111th ACNW Meeting U.S. Nuclear Regulatory Commission, July 21, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON NUCLEAR WASTE
***
MEETING: 111TH ADVISORY COMMITTEE ON
NUCLEAR WASTE (ACNW)
Conference Room 2B3
Two White Flint North
11545 Rockville Pike
Rockville, Maryland
Wednesday, July 21, 1999
The committee met, pursuant to notice, at 8:32 a.m.
MEMBERS PRESENT:
JOHN GARRICK, Chairman, ACNW
GEORGE W. HORNBERGER, Vice-Chairman, ACNW
RAYMOND G. WYMER, ACNW Member
CHARLES FAIRHURST, ACNW Member. P R O C E E D I N G S
[8:32 a.m.]
DR. GARRICK: Good afternoon. The meeting will now come to
order.
This is the third day of the 111th meeting of the Advisory
Committee on Nuclear Waste. The entire meeting will be open to the
public, and today we plan to update an overview of Spent Fuel Project
Office activities. We are going to hear a DOE presentation on the draft
environmental impact statement for the proposed Yucca Mountain
repository, and we are going to discuss potential ACNW contributions to
Agency comments on DOE's environmental impact statement, and we're going
to continue the laborious task of ACNW reports.
Howard Larson is the designated Federal official for the
initial portion of today's meeting. We are conducting the meeting in
accordance with the provisions of the Federal Advisory Committee Act.
The Committee nor the staff have received no written statements or
requests to make oral comments from members of the public during today's
session. Should anyone wish to, please make your wishes known to one of
the Committee staff.
It is requested that each speaker use one of the
microphones, identify themselves, and speak with clarity so we can hear
you.
Today we're going to start off with the Spent Fuel Project
Office briefing. It's my understanding that Bill Brach is going to lead
off and introduce himself and ask each of the subsequent speakers to
introduce themselves in terms of who they are, what they do, and what
they're going to talk about. And also the Committee Member Ray Wymer is
the designated lead discusser of this portion of our presentation.
So with that, Bill.
MR. BRACH: Good morning and thank you. As you mentioned,
we're here to give you an overview of Spent Fuel Project Office
activities as it relates to our involvement in review of dry-cask
storage activities and transportation activities. We'll be discussing
the status of our casework and transportation and technical issue
resolution and address.
With me this morning are Susan Shankman, who is our Deputy
Director for Licensing and Inspection Directorate, and to my left is
Wayne Hodges, who is our Deputy Director for Technical Review
Directorate. Both Susan and Wayne will be participating in our
presentation with you this morning.
I want to start first with just a brief overview of the
presentation we'll be making this morning. I'll be giving a brief
overview of a recent reorganization within the Spent Fuel Project Office
and discussing changes we have incorporated since we last briefed the
ACNW, which I believe was January of this year. We'll be giving an
overview of our casework with regard to our spent fuel, our dual-purpose
cask, our spent fuel storage cask, spent fuel transportation cask, and
our review of independent spent fuel storage installation activities,
overview of our communications plan, interactions with public and
stakeholders, as well as a focus discussion on some of our interactions
with the Department of Energy.
Susan will be giving an overview of our transportation
activities and studies and interactions, and Wayne will be concluding
our presentation with an overview on technical issues that we have
addressed and some of the approaches we've taken to address and bring
these issues to closure.
I'd offer that during the presentation if you have questions
of me, Susan, or Wayne, please feel free to interject.
First, just briefly, I want to mention, since we briefed you
last we've had a rather significant reorganization within the Spent Fuel
Project Office. Previously within the office we had a discrete element,
group of our organization that was involved in non-spent-fuel
transportation review activities, and a second element involved
principally in our dual-purpose storage and transportation activities
for spent fuel.
This past year, past -- end of March, same as most parts of
the NRC, we underwent a rather significant reorganization. I just want
to highlight in the reorganization that a couple of activities and
realignments occurred for which we I think will clearly increase the
efficiency and the effectiveness of our organization, but with any
change there's always a transition.
One, you'll see that under Susan we have all of our project
management activities for all casework, whether it be spent-fuel or
non-spent-fuel casework, and under Wayne we have all of our technical
review resources. And we are operating both in an integrated approach
with regard to the integration of our transportation and storage
activities, as well as a matrixed approach with our technical reviews
supporting our project management side of the house.
That's -- it's an evolving activity on our part, because as
I mentioned beforehand, we beforehand were organized in two discrete
elements where we had one group that handled all of our non-spent-fuel,
another group handling all of our spent fuel. We now are integrated in
a matrix and there's a transition period that we still are evolving in
but we are I think making good progress.
We as well, like the rest of NRC, a driving aspect of the
reorganization was to achieve the 8:1 management ratio. Our ratio was a
little bit over 9, 9:1, so we clearly are meeting the Agency's goals in
that regard.
Let me now address something I think may be of more direct
interest to you, and that is an overview of our status on our casework.
This slide, slide 4 and 5, is a summary of our dual-purpose,
storage-only transportation ISFSI work.
Let me offer that we are very proud of the accomplishments
that we've achieved over the past year. You'll see as you glance at the
status of the various cask activities many of the completions that have
occurred in the last year. I will point out too that while in the month
of March, while many folks are wrapped up in the March madness of the
NCAA basketball finals, we were wrapped up in our own March madness with
regard to a number of storage, dual-purpose, and transportation cask
activities. You'll see on this slide and the next slide there were six
major cask review activities and ISFSI activities that we successfully
brought to completion that month. And that was a very busy time for us.
There have been ten major cases that we've completed to
date. You'll notice the status of a lot of our Part 72 dual-purpose as
well as storage-only casks are what we refer to as in rulemaking.
Within Part 72, you may not be familiar, but when we complete the review
of a cask application for storage of spent fuel, we will generate a
safety evaluation report to document the conclusions in our evaluation.
We'll prepare a draft what we call certificate of compliance that would
provide the eventual authorization for the use of that cask under Part
72.
But there's a process that we go through in that the
proposed action on our part to issue a certificate, to issue the safety
evaluation report, goes through a rulemaking process where that's
published in the Federal Register notice for public review and comment.
Typically it's a 60-day, I believe it is, 60-day review and comment
period, and then we go through a final rulemaking process to show the
disposition by the staff of the comments received and changes that may
have resulted as a result of those comments.
On this overhead the TN-68 NAC and HOLTEC HISTAR are all in
that process, with the HOLTEC HISTAR 100 having been published this past
January, and we're in the final stages right now of the review and
disposition in addressing the comments received on that rulemaking. So
there is a time frame that does require after completion of our review
going through a rulemaking process. That is part of the element of
what's in Part 72 referred to as a general license concept where a
reactor or a license with a Part 50 license under the Part 72 has the
authorization to store spent fuel under what's referred to as the
general license provisions, and one of the contingencies in that
provision is that to use the general license provisions of Part 72, they
have to store their fuel in a cask that has been certified through the
Part 72 process I have just mentioned. So that the casks you see listed
here that are going through rulemaking would eventually upon completion,
successful completion, be listed by name and model number, certificate
number, in Part 72, and then a Part 50 licensee could store their spent
fuel in one of those previously certified casks by the NRC.
Two other points I just want to highlight on this one slide,
you'll note on the dual-purpose cask, BFS TranStor and BFS WESTFLEX, we
continue to see evolving change in the industry with regard to cask
manufacturing and design. This past year I trust you are aware that
Westinghouse and BNFL and Morrison Knudsen combined their -- actually
BNFL and Morrison Knudsen purchased the Westinghouse nuclear activities,
and you see BFS, TranStor BFS Westflex, that's the British Nuclear Fuels
Solutions which now has both what was before the BNFL TranStor, and the
Westflex was previously the Westinghouse design. So we continue to see
evolving change in the industry with regard to cask design.
Also note the very last item on the page, the Holtec
HI-STORM cask, storage-only cask activity, is scheduled for completion
the end of this month, and we are on schedule for meeting that time
frame.
The next page, page 5, lists as well a summary of
transportation casks and status. You'll see that two -- I mentioned
before our March Madness, two of those activities involved,
transportation casks, and at the bottom of the page ISFSIs. I'll talk a
little bit more about our interactions with DOE, but you note there that
the first two ISFSIs are actually the NRC issuing a license to the
Department of Energy for their storage of spent fuel.
The first was a license transfer. The Fort St. Vrain
reactor previously -- had an ISFSI previously owned and operated by
Public Service of Colorado. Just this past June we finished, culminated
our review of the proposed transfer of that license from Public Service
of Colorado to the Department of Energy, and that was finalized in June
of this year, and DOE Idaho is the licensed holder now for that ISFSI,
as well also at DOE Idaho the storage of the TMI-2 fuel debris is
located in an ISFSI licensed by the NRC under Part 72.
This past year as well we issued a license to the Trojan
reactor, which I trust you're aware is in decommissioning stages, and
the ISFSI license at Trojan will be permitting them to transfer their
fuel from the spent fuel pond to a dry-storage facility on site.
I'll add there are a number of other ISFSI activities under
way. Rancho Seco facility, also in decommissioning, we're projecting an
end-of-the-calendar-year date for finalization of our ISFSI review and
license issuance for Rancho Seco. Other reviews we have private fuel
storage facility, a private ISFSI application located in the State of
Utah. That review is currently under way.
As well as this next year we're expecting a second ISFSI
application from DOE Idaho for the storage of Shippingport, Peach
Bottom, and Triga fuel, and that's an ISFSI application also from the
Department of Energy, DOE Idaho, that we're expecting this next fiscal
year, as well as applications for another private storage facility
referred to as Owl Creek, proposed to be located in the State of
Wyoming. We're expecting that application this next year. And I'll
talk about it a little bit more, but we also have had interactions with
the Department of Energy, Naval Reactors, and they're requesting our
assistance in reviewing plans for an ISFSI for storage of naval reactor
fuel. That would be also at the Idaho facility.
Having covered a lot of, if you will, the products and
activities that we have been working on, and I will say feverishly, but
this slide really is, if you will, the benefits and the outcomes. What
-- with our effort in review and development, and approval of casks,
whether it be for storage or transportation, clearly, the outcomes as
laid out here are, if you will, if you will step back, the relative
importance with regard to these activities.
There are approximately about six dual purpose casks under
review that we are projecting completion for in the next few years. The
completion of those casks and certification of those casks clearly
provides more options to the reactor licensees for utilization for
storage and/or transport of their fuel, and recognize that many of the
fuels have unique characteristics, so the variety and options of the
different casks will meet some of those options. There will be a little
bit more I will mention of that in just minute.
I will mention some of the ISFSI activities and I think our
activities have been supportive of industry and regulatory needs in that
regard.
The third bullet, whether the recommendations that have come
from various committees in the House and the Senate with regard to
central interim storage facilities, other initiatives with regard to
potential storage of fresh fuel at a private facility, as well as other
transportation needs. We are looking at our activities and our efforts
with regard to transportation cask review and certification and believe
that the activities we have mapped out will meet the needs that may come
from Congress with regard to legislation and, of course, we all wait to
see how those various aspects may turn out or come out, as well as
potentially correlated for repository purposes further down stream. But
our goal is clearly to have available transportation casks available to
the industry for need -- for use as the need may be.
The last item, Wayne will be discussing at the end of the
presentation with regard to some of the technical issues that have faced
us in the last couple of years with regard to our storage and
transportation cask reviews and how we are trying to bring some of these
issues to resolution.
One purpose -- one issue I will come back to is note that
while we have a number of dual purpose of cask reviews that are in
various stages of completion, as I mentioned over the next few years,
what we are anticipating in the near term or in the future will be
amendments to those casks as licensees proceed to remove fuel from their
spent fuel ponds or further characterize the fuel that is stored in
their spent fuel ponds and realize that some of the fuel characteristics
and conditions may not meet some of the conditions as laid out in the
certificates and approved in the certificates, and we are anticipating
amendments to these certificates downstream as the utilities start the
process and realize there may be some nuances that require potential
modification to those previously approved cert. casks.
With regard to our activities, we have -- there is clearly a
lot of interest, both on the industry's part and the public's part, as
well as -- there is interest as well on the Hill downtown with regard to
our activities in storage and transportation of spent fuel, as well as
transportation of non-spent fuel.
We have developed a communications plan which has both an
internal and an external component. With regard to, first, the internal
component, clearly, we are briefing you this morning on an overview of
our activities. We had a previous briefing with the ACNW, I believe it
was in January of this year, and then roughly about a year ago. So we
are attempting on our part to keep the ACNW apprised on the status of
our activities and information, as well as other, I will call them
internal stakeholders within the agency.
Clearly, first, is one starting within the Spent Fuel
Project Office. We have frequent all-hands meetings and meetings as
well to keep the staff apprised of our objectives and direction and
initiatives. We are meeting with the region, for example, at their
periodic resident inspector counterpart meetings to apprise the regions
on status and information.
And that is especially critical on the earlier issue I
mentioned with regard to licensees that go down the -- this is power
reactor licensees, Part 50 licensees, that go down the general license
path of Part 72, where, clearly, the regional role and involvement, and
understanding of that process and the expectations of the regions in
reviewing licensees' conformance with the general license provisions of
Part 72 are critical and important.
And other stakeholders as well or the committee to review
generic requirements of CRGR. We actually have a briefing for them just
in about another two weeks with regard to an overview of our status,
and, likewise, we briefed them last in January of this year.
There is a litany on the bottom of the page that lists a
number of the interactions we have had with the industry, NEI, ANS.
Again, some outreach on our part to meet with the industry, meet with
stakeholders. We have had -- supported public meetings out in the State
of Nevada just this past June to address -- in support of Division of
Waste Management, in support of Part 63, but also some of the clear
concerns that constituents in that part of the country have with regard
to transportation safety.
So there is an exerted effort on our part to keep internally
NRC staff and management aware and informed of our activities, as well
as externally, whether it be the industry or members of the public or
others that have an interest in our activities there.
The next page, and before we transition to Susan, I just
wanted to identify -- I realize much of the ACNW's activities in the
past have focused with the agency's interactions with NRC and DOE with
regard to repository issues. I just wanted to highlight that within the
Spent Fuel Project Office we have a number of interactions with the
Department of Energy and a number of different activities. It is
interesting, there has been much discussion with regard to the role and
potential of external regulation of the Department of Energy by NRC.
I think what you will see here are a list of various issues
where the NRC is involved in either direct regulation, as I mentioned,
the two licensed ISFSIs at Idaho for the Fort St. Vrain fuel and the DOE
-- excuse me, the TMI 2 fuel debris, as well as a number of interactions
where the Department of Energy has submitted two topic reports to us.
One for a non-site-specific central interim storage
facility, which is identified in the NRC's hearing testimony to Congress
on the various proposals with regard to high level waste legislation
that involved central interim storage facility, that the NRC's review
and completion of this, this topical report, may, depending on the
direction that Congress takes in that regard, may be supportive of
meeting some of the goals and milestones that Congress was identifying
for timeframes for review of that application if it were to be passed
through legislation.
The dry system, dry transfer system topical report.
Traditionally, if a spent fuel cask, storage cask, has been loaded and
there is a need to unload that cask for whatever the purpose might be,
whether it be for economic or safety or other reasons, it is typically
done in a spent fuel pond.
The topical report that DOE has before us that we are
reviewing right now would involve the technology of a dry transfer from
one canister to another canister or packaged overpack to a second
overpack, without the requirement for use of a spent fuel pond. So that
-- this topical report has broad potential as we look downstream for,
whether it be central interim storage, private fuel storage, or
potentially at the repository if there is a need for any potential
repackaging, if that were to be the case. But this is a very
interesting topic that we currently have under review.
I mentioned the ISFSI activities with the Department of
Energy. Some other activities we have, Department of Energy has a major
program underway to bring back the research reactor fuel from various
countries overseas. That is an ongoing program. This is irradiated
spent fuel from research reactors. Department of Energy has asked our
staff to review the packagings that are used for the return of that
fuel, and we, in support of DOE, have been meeting the timeframes and
schedules. DOE has asked -- a lot of these activities a fairly
significant international nonproliferation objective and policy
perspective related, so we are clearly involved in that program and,
from our perspective, being very successful in meeting the DOE as well
as our U.S. national goals and objectives in that program.
Naval reactors, we have had a continuing interaction with
naval reactors in support of their transportation packages over the
years, as well as I mentioned they just recently have asked us, and we
are in the process of working through the administrative arrangements
for how we would support the naval reactors in reviewing an IFSFI
application for the storage of their naval fuels up at Idaho.
Two items that are not overhead, that have just been very
recently, the Department of Energy as well has asked us, inquired with
us on the possibility of supporting them in reviewing the packaging used
for the transport of tritium, that is part of their weapons production
program, but they asked us from the standpoint of the possibility of our
assisting DOE in reviewing those packagings, as well as the review of
packages used for inter -- excuse me, intra -- or excuse me, inter-DOE
laboratory transfers. So our dialogue with DOE continues in this regard
and some of it in a very direct regulatory sense, other in more of a
quasi-regulatory support role to the Department of Energy.
With this, we will move to Susan who will be discussing some
of our activities with regard to transportation safety, our roles and
ongoing activities.
DR. WYMER: Maybe if there are any questions at this
particular point it would be a good time to take those while they are
still fresh in our minds.
DR. GARRICK: Well, the only thing, I think that was an
excellent overview, and I assume that the two subsequent speakers are
going to address what you see as your challenges, the major issues
ahead, bottlenecks, if you have any problems, if you have any -- et
cetera. So we will look forward to that.
Just a comment, you mentioned research reactor fuel from
international locations, and you also identified a considerable amount
of interaction with organizations and agencies and what-have-you. And I
am sure you are, but are you familiar with the study that was performed
by the National Academy of Sciences on international research reactor
fuel and the disposition of it, and they recommendations they made to
DOE, et cetera, on what to do with it?
MR. BRACH: Personally, I am not.
MS. SHANKMAN: No.
DR. GARRICK: They did a very interesting review. It came
out of the Board on Radioactive Waste Management, and it was a very fast
track three or four month effort, but it was an excellent analysis of
the situation.
MR. BRACH: Well, maybe after the meeting --
DR. GARRICK: Yes.
MR. BRACH: -- we could maybe check with Howard to get a
reference. Personally, I am not familiar, and Wayne and Susan, so --
DR. GARRICK: Well, just call Kevin Crowley of the Board on
Radioactive Waste Management and tell him that you want the Milt
Levinstein Academy report on research reactor fuel from international
locations, and I am sure he will have you a copy the next day.
MR. BRACH: Thank you.
DR. WYMER: 202-334-3066.
MS. SHANKMAN: Okay. Would you have his number?
MR. LARSON: Yes.
MR. BRACH: Thank you. Thank you. Any other questions
before we move -- transition to Susan?
DR. WYMER: I had one sort of oblique question here.
MR. BRACH:
DR. WYMER: Have you considered the implications -- you
probably have -- of the fact that some of the reactors, power reactors
are going to go from 33,000 megawatt days per ton up to maybe 50,000
megawatt days per ton, which is a substantially different shielding
problem. And I wondering how that factors in.
MR. BRACH: Well, let me -- Wayne will be discussing that in
part.
DR. WYMER: Okay. Then let's leave that.
MR. BRACH: But the answer is, yes, the high burnup fuel, or
what we refer to as high burnup fuel is an issue that clearly we have
seen as well, that the burnup is going well beyond the 45 and oftentimes
the 50,000 megawatt days.
DR. WYMER: Yeah, it is moving in that direction.
MR. BRACH: Yes.
DR. WYMER: One other sort of small question was, has DOE
asked you to be involved at all in the packaging and transfer of some of
the decay basin stuff out at Hanford?
MR. BRACH: I don't believe so.
MS. SHANKMAN: No.
MR. BRACH: No, not to my knowledge. No, sir.
MS. SHANKMAN: No.
DR. WYMER: It seems like that is a pretty troublesome
packaging and shipping problem.
MS. SHANKMAN: Definitely. But it is all within DOE.
DR. WYMER: Yeah, you indicated they had asked for your help
on some other areas, so I thought maybe --
MS. SHANKMAN: But not on defense-related.
MR. BRACH: I was trying to be careful to describe where we
have a direct regulatory role and that is, for example, on the ISFSI
activities, the Part 72 ISFSIs, the Fort St. Vrain fuel, the TMI 2 fuel
debris and the shipping port Peach Bottom Triga fuel, which we refer to
as the second ISFSI.
The other activities where DOE has the regulatory
responsibility for the safe transport, which includes the DOE review of
the packaging, they have identified a few occasions where they have come
to ask for NRC's regulatory support in that review. But the one you
mentioned on the decay basin fuel material transfers, we have not. But
that clearly is within their realm of responsibility and authority, but
that is not a case where they have come to ask for support.
DR. WYMER: Well, if there are no other questions, we ought
to go ahead then.
MS. SHANKMAN: Okay. I won't promise to answer all the
questions that you might have, but in terms of challenges, definitely
transportation of high level radioactive material, whether it is spent
fuel or categorized as waste, is a hot button for lots of communities
and DOE, you know, has organized regional state groups and funded them,
and worked for them for transportation issues related to Yucca Mountain.
So the work that we have in our relationship with DOT is
very much involved in that, because the transport of radioactive
material falls under the DOT hazmat or hazardous material shipment
safety regulations, and that is a section of DOT that is actually modal
independent. By that, I mean they have within DOT, if you are familiar,
they have the different transportation modes. Each have their own
authority. There is FAA for air and Coast Guard for marine and the
Federal Highway Administration for roads and the Federal Railroad
Administration for rail. But the group that handles hazmat regulations
is independent of those modes and makes regulations for hazmat shipment
safety in any mode. So radioactive material is Class 7, that is just a
class of hazardous material.
And DOT is very much involved in the general safety and in
communications. You know, when you are driving along the highway and
you see a placard or one of the diamond shaped placards, those are all
regulated by DOT, exactly what the numbers are, what they mean. They
also organize the system of first responders and there is a whole system
of knowing what to do should there be an accident on the road or rail or
air that involves hazmat.
Also, DOT is part of an international community.
Transportation, obviously, is international commerce as well a physical
activity, and there is an awful lot of material that is shipped around
the world, so that anything we do in this country has to be compatible
with another country's regulations. And, therefore, the DOT
regulations, and our regulations related to the shipment of NRC licensed
material are all compatible -- I say compatible rather than exactly the
same as international regulations.
And DOT is the competent authority. That is not to suggest
that we are not competent, but in the international system, each country
has a single competent authority to whom other international -- or
nations communicate needs for revalidation of their transport packages,
so that if a package that has been reviewed in France or in Germany, or
in Japan, if a company like GE wants to use that package here, they go
to DOT and ask for it to be revalidated for use in this country.
So that is DOT's role, and NRC has a complementary role. We
have a memorandum of understanding with DOT on our role and, obviously,
NRC licensees have to follow NRC regulations and Part 71 in our
regulations speaks to transport. We also act as a technical consultant
to DOT on type B packages, those would be the packages that have
significant radiological risk, and high level waste, of course, and
spent fuel fall within that. And the type of packaging, the type B
package, as opposed to A, which is -- not to go into all the details,
but a type B package has to be accident-resistant and NRC reviews all
the type B packages even if they are not NRC licensed material. They
are -- most of them are, of course.
We also inspect the cask fabricators as well as review the
casks. We also set the theft and sabotage rules, that is Part 73. And
we also inspect and enforce both DOT's rules and our rules when it comes
to type B packages, and also some type A, type A fissile.
So that is the DOE rule -- role, I mean, and NRC's role.
And as I say, they are complementary to each other. They are both
derived from the international IAEA regulations. And, in fact, just now
we are beginning a several year project to revise Part 71, and at the
same time DOT is revising 49, Chapter 49, so that it is compatible with
the 1996 IAEA regulations, and that is because there is an international
agreement that every country will revise their regulations by the year
-- I don't know how to say zero-two, but, anyway, by the second year of
the next millennium.
Anyway, the IAEA regulations have a long history and to say
they are deterministic would be an understatement. Risk-informed
regulation has not been something that IAEA has embraced, and
particularly not in transportation. However, the NRC and DOT in this
country have made a concerted effort to have the IAEA at least spell
risk.
And at the last TRANSAC, which is an advisory committee of
IAEA on transportation of radioactive material, sort of became a little
to fruition. They passed a resolution that all proposals for future
changes to the IAE regulations would have to have a risk statement, and
that they had to be proposed by member states, rather than by the IAEA
secretary. And that's a significant shift -- just the fact that they've
agreed collectively, as a body, that risk information should be included
with any proposal for a change in the regulations. Now, I don't know
how that will eventually play out, but I see that as at least, hopefully
not a Pyhrric victory, but a small victory.
DR. GARRICK: This committee is extremely interested in the
transportation issue. We're probably not to a point yet where we can
get into it with a great deal of energy, but one of the things that
comes to my mind here is the -- it sounds like, from a regulatory
standpoint, it's a nightmare in terms of who is in charge.
Now, you talk about, of course, DOT as the authority.
MS. SHANKMAN: Um hmm.
DR. GARRICK: And the reason I'm sensitive to this
personally is because we have been trying to figure out the
transportation issue associated with the operation of WIPP in another
capacity.
MS. SHANKMAN: Um hmm. Okay.
DR. GARRICK: And it's clear that it's an area of activity
that did not get adequate attention, was not factored in in a total
systems perspective to radioactive waste management. And we, in another
capacity, are trying to review it now, and it's been extremely difficult
to nail down who's in charge, why this requirement exists, and,
depending on who counts, just in trying to get some waste from Los
Alamos in the State of New Mexico, and WIPP also in the State of New
Mexico, somebody counted up something like 4,000 requirements between
DOE, DOT, NRC, State of New Mexico, etc. etc.
MS. SHANKMAN: Um hmm.
DR. GARRICK: And that's one thing. It just seems to be
totally absent of an overview consideration from a total systems
perspective with respect to the issue of radioactive waste management.
The only reason I'm making this speech is that I hope, I hope that
there's some lessons learned here as far as the high-level waste problem
is concerned. Because, it just does not seem to be the
cross-fertilization, cross-discussion, technical exchange between
Transportation and other -- in the same manner that there is with
respect to other technical issues and other operational issues.
The old joke is that WIPP has been certified; getting the
waste there has not been. We're just hopeful that we can make a
contribution to avoiding some of these problems in the future, because
when we tried to find out why some of these requirements are there, it's
more a game of finger-pointing than it is in trying to solve the
problem. I don't know whether you're having those kinds of problems
there or not.
MS. SHANKMAN: Well, we're not having those problems, but
we're also not having a large campaign of shipment of spent fuel. So I
can't -- I mean, I can tell you the systems that are in place, as I'll
get to later, but I'll tell you now, there's so much interest in the
transportation of high-level waste in so many communities and asking for
their own, making their own decisions about what can be transported.
The Department of Transportation definitely sets the HAZMAT
material regulations for the country, and I have a figure here that we
used in another presentation, that on any given moment, but at any
single moment on the highways and byways of this country, there are
770,000 hazardous material shipments.
DR. GARRICK: Yes.
MS. SHANKMAN: And yet, we don't see a big cry about that.
We had ten rods, fuel elements going from the Limerick to TE Valacedos.
And they want a community meeting on that. So there's a psychological,
if not a physical --
DR. GARRICK: Well, the one things -- then I'll stop talking
about it -- but the one thing that you mentioned that I think holds some
hope for leveling the playing field a little bit is of course to embrace
the concept of risk informed ideas.
MS. SHANKMAN: Well, if you want, you know, we can speak to
you all about our role in approving the cast that he used for WIPP.
They're --
DR. GARRICK: No. That's outside our -- but I just use it
as an illustration of things that have happened that might give us some
hint of what to avoid in the future.
MS. SHANKMAN: Right. Now with WIPP, NRC has been given,
through legislation, the role of certifying the packaging period. We
don't approve the routes; we're not involved in the actual transport for
WIPP. So our requirements for the packaging are the same requirements
as we have for other packaging. They're not different or unique to
WIPP. I don't know if that helps. But as I said, we're working slowly
and laboriously with IAEA to bring risk-informed to the international
community.
We have some studies that we're doing. Each one is actually
related to the other one. I can't draw a clear distinction they all
have. Collectively, they're meant to help in assessing the risk of
spent fuel transportation in a way that we will be able to communicate
to the public. Right now, we believe that transport of spent fuel is a
safe activity. However, the communication and public outreach is a very
important part of this, and the more we can have it documented with
current data and current methods, the better we think we will be.
So we initiated several years ago, if you will, a re-work of
0170, which is our generic environmental impact statement for
transportation of NRC-licensed material. The re-work we're doing is
only for spent fuel. We're not looking at medical shipments or any
other shipments in general. But we're just looking at the assumptions
that we made and the data and methods that we used originally and
whether they are still bounding.
RADTRAN, which is a code developed by Sandia and used in
many, in many ways -- we use RADTRAN 5, and originally we had to use
RADTRAN 1 -- yeah. RADTRAN 5 has some risk insights, some probabilities
built into it that were not in RADTRAN 1, so this is one way in which
we're trying to -- this was not a comprehensive study. We did not spend
millions of dollars. We did not try to do the definitive study on spent
fuel risk.
We also tried to use more current data. The Volpe Center,
which the Department of Transportation's Federally funded research
center -- you know, much like ACW --
MR. BRACH: Center for Nuclear Waste Regulatory Analysis.
MS. SHANKMAN: Easy for you to say.
MR. BRACH: It's in San Antonio.
MS. SHANKMAN: Yeah, I know it's in San Antonio also.
[Laughter.]
MS. SHANKMAN: Anyway, the Volpe Center is in Boston. And
they have -- as we came to find out, and Sandia has been working with
them -- it's not completed yet and the data is not incorporated in this
study. But they have risk information on every mile of track in the
U.S., which is quite interesting and allows you to do some different
route scenarios and see what the overall risk is for the route and
whether there's a riskier element. They also have data on highway risk,
not as comprehensive as the rail risk. But they do have, you know,
riskier, if you will, intersections and configurations. And so we plan
to incorporate that and work with Volpe to incorporate that.
That study is coming to completion. It is now under peer
review. We have some -- as I said, Volpe, we need to get more data from
them and if you want, when the study is complete, we'll be glad to come
back and talk to you about it.
The modal study is focused on two modes of transportation:
on rail and highway. And when it was originally done in the early '80s
-- mid-'80s, I'm sorry -- it looked at severe accidents, actually, if
you will, beyond regulatory assumptions, but severe accidents. And when
this first modal study concluded that 99.4 percent of the accidents for
which we knew the parameters, a spent fuel cast would survive -- that's
quite a significant figure if you think about it, that there would be no
release. And even -- so it just looked at severe accidents, and we have
a brochure I'm sure you've seen that we produced out of that modal
study. It was meant to communicate the safety of certified packages to
the public.
We're now redoing the modal study. And how we're going to
do that -- we've just started the work on it -- is we're going to start
with three workshops in which we get public perceptions and concerns
first, and then design an analysis plan to speak to some of those
concerns. And of course, one of those meetings will be in Nevada. That
work will be done by Sandia, and we expect that out of that study, we
will also do some actual testing, whether it be prototype testing or
model testing or full-scale testing is not clear yet. It depends on
what the analysis of the current data shows.
The shipment survey that we have down there is a
denominator, if you will. We know how many accidents there are that
cause a release, which is none. But we don't know how many shipments
are actually made of radioactive material in this country. In 1982,
they estimated that approximately 3 million shipments were made. We're
now trying to find out whether, since 1982, there's been an increase --
which we know, of course, there has been -- and what's the magnitude of
that increase. We've had numbers thrown at us by the medical community,
that they make upwards of ten times that amount of shipments in a year.
But anyway, we're getting data.
DOT, the Volpe Center is doing the study for us and NEI is
helping us with the medical community and other licensed shippers to get
information on medical and byproduct shipment, as well as high-level
waste. So 0170 is spent fuel; the modal study is severe accidents on
spent fuel; and the shipment survey is on all shipments, to quantify the
number of shipments.
As I said, public outreach -- Bill mentioned that we went to
meetings in Nevada on Part 63 rulemaking. We're going to have workshops
related to the modal study. We're supporting our Office of Public
Affairs in the development of a video on transportation. We've gone to
many groups -- as I mentioned, the DOE-supported regional, state,
government groups, we've been to their meetings. The interest in this
goes beyond the technical data and into the psychological concern and
the physical concern about the protection of one's self, having
dangerous materials, dangerous goods going by you on the highway. And
it's going to be an effort for us to communicate the safety record,
which is very good, in a way that is comprehended by the public. The
hazardous materials safety record in this country is excellent, and
radiological safety is even higher.
So, that's where we are on transportation. Do you have any
questions?
DR. GARRICK: Anything? George? John?
MS. SHANKMAN: Thank you.
MR. HODGES: I'm Wayne Hodges, and I'm going to talk about
some of the things we're doing in the technical arena.
We have a number of standard review plans that describe what
an applicant needs to do to try to get the certificate. It provides
both guidance to our staff on what they need to look at in the review
and guidance for the industry on what to submit.
We have a couple of them that have been issued in final
form. We have a couple that are in draft. They've been out for comment
for some period of time.
Because this isn't an evolving business, earlier on, reviews
of both storage and transportation included a lot of conservatism that
was probably more than was really needed. We have been trying to take a
more realistic -- if you want to call it risk-informed, you can -- but
to the extent we can, as realistic a look in a number of areas as we can
to try to improve both the review and help with the designs.
The consequence of that is that we have issued what we call
interim staff guidances. These are updates that will eventually go into
the standard review plan, because you want to be able to have it in the
industry and have it available on a short-term basis. But before we
would go through the full process of providing the standard review plan,
we've issued this guidance. It's out on the web, so it's readily
available, and the plan is to incorporate this guidance into future
revisions to the standard review plan.
You asked a question earlier about the high burn-up and if
we were doing anything with that. We also are working with the Office
of Research. They had a program already under way, which was a
cooperative program with EPRE and DOE to look at high burn-up from a
reactor accident standpoint. But a lot of -- basically, once they cut
the specimens up and start to look at it, they can also enter a number
of questions that we would need to look at on embrittlement, creep --
and so we've had a discussion with them and we're going to be riding on
the coattails of the other program essentially, to get information on
the effects of cladding in the field, and high burn-up, as far as those
aspects are imported for storage.
We also have been looking at credit for the burn-up of the
fuel. One of the assumptions that has been made up until just recently,
that we have required them to make, is whenever you're looking at the
criticality of the fuel and the cask, you assume it's all fresh fuel.
And we know that was a bounding approach, but there was not a lot of
data available to go otherwise.
DOE did submit topical reports, a couple of them over the
last ten years, to try to get credit for the burn-up. And they were
partially successful in what they covered. And we decided this past
year that it was important to try to look at that ourselves. The Office
of Research, again, has a program underway to, one, try to see what data
are available internationally; there are some. And we'd maybe get that
to do some additional analyses and to provide a stronger foundation for
it as full a credit as possible for the burn-up of the fuel.
In the interim, one of our staff got this, and I'll go
through those -- it does cover a limited credit for the burn-up. So as
we could get information and are able to, we're trying to approach
realism.
Another program we have through the Office of Research has
to do with what it you want to use this cask for more than the 20 years
that they're licensed for? We have a program where this fall we will be
opening up the casks out at Idaho, where the fuel has been in storage
for a number of year, and look at what has happened to the fuel in that
storage, and give us some information on things like creep or the
cladding, and how, whether stuff stands up in dry storage. So we have
some programs like that underway to try to look toward the future.
If you'll turn to the next slide --
DR. GARRICK: Wayne, if I could just add one aspect of our
the Interim Staff Guidance documents -- I wanted to mention that both
from a technical perspective as well as from a management perspective,
this has been a very valuable tool that we've started in the last year.
As Wayne mentioned, we issue these, if you will, between updates to our
Standard Review Plan.
But you mentioned before in one of the earlier slides, we
have a number of cases under review, whether it be storage or
transportation, a number of different -- within our own staff --
different review teams reviewing those casks. It's very important to
us, as we come to technical closure on an issue in an individual cask
that we both -- if you all cross the office in technical review, had
that same information, that same basis, that same technical
understanding for coming to closure on that issue, communicate it across
the office so the various review teams looking at the various casks,
would have, be incorporating and using the same technical rationale and
approach.
And from a management standpoint, that's clearly important
from an internal consistency and communication, as well as -- as Wayne
mentioned, these are available to the public as well. While we
developed them for staff use as an augmentation of the standard review
plan, these are available to the industry. We've had public meetings,
workshops with the industry on the interim staff guidance documents,
soliciting and receiving industry and public input and comments. So
it's been very useful to us, and a useful tool to us in both those
regards.
MR. HODGES: The next two slides in your packet basically
list the twelve ISGs that we have issued in the last year. We started
this process last summer. So twelve of these have been issued in the
last year. There was initial, seven were issued in the early fall, and
then this past May the others were two revisions.
I can kind of mention a couple of them, and as you read
through that, if you have a question on what they are, I'll respond. I
don't think it's worthwhile to try to read through each and every one of
them and tell you exactly what they are, but if it, if you have an
interest in it, I'll be happy to respond to any of them.
But to give you a kind of an idea of what some of them do,
ISG-3, it looks -- and that's post-accident recovery and compliance with
Part 72.122. There's some things in there that are somewhat subtle.
One of the things it says is to eliminate reference to non-credible
accidents. Previously we had required -- consider, for example, that
lid magically flew off the cask and they had to calculate what the dose
was to the public. That's not a credible accident. We didn't think
that made sense. So this ISG basically eliminates that requirement. It
also means, if they want to come in an say, I can show from a
probabilistic standpoint that my cask won't tip over, then they don't
have to consider the tip-over analysis. So there are some things of
that nature that are embedded in this particular ISG.
It also basically says that as far as recovery operations,
you only have to worry about that for a design basis and optimal
conditions. You don't have to worry about that for accident conditions.
The philosophy there is that if you have the accident, you won't know
exactly what the condition will be ahead of time, and you'll need to
make your plans based upon how the accident progresses. And we think it
generally can be done. So all they have to consider from the recovery
standpoint, at the design stage, is for the design and optimal events.
The ISG-4 --
DR. GARRICK: Wayne, isn't that a little bit inconsistent
with, on the one hand, saying that you're going to eliminate the notion
of non-credible events, but on the other hand you seem to be reverting
back to a design basis philosophy that is a product of that era of
accident analysis.
MR. HODGES: Oh, well if you look and see what the design
basis events are, there are things that are credible. And so that's why
design for them. You have to be able to --
DR. GARRICK: All I'm saying is that if you're going to be
probabilistic about one part of it, why not be probabilistic about the
other part of it? The whole notion of a threshold or credibility then
is eliminated.
MR. HODGES: Well, okay. I hear where you're coming from,
and recognize, we're taking steps.
DR. GARRICK: Yes.
MR. HODGES: This is a process that was begun roughly a year
ago, and we're trying to see where we can make improvements with the
information we have on-hand today. So, I felt that this is something we
could do now. We are looking at the risk standpoints. And in fact, one
of the later slides talks about a study that has been started in the
Office of Research on the PRA for storage. And we have also this Nureg
017 study, which is basically a risk study for transportation. And we
want to try to use the risk insights from those to go further. And so
we're doing in stages.
It may be a bit of an inconsistency at this point, but I
think it's an improvement.
DR. GARRICK: No, that's a good answer.
MR. HODGES: yes, okay. Basically, number 7 -- let's see.
MR. BRACH: Number 11.
MR. HODGES: I just talked about number -- let me go to
number 4 next. Number 4 talks about closure welds for the casks. This
was one where there had been a requirement that you do either a UT or a
radiography. The generated radiography was not practical, and so it
required UT. This allows PT inspections for the cask closure welds
under certain conditions. And that is generally now, I think, what the
industry is doing. It's not necessarily what we prefer, but from a risk
standpoint. If I go to --
MR. BRACH: It's 11.
MR. HODGES: Yeah. Well, let's talk about Number 8 next.
Number 8 is the one on burn-up credit. I mentioned this just very
briefly earlier. This one, what we have on the street today says, you
can take credit for 50 percent of the actinides in burn-up. Now, that's
not a major altering from us. Except that it breaks the ice from giving
no credit for burn-up. And what we've communicated to the industry is
that as soon as we can get the information to go further, we will. And
we actually have it in process. And our goal is to have out by the end
of this month another revision to this one to allow further credit.
Number 11 talks about storage of spent fuel for higher than
the 45,000 megawatt days burn-up. This one is not a terribly generous
one at this point. It kind of lays out what the requirements are, that
what we need to be able to go beyond 45. But it also addresses the
situation for, say, a reactor that they're trying to decommission plant,
eliminate the fuel pool. And they have a few assemblies that have the
high burn-up, what do you do? And this addresses a means -- probably
not the optimum -- of what's available today of how to handle that fuel.
And so that's kind of a sampling of the guidance we
developed in the last year, and if any of it strikes you of interest, I
will be happy to try to talk about what's in them. That gives a
flavoring of the types of changes we've put in place over this past
year.
DR. WYMER: I have a question.
MR. HODGES: Yes.
DR. WYMER: What consideration have you given -- is it
necessary to have any -- on the MOX fuel, especially the un-irradiated
MOX fuel, for shipment and storage. You've got all the plutonium in
there that you don't have in ordinary fresh fuel.
MR. BRACH: Maybe if I can address that. The MOX fuel
initiative and the potential for NRC licensing of fuel facility, the
latest that I'm aware of is that the Department of Energy had plans to
handle all aspects of the transportation of that MOX material, including
the MOX fuel, between the facilities. That's still an evolving aspect.
My latest understanding is that the Department of Energy
would be handling both the safety and the safeguards aspects of the
transport of the material. And by that, DOE may come to us for support,
as we talked about, for the return of research reactor or Naval reactor
packaging designs. But that's my latest information as far as how
that's progressing, so DOE would have that responsibility. And they've
not come to us, to my knowledge, asking for support yet.
DR. WYMER: Yes. One other question had to do with
defective cladding. I'm just here searching for a little bit of
specific information about the extent of that problem.
MR. HODGES: Uh -- okay. As far as percent of the fuel, I
don't have an answer. There is a fair amount of fuel that, where
they've had problems with water chemistry in the plant. Particularly in
the early days, there were a number of problems with the cladding and
developing pinholes or some type of leakage.
If the cladding is just a hairline crack or a pinhole leak
as far the defect, then it's treated as far as putting it in the cask, a
normal undamaged fuel. If it's more than that, then the major concern
is that it would be able to maintain geometry for critical type of
considerations. And so, we would assess that on basically an individual
basis to see what needs to be done.
I can recall -- I probably shouldn't mention the accident
name -- one reactor that had a problem with some water chemistry, and
they had cladding flaking off, to the point where pellets came out of
the pins. So, there is fuel that bad. But most of it is not that bad.
DR. WYMER: Yeah. My interest is a little bit oblique. It
has some implications with respect to the waste depository storage
problems.
MR. HODGES: I --
MR. BRACH: Let me identify -- Eric Leeds is the Section
Chief in SFPO for our technical review. Eric?
MR. LEEDS: Yeah, I don't know if this answers your
question, but for one example, we just had one licensee come in from
Maine Yankee. Obviously, they're decommissioning. And out of their
pool -- they said approximately 20 percent of their fuel was in some way
distressed; 80 percent of the fuel was intact. Twenty percent -- some
of it had been reconstituted, consolidated, a number of things. I don't
know. Maine Yankee's an older plant. It's probably representative of
the problems we see at an older plant as opposed to a new. But 80
percent was fine; 20 percent was distressed fuel.
DR. GARRICK: You'll have to forgive us for jumping around
and thinking about some other problems that we have in relation to
transportation and fuel. But one of the things that's very important in
the assessment of the long-term performance of a high-level waste
repository is good knowledge of the condition of the fuel when it goes
into the repository. Is there any coordination, discussion, drivers,
what have you, in your activities, for making a contribution to having
high confidence in whatever assumptions that are made downstream in
performance assessment of the repository about fuel, that they can be
supported by your knowledge of the spent fuel? We're talking about
spent fuel at the moment.
MR. BRACH: well, e closely coordinate with NRC's Division
of Waste Management on our activities, especially as it relates to
potential disposal of the material. I'm sure you're familiar with --
earlier, there was the concept of a multi-purpose canister --
DR. GARRICK: Right.
MR. BRACH: -- and if you were -- the terminology I was
using this morning. That dual purpose being transportation and storage.
And we currently are coordinating with the Division of Waste Management.
The third leg of the, of this would be eventual disposal, and I think --
DR. GARRICK: Yes.
MR. BRACH: -- a number of folks have the perspective that
the characteristics of the storage canister, if that were to satisfy,
and we realize that the Department of Energy still has that as an issue
evolving with regard to specific characteristics for disposal. But as
to the compatibility of the fuel and the packaging for eventual
disposal, that's still an outstanding question to be answered and
addressed, but we're closely coordinating with John Greeves in the
Division of Waste Management on those aspects.
DR. GARRICK: Let me get specific. One of the things that
we were talking about yesterday that's becoming a topic of consideration
in the better management of the fuel as it goes into the storage is the
possibility of blending individual fuel elements in order to enhance the
knowledge of the radiological and thermodynamic parameters of the fuel
that's going into storage. That sounds like a bit of a nightmare in
terms of the kinds of activities that you can envision that might have
to take place at the fuel handling facility at the repository to achieve
that and do it effectively.
Our comment was, isn't there a way on the other end in terms
of measurements that might be made, in terms of how the fuel is shipped
in terms of the cask design, the whole litany of things, that could
maybe preclude the need for some of that. Because it just sounds like
this whole thing is growing and growing in terms of the handling. And
the reason that's very important is that it doesn't take a lot of
sophisticated calculations to realize that the real risk in radioactive
waste management is in the handling. And it seems as though everything
we're doing is requiring further handling.
You know, we're starting to treat low-level waste a lot more
than we ever anticipated when we thought about storage disposal. And
now we're talking about implementing handling activities associated with
spent fuel that we never ever envisioned, and I suspect if we look at it
seriously, is the risk. And we're contributing to it immensely by
imposing in the whole radioactive waste management process extensive
additional processing and handling. To me, that's a classic example of
why it's so essential for somebody to be looking at this in a total
systems perspective.
MR. BRACH: Well let me -- I very much agree with your
observation, the one aspect, as I mentioned before. The determination
of the characteristics for disposal, if that were available, clearly
we'd be, I think, talking to you about multi-purpose canisters --
DR. GARRICK: right.
MR. BRACH: -- and we'd be talking about designs that would,
to the extent possible, preclude the, such intermediate handling of
material between the three different modes of transport, storage or
disposal. Clearly, I think we have the same objective in that regard.
MS. SHANKMAN: I think, Dr. Garrett, we are not looking to
have extra handling. The purpose of the dual-purpose cask is to seal it
up once and to have different overpacks and to have -- we are asking
that when they load, that they have good records. And we're -- Wayne
can explain to you the verification that we need in terms of records
before they can declare the fuel intact so that we're relying on
records, and absent records, visual examination of video cameras; and
they have a lot more available to them to look at it before it's
packaged.
DR. GARRICK: And my only point is, is there a way for us to
be creative so that when we seal it up once we know enough about it so
that we don't have to unseal it somewhere else and shuffle the stuff
around.
MS. SHANKMAN: Right.
MR. HODGES: That's not our intent.
DR. GARRICK: Yes.
MR. BRACH: The key to that being, a successful outcome of
that objective would be knowing the design characteristics necessary for
eventual disposal.
There is one other aspect that I wanted to mention too,
that's driving the -- if you will, the task design and utilization today
is that not only are a number of nuclear power plants decommissioning
and they're looking to eventually go to Greenfield or to have only their
nuclear materials stored in the spent fuel ISFSI storage pad. So
there's an initiative there to have that cask capability today for that
storage.
A couple, a number of operating reactors are faced with a
situation where their storage of spent fuel in the spent fuel pond is
such that for them to be able to maintain the optimum load capability is
driving them as well to looking at, today, present-time, the capability
to store this spent fuel. So we have both the objective currently from
a longer term disposal and the minimization of any inter-transference,
from storage to transport to eventual disposal, to the operational needs
and economic driving needs for those plants that are decommissioning to
have that capability today. So we have both the needs we have to
address the storage requirements that utilities and licensees see today,
coupled with the -- clearly, I think we share the same objective -- the
minimization of handling during different modes of storage and transport
to eventual disposal.
DR. GARRICK: Well, I'm sorry to get us off-track a little
bit, but I think --
MR. BRACH: No, that's an important issue.
MR. HODGES: My last viewgraph is number 14. This one talks
about the PRA that has been initiated in the Office of Research on a
dual-purpose cask design. This is being conducted in-house by research
people. They're working very closely with my staff. And the individual
who's doing this has been over a couple of times to get information,
both documentation and to talk with the staff to get insights. This has
been underway for about one month at this point, so it's still in the
data-gathering and familiarization phase. But we're, you know, hopeful
for some results on this one.
MR. BRACH: We're optimistic in this regard. There's been
much risk analysis work done under Part 50 for all aspects of the
operating reactor. Intuitively, there are aspects of dry storage that
different people can come to various conclusions on with regard to
inherent risk or risks, and what we're looking for in this PRA is to get
a more evaluated and defined basis to support some of the actions that
Wayne identified. And what we're trying to do in our review is that,
where we feel there are ultra-conservatism to go with more appropriate
conservatism, we feel that hopefully the outcome of this PRA review will
get us a more solid base for us to review our programs or expand it as
needed, but to have a more established basis for many aspects of our
review.
DR. WYMER: Do you get involved at all in the problems
associated with disassembling the fuel assemblies and separating out the
pins and then shipping them independently, aggregated in some way.
MR. BRACH: Well, as far as the actual activity, that would
be typically under the Part 50 reactor license, as far as the conduct in
those activities.
DR. WYMER: Yes, that's part of shipping and packaging.
MR. BRACH: Our involvement -- and I think Susan had
mentioned it previously shipment of individual fuel rods. Clearly the
licensed shipment has to occur in an NRC- certified packaging under Part
71.
DR. WYMER: I was thinking of bundles of them.
MR. LEEDS: Yes, sir. If I may, Bill. We have, when we
went back over the interim staff guidance, the ISGs, ISG-1 was very
specific on how fuel has to be shipped, intact fuel assemblies without,
with less than pinhole leaks, hairline cracks, would constitute one
category. Another category would be, as you suggest, incomplete control
rods or individual pins, and those have to be confined in an inner
container that would go into the cask. So those are handled in another
way. And then you have fuel debris handled in another way. And we've
pretty much deliberately laid out how each type of fuel has to be
packaged to go into the cask for
For two reasons. One is the principles of Part 72 are based on, one,
maintaining cladding integrity. Of course we want to minimize handling,
but if we have to go handle again, you want the clad to be maintained,
that the fuel rods will be intact. And the second is retrievability,
another fundamental principle of Part 72 is retrievability of those fuel
assemblies if we need to get to them. When you're talking about fuel
pins, they have to be confined in an inner container for that.
I hope that answers your question, sir.
DR. WYMER: Yes, that will do. Thanks.
Any other questions on this? I'm sure we'll come back.
DR. LARKINS: Can I ask a quick question?
DR. WYMER: Oh, John. Sure.
DR. LARKINS: The update of the transportation risk, this
modal study, is that going to in any way feed into the review of DOE's
EIS -- well, it won't be in time for the DEIS, but --
MS. SHANKMAN: No, it won't be in time for the DEIS, and
when it comes time where we have to consider adopting the final EIS,
we'll use whatever information we have. The modal study is a four-year
effort, and it's just getting under way. But 0170 should be completed
by then. So we'll use the data we have.
DR. LARKINS: So you'll be contributing to --
MS. SHANKMAN: We're definitely on deck and on board to
review -- in fact, we're going to review the draft EIS transportation
aspects for high-level waste.
DR. WYMER: One other question. You're pretty much out of
the business of cask testing and running programs on minimum-risk routes
in transportation and that kind of thing? You rely on --
MS. SHANKMAN: DOT sets highway carriage safety. We look at
casks and accident resistance and normal conditions of transport.
DR. WYMER: But you don't look at routing and that kind of
stuff?
MS. SHANKMAN: Well, we do in regard to safeguards, not in
regard to safety.
DR. WYMER: I see. Yes.
MS. SHANKMAN: So the highway -- for instance, DOT says you
will take the most expeditious route, you will stay on interstate
highways rather than secondary roads, you will try to transport it at a
time where you're less likely to have congestion. You know, they have
certain guidelines in chapter 49.
We say you need to have safe havens, you need to contact
local law enforcement and know who would respond if there was a theft,
sabotage, threat. And we also have communications with Governors'
designees all related to safeguards.
DR. WYMER: Yes. There is a whole rats' nest of individual
State and local regulations. I wondered if you get involved in that
sort of thing.
MS. SHANKMAN: We don't. The Department of Transportation
of course delegates some of their authority to State and local, but when
it comes to hazardous material, they keep it at the Department of
Transportation level. But State and local governments implement some of
that. They train -- the first responders are State and local people.
So it's a complicated but working network of, you know -- you're right
that State and local governments sometimes want it escorted differently
for purposes and there are general regulations in chapter 49 about armed
escorts and --
DR. WYMER: But that's out of your purview.
MS. SHANKMAN: Just the safeguards.
DR. WYMER: Except for safeguards.
MS. SHANKMAN: Safeguards. Right. And that is within our
purview.
DR. WYMER: Okay.
DR. GARRICK: Yes. That's a very interesting issue, and we
don't quite know how to get a handle on it. But since DOT is the
competent authority, as you describe them --
MS. SHANKMAN: Um-hum.
DR. GARRICK: Are they the one agency that would attempt to
piece together all the requirements of getting radioactive material from
A to Z? In other words, it's very difficult, it's very difficult to
nail down --
MS. SHANKMAN: Um-hum.
DR. GARRICK: All the requirements in moving radioactive
material around in terms of what they are, who's the authority --
MS. SHANKMAN: Um-hum.
DR. GARRICK: And why they came about. One of the things
that we discovered in one arena was that a lot of the requirements were
originator-imposed, and had nothing to do with regulatory requirements
or what have you. I would think that somebody would like to know okay,
I'm going to have to move this stuff from here to there, exactly what
the profile is of requirements.
MS. SHANKMAN: Right. Well, we've done some to help with
that, and I'm going to send to you all a copy of our recent publication,
which is schedules for transporting radioactive material. It says if
you have this kind of material, these requirements apply to you. And
it's meant for shippers and carriers. And that's one effort.
You're right, there's a lot of overlapping requirements.
There's ICAO, you know, there's international air, international rail,
maritime, there are, you know, IMO, they all have their own concerns.
They look at dangerous goods and hazmat, and radioactive material is
just one class of that. And so they look -- but I will tell you that
radioactive material, although it doesn't pose the greatest danger,
overrides the requirements for something else. So if you have something
that's mixed, you have to consider the radioactive aspects of it first,
before you consider the other aspects. You know, there are some
exceptions, of course. That's one thing.
The other -- Earl, do you want to speak to some of this?
Earl Easton is the Section Chief in one -- but he's very
much involved in transportation for years.
MR. EASTON: Yes. Some of the points I was going to make,
you've touched upon, but when you say DOT is the competent authority,
that is only for really representation at the IAEA for administrative
purposes, for international shipments. There really is no real
competent authority or overriding authority, as you know, in the U.S.
We realized this problem, so we got together with DOT and we
developed so-called schedules modeled on an IAEA document, Safety Series
80. Basically what it does is describes materials by end use, you know,
LSA material or type B shipment or type A, and walks you through NRC and
DOT regulations.
Now primarily DOT regulations deal with the carriage of
radioactive material. That's everything when you're really out there on
the road. The NRC really primary involvement is to certify that
packages meet a certain standard. And we do implement DOT regulations
on our licensee, but primarily DOT sets all the conditions of carriage.
A lot of the other requirements are set by State and local
governments, but by law they cannot be incompatible with DOT
regulations, or DOT can preempt those. They can only be additions and
not in conflict with DOT regulations. A lot of campaigns you will see
shippers voluntarily accepting conditions either from State or local
governments or other entities that are not really regulatory in nature.
They're sort of voluntary.
MS. SHANKMAN: Let me give you an example.
DR. GARRICK: That's a very important point.
MS. SHANKMAN: Yes. The American Association of Railroads,
which has had less and less members as they consolidate, they impose on
the shipment of radioactive material by rail that the train will go no
faster than I think it's 35 miles per hour. Now there is no regulatory
requirement that trains be limited to that speed. But the members of
the railroad association and the Federal Highway -- the Federal Rail
Administration has not said well, you can't have your own standard. Of
course not. You can have whatever standard you want as an association.
What it does, though, is drive up the cost significantly of shipping
spent fuel, and is it risk-informed? I don't believe so.
However, this is extra-regulatory. It's not something in
which the Department of Transportation has -- you know, we've met with
the American Association of Railroads, and in fact Earl last year did an
extensive response to questions that they had about how our regulations
came to be, what our risk basis was, and, you know, we had a pen pal
situation for several months in which we tried to give them as much
information as we could.
Congressional research also did a study of this and looked
at how our regulations came to be, and they also agreed that this 35
miles an hour was -- was whatever.
DR. GARRICK: Yeah, I seem to remember some hearings about
20 years ago over in the ICC on this whole issue of special trains, of
capping the speed at 35.
MS. SHANKMAN: Right. Be careful we just had a TV program.
DR. GARRICK: Yeah, et cetera, et cetera. And as I recall,
it was pretty clear that special trains made no sense from a safety
standpoint.
MS. SHANKMAN: Right. Earl, do you want to talk about the
--
MR. EASTON: Well, while you mentioned special trains, DOT
is in the midst of doing a Congressionally mandated look at the use of
dedicated trains.
DR. GARRICK: Right.
MR. EASTON: This was mandated in 1992, and they were
supposed to get out in the year, but it has proved to be so
controversial that it is still in progress, so --
MS. SHANKMAN: Yeah. I mean you are required if you have
hazardous material, depending on the nature of it, to have an empty car
behind and after, you know, and there are cases where you would have a
dedicated train or you would have special, you know, special clearance
and make sure that -- you know, all of that is covered in the hazardous
material realm and it is hard I think sometimes for people to understand
that radioactive material is just a class of hazardous material, and if
we can safely transport gasoline, ammonia, chlorine, you know,
hydrochloric acid every day, every way, this is not posing a greater
risk.
DR. GARRICK: Yes.
MS. SHANKMAN: Sorry for the speech.
DR. GARRICK: Well, this is an area of great interest to us
and we need to sort of what we thing some of the principal issues are,
but I am of the opinion we will want to hear from you perhaps more
frequently.
MS. SHANKMAN: Yes. We work very closely with DOT and I can
volunteer them to come with us one time. They may not volunteer
themselves, but I am sure they would be happy to come and talk to you
about how they do their business.
DR. GARRICK: Yes. I think that would be very good.
DR. WYMER: I think we have got another question.
DR. HORNBERGER: A quick question, Susan. You mentioned
that you were lined up to look at the draft EIS. what level of effort
do you anticipate devoting to the review?
MS. SHANKMAN: Well, we are going to do as much as we can
within the timeframe that we have to look at it. When it is received, I
mean we already have people designated. We also -- we know the scope of
our review based on some conversations with High Level Waste and OGC.
So we intend to -- you know, when you say what level of effort, I have a
feeling it will be a significant level of effort in a very short period
of time, you know. And it will depend, as I guess all -- in high level
waste, on the quality of what we get from DOE.
DR. LARKINS: Just one quick question.
DR. WYMER: Sure, John.
DR. LARKINS: I realize there is close coordination with DOT
and other agencies. Is there any effort to develop an integrated safety
assessment approach to develop some risk metrics in this area?
MS. SHANKMAN: I want to be careful. No, working with the
Volpe Center and with their risk data is helpful to us and we share a
lot of information, and we have opened up that line of communication
much more than we have. With IAEA, we have looked at risk insights.
Earl, do you want to add to that?
MR. EASTON: Just to put this in perspective from DOT's
point of view, the DOT looks at radioactive material, which is only 1 or
2 percent of their shipments, so when they do risk studies, they tend to
leave that in the noise and defer to the NRC, basically, to come up with
the numbers.
MS. SHANKMAN: Right.
MR. EASTON: I know DOT has several initiatives to look at
radioactive material -- I mean hazardous materials in other arenas, and
we have talked to those folks down at DOT. But, basically, they are
saying that is not their focus, you know, they have the ValuJets and
they have the gasoline tankers.
MS. SHANKMAN: Propane, right. Propane tanks that pose a
significant risk. They have spent the last year, whenever you talk to
the management at DOT, if you say ValuJet or propane gas, they get a
deer in the headlights look. Radioactive material is their least
worrisome, as Earl says.
DR. GARRICK: Yes.
MS. SHANKMAN: Maybe because we worry about it.
DR. WYMER: Are there any other questions?
MR. LARSON: You know, every year I know the committee
appreciates coming in to talk to them. But are there issues that you
see coming in up in the next year where you would like to review with
the committee, and, conversely, is the committee interested, when they
finish the NUREG-0170 update, I don't know what the date is for that, or
progress on spent fuel shipment, things that they would like to hear
from SFPO? And I think, you know, we really have tried in the past to
get DOT interested in this, but you would probably be much more
successful in bringing them in to accompany you.
MR. BRACH: It was my understanding, I think we have been
coming to meet, brief with the ACNW and provide overview and status
similar to today on roughly about a six month frequency. I believe our
last meeting was back in January, if I understand correctly. While I
wasn't in the Spent Fuel Project Office, you know, I think about a year
ago we had a previous briefing, so I mean we clearly would be receptive
to brief you on periodicity, every six months may be about right.
Susan had identified, for example, some of the NUREG-0170
studies should be completed then. The modal study, we are projecting
the stakeholder meetings asking for public input before we initiate that
activity is going to -- planning for those meetings to be this fall. A
meeting in about six months. We would be in a position to not only give
a status or outcome of the NUREG-0170, a status of where we are in the
modal study, the Volpe study, or what we refer to commonly as the Volpe
study, but trying to determine survey information, as well as to where
we are in our status of our cask review activities, other technical
issues that may be identified between now and then, as far as resolution
of others that are ongoing. From that initial perspective, this six
months might be the right frequency, but, on the other hand, as you
already indicated, we may more frequently be receptive to requests from
the committee.
DR. WYMER: I do think transportation is going to loom
larger on our horizon in the future, so we may want to come back a
little earlier than that.
MS. SHANKMAN: Well, as I say, if you would give us some,
you know, alternate dates, we will see whether we can have DOT come and
make a presentation.
DR. WYMER: We will have to caucus.
MS. SHANKMAN: No, I understand. But, you know, I volunteer
us to get DOT in here. Wasn't that kind of me?
DR. WYMER: We thank you.
DR. GARRICK: Well, thank you very much. That was very
helpful and it is a cross-cutting discipline that you are involved in
that affects a lot of things that we are trying to understand and offer
advice on. So we are very interested in keeping close to your
activities. So, I appreciate your bringing the people that you did, and
you covered the subject very well.
MR. BRACH: Thank you.
DR. GARRICK: I think I would like to suggest we take a 15
minute break now, and then if the representatives for the next topic are
here, we will launch right into it. So, with that, we will take a
break.
[Recess.]
DR. GARRICK: We would like to come to order if we could,
and the reason I'm pushing the schedule a little bit, the Committee has
a little unfinished business that if we can get through some of the
morning topics sooner than scheduled, it would be very beneficial for us
to get back to those and be in a better position to complete our full
agenda.
We're going to now discuss or hear about the draft
environmental impact statement for the proposed Yucca Mountain
repository, and we're very pleased to have the project manager for the
EIS here with us today, Wendy Dixon. And I trust that if there's any
other presenters, she will introduce them. Also, George Hornberger, who
has not returned yet, is going to lead the discussion on this topic.
So with that, Wendy, why don't you proceed?
MS. DIXON: It is a pleasure being here today, and I'm happy
to inform you that last night we had the authorization to head to the
printers on the draft EIS, so hopefully the document will be out for
review before too long. So it's a heads-up that we've been waiting for,
and very pleased to receive.
As you said, I'm Wendy Dixon. I'm the EIS project manager.
I thought that we'd start out the discussion with, you know, a little
bit of background on, you know, NEPA and what the driver is for the
National Environmental Policy Act and hence, you know, how this document
was really formulated.
This is a different kind of document than the viability
assessment or what you'll see in the site recommendation or the license
application. Its focus is different. The purpose of NEPA is to ensure
that agencies consider environmental impacts associated with proposed
actions prior to moving forward. It's for informed decision making. It
doesn't mean that you can't have significant impacts, it's that, you
know, when you make a decision, you know what those are. And it's
basically procedural in nature. It doesn't have the kind of bar that we
have for the licensing process. There's no, you know, EPA criteria that
says you have to be here or there. There's no, you know, NRC licensing
reg. It's different, it's procedural, and it mandates a process that
must be followed by Federal agencies to move forward with major Federal
actions.
It requires a hard look at environmental consequences, and
the other purpose of NEPA is to involve the public. And there's a time
and a place for public involvement with respect to an EIS. It starts
out with, you know, a notice of intent, and something called scoping,
where you go out and you solicit input from the public on the proposed
action and what should be evaluated and reviewed in the preparation of
your EIS. Then there's a deliberative process by the agency in
preparing the document. And then it goes back to the public again as
part of the draft, a hearing process for comments on the draft. And
finally you make your final EIS and incorporate and deal with and
respond to the comments that occurred during the hearing process from
the public. So it is a document that has a public process that is
incredibly important to, you know, its existence, and, you know, and to
the decision making that comes from it.
The CEQ -- the Council on Environmental Quality -- is the
entity that is responsible for the implementing regulations tied to or
guidelines tied to NEPA. It instructs agencies in preparing EISs to
focus on those things that are truly significant. The basis, the driver
of an EIS is not for amassing needless detail, but it is to focus on
impacts in proportion to their significance. And as such, there's
something that we call the sliding-scale approach under EISs under NEPA
wherein issues and impacts are analyzed with the amount of detail that's
commensurate with their importance. Trivial issues and impacts are
identified as such without extended consideration, including only enough
discussion to show why more study is not warranted. So it's really tied
to the significance of the impact in NEPA parlance.
Again, like I said, there's not a regulatory standard as it
relates to environmental impact statements, and, quite frankly, the
adequacy of the environmental impact statements have been basically
determined by the court system. That's a body of case law that has been
developed over the years as NEPA documents have gone to court. CEQ is
responsible, as I mentioned, for issuing NEPA regulations and guidance
and moderating interagency disputes, and EPA is required to review and
rate the adequacy of all draft EISs that are prepared by other agencies.
This particular environmental impact statement is different
than most environmental impact statements, and in part that's because
the Nuclear Waste Policy Act provided additional information and
guidelines to the Department in its preparation.
This EIS is going to be used for several different purposes.
It would be a companion document to the site recommendation and tied to
the site recommendation if we move forward with that. It's a companion
document to license application. And it's to be used again by the
Nuclear Regulatory Commission to adopt to the extent practicable in
connection with the Commission's issuance of a construction
authorization for this program.
NRC -- and I know that they've mentioned this already -- has
their 10 CFR Part 51 review procedures for geological repositories, and
in that they state --
DR. GARRICK: We invited them to the meeting, but they
didn't come.
MS. DIXON: Okay. Anyway, basically the review procedures
state that it will be practicable for the Commission to adopt the DOE's
EIS unless the action proposed to be taken by the Nuclear Regulatory
Commission differs in an environmentally significant way from the action
described in DOE's license application and that significant and
substantial new information or new considerations render our EIS
inadequate.
Now one of the things that we will be doing as we move
through time on the EIS is that after it comes out final we know that
there will be things that will continue to evolve on this program.
Design will continue to evolve, TSPA calculations might change or
continue to evolve, and as time progresses, we'll periodically as
appropriate, depending upon, you know, the staff of affairs in the
project, do a supplemental, you know, analysis to find out or ascertain
whether or not any changes have occurred in the project that would
require, you know, a supplemental EIS or changes to the EIS.
And just because there's a change doesn't mean you have to
go back and change the EIS. The issue is whether or not the change is
significant, and had we dealt with the impacts appropriate in the
environmental impact statement, bounded them appropriately or not. So,
you know, it's something that we're going to have to continue to keep
our eye on as we move through time.
Public agency involvement. We have had a number of meetings
with State, county, and Federal agencies. This list includes some of
them, the BLM, Corps of Engineers, Fish and Wildlife Service, U.S. Air
Force, the Navy, county, State of Nevada, Indian tribes.
There's been all kinds of different kinds of meetings going
on earlier this spring. We had three update meetings within the State
of Nevada, walking the public through how to review the EIS, what's in
the environmental impact statement. We had periodic overviews and
status meetings with the counties and State and Federal agencies.
We've, you know, discussed specific issues and concerns with various
people, particularly the counties who, you know, have been interested in
our approach to socioeconomics or environmental justice or
transportation.
We've actually had technical workshops on various
methodologies that are tied to transportation where we walked the
affected units of local government and State participants through how
the various models work such as RISKIND and RADTRAN and HIWAY and
INTERLINE, and we did offer up to the affected units of local government
and to the Native American tribes who have had ties to Yucca Mountain
the opportunity if they so desired to put together reference documents
or a reference document for the environmental impact statement that we
would reference that would discuss, you know, their issues, their
concerns, what they saw as environmental impacts related to this
program. And the Native American group actually did take us up on that,
and then we did have input specifically with respect to our offer from
Nye County, and Clark and Lincoln did provide some background
information to be used as reference as appropriate.
DR. HORNBERGER: Why are the Air Force and the Navy
interested?
MS. DIXON: The Air Force for two reasons. One is that part
of the land that would be part of the land withdrawal, the congressional
land withdrawal at one point and a time in the future if this program
goes forward is on Air Force territory. Part of it because the Air
Force activities are very close. When we do cumulative impact analysis,
we have to look at the cumulative impacts as it relates to Air Force
activities. And part of it is that there is a heavy haul route and a
rail corridor route that goes through Nellis Air Force land, and we had
to look at potential issues tied to impacts, you know, and land-use
conflicts with the Air Force on that. So several different reasons.
The Navy has their Navy spent fuel and some high-level waste that is
part of the DOE spent fuel high-level-waste inventory that is being
calculated and analyzed in this EIS.
DR. GARRICK: Yes, we are unfamiliar with the Nevada navy.
MS. DIXON: I am sorry. Well, it is really not the Nevada
navy, but, yes, it is our navy.
[Laughter.]
MS. DIXON: Yeah, the port is, yeah, somewhat shallow.
Okay. I know that a question came up earlier on who was
preparing the Environmental Impact Statement and that is DOE's
responsibility. DOE is the preparer, this is a federal government
document. But we have, obviously, had help in its preparation, and the
contract that has helped us prepare this document, which is a prime to
the Department of Energy is Jason and Associates, and their various
subcontractors. They include Tetra Tech, Battelle and Dade Moeller and
Associates have provided support with, you know, the review and some of
the technical preparation work for us, some of the no action analyses
that are included in the document.
With respect to the database that we relied upon, this
Environmental Impact Statement had a considerably large database
compared to what is normally available for EISs. I mean, you know, we
have 10-15 years of scientific investigations at the site and,
obviously, you know, as such, there was a considerable amount of
information. And one of our challenges was to ferret out amongst this
database what was important and appropriate for an impact analysis.
We also developed new information as necessary to supplement
the existing information that was available for our use.
The purpose of the Draft Environmental Impact Statement is
to provide information on the potential environmental impacts that could
result from the proposed action to construct, operate, monitor and
eventually close a geologic repository for the disposal of spent nuclear
fuel and high level nuclear waste at Yucca Mountain. And, obviously, as
I mentioned upfront in this discussion is to solicit public input.
The EIS will support a variety of different decisions
potentially over a period of time. The first and foremost is tied to
the site recommendation, the potential decision to move forward or not
move forward with the proposed action. This is one of a number of
elements that is mentioned in the Nuclear Waste Policy Act.
With respect to other types of decisions that it could
potentially support, there are transportation decisions in the State of
Nevada, that if this program moves forward, you know, at some point in
time we might want to make a decision as to whether or not we construct
a rail line in the State of Nevada to transport fuel vis-a-vis rail all
the way to the Yucca Mountain site. If we did, there are several
different corridors that we evaluated. Which corridor would be, you
know, a good corridor to move forward on? Is intermodal, heavy haul,
you know, more appropriate? So there are several Nevada-specific
decisions that this Environmental Impact Statement could also support.
The proposed action in this Environmental Impact Statement
is to construct, to operate, to monitor and to eventually close a
geologic repository for spent nuclear fuel and high level waste. The
proposed action is tied to the 70,000 metric tons that is in the Nuclear
Waste Policy Act. You know, the limit is 70,000 metric tons, as you
know, for the first license, until such time as there is a second
repository. The breakup is 63,000 metric tons for commercial spent
nuclear fuel, 7,000 for DOE SNF and high level waste.
With respect to alternatives, I mentioned that this Nuclear
Waste Policy Act made this EIS a little bit different, and it certainly
did with respect to our review of alternatives to be considered in the
EIS. The Nuclear Waste Policy Act provided us a road map with which to
deal with alternatives and in the Nuclear Waste Policy Act it basically
said that we need not consider in this EIS either the need for a
repository, alternatives to geologic disposal or alternative sites to
Yucca Mountain. I mean Congress made a lot of these decisions for us.
These are the kinds of things that are frequently looked at. In fact,
they were looked at in a programmatic EIS tied to this program that was
done in 1980. The Nuclear Waste Policy Act, like I said, provided us a
road map, and these things were not evaluated in this Environmental
Impact Statement as such.
Based on the Nuclear Waste Policy Act and the road map
provided, what we did focus on were two alternatives and one is the
proposed action which I have described, and the other one is the no
action alternative under which there would be no development of a
geologic repository at Yucca Mountain and the fuel would basically, in
the analyses that we have done, -- and I will get into it in more detail
in a moment, -- stay where it is at existing locations.
In fact, when we went through scoping, the no action
alternative was an issue that came up very frequently. There was a lot
of the public that wanted us to, you know, consider no action equal to
the proposed action in this EIS. That is unusual for EISs. Usually,
the no action alternative doesn't really quite get that weight. We did
spend a lot of time on it in this particular Environmental Impact
Statement and took the analyses very seriously.
DR. FAIRHURST: When you say no development of a geologic
repository at Yucca Mountain, does that really imply no geologic
repository? You are not required to consider as part of that, you know,
putting it somewhere else?
MS. DIXON: Right.
DR. FAIRHURST: I am wondering why you put "at Yucca
Mountain" in there.
MS. DIXON: Okay. Well, I could have quit earlier than
that.
DR. FAIRHURST: Yeah, I was just wondering whether it was
restricted to nothing at Yucca and possibly saying no to --
MS. DIXON: It basically was either the Yucca Mountain
geologic repository or leaving it where it was.
DR. FAIRHURST: Okay.
DR. GARRICK: Wendy, when you talk about the purpose of the
draft and a variety of decisions, it is just kind of a language issue
here. It says, "Provide information on potential environmental impacts
that could result from a proposed action to construct, operate and
monitor and eventually close." It almost sounds like that once it is
closed, it is not an environmental impact issue, and I know that is not
true.
MS. DIXON: The analyses that we did went out to the 10,000
year timeframe, plus we did do analyses to peak dose, to 1 million
years.
DR. GARRICK: Okay.
MS. DIXON: So the long-term performance is part of this.
DR. GARRICK: Okay. And the basis for that is the
performance assessment as to where the peak dose occurs?
MS. DIXON: Yes.
DR. GARRICK: And so you took it out to the peak dose?
MS. DIXON: We did for a peak dose, but -- and I will get to
it in a little bit. Our calculations really focus, for the most part,
on the 10,000 year timeframe as it related to latent cancer fatalities
population dose assessments.
DR. GARRICK: Okay.
DR. FAIRHURST: Since that issue has been opened, you have
the word in there "and monitor." Do you have to go into much detail, or
can you defer that to some other document of DOE, the monitoring, what
is implied by monitoring?
MS. DIXON: From a NEPA perspective, and, again, what we are
looking at are impacts, so impacts tied to emissions into the air,
amount of land disturbed. You know, we are not interested and it is not
important for us to describe exactly the scientific aspects of what
would be tied to the monitoring. It is what are the nature of
activities that would result in land disturbance and/or, you know, air
impacts and/or vehicle emissions. So this EIS doesn't face itself with
the struggle of trying to define exactly what the monitoring would be.
It talks about the kinds of activities that could be included in
monitoring, and how those impacts, you know, play out.
DR. FAIRHURST: There is a requirement for monitoring during
the preclosure period, that is what I am talking about.
MS. DIXON: Oh.
DR. FAIRHURST: That is not part of your bailiwick?
MS. DIXON: No, it really isn't. And I guess, you know,
from a NEPA perspective, we could have used the word, you know,
performance confirmation, you know.
DR. FAIRHURST: Yeah, but that still doesn't get you out 300
years. That is the performance --
MS. DIXON: The EIS did look at potential impacts of closing
the site at 50 years, closing it at a hundred years and waiting for 300
years prior to closure. So we did try to cover the variations that
would exist, and whenever that decision may or may not be made. Did
that answer your question?
DR. FAIRHURST: Yes.
MS. DIXON: Okay. In order to perform the proposed action,
one obviously needs to get the fuel from where it currently is to the
potential Yucca Mountain site. So part of the proposed action and part
of our analyses focused on transportation and transportation impacts.
National transportation examines the transportation of the spent nuclear
fuel from its existing location. There are 77 sites that we worked off
of, 72 commercial, five DOE sites, to the Yucca Mountain site.
There were two national transportation scenarios that we
evaluated. One of them called the "mostly legal-weight truck" and one
of them is the "mostly rail" scenario. The EIS is not trying to make a
decision on what the exact mix is going to be as you move through time.
We recognize that over a period of time there is probably going to be a
variation in mixes that occur between truck transportation and rail
transportation. So what we tried to do in our analyses is bound the
impacts by looking at mostly truck and mostly rail. The reason why I
say "mostly" is that there were some situations that we couldn't push
into rail because some reactor sites didn't have the capability to deal
with, you know, heavy casks and off-loading onto rail cars.
With respect to the navy fuel, it can't go on legal-weight
trucks, so it had to include looking at rail. So we adjusted the
analyses where we needed to and, beyond that, we tried to bound the
impacts by looking at these two approaches.
DR. WYMER: Did you find that the restriction, holding
yourself to legal-weight trucks, to be restrictive? You can't always
use rail and sometimes you have to use --
MS. DIXON: Restrictive? I am not really sure what you mean
by that word. It changes the impacts.
DR. WYMER: Yeah, I guess that is what I was driving at.
Yeah. But you didn't really get into that at all, you said it is either
legal-weight or it is rail?
MS. DIXON: Mostly legal-weight or mostly rail. Like I
said, where we couldn't go on one or the other, we specified where you
couldn't make those, you know, adjustments, and we did the calculations
in those cases. For example, going back to the mostly legal-weight
trucks scenario, we didn't make the navy ship in legal-weight trucks
when we knew they couldn't. So we did the legal-weight trucks
everywhere we could and then we did the assessment adding on the rail
transport that was required.
DR. WYMER: The assumption sort of was that that was the
worst case, I guess, because --
MS. DIXON: It is as it relates to amount of shipment. I
mean the legal-weight truck has a lot more shipments in it than the rail
scenario does.
DR. WYMER: Or the extra-legal-weight trucks.
MS. DIXON: Yes. Yes. Thank you.
Other analyses that we did, other comments that we got when
we went out for scoping, and this included comments from the State of
Nevada, quite frankly, was that we look at and assess reasonably
foreseeable cumulative impacts tied to an expanded waste inventory,
i.e., look at what if the repository one day, the principal repository
one day ended up taking all of the country's spent nuclear fuel and
high-level waste. What would the impacts be for that? And there were
some comments tied to greater than greater than Class C waste, what if
you added in greater than Class C waste as part of your calculations.
So what we did in this environmental impact statement that
hopefully all will see before too long was under cumulative impacts --
not under the proposed action, but under cumulative impacts -- we had
two modules, and module 1 was taking the base case to the 70,000 metric
tons, and adding -- and doing impact calculations on the remainder of
the spent fuel and high-level waste inventory, which equals roughly
119,000 metric tons when you add it together. And then we did another
module, Module 2, which takes Module 1 and adds in there potential
impacts from greater than Class C waste and special performance waste,
which is basically DOE's equivalent of greater than Class C waste.
So those are included as part of our cume impact analyses,
and there are TSPA calculations on these additional inventories as well,
the focus really being on Module 1, because our sensitivity analyses
basically showed that the difference from adding Module 2 was, you know,
not discernable.
We also in the environmental impact statement described and
evaluated the current preliminary design concept, and we identified the
design features and alternatives that are being evaluated as part of the
EDA process that's ongoing right now. So the focus was basically for
understanding the differences and impacts, looking at three thermal
loads -- high, intermediate, and low -- the high being 85 metric tons
per acre, intermediate was 60, low was 25.
The design that we focused on for the draft environmental
impact statement is based off of the reference VA design with
adjustments to get it to low and intermediate thermal load. And then we
took a look at all of the various design features and alternatives and,
you know, made a quick assessment of environmental differences between
them, and that there were the five EDAs going on, and some of the EDA
features we looked at in terms of mitigations like drip shields would be
under the discussion of mitigations.
If the Department makes the determination between now and
the final to change the design, the final EIS will pick up and include
in its calculations whatever the design is, you know, at that particular
period of time. But we provided the path forward, you know, to that in
the preparation of the draft environmental impact statement.
This analytical structure basically provides the flow path
for, you know, how we put together the environmental impact statement,
and it has on it, as I mention, action alternative as a proposed action
to construct, operate, monitor, and eventually close. And then it has
the no-action alternative as the other major alternative that we focused
on.
The no-action alternative has two scenarios that are tied to
it. Both of them are tied to 10,000 years. One maintains institutional
control for 100 years, and then basically it doesn't take credit for
institutional controls after that, and we did the calculations on that
scenario. And then there's another scenario that takes credit for
institutional controls for the whole 10,000-year period.
And the fuel is where it is for, you know, that whole period
of time at the 77 sites across the country.
I mention the thermal load scenarios, high, intermediate,
and low. Differences for long-term performance, you know,
statistically, you know, really, you know, are not there. You know,
you'll see some number changes, but they are not statistically different
when you're finished looking at them.
What you do see in differences principally are tied to
preclosure kinds of issues. For example, when you get to low thermal
load you have a larger area, you have more construction, you have a
larger work force, more utility support, larger muck pile, you know. So
you're looking at a lot of differences tied to, you know, preclosure
kinds of issues. But, like I said, postclosure they are not as visible.
When you turn to transportation scenarios, we already talked
about mostly rail and mostly legal-weight truck. In the State of Nevada
most of you know we have no rail line that goes all the way to Yucca
Mountain, so we also did an analysis of potential impacts of
constructing a rail line that would go to Yucca Mountain, again work as
far as land disturbed, you know, we looked at five different potential
rail corridors. And then we also looked at the potential, there's three
different intermodal transfer facilities and then five different
heavy-haul routes off of them, and impacts were analyzed for those.
With respect to packaging scenarios, the focus there was
again mainly bounded from mostly canistered to mostly uncanistered. The
EIS is not trying to make a decision as to whether the fuel would come
in one way or the other. We were trying to bound impacts such that, for
example, under mostly uncanistered you would have the largest
waste-handling facility, you would have the largest work force, you
would have the largest exposures so again, bounding both ends of the
spectrum, you know, and doing your calculations on impacts from that
regard, and allowing this decision to be what it may be, as you move
forward.
DR. HORNBERGER: Just a comment. We often do things as we
know in radioactive waste that aren't -- that are difficult to
rationalize, but it's interesting that one would do a 10,000-year
institutional control on the no-action alternative, but not even
consider the possibility of any institutional control at a site in
Nevada.
Just an observation.
MS. DIXON: Well, we think that's true, too.
But, you know, NRC and I think EPA both have had discussed
that. Counting on and relying on institutional controls beyond 100
years is problematic, and we don't take credit for them in the
repository, so we did include one scenario where, you know, we didn't
credit for them for no action either. So there is a parallel baseline.
And that's really what the no action is for, is to provide a basis of
comparison against the proposed action.
We make it really clear in the EIS that we're not
foreshadowing or predicting that, you know, if you don't pick this,
you're going to end up with one of these other two. It's a baseline,
you know, from which to do analyses, and anything that might happen in
between the two is purely speculative on our part right now. We don't
know what Congress would do, where they would do it, you know. And
certainly it was not appropriate for us to go there.
DR. LARKINS: When you look at your no-action alternative in
the storage of these spent fuels at the 77 sites, is that all in
dry-cask storage facilities?
MS. DIXON: Yes. Yes. I mean, before we started the
calculations, the assumption is that all the fuel is removed from pools
and is, you know, responsibly placed in dry storage. And then when you
did the one that has institutional --
DR. LARKINS: And then you assess the performance of that
dry-storage facility over 10,000 years.
MS. DIXON: Well, there are two scenarios. One is basically
it maintains institutional control for 100 years, but during that 100
years, you're maintaining your facility, you know, and, you know, you're
replacing the building once, I think. And then after that you walk away
and it does what it does as it relates to degradation, and that varies
as you would presume based on climate and where the facility is.
When you do the one with maintenance of institutional
controls, what we did was assume that the facility was basically
replaced every 100 years and the fuel was moved from, you know, one can
to another as it got old, and, you know, we did what we thought was
appropriate to maintain the integrity of the facility.
DR. LARKINS: I'm just trying to understand how you did the
analysis. Okay.
MS. DIXON: Yes.
DR. CAMPBELL: Can I ask you if that included dose to a
critical group, for the action were you calculating dose to some
critical group?
MS. DIXON: There was worker dose. I don't know that there
was -- in the no-action scenario, Gene, was there any MEI dose that
occurred there to the worker?
MR. ROLLINS: I'm Gene Rollins with Dade Moeller &
Associates.
For each scenario -- scenario 1 was institutional control.
We estimated some maximally exposed individuals in the work force and in
the population. And that's from routine -- of course, you don't really
have any releases under institutional control, but you do have direct
radiation exposure from the various activities that go on in maintenance
of the material.
Under scenario 2 we assume that these facilities will
degrade over time, and then you have releases to the accessible
environment. Most of the impacts that we estimated were basically from
surface water going down and exposing large numbers of people to very,
very small doses of radiation. But we did do, for purposes of
illustration, we did do some MEI illustrations that showed say a
subsistence farmer living near these facilities and drinking
contaminated ground water, what their exposure could possibly be. So
you will see some of those numbers in there.
MS. DIXON: But what we're dealing with in the DEIS for no
action are basically hypothetical sites, so you can't really -- you
know, I mean, it's a hypothetical MEI at a hypothetical location within
a region, you know, that we, you know, pulled together for purposes of
analysis.
DR. LARKINS: Does that mean -- did you include external
events besides flooding or --
MS. DIXON: The maximum credible accident I think we used
was the airplane crash into the facility, if that's what you were
referring to.
DR. LARKINS: No, I was thinking about natural events.
MR. ROLLINS: The way we discuss -- the way we handle the
natural events was basically in our uncertainty discussion we discussed
how much, say, a flood or an earthquake, what kind of impact would that
have on our results. But we did not do any quantitative analysis based
on natural phenomena for scenario 2.
DR. LARKINS: Okay.
DR. WYMER: Would I be right in assuming that the dose
consequences in the no-action alternative were more than in the
geological repository?
MS. DIXON: Definitely under the no-action,
loss-of-institutional-control scenario, yes.
DR. GARRICK: That was pretty sneaky, Ray.
[Laughter.]
DR. FAIRHURST: Community moving into the abandoned
building?
[Laughter.]
MS. DIXON: Well, we had a lot of discussion on it. I mean,
what do you do as it relates to climate change, as an example. You
know, you have an ice age coming in that's going to cover a certain part
of North America, and it was like let's not go there, let's recognize
qualitatively that there be things like that happening, and, you know,
move on here with the analyses.
Short-term environmental impacts. These are examples of
analyses that we did with respect to the environmental impact statement,
pretty standard as it relates to EIS's.
Long-term impacts. In the environmental impact statement we
looked at human health impacts at four locations. This is definitely a
divergence from what you saw in the viability assessment. In the EIS we
looked at variations in impacts from an MEI at 5, at 20, at 30, and at
80 kilometers. We had a dose number and a probability of a latent
cancer fatality number. There's also a population dose number that
you'll end up seeing. We did both the mean and the 95th percentile.
As the next bullet says and what I've already mentioned,
consequences are in terms of rad dose and the probability of an LCF or
latent cancer fatality, and we also examined peak dose out to a million
years. So in the end what you ended up with was, you know,
calculations, you've got three thermal loads, you've got, you know, two
different waste inventories, you have four different locations, and TSPA
calculations were done for all of these hundred, you know, realizations
for each one of them.
DR. FAIRHURST: Was any consideration given to the potential
for advances in medical technology so that cancer would be less of a
concern?
MS. DIXON: No. We recognize that things will change,
but --
DR. FAIRHURST: Especially over a million years.
MS. DIXON: It's purely speculative as to, you know, when
you would assume that sort of thing, and NEPA says to the extent
possible say away from speculation. And that was --
DR. FAIRHURST: It's not speculation. There have been over
the past definite information that the cancer fatality rate dropped as a
proportion of the cancers.
MS. DIXON: We did not take credit for a belief at a certain
period in time we would have a cure for cancer. Although I think it's a
good point.
DR. HORNBERGER: Speaking of speculation, you mentioned that
you did a population dose.
MS. DIXON: Um-hum.
DR. HORNBERGER: Did you do population latent cancers using
the linear no threshold hypothesis?
MS. DIXON: Yes. And what we basically did was on that you
would take the number of people that were living at 5 kilometers -- the
answer is zero; that makes it fairly easy -- the number of people that
are living at 20 kilometers, and you do your calculations out there, and
there's a few people but not very many. Most of the population is at
30, and then, you know, the population at 80 and you put them together
and, you know, we had a total LCF number.
DR. CAMPBELL: These are calculations at 10,000 years?
MS. DIXON: Yes.
DR. CAMPBELL: But you are not doing these kinds of things
at a million years?
MS. DIXON: Not, LCS, there was a dose. Yeah.
DR. CAMPBELL: Okay. But you are doing this type of
analysis at a million years?
MS. DIXON: No. Well, not this kind of analysis. It was a
much higher level dose number for peak dose, wherever it might, you
know, it varied at the distances.
DR. CAMPBELL: I am just curious how NEPA rationalizes this
statement about speculative when you are talking about these kinds of
projections at even 10,000.
MS. DIXON: I understand. And under uncertainties, we spent
a little bit of time discussing that. Now, there are plenty when you
move out in that kind of a timeframe.
I mentioned the no action analysis. And we have talked
about this a little bit already. This is, you know, something that if
this program doesn't move forward, we are not really sure, you know,
what Congress will end up deciding. It is very uncertain. And what we
did was look at the two scenarios that I mentioned to you in order to
basically provide a baseline from which to compare the proposed action
against.
One other thing that we did in the Environmental Impact
Statement, and we spent quite a bit of time in doing so, was discussing
what is called, you know, responsible opposing views. And what we did
was meld in these discussions wherever the topic occurred in the
Environmental Impact Statement. So, for example, if, in the
Environmental Impact Statement there was a discussion on ground water
travel time and there was a responsible opposing view related to that,
we recognized that responsible opposing view in that particular section,
and there is a discussion there that talks to it. So there are a number
of these throughout the document as you read it.
To determine what actually fell into what we called an
opposing view or not, we had senior staff review the files, gathered
views within the public domain having a basis in credible data or
methodology. We determined the opposing views that have current
significance and are within the planned scope of the EIS. And then,
like I said, we --
DR. WYMER: Were there many of those?
MS. DIXON: Yes, quite a few.
DR. WYMER: With credible data?
MS. DIXON: Well, I guess that is a matter of opinion, but
we did include a number of opposing views in a number of different
areas. For example, I will give you one that, you know, we looked at
cultural resources as part of the Environmental Impact Statement. And,
you know, there is a view as it relates to, you know, the more
scientific, you know, viewpoint of cultural resources, and then there is
a Native American perspective from the tribes that at one point in time
or another, you know, had an affiliation, a tie to the Yucca Mountain
site. Now, there position is entirely different. And we recognize
their concerns and their interests, you know, as part of that.
Cumulative impacts is an important part of any Environmental
Impact Statement, and when you deal with an Environmental Impact
Statement that covers 10,000 years, then, you know, dose calculations at
the peak dose, which is not usual. Most EISs are for fairly short
periods of time.
Cumulative impacts become fairly interesting. When you talk
about cums, you are talking about anything that ties into the category
of reasonably past current future, so it is a fairly broad perspective.
And as an example, when you look at the cumulative impacts tied to the
national transportation of radioactive materials, you know, you end up
going back to, you know, the 1940s and, you know, medical shipments and
all kinds of things. The cum impacts take into consideration, you know,
from the beginning, you know, to what is potentially projected into the
future and we tried to do a very thorough job of our cum impact
analyses.
These are examples of some of the things that we looked at
in doing our cumulative impacts. We are sitting on the Nevada test
site. Are the cum impacts related to, you know, based on the data we
have on cum impacts from NTS activities? What is the Air Force doing?
You are all familiar with the Beattie Waste Disposal Area. Again, you
know, we tried to be fairly thorough and recognize what was out there
and to, you know, assess the cums tied to those various activities.
This is a copy of what our contents are for the Draft
Environmental Impact Statement. You have the package in front of you
and what we tried to do for your ease in deciding how to review the
document was to put page numbers in these various sections. So you can
see that the summary itself is approximately 80 pages, Volume 1, 600
pages. These are the various chapters and how we put them together. If
you turn to the CEQ regs on what an EIS should include, you will find
pretty much, you know, those topics set up as chapters here.
Then we have a Volume 2, which are the appendices. And, you
know, there is quite a bit of information in the document itself. But
if you want to know, you know, the methodology and a lot more on the
technical details that were tied to the results that you are seeing in
the Volume 1 of the EIS, you go to the appendices and all those details
will be in there for you to examine.
We have -- I think there is over 600 references that we used
for the preparation of the document. We tried to make this as
user-friendly as possible so that when we use a reference, there is a
page number there for the reference so it should make it easier for you
all to find and track the references.
I mentioned when we started this discussion that we have
authorization to go to print on this document and, hopefully, it will be
out before too long. The list on the hearings are still tentative at
this point. There is 13 that we have tentatively scheduled, one in
Washington, D.C., which is the closest, obviously, to where you all are
at. And then we set up one special meeting with the Consolidated Group
of Tribal Organizations. Again, those are the tribes that have affinity
to Yucca Mountain. And it is not called a hearing because it is special
to them, but that is set up for September 27th currently.
We have been out asking for public interest related to this
document for some period of time, and we have little cards. I don't
know if any of you all saw them or not. And it allowed people or
provided people the opportunity to check the box as to whether or not
they wanted just the summary, they wanted Volume 1, Volume 2, CD-ROMs,
whatever the case might be. So, depending upon what people have asked
for, we will send out hard copies or CD-ROMS. This document will also
be available over the Internet, so you can get it off the web.
References will also be available -- we have all the references in four
reading rooms, one of which will be in Washington, D.C., three in the
State of Nevada.
With respect to those references that are not copyrighted,
we will also put those on CDs for people that are really interested in
the references, and non-copyrighted references will also be available
over the Internet.
And we have been telling people there is all kinds of ways
to submit comments. You can come to a hearing and give them to us
verbally. You can send them to us in writing. You can provide them
over the Internet. You can send them to us in fax. And we have all the
confidence in the world that we will get a lot of comments.
DR. WYMER: When will that be on the Internet?
MS. DIXON: I can't even answer when exactly I am going to
get the hard copy to you in hand, but shortly thereafter, so, hopefully,
early August.
DR. WYMER: Okay.
MS. DIXON: Which is coming up fairly rapidly.
DR. HORNBERGER: It sure is.
MS. DIXON: Okay. This is the timeline of events and I did
want to go through it just very briefly. We did start out with scoping
in August of 1995 with the notice of intent, and we had 15 scoping
meetings. And when I was in Chicago, which I think was in October of
1995, I got a call and it was one of those great calls you like to get
that said, "Wendy, FYI, the NEPA budget was zeroed out in 1996." You
know, I am like -- so, anyway, we basically finished the scoping
process, gathered up the comments and activities on the EIS were
deferred in 1996. I mean we were down for that year.
When we resumed again in October of 1996, which was the
beginning of our FY '97 calendar year, we hired -- selected Jason to be
our contractor to help prepare the Draft and Final Environmental Impact
Statement. We dealt with all the comments that came from the scoping
process and published what we called a Comments Summary Document,
recognizing what the comments were and how we were proposing to deal
with them in the Draft Environmental Impact Statement. And since that
point in time in 1997, we have been collecting data, doing impact
analyses, and preparing the Draft Environmental Impact Statement.
It will be out for review end of this month, early next
month and right now there is a 90 day review period for the document.
DR. HORNBERGER: What is your best guess on whether that
will be extended?
MS. DIXON: The Governor of the State of Nevada has asked
for an extension and the Department has not yet responded to that
extension, so I don't -- I can't second guess what might happen.
Anyway, right now with the current schedule the FEIS is
planned to be out in August of the year 2000. Obviously I think if
there's an extension in the comment period that date will probably move
out a little bit to accommodate the extra time for comments. But we'll
have to see. I don't know.
So that concludes the presentation.
DR. LARKINS: A quick question. As DOE finalizes the
design, do you see a need for a major change or modification in the EIS?
MS. DIXON: Not from what I've seen. What we are doing
right now, and when you see the draft, what you will see, like I said,
is a recognition on the various design alternatives and features that
have been evaluated, and a recognition of the five EDAs that are being
looked at right now.
DOE hasn't made a decision on an EDA yet. But if that
happens between the draft and the final, we will do and include that
specific design as part of our FEIS calculations. And then, like I
said, as we move through time, let's say that there are continued
adjustments to whatever that EDA is, you know, that's past when the
final EIS is out, we'll do supplemental analyses periodically as the
program moves forward to find out and ascertain whether or not, you
know, our, you know, conclusions reached in the EIS are still valid or
not. And if the answer is yes, you know, we'll document that and move
on. If the answer is no, we'll have to go back and do a supplemental,
you know, EIS perhaps. So --
DR. HORNBERGER: John?
DR. GARRICK: I only have one question, I think.
When you were talking about the sliding-scale approach, you
said that issues and impacts would be analyzed with the amount of detail
that is commensurate with their importance. How did you decide on
importance, and how did the public participate in that -- in
establishing importance?
MS. DIXON: The public participates as it relates to its
concerns and issues that it provides during both the scoping time frame
and what it's worried about or interested in seeing in the document.
And, you know, also there are comments as it relates to how well we
think we dealt with that, and their comments in the draft EIS when they
see that. So the public is involved in those two aspects.
From our perspective it depends in part upon the
significance of an impact. If you end up with something that has an
incredibly small probability or the impact is less than less than less
than 1, you can do a number of variations in between that, and it
probably doesn't make a whole lot of difference, because the impact is
very small. If you have an area that is very large -- I'm moving now to
biological kinds of things -- you have an area that's very large, it is
not particularly unique, it doesn't have a critical habitat, you know,
you take a look at whether or not there's endangered species, there's
all kinds of things you look at to ascertain how much additional focus,
you know, is really necessary in that particular area, which will
change, depending upon where you're at, obviously.
DR. GARRICK: Yes. One of the things I was getting at is I
suspect that you relied quite a bit on supporting analyses and other
activities that are going on such as the performance assessment to
assign importance. So as far as acceptance of the EIS is concerned,
that probably means that it's heavily dependent upon the acceptance of
these supporting analyses. Is that right?
In other words, if the PA has no credibility, then as far as
radiological impacts are concerned, then the EIS would have some
difficulty establishing credibility.
MS. DIXON: Let me try to answer it this way. Obviously no
credibility is not a good thing. This is not --
DR. GARRICK: I'm just trying --
MS. DIXON: Where we want to end up at. However, if one
finds out, as an example, as one moves through time that we should have
been more conservative and you should have had a more conservative waste
package degradation model or something like that or the corrosion rates
were wrong, you know, you had to redo the calculations, and in redoing
the calculations the LCF numbers changed somewhat at the end, if I'm
still dealing with numbers that are very, very, very small, you can
probably do a lot of manipulation in there, and it's really not going to
change the long-term impacts from a NEPA perspective very much. It may
have an entirely different outcome from a licensing perspective, you
know. But from a NEPA perspective --
DR. GARRICK: Yes.
MS. DIXON: It may not be as important.
DR. GARRICK: But another thing I was trying to get at here
is if it turns out that there's considerable difference between the
results of the EIS and the results of these other documents --
MS. DIXON: Um-hum.
DR. GARRICK: You know, that could create some real
problems. And --
MS. DIXON: Yes. We'll have to go back and do our
supplemental analyses as things change to do what we mentioned in our
earlier, you know, have those changes in assumptions or models or, you
know, whatever, been significant enough to change our, you know, impact
analyses --
DR. GARRICK: Right.
MS. DIXON: In the EIS. And if the answer is no, we'll
document it. If the answer is yes, we're going to have to go out and do
some more work.
Ted, did you have something you wanted to add?
DR. CAMPBELL: You've got to go a mike.
MS. DIXON: Ted Doerr has been our EIS project manager from
Jason.
MR. DOERR: I was just suggesting maybe you would like to
remind them how the EIS was built in relation with VA and how the FEIS
likely would be supported and aligned with SR work in terms of
performance.
MS. DIXON: Yes. I think I mentioned that up front, that
we're going to, you know, go ahead and make the transitions that the
rest of the program does as it relates both to TSPA and to design as we
move into the final.
DR. HORNBERGER: Ray?
DR. WYMER: No, I fired all my shots.
DR. HORNBERGER: Charles?
DR. FAIRHURST: Well, I don't want to reopen this issue, but
I think maybe what John's -- what was a part of John at least would
be -- the EIS it seems to me has an opportunity or is an opportunity to
identify what is important and what is perceived to be important is a
very different, you know -- and you just have to deal with what you
consider important, right? But you're taking into account all of these
public reaction periods. And there's a perception that the radioactive
hazard is a much more significant thing than perhaps it is.
MS. DIXON: That's an issue that's hard. It's very hard to
deal with.
DR. FAIRHURST: Yes.
MS. DIXON: Because there is, as you know, a lack of
understanding, a lot of fear, you know, tied to anything that has
radioactive materials associated with it.
DR. FAIRHURST: Absolutely. And --
MS. DIXON: Well, in all honesty --
DR. FAIRHURST: You have to be reasonably objective, right?
You have to --
MS. DIXON: One of the issues that certainly exists with the
States and with the counties, you know, part of the general public, are
issues tied to perceived risk.
DR. FAIRHURST: Yes.
MS. DIXON: And NEPA, you know, stays away from those
things, you know, and basically, you know, our challenge is to make sure
that we can show there's a causal relationship between the activity and
the impact, and if that causal relationship is not there, it falls into,
you know, the perceived-risk category, and we don't take that on in the
EIS. We recognize that it exists, but it is an area that is very
difficult to contend with, and very speculative in nature.
DR. HORNBERGER: Okay. Questions from the staff?
DR. CAMPBELL: Yes. I have a couple.
You didn't reference in your presentation the WIPP EIS.
MS. DIXON: It is referenced in the EIS, though.
DR. CAMPBELL: In the EIS. Are there issues -- I mean, have
you guys gone back and looked at the WIPP EIS and the process and pulled
out of that lessons learned?
MS. DIXON: Yes.
DR. CAMPBELL: And can you share some of the key ones?
MS. DIXON: I don't know if I can tie it to specifically
lessons learned, but we have people that have been involved in preparing
this environmental impact statement that we pulled from the WIPP EIS,
that we pulled from the Idaho spent nuclear fuel EIS, and not only was
it a matter of, you know, understanding what was in the documents, using
them as references, but we actually have people that worked for us that
helped prepare those documents, which I think was more than helpful.
So if you took a look, as an example, for the methodologies
that we used for transportation, you know, for our EIS, it is very
consistent with the methodologies that have been used, you know,
successfully before for WIPP, for Idaho, you know, for other DOE NEPA
documents, and one of the NEPA challenges -- or not challenges, but
things of import, is to take a look at other documents that exist so
that you're not reinventing the wheel and incorporate by reference or,
you know, otherwise learn to the extent possible. So we really did
spend quite a bit of time doing that for this environmental impact
statement.
DR. CAMPBELL: Are there issues that are unique to Yucca
Mountain that did not show up in the WIPP EIS, or they're a very similar
sort of issue?
MS. DIXON: Issues is sort of a broad category, so if I
could define issues as being socioeconomics, land use, and those kind of
broad categories or similar, you know --
DR. CAMPBELL: Well, for example, in the WIPP EIS, did they
do an analysis that looked at leaving true waste at the various DOE
sites --
MS. DIXON: Yes.
DR. CAMPBELL: And the impacts of those relative to putting
it in the --
MS. DIXON: They went out to 10,000 years. They did not go
out to peak dose. So there are some differences there, you know, with
respect to, you know, how far they push the envelope.
DR. CAMPBELL: A second question. What -- in an EIS you're
looking at -- some of the impacts you're looking at are real-time
impacts. I'll call them preclosure impacts.
MS. DIXON: Preclosure impacts.
DR. CAMPBELL: Have to do with, you know, the physical
construction of the facility, the transport, and so on and so forth.
Others are long-term impacts, mainly radiological hazards.
Is there some sort of weighting factor for where you focus
your efforts on what the EIS looks at, or does it kind of look at those
equally? Preclosure versus postclosure impacts.
MS. DIXON: I guess, you know, it looks at them equally in a
general sense. In a specific sense, because preclosure impacts have
more disciplines involved, you know, you have socio-economics because
you have a work force, you know, which impacts the amount of money that
is being spent in the economy, and you will have land that is being
disturbed, and so if you look at the chapters dealing with preclosure
impacts, it is considerably longer than the chapter dealing with
postclosure impacts, because, as you know, the postclosure impacts are
principally tied to rad, and it is very focused, whereas, preclosure is
a really broad plethora of, you know, analyses.
DR. CAMPBELL: Okay. One last question, you refer to in
your diagram, canister versus uncanister.
MS. DIXON: Yes.
DR. CAMPBELL: What is that referring to, the waste package
itself, with or without a waste package, or is that in terms of
shipping, or what?
MS. DIXON: It is in terms of impacts that would be derived
from handling the fuel. So if the fuel came to us and it was already
canistered and you didn't have to handle it any more, you know, it
didn't have to go to your waste package facility, you didn't have to
remove it, you didn't need the pool, you know, you have less workers,
smaller building, you know, less dose. You know, if you have -- if you
go under the assumption that everything that is coming to you is
uncanistered, then you would bound the impacts on the upper end with
large facility pools, storage, handling, you know.
DR. CAMPBELL: Okay. So that is --
MS. DIXON: Impact-related.
DR. CAMPBELL: -- multi-purpose canister versus --
MS. DIXON: Single purpose, as an example.
DR. CAMPBELL: -- a single purpose canister.
MS. DIXON: Yeah.
DR. CAMPBELL: Not waste package or not waste package within
the repository.
MS. DIXON: Right. Right.
DR. CAMPBELL: Okay. Fine. Thank you.
DR. HORNBERGER: Wendy, with a 90 days comment period, you
know that the NRC, in general, and the ACNW, in particular, will have a
relatively quick turnaround time to get comments back. Again, just -- I
am just asking you for a gut level feeling, and you probably won't be
able to give it to me, but I will ask the question anyway. Could you --
do you see any particular areas of the draft EIS that you think it would
be most valuable for you to get comments on from let us say the ACNW, or
the NRC?
MS. DIXON: I obviously have to believe that the document is
very valuable in its totality, so I can't give you that.
DR. HORNBERGER: Okay.
DR. FAIRHURST: The ACNW counts on everything to be
extremely valuable.
DR. HORNBERGER: Well, I mean it is obvious that the NRC
would be interested in the radiological aspects, obviously.
MS. DIXON: The rad impacts.
DR. HORNBERGER: But to a certain extent, because the NRC
has to adopt, insofar as they can, the EIS, they have to look at the
whole thing.
MS. DIXON: Well, maybe that focuses you towards the rad
impacts as well, and there is, you know, analyses there to look at, both
for pre- and postclosure and transportation.
DR. FAIRHURST: Transportation.
MS. DIXON: Yes.
DR. HORNBERGER: Okay. Any other questions?
DR. LARKINS: Yes. Just a quick one.
DR. HORNBERGER: John.
DR. LARKINS: The Chapter 9 in there, "Management Actions to
Mitigate Potential Adverse Environment Impacts," is that something that
is required or is that something that was added?
MS. DIXON: No, that is something that we have to look at
and it is required. These are, you know, the types of things that can
be done to help mitigate impacts. And as an example, I mentioned the
fact that we would include, or have included drip shields, because,
again, we haven't picked an EDA yet. But it is right now one of the
kinds of things you could do to mitigate the impacts. You know, if it
is included it will become part of design.
DR. LARKINS: So that would include things like intervention
and monitoring?
MS. DIXON: It includes things like, you know, building
berms so you don't have, you know, hazardous constituent spills and, you
know, there is a whole suite of things that would fall under that
category of potential things that could be done to mitigate. In fact,
reclamation is a mitigation, you know, tied to land disturbance.
DR. LARKINS: Yes, that is what I was thinking. Okay.
DR. HORNBERGER: Wendy, thanks for the presentation. It was
a lot of enthusiasm and we really appreciate that and we enjoyed hearing
about it, and look forward to the full 1500 pages or whatever.
DR. CAMPBELL: And we are going to read every word.
MS. DIXON: I am sure.
DR. GARRICK: We are fully aware of the busy time that this
is for you and the sacrifice you made to come and let us hear about it,
and we do -- I just want to second George's comment, we really do
appreciate your effort.
MS. DIXON: It was a please being here.
DR. GARRICK: Thank you. Okay. This is going to end the
recorded part of our meeting. What I would like to do, to give the
recorder a few moments to shut down, is to take a five minute break and
then the committee will come back and move back into the mode of reports
and what-have-you.
[Whereupon, at 11:25 a.m., the record portion of the meeting
was concluded.]
Page Last Reviewed/Updated Friday, September 29, 2017
Page Last Reviewed/Updated Friday, September 29, 2017