112th ACNW Meeting U.S. Nuclear Regulatory Commission, September 15, 1999

                       UNITED STATES OF AMERICA

                        U.S. Nuclear Regulatory Commission
                        Two White Flint North
                        Room T-2B3
                        11545 Rockville Pike
                        Rockville, Maryland

                        Wednesday, September 15, 1999

         The committee met, pursuant to notice, at 8:35 a.m.

         B. JOHN GARRICK, Chairman, ACNW
         GEORGE W. HORNBERGER, Vice Chairman, ACNW
         RAY WYMER, Member, ACNW
         .                         P R O C E E D I N G S
                                                      [8:35 a.m.]
         DR. GARRICK:  Good morning.  Our meeting will now come to
     order.  This is the second day of the 112th Meeting of the Advisory
     Committee on Nuclear Waste.  My name is John Garrick, Chairman of the
     ACNW.  Other members of the committee include George Hornberger and Ray
     Wymer.  In addition, today we have Milton Levenson serving as an ACNW
         The entire meeting will be open to the public.  Today we are
     going to hear from Larry Camper, the Branch Chief of the Division of
     Waste Management, Decommissioning.  He is going to provide us an
     overview of the decommissioning program for Fiscal Year 2000.
         We are going to get a status report on the decommissioning
     Standard Review Plan including the modules, and the committee will
     continue its effort of preparing reports.
         Howard Larson is the Designated Federal Official for the
     initial portion of today's meeting.
         We are conducting this meeting in accordance with the
     provisions of the Federal Advisory Committee Act.  The committee has
     received no written statements or requests to make oral statements from
     members of the public regarding today's session.  As usual, should
     anyone wish to address the committee, please make your wishes known to a
     member of the Staff.
         It is requested that each speaker use one of the microphones
     and identify himself or herself and speak with sufficient clarity and
     volume so that he or she can be readily heard.
         The committee member that will lead the discussion today is
     Ray Wymer, and why don't we just proceed and let Larry get us into the
         MR. CAMPER:  Good morning.
         DR. GARRICK:  Good morning.
         MR. CAMPER:  I looked forward to this session for a couple
     of weeks.  I came down and met with you briefly at the last meeting and
     introduced myself to you and began to set the stage for a working
     relationship with the committee.  I think as you know I came to the
     decommissioning area in July.  I had spent the last four and a half
     years as the Branch Chief for Material Safety and Inspection Branch, so
     if I go way back along the way, back in 1988 to 1989 I was a Project
     Manager in the Division of Waste Management, so I had some familiarity
     with the program.  Of course, I have been on the peripheral edges of
     decommissioning over the years in Material Safety.
         But I come to the Branch and I come to you at a very
     interesting time in terms of decommissioning.  There is a great deal of
     activity going on in decommissioning.  There is a very interesting
     number of issues that that have to be addressed, and as I will point out
     to you today in my presentation I think there are some areas where the
     committee can be of assistance to us.
         The agenda item is billed as the FY 2000 Operating Plan for
     the Decommissioning Branch and Key Decommissioning Issues, but we are
     going to add a little flavor to it by having our colleagues in NRR --
     Mike Masnik is going to follow my presentation and share with you some
     insights from the NRR side of the house, because obviously
     decommissioning for reactors starts in their world and in transfers to
     our world in Materials.  Also Research, the Office of Research is going
     to make some comments somewhere along the line.  I am not sure if they
     are going to follow me or a little bit later in the agenda today, but
     Research also plays a vital role in helping us to develop guidance.
         Yesterday I think you got some sense of that when we were
     talking about the Memorandum of Understanding that we had sent to
     Research recently, and they are making a lot of effort right now to
     upgrade some of the modelling, and so there will be some input from
     Research as well.
         I do have some slides coming to you.  I apologize.  I just
     don't have them in front of you now.  Of course, as these things go,
     there is always something that trips you up at the last minute, but you
     will have them hopefully before I am too far into this talk.
         As I said, what I want to cover primarily is FY 2000 and
     other key decommissioning activities.
         Now last year I know that you got a rather extensive
     presentation from John Hickey, my predecessor as the Branch Chief, and
     so I am not going to go through a lot of the details of decommissioning
     because John stepped you through that in the last year, but I do think
     it is worthwhile to just sort of reiterate what are the key things that
     drive us, because I am going to talk to you in a few minutes about a lot
     of FTE and a lot of contract dollars, and I am going to talk to you
     about some fairly high profile stuff, but I think it is pretty important
     to remind ourselves what it is that we are trying to achieve.
         Obviously we need clearer criteria and guidance for
     decommissioning.  We need timeliness on all of our actions, and I think
     that is one of the areas that I am going to be looking a lot at as the
     Branch Chief, and I have already told the Staff this.  I am interested
     in seeing our timeliness tightened up considerably.  I must tell you in
     some cases I think we just take too long to get actions done.
         Now there are some legitimate reasons for that and the Staff
     works very hard, but I think we could probably do a little bit better
     job in terms of timeliness.
         Financial assurance of course is an area that requires a
     great deal of attention, efficiency and finality -- I am going to
     mention finality again later in the talk, and one of the things that
     really troubles John Greeves, the Division Director, is finality.  There
     is a great deal of concern out there, particularly amongst the reactor
     facilities that if they go through the License Termination Rule and they
     satisfy the 25 millirem, are they going to find themselves then having
     to deal with another federal entity, for example, EPA with a different
     standard, and the difference in cleanup cost between 15 and 25 millirem
     can be significant in certain situations, so finality is an issue that
     we are very concerned about.
         Obviously it is not totally within our control.  I think you
     know as well as I do the role of the EPA and the current way of doing
     things and in fact Chairman Jackson had sent a letter to the
     Congressional Oversight Committee suggesting that Congress perhaps
     should play a role in trying to resolve the difference between 25
     millirem and 15 millirem, so finality is a fairly big issue for us.
         In terms of size of the program in FTE and dollars, it is a
     fairly large program.  We have approximately 22 FTE at Headquarters,
     about $1.8 million.  We have 6.5 FTE in the regions, primarily
     conducting inspections.  For reactor decommissioning on the NMSS side of
     the house we have 3.4 FTE -- not quite a couple hundred thousand
     dollars, .8 FTE in the regions.  Then on the Reactor Decommissioning
     side of the house, which Michael will talk more about, has almost 18 FTE
     at Headquarters and three-quarters of a million dollars, roughly, 9 FTE
     in the regions.  In the Decommissioning Program within Research there is
     on the order of 10 FTE and approximately $2.3 million.
         So as you can see, there's a lot of effort going into
     decommissioning, a lot of FTE, a lot of contract dollars.  I think as I
     go through my talk you will see there is a great deal of activity going
     on, but we certainly know that when you have that many FTE in a program
     I know one of the concerns that Carl Paperiello had, and he and I talked
     about this before I went down and took over the Branch, is that he wants
     to be certain that we take every opportunity to reinforce with the
     Commission the level of decommissioning activity that is going on.
         I know one thing in particular he is concerned about is SDMP
     sites.  We are making a lot of progress on the SDMP front.  By about
     January or February we will have approved a number of plans and removed
     some additional sites, but what we are ultimately going to be stuck with
     is those very complex, complicated sites -- SDMP sites and otherwise, so
     while this looks like a lot of FTE, there's a great deal of activity
     going on and there will be a great deal of activity going on in the
     foreseeable future.
         Well, again it is always a good idea to sort of revisit what
     are our responsibilities and again I won't spend a lot of time with
     this, because you have seen it before just recently, but I did think it
     was useful to me in my role now to sort of stop and think about each one
     of these and if we look at those, you can see it is a fairly broad
     spectrum of responsibility, I mean ranging from guidance creation,
     interfacing with other organizations such as EPA, informing and
     involving members of the public.
         Increasingly the Commission is concerned about stakeholder
     interests and stakeholder involvement.  We go to substantial effort to
     ensure that there is adequate stakeholder involvement.  For example, we
     recently had one of our workshops on the License Termination Rule here
     at Headquarters and we made it a point to get out and contact
     stakeholders that we were aware of, individuals and organizations, and
     invite them to participate.
         The Commission has made it very clear they want to hear all
     perspectives on issues, and certainly on decommissioning you can readily
     appreciate that there is a great deal of stakeholder sensitivity at the
     sites, so stakeholder involvement is a very large deal.  We provide a
     great deal of technical assistance to the regions.  We look at
     previously approved burial sites, for example, and we probably handle
     six or seven technical assistance requests per year from the regions on
     that topic alone, so it is a fairly broad spectrum of responsibility on
     the Materials side.
         Similarly, on the reactor side the decommissioning process
     for reactors starts on NRR but there is a juncture, there is a point in
     the process where there is a handoff to us and that occurs once the
     spent fuel is permanently transferred from the spent fuel pool, and then
     we go from that point all the way to closure -- improving the License
     Termination Rule, conducting environmental assessments, and then
     ultimately getting to the point where we prepare the license termination
     action, so this is a fairly long, drawn-out affair, going on typically
     two, three, four years, with a great deal of Staff effort and many steps
     along the way.
         We are still relatively new at this.  As you know as well as
     I, reactor decommissioning is fairly new to us.  We did have a couple of
     License Termination Plans that had been provided to us that were
     rejected.  Those are coming back.  We have the Maine Yankee just around
     the corner, probably in November or so, coming in with their package,
     so, you know, we have a lot to do, but yet we are also trying to work
     our way through some new concepts and some new ideas.
         Now I think the point that I would make on these
     responsibilities on the reactor side, and it is something I have shared
     with my sections leaders and with the PMs, we have to make our calls on
     submitted information.  We have ultimately got to make a call and we can
     only do it on the written submittal, but we have to be willing to be
     flexible, to sit down with reactors that are undergoing decommissioning
     and discuss conceptual ideas.
         To develop a decommissioning plan or License Termination
     Plan costs lots of money.  To decommission a reactor costs lots of
     money, large sums of money.  We have to be willing to participate in
     conceptual discussions.  There is a concept I will talk a little more
     about here in a few minutes called "rubblization."  We have already had
     a couple of meetings with the folks from Maine Yankee and consultants
     working for Maine Yankee to discuss this conceptually.  We have to be
     willing to do that as an agency.  We can't make commitments based upon
     those discussions, but we have to be willing to explore new ideas
     because people are trying to find ways to reduce the cost of
     decommissioning, so we are going to have to be mindful of that as we
     work our way through this.
         MR. LEVENSON:  Excuse me, before you take that off, is there
     a definition for the word "permanently" as it is used there in the first
     bullet?  Since this is a transfer of responsibility it seems to me that
     it would be fairly important that that be clearly defined.
         MR. CAMPER:  Mike, I will defer to you for that.  Can you --
     would you like to comment on the term "permanently transferred from"?
         DR. GARRICK:  Announce your name, et cetera.
         MR. MASNIK:  Yes.  This is Mike Masnik.  What we are finding
     in the reactor arena is that the plants are placing the fuel in dry
     storage.  Once they transfer the fuel to dry storage, it is put in the
     dry storage containers.
         Then they actually dismantle the spent fuel pool, so the
     chances of being able to unload the fuel and then put it back into the
     fuel pool are gone.  Basically that alternative is gone, so it is in a
     sense a permanent transfer from wet storage to dry storage.
         MR. LEVENSON:  But what you are really saying is that it is
     due to the dismantlement of the pool though, not the type of storage?
         MR. MASNIK:  No.  No, the casks the fuel is being
     transferred to are designed for --
         MR. LEVENSON:  Yes, I am familiar with all of that.  I am
     just trying to define when they transfer all of the fuel out into casks
     but the pool is still intact, is that when the responsibility transfers?
         MR. MASNIK:  That's correct. Once all the fuel is in the
     casks then we initiate a transfer of project management oversight from
     NRR to NMSS.
         MR. LEVENSON:  So there is no legal requirement that they
     might not have to put some of it back as long as they have a pool.  It's
     just when the transfer is completed --
         MR. MASNIK:  That's correct --
         MR. LEVENSON:  -- the responsibility transfers?
         MR. MASNIK:  If done properly, this is completely invisible
     to the licensee.  Basically all they get is a new Project Manager who
     reports to Larry Camper instead of to myself.
         DR. GARRICK:  While we are interrupting Larry.
         MR. CAMPER:  Sure, not a problem.
         DR. GARRICK:  A couple of questions.  One is, what mechanism
     do you use to -- when you were talking about FTEs, what mechanism do you
     use to do your planning as far as the workload requirement is concerned,
     other than waiting for a licensee to come in and say they are going to
     engage in decontamination, decommissioning?
         MR. CAMPER:  Well, that is an interesting question, and
     there is really sort of two parts to the answer.  We go through a fairly
     orderly, at least we think it is a fairly orderly process of planning.
     We are planning out about two years.  And what we do is we have
     historical workloads.  We have known sites that are, you know, going to
     be undergoing decommissioning.  We also do some anticipatory thinking,
     okay.  And that then factors up to whatever FTE it equates to.
         Then there is also the surprise factor, if you will.  We do
     have to do some scrambling along the way to make adjustments in
     available FTE as developments emerge that we didn't know about.  It
     hasn't been a problem historically, as I understand it, for the
     decommissioning branch.  We think we have a pretty solid handle.  But,
     basically, it is historical information, it is current awareness and it
     is anticipated developments that we are aware of at the time.  We are
     pretty close, we are pretty close.
         DR. GARRICK:  So you could construct forecasts more or less
     curves of future requirements as far as NRC is concerned with reasonable
         MR. CAMPER:  Yes.  Yes, we could.
         DR. GARRICK:  The other thing kind of related to that is,
     and maybe it will be covered when you talk about rubbleization, is, how
     does the staff keep up with any new technologies that might be employed
     in the decommissioning process?
         MR. CAMPER:  That is a challenge, in all candor.  It is a
     challenge for a couple of reasons.  We do try to, and we do participate
     in a number of meetings, a number of society meetings.  For example,
     there is a meeting coming up very shortly up at Haddam Neck that NRR
     folks are taking the lead on.  We will be participating.  John Greeves
     and I are going to a meeting with NEI in Portland, Maine on reactor
     license termination plans and decommissioning of reactors.
         So we try very hard to get management and staff out to these
     various meetings.  We try to actively participate in them if we are
     asked to.  We also attend professional society meetings.  But it is very
     -- it is a challenge, I will tell you, in all candor, to do the
     casework, to meet the expectations that we have before us, stay as
     current as possible, and also play a leadership role by interfacing with
     these organizations as they are exploring conceptual ideas.
         Do we do it as well as we could?  I don't know.  Probably.
     Maybe we could do better.  But it really involves those three avenues.
         DR. GARRICK:  Yes.  Okay.  Thank you.
         MR. CAMPER:  You know, maintaining your state of the art
     when you are running hard is not easy.
         DR. GARRICK:  Yes.
         MR. CAMPER:  With the rubbleization, for example, and this
     was a concept that was brought to our attention, it came to us as a
     result of Maine Yankee and the consulting firm that they are using, and
     NEI is also looking at the concept of rubbleization in a more generic
     sense, and I will tell you a little bit more about that in a minute.
         DR. GARRICK:  Okay.  Thank you.
         MR. CAMPER:  So it is those kind of efforts.  We also play a
     role in inspections and we have gone through a streamlining effort in
     the last few years to try to more closely have project managers at
     headquarters interface with regional inspectors to coordinate the
     inspections, to actually participate in the inspections, and, of course,
     these inspections are being conducted following Manual Chapter 2602 and
     the inspection procedures in 87104 and 88104.
         I think the point that I would make here is that these
     inspections are obviously a very important part of the process, getting
     out there, actually seeing what is being done, but the take-home point
     is that we have gone through a substantial streamlining effort to more
     closely coordinate the activities of project managers and regional
         So what is on the scope for the near term?  We will be
     looking at on the order of five to seven decommissioning plan reviews
     for approval.  These are SDMP sites, where these were the sites that
     were grandfathered under the LTR.  According to our operating plan, we
     are to remove three SDMP sites each fiscal year.  We will be reviewing
     SDMP sites using the license termination rule criteria, about six of
     those.  We have reviews of non-SDMP complex sites using the LTR, these
     are sites like NFS Irwin and Malinckrodt.
         We will be reviewing LTPs for probably two power reactors,
     Maine Yankee being one, Trojan being the other.
         We do on the order of 20 to 30 financial assurance reviews a
     year.  We conduct about 30 of the inspections using the methodology that
     I just showed you, per year, the integrated inspection approach.  And we
     do on the order of 10 or so technical assistance requests per year for
     the regions.  So there is a great deal of casework activity, as you can
         I think it is probably worthwhile just to revisit again some
     of those FTE numbers.  And if you bear in mind the types of
     responsibilities that I talked about, coupled with the type of casework
     that we see, while, again, one might look at that size of resources and
     say that is a very large number of resources.  If one wanted to have the
     bean counter hat on and be a skeptic, I think that you need to bear in
     mind the kinds of responsibilities and things that are being done in the
     decommissioning area and the casework.  Very real casework, all of which
     has timelines associated with it, milestones along the way, and we work
     toward completion.
         We have very aggressive timelines on our technical
     assistance requests.  We try to do acceptance reviews of these things in
     a matter of 10 to 20 working days.  We try to turn them around in 45 to
     60 days.
         Financial assurance reviews, while there is no metric for
     how fast they have to be done, we try to do them as quickly as possible.
     So all of these things, there is a lot of it, and they are all monitored
     very closely, and they all have assigned timelines.
         This is the grandfathering cases.  There is a requirement in
     the license termination rule that allowed for the grandfathering
     provision and it indicated that licensees were to submit their
     submittals to us by August the 20th of '98, and we were to approve the
     decommissioning plans by August of '99, August 20, '99.  We found that
     we were not able to do that for a number of legitimate reasons such as
     the interface with states reviewing environmental assessments, responses
     from licensees, the technical quality of some of those responses and so
     forth and so on.  So we found ourselves not being able to approve all
     the DPs by August 20th.
         So we went to the Commission and we said what we want to do
     is grant an exemption to August 20th, 2000, and the Commission agreed
     with that.  And in the paper we provided this schedule to show, although
     we are asking for the exemption to August 20th, 2000, a great deal of
     progress will be made in the short-term.
         But I think the important thing here, there is two things,
     one is not only is there a lot of activity going on in terms of
     approving these decommissioning plans in the short-term, but, again,
     once we get through this particular flurry activity on these SDMP
     decommissioning plans, what is going to be left are the really tough,
     onerous cases.  So there is a lot of activity in the short-term,
     followed by some very complex sites.
         Well, we have other important non-casework activities that
     we do.  We provide support to the Decommissioning Board.  One of our
     members of our staff actually works to prepare the agenda, provides all
     the background material, coordinates with the chairman of the board to
     ensure that we have everything that the board needs to conduct its
         Yesterday you heard about the Standard Review Plan.  Nick
     will talk more with you about the Standard Review Plan later today, but
     we are working to finalize the Standard Review Plan and other related
     decommissioning guidance.
         We are playing a very active role in support of clearance
     rulemaking activities.  I mean, for example, as we speak, we have three
     members of our staff in a public meeting in San Francisco on the
     clearance rulemaking initiative.  So there is a great deal of support
     for that particular issue.  And then, ultimately, we are going to be the
     base of operations for the ongoing implementation of the clearance
     initiative, assuming it survives, assuming it is a rulemaking and
         We have been conducting a decommissioning pilot program.
     Five sites were identified.  It was narrowed down to three.  That
     decommissioning pilot program goes on.  The idea behind that is to try
     to make it more performance-oriented to allow licensees to start
     decommissioning activities without receiving prior approval from the
     NRC.  That project continues.
         West Valley Demonstration Project activities, the West
     Valley Project continues, it is a very large time sink.  One of our
     staff, Jack Parrot, is the PM, and next week Jack are going up to that
     site and do a tour, and then we are taking part in a Citizens Task Force
     meeting that evening.  So West Valley continues to a large effort.
         Support of the Interagency Steering Committee on Radiation
     Standards, ISCORS, we provide a great deal of support and effort to that
     initiative, which is very important.
         And then reexamining and rebaselining complex sites.  One of
     the things that I am very concerned about, and the staff often hears
     from me, is closure -- closure -- closure -- closure.  It ain't over
     until it is over.  We have a lot of complex sites that we are going to
     have to deal with, and we are undertaken right now a rebaselining,
     reexamination of all the sites that we have before us to deal with.
         Let me say a few more words about the rebaselining
     reexamination initiative.  We recently briefed the Commission on the
     status of SDMP sites, and at that time -- and it may be because this
     particular current Commission hasn't been around over the years when a
     lot of activities went on in the SDMP area -- but the result was they
     had a lot of questions about the SDMP area.
         So when we go back this coming spring to brief the
     Commission, we will be preparing and providing to them the biennial
     report, which is a detailed report on the SDMP sites.  We provided our
     summary report this year, but when we go back this time, we will be
     including within the Commission paper attachments for each of the SDMP
     and other sites that we have undergoing decommissioning.  As part of
     this effort, we're going back and we're taking a fresh look at what is
     on the plate and what is it going to take to get to closure.
         I want to make sure and ask the PM's to make sure that the
     SDMP data base is current and up to date.  I think you know as well as I
     do that a data base is only good if it's current.  We have been -- we
     let ourselves sort of drift into updating the data base on a quarterly
     basis or updating the data base as we prepare for these annual
     Commission briefings.  I've asked that the data base be made current.  I
     want to be able to go into it at any given time and know what the status
     is of any given site in current terms.
         I've asked the PM's to take a look at all of the technical
     and regulatory issues that confront us at that particular site.  I've
     asked that we identify major assumptions.  Within the SDMP data base
     there is a narrative section where this type of information can be
     depicted.  When we go up with the Commission paper, these attachments
     will contain information that will identify all the major assumptions
     that we have brought to bear in trying to estimate what are the major
     milestones for this particular site and what is the best estimated time
     of arrival for completion of that site that we can determine.
         Now those dates are subject to change, of course.  Licensees
     start down the pathway of decommissioning, they don't progress quite as
     they thought they would, they uncover issues they didn't know were
     there.  These things are subject to change.  But unless we have a viable
     management tool and have a pretty good handle on what it's going to take
     to bring a site to closure, we're going to find ourselves in a briefing
     five or ten years from now still talking about X, Y, and Z site.  We've
     got to have a solid plan.
         I'm including for each of the sites a project management
     information and Gantt charts that will depict all the major milestones.
     And again we owe the Commission the next report on the SDMP sites and
     other sites in March of next year.
         Now the Commission has asked that the next briefing on
     decommissioning activities be a combo, the NRR and Materials.  So the
     briefing that we provide next spring or summer following this Commission
     paper will be a joint effort between us and NRR to discuss the status of
     the decommissioning of sites at large.
         But the point I want to make here, this is not business as
     usual.  The staff and the Decommissioning Branch have worked very hard,
     they have done a very good job, they have made incredible progress in
     clearing SDMP sites off the rolls.  But unfortunately you get to a point
     where what's left is the tough stuff.  We have picked the cherries out
     of the fruit cocktail, and we need to have definitive plans and know
     exactly what we're up against in the remaining complex sites.  That's
     what this effort is all about.
         So it's twofold.  One, it will give us a current viable
     management tool, a clear understanding of where all the sites stand.
     We'll probably learn some things along the way that we really didn't
     know were issues at these sites.  It'll give us the best possible
     estimate of when we're going to be able to bring the site to closure,
     and it will give us current, meaningful information to present to the
     Commission that hopefully will address the kinds of questions and
     concerns that I heard during the last briefing.  So it's a fairly big
     undertaking for us.
         We face some challenges, the Agency faces some challenges,
     not only the Decommissioning Branch within the Division of Waste
     Management but NRR and Research.  We all face challenges.  Dose modeling
     guidance.  I mean, you heard a lot yesterday about dose modeling
     guidance.  You had some very astute questions.  I'm not going to belabor
     that point, but it is very clear to us that we need to make the modeling
     approaches, remove some of the conservativeness that's in it to make it
     as realistic as possible.  There's a lot of work going on right now
     within our shop, within Cheryl Trottier's branch to make that happen.
         Clearance Rule.  Clearance rule is a significant challenge.
     I don't know how much you're up to speed on the clearance rule, but
     basically what's happened is that the Agency published an issues paper
     in which it expressed concerns about the idea that there's no standard,
     there's no rulemaking that allows a clearance or a recycling of
     materials that have been contaminated at some levels.  It started off
     being called clearance.  We are increasingly gravitating toward the
     concept of control of solid materials, although conceptually the idea is
     that these materials can be released at some determined level.  The
     international movement tends to be on the order of 1 millirem.
         What we have found, though, is that there is tremendous
     opposition to the initiative, tremendous opposition to the initiative,
     so much so that individuals that are opposed to the concept that the
     Nuclear Regulatory Commission would allow release or recycling of any
     material that has been contaminated, or for that matter that we would
     not go out and do something to cause any material that has been
     released, even if they were released on a case-by-case basis, we have
     been releasing -- allowing release of materials on a case-by-case basis
     for a number of years.
         So there's even concern among some people that not only
     would we consider pursuing a clearance or release or control of solid
     materials, the net result of which would be to allow material to be
     recycled, but there has been material released already, and we should do
     something about that.  Their opposition has been so strong that they
     have opted not to participate in public meetings that we've scheduled.
         DR. GARRICK:  And what's the basis of the opposition?  Is
     there a --
         MR. CAMPER:  Yes.  It's radioactive.
         DR. GARRICK:  Huh?
         MR. CAMPER:  It's radioactive.
         DR. GARRICK:  Well, I know --
         MR. CAMPER:  How dare you -- the basis is that it's
     radioactive.  How dare you -- you are here, NRC, to protect us, protect
     public health and safety, how could you conceivably entertain the idea
     of allowing radioactive material, anything that's contaminated with
     radioactive material, to be recycled or reintroduced into society.  I
     mean, that's the essence of the opposition.  They're very concerned
     about any level of exposure.  The preference is zero radiation.  I mean,
     that is their concern.
         Now the thing that was a little disturbing to us, though,
     was normally most of us believe that the way to work through our
     differences is to sit down and have discussions and have an agenda and
     let's work through concerns.  But they felt that it was preordained that
     a rule would result.  Some of them expressed concerns that historically
     they've participated in rulemaking efforts, but their concerns weren't
     heard, the Agency proceeded with a rule anyway, and therefore, you know,
     you're going through the motions, you're really not going to seriously
     entertain what we have to say.
         The staff became very concerned about this, the facilitator
     became very concerned about it, the staff went back to the Commission
     and brought to the attention of the Commission the fact that there was
     this level of concern and objection, suggested that perhaps rather than
     continue with the scheduled workshops, there was one scheduled for
     Chicago in August, the meetings going on in San Francisco yesterday and
     today, there's a meeting in Atlanta in October, and there's a meeting
     here in Washington in November.
         The meeting in Chicago in August was postponed because of
     the level of opposition, and the concern really of the staff was can we
     have a viable, meaningful exchange of ideas if those whose views are so
     strongly held will not participate, are we really able to cover the
     waterfront in terms of concerns?
         We went to the Commission.  We said that, you know, we
     really may -- we ought to stop and regroup and take a different
     approach, kind of try to meet with these various stakeholders, find out
     what their concerns are, and then proceed with public meetings.  The
     Commission advised the staff to proceed with the meetings.  That's why
     the meeting in San Francisco is going on.  The Commission, the vote
     sheets reflect a concern to the Commissioners in which they believe that
     there is a need to address the development of a standard to allow
     control of solid materials in an orderly fashion, to not have to do it
     continuously on a case-by-case basis, to try to determine and explain to
     the public what is a low enough number and the rationale for that
     number.  So the Commission felt very strongly that the staff needed to
     proceed.  So the meetings are going on.  But the Clearance Rule is a
     very interesting issue.
         Restricted release cases that we think will pose some
     challenges for us because there will probably be -- as you know, under
     the License Termination Rule there is a provision for restricted
     release.  It will probably involve some very complex questions in terms
     of adequacy of institutional controls.
         And clearly there will be a lot of stakeholder involvement.
     There will be a lot of stakeholder concerns.
         DR. WYMER:  In that connection, what is the continuing
     responsibility of the NRC?
         MR. CAMPER:  Well, at some point we step out of the game.
     We have to ensure that there is adequately defined and in place
     institutional controls.  Now, we have some ideas in guidance space as to
     what those institutional controls are.  It may be another federal
     agency, for example, the DOE or some state agency.  But the way the
     process is to work, we will reach a determination that, in fact, there
     are adequate institutional controls, and that the institutional controls
     will be in place for a determined, adequate amount of time.  But we step
     out of the game at some point.
         DR. WYMER:  So the NRC can get out clean and clear.  In the
     case of a DOE facility, I know DOE is stuck forever.
         MR. CAMPER:  That's right.  Their charge is different than
     ours, you are right.
         DR. WYMER:  Okay.
         MR. CAMPER:  There will be unique proposals.  Oh,
     development the regulatory framework for partial release.  You know,
     right now we had this requirement that you are a reactor undergoing
     decommissioning, say, for example, and you submit a license termination
     plan.  Well, as you further characterize the site, as new calculational
     methods emerge, new computer programs emerge, you may need to make
     changes to your license termination plan.  There is no mechanism right
     now for that to happen.  We have to figure out a mechanism for that to
         And that is an area, by the way, that you may be of some
     assistance to us.  We have some models, some thoughts, but it is still
     early in the game.  This was talked about during the recent workshop
     that we had here on the license termination rule, but that is an
     emerging issue that we are going to have to come to grips with very
         Unique proposals by licensees.  Rubbleization is an example
     of that.  The integrated rulemaking, NRR, I think Mike will touch on
     that when he gives his talk, but there is a charge by the Commission to
     look at the question of integrated rulemaking on the reactor side of the
     house.  The decommissioning regulatory improvement initiative, again, I
     will let Mike step through that.
         And then again, this issue of finality of decisions.  I
     can't tell you how much that troubles my boss, John Greeves, and how
     much it troubles us when we go to meetings and we hear entities get up,
     whether it is NFS Irwin or it is the reactor facilities, and they say,
     you know, how do I know -- how do I know when I get through dealing with
     the Nuclear Regulatory Commission, and I am at, you know, either 25
     millirem or some other agreed-upon criteria, how do I know that that is
     it?  I mean how do I know that the EPA or a state agency is not going to
     come in?
         And I think that you guys all probably, you gentlemen and
     ladies probably all realize that, you know, there is a lot of concern
     out there that 15 millirem, you know, it 65 percent less than 25
     millirem and, therefore, it is lower and you ought to go there.  There
     are some states that talk about 10 millirem.  You know, a lot of people,
     when they look at remaining exposure levels, say, why not zero?  I mean
     why should you leave anything behind that makes any kind of dose
     contribution to someone who might come afterwards?  I mean the
     production of energy has ceased, take this stuff with you.  Get it out
     of there.  Don't leave anything.
         So, it really causes a great deal of concern for those who
     are trying to follow the rules, spend a great deal of money,
     decommission their sites, when they know full well that there may be
     someone who will come along later and second guess them.  So, finality
     is a very, very big deal.
         Okay.  Then in summary, you know, we have covered a lot.  I
     have tried to give you an idea of the operating plan and some of the big
     things that we face.  And, so, you know, what are some of the things you
     can help us with?  The clearance rule.  I think that as the clearance
     rule ripens, as we get feedback from the public in these meetings, and
     as the staff tries to move toward developing either a rulemaking or an
     issues paper, or a policy statement, or whatever comes out of this, I
     don't know, I really don't know what it is going to be because we are
     operating with the mindset that all options are on the table.  While it
     is very clear to me from reading the vote sheets of the Commissioners,
     and looking at the staff's last communication with them on the clearance
     initiative, there is a strong sentiment that something needs to be done
     in a positive manner along rulemaking to create a standard and put this
     issue to rest.
         Having said that, though, the Commission is very mindful of
     the fact, and has instructed the staff to explore all options.
     Everything is on the table.  So I don't know what we will come out of
     it, but I think that it would be useful if we would share with you on
     your agenda along the way whatever is being developed and get your input
     and perspectives on it.  That would be very helpful to us.
         Entombment is an emerging issue.  Research, I believe, is
     currently developing a paper on entombment, or will be developing the
     paper shortly, as I understand it.  Perhaps, Cheryl, you can clarify
     that for me.  But entombment is an issue that, as it moves along, I
     think you could help us a lot.
         I have just a brief blurb to read to you about entombment,
     and given that the paper hasn't been developed yet, it is still early
     and a little premature to get into it in depth, but entombment is viewed
     as an alternative in which radioactive contaminants are encased in
     structurally long-lived materials such as concrete.  The entombed
     structure is appropriately maintained and continued surveillance is
     carried out until the radioactivity decays to a level permitting release
     of the property for unrestricted use.  ENTOMB is intended for use where
     the residual radioactivity will decay to levels permitting unrestricted
     release at the facility within reasonable time periods.
         I think I know why you are chuckling in terms of reasonable
     time periods.  I.e., within the time period of continued structural
     integrity of the entombing structure, as well as confidence in the
     reliability of continued radioactivity containment and access
     restriction, perhaps on the order of 100 years.  Well, that is
     immediately a problem, obviously, because, given the nature of some of
     the isotopes and what-have-you involved in the facilities we are talking
         It goes on to say that -- it points out the fact that,
     obviously, this doesn't work real well with half-lives.  Thus, the basic
     requirement of continued structural integrity of the entombment cannot
     be insured for these facilities and ENTOMB would not be a viable
     alternative in these circumstances.
         On the other hand, if the entombing structure can be
     expected to last many half-lives of the most objectionable, long-lived
     isotopes, then ENTOMB becomes a viable alternative because of the
     reduced occupational and public exposure to radiation.  However, even in
     these circumstances, one of the difficulties with ENTOMB for any complex
     structure such as a reactor is that the radioactive materials remaining
     the ENTOMB structure would need to be characterized well enough to
     ensure that they will have decayed to acceptable levels at the end of
     the surveillance period.  If this cannot be done adequately, deferred
     decontamination will become necessary, which would make ENTOMB more
     difficult and costly than decontamination or safe storage.
         Now, you know, just quickly, that is what entombment is
     about in general terms.  But, again, as the staff develops the paper
     that I am referring to, and as we begin to materialize our thinking on
     this a bit, and explore with the Commission, again, I think that is a
     very viable role for the committee to provide some thoughts.
         DR. WYMER:  It is a little hard to see how you could have an
     unrestricted release in an entombed state.
         MR. CAMPER:  That's right.  Sure.  That's right.  Well, that
     is envisioned conceptually.  But you are right, that is right.
         Now, the other one is rubbleization.  Now, rubbleization is
     here and now, it is getting very close.  In general terms, rubbleization
     is a concept whereby a utility would go in, do some characterization of
     materials on the wall, would go through a scabbleization process, would
     end up with levels of contamination on the walls considerably higher
     than those in Regulatory Guide 1.86, would then tear the wall down,
     break it into concrete pieces of varying size.  Some of them could be
     blocks that are three or four feet in diameter.  Some can be as small as
     stones.  When you break the wall up, you are going to get all kind of
     sizes.  You then take and leave three walls of a four wall structure in
     place.  You take a bulldozer, you move all this rubble into this
     containment, these three walls.  You then cover it up and you cap it off
     and leave in a green field condition.
         A couple of interesting points about it.  By going this
     route, the amount of money that can be saved per site in terms of costs
     saved in scabbleization, cost saves in hauling material away and
     what-have-you, ranges from probably on the order of $7 million to $30
     million per site.  So we are talking significant dollars.
         Right now Maine Yankee is seriously considering including
     this approach within their license termination plan to be submitted to
     us.  We have had three meetings with Maine Yankee, including a closed
     meeting recently with Maine Yankee and their consultant, because of
     proprietary concerns about the modeling that the consultant is using for
     the rubbleization process.
         The Staff is currently developing a Commission paper on the
     rubblelization concept.  We want to share with the Commission the fact
     that this concept is emerging as a preferred path.  It appears that it
     will have generic use implications.  It appears that it will have
     substantial cost savings for those sites choosing to use it, and so we
     want the Commission to be aware of it and to provide a policy position
     on the rubblelization approach.
         During the recent workshop here on the License Termination
     Rule this was a topic on the agenda that generated a great deal of
     discussion.  The point the Staff made that day was we would rather not
     have to deal with the rubblelization issue as a concept, only in terms
     of the Maine Yankee LTP.  If this in fact is emerging within the
     industry as an approach then we would like to see the industry weigh in
     on the matter.  As a result of that Paul Genoa of NEI agreed for NEI to
     provide us a white paper for inclusion as an attachment within our
     Commission paper.
         They have committed to providing that to us by the 15th of
     September.  I also understand that the State of Maine intends to provide
     us with an issues paper on rubblelization which will be included as an
     attachment to the Commission paper, and during the day of the public
     meeting a lady whose name I forget now -- Judith Jonstra or something --
         MR. MASNIK:  Johnsrud.
         MR. CAMPER:  Johnsrud -- expressed some concern that if the
     Staff was going to include an issues paper from NEI on rubblelization,
     would we also consider including an issues paper or statement from the
     environmentally oriented groups and we said by all means we would like
     to have that.  We want all perspectives.  So again they committed to
     providing us with an issues paper by the 15th.
         I, just yesterday in fact, shared Draft Number 2 with
     Division management for them to look at it to see are we getting there
     conceptually, are we touching on all the key issues, and does this seem
     to be neutral in the sense that we are sharing with the Commission what
     the issues are without weighing in too heavily one way or the other.
         Our basic premise in this, the Staff's preferred position,
     is that if it can be demonstrated that this approach will indeed satisfy
     the 25 millirem criteria that it would be acceptable to the Staff, but
     what we want to try to do is make sure that the Commission is (a) aware
     of the concept, aware of the issues associated with it in terms of cost
     savings, generic implications, technically how the model would work and
     then (b) be aware of all the various issue and make a policy decision
     for the Staff to follow.
         Now it strikes me that once we get this Commission paper
     refined and at the appropriate point in the process in our interactions
     with the Commission to be able to share with the committee, the paper
     and get your technical insights and perspective on the issue as well and
     factor that into the equation as we proceed as well.
         One of the things that we are going to have to do if we
     assume for sake of discussion that the Commission agrees that the
     rubblelization concept is viable and says to the Staff, yes, it will
     work, then the Staff is going to have to also develop some guidance.

         There are a number of complex issues that will surface in
     rubblelization, not the least of which is that the mixture, the blocks,
     the rubble will not be homogeneous.  It will be heterogeneous.  There
     will be "hot spots," if you will, within the rubble and then you have to
     get into questions of how does one model that and what are the scenarios
     that have to be considered for the future.
         DR. GARRICK:  One of the things that I am struggling with is
     the difference between entombment and rubblelization, given the
     conservation of radiation, and I can see a difference in geometry, but
     what is the real difference here?
         MR. CAMPER:  Well, again entombment is fairly new, so I will
     speak to what I understand of it at this juncture.
         The concept of entombment is that you have got all this
     material that is contaminated.  You have still got your reactor vessel
     there and what have you.  You have got your structure.  You encase it in
     concrete.  You create a sarcophagus-like effect, if you will, and you
     leave it there for some determined period of time to allow adequate
     decay.  Structural integrity is an issue, control of the site and what
     have you, and then at some point it is no longer an issue.
         Under rubblelization what you do is you go in and you take a
     particular building, a particular area.  You through a scabblelization
     process to remove as much of the contamination as you can.  The values
     that you are left with are probably an order of magnitude or so higher
     than that which is in Reg Guide 1.86.  You then break up the wall.  You
     put this rubble -- you put it into this pit, these three walls and then
     you cover it up.
         So in the latter case you are going through a process of
     removing some contamination to some determined levels.  You then cover
     it up and go to greenfields.
         Under entombment, as I understand it, you basically go in
     and leave the structure and everything intact.  You go through some
     process of sealing it up with material like concrete and you leave it
         Certainly the geometry is different, but there are some
     differences in the concept.
         DR. GARRICK:  You wouldn't be monitoring the site either in
     rubblelization, right?
         MR. CAMPER:  No, it is unrestricted release.
         DR. GARRICK:  In entombment you are monitoring the site?
         MR. CAMPER:  That's right.  In rubblelization you are
     demonstrating that you have satisfied the 25 millirem criteria.  It is
     unrestricted release.  Under entombment it would be restricted release
     and controls.
         DR. GARRICK:  Well, I am still struggling with the law of
     radiation conservation here.  You are not removing this stuff.  You are
     just rearranging it, it sounds to me like, in going from entombment to
     rubblelization, but anyway we can talk about that.
         MR. CAMPER:  Yes.
         DR. GARRICK:  On the clearance rule, what is an example of
     what you think this committee can do to offer good or some useful advice
     on that issue?  It sounds to me like it is almost totally a policy
         MR. CAMPER:  It is.  It is a policy issue.  I agree with
         I guess the thing that would be helpful that comes to my
     mind is the more that learned bodies, sophisticated advisory groups like
     this take a look at the overall approach, the level of radiation that
     you are talking about in the standard -- for example, it is one
     millirem, consistent with what is going on in the IAEA -- the more that
     advisory groups to the NRC, not just the Staff and/or the Commission
     look at this and says in essence this seems to be a reasonable approach,
     it seems to be a number that will ensure protection of the public health
     and safety, it seems to be that the science has been considered
     properly, the more that committees such as yourself, organizations such
     as yourself take a look at that and provide that kind of scrutiny, I
     think the more it lends the credibility of the process.
         DR. GARRICK:  Has the NRC investigated similar kinds of
     criteria applying to other toxic materials and waste sites?
         MR. CAMPER:  I understand -- like chemicals, for example.
         DR. GARRICK:  Right, right.
         MR. CAMPER:  No.  Not yet.  I think certainly they are aware
     of that but, you know, at this point it's been focused on radiation.
         DR. GARRICK:  You see, there's always this tendency to think
     that radiation as a threat is unique and if there's a history and
     experience out there of establishing some sort of criteria, it is
     probably not called a clearance rule but some sort of criteria that
     constitutes adequate cleanup of other sites that involved toxic
     substances and hazardous materials.
         That might be one of the most important baselines to deal
     with in trying to bring the public into this concept as a rational
         MR. CAMPER:  Well, that is a good point.
         DR. GARRICK:  I guess I am just raising it.
         MR. CAMPER:  That is a good point.  I understand.  I
     understand your issue.
         MR. LEVENSON:  There might even be some cases to look at
     baseline with radiation.  In most of the '50s and part of the '60s you
     couldn't make low -- good counting equipment out of brass because the
     world supply of brass was contaminated from radium dials from World War
     II airplanes that just had gone into the junk recycle channels, and in
     another case a few years ago when Oregon was striving -- they didn't go
     to zero but they had a very low number -- it turned out the quarries
     couldn't throw the scrap rock back in the hole and in fact you couldn't
     bury someone who had been cremated, and so I think there's a lot of good
     history that could be developed for why zero is not a practical thing.
         MR. CAMPER:  It's a very interesting issue.  I mean there is
     a great deal of -- I don't want to use the word "hysteria" now -- but
     there is certainly a great deal of concern.  I mean for example the
     State of Tennessee recently went through authorizing an action whereby
     several tons of nickel would be released, and they were down in the dose
     range of on the order of one millirem, consistent with what is going on
     in international circles.
         There's been a great deal of concern expressed about that.
     In fact, 186 organizations signed a letter to members of Congress
     expressing some concern about that, and we have had several
     opportunities to go to Capitol Hill and explain what it was that
     Tennessee did and what was our role in Tennessee allowing this licensing
     action and does it protect public health and safety, and addressed a
     number of concerns which had been raised, and I think it is that type of
     thing, frankly, that causes the Commission to look at this and say okay,
     you know, in the sunlight let's put this thing through due process and
     try to develop a standard because right now there is no standard.
         I mean you have got certain release criteria in Reg Guide
     1.86.  You have got the non-detection criteria on the NRR side of the
     house and you have got case-by-case releases, but it does seem to cry
     out for the need to develop a standard, but having said that we all --
     we as scientists and technical people look at this and say gosh, you
     know, let's look where we are when we talk about 1 millirem or 10
     millirem or 100 millirem, for that matter, but to people who are not
     necessarily of the same scientific bent as we are, who have incredible
     concern about radiation, their position is none, zero, radiation is a
     bad thing, so trying to marry those two views is kind of tough.
         DR. GARRICK:  By definition that is impossible, so --
         MR. CAMPER:  Of course.  Of course.  Of course.  So that is
     what I had to say.  I appreciate your questions and comments and I think
     if you have no more questions on what I have been covering in the
     Decommissioning Branch I will have Mike or Stu come up.
         MR. LEVENSON:  I have one question on this differentiation
     between entombment and rubblelization.
         Material that is going to be rubblelized has generally been
     scabblelized or things have been done to remove activity, is that
     generally in a way such that whatever fraction might be loose or
     leachable, et cetera, might be lower in the rubblelized material than
     entombment, which generally means you just case something up and leave
     it there?
         MR. CAMPER:  Yes, that's correct.  They will have gone
     through a process of scabblelization to reduce the contamination, let's
     say on the concrete wall of the structure.
         MR. LEVENSON:  My question is more than the total content,
     but it seems to me you probably have changed the characterization of
     what is residual too, because if it is relatively easily removed or
     leached, you have done that.
         MR. CAMPER:  Yes.  Leachability is one of the big issues
     that we are looking at in rubblelization, you are correct.  Okay.  Other
     questions or comments?
         DR. CAMPBELL:  To follow up on John's comment about
     examples, there are a number of EPA sites where there was in some
     cases -- I am thinking of the Butte, Montana, the Anaconda mine cleanup
     there -- they had massive amounts of material that could not be moved,
     contaminating streams and waters, and they did various and sundry things
     to isolate and solidify waste and things, and in one example they had
     material that they turned into some sort of material that they could
     pass the leach test, and then Jack Nicklaus came in and they built a
     golf course over it.
         You know, there are a lot of things that have been done out
     there in hazardous materials, hazardous waste cleanup space obviously
     involving community participation where people buy into the plan because
     they get something out of it, if you will.  In this case, Butte, Montana
     got a nice golf course out of it, so there are things that can be done,
     especially in that are of rubblelization that go beyond just leaving a
         MR. CAMPER:  Right.  Thank you.  I will share those comments
     with the clearance groups.
         DR. GARRICK:  We've got the potential for 77 new golf
         MR. LARSON:  Just for the committee's edification, the
     clearance rule, I know, is going to be presented or discussed with the
     committee in December.
         Do you have any time scheduled for either entombment or
     rubblelization, when you think those issues would come, because the
     committee is trying to put together its meeting schedule for next year?
         MR. CAMPER:  Well, let me think.  Entombment -- I would have
     to ask the folks in Research.
         Cheryl, do you have any idea on entombment?  Rubblelization
     I could probably give you some idea.
         MS. TROTTIER:  Cheryl Trottier, Research.  Actually Larry's
     a little wrong about the paper.  We've already sent a paper up to the
     Commission.  We sent that up in July, and it's publicly available now.
         The next step is we're having a public workshop in December
     to hear comments from the public on the concept of entombment.
     Following that workshop, probably in the January time frame, staff will
     probably prepare another paper to go forward to the Commission on the
     issue of entombment.  So that might be a good time frame after we've had
     the public workshop to come before the Committee and let you know the
     findings that the staff has prior to going forward to the Commission.
         MR. CAMPER:  Good.  Thank you for clarifying it.  I wasn't
     aware of that date.  Thank you.
         With regards to rubblelization, our objective is to get our
     paper finished in September and get it up to the Commission.  So I would
     think that we'd have to look at this in terms of just when in the
     process we could share with the Committee.  But I would think that we
     would be looking in the near term, I mean, within the next two or three
         MR. LARSON:  November, with everything else.
         MR. CAMPER:  Is that shaping up to be your monster --
         DR. GARRICK:  Our singularity.
         DR. CAMPBELL:  The meeting from heck.
         MR. CAMPER:  Realistically I think we're in the
     November-December time frame is probably doable.  Okay?
         Okay.  Stu, are you going to cover NRR?
         MR. RICHARDS:  I'm going to do this from a sitting position.
         Good morning.  My name's Stu Richards.  I'm the project
     director for Project Directorate IV and Decommissioning in NRR.  I
     appreciate the opportunity to be here this morning.
         I've been invited to come over and explain a little bit
     about what NRR is doing in the decommissioning area.  We're a copartner
     with NMSS in decommissioning of power reactors, and I'd like to explain
     a little bit of our overview.  I have a fairly short presentation, so
     we'll move right along.
         This slide simply states that our activities are consistent
     with the four pillars of the Commission.  You've probably heard this a
     number of times, so this is an additional advertisement that we're on
     board with that concept.
         This slide projects our resources for fiscal year 2000.  I'd
     like to note that the 17.5 FTE for headquarters is an increase over what
     we had for fiscal year '99.  We were at about 12 FTE, so that's a pretty
     significant increase, and it reflects some of the regulatory framework
     development work that we're doing, and I'll talk about that in a minute.
         That 17.5 FTE is split into two parts.  One is the project
     management and licensing, so-called casework, and the second part is for
     rulemaking and guidance development.  That's the new piece that's taking
     up a lot of our time in the next year or two.
         It also shows the FTE for regional inspection effort, 9 FTE
     there, and $740,000 for technical assistance.
         I'd like to make sure you understand that we're talking
     about activities for power reactors only.  I'm not talking about
     non-power reactors or any of the material sites here.
         Okay.  This slide gets into primarily where we spend most of
     our time.  When a reactor, an operating power reactor transitions into
     the decommissioning phase, their focus becomes to eliminate the
     requirements that apply to operating power reactors that no longer make
     sense for a decommissioning plant.  So we spend a considerable time
     right after the plant shuts down working with the facility to modify
     their license and to address exemptions within Part 50 to try and
     eliminate those requirements that no longer apply to the state of the
         I think Larry already mentioned that under the memorandum of
     understanding with NMSS, NRR retains project management responsibility
     for power reactors until such time as the spent fuel is moved out of the
     spent fuel pool.  So that's where the transition occurs.  In the
     meantime, until that occurs, we work very closely with NMSS and through
     the Decommissioning Management Board to provide oversight with the power
     reactor licensees.
         DR. WYMER:  I think you said too that the fuel when it's
     transferred into dry storage is taken apart.  Is that right?  Did I hear
     that right?
         MR. RICHARDS:  No, I don't think so.  No.  The fuel is -- a
     canister will hold a number of assemblies, but the fuel remains intact
     when it's shipped, or it's placed in dry storage.
         DR. WYMER:  I thought I heard him say it was taken apart and
     therefore it couldn't be put back into the pool.
         MR. RICHARDS:  No, I think Mike Masnik said that what
     happens is that one of the purposes of moving the spent fuel into dry
     storage is it then allows you to dismantle the building that contains
     the spent-fuel pool.  So --
         DR. WYMER:  I was going to say, I didn't think the
     reactor --
         MR. RICHARDS:  Yes.
         DR. WYMER:  Taking the fuel apart.
         MR. RICHARDS:  The advantage there is you end up with a
     small area on the site that has fuel in dry storage --
         DR. WYMER:  Yes.
         MR. RICHARDS:  Relatively simple to maintain, and then you
     can dismantle the rest of the buildings, hopefully terminate your Part
     50 license, and release the site except for that area that the ISFSI's
         DR. WYMER:  I must have misinterpreted what he said.
         MR. RICHARDS:  Okay.  Part of our process is to keep the
     public informed.  There is quite a bit of public interest when a plant
     goes into decommissioning.  The public wants to know what's going to
     happen to that facility, and it's interesting that how often we go to
     these public meetings and find out that people are somewhat comfortable
     with the facility being there, but then they're uncomfortable with the
     fact that now it's going to be dismantled and taken apart, and the
     material moved on highways and what have you through perhaps their
     neighborhood.  So they have a considerable amount of public interest in
     what goes on in decommissioning.
         We participate in those public meetings frequently with NMSS
     in attendance also.  We usually have a public meeting when they submit
     their postshutdown decommissioning activities report -- they have to
     submit that within two years of shutting down -- and then again with the
     license termination plan.  It's also not uncommon that the local
     citizens will have interest in the plant, and there may be requests to
     go to other public meetings.  For instance, at Maine Yankee, they have
     an advisory panel that meets on a monthly basis, and the NRC
     participates routinely in those meetings.
         We are the program office for inspection activities at
     decommissioning power reactors, and we control the inspection program.
     We work closely with the regions to ensure that that program is
         At power reactors when they're operating normally we
     maintain a full-time resident staff.  When the power reactor shuts down
     and enters decommissioning, usually about six months to a year after it
     shuts down, there will no longer be a full-time resident staff at the
     site, and the time spent doing inspections at the site's commensurate
     with the level of activity going on as far as decommissioning goes.
         I'm not going to read the slide to you, so unless there's
     any other questions, we'll move on.
         This slide discusses briefly one of our major activities
     over the next couple of years.  The industry has basically complained
     that when they go into decommissioning, the process is not very
     efficient, that the Part 50 regulations are written for operating
     reactors and don't reflect the decommissioning process.  As a
     consequence, as I mentioned before, they typically come in and need to
     request exemptions from various requirements.  A number of these
     requirements are quite expensive until they can get relief from us.
     Examples include financial protection offsite, security requirements,
     emergency planning, and they would prefer not to have to go through the
     lengthy review process to get exemptions from those requirements.
         What we've undertaken is a two-step process.  This process
     has been described to the Commission in SECY Paper 99-168, it's before
     the Commission, and we're seeking their approval, but right now it's on
     a little bit of a hold.
         What the paper basically says is that these few steps
     include first off a Technical Working Group that is assessing the risk
     associated with decommissioning plants.  And primarily the risk for the
     surrounding population initially after the plant shuts down is centered
     on the spent fuel, and the probability that the spent fuel could have a
     zirconium fire, which would release, of course, the material offsite.
     So the Technical Working Group is trying to put into perspective the
     risk of that occurring.
         Once we've completed that work, we intend to factor the
     results of that review into a new regulatory structure, and what we
     proposed to do is to take Part 50 and other parts within Title X, review
     it for applicability to decommissioning plants, and then separate all
     those requirements out and put them in one location within the
     regulations to the degree we can, such that when a plant enters
     decommissioning, instead of having to go through a lot of amendments and
     exemptions on a case-by-case basis, we hope that plants will be able to
     transition into this new part and a lot of these things will be
     implemented basically automatically as long as they meet the criteria
     laid out in that part, and that'll cut down a lot of the resources both
     for the industry and us.
         And hopefully save us resources, but at the same time
     maintain the same level of safety.  In addition, we're putting together
     some other regulatory guides on various issues associated with
     decommissioning.  We've got a lot going on there.
         Any questions on this side?
         [No response.]
         MR. RICHARDS:  This slide lays out some of our principal
     activities for fiscal year 2000, describe some of the things that we're
     spending the majority of our time on.  We do have various licensing
     reviews; the licensure measurement reviews for Trojan, Main Yankee, and
     we're expecting Connecticut Yankee to come in.
         Defuel tech spec conversions, again, that gets back to
     utilities seeking to save cost by eliminating requirements that don't
     make any sense for decommissioning plants.
         Planning basis is that we have one additional power reactor
     entering the decommissioning phase each year and we are anticipating
     that occurring for many years out.  Of course, that's yet to be seen
     whether that will come about.  But for planning purposes, that's where
     we're at.
         We're dealing with partial site releases at four facilities
     right now.  We're, also, involved with the ISFSI issues, the licensing,
     and then the loading of ISFSIs.  I've already mentioned the public
     meetings and, of course, we work extensively with the regions, as far as
     inspection and oversight goes.
         In summary, in NRR, there's a lot of work going on in the
     decommissioning area.  I'm very fortunate to have a good staff doing a
     lot of very good work and I think we're getting on with the problem.
     That's my last slide and I'd entertain any questions you have.
         DR. GARRICK:  With the experience that you have with Yankee
     Row and Trojan and Ft. St. Vrain and Pathfinder and Saxton, etc., etc.,
     I would guess that you have -- you're beginning to accumulate a
     considerable amount of tricks of the trade, so to speak, or lessons
     learned or areas where technology is needed.  At some point, it might be
     useful for this committee to get a kind of technical lessons learned
     summary of our accumulative knowledge so far in decommissioning.  Is
     that something that maybe downstream we could have you do?
         MR. RICHARDS:  I'm certain that we can.  I'd like to work
     with NSS on that.
         DR. GARRICK:  Right.
         MR. RICHARDS:  There's kind of two angles on this.  I think
     in the initial phases of decommissioning, the tricks of the trade, so to
     speak, are how can we move quickly from an operating reactor status to a
     decommissioning reactor status and that's primarily working through the
     licensing process with us, perhaps has to do with how you treat the
     spent fuel initially.  And the industry has learned some tricks of the
     trade there.
         DR. GARRICK:  Well, one of the big discussion points, of
     course, is the size of components that you can remove --
         MR. RICHARDS:  Yes.
         DR. GARRICK:  -- maybe the most outstanding example being
     the reactor vessel from Trojan and how much does that experience relate
     to other sites that might engage in a similar approach.  That option is
     not available in some cases, but it's still kind of important, it seems
     to me, to appreciate what the implications are of having flexibility on
     how to decommission and decontaminate a site.  So, you know, we don't
     have standard plants, but maybe we can move in the direction of a
     standard decommissioning process, to the extent that resources permit
     and disposal sites allow.  But, I think we would be very interested in,
     on the basis of the experience to date, what really are some of the
     bottlenecks, trouble points, opportunities for streamlining this whole
         MR. RICHARDS:  Good.  We'd be glad to come back and provide
     a more detailed presentation on that, in conjunction with NSS.
         DR. GARRICK:  Good.  Again, I think that would be good.  I
     think the committee would be very interested in that.
         MR. RICHARDS:  Any other questions?
         [No response.]
         MR. RICHARDS:  Thank you, very much, for your time.
         DR. GARRICK:  Where are we, Ray?  Oh, there he is.
         MR. ORLANDO:  Well, again, good morning.  I'm back to talk a
     little bit more about the standard review plan that we're developing to
     support decommissioning.  Just to recap the milestones real quickly,
     we've indicated, in our staff plan that we had put together, that we
     wanted to develop the default tables, identify the technical and policy
     issues by December of last -- of '98, and complete our draft SRP modules
     by June.  The next big step is to look at the comments on the DG-4006,
     which the comments were due the end of last month; but if you have
     comments, Research has indicated that they'll take comments out for a
     couple of more months.  This is based on some comments that were request
     -- or that were made at our last decommissioning workshop, and I'll talk
     about the workshop in just a second.  The next thing we want to do is
     submit the draft SRP up for final review and then publish it in July of
         Now, yesterday, Bobby went over some of the things in the
     standard review plan that the Commission issued regarding the SRP.  And,
     principally, the Commission told us to publish the draft guides, the
     U-4006, we did that; provide them with a time line, which we did; work
     towards developing the more user friendly standard review plan, include
     ACNW in the review, use the probabilistic approach for the teddy, review
     the conservatism, and test the D&D on a complex site.  Now, Bobby went
     over the last three bullets with you in some detail yesterday and I
     think you're aware of what we've done, as far as the first four.
         What I'd like to do is start in your packages and talk a
     little bit about how we are maintaining a dialogue with the public
     through the comment period, how we're ensuring that the standard review
     plan incorporates an iterative risk-based approach, and ensure that the
     standard review plan provides clear guidance on what constitutes ALARA.
     And I'd, also, like to talk to you a little bit about what you can do
     for me, with regard to the standard review plan.
         Okay.  As far as maintaining a dialogue with the public,
     we've had several workshops, starting in December of 1998.  The first
     one focused principally on dose modeling.  The next two or three focused
     on dose modeling for one day and they were held in January, March, and
     June of '99.  Those focused the first day on dose modeling and then the
     second day on different issues, restrictive use, ALARA.  The one in June
     focused on ground water modeling, which was dose modeling entirely.  And
     now, our last workshop that we held back in August, we talked about --
     we have one day that was devoted to license termination plan; then the
     next day, we opened the morning up to the states and they presented
     their perspectives and views on decommissioning; and then in the
     afternoon, we talked a little bit about surveys and what would -- what
     was needed for surveys for decommissioning.
         We had anticipated having one more workshop in October.  But
     based upon the fact that we had pretty much covered all of the different
     issues -- issue areas that we had identified and had discussed a lot
     with the stakeholders, gotten their input, gotten some technical input,
     as Bobby talked about yesterday, getting some resuspension factor data
     from licensings and what not, and given the fact that we had published
     for comment most of the standard review plan modules, we decided to put
     the last workshop off until February of 2000.  And that workshop will
     probably focus exclusively on taking verbal comments, not to the
     exclusion of written comments, but discussing the standard review plan,
     seeing if anybody has any questions about what we've said, maybe some
     things they just want to talk about, opening it up for at least two days
     to just talk about that with both the industry and other stakeholders.
     And I don't mean to indicate that the industry is not a stakeholder, but
     I think we tend to say stakeholder and kind of consider that to be
     perhaps the folks, who would consider themselves to be environmental or
     citizens groups.
         What I had proposed during the last workshop was perhaps to
     have four sessions:  one for the nuclear power industry; one for fuel
     cycle folks, the material folks; one for the states; and one for
     interested non-industry types, or perhaps we can do it as just a more --
     I don't want to call it a free for all, but just more of an integrated
     approach.  I'd like to give everybody an opportunity to make their
     statements and sometimes it's easier if people are up there with folks
     that they'd feel more comfortable, as opposed to being at the table with
     people that they don't feel particularly comfortable with.  So, I'm
     going to work through that, probably propose that and see if I can't get
     anybody to give me their feedback on that.  And I, obviously, take the
     ACNWs input on that issue.
         We have, also, established a Website -- or, actually, we had
     had -- Chris Daley, in the Office of Research, had been -- had
     established a Website through the Lawrence Livermore National
     Laboratory, where we had posted the different SRP modules and agendas
     and things like that.  We have been able to hyperlink that to the NRC
     external Website.  Now, instead of an individual having to go actually
     out to LANL to find the SRP modules and whatnot, they can just go to the
     NRC external Website, go to that page, go through -- go to NRC, go to
     radioactive waste, go to nuclear facilities decommissioning, go down to
     special projects, and it's listed.
         We've, also, posted all of the transcripts of the meetings
     on that Website, and those are at a separate place that they can go out
     and either download it as an HTM file or Word Perfect file.  So, people
     can actually see what was said, which is kind of scary, because
     sometimes I don't realize what I've said.  So, as far as maintaining the
     dialogue, that's what we've done.
         Now, one of the other things that the Commission told us to
     do was use a risk-informed iterative approach to -- in developing the
     standard review plan.  Well, we took a look at that and tried to think
     how can you do something like this.  The standard review plan, and I'm
     sure you've all have seen standard review plans, they tend to address --
     they are typically laid out in a sequence, such that it says here is
     what we want, here is what we accept, here is what we think should be in
     a particular document, here's our acceptance criteria for that.  To
     develop something that was risk-informed and allowed for an iterative
     approach, we could either do -- make one big SRP that said go forth and
     do good, because then you would make all of your decisions based upon
     that criteria; or we could go the other route, which is the way that we
     decided to go, which is to develop very, very, very detailed
     prescriptive SRP modules.
         Once you all start taking a look at them, you'll see that
     there is an awful lot of information being requested by the staff in
     there.  It's important though to recognize one thing, and that's that we
     don't expect every licensee to turn in or to submit all of that
     information.  And here's how the risk-informed part comes in.  What
     we'll do is establish, in a couple of -- probably in the NMSS
     decommissioning handbook -- I'm not sure if you all are familiar with
     that tune, but that's it.  If you want, I can provide you with a copy.
         The NMSS handbook -- what we do is establish the minimum
     information needs in the revised NMSS handbook.  Now, in the NMSS
     handbook, what it talks about -- I'll go ahead and just pass this around
     -- it sets up what we call decommissioning types, and those are based,
     at least in that version of the handbook, on the type of radioactive
     material that a facility would have or the type of activities that it
     undertook, and it lays out in the handbook the steps that the staff and
     the licensee would be expected to undertake to decommission that
     facility.  Now, that's not meant to be a technical review document; it's
     more of a framework kind of document.  Like, the staff will do an
     acceptance review, it doesn't tell you how to do an acceptance review,
     it just says the first thing you'll do is an acceptance review;
     establish a TAC or RITS number; you'll have this meeting or that
     meeting.  And it gets into a little bit what needs to be in
     decommissioning plans and things.
         But what I would anticipate doing is taking and revising the
     decommissioning types, so that they more align themselves with how is
     the licensee going to decommission.  In other words, are they going to
     just use default parameters, you know.  First of all, the first type of
     licensee that we have out there or, in fact, the majority of our
     licensees will never turn in a decommissioning plan.  What they're going
     to send us is a Form 314 and a statement that says, I've sent all of my
     sealed sources back and I'm taking down all my signs, and that's the --
     because most of our licensee are sealed source users or gauge users or
     something like that.
         Other licensees perhaps would -- or another type of licensee
     may turn in some information, but not a whole lot.  That could be
     perhaps a small hospital that has a little nuclear medicine laboratory
     that they were only using technetium-99.  Well, to decommission that
     facility, all you've got to do is send your dose calibrated check
     sources back, send us a little note on a 314, and say I sealed up the
     room for 20 -- for six days.  Well, technetium-99, as you know, 60
     hours, it's pretty much gone, any contamination that would be around.
         So what I would anticipate doing is revising the
     decommissioning types in here to better look -- to more align themselves
     with the type of decommissioning that the licensee is undergoing, as
     opposed to what they did when they were an operating facility.  So, you
     may have a generic type or just one that uses just the screening
     numbers; one where perhaps you have just internal surface contamination
     just in the building, nothing outside; maybe another type would be --
     and perhaps they would use a little bit of dose modeling; maybe one
     where you'd have a little bit of soil contamination and a little bit of
     internal structural contamination and perhaps they'd modify one or two
     of the parameters, so they do a little -- some very limited site
     specific; another type would be where you would -- where the licensee
     would intend to submit all site specific -- I mean, they come in with
     whatever code they were going to use and they would say, you know,
     here's all of the environmental data about our site, here's what we
     think the dose; then, perhaps, the last type might be sites that are
     going to decommission under the restricted use criteria.
         Again, the idea would be to establish these minimum
     information needs, using the SRP to evaluate what the licensee
     submitted.  So, what could happen is, in the handbook, is for type one,
     it might say, you would -- you would submit bullet one, three, five,
     seven, nine, and fifteen of SRP module on environmental information, or
     something like that.
         The next thing that would be part of this, and this would be
     in the SRP, is that we would meet with the licensee before they turn in
     a decommissioning plan.  As you know, licensees, under the licensee
     timeliness rule, are required to inform NRC staff within x amount of
     time, about two years, of permanent cessation of licensed activities.
     They have to submit to us a notification that they permanently ceased
     operation.  They, then, within a year, either have to submit a
     decommissioning plan or submit -- and begin decommissioning or complete
     the decommissioning.
         Once we get that information that a licensee has decided to
     permanently cease operation and is going to be submitting a
     decommissioning plan, what the staff would do would be meet with the
     licensee to start going through and discussing with them what did you do
     at your facility, you know, where do you fall in this general matrix of
     sites and decommissioning types that we have, talk about the SRP, talk
     about what information needs the staff may have, and, in effect, scope
     out what the decommissioning plan is going to need to have.  So, we
     would make a risk-informed approach as to -- or incorporate the
     risk-informed approach in the submission of the decommissioning plan,
     using both the SRP and the handbook.
         And I have to work through a lot of the issues associated
     with modifying the handbook and incorporating all of that.  But when
     you're going through the standard review plan, remember that that was
     written for essentially the worst case scenario that we could come up
     with.  Every piece of information that we could think of that needed to
     be -- conceivably could ever be asked, should be outlined in that.  It
     doesn't necessarily mean we're going to ask every licensee to submit all
     of that information.  So, just keep that in mind when you're reading it.
         And then the iterative approach is obvious with the meeting
     with the licensees and doing the acceptance review and, as Larry was
     talking about earlier, having licensees come in with novel concepts, as
     part of the decommissioning process.  And coupled with that is a
     directive by Dr. Paperiello for a streamlined approach to licensing
     actions and it includes several components, including ensuring that the
     reviews are within our philosophy; develop technical evaluation reports,
     as the basis for developing questions.  The focus there is to only have
     one request for additional information or RAI per each submission.  And
     one way that we can address that, and we'll talk about it in what I call
     the how-to-use section of the standard review plan, we'll discuss this,
     but one of the things we want to make sure we do is, you know, if
     licensees have questions or there are issues that need to be discussed
     during our review of the decommissioning plan, we call the licensee and
     have a meeting.
         The meeting would be opened to observation by members of the
     public.  Typically, at the end of those meetings, we'll let members of
     the public ask questions.  We'll typically do those through the normal
     business day, so they're not necessarily done in a public meeting with a
     capital PM form, but they are opened to observation by members of the
     public.  At the conclusion of the meeting, if any resolutions are made
     or any qualifications are needed, that's summarized in a meeting or
     summary and then that's made available to the public through the normal
     document process.  Again, we want to limit the RAIs to a single set.
     And as I said, we'll incorporate this approach and have incorporated
     this approach into the standard review plan.
         The next thing the Commission asked us to do is give clear
     guidance on ALARA.  We've taken two tacks on that in the SRP.  The first
     one is that if a licensee or responsible party doesn't have to make any
     ALARA demonstrations, if first they have done some kind of housekeeping
     -- it's actually the second bullet up here; sorry about that -- and they
     can show that the facility meets the generic screening levels.  What we
     were concerned about and what the region specifically said was that they
     didn't want to be in a situation where a licensee can walk into a room
     that nobody had gone into for five years, it was covered with dirt and
     dust and trash, do a couple of wipes, wave a meter around, and come back
     and say, hey, it meets your screening levels, I'm done.
         That's not the idea.  The idea is that the licensee would go
     in and do a cleanup, do some kind of good housekeeping type cleanup:
     clean the walls, wipe everything down, get the facility in a reasonable
     shape, then do their surveys to demonstrate that the facility met the
     generic screening levels.  And at that point, we would go ahead -- as
     long as they made the demonstration, then we'd go ahead and say that
     they did not have to make -- or do any separate ALARA demonstrations.
         Another way we're addressing it in the SRP, and it's not
     discussed here, is that Chris McKinney has developed some guidance on
     doing what I think of as rolling ALARA assessments and that's, as they
     are -- as the licensee is going through the process, they sometimes have
     to make a judgment as to whether they need to continue cleaning at a
     certain level or perhaps they can go a little bit -- a little bit
     further on, and that's discussed in the ALARA section of the module --
     excuse me, the ALARA module of the SRP.
         Now, as far as maintaining the SRP, one of the things we
     think -- we're thinking about doing is, clearly, we're going to publish
     it -- we're not thinking about that, we're going to publish the SRP in
     July of 2000.  One of the things that I found when we published the
     decommissioning handbook, and you can see my name is the first -- is one
     of the names on the author list there, is that we had sent the NMSS
     handbook out for review and comment by the regional folks and they had
     done a pretty good critique of it and given us some information on
     things they thought needed to be changed, and we incorporated all of
         But, until you actually go out and use a guide on a site or
     in a real world situation, you don't really know if it's going to work.
     There are some things you can identify that will or won't work, but it's
     been my experience that, you know, you've got to drive it a few miles
     before you find out if it's actually going to run.  So what we intend to
     do is publish the SRP as a final, but then with a planned revision maybe
     two or so years down line.  And we'll track issues and problems that we
     have in implementing either one of the philosophical approaches or some
     of the information needs, you know, or whatever, just keep a list of
     them.  And then at the end of that two or so year period, reconvene the
     whole SRP workshop process, get every -- we got everybody, who was
     there, get them back in the same room, and say, okay, here's the
     problems we've identified, do you have anymore, let's start thinking
     about solutions, let's think about a better way to make this thing -- to
     make this work.
         DR. WYMER:  Doesn't that sort of open up this question of
     finality again?
         MR. ORLANDO:  Well, that's why we would issue it as a final.
         DR. WYMER:  Yeah, but then you're going to go back and
     change it.
         MR. ORLANDO:  We're not -- I don't think we're going to be
     changing too much.  The dose numbers, I don't think, are going to
     change.  I don't know if dose modeling is going to change.  Hopefully,
     that's going to be a pretty strong module in and of itself.  So, I don't
     think where that's going to be a problem.  I'm thinking more along the
     lines of some of the other things.  So, for example, who needs to submit
     certain information; perhaps, it's superfluous, instead of constantly
     requiring more rocks; and just maybe problems in just the implementation
     process, you know, is the information getting out the way it should be,
     you know.  In a couple of years, perhaps, we will have had a few
     restrictive release cases come in.  How did we handle those; how can we
     handle those better, things like that.
         And like the previous couple of speakers, the other -- the
     last thing I'd like to leave you all with is what you can do for me.
     We'd like to get your review and comment on the draft SRP modules, and
     let's change that to November -- no, I'm just kidding.  We're giving
     everybody else until February, so --
         If during the course of your review, and even if you want to
     schedule it now to maybe target completion of your review, if you'd
     like, I'd be more -- we'd be more than happy to come in and discuss
     individual modules, individual information requirements, whatever, in
     the modules.  The only thing I would ask is that you let us know which
     ones you want to talk about, so that -- because there have been several
     authors for some of these things, and it would be nice to be able to
     have them available to answer questions about what they were thinking of
     when they were doing and things like that.  Keep in mind that all of
     this is out for draft.  We're going to be getting comments from the
     public.  In addition, if you would be interested, you know once we get
     all of the comments in and get them compiled, perhaps we'll come back
     and give you a little talk on what was the reaction and what were the
     principle comments made.  So, you know, there are some more
     opportunities for the ACNW to participate in the process and I'll leave
     it up to you all to let me know when you want to do it.
         Having said that, I'll shut up and go answer questions.
         DR. WYMER:  Are there questions?
         DR. GARRICK:  Yeah.  We need to study this a lot more before
     -- especially me, before I get nasty.
         MR. ORLANDO:  I appreciate that.
         DR. GARRICK:  One of the things that kind of bothers me
     about this whole process is that we seem to be talking out of both sides
     of our mouths.  On one side, we're talking about streamlining and
     risk-informed that is supposed to relieve -- provide relief to
     licensees, etc; and on the other side, we're prescribing the hell out of
     everything, which seems to be a total contradiction to the underlying
     philosophy that we're supposed to be implementing, at this point.  And
     as I say, I haven't studied the modules enough to know, but I see
     prescription all over it, and even to the -- even to the level of the
     number of pages that you use to address the specific issues and what
     have you.  And just from a global perspective, I just don't think we're
     getting it.  I don't think we're moving in the direction that it is
     intended by the spirit of what the Commission, at least my
     interpretation, wants.  What am I -- what am I reading wrong here?
         MR. ORLANDO:  Well, I will agree.  If you -- and as I said
     earlier, if you look at the modules and say everybody has to turn this
     in and this is exactly what everybody has to turn in, yeah, it is very
     prescriptive and it's very long and it is -- it does get into, you know,
     length of suggested -- well, I would say that is suggested length of
     pages.  The idea, again, is this is a tool for the staff to use, okay.
     And in some cases, you -- the people, who work in the decommissioning
     group, at least the ones that I work with, what we wanted to do is
     provide them with a tool that addressed all of the issues that they may
     have to face, like how do you know what to turn in, how do you know what
     to ask for, how do you evaluate something that you get from a licensee.
     I don't think anybody -- at least I don't feel that I'm capable of
     sitting down and looking at every technical aspect of every
     decommissioning plant and knowing that the correct answer is.  So, this
     -- the SRP is meant as a guide, to say, okay, if you have this, then
     here's what you've ask for.
         The key is to say, okay, what do you ask for, and that's in
     the how-to-use part.  And there, again, we will try and identify only
     those pieces of information that the staff really needs, in order to
     make the assessments that they're supposed to make to approve the
     decommissioning plant.  Decommissioning plans say what has to be in
     them.  I mean, that's outlined in 30, 40, 70, and 72.  And, you know, so
     a licensee has to turn in certain chunks of information.  What the SRP
     is supposed to do is to help guide the staff through, okay, this is what
     we need.
         Now, as far as being helpful, it seems to me that if you
     come up with standard requests and standard evaluation criteria, then
     the licensees know what they're going to be expected to turn in; the
     staff knows what the licensees are going to be turning in.  And when
     that comes in, it makes the review go quicker and better, because the
     staff can say, okay, it contains this, this, this, and this; here's the
     reg guide perhaps I have to go to; here's this what I have to go to, as
     opposed to a staff member going, you know, how does this work; let me
     think about this; here's yet another issue that I'm not familiar with.
         I guess to sum it up, yeah, if you look at them just and
     say, here's all the SRP modules, here's -- they are -- they do come
     cross as very prescriptive.  The key is in how you implement it.
         MR. CAMPER:  Can I add something to that?
         MR. ORLANDO:  He's my boss, so he can add as much as he
     wants.  Yes.
         MR. CAMPER:  I just want to add a comment.  I think your
     comment is exactly on the mark.  I mean, one of the first questions that
     I asked Nick when I came to the branch and started looking at the SRP
     was the question you just asked, because I looked at the SRP and like
     you, I thought it was terribly prescriptive.
         I had, in a previous job, led an effort to update and
     consolidate something on the order of more than a thousand guidance
     documents in the materials area and we turned them into the NUREG-1556
     series, which will be about 24 volumes.  And the idea is if I want to
     deal with radiography, I go pick up radiography or well log or what have
     you.  And what we did, in that effort, was each team that was put
     together to write the guidance document was challenged to make the
     document as risk-informed and performance oriented as possible, to make
     sure that anything we were asking for or alluding to in guidance base,
     there was a clear regulatory basis for asking for it.  What did we do
     with it once we got it?  Did we really need it.  Were we building in as
     much flexibility as possible?
         Now, in the perfect world, you would start off under a
     risk-informed performance oriented approach, whereby you would make all
     of your regulations, in the first instance, risk-informed and
     performance oriented and from that, guidance would flow.  Well, that's
     not what's happened.  What's happened is the risk-informed performance
     oriented issue is an issue that the Commission has directed the staff to
     do and they have asked us to start doing it now, make it happen now.
     Well, you don't have the luxury of going back and changing all of your
     regulations to start reacting now.  What you do, though, is that at
     every opportunity, at every juncture, you try to bring to bear
     risk-informed performance oriented approach.
         Now, in querying Nick on this particular document, he
     offered what I thought were two interesting insights.  One was that
     unlike the operating world, be it materials or reactors, licensees
     typically go through decommissioning once or they might go through, in
     the materials world, decommissioning portions of their site over time.
     But, generally, it's a one time or not more than a couple of times type
     of thing and, therefore, the need for information seemed to be there.
     You didn't have years and years and years of operating experience to
     draw upon.  So, there was value in providing this lengthy detailed push
     to information as a useful tool.  Well, that's okay.  I can conceptually
     live that.
         But what are we going to do to make it very clear that all
     of this stuff doesn't apply to everybody and that here are the
     guidelines and you have flexibility built into it, in terms of
     customizing your program following this guidance?  Well, Nick is
     currently working on a sort of how to use the SRP, if you will, and that
     particular chapter is going to do as much as we possibly can to bring
     the flexibility to bear, make it clear that you may use this guidance or
     those parts of it that fit for your particular program or need and that
     it is only guidance and you may modify your program or develop
         So, I think that where we need to get at that, and we would
     frankly appreciate a great deal of scrutiny on your part when you look
     at that particular chapter, have we done what we could do to build in
     that flexibility.  But that's sort of, you know, how we're handling it
     and why and, again, I would reiterate that I thought your comment was
     right on the mark.
         DR. GARRICK:  Thank you.
         DR. WYMER:  When will we have that chapter, Nick?
         MR. ORLANDO:  Well, I had hoped to have it done actually by
     this meeting, but I've been kind of pulled away to address some waste
     issues, another hat that I wear.  So, I'm hoping within the next couple
     of weeks.  It will have to go to the decommissioning management board
     first for their review and, you know, then it will be released to you
     all.  Hopefully, we'll have -- just to give you an update on the other
     draft modules, I hope to have the first two or three modules of -- some
     modules of module five, which is the dose modeling that Bobby talked
     about yesterday, they should be being finalized this week, I hope.
         DR. WYMER:  Thank you.
         DR. GARRICK:  Thank you.
         MR. ORLANDO:  Is that it?  Thank you, very much.
         DR. GARRICK:  Who is going to present the continuing
     discussion of the D&D and RESRAD?
         MS. TROTTIER:  This is called management support.
         MR. LARSON:  While Cheryl is handing them out, would the
     committee sometime be interested in hearing how the pilot program went,
     which was supposed to be related to the development of the SRP, and
     would you eventually still want to hear, you know, one of your comments
     in your original letter on the decommissioning of a complex site, using
     D&D, etc., so that you can --
         DR. GARRICK:  Given that we made an issue of it in our
     letter, I think, yes, we would like to hear about that.
         DR. LARKINS:  Of the steps of yesterday, they hadn't done
     it.  They did two simple sites and we're working on doing a complex site
         MR. LARSON:  Yeah, they did, but there are several parts.
     One is a pilot program, which is supposed to be, you know, industry
     volunteering to implement this SRP and then the other is the complex
     site, which someday the committee indicated they'd like to hear.
         DR. LARKINS:  Some day.
         DR. GARRICK:  Okay.
         MR. OTT:  Okay.  I think this is the first time I've come to
     you since we've reorganized.  I think the last time I was here I was
     wearing too different hats.  Since then, we are now a single branch,
     where Cheryl is the branch chief, I'm the assistant branch chief, and we
     have merged the two programs.  Things like RESRAD and D&D are now
     actually considered to be part of the overall development that we were
     doing with SEDSS.
         I'm going to start off with a brief overview of what we're
     doing in general for decommissioning.  This just -- I mean, you've had
     NRR and NMSS go through a rather lengthy discussion of everything
     they're doing.  We're focusing primarily on RESRAD, D&D, and SEDSS here
     today, but I just wanted to list for you all those things that we are
     doing that relate to those 10 FTEs and $2.3 million that were listed
     earlier in the NMSS slides.
         We are providing a significant effort with regard to the
     technical basis for clearance rule.  We've got two different efforts
     going on:  one with Bob Meck, which is a very large contract with SAIC
     that was just let on the technical basis for clearance, in general; and
     we've got a smaller effort that Tom Nicholson has placed through the
     U.S. Department of Agriculture, the Agricultural Library over in
     Beltsville.  He's looking at soil clearance and trying to find out, you
     know, what the people use soil for.  That particular effort is ongoing
     right now.
         We're doing significant amount of process modeling, which
     usually primarily comes from the radionuclide transport program.  We're
     looking at absorption modeling, both USGS and Sandia and cooperatively
     through the NEA absorption project.  It's an international effort.
         We're looking at conceptual model uncertainty at the
     University of Arizona -- that's another one of Tom Nicholson's project;
     malignant barrier performance at NIST; and we, actually, have had some
     contacts from people that are talking about things like entombment, with
     regard to the program that was developed at NIST for long-term
     performance of barriers -- concrete barriers.  So, we're actually
     finding that something that was started out to deal with covers and
     barriers for low-level waste disposal is actually having applications
     beyond that.
         We've got the work that's being done on slag degradation at
     Johns Hopkins University at PNNL, and then radionuclide solubilities at
         DR. WYMER:  Right on the face of it, that looks like there's
     a lot in common with the modeling that goes on with -- in connection
     with the Yucca Mountain Repository.  To what extent are those integrated
     or do they --
         MR. OTT:  There's probably a lot that's of value to the
     Yucca Mountain program.  Our limitation is that we don't do anything
     that is specifically only applicable to the Yucca Mountain.  So, if
     anything gets in the area of things like elevated temperatures, we're
     not working on it.  If it's particularly related to things like seismic
     effects or vulcanism, those programs were terminated and transferred to
         DR. WYMER:  But, you do integrate with respect to the type
     of modeling that you do and the --
         MR. OTT:  Yeah.
         DR. WYMER:  -- type of codes that you use and so on?
         MR. OTT:  Right.  And as a matter of fact, things like the
     NEA absorption project, we have contacts down at the Center for Nuclear
     Regulatory Analysis.  We provide them with copies of documents and they
     review them and things like that.  So, there is a connection between
     that.  We try to keep in touch as much as we can of what's going on with
     the program.
         In terms of integrated performance model -- assessment model
     development, we're doing the work that we're going to talk about for the
     next few minutes on RESRAD, D&D, SEDSS, and there's actually a small
     effort going on with PNNL, which is looking at parameter distributions
     primarily for the hydro models.
         And the last issue there is the one that you dealt with for
     a few minutes this morning on entombment.  The entombment paper went up
     actually July 19th.  July 19th is when the Commission paper went up.  I
     don't have the number on it, but you can probably track it from the
     date, if you want to get a look at it.
         There is the workshop scheduled for December 15th -- 14th
     and 15th.  Recommendations are officially scheduled to come out in
     March.  We'll probably -- we can easily come in in January or February
     and talk to you, as Cheryl suggested.  One observation I might make
     about entombment is that there are a range of options for entombment, as
     there are ranges of options for almost anything you do.  And part of
     what's being discussed is -- some of the things that are being more
     seriously discussed here, in terms of options, are to remove everything
     above Class C, all waste that's above Class C and activity will be taken
     offsite and disposed of elsewhere.  So, it's one of the options that is
     under consideration.
         DR. GARRICK:  Bill, just to give us a sense of the size of
     this effort, what is the rate of expenditure for what you just put on
     the board, approximately?
         MR. OTT:  It's about $2.3 million a year.
         DR. GARRICK:  Yeah; okay.
         MR. OTT:  That doesn't necessarily -- we took what was
     basically the radionuclide transport budget, some of the activities have
     been moved into it; some, like the clearance activities, is outside of
     that particular amount of money, so there's another $600,000 that's in
     one of the clearance contracts.  Actually, the soil -- the soil money,
     I'm not certain which bin that came out of.  We're still working under a
     budget structure that has three bins in it:  reactors and materials and
         I'm going to talk a little bit, before I actually get into
     the three codes that we're working on, about what the objective of this
     program is looking at these three different codes.  We've got a range of
     sites out there.  We've got a range of contamination program --
     problems.  And you don't necessarily want to develop one code that
     addresses all problems, because, in many cases, you'd be developing a
     tool, which is way too complex and way too difficult to run to handle
     many of the problems.  So, we're looking at a set of tools for dose
     modeling that's well matched to the range of complexity of sites and the
     range of source term.  So, we want something that we can handle.  It's
     really much simple to handle simple sites, something with model
     complexity to handle the more difficult sites, and something that is
     really sophisticated to handle really -- considered to be the really
     problem sites.
         Now, we, essentially, are working on D&D and SEDSS.  RESRAD
     is a program that was developed by -- well, let me go do this in order.
     D&D:  D&D is developed as a very simple tool for screening.  The concept
     of screening is to be able to get rid of sites that aren't really a
     problem, without spending a lot of effort of them.  If you get to the
     point where -- that the screening model is predicting that you are near
     the margin, you want to step back and take a look at it.  This
     particular version will take -- well, I'm not going to talk about each
     one of them individually.  I'm not going to go into detail right now.
         The original objective was to provide a model that doesn't
     have any need for a large amount of in situ data.  I've got a simple
     contamination.  I think it's so small and I think that it's so well
     localized, that I don't really have a problem.  You use D&D.  It
     confirms your guess and you're done with your problem.  That's what D&D
     was designed for, very, very simple situations.  It turns out that
     they're putting a little bit of site specific ability into it.  We can
     make it applicable to a wider range of sites, a little bit more
     sensitive.  And if you look at what's being done -- we'll talk about
     that later.
         Okay, RESRAD:  we're developing at Argon a probabilistic
     version of RESRAD.  RESRAD, as it currently exists, is a deterministic
     model.  And it was decided that it was needed to have something that was
     more in keeping with the ability to look at distributions of parameters
     and key assumptions, the fault values.  We're looking at giving RESRAD a
     pedigree, which goes in and looks at all the problems that people have
     looked at in D&D, and say, this is a problem with D&D.  The RESRAD
     people go ahead and ask those questions.
         Sandia Environmental Decision Support System, we've talked
     to you about that a number of times in the past.  It's primarily being
     designed to look at more complex sites, being able to bring in more
     complex models, more context search term models.  It's one -- it's a
     general tool that is not designed to just be dependent on one given
     module for any given particular calculation.  If a 1D groundwater model
     doesn't work, SEDSS will be able to bring in a 2D groundwater model.  If
     a 2D groundwater model doesn't work, it will be able to bring in a 3D
     model.  You may know from the start that you want to use a 3D model.
     You go directly to a 3D model.  It will depend on a lot of things and
     exactly what your problem is.
         Let's look at where we are in D&D.  Version I is out.  It's
     been available since I guess last -- last July.  It's testing potential
     users.  There's -- we're getting comments over the Web.  The comments
     are being considered by Sandia and summarized.  Chris is here.  If
     anybody wants to know what -- get an idea of what the character of those
     comments are, she can address that.  I get the impression that a lot of
     them are, you know, which button do I press and how do I do this.  So, a
     lot of the comments aren't coming back, you know, this is a real problem
     with D&D.  It's more a question of how do we use it.
         NUREG/CR 5512 Volumes I and II are available.  Three and
     four are in the process of publication.  Basically, what that means is
     we sent them down to publications and they just sent them back to us for
     some formatting changes.  And we've got to get that fixed and send them
     down to them again.  Volume IV is the comparison between RESRAD and D&D.
     I read that in the draft form and it's a very interesting document.  You
     asked the question yesterday, is RESRAD always conservative, and the
     answer is no.
         The detailed comparison in NUREG 5512 Volume IV tells you
     exactly what kinds of assumptions are made in RESRAD and in D&D on
     comparable parameters and comparable considerations.  And it tells you
     those areas where RESRAD may have assumptions in it that really need to
     be fixed, as well.  So, in the final analysis, you can look at RESRAD
     and find situations under which it doesn't really do a very good job
     either.  That's not something that's unexpected.  That's typical in
     models like this.
         We're going to have a training course for Volume I of
     Version I of D&D in October and November.  Ralph Cady is going to be the
     one that actually presents the course.  It's going to be presented here
     at headquarters and out in the regions.  He's been working on it for the
     last three or four weeks, in terms of putting it together.
         In the future, we're going to have Version II, which is
     going to be fully probabilistic.  We had a -- we actually do have a
     version of D&D that's probabilistic, but it's not user friendly.  So,
     the Version II that's going to come out here is going to be a user
     friendly probabilistic version for anybody's use.  The first version of
     that will be available in October.  We expect to be able to release it
     to the public in March of next year.  Documentation of the testing
     period and any adjustments that were made during that period will be
     available about two months later.  We're going to have training in May
     and June of 2000.  This training will be developed and run as part of
     the contract with Sandia.
         DR. LARKINS:  If you are trained on Version I, do you need
     to be trained on Version II?
         MR. OTT:  Yes.  Essentially, the training on Version I won't
     tell you how to use the probabilistic drivers.
         RESRAD:  if you look at the numbers on RESRAD, you've got
     Version VI of RESRAD and Version III of RESRADBUILD.  These programs
     have been around for a long time.  Bobby used the words yesterday that
     RESRAD has been validated and I forget what the other word was.  It
     doesn't matter.  To say it's been validated is probably a little strong.
     It has been compared to other codes and -- benchmarking was the other
     word -- benchmarking exercises.  In talking to the staff today, one of
     them mentioned that, in one of these exercises, the conclusions came out
     that RESRAD did a very good job of reproducing the data.  It then made
     the observation that they were so close because of compensating errors.
     The staff member wanted to say fortuitously compensating errors.
         This is, also, something that's not unusual.  When you've
     got a complex code and you've got a mistake in one place, a mistake in
     the other, they can quite often cancel out.  I think that once Tin's
     contract -- Tin Mo is the contract manager for the Argon contract that
     we've placed on RESRAD, we will probably have a much stronger pedigree
     on what is in RESRAD, in terms of the basic assumptions and where there
     are conservatisms and what the conservatism there is than currently
     exists in the RESRAD documentation.  This will be an NRC version of
     RESRAD.  There will be not a DOE version.  DOE may come out with RESRAD
     Version VII and Version VIII and Version IX, but we're developing a
     version, with a lot of degree of concern over the assumptions and the
     parameters in there, which is based on Version VI and 3.0 of RESRAD and
         The contractors placed this summer -- the first deliverable
     was basically a listing of parameters, what is in RESRAD, what
     parameters are there, what do we have to pay attention to.  The second
     deliverable, which is underway now, will come in October, is which one
     of these parameters are really important, which ones can variation cause
     a significant effect on the dose that comes out of it.  That's
     essentially a report on physical metabolic and behavioral parameters.
         The language in these comes from the contract.  When you say
     "complete probabilistic interface modules," that essentially means
     that's the NRC version of RESRAD.  That will be finished in June of 2000
     and available for testing.  We'll complete testing of the probabilistic
     version by September of next year and then will have final documentation
     done November.  So, basically, this will -- we'll have the probabilistic
     version of RESRAD about nine months after we have the probabilistic
     version of D&D.
         SEDSS:  SEDDS is an outgrowth of what we did Sandia over a
     number of years, first in high-level waste and then in low-level waste,
     as our primary contractor and performance assessment.  And then, it was
     determined that we needed this fairly general tool, to be able to handle
     the complex sites in the decommissioning program.  The PC version, with
     what we call the "old architecture," was available in May of '98.  And I
     thought "old architecture," because we're very conscious of the fact
     that the ability to interface modules and move programs in and out of
     other programs, the technology to do that is changing.  And we want the
     final SEDSS version to be as flexible, as possible, with regard to
     bringing in improvements, as time passes.  So, we're trying to have an
     architecture, which is up to date as possible.  Now, we recently made a
     significant change and are working on a new architecture for the program
     right now.  So, we've taken a step back and have redesigned the program.
         We expect to have the first version under the new
     architecture with existing capabilities, plus the 5512 decision
     methodology, in March of 2000.  We expect to have it with the existing
     version, with existing capabilities, in January.  We expect to have the
     incorporation of multidimensional groundwater model in January of 2001.
         The last slide is nothing more than -- just a listing of
     everything I've just gone through on one page, so you can look and
     compare and see what the various dates are.  All of these dates are
     listed in the slides that I've just shown you previously.
         DR. LARKINS:  Are there user's groups for each of these
     codes to exercise these codes, as they're developed, or get some feel
     for how --
         MR. OTT:  Well, D&D Version I is out and being tested in the
     general public right now.  It's, also, being tested by staff and being
     applied by Sandia.  You heard yesterday that Sandia has applied it to a
     couple of simple sites, not the complex ones that you're talking about.
     For SEDSS, I don't think it's far enough long for that to be the case.
     RESRAD, I don't know whether DOE has a group that looks at RESRAD or
     not.  We do not, at this point, have such a user's group for RESRAD.
     Are you planning anything like that, Tin?
         MR. MO:  You're asking me if DOE has --
         MR. OTT:  No, no, no.  I was asking if we were planning to
     have -- if it was in our plans to have some kind of a user's group for
         MR. MO:  User's group, meaning what?
         DR. LARKINS:  Are there people out there, who are going to
     take these codes and use them and exercise them, to get some feel as to
     how good they are.
         MR. MO:  Right now, I think, in a few days, they will mail
     -- mail to us the beta version of 5.99, which will become 6.0 -- RESRAD
     6.0, once it's tested.  And we will get an NMSS staff and research
     staff, they'll be using it on test cases that Mike has developed and
     other cases.  And so, I would say, yes, we have a user's group here to
     test them, way before June 6, 2000.
         MR. OTT:  I think, in the general sense, you're talking
     about, that's not what you were looking for.  You were looking for a
     more general users.
         DR. LARKINS:  Yes.
         MR. OTT:  And I don't think that's currently in our plans.
         MR. LEVENSON:  In Version I, you said staff is using it,
     Sandia is using it, and the public -- some public groups are using it.
     Who are the public groups involved?
         MR. OTT:  I would have to ask Chris to give you any details,
     if she knows or not.  Chris Daily, she's the project manager for the D&D
         MS. DAILY:  It looks like a pretty broad range of people:
     there are some that are university professors that are using it; some of
     them are using it in their classes; there's industry people -- just a
     range of people that are taking a look at it; some of the states are
     interested in it, also.
         MR. OTT:  I think EPRI has actually done --
         MS. DAILY:  Yeah, and EPRI has looking at it and that's part
     of their comparison of D&D and RESRAD.
         MR. OTT:  Right.
         DR. GARRICK:  One of the problems I have is that it's almost
     an oxymoron to me to have D&D have a probabilistic version, given that
     the whole concept of D&D was that of a bounding screening analysis.  Why
     on earth would you want to spend the time to try to create a
     probabilistic version of a bounding model, when you're doing it on the
     more site and facility specific case?
         MR. OTT:  Well, RESRAD is a late development.  In terms of
     doing something with RESRAD --
         DR. GARRICK:  Yeah.
         MR. OTT:  -- that started this summer.  The D&D code was
     developed as part of the implementation of the licensee termination
     rule.  In terms of putting a probabilistic driver on it, it turns out
     that what you have there can be made more site specific.  When you use
     D&D, there is an assumption made that you can use it anywhere in the
     country.  And, basically, that means that you have to be more or less
     conservative, since you're using it in a screening mode with regard to
     everything, including things like groundwater parameters; whereas, if
     you actually know a little bit and can tell actually what the soil type
     is, you can narrow down the uncertainty in a lot of parameters by a
     significant amount and perhaps lower the dose calculation by a couple of
     orders of magnitude.  So, you can actually make D&D into a much more
     useful tool by giving it distributions that require minimal site
     specific information.
         D&D Version I doesn't require any site specific information.
     You give it a little bit of site specific information and you can reduce
     the level of conservatism in the code significantly with regard to site
     specific parameters.  So, it becomes -- Chris would like to add
     something to that, too.
         MS. DAILY:  It sounds like an oxymoron, but we actually had
     to go through the process of developing distributions for the parameters
     in developing our basic probabilistic version of D&D, in order to
     develop the fault parameters.
         MR. OTT:  Yeah.
         DR. WYMER:  I'd like to make an observation.  I'm not sure
     that there's anything that can be done about it, but it seems to me that
     probably the poor person out there trying to decide which of these
     things to use -- with respect to my site, I've got a couple of D&D
     versions, I've got a couple of RESRAD, I've got a SEDSS, and they keep
     changing.  How in the world do I know what to do?
         MR. OTT:  Well, you're not going to find D&D changing past
     this particular version, I don't believe.  And I think that Version --
     Version II is going to be set up, so it can do Version I calculations,
     in the user friendly fashion.  D&D is going to be set up as -- Version
     II is the only one that is --
         DR. WYMER:  That still doesn't solve the problem of setting
     put a plethora of codes out there.
              MS. JENKINS:  No, well, you can look -- you can find
     more than D&D, RESRAD, and SEDSS, as well.  I mean, you can find MEPAS
     and you can find other codes by other vendors.
         DR. WYMER:  But, these are the ones that NRC is going to --
     people are using.
         MR. OTT:  These are ones that NRC will use.  NRC -- NRC
     staff will find it fairly easy to make their decisions on which code to
     apply in any given situation.
         DR. WYMER:  Well, I know that the NRC staff will, but -- I
     don't think there's an easy answer, but I just --
         MR. OTT:  There isn't an easy answer.  And I was trying to
     come to grips with this question a little bit.
         DR. WYMER:  I was debating whether to use this or not.
         MR. OTT:  You have a problem.
         DR. WYMER:  Okay.
         MR. OTT:  You have a range of sites out there with varying
     complexity, varying site complexity and varying source term complexity.
     The first question you ask is what's the distribution of sites.  I don't
     know and I'm not certain that NMSS knows with any degree of certainty
     how many sites they have in any part of this distribution.  Let's make a
     guess.  I don't know if these dots are going to show up or not.  Do
     they?  Oh, they do, okay.  And from everything we've heard -- excuse me
     -- from everything we've heard, you would expect that the vast majority
     of sites are going to be simple, from the point of view of both
     contamination and site, a very small area contaminated.  So, you're
     going to have all of these sites down here.  Well, gradually, you get a
     few sites in more complex areas.
         If you want a tool that's going to handle this particular
     site, you want to apply it to this particular site, I don't think so.
     This site out here is going to require a great deal of information and
     knowledge about natural systems, about hydrology, about geology, about
     how to model those natural systems.  The one up here is going to require
     a great deal of information about decay chains and have a whole host of
     radionuclides.  You're going to need a code that's capable of handling
     multiple radionuclides and decay chains and, also, propagating them
     through the environment.  Now, I guarantee none of this information,
     because this is purely a thought exercise right now.  But, I'm trying to
     get an idea of why we have -- or how these codes relate to each other.
         So, then, I put the third slide together.  SEDSS is not
     going to handle every site that's out there, and I'll make that
     observation first.  You wouldn't to apply SEDSS to Yucca Mountain.  You
     probably wouldn't apply SEDSS to a low-level waste to a site.  You get
     to a site where you know you've got a huge inventory and you've got a
     very complex geologic or hydrologic system.  It's almost inevitable that
     you're going to develop a site specific model, okay.  Yucca Mountain is
     doing it.  We're doing it for Yucca Mountain.  You'll find it happening
     in all the low-level waste sites.  You'll find it happening at every
     high-level waste site around the world.  They're not going to develop a
     generic model.  They're going out and doing -- developing a model, which
     is very specific to both the site and the design.
         If we back off and we come in, SEDSS is going to be able to
     handle a lot of sites, which are fairly complex, because we're going to
     be able to have an ability to have multiple dimension on groundwater
     problems and fairly complex geometries.
         RESRAD is not a very complicated code, itself.  Its
     groundwater model is, also, very, very simple.  It has more flexibility
     than D&D in certain areas, but D&D Version II is going to have a fair
     amount more flexibility than Version I.  Some of those problems that
     were mentioned yesterday, such as the area problem, that's going to be
     addressable in Version II.  The question of whether -- of what
     percentage of your diet comes from the site is addressable in Version I.
     And if you look at all the documentation on D&D Version I, there are a
     lot of things that you can do with it, be it not easily, that address
     some of those problems.
         As we finish D&D and RESRAD, I expect that these two lines
     are come even closer together.  But, there will probably still be some
     flexibility in RESRAD that doesn't appear in D&D.  The question is, how
     many sites in here benefit from the changes that were made in RESRAD.
     And if you're in this situation right here, D&D is a much easier code to
     use than RESRAD and much more user friendly to the public.  For the site
     that doesn't require any in situ information and allow somebody, who is
     fairly unsophisticated, to go in, put in his source term, and come out
     with a calculation that allows him to get through the decommissioning
     process, it's a valuable tool, even if it only helps 10 or 15 of those
     people.  And it should apply to hundreds of sites.
         With RESRAD's history and the comfort that a lot of
     contractors have out there, having an NRC version, which is
     probabilistic, that they'd come in and look at is probably a boon --
     probably a benefit to them.
         I don't know how to measure this margin and I don't know how
     to really judge it.  This is a thought exercise.  I'm trying to put down
     on paper the question that you've been raising about, you know, why D&D,
     why RESRAD, what do they apply to.  If I do nothing more than give you a
     way of conceptualizing and looking at the problem, I knew that I've been
     -- had some success.
         DR. LARKINS:  This sort of gets back to my question about
     users, though.  It looks like you may have a significant number of users
     for D&D and RESRAD and only a few people will actually be running SEDSS.
         MR. OTT:  Right.  I mean, the point should be made that
     RESRAD will probably -- can handle any site that D&D can handle, and
     SEDSS can handle anyone that RESRAD and D&D can handle, especially once
     we get the 5512 methodology into SEDSS.  It's a case of each one of
     these requires a different level of sophistication in the user.  RESRAD
     is not as user friendly -- is not going to be as user friendly as D&D
     is.  SEDSS is certainly not going to be as user friendly as the other
     two are.  It's designed for you to be able to handle a complex site.
     It's going to be -- it's going to need somebody that conceptualize -- to
     conceptualize that concept site and know how to put it into SEDSS.  I
     mean, you don't just hand SEDDS over to the guy that owns the source and
     tell him to run it.  It's not what you do.
         DR. LARKINS:  SEDSS would mainly be run by the NRC staff and
     the contractors and others --
         MR. OTT:  A reasonably sophisticated contractor.  In fact,
     the owner would probably contract for somebody else to run it.  It's not
     going to be something that you just -- you need to have a hydrologist to
     run this.  You don't model these sites without having a hydrologist
     around or somebody -- a soil scientist that understands soil and soil
         MS. SANTIAGO:  I'd like to interject for just a second.
     When you asked -- my name is Pat Santiago from NMSS.  You asked how does
     someone know how to use these things.  NMSS staff and I think Research
     and other offices have participated in public workshops with licensees.
     We have guidance documents.  They come in all the time and meet with
     staff on what they should do, what parameters they may choose, and that
     will continue as these different codes develop.
         DR. WYMER:  I'm sure that the big organizations will
     certainly do that.  It's the little guy that's trying to get to the site
     and doesn't even know the stuff is out there.
         MS. SANTIAGO:  Well, then, that's why the staff interaction
     is key and the regional offices assist in that.  We've had meetings with
     various licensees to help them go along, just like we are helping
     different staff on it, too, at this point.
         MR. OTT:  That's a good observation.  Lynn, you had a
         MS. DEERING:  Yeah, quick question.  My understanding was is
     that D&D was going to be implemented in SEDSS, is that correct?
         MR. OTT:  Yes.  Well, the 5512 methodology is going to be
     implemented in SEDSS.
         MS. DEERING:  And what does that mean exactly?
         MR. OTT:  It means it will be capable of doing the
     calculations.  We're not taking modules out of D&D to put them into
     SEDSS, but SEDSS will be capable of doing the same calculation.
         MS. DEERING:  So, if you wanted to use just the D&D -- a
     simplistic D&D type calculation, you could have SEDSS as your tool and
     just choose to use that version of it?
         MR. OTT:  Right.  The problem is that, if you want to use
     SEDSS, you're going to have to be more a sophisticated user.  It's not
     going to be that easy to just choose the -- you're not going to go out
     and buy this very, very complicated code, to be able to use D&D.  If you
     already have it on your shelf and you're a sophisticated user, you might
     elect to use the D&D option.
         MS. DEERING:  Well, what complicated codes are in SEDSS?
         MR. OTT:  Well, I would have to have -- well, okay.  Ralph
     would be the one to answer that question.  As an example of what is not
     necessarily in there yet, but will be in there, the BLT code from
     Brookhaven will be in there, essentially the breach, leach and transport
     code that was developed for low level waste, a fairly sophisticated code
     for dealing with very heterogeneous waste form, or set of waste that
     might be present at a site.  We will have one, two and three dimensional
     hydrologic codes in there, or models in there.
         If the demonstration work at Naturita on sorption models is
     successful, which we hope it will be, we would eventually envision a
     mechanistic sorption model in SEDSS that would allow you to do those
     calculations without relying on a constant KD.  So those are the kinds
     of sophistications that we would envision being in SEDSS.
         MS. DEERING:  Is EPA still funding it?
         MR. OTT:  SEDSS?
         MS. DEERING:  Yes.
         MR. OTT:  They have got a test period being funded right
     now, they are looking at applying it to some of their sites and making a
     decision on whether they want to continue or not.
         MS. DEERING:  Because a lot of those codes, they probably --
     they are NRC type codes.
         MR. OTT:  There has been a problem because of our reliance
     on EPA funding in the past, since sometimes it has not come through as
     scheduled.  And we made a deliberate determination during our last
     contract negotiations that we would not be dependent on EPA funding any
     more.  So we are making certain that whatever we do does not require EPA
     support, or not dependent on EPA work being completed.
         EPA, as a matter of fact, has requested that their version
     of the code not have an NRC logo on it, because they are worried about
     being tainted.
         MS. DEERING:  I can understand that.
         MR. OTT:  So there are political problems that we have run
     into trying to work with EPA on the development of SEDSS, and it has
     caused us to rethink what we are doing.  And some of the decisions that
     we have made with regard to architecture have been made unilaterally
     because of our long-term need for the code, as opposed to what we and
     EPA need for the code together.
         DR. WYMER:  Okay.  Thank you very much.
         DR. GARRICK:  There is a lot more we could talk here, but we
     will have to do it later because the committee is very interested in
         MR. OTT:  I need to remind you that we are supposed to come
     before you in November or December timeframe, I don't remember which.
         DR. CAMPBELL:  November.
         MR. OTT:  To talk about the general program.
         DR. GARRICK:  Good.  Okay.
         MR. OTT:  I certainly think any of you or your staff that
     would be interested in attending the training programs for DandD would
     be more than welcome to participate, either for Version 1 or for Version
     2, come next June.
         DR. GARRICK:  Thank you.
         MR. OTT:  Anything else I forgot?  Okay.
         DR. GARRICK:  Well, according to the agenda, it is now 11:00
     and unless there is comments from the committee, I guess this is break
         [Whereupon, at 11:03 p.m., the meeting was concluded.]

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