ML20199L621

Corrected Transcript of ACNW 96th Meeting on 971121 in Rockville,Md.Pp 142-177.W/certificate & Presentation Matl

ML20199L621
Person / Time
Issue date:	11/21/1997
From:	NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW)
To:
References
NACNUCLE-T-0118, NACNUCLE-T-118, NUDOCS 9712020073
Download: ML20199L621 (72)

Text

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t R 3 \\ A __ /9c/NT-O /If n OFFICIAL TRANSCRIPT OF PROCEEDINGS V NUCLEAR REGULATORY COMMISSION ADVISORY COMMFITEE ON NUCLEAR WASTE

Title:

96TII ADVISORY COMMITFEE ON NUCLEAR WASTE (ACMV) MEETING Docket No.: ~ ]RUS (M f4W) p[ ykt; uklLif4M TO BJWHlIl M RS I 2[26 / Work Order No.: ASil-300-51

s '130 i

inuw o/ .f W' LOCATION: Rockville, Maryland DATE: Friday, November 21.1997 PAGES: 142 - 177 ACf#! OFFICE COPY-RETAIN FOR THE UFE OFTHE COMMITTEE ANN RILEY & ASSOCIATES, LTD. ,p- , g e ) 'g O C 2-12501 Street, NW, Suite 300 '~ Washin 0005 II'll ll111111ll111 u.

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.. ~. --.. . ~ .... ~ h .f .g R_ -l y c 33, -I i i DISCLAIMER . UNITED STATES. NUCLEAR 1 REGULATORY COMMISSION'S i ADVISORY COMMITTEE ON NUCLEAR' WASTE-NOVEMBER 21, 1997 g 4 -The_ contents of this transcript of the proceeding oflthe-United States Nuclear Regulatory-Commission ~ Advisory Committee on Nuclear Waste, taken on November 21, 1997, as reported herein, is a record of the discussions recorded at - the: meeting. held.on the above date. This transcript had not been reviewed, corrected and edited.and it may contain inaccuracies. a-t 4 7 ,-.,y ~ -.,,--.--,.,w.

_.-.--m 142 _. UNITED' STATES NUCLEAR-REGULATORY COMMISSION-

X 2

ADVISORY COMMITTEE ON NUCLEAR WASTE: '3- .t 4 96TH ADVISORY ' COMMITTE' ON 5 -- NUCLEAR WASTE _(ACNW) MEETING 6-7 U.S. Nuclear Regulatory Commission 8 Two White Flint North, Room 2B-3 9-11545 Rockville' Pike ,10 - Rockville, Maryland ' 20852-2738 13 12 Thursday, November 20, 1997 13 14-The Committee met pursuant to notice at 8:30 a.m. 15 16 MEMBERS PRESENT: 17 B. JOHN GARRICK, Chairman, ACNW 18 GEORGE HORNBERGER, Vice Chdirman, ACNW 19' F. FAIRHURST,. Member, ACNW 20 RAYMOND G. WYNER, Member, ACNW 21 HAROLD LARSON, Member, ACNW 22 JOHN ~ T. LARKINS, Executive Director, ACRS/ACNW 23 24 25 t ANN RILEY & ASSCOTATES, LTD. Court, Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 w- ,,,i- ,-rmi-- v--- -*,-',,rv ---~wewev - - - * + - se n.- =----i--+"w-4 e-- -m-+r--v-e,,- -, -. v ,m---t-

143 1-STAFF!AND PRESENTERS SEATED AT THE COMMISSION TABLE: 2-RICHARD K. MAJOR, STAFF GIORGIO_GNUGNOL'I,-ACNW OTAFF 4 ANDREW C. CAMPBELL, ACNW STAFF 1 -5 LYNN DEERING,_ACNW: STAFF 1 6 JOHN W. SORENSEN 7 i 8 9

10 11-12 13 14

(Q 15 16 17 18

- 19 20-21 22 23 24s . 25 4_ ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 Y -4.v----,,- -v,,, - a w --.e >m--- -w -t

144 -11 PROCEEDI:NGS () 2_ [8:30 a.m.] 3-MR.'GARRICK: -The1 meeting will now come to order. -4' .This.is the second'dayc of the 96th' meeting ofsthe- =5. _ Advisory Connittee on Nuclear Waste. My name is John 6 Garrick, Chairman of the ACNW. .7 Other members of the Committee include George '8 Hornberger,-Raymond Wymer, and Charles-Fairhurst. 9 Today the Committee'will first review waste 10 classification at-West Valley, Hanford, and Savannah River. 11 We will prepare for our next' meeting with the Commission, 12 -which is scheduled for December 17th, 1997 and we will 13-continue _the process of preparing ACNW reports. 14 Richard Major is the designated Federal officer -15 for the initial portion of-today's meeting. 16 This meeting is being conducted in accordance with 17 'the provisions of the Federal Advisory Committee-Act and 18 should anyone wish to address the Committee, please make 19 your wishes known'to one of the Committee staff. 20-It is requested that each speaker use one of the L211 microphones, identify himself or herself and speak with 22-sufficient clarity and volume so that he or she can'be 23 readily heard. '24 .The Committee member that is-going to at least ~25 initially _ lead the discussion for-our first topic,.which has O* ANN RILEY & ASSOCIATES, LTD. Court Reporters -1250 I' Street, N.W.,-Suite 300 . ashington, D.C. 20005 W (202) 842-0034 ~._,. -. ~.

145 1 to do with waste classification, is Raymond Wymer, so Ray -- [\\ 2 MR. WYMER: Thank you. I think the discussion LJ 3 this morning will probably center pretty much around the 4 issue of what is incidental waste, and we will find out a 5 little bit more from our speaker, Jennifer Davis, when she 6 talks and what are the implications of c.~assifying the 7 Savannah River tank waste and the Hanford tank waste as -- 8 after you remove the bulk of the high-level activity from 9 the tanks. Is it in fact incidental waste, what's left? 10 There are three criteria that the NRC applies to 11 this basically -- one, that waste has been processed to 12 remove key radionuclides to the maximum extent technically 13 ind economically practical; and two, that the waste will be 14 incorporated in the solid physical form at a concentration ( 15 that does not exceed the concentration limits for Class C 16 low-level waste; and finally, that the vastes are to be 17 managed pursuant to the Atomic Energy Act, 18 I would like to add that the situation for 19 declaring incidental waste seems to be more straight-forward 20 and clear-cut at Savannah River in regard to those tanks 21 than it will be at Hanford because of the fact that the 22 single-shell tanks at Hanford, some perhaps 60 of them, have 23 leaked, and it's not clear that if you leave a small 24-fraction of the waste in those single shell tanks that that 25 could be declared to be incidental waste that you have not [l i ANN RILEY & ASSOCIATES, LTD, b-Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

146 1 -in fact left more radioactivity beneath and around the tanks ( ) 2 than are in the tanks, and what exactly is the meaning o' 3 incidental waste under those conditions, with respect to the 4 protection of the public. 5 So with that little introduction, I would like to 6 ask Jennifer Davis to give us the history and the current 7 status. 8 MS. DAVIS: Good morning. As Dr. Wymer said, my 9 name is Jennifer Davis and I will be talking about 10 incidental waste today. 11 Now I am not sure there is really much I need to 12 say, since I think he's pretty much covered it all -- 13 (Laughter.] 14 MS. DAVIS: -- but I'll go through it pretty 15 quickly. 16 What the talk is going to cover today is the 17 background on the concept of incidental waste, the statutory 18 basis for NRC's interest in the concept of incidental waste, 19 the criteria for incidental waste determinations -- as Dr. 20 Wymer said we have the three criteria promulgated in a 1993 21 letter; waste classification determinations at Hanford, 22 Savannah River, and West Valley, what their status is and 23 what we expect some of the issues to be. 24 Now for the background, the concept of incidental 25 waste first showed up in the statement of considerations for A ( ) ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 : Streeu. N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

~... 147 1 'the promulgation of Appendix F to Part 50 and-it provided~, 2 ;-

Appendix'F orovided definition for plant high-level-liquid 3

waste,c as you see before you -- aqueous waste resulting from -4 reprocessing and that sort of thing -- and the concentrated 5-waste from subsequent extraction cycles. 6 Now some supplementary information in the Appendix 7 F statement of considerations specified that the ultimate 8 disposition of high-level waste is a Federal responsibility. 9 It recognized reprocessing plant operations including -10 storage and treatment, isolation of high-level waste will 11 generate low-level or incidental waste, and it identified 12 some examples of incidental waste, including cladding holes, 13 irradiated or contaminated fuel structure hardware, ion 14 exchange beds, sludges, and contaminated lab items, but it .15 really didn't go into any kind of detail regarding these 16 examples. 17 In addition, the statement of consideration for 18 Appendix F to Part 50 indicated that studies were underway 19 to determine if transuranic contaminated incidental wastes 20 were unsuitable for disposal in a licenced low-level waste 21 burial facility, and.that issue was resolved with the 10 CFR 22 Part 61 for low-level waste disposal. 23 Now why are we interested in the incidental waste 24 determination at_the Department of Energy? Well, the Energy 25 Reorganization Act specified that NRC has a responsibility ~( ANN RIL" & ASSOCIATES, LTD. Court Reporters =1250 1 Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

148 l 1 for licensing long-term storags and disposal of high-level l () 2 wastes, so if in fact these wastes are determined to be 3 high-level wastes, then we have the responsibility for I 4 licensing that, j 5 If they can be considered to be low-level or 6 incidental wastes, then DOE has a responsibility, so it is 7 important to resolve this issue so that the determination of 8 responsibility can be made. 9 Now the criteria for incidental waste 10 classification were formulated in a 1993 denial of a 21 . petition from the states of Washington and Oregon regarding 12 the Hanford actually double shell tanks, and what happened 13 was Hanford was intending to -- well, let's see -- oh, 14 that's the next slide, I'm sorry. 1 () 15 The waste: are concidered to be accidental if the 16 wastes have been separated to the extent technically and l 4 17 economically feasible, the wastes can be incorporated in a ) 18 solid physica1' form at Class C or less, and the disposed 19 waste will be managed to satisfy the performance criteria in 20 10 CFR, Part 61. 4 21 Now what is important to remember with this is j 22 that these criteria were developed for waste removed from 23 tanks at Hanford and processed to separate the high-level 24 waste. fraction from a-low-level or incidental waste ? 250 fraction. -They ttre not initially intended for wastes *. hat ( ANN RILEY & ASSOCIATES, LTD. Court Reporters ,t 1250~I Street N,W,, Suite 300 Washington, D.C 20005' (202): 842-0034 s .f r

t l 149 'l- . ould remain in-tanks, so this-is the distinction and for w () 2 the tank closures we are applying this criteria as 3 appropriate but with the consideration that it_was not ' nitially developed for that purpose. i 4 5 Now something to consider with respect to the 6 first criteria-for removal to the extent-technically and [ 7L economically feasible, what we looked for is some kind of 8 consistent and' objective criteria for determining when the 9 limits of technical and economic feasibility have been 10 reached, and this.is actually a graph from Savannah River. 11 What it shows is the different processes to remove 12 waste from the tanks and this shows the waste -- the first 13 row shows waste in the tank prior to transfer, prior to -14 transfer out of the tank. The middle column shows the waste t , () 15-removed by transfer so in essence waste removal here, the 16 waste removed here is quite a bit -- the bulk waste removal, 17 and this is what is remaining in the hoel once this waste is 18 removed from the starting inventory in the tank. This is 19 curies, by the way. 20 So then this heel would be the same as this block 21 here prior to transfer, and then you go through the steps 22

again, The first water wash would remove this much bulk, 23_

the cu7les, and then this much would be-temaining in the 24 heel -- so you go through like this. 25- -As you see, you reach a point where you're not O' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W.. Suite 300 -Washington, D.C, 20005 (202) 842-0034 ..v. a.a u

-- - -.--- __ - --.~.- 150 l I getting very much, if you will, bang _for your buck. The () 2 processes:do not remove that much more waste, so you need to ~ make~a determination-of where your cutoff is going to be and 3 . hat the practicality is. 4 w 5 What we are looking for in our reviews is-6 .something consistent and objective -- consistent from tank-f 7 to tank -- so a methodology per site that can be applied l 8 consistently 4 l 9 MS. DAVIS: 'Okay. And this slide is pretty much a 10 repeat of what I said, It is.-- the criteria were developed .11 for waste removed from the tanks. 12 Now, the first site that I am going to talk about j 13 specifically is the waste classification at Hanford. And 14 this is actually what started, if you will, the whole () 15 process. 16 DOE identified ten tanks as high level waste for 17 treatment, vitrification disposal in a repository. And then 18 identified 18 tanks as low level or incidental, and this was 19 in 1988. 20 Now, if you looked at the curie content in.the low 21 level waste tanks, as opposed to the high level tanks, what i 22 you saw was-that the curie contents were not very different 23 at all.: l24 So the staff did not agree with the DOE 25 classification of waste in the 18 low level waste, t O' ANN-RILEY 4t. ASSOCIATES, LTD. _ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 1202) 842-0034 3 i 1 w,= ..,,w__,.._.a,.-.;,w..,_..w.. a

151 1 doubled-shelled tanks. And so there was some concern about () 2 the DOE waste classification in the 1993 Bernero letter 3 which developed the incidental waste criteria. 4 And we -- the NRC stated that DOB should 5 reconsider the tank waste remediation plants. 6 So in 1993, DOE at Hanford revised their plans for 7 managementoof the double-shelled tank waste and has come up 8 with a tank waste remediation system, which I am assuming 9 that you all are fairly familiar with. And I see Mike Tokar 10 has just entered the room, so -- he is our TWRS guy. 11 And the Department of Energy made a commitment to 12 consider process waste in all tanks as high level waste to 13 start. And then to process them and consider the outputs of 14 the processing as incidental waste or as high level waste. () 15 And in November of 1996, the Department of Energy 16 requested our agreement that the low activity fraction from 17 the high level waste treatment is incidental and is not 18 subject to NRC licensing authority. And their request i 19 included some preliminary plans for segregation of the high 20 level waste into a low activity and a high activity for 21 action. 22 It included the technical basis for classification 23 of the low activity fraction as incidental. And it shows 24 plan-for on-site disposal of the low activity fraction, and 25-repository disposal for the high activity fraction. ANN RILEY & ASSOCIATES, LTD. \\- Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034- ,.,.m, m y-.

152 1 Now, staff performed a review on Hanford's () 2 technical basis and presented our results to the Conmission 3 for their review. They responded with a SRM of May 28th, 4 1997. 5 Our review was based on tho three criteria from 6 the Bernero letter and the preliminary conclusion is that 7 the low activity fraction can be considered as incidental. 8 Now, this is a provisional agreement, and that is 9 because the technical basis that we received was a very 10-preliminary one. It did not include a disposal facility for 11 the low activity fraction. It included plans for one, but 12 not a lot of specifics. And the disposal facility design 13 was incomplete. 14 The treatment alternatives had not been selected, () 15 although there was a good bit of discussion of them in the 16 -- where did the -- excuse me -- where Hanford addressed 17 crite-ia 1. They addressed their plans for technical and 18 economic feasibility of separate of the waste. So there was 19 a good bit of discussion of the treatment alternatives. 20 And what is in the tanks has not been well 21 characterized. Because of the history of Hanford, I think a 22 lot of the characterization information has been lost over 23 the years with retirements and that sort of thing. And so 24-we requested that they would characterize the waste from 25 each tank as they removed that waste. O' ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington,- D.C. 20005 (202) 842-0034

153 1 So the contractors are currently developing the () 2 design con:epts for the low level waste, or incidental waste 3 disposal, and they will be resubmitting that information to 4 us when they -- when they are ready. 5 So as I am leading up to, future reviews are still 6 going to be required for the Hanford incidental waste. 7 And, again, something I guess I didn't really 8 point out. For the Hanford case, what this is so far is for 9 waste removed from the tanks, Hanford has not yet addressed 10 waste remaining in the tanks, or tank closure. 11 However, Savannah River is considering tank 12 closure in place and in January 1996 they began retrieving 13-and treating waste that were in the tanks. And in April 14 1996, NRC staff met with the Department of Energy to discuss () 15 tank closure in place. 16 Now, the key issue here is whether the high level 17 waste removal that has gone on so far and that would be 18 planned to go on is sufficient to classify the waste 29 remaining in the tanks as incidental. And in August of 20 1996, Department of Energy at Savannah River requested our 21 review of their methodology for classifying the residual 22 waste as incidental. 23 Now, what happened was in December -- in December 24 of '96, they provided additional information, but the 25 full-fledged review did not actually start because there was < O ANN RILEY & ASSOCIATES, LTD. Court Reporters L 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 ,_r. -..,-.--,m _.~...,, ~ .-- -...-.--_..-, -- ~.

154 1 no funding for this sort of review. But the Department of 2 Energy at Savannah River and the NRC signed a memorandum of 3 understanding and an interagency agreement to take care of 4 this in, I believe, July of this year. 5 So the DOE actually initiated closure of two tanks 6 in 1997 that they considerM would meet the three criteria F 7 of the Bernero letter. That is tank 20, which has been 8 closed, and tank 17, which is in the process. 1 So they recognized, and we recognize that they 10 would be closing this at their risk, but we did not issue 11 any formal objections. 12 Okay. As I said before, this criteria really 13 applied to waste removed from the tanks, and the Department 14 of Energy at Savannah River recognizes this. They have bQ 15 requested that we consider alternative provisions in 10 CFR 16 61.58 to -- to provide alternatives for satisfying the 17 classification, the waste classification, since there is 18 some concern that the waste remaining in the tanks may not 19 be able to meet the Class C or last criteria. So they have 20 requested that we consider the Section 61.58, 21 They have also requested that we consider using 22 the branch technical position on concentration averaging and 23 encapsulation as a way to meet the criteria to the greater 24 than Class C requirements. 25 Now, in August of 1997, after we had signed the b ANN RILEY & ASSOCIATES, LTD. \\ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034-

155 1 memorandum of understanding and the interagency agreement, () 2 they subuitted an updated regulatory basis-for tank closure 3 methodology. And we have begun that review. We expect the 4 review to be complete, including Commission review, by April S of 1998. And we intend to consider using the-existing 6 incidental waste classification criteria and applying that, 7 as appropriate. 8 Now, we have some discussions on whether to apply 9 the decommissioning rule or not for, as you wil2. see a 10 little bit later on, some consistency with similar tank 11 closures at West Valley. 12 However, I am not sure that this is really going 13 to be appropriate in this case because, for one think, DOE's 14 methodology does not -- does not address the decommissioning () 15 criteria. And so, I think that for this case, it is 16 something that we will think about, but I doubt that we will 17 go ahead and end up applying it. And we will consider the 18 flexibility in Part 61.58 for the satisfying Criterion 2 and 19 will likely go up to the Commission either options or 20 recommendations on this topic. 21 Now, here is another Savannah River-provided 22 slide. And this is how they plan to close the tanks. They 23 will fill in with a layer of a reducing grout which is 24 designed to chemically stabilize any waste remaining in the 25 tanks to -- well, to provide reducing factors and to provide - O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

l t 156 -1 a, I believe, PH to chemically mobilize the waste. () 2 Then they are going to fill in with a controlled, 3 low strength material that has -- does not have a very high 4 compressive strength, but will provide some stability, and 5 will -- has a low heat of hydration so that the pours can be 6 effectively continuous. So that this process does not take i 7 forever and so that the heat of hydration does not affect 8 the carbon steel tanks. 9 Then the top is going to be filled in with a 10 higher strength grout which has fairly good flow capability 11 ao that it can fill in voids and that sort of thing up here. 12 And this will help provide an additional intruder barrier. 13 Now, for West Valley, they are starting this 14 process. They are starting to look at how they are going to () 15 close their tanks. And they are currently implementing our 16 statutory requirement excuse me -- the statutory 17 requirements of the West Valley demonstration project at 18 --for site decontamination and decommissioning. And this is 19 a lot more involved that just tank closure. There's a lot 20 of other things going on, and there should be a Commission 21 paper on that in the near future. 22 There ar, four high level waste tanks at West 23 Valley, two large and two small. One of the small tanks is 24 only slightly contaminated. And in January of 1996, the West Valley issued a DEIS for completion of the West Valley ea O 5-sI ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

157 1 demonstration project and closure of long-term management of 2 site facilities. 3 Now, this is either going to be updated with a 4 further EIS or a supplementary EIS to address some of the 5 alternatives for tank disposition. This has changed 6 somewhat since January of '96. And there are four 7 alternatives. 9 The first one is dismantlement of the tanks and 9 shipment of the waste off-site. The next one is 10 dismantlement of the tanks and on-site waste storage for an j 71 indeterminate time period. The third is in-place i 12 stabilization similar to what Savannah River is planning to 13 do. And the fourth is a no-action alternative, monitoring 14 and maintenance as-is, which is really the base case. This () is not really an option for long-term -- long-term care. 15 16 Now the incidental waste classification criteria would 17 facilitate any of really the first three alternatives, and 18 the DOE and I sort of are there. Oh, as I said, they're not 19 that close to completing the EIS process. They're working 20 on a record of the decision with the preferred alternative 21 along with their citizens advisor group. And they are 22 paying attention to the progress of the tank closure at 23 Savannah River, and this ir expected to provide a precedent -24 for tank closures at West Valley and eventually at Hanford 25 when that becomes necessary. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 4 ~,.._,_. _._. _

f 158 1 This is a picture of the inside of one of the () 2 tanks at West Valley, and as you'll see, I don't know if you 3 notice, but in the Savannah River tank, most of this 4 i 4 interior was fairly empty. I believe Savannah River has six { 5 inlets, but they do not have all of this structural -- this 6 structural internals to the tanks es West Valley does. And 7 this is expected to complicate the cleaning and waste 8 removal, if you will. 9 So in summary there are criteria that exist for 10 distinguishing high-level waste from incidental waste so 11 that we don't have to call it all high-level waste. We have 12 a preliminary review complete for Hanford waste removed from 13 the tanks. We're in the process of reviewing the Savannah 14 River waste classification methodology for waste remaining O (,/ 15 in the tanks. And we expect that West Valley will also have 16 a proposal for waste remaining in the tanks sometime in the 17 future. And that eventually it is likely that Hanford will 18 have some sort of proposal for this as well. That Hanford 19 process is likely to be the most complicated. 20 Questions? 21 MR. WYMER: I have a couple to sort of kick things 22 off here. The one is triggered by the picture that you 23 showed of the Savannah River tank that shows a reducing 24 grout. When they talk about putting in a reducing grout, 25 then that means that they must consider that there's O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

159 1 something there that needs reducing, and that gets you to () 2 the question of characterization, which seems to me to be a 3 key issue here. What is in fact left in the tank after 4 they've taken out all that they can reasonably get out, ano 5 specifically, you know, which elements, which radioisotopes 6 are left, since each of those has quite a dramatically i 7 different health impact if it gets loose and moves around? i 8 So that was -- not so much a question as an 9 initiation of a discussion of the ineJe. To what extent 10 will a good characterization of the residues be required, 11 and is that specified? 12 MS. DAVIS: Yes, it is specified in their 13 methodology, and in fact they have a closure module for each 14 tank that goes through the review process at the local EPA () 15 and the South Carolina Department of Health. Now we will 16 not be reviewing each tank closure module ourselves. We 17 will be reviewing the general methodology. And so each tank 18 is -- the contents of each tank are characterirsd an each 1? tanx is prepared for closure. 20 I believe the main radionuclides in fact in all of 21 these tanks at Hanford and at Savannah River and West Valley 22 are -- the bulk of the curies are from cesium and strontium. 23 Now I believe there's also some transuranics and some 24 plutonium in the Savannah River tanks, but I don't know for 25 sure. I could get back to you with that information. ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

i l 160 1 MR. WYMER: Okay. The second question I had was () 2 triggered by your viewgraph on the West Valley waste 3 classification guides here, and it talks about the i 4 identified alternatives for tank disposition. You had four j 5 of them, and a couple of them required dismantling. And I 6 wondered to what extent is the overall health and safety 7 effects of these processes taken into account when you 8 decide what's the best way to proceed. That is, for 9 example, if you're going to dismantle the tanks, then 10 there's a reasonable expectation of worker exposure. On the 21 other hand, there's a reasonable expectation that the site 12 will be left a good deal cleaner. 13 MS. DAVIS: Right. The balance there is when the 14 alternatives are being evaluated, one of the things they do () 15 look at is the done to workers, and of course the dose to 16 intruders or public if the tanks are left in place. It is 17 expected that if tha *anks are left in place -- or, excuse 18 me, if the tanks are removed, the costs would be much higher 19 if you assign a dollar value per unit of worker exposure. 20 MR. WYMER:

Yeah, 21 MS. DAVIS:

That the costs would be a great deal 22 higher. Now the problem is that there's some concern that. 23 the. intruder doses cannot be met if the tanks are left in 24 place, and so as I addressed the possibility of applying the-25 decommissioning rule to Savannah River, that's primarily in ANN RILEY & ASSOCIATES, LTD, ~/ Court Reporters 1250 I Street, N.W.y Suite 300 Washington, D.C. 20005 (202) 342-0034

i i 161 1 view of what we intend to do or what we're looking at with () 2 West Valley. And in ef fect if the decommission rule is 3 applied, that could allow for institutional controls in 4 perpetuity, which would limit the $ntruder doses. 5 MR. WYMEL: In perpetuity is a long time. 6 MS. DAVIS: Yeah, well, I realize that. Let's say 7 on the order of a thousand years, which is still, I think, a 8 very long time. And, yes, there's been quite a bit of 9 discussion on that, as you can imagine. 10 MR. WYMER: I'm sure there is. 11 MS. DAVIS: So that would in effect limit the 12 intruder doses, and so you may not need to consider removing 13 the tanks. But if you do a traditional intruder analysis in 14 compliance tith the EIS for Part 61, then the intruder doses k 15 are fairly high. And so that's why you want to consider 16 tank removal. 17 MR. WYMER: Okay. Are there any other questions? 18 George? 19 MR. HORNBERGER: Just a followup on that. In the 20 intruder calculations, I mean, if you look at the design 21 for -- that you showed for the conceptual design for the 22 Savannah River -- 23 MS, DAVIS: Um-hum. 24 MR. HORNBERGER: It's going to be pretty hard for 25 an intruder to -- you'd have to work really hard to get at O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

162 1 that. () 2 MS. DAVIS: Right. Well, I think that's part of 3 the intruder analysis, is you need to consider 4 reasonableness. Do you really expect that someone is going 5 to say attempt to dig a basement, find, you know, 30 feet of 6 concrete and continue trying to dig a basement? You know, I 7 don't think so. You've got to apply some reasonableness to 8 that. And so that's a large part of what that high-strength 9 material at the top-is for, is intruder deterrent. 10 MR. HORNBERGER: Also, another followup to one of Il Ray's questions. On the classification -- or the 12 characterization, is part of the plan a sampling plan in the 13 tanks that would take into account heterogeneities? I mean, 14 as I understand it, these sludges aren't necessarily () 15 homogeneous mixtures. i 16 MS DAVIS: No. No, the sampling plan includes 17 consideration of that. I think any sampling plan has to. 18 MR. HOkNBERGER: It's just not -- well, I don't 19 know. It's not necessarily the easiest thing to do to get 20 in there. 21 MS. DAVIS: No, it's not sampled in only one 22 place. 23 Well, there are six risers, though, or seven 24 risers at the top of the tank that they can put in equipment 25 for sampling and that kind of thing, and in fact that's how l ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 i -v-w g_., y-. ,,ry y ,,w ,wwy---ye-..--,,., ---w,1.,.- .wg.-, ,- i

i 163-1 2 1 .the' cement is added-to the tank and pours through those () 2 risers. 3 MR. WYMER: Now let me return to something I said l 4 in my -- a couple of opening comments. At Hanford you do j 5 have a.special problem in that'the tanks have leaked. What 6 consideration is being given to this application of the 7 incidental waste idea when in fact there's as much out of l 1 8 the tanks as -- maybe more than there would be left in the 9 tanks after they're cleaned up? j i .10 MS. DAVIS: Well, I think there's been some 11- -discussion within the DOE group about that sort of thing. 12 We really have not -- or the waste management has not gotten 13 ' involved in those discussion because as of yet we are not 14 considering Hanford tank closure in place. l () 15 MR. WYMER: Um-hum. 16 MS. DAVIS: Now I don't know if the tank weste 17 remediation system group has considered that sort of thing i 18 or not, but we really haven't looked at that yet. We're 19 only looking at the waste removed from the Hanford tanks. 20 .MR. WYMER: Well, I think I can tell you that 21 they've not done a lot.of looking at what's-outside the i 22 tanks so far. They know it's thera. 23 MS. DAVISi Right. 24 MR. WYMER: They don't quiet know what to do about 1 25 it. i i I O ANN RILEY & ASSOCIATES, LTD. . Court Reporters 1250 I Street, N.W.,. Suite 300 2 84 I b34 L

164 1 MR.- GARRICK: Yeah. Jennifer, can you comment at () 2 all on what the implications might be of what's going on 3 with respect to the tanks and waste classification beyond 4 the tanks? Is this going to have any impact on activities 5 out beyonu the tanks as far as the waste management and 6 closure of facilities is concerned? 7 MS. DAVIS: Do you mean the closure of facilities 8 other than the tanks? 9 MR. GARRICK: Yes. 10 MS. DAVIS: Well, certainly at West Valley that's 11 one of the things that's being considered, some of the 12 process buildings as well are being -- the -- even the 13 incidental waste classification criteria is being considered 14 to be applied to some of these buildings that have been used () 15 for reprocessing. Some of them do have -- I understand when 16 fuel is reprocessed the ends are chopped off, and some of 17 that material I think is still in the bottom of one of the 18 processing buildings at West Valley. So that's certainly an 19 issue that's going to need to be addressed. 20 I believe at Savannah River what's going to happen 21 is once a group of tanks or the tank farm is closed, the 22 entire area or subarea -- it will be considered whether they 23 will put over a cover to protect against water infiltration 24 and that kind of thing. And that would cover up existing 25 structures that are outside of the tanks, some of the piping O-r ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

165 1 and I think some of the evaporators and that sort of thing. () 2 MR. GARRICK: A couple of the t.echnical issues j 3 that of course are really hot buttons as far as tank wasto j 4 is concerned are the -- is the end state of the waste that i 5 you get out of the tank, for example, and then the whole 6 issue that you've referred to called closure. And it's i 7 really very difficult as a matter of fact to focus in on a 8 specific strategy for remediation until you have some 9 resolution of what constitutes closure and what constitutes 10-the end state of the waste. How involved is NRC in that 11 activity? 12 MS, DAVIS: I'm not sure I really understand the 13 question. What do you mean by the distinction between the 14 closure and the end state? () 15 MR. GARRICK: Well, what I'm getting to is that if 16 in fact you're trying to find ways of retrieving tne waste 17 and maybe even processing the waste into low-activity and 18 high-activity fractions, those processes become extremely 19 dependent upon the product that you're ultimately trying to 20 develop. So that's one issue. And one of the criticisms of 21 the DOE program is that it's not generally been end-state 22 eriented except in a kind of a general way that we're going 23 to make borosilicate glass logs, and while those are 24 described chemically and physically in a variety of 25 documents, there's still some uncertainty about what from a s g .c ANN RILEY & ASSOCIATES, LTD. - \\ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

i 166 1 chemical engineering standpoint the specification ought to () 2 be on the end state. So that's an issue, and it's very 3 important in getting it resolved to come to grips with the 4 kind of technologies that should be employed and the kind of 5 procesees that should be involved. So I was just various if 6 the NRC was at all involved in that type of issue. 7 And then of course the other thing is the issue of f 8 closure. Depending on the strategy you take, then there's 9 the problem of doing what Savannah River has done, say at 10 Hanford, of picking a way to ultimately close out the tanks, 11 either by removing them and processir.3 them in some fashion, 12 or some sort of in-place stabilization. And I was -- and i 13 given that this is such a hot issue, especially with respect 14 to the stakcholders -- ) 15 MS. DAVIS: Um-hum. 16 MR. GARRICK: I was curious if the NRC was playing 17 a role in this whole arena, i 18 MS. DAVIS: I think we are in certain aspects of 19 it. I mean certainly for the Hanford review, for the waste t 20 removed from the tanks, that was one of the things that we i 21 looked at for the waste classified as low activity or l 22 incidental -- what would the final waste form be. I 23-Unfortunately, when we did the review this is one 24 of the things that was rtill fairly nebulous at the time we 25 did the review-There was a consideration that the waste O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

I f 167 I might either be vitrified or molten metal processing might () 2 be used for the waste form. 3 Now I believe that both of the TWRS contracts are 4 planning to vitrify the low activity portion but at the time 5 that was something that we were concerned with and in fact 6 for the waste classification. The classification as Class C 7 or better really depended on that the waste would be glass 8 logs. If it was molten metal processing we needed to 9 revisit that issue. i i 10 So we got into it to that degree at Hanford, but 11 again the methodology there was very preliminary so we di 12 not get into that with any depth. 13 Now for the high-level waste portion I b .t nev 14 that the glass waste is ooing to be a very small t rw;;antage ) of the waste disposed at the repcsitory and that it 15 16 something that we are looking at as part of the high-Je ,,o 17 waste reviews or planning to look at for viability 18 assessment and when we get the license application, that 19 sort of thing. 20 But I think, as you are aware, Part 60 is being 21 revisited and so I don't really know how thoroughly that i 22 will be discussed in there, but I think it is something we 23 definitely need to look at before license application. 24 MR. GARRICK:- Thank you. l 25 MR. WYMER: Just as a point of information, it is i O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

p{} 168" true that the two private contractors that are doing Phase 1 ~ hh fff 2 q snd Phase 2 out there -- Phase i so far -- have decided to Ekk 3 'e vitrification for low-level waste. inf l 3 It is also true though that the request for y 6 iroposal gives them the option of using other means of aclidificot'.on, and they are considering grouting, and there is also consideration being given to fixing the low-level 4 8 waste in sulfur. 9 MS. DAVIS: Okay. Well, that was -- in sulfur or 10 in like a sulfur or coment? 11 !!R. WYMER: In what? 12 MS. DAVIS: There ja some kind of cement that is 13 basically -- I guess it's really a polymer. They call it 14 sulfur cement. 15 MR. WYMER: Well, sulfur exibus in six allotropic 16 f orins and one of them is a polymer -- that is probably what 17 it is. 18 MS. DAVIS: Well, in any case, our provisional 19 acceptance of the Hanford methodology for classification, 20 their waste is incidental, dit. say thac it needed to be 21 revisited and that we were considering waste glass at the 22 time that we reviewed it, but they -- I guess we're 23 expecting a revised or a resubmitted proposal in about the 24 year 2000. In fact, te already have a ticket on it so I 25 don't know if you are familihr with our ticket process here, ANN RILEY & ASSOCIATEE,, LTD. Court Reporters 1250 I :treet, N.W., Suice 300 Washington, D.C. 20005 (202) 842-0034

169 1 but I have got a project due in the year 2000 on the Hanford () 2 review so we are already expecting to get that in again in a 3 couple years. I expect that it will be a lot more detailed. 4 MR. WYMER: This is sort of off-the-wall a little 5 bit, but let me put a bug in your ear. 6 There are wastes out at Hanford that are called 7 trenched wastes -- as you are probably familiar with. They 8 dig a big hole in the ground and they line it with logs and 9 they have dumped a lot of stuff in there -- a lot of curies. 10 Some day they are going to deal with that and they 11 may say, okay, why isn't this incidental waste? i 12 MS. DAVIS: Well, I'll tell you why. Because the 13 waste has not been removed to the extent technically and 14 economically practical, and I am betting that it would not () 15 meet the Part 61 performance objectives. 16 MR. WYMER: I suspect that it will be very, very 17 expensive to take care of that, so maybe it has been removed 18 to the extent that is economically practical. 19 MS. DAVIS: I don't know. I think that is a big 20 issue with this is where do you draw the line between $500 21 million and over 500 millirem to the intruder, and I think 22 this is why the institutional controls issue is going to be 23 a very real one. 24 MR. WYMER: Okay. 25 MR. FAIRHURST: Institutional controls -- O ANN RIL3Y & AS90CIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 i (202) 842-0034 =. - ~

170 1 MR. WYMER: Microphone -- () , 2-MR. FAIRHURST:. It's not a very important 3 question. 4 [ Laughter.) J 1MR. WYMER: But we wouldn't want to miss'a word.- i 6-MR. FAIRHURST: Just the idea of 1000 years of 7 institutional controls. How did that arice? i i 8 MS, DAVIS: Well, it is part of the 9- , decommissioning rule and in-fact there are other-factors 10 that need to be considered with that. !11 There are dose limits to the publin and to an 12 intruder that go along with extended-institutional controls. 13 If you wanted to find out those details, I believe i 14 it's been pcklished in the Federal Register very recently () 15 and I could get you that citation. 16 MR._FAIRHURST: But it would seem to me that it's { i go ng to be hard to get people to agree to that length of -- 17 -18 given that others have been talking about 100 years and 19 maximum two, three, four hundred years. 20 MS, DAVIS: Well, I belluve there was a good deal -21 of.public comment cn1 that issue when'the rule went out for 22 public comment. i 23 I think that this is fairly limited to Government 24 ownership and that. kind of thing where'it is considered that 25~ the Government could be responsible for a site for a O ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Fuite 300-Washington, D.C. 20005 (202) 042-0034. .._;__..-m

..__..___,--_n.____.

i 171 1 chousand years. () 2 I am not as familiar on the details as I would 3 like to be. Others in the Division are more fami iar with 4 that -- but I can get you the Federal Register citation if 5 you would like to take a look. 6 MR. WYMER: Following up on that, it does seem 7 like it's perhaps not the wisest course to have any sort of 8 a closure plan that involves the extensive use of 9 institutional controls and if you are not pretty sure that 10 you can walk away from it and everything is going to be all 11 right then you probably don't have a good plan. 12 MS. DAVIS: Well, I think that is where the 13 breakdown comes on when you can allow extended institutional 14 con;rols. It looks like Mike would like to address that. () 15 MR. BELL: Dr. Garrick and I can I guess enter the 16 discussion here. 1*r I am Michael Bell, Chief of the Performance 18 Assessment and High-Level Waste Integration Branch at NRC. 19 I think basically what the Committee is drifting 20 into is a completely different area, which is the criteria 21 for cleanup of contaminated sites. 22 It is something that affects RSDMP program and in 23 the larger sense for the nation it affects how all tha DOE 24 facilities that have in some cases a high degree of 25 contamination are going to be remediated. I~T ANN RILEY & ASSOCIATES, LTD. k-Court Reporters. 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

I i 172 1 What has happened in the last couple of years is 2 the realization both within the NRC for facilities we 3 license and within the Department of Energy that while 4-cleaning up the site t.o unrestricted use is the goal, there 5 are-a number of facilities that are contaminated to such a l 6 degree that the cleanup for unrestricted use would just be l 7 extraordinarily expensive, result in-very high occupational j 8 radiation exposures, e.nd there will be a number of sites F 9 around the country both commercial and Department of Energy 10 sites that will be -- contamination will be left in place, 11 stabilized to the best extent practical, and then l 12 essencially institutional controls will be needed, either 13 Government landownership, restrictions on future use of the 14 land, and such. 15 For NRC-licensed sites, as Jennifer mentioned, 16 just about. two months ago the Commission published its new 1" cleanup criteria rule that has essentially three levels of 18 cleanup. 19 A site can be released for unrestricted use if the 20 projected doses to future intruder wouldn't exceed 25 21-millirems per year. If you can't clear up to those levels i '22 then doses in the range between 25 and 100 millirem a year 23 to a future intruder would be permissible with a certain 24 . level of iristitutional controls and financial arrangements 25-being put-in place to pay for any maintenance and for ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite'300 Washington, D.C. 20005 (202) -842-0034- -.-,----+;. .----n,. ,,r,--- -. - - -, - - -,i ,w.w e m,,,,, --.-,, ,,,n., ,,--,n-n-,

~. _. - _ _ _ _ _ - -.. I i 173 1-ensuring that the institutional controls would be ] () 2. maintained. 3 MR. WYMER: Well, V4ike,-I wasn't really talking 4 about unrestricted use. 5 My point really was that -- MR.-BELL: Yes, I mean here we are into cases l 7L where things are going to be left behind in so.ne cases, j i 8 whether it is the Hanford tanks or the crypts at Hanford or 9 other contaminated facilities that, you know, doses to a 10 potential intruder may be in the range of hundreds of 6 11 millirem per year, and in thoue cases we would permit it 12 with the provision for institutional controls. In some 13. case 0 that may be Federal Government land ownership, but in 14 other cases it may be state ownership. l ) 15 MR, WYMER: Well,_let me slip a word in edgewise 16 here -- 17 MR. BELL: _ And the funding arrangements made, paid 18 to do the maintenance. 19 MR. WYMEC: HMy point was that any plan that 20 involves in the-long run relying on institutional control _ g 21 for the protection of the public, and that is an integral 22 -part of it, is a_ pretty touchy plan. 23 Maybe you-can-have institutional = controls-for 50 [ 24-years, 100 years, maybe even 200 years but if you leave an s 25 amount of radioactivity ini he tanks-or anywhere that t ("\\ ANN RILEY & ASSOCIATES, LTD. -Court Reporters 1250 I Street, N.W., Suite 300 LWashington, D.C. 20005 t (202) 842-0034 -. _..~ _ _ _ _. _ _.. - _.. _ _ - - -._,_, _.. _, -.. _ -... _ _. -.-. _.-....... -.____.-,._~ m.

174 i 1 without institutional control will lead to a problem after g) 2 that period of time, then that is a poor plan. ( 3 MR. BELL: Well, I 'nean that may be your judgment. 4 It was not the Commission's judgment when they put 5 the decommissioning rule in place and it is also the scheme 6 that is really in place for the cleanup of uranium mill 7 tailing sites. Both of those essentially institutional R control arrangements for a period of 1000 years is the basis 9 for the release of the sites. 10 MR WYMER: A thousand years is a long, long time 11 for any control of anything. Well, obviously that's enough -12 of that. 13 MR. GARRICK: Really Mike w&s helping me -- 14 MR. BELL: And John mentioned in his presentation n(_,) 15 yesterday we are planning to come down and talk to you on 16 the cleanup criteria and the guidance that is being 17 developed for licensees to implement the criteria, so I 18 think it sounds like you are going to be very interested on 19 this. 20 MR. GARRICK:

Yes, I think Mike Dell's comments 21 were relevant to where I was heading and that is that given 22 our increased knowledge about the tanks as an example of a 23 cleanup activity where we are going to have-to be thinking 24 more in terms of not beinq able to achieve the ultimate goal 25 of unrestricted land use and it seems that that fact is C')

ANN RILEY & ASSOCIATES, LTD. Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034-I

i 175 1 becoming increasingly realized not only by the experts but ( ) 2 also by the stakeholders, and then the question becomes, \\_/ 3 well what other alternatives really exist and how involved 4 is NRC in not necessarily developing those alternatives -- 5 that is the licensee's problem -- but perhaps in 6 understunding them and their implications ? It is very clear, as Mike says, that there is 8 going to be some locations in the United States, especially 9 when we are talking about high-level waste tanks, where the 10 strategy is going to have to involve some sort of in-place 11 resolution when it comes to closure, and most likely not 12 achieving for some particular areas a green field solution. 13 So with increased emphasis on needing to do that 14 so that we don't break the national budget, I guess the () 15 Committee is kind of interested in what the NRC is doing in 16 anticipation of some changes of direction with respect to 17 remediation and cleanup. 18 I think that is something we very much are 19 interested in and will want tn hear n. ore about in the 20 future. 21 MS. DAVIS: A"O there any more questions on the 22 incidental waste that I can answer? I'm afraid 23 decommissioning is not my specialty. 24 MR. WYMER: I think not. Well, thank you very t 25 much. ANN RILEY & ASSOCIATES, LTD. \\ Court Reporters 1250 I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034 y -.e-~ w p y nem ws pm-,- ai's qv + + - - m w

I -q 176 l -1 1 MS. DAVIS - Okay.. Sure.: You're very'welcome. () 2 .MRi GARRICK: Jennifer, they're not leaving 3 because:they're disgusted. I 4 M S 1>. W I S : -Oh, no. Ilhnow. 5 MR GARRICK: They have a meeting with the 1 6= Chairman. But I guess unless there's other comments or -- f 7 yes, go ahead, Mike'. 8 MR. BELL: Could I make a brief announcem.;t? In '9 the' charts that I used yesterday, it was pointed out to me ) ~10 that if you -- witn the FTEs, if you added up the columns, 11 the columns don't add up to the totals at the bottom. The 11 2 charts were very misleading and incomplete. 13 MR GARRICK: And not quite labeled correctly. l 14 MR. BELL: The line items for the KTI showed j k 15 direct FTEs, and the bottom-line numbers included' things 16 like contract management and overhead and support by IRM and 17-OGC=and other offices, and I will be providing the AC&W 18 staff with a work --- cc nplete and labeled table that they'll 19- ' provide to the committee. But in the event somebody was 20 going to be, you know, Jooking through that material again 21-and.worryfsg about how we' set-our priorities, I'didn't want 22 them to waste r ic* of their_ time trying to understand an-23 incomplete tabis 1 opologize. 24 MR. GARRICK - Thank you. 'IS Are_there any other comments, suggestions,: C') ANh RILEY & ASSOCIATES,- LTD. . Court Reporters 1250 I Street,.N.W., Suite 300 Washington, D.C. 20005 (202). 842-0034 ,v. - -- +

I-177 ~ 1L discussions ~from the Staff-or the remaining Members on 2 incidental waste? 3 If not,'I-think what we'll1 ~do at-this point is 4 take our recess early,-and when we_ reconvene, we will'go

5L into ourLdiscussion of our upcoming Commission meeting, and 6

report preparation and so forth, in which.:ase se will' not 7 need the recording.- So let's recess. 8 (Whereupon, at 9:26 a.m., the open meeting was ~9= concluded.]' r 10 11 12 13 14 15 16 17 18 33 l b 2G $ 21-22 + (-- 23 24 L 25 i ANN RILEYJ& ASSOCIATES, LTD. Court Reporters _ 1250 I: Street, N.W.,. Suite'300 ' Washington, D.C.'20005 (202) 842-0034= 1 a.

.. ~.. - - - 7 REPORTER'S CERTIFICATE This:is to certifyLthat the-attached' proceedings bdfore-the United States Nuclear Regulatory Commission'in the matter of: NAME-OF PROCEEDING: 96TH ADVISORY COMMITTEE ON NUCLEAR-WASTE-(ACNW)-MEETING DOCKET NUMBER: PLACE OF: PROCEEDING: Rockville, Maryland were held.as herein appears, and that this is the original transcript:thereof for the file of the United States Nuclear Regulatory Commission taken by me and-thereafter reduced to -typewriting by me or under the-direction of the court () reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. {fM1kOf1 LJ ~> Jon Hundley Official Reporter Ann Riley & Associates, Ltd. lq zu -e-4eei e a>- m m.,-,y-i---.,-pg.---rr~,m%.,

O O O DRAFT NUREG 1567 l STANDARD REVIEW PLAN FOR SPENT FUEL DRY STORAGE FACILITIES (FSRP) ~ W O@ 99 e.s g / 6,h / s.

1. 4**#

i Susan Shankman, Deputy Director i SPENT FUEL PROJECT OFFICE i OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS November 20,1997 1

O O O I FSRP PERPOSE 1 4

• FSRP provides guidance for reviewing license applications for commercial inc ependent spent fuel storage installations (ISFSIsj i

I I

u O O O 1 OTHER XRC GUIDANCE DOCEMENTS 1

• Regulatory Guide (RG) 3.48, " Standard Format and i

Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation" i

• SRP for Dry Cask Storage Systems (SUREG 1536) l f

o o o

SUREG 1567 CHAPTER ORGAXIZATION

• Iieview Objective
• Areas of Review
• Regulatory Requirements
• Acceptance Criteria i
• Review Procedures i

1 4

• Evaluation Findings 1
• References

O O O AREAS OF REVIEW

• Site Characteristics 1
• Principal Design Criteria i
• Waste Confinement and Management
• Structural Evaluation l

i B l 1 l

O O O~' AREAS OF REVIEW (CONT) l Thermal Evaluation i l Radiation Protection Evaluation 1 i Criticality Evaluation Confinement Evaluation Accident Analyses l

o o o ~~~ 1 AREAS OF REVIEW (CONT) i

• Conduct of Operations
• Technical Specifications i
• Quality Assurance
• Decommissioning

l O O O i

p. ~ n,

{*} United States l %..... *~ Nuclear Regulatory Commission i 1 i Overview of HLW FY98 Budget Priarities And Proposed AC3W Interactions Presented to: j Advisory Committee on Nuclear Waste November 20,1997 i 1 By: Michael J. Bell, Acting Branch Chief Performance Assessment and HLW Branch Office of Nuclear Material Safety and Safeguards i 1

l l O O O ,....,) United States i { %....,./ Nuclear Regulatory Commission PRESENTATION OUTLINE

• Introduction
• FY 97 Accomplishments i
• Major Programmatic Milestones i
• FY 98 Priorities l
• Future ACNW Topics 2

Novernher 18,1997 I

O ascswT enoanau ^ccouetissuenTs 3 Agreement on performance-based program B Defined areas of agreement on performance assessment methodology 3 Agreed with DOE on methods for evaluation of future climates S Narrowod viable tectonic models at Yucca Mcuntain 3 Resolution achieved on identifying faults that may significantly affect respository design or performance 3 Agreement on thermal testing program B Agreement on methods to bound present-day shallow b^ infiltration 3 Resolved with DOE that erosion is not significant to Yacca Mountain Accepted DOE's QA program (monitoring implementation) B Reached agreement with DOE on the upper bound for the probability of a direct extrusive disruption of the repository by a volcanic event. Ov

SULARY SCHEDULE OF HIGH< LEVEL WOE REPOSITORY REGULAT $ $jc c.- 4 1990, f 'FV1999 FY2000 FY2001 FY2002 7 E IF TRANSURANIC CONTAMIN/.TED, INCIDENTAL WASTES UNSUITABLE FOR DISPOSAL IN A LICENSED LLW BURIAL FACILITY (PART 61 PROMULGATED LATER WITH CRITERIA FOR CLASSIFYING WASTE A,B.C, OR G FCC) I [ l ( e 5

O O O 1 2 i NRC INTEREST IN INCIDENTAL WASTE t l e WHY IS NRC INTERESTED IN WASTE CLASSIFICATION AT DOE FACILITIES (i.e., HLW or incidental)? j i-i e ENERGY REORGANIZATION ACT OF 1974 SPECIFIES THAT LONG-TERM STORAGE OR DISPOSAL OF DEFENSE-RELATED HLW IS SUBJECT TO NRC LICENSING. 1 e NRC DOES NOT REGULATE DOE MANAGEMENT OF LLW OR INCIDENTAL WASTE. 4 e WASTE CLASSIFICATION DETERMINATIONS ARE NECESSARY TO ENSURE c WASTES NOT SUBJECT TO NRC LICENSING. i i 6 i

O O O CR!TERIA FOR INCIDENTAL WASTE CLASSIFICATION e INCIDENTAL WASTE CLASSIFICATION CRITERIA FORMULATED IN FEBRUARY i 1993 COMMISSION DENIAL OF RULEMAKING PETITION (1990) FROM STATES l { OF OREGON AND WASHINGTON RE HANFORD TANK WASTES PETITION REQUESTED CLARIFICATION OF PROCESS FOR WASTE CLASSIFICATION DENIAL BECAUSE PRINCIPLES FOR WASTE CLASSIFICATION WELL-ESTABLISHED e WASTES INCIDENTAL IF: i 1. WASTE PROCESSED AND KEY RADIONUCLIDES REMOVED TO MAXIMUM i l EXTENT TECHNICALLY AND ECONOMICALLY FEASIBLE. l 2. WASTE WILL BE INCORPORATED IN SOLID PHYSICAL FORM AT CONCENTRATIONS LOWER THAN PART 61 CLASS C LIMITS. 3. WASTE WILL BE MANAGED TO SATISFY PERFORMANCE OBJECTIVES IN PART 61. l l l 7 l 1

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O O O CRITERIA FOR INCIDENTAL WASTE CLASSIFICATION (cont'd) 1 l l e WASTE CLASSIFICATION CRITERIA, PETITION DENIAL, PROVIDED TO DOE IN MARCH 1993 LETTER (BERNERO TO LYTLE) AS GUIDANCE FOR APPROPRIATE MANAGEMENT OF WASTES REMOVED FROM TANKS AT i HANFORD l t ? I i

O O O l i WASTE CLASSIFICATION A f HANFORD l l l i I e INTERACTIONS WITH DOE INITIATED IN 1988 TIME FRAME TO DISCUSS DISPOSITION OF WASTES IN 28 DOUBLE SHELL TANKS (DSTs) l DOE IDENTIFIED 10 TANKS AS HLW FOR TREATMENT, VITRIFICATION, AND DISPOSAL IN REPOSITORY [ i DOE IDENTIFIED 18 TANKS AS LLW OR INCIDENTAL FOR DIRECT GROUTING, ONSITE DISPOSAL l l l e STAFF DID NOT AGREE WITH DOE CLASSIFICATION OF WASTES IN THE 18 DSTs f l CONCERN ABOUT DOE WASTE CLASSIFICATION EXPRESSED IN MARCH 1993 BERNERO LETTER l DOE SHOULD RECONSIDER TANK WASTE REMEDIATION PLANS 1 9 f

O O O WASTE CLASSIFICATION AT HANFORD (cont'd) e IN 1993, DOE REVISED PLANS FOR MANAGEMENT C.' DST WASTE AND l lNITIATED TANK WASTE REMEDIATION SYSTEM (TWRS) PROGRAM TWRS REFLECTS INTEGRATED STRATEGY FOR MANAGEMENT OF WASTES IN ALL SINGLE SHELL TANKS (SSTs) (149) AND DSTs (28) l DOE COMMITMENT TO CONSIDER, PROCESS WASTES IN A.LL TANKS AS I HLW e IN NOVEMBER 1996, OOE REQUESTED NRC AGREEMENT THAT LOW-ACTIVITY i FRACTION FROM HLW TREATMENT IS INCIDENTAL, NOT SUBJECT TO NRC LICENSING AUTHORITY (LETTER FROM KINZER TO PAPERIELLO). I DOE REQUEST INCLUDED: 1. preliminary plans for segregation of HLW into high-activity, low-activity fractions 2. technical basis for classification of low-activity fraction as incidental f i 3. plans for onsite disposal of low-activity fraction and repository disposal of high-activity fraction t 10

O O O WASTE CLASSIFICATION AT HANFORD (cont'd) STAFF / COMMISSION REVIEW (SRM DATED MAY 28,1997) OF DOE WASTE CLASSIFICATION METHODOLOGY COMPLETED IN JUNE 1997 (LETTER FROM j PAPERIELLO TO KINZER) REVIEW BASED ON CONFORMANCE WITH THREE CRITERIA IN 1993 BERNERO LETTER PRELIMINARY CONCLUSION THAT LOW-ACTIVITY FRACTION IS ] j l INCIDENTAL, NOT SUBJECT TO NRC LICENSING CONCLUSION PROVISIONAL DUE TO PRELIMINARY CHARACTER OF DOE i PLANS FOR WASTE TREATMENT SEGREGATION AND DISPOSAL: 1. disposal facility site not selected l 2. disposal facility design incomplete i 3. treatment alternatives (e.g., evaporation, ion exchange, etc.) not selected 4. HLW tanks not well-characterized i l e DOE CONTRACTORS CURRENTLY DEVELOPING DESIGN CONCEPTS FOR TWRS 1 i l 11 l l j I

1 0 O O WASTE CLASSIFICATION AT HANFORD (cont'd) i l l i i FUTURE REVIEWS OF Dt,E DESIGN CONCEPTS, PERFORMANCE i i ASSESSMENTS, TANK CHARACTERIZATION NECESSARY TO MAKE FINAL DETERMINATIONS RE INCIDENTAL WASTE CLASSIFICATION i 4 i i l 4 i l { I e. j i i l [ I 12 i i i l

O O O 1 WASTE CLASSIFICATION AT SAVANNAH RIVER t L e IN JANUARY 1996, DOE INITIATED PROCESS FOR RETRIEV L, TREATMENT, AND VITRIFICATION (OWPF) OF HLW IN 51 TANKS l i. IN APRIL 1996, STAFF MET WITH DOE TO DISCUSS PLANS FOR CLOSURE OF = j-l- TANKS EMPTIED OF CONTENTS t i j KEY ISSUE WHETHER HLW REMOVAL SUFFICIENT TO CLASSIFY RESIDUAL j e TANK WASTES 'GNCIDENTAL" l 4 l: e IN AUGUST 1996, DOE REQUESTED JTAFF REVIEW OF METHODOLOGY FOR CLASSIFICATION OF RESIDUAL WASTES LEFT IN THE TANKS AS l l "lNCIDENTAL" i e IN DECEMBER 1996, DOE PROVIDED ADDITIONAL INFORMATION ON CURRENT "LANS AND SCHEDULES FOR TANK CLOEURE DOE INITIATED CLOSURE OF TWO TANKS IN 1997 THAT CAN MEET i EXISTING WASTE CLASSIFICATION CRITERIA i O i l

O O O WASTE CLASSIFICATION AT SAVANNAH RIVER (cont'd) l l e DOE RECOGillZED THAT THREE CLASSIFICATION CRITERIA (1993 BERNERO LETTER) DEVELOPED WITH FOCUS ON TREATMENT OF WASTES REMOVED r FROM TANKS, NOT TANK CLOSURE l i i DOE REQUESTED STAFF CONSIDERATION OF ALTERNATIVE PROVISIONS IN SECTION 61.58 FOR SATISFYING PART 61 CLASS C LIMITS (CRITERION 2) t l e REQUIREMENTS IN 61.58 RECOGNIZE ACCEPTABILITY OF OTHER l PROVISIONS FOR WASTE CLASSIFICATION (i.e., A, B, or C), IF PERFORMANCE OBJECTIVES OF PART 61 ARE SATISFIED j l e DOE ALSO REQUESTED GUIDANCE ON APPLICATION OF "BTP ON CONCENTRATION AVERAGING AND ENCAPSULATION" FOR TANK CLOSURE i I 14 i 4

O O O i i WASTE CLASSIFICATION AT SAVANNAH RIVER (cont'd) { e IN AUGUST 1997, DOE SUBMITTED UPDATED REGULATORY BASIS FOR TANK l INCIDENTAL WASTE CLASSIFICATION, FOR STAFF REVIEW i l e STAFF REVIEW OF DOE WASTE CLASSIFICATION METHODOLOGY j UNDERWAY-EXPECT COMPLETION, INCLUDING COMMISSION REVIEW, BY APRIL 1998 l h I e STAFF INTENDS TO CONSIDER EXISTING INCIDENTAL WASTE CLASSIFICATION CRITERIA (BERNERO LETTER) AND NEW j c DECOMMISSIONING RULE CRITERIA, AS APPROPRIATE, FOR SAVANNAH l j RIVER TANK CLOSURE EVALUATION i I e STAFF WILL ALSO CONSIDER FLEXIBILITY IN _JTION 61.58 FOR SATISFYING j CRITERlON 2 (BERNERO LETTER) 15 L..

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L-o o o l WASTE CLASSIFICATION AT WEST VALLEY l i DOEINYSERDA CURRENTLY IMPLEMENTING STATUTORY REQUIREMENTS OF l l-WEST VALLEY DEMONSTRATION PROJECT ACT FOR SITE l DECONTAMINATION AND DECOMMISSIONING i FOUR HLW TANKS (TWO LG., TWO SML.) AT WEST VALLEY IN NEED OF D&D, e ONE SMALL TANK ONLY SLIGHTLY CONTAMINATED i e IN JANUARY 1996, DOEINYSERDA ISSUED DEIS FOR COMPLETION OF WVDP AND CLOSURE OR LONG-TERM MANAGEMENT OF SITE FACILITIES e DEIS IDENTIFIED ALTERNATIVES FOR TANK DISPOSITION l l 1. DISMANTLEMENT-OFFSITE WASTE SHIPMENT 2. DISMANTLEMENT-ONSITE WASTE STORAGE 3. IN-PLACE STABILIZATION i 4. NO ACTION-MONITORING AND MAINTENANCE AS IS i i 4 i Ib f

O O O l l L l l WASTE CLA SSIFICATION AT WEST VALLEY (cont'd) t t l INCIDENTAL WASTE CLASSIFICATION CRITERIA WOULD FACILITATE SELECTION AND IMPLEMENTATION OF ANY OF TANK DISPOSITION ALTERNATIVES e DOE /NYSERDA NOT CLOSE TO COMPLETING EIS PROCESS i l NO ROD WITH PREFERRED ALTERNATIVE FOR MANY MONTHS l i i DOEINYSERDA MONITORING PROGRESS OF TANK CLOSURE AT SAVANNAH e RIVER l i ) i l l t l '7

i l 1 t I O {* Y

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A y LC l [ 1 7 ~ / ~ f, j I l N jt O % ~l vB I I K T C A O Z - Ni L t L ? s ~ R N'\\ ET 0 E E A L 9 S E I t i-L R i/' T E E 'E R S b GK S S d AN P di-< L N R A ~ E A yI m. OT C O C T B A S i R '5 te g ** N le A V s C P E i. OP J, N M 1 E G P H g i 4' g # o R r ~ a ,h(' m l g! i A t h P S ~ ElF:{L C 4 , J O W.s % lI i l W 4 g v tD q %x &M u f e P r I i 2: /aM ii. s tu e N d. ? t - s s NN s m J I a i L y-l g a R h E %~ 4-, F ~ T N W N A I \\" S NA R . N T E N .M S A P W / t L l ,i I E ~~ l E j I l T I S KR G O N W MI D IR A G R F L A F N O R O E O R T N I }.' I, li ), 9

i l.

SUMMARY

4 6. l 1 CRITERIA EXISTS FOR DISTINGUISHINb HLW FROM INCIDENTAL WASTES 1 l l l e PRELIMINARY REVIEW COMPLETE OF DOE METHODO._OGY FOR l CLASSIFICATION OF TREATED HANFORD TANK WASTES t i REVIEW OF DOE METHODOLOGY FOR CLASSIFICATION OF SAVANNAH RIVER l 4 RESIDUAL TANK WASTES IN PROG'RESS 1, j \\ \\ o EVALUATION OF PROPOSALS FOR WASTE CLASSIFICATION FROM WEST l VALLEY AWAITING COMPLETION OF EIS PROCESS s i i i 4 i i a i 4 l 1 1 18 j I

O O O 9 Description of Comments i

• 207 Comments recieved on draft XEREG 1567 i

l

• 70 Comments recieved on draft :SUREG 1536 i

e considered relevant

• Areas Comments recieved l

t> Clarification on NRC acceptance critena l t> Structural > Accident Analysis j .}}