Advisory Committee on Nuclear Waste 124th Meeting, January 16, 2001
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title: Advisory Committee on Nuclear Waste
124th Meeting
Docket Number: (not applicable)
Location: Rockville, Maryland
Date: Tuesday, January 16, 2001
Work Order No.: NRC-030 Pages 1-113
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers
1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005
(202) 234-4433. UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
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124TH ACNW MEETING
ADVISORY COMMITTEE ON NUCLEAR WASTE
(ACNW)
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TUESDAY
JANUARY 16, 2001
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ROCKVILLE, MARYLAND
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The Advisory Committee met at Conference
Room 2B3, Two White Flint North, B. John Garrick,
presiding.
COMMITTEE MEMBERS:
JOHN GARRICK
Chairman
GEORGE HORNBERGER
Member
MILTON LEVENSON
Member
RAYMOND WYMER
Member
ACRS STAFF PRESENT:
John T. Larkins, Executive Director
Lynn G. Deering
Howard J. Larson
Andrew Campbell
ALSO PRESENT:
Jeff Ciocco
Stephanie Bush-Goddard
Nelson
Bret Leslie, NRC Staff
Lisa Gue
Mr. Major
Carl Feldman
Bob Nelson
Paul Genoa
. I-N-D-E-X
AGENDA ITEM PAGE
Opening Remarks by Chairman Garrick 4
ACNW Sufficiency Review Application
Task Action Plan 6
Comments on the Yucca Mountain Project
Lisa Gue, Public Citizen Group 42
Entombment Option for Decommissioning Power
Reactors
Comments by Stephanie Bush-Goddard 60
Comments by Paul Genoa 98
Comments by Lisa Gue 107
Adjournment 112
. P-R-O-C-E-E-D-I-N-G-S
(10:22 a.m.)
CHAIRMAN GARRICK: Good morning. The
meeting will now come to order. This is the first day
of the 124th meeting of the Advisory Committee on
Nuclear Waste.
My name is John Garrick, Chairman of the
ACNW. Other members of the Committee present include
George Hornberger, Milt Levenson and Richard -- or
Raymond Wymer.
During today's meeting the Committee will
discuss progress on ACNW's Sufficiency Review
Application Task Action Plan, discuss with the NMSS
staff several questions related to the Entombment
Option for Decommissioning Power Reactors; discuss
Planned ACNW Reports on several topics, including the
Entombment Option, Key Technical Issue Resolution, the
Staff's Progress on Total Performance Assessment, and
the Annual Research Report to the Commission.
Howard Larson is the designated Federal
Official for today's initial session. The meeting is
being conducted in accordance with the provisions of
the Federal Advisory Committee Act.
We have received no written statements
from members of the public regarding today's session.
Should anyone wish to address the Committee, please
make your wishes known to one of the Committee staff.
And as usual, it's requested that speakers
use one of the microphones, identify themselves and
speak clearly. Before proceeding with the first
Agenda item, I'd like to cover some brief items of
current interest.
As we all know by now, President Elect
Bush has nominated out-going U.S. Senator Spencer
Abraham of Michigan to be Secretary of the Department
of Energy, and New Jersey Governor Christy Todd
Whitman to the Administrator -- to be an Administrator
of the Environmental Protection Agency.
Utah regulators have given preliminary
approval to Envirocare of Utah to its request to be
allowed to dispose of more low-level waste, most Class
A, plus more Class B and C waste. There is a 60-day
public comment period after which approval by both the
Governor and the State Legislature is required.
On January 3rd of this year, the National
Research Council held its first meeting of the
Committee on Alternatives for Controlling the Release
of Solid Materials from Nuclear Regulatory Commission-
Related Facilities.
This is related to a proposed clearance
rule. The Committee is chaired by Richard S. McGhee.
So with that, the -- and unless there are comments on
any of those items, I think we will proceed directly
into our Agenda.
And the first item is progress on ACNW's
Sufficiency Review Application Task Action Plan, and
I think the ACNW staff member that's going to lead
this discussion is Lynn Deering.
MS. DEERING: Yes, sir. Thank you. I'm
on Tab 3, and this section of the notebook contains a
write-up of a revised approach to our Sufficiency and
KTI Resolution Review. And this is draft six of that
thing.
Each notebook it gets changed a little
bit. It gets better and better and one of these days
we're going to do something with it. We're going to
take it somewhere and --
CHAIRMAN GARRICK: You'll stop calling it
draft and call it version VER.
DR. LEVENSON: REV zero.
(Laughter)
MS. DEERING: Well, yes, we'll start all
over. But at one point we were going to maybe brief
-- use that one-pager to brief Commissioner TAs. In
light of the fact we may be just briefing the whole
Commission in March on that same subject, perhaps
that's what we'll do with it.
And in fact, I've already developed some
draft view graphs from it. Yes.
DR. LARKINS: I just was going to mention
-- interject a point here -- now, even with the, what
looks like the deferred schedule on the site
termination, when I talked to the various Commissions
they felt that it was still a good idea that we
proceed with our planning and our review, because they
felt that would give us an opportunity to get ahead of
the curve and it would still be timely. So I just
wanted to interject that.
MS. DEERING: Good. Okay, because that is
our plan to proceed ahead. And one of the things I've
asked NRC staff, Jeff Ciocco and Jim Furth, if they
can add during this discussion, enlighten us a little
bit about their schedule, given the delays, but how
they're proceeding, so that we know if there's drivers
for us in terms of what they're doing.
And so we've got that in the notebook.
Item 3, is the template that we developed following
the San Antonio meeting to conduct our reviews, help
us conduct our reviews. And the Committee members
have filled out the templates to various degrees for
discussion today.
We will use some of those draft templates
for discussion on the individual vertical slices, to
what we have. You know, and I think from here also we
want to talk about schedules, where we go from here.
And Ray's already proposed and George
concurred that we use the March meeting to really
start. We're going to actually start our reviews and
give status reports and official reports, and maybe
some presentations and view graphs about where we
stand in March.
So I'm just going to, before I turn it
over to individual KTI vertical slices, just sort of
update for the audience, if nothing else, and for
ourselves where we stand on this. The last month or
the month before last in San Antonio we agreed that we
may actually add an additional product to our overall
review.
And that was, we may do some comments on
the SRCR itself. Although that is not the primary
objective of what we're doing, it -- but it may be an
outcome, and I've revised the one-pager to reflect
that.
And again, the one-pager was revised to
kind of put the focus on the fact that we're
conducting -- and I'm just going to read excerpts from
this.
So you don't need to follow along, per se.
But we're going to conduct vertical slice reviews
-- hold on, I've lost my spot -- vertical slice
reviews of the staff's KTI issue resolution process,
rather than a report itself.
So Ray, you made a really good point this
morning about having attended the technical exchange.
One of the things you said was you weren't sure you
agreed with the resolution, at least on one of these
sub-issues, in terms of the closed pending status and
maybe the basis for that.
And I think that's exactly what we're
trying to do with these vertical slices, is get at
that kind of issue. Do we agree with the
defensibility of what the staff's doing, the
transparency of what the staff's doing in the issue
resolution process, the traceability?
Are they being overly conservative? Are
they being underly (sic) conservative? Are we buying
in with what we hear and see? And so I think that's
a really good example. That just really nails what I
think we're trying to do here.
And again, we're using all the SRCR. Even
though we did not -- it won't be issued until
December, all the technical bases documents are out,
the PMRs, the AMRs and I am about to ask Jeff to
comment here on their schedules and the tools that
they're using.
But we have what we need, as the staff has
what they need, even before the SRCR is submitted, to
get a good jump start on this whole review.
So Jeff, could you let us know what you
guys are doing?
MR. CIOCCO: Yes. My name's Jeff Ciocco.
I'm with the NRC staff. I'm a little bit hoarse this
morning, so excuse me. We are proceeding by
implementing the staff sufficiency guidance and
beginning to initiate our preparation of sufficiency
comments.
As you know, there's a lot of uncertainty
as to when the DOE will release its Site
Recommendation Consideration Report. We do have the
AMRs/PMRs. We have the preliminary pre-closure safety
evaluation. We don't have the TSP/ASR.
MR. WYMER: We received some of those just
last week.
MR. CIOCCO: Okay. We have received some
of the TSP/ASR reports. And we also have the
uncertainty with the new Volume 3 of the SRCR, which
is the NWTRBs cold versus hot repository design. So
we are beginning to initiate the review in order to
get ahead and to -- really to, I guess to get ahead of
the submission of the DOE's SRCR.
MS. DEERING: Are you using --
CHAIRMAN GARRICK: Microphone.
MS. DEERING: Sorry. Do you have what you
feel you need in the way of your preliminary guidance
to -- for now. I know it's not a final document, but
you have a structure, and in part, using -- or how do
you conduct your review? Put it that way.
(Laughter)
MS. DEERING: Are you at the point where
you're just gathering -- let me back up. Maybe that's
not something I can ask you. Are you -- what schedule
are you using to try to pull your comments
together?
MR. CIOCCO: Well, the site recommendation
schedule had us to generate sufficiency comments by
May of 2001.
MS. DEERING: Right.
MR. CIOCCO: And depending on when the DOE
submits the SRCR, we may be compressed to still submit
comments by May 2001. There's, you know, obviously
uncertainty in that. So we're kind of backing out a
schedule from May 2001 and generating comments.
MS. DEERING: Okay.
MR. CIOCCO: Well, obviously, we're going
to have to evaluate those comments when the SRCR comes
in. We don't know what the actual contents of the
report are going to be, but we know what the technical
basis documents are now that we have received, and
those are public documents.
MS. DEERING: Okay. That's helpful. So
that means we might want to keep with that schedule
also, the May 2001, keep that in mind as a target
ourselves, because there's a lot of uncertainty. So,
or at least get something preliminary together.
I think what we might want to do, then, is
talk a little bit about these templates and where we
stand in the various -- on the various vertical
slices. And Ray, you were -- you did a really nice
job on yours, and Andy's got this draft on the working
group.
So you all might want to start, sort of
kick it off and brief us on, you know, some of your
insights in filling out the template and whatever you
want to talk about.
DR. WYMER: Okay. Well, I wasn't terribly
enthusiastic about it when it first came up, but as I
get into it, it seemed like it was probably
worthwhile.
DR. HORNBERGER: "It" being the template.
DR. WYMER: The template, yeah.
DR. HORNBERGER: I just wanted to correct
that for the record.
DR. WYMER: Yes. That was a capital "I"
there on the end.
DR. HORNBERGER: Because somebody might
have misinterpreted it and thought you weren't excited
about the chemistry issue.
DR. WYMER: Oh, I doubt if this group
would ever make that mistake. It did force me to,
probably sooner than I would have, to go into a real
reading of the AMRs and looking through a lot of the
stuff. So I thought it was a worthwhile exercise, all
in all.
I questioned one of the points that Lynn
put into her outline, is the NFC's previous resolution
status prior to technical exchange and source. I
didn't know how that contributed to going forward. So
I didn't do anything on that particular item.
DR. HORNBERGER: Ray, I think that -- I
don't disagree with you're not pursuing it -- but I
think that our -- I believe that our thinking had been
that we might get some insight as to if there was a
change in the issue's status as to exactly what it was
that led the staff to conclude that such a change was
warranted, and that would give us sort of a time line
or a course, a path to resolution and might give us
some insights. That's all.
DR. WYMER: Yes, I thought that's probably
what the objective was, but it seemed to me that if we
knew what the current status was and we're going
forward from that point, that was what was important.
But okay.
There's differences of opinion. But we do
plan, as you know, to hold this little working group's
-- not exactly a working group, but a group of us get
together, three consultants and Andy and myself are
going to get together and discuss the KTIs that relate
-- and the AMRs that relate to mainly the corrosion
issue, but peripheral issues that related to that,
that have to do with transport of radio nuclides.
And so we've put together a plan to
proceed to an outline that we're going to follow in
holding our meeting, which will allow us to go into
considerable depth vertically.
And Andy has also superimposed on that in
order to cover some of the issues, the other KTIs that
are not our direct interest, the horizontal slice,
which broadens out what we're going to discuss, too,
things like transport phenomena.
If I recall the RAD transport in
particular is an issue that we're interested in.
MS. DEERING: Yes.
DR. WYMER: So as we're going a little
farther than maybe than you anticipated with respect
to making this in-depth vertical slice, in that we're
pulling in outside people to help us with our
thinking, people that have a more detailed background
in some of these specific areas.
And that's pretty well outlined in the
stuff that you've handed out to the Committee, at
least, which is generally available to anybody who has
the temerity to be interested in all of these details.
I don't know what else, really, to say,
Lynn, without getting into the stuff I specifically
wrote on the KTIs. Generally, I think it's a
worthwhile exercise.
MS. DEERING: Yes. And you're comfortable
-- it's a worthwhile exercise. You think it's a
doable exercise, right?
DR. WYMER: Yes.
MS. DEERING: We can get there from here?
DR. WYMER: Yes.
MS. DEERING: I mean, because some of this
was experimental in the beginning. Like, are we even
on the right track; how far can we go with it.
DR. WYMER: Yes, I think we can. And in
my write-up of the vertical slice template I have a
fairly extensive attachment that I hooked on that
deals with the resolution of the key technical issues,
at least on container life and source term, which is
our principal thrust.
So there is an attachment that deals in
some detail with the corrosion processes and the
lifetime of the containers. And it says what the
steps are that NRC and DOE plan to take with respect
to resolution of these key technical issues, with even
down to the particular AMRs that are -- that ought to
be looked into.
One thing that came out of this review
last week when we went to the resolution meetings, KTI
resolution meetings, is that a lot of the AMRs are
going to be redone. They're going to be extended and
there are revisions already in hand that I did not
have at the time I wrote this.
And there are other revisions that are
planned. So in a way, we're always running behind,
and I don't know a way, really, to get around that
except that some of the issues that I may have pointed
out or come up with are already at least partially
resolved.
This will be kind of a problem for us when
we hold our little group meeting, too, that we will
not have the latest AMRs in hand. And a lot of them
are requested at this meeting by the NRC staff, but we
probably will not have those by the time of our
meeting.
We certainly will not have had time to
review them at the time of our meeting.
MS. DEERING: Yes, I recall, too, a lot of
the staff requested as part of issue resolution a
particular analysis. And DOE would say, yes, that'll
be in our AMR and that will be submitted in 2002.
DR. WYMER: Yes. There were about three
or four, maybe more, that were specifically said 2002
and we said, well, that doesn't do us a lot of good.
MS. DEERING: Except that I don't think to
do our vertical slice and the conclusions we will
make, I don't -- I think there's a way to get around
that.
DR. WYMER: Yes.
MS. DEERING: We don't have to say all
information was provided and information was adequate
or anything like that, Ray, George.
DR. HORNBERGER: Right. But it's also
true, I think, that the AMRs are available. What
you're talking about is the additional information in
the next revision of an AMR that won't be required to
have the issue closed.
So the AMR itself is available. It's just
that the additional information that NRC staff has
requested won't be available.
DR. WYMER: Well, that's certainly true,
but some of that information is so important that it
would be nice to have it, you know.
DR. LEVENSON: Yes, but at this point
isn't the most significant thing staff recognition
that that is important and that is needed and they're
going after it? We don't necessarily have to see the
data.
We just want to make sure that they
haven't missed something, if they've identified it and
are insisting on it.
DR. WYMER: And if I were to make a
general observation about this KTI resolution meeting,
it is that most of the stuff that was requested was,
where is your data.
That was the thrust, where's the
information that backs up this statement that you
made. And that's 90 percent at least of what was
asked for, was supporting data.
DR. WYMER: Which is what we'd like to
see.
MS. DEERING: Yes, that's a good point.
MR. CAMPBELL: And that was true in the
RAD transport tech exchange, is a significant amount
was either what is the data to support your position,
or how are you going to get that data.
DR. WYMER: Yes. That was one of the
things I liked about the meeting and the discussion in
the caucus, was the emphasis on factual support for
fairly broad and sweeping statements that were made by
DOE.
I thought it was a good process. I'll
repeat that for the larger group, or I thought it was
a good process.
CHAIRMAN GARRICK: Yes. And in connection
with the process question it's important for us to
remind everybody here that what we're doing here is a
departure from our normal way of doing business, of
reviewing an applicant's material and offering
comments and advice, et cetera.
Given the large amount of material that's
involved and tremendous amount of reading that is
necessary to even get through it, much less evaluate
and analyze it, the Committee and the staff has made
the decision that the vertical slice concept of not
only doing a vertical slice, but focusing more on what
the NRC's doing than on necessarily what the DOE is
doing, is a more efficient way to get to the issues.
And I guess the question we have to keep
asking ourselves, is this giving us visibility into
the process that the NRC is employing to review
something like the SRCR, and are we learning more
about how effective that process is?
And in the meantime, are we also staying
alert to technical questions that may require us to go
back to the source material, the DOE source material,
to get to the -- get real satisfaction on them? Is
that happening, is something we have to be very alert
to.
DR. HORNBERGER: Of course, I'd point out
that all of this stuff we're talking about looking at,
PMRs and AMRs, is in fact to be resource material.
CHAIRMAN GARRICK: Right.
DR. HORNBERGER: So that's exactly what
we're doing.
DR. WYMER: That's right.
CHAIRMAN GARRICK: Yes. Yes.
DR. WYMER: That's all I have, Lynn.
DR. LEVENSON: Yes. I have one question
for Ray.
CHAIRMAN GARRICK: Oh, a question.
DR. LEVENSON: Under -- in your thing you
wrote under DOE's current modeling approach and
position:
"The DOE's current models are based on
the assumption that the environment on
the surface of the waste package is the
same as that on the drip shield."
Does that mean we're spending some
hundreds of millions of dollars of money for drip
shields, and taking no credit for it at all?
DR. HORNBERGER: Chemistry clinic.
CHAIRMAN GARRICK: Water flow right up
their --
DR. WYMER: I don't know that it means
exactly that, but it does mean that they just assume,
as it says, that the water hasn't changed after it's
gone off the drip shield into the package, and that's
probably not true.
DR. LEVENSON: Oh, okay. So this is not
-- it's not the total environment. It's only the
chemistry of the water.
DR. WYMER: That's it.
DR. LEVENSON: Okay.
DR. WYMER: Because the total environment
includes quantity of water.
DR. LEVENSON: Yes, okay. That's how I'd
--
DR. WYMER: Yes, I'm sorry. That wasn't
clear.
DR. LEVENSON: Okay.
DR. WYMER: John, you had a --
DR. LARKINS: Yes. Well, you had
questions to answer for Commissioners where you, you
know, these questions. And it says: "Is the issue
resolution process sufficient for the sub-issues," and
you say maybe not, because of the absence of, you
know, maybe some things have been overlooked. How do
you --
DR. WYMER: How do you know what you
haven't thought about, yes.
DR. LARKINS: Yes.
DR. WYMER: And a very good case in point,
of course, is the trace impurity corrosion of Alloy
22. That wasn't thought of until it came up. So you
can't know what you don't know, but these things do
emerge with time and with additional experimental
studies.
And that's where it's all at. You've just
got to go out there and look at the system more and
get data, and things will continue to crop up,
especially in the coupled effects area because the
system's so extraordinarily complicated chemically.
DR. LARKINS: Yes. I guess what you're
saying is for the way it's -- the sub-issues are
defined that it may be sufficient; however, because of
uncertainties in the knowledge base there that you
-- there may be some things which aren't included.
DR. WYMER: I would bet there are things,
you know. It's almost a certainty that there are
things that will crop up. But of course, till they
crop up we don't know what they are.
DR. HORNBERGER: Now, to me there's, shall
I say, a danger for us here and that is that this is
typically -- we know this is true in science, okay
-- there are always surprises. We know that there are
surprises.
So the scientific approach to a question
never leads to an answer, but this is an engineering
project, and basically, I think that we have to keep
in mind that the whole idea is to try to engineer it
so that it is at least robust against surprises.
Not that all of the issues or all of the
scientific issues have to be explored in goriest
detail, but rather that a safety case can be made.
DR. WYMER: Yes.
DR. HORNBERGER: And so I also think that
as we go through the vertical slice, what John has
really emphasized for us, is to keep the RIPB -- keep
the risk perspective in mind as we go through it and
not lose sight of that.
DR. WYMER: Yes, and what you look for is
not the technical details, but the gross things like,
is Alloy 22 really going to last 11,000 years, some of
these key issues.
If they're not of that magnitude then they
do get washed out because the engineering approach,
using George's term here, does allow you to ignore a
bunch of stuff that is chemically interesting, it will
happen chemically, but doesn't matter.
DR. LEVENSON: If there is no impact on
safety, then why do we pursue getting it? Then it's
just a matter of satisfying somebody's curiosity. I
think we have to assure ourselves, is that things that
have a significant impact on safety are not
overlooked.
DR. WYMER: Yes.
DR. LEVENSON: Not that nothing is
overlooked.
DR. WYMER: Yes, absolutely.
MS. DEERING: Right. Right. That's not
necessarily easy to do.
DR. LEVENSON: Oh, no. No. No, certainly
not, but there's a lot of things that you can in fact
discard. If you say you have no idea what this is,
but if you say, this is the maximum range it could be
and it doesn't matter where in that range it is, it
has nothing to do with safety.
MS. DEERING: Yes, and I hope that that's
going to be definitely a part of each of our reviews
wherein we could make comments that if we feel the
staff has considered the risk significance of an issue
before they've pursued it rigorously, for example, you
know, that's something we need to be conscientious
about, is staff pursuing issues that don't have risk
significance.
And do we -- is there a way for us to even
know that? But one of the ways is to look at the
staff's process and the risk insights that they're
coming up with. You know, it involves going pretty
deep into this review.
DR. LEVENSON: Well, almost. The reason
being that unfortunately to some extent the staff is
not limited to only looking into risk issues. They're
also charged with assuring compliance. So they may
look into things that we don't think would be
necessary, but they have no choice. So we have to
recognize that.
DR. WYMER: Well, let me make one more
point. One of the areas that we need to look at most
carefully in this vertical slice thing is assumptions.
There are a bunch of assumptions made, just sort of
carte blanc. They're just made.
These are assumptions. We think there are
good reasons for these assumptions, so I think to
critically review assumptions, because as a friend of
mine always used to say, assumptions drive
conclusions, and they do. So we need to really pay
close attention to assumptions.
MS. DEERING: That's really a good point.
MR. CAMPBELL: In terms of just in
addition to what Ray said, the whole issue of defense
in depth is a key to why we're looking beyond the
corrosion issues related to the waste package.
And the idea here is that our vertical
slice will focus on the waste package and corrosion
issues. But we really needed to look at the other
components of the system that contribute to
performance in the absence of the waste package.
And those are, you know, in package
chemistry, in drift chemistry, transport to the
accessible environment. And those, basically, the
three key areas outside of container life and
container performance that need to be looked at.
And you know, one of the things that we
have to be aware of is that the conceptual models
built into everything into TSPA do necessarily leave
things out. So the question is, in that process has
something very important been left out.
So that's part of what we're going to look
at in the context of this meeting.
MS. DEERING: That sounds really good. Do
you want to talk about your work?
MR. CAMPBELL: I think Ray's actually
covered most of the things. We have three consultants
in different areas, RAD transport, Jim Clark. Paul
Schuman's a corrosion expert, and we have Marty
Steiver (phonetic) coming in, and kind of divvied it
up in terms of individual responsibilities to look at
different areas based upon their expertise.
And we're not coming here to draw
conclusions, but to, rather, put our heads together
and, you know, see if there are general trends that we
see in our individual analyses that warrant, you know,
further analysis and more focus.
I think that's -- I've tried to cast the
questions that each of us will, you know, bring to the
table in terms of the questions that were posed in the
vertical slice template.
CHAIRMAN GARRICK: Yes. And I think one
of the things that I'm hopeful that we'll find in the
vertical slice exercise with the TPA and TSPA is
whether or not we indeed have a baseline or a
reference point to work with.
There's two things that I think we want to
get out of the TSPA that make the process sound. One
is a kind of a realistic appraisal of what the real
risk is of this repository.
The other is what will -- addresses this
issue that we keep raising about integration and
interaction and systems interaction and what have you.
And that's the issue of context and perspective.
So if we can get some sense on the basis
of the current design specifications, what the safety
issue is, what the risk really is, including of course
it's uncertainty, and get the sense of how all the
pieces fit together that lead to that estimate of
risk, then that will help all these other exercises
greatly in terms of saying, well, how relevant is
this, this or that issue, and what kind of backup
lines of defense really appear to be important here.
So we'll be looking for that. We're a
little behind in the TSPA vertical slice exercise from
the others. Part of the problem is we've been anxious
to have the full benefit of the TSPA SR and also the
technical exchange meeting that keeps getting
scheduled and rescheduled.
But I think we'll be able to have
something in -- for the November -- or for the March
meeting that will allow us to at least talk to it in
terms of the scope, but I don't think we'll be as far
along as the other three.
DR. LARKINS: John, are you saying that
when Ray and Andy finish their exercise and identify
the areas where they see a need for more information
or a better understanding on their part that they need
to fold us into --
CHAIRMAN GARRICK: Right.
DR. LARKINS: -- looking at the TSPA --
CHAIRMAN GARRICK: Yes.
DR. LARKINS: -- to see.
CHAIRMAN GARRICK: There's got to be
something we do that tells us --
DR. LARKINS: How do we do that?
CHAIRMAN GARRICK: -- the importance of
these individual pieces and parts.
DR. LARKINS: Yes.
CHAIRMAN GARRICK: And right now, that is
the TPA TSPA, and we can criticize it and we should,
but what we should be doing is saying, okay, how can
we overcome these problems that we have with it,
because somewhere along the line we have to ask
ourselves, is -- has enough work been done.
DR. LARKINS: Yes.
CHAIRMAN GARRICK: Is the analysis
adequate? And we certainly need to be guided on how
far we go in this whole issue of trying to resolve
uncertainties. And if we find ourselves -- and I
think Milt was alluding to this a little while ago
-- if we find ourselves in a position where an issue
is being addressed and another order or magnitude of
change in the uncertainty isn't going to impact it,
then you know, we need to -- we'd like to know that
and we need to move on.
DR. LARKINS: I think it sounds like it
would be worthwhile having the staff involved in some
of these, because if you're going to come back later
on and say, you know, how have you taken these issues
into consideration in your analysis, either with TPA
or reviewing TSPA, they ought to get to understand how
these insights came about doing this vertical slice
approach. So I didn't know whether you'd planned on
--
MR. CAMPBELL: We do.
DR. LARKINS: Okay.
MR. CAMPBELL: And we haven't had a chance
to talk to them until we kind of settled upon our
approach. As you point out, the integration into the
vertical slice for TSPA is part of this plan, and
actually, 4 and 5 of our meeting goals was to feed
into TSPA.
If you will, what Ray and I are doing is
kind of a process level model, look-see. And what
John and I intend to do is more of a higher level TSPA
model looking back. And hopefully, we'll be able to
make those connections.
And then, as you point out, having staff
involved and discussions with staff is intended. It's
just we haven't set anything specific up at this
point.
DR. WYMER: It seems to me that one of the
important points with respect to this TSPA thing is
what John already alluded to, namely, the propagation
of uncertainties, plus the issues of what do you lose
in the abstraction, in particular a couple processes.
DR. LEVENSON: I think, you know, there's
two pieces that I have in the way, and one is the
propagation of the uncertainties, but we're spending
a lot of time looking at details.
And if in fact in the abstraction process
those things are wiped out, why are we spending time
assessing whether something is done properly if it
doesn't propagate through, not only the uncertainty,
does it itself propagate through?
And it's why I think we have to -- I think
this vertical slice thing can't just be a vertical
slice through the KTIs. I think we have to take one
or two at least and follow them through the
abstraction process into the TSPA, to see what it
really means.
MR. CAMPBELL: The focus of the issues,
this isn't intended to be a random walk through either
the process models, AMR, PMRs or TSPA. We've allowed
the modeling that's been done to date, both by the
staff and TPAs, the TPA analyses and by DOE and their
TSPA analyses to help guide the picking of the issue
areas to look at.
CHAIRMAN GARRICK: Yes. This Committee
has always been pushing for some indication of how
much safety are we getting from what. We've always
wanted that. When we talk about introducing
engineered barriers, we've talked about being able to
quantify the contribution of individual barriers, at
least to the extent that it's reasonable.
And I think when it comes to simplifying
a specific model we want to know what the impact of
that is, you know. Ray was talking about assumptions.
Some analysts will say assumptions are the curse of
any -- of the truth because you don't want to assume
your way out of reality.
And that's why we keep pushing for, well,
let's understand first what is our best shot at how
this thing really does perform. And then we can start
whacking away at how good this part of the analysis is
and that, and get to the issue of assumptions.
But I think we've already been talking
about in the TSPA vertical slice of trying to back out
the critical assumptions so they're more visible and
in terms of their impact on something like a realistic
assessment of what the risk is, what the performance
is.
Then we can choose to be as conservative
as we want, but we need a reference. So we need that
baseline to know, to be able to measure how
conservatively we might be making some of these
estimates.
How about the -- how about yours, George?
Are you satisfied that we can achieve what we want
with this process in the -- on the one that you're in
charge of here?
DR. HORNBERGER: Yes. I mean, and I think
that Lynn actually laid out the guts of it in her
outline last time. And as long as, at least the way
I envision it, we're talking a slightly more narrow
view than what Ray and Andy have just outlined for the
chemistry, and that is to focus, really, primarily on
the flow paths in the saturated zone.
There are obviously lots of other issues
that touch upon that, but to the extent that we can,
given our limited availability of time and resources,
I would like to see us focus as tightly as we can on
the issue that we described.
And I think if we do that there's plenty
to look at. It's not as if -- that just makes it
easy.
MS. DEERING: Yes. I think George and I,
based on the piece that you wrote, George, this helps
tighten it up even more. And I feel like now it's
just a matter of starting, getting started.
DR. HORNBERGER: Yes, I do, too.
MS. DEERING: And whether the data's been
provided or not, I don't feel it's going to hang us
up. It's more the fact that it's been asked for, and
from a risk perspective is it the right data to ask
for, and maybe make the assumption that it will be
provided.
DR. HORNBERGER: Right.
MS. DEERING: And maybe we have an idea of
whether that's -- how realistic that is or not, I
don't know. You know, we already know there's
problems in getting data in terms of permitting from
Nye County.
Some of that alone is problematic. Just
getting data, even if there's funding, is not
necessarily easy and something you can count on
happening. But so I'm keeping that in mind. I think
we've got plenty to work with.
And we'll talk and I'll talk with the
staff, and come March we'll put together something,
you know, that shows we've actually cut into this a
little bit, which we haven't done yet. See, that's
true in all of our cases.
I think we're sort of on the edge here.
We've been defining what we want to do and whether
it's even -- you know -- sort of a feasibility
assessment: is it even reasonable to consider can we
go there before we get too involved? And I think
that's exactly where we should be right now.
DR. LARKINS: Sound like, yes, this is
going to be somewhat iterative in nature.
MS. DEERING: Yes.
DR. LARKINS: You're going to go through
this one time, and then you're going to discover
things and then you're going to need to go back and
take another look at these things.
MS. DEERING: And each one so closely
links to another, like George's and mine, it
definitely bumps up against the retardation issue and
the alluvium, you know, first defining flow paths, how
much water even goes into the alluvium.
And then so there's going to be, I think,
the staff here, we've been meeting weekly, or we've
been trying. We've sort of tapered off from that, but
once we get started on these, we ourselves need to,
once we share insights with each other, where we
stand, you know, what works, what doesn't, so we'll
make a commitment to do that.
CHAIRMAN GARRICK: On the basis of a
preliminary look-see does anybody, any of the members
have any concerns that are rather significant at this
point that ought to be telegraphed in terms of either
the modeling or the input information, that is to say,
the data?
DR. LEVENSON: I have one question, John,
and that is, it goes back to the template from the KTI
meeting that Rich and I attended. We certainly got
nothing that would let us address the last question,
namely, what's the risk significance of the issues
being discussed.
CHAIRMAN GARRICK: Yes.
DR. LEVENSON: There was no discussion
whatsoever.
CHAIRMAN GARRICK: At your meeting?
DR. LEVENSON: Yes.
MR. MAJOR: There was a debate. I mean,
the Department of Energy would come out and make a
presentation and they would claim the colloids didn't
contribute much to the overall dose, and therefore, it
didn't need to be considered much further than they
already have.
And then you have the NRC staff on the
other hand saying, well, you know, we're a bit
skeptical about that; have you considered A, B, C and
D.
DR. LEVENSON: Yes, but that was on
specific, very narrow things, not relevant, really, to
the overall question of risk. I mean, because whether
you do or don't generate colloids is one little piece.
Then you've got questions of transport of
colloids and trapping and you got all these other
things so that the things were addressed bit by bit.
The risk did not to me appear to be a basic part of
the issues of what was important or why.
MS. DEERING: Can Bret Leslie make a
comment? He wants to comment on that issue.
MR. LESLIE: This is Bret Leslie, from the
NRC staff. And I agree with the assessment. I
attended the first one of these technical exchanges,
and at the first one they didn't even have any
insights into risk.
And we requested that they try at the
beginning of these meetings to put a TSPA overview so
that we could understand things, and DOE was very
reluctant to go into this in much detail.
And therefore, what they agreed to provide
at this because they felt it was the purview of TSPA,
that they didn't want to have to repeat the TSPA
meeting in every one of these meetings.
So what they're trying to do to help put
the risk perspective for the NRC staff in place is to
look at, for instance, colloids, which was one of the
topics, and say, this is how we dealt with colloids
generation, which is one of the topics we were talking
about.
So I agree with that but we're somewhat
limited by what DOE is going to provide us, you know.
DR. LEVENSON: But what that would
indicate is the templates that we're using for
vertical slices is -- the risk issue should be deleted
from each individual one and maybe ought to be a
separate one, if they're treating it separately.
CHAIRMAN GARRICK: Well, this is all a
matter of style and how it's done, but one argument
could be that -- to take the position that, well, as
a matter of fact, that's exactly what we should be
doing.
That is to say, what we should be doing is
every time an issue comes up, start with the TSPA and
ask ourselves, where does that issue appear in the one
analysis that we have defined as integrating
everything and bringing all the pieces and parts
together.
As a matter of fact, I'm reminded of when
we really began to make progress on the WIPP
performance assessment was when we did just exactly
that. We took the position that we're not going to
have anymore discussions of technical issues without
it first being put to the test of the PA.
And so whenever we would start a
presentation we started with the idea of, well, where
does this issue fit in the grand scheme of things, and
the measure for -- the grand scheme measure is the
performance assessment until something comes along
better, and then go from there so that people are
using a legitimate reference in the discussion.
So you know, it may be that just what DOE
is saying we should avoid here is exactly what we
should be doing. And maybe that's something for us to
consider.
MS. DEERING: Well, is there also the
other half of it, which is NRC's risk insights, you
know, because that's important, too, because NRC has
done -- has in its pocket some of its own ideas about
what's important.
And I don't know to what extent that has
been shared with us. I mean, but I think one on one
that that would be a reasonable thing, for us
technical staff to talk to NRC technical staff and try
to help out along those lines.
You know, it's not something that probably
you're going to hear in a public meeting.
CHAIRMAN GARRICK: Yes. Yes.
DR. WYMER: The problem is, is that lots
of different -- there's a lot of kinds of risk, and it
seems to me that if you don't discuss risk as you have
in your outline for this vertical template, you're
going to miss a lot of risk.
If you take a sort of a top-down view
you're not going to unearth some of the risk that you
will unearth by a detailed discussion within the AMRs
and the KTIs. So and then there are sort of overall
risks that are not specific technical risks, but have
to do with risks of whether something in fact will be
accepted or not accepted in a broader sense, because
of public outcry or because of some regulation or
because of something else.
So there's different hierarchies of risk
and I think to get at some of the technical risks you
really got to get into the nitty-gritty. Then you
decide based on the overall plan of approach, the
TSPA, the TPAs, whether or not the risks that you've
unearthed are relevant risks, and you weed them out if
they're not.
But I think you're going to miss them if
you don't go into the details.
CHAIRMAN GARRICK: Okay. We've had a
request to -- from a public citizen group to make a
comment.
MS. GUE: Thank you, Mr. Chairman. I'm
Lisa Gue with Public Citizens Critical Mass Energy and
Environment Program. Certainly, we're very interested
to follow along in your vertical slice process.
And we share some of the concerns that
your committee has stated, and also the Technical
Review Board, with respect to the uncertainties of the
most recent outlines available from the Department of
Energy.
The specific comment I'd like to make
jumps back to the beginning of this discussion with
respect to the sufficiency report that NRC will issue
referencing the SRCR document.
And I want to bring to the attention of
this Committee some of the very serious concerns that
Public Citizen, together with other -- working
together with other public interest groups nationally,
and also State of Nevada groups, have on the SRCR
document and the process leading up to its release.
I guess there's three main concerns, or
I'd categorize our concerns into three areas, anyway.
First of all, this of course is not a legislative
document. It's not specifically outlined as part of
the Nuclear Waste Policy Act.
But the DOE has chosen to use the SRCR as
-- in order to fulfill the requirement for public
comment on a final recommendation. And our concern
with respect to the opportunities for public comment
is that the last formal opportunity that the public
had to comment on the Yucca Mountain process was in
response to the draft Environmental Impact Statement.
Yet, as members of the public we have not
yet received any feedback as to how or if our previous
comments have been integrated into the proposal. And
yet -- and so now we are seriously questioning whether
we will in fact participate in the SRCR comment
period, simply because we have no indications of how
worthwhile it is for us to spend our time trying to
understand these very technical documents, if in fact
our comments are not taken into account.
I guess our second main concern is the
timing of the report. As you know, the SRCR was
originally scheduled to be released at the end of
December of last year.
And that was due at a time -- or according
to that original schedule and also according to
looking at the overview that was prepared, the SRCR
was to be making comments on the suitability of the
Yucca Mountain site prior to the finalization of
several key scientific studies, and also prior to the
finalization of key regulations, most notably, the EPA
Radiation Protection Guidelines.
And we feel that this is really a very
inappropriate display of premature confidence on the
part of the DOE, and we would extend that to the NRC's
sufficiency report, too, if it's released before the
consideration of how this site would be able to meet
these standards that have not yet been released.
And certainly, several specific aspects of
your conversation could fit into this category with
respect to, for example, the regulatory period, which
is one aspect of those EPA regulations which now
appear that they won't come out before the change in
administration, and therefore, will be delayed to an
uncertain point, hopefully in the new year.
And finally, I guess I want to bring to
your attention -- hopefully -- I'm sure you're already
aware of this, but the internal memo that was leaked,
written by a DOE contractor, TRW, and attached to this
overview of the SRCR document, and that surfaced last
December, has seriously damaged, I guess, the
credibility of the DOE's site characterization process
in the public mind.
The indications, both of the overview
itself and more specifically stated in the leaked memo
were that, first of all, the technical suitability of
the Yucca Mountain site was not the first priority of
the DOE, but rather, to offer a financially and
politically possible solution to the industry's
nuclear waste crisis.
And secondly, that this document was
available to be used by presumably industry lobbyists
to garner support for the Yucca Mountain Project in
Congress.
Certainly, it's inappropriate, of course,
for a federal agency that's been specifically mandated
to study the suitability of the Yucca Mountain site to
have, even via its contractors, such a blatant and
obvious display of bias.
And it really has, like I say, undermined
the credibility of this process and been very
discouraging to members of the public who have been
participating in good faith in the various
opportunities for public involvement in the process.
And now, it seems that in fact from the
perspective of the DOE, a favorable recommendation for
the Yucca Mountain site is in some ways a foregone
conclusion.
So into that context, and I'm sure you're
aware that, in fact, we work together, like I say,
very closely with citizens groups in Nevada and other
national groups, and as well, the federal delegation
from the -- the congressional delegation from the
State of Nevada in looking at this problem and drawing
attention to it.
And I'm sure you're aware that the SRCR
has actually now been delayed pending the results of
an Inspector General investigation. But I did just
want to bring to your attention that into this context
there are actions of the NRC, as well, that serve to
further undermine the public's confidence in this
process.
One of those is the prelicensing
conversations on the key technical issues, which
sometimes seem to be phrased or framed in the sense of
moving towards the inevitable licensing of the Yucca
Mountain Project, in terms of when the license
application is submitted rather than if, when clearly
and formally the situation still is if, and other
-- or I guess actions of other divisions of the NRC
further feed into this sense.
And I'd just bring to your attention, I
know I've raised it to you before, the draft
Environmental Impact Statement for the private fuel
storage proposal, which was drafted by the NRC and
which makes explicit reference to a Yucca Mountain
facility as the eventual destination of waste that
would be stored at the PFS facility.
So I just -- I appreciate the opportunity
to comment to you today and I want to make you aware
of those issues, and technical issues and also
procedural issues, I guess. We're very aware that the
Yucca Mountain proposal lies at the intersection of
very challenging science and challenging public policy
considerations.
And both of those require, I guess, a
process which displays optimal integrity. And neither
the science nor the policy will be accepted by the
public without a process that displays that level of
integrity. Thank you.
CHAIRMAN GARRICK: Before you sit down can
I ask you a question?
MS. GUE: Yes.
CHAIRMAN GARRICK: You said regarding your
first concern about the SRCR that you had received no
feedback from DOE on previous comments. Will you
remind me again what specific comments those were and
what form they took?
MS. GUE: I was referring in general to
the comments that were made, both in writing and
through participation in formal meetings, on the draft
Environmental Impact Statement.
CHAIRMAN GARRICK: Yes.
MS. GUE: So we were hoping that we would
have -- the public would have access to the final
Environmental Impact Statement to be able to see how
those comments were integrated prior to the comment
period on the final -- on the recommendation by the
DOE.
CHAIRMAN GARRICK: Okay.
MS. GUE: But as it happens, the comment
period on the SRCR is scheduled to close just as the
final Environmental Impact Statement is scheduled to
be released. And as you pointed out, all those time
lines are now somewhat in question, but that's the
best information we have.
CHAIRMAN GARRICK: Okay. I understand.
MS. GUE: Yes.
CHAIRMAN GARRICK: Thank you.
MS. GUE: Thank you.
CHAIRMAN GARRICK: Thank you. Did you
want to make any comments on the thermal effects,
vertical slice, Milt?
DR. LEVENSON: No. I think most of the
comments --
CHAIRMAN GARRICK: Better pull that mike
down.
DR. LEVENSON: Okay. Most of the comments
arising from the meeting we attended have already been
made. I would like to pursue the possibility of
having a one on one session with somebody from the NRC
staff to have what I would call a guided tour through
the AMRs, the PMRs, the abstractions, the modeling and
to the total system performance assessment of one of
some quite narrow issues, either the question of, does
all of the water really always move away from the
drift in both the pre-closure and post-closure time?
Or a guided tour and assessment of what
really are the differences regarding water movement
and transport if the temperature is 110 degrees
centigrade versus 95 degrees centigrade. Been a great
deal of discussion and assumptions about importance of
boiling.
I've not seen any technical information or
discussion as to why it's important. I mean,
superficially, there's no inflection in the vapor
pressure curves. So I would really like that.
You know, I'd be willing to take the time
and come and have a one on one, somebody lead me
through why these issues are handled with a basic
assumption. I mean, is there support in the AMR, in
the PMR? Or do they turn out to not be so important
during the abstraction?
CHAIRMAN GARRICK: Yes.
DR. LEVENSON: And I don't know whether
it's appropriate, but that would really help me
evaluate the total process.
CHAIRMAN GARRICK: I think it is
appropriate and I think it would be very helpful.
Okay.
Lynn, where are we?
MS. DEERING: Well, it sounds like we're
wrapping up this session. With the anticipation of
March, we will come in here having started -- getting
a good start on these reviews. And I'll --
CHAIRMAN GARRICK: Right.
DR. WYMER: With view graph presentations?
Is that what you were suggesting?
MS. DEERING: Yes. Well, how much time do
you think we need next month to do -- maybe set aside
at least a couple hours?
DR. LEVENSON: Half an hour for each one,
anyway.
MS. DEERING: March, next meeting.
CHAIRMAN GARRICK: Yes.
DR. LEVENSON: February is saturated
without this going.
MS. DEERING: Yes. That gives us two
months, which I think is good. That's just what we
need. So we'll put at least two hours on the Agenda.
DR. LEVENSON: I would like to then have
my one on one sufficiently in advance of the next
meeting.
MS. DEERING: Okay. So are you -- is your
little team going to organize that?
DR. LEVENSON: I'll organize it.
MS. DEERING: Okay.
DR. HORNBERGER: Sounds like it'll be the
entire month of February.
MS. DEERING: Yes. You know, I might --
I just wanted to add, the NWTRB meeting coming up the
30th and 31st, I think is going to be extremely
informative about some of DOE's -- let me just try to
explain what I understand about it.
The schedule's going to be on the website
today, and I'll peel that off and bring it back after
lunch. But the TRB is going to attempt to ask DOE
very pointed and specific questions of a technical
nature about its analysis. And a lot of this I --
DR. LEVENSON: Is that a new format?
MS. DEERING: Yes. There's no -- that's
going to be -- and DOE, of course, knows what the
questions for the most part, I think, are going to be.
But DOE's essentially going to walk the Board through
how it's treating -- I don't want to say tracing a
particle all the way through, but that's the
impression I'm getting.
Now, when I look at the Agenda we'll see,
but you know, flow and transport in the unsaturated
zone, waste package issues and waste package
degradation, juvenile failure, flow in the saturated
zone.
You know, it's really attempting to shake
out the uncertainties, the hard questions, and see
what we really understand now.
DR. LEVENSON: What's the date of that
meeting?
MS. DEERING: The 30th and 31st. It's in
Amargosa Valley, of January.
DR. LEVENSON: January.
MS. DEERING: I just wanted to put that
out as -- I'm planning on attending that and I -- for
George's and my vertical slice we think there's going
to be some real valuable stuff in there. But if
others are interested, we'll look at the Agenda this
afternoon.
CHAIRMAN GARRICK: Are you going?
DR. HORNBERGER: No.
CHAIRMAN GARRICK: Okay. Any other
comments from Committee members, staff, George, Ray?
DR. WYMER: I've said my piece.
MR. MAJOR: May I share one --
CHAIRMAN GARRICK: Yes.
MR. MAJOR: -- thing with the Committee
members? Following each of these technical exchanges
the staff and the DOE do a summary. And in that
summary they capture the highlights of the meeting and
they also capture the additional information that the
staff is looking for and that DOE agreed to provide.
And I'm going to hand you a copy of the
summary from this last meeting. I guess the staff
does a valiant effort and an awful lot of work goes
into putting these things together.
CHAIRMAN GARRICK: Yes.
MR. MAJOR: They do it at the meeting and
then they're signed and agreed to by the senior NRC
person there and the senior DOE individual. So if you
want to get a sense as to the types of things that
come out of these meetings, when you get this brief
summary it'll give you some idea of what comes out of
these. It shows you how they're moving towards
resolution.
CHAIRMAN GARRICK: Okay.
DR. HORNBERGER: Something had occurred to
me and I don't know if this is -- will help it be
possible or perhaps it may even be trivial. It
strikes me that in some of our discussions about the
risk implications of different assumptions or as we
dig into things, how big an affect things might have,
or at least some insights.
I know Andy has done some work with the
TPA code. It's even, at least in my mind, perhaps
feasible to either look at what the staff has done in
the way of looking at things in terms of sensitivity
analyses, and try to get at things that way.
Or possibly, you know enough about it that
if there were special purpose runs to be done, either
you could ask somebody to do them or potentially even
do them yourself. Is that totally out of the
possible?
MR. CAMPBELL: It's possible; it's
possible. It would take me a little bit of time to
tool up, back into that mode. What you're referring
to is when we had Cheryl Hawkins here --
DR. HORNBERGER: Right.
MR. CAMPBELL: -- as a summer intern. And
you know, frankly, I was relying heavily on Cheryl's
computing capabilities to run that. I'm familiar
enough with it I could do it.
It might not be the most efficient use of
my time, but it certainly would be worthwhile to be
able to go back to the staff and say, have you guys
looked at this.
DR. HORNBERGER: Look at this.
MR. CAMPBELL: To these particular
combinations of things.
DR. HORNBERGER: Right.
MR. CAMPBELL: And so we do have --
DR. HORNBERGER: Let me just --
MR. CAMPBELL: -- at least some tool. And
in fact, we actually have a tool that was all there.
Now, it might require a little bit of change to adapt
to the latest version of TPA, but there was this tool
that Cheryl put together that allows us to look at
kind of -- what do they call it Kilmagoroff,
(phonetic) Smirnoff type of sensitivities.
MS. DEERING: Isn't that George's tool?
MR. CAMPBELL: Yes, it is, by the way,
George's original tool, but Cheryl did a lot of work
to make it work on the TPA code. And I mean, the
insights, I gave you a thick document that Cheryl
wrote up as a final report last November that kind of
gives you how the insights from that analysis compared
to staff insights. And there was a good comparison.
DR. WYMER: One of the problems with
respect to the code that sort of came out of this
meeting we attended, there's an awful lot of stuff at
room temperature in the databases, but there's
precious little outside of room temperature in the
chemistry area.
And then also, in some of the minerals
that form -- there really aren't data, the
thermodynamic data that you need in order to decide
which compounds take precedence over other compounds
with respect to what's going to form.
So there are some fairly significant data
deficiencies, it seems to me, especially with respect
to temperature, but also with respect to just
fundamental thermodynamic data for stability of
mineral phases.
MR. CAMPBELL: Yes. There's, I mean, in
general there's a lot of room temperature, you know,
25 C type of data maybe going up to 50 C, and you have
a little bit around three or 400 C just before you get
to the critical point.
And then you don't have data until you get
way up into real high temperature pressure regimes
that you have --
DR. WYMER: Yes.
MR. CAMPBELL: -- deep within the earth.
The way that's generally handled is that the
thermodynamics people do these correlation type of,
you know, thermodynamic extrapolations.
DR. WYMER: You can do some of that, yes.
MR. CAMPBELL: Which can bound thermo data
to some degree, but you're right. There's not a lot
of data at this 100 to 300 degree range.
DR. WYMER: The argument's made that
before it's important the temperature's down again
before it ever seems to be. And that, of course, is
an issue, not an answer.
MR. CAMPBELL: And processes occur much
faster at these higher temperatures.
DR. WYMER: Yes.
MR. CAMPBELL: That's why it pops up as an
issue. I guess the real question for us is, are these
kinds of extrapolations done sufficient to bound the
problem?
Are they sufficiently conservative to
bound the problem so that, you know, the fact that you
don't actually have the data but you're relying on
some basic properties of Gibbs' Rule or whatever, to
get that -- some estimate of the data that you need,
is that sufficiently robust in the temperature
pressure regime you're interested in to answer the
question.
DR. WYMER: And it's another case of
whether sometimes you're drifting off into
assumptions, again, too, and solving your problem by
assumptions. So the whole thing is complicated.
MR. CAMPBELL: And I'm sure Dr. Steindler
will raise those issues, true to form.
(Laughter)
CHAIRMAN GARRICK: Any other comments,
questions, concerns?
(No response)
CHAIRMAN GARRICK: Okay. Well, I think
what we'll do is -- don't we have some lunch meetings?
MS. DEERING: Yes.
CHAIRMAN GARRICK: Yes. So why don't we
adjourn and get ready for that, and then come back
here at 1:00 o'clock for the discussion on entombment,
okay?
(Whereupon, the foregoing Meeting went
off the record 11:35 a.m., and went back
on the record at 1:05 p.m.)
. A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N
(1:05 p.m.)
CHAIRMAN GARRICK: The meeting will come
to order. The next item on our Agenda is the
Entombment Option Decommissioning Power Reactors. The
member that will lead the discussion on this is Dr.
Wymer. Ray, it's your subject.
DR. WYMER: Hi, Stephanie.
MS. BUSH-GODDARD: Hello. How are you?
DR. WYMER: Fine. We're struggling with
this, and I'm sure you are, too. And so we thought
we'd just have a sort of a discussion. Now, if you
want to use some view graphs, I understand you might
want to, that's fine in answering these questions.
MS. BUSH-GODDARD: Okay.
DR. WYMER: But entombment doesn't seem
like an unreasonable idea to us, but there seem to be
some major stumbling blocks to it. The greater than
Class C issue is certainly a biggie.
And then the -- getting decommissioning
done in six years after a license is terminated is
another potential problem that ties in with Class C
waste a little bit, maybe.
And whether or not we need changes in the
Waste Policy Act, and there are many, many facets or
hurdles to it, and whether or not you can safely seal
up and leave in place a reactor vessel, and what are
the implications of that.
And so we just wanted to kick this around.
You have these six issues.
MS. BUSH-GODDARD: Questions, yes.
DR. WYMER: And then I don't know whether
you wanted to proceed using view graphs addressing
each of the issues and talk from those. But in
general, we just wanted to exchange ideas and get some
notion of what the staff's developing, revolving
position is, insofar as you can do that.
MS. BUSH-GODDARD: Okay.
DR. WYMER: In this kind of a meeting.
MR. LARSON: I didn't give them to her in
any priority order, Ray. So you may have a specific
--
DR. WYMER: Each one of them is a
difficult problem.
MS. BUSH-GODDARD: Okay. What I do is I
have them on presentation and I also have them -- I'll
put them up.
DR. WYMER: Fine.
MS. BUSH-GODDARD: And we've kind of
answered them in bullet style. So I guess --
DR. WYMER: Okay. And then later on as
the conversation goes on, I guess if we have the
Nuclear Energy Institute representative, we'd like to
get their point of view on these issues to sort of
broaden the base from which we're trying to address
them.
MS. BUSH-GODDARD: Yes.
DR. WYMER: Okay. So if you just want to
start off, that's fine, and then we'll talk as we go.
MS. BUSH-GODDARD: Okay. As Ray said, my
name is Stephanie Bush-Goddard. And the ACNW
Committee sent us about six questions that -- okay --
that they wanted us to answer. And I would also like
to ask if my colleagues in the audience that are also
working on the entombment scenario, in particular Carl
Feldman and Bob Nelson, if they would like to comment
on the questions to help along.
DR. WYMER: Sure.
MS. BUSH-GODDARD: The first question was
how to handle the question of GTCC waste. And in
doing that we're developing a rule-making plan and an
advanced notice of proposed rule-making. So the
suggestions that I'm giving as the answers are not
necessarily the Commission's view, but are discussions
that we are developing.
If you look on page 2, we're developing an
option in the rule-making plan to establish
performance objectives and technical requirements for
an entombment facility.
(Pause)
CHAIRMAN GARRICK: Go ahead.
MS. BUSH-GODDARD: Okay. And in here
we're addressing GTCC wastes that these requirements
might be under a new part. They might be similar to
some of Part 61 requirements. Some of them may be
pathway analysis and performance requirements.
And in doing this we can address some of
the 1,000 year limitations that the License
Termination Rule has. So that's one way we're
addressing greater than Class C, maybe just developing
a new regulation particular to an entombed facility,
and specifically to handle GTCC waste.
CHAIRMAN GARRICK: At reactor sites only.
MS. BUSH-GODDARD: At this moment we're
looking at even expanding that to maybe other
nonreactor facilities. Yes.
CHAIRMAN GARRICK: Have you resolved the
question of threshold values and what have you?
MS. BUSH-GODDARD: No. We're definitely
in the preliminary stages. We've had the package to
go around for office concurrence only once.
CHAIRMAN GARRICK: Yes.
MS. BUSH-GODDARD: And like you said, we
had so many difficult issues. We've had to have a
couple of management meetings and numerous working
group meetings just to get over the basic things. So
no, we haven't --
DR. WYMER: No.
MS. BUSH-GODDARD: -- looked into that.
DR. WYMER: I can certainly understand
that.
MS. BUSH-GODDARD: Another option is
concentration averaging; as we know, what happened
with the Trojan reactor case where they did
concentration averaging over the reactor pressure
vessel. So that's another way to handle GTCC.
And in doing that now we will not
necessarily be classified as GTCC waste, and then
won't have those limitations on it.
DR. WYMER: Now, was that reactor vessel
filled with concrete? Was that empty?
MS. BUSH-GODDARD: I'm not sure. Do you
know, Dr. Feldman?
DR. FELDMAN: Yes. It's filled with
grout.
DR. WYMER: Yes, grout.
MS. BUSH-GODDARD: Okay.
DR. WYMER: Grout.
CHAIRMAN GARRICK: You've got to speak
into a microphone.
MS. BUSH-GODDARD: Okay. Yes, it was
filled with grout.
CHAIRMAN GARRICK: Got the answer.
MS. BUSH-GODDARD: Yes.
DR. WYMER: Thanks. Okay.
MS. BUSH-GODDARD: So there's two ways of
handling it.
DR. WYMER: Is it considered that those
reactor vessels will be sealed so that effectively
nothing can get inside, anything that attacks it would
be from the outside?
MS. BUSH-GODDARD: There's two ways to
look at that. Over time you could have the
possibility of something leaking out of the concrete
or the steel structure. So I think in the pathway
analysis that you would have to do, you would have to
consider all pathways.
And that's, you know, something, water or
whatever getting in and then bringing the
radioactivity out.
DR. WYMER: Is it considered that there'll
be other contaminated materials that might be thrown
into the reactor vessel and then grouted in place in
there, or?
MS. BUSH-GODDARD: At this particular time
-- do you mean things like spent fuel?
DR. WYMER: No. No. No. No.
MS. BUSH-GODDARD: I was just going to
say.
DR. WYMER: No, other contaminated --
DR. FELDMAN: Control rods.
MS. BUSH-GODDARD: Oh.
DR. WYMER: Yes, contaminated metal and
parts of the reactor itself.
MS. BUSH-GODDARD: That are outside?
DR. WYMER: That are not part of the
containment vessel, but which are part of the reactor.
MS. BUSH-GODDARD: Oh, I don't know. We
haven't got to that detail yet.
DR. WYMER: Okay. That seemed to me in
thinking about it that that might be a rather
important consideration.
MS. BUSH-GODDARD: Okay.
DR. FELDMAN: Hi. I'm Carl Feldman. I
just commented the -- I'm over here. Actually, let me
move more -- I'm sorry. The idea is a general idea,
so we would put in various low level waste materials
or whatever in the reactor vessel, and then grout the
whole thing in.
DR. WYMER: Okay.
DR. FELDMAN: Or you might not even grout
it, depending on how -- what the content is.
DR. WYMER: Yes. Yes, that does have
implications with respect to how valid the volume
averaging --
DR. FELDMAN: Yes.
DR. WYMER: -- concept is.
DR. FELDMAN: Yes.
DR. WYMER: Yes.
DR. FELDMAN: Again, this is preliminary.
So depending upon how much -- whether they want to use
greater than Class C waste or not, and what the
options are, are still open right now.
DR. WYMER: The reactor vessel would have
sealed lid on it.
DR. FELDMAN: Yes, the reactor vessel
would be sealed and you might or might not grout it,
depending upon what's in there and the pathway
analysis and the whole show.
DR. WYMER: Yes, okay. These are the kind
of things we need to get so we could think
intelligently.
CHAIRMAN GARRICK: If you're going to
change a rule or something wouldn't it be better just
to create a entombment-specific rule and get away from
the A, B, C classification completely, and
establishing the thresholds for the entombment option.
DR. WYMER: Our position when we framed
this rule was basically using the license termination
rule types of criteria. It took us forever to do that
one. We're not saying those are good limits.
It's just a question of making sure you
have adequate pathway analysis and isolation from the
environment, so working around that. But the idea
there was to think about 50-82, which is the 60-year
time limit, and the license termination rule and
whether -- and how far you could go with those as they
exist now, and what you would have to modify to be all
inclusive or a broader type of entombment
consideration. So that was our --
DR. LEVENSON: Is it envisioned that --
I'm having a little trouble grasping what we're
talking about. Is the entombed article, would that be
the pressure vessel and whatever you might put inside
it? Or is it much more generic?
Would you entomb a contaminated steam
generator right next to a pressure vessel? What are
we talking about, first of all?
DR. FELDMAN: No. We're talking about the
reactor containment building, vessel, et cetera, and
using that as the primary entombment configuration.
And whatever you want to cut up and put in there is a
possibility, too.
DR. LEVENSON: Okay. So it's not -- the
discussion to date has been just on the vessel.
DR. FELDMAN: No.
DR. LEVENSON: You're not limiting it to
that.
DR. FELDMAN: No.
MS. BUSH-GODDARD: No.
DR. LEVENSON: Okay.
MR. LARSON: So you're including
entombments greater than Class C waste --
DR. FELDMAN: As a possibility.
MR. LARSON: -- in the containment
building.
DR. FELDMAN: As a consideration for
consideration -- as something to think about, yes.
DR. WYMER: And learning a new regulation
to cover that.
MS. BUSH-GODDARD: Yes, as a possibility.
DR. WYMER: Perhaps.
DR. LEVENSON: Or a modification.
MS. BUSH-GODDARD: Or a -- yes.
DR. WYMER: A modification to the existing
regulation. Yes, okay. But you're not really giving
serious consideration to what John said; namely, we're
writing another --
DR. FELDMAN: Well, I think that's another
option that was -- that is coming up that Stephanie is
going to discuss. There was one of these so-called
option threes. I think option one was leave it alone.
Option two is modify it by modifying maybe
50-82 and the license termination rule as appropriate,
and option three, one version of option three is to
create a new rule. We're still toying with that kind
of concept. It's not --
DR. WYMER: Yes. The precedent that I see
is you did create a new rule Yucca Mountain, and that
was a big deal. And I think this -- a look at
entombment is a big deal. And so it's a parallel.
DR. FELDMAN: Well, some of it is not that
big a deal in the sense that the license termination
rule -- part of the reason for this while
entombmentation consideration comes about because the
license termination rule allows for restricted release
with conditions.
DR. WYMER: Yes.
DR. FELDMAN: And while that's limiting
for the general entombment considerations for the
reactors, nevertheless, it leads to that kind of
investigation. And so it's almost more -- it's a more
natural kind of process to look at it that way.
At least that's why we look at it
initially that way.
DR. WYMER: So if you went to a restricted
release mode, for example, just discussing that for a
minute --
DR. FELDMAN: Yes.
DR. WYMER: -- then you would -- the
utility would have to come up with some sort of a
long-term financial --
DR. FELDMAN: Yes.
DR. WYMER: -- program that would
guarantee --
DR. FELDMAN: Yes, but it's the same now,
too. It's the same restrictive release for non-
entombment. For whatever set-up they have, there has
to be adequate financial resources to maintain it.
DR. WYMER: Yes.
DR. FELDMAN: It would be maintained
presumably by the state or some group.
DR. WYMER: Yes, now, that's a little
different.
DR. FELDMAN: It's different, yes, I know.
I know.
DR. WYMER: So there is quite a
difference.
DR. FELDMAN: But this is sort of a
generalization of that and one way to look at it.
DR. WYMER: Okay. So there's no
consideration that is being given to whether or not
the utility would have to be responsible or whether
some governmental body would have to be responsible?
DR. FELDMAN: Yes. That has to be
included as part of the -- whatever look at this thing
is going to --
DR. WYMER: Yes, okay.
DR. FELDMAN: The other thing is, the
license termination rule is limiting, too, in that the
100 millirem and 500 millirem, while that's something
we would want to stay within, when you have -- if
you're thinking about a very hot type of situation --
DR. WYMER: Yes.
DR. FELDMAN: -- then there's the
potential for exceeding that, and so you have to worry
about that, too.
DR. WYMER: Right.
DR. FELDMAN: So.
DR. WYMER: Okay. Yes. That's very
helpful. This discussion is helpful.
Okay. Stephanie.
MS. BUSH-GODDARD: Okay. The next
question is how to address the issue of engineered
barriers. Once again, there are a couple of things
that we're looking at. First, let's kind of look at
the demonstration decommissioning criteria -- excuse
me -- for the West Valley Demonstration Project, and
define engineered barriers as they did, saying that if
a barrier does not require an institution or a human
factor to maintain its effectiveness, then it's an
engineered barrier.
But we're also thinking about maybe
amending the regulations to clarify what an engineered
barrier is. So that's --
DR. WYMER: Okay. You're --
MS. BUSH-GODDARD: And once again, that's
preliminary, too, you know.
DR. WYMER: You're walking on soggy
ground, there.
MS. BUSH-GODDARD: This is a soggy
package.
(Laughter)
DR. LEVENSON: We can do it on dry ground.
MS. BUSH-GODDARD: That's true. And then
I said other, like I said, once you put out the AMPR
we're going to get comments from commenters, maybe
some licensee or some other entity might give us a
definition of how we should define engineered
barriers.
DR. WYMER: Okay. You might come back to
that, but let's go ahead.
MS. BUSH-GODDARD: Okay.
DR. WYMER: I've now had -- now, I've got
to digest that.
CHAIRMAN GARRICK: Is that the definition,
a unique definition? Is that new for engineered
barrier?
MS. BUSH-GODDARD: It means a -- the West
Valley definition?
CHAIRMAN GARRICK: Yes. Yes. Is that
what we mean when we say engineered barrier?
MR. NELSON. Yes. This is Bob Nelson,
Chief of the Facilities Decommissioning Section,
Decommissioning Branch, Division of Waste Management.
The interpretation that's expressed in the
-- that -- excuse me -- that Stephanie summarized here
is based on a review of past practice, how the Agency
has treated engineered barriers in other cases, and
also, based on the analysis of the language in the
statements of consideration in the rule itself.
The OGC created a rather lengthy paper
addressing this, but the basic conclusion was that
based on that review and past practice that if an
engineered barrier did not require human intervention
to maintain its effectiveness, then it should not be
considered an institutional control.
DR. WYMER: Okay. What would be an
engineered barrier, for example? Would it be a --
MR. NELSON: I can address that, first of
all generally, and then more specifically. Normally,
an engineered barrier is a -- some constructed device
or feature that typically is incorporated into a
design, a waste design, to either limit infiltration
of water or slow or retard groundwater flow or
resurface water flow.
DR. WYMER: Yes, that --
MR. NELSON: Around the grout. That's
generally what an engineered barrier's considered to
be.
DR. WYMER: I would like an example or
two.
MR. NELSON: A cap.
DR. WYMER: A cap to do what?
MR. NELSON: A cap, a slurry wall, a
swale.
DR. WYMER: Okay.
MR. NELSON: A grout curtain.
DR. WYMER: Yes.
MR. NELSON: All of those things would
normally be considered engineered barriers. The
problem with assuming calling those, then,
institutional controls is that the license termination
rule requires you to do an analysis when institutional
controls fails.
And that means a time zero assumption that
all your engineered barriers vanish, which is an
unreasonable, in minds of a lot of folks, an
unreasonable assumption. You should be able to take
credit for the barrier for as long as you can justify
taking credit for it.
Assuming that a cover vanishes
instantaneously or a concrete wall evaporates is a
little conservative.
DR. WYMER: Yes.
MR. NELSON: So the definition -- I'd call
it an interpretation rather than a definition that OGC
has proposed is that to the extent that you have to
rely on human intervention to maintain effectiveness,
that you can no longer count on its effectiveness.
CHAIRMAN GARRICK: So it's defined in
terms of the transport or movement of water?
MR. NELSON: Well, that's generally how an
engineered barrier is --
CHAIRMAN GARRICK: As opposed to
radiation?
MR. NELSON: Well, I used the -- clearly
a cover wall, so affect direct radiation exposure, as
will the other, as I mentioned. But the principal use
of an engineered barrier has been, at least in our
practice, has been focused on migration rather than
controlling direct exposure, although clearly, things
like a cover will have a direct impact on direct
exposure.
CHAIRMAN GARRICK: Okay. That helps a
lot. Thanks.
CHAIRMAN GARRICK: Yes, thank you.
MS. BUSH-GODDARD: Okay.
DR. WYMER: That's a pretty
straightforward answer, no.
MS. BUSH-GODDARD: Well, we're saying
maybe not. The approach can definitely develop within
the existing acts, but the regulations might need to
be changed as we were talking about, amending 50-82,
maybe --
DR. WYMER: I might take the word "might"
out of there.
MS. BUSH-GODDARD: Okay.
DR. WYMER: Say regulations need to be
adjusted.
MS. BUSH-GODDARD: Okay.
DR. WYMER: There's no might about it, is
there? Won't they have to be?
MS. BUSH-GODDARD: Well, like, for
instance, if you look at an option one where you don't
-- there's no rule-making, you can do an entombment
approach within the existing regulations, within the
60-year limit, but that might be limited. So --
DR. WYMER: With what they created, the
Class C waste won't fit in there.
MS. BUSH-GODDARD: No, exactly. You'd
definitely have to take out the pertinent class.
DR. WYMER: So that they need to be
adjusted.
MS. BUSH-GODDARD: Okay.
DR. LEVENSON: For GTCC.
MS. BUSH-GODDARD: For -- okay, yes.
DR. WYMER: Yes, for GTCC.
DR. WYMER: But that's in there, see.
MS. BUSH-GODDARD: Okay.
DR. LEVENSON: Now, even if it -- but
since it's a generic it might not be GTCC.
DR. WYMER: Have to go to a microphone
there.
DR. LEVENSON: If we're talking about a
generic case then, since it isn't primarily focused on
the pressure vessel, you might have cases where you
want to entomb everything but the pressure vessel --
DR. WYMER: Right.
DR. LEVENSON: -- at a sight, and it might
not be GTCC.
DR. WYMER: So that --
DR. LEVENSON: So I think this is correct.
DR. WYMER: Okay. So you'd have to
partition the new regulation.
DR. LEVENSON: Oh, it clearly would be
different if there is or is not GTCC.
DR. WYMER: Yes.
DR. LEVENSON: But these are all within
the generic envelope they're looking at.
MR. NELSON: Bob Nelson again, the
Division of Waste Management. The point of the first
bullet is that the entombment can be done today under
the existing laws and regulations. It's only source
term constraining.
DR. WYMER: Right.
MR. NELSON: If you reduce the source term
enough you can entomb under the LTR, under the license
termination rule. To some, 50-82 limits the amount of
time you can allow -- you can have time to help you
out on that, to 60 years.
But if you remove, then, the higher
activity components from the containment, you could
entomb the rest under the LTR. So it's just source
term constraint.
DR. WYMER: I guess I'm having a sort of
a semantic difficulty here.
DR. FELDMAN: May I make a qualification
of 50-82? Carl Feldman, research. 50-82 is for case
specific approval.
DR. WYMER: Yes.
DR. FELDMAN: So provided it's some kind
of a health and safety situation. So it could go way
beyond the 60 years, if it were health and safety.
DR. WYMER: I'm having a little problem
with the words. I guess to me entombment meant
something different than what it means to you. In one
case you've just got a little old waste disposal
facility on site.
In the other case, you got a reactor
vessel that has some activity in it and you're
entombing it. Those are two different things in my
mind. Now, maybe they're not in yours.
DR. FELDMAN: The GIS that we did back in
I guess '88, entombment dealt with putting something
in some kind of a barrier and going to a termination
of license through decay.
DR. WYMER: No.
DR. FELDMAN: That's the -- I'm sorry --
that's the original concept. Now, you know, what they
want to call it now, I don't know. But --
DR. WYMER: Yes.
DR. FELDMAN: -- the idea is to terminate
-- everything we structured in the decommissioning
rule and GIS was to terminate that license.
DR. WYMER: I had a narrower view of it.
My view was that what this entombment thing was all
about was to enable you to -- the utility to save
money by leaving the reactor vessel in place then --
DR. FELDMAN: Yes, sure. Sure.
DR. WYMER: -- entomb it, and that's a
much narrower point of view than what I'm hearing
expressed now, and I think it needs to be sorted out
a little bit better.
MS. BUSH-GODDARD: Well, that's -- we are
in the rule-making plan stage now, and I think what
we're doing is trying to put all the options on the
table.
DR. WYMER: Okay.
MS. BUSH-GODDARD: Whereas, I think in the
past it was considered strictly as a decommissioning-
type activity.
DR. WYMER: Yes.
MS. BUSH-GODDARD: But now, we are also
looking at the possibility of maybe it being more-so
a disposal-type activity as opposed to
decommissioning.
DR. WYMER: Right.
MS. BUSH-GODDARD: But these are only
options that are on the table.
DR. WYMER: Sure. And that's all we -- I
realize that's all we're discussing.
MS. BUSH-GODDARD: Yes.
DR. WYMER: But I wanted to make it clear
that there was some confusion in my mind, and I
suspect that there is -- my mind is not the only one
that's --
DR. FELDMAN: I think it's a broadening of
the Commission paper that requested entombment of
power reactors.
DR. WYMER: Yes.
DR. FELDMAN: But that just basically
talked about power reactors and decommissioning.
DR. WYMER: Yes, and that's the context in
which I was thinking about it.
MS. BUSH-GODDARD: Yes.
DR. WYMER: And I guess I would prefer to
continue thinking about it that way.
DR. LEVENSON: Well, that's why I had
asked the question I asked.
DR. WYMER: Yes. Okay. Well, okay. You
see what my problem is.
MS. BUSH-GODDARD: Okay. We talked about
the 50-82 limits, and I assume that you meant the 60-
year decommissioning time limit or time limit for
decommissioning?
DR. WYMER: Yes, that's one of the big
points in there. Yes.
MS. BUSH-GODDARD: Okay. Like I said, the
LTR, as both Carl and Bob said, might limit some
facilities. If we keep the 60-year time limit, we
might not be able to keep the LTR.
DR. WYMER: Yes.
MS. BUSH-GODDARD: But also, a question
is, if credit can be given to engineered barriers for
dose reduction, we might be able to meet the 60-year
limit or shorten it. So the question is to what
extent can dose reduction credit be given.
DR. WYMER: Yes. I guess I was thinking
in terms of lengthening it. So you're talking in the
opposite direction.
MS. BUSH-GODDARD: Well, no, I'm talking
in both -- I'm talking in all directions --
DR. WYMER: Okay.
MS. BUSH-GODDARD: -- actually.
DR. WYMER: Okay.
MS. BUSH-GODDARD: If you can give little
dose reduction credit you would have to lengthen the
60-year time frame.
DR. WYMER: Yes.
MS. BUSH-GODDARD: So I think that's the
question that we're also struggling with.
DR. WYMER: And if you allow the barriers
to evaporate, then you also -- we're going to have to
lengthen the time.
DR. FELDMAN: When we did the license
termination rule we had no entombment concept at all.
We weren't even -- we weren't looking at that at all.
DR. WYMER: Yes. I realize that, yes.
This is an extension.
DR. FELDMAN: Sure, yes.
DR. WYMER: Yes.
MS. BUSH-GODDARD: Yes.
DR. WYMER: Okay.
MS. BUSH-GODDARD: Is waste concentration
averaging applicable and acceptable? Talked about the
Trojan Reactor case and there, permission was given by
an agreement state. We don't have an answer on this
one yet.
But in looking at it, DOE was given the
responsibility for developing a national disposal
strategy and we were given the responsibility for
licensing.
DR. WYMER: Yes.
MS. BUSH-GODDARD: So waste -- you know,
that's kind of a gray area, you know. I think they're
waiting on us for some lead in this, and we're looking
to see what they want to do. So I don't have a
definite answer for this, either.
DR. WYMER: Yes. One of the reasons I
asked the question about, is the containment vessel
going to be sealed, is if it is and you can make some
case for it staying sealed for awhile, then you can't
really do concentration averaging because -- volume
averaging, because you can't use the internal volume
if no water gets in there.
And if the radioactivity doesn't disperse
itself inside that volume then there's no logic to
using volume averaging, just because it would all be
external and there's no volume there on the outside of
the container.
So there's a logical, technical problem
there, as well. And it's, just exactly what do you
mean by volume averaging? That's also relevant to the
question of how much trash do you throw inside the
vessel?
DR. FELDMAN: Yes.
DR. WYMER: If you throw a lot in there
and it has a lot of radioactivity --
DR. FELDMAN: Right.
DR. WYMER: -- relative to what's induced
in the --
DR. FELDMAN: Right.
DR. WYMER: -- in the containment vessel,
then volume averaging makes sense. But if you throw
the waste in, trash in there and it's low level, then
it doesn't add anything to the radioactivity and
volume averaging doesn't make much sense against it.
All these things are a problem.
DR. FELDMAN: Well, the case in point is
Trojan, where they took the vessel out intact, filled
it up with some concrete or fill or whatever, then
buried it in Hanford.
DR. WYMER: Yes.
DR. FELDMAN: It has a volume-averaged
type of currie concentration so that they could meet
the low-level waste criteria.
DR. WYMER: But that does assume that
you're going to get dispersion of that --
DR. FELDMAN: Yes.
DR. WYMER: -- of the radioactivity within
that grout.
DR. FELDMAN: Ultimate -- yeah, yes, it
does.
DR. LEVENSON: Ultimately.
DR. WYMER: Ultimately.
DR. FELDMAN: Ultimately.
DR. WYMER: Yes, ultimately. Okay. Well,
these are problems.
DR. FELDMAN: Yes.
DR. WYMER: Okay.
MS. BUSH-GODDARD: Then the last question
was, should the facility be monitored during the
entombment period, and how? As we talked about, we
haven't really developed the definition of an
entombment period.
You know, for example, is it a
decommissioning, or is it a disposal or just whatever.
So it's hard to answer that question. However, if you
adopt the LTR criteria, then once the license is
terminated, of course, and you meet the requirements,
the entombment facility is no longer monitored.
DR. WYMER: Yes. Yes.
MS. BUSH-GODDARD: However, the other
option that we're suggesting is that you develop these
performance objectives and technical requirements, and
in that period of time you would have to do some
monitoring until you terminate the license.
DR. WYMER: Yes.
MS. BUSH-GODDARD: Under whatever
criteria.
DR. WYMER: So it's your sort of general
approach that if you expand on this regulation or
write a new one, that it'll be broad enough and go in
enough different directions that now matter what the
utility decide to do, you got them surrounded.
If they decide to go to a restricted
license termination, then there's some -- some
provision has to be set up for institutional
management.
MS. BUSH-GODDARD: Yes.
DR. WYMER: If you change the regulation
with respect to greater than Class C so that you can
have greater than Class C on the site, then that's
another deal that has to do with engineered barriers
and has to do with modeling to demonstrate
containment.
MS. BUSH-GODDARD: Yes.
DR. WYMER: So you're going to cover it;
every way it might go, you've got it covered. Is that
-- that's your general approach?
MS. BUSH-GODDARD: Yes, to put all the
options out.
DR. WYMER: And entombment is going to be
kept as a broad term, rather than one that applies
fairly specifically to reactors, containment vessels.
MS. BUSH-GODDARD: Well, not necessarily
so. If we get comments back, you know, it depends on
I guess how the comments go, and you know, how the
Commission wants to proceed on what we send up and
what we suggest.
So it could be only limited -- it could be
the decommissioning only of power reactors.
DR. WYMER: Yes.
MS. BUSH-GODDARD: Where you have to meet
the license termination rule, and maybe extending the
60-year time frame.
DR. WYMER: Yes.
MS. BUSH-GODDARD: So it just depends.
DR. WYMER: It would be cleaner to
separate it out cleanly for reactors, since that's a
whole separate -- in my judgment -- a whole separate
class of thing quite apart from low-level waste
disposal sites.
MS. BUSH-GODDARD: Yes.
MR. LARSON: But then you got intermediate
things like a hot cell, which you could look at that
as a containment in the sort.
MS. BUSH-GODDARD: Yes.
MR. LARSON: But you're saying you don't
know whether you'd consider that or not, as opposed to
Ray's end thing of a low-level waste disposal
facility. So you know, the Committee was going to
comment the last time, but they expected that they
would get AMPR, the plan within a couple of weeks.
MS. BUSH-GODDARD: Yes.
MR. LARSON: And the Committee'd probably
be interested in what the current schedule is or when
they expect to see something because, you know, they
haven't seen the logic as to anyone of these
approaches.
MS. BUSH-GODDARD: Well, exactly. I can
say that we did get an extension today.
DR. WYMER: We understood that.
MS. BUSH-GODDARD: And this is an
extension to extend the Commission date of sending the
rule-making plan and AMPR up to SECE (phonetic), I
believe it's June 1st.
DR. HORNBERGER: That was a blessing,
wasn't it?
MS. BUSH-GODDARD: Oh, definitely a
blessing. So we're still at the drawing table.
DR. HORNBERGER: Yes. Well, we can't
really prepare a letter until we see a lot more
definition, until you people -- until you clarify all
of these issues and what exactly -- how you're going
to deal with it.
MS. BUSH-GODDARD: Now, we are sending
paper off for office concurrence, and I think you all
are on that distribution, and that's going to be
within two weeks, definitely within two weeks.
DR. WYMER: Well, that'll -- okay --
that'll be something, yes. Well, that's all very
helpful, Stephanie. We appreciate your bringing us up
to date, and it clarifies a lot of -- well, it doesn't
clarify a whole lot, but it explains a lot to me.
It's no more clear to me than it is to you.
MS. BUSH-GODDARD: Exactly, yes.
CHAIRMAN GARRICK: It sounds like this is
kind of a variation on the theme of in situ disposal.
Is there a general category of disposal that if you
would look at it rather than in the context of
entombment that would give you greater flexibility on
licensing?
Have you considered a general approach to
in situ disposal?
MR. NELSON: I think -- excuse me. Bob
Nelson again. The staff's trying to flesh out the
options that it's presenting us have raised a lot of
these types of questions. And after we got past
option one, which is just let the license termination
rule handle it and don't make any changes, we got into
all of these things.
Is it just -- should it just be focused on
reactors or are we -- are there things here that would
have -- that are more generic and would apply to in
situ type disposals?
The question of how to treat engineered
barrier really kind of launched this discussion
because we were moving forward to the Commission with
a position on engineered barrier versus institutional
controls on West Valley.
And we saw that a position on that needed
to be taken that was consistent with what we were
doing at West Valley, or we had to have a clear reason
why there should be some other approach taken for
"entombment."
So that discussion kind of drove us into,
well, aren't there other generic issues here that we
need to consider. So the long answer to your
question, but yes, it did open the generic question.
So we were looking at, one, don't do
anything. That was pretty clear. The other option
was, okay, well, let's make some possible -- option
two was -- some changes, like for example, extending
the time limit in 50-82, maybe clarifying the
definition of engineered barriers and some other
things.
In other words, making some modifications,
minor modifications to a set of regulations. And then
the third option was, well, let's just develop
something new for this thing.
CHAIRMAN GARRICK: Yes.
MR. NELSON: Whatever this thing is.
CHAIRMAN GARRICK: Well, if we --
MR. NELSON: And that's really been the
focus of the staff's development --
CHAIRMAN GARRICK: Yes. The idea here is
that if we're really trying to move in the direction
of a RIPB, risk informed performance base practice of
regulation it would seem that you could define a
category of conditions that would apply to all in-
place disposal situations and be done with it.
CHAIRMAN GARRICK: That's definitely an
approach.
DR. WYMER: A comment --
CHAIRMAN GARRICK: But remember that we're
not trying to define the way the staff's going to go.
What we're trying to do is frame options that we can
put out in an AMPR to get a discussion going and get
some feedback, along with some focused questions on
those options.
So we're not narrowing down what we want
to do. We want to make the options broad enough that
it covers a reasonable span of potential paths forward
on this topic.
MR. NELSON: That's exactly what I'm
getting at.
DR. WYMER: Yes.
MR. NELSON: Because otherwise you get
into a situation, well, we've done this for reactors
and now we're going to do this for hot cells. Then
we're going to do this for waste storage facilities.
We're going to do this for fuel fabrication
facilities. We're going to do this for reprocessing
and so on and so forth.
DR. WYMER: It's a fine balancing act
between being so general that you can't work with it
and being so specific that you've got a hundred cases.
DR. FELDMAN: Could I just comment? The
approach for the reactor was that it was sort of a
natural thing, and if you were going to go -- I'm
sorry -- if you were going to go for an entombment and
you wanted some sort of easier path to follow, then
reactors are the types of things, especially power
reactors, because they're not -- they're nice
-- they're sort of tidy.
You have all sorts of barriers built into
them. You have decay processes that are fairly robust
in some situations and you have, then, as part of the
metallurgical structure you don't readily -- wouldn't
expect them to readily leach out, depending upon how
you treated them and so on.
And so that was why this was a fairly
reasonable way to go initially, and if you broaden it
too much, as you say, then you run into a lot of
problems.
DR. LEVENSON: I have a question, John.
We talk about power reactors, but you really aren't.
You're talking about PWRs.
DR. FELDMAN: No.
DR. LEVENSON: BWRs aren't -- don't have
containment buildings. I mean, they're --
DR. FELDMAN: Well, yes. Yes.
DR. LEVENSON: -- significantly different
--
DR. FELDMAN: Yes.
DR. LEVENSON: -- problems. The pressure
vessels are --
DR. FELDMAN: Sure.
DR. LEVENSON: -- a factor of two or three
thinner. The problems would be quite different.
DR. FELDMAN: But they're are -- you're
right, but there are engineering compensations even
for those, depending upon --
DR. LEVENSON: But they're different.
DR. FELDMAN: They're different, yes,
they're different.
CHAIRMAN GARRICK: Yes.
DR. WYMER: Okay. Well, it really has
been helpful, Stephanie. It gives a good feeling of
where we are at the present time, and we appreciate
your coming in and sharing these problems with us, and
your struggles toward solving them.
CHAIRMAN GARRICK: I think Andy has
another --
DR. WYMER: Are there other questions?
MR. CAMPBELL: Yes. Actually, the more
you talk about the entombment option, the more it
sounds like a Part 61 site when you think in terms of
the total number of curries and so on.
How are you going to resolve all the
various limits in Part 61 with respect -- I mean, in
essence, if you go down this road you're not sending
anything to a Part 61 site which would normally have
gone to a low-level waste site.
You're disposing of it on site, but within
Part 61 -- I mean, Trojan's a special case because it
went to an already existing Part 61 site, and
therefore, met the siting requirements and so on and
so forth that you normally associate with a Part 61
low-level waste site.
Now, you're talking about reactor sites,
which more often than not were chosen because they're
near water. They're not necessarily stable for all
kinds of long time frames. You're talking about
greater than Class C waste, which is under Part 61 not
considered -- generally not considered suitable for
near surface disposal.
You've got a lot of issues with Part 61
and how are you going to deal with that?
DR. WYMER: Well, I'd sort of like to
solve this discussion if we can and give Paul Genoa
here a chance to give us the NOI perspective on this
thing, if you will, Paul.
MR. GENOA: Well, thank you, Mr. Chairman.
I appreciate this opportunity again. I'm Paul Genoa
with the Nuclear Energy Institute, and have been
looking at the issue of options for operation and
decommissioning of power reactors primarily.
And many of the questions you've asked
today have been asked by our members, as well.
Fundamentally, our thinking is that at the early
stages that clearly we believe that there are options
for decommissioning facilities other than digging them
up and moving them to another part of the country, and
it can be done safely, we believe.
The license termination rule, being a
performance-based rule, really begs the question,
well, how can you interpret that. Is there a way to
meet the license termination criteria by simply
isolating the material at a facility on site in a way
that it doesn't exceed the performance-based rule?
We think the answer's yes. Unfortunately,
it gets very quickly complicated. Initially, our
proposal at the NRC's workshop in entombment -- and we
would very much like to see the name change. We think
that the name is confusing.
We think something like enhanced SAFE
store or enhanced isolation or any number of other
words might be better. But fundamentally, we thought
that there are a range of options all the way from
operating the plant routinely, as you always have,
sending all the waste to a low-level waste facility,
coming to decommissioning, doing chemical cleaning,
perhaps to scour out all the active you can reasonably
scour from the facility, perhaps even removing the
greater -- the Class C components from the core,
putting them into storage like fuel oil with the fuel,
and ultimately just leaving the facility itself on
site, which would be a very lower activity.
That would be on one end of the extreme,
and the other, as you've mentioned, is the possibility
of actually entombing the reactor itself. Now, the
question of engineered barriers, I think that
shouldn't be confused with institutional controls.
Clearly, if you're going to leave residual
activity and you're going to have a restricted release
scenario as envisioned by the LTP, there will be
ongoing institutional controls that will -- must be in
place.
And it has to be outside the operator's
hands, and the operator will be responsible for
funding of all sorts of active maintenance over time,
and for funding those institutional controls. But
they're going to have to be doable controls, probably
a state or federal government control.
But you know, that can be explored clearly
outside of the operator's control. Certainly, it
would be easier to do institutional controls for 130
years than 1,000 years.
And so, you know, often we believe that
we'd like the option, but it would be nice to walk
before we run, and perhaps to show that the entombment
can be managed for any type of a facility with a
constrained source term within it.
But then if you want to also look at some
special conditions that would allow greater than Class
C to be entombed within the structure, that would
certainly make sense, but it would raise the bar
considerably.
We just hope that the debate doesn't get
like, like in clearance, where we only talk about
metals. In reality, it's a much broader rule. The
same thing with entombment. There are a variety of
scenarios that could be envisioned.
We think on the issue of engineered
barriers you're really thinking, what are the
assumptions that I can put legitimately into a dose
modeling scenario that would give me an accurate dose.
And as we've seen in performance
assessments space for Part 61, there's been views
that, well, you know, engineered barriers we can maybe
credit for about 500 years.
But beyond that you're -- you know
-- perhaps we could count on the chemical properties
of concrete or a large cementatious mass would, you
know, inhibit certain isotopes from migrating. Maybe
we could buy that more than 500 years.
But clearly, as we see in the entombment
option for everything other than greater than Class C,
you only need about 130 years. Certainly, there are
engineered barriers that we could count on.
And what we would ask is the Commission,
is it deliberate to really reflect on what we've
learned our high level waste program. Certainly,
engineered barriers are going to be used at Yucca
Mountain or some other predecessor of that facility.
And we would hope that you would recognize
that those are out there and available. But
institutional controls, they're currently being used
by the EPA and Super Fund, and we're going to have to
look at those for DOE facilities and other facilities
across the country.
We think that's not insurmountable. We
don't believe that you need to change the Nuclear
Waste Policy Act or the Low-Level Waste Policy Act,
necessarily. Again, entombment could be an option
that doesn't even deal with the greater than Class C
waste.
However, there certainly are advantages.
When I was here last I offered to you that it makes us
question the value of cutting up the reactor
internals. Connecticut Yankee is now cleaning up from
that process.
They will expend about 160 MAN REM, maybe
170 in that job. Now, the difference is really not
because they cut it up. It's because how they cut it
up.
Absent waste acceptance criteria, they
made -- from DOE -- they made a decision that the
safest thing is to cut up into real small pieces
that'll fit into what they call fast cans or fuel-size
cans.
That extra cutting is what caused the
extra dose. Main Yankee's going to use another
approach, but they're doing it at risk because they
don't have clear guidance from DOEO, what it would
take to accept this material.
Now, they're cutting up into bigger chunks
and it's not as dose intensive. So you know, there
are different ways to do this. Solving entombment is
one solution, but encouraging DOE to come up with a
waste acceptance criteria would certainly be another.
And I guess finally, what we're looking
for is options, and we would hope you'd continue to
expand the thinking on this concept and perhaps change
the title of this concept to allow for what we believe
certainly are realistic opportunities to safely
isolate materials at facilities.
And my final comment would just be that we
are looking at this not just as a way to save a buck.
I mean, that certainly is an element of everything.
There's always economic considerations. But you
really need to take it in holistically.
This is an opportunity perhaps to maintain
some benefits at a community that has hosted a
facility during its operational life. You know, why
take 4- or $500 million and dig that facility up and
take the facility and the dollars to some other place
in the country, when perhaps it can be safely isolated
on site and funds can stay in the local community for
oversight, monitoring, you know, jobs for security and
so forth.
So the concept we view is that this would
be tried as an option not by everybody, but by a
facility that is industrial in nature, that will
continue to be an industrial facility for sometime in
the future, that looking over an entombed reactor on
site would not be a large burden if it was done
properly.
That would reduce cost, would create jobs,
oversight for the community and for the state
government and the regulator and so forth. So those
are some of my thoughts.
DR. WYMER: Well, thank you very much.
Let me ask you a technical question you probably won't
be able to answer. Is it likely even that a reactor
containment vessel with the induced radioactivity in
it would be less than --
DR. LEVENSON: You mean a pressure vessel?
DR. WYMER: Pressure vessel. I'm sorry,
pressure vessel -- would be less than Class C waste at
the end of 60 years? Don't you think that that vessel
would be greater than Class C for longer periods of
time than that?
MR. GENOA: Yes, unless you cut the
internals out of it. Those internals are by
definition, if you separate them, those are greater
than Class C.
DR. WYMER: But the --
MR. GENOA: The reactor core barrels.
DR. WYMER: -- but the vessel itself is --
MR. GENOA: The reactor vessel is not
necessarily.
DR. WYMER: Not necessarily.
MR. GENOA: Yes. And just for a point of
clarification, the grout at the Trojan facility was
not for concentration averaging. The grout was there
to fix the internal contamination, so in a
transportation accident it wouldn't be released. That
was part of the scenario. So --
DR. WYMER: But the volume averaging,
nonetheless, took into account the internal volume.
MR. GENOA: It didn't take -- I don't
believe it used the volume of the dead air space. It
took the activity and the activity of the radiated
metal within the eight to ten-inch reactor vessel.
DR. WYMER: Oh.
MR. GENOA: And averaged all the activity
within that mass and decided that that was less than
Class C.
DR. WYMER: Didn't take into account the
enclosed volume?
MR. GENOA: No. It actually is a mass.
It wasn't a volume concentration.
DR. WYMER: Yes.
MR. GENOA: But we can verify that.
DR. WYMER: Wasn't volume averaging; it
was mass averaging?
MR. GENOA: Yes.
DR. WYMER: Okay. Well, thanks. Thanks.
Any comments or questions of Paul while he's sitting
here?
MR. GENOA: I guess I answered them all.
Thank you very much.
DR. WYMER: Yes, well, thank you. And any
other questions of Stephanie while we've got her here,
or any comments?
CHAIRMAN GARRICK: Well, we do have a
comment.
DR. WYMER: Have we got one from back
here?
CHAIRMAN GARRICK: Yes, the Public Citizen
Group.
MS. GUE: Thanks again, Mr. Chairman.
Lisa Gue from Public Citizen. At this preliminary
stage as you're considering this issue, I just wanted
to remind you of Public Citizen's continuing objection
to the concept of entombment as a viable option for
decommissioning.
Our membership across the country,
including at nuclear power sites or the communities
around them is certainly clearly opposed to this
concept of creating no -- which would potentially
create 104 nuclear sacrifice zones or low-level waste
dumps across the country.
And certainly, in this more broad concept
that's here being described as an option, this does
not seem like a reasonable or responsible policy for
managing low-level waste. It becomes even more
objectionable when the stated objective is to make it
more cost-effective for nuclear utilities to
decommission.
We certainly don't feel that that's --
that that is in the public interest for the motivation
for regulation. Our conviction is that nuclear
utilities have accepted the burden and the cost of
decommissioning when they've decided to invest in
nuclear power, and that it shouldn't -- it's not
acceptable for that burden to now be transferred onto
the public, in violation of the spirit of the license
termination requirements.
DR. WYMER: Thank you.
CHAIRMAN GARRICK: Yes, thank you.
DR. WYMER: Well, if there's no other
comments or questions, we're right on schedule.
Thank you very much, Stephanie. We'll
look forward to seeing you again.
MS. BUSH-GODDARD: Yes.
DR. WYMER: Thanks, Paul.
CHAIRMAN GARRICK: Yes. Ray, I guess what
we're concluding from this is that it's premature to
write a letter?
DR. WYMER: Oh, yes, it is.
DR. HORNBERGER: Is the staff looking for
comments on their paper that's supposed to be coming
out in the next few weeks?
CHAIRMAN GARRICK: I don't know.
DR. WYMER: Well, I think it's premature.
CHAIRMAN GARRICK: It's -- have they gone?
MS. BUSH-GODDARD: What was the question?
I'm sorry.
CHAIRMAN GARRICK: Well, we're at -- the
Committee has to decide whether we wish to write a
letter or a report on entombment, and based on what
I'm hearing here it sounds as though maybe it's
premature to do that.
But unless staff wants to have the
opinions of the Committee about the issue in general
or in some other form --
DR. LARKINS: Sounds like after you see
the paper and the various options, you might -- that
might be the more appropriate time or reasonable time
to weigh in on this.
CHAIRMAN GARRICK: Yes. Yes.
DR. WYMER: Certainly not before then.
MS. BUSH-GODDARD: I think that's a good
idea.
DR. LARKINS: No. It says, clearly, the
objectives still seem to be --
CHAIRMAN GARRICK: Well, unless we have
some ideas that -- about the whole issue or that we
have some concerns about the general direction that it
was taking, I would agree, yes.
MR. LARSON: Stephanie, you said it was a
concurrence paper that --
MS. BUSH-GODDARD: Yes.
MR. LARSON: I mean, so it's going to be
publicly released or it's going to be pre-decisional,
or what's it going to be?
MS. BUSH-GODDARD: No, it's definitely
pre-decisional. When I said office concurrence, it's
the NRC Offices.
MR. LARSON: Okay.
MS. BUSH-GODDARD: NRR research, that type
of thing, and having their directors sign off on it.
DR. LARKINS: I think we'll get it for
information, probably.
MS. BUSH-GODDARD: Yes, exactly.
DR. LARKINS: Yes. So you can take a look
at it then and decide if it's something that the
Committee wants to weigh in, or it could wait till you
get comments. During the public comment period there
are a number of different times when the Committee can
provide comments.
MS. BUSH-GODDARD: Yes. Now, we're not
sending it out for public comment until it's gone up
the --
DR. LARKINS: No, I understand. I
understand the process.
MS. BUSH-GODDARD: Okay.
MR. LARSON: In light of the broad scope
of options that you seem to be looking at, what is it
going to be, a 90-, 180-day public comment period or?
MS. BUSH-GODDARD: I think right now we're
looking for a 90-day comment period. But you know,
that can always be extended.
CHAIRMAN GARRICK: Any other comments,
questions? Staff? All right. Well, thank you again.
MS. BUSH-GODDARD: You're welcome.
DR. WYMER: Thank you very much.
CHAIRMAN GARRICK: Okay. I think this
brings us to the conclusion of our presentation part
of our Agenda and that we're now in a position to move
into a discussion and the preparation of reports.
And I'd like to suggest a very short break
so that the court reporter can remove his equipment
and sign off, and then we'll start our reports. So
we'll have a short break now.
(Whereupon, this portion of the 124th
meeting of the Advisory Committee on Nuclear Waste was
concluded at approximately 2:01 p.m.)
Page Last Reviewed/Updated Monday, October 02, 2017
Page Last Reviewed/Updated Monday, October 02, 2017