112th ACNW Meeting U.S. Nuclear Regulatory Commission, September 14, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON NUCLEAR WASTE
112TH ADVISORY COMMITTEE ON NUCLEAR WASTE
U.S. Nuclear Regulatory Commission
Two White Flint North
11545 Rockville Pike
Tuesday, September 14, 1999
The committee met, pursuant to notice, at 11:00 a.m.
JOHN GARRICK, Chairman, ACNW
GEORGE W. HORNBERGER, Vice Chairman, ACNW
RAY WYMER, Member, ACNW
. P R O C E E D I N G S
DR. GARRICK: Good morning. The meeting will now come to
order. This is the first day of the 112th Meeting of the Advisory
Committee on Nuclear Waste. My name is John Garrick, Chairman of ACNW.
Other members of the committee include George Hornberger and Ray Wymer.
The entire meeting will be open to the public and during
today's meeting we will discuss committee activities and future agenda
items. We will hear from NMSS representatives discuss how the NRC will
use and integrate Decommissioning Standard Review Plan dose modeling.
We will be provided with an overview of the DWM High Level Waste Program
for the fiscal year 2000 operating plan. We will continue to prepare
for sessions with the local stakeholders to be held this fall in the Las
Vegas, Nevada area and discuss possible ACNW reports on a white paper on
near-field chemistry considerations and a report on joint ACRS/ACNW
committee on NMSS's approach to risk-informed performance based
Howard Larson is the Designated Federal Official for today's
This meeting is being conducted in accordance with the
provisions of the Federal Advisory Committee Act. We have received no
written statements from members of the public regarding today's
session. Should anyone wish to address the committee, please make your
wishes known to one of the committee's staff.
It is requested that each speaker use one of the microphones
and identify himself or herself and speak clearly and loudly so that he
or she can be heard.
Before proceeding with the first agenda item, I would like
to cover some brief items of current interest.
Our colleague, Dr. Charles Fairhurst, resigned as a member
of the Advisory Committee on Nuclear Waste effective July 31, 1999.
This quick decision resulted from an opportunity to become more directly
involved in some of the design activities associated with the Yucca
Effective August 6th the Office of the EDO was realigned
with Dr. Frank Miraglia to serve as Deputy EDO for Reactor Programs and
Dr. Malcolm Knapp will serve as the Deputy EDO for Materials, Research
and State Programs. Reporting to Mal Knapp will be the Office Directors
of NMSS, Research, and State Programs.
It was announced on August 12th that Dr. Malcolm Knapp will
leave the NRC in January. Dr. Paperiello has been selected to succeed
him as the Deputy EDO for Materials, Research and State Programs, and
that will be effective September 20th, 1999.
Succeeding Paperiello as Director of NMSS is William Kane,
who is currently Associate Director for Inspection of Programs in the
Office of Nuclear Reactor Regulation.
Lawyer-physicist Richard Meserve was nominated to the
Nuclear Regulatory Commission and will be appointed Chairman once
confirmed by the Senate. This was announced by President Clinton on
Friday. If approved, Meserve will fill the seat vacated by Shirley
Jackson, who left in July to become President of Rensselaer Polytechnic
Meserve is a partner in the Washington, D.C. law firm of
Covington & Burling and chairs National Academy of Sciences committees
on subjects of interest to this committee. Meserve received a Ph.D. in
Applied Physics from Stanford University and a law degree from Harvard
Law School. He was a Law Clerk for Supreme Court Justice Harry Blackmun
for a year in the mid-70s and was legal counsel to the President's
Science and Technology Advisor during the Carter Administration.
President Clinton nominated Ivan Itkin to head DOE's Nuclear
Waste Program, which has been without a permanent Director for more than
two years. He has a Master's Degree in Engineering from NYU, a Ph.D. in
Mathematics from the University of Pittsburgh, and from the 1950s to the
early '70s he worked as a scientist for Westinghouse -- Bettis Atomic
Laboratory -- designing and developing reactors for nuclear propulsion
systems for the U.S. Navy.
Finally, the NRC has named Mr. John D. Sieber to the
Advisory Committee on Reactor Safeguards. Mr. Sieber comes with a lot
of experience in the utility business. He has also served as a member
and director of many organizations including the Electric Power Research
Institute, Nuclear Electric Insurance, Limited, the Nuclear Energy
Institute, and the Institute of Electrical and Electronics Engineers,
and the Westinghouse Owners Group.
With that, I think that unless there are any comments, we
will proceed with our agenda and our opening topic is Decommissioning
SRP Dose Modeling and I think Nick Orlando is going to lead off and will
also introduce subsequent speakers.
MR. ORLANDO: Thank you, yes. What we are going to talk to
you about today is this is just a continuation of several of the
briefings we have held for the ACNW over the past couple of years on the
status of the development of our Standard Review Plan for
Decommissioning. As you can see by my slide there, I am going to speak
a little bit today and then tomorrow I am going to come back and talk in
a little bit more detail about some of the things that I have been
specifically working on.
Today Boby Eid is going to talk about dose modeling and Norm
Eisenberg is also going to address some issues associated with dose
To remind everybody, the purpose of the SRP was to
evaluate -- or to enable the Staff to evaluate information submitted by
licensees in a timely, efficient, cost-effective manner to make sure
that all of the regulations are met. The way we are setting the SRP up,
it provides a description of the contents of each module in the
decommissioning plan and then lays out acceptance and evaluation
criteria, and as I say here on the slide, we will be using this SRP to
evaluate decommissioning plans and other information submitted to
support the license termination under the Licence Termination Rule.
We have established several milestones in the SRP
Development Plan that we shared with the ACNW way back when -- back in I
guess it was late '98 or early '99. We did establish the SRP Work
Groups in September. We developed the default tables -- actually Boby
and the Dose Modeling Group developed the default tables for surfaces to
replace the numbers in Reg Guide 1.86. That was published in November
of '98. We finished our identification of the technical and policy
issues requiring resolution in the SRP and briefed the ACNW at that time
back in December.
In June of this year we completed the development of most of
the SRP modules. I think in June we had all but about five of them out
and on the Web. We have a webside which there is a slide on that in a
In July and August we completed developing the remaining --
of the 16 modules we had all but the dose modeling module out and the
dose modeling module has been separated into four submodules, of which
two of them are completed and should be on the Web shortly and the final
two, which get into the site-specific modeling for restricted and
unrestricted use situations will be forthcoming and Boby will talk a
little bit about that.
Right now we are still shooting to -- I have one more module
to complete, which I had hoped to have for you all today. Unfortunately
I did not get that done in time, what I call the "how to use" module.
It lays out some of the things that I will talk about in my discussion
tomorrow, but it gives sort of an overview of how to use the SRP and how
we are incorporating our streamlined licensing action approach into the
As far as the rest of the milestones here, the comment
period for DG-4006 officially closed last month. However, at the
workshop that we held in August, Steve McGuire indicated that NRC would
be receptive to taking comments for a few more months if people could
get them in to us. Some of the citizen groups that attended the last
workshop asked for a couple of more months and Steve said yes.
We are still intending to have the final Standard Review
Plan done to coincide with the final Reg Guide, and that will be July of
2000, so we are still on track there.
To remind everybody and to kind of put a little bit of a
context for what I am going to talk about -- what Boby and Norm are
going to talk about today and what I am going to talk about tomorrow,
the Commission back in July of '98 sent us an SRM and in there they said
do certain things.
Well, the first one was publish draft guidance. We did
that. Provide the Commission with a timeline for developing the
Standard Review Plan -- we did that. We are in the process of
developing the user-friendly SRP. My understanding is that Howard has
provided you with copies of the Standard Review Plan and I will talk
about how that really is user-friendly a little bit tomorrow.
We have included ACNW in the review and comment on the SRP.
Boby is going to address the next three bullets on how to use the
probabilistic approach and review the potential conservatism in the D&D
code and test the D&D code on a complex site.
Tomorrow what I would like to do is talk a little bit about
how we have maintained a dialogue with the public during the comment
period, how we are ensuring that the SRP incorporates the risk informed
iterative approach in NUREG-1549, and discuss how the SRP is going to
provide clear guidance on complying with ALARA.
Having said all that, what I would like to do now is turn it
over to Boby for a detailed discussion of some of the dose modeling
issues, and then follow it up by Norm Eisenberg with some issues that
has been working on.
Unless you all have any questions now for me at this time?
DR. GARRICK: I failed to note that Ray Wymer will lead the
discussion for the committee on this particular session.
MR. LARSON: What you are saying, though, Nick, is that all
the viewgraphs from maintaining a dialogue, stakeholder input on, you
will discuss tomorrow.
MR. ORLANDO: Yes, sir.
MR. LARSON: Okay.
MR. ORLANDO: Yeah, I gave you the whole package today as
opposed to trying to give you two of them.
DR. WYMER: Other questions, John or George?
DR. GARRICK: No.
DR. WYMER: Why don't we then just proceed.
MR. ORLANDO: Thank you very much.
MR. EID: Before I start, I would like to mention that the
work on the dose modeling module for the SRP is a collective effort of
NMSS staff, Research staff, as well as work of contractors. I would
like to give credit for all of the staff from both offices and also for
contractors. There are lots of people participating in this activity I
cannot mention by names, maybe you recognize those. The title of the
presentation I would like to give you today is about the Standard Review
Plan and specifically about the activities and status of the dose
The presentation outline will include the status of the dose
module. Specifically, I will provide an outline of the dose modeling
module and the appendices and outline of some of the completed
activities. Also, I will provide dose modeling SRP activities and those
are under development. They will lead to path forward in completion of
the SRP. Specifically, I will address the assessment of conservatism in
DandD screen model and code. This is an issue that was raised
previously, and the development of new codes and associated reviews of
these models and codes, evaluation of approaches and selection of
parameters in dose modeling. Then I will provide you an overview of the
codes and models use and integration, about what these models can be
used for, and how they will be integrated. Then I will talk about the
schedule for completion of the SRP dose module and the summary and
First of all, the outline of the SRP dose module, it will
appear as within the SRP at large as a chapter, and under this chapter
there will be sub-module, there will be sub-modules. Those, they will
include five sub-modules. The first is dose modeling evaluation as
generic dose modeling. Then unrestricted release using screening
criteria, unrestricted release using site-specific information,
restricted release conditions, and release under alternative criteria.
And those are consistent with the current decommissioning rule.
Now, the technical details about the criteria for dose
modeling, they will be included, what we call TBD, technical basic
documents, they will be included as appendices in the SRP. And dose
will cover the criteria for conducting screening, when you conduct
screening, what kind of screening analysis you do, and then the criteria
for source term abstraction, how you try to examine your source term to
be whether consistent with the model or not. Then the criteria for
modifying pathways, under what conditions you could eliminate pathways.
Criteria for establishing conceptual models, how you establish
conceptual models for your side, concerning the critical group receptor
and concerning the source term that you have at the site. And then the
criteria for selecting dose modeling codes, and also provide generic
description of those codes, the most common codes, specifically DandD,
RESRAD, RESRAD-BUILD and SEDSS.
Also, we will address the criteria for modifying parameters,
how you change the parameters, then the criteria for treating
uncertainty in dose modeling.
Also, the dose modeling group, they were quite active in
developing interim guidelines for dose modeling and dose modeling of
test cases, as well as requested by the Commission. So we developed the
preliminary guideline for evaluating dose assessment in support of
Also, we evaluated dose modeling for two test cases of
onsite burials under the old 20.304, and we evaluated dose using RESRAD
and DandD codes.
In addition, we completed the evaluation of eight simple
decommissioning cases using DandD with modification and doing some kind
of changes to the source term and the input parameters.
The staff also developed screening default tables. As Nick
mentioned, the first one it was for building surface contamination for
beta and gamma emitters, then the screening tables of common
radionuclides for superficial soil and based on specific radionuclide
parameter values rather than on the collective or the whole default
values for all radionuclides.
Also, we are developing a screening table for alpha emitters
for surface contamination, which is building surface contamination, and
the technical work has been nearly completed. We may need some peer
review and we are intending to finalize it. We intend for the
superficial soil screening tables to develop an FRN by September, by the
end of this month -- that is an optimistic schedule -- and also to
develop the alpha surface contamination by October 30th.
Regarding the write-up of the dose module, we decided to go
ahead, to proceed with writing the structure of the dose module, which
is included in the dose modeling evaluation, this is in Section 5.0; the
unrestricted release using screening criteria Section 5.1; unrestricted
release using site-specific information, Section 5.2; restricted release
Section 5.3; and the alternative criteria. And those, as you can see,
they are consistent with the original sub-models that Nick told about.
Also, the staff was quite active in coordinating with
industry based on recommendation of our management and the Commission.
We coordinated and participated in four public workshops to discuss
specifically dose-modeling issues. Those workshops, they were useful,
we received lots of feedback. We received information from the licensee
for their sites.
Also, coordinated with Research to establish website to
address and respond to users' dose modeling issues. There were some
issues that were raised through the Internet and we tried to respond to
those issues as much as we can.
Then, also, we gave presentations at EPRI and NEI workshops
and the Health Physics Society professional meeting. Indeed, there was
a special session about decommissioning and the dose modeling at the HPS
Also, a paper is being planned to be delivered at the
International Atomic Energy Agency professional meeting.
The other activities that are under completion or we are
developing include comparison of DandD Version 1.0. We did compare
Version 1.0 as the code is now, without any changes, against RESRAD and
RESRAD-BUILD, and there is a NUREG being prepared by the contractor.
Also, we conducted assessment of specific critical
parameters, specifically, resuspension factors, soil to plant transfer
factors and other factors, but the resuspension factor is one of the
famous factors that was controversial and we spent lots of time on that.
We conducted assessment of source term abstraction using
DandD code, using test cases and using the interim guidance so we
addressed the issue of source term abstraction. If you have a source
term at your site and it is different than the source term of the model,
what kind of minor modification you could change considering the
Also, assessment of DandD, Version 1.0, single default
parameter set for all radionuclides, we looked into that issue. And
currently, as you know, the DandD, Version 1, it has a generic default
value for all radionuclides, one set of default values, and a question
whether this could be varied or not over conservative or not, where
there is that issue.
Then development of DandD, Version 2.0. Based on the
comments that we received from the previous bullet about the selection
of the solution vector for to select single default parameters set for
all radionuclides, the suggest was to develop DandD, Version 2.0, it
will deal better with the uncertainties and the probabilistic approach
for selection of parameters.
Then we are currently working on the possibility to develop
refined screening approach and this is if indeed Version 2.0 allows the
selection of pathways, clearly, so one approach is to see if we can
eliminate certain pathways for certain cases and develop what we call
the refined screening approach based on elimination of pathways.
Also, we will also work on to determine with alternate codes
or models could be used for screening. We are developed RESRAD and
RESRAD-BUILD probabilistic, and one of the issues was we have DandD, it
is probabilistic, the staff adopted the probabilistic approach, which I
will be discussing. And, therefore, the question is, if we have
probabilistic codes like those and they are acceptable in their models,
can we use them as alternative codes for screening? It, again, is a big
issue. I will be addressing and talking to you, maybe also you will ask
questions, so I will answer those during the questions.
Other areas of development, development of -- those are
codes that were developed in cooperation with the Research staff and
NMSS staff, and the contractors, and they are currently under
development. Research has the lead in terms of project management for
development of those codes. We have development of RESRAD, RESRAD-BUILD
probabilistic codes currently going on, development of DandD Version 2.0
probabilistic code, which I just mentioned, development of Sandia system
for environmental analysis, it is called SEDSS (SNL), it is under
development. And also there is other project which is carried out by
PNNL regarding development of probabilistic hydrologic parameters.
Again, the Research staff will present on September 15th at
the ACNW, tomorrow, talking about the status and summary of these codes
and models development.
In addition, we conducted technical experts workshop and
solicited licensees and interest groups' inputs, plus very heated
discussion among the group itself. And, finally, we endorsed the
probabilistic approach for selection of codes and parameters and for
treating those uncertainties. The staff supported dose modeling group.
Staff supported the selection of the mean dose value for site-specific
analysis. We spent lots of time wrestling with this issue. And then,
finally, for site-specific analysis, the staff supported selecting the
The staff would accept a deterministic approach for
parameter selection, however, some licensees, they may do deterministic
approach in dose analysis, and then we may accept the deterministic
approach for parameter selection and dose modeling using conservative
bounding analysis and sufficient characterization of data of the
Now, I will give you an idea about the codes and the models
they are developed or currently we are having, and where they can be
used, what possibly can be used for the decommissioning sites. That is
what the staff believe in, at least from NMSS point of view, what we
believe that those codes they can be used.
First, I will talk about DandD code, Version 1.0, the
current version without any modifications. The current version has been
used for generation of beta/gamma emitters for building surface
contamination release levels. So we did use it for a generation of
building surface release levels for beta and gamma. And we have FRN and
the public actually they are using it. Also, it has been used for
simple decommissioning cases for screening analysis, however, there were
some changes or minor modification to the source term and the parameter
modification. So it has been used for these simple cases.
DandD model, now the model itself, using each radionuclide,
not Version 1.0, but the model itself it was used, considering each
radionuclide specific parameter, it is currently being used to generate
default tables for superficial soil.
DandD code, Version 1.0, with the code reconstruction of the
PDF for resuspension factor, which I mentioned we are working on right
now, we are about to complete. That will be used to generate default
tables for alpha emitters or building surface contamination release
levels. As you know, the alpha emitter surface contamination release
levels are quite conservative right now and the question is, what can we
do about, you know, the conservatism resuspension was the most sensitive
factor. We did reevaluation of the resupsension factor, and based on
that, we think we could establish new default tables for building
surface contamination of alpha emitters.
The current approach in DandD, Version 1. 0, for selection
of a single default parameter set for all radionuclides produces dose
anomalies, and this issue also was raised by the licensees and by the
users in the workshops. We have analyzed the situation. We tried to
find where are the problems, and because of the selection, current
selection of the default parameters, and we have an answer to that.
Use of DandD, Version 1.0, be believe that it could be used
in site-specific analysis. It will be very limited, however, it could
be used for screening analysis.
Now, there is a Version 2.0, it is being developed, also
along with SEDSS, actually, development, so it may also include some
kind of probabilistic analysis using DandD model. For DandD Version
2.0, it will allow probabilistic modification of input parameters.
Currently, they are a single set of default parameters and you cannot
change it in a probabilistic fashion. It will reduce excessive
conservatism inherent in DandD version 1.0, because of the solution
vector currently that I talked about. It will modify certain default
critical parameters. Based on the dose modeling group discussion
interaction with the contractor, we found that there are certain
parameters, they are conservative, and they could be changed.
It will enable smooth transition from screening to
site-specific analysis because it is probabilistic. It may allow
selection or deletion of specific pathways. We were told that, where
pathways, they can be eliminated or modified using the newer version,
2.0. Also the version, however it will be limited due to the DandD
model assumptions. So the model assumptions, they are sufficiently
conservative, or highly conservative, and the model is very simple.
However, still, we are, you know, stuck with this model.
Then it is expected to be used for screening and simple
cases of site-specific analysis.
As I said, we are developing, through other contractors and
through Research for the RESRAD probabilistic NRC code version, because
it is a specific version for NRC's use, and it would allow probabilistic
analysis using RESRAD model. Also, it will establish the distribution
of parameters and facilitate review of level of conservatism of
licensees' dose analysis. When they licensees, they insist on using
RESRAD on something, their dose analysis would be in a better position
using RESRAD probabilistic to evaluate and assess what kind of
selection, what kind of conservatism in the selection of the parameters
and the conceptual model that it was used.
Also, it will reduce unnecessary conservatism in DandD model
because of flexibility. You could change the source term. The source
term in DandD assumes that the contamination in the top 15 centimeter of
the soil, whereas, RESRAD, it will have more flexibility because you
could have different thicknesses, and also it will treat in different
way the source term configuration, treatment of the cover, and the
treatment of the unsaturated and the saturated zones.
It is more suitable than DandD for complex modeling because
simply, as I said, it deals differently in treating those kind of
compartments. It has a large existing user base. It is one of the
important things, many, many licensees, they are using RESRAD and they
are telling us we won't use RESRAD. That is another reason. It has
been extensively tested and benchmarked.
RESRAD probabilistic NRC code version also is developed to
allow probabilistic analysis using RESRAD-BUILD model. RESRAD-BUILD
model is a dynamic model to calculate to airborne concentrations,
whereas the current model in DandD is a static, simple model. The code
allows for air inflow and source-term, allows for dilution of the
radioactivity and the airborne contamination. It uses resuspension rate
rather than resuspension factor. Resuspension factor is the ratio of
concentration between the air and on the surface, whereas suspension
rate actually deals with the rate that the material will be deposited,
which is the fraction of the method that will be deposited on the
It is useful for site-specific and complex modeling of
Other models and codes which we call it actually a system is
called Sandia Environmental Decision Support System, SEDSS, is being
developed that is actually a system of group of models and codes that
are incorporated in this kind of code. It is a system to incorporate
screening and site-specific dose modeling analysis using decommissioning
decision framework and 1549. It is useful for making timely and
cost-effective decisions regarding characterization, dose analysis,
remedial actions, and license termination.
It facilitates transition from screening to more complex
dose analyses. It is useful for sites requiring advanced, sometimes
multidimensional groundwater modeling and offsite release situations,
whereas the current models whether they are RESRAD or DandD, they handle
onsite analysis, not offsite releases.
The system needs to be user friendly. That is what we are
hoping, and also it needs to do more testing and evaluation to ensure
that it will accommodate its use for decommissioning sites.
Finally, I would like to talk about the schedule for
completion of the SRP dose module. We intend to complete the dose
modeling section, all the sections, without the technical basis
documents by November, by end of November, 1999, this year. Also I
intend to complete the technical basis documents by June 14th, by the
middle of June, the year 2000, and now the specific date for completion
of the technical basis documents -- that is important because in case
you would like to look at the potential review by the ACNW to appreciate
that is there, so we have in May for the operating criteria for
conducting the screening, the criteria for source term abstraction -- it
is in January, or middle of January, criteria for modification of
pathways, hopefully by end of December, by the end of this year,
criteria for establishing conceptual models, hopefully by November, the
criteria for selecting computer codes -- this will be by mid-June,
criteria for modifying parameters by middle of May, criteria for
treating uncertainty by the beginning of March, and the completion of
the overall SRP dose module by end of July, 2000.
In summary, the Staff working on the dose modeling from both
NMSS and Research made significant progress on analysis and resolution
of dose modeling issues.
The Staff conducted model comparison and assessment of
conservatism in parameter selection and current dose modeling
Also the Staff developed default tables and interim guidance
to facilitate release of simple decommissioning sites.
The Staff conducted dose modeling for test cases an simple
decommissioning cases for evaluation modeling approaches.
The Staff coordinated with stakeholders to exchanges ideas
and experience in dose modeling through the workshops and through the
The Staff is developing probabilistic codes and parameters
in support of the risk-informed based approach.
Also, the work on the dose module is proceeding according to
the current task plan in spite of some difficulties -- some senior Staff
left -- but we coped with all of these conditions and still we are on
target to complete the dose module by July 31st, 2000. Thank you.
DR. WYMER: Thank you. I have several questions.
I want to break it into two parts, so first let me ask what
we talked about privately, what part of this do you want us to give you
MR. EID: I believe that there are certain issues that we
struggled with I think it will be good for the ACNW to look at. Some of
those issues are for example the generic approach for screening, then in
the probability analysis to select the mean value versus the 90th
percentile, and in the screening analysis for the site-specific analysis
we have achieved resolution on that but for screening analysis we said
the Commission will look into the problem further, the possibility for
using other models and codes.
Also, I would like you to review all of -- if it is
possible, depending on your time -- if you would take a look at the
documents for dose here -- for the technical basis documents wherever it
is possible, just -- you do not need to review everything, but to tell
us about your ideas about it would be good.
We would like to receive some kind of direction, so that is
another area, but we know that your time does not allow it because you
don't need to go back and then review all these models and codes and so
on to come to some kind of conclusion to understand that.
However, you know, taking a quick look at some of those
things that they could be finished early also it could help the Staff.
MR. McCONNELL: Dr. Wymer?
DR. WYMER: Yes.
MR. McCONNELL: Keith McConnell. I am with the NRC Staff.
I think that it is our expectation that after the first of the year,
once we are further along in some of these technical basis documents and
have completed all the modules that we would come back to the committee
and present that information in more detailed fashion, and that might
assist your review.
DR. WYMER: I'm sure it would.
MR. McCONNELL: And also I think in past letters the
committee has expressed concerns in a couple of areas, particularly I
think conservatism in the dose modeling analysis, and I think we
probably in those meetings that we have next year ought to assess your
belief on how far we have come to addressing your concerns.
DR. WYMER: Okay. Fine.
MR. ORLANDO: Dr. Wymer, this is Nick Orlando. To back up
what Keith said, one of the things I am going to request tomorrow, just
as far as ACNW assistance, review of any of the other SRP modules that
are out there would be welcome, and if the ACNW wants, we can arrange to
come back in and talk about all of them or some of them at your request,
so we can work next year to set that up and to have those kinds of
briefings for you in detail.
DR. WYMER: Yes, that would probably be helpful.
Let me ask now, John or George, do you have any comments?
DR. GARRICK: I think we have had some discussion on this
before, but I guess ideally what you would like to have is a code that
you could peel off layers of, depending upon the complexity of the
problem you are analyzing.
Is SEDSS moving in the direction of orchestrating the
algorithms of DandD and RESRAD to provide that kind of modeling
MR. EID: I believe maybe Bill Ott would like to talk about
it or to comment on that.
MR. OTT: I am Bill Ott from the Office of Research.
We will talk about this a little more tomorrow, but our
vision of SEDSS is being able to handle all of these things, however
SEDSS is going to be much more complicated code, so in the final
analysis if somebody wants to do a screening calculation and they don't
have a lot of expertise, they may want to try and run DandD because it
will be much more simple to use.
We anticipate having a toolbox of progressively more complex
tools that anybody can dip into at the appropriate level and solve their
DR. WYMER: George?
DR. HORNBERGER: I just have a couple of questions related
to this issue of conservatism.
When you were talking about DandD on one of your slides you
say that DandD has excessive conservatism and actually you then said
"but you are stuck with this model."
How do you determine that it is excessive conservatism?
What is your criterion? What is your metric?
MR. EID: Well, I would call it highly conservative now.
Conservatism depends how you define it. Comparing to other codes
currently that are used and accepted by the community, DOE, EPA and
others, the numbers that you generate from DandD, they are very high.
Now the conservatism -- you go back and take a look and see where is the
problem, why is it indeed is conservative or is it just simply the
In the dose module analysis for screening we start with the
conservative scenario. That is the starting point. In this assumption
we assume that the individual living on the site is eating the crops,
ingesting the food, having a fish farm, having a chicken farm, having
dairy products, having corn, having wheat -- growing everything on that
farm. That is to start from, from the scenario.
That is fair for the modeler because you cannot move forward
without having this assumption. You need to have this assumption for
the scenario in order to move forward.
This is in the latest documents we have. Unfortunately we
cannot change it. This is the assumption of the scenario.
Now when you move forward a little bit, you could go and
say, okay, you have input parameters. You will need to develop
parameters for that model -- how these parameters were developed for
that model, what kind of selection of parameters.
The analysis was extensive the way the parameters were
selected. However, when it comes to the selection of single default
sets for all radionuclides, so we are becoming now much more
conservative. In the beginning in the screening analysis we said, okay,
the 90th percentile for selection of the four parameters.
In the current code for many radionuclides you are not at
the 90th percentile. You are at the 99th percentile or it could be
higher. Therefore, if you look at the numbers for the screening
analysis, using the single default sets for one single radionuclide and
then go and run the code for the same radionuclide and look at the
numbers, you will find those numbers currently by the current code you
are about a factor of 10 higher than the codes using the same model,
using the four parameters for that specific radionuclide.
DR. HORNBERGER: My impression was that DandD was a
screening code, however, and am I to take it that you think that proper
use of the screening code should give the same numbers as use of a code
that is designed more to simulate a site-specific case?
MR. EID: No, I am really talking about selection currently
of the solution vector and DandD Version 1.0. That is what I am talking
The way the solution vector to establish default parameters
SIDS, single default parameter SIDS for all radionuclides produces very
highly conservative values.
DR. HORNBERGER: But I guess my point --
MR. EID: If you run -- no, you do not have --
DR. HORNBERGER: Is this bad for a screening code? That is
what my question is.
MR. EID: Yes.
DR. HORNBERGER: It is?
MR. EID: Yes. I believe it is overly conservative. Yes.
DR. HORNBERGER: So the numbers are too high? That is what
you are saying?
MR. EID: The numbers, they are too high -- because when you
go back and look at it, the default table generated for each specific
radionuclide, you will find that there is an order of magnitude of
one -- of ten excessive conservatism currently in the current code.
DR. HORNBERGER: So what you are saying is that way too many
sites would fail to pass the screening test -- sites that should pass
the screening test will not? That is what you are saying? That is your
definition of what makes it so --
MR. EID: What I am saying is that there is most likely this
will cause more burden on the users to have this as a starting point,
which we know it is overly conservative.
MR. McCONNELL: Dr. Hornberger, if we could help out a
little bit here. I think the example perhaps might be the resuspension
factor where the original resuspension factor, we found it in doses that
were or concentrations that were down at detection levels, and through
our work with the industry we found out that perhaps the resuspension
factor originally used was too conservative based on data that exists in
the industry and so we are now modifying that resuspension factor and
coming out with a different table -- and I will turn it over to Cheryl.
MS. TROTTIER: I just want to try to avoid you wasting a lot
of time on something that may not be a major issue.
What Boby hasn't mentioned is that Version 2 will solve a
lot of these problems and that is why we are going ahead with Version 2.
The beta test version of Version 2 will be available this fall, so we
anticipate by springtime our licensees and licensing staff will have
Version 2 available.
It is still a screening model. It is still not intended to
give you the same kind of doses that you might get from a model that
uses site-specific data, but it will eliminate some of this excessive
conservatism that the Staff has been concerned about.
MR. EISENBERG: Could I just add one thing? To add a little
numerical flavor. We all understand that these models and codes have a
lot of uncertainty, the databases have a lot of uncertainty, and so we
are not talking about one percent or two percent of the value. We are
talking about one or two orders of magnitude.
I think that is what Boby means when he says that it is
excessively conservative. It is well above the noise level and
something that should be addressed.
DR. HORNBERGER: But you still -- you told me that you are
solving a problem and I am trying to understand what the problem is,
okay? Now, Norm, what you just said is that the calculation is one or
two orders of magnitude higher than what? Higher than reality? Higher
than what you would get if you went out and did some measurements? Or
higher than produced by RESRAD?
MR. EISENBERG: All of the above.
DR. HORNBERGER: All of the above. Okay. Where do you want
a screening code to be? Do you want it to be roughly equivalent to what
you would get for RESRAD? Is that your objective for a screening code?
MR. EISENBERG: I think that might be an ideal situation.
What we are talking about is that if you run DandD, and then you run
RESRAD with the same parameters, you will get a sizeable difference in
many cases or in some cases.
DR. HORNBERGER: Is DandD always higher?
MR. EISENBERG: DandD is not always higher --
DR. HORNBERGER: I doubt that --
MR. EISENBERG: In some situations it certainly is, and you
have to remember, and I will speak to this in a few minutes under my
issues, but even though intuitively one would expect a screening code to
have additional conservatism above and beyond what you would expect for
a site-specific case, remember this is a risk-informed or probabilistic
analysis where we have taken into account the distribution of parameters
and since we have taken it into account, should it really be more
conservative because the bottom line is it is a dose estimate. We are
obtaining a dose estimate by which people will make a decision.
The licensee will decide to either submit their plan for
termination based on no additional work or they will decide to spend
additional money to do site characterization or cleanup, whereas the
Staff will decide to release the site or not based on these dose
calculations, so it is a dose calculation.
The question is what is the appropriate level of
conservatism for a dose calculation, especially in a probabilistic
MR. EID: I would like to say that we are not taking RESRAD
as a target for us for screening. I hope this is understood.
DR. HORNBERGER: Yes.
MR. EID: We are trying to have reasonable codes that they
deal with screening analysis but reasonably conservative. Now I am
saying, currently for the code it has the four parameters SIDs for all
radionuclides. This approach is not a good approach. That is what I am
If we analyze the values using the same code, the same
model -- we are not changing the model here in this case -- I will give
you two examples, the Strontium-90 and Cesium-137.
If you take the single default sets for the specific
radionuclide which is the most appropriate for that radionuclide, so the
numbers would be different by one order of magnitude for both cesium and
strontium. The code is forcing selection of certain sensitive
parameters currently in order to get very high dose above the 90th
percentile, and Cheryl indicated that and she said this would be
corrected in Version 2.0, so we will have a correction for that. That
is an example, okay?
Now you say shall we use Version 1 or Version 2.0?
DR. HORNBERGER: No, that is not what I am asking. That
isn't what I am asking and I understand what you are saying.
What I am asking is what leads you to have to go to Version
2 -- and so you get a calculated dose that is an order of magnitude
higher. When we had the first presentation on DandD, my question was,
okay, how many sites if you applied DandD are going to pass the
screening, because that is the issue. If you are being really
conservative, and you are still -- this is supposed to be an easy tool.
You apply it. You are overly conservative. You come in and say we
don't exceed the dose limit. It is a dose calculation.
We can quibble, I don't think it is probabilistic, but a
dose calculation -- if you are going to release, if you are going to
allow safe sites to be released with an easy calculation, what is wrong
with that? Isn't that what a screening model is supposed to do?
MR. McCONNELL: Dr. Hornberger, I don't think we disagree.
I think we agree that in essence a screening model needs to be
conservative, but you could make it so conservative that nothing would
be screened out.
DR. HORNBERGER: That's what I asked.
MR. McCONNELL: And that is what we are trying to do here --
DR. HORNBERGER: If no sites pass, that I understand. You
have to go to Version 2.
MR. McCONNELL: Right, and case -- in the examples that Boby
has giving, strontium and cesium, and also with respect to the alpha
emitters, we were in a position that in essence no sites with that
contamination would pass the screen, and so we are trying to come up
with kind of reasonable approaches to those problems, but in essence we
agree with what you are saying.
DR. HORNBERGER: Okay.
MR. EID: And that is the source of complaints we received
from the workshops from the licensees. What is wrong with your numbers?
You are off completely. I made simple calculations and you are off
Another example is the resuspension factor. Currently we
have values. They are much below the detection limits for the alpha
emitters and we tried to investigate and discuss what is problem, the
most sensitive part of the suspension factor that currently we are
DR. GARRICK: Would you have done anything differently if
you hadn't received a rather, as I understand it, strong reaction
relative to the desire in a lot of users to continue using RESRAD?
I got this sense the last time around that DandD was the
tool and that RESRAD came back into the fold principally because of
pressure from the users. Is that incorrect?
MR. EID: I would say, you know, have a large base for the
users is one of the reasons for the developing the code to help us in
our review, but it was not really the reason or trying to say, well,
developing RESRAD, the only reason.
However, I would say, you know, that dealing with DandD, we
realized from the beginning that there are some over-conservatisms in
DandD, and we looked into the report submitted by SNL for the dose
comparison using RESRAD and DandD and RESRAD-BUILD and we find some
We tried to see what are those differences, related to the
model or related to the parameters. The parameters were significant,
yes, because the parameters are different we try to see if we can deal
with the parameters, but currently the approach for dealing with the
parameters is conservative. It is highly conservative.
Now when we try to put similar parameters, you reduce those
kind of changes -- that kind of large differential between the codes.
Now still there are some differences also in the models, so I would say
yes, because we have in our model comparison we did recognize that there
are some numbers that do not make much sense.
DR. WYMER: Maybe we ought to move on. I suspect we have
gotten as far as we are going to get on this point.
Norm Eisenberg, I guess, is going to make the next
MR. LARSON: Ray, just one question. I know Nick had said
that you were going to address the use of DandD -- you know, the last
item in the SRM, testing DandD in a complex decommissioning site, and
use it as a pilot for developing the SRP --
MR. EID: Can you say that again?
MR. LARSON: Pardon?
MR. EID: Can you say that again, please?
MR. LARSON: Well, Nick's viewgraph, July 8th SRM, the last
one was test the DandD code on a complex decommissioning site and use it
as a pilot for developing the SRP, and he said you would address that.
MR. EID: It has been used for two test cases. Mark, could
you mention something about this, if you don't mind?
MR. LARSON: Complex site.
MR. EID: Excuse me?
MR. LARSON: Complex site.
MR. EID: Yes, it has been tested for two complex sites. I
don't know if I would call them complex but they are -- I don't know if
they can be categorized as complex.
MR. LARSON: Mark?
MR. THAGGARD: Yes, the two test cases that Boby alluded to
are not complex. They are fairly simple sites, but we do have some work
going on right now with Sandia is actually running the code on a very
complex site, and that work hasn't been completed yet.
It is due to be completed by the end of this calendar year,
so we don't really have anything to report on that at this time.
I am Mark Thaggard.
DR. WYMER: Norm, please.
MR. EISENBERG: Thank you, Boby.
MR. EID: Thank you.
MR. EISENBERG: If Dr. Hornberger took issue with what Boby
said, he is going to love this.
MR. EISENBERG: Okay. I am Norman Eisenberg. I work for
the Division of Waste Management. You have heard all this before this
morning, so I am going to breeze through what the currently scheduled
products are. What I would like to do is talk about a set of issues
that have come up in this dose modeling work.
DR. GARRICK: One thing I have noticed about this group is
that each one of you have chosen a different corner in which to put the
DR. GARRICK: In your handouts. I like yours the best, by
MR. EISENBERG: Okay. The Staff will try to respond to that
MR. ORLANDO: Is that a recommendation?
DR. CAMPBELL: Upper left.
MR. EISENBERG: Then I would like to talk about how these
issues are planning to be resolved. I will summarize the status and
make some -- say what our recommendation is or what our conclusion is.
This is rather large and complicated project. As you know,
we have the dose modeling chapter in the Standard Review Plan as one of
the planned products. We have the technical basis document, which will
be an appendix to the Standard Review Plan but will contain a lot of the
details about dose modeling.
The finalized Regulatory Guides and NUREG reports that the
Office of Research has responsibility for developing, we have already
put out some default tables in the Federal Register for use by
licensees. There are planned to be more and of course we will have
Sorry, I have got to get my comments here. There were two
sources of issues. I am sure the committee remembers that Dr.
Paperiello had a session with you all, and one of the things he
indicated was that there were a number of issues he had about
decommissioning, especially about conservatism, that he wasn't sure
whether the staff was as responsive as he would like. We have discussed
that extensively with him.
He has seen a slightly different version of this same
presentation that I am giving you, and he agreed that these are his
issues, -- so the first set of issues you will see are Dr. Paperiello's
issues -- that we correctly articulated them and that he also agreed
that we should present them to you.
Now, what we did is that we said how the staff is addressing
these issues and how we are going about it. And there were also in the
staff discussions, which have been fairly extensive, as you can well
imagine, a lot of other issues have come up that were not necessarily
ones that Dr. Paperiello had but which are in a similar vein and are
technical policy issues. They are not really strictly technical issues.
And so I have articulated some of those in this presentation also.
So I think this is a nice presentation, discussion to kind
of focus on some of these technical policy issues which should be
fertile ground for the committee to perhaps get involved in.
Now, to decide how to handle these, of course, we, as
always, have limited resources, but there is a list of ways to handle
them on this slide. Some we will address directly in the Standard
Review Plan. And, in general, the issue, if it relates to screening,
will not be necessarily addressed in the Standard Review Plan, but it
will be addressed in the Standard Review Plan for site-specific
analyses. So that is perhaps the most direct thing.
In other cases, we have put a mechanism to fix things or to
address the issue in place in our user need letter to Research. Now,
let me hastily add that the Office of Research, on their own initiative,
is moving ahead to address those issues, many of those issues on their
own initiative, but it is nice I guess that we give this kind of
agreement in writing. So there are some things that we have down in the
user need letter.
Now, some of the activities in the user need letter will not
be reached on the same schedule as when the Standard Review Plan is due
out. Some of the computer code development will take a little longer.
So this spreads over a bigger region of time.
As the committee also is aware, there is a Risk Assessment
Task Force which has been working on how to do risk-informed regulation
in the materials world for NMSS. You have been briefed on that. This
task force is just getting up and started, and eventually will operate
on an office-wide basis to handle a number of technical issues and
policies issues, as well as specific decisions on an office-wide basis.
So, some of these issues, it sounds like they really have implications
for all materials regulation and should be properly addressed in that
context. So we are deferring some of these issues to them. That group
may be able to address them and may not, but it is kind of out of our
hands in decommissioning. We certainly would encourage them to address
And then there is other things that, in order to address
thoroughly and completely, you really need to go back and address some
of the legacy documents. Earlier, the earlier chapters of NUREG-5512,
some of the items that were done for preparing for the rule, we are not
currently planning to go back and address those. So here you kind of
have a sequence of ways that the staff is moving to address the issues
which I will now go ahead and try to present to you.
Okay. So what are some of these issues? Oh, and I have to
say that the issues -- the way we are addressing them is in this column
titled "BIN," that is the bin we are putting them in as to how we are
So one of the issues is, how do we eliminate exposure
pathways when the site conditions or land-use patterns justify it?
Well, for example, suppose your site overlies an aquifer which has got
high solids content, dissolved solids or salty, which I guess is the
same thing. why wouldn't you turn off, say, drinking water and
agricultural use of the water, and turn off those pathways, because
people are not going to do it?
Well, we will address it in both the Standard Review Plan,
which would allow elimination of pathways with justification. Of
course, the licensees would have to justify and provide a basis for such
a change, and the newer version of DandD, DandD-2, will have a rather
easy, user-friendly way to turn off specific pathways. So it is a
two-pronged to address this issue. So that is one example.
A second issue is area factors, and especially how much food
is obtained from a site that has a limited area. If the area of a site
is not large enough to produce the food that is indicated by the default
assumptions in the code, that is, if it is only a few hundred square
foot and it can't produce all the foodstuffs that are assumed in the
code, and I think the code currently assumes 25 percent of the
foodstuffs come from the contaminated site, then that assumption needs
to be changed. The percentage of foodstuffs from the contaminated site
has to be lowered. And this is something that we have asked in the user
need letter, in fact, it specifies reducing the excess or unnecessary
conservatism in the code, and this would be an example of that.
DR. GARRICK: Norm, let me ask something.
MR. EISENBERG: Yes.
DR. GARRICK: While we are on this business of eliminating
pathways. If a user or an applicant uses a bounding analysis to
indicate that -- to justify that, for example, atmospheric pathways
don't have to be considered, is that okay? One of the things that is
important in doing risk assessment work is to do analysis to require the
scope of the risk assessment work, and if in that analysis you can, by
simple bounding methods, demonstrate convincingly that a particular
scenario cannot occur, then why waste a lot of time and effort trying to
do a probabilistic analysis? I never thought I would say that, but --
MR. EISENBERG: Well, good.
DR. CAMPBELL: You are on the record, John.
MR. EISENBERG: You are getting in with the Waste Management
DR. GARRICK: Right, right. Yes. So, does that option
exist? I mean you are not going to --
MR. EISENBERG: Well, I think what you are asking, and we
have to always, when we talk about the modeling approaches, we have to
remember that we think in terms of a sequence.
DR. GARRICK: Right.
MR. EISENBERG: And the first sequence is a screening
analysis, and then there is a more detailed analysis. And I think the
staff would be very receptive to a licensee that, for example, ran the
full -- all the pathways in the screening analysis, made a determination
that, for example, the air dispersion pathway was negligible because in
the nature of the radionuclides, or the nature of the source term, and
then in the detailed site-specific analysis only treated groundwater
contamination or direct radiation, or whatever other issue needed to be
addressed. I see no reason why the staff would have a problem with
Now, I don't know if right now we have plans to specifically
say that in the SRP, but it sounds like a good idea, that that is
something we should say.
DR. GARRICK: Yes. Yes. Okay. Thank you.
MR. EISENBERG: Okay. So I think that is enough for area
factors. Another issue is the DandD code uses an infinite plane to
approximate the dose from direct radiation. Obviously, we are always
dealing with a finite plane, so that is a case where we know the code is
always conservative. Now, you have to put a little footnote and say,
well, you know, in some of these situations, if you are inside a
building, you could get exposure from the walls and the ceiling if they
happen to have contamination. But it does seem to be a conservative
approximation. And, once again, that is something that would be
addressed under the general category of removing unnecessary
conservatisms in the DandD code.
The next issue is the use of more realistic scenario and
possibly do the dose calculation by factoring in probabilities of
various scenarios. Now, the whole approach to dose modeling for license
termination has been in the mindset that you would use default bounding
scenarios for the dose modeling, certainly on the screening basis, and
so that we really couldn't do this without modifying the legacy
documents. However, for the Standard Review Plan, we certainly are
going to say that if the land-use patterns or other factors that the
licensee could substantiate would indicate that certain scenarios are
eliminated, or that they can specify scenarios with a certain
probability, we would certainly accept that kind of either elimination
of scenarios, change of scenarios, or use of a more complete
probabilistic analysis using the probabilities of the scenarios. So
that is why it is, again, a split response to that issue.
You know one thing I probably should mention is the DandD
code represents the models that are specified in NUREG-5512, and to
change the models, we need to specify a rationale for the change and
document the rationale somewhere. We may not need to go all the way
back to the legacy documents and change that, but we do -- I think we
owe it to the whole public that we give our rationale for making these
changes. So some of this requires a little more work than might meet
the first glance.
The fish issue -- the fifth issue, it is a fish issue, is --
Are the total amount of foods that are ingested reasonable? And there
is some indication that for some food types, whether they are vegetables
or meats, some of the standard health physics assumptions would, if
played out over a year, indicate that people are eating unreasonable
quantities of particular kinds of foods, and, really, those assumptions
need to be adjusted in the code. Unless you are me, of course, who eats
too much of everything, but that is --
DR. GARRICK: According to a recent study, our youth is
eating too many french fries.
MR. EISENBERG: Okay. So that is another issue and that
would be addressed in the user need as taking care of unnecessary
Okay. Another issue is that, you know, we have for people
exposed to naturally occurring radionuclides, or those from fallout, we
have a lot of data. There have been studies where cadavers have been
autopsied and the actual uptake of these radionuclides by humans have
been determined and shouldn't our dose modeling correspond to these
essentially actual field experiments?
And the problem appears to be with the exposure scenarios,
that is, the resident farmer and the building occupancy scenarios are
specified in various parts of 5512 and 1549, NUREG-1549, and so for
screening, it is very hard to adjust these, so we really would need to
go back and change the legacy documents. It is clear that on average
the exposures are not going to be as bad as for these scenarios that are
specified in these documents, these assumptions.
For site-specific, of course, that can be modified and the
Standard Review Plan would allow changes in these scenarios and specify
some criteria for the rationale that would need to be provided by the
The next issue, the model would be validated and closer to
measured results rather than conservative. There is a note to this
effect in the user need letter on addressing validation.
Another issue is to make corrections for the resuspension
factor and plant uptake. Boby has already spoken about this and there
are specific statements in the user need letter. And there is
continuing staff work on these two problems, and, as Boby mentioned, we
have gotten quite a bit of help from workshop participants on those
issues, especially the resuspension factor.
Okay. Three more. We should a less conservative, more
realistic groundwater model. The model is specified in 5512. It is
very conservative, so we are not going to change it for screening, but
for site-specific, we could employ a tool such as SEDSS and that is
called for in the user need letter.
The comparisons of the concentrations, the cleanup
concentrations that we would have compared to other organizations and
their cleanup concentrations, such as the EPA or the NCRP, once again,
the problem stems back to the scenarios, and since they use different
scenarios, they, of course, get different concentrations. And so we
would have to modify the legacy documents to get to that point.
And then there is an issue which is somewhat controversial,
which Dr. Paperiello likes to call "MARMOD," which is a multi-agency
agreement on modeling for dose assessments.
DR. GARRICK: Yes.
MR. EISENBERG: Where all federal agencies, or the concerned
federal agencies would agree on a single code for contaminant migration
and dose demand, and that is also something that, again, would be
inconsistent with what is currently specified and we would have to go
back and perhaps modify some of the legacy documents. So those are Dr.
Paperiello's issues and our response to them.
Now, I would like to talk about a few other technical policy
issues, and these have come up in the context of the staff conducting
this work on the Standard Review Plan. First of all, should we use the
mean for dose modeling decisions and consider perhaps a bound on a high
percentile of the dose distribution, which is -- that distribution comes
from considering parameter uncertainty? We would have to modify the
legacy documents for screening.
Now, it sounds like Dr. Hornberger might have some problems
with using the mean of the dose distribution for a screening decision,
but maybe not. But draft NUREG-1549 indicates that the choice of the
default parameters should assure that the dose calculated for screening
is very unlikely to be exceeded when you do a site-specific calculation.
Now, I am not sure that that level of conservatism is needed for these
kinds of decisions.
Another problem is that margin, defense-in-depth,
conservatism, et cetera, are all terms used to account for uncertainties
in modeling, and these have been used for a long, long time in
engineering and the physical sciences to make these decisions. The
question is, is as we move into a risk-informed environment, what role
do these types of considerations have?
And I don't know if you can see it, but I tried to draw a
few pictures at the bottom of the page to try to illustrate the point.
This also relates to the first point. Suppose these are probability
distributions of dose, and suppose we have a case where we have a dose
limit. Well, what is an acceptable relationship between the dose
distribution and your dose limit? I think everybody would agree that if
your dose distribution is fully below the dose limit, it should be okay.
Suppose it just bumps up against it. Well, you know, for a
lot of engineering systems, this is not okay. You want actually some
separation like there is here. If you are building a bridge and you
want to design it for 500 ton traffic, and you do your calculation and
it is right at the limit, you generally say put in an order of magnitude
-- not an order of magnitude, but a factor of two for safety, or some
factor of safety, and you might want the bridge to be able to hold 10
tons, not five tons. So some people might have trouble with this one.
Well, suppose a small fraction of the dose distribution
falls over the limit. Suppose 5 percent is over, so 95 percent is
below. Is that okay? And then should we use the mean? Suppose the
mean of the distribution is at the limit, is that okay? And I didn't
draw, of course, the other example, which is suppose most of the
distribution is above the limit. I think a lot of people might have
trouble with that one.
But this is the kind of decision that needs to be made and
there are a lot of things that go into this. And I think one important
thing that needs to be recognized is that if these distributions are
based on uncertainty in parameters, you have not included all the
uncertainties. You have not included the uncertainties in the exposure
scenarios. You have not included the uncertainties in the models. And
if we know that both of those are conservative, not necessarily
quantified to any degree, but we know that in general they are
conservative, my feeling would be that we can move pretty far in this
direction. But this is a real issue I think for most of materials
DR. WYMER: Well, Norm, all that says, though, that kind of
plot, all it tells me is that there is a certain probability that the
dose will exceed an acceptable limit. It doesn't say how bad it will
exceed it, how much.
MR. EISENBERG: Right. Okay. And let me say two things
about that. It doesn't say how the dose -- how likely it is that the
dose will be exceeded. What it says is, given your calculation and what
you put into your calculation, what is the probability that the dose
will be exceeded. That doesn't necessarily correspond to what actually
might happen. That is the first thing.
The other thing is that, if you look at Issue 1 under Other
Issues, it says that in addition to limiting the mean of the
distribution to be, say, below the dose limit, you would have a second
limit. This was done in the low level waste branch technical position.
The mean had to be below 25 millirem. The 95th percentile of the dose
distribution had to be below 100 millirem. So that kind of put a cap on
the extreme values that you might get from this situation. It would be
a very low probability that you would get really high doses. Of course,
some of us would argue that is a very low probability that you would get
very high doses from any of these situations unless some very strange
Okay. Which leads me into the third issue, which is, as the
hazard and the likely consequences, that is sort of the mean dose,
decrease, can the degree of assurance that the standard is met decrease?
In other words, if we were talking the dose from a core melt and this
limit was just below 500 rem, which is the LD 50 for direct exposure,
and prompt fatality, you might want to make sure you are very far away
from that. But when this limit is 25 millirem, and when the likely
consequences, or even the extreme consequences from these activities are
lower, can we allow less certitude that we meet the limit? This is a
very interesting policy issue.
DR. GARRICK: Of course, one of the practices that makes
sense is if your bounding analysis indicates that the margins are
questionable, then you really need to go to a more complex model. If
you have to go to a more complex model, then why wouldn't you want to
provide the curve to the decision-maker rather than monkey around with
some central pendency parameter of the curve, because it is important --
I think the low level waste people came close to doing it right --
MR. EISENBERG: Thank you.
DR. GARRICK: -- because they did establish some sort of a
control on the distribution, whereas if you have got a situation where
the distribution is -- the mean might be the same but in one case the
distribution covers two orders of magnitude and the other case it covers
ten, to me that is an entirely different piece of information with
respect to decision-making.
I think that has to be somehow accounted for.
MR. EISENBERG: Perhaps you bring up another issue, which is
if we are going to do risk-informed regulation, can we communicate to
the decision-makers within the agency and to our many publics -- the
industry, the general public, other interested parties -- can we
communicate a kind of a -- how should I put it -- some kind of reasoned
approach to decision-making because that is after all what our
regulations and our guidance states, or do we have to really put some
limits that people can easily understand, that the 95th percentile will
not be above a certain amount? It is a question of how -- can we just
say, well, we'll look at the distribution and we'll do the right thing?
I am not sure that that is the spirit of what the agency is engaged in,
that we really do need to tell the public how we are going to make these
DR. GARRICK: I agree.
MR. EISENBERG: So the question is how do we do that,
especially when we are in this risk-informed context.
DR. GARRICK: Yes.
MR. EISENBERG: I think we agree.
DR. GARRICK: Yes.
MR. EISENBERG: Okay. Two more issues. It has been
suggested that we establish a tier of analysis -- this relates to a
previous issue -- a tier of analysis where you don't have to go in and
modify, do a complete site-specific analysis or any type of
site-specific analysis but if you have information which will modify the
exposure pathways and you don't want to modify any of the other
parameters you can go in, even though you know that if a site, for
example, has some peculiarities or some conditions that would not allow
certain pathways to be activated, it likely changes the parameters for
Given all that, should there be a tier of analysis that
would allow changing the pathways but not changing any other parts of
the analysis, and we are planning to do that in the Standard Review
Plan. Some of the earlier documents talk about screening analyses and
site specific analyses and not kind of something that is in between
which would allow a generic analysis in parameter space but a
site-specific analysis in exposure pathway space.
Finally, 1549 states a decision framework, and the decision
framework -- I can show you a picture if you like -- but it is basically
an approach where you do screening. If you don't pass screening, then
you have several options. You can go to restrictive release. You can
go to remediation or you can do more site characterization, all of which
options are, except restrictive release, but the other two would change
your dose calculation.
It also says, this statement I said before, that your
screening calculation should provide a high degree of confidence that
any site-specific analysis would provide a lower dose. Well, what that
does is it means that there is a real premium on doing a site-specific
calculation. That is one way to look at it, but another way to look at
it is we are forcing some licensees to go ahead and do one of those
alternatives when in fact a more realistic approach to dose modeling at
the screening level would let them through and they could avoid that and
they still would be not making a threat to public health and safety, so
this bias towards more site characterization, that is not something that
is within the NRC Staff's portfolio.
Our job is to ensure public health and safety, not to be in
the business of getting our licensees to do more site characterization.
We always make decisions under uncertainty. It is just a question of
how much uncertainty.
So those are the issues --
DR. GARRICK: We have a very tight schedule here, and are
you going to be able to wrap it up in about five minutes now?
MR. EISENBERG: Yes.
DR. GARRICK: I realize that we are the problem as much as
MR. EISENBERG: I'll breeze through it.
The bottom line is most of these issues will be addressed in
the Standard Review Plan or by research, by their own initiatives and
also per the user need. Some issues won't be addressed without a
substantial increase in effort and time.
We do not want to modify the legacy documents because we
don't have the resources. Although some of the site-specific analyses
may be onerous for some licensees, it at least provides a path forward.
We are not sure even if we do the fixes we are talking about
how many licensees we are affecting and if it is a small number, the
benefit to the total licensee base is not clear even though they all
have to pay for it.
Anecdotal data suggests that the screening approach will
permit license termination at a substantial number of sites.
So the Staff will reflect some of these policy decisions
that were sort of indicated in the issues in the guidance and these are
the forms of the guidance and the resolution of some issues will be
DR. WYMER: Thank you. Is there one burning question?
DR. GARRICK: I heard a new term today -- "legacy
One of the impressions one might get here who is pushing for
an accelerated effort in getting into a risk-informed mode of thinking
here is that your decision to not change the legacy documents could be
interpreted as a decision to not change anything and that all we are
doing with a risk-informed approach is adding burden rather than
reducing it, and that flies in the face of the PRA policy statement that
says we ought to be reducing the burden.
MR. EISENBERG: I suppose there is a danger that that could
be the impression, but in fact we are, I believe, fully embracing a
risk-informed approach in our treatment of site-specific analyses and in
other parts of the Standard Review Plan, and so it is a matter of
practicality. We could spend years refining the screening tool so that
it would be perfect and we are not sure that the benefits would be
warranted. Of course the use of, possible use of other codes for
screening, such as the RESRAD probabilistic may also provide another
avenue that would help.
I think some of these issues should be directed and in fact
to anticipate a possible question, it would be good I think if the
committee would comment on, one, whether these are the correct issues,
and two, whether the Staff positions that we have taken are correct, and
three, whether the pragmatic choices that we have made are feasible, and
that gets to what Dr. Garrick was just asking -- you know, this may be a
pragmatic decision but is it really going to get to where we need to go.
DR. WYMER: Other burning questions?
DR. HORNBERGER: Actually, I am just going to make a
comment. I won't even ask Norm a question, but I can't resist a
First of all, I certainly don't have any problem using a
mean of a distribution in the screening analysis, but I guess what I
often wonder about is how one goes about -- you said it just now --
refining screening analyses to I think you used the words "a perfect
screening tool." I don't know what a perfect screening tool is, but
just as an example of refining you mentioned that you wanted to look at
the amount of food consumed, and I will just tell you a little anecdote.
I was on a committee once at Oak Ridge and we were looking
at an analysis like this for mercury ingestion. They were looking at
mercury from fish from the contaminated sediments in the streams there
and the committee thought that it was really ridiculous. They had the
exposed individual eating something like three pounds of fish a week
every week every year, and we said there is nobody that does that, but
then of course we went to a public meeting and ran into a guy who -- not
a very well-off person -- and he lived in a very modest shack right on
the Clinch River and he ate one heck of a lot more fish than three
pounds a week, according to him, and so we sort of changed our mind as
to what was conservative and what wasn't.
DR. WYMER: And on that note, since we are going to spend
tomorrow morning on the same general topic area and in light of our
Chairman's statement that we need to cut this off, maybe we will wait
until tomorrow to pursue some of the other questions. I had a couple
but they can wait. Thanks.
DR. GARRICK: Thank you very much. Unless there is further
discussion, we'll adjourn for lunch.
[Whereupon, at 12:35 p.m., the meeting was recessed, to
reconvene at 1:20 p.m., this same day.]. A F T E R N O O N S E S S I O N
DR. GARRICK: The meeting will come to order. I guess Bill
Reamer is going to lead off the discussion this afternoon.
MR. REAMER: With Keith McConnell.
DR. GARRICK: On operating plan overview for high level
MR. REAMER: Do you have my package? Do you have my slides?
MR. LARSON: No.
DR. GARRICK: This will be plenty of food in the next hour.
MR. REAMER: One is high level, the other is the low level
waste branch technician position which you are interested in. And I am
on page 2, actually.
I will talk a little bit about the FY '99 accomplishments,
more from the sense of kind of picking up the thread of where we are in
our activities. I will also address kind of the context for our
operating plan for FY 2000, meaning the goals and strategies from above
that condition our planning.
The third item is the high level program schedule that I
will get to. The fourth item, there are several slides, I will go over
my FY 2000 priorities, but there are a couple of slides I have included
that relate to the prioritizing process that we spent a good deal of
time on in June with you. And they are part of the package, but I don't
intend to spend very much time on them unless you want to, but I am
happy to spend however much time you want to. And then I will close
with what we see as the potential topics of interest for you.
DR. GARRICK: Okay.
MR. REAMER: So on three, if we pick up the thread in FY '99
where we are working on our comments on the EPA standard, we have got
our Part 63 out, proposed. We have gotten our comments, we have held
public meetings. We are analyzing those comments, there are 700
comments, it is a big job. We have completed our comments on the
viability assessment, given those to DOE. More detailed comments we are
giving to DOE in the Issue Resolution Status Reports, the last item on
that slide. Just above that, we have completed our 3.2 version of the
TPA code, provided the user manual to DOE.
We still intend to issue revisions of our Issue Resolution
Status Report -- of each of the status reports this year with one
exception, and performance assessment, we are going to defer that until
later in the calendar year.
DR. GARRICK: Bill, in your public meetings, did you learn
anything that might be important for us to have background on for our
upcoming meeting out there? Well, that is a very broad question.
MR. OTT: Yes.
MR. REAMER: You know, it is a process. You don't just
learn it all. You kind of slowly kind of pick it up and understand that
they are very concerned about the repository coming and they don't
totally appropriate how NRC fits into the scenario. And they really
start from -- you have to kind of start from the beginning. Of course,
you have already had one meeting.
DR. GARRICK: Right.
MR. REAMER: But I have found that we -- we held meetings in
March and went back in June, because many of the comments we heard in
March were, who are you? And what do you do? And what is your role?
And how are you going to help us? And so in June we went back with very
basic, like, you know, we are not the sponsor of this repository, but we
are planning for the possibility of a license application that will site
a repository right here. You know, they are trying to lead people to
understand how we could be doing all this work, at the same time not
being kind of part of the DOE effort to site the repository at that
DR. GARRICK: I just wonder if there were any real hot
buttons that came out that you think, if we knew about, we might be able
to better prepare ourselves.
MR. REAMER: Keith, does anything occur to you? You are now
talking about specific comments that we heard?
DR. GARRICK: Yes. Any issues or an aggregation of
MR. REAMER: About Part 63. Comments like, for example, how
does the proposed 25 millirem all-pathway standard protect children?
That is certainly a comment we heard a number of times. What were some
of the others?
MR. McCONNELL: Well, that was the one that I was going to
recommend. But I also I think there was -- it was outside the purview
of Part 63, but there is a lot of interest in transportation issues, as
you might expect, and probably have heard.
At the first meeting I think we had a different audience to
a certain extent than the second group of meetings than the first. But
in the first group of meetings, there were a number of comments on
defense-in-depth, particularly from I think the State of Nevada, and how
Part 63 embodied defense-in-depth.
MR. REAMER: I would be happy to kind of go back and look at
our notes and lessons learned and kind of offline provide to your staff,
you know, any other thoughts we have in this area.
DR. GARRICK: Yes, right. I think maybe if Lynn could
follow up on that and dig into it.
MS. DEERING: Yes, and I was at least several of those
materials, so I have captured already some of those thoughts.
DR. GARRICK: Okay. I sense some of this already in your
MS. DEERING: Yes. But I will talk with them.
DR. GARRICK: Thanks.
MR. REAMER: Okay. Back on to Slide 4. The top three items
all relate to our kind of enhanced efforts in the QA area. We are
presented with a challenge in the QA area because of DOE's own
difficulties in implementing their QA program, and we have addressed
that through increased meetings with DOE on the QA topic at a
management, senior -- very senior management level, established our own
task force to more deeply probe, paid attention to our auditing, our
observing of DOE QA audits. We are going to be increasing the number of
audits that we are observing, just trying to build confidence in this
The fourth item, the DEIS review plan. We have, of course,
talked with you about that. The review is well under way.
And the next two items, we held the public meeting
associated with your meeting a year ago. Completed our procedural
agreement with DOE and completed our outline on the Yucca Mountain
Okay. So that is the thread from '99. The next three
slides are what I call the context, the strategic context. We start at
the very top level on Slide 5, which is basically prevent adverse
impacts to the environment, to the public health and the safety. When
we take that down to the high level waste program, we say to do this, we
need to kind of get ready to handle a license application, establish our
capability, identify issues that we think are important, provide
feedback to the Department of Energy.
Slide 7 states performance goals that we used in our FY 2000
budget planning. We had a planning, budgeting, performance, measures
process that we went through in January and February for FY 2000. The
four performance goals in Slide 7 are what came out of that. The areas
where I think we found that we needed more effort are Number 2,
stakeholder confidence. You know, we are basically I think tracking
many of the same concerns or interests in risk commission. We are
calling something maybe a little different, but we are still on the same
path in a sense that you are on. That was the main one, stakeholder
confidence. I think that is the thing I would mention on Slide 7.
The next slide, I think perhaps you all have seen before, it
is our program schedule. It tries to, on the lefthand side, show the
areas of interest in the program, the areas of attention in the program.
And then we timeline it out. There are a couple of places where I think
I would like to update this. I was looking at it last night, and I
think maybe there have been some changes. The fifth item down, where we
are talking about the site recommendation, and we have the draft DOE
site recommendation, I think that date really is November of 2000 when
we expect that DOE will request our comments, rather than in FY 2000, it
is going to be FY 2001.
And the review DOE EIS, two items on down below that, if you
can follow me, the NRC comments are now expected to be produced in
February 2000 timeframe, and the final DOE EIS is more in the November
And then my next to last line, the license application, we
still carry the 2002 license application date, but you have probably
seen the kind of informal statements we have seen, and so I am putting a
question mark next to that 2002 date for the LA.
Slide 9, 10 and 11 in your -- actually, 12, 9 through 12 are
what we talked about in June, about how we prioritize, you know, how we
are taking into account your recommendations that we use performance
assessment to prioritize, that we never stop pushing the risk-informed,
performance-based approach right on down from the regulation down into
the review plan, down into the review. And, you know, it needs to be --
the third bullet, if we are going to prioritize, we need to do it in a
way that people can see and understand.
Ten and eleven just kind of describe the budget process. We
are pretty in the next to the last tick on Slide 11 right now and doing
our FY 2000 Ops Plan based on our expectation of what Congress will
produce in the way of a budget. We don't have yet a signed budget.
Slide 12 is a very brief summary of the prioritizing process
that we talked about again in June.
In Slide 13 a point that we really didn't get into in June
that I think is worth mentioning here, before we get to the meat, which
is what are you going to do in FY 2000 is that we really do see
ourselves as transitioning from prelicensing to licensing. We may stay
in a prelicensing context. Maybe that won't end in 2000 with the filing
of an LA. It might be 2003 but still this transition is happening.
We are maturing in terms of our own capability. It is time
to start thinking more like in our regulatory mode where we expect that
DOE will propose and we will dispose, and we are starting to get our
framework into place. We expect to have our rule done. We expect to be
well along in our Yucca Mountain Review Plan in FY 2000, and we are
looking to March as the date -- well, we are looking to March as
approximately the date when we will have our review plan at least
post-closure done in draft, and we will be interacting with you before
that time as well on it.
DR. HORNBERGER: Bill, how will the Review Plan build on the
IRSRs and how will it be different?
MR. REAMER: It will be different because it will pull
together how we are going to do our review in the context of a Part 63,
which the IRSRs really don't have that anchor point because we didn't
have a Part 63. We didn't have a regulation to -- we didn't have that
top level framework, so it will be different in that sense.
They will be the same in that they will bring in from the
IRSRs the acceptance criteria and use them to anchor the Staff's review
in each of the technical areas that are covered in the Review Plan.
Slide 14 is again a reminder that as we enter -- it is a
reminder to me, I think -- to keep reminding my staff as well that as we
enter into the licensing mode we have a way that we regulate. It is the
licensee's responsibility to conduct the activities safely. We are not
out there independently guaranteeing safety. We are out there
rigorously reviewing what the applicant is proposing to do. We are
serving as a check on the applicant, and that is increasingly I think
what you will hear from us and see from us as we move more into a
licensing footing and away from a building our capability footing.
DR. WYMER: Just down there on the next to the last line you
say the likely safety and safeguards benefits are the greatest. That is
as they are discerned by the NRC?
MR. REAMER: Right. We want our review to be efficient. We
want our review to produce the best bang for the buck and we can't
review everything. We can't independently verify everything. We really
need to focus our review, our audit review on those areas where we think
We start of course first with where DOE says it matters --
DR. WYMER: Okay.
MR. REAMER: -- and we make sure that we agree there, and
then we say is that complete? No, it is not complete. We think it
matters in the following other respects.
DR. WYMER: That was the thrust of my question. Thanks.
MR. REAMER: Okay -- and now what the briefing is about,
what are we going to be doing, and this is impossible to read on the
slide I'm sure but --
DR. GARRICK: You are beginning to be like an engineer here.
MR. REAMER: I take that as a compliment.
DR. HORNBERGER: And I could say for a lawyer it is a
MR. REAMER: I could start talking about Dr. Garrick's kids
here in a minute, you know.
Okay. The column on the left are priorities. You probably
care about the FY 2000 column on the left. The columns on the right are
resources. "C" stands for Center. "NRC" stands for NRC -- I think you
probably care about the FY 00, the farthest right column in terms of
where we are putting our resources.
The activities are kind of in the middle.
The first item under the Key Technical Issues, as I
mentioned, are development of our -- working on our performance
assessment capability and also our IRSR in this area will be deferred.
The second item down, in the EPA standard, there are really
three items that we lump under that -- comments on the proposed 197;
secondly our Part 63 activities; thirdly, something that I was realizing
last night we haven't really talked too much about, which is DOE's
siting guidelines for its site recommendation and we hear from DOE their
plan to propose revised siting guidelines 10 CFR 963, to put that out as
a proposed rule some time this fall.
The Staff would expect to comment on those proposed
guidelines. DOE's expectation is that it want to be in a position to be
able to finalize the guidelines some time next calendar year, probably
maybe the middle, ideally, of the next calendar year, to get them in
place so that come November of 2000 when they are coming forward with
their site recommendation considerations report, you know, they can base
it in their siting guidelines, 10 CFR 963 -- their revised siting
guidelines, so that is an activity that is kind of hidden in the second
The next eight or so items are issue resolution key
technical areas. As I mentioned, generally what we try to do is issue a
revision each year. This year our revisions have focused mainly on the
VA. Next year you can bet that they are going to be focused on site
recommendation and the documents related to site recommendation.
Then we have a number of items that don't have priorities
but I went through these anyway and highlight what are my high
They are the DEIS, where we will be completing our review,
QA. Getting ready for site sufficiency is about three or four items
down, called Sufficiency Comments. That basically means our comments on
the site recommendation. We need to be thinking about our -- you know,
the nature of our review, the scope of our review, how we are going to
apply the Yucca Mountain Review Plan in doing that review -- of course,
the Yucca Mountain Review Plan right under the sufficiency comments and
the public outreach.
If we go to 14 we now have, presto, the topics for FY 2000.
This is our suggestion of where we think you may be interested but you
obviously have your own ideas -- the EPA standard, our follow-up to
complete Part 63, the Yucca Mountain Review Plan. We have said FY 99
issue resolution status reports, but I think you really are more
interested in progress on issue resolution as we went through in June in
terms of closing issues, how we are we coming on closing issues, what is
our path to resolution, do we have a path to resolution, the performance
assessment items, sensitivity analysis, and the 4.0 version, which under
our current plan will incorporate the results of our peer review.
The peer review was conducted in July. I think there is a
report that is due very shortly. I am kind of pulling together what the
comments are, not an analytical report but more pulling together the
DR. HORNBERGER: So the peer review panel didn't give you a
report of their own?
MR. McCONNELL: No, they gave us individual reports and the
Center is pulling together the comments. There is an issue with respect
to the FACA and so they provide individual reports.
DR. HORNBERGER: Yes, and we will get a copy of that when
you get that?
MR. McCONNELL: Yes, we will get you a copy.
MR. REAMER: Okay. The results of our review of the DEIS in
terms of comments, defense-in-depth -- a topic which we know you are
very interested in and comes forward in both the Part 63 and the Yucca
Mountain Review Plan.
Then two items that are not on here that I think probably
should be are sufficiency comments -- in other words, getting ready for
the site recommendation comments that by statute we have to make -- and
Part 963, and the Staff comments on DOE's proposed rule when that is
MR. LARSON: Do you have dates for those so the committee
can get a sense of if they are all going to happen in the next five
MR. REAMER: I think it is close to that.
MR. LARSON: Yes, that is what I thought.
MR. REAMER: I think their -- DOE's schedule is to try to
get something cleared by OMB and out pretty quickly.
MR. LARSON: No, I meant on all of these. You know, if we
went through each one of these, like the first one, NRC staff comments
on the proposed EPA, Yucca Mountain standard. That is what, next month?
MR. REAMER: Yeah, we could -- is that on the calendar for
next month? Is that on our agenda? It may well be the right time to do
it, because I think that would be consistent with what we are working
MR. LARSON: No, but I just was -- just for the committee's
MR. REAMER: Yes.
MR. LARSON: As to the sequence or schedule of these.
MR. REAMER: Yes, okay. So we are looking at October as a
possibility to discuss our comments, assuming that there are comments
that are out. Proposed Part 63, I think is on for December.
MR. LARSON: November.
MR. REAMER: Oh, November. Okay.
MR. LARSON: Isn't it November?
MR. REAMER: I may be -- I guess I am working from an
outdated schedule. Yucca Material review plan, I have that as December,
is that right? December?
MR. McCONNELL: I thought both were in November.
MR. REAMER: All right. I am not going to look at the
schedule anymore. It is the wrong schedule.
DR. HORNBERGER: Get you in trouble.
MR. REAMER: I don't think we do have a date to talk about
issue resolution with you, I am not aware of date. I am not aware of a
date with respect to performance assessment capability either,
sensitivity analyses or the 4.0. The DEIS, is that December?
MR. LARSON: November.
MR. REAMER: November. I am perfect. Let's see,
DR. GARRICK: I think in mathematics, we call this a
MR. REAMER: November. Yeah, I think if I had said November
for every one of these, I would have gotten them all right.
DR. CAMPBELL: So you are planning on a presentation on
defense-in-depth in November?
MR. McCONNELL: Right. But it is in the context of the
Yucca Mountain review plan, because that is where we are first starting
to put in some of the -- how we would review defense-in-depth, the more
detailed information related to the requirements that are in the
proposed Part 63. So it is not as ominous as it sounds. We are going
to be talking about the Yucca Mountain review plan, but the emphasis is
going to be on defense-in-depth.
DR. HORNBERGER: Good.
MR. REAMER: Sufficiency comments I thought at one point was
on for January.
MR. LARSON: Yeah, January.
MR. REAMER: Okay. got that one.
MR. LARSON: That keeps shifting.
MR. REAMER: And Part 963 I think is not on. I think I will
have to get back to you on that in terms of a date, because I am a
little fuzzy on what DOE's schedule is. For example, what is their
comment period? Is it 90 days, 180 days? I am not sure about that.
But that would help to condition when we would be ready with comments to
discuss with you.
MR. LARSON: There has been a lot of discussion on why they
are doing 963, but that's another issue.
MR. REAMER: I have heard, you know, and I don't know, maybe
this is something independent, this is probably is something the
committee may independently want to hear from, that a lot of changes
have happened now in kind of the regulatory structure. There is not a
Part 60. There is likely to be a Part 63, there is a now a 197 likely
coming and their goal is to be consistent with that regulatory
structure, and they may have the view that 960 needs to changed to
achieve that, and their vehicle to do that is to put out a separate
Do we want to move on to the low level waste BTP?
DR. GARRICK: Any questions on this?
MR. REAMER: Is this getting to what the committee wants to
DR. GARRICK: This is useful, yes.
MR. REAMER: Okay.
DR. GARRICK: This is something we certainly should do as
much as we can, is to get a sense from NMSS and its divisions of where
they might seek our advice. So, we appreciate this.
MR. REAMER: Good. Okay. The next batch of slides deals
with the branch technical position on performance assessment methodology
for low level waste radioactive waste disposal facilities. We have
deferred activity for a couple of years in this area, I think basically
because of resource limits, but we have picked it back up. FY 2000 is
our year to complete and hopefully be able to prepare a final branch
We have already received public comments on the draft and we
have analyzed those comments. I am on Slide 2. Analyze those comments
and are preparing responses to them.
We move to Slide 3, and we will talk about the schedule.
Our schedule includes the possibility for a public meeting on the BTP
early in calendar year 2000. Meeting with you on the draft BTP in the
spring. Getting your comments, factoring them into our package and our
thinking, and getting to the Commission with a draft final branch
technical position approximately July 2000.
MR. LARSON: You have had a chance to look at the comments,
the public comments. Are there any surprises?
MR. REAMER: On the BTP?
MR. LARSON: Yes.
MR. McCONNELL: No, not really. The one issue that comes to
mind is the timeframe for doing the calculation and that is always a hot
topic in low level waste. So that was probably -- it wasn't a surprise,
but where the emphasis is going to be.
DR. CAMPBELL: Are there any plans to coordinate the
positions on how to handle dose values from a probabilistic type of
analysis that, you know, we came up with for the low level waste
performance assessment with what Norm described earlier, what they are
debating, what you guys are debating right now for decommissioning?
Is there a goal of trying to be consistent across low level
waste and decommissioning or might those end up by being two different
ways of interpreting dose use?
MR. REAMER: You know, I can't answer specifically I mean
generally I wouldn't know why they would be inconsistent or different.
Do you have a more specific question?
DR. CAMPBELL: Well, Norm gave a presentation earlier and
drew several types of ways of interpreting a probabilistic distribution
relative to a single value standard, discussed some of the debate going
on, and mentioned --
MR. REAMER: About mean versus 95th --
DR. CAMPBELL: Mean versus 95th percentile versus all the
MR. REAMER: Doesn't the draft use mean?
MR. McCONNELL: Yes. Well, you know, high level waste we
are using the mean for compliance, the expected dose. Low level waste
BTP takes that position and that is the direction we are heading in
One of the reasons all of these activities, dose modeling,
decommissioning, low level waste BTP and the high level waste effort are
combined into Bill's branch is so that there is the consistency applied
across programmatic areas.
DR. GARRICK: We have already talked about some of it, but
can you give us the highlights of the public comments on Part 63, or is
that something we can't do yet?
MR. REAMER: I think we are not probably staffed to do it
right today. The November meeting I thought was going to be aimed at
what we were calling kind of the really strategic issues, the major
comments, the important comments.
DR. GARRICK: Do we sense there is going to have to be a
MR. REAMER: That is not my sense, no.
MR. McCONNELL: I don't believe so. We are having to do
some fine tuning and perhaps do a better job of explaining some things,
particularly in the statement of considerations for Part 63.
DR. GARRICK: Yes.
MR. McCONNELL: But in general I don't think that there will
be major revisions to Part 63.
MR. REAMER: The one exception might be there is a
provision, provisions sections on performance confirmation, and my
understanding is maybe we didn't -- we could do a better job of being
performance based than we proposed and so we want to look at that.
DR. GARRICK: I was also thinking back at our meeting in
Nevada last year where the Nevada people were extremely critical, and
whether or not there was any repercussions from that that resulted in
any new directions or major changes.
I am thinking of the letter that was sent in to the Chairman
by the Governor and various other communications that took place
MR. REAMER: There are several letters that have come. Are
we talking about transportation or are we talking about defense-in-depth
and the subsystems?
DR. GARRICK: Well, I am talking about pieces and parts of
MR. REAMER: 63, yes.
MS. DEERING: Excuse me, wasn't there the issue of not
issuing the standard before EPA's standard, issuing your regulation
before EPA's standard? That was one of the things the --
DR. GARRICK: That was the timing --
DR. HORNBERGER: That was the major part of it, as I recall.
MR. REAMER: We still see the efficiency of completing the
work that we have proposed, completing the work on the proposed Part 63,
and I don't think we have been maybe as successful as we had hoped to be
to really explain why that is, but it just seems to me to be pretty easy
to understand, and I haven't done the job of explaining that we have a
very limited time period to complete our rulemaking.
If we can bite off a substantial portion of that and get it
done, we help ourselves when it comes time to conform to that final EPA
standard -- which is not final.
I mean our obligation is to conform to the final standard,
not to the proposed standard, so we need a final standard. If we wait
and put our rulemaking on hold until that point, I think we have a much
larger job than if we complete those portions of the rule that we can
complete now, with the understanding and commitment to conform that rule
to the EPA standard when it is issue in final.
DR. HORNBERGER: If -- and this would be a really worst case
scenario -- but if the draft EPA standard did become final, how big a
job would it be to make Part 63 conform?
MR. REAMER: Well, I have two answers to that.
One, we need to wait and see.
DR. HORNBERGER: I realize that. I said it is a worst case
scenario. I was just curious.
MR. REAMER: We need to wait and see on what that standard
is. We haven't even filed our comments yet.
DR. HORNBERGER: Right.
MR. REAMER: And our hope is that EPA will read our comments
or someone will read them and take them to heart and --
DR. HORNBERGER: That is our fondest hope too.
MR. REAMER: In fact, we will have an individual protection
standard rather than a groundwater standard that becomes the limiting
DR. HORNBERGER: You don't have to give me the other answer.
It was an unfair question.
MR. REAMER: Okay. I will tell you this. I think we will
get it done in the statutory period. The statute says we do it in a
year and we will do it in a year.
DR. CAMPBELL: But by having the Part 63 finalized at that
point, the task of revising Part 63 to make it consistent with and
conform with whatever is EPA's standard is a lot easier than if you were
having to start from scratch.
MR. REAMER: That's correct. That is the message I think we
haven't been terribly successful in getting to the people in Nevada who
still distrust us and they distrust the federal government, they
distrust the NRC, DOE, and it is really our job to try to gain that
trust and to -- as I said, I think we begin by telling them what we are
going to do and then we do it, and we listen to what they have to say
and we respond.
DR. WYMER: Doesn't the fact that several sites have already
sort of de facto adopted the 4 millirem standard, like Savannah River
and Fernald, doesn't that really make your job extremely hard, to stick
to 25, or almost impossible?
MR. REAMER: I am not intimately familiar with those sites
and how they have in fact adopted it, and I don't know whether it is
like what is being proposed or not, but what we are focusing on is what
has been proposed, and what we are finding is a potentially very
stringent limiting condition, so I guess we will make that apparent in
DR. GARRICK: What was the gist of the NRC response to the
25 MR question during the public --
MR. REAMER: 25 versus 15 or 25 as it --
DR. GARRICK: 25, like the one you posed.
MR. REAMER: Is it protective of children?
DR. GARRICK: Yes, how does it protect our children?
MR. REAMER: Well, our response was that it is the standard
that is recognized in all of our activities.
It takes into account -- it is a standard focused on an
adult but it takes into account all the factors that we think are
appropriate to consider, and it is the same standard we apply
everywhere. It is the standard we are applying here.
DR. WYMER: That doesn't make it right, that just makes it a
standard. I mean, you know, that isn't really a good argument.
MR. REAMER: Well, we could go back, I guess, and revise our
approach to regulating radiation.
DR. WYMER: Yes.
MR. REAMER: You know, if we are going to revise it for this
activity, we had better revise it across the board. It seems to me we
are using Part 20, we are using Part 20 in many areas, and we can -- we
periodically review Part 20 based on international developments, and if
the international community moves towards focusing on the infant and
children as the right surrogate for purpose of protection, then we will
certainly consider that. And generally, Part 20 conforms to
international standards, international recommendations, so I think, you
know, we would move to that approach.
But for this one activity to depart and say, okay, for here
we are going to handle it differently, it is not our approach.
DR. HORNBERGER: Isn't it true that the international
standard, so to speak, focuses more on the 100 millirem, and says, well,
okay, we will make it even safer and divide it by a factor of 4, and,
therefore, I mean you still get a questions mark.
MR. REAMER: That's right.
DR. HORNBERGER: What are you doing to protect our children?
But we are already down in the very low range.
MR. REAMER: That's correct. The point is that the agency
believes that 25 is protective.
DR. HORNBERGER: Right.
MR. REAMER: And it believes it in all of its activities,
and that is the international sense.
DR. HORNBERGER: Presumably, that is based on studies, data?
MR. REAMER: Correct.
MR. LARSON: The LNT.
DR. HORNBERGER: The LNT, let's hope not.
MR. LARSON: How about waste confidence, is that going to
come up this year? Waste confidence, I see -- you know, it is on the
Commission list for 2000. What is it, after --
MR. REAMER: There is not really anything I can kind of
report to you on that right now, Howard.
MR. LARSON: I mean it is not on your schedule either.
MR. REAMER: You know, it is on my issues, priorities and
resources. It is on my list. It is something I need to --
DR. LARKINS: I think something is supposed to come back to
the Commission in December, the first part of December on that.
MR. REAMER: I haven't lost it, but it is not one of my
priorities right now. I could -- I may be told differently. It will
probably be done this year.
MR. LARSON: Yes, okay. But the resources allocated to it
are minimal, like zero.
DR. GARRICK: That's pretty minimal.
MR. REAMER: That's right. That is a placeholder for -- you
know, that is what we plan for, but we may need to put some resources --
we also plan for, you know, a draft license application and, you know,
we have got a fair amount of resources planned there, too. And my sense
is there is not going to be a draft license application in FY 2000.
This needs to be revised.
MR. LARSON: Years ago there was talk of the agency making
up certain rulemakings it was going to propose and then it got out of
that thought process. And then I thought last year, or earlier this
year, the agency thought it was worthwhile to have rulemakings on
certain issues related to high level waste to shorten the -- are there
any of those planned? I guess there are none planned for 2000.
MR. REAMER: No.
MR. LARSON: Okay.
MR. REAMER: What we told the Commission, if I remember
correctly, is that this was a way in which we might proceed in the
MR. LARSON: Yes.
MR. REAMER: We had no right candidates at that point, and
there are none at this point either.
DR. HORNBERGER: What are the units on the numbers in this
MR. REAMER: Which numbers?
DR. HORNBERGER: Like 46 at the bottom right.
MR. LARSON: FTEs.
DR. HORNBERGER: Are they FTEs or are they millions of
MR. REAMER: FTE.
DR. HORNBERGER: You would rather they be millions of
DR. GARRICK: I guess up here is the millions of dollars, at
the top, 18-1/2.
DR. HORNBERGER: Yes.
DR. CAMPBELL: What impact will Congressional action have on
these budgets and what have you heard in terms of any bills making their
way through Congress in terms of NRC's budget, and, in particular, the
high level waste budget?
MR. REAMER: Yeah, the high level waste budget in both the
Senate passed and the House passed version is pretty close to what we
proposed. DOE is the one who has got the problem.
DR. CAMPBELL: Yes.
MR. REAMER: They have a wide disparity between the House
and the Senate has 355, the House has 281. My impression is 355 doesn't
get the license application in 2002, and the House version 281 means
even more potential changes. But now that is a DOE issue. I am only
kind of repeating what my understanding is. Did that respond?
DR. CAMPBELL: Yes.
DR. GARRICK: Any other questions?
DR. GARRICK: Thank you.
MR. REAMER: Okay. Thank you.
DR. HORNBERGER: It was very useful.
DR. GARRICK: Yes, it really helps.
MR. LARSON: We should get decommissioning tomorrow.
DR. HORNBERGER: How does -- just looking at some of the
things that are coming along, how does that tally with the schedule for
calendar '00 that we talked about?
MR. LARSON: Well, if you have to do everything in November,
you are going to have a busy November, December.
DR. HORNBERGER: Well, also, they have the low level BTP in
the spring, and I am just trying to think, you know, we were talking
about being on the road in the spring.
MR. LARSON: Yes, I guess at this point I wouldn't change
anything, because what they are talking, finalizing it in July.
DR. HORNBERGER: No, no. No, I know, I realize that. So we
MR. LARSON: You may want to, when you are talking to the
Commission, go into it.
DR. LARKINS: When it is appropriate, because sometimes they
are mainly for information.
MR. LARSON: Trying to remain within the eight or nine
meetings, the eight meetings a year.
DR. HORNBERGER: No, I don't want to say that. I am going
to try like hell to remain within the agency here.
DR. GARRICK: Okay. Any other discussions?
DR. GARRICK: Then I would suggest we adjourn this portion
of our meeting. And I think for our discussions later on, we don't need
a reporter, do we? Because we are going to go back to discuss reports
when we get back.
MR. MAJOR: Risk communication but we do not need a
DR. GARRICK: But that is staff. We do not need a recorder.
So I think this adjourns today's session.
[Whereupon, at 2:06 p.m., the meeting was recessed, to
reconvene at 8:30 a.m., Wednesday, September 15, 1999.]
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