point because I haven't read it yet, 18 but I would say that it seems to have a number of features 19 that seem to me -- that are very good.
20 First, it seems to be very protective of the 21 public.
22 Second, at least for the isotopes that I'm 23 interested in, the levels seem both measurable and generally 24 achievable. It's important that we be able to achieve -- to 25 achieve those levels, as opposed to just being ANN'RILEY & ASSOCIATES, LTD.
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402 1 distinguishable from background.
O (J 2 And third, it' allows for a special case exceptions -
t 3 if the scenarios that were used in developing the guide, for 4 instance, don't apply to -- to your particular situation. \
-5' So, I think the NRC -- I would urge again -- it 6 has been said before that the NRC take a good look and 7 consider-very hard the ANSI standard.
I 8 MR. CAMERON: Okay. Thank you, Rich, for that j
9 opinion. I did want to make sure that we gave our sister 10 federal agencies an opportunity to -- to chime in on this.
11 And we heard from the Corps. And now I think Andy is going i 12 to give us some opinions. And I would like to check in with 13 John Karnak from the EPA, because of their very important 14 role in all this, before we end today. Andy?
('M
) 15 MR. WALLO: Well, actually, I was tieing more to 16 Bill's comments and the comments on the one millirem 17' standard. I just wanted to note that in general I think the 18 levels that were in the proposed ANSI standard, at least, 19 were certainly detectable by one means or another. But the 20 one-millirem statement, whether one way millirem is 21 detectable depends a lot on how you calculate one millirem 22 and what the level comes out of it.
23 So, if you deal with concentration levels, ye.s, 24 there are levels that are detectable and at the one millirem 25 level. Depending on how you calculate it they may not set f%_
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403 1 off.
\
2 l- Y[ On the other hand, these things deal with volumes.
3- And a very small volume that would never give one millirem l
4 could be sufficient' concentration to set off your detectors.
5 This.is -- it's not a simple cut. Nobody can say one 6 millirem is fine to measure, you won't detect it at your 7 plants. It depends on a whole configuration of assumptions 8 and techniques. And I think that's something this 9 measurement issue has to be looked into in more detail to 10 take a look at this. It's not a health and safety issue 11 it's, as Debra said, it's an annoyance issue that we need to 12 resolve and look at from a technical standpoint.
13 I think that was the primary comment I wanted to 14' make there. I' don't really, at this point, have anything to O)
(_ 15 add on 311 the other questions. We'll probably provide 16 things in writing or talk at some of the other meetings.
17 MR. CAMERON: -Okay. Thanks, Andy. And the one 18 thing that you did bring-up is that I think you were saying 19 is that there is a need for. additional information in terms 20 of how we solve this, how the detectability issue is solved 21 before any sort of a level could be set; is that -- that's 22 . correct?' All right. Andy said.
23 Let me ask John if he has anything to add to.this 24 'from the -- the EPA perspective. Now that you've sort of i i
25 broken your silence at the beginning that you promised your l
,,m -
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1 1
404 1 boss. So,Lyou might as well go all the way.
[ '2 MR. KARNAK: Well, I expect I can go on record as 3 saying.I'm glad this is NRC's record and not EPA's.
4 Someone. mentioned earlier about one being a 5 predisposed number, and Id I'd just like to mention that in 6 'the NRC,' or excuse me,.in-the EPA analysis -- and I must 7 defend NRC, that-they were. apart and helped us with this -- l I
'8 . we looked at one tenth of a millirem and 15 millirem, and we 1 i
-5L choose those numbers simply because we needed some number to 10 be able to do an analysis. It wasn't -- we didn't 11 -presuppose that any one of those ought to be the level to 12 pick, but rather, one millirem, kind of in line with what 13' has been talked about at the other levels, a tenth just 14 -drops an order of magnitude so you can, you know, just kind
() 15 of take a look at what's happening. And 15 was what we were 16' 'looking at as a clean up standard for sights. So, that's 17 kind of the reason why we came with those three.
18 And we did not show a zero or no release in there 19 because we figured multiplying by zero really just didn't 20 get!us very much. So,'we didn't bother -- we didn't go to !
21 an. analysis at that level. And I just want to say that the i 22 HNRC did look:in on some of these things with us. So, I hate !
- 23. to defend NRC but nonetheless, I'd like to suggest that,they s
24 did have a look at this, too, 25 but. CAMERON: Okay. Thanks, John. I take it from
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405 '
1 what_you'said at the beginning that EPA has no intention of
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.() .2 3
-doing'a generally applicable standard on this issue at this poir.t ? '
4 MR. KARNAK: Since we're on - 'since we're on the i 5 ' record, I don't want to say on the record that I hate to
.6 agree with NRC. We , in fact, do agree on many occasions and 7 'we work together quite'well.
- 8- We, right now, are now looking at a generally 9 applicable standard, as I mentioned earlier at the outset.
10 We thought about it and felt, you know, based on the !
11 information that we collected at the time that we wanted to i 12 work on orphan sources and try to help the states get those !
13 out of harm's way. And we felt like that we ought to look 14 at-the-international area because a number of issues have
-[>~ -)
15 been brought to our attention, and the possibility of that- 1 1
16 . material coming in at much higher levels, and we felt that
- 17 was a place to concentrate our efforts.
18 MR. CAMERON: Okay. Thank you very much, John.
19 We have -- do we have other comments? Frank, do you want to 20 put a question to the -- to the group? All right.
21 MR. CARDILE: This is Frank Cardile. Before, I 22- guess, 3:00 o' clock, is that -- before we leave, I don't
~
23 know if we've really gotten down to number three, this,is 24 what additional information is needed, but we're getting
.25 late in the day, and I guess this is in the form of a ANN RILEY & ASSOCIATES, LTD.
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406 1,
, equest,to the pedple'in theLaudience who will be providing f-s .
2 us comments.
(} We talked a little bit, to get back into a 3 '
'little. bit different subject, back to the restricted use, we 4 had put it;up on'ourflist of alternatives as a viable 5- alternativ'e rate.-- potentia) viable alternative.
It 6
somewhat came out of the license termination. rule where that 17 ,'was'o) a of the alternatives.we use in there as a method for 8 terminating a license.
9, q<heardlconversation yeaterday which seemed to 10 support a license, a restricted use. I thought I heard some 11' conversation this morning where it was -- it would seem to 12 be some of the prob'l' ems with. restricted use were raised.
13 So,.I' guess the question I'd like to ask everyone, 14 and'I don't really want' us to get into it today, you don' t s . 15 have to start discusaing it.further, but what would be 16 useful to the staff would be in your comments to us to 17 provide your thoughts and viewpoints on restricted use.
18 ] Whether you think'it would work.
19 I wrote down a couple of quick notes here that, as
'.20; you probably all well know, in'the license termination rule 21 the!NRC license, of course, would be terminated dhile the 22 restrictions stayed in place. But there would be deeds and 23 zoning ordinances by which the restrictions would be, you i,
241 ( know, kept in place. and they'd be held at the local, sat, 2 15 government office.
O)
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l 407 1 And of course it would be relatively easy to go l ( ) 2; buy'a site where the land was and confirm that the land was 3 indeed being used for its restricted purpose, mainly 4 industrial use versus a farm.
5 And of course we identti. d a few things this 6- morning that are different her4. And thought I heard a 7 little bit of these may be major problems. For example, 8 you'd have to have a new licensing scheme for, perhaps, 9 scrap dealers. Well, that's differene, from the license 10 termination rule.
11 And of course it would obviously not be 12 particularly easy -- I think somebody pointed out this
- 13. today -- to make sure that the material is indeed being used 14 for its restricted use.
.D~
(s-) 15 So, I guess to cut it short, but what I'm really 16 asking for is this is something that's a little harder to 17 calculate for NRC staff then, for example, Bob to keep 18 working on NUREG 1640 and different dose modelings.
19 { So, we're looking for your comments to aid us on 20 this as we go forward on the restricted use and whether it's !
21 viable for this type of situation. But we really don't have 22 to follow that further right now. j I
23 MR. CAMERON: Okay. That would be a long thread 24 to follow, I think. But I just -- Frank reminded me of 25 something that should be said here. The NRC would welcome s- 1 I I ANN RILEY & ASSOCIATES, LTD.
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408 1 written comments, but don't -- don't get the impression that
[ } 2' the comments that you provided over this -- these two days, Q/
3_ are not going to be considered as if they were a written l 4 comment and grist for the NRC's mill. And we are getting --
5- we are getting close to 3:00, so we're going to start to 6 wrap up here. Andy. I 7 MR. WALLO: I just wanted to clarify your 8 clarification of my comment after I thought about it. I.did j 9 want to agree that there is no general consensus on the one 10 millirem necessarily everywhere, but it is -- but the number 11 is someplace'down low like that.
12 But the comment on my comments on the measurement 13 system and needing more inforination, it's not so much that 14 you need the information about the steel mills and the 15 _ landfill measurement system to decida on what's a safe i 16 level, you probably do need it to decide on what are 17 appropriate standards on a concentration basis.
18 But I think you can separate deciding on what's 19 the appropriate safe level, the partitioning of your 100 20 millirem separate from deciding what you need to measure to 21 make sure you're not causing these annoyances out in the 22 -other communities, So, they're related but not necessarily 23 tied, as I think you summarized.
i 24 MR. CAMERON: Okay. Thanks, Andy. I can see that 25 there's a new word creeping into the lexicon here:
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E 409 1 annoyances. So, thanks for that, Debra, i i
2 I think I want to give Don the last word before we 3 close. I don't see -- I do see.
4 MR. KARNAK:- Just that you list the website with 5 the material associated with this project.
6 MR. CAMERON: Okay. Can we -- do we have a 7 special website address at this point? Trish.
8 MR. HOLAHAN: Currently the issues paper is listed j 9 on the_ rule making form website, and I'm sorry, I don't have 10 it to rattle off the top of my head. What I mentioned !
l 11 yesterday is that we're going to have a web page !
l 12 specifically for this issue, and that hasn't been 13 established but we'll hopefully get it in very short order 14 and then we'll have all documents associated with this q !
15 effort, to include links to the technical basis documents, 16: the 1640 and the likes on that.
17 MR. CAMERON: Okay. Thank you. Before I turn it l 18 back to Don I just -- I just wanted to thank all of you for 19 the discussion. It was a -- it was a really nice group for 20 all of us to work with, and I know it was beneficial for the l
21 NRC, and we hope it was beneficial for you to start thinking 22 about this. And I wanted to thank the people from Meridian 23 for all the convening support and logistical support that 24 they gave for this effort, it was really invaluable. And 25 thank Nancy of Jackson & Associates for th0 stenography
,9 ANN RILEY & ASSOCIATES, LTD.
(/ Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 -
l (202) 842-0034
E 410 1 help. And Hoite, wherever he is out there, that's our l' \ 2 uniformed police officer from the San Francisco Police
~'b 3 Department.
4 And Don,-I'll turn it back to you for closing.
5 MR. COOL: Okay. Thank you, Chip. I think most 6 of what could be said has been said in one form or another 1 7 at this point. Every time you start into one of these 8 processes you always'do it with a little bit of trepidation 9 because you, quite frankly, have no idea. There's no good l
10 way to' stick your toe in the water and find out exactly what 11 the temperature is. You have to jump in. I very much 12 appreciate all of your participation. I think there has 13_ been a great deal of valuable information and exchange of i
14 information. I would encourage each of you to think hard
() 15 about what you've heard here, think hard about the things i 16_ that.have been laid out, do some reflecting, and communicate
- 17. the'results of that to us. That is as much a value coming 18 out of these workshops as the actual transcript. And 19 certainly that's not to demean what we've got here, because 20 there's a huge amount of information to go -- go and sort 21 our way through. But there is the great added value of now 22 going back and being able to think about it, on the plane or 23 as you're driving back up through, if you happen to be. going 24 sort of back north into wine country or something.
25 So, let's -- to just continue to process along
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ANN RILEY & ASSOCIATES, LTD.
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that in formation as yev go. But I do very much appreciate ]
2
( each of.you for -- for participating. And I look forward to 3 continuing to hear from you on your thoughts and ideas. And 4 with that, thank you very much.
5 [Whereupon,'at 2:55 p.m., the workshop was <
l6 concluded.]
7 8
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'[) ANN RILEY & ASSOCIATES, LTD.
' \s / Court Reporters 1025 Connecticut Avenue, NW, Suite 1014 Washington, D.C. 20036 (202) 842-0034
r l
REPORTER'S CERTIFICATE This is to certify that the attached proceedings
,s
() before'the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING: RELEASE OF RADIOACTIVE MATERIAL WORKSHOP CASE NUMBER: l PLACE OF PROCEEDING: San Francisco, CA l 1
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear e-k,,m) Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting compaly, and that the transcript is a true and accurate record of the foregoing proceedings.
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J REGULATORY ASSESSMENT PERFORMANCE INDICATORS FOR GASEOUS DIFFUSION PLANTS September 16,1999 O
v OUTLINE e Perspectives on Reactor Program o Application to the GDPs e Concluding Remarks .
1 d
I l
O ASSESSING REGULATORY PERFORMANCE e Relevant to regulatory mission:
" protection ofpublic (including worker) health and safety and the environment" e intuitive (self-revealing) indicator o Comparable to others FEATURES OF NRC OVERSIGHT PROGRAM FOR REACTORS e " Top-down" approach starts and ends with the Regulatory Mission in mind e Color Codes provides "at-a-glance" an intuitive assessment of performar;ce e Standard format allows for comparisons and "benchniarking" -
l l
O
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" TOP-DOWN" APPROACH Mission li. PROTECTION OF PUSUC HEALTH & SAFETY & [NVIRONMENT]
u.,'_., Strategic i dw. 1 II a.. iu , -#1 i i Performance Areas I m e= ll = l 1 a.r w% l I i I messoasva= ll os e a. l l _h, j i 1- i Cornerstones l
of Safety l ,
............ 9.ross , cutting Issues l Human Performance ---SCWE--Corrective Action Program m
)
COLOR CODE EVALUATION l e Three. color scheme adequate e Need to develop an objective methodology to apply color codes to inspection findings l e Need to pre. position an NRC Response Action Matrix
(
(3!
v 3
i 1
(a GRADUATED REGULATORY RESPONSE, OVERSIGHT & EFFECT l
e GREEN, no NRC Response; reducedinspection frequency; no new actions or commitments 1 i
1 e WHITE, increased Regulatory Response; normai inspection frequency; actions within corrective action program i
e YELLOW, requiredRegulatory Response; l increased inspection frequency; possibility of
\ new commitments O
BENEFITS OF PROGRAM e Focuses resources on risk significant activities and areas ofindicated weakness e increases predictability and consistency of NRC response l e Rewards good performers ,
o Provides public with clearer perspective of risk l
1 l Li 1 -
4 l
. . ... 3 ;
l O !
APPLICATION TO THE GDPs e Crucial to agree on definitions of performance indicators which reflectlower risk significance and design differences from reactors l
e Difficulties in establishing thresholds ,
> No PRA
> No Peers
> No Precedence
- Rely on safety analysis report update, engineering judgment, and experience O
STRATEGIC AREAS AND CORNERSTONES OF SAFETY e Process Safety
> Barriers (?)
> Emergency Preparedness e Radiation Safety
> Occupational
> Public
> Transportation
- e Safeguards
> PhysicalProtection O
5
...,)
l l
l I
(O V
l PERFORMANCE INDICATORS l
o Process Safety
> Unplanned Safety System Actuation / Challenges
> Safety System in service Failure on Demand j > l_oss of Criticality Contingencies
, Drill Exercise Performance
> ERO Drill Participation
> Alert and Notification System Reliability l
- Radiation Safety
> Occupational Exposure Control Effectiveness
, Radiological Effluent Occurrence (includes UF, release)
> Transpodation Deficiency e Safeguards
, Safeauards Event
(
C CROSS-CUTTING ISSUES e Human Performance
> Errors
> lssues
> Training eSCWE
> Resolution Rate
~ e Corrective Action Program
> Self-identification
> Timeliness
> Adverse trends v
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O GOOD BUSINESS MANAGEMENT REQUIRES DIFFERENT INDICATORS e NRC indicators are hiah-level (outcome-based):
reported auarteriv; thresholds for reaulatory response e USEC indicators are low-level; process issues (precursors) e USEC indicators need to be monitored more frequently with lower thresholds for management response '.
e Additional indicators may be needec' for special cases O
O V
1 l
" COMPLETE" SET OF INDICATORS USEC Indicators NRC ;
Indicators '
l 4
O V
CONCLUSION e USEC cohalders that the new NRC Oversight Program for reactors can be ludiciously applied to assess regulatory performance at the GDPs in a way that provides benefit to
! the NRC, industry, and public
> Focus oversight on risk areas and areas of indicated weakness
> Establish inspection-level commensurate with risk & performance
> Create a " report card" that is unambiguous and understandable 1
! e USEC is ready to partner with the NRC to develop regulatory performance measures for the GDPs mo O
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4
- sECY49-IS9 EVALUATION AND PROPOSED RE .. CYCLE FACILITY SAFETY INSPECThMp PROGibAffov>NRC, COMMISSION'SECYs'1999188scy.html 1
SECY-99-188 N- . July 21,1999 FOR: The Commissioners-
$ FROM. ' William D[ Travers /s/
.), ' Executive Director for Operations
SUBJECT:
EVALUATION AND PROPOSED REVISION OF THE NUCLEAR FUEL CYCLE i
, FACILITY- S AFETY INSPECTION PROGRAM i
PURPOSE:
' To inform the Commission about the staffs evaluation and proposed revision of the Agency's nuclear fuel l , . cycle facility safety inspection program and related changes.
- l. o , .. c E DISCUSSION:
The~staffis evaluating and proposing revisions to the baseline safety inspection program that applies to ,
ten nuclear fuel cycle facilities. The facilities include two gaseous diffusion plants, two highly enriched ~ l uranium fuel fabrication facilities,'iive low-enriched uranium fuel fabrication facilities, and one uranium -
.]
- hexafluoride (UF6) production facility. These facilities possess large quantities of materials that are )
. potentially hazardous (i.e., radioactive, toxic, and/or flammable) to the workers, public, and environment. '
This initiative resulted from the staffs fundamental reviews ofits regulatory program, as part of the
" reinventing government" process and consideration oflessons learned, from several U. S. Nuclear Regulatory Commission (NRC) initiatives for improving regulatory oversight, including process -
improvements for oversight of reactors. In this regard, the staffs initiative to evaluate and propose revisions to'the safety inspection program comports with: .
i
- - NRC's Strategic Plan (i.e., the Agency's mission, vision, goals, good regulation principles, and l J philosophy), .
- i
.'* The Commission's " White Paper on Risk-Informed and Performance-Based Regulation"; I
~
- = SECY-992100 (March 11,1999), " Framework for Risk-Informed Regulation in the Office of J Nuclear Material Safety and Safeguards";-
- i Commission expectations for more objective, reliable, and predictable indications of performance; l
- The risk-informed, performance-based proposed rule: "10 CFR Part 70. Domestic Licensing of
( Special Nuclear Material"; and
- NRR's initiative to improve the reactor oversight F > cess.
,7 The' goals are to have objective indications of acceptable and changing safety performance relative to l : licensees controlling hazards to acceptable levels of risk; increase stakeholder confidence in NRC;
' increase regulatory effectiveness and. efficiency; and optimize regulatory burden. In this regard, the staff L plans to revise the fuel cycle facility safety' inspection program to use: 1) a more risk-informed, l ,
performance-based approach to focus on the more significant risks at fuel cycle facilities; 2) more
' t of '4 i Ott ( rinon 4 M1 In t ,
3 1 l
- sECY-99-189 EVALUATION AND PROPOSED RE... CYCLE FACILITY SAFETY INSPECTEMyi.PROGRAffov/NRCeCOMM1sslON'SECYs/1999-188scyhtml 1-
~o bjective safety performance indicators (PIs) with accompanying performance thresholds; h " third-party" i
p (e.g., fire and nuclear insurer inspections) safety inspections; and 4) NRC inspections. The Pls, together -
L) with risk-informed inspection findings, are intended to provide an objective and reliable basis to I
. determine if a fuel cycle facility is safe, to identify cost-efficient safety improvements, and to provide early indications of declining safety performance. In addition, the Licensee Performance Review (assessment) l process, which evaluates PIs and inspection findings, will be enhanced based on a better understanding of i the most important safety features of the facility's "as-exists" configuration and operations, and using more risk-informed PIs and inspection findings. This will facilitate clear and predictable regulatory y 1 decisions such as determining overall safety performance; identifying needed changes in Agency I inspection emphasis; and supporting enforcement actions. Corresponding changes in the enforcement
. program are also under consideration.
A task force consisting of two teams will evaluate and propose inspection program revisions: 1) a !
program framework development team consisting of branch chiefs from Headquarters and certain regions responsible for fuel cycle facility inspection activities; and 2) an inspection procedure writing team consisting of fuel facility -inspectors. Where appropriate, lessons-learned from NRR's ongoing i improvement of the reactor oversight process will be used by the teams. The activities of the task force will be closely integrated and both teams will interface with stakeholders through public notifications and meetings to provide opportunities to exchange information and receive feedback. Based on lessons learned from NRR's ongoing revision of the reactor oversight program, a communication plan is being prepared for meaningful, effective, and efficient involvement ofinternal and external stakeholders. Public meetings are planned to exchange views concerning the inspection program, its revision, and implementation. A public workshop is planned to inform fuel cycle fheility licensees and other interested
_stakeholders concerning implementation of the revised inspection program. Inspector training it, planned
_ to implement the revised inspection program.
A top-down approach will be used to develop an inspection progiam framework. This approach will stert .
with a desired outcome, identify performance goals to dieve the outcome, and then identify specific objectives and information needs to meet each performance goal. This framework will start at the mission level. Part of NRC's mission is to ensure that fuel cycle facilities are operated in a safe manner (i.e.,
acceptable risk for the worker, public, and environment). Probabilistic risk assessments are not required for fuel cycle facilities; however, licensees have performed safety analyses that vary in scope and content.
In the absence of an Integrated Safety Analysis (ISA) and identification ofitems relied on for safety, as a would be required in the proposed revision of 10 CFR Part 70, staff will rely heavily on available safety analysis, facility operating experience, perf 3rmance reviews, and engineeringjudgment for safety insights concerning the root causes (precursors) for failure to control hazards to acceptable levels of safety. These available safety insights will be used to identify the most important elements, in strategic performance 3 areas, that form the foundation (cornerstones) for meeting the Agency mission. Future implementation of the currently proposed revision of 10 CFR Part 70 (i.e., performance ofISAs) will provide additional insights. The cornerstones will serve as the fundamental building blocks for the inspection program.
' Acceptable performance'in these cornerstones will provide reasonable assurance that the NRC mission is satisfied.
Where available, PIs with accompanying performance thresholds will be selected as a means for measuring the performance of key attributes in each of the cornerstone areas. The extent of NRC actions
' will be graded based upon the relative deviation from the PI threshold. These thresholds will correspond O
V to levels of performance (performance bands) requiring minimum inspection (baseline); performance that could result in increased inspection; performance that will require increased inspection or other forms of ;
NRC engagement (e.g., management meetings, Commission meetings, Orders, etc.); and performance
' that is unacceptable. For areas of performance where a PI is not available or sufficient, the staff will !
,- n m onn o m
e .
SECY.99-189 EVALUATION AND PROPOSED RE... CYCLE FACILITY SAFETY INsPECTENp PRMRM4ov NRC COMMisslON sECYs'1999-188sey.html i p
conduct supplemental ineections as part of the baseline inspection program.
v) r l
The baseline inspection program, together with PI information, will be the Agency's mechanism to remain 3
i cognizant of risks and conditions impacting risks at fuel cycle facilities. The program will obtain a '
minimum level of factud information concerning licensee performance in: 1) controlling hazards to acceptable levels of risks; 2) identifying and resolving safety performance issues; and 3) reporting PI data (complete, accurate, and timeiy). PIs, along with baseline inspections, are intended to provide sufficient data to assess performance in the risk-significant areas of each comerstone. .PIs are not intended to provide complete coverage of every safety aspect of fuel facility configuration, hazards, or activities. ;
Objective performance evaluation thresholds are intended to help determine the level of regulatory 1 activities / engagement (e g., additional inspection, enforcement, changes in requirements, etc.)
commensurate with performance in each cornerstone area. l 1
Risk-informed baseline inspection procedures will be developed for inspectable areas within each l cornerstone. Inspectable areas will be selected based on risk significance (i.e., important for meeting a cornerstone objective as derived from a combination of operating experience, deterministic insights, and i regulatory requirements). The scope ofinspection wUl be modified based on the associated PIs. When an indicator exists, the more comprehensively the indicator measures an area and indicates acceptable l performance, the less extensive will be the scope ofinspection. Supplemental inspections, which will be discretionary or reactive, and in addition to baseline inspections, will be conducted in response to l declining performance, events, or issues of a generic or facility-specific nature.
RESOURCES:
4 n :
V Resources required in the short term to evaluate and propose revisions to the fuel cycle facility safety inspection program were not budgeted. The staff plans to reprogram resources from the inspection program by reducing the number and extent ofinspections on lower risk activities that are currently required by Manual Chapter and thereby included in the Master Inspection Plan for FY99 to have resources to evaluate and develop proposed revisions to the inspection program. Two FTEs are projected to be available in fiscal year 2000 due to USEC's postponement of AVLIS, and will be reprogrammed for um in completing revision and implementation of the safety inspection program.
COORDINATION:
The Office of the General Counsel has reviewed this Commission paper and has no legal objections to its content.
The Office of the ChiefInformation Officer has reviewed this Commission paper for information techno!ogy and information management implications and has no objections.
The Office of the Chief Financial Officer has reviewed this Commission paper for resource implications and has no objections.
original /s/ by r^T, William D. Travers C) Executive Director for Operations CONTACT: Walter Schwink, NMSS/FCSS 301-415-7253 _
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