114th ACNW Meeting U.S. Nuclear Regulatory Commission, November 17, 1999
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
ADVISORY COMMITTEE ON NUCLEAR WASTE
***
MEETING: 114TH ADVISORY COMMITTEE ON
NUCLEAR WASTE (ACNW)
U.S. Nuclear Regulatory Commission
Two White Flint North
Room T-2B3
11545 Rockville Pike
Rockville, Maryland
Wednesday, November 17, 1999
The Committee met, pursuant to notice, at 1:03 p.m.
MEMBERS PRESENT:
JOHN GARRICK, Chairman, ACNW
GEORGE W. HORNBERGER, Vice Chairman, ACNW
RAYMOND G. WYMER, Member, ACNW
. P R O C E E D I N G S
[1:03 p.m.]
DR. GARRICK: Good afternoon. The meeting will now come to
order. This is the first day of the 114th 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, we have Milt Levenson serving as an ACNW
Consultant.
During today's meeting we will discuss committee activities
and future agenda items, discuss the research plan for environmental
transport of radionuclides in the geosphere, and discuss the
rubblization approach.
Richard Major is the Designated Federal Official for today's
initial session. This meeting is being conducted in accordance with the
provisions of the Federal Advisory Committee Act and we have received no
written statements from members of the public regarding today's session.
Should anyone wish to address the committee, please make your wishes
known to one of the committee's staff.
As usual, we request that speakers use one of the
microphones, identify themselves.
Before proceeding, there are a couple of items we would like
to cover. Or course, we are all aware that on October 29th, Dr. Richard
Meserve was sworn in as Chairman of the U.S. Nuclear Regulatory
Commission. We have some Staff changes effective November 1st. Howard
Larson has been assigned to the position Associate Director of Technical
Support of the ACRS/ACNW. Howard brings to the position a great deal of
management experience in industry and government and of course the
nuclear Navy.
Andy Campbell will begin a six-month rotational assignment
in the Office of Nuclear Regulatory Research beginning on Monday,
November 22nd. Andy will join the Radiation Protection Environmental
Risk & Waste Management Branch and we expect to welcome John Randall
from Research, who will trade positions with Andy for the time being.
The Nuclear Regulatory Commission has launched a new study
on spent nuclear fuel cask responses to severe transportation accidents.
As you know, many years ago this was something that was studied
extensively.
There is a meeting going on that is of interest to the waste
community. It is going to take place the first part of December. Some
75 experts representing a broad spectrum of opinion will meet early
during the next month to try to develop some consensus on issues around
the health effects of low level ionizing radiation including how to
regulate in the face of scientific uncertainty. If they accomplish
those goals, they will have achieved a miracle.
There will be a follow-on meeting, a conference call,
"Bridging Radiation Policy and Science," and it will be held at the
Airlie Center in Warrenton, Virginia and among the organizers of this
meeting is Gail DePlanque, former NRC Commissioner, and Manny Munson,
President of the International Nuclear Law Association.
Unless there's comments or some other announcements that the
members or staff would like to make, I think we will proceed with our
agenda and we are going to hear about the research plan for
environmental transport, and it is nice to see Margaret Federline. We
haven't seen you for awhile.
MS. FEDERLINE: Yes, I really appreciate the opportunity to
be with you. I have missed you.
DR. GARRICK: Well -- you have the floor.
MS. FEDERLINE: Thank you very much, Dr. Garrick. I
appreciate it.
We really appreciate the effort that the committee is
putting into reviewing our research program in the waste area. We
appreciated the comments that you made on NUREG 1635 and let me just
throw those up on the slide for the benefit of the audience.
Ashok and I have looked at the processes in the Office of
Research and we couldn't agree with you more that with limited funds we
have to improve the focus of the activities within the Office and to
make sure that they focus on the critical issues and that definitive
goals are set.
In order to do that, we initiated over the past year a
self-assessment. I want to talk with you -- Ashok had an opportunity to
talk with the ACRS and I wanted to take this opportunity to talk with
you folks and just give you some background in terms of what we are
trying to do in the Office, which also directly affects the
Environmental Transport Program, so the objective of my briefing today
is to describe the process that we are using for planning and
prioritizing research activities. I will discuss it overall for the
Office and Cheryl Trottier will get into more detail for the
Environmental Transport Program.
I want to discuss the relationship of our waste activities
to NRC's performance goals and we are also really interested in your
ideas about how we should prioritize our research. Let me just touch on
a few points of background.
I know the committee is very familiar with direction-setting
Issue 22. This was the issue that the Commission provided guidance to
the Staff on the future role of Research in achieving our mission, and
as you will recall, in that document the Commission told us to ensure
that we continue elements of confirmatory and anticipatory research,
that we are supposed to address both current and emerging issues, and
that we are to focus on the issues of highest safety significance and
that Staff should explore cooperative research with DOE and the industry
and that we should also involve our stakeholders early in the processes
and also he urged us to participate with the international community and
make sure that we are learning the lessons there and a number of these
principles are very important in the waste program and I will touch on
those in just a minute.
Now recently the Commission asked us to develop a vision for
the Office of Research and I want to discuss that with you for a minute
and get your feedback as to how it fits in the waste arena.
We also realize that Research needs to be responsive to the
changing environment. A lot is going on with the industry right now
with deregulation, and of course waste is one of the preeminent issues.
If we don't, if it is not possible to solve the waste issue in a safe
and effective manner, it is going to be difficult to proceed with
license renewal and other issues, so as we see industry looking to use
more efficiencies in the arena that we are dealing with, several issues
come to the forefront -- the storage and transportation of spent fuel as
well as the successful disposal -- so we are focusing broadly in the
Office on all of those issues.
Now as part of our self-assessment effort we have defined a
vision and objectives to guide the work in the Office. I have listed
here the NRC vision. I won't go through it in detail, and I have also
listed the Research vision, to give you an idea of how the two fit
together. The Research vision flows in fact from the agency vision.
The next slide discusses the key elements of the vision that
we see. There are three really critical aspects, as we see it, to our
vision. The first is technical independence from the licensees. We
think it is very important that there is a credible technical basis for
NRC regulatory decisions. Now this doesn't preclude joint planning of
experiments. In other words, there's advantage, and we have done that
with EPRI in a number of cases, looking ahead and planning research so
that we cannot duplicate each other's work.
We also think that there is need for realism in the
technical basis and a focus of the Environmental Transport Program is to
bring more realism to the decommissioning program right now.
We also feel that Research has a role to be forward-looking
for the agency. I think with the responsibilities of the program
offices to deal with near-term and short-term problems Research is the
Office that is better equipped to sit back and sort of look at where
should we be five years from now, what issues do we need to prepare for,
so that is really a key element of our vision.
Of course, underlying this is the maintenance of technical
expertise which underlies the vision and this is an extremely important
component of our work. The committee expressed great concern about the
size of the Research program in Waste Management, and that is something
that we are very worried about too. We are trying to balance that with
the need to maintain a core research capability in that area and I think
that is one area that the committee can be helpful to us in how best to
do that.
Our operating plan is our management tool that we are using
to ensure that all of our activities are focused on the highest priority
activities. The Research Operating Plan is directly tied to the four
operating goals. This is maintain safety, reduce unnecessary burden,
enhance public confidence, and increase the effectiveness, efficiency
and realism of the activities that we do.
This year we have gone to an outcome-based budget -- in
other words, no longer will you see disciplinary efforts within the
Office of Research. In the past, you know, we have had efforts in the
area of hydrologic transport. We are now becoming more
outcome-oriented, which relates to the issues that we need to be solved,
and Cheryl is going to talk specifically about the issues in
environmental transport.
Now our goal is to both support customer needs and
anticipate fewer future issues, so this means that the licensing offices
are urging us to focus on the needs that they have immediately, but we
must balance that with a long-term look in the area of waste management,
and that is another issue that we are struggling with and we will be
eager to hear your advice on.
Now an important aspect of our self-assessment was the need
to increase our contribution to the agency mission, and our objective in
doing that was really to define our desired outcomes. What do we want
to achieve with this work, and key to that was a systematic, top-down
look from the Office level of what are the important things that we
ought to be focusing on in the Office, and out of that came
environmental transport and decommissioning as very important to
achieving Office goals -- this is bringing realism and maintaining
safety.
You will see, as Cheryl describes, that we have given
priority to work with the greatest outcome leverage. There are a number
of activities on our plate in the waste management area, but because of
resource constraints we have been forced to ask ourselves what are the
most important and what weigh in with other priorities in the Office,
and so this has achieved some constraints in what we are able to do in
the waste management area.
We have also given attention to sunsetting work, which we
don't think leverages our outcomes in a number of areas.
So how did we approach this? Actually, the self-assessment
was a much broader activity, focusing all of the processes in the Office
of Research, looking at our contracting mechanisms and determining if
they were effective and looking at our staffing. As a matter of fact we
have during the past year been through a reorganization where we tried
to better align the functions within the Office to serve our needs, but
today I'm mainly focusing on our, what we call our pilot of the
Performance Budgeting and Performance Management process -- the PBPM
Process, as is it referred to in the agency.
Now we and NRR piloted this for the agency and we are moving
into sort of the second phase of this right now. I have outlined on
this slide our approach for doing this planning effort, and I think two
critical things that I want to emphasize on this slide are the bottom
two points, developing outcome-based performance measures.
What we have tried to do with all of our work is identify
performance measures so we will know when we have gotten there, and then
we are managing to those performance measures in our operating plan, and
Cheryl will discuss some of that with you as well in detail.
Just to give you an idea, as I mentioned earlier, in the
past we have been organized in the Office according to Thermal
Hydraulics and Severe Accidents. What we tried to do in stepping back
with this systematic process was to ask ourselves where do we want to be
and what are the strategies that we need to use to satisfy the agency
mission, and on the left-hand side of the slide you can see that
developing the technical basis to address safety issues and determining
the regulatory significance of new information, and preparing the NRC to
make timely future decisions.
We are now organized under these what we call Planned
Accomplishments, which we refer to as Key Issues. Now under these we
organize all of our activities, so all of the activities which relate to
developing and employing risk information would be organized and we
would prioritize and we would manage those to performance outcomes, and
you can see on the slide that many of these Planned Accomplishments have
tied to more than one of our agency goals.
We did indicate to you that we were performing a
prioritization effort in the Office and as part of the 2001 budget
submittal we tried to put everything on a level playing field in the
Office and using a multi-attribute decision analysis method, using the
analytical hierarchy process we prioritized all of the Office activities
in a 1 through N manner.
I have listed on this slide the criteria we used to do
this -- issue credibility -- in other words, what is the real evidence
of a problem? Do we have an actual finding that shows it is important?
Is it a result of a risk assessment? What is telling us that the issue
is credible?
Also, what is the safety significance and to a large degree
we used risk assessment to the extent we could in making that
determination.
We measured the burden reduction significance -- in other
words, what payoff would this activity have in terms of burden
reduction.
Applicability -- we looked at the number and types of
licensees that the activity would affect, and what we actually through a
parallelized comparison we came up with a relative prioritization for
all activities within the Office.
Now was the process perfect? I would have to say no, it
wasn't perfect the first time around. It is a very difficult process
and we really think that we need to make some improvements in the
criteria. We also think that we could make some improvements in the
transparency of the process and we are working on that right now for the
next budget cycle.
We also want to simplify the process. We had developed a
software tool that helped us, but we think that we can simplify the
process even further.
And another challenge that we have this year is really
improving our discussion of the tie between the issues and the agency
goals. I have included an example in my briefing near the end which
will give you an idea of how we are trying to achieve this transparency.
So, in looking back over '99, we asked ourselves, we have
put a lot of effort into this activity, and what do we think we really
achieved this with effort? First, we think we have, in our own mind,
achieved a link between research activities and agency goals. We think
that could be improved in our narratives and we are going to work on
doing that for the coming year.
We have developed an outcome-based budget. And this has
been extremely important for integration within the office. What we
have tried to do is tie together the engineering, the risk assessment
and other activities that are all needed to support common issue
resolution and make sure that the timing of all those activities was
such that it would produce the outcome.
It promotes integration of activities. As I have said, we
are now finding that our divisions and branches are having regular
meetings on a weekly basis to talk about the various inputs to the issue
outcome, and I think that is a very positive thing. We have developed
and used a new outcome-based prioritization for informing our budget
decisions. So as the Commission makes decisions about cuts, we have a
prioritization, and we have a documented basis for our prioritization
which helps us make our decisions.
In the waste area, I just wanted to give you an example of
what we are trying to do with this process. The agency performance goal
which I have used as an example is reducing unnecessary regulatory
burden. The research planned accomplishment in this area is develop the
technical basis to facilitate reductions to unnecessary burden.
The budget issue is to develop realistic models for
assessing radiation exposure, and one of the activities in the 2000-2001
timeframe is to examine the assumptions and the conceptual model and
parameters of existing models, and to develop more realistic models
which can be implemented in computer codes. And one of our operating
plan milestones is to develop probabilistic version of RESRAD by August
of 2000. So our effort in this regard is to make sure that we can see,
and staff can see, a clear link between what each of the activities are
and what the outcome goal will be for the agency.
So let me just stop. I will be turning it over to Cheryl
who will discuss -- I know the committee is interested in more details
in the waste area, and Cheryl will be providing those, but I thought it
was important to provide you sort of an upfront piece on where we are
headed, and I would be happy to answer any of your questions.
DR. GARRICK: Yes. I failed to mention that we are asking
George Hornberger to lead this discussion.
DR. HORNBERGER: Thanks, John. Thank you very much,
Margaret. Do we have questions?
DR. WYMER: I have one.
DR. HORNBERGER: Go ahead, Ray.
DR. WYMER: On your Viewgraph Number 10, where you list your
prioritization points, where in there does the magnitude of the problem
fit? That is, there is some problems are a lot of sites, some are just
at a few, but some are at a single site, but it is a big problem at that
site.
MS. FEDERLINE: Right.
DR. WYMER: Which one of these nine does that fit under?
MS. FEDERLINE: We would cover that under 2 and under 5.
Number 2 relates to the risk significance, what at stake. If it is a
big consequence issue, or is it a very high probability, we would pick
it up there. And then we would look also at the numbers and types of
licensees under Number 5. And this is one shortcoming that I think we
see with the overall -- the agency goals are fine as goals, but as a
prioritization method, we think there are other factors that need to be
considered as sort of subfactors under the performance goals for the
agency.
DR. WYMER: Okay.
DR. HORNBERGER: John.
DR. GARRICK: You mentioned, I guess it was the last slide,
Slide 12, the NRC performance goal is to reduce unnecessary regulatory
burden. How are you going to measure that? How are you going to
measure burden reduction?
MS. FEDERLINE: We actually have an effort in our regulatory
effectiveness branch. What our intention is is to go back and look at
selected initiatives and see what is realized when they are in place.
You know, that will be, of course, sort of an after the fact effort, but
we believe that we need to go back and look at these initiatives and
say, did they really pay off as we estimated they would?
DR. GARRICK: Yeah, the reason I bring it up is because
regulatory burden relief is also discussed in the PRA policy statement
and, of course, most applicants would argue that the burden is
increased, not decreased, because we are in this transition period where
we don't want to give up the way we have done it in the past until we
learn more about ho to do in the future.
MS. FEDERLINE: Right.
DR. GARRICK: And that makes sense. But at the same time,
it seems that if indeed some regulatory relief is a major component of a
goal, that some sort of metric has to be developed to see if you are
making any progress on that. That was really the reason.
MS. FEDERLINE: Yes. And that is really one of our primary,
-- as I said, we had the reorganization in the office, and we felt that
a regulatory effectiveness group within the office that could look more
broadly at office activities and provide us feedback was sort of a
check-and-balance kind of system.
DR. GARRICK: Just one other comment, in your
multi-attribute approach, you talk about risk, safety significance, et
cetera. I guess one of the things I was kind of looking for here was
some of the underlying elements of your strategy for implementing your
vision statement. An example of that would be that we are transitioning
into a risk-informed approach to regulatory practice. You do talk about
strategies, but I guess I was trying to -- maybe you can help me see
what some of the real foundations here are of the strategy for
implementing that vision.
MS. FEDERLINE: Yes, I think our strategy for -- you are
talking about the strategies for implementing the overall vision within
the waste area?
DR. GARRICK: Right, right, right. And I am looking for
kind of a capstone component of that strategy and what it is.
MS. FEDERLINE: What we have been doing is working on an
arena basis with NMSS and we are currently revising the strategic plan.
As part of that, there will be strategies that we are working on, and
many of them are articulated -- of course, obviously, they are not the
right words, but many of those are incorporated in Slide 9, where I am
talking about improving analytical tools and data to support realistic
decisions. That is a key strategy for the waste arena. How are we
going to get to reducing burden and maintaining safety?
DR. GARRICK: Do you think you have advanced to a point now
where, if you were challenged on the attribute of risk, that you could
put forth the risk relevance, importance ranking of the research
program?
MS. FEDERLINE: No, I don't think we have, and that is one
thing that Cheryl is going to be discussing with you. One of our major
strategies within our own program is to look at a range of performance
assessments. You will probably recall, under DSI-22, the Commission
said one of the things that research does well is understand and develop
methods. And what we want to do is look at a range of the existing risk
assessment methods for waste, and look at where the underlying
uncertainties are. Where are the uncertainties that make the most
difference?
And my belief is that that should drive our research
program, and we have seen that in the decommissioning area and the --
Cheryl -- the building --
MS. TROTTIER: Indoor resuspension.
MS. FEDERLINE: I'm sorry. Indoor resuspension. I can't
keep that in my mind. But our performance assessment drove that as a
key factor and so we were able to actually go out and get some
information from industry. There are going to be places where are not
going to be able to get that information from industry, that we might
have to do some actual research. But I would see our agenda in waste be
more driven by our understanding of the risk assessment methodologies as
they exist.
DR. GARRICK: Okay. Thank you.
DR. HORNBERGER: Milt, did you have anything?
Cheryl, I have two questions, one quite specific and the
other more general. Let me do the specific one first. In your new
program areas, one of them, at the bottom, is enhancing public
confidence. And I am curious as to whether you are doing research in
that field, that is, how NRC might improve the techniques, or whether
that just means that you are participating in informing the public and
engaging the public to create the confidence.
MS. FEDERLINE: I think at this point there is an effort
afoot to develop a communications strategy for the agency, and so it is
not really played out what each office is going to be doing. But I can
tell you in the research area, one of our goals here is to enhance our
communication with our stakeholders, to engage our stakeholders earlier
in the development of the research process. Make sure that we are in
sort of an agreement as to what the planning is that needs to be done.
So our public confidence effort is mainly an information exchange, a
confidence.
DR. HORNBERGER: Okay. The more general question is a
difficult one because, on the one hand, as -- well, as you pointed out
in your first slide, we suggested that one of the things that we thought
that you should be doing is just what you described, going through some
form of prioritization. Now, the trick is, of course, when you are
dealing with research, is how one does that and doesn't get so focused
on short-term objectives that you can't do some of the other things that
a research organization has to.
MS. FEDERLINE: Right.
DR. HORNBERGER: For example, maintaining your core of
excellence, or whatever your exact words were, may not jibe with purely
short-term payoff items.
MS. FEDERLINE: Right.
DR. HORNBERGER: How are you balancing this?
MS. FEDERLINE: That is a very difficult area and that is an
area where we would interested in your advice. Let's see, if we look at
-- let's see. If we look at Slide 10, you can see that using these
criteria, for instance, issue credibility, if it is a long-term issue,
it is going to get a lower score. It was very hard for us to capture
criteria in here that would adequately reflect the emerging technology
area. And if you can think of any that could help us, we would be --
this is a problem we struggle with all the time. But we have thought
about it, and, you know, we just haven't come up with a good answer yet.
DR. HORNBERGER: Of course, like most people, we are better
at pointing out problems than suggesting solutions.
MS. FEDERLINE: Well, but we haven't given up on the
problem.
DR. HORNBERGER: No.
MS. FEDERLINE: We are still thinking about it. It is just
very difficult.
DR. HORNBERGER: And we will think also. But I don't want
to promise you that we will have any creative suggestions for you.
MS. FEDERLINE: Okay.
DR. HORNBERGER: It is a very tough problem.
DR. WYMER: Actually, you are sort of on the horns of a
dilemma here because to be prepared for long-range problems, you have to
maintain a general expertise, which isn't consistent with addressing
specific problems. So I am not sure how you ever do resolve the issue.
MS. FEDERLINE: Yes.
DR. GARRICK: One of the things I was struck by is this
change from a discipline-oriented approach to what I might call a
program- or project-oriented approach. Is there any problems with that
in terms of maintaining quality or recruiting, or what-have-you?
Because researchers tend to want to be identified with a discipline more
than they want to be identified with a program or a project.
MS. FEDERLINE: Well, the way we have tried to address that
is by keeping a functional organization, in other words, our planning
and budget categories are based on -- and project is not a good
characterization. We have tried to look at broader issues.
DR. GARRICK: Yes.
MS. FEDERLINE: You know, more sort of, more -- a longer
scope or broader scope issue. But the way we have tried to get at that
is the importance of people doing important work, working together, and
drawing synergy from one another. We have tried to make our
organization more functional and bring together relationships of people.
In other words, risk people, you know, need to work with the severe
accident folks, for instance, to try to get a clear relationship, to try
and bring the related functions together.
DR. GARRICK: Yes.
MS. FEDERLINE: It is just very difficult to go and explain
a thermal-hydraulics program, or an environmental transport program
without putting it in the context of what it is we are trying to solve,
or where we are trying to get long-term.
DR. GARRICK: So it is kind of issue-based, I guess would be
--
MS. FEDERLINE: Yes.
DR. GARRICK: Yes.
MS. FEDERLINE: Yes. These are our 10 key technical issues.
DR. GARRICK: Right, right. Yes. Now, that opens up a few
more questions.
MS. FEDERLINE: Forget I mentioned it. I would like to turn
things over to Cheryl Trottier. She is our Branch Chief in this area.
DR. HORNBERGER: Thanks very much, Margaret.
DR. GARRICK: Yes, thanks.
MS. FEDERLINE: You are welcome.
DR. HORNBERGER: We will have to do more about research just
so we can get to interact with you more frequently.
MS. FEDERLINE: Absolutely, I would really look forward to
that Your ideas are always very helpful to us.
MS. TROTTIER: Good afternoon. As Margaret has said, I am
Cheryl Trottier, and I am the Chief of this branch. It takes too much
to say it, but it has a very long name, we have to change our name.
But, anyway, this is the first time I have come to you in this new role.
As of our reorganization in the spring, we have basically merged our
former Radiation Protection and Health Effects Branch with the Waste
Management Branch, so there are a lot of things that, within the branch,
we do differently, but it is nice to see there are a lot of things which
have caused cohesiveness. There is a lot of interaction between the
kinds of work that the former Waste Management Branch did and the kinds
of work that we are doing in Radiation Protection these days, so it is
turning out to be a very good mix.
Margaret did a good job of introducing prioritization, which
I am glad she did, because it is much better when she does it than when
I do it. But what I am going to try and do is walk you through how this
process worked in the waste arena. And I thought I would first just
give you a couple of summary slides that speak to the kinds of issues
that were identified, and then I will talk in more detail for each of
those issues, the kinds of projects that we are engaged in that fall
under those issues.
So under the performance goal, maintain safety, three issues
came out. The first one basically dealt with developing monitoring
techniques for volumetric contamination. And this can cover a variety
of areas and, as I said, I will get into more detail with that.
The second issue that came out was a need for realistic
analysis of groundwater systems.
And the third issue that came out was one of developing
monitoring strategies for the decommissioned sites, because there will
be cases where the licensing office we believe will need some support
there.
Then the next performance goal, and, really, for the waste
arena, even though they could have probably fit under three categories,
for the waste arena, they basically fell into these two categories of
maintain safety or reduce unnecessary burden reduction. And as we walk
through these, you will see a lot of these could have fallen into
effectiveness and efficiency, but, in fact, for this part of the process
anyway, maybe down the road, they might change, but at this point they
are under the unnecessary regulatory burden aspect.
And the first one, which I will spend quite a bit of time
on, was -- the first issue identified was to provide and maintain
integrated computational tools. We have talked about that before, but I
will give you an update on where we are with that. And then the rest of
these basically support that and some other initiatives that are
currently of interest in the licensing office, that is to develop
realistic analysis, models that support realistic analysis of
radionuclide transport, data and models to support realistic analysis of
groundwater flow. Again, data and models to assess the effectiveness of
engineered systems, and I will talk a little bit about that, because we
may not have discussed that recently. And then the last one is develop
data and models on contaminant degradation and release.
I will mention that for most of these projects, they were
ongoing projects within the office. There is one new initiative that
came out of this prioritization effort, and that, in fact, is on this
first slide. So then to talk about the projects that fell under these
issues, the first issue, which was the maintaining safety issue, has
these three projects and -- or, actually, there is more than three
projects because under the first issue there are two projects. The
first issue is the one that dealt with volumetric contamination. And I
want to apologize because I am suffering with a cold today. I am
getting to the end of it, but anyway.
This really addresses both decommissioning and support for
the development of a possible rulemaking, -- we are not in rulemaking
space yet, -- that would support clearance of material that is released
from licensee control. It deals with the issue of how you measure
volumetrically contaminated radioactive material. In other words, if
you are sending off soil from the site, or in the case of decommissioned
site, our current guidance really only addresses the first few
centimeters. The modeling does not go down with depth. The survey
techniques really don't address depth. And so this work that we are
having done in both of these contracts will help with the techniques,
the survey methods, the instrumentation that will enable licensees to do
those kind of measurements.
And the next project -- excuse me -- that falls under this
safety performance goal is one that addresses parameter uncertainty.
Yes, thank you, John. Gosh, you brought my water. Thank
you, Margaret. That is called management support. Thank you.
Parameter uncertainty and groundwater modeling. We have had
that project going on for several years, and we believe that this is one
of the aspects that is critical to the licensing office to assist them
in making a lot of the decommissioning decisions that face them today.
And then this is one of our new -- oh, I am going to mention
to you I have a little coding system on this chart that may help make
more sense out of it. I have ranked these in order of priority, and
those priorities were really assigned by the licensing office. During
the process of doing our prioritization, we also met with the licensing
office and gave them the initial results of our prioritization. And
they came back to us with their assessment of how close we were to the
mark in identifying the important issues.
And so the items here, or the projects that are identified
as high priority are those that the licensing office indicated to us
were a high priority. Under that first bullet, I also indicated that
this supports the SRM that the Commission issued to the staff to go and
investigate a potential rulemaking on volumetric release.
And the reason I went back to that is this last project is
one of our anticipatory research initiatives. That is really the reason
why it has a "no priority," because NMSS focused on those areas where
they had user needs, and they had already identified work that they
needed.
We believe this is a critical component for the Office of
Research, to continue to do anticipatory work. In fact, that is why we
have the experts that we have, so that we can look down the road to see
where the needs may be in the future, because many times the research
takes more than a year to complete, and oftentimes a licensing office
needs an answer in a year. So if we just simply wait for them to come
to us with their needs, then many times we won't be able to be
responsive. So we will continue to try to identify -- that is one of
the things that we will get to when I get to the end of this, where we
are trying to refine that process of how we effectively identify where
the future needs are. But that is a new initiative that I currently do
not have money for this year, but we will start it in probably either
the end of this fiscal year or the beginning of '01.
Okay. Now we will move into the second performance goal
area, and that is unnecessary regulatory burden. I will begin here with
the issue addressing the integrated computational tools, which at this
time involve three projects, enhancements to the Sandia Environmental
Decision Support System, which I know we have brief the committee on
before, and that is an ongoing project.
The development of a probabilistic version of DandD. Now,
what this is really doing, and I will speak to this further as we get to
the next slide, is removing some of the conservatisms that are inherent
in DandD. There are some conservatisms that you can't get rid of
because it is screening code, but there are some that were put in mainly
in order to get the code developed quickly. The mechanisms for
developing the original set of defaults added conservatisms that weren't
warranted.
And the third is a fairly new initiative, and we may not
have come before the committee with this before, and that is to develop
a probabilistic version of the RESRAD code.
I thought it might be worthwhile to digress a little from
the overall prioritization effort and walk through a little of where we
are on these computational tools. Again, under DandD, the version that
we have out today really produces bounding estimates, and it is
important to remember that part of the reason for that is it is based on
a model that was developed to support rulemaking, not necessarily as an
implementation tool.
It has worked as a handy screening tool, and really serves
as a basis to help licensees make decisions in that they don't actually
have to know anything about their site to run DandD. And in some cases,
there will be licensees who won't need to do anything other than run
DandD, and they can then make decisions about terminating their
licensee. They won't need to run a more sophisticated code or go out
and collect site data in order to make those decisions.
Currently there is a version of RESRAD that is available
that has been used by licensees. The licensing office specifically
asked us to look at developing another version of RESRAD because, while
licensees are very comfortable with using RESRAD, it creates a burden on
the licensing staff in having to review each submittal because RESRAD
was really developed for DOE sites, where there is a lot of
characterization, and you can't really run RESRAD in default mode, it is
not intended to be run in default mode. So, therefore, the licensing
office needs to have some assurance about the parameters that licensees
select, and the effort that we are underway with now will help them do
that.
SEDSS is available today. Unfortunately, it is very hard
for the average user to use SEDSS. It is something that the staff has
been able to make sure of, but the current version of it is not what we
call really user friendly.
Okay. This is what we are going to accomplish this year.
In fact, I believe we now have, or are about to have a beta version of
DandD available. Again, the primary purpose of this version is simply
to reduce the amount of conservatism in it. It is still a screening
code, it is still based on the 5512 model. And, again, its only real
purpose is to be useful as a first step, and for a few licensees who
really do not have significant amounts of soil contamination, I believe
it will be a very useful tool for all of their decommissioning
decisions.
The work we are doing on RESRAD is similar to the work that
was done to develop the version of DandD that we have today, in that
they are using a Monte Carlo approach for treating parameter
uncertainty, and what that will then produce is a distribution which
will be sampled and licensee's submittals then can be compared against
those distributions.
And the work we are going to accomplish with SEDSS this year
is to put together basically a PC version of SEDSS. That version will
still use the same modeling that it has in the version we have today,
and what that means is it only has a one-dimensional groundwater model.
So it is still not going to be the kind of SEDSS we eventually hope to
get to, but at least it will have some improvements in it this year.
And just to give you an indication of where we are going
with these, we're anticipating that by the end of FY2000, the work on
D&D and RESRAD will be primarily done. There will be some documentation
that will still be needed to be completed. But the actual code work
will be done and will be available for licensees to use.
Then the future work will focus on SEDSS. And what we are
doing is, a lot of the work within the Branch today will support these
enhancements to SEDSS. And I list a few here of the areas that research
that we see needed down the road to help reduce the uncertainties. And
that is to focus on the forms of the radionuclides during release and
transport, during inhalation and ingestion by people, and the metabolism
and dosimetry of the forms once they're ingested -- in other words,
completing the whole process eventually is our goal.
Now I'd like to give some examples of some of the specific
projects that go into supporting the development of more realistic
models. And under the first, which deals with absorption process, there
are actually two projects ongoing; one dealing with the mechanisms
primarily, and one which is focusing on field studies. And that is a
cooperative effort with the USGS. And both of these are ongoing efforts
that are about halfway completed. Both of these projects, you'll
notice, were under user need, but the Office has identified them as a
low priority.
The second bullet here is model uncertainty in groundwater
models. This is also work that's about halfway completed. And this
falls into the area of anticipatory. The user needed -- the Licensing
Office did not provide us a user need. And we do believe that the work
that's being done in this project will eventually feed into SEDSS.
The last project on this sheet, which is the last bullet, is
a project that is addressing engineered barriers. And you've probably
been briefed on this in the past, which is the 4SIGHT code. That work
is being done in cooperation with NIST. Again, this is anticipatory
work. This work, I think, was originally started to support low-level
waste research. And what it now appears is, a lot of the information
that can be obtained through this code may help the Staff in making
decisions for any situation where a licensee may choose to use the
entombment option for decommissioning, because it's a very useful code
for evaluating the concrete degradation issues that would be a key
element of an entombment decision.
This is also one of the projects that I like to speak about
from the standpoint of how I think the Office is effectively using the
research expertise that it has, because in this case the Staff person
actually works at NIST at least one day a week. And really, that's an
effective way to keep researchers interested in their work and it's a
very effective way to use the dwindling dollars that the office has
because the more cooperative efforts we have through the resources that
are available locally -- and there are a lot of resources available
locally -- the more benefit I think we're gonna get in the long-run.
And I really encourage the staff to seek out these kinds of research
programs, where they can do a cooperative effort with another Federal
agency or university, which has the equipment and tools that enables
them to do the research.
These are examples of the last two projects -- we have other
projects going on in the Office, but I focused on those things for which
future year money, or 2000-year money has been allocated. There are
some projects that are near in completion that did not use current
dollars.
These are, this is the last two projects that I'm gonna
speak to. And these really did come under a user need that supports the
decommissioning decisions for the licensing office dealing with
primarily slags and, in particular, looking at solubility and leach
rates.
The second project is another one of the in-house
cooperative work. In fact, almost all of it is done in-house, where the
researcher spends considerable time at Hopkins University doing the
research. And you know, we're getting very good results out of that for
very little money, and that's a really important feature of it.
And now I come to our last slide, which is the one where I
said of the -- primarily asking for some guidance from you. The process
that we went through was an office-wide process. But in identifying
issues, one of the things the Staff has to be able to do is have some
idea of where to look. How do I know where the problems are? And so,
what this slide really lists is our ideas as to sources for input in
defining where future research is needed.
Margaret talked about self-assessment. And beyond the work
that we did in-house is the idea that by doing, or looking at, different
performance assessments, it's a way for us to gain other information on
areas which may need further work.
Another area where we thought we could gain some insight was
from going out to stakeholders. And lumped into that group is having
peer review of research results to identify where further work my be
needed: of course, working with the program offices who frequently know
what's needed, at least short-term; seeking guidance from groups like
the ACNW; participating in outside meetings, having research staff
participate in outside meetings and technical conferences, to know how
others are coming in their research efforts and, and hopefully
identifying where gaps exist. And also that's an effective way to avoid
duplication of research.
And in some cases we have had a lot of success in conducting
public meetings and in doing program reviews, which we have recently
tried to do in a much more formal way. I think last year, maybe in the
Spring, Staff told you about the program review that we did at Sandia
last December. Well, in June we conducted a program review at
Beltsville, Maryland on hydrology, and it was a very successful program
review, where numerous scientists came in and discussed their research.
And we shared with other agencies as well at that meeting.
And then the third source is really industry initiatives,
because sometimes industry does identify problems. And a good example
is entombment. There are some licensees out there who have indicated an
interest, that they may like to pursue the entombment option. Well that
then is a challenge for the Licensing Office, and those are sometimes
areas where research can help by filling in the gaps on what the
licensing office doesn't have in their data for making those kinds of
decision.
And that ends my formal presentation, so I'll take
questions.
DR. HORNBERGER: Thank you very much, Cheryl. Don, do you
want to start it?
DR. GARRICK: Looking at this list of sources of input in
defining future research, in the past, what have been the top two or
three sources that you've depended on or that's been the most effective?
MS. TROTTIER: I would guess -- and see, here I'm going to
call on my vagrant assistant branch chief who's gone off to the EDO's
office for hopefully only six months to maybe help because I'm very new.
But I would suspect staff expertise and peer review, but Bill, can you
add to that?
MR. OTT: I would say -- Bill Ott, Office of Research. I
guess I'll cling to that affiliation right now.
MS. TROTTIER: That's great.
MR. OTT: One particular avenue that Cheryl didn't mention
explicitly is that we maintain a small contract with the National
Academy of Sciences -- to general support for one of the committees.
Every year we go to that committee and we discuss parts of our research
program. Generally, it's been in the areas of hydrology, the work on
4SIGHT, and things like that. The National Academy then gives us back
informal feedback. We don't give them enough information or enough
money to come back with a formal report, but we do get informal feedback
from them on the content of the work and the direction of the work.
We do, of course, aggressively go after peer review. We've always done
that. That's an office policy. Stakeholders internally -- of course,
the Office of Nuclear Material Safety and Safeguards; our own staff;
attendance at professional meetings in which we make presentations and
actively go out and solicit interactions from the participants.
This year is the first year that we aggressively went out
and tried to expand the program reviews. And we did this in two way.
First, instead of holding individual project reviews, we tried to hold
two or three project reviews together to increase the number of
scientists themselves who were interacting in the program. Then we
invited, actually sent out letters of invitation, to a lot of people.
We sent them out to EPA. We sent them out to USGS. Other -- the
Department of Energy. We sent even letters out to some of our
international partners with whom we do information exchange.
We got probably 30 percent response in terms of people
coming into those meetings. But Sandia one was the first one and had
the least participation. The hydrology one in Beltsville was the second
one. We had more participation in that one. And some of those people
said, next time you go to do the chemistry, give us the call rather than
someplace else where you send it in the Agency because we think we
should have been there in Sandia.
We got a lot of positive feedback from the other Federal
agencies, both DOE and EPA, at the meeting in Beltsville with regard to
the applicability of the work we were doing, how it would benefit them,
and things they were doing that were relevant to us and whether we were
on track to help them and that kind of thing. So it's a case of, I
think it's evolving. And I think we're actually making progress.
DR. GARRICK: What's the principle mechanism of getting
industry feedback?
MR. OTT: We invited -- as I said, before this year we
didn't really actively invite the industry. We invited NEI and EPRI to
participate in both the Sandia and the Beltsville workshops. EPRI
participated in both of them. Did NEI -- NEI did not participate in
either one of them, but the NEI people said that they would consult the
EPRI people that attended the Beltsville meeting. They just didn't
respond to us on the meeting out in Sandia. But principally right now,
that's the mechanism that we're going through trying to get them to come
in and see the work at the ground level, where the individual
researchers are presenting the guts of what's going on in the program
review context.
MS. TROTTIER: And I will point out, we've had a lot of
public meetings as we're finalizing this guidance for the license
termination rule. And licensees are usually eager to point out areas
where they need further work. So I think those kinds of exchanges are
helpful in identifying areas where there may be shortcomings.
DR. GARRICK: Yeah. Now, you said earlier that you rely a
lot on performance assessment work, and you also made specific reference
to going to the licensing people to get that input.
MS. TROTTIER: Um hmm.
DR. GARRICK: Is there good correlation between those kinds
of searches? Are the licensing people increasingly going to the
performance assessments to evaluate what's important?
MS. TROTTIER: I believe they are using performance
assessment more and more, and in fact that's how they have identified
some of the flaws that we've needed to work on in the existing models.
DR. GARRICK: Thank you.
MS. TROTTIER: Bill did you want to add something?
MR. OTT: Yeah, I wanted to add one thing to that. When you
talk performance assessment in this context, you're talking about it in
a broader sense than applying one of these models?
DR. GARRICK: Right.
MR. OTT: Because I think what we get a lot from the
licensing office is experience from the licensing review, which may not
have employed one of these models.
DR. GARRICK: Right.
MR. OTT: But they detect it in trying to do analyses, no
matter how they did them, that there was a problem and they needed
information.
DR. GARRICK: Yeah.
DR. HORNBERGER: I don't have a question; I have an
observation. Your page 8 viewgraphs, viewgraph you have items A, B, and
C. A and B are basically speciation concerns.
MS. TROTTIER: Um hmm.
DR. HORNBERGER: And about three weeks ago, there was a work
shop held by the Nuclear Science Committee of the Nuclear Energy Agency
of the OECD --
MS. TROTTIER: Um hmm.
DR. HORNBERGER: -- that was specifically directed at
speciation in the context of waste management and environmental
pollution. And they're in the process of preparing a report on that.
And I'd be happy to give you a contact if you'd care to pursue it.
MS. TROTTIER: Yes. We would appreciate that.
MR. LEVENSON: I've gotta couple of questions that are "new
boy on the block" questions, so they're for clarification.
On slide 2, you talk about the need for realistic analysis
of groundwater systems. Is that chemical analysis or computer modeling
analysis? Which definition of the word?
MS. TROTTIER: Mostly computer modeling analysis, but I
think I would like Tom to answer that because Tom is doing more than
modeling, really.
MR. LEVENSON: Okay, see, because the other two items on
that page are monitoring techniques rather than modeling.
MS. TROTTIER: Um hmm.
MR. NICHOLSON: With regard to the modeling of groundwater --
DR. HORNBERGER: Tom, give your name please.
MR. NICHOLSON: Excuse me?
DR. HORNBERGER: Give your name for the record.
MR. NICHOLSON: Oh -- Tom Nicholson, Office of Research.
With regard to the groundwater models, one of the dilemmas is that
depending on how the licensing staff chooses their code, it may
represent a very simplistic view of the groundwater system and maybe a
one-dimensional model. It may handle things in a very lump-parameter
fashion. And so therefore, some people want us to take credit and give
information with regard to realistic groundwater flow systems. And so
therefore, we're trying to capture those realistic flow systems by
varying the code, as Cher went through. We're also looking at the
conceptualization of groundwater flow systems.
MR. LEVENSON: You're giving me more information than I
wanted.
[Laughter.]
MR. NICHOLSON: Okay.
MR. LEVENSON: My question basically is, what's the
difference between Item 2 on page 2 and Item 3 on page 3?
MR. NICHOLSON: Item 2 on page 2 is to basically look at
groundwater flow systems so we can think of it in terms of one-, two-,
three-dimensional models. We can also look at various processes. We
can handle heterogeneities with regard to realistic groundwater flow
models. So Item 2 on page 2 is more oriented toward modeling. Now what
we the other question, Sir, on page 3?
MR. LEVENSON: Page 3, Item 3, which I think is what you
just said.
MR. NICHOLSON: Yes. That is almost identical. Yes, it is.
MS. TROTTIER: Actually, Tom -- because we had this
confusion with trying to write these short. This is the, the -- Item 1,
page 2, is the PNNL work.
MR. NICHOLSON: Okay.
MS. TROTTIER: And item on page 3 is the Arizona work.
MR. NICHOLSON: Okay. With regard to the PNNL work, the
investigators at PNNL are looking at uncertainties with regard to the
parameters. So it's parameter uncertainty they're looking at. And some
of the models used in decommissioning have generalized to use default
values. And now people want to put in what would be more realistic
values. So PNNL is coming up with distributions of parameter. So if
you know the soil textural class, you can go then to a table and look at
what the ranges would be in sampling from those.
With regard to the other project, conceptual model
uncertainty, that's going on at the University of Arizona. And that's
what I described earlier, looking at issues of dimensionality, looking
at issues of scale, heterogeneity, the type of assumptions you make when
you choose your model.
DR. GARRICK: Are analogs being used in the conceptual model
uncertainty analysis?
MR. NICHOLSON: No.
MR. LEVENSON: One page 4 -- I hope the third bullet where
you say "no priority" was intended to be "no priority from licensing
people"?
MS. TROTTIER: Yes --
MR. LEVENSON: As I think --
MS. TROTTIER: And resisted -- the first time I did these
slides, I didn't put anything there because it bothered me so much to
see "no priority." But for accuracy, I put it in. What it means is
that priority designation came from the licensing office. And if it was
an anticipatory activity on the part of Research, which meant they did
not have a user need, then they labeled it as "no priority."
MR. LEVENSON: Okay, but I hope it's your office priority --
MS. TROTTIER: It is our office priority.
MR. LEVENSON: -- would not automatically follow necessarily
any of their priorities.
MS. TROTTIER: No. No, no it doesn't. But it was, if you
remember from what Margaret spoke with you about, user need was an
aspect of our prioritization.
MR. LEVENSON: I just have one other question. On page 11,
on the input on defining future research, having been on quite a few
Academy committees over the years and having been on many peer reviews,
normally the guidance you get is to review what people are doing. Does
your request to the Academy committee ever say, don't bother reviewing
what we're doing; what's more important is, can you identify what we're
not doing that we should be doing. Is that question ever posed?
MR. NICHOLSON: Yes it is, Sir. Jake Philip and I go to
these National Academy of Science -- Jake is the liaison to the Board on
Rock Mechanics. I'm the liaison to the Water Science and Technology
Board, and yes, we do ask that question.
MR. LEVENSON: But that's a very limited area if it's only
asked of that Board, isn't it?
MR. NICHOLSON: We have -- last March, we were the principle
sponsor, along with DOE, of a workshop on flow through the fractured
vadose zone. It was dealing with conceptual models. And we and the
National Academy of Science organized a panel and brought in a large
international group to look at conceptual models of flow through
fractured rock in the unsaturated zone. And at that time, we were
actively looking obviously for input from a variety of scientists --
source scientists, hydrogeologists --
MR. LEVENSON: Well, I didn't mean extremely limited in your
source. I mean, you're asking a very, very narrow question. There are
many other questions in the waste area. There should be research going
on. So if you ask experts in rock mechanics what you should be doing,
you may get a very good list of things, but there are a lot of things
other than rock mechanics. How do you get -- is the National Academy
committee that narrowly defined for this purpose, this group?
MR. NICHOLSON: Well, as I said before, the other committee
we interact with is the Water Science and Technology Board. And there's
also a Board on Radioactive Waste. Now, we're not the contact on that;
that's NMSS. But we actively attend the meetings and discuss with them
various projects. They review every year, they go through a process
where they bring in invited speakers and go through a variety. Often
it's DOE, either DOE clean-up of former material sites, or Yucca
Mountain. And we learn an awful lot through that also.
DR. HORNBERGER: But to follow up just a moment on Milt's
questions, research does not liase with BRWM. You simply, you liase
with rock mechanics and WSTD.
MR. NICHOLSON: Right. Right --
DR. GARRICK: I guess the connection I'm trying to make
there is, Margaret talked about moving away from a disciplinary
approach, more to a multi- or interdisciplinary program approach. And
just as an observation, the Board on Radioactive Waste Management is
much more oriented toward the latter than the former and it could be an
important inter-liaison for research as well, especially if this is a
change in the strategy.
MR. NICHOLSON: Um hmm.
MS. TROTTIER: Yes, I think we need to make sure Research
participates in those meetings and asks those questions.
DR. HORNBERGER: From the other side, I'll just make a
remark, because one of the other things I do is chair the Commission on
Geosciences and Environment Resources, under which is the Water Science
and Technology Board and the Board on Radioactive Waste Management. At
any rate, we just went through a review of the Board on Radioactive
Waste Management, and one of the messages that was certainly suggested
to them is that their meetings could really play an important role if it
provided a forum, not be so tightly restricted to DOE issues, but not to
have broader issues. So BRWM might be quite responsive to hearing from
you.
MS. TROTTIER: Good.
DR. GARRICK: We've got a lot of incest.
[Laughter.]
DR. HORNBERGER: Any other questions? Cheryl, I have, let's
see, a couple of questions.
On page 9, where you went through several of the examples, my question
is, do, would I expect to see the listing in terms of the priority
rankings somewhat different in the future after having heard Margaret's
pitch as to how you've gone through prioritizing. Because, when I go
down this the user need, low priority; the next ones are anticipatory --
anticipatory. So I don't see any on here that are user-need high
priority. I'm, am I right in inferring that in the future I might
expect to see one or two there?
MS. TROTTIER: Well, what I didn't mention is I listed these in order of
their priority. So when I got to page 9, I was moving into the lower
priority things. And the one under reducing unnecessary burden that
were highest on the priority were the three codes. Those three came out
as very high -- or at least that issue. I shouldn't say those projects,
because this was an issue-based prioritization. That issue came out
high on the prioritization because it was high as a user need.
I think the future prioritization may change this some.
It's hard to say. You know, this was our first attempt --
DR. HORNBERGER: And I, I don't mean to do anything like
cast dispersions on any particular project.
MS. TROTTIER: Yes.
DR. HORNBERGER: I was asking a much more general question.
Just in general, might I anticipate seeing more that don't either fall
into the anticipatory or the low priority category?
MS. TROTTIER: Yes, you might. You most likely will.
DR. HORNBERGER: John, did you have a follow-up?
DR. LARKINS: Yes. If you use the attributes that are
listed in Margaret's presentation on page 10, then aren't you always
going to come out with your anticipatory programs being ranked lower --
MS. TROTTIER: Yes.
DR. LARKINS: -- than those for which you have a research
request?
MS. TROTTIER: Yes.
DR. LARKINS: And in times where you have competing dollars,
it seems like that might automatically eliminate the anticipatory work
from the other.
MS. TROTTIER: That's going to be a challenge for the
Office. It's going to be a particular challenge if we go to agency-wide
budgeting by arena. In other words, not office-wide budgeting, but if
we go to agency-wide budgeting, then that anticipatory work is going to
be really hard to compete in the face of licensing.
DR. LARKINS: Right.
MS. TROTTIER: So, I --
DR. LARKINS: I might suggest that when you do your
multi-attribute decision or AHP, that you look at weighting different
factors.
MS. TROTTIER: Differently.
DR. LARKINS: Differently.
MS. TROTTIER: Yeah, that's my fear is how we maintain our
-- it's important to maintain our anticipatory program.
DR. HORNBERGER: Absolutely. Absolutely. That's again one
of the difficult issues that I painted for Margaret that I wanted to
disabuse her the notion that we might solve that problem for you.
MS. TROTTIER: Right. I understand that. Bill, did you
want to add something?
MR. OTT: Margaret made the observation that the process we
used was fairly complex. It's complex only in the number of factors
that are used; conceptually, it's not that difficult. But it's almost
too simple to say that it automatically ranks low if it doesn't have
user need, because there are so many factors that were considered that
if something with a user need doesn't also have some factor like
leverage or something like that that can boost a project above one that
has a user need because it's only one of -- I think if you total the
number of factors, it's something like 20 that get various scores in
this process.
DR. LARKINS: So there are more than nine that are listed.
MR. OTT: The nine that are listed are the primary criteria.
Under them there are sub-criteria, and then there are importance
measures and things like this. So things can, can adjust based on
relative scores because they're not always necessarily related to user
need.
MR. KING: Tom King. Let me follow up on that. There are
only nine factors. Each one has a different weighting to it, so they're
not all weighted equally. And under each of the nine factors, there are
some sub-criteria that tell you, for that factor, should it get the full
weight, should it get some fraction of that weight, depending upon how
well, for that factor, certain sub-criteria are met.
So there's really only nine factors, but there are a score
-- each of the nine factors, and then each of the nine factors
themselves have different weighting. And we can get you the numbers,
the weighting scheme if you want to see it. But it is complex.
DR. LARKINS: I guess the only question I would have is, how
do you do budget reductioning significance? And then you have to have
an estimate of what the impact of once you develop an outcome, how that
outcome is going to reduce the burden, for individuals, for licensees,
for staff.
MR. OTT: Believe me, we struggled with issues like that.
DR. HORNBERGER: Yeah.
MR. OTT: And the other point that Margaret made is that
it's changing. This was the first attempt. And there could be a change
in the criteria structure as well as the weighting scheme in this next
go-around based on the experience that we had last time.
DR. HORNBERGER: And I think that it's clear. And I think
everybody who's gone through anything like this is, recognizes that
there's a certain arbitrariness to how you assign the weights and how
you divvy things up and how you estimate this. But I think that the
important thing is that you go through the process and you recognize
those nine factors. And what you wind up with, you hope, I think, is a
balanced portfolio, which is I believe what you're all looking for.
MR. KING: Yeah, and we didn't blindly follow the numbers
that came out. They informed the decision process. Other factors came
in as well.
DR. HORNBERGER: Of course. Well, I would hope so.
MR. KING: Cheryl, my other question has to do with your,
on the slide you list the sources of input in defining future research
and how you get outside input, if you will. And my question has to do
-- so you conducted these public meetings, and I think I -- I certainly
talked to Bill and probably Tom, and they both told me that the June
workshop in particular they were very happy with.
MS. TROTTIER: Right.
MR. KING: Now my question is, when you conduct these
things, is there some written record? Is there a written report?
MS. TROTTIER: Yes. And in fact, on the June workshop we
published proceedings or are publishing proceedings.
MR. KING: Okay.
MS. TROTTIER: We normally transcribe them, so there is a
written record.
MR. KING: Okay, but proceedings, that would be the
presentations.
MS. TROTTIER: Right.
MR. KING: What I am wondering is, when we think about how
ACNW might give its input, if there were some record of, ah, here are
the lessons that we learned. Here is the evaluation. Here is
somebody's comments, outside comments on the research. Or here's the
Staff's take on what we learned. Is there anything like that written?
MS. TROTTIER: There is a transcript. But you're really
looking for more than a transcript.
DR. HORNBERGER: A transcript --
DR. GARRICK: We're looking for an evaluation of the --
yes.
MR. OTT: We need to back off on that a little bit. The
decommissioning workshops, we had transcripts for.
MS. TROTTIER: Right.
MR. OTT: The research program reviews, we did not.
MS. TROTTIER: I know that. We did not.
MR. OTT: We did not have a transcript for those. It was
our intention for the Sandia workshop to put together a summary. Our
intentions were better than our performance and we didn't do that. I
don't know if you did that for --
MR. NICHOLSON: We did put a short summary together.
MR. OTT: Tom put a short summary together for the
hydrology workshop. So the first one, our intentions were great. We
didn't quite follow through. We've begun following through on
hydrology. Hopefully, the next time we'll have our act together and
we'll have a good written summary after the conclusion, sort of learning
this process as we go along and trying to get, you know, more input into
the program.
Our primary reason for not having a transcript was to not
have it be a detriment to open flow of information. And there were
people there from other Federal agencies that have licensing
responsibilities and all the rest of that. And they won't necessarily
say things on the public record that they will if it's not recorded. So
we deliberately did not do that. And any summary would necessarily, not
necessarily attribute views to individuals to individuals as much as
views to discussion or summaries of the discussions that went on.
DR. HORNBERGER: Believe me, I don't want to read a
transcript of any of these anyway.
[Laughter.]
DR. HORNBERGER: That wasn't my point.
MS. TROTTIER: Right.
DR. HORNBERGER: But if there is a summary, for example,
that Tom has prepared, it would be very useful for that to be provided
to ACNW. It would also, to tell you the truth, be useful, I think, to
us -- you have your solicited input from outside experts who attend
meetings at technical conferences. And I understand that this is all
done in the hallways for the most part. Nevertheless, if your people
write a trip report when they come back from such things, particularly
if the trip report says, yes, in the discussion this is an issue that
came forward, these kinds of things I think would be useful to us to
see.
MS. TROTTIER: Okay. We can do that.
DR. HORNBERGER: Anything else?
DR. GARRICK: No.
MS. TROTTIER: Thank you.
DR. GARRICK: Thank you. We're right on schedule -- unless
there's another presenter. You don't have another presenter?
MS. TROTTIER: No.
DR. GARRICK: All right. Then we are right on schedule,
and our agenda says at this point, we have a break and we'll take that
break right now.
[Recess.]
DR. GARRICK: Could we come to order, please. Our next
agenda item is on rubblization and the committee member that's gonna
lead the discussion on this is Dr. Wymer. And I guess Larry Camper and
Larry Pittiglio are going to conduct the briefing.
DR. WYMER: Well, you just stole my thunder.
[Laughter.]
MR. CAMPER: That's it, huh?
DR. WYMER: So please proceed.
MR. CAMPER: Well good afternoon. It's a pleasure to be
with you again. And we're going to cover with you this afternoon a
concept on this rubblization. And it is interesting and challenging
concept.
The license termination rule went into effect in August of
1996. That rule established criteria in Part 20, Subpart E for
restricted and unrestricted release of sites and unrestricted released
in 20.1402. And now the Staff is implementing that rule. And we find
that license termination plans are coming in. Concepts are emerging
from industry to fulfill the requirements of the rule. And what we're
going to discuss with you today is one of those concepts.
I emphasize that it's a concept because we don't have an
application yet, and therefore it's, it's somewhat difficult to talk
about the specifics of a particular application, perhaps to go into a
meaningful discussion in terms of quantitative data and things of those
nature. But the concept is coming and there will be variations of this
concept, we believe. So I think that there are two very valuable things
that the Committee can do for us at this juncture.
One is, having reviewed the paper and these slides, if you
have major observations or thoughts, concerns about the concept, the
approach, or the approach the staff is taking, it would be interesting
the hear those.
And probably more even more important would be, given that
the Staff does not believe that there's a policy matter here, rather
there is a concept and informational issue here -- which is why we
prepared the Commission paper -- if you have thoughts that might aid us
as we review applications and go about the concept of rubblization, that
would be of great value to us.
Rubblization -- what is this term? -- which, by the way, no
one can agree upon how to spell.
[Laughter.]
MR. CAMPER: -- simply stated, it's the demolition of
concrete structures combined with the use of some or all of the
resulting rubble as on-site fill. Next slide.
We do, as I pointed out, believe that this is an
implementation issue rather than a policy issue, but we have prepared a
Commission paper for the Commission's awareness. We want to do this
because it is controversial in nature. If you had the opportunity to
review the Commission paper, you'll note that it contained a number of
enclosures. The enclosures cover a broad spectrum of views. Some for;
some strongly against, and some in between.
What I'm sharing with you today, of course, is the Staff's
views as presented in the Commission paper. Obviously we will see what
the Commission has to say about it in the near-term.
One of the things that makes this concept somewhat sensitive
is that it was not specifically considered within the statements of
consideration. But as the Staff points out in the paper, we believe
that it is consistent with the license termination rule and would be an
acceptable means for meeting the license termination rule, provided
obviously that the conditions of the rule are satisfied.
Rubblization concepts applies to contamination concrete
buildings, primarily at reactor sites, although they would not have to
be limited to reactor sites, but primarily reactor sites. Removing
equipment from the buildings, obviously in the early stages of
dismantlement and decommissioning.
Decontaminating the building surfaces using scabbling or
some other means. These building are primarily the turbine building,
the reactor building, spent-fuel building, and some auxiliary buildings,
and demolishing the above-grade part of the structure, which is going to
then create rubble materials ranging from gravel size to very large
blocks. It's going to result in a very heterogeneous mix of
contaminated and non-contaminated materials. Next slide.
The next step then is to place the concrete rubble into the
below-grade structure. Perhaps three walls would be left standing, and
some of the approaches as they were being put in below surface. Grading
the site to a restored condition.
And in couple of minutes Larry particularly is going to show
you exactly what that looks like. This is the classic green field
effect, if you will. It will involve modeling, how the licensee will
consider these elevated areas of contamination, the fact that it's a
heterogeneous mix, possible intruder scenarios. And this may vary from
licensee to licensee. It probably will, and they have the capacity to
propose different models.
It means satisfying the license termination rule -- i.e., 25
millirem and ALARA; all pathways considered. And there will probably be
variations on this theme. Next slide.
A number of issues or considerations had emerged. Some of
them were controversial, resulting from a number of stakeholder
concerns. The papers, issues papers are contained within the Commission
paper, and I'll come back to those key issues in a couple of minutes.
Leaving rubblized concrete on-site is not new. Similar
approaches were taken at Shoreham Nuclear in Ft. St. Vrain, and the
large concrete blocks were left on-site.
The sites were subsequently released for unrestricted use. However,
there are new aspects under the rubblization concept. Those being,
placing the rubblized concrete below grade structure and below grade
structure; demonstrating compliance with the 25 millirem per year, which
wasn't in place at the time we released the earlier sites that I
mentioned; and higher levels of residual contamination.
Now, the higher levels of residual contamination is one of
the more sensitive issues of the concept. These values can be several
times higher than the building occupancy scenario using the D&D. Those
values were published in the Federal Register notice in November of
1998. So the licensee would decontaminate up to a point, and the values
may be higher, may be higher than would be the values in the table that
I cited in the Federal Register notice. Next slide.
NUREG 1496, which is the generic environmental impact
statement in support of the radiological criteria of the license
termination rule at nuclear facilities did not specifically address the
concept of rubblization. However, the Staff believes that there is
encompassing language within that GEIS, and we point that out in the
Commission paper, that gets at the concept of recycling and the doses
associated with recycling. And we believe there's an adequate level of
conservatism built into the GEIS to address this type of approach
because of dilution and so forth of the material.
The licensee of course though will have to identify and
address possible exposure pathways. These can be groundwater
considerations, resident farmer consideration, and possible excavation.
And we'll have to develop intruder scenarios.
There is a need for guidance for dose assessment modeling.
We have not yet received an application. We've not yet reviewed
conceptual models. Therefore, the Staff is going to have to develop
guidance along the way as we receive these, and we plan to do that as we
go through a case-by-case review.
There are two big things that drive this concept for the
industry -- that being, a reduction in the volume of low-level waste.
The point is that walls would be scabbled to a certain point. Somewhat
higher levels of residual contamination would be left behind; therefore,
there would be overall less material to be removed and taken away to a
burial site.
And there is substantial potential cost savings. The Staff
includes in the Commission paper, or will include in the Commission
paper, an example of what those savings might be. The value is
somewhere on the order of $8- to $16 million per site, so there is a
substantial economic driver in this for industry. Next slide.
There are a number of stakeholders. We did hold a public
workshop recently in August, and there was a session during that
workshop on rubblization. We did that because we wanted to afford an
opportunity to get direct input from stakeholders. And there was a lot
of dialog.
The stakeholders, the most viable stakeholders or the most
readily apparent stakeholders that we have identified thus far are NEI,
utilities, the public, environmentalists, states, Federal agencies -- in
particular, EPA -- and low-level waste compacts. Now the issues papers
that are included within the draft Commission paper includes issues
papers from NEI, from the Sierra Club, and from the State of Maine.
There are two letters from the State of Maine. We have nothing in
writing at this point from EPA. We have a verbal indication of EPA's
concerns, and the concern that we've heard expressed thus far is whether
or not this type of site would require a RCRA permit.
We did have a meeting with EPA last week on some other
issues, and at that time they indicated to us that they would try to
provide us with a one- to two-page summary expressing their concerns.
And if we can get that in a timely manner, we will include that in the
paper as well. If not , we'll provide it to the Commission as an
addendum to the Commission paper.
DR. HORNBERGER: Larry, could I interrupt for just a
second?
MR. CAMPER: Sure.
DR. HORNBERGER: RCRA would apply even if there were no
hazardous materials other than radionuclides? That's EPA's
interpretation?
MR. CAMPER: Yes, because of the concrete and the water
leaching through the concrete and that type of thing.
DR. HORNBERGER: But nothing but, besides radionuclides to
lead to contamination?
MR. CAMPER: I believe they have, they've really not
articulated fully their concerns. They've only indicated to us that
they believe that this type of approach may warrant a RCRA permit.
They've really not been specific on that point. We would love to get
more of an articulation, frankly. And we hope that we will.
So the issues papers that are contained within the
Commission paper support the number of a concerns. What we've tried to
do in this particular graphic is to cull out the big ones, the first
being ALARA. There is some concern that the approach would not be
ALARA. Leaving some material behind is not consistent with ALARA in the
minds of some. Now the Staff intends to review these applications on a
case-by-case basis, and we will be looking closely at the ALARA
consideration.
I think that that fundamental question that you get into
when you look at ALARA -- there are really two. How far do you go in
scabbling? How much material is left behind? And does that seem
reasonable, considering the fact that costs to do further
decontamination, given that you're already in the dose range of 25
millirem or less and it costs a lot of money to do decontamination.
And if you compare that to the value of $2,000 per person
rem averted exposure, you can readily see that you can spend a lot of
money very quickly in reducing that exposure only a very few millirem,
if any. So I think that's going to be a challenging issue for the
licensees and it's going to be a challenging issue for the Staff. And I
think that's probably going to be one of the biggest challenges that the
industry and the NRC faces as we look at these. DG-4006 does address
the ALARA concept. It provides guidance for licensees to follow as they
go about dealing with this issue.
There's a concern by some that this approach would represent
a departure from previous practice -- i.e., take away as much material
as you can. We have had sort of an operating philosophy, if you will,
that we would remove all possible radioactive material.
However, the Staff looks at the license termination rule,
which contains now a dose-based standard which says 25 millirem an
ALARA. And that seems to imply that some material, albeit small
quantities, could be left behind. And therefore, we believe that the
approaches can be consistent with the license termination rule, but
there are those that are concerned that it is a departure from previous
practice.
There's also the concern in the minds of some that this is
equivalent to a proliferation of low-level radioactive waste burial
sites, that there would be multiple sites across the country -- where
there were previously operating reactors, now there are piles of rubble
buried beneath the surface that contain trace amounts of radioactive
material, or minor amounts of radioactive material. And the question
that is asked, isn't that really the same as a low-level waste burial
site?
And another question that gets asked: Isn't that really the
same as a low-level waste burial site? Another question that gets asked
is, does that warrant the Part 30 license? Or, isn't this really a Part
61 type of activity.
The Staff, as we stated in the draft paper, doesn't think
so. We think there's a distinct difference between relatively small
amounts of radioactive material being left behind, consistent with the
dose-based standard in Part 20, Subpart (e), versus operating a
low-level radioactive waste site license under Part 61 to receive
materials from other licensees and so forth.
The first three points -- ALARA, departure from previous
practice, proliferation of low-level sites -- are somewhat philosophical
in nature, as opposed to being purely technical in nature. But be that
as it may, they are issues that the Staff has tried to address in the
paper, express our thinking on and will continue to deal with, I'm sure,
as we interface with licensees, possible hearings, and that type of
thing.
The last point is that there is a feeling by some that there
is a potential conflict with the proposed initiative on control of solid
materials. Again, the staff, at this juncture, draws a distinction
between release or control of release of solid materials at operating
facilities versus release for unrestricted use in a site that is
undergoing license termination. However, we think that this point will
need to be clearly addressed in the statements of consideration for the
control of solid materials initiative, should that initiative come to
rulemaking.
Next slide. So, how are we trying to deal with this? We've
been talking about it a lot amongst ourselves; we have been interfacing
with industry on it; we have discussed it at great length within the
decommissioning board; and we are preparing a Commission paper to make
the Commission aware of this emerging concept.
We don't believe that there is a policy issue here, which is
why the paper is structured as an information paper. We believe that
the approach provided for licensee clearly demonstrates satisfying the
criteria the License Termination Rule is an implementation issue. But
because it is controversial and because there has been some concern
expressed, for example by the State of Maine, we believe that we need to
be very sensitive to those concerns and we want the Commission to be
aware of those issues; and should the Commission have some concern and,
of course, tell the staff as to what those concerns would be, then we
would make modifications accordingly.
Now, this concept rubblization is the first of these types
of concepts, but there will be others and there will be variations to
rubblization. But -- and I think that the staff will continue to keep
the Commission informed along the way, if there are sensitive and
controversial approaches that emerge. We, also, stated in the paper
that prior to approving the concept of rubblization in a given license
termination plan, review, and approval, we would inform the Commission.
We're going to do a case-by-case review. Given that there
is no guidance currently on this in particular or given that there is
still some modeling issues to be thought about and worked through, it
may be a little bit slower process, as a result of that. But until such
time as we get some of these, can see how it actually goes, what is the
actual submittal to us, we'll have to do these on a case-by-case basis
and develop guidance along the way.
The licensee will have to meet the License Termination Rule,
obviously. The licensee will need to clearly demonstrate that they've
satisfied ALARA and that they've met the 25 millirem and ALARA standard.
If they do, as we expressed in the draft Commission paper, the staff
believes it would be appropriate to approve the concept.
I mentioned we are informing the Commission, at this point,
as to how we want to proceed and why. We'll keep the Commission
informed along the way, as we gain additional experience and knowledge
with the concept, and we would go to them on each specific approval.
Larry is going to -- Larry Pittiglio, and I think most of
you know Larry. Larry is an engineer within the Division of Waste
Management in my branch. Larry is the project manager for the
rubblization paper. He's been very involved from the beginning. He is
the author of the paper. He has been actively involved in the
discussions and presentations. And what he is going to try to do now is
sort of put this into some pictures for you, which I think helps to see,
and then I'll come back and make a few summary comments.
MR. PITTIGLIO: The first picture you see is simply a
picture of the Maine Yankee facility. That's the way it is today and
that's the way it looked when it operated. But, it's just a
presentation of the facility.
This next picture I'm going to put up is what the facility
will look like with rubblization. Basically, the licensee, in a
proposed decommissioning or license termination plan, had committed to
green field the facility. That meant removing of all the structures.
So, that's an artist type conception of what the facility would look
like after decommissioning is complete.
This particular picture right here shows the containment.
The red represents the concrete part of the structure. As Larry had
mentioned, in the rubblization approaches that we've seen, all of the
equipment would be removed from the facility and the above-grade part of
the structure would be knocked down and rubblized and placed into the
below-grade structure.
Basically, the over piece that I just set on it is what you
would see below grade. That would be what would remain. The blue
represents the concrete shelf filled with rubblized concrete material.
That would be between three and ten feet below grade, depending on the
approach. And the green field picture is really what the site would
look like as it's regraded.
What is rubblization? We just have a couple of construction
pictures to show you. That's typically what rubblization is, variation
in chunks of concrete. This particular picture just shows a building
being knocked down, the rebar. What we'll see, as far as a proposal,
whether it be large pieces of rubble with rebar or granular sizes, we
don't know. The concept allows significant variation.
And, again, I just have one more construction picture to put
up. Again, that's just some more rubblized concrete.
MR. LEVENSON: It looks more like destruction than
construction.
SPEAKER: It does, doesn't it.
DR. GARRICK: The size of that rebar is considerably smaller
than the containment rebar.
MR. PITTIGLIO: Yes.
MR. CAMPER: So, in the final analysis, you'll see that this
concept is interesting; it's challenging; it's somewhat controversial.
It is the first of many, as I've mentioned, to address the License
Termination Rule. The staff believes that we have a dual goal. One the
one hand, we need to be performance oriented and risk informed, as we
evaluate this concept, and we do believe that it is consistent with what
we interpret it as a performance oriented rule; yet, we have to ensure
that we satisfy the specific criteria of the rule -- i.e., 25 millirem
and ALARA.
There are a number of technical and policy issues to work
through. We've identified those with an attachment and we'll address
those as we go along case-by-case. And we may see this as early as the
Maine Yankee LTP, which we actually anticipate getting very soon now.
There has actually -- there's been talk of us receiving it in November.
I notice representatives from Maine Yankee are here today; perhaps, they
can give us their current thinking and time line. But, it is coming
very soon. And so, that is why we feel a sense of urgency in getting
your perspectives and we do appreciate you putting us on your agenda.
And we feel a sense of urgency, obviously, in getting the Commission
paper up to the Commission and their staff, so that they can take a look
at this, because we will be dealing with it in real time, in a real
case, we think, very shortly.
So that's all of our formal comments. We'll be happy to try
to entertain your questions and hopefully have some good answers for
you. Thank you.
DR. WYMER: John, do you have any questions? Comments?
DR. GARRICK: Well, yeah, a little bit. What can you say
about land use for the option of rubblization?
MR. CAMPER: Well, the approach that is being proposed is
unrestricted use. As you know in Part 20, Subpart E, there are two
pathways that a licensee might follow: restricted use or unrestricted
use. This is being envisioned -- this is envisioned under unrestricted
use.
DR. GARRICK: Well, suppose somebody wants to build a big
facility, where it's required that they dig into the rubble. Is that --
does that present any unusual problems?
MR. CAMPER: It doesn't present an unusual problem, but it
does present a problem, in that the licensee is going to have to
consider intruder scenarios, including excavation or possible excavation
of the site; subsequently, someone coming in and removing the rubble and
deciding to turn the remaining three walls into some type of living
quarters. Therefore, there is an occupancy consideration that will have
to be considered. There is intruder scenarios that will have to be
considered. There is the resident farmer scenario that will have to be
considered. And we will be expecting the licensee and, in turn, we will
be reviewing for adequacy all of those kinds of considerations.
Because, I mean, obviously, if it's released for unrestricted use and a
number of years go by, no one can truly predict what will be -- this
land will be used for. So, we have to consider those kinds of
contingencies, at this point.
MR. PITTIGLIO: And we have identified that in the
conclusion section of the Commission paper as a recommendation.
DR. GARRICK: But, I don't know. Something -- you're
complying with the License Termination Rule, but not with Part 20,
necessarily.
MR. CAMPER: The License Termination Rule is part of Part 20
--
DR. GARRICK: Well --
MR. CAMPER: -- Part 20(e).
DR. GARRICK: But, you're not required, as I -- I thought I
heard you say you're not required to comply with 20 Part 2.002 or
whatever it is.
MR. CAMPER: Well, the staff believes that 20.2.002 is not
applicable, because that part states that you may request approval to
dispose of a material by a means not authorized by the regulations. The
staff looks at Part 20, Subpart E, the License Termination Rule, which
has 25 millirem and ALARA, and interprets that to mean that the
Commission intended that some material could be left behind. Therefore,
in this concept, I'm not seeking approval to do something that's not
inherently authorized from the regulation.
DR. GARRICK: Yeah. When you get an application, are you
going to ask for risk cost benefit type of analysis of alternatives?
MR. PITTIGLIO: Alternative?
DR. GARRICK: Alternative to rubblization?
MR. PITTIGLIO: No, we would not. We would -- the only
thing in the cost benefit side of the analysis would certainly be the
ALARA part of it, to demonstrate ALARA. But, if the licensee elects to
present one and one only approach, rubblization, we would review it and
make a finding. But, we're not asking them to come in with other
options and other costs.
DR. GARRICK: Do you have a sense of what the risk benefit
of this approach is versus hauling the stuff away, considering the
scenarios that would be involved with both cases?
MR. CAMPER: No, not specifically, because, again, we don't
really have any specific applications that we could, you know, turn the
numbers on and crunch the data; so the answer really is no.
As I pointed out in my comments, I believe that one of the
toughest parts of this is going to be for the licensee to make the
clear, logical argument that it is ALARA. It's not to say that it can't
be done, because I think that it can be. But, that's going to be
something they're going to have to do.
Now, there may be other alternatives. What you're -- the
essence of your question really gets at, there may be various means for
satisfying the rule versus carrying the material away.
DR. GARRICK: Right.
MR. CAMPER: There's occupational exposure involved in that.
There's other possible exposure due to transportation, so forth and so
on. We have to look at that generically along the way.
DR. WYMER: Doesn't one of the decommissioning modules
require alternatives?
MR. PITTIGLIO: No.
DR. WYMER: Yeah, it does.
MR. PITTIGLIO: The other part that's important to point out
is that the rule, not only does it say ALARA and 25 millirem, it says
you should reasonably represent the conditions of the site, at the time
the license is terminated. If the licensee is clearly committed in the
license termination plan to -- and made the statement that we -- the
buildings will not be left standing, that we intend to knock the
buildings down, that, to me, indicates you need -- that's a condition
that's going to exist or reasonably represent the site, at the time the
license is terminated. And I think it's one direction why they're going
-- if they elect to go to rubblization, one, they committed to take the
building down and then, two, they are even in the cost of filling in the
hole is significant savings by using the rubblization concept.
DR. WYMER: Well, either you or me or both of us need to
reread the modules, I guess.
MR. CAMPER: What module are you referring to, sir?
DR. WYMER: I don't remember which -- I don't remember it by
name. There's too many of them. But, I just read through them very
recently and one of them called for alternatives.
DR. HORNBERGER: Did EPA indicate that the four millirem
groundwater standard would be -- groundwater protection standard would
be -- have to be met? And even though that might not be your direct
responsibility for license determination, it might be very critical to
an evaluation.
MR. CAMPER: Well, much -- even though much more broadly
than rubblization. I mean, the difference that exists between the
positions, in our case, a rule -- the 25 millirem all pathways versus a
position, if you will, derived from risk-based regulations that result
in the 15 and four. EPA has never said to us, specifically in the
context of rubblization, these licensees are going to have to meet the
four millirem groundwater consideration. No, they've never said that to
us. But, clearly, we are concerned about that and, frankly, so are the
licensees.
We have a lot of discussions with licensees that are worried
about that very issue. And every time we get an opportunity, either
myself or John Greeves, the Division Director, we express our concerns
about finality. And, ultimately, that issue needs to be resolved.
It's, we think, beyond our capacity to resolve it, certainly in the
context of this particular issue that we've discussed. But that is a
major issue that, at some point, will need to be addressed. But, it's
far beyond just rubblization.
DR. HORNBERGER: Yes, it is. I recognize that, obviously.
Now, let me just rephrase it, to make it an easier question for you.
MR. CAMPER: Sure.
DR. HORNBERGER: Have you looked at -- or has anyone looked
at any calculations? And I realize you don't have a specific
application, but just in a general sense, as to whether or not such a
standard -- a four millirem groundwater protection standard would,
indeed, cause problems for things like rubblization. No one has done
the calculations or anything?
MR. CAMPER: No, not -- not that I'm aware of, no.
DR. HORNBERGER: That's all I have.
DR. WYMER: Milt?
MR. LEVENSON: I've got a couple of questions, again,
primarily for clarification. On page two, where you say, "removing
equipment from the buildings," does the concept, as it stands now,
permit --
MR. CAMPER: Excuse me, are you in the slides or the paper?
MR. LEVENSON: The slides.
MR. CAMPER: Okay; thank you.
MR. LEVENSON: Removing the equipment from the building, is
the implication that no metal debris will be allowed to be part of the
rubble? Because if the answer is yes, then what do you do about rebar?
And if the answer is no, can small pieces of equipment, also, be buried
there?
MR. PITTIGLIO: The proposals that we have discussed clearly
had the equipment and structural -- major structural steel components
removed. Whether or not the rebar will be left in the concrete is an
issue that we'll have to look at on a case-by-case basis and it probably
is related to the size of the component. For the proposals that we have
seen, where the rubble material was a gravel size, obviously, the rebar
is removed. For other conversations we've had, where components could
weight four or five tons, it may well be that the rebar will be left in
place and the concrete will be cut into a large box.
The paper addresses the concept. Certainly, there is many,
many different combinations. There may be a combination of gravel and
large box. We don't -- we haven't had an application and we don't know
what we'll get, until we receive them. And it's highly probable that if
we get more than one, they'll be different.
MR. LEVENSON: At the moment, then, the concept either
includes nor excludes things other than concrete, namely metal?
MR. PITTIGLIO: Right; that's right.
MR. LEVENSON: Because the next piece after the rebar, the
picture you showed, is the steel liner of the containment building at
the below-grade part. Your concept, that has to be removed or is that
just additional --
MR. CAMPER: Well, in the industry's concept that has been
proposed, in conceptual space, what's left behind, what has been
discussed is concrete, possibly rebar, but no steel liners and no metal
equipment. And there are people here from industry, who could address
that probably even better than us. But, that is our understanding, that
it would be limited to concrete, possibly rebar.
MR. PITTIGLIO: However, one of the recommendations that we
did make in the paper, for the shell that remained in place, to which
the rubblized material was inserted, that it be addressed as building
surface contamination limits, unless the licensee can come in and
clearly demonstrate that it would not be reused as a building for some
-- at some time. I don't know if that helped or not.
MR. LEVENSON: On the question of radiation, the exposure in
ALARA -- I'm a little confused by some of the things you said, because I
had never heard ALARA being applied to some potential low probability
exposure in the future. I've always heard it applied to exposure in the
here and now. And so, doing the ALARA for this, you're going to have to
include all of the exposure of the people doing the waste disposal, if
you ship it off site; is that right, handling the burial ground people,
etc.?
MR. CAMPER: Cheryl, you were shaking your head there?
MS. TROTTIER: Actually, I think our analysis simply
requires them to do basically a cost benefit analysis on their choice of
decommissioning option. If that means that they're going to ship
material, then that part needs to be considered. But, they're not doing
an ALARA analysis on what's happening at the low level waste site. The
ALARA analysis is the cost to meet a certain value compared to the
$2,000 per person rem. I mean, that's the base line. In other words,
if it costs significantly more, then that's part of their decision
process.
MR. LEVENSON: Well, that's my understanding of it, but
there was some implication that the residual 25 mr in exposure of future
people might be part of the ALARA analysis and I didn't understand that.
Maybe that wasn't intended.
MR. CAMPER: Well, Cheryl -- Cheryl is the branch chief of
Research and was involved with the rule when it was written, which is
why I deferred the question to her. So, Cheryl, do you want to add to
that?
MS. TROTTIER: Calculations, if I remember correctly, are
basically a thousand year calculations, but the site use can be the kind
of use you would expect at the time you terminate the license. You
don't need to hypothesize what society will be doing a thousand years.
You could assume they're doing the same thing today that they're going
to do a thousand years from now. But, the actual dose calculations are
supposed to cover that time period, not beyond.
MR. LEVENSON: Cover -- the hypothetical one is a thousand
years out on site and don't cover the very real doses that people get
this year at a waste disposal site handling the material?
MS. TROTTIER: Now, in order to meet -- this is not the
ALARA analysis. This is demonstrating that you meet the rule --
MR. LEVENSON: Yeah, okay, that's --
MS. TROTTIER: -- the modeling you do for that.
MR. LEVENSON: -- that's specifically about the ALARA.
MS. TROTTIER: Yeah. I don't believe to do the ALARA
analysis, that we even address that issue in the guidance that we've put
out so far.
MR. CAMPER: It is interesting, though. Your question is
interesting from a practical standpoint, because if you look at exposure
to individuals in the future, the rule doesn't say 25 millirem. It says
25 millirem and ALARA. Therefore, as a practical matter, the staff is
going to be looking to see that the licensees have decontaminated to the
maximum extent possible that's consistent with the ALARA guidelines and
cost considerations. Now, from that, one can imply that there are
implications of exposure or reduction of exposure to members of the
public in the future, not just ALARA, as we classically think of it.
And you're right, which is normally occupational work, this type of
thing. That's a really very astute question.
DR. WYMER: I have several comments and then a couple of
specific technical questions. And you have to realize that we're very
new to this rubblization concept.
MR. CAMPER: Well, so are we.
[Laughter.]
DR. WYMER: That's my excuse; because I want to say, if I
say something that's obvious or stupid, you want to give us some leeway
here.
The comments relate to things that you already addressed,
but I think they're important enough to stress. One was that this
probably is precedent setting and it probably will be extrapolated into
areas that are not presently anticipated. There will be some clever
people out there saying this is just like rubblization; therefore, we
can do it, too. So, I think it's worth stressing that you need to be
very sensitive to the fact that you're setting a precedent here very
likely. You know that and you've already alluded to that. But, I felt
it was worth stressing.
The other thing is that, to my mind, at least, the line
between rubblization and low-level waste disposal is very blurred. If
you're to take this concrete and can it up and send it off to Enviro
Care, it would be a low-level waste disposal issue. You're leaving it
on site and you're calling it something else, that's all, and you're
alluded to that, too. But, it is a pretty darned blurred line. So,
those are the two general comments.
Specifically, in most of what I've seen written, what little
I've had a chance to read so far, you're addressing primarily
radioactivity from neutron activation of constituents of a reactor
containment vessel. There are other kinds, as I'm sure you know, of
possibilities of containment of the structure. For example, the storage
pool, you could have some leakers that are going to be contaminated and
it's not activation products, it's fishing products, actinites. And
there are other kinds of facilities, other than reactors. But, I grant
you, reactors are certainly the big ones right now.
But some specific technical questions: how in the world
will you go about measuring the bulk contamination that you have in this
concrete -- this rubble that's being pushed into a hole? I noticed, we
heard from the research people, they're going to take a look at this
over the next couple of years and it seems to me, that's a really -- a
really tough issue, unless you get into some fairly detailed analysis of
that stuff, and the whole idea of rubblization is to -- one of the ideas
is to reduce cost, so you don't get into a lot of additional work. So,
the measuring of the bulk contamination seems to me to be an important
issue.
And then in the modeling business, how in the world are you
going to evaluate the leaching behavior of this porous material that may
be shot through with rebar that's activated and it will rust and leach
out? How will the leaching be addressed? You know, this is not a
trivial question, I don't think, that again requires more input than
would be -- the people will likely be ready to provide. Those were
essentially the technical list.
MR. CAMPER: Let me try to address a couple of your points,
the first one being -- you know, we have moved into an era of much more
emphasis upon performanced-based risk informed regulation, and that's a
positive thing. I think most of us would agree with that. But, it does
present a number of challenges to the staff, as licensees go about
identifying approaches that are performance oriented.
This is something that I often talk with our staff about.
We -- in this case, it's rubblization; there will be others. We're
going to have to devote a fair amount of intellectual energy into
addressing various approaches that are performance based. And that will
be -- as you said, there are clever people out there and they will come
up with some unique concepts that none of us have thought about yet.
DR. WYMER: I'm sure they do.
MR. CAMPER: And the staff will have to deal with them one
at a time, as they come in the door, and take the lessons learned and
put it into guidance and hopefully improve the process along the way.
But, that's what it means. That's one of the things that happens, as
you move into performance-oriented regulation. And that's the challenge
we face and we're going to have to do the best we can to meet it.
With regards to measuring bulk material, the idea is that
these walls will be evaluated and characterized, if you will, following
like a MARSSIM type approach, prior to demolition and burial.
The leaching issue, you're absolutely right. The modeling
considerations with this are a challenge. Leaching is one of those.
There are others. But the licensees are going to have to do a thorough
and adequate job demonstrating modeling and dose assessment to us and
we, in turn, are going to have to do a good job at evaluating it and
ensure that's acceptable. But, you're right, that is a challenge.
And as I mentioned in my comments, to, it may slow down the
process. I mean, you know, like everything else, you know, there's a
good and a bad. I mean, the good is that their licensees are trying to
find ways to have more flexibility, introduce you to new concepts. The
downside of that is since you're not following a purely prescriptive
predefined approach, the staff will have to wrestle with that. They
will have to work its way through it. That may take time. That may
require some further communications with the Commission along the way.
But, that's the trade off. But, your points are on the mark.
DR. GARRICK: In many ways, this is a very interesting
concept, because it does attempt to simplify rather than complicate the
process of waste management. And we don't see enough alternatives that
do that. We're always seeing alternatives that require more processing,
more treatment, more handling, and what have you. So, if this is a
concept that really can work, it could have really far reaching
implications, given the number of sites that we're talking about.
Given that I would think that one of the institutions of
industry, like the Electric Power Research Institute or INPO or Edison
or somebody, would have provided an analysis -- or the NRC or DOE or
somebody would provide the analysis that would make it clear what the
case is for rubblization. And yet, we sort of are sitting here saying
that let's wait until we get an application and then we'll put the total
burden of that question on our first applicant.
Something here doesn't quite hang together. You're talking
about a new concept of waste management and it's pretty dramatic and
it's a total consideration. And yet, there does not seem to be a case,
from a technical standpoint, for why we should do this. And the answer
seems to be, well, we're going to wait until the applicant comes in and
then we're going to beat the hell out of him, until he gives us what we
want.
MR. CAMPER: I didn't say that.
[Laughter.]
DR. GARRICK: So, I'm surprised that the case for
rubblization, it hasn't been advanced. And I'm critical of both
industry and government for not providing that, given the implication
here, which seems to be -- which could be significant and it could be
very much in the public's interest to go in this direction, if a real
genuine risk-based and cost-based analysis was performed.
MR. CAMPER: Well, let me take an attempt at trying to
answer your question or your comment and, certainly, I can speak to it
from our side. In the decommissioning arena, we have a lot of activity
going on. There are a lot of sites being decommissioned. The staff is
working feverishly to provide all the guidance that is necessary to
implement the LTR, whether that be DG40006 or the standard review plan
or working within our NUREG 1700 and so forth. We have been spending
the mainstay of our energy in dealing with actual case work in
decommissioning sites.
Now, we have LTPs coming on line. In fact, we actually have
an LTP in house right for the reactor site. So, we're using the staff
that we had to deal with actual casework or develop or refined guidance
of a generic nature. We simply don't have the resources to put into
further analyzing or creating the type of scientific data that we'd all
like to see for this particular concept or for others that might come
along. We really have no choice but to deal with them, as they present
them to us. Because for one thing, while we believe there's a pretty
high probability that we're going to a rubblization application. We
don't know that for sure. We think that's the case. We believe that to
be the case, but we don't know with virtual certainty. So, we just
don't have the resources to do that.
With regards to industry, and there are industry
representatives here who can speak on their behalf far better than I,
the industry has, at least this point, given us an issues paper that
expresses their position. NEI, for example, has a paper within the
Commission paper, but that's certainly not the type of analyses or study
that you're alluding to, obviously, and I don't know what inclination
the industry might have to do more on those lines.
Paul Genoa of NEI, if you want to comment on that, or other
members of the industry.
DR. GARRICK: Please give your name and affiliation.
MR. GENOA: Yes. My name is Paul Genoa and I represent the
Nuclear Energy Institute and, in fact, was involved in both the
presentation on the rubblization issue and helping to shepherd an issue
paper on rubblization. And my comment would just be that, you know,
this is brand new and we are right at the -- right at the inception of,
you know, what these different concepts could be and so we provided the
paper in that context. We haven't even scoped out all the different
specific ways you might approach this to lay out a detailed analysis,
like you suggest. That could happen; but as often as the case, if we
wait for the research to be done, the people who are actually want to
use this approach, the licensees, may be ahead of us. In this case,
they are. I think it's very likely you're going to see a concrete
example of a rubblization approach sooner than we would get a generic
approach together for you.
MR. PITTIGLIO: And in all honesty, I'm not sure that we can
develop generic guidance that would cover the number of spectrum of
potential cases under the rubblization concept. We've certainly --
DR. GARRICK: Well, if you could do it just for reactors,
you would have done a major thing. In other words, if you just picked
one specific facility type -- there are facility types that represent
the billions of dollars of decommissioning costs. So, as far as
wouldn't know where to start, there's probably some candidates out there
that would be a source of learning a great deal about the concept, I
would think.
MR. PITTIGLIO: Well, yeah, I agree with you. I mean, I
think the concern is that if you don't make an assumption regarding the
size of the rubblized component to support your modeling and so forth,
your analysis isn't going to be effective. Yet, if one approach uses
the component that's a sizable piece of gravel and another application
comes in with blocks that weigh between four and six tons each, the
guidance that we develop for the rubblized gravel size probably would be
of no benefit to the concept that may come in that's significantly
different, even though it is "rubblization."
DR. GARRICK: Well, that may be; but I still think that
because this has become an issue to the point it has, that somebody has
some pretty good ideas as to the benefit that they ought to receive from
this. And given that it is a concept that can be replicated many, many,
many times and, therefore, has widespread impact on the whole waste
management field, I can't think of too many things where a little bit of
analysis could have as much payoff. And that's the thing that I think
is missing here, is -- so why do you want to do this. And I think it's
-- conceptually, it's quite appealing; but I think to make a decision on
it, I would want to know a lot more about the costs and benefits and
risks.
MR. LEVENSON: John, since I'm not a member of the
committee, I'll talk a little -- I don't have to have the same limits
that you do maybe. Historically, such a thing would be handled --
DR. GARRICK: I don't have any limits.
MR. LEVENSON: -- by EPRI forming a owners group and
starting preliminary negotiations with the NRC. I don't think the
initiative is with the NRC.
DR. GARRICK: Well, that's why I --
MR. LEVENSON: I think the initiative is with the owners.
DR. GARRICK: Well, I started from that perspective. I'm
surprised that EPRI or owners group or Edison Electric or INPO or
somebody that's concerned about this issue hasn't come forward with a
more convincing case and I'm surprised that, you know, we're waiting for
the first application to really come to grips with an attempt to
quantify the impact of rubblization; but, maybe that's -- maybe that's
inevitable.
MR. LEVENSON: The first applicant may be a masochist and
wants to do it on its own.
DR. GARRICK: Well, that may be. It may postpone. Because
if I were interested, I think I would want to be at least the second
applicant.
[Laughter.]
MR. LEVENSON: Back to one comment that Ray made and flew by
very quickly, because I, also, had circled it in a letter, you refer to
neutron activated materials and, in fact, the bulk of the contamination
on the concrete and rubble and surfaces and everything else are fission
products, not neutron activated materials. And if there's some special
case for neutron activated materials or even the use of the term, I
don't understand it, because there are some isotopes that are both
neutron activation and fision products. The implication, you want
people to differentiate? I don't understand the use of the word
"neutron activated," when we're talking about removing radiation,
radioactive materials.
MR. PITTIGLIO: The first part of the paper basically dealt
with the surface contamination limits and the majority of the
contamination, we believe, exists in, from what we've seen or from
approaches that have been addressed by the licensees, less than the
first quarter inch of material, so that the scabbling approach to remove
it to a certain level and the surface contamination limits were how the
rubblization concept was addressed.
We do have some concern about activated components.
Basically, I think that when we looked at -- what we've seen is that if
the contamination is in a very surface -- the first couple of
centimeters of the surface, we're not going to have a problem with
activation in the rebar and so forth. But, we didn't want to not
identify that as a concern in the paper. That's why I think that that
--
MR. LEVENSON: I don't understand the differentiation. I
mean, the 25 mr --
MR. PITTIGLIO: That's correct.
MR. LEVENSON: -- sets the total, whether the source term is
an activated material or a fision product.
MR. PITTIGLIO: That's correct.
MR. LEVENSON: I don't understand the use of this at all. I
don't know what this -- this would tell me nothing, if I were trying to
interpret what this meant. Is this outside the limit of the 25? Do I
have to remove all activation? I don't understand it.
Norman?
MR. EISENBERG: I'm Norman Eisenberg, Division of Waste
Management. The concern is that the paper states that if you meet the
building occupancy requirement, you'll be okay for rubblization. That's
only true if all the contamination is on the surface. If you've got
neutron activated components that are deep in the walls, then that is
not the case. So that caveat was put in there just to cover that.
MR. LEVENSON: But that doesn't cover anything, because most
concrete structures have cracks and I could have stuff deep in the
concrete that's a fision product. I don't understand the
differentiation here.
MS. TROTTIER: Can I add a little clarification here? The
License Termination Rule is 25 millirem all pathways plus ALARA. There
are two scenarios that we analyzed: one, a building is left intact.
Remember one thing: NRC only requires that the radioactive material be
removed to the level that meets the rule. This is a dose-based rule.
So, what it says is, if I'm going to leave the building and walk away
from the building, the dose the person is going to get working in the
building meets the rule.
But if there is buried material, a licensee is supposed to
include that in their dose estimate, if there is a way that that can get
to the person working in the building. Now, you know, it's unlikely
buried in concrete that's going to happen, but piping and things like
that -- I mean, you know, you can have ventilation systems, etc. But,
anyway, the concept behind those values was you were leaving the
building there and then you can walk away. The building can be torn
down. But, conceptually, because of the concern of nature of the
modeling, you were going to be protective.
Then the other model, of course, is you have no building and
you are measuring soil activity for demonstrating compliance with a
farming type of scenario, because, you know, that's the most restrictive
case. But, the concept where those values that were used for the
building was that you were going to leave the building there and that
would be the dose you would get from working in the building.
MR. LEVENSON: I understand that and that doesn't
differentiate what the source of the source is. That's what this --
MS. TROTTIER: You're right.
MR. LEVENSON: -- this is confusing.
MS. TROTTIER: It does not.
MR. EISENBERG: Perhaps a better distinction would have been
whether the contamination was solely on the surface or whether there was
a possibility for components to be deep within the walls, that would
then become available for providing a source --
MR. LEVENSON: I have no problem with that.
MR. EISENBERG: -- under rubblization. But, those deep
components would only get there if they were activated components.
MR. LEVENSON: That's not true.
MR. EISENBERG: Well, there is a report that models the
fusion of fision products, primarily from the surface into the concrete,
and even with cracked concrete, the penetration was -- dropped off
dramatically with distance, whereas activation products could be several
meters in. But --
MR. LEVENSON: I don't know about the computer model. I
have been involved with the complete dismantling of a number of reactors
and I can tell you that fision product activity gets fairly deep some
places.
DR. GARRICK: Especially the volatile ones --
MR. LEVENSON: Yeah.
DR. GARRICK: -- the more volatile ones.
MR. LEVENSON: I mean, that's just the physical world. It
doesn't necessarily conform to the model.
DR. GARRICK: But, I can understand a little bit of Norm's
perspective on this; that if you didn't mention induced activation,
someone would surely ask, well, what about induced activation.
MR. LEVENSON: But, it's total activity you're measuring.
DR. GARRICK: Yes, I know that; I know that. But, I'm, also
-- I can, also, appreciate why --
MR. CAMPER: That is why the --
DR. GARRICK: Yeah, why it was culled out. It's a more
subtle source than fision product contamination.
MR. CAMPER: I was going to say, the comment was suggested
by Dr. Eisenberg's group and it was for that clarifying point. Now, if
there's a better way to say that, we still have time to --
DR. GARRICK: We now know who to blame, then.
DR. HORNBERGER: I think the more I learn about this, the
curiouser it gets. It strikes me now that you're telling me that a site
could pass the License Termination Rule with a building intact --
MR. CAMPER: That's possible.
DR. HORNBERGER: -- and fail, if they knocked the building
down and left the rubble there. You're telling me this is a
possibility?
MR. PITTIGLIO: No.
MR. CAMPER: No, I don't draw the same --
MR. PITTIGLIO: What we're saying is that first of all, the
building should be left standing. You could use site specific surface
contamination limits or you could -- if you met the screening limits,
you would have to do nothing else.
DR. HORNBERGER: Yeah.
MR. PITTIGLIO: All right, and that would meet the 25
millirem.
DR. HORNBERGER: Right.
MR. PITTIGLIO: After the license was terminated, you could
knock the building down with no argument. You could knock the building
down with no argument, as far as we're concerned, if you met those
limits. This particular concept, though, because of the way it's done
and because of the conversations we've had with those that are proposing
it, they are going to, in most cases, have a significantly higher
surface contamination number of value than would -- than our screening
or even your site specific value resulting from a D&D run for an
occupancy scenario. The reason that they wind up with that number is
because they take the contaminated surface material, place it in the
shell, and the analysis they do with leaching and so forth and because
of the time it takes for leaching, allows them to have a number that
would be higher than if they left the building in place.
DR. HORNBERGER: yeah, but it strikes me -- I understand
that, all right.
MR. PITTIGLIO: Okay.
DR. HORNBERGER: But, it's -- unless misheard, I thought
that we were just talking about if you pass the screening for the
surface contamination, you still now have to do an additional analysis,
because when you rubblize, you could have, for example, activation
products that we wouldn't have exposed, that the surface wouldn't lead
to exposure in an intact building and, therefore --
MR. CAMPER: Well, you're going to have to evaluate a number
of scenarios: intruder scenarios; the occupancy scenarios, where
someone can go back in there later and take the rubble out and occupy
the building.
DR. HORNBERGER: Yeah. No, I'm just trying to understand
it.
MR. CAMPER: I understand that.
DR. HORNBERGER: It strikes me that if you can terminate a
site with a building intact --
MR. CAMPER: Right.
DR. HORNBERGER: -- but it's still -- I haven't heard you
tell me why that same site, if they proposed to knock it down and
rubblize it, it might not pass. I'm not saying it wouldn't, but it
might not, because you're considering an additional source.
MS. TROTTIER: Can I comment on that?
MR. CAMPER: Please.
MS. TROTTIER: Part of it is making it seem too simplistic.
We have those screening models and licensees can use them, but we have a
big caveat in our guidance, if they apply. So, if you had a site, where
you think you might have some major problems internal to the building,
the staff would not likely approve someone just using a screening model.
They would want some site specific model.
And, again, there's nothing to prevent the licensee from
walking away and someone later on demolishing the building. What we
hope -- and I will say this, because this is the -- this is the risk in
performance based regulation, is the licensee has the obligation to
demonstrate that they meet the criteria and they have to do it
responsibly. You know, they are not to be hiding truth, and there's no
way for the NRC staff to go in and do thorough checks of building
interiors like this. So, it's important that the licensee, as all cases
through the licensing process, tell the truth. We rely on that. It's
the key of our program.
DR. HORNBERGER: Just to clarify, my question did not -- I
did not mean to imply, by any stretch of the imagination, that I was
talking about somebody lying.
MR. CAMPER: No, of course not.
DR. HORNBERGER: That had nothing to do with my question.
MR. CAMPER: Accurate -- she means accurate and thorough.
DR. CAMPBELL: So far I haven't heard what the key
radionuclides are; what kinds of total activity it is you're talking
about and the kinds of concentration you're talking about. What I'm
hearing for this discussion is an issue about pathways. I believe the
building standing, the exposure to someone working in the building is
probably a gamma exposure of some sort, presumably. If you break it
down into pieces, pour it all into the basement of the reactor, you
could possibly have some sort of a pond forming, containing water. You
cover -- your scenario for the site as a green field doesn't show the
covered limiting water getting into the system. So, you could have a
backup type of effect of leaching.
So, you could conceivably have a situation where an exposure
scenario, if you will, of somebody working inside a building has one
dose; whereas an exposure scenario with an intruder farming on the site,
drinking water from a well -- and a lot of these sites, and Maine Yankee
was chosen -- they're chosen because they're close to water; the water
table is shallow. These are all things that would preclude a site under
Part 61, although I will say, you know, Barnwell and the other -- and
Richland were grandfathered in; but, nevertheless, it would preclude a
site from being selected for a low level waste site for Part 61. So,
there are issues about the total amount of radioactivity, its
concentrations, what those radionuclides are and, therefore, the issue
Ray raised about speciation, it's the leachability and then the site
issues, themselves, about how much water is going to get in, how you're
going to model the leaching, and so on. So, there are a lot of issues
that are --
MR. CAMPER: Yes, they are and they --
DR. CAMPBELL: -- kind of enter into all of this discussion.
MR. CAMPER: -- all ultimately come back to whether or not
the dose criterion is satisfied. The proposal -- we've seen -- we've
talked about a number of conceptual approaches with licensees thus far.
But, the numbers of residual contamination that would be left behind, in
some cases, are several times, perhaps even on the order of magnitude,
they are more higher than the screening values. But, ultimately,
whatever those materials are that are left behind are going to have to
be properly characterized, in terms of concentrations, nuclides, and,
ultimately, whether or not this satisfies the dose criteria. It is a
dose based regulation.
DR. CAMPBELL: So, you don't know, at this point, what the
key radionuclides are, the kinds of concentrations they're talking
about?
MR. CAMPER: Well, we've not seen the application.
DR. CAMPBELL: Okay. Well, that means there are pathways
and those pathways --
MR. CAMPER: But on your bathtub effect, the answer to that
is absolutely yes. In fact, one of the models that have been discussed
was conceptually included the flooding -- flooding the rubblized
structure.
DR. CAMPBELL: Which will probably --
MR. PITTIGLIO: Which will drill a hole in shells to allow
the water to come in and put a well --
MR. CAMPER: Right.
MR. PITTIGLIO: -- on top of it.
MR. CAMPER: But, again, the issue there is 25 millirem all
pathways.
DR. CAMPBELL: Or possibly four millirem.
MR. CAMPER: Well, now, that -- again, in our regulatory
space, it's 25 millirems all pathways.
DR. CAMPBELL: Okay.
MR. CAMPER: But, yes, I mean, they're good points.
DR. GARRICK: But that's part of, Andy, what I'm referring
to, when I say it's too bad there isn't an analysis that answers some of
these questions.
DR. CAMPBELL: Well, I had written down, before you even
said an EPRI research, a question mark.
DR. GARRICK: Yeah.
DR. CAMPBELL: This is clearly something EPRI ought to be
working on.
DR. GARRICK: This is such an industry-wide opportunity; if
they really see major savings here, that you would think that somebody
would be motivated to do that.
MS. TROTTIER: I can add one clarifying point to Andy's
question. To support the 1998 decommissioning rule, we did do a GIS,
looking at the process of decommissioning for a number of facilities.
And Cobalt 60 and CZ-137 were the prime components there and I would
expect for most licensees that to be the case.
DR. GARRICK: Yeah.
DR. HORNBERGER: Oh, sure.
DR. GARRICK: Strontium, cobalt, and cesium, and maybe some
of the volatile -- more volatile.
DR. HORNBERGER: Have we exhausted this or we've exhausted
the speakers here?
MR. CAMPER: It's entirely up to you.
DR. GARRICK: When do you expect your first application?
MR. PITTIGLIO: The licensee, at one time, had indicated
possibly by Thanksgiving. Is that still --
MR. CAMPER: I was going to ask, did you want to comment on
that, Maine Yankee, as to when?
MR. ZINKE: I am George Zinke from Maine Yankee. We had
anticipated -- well, initially, we had anticipated by first of November
and, in fact, our LTP is all prepared, reviewed, and on my desk ready to
submit. We're delaying submittal, because of the controversy in what
we've been discussing and the controversy in our State over the 25,
which then brings in EPA and just a whole raft of issues that we are
trying to come to agreements with our State, as far as what the actual
condition of the site will be left. And we're trying to come to that
agreement before we submit, because if we submit prior to getting some
of those agreements, we create a real emotional contentious situation.
So, you know, we're hoping that we will submit this year, but it's --
DR. WYMER: Let me ask, is the issue of 25 versus 15
important to you?
MR. ZINKE: It's important to our State. And it's not a 25
versus 15 anymore; it's 25 versus lower numbers than that. So --
DR. WYMER: Yeah, for your State?
MR. ZINKE: Yes.
DR. WYMER: And these are -- these become important to you
--
MR. ZINKE: Yes.
DR. WYMER: -- with respect to the analysis you've made?
MR. ZINKE: Yes.
MR. CAMPER: In our discussions with various reactor sites,
the 25-15 is not a particular difficult issue, if an issue at all.
Twenty-five versus four might be.
DR. WYMER: Yeah. I was just wondering, in a practical
case, whether these things were reaching the cutoff point for you, and
you said yes.
MR. ZINKE: Yes, and it's a matter that -- you know, we've
done now cost evaluations, well, what if I have 25, what if I have 15,
what if I have 10, what if I have four, so that as we talk with the
State, we have an understanding of what it's going to end up costing us.
DR. WYMER: Some place in there, you cross the line and the
cost starts going up?
MR. ZINKE: Yeah. The cost goes up every place you keep
dropping.
DR. WYMER: It's conceivable that it wouldn't. It could be
so low that it wouldn't matter in the first case; but that isn't the
case, obviously.
MR. ZINKE: Yeah, there is -- I mean, the 25 is a limit and
so our license termination plan shows how we would meet the limit. And
in all practicality, when you scabble and when you're doing remediation,
you're going to be well below the 25.
DR. WYMER: Yeah.
MR. ZINKE: But, then, you, also, have to consider the cost
of -- you know, the samples and the surveys to prove it's lower. So, it
cost more to prove that it's lower, even if it's the same ground or the
same stuff, than it would be to prove that it's at 25.
DR. WYMER: Well, that's one of the points I made, I think,
earlier.
MR. ZINKE: Yes.
DR. WYMER: Okay.
MR. LEWIS: Excuse me.
DR. WYMER: It gets you around the ears pretty good.
MR. LEWIS: I have -- my name is Steven Lewis from the
Office of General Counsel. I wanted to try to help out on the question
that I think was posed by the Committee earlier and I didn't -- I didn't
hear the kind of answer that I wanted to totally leave you with, and
that had to do with evaluation of alternatives. The staff's position is
that the GEIS that was prepared for the License Termination Rule
encompassed within it not specifically something called rubblization,
but other types of scenarios that encompassed -- are inclusive enough to
encompass the rubblization that we're seeing now.
What I did want to assure you about is that staff is well
aware that we have to comply with NEPA in this process. For example, at
the license -- at the stage of amending a license, to approve the
license termination plan, we will have to do whatever NEPA requires of
us and the Commission may tell us, in response to a paper -- that in the
paper that we give them, they may give us some guidance with respect to
how we go about meeting our NEPA obligation. But, we are well aware of
it and that's why it's being -- it definitely will be addressed in the
paper we give to the Commission.
DR. WYMER: Which means alternatives?
MR. LEWIS: Well, that's clearly -- clearly one of the
things that we have to -- we have to make sure that everyone understands
and is comfortable with the scope of the generic environmental impact
statement that has already been done and that rubblization fits within
it. And, yes, I am speaking in terms of analysis of alternatives, yes.
DR. WYMER: Thank you.
DR. GARRICK: Okay.
DR. WYMER: Well, thank you, very much, for your
forbearance.
MR. CAMPER: Well, thank you. I'd, also, like to thank
Steve and Cheryl and Norm Eisenberg for their comments. It is a
challenging and complicated history. Cheryl has a great history of the
rule, Steve is our legal counsel, and Norm is a modeling performance
assessment guru, so I appreciate all their input, as well.
Thank you for your questions and as you formulate your
thoughts about this, again, if -- the things that you've heard today, or
there are questions we've answered, if there are things that we can have
on our scope and we're implementing and considering this on a
case-by-case, that would be extremely helpful to us. And you've raised
a lot of good points. Thank you.
DR. GARRICK: Thank you. I think the plan is that we'll
declare a short break here. And I don't think we'll need the reporter
following the break, because we're going to go into discussion of
reports and letters for the rest of the day. So with that, let's have
-- let's take a short break, a five-minute break.
[Whereupon, the recorded portion of the meeting was
recessed, to reconvene at 8:30 a.m., Thursday, November 18, 1999.]
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