112th ACNW Meeting U.S. Nuclear Regulatory Commission, September 15, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON NUCLEAR WASTE
***
112th ADVISORY COMMITTEE ON NUCLEAR WASTE
U.S. Nuclear Regulatory Commission
Two White Flint North
Room T-2B3
11545 Rockville Pike
Rockville, Maryland
Wednesday, September 15, 1999
The committee met, pursuant to notice, at 8:35 a.m.
MEMBERS PRESENT:
B. JOHN GARRICK, Chairman, ACNW
GEORGE W. HORNBERGER, Vice Chairman, ACNW
RAY WYMER, Member, ACNW
. P R O C E E D I N G S
[8:35 a.m.]
DR. GARRICK: Good morning. Our meeting will now come to
order. This is the second day of the 112th Meeting of the Advisory
Committee on Nuclear Waste. My name is John Garrick, Chairman of the
ACNW. Other members of the committee include George Hornberger and Ray
Wymer. In addition, today we have Milton Levenson serving as an ACNW
Consultant.
The entire meeting will be open to the public. Today we are
going to hear from Larry Camper, the Branch Chief of the Division of
Waste Management, Decommissioning. He is going to provide us an
overview of the decommissioning program for Fiscal Year 2000.
We are going to get a status report on the decommissioning
Standard Review Plan including the modules, and the committee will
continue its effort of preparing reports.
Howard Larson is the Designated Federal Official for the
initial portion of today's meeting.
We are conducting this meeting in accordance with the
provisions of the Federal Advisory Committee Act. The committee has
received no written statements or requests to make oral statements from
members of the public regarding today's session. As usual, should
anyone wish to address the committee, please make your wishes known to a
member of the Staff.
It is requested that each speaker use one of the microphones
and identify himself or herself and speak with sufficient clarity and
volume so that he or she can be readily heard.
The committee member that will lead the discussion today is
Ray Wymer, and why don't we just proceed and let Larry get us into the
topic.
MR. CAMPER: Good morning.
DR. GARRICK: Good morning.
MR. CAMPER: I looked forward to this session for a couple
of weeks. I came down and met with you briefly at the last meeting and
introduced myself to you and began to set the stage for a working
relationship with the committee. I think as you know I came to the
decommissioning area in July. I had spent the last four and a half
years as the Branch Chief for Material Safety and Inspection Branch, so
if I go way back along the way, back in 1988 to 1989 I was a Project
Manager in the Division of Waste Management, so I had some familiarity
with the program. Of course, I have been on the peripheral edges of
decommissioning over the years in Material Safety.
But I come to the Branch and I come to you at a very
interesting time in terms of decommissioning. There is a great deal of
activity going on in decommissioning. There is a very interesting
number of issues that that have to be addressed, and as I will point out
to you today in my presentation I think there are some areas where the
committee can be of assistance to us.
The agenda item is billed as the FY 2000 Operating Plan for
the Decommissioning Branch and Key Decommissioning Issues, but we are
going to add a little flavor to it by having our colleagues in NRR --
Mike Masnik is going to follow my presentation and share with you some
insights from the NRR side of the house, because obviously
decommissioning for reactors starts in their world and in transfers to
our world in Materials. Also Research, the Office of Research is going
to make some comments somewhere along the line. I am not sure if they
are going to follow me or a little bit later in the agenda today, but
Research also plays a vital role in helping us to develop guidance.
Yesterday I think you got some sense of that when we were
talking about the Memorandum of Understanding that we had sent to
Research recently, and they are making a lot of effort right now to
upgrade some of the modelling, and so there will be some input from
Research as well.
I do have some slides coming to you. I apologize. I just
don't have them in front of you now. Of course, as these things go,
there is always something that trips you up at the last minute, but you
will have them hopefully before I am too far into this talk.
As I said, what I want to cover primarily is FY 2000 and
other key decommissioning activities.
Now last year I know that you got a rather extensive
presentation from John Hickey, my predecessor as the Branch Chief, and
so I am not going to go through a lot of the details of decommissioning
because John stepped you through that in the last year, but I do think
it is worthwhile to just sort of reiterate what are the key things that
drive us, because I am going to talk to you in a few minutes about a lot
of FTE and a lot of contract dollars, and I am going to talk to you
about some fairly high profile stuff, but I think it is pretty important
to remind ourselves what it is that we are trying to achieve.
Obviously we need clearer criteria and guidance for
decommissioning. We need timeliness on all of our actions, and I think
that is one of the areas that I am going to be looking a lot at as the
Branch Chief, and I have already told the Staff this. I am interested
in seeing our timeliness tightened up considerably. I must tell you in
some cases I think we just take too long to get actions done.
Now there are some legitimate reasons for that and the Staff
works very hard, but I think we could probably do a little bit better
job in terms of timeliness.
Financial assurance of course is an area that requires a
great deal of attention, efficiency and finality -- I am going to
mention finality again later in the talk, and one of the things that
really troubles John Greeves, the Division Director, is finality. There
is a great deal of concern out there, particularly amongst the reactor
facilities that if they go through the License Termination Rule and they
satisfy the 25 millirem, are they going to find themselves then having
to deal with another federal entity, for example, EPA with a different
standard, and the difference in cleanup cost between 15 and 25 millirem
can be significant in certain situations, so finality is an issue that
we are very concerned about.
Obviously it is not totally within our control. I think you
know as well as I do the role of the EPA and the current way of doing
things and in fact Chairman Jackson had sent a letter to the
Congressional Oversight Committee suggesting that Congress perhaps
should play a role in trying to resolve the difference between 25
millirem and 15 millirem, so finality is a fairly big issue for us.
In terms of size of the program in FTE and dollars, it is a
fairly large program. We have approximately 22 FTE at Headquarters,
about $1.8 million. We have 6.5 FTE in the regions, primarily
conducting inspections. For reactor decommissioning on the NMSS side of
the house we have 3.4 FTE -- not quite a couple hundred thousand
dollars, .8 FTE in the regions. Then on the Reactor Decommissioning
side of the house, which Michael will talk more about, has almost 18 FTE
at Headquarters and three-quarters of a million dollars, roughly, 9 FTE
in the regions. In the Decommissioning Program within Research there is
on the order of 10 FTE and approximately $2.3 million.
So as you can see, there's a lot of effort going into
decommissioning, a lot of FTE, a lot of contract dollars. I think as I
go through my talk you will see there is a great deal of activity going
on, but we certainly know that when you have that many FTE in a program
I know one of the concerns that Carl Paperiello had, and he and I talked
about this before I went down and took over the Branch, is that he wants
to be certain that we take every opportunity to reinforce with the
Commission the level of decommissioning activity that is going on.
I know one thing in particular he is concerned about is SDMP
sites. We are making a lot of progress on the SDMP front. By about
January or February we will have approved a number of plans and removed
some additional sites, but what we are ultimately going to be stuck with
is those very complex, complicated sites -- SDMP sites and otherwise, so
while this looks like a lot of FTE, there's a great deal of activity
going on and there will be a great deal of activity going on in the
foreseeable future.
Well, again it is always a good idea to sort of revisit what
are our responsibilities and again I won't spend a lot of time with
this, because you have seen it before just recently, but I did think it
was useful to me in my role now to sort of stop and think about each one
of these and if we look at those, you can see it is a fairly broad
spectrum of responsibility, I mean ranging from guidance creation,
interfacing with other organizations such as EPA, informing and
involving members of the public.
Increasingly the Commission is concerned about stakeholder
interests and stakeholder involvement. We go to substantial effort to
ensure that there is adequate stakeholder involvement. For example, we
recently had one of our workshops on the License Termination Rule here
at Headquarters and we made it a point to get out and contact
stakeholders that we were aware of, individuals and organizations, and
invite them to participate.
The Commission has made it very clear they want to hear all
perspectives on issues, and certainly on decommissioning you can readily
appreciate that there is a great deal of stakeholder sensitivity at the
sites, so stakeholder involvement is a very large deal. We provide a
great deal of technical assistance to the regions. We look at
previously approved burial sites, for example, and we probably handle
six or seven technical assistance requests per year from the regions on
that topic alone, so it is a fairly broad spectrum of responsibility on
the Materials side.
Similarly, on the reactor side the decommissioning process
for reactors starts on NRR but there is a juncture, there is a point in
the process where there is a handoff to us and that occurs once the
spent fuel is permanently transferred from the spent fuel pool, and then
we go from that point all the way to closure -- improving the License
Termination Rule, conducting environmental assessments, and then
ultimately getting to the point where we prepare the license termination
action, so this is a fairly long, drawn-out affair, going on typically
two, three, four years, with a great deal of Staff effort and many steps
along the way.
We are still relatively new at this. As you know as well as
I, reactor decommissioning is fairly new to us. We did have a couple of
License Termination Plans that had been provided to us that were
rejected. Those are coming back. We have the Maine Yankee just around
the corner, probably in November or so, coming in with their package,
so, you know, we have a lot to do, but yet we are also trying to work
our way through some new concepts and some new ideas.
Now I think the point that I would make on these
responsibilities on the reactor side, and it is something I have shared
with my sections leaders and with the PMs, we have to make our calls on
submitted information. We have ultimately got to make a call and we can
only do it on the written submittal, but we have to be willing to be
flexible, to sit down with reactors that are undergoing decommissioning
and discuss conceptual ideas.
To develop a decommissioning plan or License Termination
Plan costs lots of money. To decommission a reactor costs lots of
money, large sums of money. We have to be willing to participate in
conceptual discussions. There is a concept I will talk a little more
about here in a few minutes called "rubblization." We have already had
a couple of meetings with the folks from Maine Yankee and consultants
working for Maine Yankee to discuss this conceptually. We have to be
willing to do that as an agency. We can't make commitments based upon
those discussions, but we have to be willing to explore new ideas
because people are trying to find ways to reduce the cost of
decommissioning, so we are going to have to be mindful of that as we
work our way through this.
MR. LEVENSON: Excuse me, before you take that off, is there
a definition for the word "permanently" as it is used there in the first
bullet? Since this is a transfer of responsibility it seems to me that
it would be fairly important that that be clearly defined.
MR. CAMPER: Mike, I will defer to you for that. Can you --
would you like to comment on the term "permanently transferred from"?
DR. GARRICK: Announce your name, et cetera.
MR. MASNIK: Yes. This is Mike Masnik. What we are finding
in the reactor arena is that the plants are placing the fuel in dry
storage. Once they transfer the fuel to dry storage, it is put in the
dry storage containers.
Then they actually dismantle the spent fuel pool, so the
chances of being able to unload the fuel and then put it back into the
fuel pool are gone. Basically that alternative is gone, so it is in a
sense a permanent transfer from wet storage to dry storage.
MR. LEVENSON: But what you are really saying is that it is
due to the dismantlement of the pool though, not the type of storage?
MR. MASNIK: No. No, the casks the fuel is being
transferred to are designed for --
MR. LEVENSON: Yes, I am familiar with all of that. I am
just trying to define when they transfer all of the fuel out into casks
but the pool is still intact, is that when the responsibility transfers?
MR. MASNIK: That's correct. Once all the fuel is in the
casks then we initiate a transfer of project management oversight from
NRR to NMSS.
MR. LEVENSON: So there is no legal requirement that they
might not have to put some of it back as long as they have a pool. It's
just when the transfer is completed --
MR. MASNIK: That's correct --
MR. LEVENSON: -- the responsibility transfers?
MR. MASNIK: If done properly, this is completely invisible
to the licensee. Basically all they get is a new Project Manager who
reports to Larry Camper instead of to myself.
DR. GARRICK: While we are interrupting Larry.
MR. CAMPER: Sure, not a problem.
DR. GARRICK: A couple of questions. One is, what mechanism
do you use to -- when you were talking about FTEs, what mechanism do you
use to do your planning as far as the workload requirement is concerned,
other than waiting for a licensee to come in and say they are going to
engage in decontamination, decommissioning?
MR. CAMPER: Well, that is an interesting question, and
there is really sort of two parts to the answer. We go through a fairly
orderly, at least we think it is a fairly orderly process of planning.
We are planning out about two years. And what we do is we have
historical workloads. We have known sites that are, you know, going to
be undergoing decommissioning. We also do some anticipatory thinking,
okay. And that then factors up to whatever FTE it equates to.
Then there is also the surprise factor, if you will. We do
have to do some scrambling along the way to make adjustments in
available FTE as developments emerge that we didn't know about. It
hasn't been a problem historically, as I understand it, for the
decommissioning branch. We think we have a pretty solid handle. But,
basically, it is historical information, it is current awareness and it
is anticipated developments that we are aware of at the time. We are
pretty close, we are pretty close.
DR. GARRICK: So you could construct forecasts more or less
curves of future requirements as far as NRC is concerned with reasonable
confidence?
MR. CAMPER: Yes. Yes, we could.
DR. GARRICK: The other thing kind of related to that is,
and maybe it will be covered when you talk about rubbleization, is, how
does the staff keep up with any new technologies that might be employed
in the decommissioning process?
MR. CAMPER: That is a challenge, in all candor. It is a
challenge for a couple of reasons. We do try to, and we do participate
in a number of meetings, a number of society meetings. For example,
there is a meeting coming up very shortly up at Haddam Neck that NRR
folks are taking the lead on. We will be participating. John Greeves
and I are going to a meeting with NEI in Portland, Maine on reactor
license termination plans and decommissioning of reactors.
So we try very hard to get management and staff out to these
various meetings. We try to actively participate in them if we are
asked to. We also attend professional society meetings. But it is very
-- it is a challenge, I will tell you, in all candor, to do the
casework, to meet the expectations that we have before us, stay as
current as possible, and also play a leadership role by interfacing with
these organizations as they are exploring conceptual ideas.
Do we do it as well as we could? I don't know. Probably.
Maybe we could do better. But it really involves those three avenues.
DR. GARRICK: Yes. Okay. Thank you.
MR. CAMPER: You know, maintaining your state of the art
when you are running hard is not easy.
DR. GARRICK: Yes.
MR. CAMPER: With the rubbleization, for example, and this
was a concept that was brought to our attention, it came to us as a
result of Maine Yankee and the consulting firm that they are using, and
NEI is also looking at the concept of rubbleization in a more generic
sense, and I will tell you a little bit more about that in a minute.
DR. GARRICK: Okay. Thank you.
MR. CAMPER: So it is those kind of efforts. We also play a
role in inspections and we have gone through a streamlining effort in
the last few years to try to more closely have project managers at
headquarters interface with regional inspectors to coordinate the
inspections, to actually participate in the inspections, and, of course,
these inspections are being conducted following Manual Chapter 2602 and
the inspection procedures in 87104 and 88104.
I think the point that I would make here is that these
inspections are obviously a very important part of the process, getting
out there, actually seeing what is being done, but the take-home point
is that we have gone through a substantial streamlining effort to more
closely coordinate the activities of project managers and regional
inspectors.
So what is on the scope for the near term? We will be
looking at on the order of five to seven decommissioning plan reviews
for approval. These are SDMP sites, where these were the sites that
were grandfathered under the LTR. According to our operating plan, we
are to remove three SDMP sites each fiscal year. We will be reviewing
SDMP sites using the license termination rule criteria, about six of
those. We have reviews of non-SDMP complex sites using the LTR, these
are sites like NFS Irwin and Malinckrodt.
We will be reviewing LTPs for probably two power reactors,
Maine Yankee being one, Trojan being the other.
We do on the order of 20 to 30 financial assurance reviews a
year. We conduct about 30 of the inspections using the methodology that
I just showed you, per year, the integrated inspection approach. And we
do on the order of 10 or so technical assistance requests per year for
the regions. So there is a great deal of casework activity, as you can
see.
I think it is probably worthwhile just to revisit again some
of those FTE numbers. And if you bear in mind the types of
responsibilities that I talked about, coupled with the type of casework
that we see, while, again, one might look at that size of resources and
say that is a very large number of resources. If one wanted to have the
bean counter hat on and be a skeptic, I think that you need to bear in
mind the kinds of responsibilities and things that are being done in the
decommissioning area and the casework. Very real casework, all of which
has timelines associated with it, milestones along the way, and we work
toward completion.
We have very aggressive timelines on our technical
assistance requests. We try to do acceptance reviews of these things in
a matter of 10 to 20 working days. We try to turn them around in 45 to
60 days.
Financial assurance reviews, while there is no metric for
how fast they have to be done, we try to do them as quickly as possible.
So all of these things, there is a lot of it, and they are all monitored
very closely, and they all have assigned timelines.
This is the grandfathering cases. There is a requirement in
the license termination rule that allowed for the grandfathering
provision and it indicated that licensees were to submit their
submittals to us by August the 20th of '98, and we were to approve the
decommissioning plans by August of '99, August 20, '99. We found that
we were not able to do that for a number of legitimate reasons such as
the interface with states reviewing environmental assessments, responses
from licensees, the technical quality of some of those responses and so
forth and so on. So we found ourselves not being able to approve all
the DPs by August 20th.
So we went to the Commission and we said what we want to do
is grant an exemption to August 20th, 2000, and the Commission agreed
with that. And in the paper we provided this schedule to show, although
we are asking for the exemption to August 20th, 2000, a great deal of
progress will be made in the short-term.
But I think the important thing here, there is two things,
one is not only is there a lot of activity going on in terms of
approving these decommissioning plans in the short-term, but, again,
once we get through this particular flurry activity on these SDMP
decommissioning plans, what is going to be left are the really tough,
onerous cases. So there is a lot of activity in the short-term,
followed by some very complex sites.
Well, we have other important non-casework activities that
we do. We provide support to the Decommissioning Board. One of our
members of our staff actually works to prepare the agenda, provides all
the background material, coordinates with the chairman of the board to
ensure that we have everything that the board needs to conduct its
meetings.
Yesterday you heard about the Standard Review Plan. Nick
will talk more with you about the Standard Review Plan later today, but
we are working to finalize the Standard Review Plan and other related
decommissioning guidance.
We are playing a very active role in support of clearance
rulemaking activities. I mean, for example, as we speak, we have three
members of our staff in a public meeting in San Francisco on the
clearance rulemaking initiative. So there is a great deal of support
for that particular issue. And then, ultimately, we are going to be the
base of operations for the ongoing implementation of the clearance
initiative, assuming it survives, assuming it is a rulemaking and
what-have-you.
We have been conducting a decommissioning pilot program.
Five sites were identified. It was narrowed down to three. That
decommissioning pilot program goes on. The idea behind that is to try
to make it more performance-oriented to allow licensees to start
decommissioning activities without receiving prior approval from the
NRC. That project continues.
West Valley Demonstration Project activities, the West
Valley Project continues, it is a very large time sink. One of our
staff, Jack Parrot, is the PM, and next week Jack are going up to that
site and do a tour, and then we are taking part in a Citizens Task Force
meeting that evening. So West Valley continues to a large effort.
Support of the Interagency Steering Committee on Radiation
Standards, ISCORS, we provide a great deal of support and effort to that
initiative, which is very important.
And then reexamining and rebaselining complex sites. One of
the things that I am very concerned about, and the staff often hears
from me, is closure -- closure -- closure -- closure. It ain't over
until it is over. We have a lot of complex sites that we are going to
have to deal with, and we are undertaken right now a rebaselining,
reexamination of all the sites that we have before us to deal with.
Let me say a few more words about the rebaselining
reexamination initiative. We recently briefed the Commission on the
status of SDMP sites, and at that time -- and it may be because this
particular current Commission hasn't been around over the years when a
lot of activities went on in the SDMP area -- but the result was they
had a lot of questions about the SDMP area.
So when we go back this coming spring to brief the
Commission, we will be preparing and providing to them the biennial
report, which is a detailed report on the SDMP sites. We provided our
summary report this year, but when we go back this time, we will be
including within the Commission paper attachments for each of the SDMP
and other sites that we have undergoing decommissioning. As part of
this effort, we're going back and we're taking a fresh look at what is
on the plate and what is it going to take to get to closure.
I want to make sure and ask the PM's to make sure that the
SDMP data base is current and up to date. I think you know as well as I
do that a data base is only good if it's current. We have been -- we
let ourselves sort of drift into updating the data base on a quarterly
basis or updating the data base as we prepare for these annual
Commission briefings. I've asked that the data base be made current. I
want to be able to go into it at any given time and know what the status
is of any given site in current terms.
I've asked the PM's to take a look at all of the technical
and regulatory issues that confront us at that particular site. I've
asked that we identify major assumptions. Within the SDMP data base
there is a narrative section where this type of information can be
depicted. When we go up with the Commission paper, these attachments
will contain information that will identify all the major assumptions
that we have brought to bear in trying to estimate what are the major
milestones for this particular site and what is the best estimated time
of arrival for completion of that site that we can determine.
Now those dates are subject to change, of course. Licensees
start down the pathway of decommissioning, they don't progress quite as
they thought they would, they uncover issues they didn't know were
there. These things are subject to change. But unless we have a viable
management tool and have a pretty good handle on what it's going to take
to bring a site to closure, we're going to find ourselves in a briefing
five or ten years from now still talking about X, Y, and Z site. We've
got to have a solid plan.
I'm including for each of the sites a project management
information and Gantt charts that will depict all the major milestones.
And again we owe the Commission the next report on the SDMP sites and
other sites in March of next year.
Now the Commission has asked that the next briefing on
decommissioning activities be a combo, the NRR and Materials. So the
briefing that we provide next spring or summer following this Commission
paper will be a joint effort between us and NRR to discuss the status of
the decommissioning of sites at large.
But the point I want to make here, this is not business as
usual. The staff and the Decommissioning Branch have worked very hard,
they have done a very good job, they have made incredible progress in
clearing SDMP sites off the rolls. But unfortunately you get to a point
where what's left is the tough stuff. We have picked the cherries out
of the fruit cocktail, and we need to have definitive plans and know
exactly what we're up against in the remaining complex sites. That's
what this effort is all about.
So it's twofold. One, it will give us a current viable
management tool, a clear understanding of where all the sites stand.
We'll probably learn some things along the way that we really didn't
know were issues at these sites. It'll give us the best possible
estimate of when we're going to be able to bring the site to closure,
and it will give us current, meaningful information to present to the
Commission that hopefully will address the kinds of questions and
concerns that I heard during the last briefing. So it's a fairly big
undertaking for us.
We face some challenges, the Agency faces some challenges,
not only the Decommissioning Branch within the Division of Waste
Management but NRR and Research. We all face challenges. Dose modeling
guidance. I mean, you heard a lot yesterday about dose modeling
guidance. You had some very astute questions. I'm not going to belabor
that point, but it is very clear to us that we need to make the modeling
approaches, remove some of the conservativeness that's in it to make it
as realistic as possible. There's a lot of work going on right now
within our shop, within Cheryl Trottier's branch to make that happen.
Clearance Rule. Clearance rule is a significant challenge.
I don't know how much you're up to speed on the clearance rule, but
basically what's happened is that the Agency published an issues paper
in which it expressed concerns about the idea that there's no standard,
there's no rulemaking that allows a clearance or a recycling of
materials that have been contaminated at some levels. It started off
being called clearance. We are increasingly gravitating toward the
concept of control of solid materials, although conceptually the idea is
that these materials can be released at some determined level. The
international movement tends to be on the order of 1 millirem.
What we have found, though, is that there is tremendous
opposition to the initiative, tremendous opposition to the initiative,
so much so that individuals that are opposed to the concept that the
Nuclear Regulatory Commission would allow release or recycling of any
material that has been contaminated, or for that matter that we would
not go out and do something to cause any material that has been
released, even if they were released on a case-by-case basis, we have
been releasing -- allowing release of materials on a case-by-case basis
for a number of years.
So there's even concern among some people that not only
would we consider pursuing a clearance or release or control of solid
materials, the net result of which would be to allow material to be
recycled, but there has been material released already, and we should do
something about that. Their opposition has been so strong that they
have opted not to participate in public meetings that we've scheduled.
DR. GARRICK: And what's the basis of the opposition? Is
there a --
MR. CAMPER: Yes. It's radioactive.
DR. GARRICK: Huh?
MR. CAMPER: It's radioactive.
DR. GARRICK: Well, I know --
MR. CAMPER: How dare you -- the basis is that it's
radioactive. How dare you -- you are here, NRC, to protect us, protect
public health and safety, how could you conceivably entertain the idea
of allowing radioactive material, anything that's contaminated with
radioactive material, to be recycled or reintroduced into society. I
mean, that's the essence of the opposition. They're very concerned
about any level of exposure. The preference is zero radiation. I mean,
that is their concern.
Now the thing that was a little disturbing to us, though,
was normally most of us believe that the way to work through our
differences is to sit down and have discussions and have an agenda and
let's work through concerns. But they felt that it was preordained that
a rule would result. Some of them expressed concerns that historically
they've participated in rulemaking efforts, but their concerns weren't
heard, the Agency proceeded with a rule anyway, and therefore, you know,
you're going through the motions, you're really not going to seriously
entertain what we have to say.
The staff became very concerned about this, the facilitator
became very concerned about it, the staff went back to the Commission
and brought to the attention of the Commission the fact that there was
this level of concern and objection, suggested that perhaps rather than
continue with the scheduled workshops, there was one scheduled for
Chicago in August, the meetings going on in San Francisco yesterday and
today, there's a meeting in Atlanta in October, and there's a meeting
here in Washington in November.
The meeting in Chicago in August was postponed because of
the level of opposition, and the concern really of the staff was can we
have a viable, meaningful exchange of ideas if those whose views are so
strongly held will not participate, are we really able to cover the
waterfront in terms of concerns?
We went to the Commission. We said that, you know, we
really may -- we ought to stop and regroup and take a different
approach, kind of try to meet with these various stakeholders, find out
what their concerns are, and then proceed with public meetings. The
Commission advised the staff to proceed with the meetings. That's why
the meeting in San Francisco is going on. The Commission, the vote
sheets reflect a concern to the Commissioners in which they believe that
there is a need to address the development of a standard to allow
control of solid materials in an orderly fashion, to not have to do it
continuously on a case-by-case basis, to try to determine and explain to
the public what is a low enough number and the rationale for that
number. So the Commission felt very strongly that the staff needed to
proceed. So the meetings are going on. But the Clearance Rule is a
very interesting issue.
Restricted release cases that we think will pose some
challenges for us because there will probably be -- as you know, under
the License Termination Rule there is a provision for restricted
release. It will probably involve some very complex questions in terms
of adequacy of institutional controls.
And clearly there will be a lot of stakeholder involvement.
There will be a lot of stakeholder concerns.
DR. WYMER: In that connection, what is the continuing
responsibility of the NRC?
MR. CAMPER: Well, at some point we step out of the game.
We have to ensure that there is adequately defined and in place
institutional controls. Now, we have some ideas in guidance space as to
what those institutional controls are. It may be another federal
agency, for example, the DOE or some state agency. But the way the
process is to work, we will reach a determination that, in fact, there
are adequate institutional controls, and that the institutional controls
will be in place for a determined, adequate amount of time. But we step
out of the game at some point.
DR. WYMER: So the NRC can get out clean and clear. In the
case of a DOE facility, I know DOE is stuck forever.
MR. CAMPER: That's right. Their charge is different than
ours, you are right.
DR. WYMER: Okay.
MR. CAMPER: There will be unique proposals. Oh,
development the regulatory framework for partial release. You know,
right now we had this requirement that you are a reactor undergoing
decommissioning, say, for example, and you submit a license termination
plan. Well, as you further characterize the site, as new calculational
methods emerge, new computer programs emerge, you may need to make
changes to your license termination plan. There is no mechanism right
now for that to happen. We have to figure out a mechanism for that to
happen.
And that is an area, by the way, that you may be of some
assistance to us. We have some models, some thoughts, but it is still
early in the game. This was talked about during the recent workshop
that we had here on the license termination rule, but that is an
emerging issue that we are going to have to come to grips with very
quickly.
Unique proposals by licensees. Rubbleization is an example
of that. The integrated rulemaking, NRR, I think Mike will touch on
that when he gives his talk, but there is a charge by the Commission to
look at the question of integrated rulemaking on the reactor side of the
house. The decommissioning regulatory improvement initiative, again, I
will let Mike step through that.
And then again, this issue of finality of decisions. I
can't tell you how much that troubles my boss, John Greeves, and how
much it troubles us when we go to meetings and we hear entities get up,
whether it is NFS Irwin or it is the reactor facilities, and they say,
you know, how do I know -- how do I know when I get through dealing with
the Nuclear Regulatory Commission, and I am at, you know, either 25
millirem or some other agreed-upon criteria, how do I know that that is
it? I mean how do I know that the EPA or a state agency is not going to
come in?
And I think that you guys all probably, you gentlemen and
ladies probably all realize that, you know, there is a lot of concern
out there that 15 millirem, you know, it 65 percent less than 25
millirem and, therefore, it is lower and you ought to go there. There
are some states that talk about 10 millirem. You know, a lot of people,
when they look at remaining exposure levels, say, why not zero? I mean
why should you leave anything behind that makes any kind of dose
contribution to someone who might come afterwards? I mean the
production of energy has ceased, take this stuff with you. Get it out
of there. Don't leave anything.
So, it really causes a great deal of concern for those who
are trying to follow the rules, spend a great deal of money,
decommission their sites, when they know full well that there may be
someone who will come along later and second guess them. So, finality
is a very, very big deal.
Okay. Then in summary, you know, we have covered a lot. I
have tried to give you an idea of the operating plan and some of the big
things that we face. And, so, you know, what are some of the things you
can help us with? The clearance rule. I think that as the clearance
rule ripens, as we get feedback from the public in these meetings, and
as the staff tries to move toward developing either a rulemaking or an
issues paper, or a policy statement, or whatever comes out of this, I
don't know, I really don't know what it is going to be because we are
operating with the mindset that all options are on the table. While it
is very clear to me from reading the vote sheets of the Commissioners,
and looking at the staff's last communication with them on the clearance
initiative, there is a strong sentiment that something needs to be done
in a positive manner along rulemaking to create a standard and put this
issue to rest.
Having said that, though, the Commission is very mindful of
the fact, and has instructed the staff to explore all options.
Everything is on the table. So I don't know what we will come out of
it, but I think that it would be useful if we would share with you on
your agenda along the way whatever is being developed and get your input
and perspectives on it. That would be very helpful to us.
Entombment is an emerging issue. Research, I believe, is
currently developing a paper on entombment, or will be developing the
paper shortly, as I understand it. Perhaps, Cheryl, you can clarify
that for me. But entombment is an issue that, as it moves along, I
think you could help us a lot.
I have just a brief blurb to read to you about entombment,
and given that the paper hasn't been developed yet, it is still early
and a little premature to get into it in depth, but entombment is viewed
as an alternative in which radioactive contaminants are encased in
structurally long-lived materials such as concrete. The entombed
structure is appropriately maintained and continued surveillance is
carried out until the radioactivity decays to a level permitting release
of the property for unrestricted use. ENTOMB is intended for use where
the residual radioactivity will decay to levels permitting unrestricted
release at the facility within reasonable time periods.
I think I know why you are chuckling in terms of reasonable
time periods. I.e., within the time period of continued structural
integrity of the entombing structure, as well as confidence in the
reliability of continued radioactivity containment and access
restriction, perhaps on the order of 100 years. Well, that is
immediately a problem, obviously, because, given the nature of some of
the isotopes and what-have-you involved in the facilities we are talking
about.
It goes on to say that -- it points out the fact that,
obviously, this doesn't work real well with half-lives. Thus, the basic
requirement of continued structural integrity of the entombment cannot
be insured for these facilities and ENTOMB would not be a viable
alternative in these circumstances.
On the other hand, if the entombing structure can be
expected to last many half-lives of the most objectionable, long-lived
isotopes, then ENTOMB becomes a viable alternative because of the
reduced occupational and public exposure to radiation. However, even in
these circumstances, one of the difficulties with ENTOMB for any complex
structure such as a reactor is that the radioactive materials remaining
the ENTOMB structure would need to be characterized well enough to
ensure that they will have decayed to acceptable levels at the end of
the surveillance period. If this cannot be done adequately, deferred
decontamination will become necessary, which would make ENTOMB more
difficult and costly than decontamination or safe storage.
Now, you know, just quickly, that is what entombment is
about in general terms. But, again, as the staff develops the paper
that I am referring to, and as we begin to materialize our thinking on
this a bit, and explore with the Commission, again, I think that is a
very viable role for the committee to provide some thoughts.
DR. WYMER: It is a little hard to see how you could have an
unrestricted release in an entombed state.
MR. CAMPER: That's right. Sure. That's right. Well, that
is envisioned conceptually. But you are right, that is right.
Now, the other one is rubbleization. Now, rubbleization is
here and now, it is getting very close. In general terms, rubbleization
is a concept whereby a utility would go in, do some characterization of
materials on the wall, would go through a scabbleization process, would
end up with levels of contamination on the walls considerably higher
than those in Regulatory Guide 1.86, would then tear the wall down,
break it into concrete pieces of varying size. Some of them could be
blocks that are three or four feet in diameter. Some can be as small as
stones. When you break the wall up, you are going to get all kind of
sizes. You then take and leave three walls of a four wall structure in
place. You take a bulldozer, you move all this rubble into this
containment, these three walls. You then cover it up and you cap it off
and leave in a green field condition.
A couple of interesting points about it. By going this
route, the amount of money that can be saved per site in terms of costs
saved in scabbleization, cost saves in hauling material away and
what-have-you, ranges from probably on the order of $7 million to $30
million per site. So we are talking significant dollars.
Right now Maine Yankee is seriously considering including
this approach within their license termination plan to be submitted to
us. We have had three meetings with Maine Yankee, including a closed
meeting recently with Maine Yankee and their consultant, because of
proprietary concerns about the modeling that the consultant is using for
the rubbleization process.
The Staff is currently developing a Commission paper on the
rubblelization concept. We want to share with the Commission the fact
that this concept is emerging as a preferred path. It appears that it
will have generic use implications. It appears that it will have
substantial cost savings for those sites choosing to use it, and so we
want the Commission to be aware of it and to provide a policy position
on the rubblelization approach.
During the recent workshop here on the License Termination
Rule this was a topic on the agenda that generated a great deal of
discussion. The point the Staff made that day was we would rather not
have to deal with the rubblelization issue as a concept, only in terms
of the Maine Yankee LTP. If this in fact is emerging within the
industry as an approach then we would like to see the industry weigh in
on the matter. As a result of that Paul Genoa of NEI agreed for NEI to
provide us a white paper for inclusion as an attachment within our
Commission paper.
They have committed to providing that to us by the 15th of
September. I also understand that the State of Maine intends to provide
us with an issues paper on rubblelization which will be included as an
attachment to the Commission paper, and during the day of the public
meeting a lady whose name I forget now -- Judith Jonstra or something --
MR. MASNIK: Johnsrud.
MR. CAMPER: Johnsrud -- expressed some concern that if the
Staff was going to include an issues paper from NEI on rubblelization,
would we also consider including an issues paper or statement from the
environmentally oriented groups and we said by all means we would like
to have that. We want all perspectives. So again they committed to
providing us with an issues paper by the 15th.
I, just yesterday in fact, shared Draft Number 2 with
Division management for them to look at it to see are we getting there
conceptually, are we touching on all the key issues, and does this seem
to be neutral in the sense that we are sharing with the Commission what
the issues are without weighing in too heavily one way or the other.
Our basic premise in this, the Staff's preferred position,
is that if it can be demonstrated that this approach will indeed satisfy
the 25 millirem criteria that it would be acceptable to the Staff, but
what we want to try to do is make sure that the Commission is (a) aware
of the concept, aware of the issues associated with it in terms of cost
savings, generic implications, technically how the model would work and
then (b) be aware of all the various issue and make a policy decision
for the Staff to follow.
Now it strikes me that once we get this Commission paper
refined and at the appropriate point in the process in our interactions
with the Commission to be able to share with the committee, the paper
and get your technical insights and perspective on the issue as well and
factor that into the equation as we proceed as well.
One of the things that we are going to have to do if we
assume for sake of discussion that the Commission agrees that the
rubblelization concept is viable and says to the Staff, yes, it will
work, then the Staff is going to have to also develop some guidance.
There are a number of complex issues that will surface in
rubblelization, not the least of which is that the mixture, the blocks,
the rubble will not be homogeneous. It will be heterogeneous. There
will be "hot spots," if you will, within the rubble and then you have to
get into questions of how does one model that and what are the scenarios
that have to be considered for the future.
DR. GARRICK: One of the things that I am struggling with is
the difference between entombment and rubblelization, given the
conservation of radiation, and I can see a difference in geometry, but
what is the real difference here?
MR. CAMPER: Well, again entombment is fairly new, so I will
speak to what I understand of it at this juncture.
The concept of entombment is that you have got all this
material that is contaminated. You have still got your reactor vessel
there and what have you. You have got your structure. You encase it in
concrete. You create a sarcophagus-like effect, if you will, and you
leave it there for some determined period of time to allow adequate
decay. Structural integrity is an issue, control of the site and what
have you, and then at some point it is no longer an issue.
Under rubblelization what you do is you go in and you take a
particular building, a particular area. You through a scabblelization
process to remove as much of the contamination as you can. The values
that you are left with are probably an order of magnitude or so higher
than that which is in Reg Guide 1.86. You then break up the wall. You
put this rubble -- you put it into this pit, these three walls and then
you cover it up.
So in the latter case you are going through a process of
removing some contamination to some determined levels. You then cover
it up and go to greenfields.
Under entombment, as I understand it, you basically go in
and leave the structure and everything intact. You go through some
process of sealing it up with material like concrete and you leave it
there.
Certainly the geometry is different, but there are some
differences in the concept.
DR. GARRICK: You wouldn't be monitoring the site either in
rubblelization, right?
MR. CAMPER: No, it is unrestricted release.
DR. GARRICK: In entombment you are monitoring the site?
MR. CAMPER: That's right. In rubblelization you are
demonstrating that you have satisfied the 25 millirem criteria. It is
unrestricted release. Under entombment it would be restricted release
and controls.
DR. GARRICK: Well, I am still struggling with the law of
radiation conservation here. You are not removing this stuff. You are
just rearranging it, it sounds to me like, in going from entombment to
rubblelization, but anyway we can talk about that.
MR. CAMPER: Yes.
DR. GARRICK: On the clearance rule, what is an example of
what you think this committee can do to offer good or some useful advice
on that issue? It sounds to me like it is almost totally a policy
issue.
MR. CAMPER: It is. It is a policy issue. I agree with
that.
I guess the thing that would be helpful that comes to my
mind is the more that learned bodies, sophisticated advisory groups like
this take a look at the overall approach, the level of radiation that
you are talking about in the standard -- for example, it is one
millirem, consistent with what is going on in the IAEA -- the more that
advisory groups to the NRC, not just the Staff and/or the Commission
look at this and says in essence this seems to be a reasonable approach,
it seems to be a number that will ensure protection of the public health
and safety, it seems to be that the science has been considered
properly, the more that committees such as yourself, organizations such
as yourself take a look at that and provide that kind of scrutiny, I
think the more it lends the credibility of the process.
DR. GARRICK: Has the NRC investigated similar kinds of
criteria applying to other toxic materials and waste sites?
MR. CAMPER: I understand -- like chemicals, for example.
DR. GARRICK: Right, right.
MR. CAMPER: No. Not yet. I think certainly they are aware
of that but, you know, at this point it's been focused on radiation.
DR. GARRICK: You see, there's always this tendency to think
that radiation as a threat is unique and if there's a history and
experience out there of establishing some sort of criteria, it is
probably not called a clearance rule but some sort of criteria that
constitutes adequate cleanup of other sites that involved toxic
substances and hazardous materials.
That might be one of the most important baselines to deal
with in trying to bring the public into this concept as a rational
approach.
MR. CAMPER: Well, that is a good point.
DR. GARRICK: I guess I am just raising it.
MR. CAMPER: That is a good point. I understand. I
understand your issue.
MR. LEVENSON: There might even be some cases to look at
baseline with radiation. In most of the '50s and part of the '60s you
couldn't make low -- good counting equipment out of brass because the
world supply of brass was contaminated from radium dials from World War
II airplanes that just had gone into the junk recycle channels, and in
another case a few years ago when Oregon was striving -- they didn't go
to zero but they had a very low number -- it turned out the quarries
couldn't throw the scrap rock back in the hole and in fact you couldn't
bury someone who had been cremated, and so I think there's a lot of good
history that could be developed for why zero is not a practical thing.
MR. CAMPER: It's a very interesting issue. I mean there is
a great deal of -- I don't want to use the word "hysteria" now -- but
there is certainly a great deal of concern. I mean for example the
State of Tennessee recently went through authorizing an action whereby
several tons of nickel would be released, and they were down in the dose
range of on the order of one millirem, consistent with what is going on
in international circles.
There's been a great deal of concern expressed about that.
In fact, 186 organizations signed a letter to members of Congress
expressing some concern about that, and we have had several
opportunities to go to Capitol Hill and explain what it was that
Tennessee did and what was our role in Tennessee allowing this licensing
action and does it protect public health and safety, and addressed a
number of concerns which had been raised, and I think it is that type of
thing, frankly, that causes the Commission to look at this and say okay,
you know, in the sunlight let's put this thing through due process and
try to develop a standard because right now there is no standard.
I mean you have got certain release criteria in Reg Guide
1.86. You have got the non-detection criteria on the NRR side of the
house and you have got case-by-case releases, but it does seem to cry
out for the need to develop a standard, but having said that we all --
we as scientists and technical people look at this and say gosh, you
know, let's look where we are when we talk about 1 millirem or 10
millirem or 100 millirem, for that matter, but to people who are not
necessarily of the same scientific bent as we are, who have incredible
concern about radiation, their position is none, zero, radiation is a
bad thing, so trying to marry those two views is kind of tough.
DR. GARRICK: By definition that is impossible, so --
MR. CAMPER: Of course. Of course. Of course. So that is
what I had to say. I appreciate your questions and comments and I think
if you have no more questions on what I have been covering in the
Decommissioning Branch I will have Mike or Stu come up.
MR. LEVENSON: I have one question on this differentiation
between entombment and rubblelization.
Material that is going to be rubblelized has generally been
scabblelized or things have been done to remove activity, is that
generally in a way such that whatever fraction might be loose or
leachable, et cetera, might be lower in the rubblelized material than
entombment, which generally means you just case something up and leave
it there?
MR. CAMPER: Yes, that's correct. They will have gone
through a process of scabblelization to reduce the contamination, let's
say on the concrete wall of the structure.
MR. LEVENSON: My question is more than the total content,
but it seems to me you probably have changed the characterization of
what is residual too, because if it is relatively easily removed or
leached, you have done that.
MR. CAMPER: Yes. Leachability is one of the big issues
that we are looking at in rubblelization, you are correct. Okay. Other
questions or comments?
DR. CAMPBELL: To follow up on John's comment about
examples, there are a number of EPA sites where there was in some
cases -- I am thinking of the Butte, Montana, the Anaconda mine cleanup
there -- they had massive amounts of material that could not be moved,
contaminating streams and waters, and they did various and sundry things
to isolate and solidify waste and things, and in one example they had
material that they turned into some sort of material that they could
pass the leach test, and then Jack Nicklaus came in and they built a
golf course over it.
You know, there are a lot of things that have been done out
there in hazardous materials, hazardous waste cleanup space obviously
involving community participation where people buy into the plan because
they get something out of it, if you will. In this case, Butte, Montana
got a nice golf course out of it, so there are things that can be done,
especially in that are of rubblelization that go beyond just leaving a
field.
MR. CAMPER: Right. Thank you. I will share those comments
with the clearance groups.
DR. GARRICK: We've got the potential for 77 new golf
courses.
[Laughter.]
MR. LARSON: Just for the committee's edification, the
clearance rule, I know, is going to be presented or discussed with the
committee in December.
Do you have any time scheduled for either entombment or
rubblelization, when you think those issues would come, because the
committee is trying to put together its meeting schedule for next year?
MR. CAMPER: Well, let me think. Entombment -- I would have
to ask the folks in Research.
Cheryl, do you have any idea on entombment? Rubblelization
I could probably give you some idea.
MS. TROTTIER: Cheryl Trottier, Research. Actually Larry's
a little wrong about the paper. We've already sent a paper up to the
Commission. We sent that up in July, and it's publicly available now.
The next step is we're having a public workshop in December
to hear comments from the public on the concept of entombment.
Following that workshop, probably in the January time frame, staff will
probably prepare another paper to go forward to the Commission on the
issue of entombment. So that might be a good time frame after we've had
the public workshop to come before the Committee and let you know the
findings that the staff has prior to going forward to the Commission.
MR. CAMPER: Good. Thank you for clarifying it. I wasn't
aware of that date. Thank you.
With regards to rubblelization, our objective is to get our
paper finished in September and get it up to the Commission. So I would
think that we'd have to look at this in terms of just when in the
process we could share with the Committee. But I would think that we
would be looking in the near term, I mean, within the next two or three
months.
MR. LARSON: November, with everything else.
MR. CAMPER: Is that shaping up to be your monster --
DR. GARRICK: Our singularity.
DR. CAMPBELL: The meeting from heck.
MR. CAMPER: Realistically I think we're in the
November-December time frame is probably doable. Okay?
Okay. Stu, are you going to cover NRR?
MR. RICHARDS: I'm going to do this from a sitting position.
Good morning. My name's Stu Richards. I'm the project
director for Project Directorate IV and Decommissioning in NRR. I
appreciate the opportunity to be here this morning.
I've been invited to come over and explain a little bit
about what NRR is doing in the decommissioning area. We're a copartner
with NMSS in decommissioning of power reactors, and I'd like to explain
a little bit of our overview. I have a fairly short presentation, so
we'll move right along.
This slide simply states that our activities are consistent
with the four pillars of the Commission. You've probably heard this a
number of times, so this is an additional advertisement that we're on
board with that concept.
This slide projects our resources for fiscal year 2000. I'd
like to note that the 17.5 FTE for headquarters is an increase over what
we had for fiscal year '99. We were at about 12 FTE, so that's a pretty
significant increase, and it reflects some of the regulatory framework
development work that we're doing, and I'll talk about that in a minute.
That 17.5 FTE is split into two parts. One is the project
management and licensing, so-called casework, and the second part is for
rulemaking and guidance development. That's the new piece that's taking
up a lot of our time in the next year or two.
It also shows the FTE for regional inspection effort, 9 FTE
there, and $740,000 for technical assistance.
I'd like to make sure you understand that we're talking
about activities for power reactors only. I'm not talking about
non-power reactors or any of the material sites here.
Okay. This slide gets into primarily where we spend most of
our time. When a reactor, an operating power reactor transitions into
the decommissioning phase, their focus becomes to eliminate the
requirements that apply to operating power reactors that no longer make
sense for a decommissioning plant. So we spend a considerable time
right after the plant shuts down working with the facility to modify
their license and to address exemptions within Part 50 to try and
eliminate those requirements that no longer apply to the state of the
plant.
I think Larry already mentioned that under the memorandum of
understanding with NMSS, NRR retains project management responsibility
for power reactors until such time as the spent fuel is moved out of the
spent fuel pool. So that's where the transition occurs. In the
meantime, until that occurs, we work very closely with NMSS and through
the Decommissioning Management Board to provide oversight with the power
reactor licensees.
DR. WYMER: I think you said too that the fuel when it's
transferred into dry storage is taken apart. Is that right? Did I hear
that right?
MR. RICHARDS: No, I don't think so. No. The fuel is -- a
canister will hold a number of assemblies, but the fuel remains intact
when it's shipped, or it's placed in dry storage.
DR. WYMER: I thought I heard him say it was taken apart and
therefore it couldn't be put back into the pool.
MR. RICHARDS: No, I think Mike Masnik said that what
happens is that one of the purposes of moving the spent fuel into dry
storage is it then allows you to dismantle the building that contains
the spent-fuel pool. So --
DR. WYMER: I was going to say, I didn't think the
reactor --
MR. RICHARDS: Yes.
DR. WYMER: Taking the fuel apart.
MR. RICHARDS: The advantage there is you end up with a
small area on the site that has fuel in dry storage --
DR. WYMER: Yes.
MR. RICHARDS: Relatively simple to maintain, and then you
can dismantle the rest of the buildings, hopefully terminate your Part
50 license, and release the site except for that area that the ISFSI's
in.
DR. WYMER: I must have misinterpreted what he said.
MR. RICHARDS: Okay. Part of our process is to keep the
public informed. There is quite a bit of public interest when a plant
goes into decommissioning. The public wants to know what's going to
happen to that facility, and it's interesting that how often we go to
these public meetings and find out that people are somewhat comfortable
with the facility being there, but then they're uncomfortable with the
fact that now it's going to be dismantled and taken apart, and the
material moved on highways and what have you through perhaps their
neighborhood. So they have a considerable amount of public interest in
what goes on in decommissioning.
We participate in those public meetings frequently with NMSS
in attendance also. We usually have a public meeting when they submit
their postshutdown decommissioning activities report -- they have to
submit that within two years of shutting down -- and then again with the
license termination plan. It's also not uncommon that the local
citizens will have interest in the plant, and there may be requests to
go to other public meetings. For instance, at Maine Yankee, they have
an advisory panel that meets on a monthly basis, and the NRC
participates routinely in those meetings.
We are the program office for inspection activities at
decommissioning power reactors, and we control the inspection program.
We work closely with the regions to ensure that that program is
accomplished.
At power reactors when they're operating normally we
maintain a full-time resident staff. When the power reactor shuts down
and enters decommissioning, usually about six months to a year after it
shuts down, there will no longer be a full-time resident staff at the
site, and the time spent doing inspections at the site's commensurate
with the level of activity going on as far as decommissioning goes.
I'm not going to read the slide to you, so unless there's
any other questions, we'll move on.
This slide discusses briefly one of our major activities
over the next couple of years. The industry has basically complained
that when they go into decommissioning, the process is not very
efficient, that the Part 50 regulations are written for operating
reactors and don't reflect the decommissioning process. As a
consequence, as I mentioned before, they typically come in and need to
request exemptions from various requirements. A number of these
requirements are quite expensive until they can get relief from us.
Examples include financial protection offsite, security requirements,
emergency planning, and they would prefer not to have to go through the
lengthy review process to get exemptions from those requirements.
What we've undertaken is a two-step process. This process
has been described to the Commission in SECY Paper 99-168, it's before
the Commission, and we're seeking their approval, but right now it's on
a little bit of a hold.
What the paper basically says is that these few steps
include first off a Technical Working Group that is assessing the risk
associated with decommissioning plants. And primarily the risk for the
surrounding population initially after the plant shuts down is centered
on the spent fuel, and the probability that the spent fuel could have a
zirconium fire, which would release, of course, the material offsite.
So the Technical Working Group is trying to put into perspective the
risk of that occurring.
Once we've completed that work, we intend to factor the
results of that review into a new regulatory structure, and what we
proposed to do is to take Part 50 and other parts within Title X, review
it for applicability to decommissioning plants, and then separate all
those requirements out and put them in one location within the
regulations to the degree we can, such that when a plant enters
decommissioning, instead of having to go through a lot of amendments and
exemptions on a case-by-case basis, we hope that plants will be able to
transition into this new part and a lot of these things will be
implemented basically automatically as long as they meet the criteria
laid out in that part, and that'll cut down a lot of the resources both
for the industry and us.
And hopefully save us resources, but at the same time
maintain the same level of safety. In addition, we're putting together
some other regulatory guides on various issues associated with
decommissioning. We've got a lot going on there.
Any questions on this side?
[No response.]
MR. RICHARDS: This slide lays out some of our principal
activities for fiscal year 2000, describe some of the things that we're
spending the majority of our time on. We do have various licensing
reviews; the licensure measurement reviews for Trojan, Main Yankee, and
we're expecting Connecticut Yankee to come in.
Defuel tech spec conversions, again, that gets back to
utilities seeking to save cost by eliminating requirements that don't
make any sense for decommissioning plants.
Planning basis is that we have one additional power reactor
entering the decommissioning phase each year and we are anticipating
that occurring for many years out. Of course, that's yet to be seen
whether that will come about. But for planning purposes, that's where
we're at.
We're dealing with partial site releases at four facilities
right now. We're, also, involved with the ISFSI issues, the licensing,
and then the loading of ISFSIs. I've already mentioned the public
meetings and, of course, we work extensively with the regions, as far as
inspection and oversight goes.
In summary, in NRR, there's a lot of work going on in the
decommissioning area. I'm very fortunate to have a good staff doing a
lot of very good work and I think we're getting on with the problem.
That's my last slide and I'd entertain any questions you have.
DR. GARRICK: With the experience that you have with Yankee
Row and Trojan and Ft. St. Vrain and Pathfinder and Saxton, etc., etc.,
I would guess that you have -- you're beginning to accumulate a
considerable amount of tricks of the trade, so to speak, or lessons
learned or areas where technology is needed. At some point, it might be
useful for this committee to get a kind of technical lessons learned
summary of our accumulative knowledge so far in decommissioning. Is
that something that maybe downstream we could have you do?
MR. RICHARDS: I'm certain that we can. I'd like to work
with NSS on that.
DR. GARRICK: Right.
MR. RICHARDS: There's kind of two angles on this. I think
in the initial phases of decommissioning, the tricks of the trade, so to
speak, are how can we move quickly from an operating reactor status to a
decommissioning reactor status and that's primarily working through the
licensing process with us, perhaps has to do with how you treat the
spent fuel initially. And the industry has learned some tricks of the
trade there.
DR. GARRICK: Well, one of the big discussion points, of
course, is the size of components that you can remove --
MR. RICHARDS: Yes.
DR. GARRICK: -- maybe the most outstanding example being
the reactor vessel from Trojan and how much does that experience relate
to other sites that might engage in a similar approach. That option is
not available in some cases, but it's still kind of important, it seems
to me, to appreciate what the implications are of having flexibility on
how to decommission and decontaminate a site. So, you know, we don't
have standard plants, but maybe we can move in the direction of a
standard decommissioning process, to the extent that resources permit
and disposal sites allow. But, I think we would be very interested in,
on the basis of the experience to date, what really are some of the
bottlenecks, trouble points, opportunities for streamlining this whole
process.
MR. RICHARDS: Good. We'd be glad to come back and provide
a more detailed presentation on that, in conjunction with NSS.
DR. GARRICK: Good. Again, I think that would be good. I
think the committee would be very interested in that.
MR. RICHARDS: Any other questions?
[No response.]
MR. RICHARDS: Thank you, very much, for your time.
DR. GARRICK: Where are we, Ray? Oh, there he is.
MR. ORLANDO: Well, again, good morning. I'm back to talk a
little bit more about the standard review plan that we're developing to
support decommissioning. Just to recap the milestones real quickly,
we've indicated, in our staff plan that we had put together, that we
wanted to develop the default tables, identify the technical and policy
issues by December of last -- of '98, and complete our draft SRP modules
by June. The next big step is to look at the comments on the DG-4006,
which the comments were due the end of last month; but if you have
comments, Research has indicated that they'll take comments out for a
couple of more months. This is based on some comments that were request
-- or that were made at our last decommissioning workshop, and I'll talk
about the workshop in just a second. The next thing we want to do is
submit the draft SRP up for final review and then publish it in July of
2000.
Now, yesterday, Bobby went over some of the things in the
standard review plan that the Commission issued regarding the SRP. And,
principally, the Commission told us to publish the draft guides, the
U-4006, we did that; provide them with a time line, which we did; work
towards developing the more user friendly standard review plan, include
ACNW in the review, use the probabilistic approach for the teddy, review
the conservatism, and test the D&D on a complex site. Now, Bobby went
over the last three bullets with you in some detail yesterday and I
think you're aware of what we've done, as far as the first four.
What I'd like to do is start in your packages and talk a
little bit about how we are maintaining a dialogue with the public
through the comment period, how we're ensuring that the standard review
plan incorporates an iterative risk-based approach, and ensure that the
standard review plan provides clear guidance on what constitutes ALARA.
And I'd, also, like to talk to you a little bit about what you can do
for me, with regard to the standard review plan.
Okay. As far as maintaining a dialogue with the public,
we've had several workshops, starting in December of 1998. The first
one focused principally on dose modeling. The next two or three focused
on dose modeling for one day and they were held in January, March, and
June of '99. Those focused the first day on dose modeling and then the
second day on different issues, restrictive use, ALARA. The one in June
focused on ground water modeling, which was dose modeling entirely. And
now, our last workshop that we held back in August, we talked about --
we have one day that was devoted to license termination plan; then the
next day, we opened the morning up to the states and they presented
their perspectives and views on decommissioning; and then in the
afternoon, we talked a little bit about surveys and what would -- what
was needed for surveys for decommissioning.
We had anticipated having one more workshop in October. But
based upon the fact that we had pretty much covered all of the different
issues -- issue areas that we had identified and had discussed a lot
with the stakeholders, gotten their input, gotten some technical input,
as Bobby talked about yesterday, getting some resuspension factor data
from licensings and what not, and given the fact that we had published
for comment most of the standard review plan modules, we decided to put
the last workshop off until February of 2000. And that workshop will
probably focus exclusively on taking verbal comments, not to the
exclusion of written comments, but discussing the standard review plan,
seeing if anybody has any questions about what we've said, maybe some
things they just want to talk about, opening it up for at least two days
to just talk about that with both the industry and other stakeholders.
And I don't mean to indicate that the industry is not a stakeholder, but
I think we tend to say stakeholder and kind of consider that to be
perhaps the folks, who would consider themselves to be environmental or
citizens groups.
What I had proposed during the last workshop was perhaps to
have four sessions: one for the nuclear power industry; one for fuel
cycle folks, the material folks; one for the states; and one for
interested non-industry types, or perhaps we can do it as just a more --
I don't want to call it a free for all, but just more of an integrated
approach. I'd like to give everybody an opportunity to make their
statements and sometimes it's easier if people are up there with folks
that they'd feel more comfortable, as opposed to being at the table with
people that they don't feel particularly comfortable with. So, I'm
going to work through that, probably propose that and see if I can't get
anybody to give me their feedback on that. And I, obviously, take the
ACNWs input on that issue.
We have, also, established a Website -- or, actually, we had
had -- Chris Daley, in the Office of Research, had been -- had
established a Website through the Lawrence Livermore National
Laboratory, where we had posted the different SRP modules and agendas
and things like that. We have been able to hyperlink that to the NRC
external Website. Now, instead of an individual having to go actually
out to LANL to find the SRP modules and whatnot, they can just go to the
NRC external Website, go to that page, go through -- go to NRC, go to
radioactive waste, go to nuclear facilities decommissioning, go down to
special projects, and it's listed.
We've, also, posted all of the transcripts of the meetings
on that Website, and those are at a separate place that they can go out
and either download it as an HTM file or Word Perfect file. So, people
can actually see what was said, which is kind of scary, because
sometimes I don't realize what I've said. So, as far as maintaining the
dialogue, that's what we've done.
Now, one of the other things that the Commission told us to
do was use a risk-informed iterative approach to -- in developing the
standard review plan. Well, we took a look at that and tried to think
how can you do something like this. The standard review plan, and I'm
sure you've all have seen standard review plans, they tend to address --
they are typically laid out in a sequence, such that it says here is
what we want, here is what we accept, here is what we think should be in
a particular document, here's our acceptance criteria for that. To
develop something that was risk-informed and allowed for an iterative
approach, we could either do -- make one big SRP that said go forth and
do good, because then you would make all of your decisions based upon
that criteria; or we could go the other route, which is the way that we
decided to go, which is to develop very, very, very detailed
prescriptive SRP modules.
Once you all start taking a look at them, you'll see that
there is an awful lot of information being requested by the staff in
there. It's important though to recognize one thing, and that's that we
don't expect every licensee to turn in or to submit all of that
information. And here's how the risk-informed part comes in. What
we'll do is establish, in a couple of -- probably in the NMSS
decommissioning handbook -- I'm not sure if you all are familiar with
that tune, but that's it. If you want, I can provide you with a copy.
The NMSS handbook -- what we do is establish the minimum
information needs in the revised NMSS handbook. Now, in the NMSS
handbook, what it talks about -- I'll go ahead and just pass this around
-- it sets up what we call decommissioning types, and those are based,
at least in that version of the handbook, on the type of radioactive
material that a facility would have or the type of activities that it
undertook, and it lays out in the handbook the steps that the staff and
the licensee would be expected to undertake to decommission that
facility. Now, that's not meant to be a technical review document; it's
more of a framework kind of document. Like, the staff will do an
acceptance review, it doesn't tell you how to do an acceptance review,
it just says the first thing you'll do is an acceptance review;
establish a TAC or RITS number; you'll have this meeting or that
meeting. And it gets into a little bit what needs to be in
decommissioning plans and things.
But what I would anticipate doing is taking and revising the
decommissioning types, so that they more align themselves with how is
the licensee going to decommission. In other words, are they going to
just use default parameters, you know. First of all, the first type of
licensee that we have out there or, in fact, the majority of our
licensees will never turn in a decommissioning plan. What they're going
to send us is a Form 314 and a statement that says, I've sent all of my
sealed sources back and I'm taking down all my signs, and that's the --
because most of our licensee are sealed source users or gauge users or
something like that.
Other licensees perhaps would -- or another type of licensee
may turn in some information, but not a whole lot. That could be
perhaps a small hospital that has a little nuclear medicine laboratory
that they were only using technetium-99. Well, to decommission that
facility, all you've got to do is send your dose calibrated check
sources back, send us a little note on a 314, and say I sealed up the
room for 20 -- for six days. Well, technetium-99, as you know, 60
hours, it's pretty much gone, any contamination that would be around.
So what I would anticipate doing is revising the
decommissioning types in here to better look -- to more align themselves
with the type of decommissioning that the licensee is undergoing, as
opposed to what they did when they were an operating facility. So, you
may have a generic type or just one that uses just the screening
numbers; one where perhaps you have just internal surface contamination
just in the building, nothing outside; maybe another type would be --
and perhaps they would use a little bit of dose modeling; maybe one
where you'd have a little bit of soil contamination and a little bit of
internal structural contamination and perhaps they'd modify one or two
of the parameters, so they do a little -- some very limited site
specific; another type would be where you would -- where the licensee
would intend to submit all site specific -- I mean, they come in with
whatever code they were going to use and they would say, you know,
here's all of the environmental data about our site, here's what we
think the dose; then, perhaps, the last type might be sites that are
going to decommission under the restricted use criteria.
Again, the idea would be to establish these minimum
information needs, using the SRP to evaluate what the licensee
submitted. So, what could happen is, in the handbook, is for type one,
it might say, you would -- you would submit bullet one, three, five,
seven, nine, and fifteen of SRP module on environmental information, or
something like that.
The next thing that would be part of this, and this would be
in the SRP, is that we would meet with the licensee before they turn in
a decommissioning plan. As you know, licensees, under the licensee
timeliness rule, are required to inform NRC staff within x amount of
time, about two years, of permanent cessation of licensed activities.
They have to submit to us a notification that they permanently ceased
operation. They, then, within a year, either have to submit a
decommissioning plan or submit -- and begin decommissioning or complete
the decommissioning.
Once we get that information that a licensee has decided to
permanently cease operation and is going to be submitting a
decommissioning plan, what the staff would do would be meet with the
licensee to start going through and discussing with them what did you do
at your facility, you know, where do you fall in this general matrix of
sites and decommissioning types that we have, talk about the SRP, talk
about what information needs the staff may have, and, in effect, scope
out what the decommissioning plan is going to need to have. So, we
would make a risk-informed approach as to -- or incorporate the
risk-informed approach in the submission of the decommissioning plan,
using both the SRP and the handbook.
And I have to work through a lot of the issues associated
with modifying the handbook and incorporating all of that. But when
you're going through the standard review plan, remember that that was
written for essentially the worst case scenario that we could come up
with. Every piece of information that we could think of that needed to
be -- conceivably could ever be asked, should be outlined in that. It
doesn't necessarily mean we're going to ask every licensee to submit all
of that information. So, just keep that in mind when you're reading it.
And then the iterative approach is obvious with the meeting
with the licensees and doing the acceptance review and, as Larry was
talking about earlier, having licensees come in with novel concepts, as
part of the decommissioning process. And coupled with that is a
directive by Dr. Paperiello for a streamlined approach to licensing
actions and it includes several components, including ensuring that the
reviews are within our philosophy; develop technical evaluation reports,
as the basis for developing questions. The focus there is to only have
one request for additional information or RAI per each submission. And
one way that we can address that, and we'll talk about it in what I call
the how-to-use section of the standard review plan, we'll discuss this,
but one of the things we want to make sure we do is, you know, if
licensees have questions or there are issues that need to be discussed
during our review of the decommissioning plan, we call the licensee and
have a meeting.
The meeting would be opened to observation by members of the
public. Typically, at the end of those meetings, we'll let members of
the public ask questions. We'll typically do those through the normal
business day, so they're not necessarily done in a public meeting with a
capital PM form, but they are opened to observation by members of the
public. At the conclusion of the meeting, if any resolutions are made
or any qualifications are needed, that's summarized in a meeting or
summary and then that's made available to the public through the normal
document process. Again, we want to limit the RAIs to a single set.
And as I said, we'll incorporate this approach and have incorporated
this approach into the standard review plan.
The next thing the Commission asked us to do is give clear
guidance on ALARA. We've taken two tacks on that in the SRP. The first
one is that if a licensee or responsible party doesn't have to make any
ALARA demonstrations, if first they have done some kind of housekeeping
-- it's actually the second bullet up here; sorry about that -- and they
can show that the facility meets the generic screening levels. What we
were concerned about and what the region specifically said was that they
didn't want to be in a situation where a licensee can walk into a room
that nobody had gone into for five years, it was covered with dirt and
dust and trash, do a couple of wipes, wave a meter around, and come back
and say, hey, it meets your screening levels, I'm done.
That's not the idea. The idea is that the licensee would go
in and do a cleanup, do some kind of good housekeeping type cleanup:
clean the walls, wipe everything down, get the facility in a reasonable
shape, then do their surveys to demonstrate that the facility met the
generic screening levels. And at that point, we would go ahead -- as
long as they made the demonstration, then we'd go ahead and say that
they did not have to make -- or do any separate ALARA demonstrations.
Another way we're addressing it in the SRP, and it's not
discussed here, is that Chris McKinney has developed some guidance on
doing what I think of as rolling ALARA assessments and that's, as they
are -- as the licensee is going through the process, they sometimes have
to make a judgment as to whether they need to continue cleaning at a
certain level or perhaps they can go a little bit -- a little bit
further on, and that's discussed in the ALARA section of the module --
excuse me, the ALARA module of the SRP.
Now, as far as maintaining the SRP, one of the things we
think -- we're thinking about doing is, clearly, we're going to publish
it -- we're not thinking about that, we're going to publish the SRP in
July of 2000. One of the things that I found when we published the
decommissioning handbook, and you can see my name is the first -- is one
of the names on the author list there, is that we had sent the NMSS
handbook out for review and comment by the regional folks and they had
done a pretty good critique of it and given us some information on
things they thought needed to be changed, and we incorporated all of
that.
But, until you actually go out and use a guide on a site or
in a real world situation, you don't really know if it's going to work.
There are some things you can identify that will or won't work, but it's
been my experience that, you know, you've got to drive it a few miles
before you find out if it's actually going to run. So what we intend to
do is publish the SRP as a final, but then with a planned revision maybe
two or so years down line. And we'll track issues and problems that we
have in implementing either one of the philosophical approaches or some
of the information needs, you know, or whatever, just keep a list of
them. And then at the end of that two or so year period, reconvene the
whole SRP workshop process, get every -- we got everybody, who was
there, get them back in the same room, and say, okay, here's the
problems we've identified, do you have anymore, let's start thinking
about solutions, let's think about a better way to make this thing -- to
make this work.
DR. WYMER: Doesn't that sort of open up this question of
finality again?
MR. ORLANDO: Well, that's why we would issue it as a final.
DR. WYMER: Yeah, but then you're going to go back and
change it.
MR. ORLANDO: We're not -- I don't think we're going to be
changing too much. The dose numbers, I don't think, are going to
change. I don't know if dose modeling is going to change. Hopefully,
that's going to be a pretty strong module in and of itself. So, I don't
think where that's going to be a problem. I'm thinking more along the
lines of some of the other things. So, for example, who needs to submit
certain information; perhaps, it's superfluous, instead of constantly
requiring more rocks; and just maybe problems in just the implementation
process, you know, is the information getting out the way it should be,
you know. In a couple of years, perhaps, we will have had a few
restrictive release cases come in. How did we handle those; how can we
handle those better, things like that.
And like the previous couple of speakers, the other -- the
last thing I'd like to leave you all with is what you can do for me.
We'd like to get your review and comment on the draft SRP modules, and
let's change that to November -- no, I'm just kidding. We're giving
everybody else until February, so --
If during the course of your review, and even if you want to
schedule it now to maybe target completion of your review, if you'd
like, I'd be more -- we'd be more than happy to come in and discuss
individual modules, individual information requirements, whatever, in
the modules. The only thing I would ask is that you let us know which
ones you want to talk about, so that -- because there have been several
authors for some of these things, and it would be nice to be able to
have them available to answer questions about what they were thinking of
when they were doing and things like that. Keep in mind that all of
this is out for draft. We're going to be getting comments from the
public. In addition, if you would be interested, you know once we get
all of the comments in and get them compiled, perhaps we'll come back
and give you a little talk on what was the reaction and what were the
principle comments made. So, you know, there are some more
opportunities for the ACNW to participate in the process and I'll leave
it up to you all to let me know when you want to do it.
Having said that, I'll shut up and go answer questions.
DR. WYMER: Are there questions?
DR. GARRICK: Yeah. We need to study this a lot more before
-- especially me, before I get nasty.
MR. ORLANDO: I appreciate that.
DR. GARRICK: One of the things that kind of bothers me
about this whole process is that we seem to be talking out of both sides
of our mouths. On one side, we're talking about streamlining and
risk-informed that is supposed to relieve -- provide relief to
licensees, etc; and on the other side, we're prescribing the hell out of
everything, which seems to be a total contradiction to the underlying
philosophy that we're supposed to be implementing, at this point. And
as I say, I haven't studied the modules enough to know, but I see
prescription all over it, and even to the -- even to the level of the
number of pages that you use to address the specific issues and what
have you. And just from a global perspective, I just don't think we're
getting it. I don't think we're moving in the direction that it is
intended by the spirit of what the Commission, at least my
interpretation, wants. What am I -- what am I reading wrong here?
MR. ORLANDO: Well, I will agree. If you -- and as I said
earlier, if you look at the modules and say everybody has to turn this
in and this is exactly what everybody has to turn in, yeah, it is very
prescriptive and it's very long and it is -- it does get into, you know,
length of suggested -- well, I would say that is suggested length of
pages. The idea, again, is this is a tool for the staff to use, okay.
And in some cases, you -- the people, who work in the decommissioning
group, at least the ones that I work with, what we wanted to do is
provide them with a tool that addressed all of the issues that they may
have to face, like how do you know what to turn in, how do you know what
to ask for, how do you evaluate something that you get from a licensee.
I don't think anybody -- at least I don't feel that I'm capable of
sitting down and looking at every technical aspect of every
decommissioning plant and knowing that the correct answer is. So, this
-- the SRP is meant as a guide, to say, okay, if you have this, then
here's what you've ask for.
The key is to say, okay, what do you ask for, and that's in
the how-to-use part. And there, again, we will try and identify only
those pieces of information that the staff really needs, in order to
make the assessments that they're supposed to make to approve the
decommissioning plant. Decommissioning plans say what has to be in
them. I mean, that's outlined in 30, 40, 70, and 72. And, you know, so
a licensee has to turn in certain chunks of information. What the SRP
is supposed to do is to help guide the staff through, okay, this is what
we need.
Now, as far as being helpful, it seems to me that if you
come up with standard requests and standard evaluation criteria, then
the licensees know what they're going to be expected to turn in; the
staff knows what the licensees are going to be turning in. And when
that comes in, it makes the review go quicker and better, because the
staff can say, okay, it contains this, this, this, and this; here's the
reg guide perhaps I have to go to; here's this what I have to go to, as
opposed to a staff member going, you know, how does this work; let me
think about this; here's yet another issue that I'm not familiar with.
I guess to sum it up, yeah, if you look at them just and
say, here's all the SRP modules, here's -- they are -- they do come
cross as very prescriptive. The key is in how you implement it.
MR. CAMPER: Can I add something to that?
MR. ORLANDO: He's my boss, so he can add as much as he
wants. Yes.
MR. CAMPER: I just want to add a comment. I think your
comment is exactly on the mark. I mean, one of the first questions that
I asked Nick when I came to the branch and started looking at the SRP
was the question you just asked, because I looked at the SRP and like
you, I thought it was terribly prescriptive.
I had, in a previous job, led an effort to update and
consolidate something on the order of more than a thousand guidance
documents in the materials area and we turned them into the NUREG-1556
series, which will be about 24 volumes. And the idea is if I want to
deal with radiography, I go pick up radiography or well log or what have
you. And what we did, in that effort, was each team that was put
together to write the guidance document was challenged to make the
document as risk-informed and performance oriented as possible, to make
sure that anything we were asking for or alluding to in guidance base,
there was a clear regulatory basis for asking for it. What did we do
with it once we got it? Did we really need it. Were we building in as
much flexibility as possible?
Now, in the perfect world, you would start off under a
risk-informed performance oriented approach, whereby you would make all
of your regulations, in the first instance, risk-informed and
performance oriented and from that, guidance would flow. Well, that's
not what's happened. What's happened is the risk-informed performance
oriented issue is an issue that the Commission has directed the staff to
do and they have asked us to start doing it now, make it happen now.
Well, you don't have the luxury of going back and changing all of your
regulations to start reacting now. What you do, though, is that at
every opportunity, at every juncture, you try to bring to bear
risk-informed performance oriented approach.
Now, in querying Nick on this particular document, he
offered what I thought were two interesting insights. One was that
unlike the operating world, be it materials or reactors, licensees
typically go through decommissioning once or they might go through, in
the materials world, decommissioning portions of their site over time.
But, generally, it's a one time or not more than a couple of times type
of thing and, therefore, the need for information seemed to be there.
You didn't have years and years and years of operating experience to
draw upon. So, there was value in providing this lengthy detailed push
to information as a useful tool. Well, that's okay. I can conceptually
live that.
But what are we going to do to make it very clear that all
of this stuff doesn't apply to everybody and that here are the
guidelines and you have flexibility built into it, in terms of
customizing your program following this guidance? Well, Nick is
currently working on a sort of how to use the SRP, if you will, and that
particular chapter is going to do as much as we possibly can to bring
the flexibility to bear, make it clear that you may use this guidance or
those parts of it that fit for your particular program or need and that
it is only guidance and you may modify your program or develop
alternatives.
So, I think that where we need to get at that, and we would
frankly appreciate a great deal of scrutiny on your part when you look
at that particular chapter, have we done what we could do to build in
that flexibility. But that's sort of, you know, how we're handling it
and why and, again, I would reiterate that I thought your comment was
right on the mark.
DR. GARRICK: Thank you.
DR. WYMER: When will we have that chapter, Nick?
MR. ORLANDO: Well, I had hoped to have it done actually by
this meeting, but I've been kind of pulled away to address some waste
issues, another hat that I wear. So, I'm hoping within the next couple
of weeks. It will have to go to the decommissioning management board
first for their review and, you know, then it will be released to you
all. Hopefully, we'll have -- just to give you an update on the other
draft modules, I hope to have the first two or three modules of -- some
modules of module five, which is the dose modeling that Bobby talked
about yesterday, they should be being finalized this week, I hope.
DR. WYMER: Thank you.
DR. GARRICK: Thank you.
MR. ORLANDO: Is that it? Thank you, very much.
DR. GARRICK: Who is going to present the continuing
discussion of the D&D and RESRAD?
MS. TROTTIER: This is called management support.
[Laughter.]
MR. LARSON: While Cheryl is handing them out, would the
committee sometime be interested in hearing how the pilot program went,
which was supposed to be related to the development of the SRP, and
would you eventually still want to hear, you know, one of your comments
in your original letter on the decommissioning of a complex site, using
D&D, etc., so that you can --
DR. GARRICK: Given that we made an issue of it in our
letter, I think, yes, we would like to hear about that.
DR. LARKINS: Of the steps of yesterday, they hadn't done
it. They did two simple sites and we're working on doing a complex site
later.
MR. LARSON: Yeah, they did, but there are several parts.
One is a pilot program, which is supposed to be, you know, industry
volunteering to implement this SRP and then the other is the complex
site, which someday the committee indicated they'd like to hear.
DR. LARKINS: Some day.
DR. GARRICK: Okay.
MR. OTT: Okay. I think this is the first time I've come to
you since we've reorganized. I think the last time I was here I was
wearing too different hats. Since then, we are now a single branch,
where Cheryl is the branch chief, I'm the assistant branch chief, and we
have merged the two programs. Things like RESRAD and D&D are now
actually considered to be part of the overall development that we were
doing with SEDSS.
I'm going to start off with a brief overview of what we're
doing in general for decommissioning. This just -- I mean, you've had
NRR and NMSS go through a rather lengthy discussion of everything
they're doing. We're focusing primarily on RESRAD, D&D, and SEDSS here
today, but I just wanted to list for you all those things that we are
doing that relate to those 10 FTEs and $2.3 million that were listed
earlier in the NMSS slides.
We are providing a significant effort with regard to the
technical basis for clearance rule. We've got two different efforts
going on: one with Bob Meck, which is a very large contract with SAIC
that was just let on the technical basis for clearance, in general; and
we've got a smaller effort that Tom Nicholson has placed through the
U.S. Department of Agriculture, the Agricultural Library over in
Beltsville. He's looking at soil clearance and trying to find out, you
know, what the people use soil for. That particular effort is ongoing
right now.
We're doing significant amount of process modeling, which
usually primarily comes from the radionuclide transport program. We're
looking at absorption modeling, both USGS and Sandia and cooperatively
through the NEA absorption project. It's an international effort.
We're looking at conceptual model uncertainty at the
University of Arizona -- that's another one of Tom Nicholson's project;
malignant barrier performance at NIST; and we, actually, have had some
contacts from people that are talking about things like entombment, with
regard to the program that was developed at NIST for long-term
performance of barriers -- concrete barriers. So, we're actually
finding that something that was started out to deal with covers and
barriers for low-level waste disposal is actually having applications
beyond that.
We've got the work that's being done on slag degradation at
Johns Hopkins University at PNNL, and then radionuclide solubilities at
PNNL.
DR. WYMER: Right on the face of it, that looks like there's
a lot in common with the modeling that goes on with -- in connection
with the Yucca Mountain Repository. To what extent are those integrated
or do they --
MR. OTT: There's probably a lot that's of value to the
Yucca Mountain program. Our limitation is that we don't do anything
that is specifically only applicable to the Yucca Mountain. So, if
anything gets in the area of things like elevated temperatures, we're
not working on it. If it's particularly related to things like seismic
effects or vulcanism, those programs were terminated and transferred to
NMSS.
DR. WYMER: But, you do integrate with respect to the type
of modeling that you do and the --
MR. OTT: Yeah.
DR. WYMER: -- type of codes that you use and so on?
MR. OTT: Right. And as a matter of fact, things like the
NEA absorption project, we have contacts down at the Center for Nuclear
Regulatory Analysis. We provide them with copies of documents and they
review them and things like that. So, there is a connection between
that. We try to keep in touch as much as we can of what's going on with
the program.
In terms of integrated performance model -- assessment model
development, we're doing the work that we're going to talk about for the
next few minutes on RESRAD, D&D, SEDSS, and there's actually a small
effort going on with PNNL, which is looking at parameter distributions
primarily for the hydro models.
And the last issue there is the one that you dealt with for
a few minutes this morning on entombment. The entombment paper went up
actually July 19th. July 19th is when the Commission paper went up. I
don't have the number on it, but you can probably track it from the
date, if you want to get a look at it.
There is the workshop scheduled for December 15th -- 14th
and 15th. Recommendations are officially scheduled to come out in
March. We'll probably -- we can easily come in in January or February
and talk to you, as Cheryl suggested. One observation I might make
about entombment is that there are a range of options for entombment, as
there are ranges of options for almost anything you do. And part of
what's being discussed is -- some of the things that are being more
seriously discussed here, in terms of options, are to remove everything
above Class C, all waste that's above Class C and activity will be taken
offsite and disposed of elsewhere. So, it's one of the options that is
under consideration.
DR. GARRICK: Bill, just to give us a sense of the size of
this effort, what is the rate of expenditure for what you just put on
the board, approximately?
MR. OTT: It's about $2.3 million a year.
DR. GARRICK: Yeah; okay.
MR. OTT: That doesn't necessarily -- we took what was
basically the radionuclide transport budget, some of the activities have
been moved into it; some, like the clearance activities, is outside of
that particular amount of money, so there's another $600,000 that's in
one of the clearance contracts. Actually, the soil -- the soil money,
I'm not certain which bin that came out of. We're still working under a
budget structure that has three bins in it: reactors and materials and
decommissioning.
I'm going to talk a little bit, before I actually get into
the three codes that we're working on, about what the objective of this
program is looking at these three different codes. We've got a range of
sites out there. We've got a range of contamination program --
problems. And you don't necessarily want to develop one code that
addresses all problems, because, in many cases, you'd be developing a
tool, which is way too complex and way too difficult to run to handle
many of the problems. So, we're looking at a set of tools for dose
modeling that's well matched to the range of complexity of sites and the
range of source term. So, we want something that we can handle. It's
really much simple to handle simple sites, something with model
complexity to handle the more difficult sites, and something that is
really sophisticated to handle really -- considered to be the really
problem sites.
Now, we, essentially, are working on D&D and SEDSS. RESRAD
is a program that was developed by -- well, let me go do this in order.
D&D: D&D is developed as a very simple tool for screening. The concept
of screening is to be able to get rid of sites that aren't really a
problem, without spending a lot of effort of them. If you get to the
point where -- that the screening model is predicting that you are near
the margin, you want to step back and take a look at it. This
particular version will take -- well, I'm not going to talk about each
one of them individually. I'm not going to go into detail right now.
The original objective was to provide a model that doesn't
have any need for a large amount of in situ data. I've got a simple
contamination. I think it's so small and I think that it's so well
localized, that I don't really have a problem. You use D&D. It
confirms your guess and you're done with your problem. That's what D&D
was designed for, very, very simple situations. It turns out that
they're putting a little bit of site specific ability into it. We can
make it applicable to a wider range of sites, a little bit more
sensitive. And if you look at what's being done -- we'll talk about
that later.
Okay, RESRAD: we're developing at Argon a probabilistic
version of RESRAD. RESRAD, as it currently exists, is a deterministic
model. And it was decided that it was needed to have something that was
more in keeping with the ability to look at distributions of parameters
and key assumptions, the fault values. We're looking at giving RESRAD a
pedigree, which goes in and looks at all the problems that people have
looked at in D&D, and say, this is a problem with D&D. The RESRAD
people go ahead and ask those questions.
Sandia Environmental Decision Support System, we've talked
to you about that a number of times in the past. It's primarily being
designed to look at more complex sites, being able to bring in more
complex models, more context search term models. It's one -- it's a
general tool that is not designed to just be dependent on one given
module for any given particular calculation. If a 1D groundwater model
doesn't work, SEDSS will be able to bring in a 2D groundwater model. If
a 2D groundwater model doesn't work, it will be able to bring in a 3D
model. You may know from the start that you want to use a 3D model.
You go directly to a 3D model. It will depend on a lot of things and
exactly what your problem is.
Let's look at where we are in D&D. Version I is out. It's
been available since I guess last -- last July. It's testing potential
users. There's -- we're getting comments over the Web. The comments
are being considered by Sandia and summarized. Chris is here. If
anybody wants to know what -- get an idea of what the character of those
comments are, she can address that. I get the impression that a lot of
them are, you know, which button do I press and how do I do this. So, a
lot of the comments aren't coming back, you know, this is a real problem
with D&D. It's more a question of how do we use it.
NUREG/CR 5512 Volumes I and II are available. Three and
four are in the process of publication. Basically, what that means is
we sent them down to publications and they just sent them back to us for
some formatting changes. And we've got to get that fixed and send them
down to them again. Volume IV is the comparison between RESRAD and D&D.
I read that in the draft form and it's a very interesting document. You
asked the question yesterday, is RESRAD always conservative, and the
answer is no.
The detailed comparison in NUREG 5512 Volume IV tells you
exactly what kinds of assumptions are made in RESRAD and in D&D on
comparable parameters and comparable considerations. And it tells you
those areas where RESRAD may have assumptions in it that really need to
be fixed, as well. So, in the final analysis, you can look at RESRAD
and find situations under which it doesn't really do a very good job
either. That's not something that's unexpected. That's typical in
models like this.
We're going to have a training course for Volume I of
Version I of D&D in October and November. Ralph Cady is going to be the
one that actually presents the course. It's going to be presented here
at headquarters and out in the regions. He's been working on it for the
last three or four weeks, in terms of putting it together.
In the future, we're going to have Version II, which is
going to be fully probabilistic. We had a -- we actually do have a
version of D&D that's probabilistic, but it's not user friendly. So,
the Version II that's going to come out here is going to be a user
friendly probabilistic version for anybody's use. The first version of
that will be available in October. We expect to be able to release it
to the public in March of next year. Documentation of the testing
period and any adjustments that were made during that period will be
available about two months later. We're going to have training in May
and June of 2000. This training will be developed and run as part of
the contract with Sandia.
DR. LARKINS: If you are trained on Version I, do you need
to be trained on Version II?
MR. OTT: Yes. Essentially, the training on Version I won't
tell you how to use the probabilistic drivers.
RESRAD: if you look at the numbers on RESRAD, you've got
Version VI of RESRAD and Version III of RESRADBUILD. These programs
have been around for a long time. Bobby used the words yesterday that
RESRAD has been validated and I forget what the other word was. It
doesn't matter. To say it's been validated is probably a little strong.
It has been compared to other codes and -- benchmarking was the other
word -- benchmarking exercises. In talking to the staff today, one of
them mentioned that, in one of these exercises, the conclusions came out
that RESRAD did a very good job of reproducing the data. It then made
the observation that they were so close because of compensating errors.
The staff member wanted to say fortuitously compensating errors.
This is, also, something that's not unusual. When you've
got a complex code and you've got a mistake in one place, a mistake in
the other, they can quite often cancel out. I think that once Tin's
contract -- Tin Mo is the contract manager for the Argon contract that
we've placed on RESRAD, we will probably have a much stronger pedigree
on what is in RESRAD, in terms of the basic assumptions and where there
are conservatisms and what the conservatism there is than currently
exists in the RESRAD documentation. This will be an NRC version of
RESRAD. There will be not a DOE version. DOE may come out with RESRAD
Version VII and Version VIII and Version IX, but we're developing a
version, with a lot of degree of concern over the assumptions and the
parameters in there, which is based on Version VI and 3.0 of RESRAD and
RESRADBUILD.
The contractors placed this summer -- the first deliverable
was basically a listing of parameters, what is in RESRAD, what
parameters are there, what do we have to pay attention to. The second
deliverable, which is underway now, will come in October, is which one
of these parameters are really important, which ones can variation cause
a significant effect on the dose that comes out of it. That's
essentially a report on physical metabolic and behavioral parameters.
The language in these comes from the contract. When you say
"complete probabilistic interface modules," that essentially means
that's the NRC version of RESRAD. That will be finished in June of 2000
and available for testing. We'll complete testing of the probabilistic
version by September of next year and then will have final documentation
done November. So, basically, this will -- we'll have the probabilistic
version of RESRAD about nine months after we have the probabilistic
version of D&D.
SEDSS: SEDDS is an outgrowth of what we did Sandia over a
number of years, first in high-level waste and then in low-level waste,
as our primary contractor and performance assessment. And then, it was
determined that we needed this fairly general tool, to be able to handle
the complex sites in the decommissioning program. The PC version, with
what we call the "old architecture," was available in May of '98. And I
thought "old architecture," because we're very conscious of the fact
that the ability to interface modules and move programs in and out of
other programs, the technology to do that is changing. And we want the
final SEDSS version to be as flexible, as possible, with regard to
bringing in improvements, as time passes. So, we're trying to have an
architecture, which is up to date as possible. Now, we recently made a
significant change and are working on a new architecture for the program
right now. So, we've taken a step back and have redesigned the program.
We expect to have the first version under the new
architecture with existing capabilities, plus the 5512 decision
methodology, in March of 2000. We expect to have it with the existing
version, with existing capabilities, in January. We expect to have the
incorporation of multidimensional groundwater model in January of 2001.
The last slide is nothing more than -- just a listing of
everything I've just gone through on one page, so you can look and
compare and see what the various dates are. All of these dates are
listed in the slides that I've just shown you previously.
DR. LARKINS: Are there user's groups for each of these
codes to exercise these codes, as they're developed, or get some feel
for how --
MR. OTT: Well, D&D Version I is out and being tested in the
general public right now. It's, also, being tested by staff and being
applied by Sandia. You heard yesterday that Sandia has applied it to a
couple of simple sites, not the complex ones that you're talking about.
For SEDSS, I don't think it's far enough long for that to be the case.
RESRAD, I don't know whether DOE has a group that looks at RESRAD or
not. We do not, at this point, have such a user's group for RESRAD.
Are you planning anything like that, Tin?
MR. MO: You're asking me if DOE has --
MR. OTT: No, no, no. I was asking if we were planning to
have -- if it was in our plans to have some kind of a user's group for
RESRAD.
MR. MO: User's group, meaning what?
DR. LARKINS: Are there people out there, who are going to
take these codes and use them and exercise them, to get some feel as to
how good they are.
MR. MO: Right now, I think, in a few days, they will mail
-- mail to us the beta version of 5.99, which will become 6.0 -- RESRAD
6.0, once it's tested. And we will get an NMSS staff and research
staff, they'll be using it on test cases that Mike has developed and
other cases. And so, I would say, yes, we have a user's group here to
test them, way before June 6, 2000.
MR. OTT: I think, in the general sense, you're talking
about, that's not what you were looking for. You were looking for a
more general users.
DR. LARKINS: Yes.
MR. OTT: And I don't think that's currently in our plans.
MR. LEVENSON: In Version I, you said staff is using it,
Sandia is using it, and the public -- some public groups are using it.
Who are the public groups involved?
MR. OTT: I would have to ask Chris to give you any details,
if she knows or not. Chris Daily, she's the project manager for the D&D
project.
MS. DAILY: It looks like a pretty broad range of people:
there are some that are university professors that are using it; some of
them are using it in their classes; there's industry people -- just a
range of people that are taking a look at it; some of the states are
interested in it, also.
MR. OTT: I think EPRI has actually done --
MS. DAILY: Yeah, and EPRI has looking at it and that's part
of their comparison of D&D and RESRAD.
MR. OTT: Right.
DR. GARRICK: One of the problems I have is that it's almost
an oxymoron to me to have D&D have a probabilistic version, given that
the whole concept of D&D was that of a bounding screening analysis. Why
on earth would you want to spend the time to try to create a
probabilistic version of a bounding model, when you're doing it on the
more site and facility specific case?
MR. OTT: Well, RESRAD is a late development. In terms of
doing something with RESRAD --
DR. GARRICK: Yeah.
MR. OTT: -- that started this summer. The D&D code was
developed as part of the implementation of the licensee termination
rule. In terms of putting a probabilistic driver on it, it turns out
that what you have there can be made more site specific. When you use
D&D, there is an assumption made that you can use it anywhere in the
country. And, basically, that means that you have to be more or less
conservative, since you're using it in a screening mode with regard to
everything, including things like groundwater parameters; whereas, if
you actually know a little bit and can tell actually what the soil type
is, you can narrow down the uncertainty in a lot of parameters by a
significant amount and perhaps lower the dose calculation by a couple of
orders of magnitude. So, you can actually make D&D into a much more
useful tool by giving it distributions that require minimal site
specific information.
D&D Version I doesn't require any site specific information.
You give it a little bit of site specific information and you can reduce
the level of conservatism in the code significantly with regard to site
specific parameters. So, it becomes -- Chris would like to add
something to that, too.
MS. DAILY: It sounds like an oxymoron, but we actually had
to go through the process of developing distributions for the parameters
in developing our basic probabilistic version of D&D, in order to
develop the fault parameters.
MR. OTT: Yeah.
DR. WYMER: I'd like to make an observation. I'm not sure
that there's anything that can be done about it, but it seems to me that
probably the poor person out there trying to decide which of these
things to use -- with respect to my site, I've got a couple of D&D
versions, I've got a couple of RESRAD, I've got a SEDSS, and they keep
changing. How in the world do I know what to do?
MR. OTT: Well, you're not going to find D&D changing past
this particular version, I don't believe. And I think that Version --
Version II is going to be set up, so it can do Version I calculations,
in the user friendly fashion. D&D is going to be set up as -- Version
II is the only one that is --
DR. WYMER: That still doesn't solve the problem of setting
put a plethora of codes out there.
MS. JENKINS: No, well, you can look -- you can find
more than D&D, RESRAD, and SEDSS, as well. I mean, you can find MEPAS
and you can find other codes by other vendors.
DR. WYMER: But, these are the ones that NRC is going to --
people are using.
MR. OTT: These are ones that NRC will use. NRC -- NRC
staff will find it fairly easy to make their decisions on which code to
apply in any given situation.
DR. WYMER: Well, I know that the NRC staff will, but -- I
don't think there's an easy answer, but I just --
MR. OTT: There isn't an easy answer. And I was trying to
come to grips with this question a little bit.
DR. WYMER: I was debating whether to use this or not.
MR. OTT: You have a problem.
DR. WYMER: Okay.
MR. OTT: You have a range of sites out there with varying
complexity, varying site complexity and varying source term complexity.
The first question you ask is what's the distribution of sites. I don't
know and I'm not certain that NMSS knows with any degree of certainty
how many sites they have in any part of this distribution. Let's make a
guess. I don't know if these dots are going to show up or not. Do
they? Oh, they do, okay. And from everything we've heard -- excuse me
-- from everything we've heard, you would expect that the vast majority
of sites are going to be simple, from the point of view of both
contamination and site, a very small area contaminated. So, you're
going to have all of these sites down here. Well, gradually, you get a
few sites in more complex areas.
If you want a tool that's going to handle this particular
site, you want to apply it to this particular site, I don't think so.
This site out here is going to require a great deal of information and
knowledge about natural systems, about hydrology, about geology, about
how to model those natural systems. The one up here is going to require
a great deal of information about decay chains and have a whole host of
radionuclides. You're going to need a code that's capable of handling
multiple radionuclides and decay chains and, also, propagating them
through the environment. Now, I guarantee none of this information,
because this is purely a thought exercise right now. But, I'm trying to
get an idea of why we have -- or how these codes relate to each other.
So, then, I put the third slide together. SEDSS is not
going to handle every site that's out there, and I'll make that
observation first. You wouldn't to apply SEDSS to Yucca Mountain. You
probably wouldn't apply SEDSS to a low-level waste to a site. You get
to a site where you know you've got a huge inventory and you've got a
very complex geologic or hydrologic system. It's almost inevitable that
you're going to develop a site specific model, okay. Yucca Mountain is
doing it. We're doing it for Yucca Mountain. You'll find it happening
in all the low-level waste sites. You'll find it happening at every
high-level waste site around the world. They're not going to develop a
generic model. They're going out and doing -- developing a model, which
is very specific to both the site and the design.
If we back off and we come in, SEDSS is going to be able to
handle a lot of sites, which are fairly complex, because we're going to
be able to have an ability to have multiple dimension on groundwater
problems and fairly complex geometries.
RESRAD is not a very complicated code, itself. Its
groundwater model is, also, very, very simple. It has more flexibility
than D&D in certain areas, but D&D Version II is going to have a fair
amount more flexibility than Version I. Some of those problems that
were mentioned yesterday, such as the area problem, that's going to be
addressable in Version II. The question of whether -- of what
percentage of your diet comes from the site is addressable in Version I.
And if you look at all the documentation on D&D Version I, there are a
lot of things that you can do with it, be it not easily, that address
some of those problems.
As we finish D&D and RESRAD, I expect that these two lines
are come even closer together. But, there will probably still be some
flexibility in RESRAD that doesn't appear in D&D. The question is, how
many sites in here benefit from the changes that were made in RESRAD.
And if you're in this situation right here, D&D is a much easier code to
use than RESRAD and much more user friendly to the public. For the site
that doesn't require any in situ information and allow somebody, who is
fairly unsophisticated, to go in, put in his source term, and come out
with a calculation that allows him to get through the decommissioning
process, it's a valuable tool, even if it only helps 10 or 15 of those
people. And it should apply to hundreds of sites.
With RESRAD's history and the comfort that a lot of
contractors have out there, having an NRC version, which is
probabilistic, that they'd come in and look at is probably a boon --
probably a benefit to them.
I don't know how to measure this margin and I don't know how
to really judge it. This is a thought exercise. I'm trying to put down
on paper the question that you've been raising about, you know, why D&D,
why RESRAD, what do they apply to. If I do nothing more than give you a
way of conceptualizing and looking at the problem, I knew that I've been
-- had some success.
DR. LARKINS: This sort of gets back to my question about
users, though. It looks like you may have a significant number of users
for D&D and RESRAD and only a few people will actually be running SEDSS.
MR. OTT: Right. I mean, the point should be made that
RESRAD will probably -- can handle any site that D&D can handle, and
SEDSS can handle anyone that RESRAD and D&D can handle, especially once
we get the 5512 methodology into SEDSS. It's a case of each one of
these requires a different level of sophistication in the user. RESRAD
is not as user friendly -- is not going to be as user friendly as D&D
is. SEDSS is certainly not going to be as user friendly as the other
two are. It's designed for you to be able to handle a complex site.
It's going to be -- it's going to need somebody that conceptualize -- to
conceptualize that concept site and know how to put it into SEDSS. I
mean, you don't just hand SEDDS over to the guy that owns the source and
tell him to run it. It's not what you do.
DR. LARKINS: SEDSS would mainly be run by the NRC staff and
the contractors and others --
MR. OTT: A reasonably sophisticated contractor. In fact,
the owner would probably contract for somebody else to run it. It's not
going to be something that you just -- you need to have a hydrologist to
run this. You don't model these sites without having a hydrologist
around or somebody -- a soil scientist that understands soil and soil
parameters.
MS. SANTIAGO: I'd like to interject for just a second.
When you asked -- my name is Pat Santiago from NMSS. You asked how does
someone know how to use these things. NMSS staff and I think Research
and other offices have participated in public workshops with licensees.
We have guidance documents. They come in all the time and meet with
staff on what they should do, what parameters they may choose, and that
will continue as these different codes develop.
DR. WYMER: I'm sure that the big organizations will
certainly do that. It's the little guy that's trying to get to the site
and doesn't even know the stuff is out there.
MS. SANTIAGO: Well, then, that's why the staff interaction
is key and the regional offices assist in that. We've had meetings with
various licensees to help them go along, just like we are helping
different staff on it, too, at this point.
MR. OTT: That's a good observation. Lynn, you had a
question?
MS. DEERING: Yeah, quick question. My understanding was is
that D&D was going to be implemented in SEDSS, is that correct?
MR. OTT: Yes. Well, the 5512 methodology is going to be
implemented in SEDSS.
MS. DEERING: And what does that mean exactly?
MR. OTT: It means it will be capable of doing the
calculations. We're not taking modules out of D&D to put them into
SEDSS, but SEDSS will be capable of doing the same calculation.
MS. DEERING: So, if you wanted to use just the D&D -- a
simplistic D&D type calculation, you could have SEDSS as your tool and
just choose to use that version of it?
MR. OTT: Right. The problem is that, if you want to use
SEDSS, you're going to have to be more a sophisticated user. It's not
going to be that easy to just choose the -- you're not going to go out
and buy this very, very complicated code, to be able to use D&D. If you
already have it on your shelf and you're a sophisticated user, you might
elect to use the D&D option.
MS. DEERING: Well, what complicated codes are in SEDSS?
MR. OTT: Well, I would have to have -- well, okay. Ralph
would be the one to answer that question. As an example of what is not
necessarily in there yet, but will be in there, the BLT code from
Brookhaven will be in there, essentially the breach, leach and transport
code that was developed for low level waste, a fairly sophisticated code
for dealing with very heterogeneous waste form, or set of waste that
might be present at a site. We will have one, two and three dimensional
hydrologic codes in there, or models in there.
If the demonstration work at Naturita on sorption models is
successful, which we hope it will be, we would eventually envision a
mechanistic sorption model in SEDSS that would allow you to do those
calculations without relying on a constant KD. So those are the kinds
of sophistications that we would envision being in SEDSS.
MS. DEERING: Is EPA still funding it?
MR. OTT: SEDSS?
MS. DEERING: Yes.
MR. OTT: They have got a test period being funded right
now, they are looking at applying it to some of their sites and making a
decision on whether they want to continue or not.
MS. DEERING: Because a lot of those codes, they probably --
they are NRC type codes.
MR. OTT: There has been a problem because of our reliance
on EPA funding in the past, since sometimes it has not come through as
scheduled. And we made a deliberate determination during our last
contract negotiations that we would not be dependent on EPA funding any
more. So we are making certain that whatever we do does not require EPA
support, or not dependent on EPA work being completed.
EPA, as a matter of fact, has requested that their version
of the code not have an NRC logo on it, because they are worried about
being tainted.
MS. DEERING: I can understand that.
MR. OTT: So there are political problems that we have run
into trying to work with EPA on the development of SEDSS, and it has
caused us to rethink what we are doing. And some of the decisions that
we have made with regard to architecture have been made unilaterally
because of our long-term need for the code, as opposed to what we and
EPA need for the code together.
DR. WYMER: Okay. Thank you very much.
DR. GARRICK: There is a lot more we could talk here, but we
will have to do it later because the committee is very interested in
this.
MR. OTT: I need to remind you that we are supposed to come
before you in November or December timeframe, I don't remember which.
DR. CAMPBELL: November.
MR. OTT: To talk about the general program.
DR. GARRICK: Good. Okay.
MR. OTT: I certainly think any of you or your staff that
would be interested in attending the training programs for DandD would
be more than welcome to participate, either for Version 1 or for Version
2, come next June.
DR. GARRICK: Thank you.
MR. OTT: Anything else I forgot? Okay.
DR. GARRICK: Well, according to the agenda, it is now 11:00
and unless there is comments from the committee, I guess this is break
time.
[Whereupon, at 11:03 p.m., the meeting was concluded.]
Page Last Reviewed/Updated Friday, September 29, 2017