ML20024E799
| ML20024E799 | |
| Person / Time | |
|---|---|
| Issue date: | 08/15/1983 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20024E798 | List: |
| References | |
| REF-WM-1 NUDOCS 8309070073 | |
| Download: ML20024E799 (55) | |
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STANDARD REVIEW PLAN FOR I
SITE CHARACTERIZATION PLANS i
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o DIVISION OF WASTE MANAGEMENT U. S. NUCLEAR REGULATORY COPMISSION i
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l CONTENTS i
Page
1.0 INTRODUCTION
.4
2.0 BACKGROUND
5 2.1 Site Characterization (5C).............................
5 2.2 Site Characterization Plan (SCP).......................
5 2.3'SiteCharacterizationAnalysis(SCA)...................
6 2.3.1 General Nature of the SCA.......................
6 2.3.2 General Approach to SCA Development.............
7 1.0 GENERAL APPROACH TO REVIEW AND ANALYSIS.....................
9 3.1 The NRC Staff's Job....................................
9 3.2 General Approach.......................................
10 3.3 Specific Approach......................................
11 3.3.1 Site Selection..................................
11 3.3.2 Site Characterization Program...................
11 3.3.2.1 Type of Material for Review.............
11
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3.3.2.2 Nature of Analysis......................
12 3.3.2.3 Review Guidelines.......................
13 4.0 SITE CHARACTERIZATION ANALYSIS PRODUCTS.....................
15 4.1 Document Types.........................................
15 4.2 Product Descriptions...................................
15 4.2.1 Site Characterization Analysis (SCA)............
15 4.2.2 Site Technical Position (STP)...................
16 i
4.2.3 Generic Technical Position (GTP)................
17 83/08/15 2
STANDARD REVIEW PLAN
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4.2.4 DOE-NRC Meeting Summaries, NRC Technical letter, and Informal Contractors Reports........
17 5.0 REVIEW PR0CEDURE............................................
19 5.1 Organization...........................................
19 5.1.1 General Orgranization Requirements..............
19 5.1.2 General Organization Structure..................
19 5.1.3 Project Team Responsibilities...................
20 5.1.3.1 Technical Integration Group.............
20 5.1.3.2 Technical Assessment Groups.............
20 5.1. 4 Special Multi-Disciplinary Problem Areas........
22 5.2 Steps in SCP Review and Analysis.......................
23
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5.2.1 General Preparation.............................
23
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5.2.2 Specific Steps..................................
24 Appendix A Establishing Licensing Information Needs..........
A-1 Appendix B Standard Outlines and Review Questions for SCP Review Products...............................
B-1 Appendix C Routine Document Reviews..........................
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STANDARD REVIEW PLAN w.' ::
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'1. 0 INTRODUCTION This review plan is developed for use by NRC staff and NRC contractors and consultants who will be involved in the SCP Review.
The plan provides a set of procedures to prepare for SCP receipt and review, which includes working with DOE to assure that the SCP is of adequate scope and quality and to identify and resolve questions of site characterization plans and approaches.
It will be applied to each site for which DDE intends to submit an SCP.
The plan is designed to provide the basic organization and approach used in SCP reviews.
It is not intended to be a rigid set of procedures; some details in the plan may be altered as necessary to reflect unique project-specific conditions and the overall evolution of the repository program.
This plan was initially prepared in the Spring of 1982.
This revised edition incorporates changes based on NRC experience in reviewing the BWIP SCR and requirements of the Nuclear Waste Policy Act of 1982 (NWPA).
The effective implementation of this review plan depends heavily on obtaining up-to-date, site specific information prior to receipt of the SCP.
This will derive from a variety of activities that both precede and are concurrent with each SCP review.
These include, to the extent practicable, continuing inter-actions between NRC and DOE - site visits, topical and programmatic -
discussions, and other technical interchanges.
Interactions will also be needed with other involved parties, such as State agencies, Indian tribes and the U.S. Geological Survey.
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'2. 0 BACKGROUND 2.1 Site Characterization (SC)
" Site characterization," as defined in Nuclear Policy Waste Act of 1982 (NWPA, P.L.97-425, January 7,1983) and similarly in 10 CFR 60 (at 46 FR 13980) means the program of exploration and research, both in the laboratory and in the field, undertaken to establish the geologic conditions and the ranges of those parameters of a particular site relevant to the procedures under 10 CFR 60.
Site characterization includes borings, lateral excavations and borings, and in situ testing at depth needed to determine the suitability of the site for a geologic repository and the adequacy of the proposed repository design, but does not include preliminary borings and geophysical testing needed to decide whether site characterization should be undertaken.
The objective of site characterization (SC) is to collect pertinent geological and other site characteristic information so that the construction authorization application will be complete enough to enable NRC to do the evaluation and make the findings required by 10 CFR 60.31: namely, a meaningful analysis of (a) the suitability of the site to isolate radionuclides and (b) the adequacy of the repository design to site conditions.
r 2.2 Site Characterization Plan (SCP)
The NWPA details procedures to be followed by NRC in connection with the licensing of high-level waste repositories.
Section 113(b)(1) of the NWPS requires DOE to submit--and NRC to review and comment upon--a site characterization plan (SCP) prior to shaft sinking that in large part is described in terms identical to, or parallel to, the earlier NRC regulations, 10 CFR 60 - " Disposal of High-Level Radioactive Waste in Geologic Repositories" (46 FR 13971).
As part of the pre-licensing procedures set forth in 10 CFR 60 tne Department of Energy (00E) is required to submit a Site
' Characterization Report to the NRC as early as possible after commencement of planning for a particular geologic repository operations area and prior to site characterization.
In both cases, the basic purpose of the SCP is clear: to provide a mechanism for identifying problems at a proposed repository site and the plans for resolving them at an early time in order to avoid delays in the licensing process.
It is anticipated that each SCP will be an extensive document covering the many technical aspects of characterizing a high-level waste repository.
Section 113(b)(1) the NWPA identifies the types of information to be provided in the SCP.
"(A) a general plan for site characterization activities to be conducted at such candidate site, which plan shall include --
(i) a description of such candidate site; (ii) a description of such site characterization activities, including the following: the extent of planned excavations, plans for any onsite testing with radioactive or nonradioactive material, plans for any 83/08/15 5
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investigation activities that may affect the capability of such candidate site to isolate high-level radioactive waste and spent nuclear fuel, and plans to control any adverse, safety related impacts from such site characterization activities; (iii) plans for the decontamination and decommissioning of such candidate site, and for the mitigation of any significant adverse environmental impacts caused by site characterization activities if it is determined unsuitable for application for a construction authorization for a repository; (iv) criteria to be used to determine the suitability of such candidate site for the location of a repository, developed pursuant to section 112(a);
and (v) any other information required by the Commission:-
(B) a description of the possible form or packaging for the high-level radioactive waste and spent nuclear fuel to be emplaced in such repository, a description, to the extent practicable, of the relationship between such waste form or packaging and the geologic medium of such site, and a description of the activities being conducted by the Secretary with respect to such possible waste form or packaging or such relationsnip; and (C) a conceptual repository design that takes into account likely site-specific requirements."
A uniform format for presenting the information which was originally required under 10 CFR 60 is detailed in the NRC " Standard Format and Content of Site Characterization Reports for High-Level Waste Geologic Repositories" (Regulatory Guide 4.17, July,1982). Although this guide have been superseded by the NWPA, details presented in the guide on data collection and analysis are still relevant for most technical aspects of site characterization.
2.3 Site Characterization Analysis (SCA) 2.3.1 General Nature of the SCA The Director of NMSS will complete a review of the SCP and provide comments thereon to DOE in accordance with the DOE project decision schedule.
The SCA will present NRC staff comments on the appropriateness of the SC plan proposed in the SCP.
The SCA will not include any NRC opinions on site suitability.
The SCA represents the beginning of a process of reviewing the DOE program at each site and will focus on major issues and associated licensing information needs.
The SCA is advisory in nature; it conveys NRC comments and advice on the thrust of DOE's plans for site characterization.
Details occurring later 83/08/15 6
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' n the DOE program will be followed through DOE's semiannel reports on the i
progress of site characterization.
The SCA is intended to be a concise analysis, emphasizing open items for continued follow-up discussion.
The SCA will not provide coverage of all items presented in the SCP; for a complete understanding of the SCP, readers will need to refer to the SCP and supporting materials submitted by DOE.
Technical positions, preliminary and supporting analyses, NRC contractor reports and related materials will be provided as appendices to the SCA.
2.3.2 General Approach to SCA Development This review plan indicates how NRC will review each SCP and develop a Site Characterization Analysis (SCA) from the Office of the Director of NMSS.
It is essential to issue the SCA as soon as possible after receipt of the SCP to avoid delays in the national program.
Because a short turnaround time from receipt of the SCP to issuance of the SCA is necessary, NRC emphasis will be placed on " advance work" prior to receipt of the SCP.
This advance work will consist of activities such as: developing technical background material; reviewing available site data; and establishing and maintaining contact with DOE technical staff, State agenciesond otner g [d a
individuals and organizations who are likely to be involved in the e
preparation / review of the SCA.
Continuing interaction with DOE and other Q#
interested parties is essential to NRC's development of a sound and effective SCA in the short time that will be available.
Elapsed time between receipt of the SCP and publication of the SCA is expected to be between 4 and 10 months, depending in part on how the question of formal public comment is treated in 10 CFR 60 when it is amended to conform with the NWPA,* and on the availability of information and data prinr to SCP receipt.
Upon receipt, the SCP will be given a brief acceptance review by the NRC staff to determine whether it contains the information required by the NWPA and 10 CFR 60.
If it is not adequate for review it will be returned with comments t
on the basis for such action.
Once the SCP is accepted, the NRC staff will critically review the SCP and then prepare the SCA.
The SCA will include consideration of all pre-SCP consultations with DOE, States, the USGS and other organizations.
Under the current provisions of 10 CFR 60, a draft SCA will be published for public comment (the comment period shall not be less than 90 days).
I All public comments will be available at the PDR and transmitted to Governors and chief executives as noted above.
The NRC will prepare written responses to State, Indian tribal and local government comments, and shall make these responses available at the PDR.
A final SCA will incorporate public comments received by the NRC.
It is as yet uncertain whether the current provisions are consistent with the intent of the NWPA.
An amendment to 10 CFR 60 will resolve this and other matters related to conformity with the NWPA.
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'The NRC analysis of the SCP has as its main objective the review of DOE's identification of issues and site characterization program.
Specifically, does the SCP adequately:
1.
establish what is known about a site from site screening, selection and exploration activities completed to date, 2.
describe the issues
- that 00E has identified at a site in light of the results of investigations to date, and 3.
oescribe the detailed plans of work for data acquisition and analysis to meet information needs for issues.
Since the DOE program of site characterization will need to be a phased process, NRC expects that the SCP may be better defined and more detailed for early phases of site characterization (e.g., testing in the exploratory shaft) and less detailed for later phases (e g., testing in an underground facility with two shafts). As DOE finalizes the plan for later phases of site characterization, additional details can be submitted to NRC in periodic updates to the SCP, as provided for by the NWPA and in 10 CFR 60, and other mechanisms appropriate.
e The NRC review must encompass the plan for all site characterization activities for gathering information needed to conduct the full 10 CFR Part 60 evaluation of site suitability and acceptability of design.
Although the levels of detail in the SC plan may vary among issues, the NRC review team must ensure that DOE has a plan to adequately address all issues; the SCA will contain a summary of all NRC concerns, comments and open items.
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An issue, as used in the context of the NRC SCP reviews, is a question that must be answered or resolved to complete licensing assessments of site and design suitability ir. terms of 10 CFR 60 performance objectives and requirements.
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' 3. 0 GENERAL APPROACH TO REVIEW AND ANALYSIS This section of the review plan describes the conditions and procedures which will govern the review of each SCP.
3.1 The NRC Staff's Job The NRC staff's approach to review of DOE site characterization programs and prelicensing activities in general, stems from what its responsibility is in licensing.
The job of the NRC staff reviewers in licensing will be to critically evaluate data and analyses submitted in the license application in support of the proposed repository site and design and to independently draw conclusions about whether regulatory requirements and performance objectives are met. This will involve, first, reviewing specific data and detailed information on how data was collected to independently establish data relevance and quality.*
Second, data included in DOE's analyses, as well as that collected but not explicitly used, will be evaluated by the staff and its supporting contractors to independently determine whether the data are adequate to support the conclusions of DOE's analyses or whether the data, in fact, require that more conservative conclusions be drawn.
In making these determinations, the staff will rely on expertise, judgment, and experience in addition to use of mathematical models and computer codes.
Prior to receipt of a license application, the job of the NRC staff reviewers becomes one of establishing what information must be included by 00E in its license application to allow the staff to do its licensing job in a timely and efficient, but, at the same time, thorough and technically sound manner.
Review of the SCP and preparation of the SCA are a key step in establishing what will be the information requirements for licensing.
In fact, 00E is now conducting major programs of site investigation and design development work.
Programs of laboratory and field testing are origoing in the many areas involved in the respository system:
hydrology; geochemistry; geologic stability; waste form and package materials and design; engineered barriers such as shaft and borehole seals; and rock mechanics.
Construction of shafts and underground test facilities is imminent and plans for these are being finalized.
Experience has shown that early and ongoing NRC staff technical reviews are essential to assure that this work is providing information needed for licensing.
The sito work is by definition exploratory, one phase of the program depending upon results of previous phases.
Effective NRC staff review requires keeping current with the large volume of data being generated so that Data actually presented in license application will either be summarized or, of necessity be only a small part of what will have been gathered and available.
The NRC reviewer must review on a selected basis (as dictated by experience and expertise) data and information at all levels down to primary, raw data.
This is needed to make an independent conclusion on data relevancy, quality and interpretation.
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6 issues can be raised at an early time and thus assure that DOE programs are directed to resolve them. Also, informal consultation wih DOE investigators is required on an ongoing basis in each of the many technical areas involved.
This data review and consultation process involves more than review of SCPs and preparation of SCAs by NRC staff.
Supplementing and preceding the SCAs are documented site reviews and technical meetings and single-issue site technical positions.
These have proven to be required in heading off problems in ongoing programs.
Because staff involvement must be started early and be kept active at each of the sites under investigation, that involvement is relatively insensitive to specific DOE plans for such events as SCP submittal and start of the exploratory shaft.
Thus, the submission of SCPs marks only a nominal change in staff pre-licensing activities.
3.2 General Approach In establishing licensing information requirements, the most immediate problem with respect to site characterization activities is "specifically, how much of what types of information is needed and enough?" or "how much testing and analyses is needed and enough?" The staff's approach to pre-licensing activities in general and SCP reviews in particular is mindful of this problem.
In this respect, the staff's approach and its underlying logic are described in detail in Appendix A.
In essence, that approach is a systematic, iterative review process that uses preliminary performance assessments and sensitivity studies to establish when enough is known and thereby achieve closure.
In this way all investigations are, in some fashion, related to quantitative performance assessments and their relative importance established.
The process puts the burden on DOE to take the lead in identifying the specific information that will be required to assess performance of the repository system.
This is consistent with DOE's role in the repository development and licensing process.
The "^~ -" s adopted by 10 CFR 60 gives DOE the flexibility and the attendant responsibility to 4t M what each repository component will contribute to overall perform nc.
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.a J must be before licensing information needs can be established.
hm The elements of the staff's systematic, iterative approach and their interactions are shown in the simplified logic diagram in Figure 1.
This sequence of elements is flexible.
The initial element (1) in the systematic, iterative process is one of establishing the present level of understanding about the site.
This is followed by (2) the identification of the performance issues which eventually must be addressed to determine whether the site and the engineered system will comply with NRC regulations.
These issues are the basis for (3) the development of specific assessment methods, including conceptual, mathematical, and numerical models.
Inputs and assumptions to these models help determine the information needs that must be addressed during site characterization. Of all the steps in the systematic, iterative process, (4) sensitivity studies are perhaps the critical element since they can be conducted at several levels using a variety of methods to determine what are the essential information gaps.
In some areas, it is also necessary for DOE to (5) establish initial (preliminary) component requirements in parallel with the development of assessment methods and sensitivity studies.
These requirements should evolve along with the program and may be adjusted as the whole process is repeated 83/08/15 10 STANDARD REVIEW PLAN
a when new information or methods are developed.
The nature of many of these i
requirements can be inferred directly from the performance issues, and, once they have been established, they also make an essential contribution to identi-7 i
fying information needs.
Acceptable levels of uncertainty that directly affect i
the amount and quality of data needed are also established here.
Finally, this i
is the element in which relative component performance contributions (trade offs) are adjusted to compensate for uncertainties in various components.
Elements (1)'to (5) all contribute to (6) identifying information needs.
Once these needs have been identified, (7) the establishment of_ test plans and procedures follows directly, and forms the basis for (8) generating data and determining.the uncertainties associated with them.
These data and uncertainties can be then used to upgrade the sensitivity studies and the assessment methods and refine the component requirements. The process by its nature is an evolving, iterative one.
It must start with the use of substantial judgment, relatively simple models, and-sparse data. As more data are gathered, the process can be iterated at progressively more refined levels until an acceptable level of uncertainty is reached and (9) findings made.
3.3. Specific Approach
.r 3.3.1 Site Selection W
Under. the NWPA, NRC will have concurred % siting guidelines before SCP i
submittal.
Section 113(b)(1) of the NWPA requires that the criteria used to determine site suitability be. included in the SCP.
NRC staff responsibility is to confirm that the criteria are included in the SCP.
i 3.3.2 Site Characterization Program 3.3.2.1 Type of Material for Review (a) Site conditions: (1) reports which describe existing properties of the i
site, (2) reports on the interpretation of the geologic history of the (p k l
site, (3) data summaries such as representative core logs and borehole 1
test results, and (4) scientific literature relevant to understanding l
properties or processes which may. impact the site.
Other data will be b
available in advance from DOE at the specific site.
(b) Conceptual repository _ design:
preliminary safety design criteria, functional description of. components important to safety and isolation, conceptual drawings.
(c) Waste form and package:
for the reference design concept and principal alternatives -- preliminary safety design criteria, functional description with respect to safety and isolation, conceptual drawings.
l (d). Identification and discussion of plans for resolution of issues in siting, design, waste form d performance assessment.
(e) Sitecharacterizationprogram:kescriptio
.(eststobeconducted underground, at ground surface and in laboratorP-objective, selected method and technique, application, alternative methods / techniques.
Design 83/08/15 11 STANDARD REVIEW PLAN
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l of underground test facility -- design criteria, drawings, specification.
Schedule of activities with milestones, decision points,i ouguts "S
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p(gan.ed 6 Ct (f) Plans for decontamination and decommissioning and for the mitigation of adverse environmental impacts of SC if site is found unsuitable for a repository.
(g) Description of the quality assu ance (QA) program for SC at the selected site, supported (perhaps) by QA reports and documents from other sites.
Through site visits and meetings with DOE to review site data and informally consult on plans, NRC and its contractors should be reasonably familiar with much of this material.
3.3.2.2 Nature of Analysis Q
(a) Review data and informucion from investigations to date and evaluate the b%
interpretations by DOE.
How were the data collected and what is the N*d 0 qualityofthedataandtheirrelevancetQiteissup (b) Evaluate each issue: (i) identification; (ii) importance to repository a aa performance, (iii) degree of resolution; (iv) specific information needs W
for resolution; and (v) SC investigations needed to develop information M
for resolution. Analyze data in SCP and at site to determine whether all NM relevant issues are recognized and developed.
40 t (c) Determine whether proposed investigations to address outstanding issues ad are properly conceived.
Determine whether appropriate tests, test g[%f methods and investigative strategies are proposed.
Evaluate appropriate-g ness and reasonableness of program schedule, milestones and plans.
Judge wgo q
applicability and suitability of QA program, determine acceptability of
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activities to be covered under QA; determine suitability cf QA procedures. 3M Q'\\
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M (d) For repository and waste form / package design, examine' validity of design Mhdo i*
criteria and functional description, and adequacy of design.
For
- 'M repository, analyze integration and compatability of exploratory shaft and
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underground test facility with repository design.
(e) Check DOE's modeling (if available) of groundwater flow /radionuclide
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migration.
Establish the importance of site specific variables through sensitivity studies and preliminary modeling based on existing, limited
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(f) Evaluate plans for decontamination and decommissioning of the sited
' b (g) Evaluate plans for the mitigation of any significant adverse environment
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impacts _ caused-by-site characterization activities if itydeTirmined
'that the site is unsuitable for application for a consiTuction authoriza-tion for a repository.
v review and anatyris-wi.Q _ require assistance from outside contractors and consultants with guidance provided-by41RC_on_(1) method and completeness of I
review, (2) form of output, and (3) timing of re_vieWactivitiesc-- All_ reviewers l
should note that there may be several site reviews and other staff activities
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going on in parallel.
Since there will likely be constraints on time available for SCP reviews, care must be given to determining priorities of issues, levels of detail of analyses, schedules for issue resolution, and other aspects of
-each SCP review.
3.3.2.3
, Review Guidelines All reviewers will need to be sensitive to the following points while reviewing the SCP and preparing any documentation related to the review:
1.
Relevance to Licensing - The entire analysis, from beginning to end, should be tied to information required in licensing assessments (10 CFR 60 assessments).
Sufficiency - The staff should. @b: k (4hN e
2.
.51: t: d;.-.en. m o so aoi.J.et it i:
- rr.:d : brut '" nely what is necessary and sufficient to ultimately -
make licensing findings.
Bounding approaches may be appropriate and, given that 00E is working with limited time and resources, the staff must 40g #8 g bc :ble to-d::;r.-t,aic Usai ii e aa+ ::h'ngformorethanisnecessaryg 3.
Sensitivity to Real World Factors - The HLW program is a real-world effort subjecttoconstraintsoftimeandrefources.
Reviewers should be yg appropriately sensitive to such factors ca - t : f ' :;...-.. L. o. o
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For exampid, appropriate consideration 'should g
be given to the following factors:
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DOE resources are limited; c>%d u to b.
SC investigations are appropriate and necessary; Mw c.
Flexibility is required to allow for adjustments in what is of g"'" cius necessity an investigative program.
Adjustments will be made within T-M each program area and in relative priorities among program areas as the overall program progresses; d.
Lead times vary. Not all matters must be settled at the start of site characterization.
The reviewer should be careful to identify what is on critical path; What is necessary is that a complete program be h out in broad e.
terms and details settled on at least the first steps of SC investigations and the long lead-time items.
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X.Js appropriate, a-Reviewers should not piece-meal a h eM.
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making allowance for compensating factors.
4.
Completeness of Review -
a.
If information is not presented or referenced in the SCR or in information formally submitted, "it does not exist" for purposes of review.
Thus, important information is missing (even though it is understood to exist from discussions with DOE in workshops and the 83/08/15 13 STANDAR0 REVIEW PLAN
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like) it should be treated as missing and a critical comment is in
- order, b.
DOE programs must, to the extent practicable, clearly identify, characterize and account for uncertainties and limitations. Where this is not the case a comment it in order.
Specifically, the reviewer should comment: (i) where unaddressed uncertainty leads to lack of plans directly in the program area involved or (ii) where it leads to lack of plans in other areas.
There can be no significant problems in the SCP that are not com-c.
mented on.
The reviewer should recognize that the most effective and responsible way to give guidance to DOE is through comment on its plans.
DOE should not be left wondering what NRC thinks of its program or planned approaches as decribed in the SCR.
Therefore, the make reviewer should make sure that he or she is pointedly commenting on such items as:
-(i) identification and description of work elements; information needs (data and analysis) for work elements; priorities placed on work elements; mandatory measurement conditions; (ii) logic and sequencing.
diagrams,'(iii) schedules, and (iv) major specific points of approach to investigations such as bounding or simplifying assumptions made to make the program feasible.
5.
Coordination - The review of the SCP~must be well coordinated among technical program areas.
83/08/15 14 STANDARD REVIEW PLAN
'.0 SITE CHARACTERIZATION ANALYSIS PRODUCTS 4
4.1 Document Types There are several different document formats including the SCA that are used by the NRC staff for establishing these licensing information needs.
While the purpose of all of these documents is to establish and document on a timely basis what information is needed in a licensing application to perform licensing assessments, the specific circumstances under which a document is prepared are variable.
Thus, a variety of documents is used to do the job.
In general, the variability arises from (a) the stage of the National program (b) variability in the nature of the technical issues in HLW, (c) the site specific nature of many of the issues, (d) the evolving or changing nature of issues with time and (e) variability in what is an appropriate level of detail.
In addition, the NRC staff does not control variables such as timing of submittal of DOE documents, such as an SCP, to the NRC or programmatic milestones in the DOE investigations.
The variety of documents allows the staff the flexibility to provide timely guidance to DOE before and in preparation for SCP submittal.
The available document forms are:
(1) Site Characterization Analysis (SCA),
(2) Site Technical Positions (STP),
Mk (3) Generic Technical Positions (GTP),
h4 (4) DOE-NRC Meeting Summaries, Technical Letters, and Informal Contractor h >a
- Reports, While each of these documents is unique in certain respects, they also have one essential thing in common:
they are effective in accomplishing their purpose only after having been transmitted to the DOE and the public.
Descriptions of the purpose and content of the SCA and related products are provided below with emphasis on their unique aspects and the specific roles they play in pre-licensing interaction with the 00E.
Standard outlines for SCA's, STP's, GTP's and Meeting Summaries are contained in Appendix B.
4.2 Product Description l
4.2.1.
Site Characterization Analysis (SCA)
The SCA is the most visible and comprehensive of the various pre-licensing documents.
It documents the staff's analysis of the basic thrust and strategy of the DOE program and is the principal mechanism for providing guidance to DOE as required by 10 CFR 60 and the NWPA.
It is prepared by the entire review team under the general direction of the Project Manager following the staff's SCP review.
There will be widespread distribution of the SCA -- in addition to distribution to DOE and the PDR, it will be published as a NUREG and distributed directly to States, as&enMw9tv affected Indian tribes, interested members of the public and other NRC offices.
The SCA is a one-time-only document that is issued at the beginning of site characterization.
Follow-up on the nature and extent of SC activities is provided in par l
&by semi-annual reviews which will be issued until receipt of a license 83/08/15 15 STANDARD REVIEW PLAN
e application.
Preparation of the SCA is initiated by receipt of DOE's SCP.
Where possible, the staff analyses that are presented in the SCA and subsequent reviews will be based on and will reference positions that are documented in Site Technical Positions, Generic Technical Positions and other guidance documents.
4.2.1.1 SCA Appendices Appendices will be prepared by NRC staff to support selected aspects of analyses in the SCA text.
The appendices will be contained in the NUREG document.
The major appendices are:
Description of Site and SCP - Maps of the site and table of contents of the 1
SCP.
Detailed NRC Staff Comments on the SCP - Detailed NRC staff comments on the SCP, presented in the same topical order as Chapters 3 through 10 of the SCA text. The staff comments address the SCP in terms of two central questions:
(1) does the SCP adequately identify and characterize the issues? and (2) will the proposed site characterization program be sufficient to obtain needed
~
information to address these issues?
Identification of Site Characterization Issues - A comprehensive and systematic t
identification of potential issues at the site, prepared by the staff before receipt of SCP to ensure that the SCP review is complete and relevant to potential licensing assessments.
On the basis of information available to-staff, the listing of issues in this appendix will be developed by rigorously considering the performance assessments that will be conducted in determining compliance with licensing requirements of 10 CFR 60 Subpart E and the NWPA, and compared to the statement of issues presented in the SCP.
Detailed Technical Analyses - Detailed, site-specific data and analyses which provide supporting information for selected, major site issues as addressed in the SCA. Typical subject matter may include hydrostratigraphy and geologic controls, environmental conditions for the waste form and metallic waste package component, stability of openings, retrievability systems and other subjects as appropriate to each site.
i 4.2.1.2 SCA References Selected, key technical reports will be included as references to the SCA.
These will include the general results of major technical assistance efforts of a several year period addressing selected, major issues and identifying the basic elements of an acceptable SC program to allow addressing these issues in i
licensing.
These reports will focus on chief technical issues, such as those in geochemistry and hydrology, which are new, unconventional and unique to a high-level waste repository.
They will be made available for public inspection at the NRC PDR.
4.2.2 Site Technical Position (STP)
STPs provide a concise standard format for formally and visibly establishing staff positions on site specific issues.
The set of STPs for a given site provides a means of tracking and tracing positions taken by the staff.
The scope of the material encompassed by STPs is highly variable.
In each 83/08/15 16 STANDARD REVIEW PLAN
s
' technical area, they will include one " umbrella" STP that establishes what the technical issues are and other STPs of more limited scope that establish what are acceptable methods of analysis, minimum information needs, or acceptable methods of data gathering.
STPs are prepared by the topic review groups under the direction of the Project Manager. They will be distributed to the PDR, DOE, interested states and potentially affected Indian tribes.
Comments will be encouraged.
The umbrella STPs will be issued prior to receipt of the SCP; others will be issued as appropriate throughout the pre-licensing period.
STPs were devised to provide maximum flexibility in completing a series of technical positions that have sufficient formality'to get staff positions on record and to 00E.
STPs will be concise (few pages) to assure the flexibility required to establish positions in an efficient and effectivo manner. An STP
~
might be a one page endorsement of another document, such as a contractor letter report, or a few pages that stand on their own.
g k
STPs serve to establish staff positions in analyses that will be presented in T
the SCA and licensing documents.
Preparation of an STP (other than an umbrella g
STP) is initiated by the need for documentation of a staff concern or of a response to a major question raised by DOE in a meeting, workshop, letter or M
p other document.
4.2.3 Generic Technical Position (GTP) g Some issues tend to lend themselves to generic treataent for efficiency.
GTPs @ b kl provide the mechanism for formally and visibly establishing staff positions on J "f s
generic issues.
In general, the scope of a GTP is quite broad, e.g., general "4
information needs to resolve borehole and shaft sealing issues (by their nature * -
M
} more specific topics will tend to be site specific and more appropriately, addressed in STPs).
Other examples of issues that may be documented in GTPs
\\
are issues related to waste form, waste containers, performance assessment' O
modeling, and quality assurance programs.
W I[
GTPs are prepared by the topic review groups under the direction of the section s
leader. A draft GIP will be transmitted to DOE and other interested agenties s
and technicae experts for review and comment.
In additien, a notice of f,commentperiod.
availability will be published in the Federal Register with a sixty day public hp
,I of the GTP will be placed in the Federal Register and copies will be After incorporating public comments, a notice of availability transmitted to DOE.
GTPs establish staff positions on generic issues to provide guidance to DOE on what must be achieved in the various icvestigations at potential repository sites.
Tha GTPs will support staff analyses documented,in '.he SCA and subsequent reviews.
Preparation of a GTP,is initiated by the need for documentation of a staff concern on a broad generic question.
4.2.4 DOE-NRC Meeting Summaries, NRC Technical Letters, and Informal Contractor Reports These products provide the staff with mechanisms to document licensing information needs in a timely transmittal to DOE.
83/08/15 17 STANDARD REVIEW PLAN C
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REVIEW PROCEDURE JA 5.1 O_rpnization 5.,5.1 General Organizational Requirements
~,
Two broad reguirements determine the nature of the organizational structure that 15 appropriate for SCR reviews.
These requirements are the following:
1.
The HLW repository is a system of closely coupled and interrelated natural
,ar.d. engineered barriers.
Therefore, there must be strong technical
! integration on an ongoing basis. What is technically required and
! Eufficient in analyzing performance of any system component is determined in part by performance of other system components.
Assessment of any 4
qcopponent, performance requires inputs from a wide variety of technical spedialties.
N s
2.
There must be technical groups having distinct experience and expertise with a fendamental responsibility of assuring technical quality and defensibility. These groups must also act to assure that there is 7
acpropriste consistency on technical positions taken from one site to s
L
,Ns another.
5.1.2 General Organization Structure A matrix management structure, in which technical expertise and capability is massed in core groups (topics review groups), best incorporates the organizational requirements. An approach based on this structure centralizes the work in a given technical discipline, or group of tightly linked disciplines, in one place to provide maximum technical strength.
It would avoid dilution of technical effort and expertise.
(A " spatial" or repository component breakdown, e.g., near-field /far-field, or " engineered system"/ natural system" breakdown would tend to result in fragmentation and duplication of the technical disciplines and expertise.) Technical integration and must be provided of these groups. This comes from a separate " technical integration" group.
This organization provides the strong checks and balances required to assure (a) high competence and quality in each of the major technical areas involved N
in repository licensing and (b) strongly integrated assessments of repository p
performance by these groups.
@a
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The overall responsibility of directing the review and analysis of the SCP and e; m preparation of the SCA rest with the Project Manager (PM).
The responsibility
,4 of directing and executing the review and analysis of site issues within each "1
' topic review group rests with a Group Coordinator (GC) 1.e., a designated i
senior ms:ber of the topic review group or section leader.
Because of the i i extensive interrelationship among issues -- the fact that the data required to resolve many of them are exactly the same -- there will be a need for operating
,~
as teams according'to the topics described above.
GCs have the responsibility of assisting the PM in:
(a) assuring rapid dissemination of relevant information to all group members and assuring that all members are current on each others activities; (b) assuring coordination among specific activities of group members through frequent meetings, phone conferences, etc.; and (c) essuring coordination of reports from group members.
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19 STANDARD REVIEW PLAN y
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Y aDOE-HRC Meeting Summaries - Meeting summaries document DOE /NRC workshops and
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J other, technical meetings.
These surr.maries include an agenda, a list of infoNaation/ data reviewed, NRC observations on the scope of DOE investigations, DOE-.obs'rvations, agreements and open items requiring further interactions.
e Summary meeting notes are prepared and signed before the close of the meeting.
Typed copies are then distributed to the DCC, the PDR, NRC and DOE staff and other interested groups.
The meeting summaries provide DOE with timely feedback on NRC staff concerns and focus NRC staff analyses on recent data and interpretations from DOE siting investigations.
NRC-Technical-Letters - Technical lett'ers provide a timely format to document generic or site specific issues and quickly bring these issues to the attention
~
of DOE.
Technical letters on such subjects as shaft construction and sealing may be appropriate when a concern is identified by the staff.
They provide an
',s cuportunity to initiate interaction with the DOE to clarify licensing S:einformattori-lneeds in advance of, the more comprehensive staff analyses.
These f y tech'Qcal let.ters will be distributed to DOE and the PDR.
4...
71nformal' Contractor Reports - Ir. formal contractor reports document contractor N
observaticus resulting from trips, such as NRC/ DOE workshops, professional society meetings or other technical matings,-or technical reviews of DOE
.doedments' or other technical reports.
These reports are initiated by request of the staff for a~ contractor to participate in a meeting, to review a documsnt, or to-document a technical concern identified by the staff or its contractor..These' reports can be used to support staff analyses that are docurrentsd in formal reports, technica! positions, and meeting summaries.
The informal reports,will be routinely placed in the PDR.
Contractor trip reports documenting observations 'o'n1r10E/NRC technical meetings will be forwarded to DOE with DOE /NRC Meeting Summaries. Other informal contractor reports will be transmitted to DOE with a cover letter or as supporting material to an STP if they document si iificant technical concerns or guidance.
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.The responsibility of WMHT, WMHL and WMPI line management (section leaders and branch
'. chiefs) for-assuring the-technical adequacy of evaluations remains unchanged
- (Figure 2).
Their review of products - in addition to reviews performed by group coordinators and the PM provides the mechanism for the line managers to discharge their responsibilities.
In most cases,'the section leaders will be i
the1 group coordinators.
'For-review purposes, the content of the SCP is considered to be embraced within six review topics.
Each member of the review team is assigned to one or more j
topic review aroups (Figure 3).
These are:
~1.
Technical Integration 2.
Geochemistry 3.
Materials Sciences 4.
~ Geology / Geophysics:
5.
Hydrology 6.
Facility Design /Geoengineering 5.1.3 Project Team Responsibilities
' 5.1. 3.1 Technical Integration Group
~
The following are responsibilities applicable to the Technical Integration Group:
Integration of technical assessment groups in all licensing assessments, o
including determination of-compliance with numerical performance objec-4 tives.
Integrates assessment group establishment of licensing information requirements.for such assessments.
' Containment - Waste Package Lifetime
~
Release.-EngineeredBarferSystem
~*
EPA Standard - Release to Accessible Environment 0thers - e.g.', Favorable and Adverse. Conditions, Radiation Exposures, Retrievability, Sealing h
o Integration group directs staff efforts in ongoing, overall. system and component performance sensitivity studies.
- o Produces performance assessment chapter and related technical sections (e.g., NUREG-0960, Appendix C) of SCA's.
5.1.3.2 Technical Assessment Groups
.The following are general responsibilities applicable to each technical assessment group.:
Each group has responsibility for independent assessment of.
L those aspects of HLW repository performance related to the group's area of L
technical responsibility / capability.
Assessment Methodology (quantitative and qualititative methods and models) o
-appropriate for area of technical responsibility / capability.
83/08/15 20 STANDARD REVIEW PLAN 1
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.o Identification of licensing information needs in terms of assessment methods on an ongoing basis.
Identification of specific data gathering strategies and methods on an o
ongoing basis.
Ongoing review of data and data gathering methods to establish o
uncertainties and limitatic,u in data base in its area of technical responsibility.
I Direct sensitivity studies of processes in area of. technical o
responsibility,.as appropriate, on an ongoing basis to establish relative importance of uncertainties and limitations.
i o
Computer code and other computational aspects.of licensing assessments and pre-licensing sensitivity studies in area of the groups responsibility /
capability.
o Develop and contribute to licensing products in area of technical l
responsibility / capability.
i-SCA Chapters Site Technical Positions lg Generic Technical Positions Inputs to Regulations, Review Plans Interface with technical-integration groups and other technical assessment o
groups responsible for understanding (at a broad level) the full suite e
of issues involved in complete assessment of overall system and component' performance in order to establish what specific technical responsibilities of groups are and thus assure complete, well integrated, non-duplicative j-HLW staff assessments.
5.1.3.2.1 Geochemistry Chemistry 'of earth materials through time o
Solubility and sorption o
. Chemical environment
'o Mineral stability o
Hydrochemistry 5.1.3.2.2 Materials Sciences Chemical and physical properties of metal and solid waste form materials through time.
o.
. Corrosion o
Leaching o
Physical stability 4
83/08/15 21 STANDARD REVIEW PLAN i
o
-,.e
4 5.1.3.2.3 Geology / Geophysics Geologic framework and its stability through time.
Stratigraphy / structural geology o
Tectonics / seismicity o
5.1.3.2.4 Hydrology Groundwater movement through time.
Hydraulic conditions (e.g., heads, conductivity) o o
Flow paths and directions 5.1.3.2.5 Facility Design /Geoengineering Practical aspects of underground facility design, construction, operation and testing.
Rock properties and conditions related to rock deformation through time.
o Facility design and construction Waste handling and emplacement operations o
Installation and mechanical properties of engineered barrier materials o
Operating environment and feasibility of underground operations, including o
retrievability and testing Lead within the division for quality assurance (QA) o o
QA program reviews o
Rock stress / strain o
Rock strength l
o Stability of openings l
5.1.4 Special Multi-Disciplinary Problem Areas l
There are a number of special interdisciplinary problems areas that will best be handled by having selected staff members in technical assessment groups give assistance to the technical integration group in coordinating staff efforts.
While the organization provides by its fundamental structure for integration of staff in assessing performance of the repository and its components, there are some areas that are taken together and considered on special bases due to a i
number of circumstances:
(a) uniqueness or difficulty of the problem involved, (b) inapplicability of conventional technology or practices or (c) a requirement for nearly equal contributions from several disciplines.
Some of the major examples and some possibilities for technical groups which'could appropriately be selected for assistance in integration are:
83/08/15 22 STANDARD REVIEW PLAN
. ~...
_ ~.
Problem Area Assisting Group Underground Testing Mining, Geoengineering
& Facility Design Thermal-Hydrological-Mechanical-Chemical Mining, Geoengineering Interactions
& Facility Design Sealing of Boreholes & Shafts Mining, Geoengineering
& Facility Design Monitoring & Testing Instrumentation Mining, Geoengineering
& Facility Design Performance Confirmation Program Materials Sciences Exploratory Shaft Construction Mining, Geoengineering and Testing
& Facility Design Computer Codes and Hydrology Computation 5.2 Steps in SCP Review and Analysis i
5.2.1 General Preparation The activities described herein are mainly those to be undertaken by the NRC, its contractors and consultants.
These activities depend heavily on an active exchange of information between DOE, NRC and various contractors..The inter-actions with DOE have a dual purpose: (1) to enable the NRC staff and its contractors to stay current with respect to the status of DOE's investigations
.and (2) to consult on matters concerning the resolution of potential licensing issues. They include site visits, topical discussions and programmatic discussions, all of which represent'a thorough technical interchange to facilitate the review process.
In addition, discussions on matters related to the site investigations are expected to be held with a wide range of non-DOE groups, such as the U.S. Geological Survey, U. S. Bureau of Mines, U.S. Army Corps of Engineers, state groups, Indian tribal groups, citizen organizations, and the National Academy of Sciences.
These activities are essential parts of this review plan even though they are, of necessity, somewhat ad-hoc in nature l
and cannot be specifically defined or enumerated.
In fact, it is only because l-of these activities that it will be'possible to complete a review of the SCP I
and prepare an SCA rapidly.
Another staff activity in preparation for a timely SCP review is routine review of technical reports, as they are received by the NRC staff.
Such reviews provide a partial basis for identification of site issues *, which are the basic Af "
l M
/
u m
V A site issue is a question about a site or design that is so.i4.i.sa,1 to determination of site suitability and adequacy of repository design at the construction authorization stage.
All site issues will be linked to performance objectives and requirements of 10 CFR 60; they will not be merely a function of degree of controversy.
83/08/15 23 STANDARD REVIEW PLAN
.. = -- -
w units for the SCP review and analysis.
Upon completion of each such review, a l
Document Review Summary.is written by the staff review.
The standard procedure for document reviews and the standard outline for Document Review Summaries are specified in Appendix C.
A catalogued collection of the reports that are pertinent to each project is housed in the Document Control Center.
5.2.2 Specific Steps In preparation for the SCP review, a review team is named and a Project Manager (PM) is selected.
Most of these individuals are members of the NRC's High-Level Waste Technical Development Branch (WMHT) and the High-Level Waste Licnesing Management Branch (WMHL).
The SCP analysis involves two main activities:
1.0 Pre-SCP Review Activities 2.0 Preparation of Draft SCA The general sequence of major steps for each of the two main activities is described in the following narrative.
Figures 4 thru 7 show in more detail the organization of the review and the milestones and approximate schedule for each review activity.
Note that some products will be produced and reviewed in parallel.
Pre-SCP Review Activities 1.1 GC in consultation with appropriate section leaders designates responsible reviewers for pre-SCP activities.
1.2 PM and GC in consultation with appropriate section leaders establish schedules and priorities for pre-SCP review activities.
1.3 Under direction of the GC each topic review group prepares a draft STP that identifies site issues to be handled by the group (umbrella STP).
Site issues will be identified mainly from trip reports, project reviews
/M performed by staff and others, and other dvaments already in hand.
After \\
~
review by the GC, PM, and appropriate section leaders, the draft umbrella STP is distributed to the DOE project. At an early time a systematic and comprehensive review of site issues will be tabulated and categorized for tracking purposes.
1.4 Using the draft umbrella STP as a basis, the PM and GC in consultation b
with the DOE project prepares a technical workshop agenda.
1.5 The topic review group participates in and documents the workshop proceedings.
The workshop summary is signed by the PM and the lead representative of the DOE project and is placed in the PDR.
1.6 Based on information obtained at the workshop and under the direction of the GC, a final umbrella STP is prepared. After review by the GC, PM, section leaders as appropriate, and appropriate branch chiefs, the STP is transmitted to the DOE project by the PM.
Upon completion of all umbrella STP's pertaining to a project, the technical integration group prepares the "boilerplate" for Appendix C to the SCA.
83/08/15 24 STANDARD REVIEW PLAN
.~
1.7 The GC, in consultation with appropriate section leaders, and the PM selects and schedules topics, pertaining to the site issues, to be addressed in additional STPs.
Selection is based on the criteria shown in Table 1.
The selection process is documented under the direction of the GC.
1.8 Under the direction of the GC, complete additional STPs.
After review by the GC, PM, section leaders as appropriate, and appropriate branch chiefs, the PM transmits the STP to the DOE project.
Preparation of SCA
[ Note: Throughout preparation of the SCA, NRC staff will have discussions with DOE, NRC consultants, States and other groups largely for clarification of questions on information contained in the SCP.
These communications will be on an informal, " rapid-turnaround, not-to-interfere-with-schedule" basis.]
2.1 Upon receipt of the SCP, each GC (a) provides each reviewer with the SCP and (b) identifies the portions of the SCP review for which each reviewer is responsible.
2.2 Under direction of GCs topic review groups prepare detailed comments on the SCP for incorporation into Appendix B tc the SCA by the PM.
GCs deliver comment to PM.
2.3 Under direction of GCs, topic review groups prepare a Key Issue Point Paper (KIPP)* for each issue that the group proposes to develop in the SCA Chapters.
GC delivers KIPPs to the PM who then distributes the complete set to all topic review groups.
2.4 PM and GCs meet to review KIPP and agree on issues to be developed in SCA Chapters.
2.5 Under direction of GCs, topic review groups revise KIPPs in response to meeting comments and incorporate KIPPs into rough " key-word" drafts ** of SCA Chapters. GC delivers draft to the PM.
2.6 PM integrates drafts of SCA chapters into rough key-word draft of SCA (Draft #1).
2.7 Draft #1 is reviewed by GCs, PM, section leaders, and WMHT and WMHL branch chiefs.
Comments are delivered to FM for distribution to cognizant GCs.
2.8 PM and GCs brief Division and Officer Directors (WM and NMSS).
A succinct set of " bullets" that summarizes the staffs analysis of a key issue.
KIPPs are an intermediate product used only in developing the first draft SCA.
Draft in the form of " bullets".
83/08/15 25 STANDARD REVIEW PLAN
m 2.9 Under direction of GCs, topic review groups prepare Draft #2 chapters by
" fleshing-out" Draft #1 chapters and resolving review comments.
GC deliveri Draft #2 chapters to the PM.
2.10 Technical integration GC delivers draft of Appendix C to PM. All GCs deliver drafts of SCA Appendices to PM.
2.11 PM integrates drafts of SCA Chapters and Appendices into Draft #2.
2.12 SCA Draft #2 is reviewed by GCs, PM, section leaders, and branch chiefs.
Comments are delivered to PM for distribution to cognizant GC.
2.13 Under direction of GCs, topic review groups revise Draft #2 chapters and appendices.
GC delivers revised products to PM.
2.14 PM integrates revised drafts of SCA chapters and appendices into Draft #3.
2.15 SCA Draft #3 is reviewed (revised into Draft #4) by DWM.
2.16 SCA Draft #4 is reviewed (revised) by NMSS, ELD, RES, and other NRC offices as appropriate.
[ Review by other NRC offices will be selective.]
2.17 NRC staff finalizes SCA Draft,#4 for publication.
2.18 SCA is published M w%
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83/08/15 26 STANDARD REVIEW PLAN
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Technical:
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. High degree of importance to performance and Unique problem (not resolvable by conventional methods) o-or Controversial technical area (significant disagreement within technical o
community)
I or o
Rosolution requires lona lead-time Management:
'o Competing demands on staff time 4
Table 1.
Criteria for selection of specific topics for additional STPs 83/08/15 27 STANDARD REVIEW PLAN
Figure 1 SYJTEMAKZC e.T764Q7%Mr Meccts ESTABLISH I
PRESENT UNDERSTANDING 1 r J
IDENTIFY 2
PERFORMANCE IS, SUES 1 r i r E
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ASSESSMENT SENSITIVITY REQUIREMENTS g
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PLANS ANC PROCEDURES
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83/08/15 29 STANDARD REVIEW PLAN W -
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83/08/15 32 STANDARD REVIEW PLAN
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STANDARD REVIEW PLAN
i FIGUR' 7 SCA PRODUCTS - INTERGRATED SEQUENCE AND SCHEDULE ** -
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83/08/15 34 STANDARD RFVTFW PIAN
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e APPENDIX A ESTABLISHING LICENSING INFORMATION NEEDS
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ESTABLISHING LICENSING INFORMATION NEEDS k'
1.
Nature of the Problem N
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NRC regulations base the licensing of HLW repositories on an assessment of y
overall repository performance.
Establishing information needs to predict A
performance of any complex, technical system involving a large number of components and application of many different technical disciplines is difficult.
Doing so involves implicit decisions about what are acceptable
's
/
7 levels of uncertainty and consequently about the allocation of available Q#
L resources to the individual areas of repository performance within the overall f
system.
Such decisions are difficult at best, particularly so when the 0
information about the system is only slowly developing.
Specifically, these decisions are complicated when the basic constitutive relationships which link performance of the system components to each other and to the overall system are so imperfectly known or not known at all as they are in the beginning.
The number of parameters, their interactions and the scope of investigations that might be needed to understand precisely the performance of the complex repository system is potentially staggering.
Literally, hundreds of parameters t
and thousands of data points can be identified as determining the performance of a repository system. When each of the potentially soluble forms of radio-nuclides in the waste package are considered, under the full range of geologic, hydrologic, and chemical conditions that will exist over long periods of time l-in the waste package, near and far-field, it is obvious that the number of
(
specific tests that might, on a first cut at the problem, be proposed is likely to be greater than could ever be done in a reasonable time, and more than needed to determine repository performance with confidence. This is true in the near-field of waste package where radiation, high temperatures and temperature gradiants will add to the complexity.
It is also true in the natural systems which are inherently highly complex and variable. It is clear L
that a program of enormous dimensions could be envisioned to completely
' characterize and understand the large volume of the natural system surrounding l
l a geologic repository.
To some extent, judgement and experience can lead inarguably to identification of the mors important components and the specific parameters which must be L
measured to obtain at least a general understanding of system component b
performance.
For example, groundwater flow is clearly the primary natural I
process that will be involved with radionuclide transport.
Furthermore, to e
understand the groundwater flow system around the repository, hydraulic conduc-l tivity and groundwater pressure gradients must be determined.
However, the I
next and more difficult question is "how many specific measurements are needed or are enough?" To answer this question, decisions must be made about the l
relative contribution to repository performance that might be expected of various aspccts of respository system performance and in turn, the allocation l
of limited resources to investigations of each aspect. Such decisions are l
highly site-specific and are a large part of the essential business of site characterization.
l-The complexity and vast dimensions of this problem, establishing minimum i
information needs and quality contrasts sharply with the existing, practical constraints.
Public health and safety is the ultimate concern.
However the o
83/08/15 2
SRP APP A 1
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real world constraints including limited resources, tight schedules established by public law and limits of technology cannot be ignored; they add a further load to theTalr'ady burdensome problem.
e Clearly, the above problem must be resolved before licensing in order to support a finding of reasonable assurance that there is com fance with the performance objectives of 10 CFR 60.
The problem is a prac' tal one demanding a solution so that the limited resources and time available to them during the site characterization period can be most effectively used. A solution is also needed so that the NRC staff can give proper and effective guidance to DOE, as well as directing its own internal activities including supporting research programs.
2.
Alternative Approaches j
The NRC staff considered two approaches to resolving the problem of estab-lishing licensing information needs.
The first is a prescriptive approach, and the second a systematic, iterative approach.
2.1 Prescriptive Approach The prescriptive approach involves the NRC staff specifying, before Nite char-acterization, how much of what type of information is needed and the level of acceptable uncertainty (reliability) that must be achieved in the measurements.
Then, the DOE investigators would be free to select the methods of measurement and analysis.
There are two basic ways to implement the prescriptive approach.
One, which has great intellectual appeal, involves deriving from overall system perfor-mance requirements, individual component and subcomponent performance require-f ments.
This would be the way to establish, in turn, required levels of uncertainty that must be obtained in measurements and ultimately the types and
' amounts of information needed.
The second way to implement this approach would be one of arbitrarily prescribing required uncertainty levels that must be achieved in system component performance and parameter measurements.
l In theory the advantage of the prescriptive approach is that it would give DOE investigators freedom to select the methods of data collection and analysis and determine the amount of informaticn needed by giving them a fixed, unambiguous l
target for their investigations and reducing uncertainty about regulatory
-requirements. While the objectives of this approach are ideal, it is, unfor-tunately, the NRC staff's experience that they cannot be achieved.
In reality, prescription by the NRC staff on the one hand, if arbitrarily made would be unduly constraining, contradict the approach taken in 10 CFR 60 and be technically indefensible and on the other hand, if attempted by derivation from overall system performance, would simply not be possible for such a complex, first-of-a kind,isitte-dependent program as licensing a geologic repository.
In early m\\r44Wof 10 CFR 60, NRC proposed several numerical performance m um, objectives;.however, there was concern that these numerical performance objectives would prevent DOE from being able to allocate performance to subsystem components on a site-specific basis.
In recognition of the need for such flexibility the final rule was revised to clarify that the numerical 83/08/15 3
SRP APP A s.
~
performance objectives would be applied in a flexible manner.
There is diversity in the potential sites presently being investigated by DOE as well as in potential, future siting areas.
In order to take full advantage of the unique attributes of a site as well as to compensate for a site's weaknesses, DOE will need flexibility to develop designs and plan its site characterization program.
Such flexibility would not exist with an arbitrary prescriptive approach.
For example, an arbitrary prescriptive approach would not allow providing less reliability in a waste package at a site, having demonstrable and highly favorable site features, than in a waste package at a site with poorer or less certain site features.
Because site features will be different at each site, it would be unduly constraining and technically unsupportable for NRC to establish highly prescriptive reliability requirements on a generic basis before site characterization.
Also it would not make sense as a matter of practical policy to arbitrarily establish requirements because the tradeoffs to be made at one site between subsystem components involve complex questions which potentially addros far more than just matters of public health and safety.
Program resources and schedules must also be considered.
For example, the NWPA limits the time period for site characterization before a selection on one site is made. The applicant rather than the regulator should take the lead on these tradeoffs.
The regulator only has responsibility for assuring that the safety standards are met.
With respect to a derivative, prescriptive approach, one that would. rigorously derive and prescribe meaningful, quantitative performance requirements, it is simply not practical before site characterization. This is due to the combina-tion of an initially high level of uncertainty in both site information and understanding of constitutive relationships between system components together with the lack of finely developed site-specific performance assessment methods.
+
For example, as documented in the NRC staff analysis of the BWIP SCR the
, uncertainty in such a fundamental indication of site performance as groundwater l
travel time ranges over nearly six orders of magnitude.
The minimum travel times are on the order of several tens of years (i.e., far less time than needed for the waste to decay to innocuous levels) to a million years.
Finally, it is literally impossible to specify in advance how many tests will be necessary due to the exploratory nature of the program. What tests will be finally required, depends on the results of the testing itself:
if the initial tests results are spread over a wide range of values (high uncertainty), a large amount of testing may be needed to narrow the range; on the other hand, if the early tests tend to cluster around a single value, few, if any, additional tests may be needed.*
One example to illustrate the above point involves a single test for effective porosity with a result that is between.01% and.0001%.
Effective porosity is What is an allowable level of uncertainty for such testing and in turn how much more testing is needed is dependent on what is the level of uncertainty in other parts of the system.
83/08/15 4
SRP APP A
t directly proportional to groundwater travel time, which is an important element in repository performance.
The above range of effective porosity values would mean a two order of magnitude range of calculated groundwater travel times (e.g., 10,000 to 100 years).
How much more testing will be needed? The general answer is that enough testing needs to be done to permit a reasonable estimation of groundwater travel time; however, no one can answer now the question as to how many more tests will be needed.
That will depend on the range of values in the next few tests and the degree of precision that can be obtained in the test methods.
Also, how much testing will be necessary to understand a particular site I
feature depends on a number of matters.
- 1) The precision of available testing J
methods is important:
the less precise the method, the more tests are needed.
- 2) The relative significance of the feature in repository performance must be taken into account: more needs to be known about features that are critical to i
performance than about features that are less critical.
s The above discussions clearly describe why prescription of how much information is needed for licensing before site characterization begins is not possible and must inevitably fail. This failure will likely become the focus of much t
attention and energy which would detract from ongoing constructive investiga-tions. Also, such apparent misdirection and readjustment of program require-ments would adversely effect public confidence in the program.
In summary, the prescriptive approach is inappropriate for the following
- 1) needed program flexibility is denied; 2) requirements based on high reasons:
4 degress of uncertainty are not meaningful; and 3) such an approach will inevitably confuse licensing, distract from the resolution of the real tech-nical issues and might destroy the public's confidence in the decision making process.
(
, 2. 2 Systematic, Iterative Approach l
L Fortunately, this does not mean that there is no rational basis upon which to settle the problem of establishing how many of what type of test are needed and enough. There is a rational process for establishing what information is l
required for licensing or put in other words, what must be accomplished in the L
site characterization program.
This process is based on the derivative, prescriptive approach described above and includes the modifications needed to make it practicable.
It is a systematic, iterative approach that is described l.
in the SCA for the Hanford Site (NUREG-0960).
2.2.1 General Characteristics l
The principal characteristics of this systematic, iterative approach are:
l 1.
At each site DOE will take the lead in identifying the specific infor-l mation that will be required to assess performance of the repository system. This is consistent with its role in the repository development and licensing process. The metr: approach _ ~ -edopted by 10 CFR 60j ;;ivo
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i DOE the flexibility and attendant responsibility.to dahaamue what each I
repository-cn=nanan+ "_ contribute to overall performance.
Such pW
.t:-int'r: -+ 5: ni before licensing information needs can be
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DOE will have generated the data base upon which W"
l 83/08/15 5
SRP APP A
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uncertainties including data gaps will be identified. Also, DOE has the responsibility for d2veloping the conceptual repository designs including waste containment systems, upon which the identification of information needs must also rest.
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2.
Without a large data base to support rigorous assessments, there is still
.a sound basis for identifying information needs sufficiently well to begin a program of investigations. The basis upon which information needs are identified is the identification of the performance assessment methods that will be used to determine compliance of the repository system of natural and engineered barriers with 10 CFR 60 requirements.
Specific data needs can be identified from consideration of the performance assessment methods, including scenarios and associated conceptual and mathematical models that will be used; the simplifying assumptions underlying the methods; and the needed input parameters to such models.
By considering specific assessment methods in a systematic way (e.g.,
using decision tree analysis) together with some limited quantitative sensitivity studies and expert judgement, the relative importance of information needs can be established.
3.
The precision with which information needs are identified and limited resources allc.cated among competing demands will increase with time.
First, the constitutive relationships that link performance of various 3
components of the system to each other and to the overall system perfor-mance are better understood as investigations proceed.
Second, the knowledge of the parameters required by applying the various constitutive models become better known.
The identification of information needs must, therefore, be altered with time as investigations proceed.
4.
Quantitative sensitivity studies must be attempted from the beginning in identifying information needs. These should be performed at several different levels:
at the overall system level as well as at the level of individual system components, or at a level which evaluates selected important aspects of the problem such as groundwater flow. These studies should allow for the full range of uncertainties existing with respect to each parameter and in the models themselves.
i Given the large uncertainties at the beginning of investigations about the l
basic constitutive models linking system components, efforts to do overall I
system performance sensitivity analyses may likely be impracticable.
Nevertheless, continuing to attempt them will force a strong focus on areas of greatest uncertainty.
Eventually, an overall performance assessment will be required in licensing.
Starting early to attempt doing them and continuing such efforts is essential despite early " failures".
5.
NRC!s role in this process is one of conducting many selective and inde-pendent assessments concurrently with DOE following the process described below.
Initially, this will involve qualitative analyses and expert judgement to identify important issues (See Appendix C, BWIP SCA), release scenarios, and various conceptual models.
Some selective mathematical and numerical models will be selected and used in various sensitivity studies.
Using this knowledge, information needs and data collection and analysis methods and procedures will be selectively and independently evaluated.
83/08/15 6
SRP APP A e
~
2.2.2 Specific Characteristics The elements of-the staff's systematic, iterative approach and their interactions are shown in the simplified logic diagram in Figure 1.
This sequence of elements is flexible.
The initial element (1) in the systematic, iterative process is one of establishing the present level of understanding about the site.
This is i-followed by (2) the identification of the performance issues which eventually must be addressed to determine whether the site and the engineered system will comply with NRC regulations.
These issues are the basis for (3) the development of specific assessment methods, including conceptual, mathematical, and numerical models. -Inputs and assumptions to these models help determine the information needs that must be addressed during site characterization.
Of all the steps in the systematic, iterative process, (4) sensitivity studies are perhaps the critical element since they can be conducted at several levels using a variety of methods to determine what are the essential information gaps.
In some areas, it is also necessary for DOE to (5) establish initial (preliminary) component requirements in parallel with the development of assessment methods and sensitivity studies.
These requirements should evolve along with the program and may be adjusted as the whole process is repeated when new information or methods are developed.
The nature of many of these requirements can be inferred directly from the performance issues, and, once they have been established, they also make an essential contribution to identi-fying information needs. Acceptable levels of uncertainty that directly affect the amount and quality of data needed are also established here.
Finally, this is the element in which relative component performance contributions
-(trade-offs) are adjusted to compensate for uncertainties in various components.
. Elements (1) to (5) all contribute to (6) identifying information needs.
Once these needs have been identified, (7) the establishment of test plans and procedures follows directly, and forms the basis for (8) generating data and determining the uncertainties associated with them. These data and l
uncertainties can be then used to upgrade the sensitivity studies and the L'
nature is an evolving, iterative one.
It must start with the use of assessment methods and refine the component requirements. The process by its substantial judgment, relatively simple models, and sparse data. As more data are gathered, the process can be iterated at progressively more refined levels
'until an acceptable level of uncertainty is reached and (9) findings made.
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83/08/15 7
SRP APP A l
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i Figure 1 S Vs rE n n i.r c,.T 7 64 M r% W Moccts ESTABLISH I
PRESENT UNDERSTANDING I
3 r IDENTIFY 2
PERFORMANCE ISSUES
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ESTABLISH DEVELOP 3
PERFORM SYSTErk COMPONENT 9
ASSESSMENT SENSITIVITY REQUIREMENTS l
METHODS 9
STUDIES I
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1 r IDENTIFY 2
INFORMATION NEEDS i
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ESTABLISH TEST 7
PLANS AND
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AND DETERMINE UNCERTAINTIES 1 r REACH
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83/08/15 8
STANDARD REVIEW PLAN
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APPENDIX B STANDARD OUTLINES AND REVIEW QUESTIONS FOR SCP REVIEW PRODUCTS Outline for Site Characterization Analysis.......................
B-1 Outline for SCA Chapters 3-10....................................
B-2 Review Questions for SCA Chapters 3-10...........................
B-3 Outline for Site Technical Positions.............................
B-4 Review Questions for Site Technical Positions....................
B-5 Outline for Generic Technical Positions..........................
B-6 Outline for Workshop - Meeting Minutes...........................
B-7 Outline for Key Issue Point Papers...............................
B-8 83/08/15 2
SRP APP B
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0UTLINE FOR SITE CHARA'CTERIZATION ANALYSIS (SCA)
CONTENTS Page
_s AB ST RACT.....................'......... c............................... iii ACRONYMS AND INITIAILSMS..............................................
vif s
EXPUtNATION OF FREQUENTLY USED TERMS...'...............................
ix SUMARY AND CONCLUSIONS...............................................
xi CHAPTER 1 INTRODUCTION........'...................................
1-1 CHAPTER 2 DESCRIPTION OF SITE AND PROPOSED FACILITIES............
2-1
^
CHAPTER 3 GROUN0 VATER...:......................................
. 1-CHAPTER 4 GE0 LOGY................,,.............
4-1 CHAPTER 5 -
GEOCHEMISTRY...........................................
5-1 CHAPTER 6 REPOSITORY DESIGN......................................
6-1
' CHAPTER 7 WASTE FORM / WASTE PACKAGE................'...............
7-1 CHAPTER 8 SITE SELECTI,0N AND ENVIRONMENTAL FXCT6RS...............
' 8;1W,
w CHAPTER 9 PERFORMANCE ASSESSMENT.................................
9-1 s
CHAPTER 10 QUALITY ASSURANCE PROGRAM..............................
10-1 CHAPTER 11 e SUMARY 0F NRC C0MMENTS................................
11-1 APPENDIX A MAPS AND SECTIONS OF THE PROPOSED SITE.................
A-1 APPENDIX B SPECIFIC CO MENTS ON THE SCP...........................
B-1 APPENDIX C ISSUES IDENTIFIED BY NRC, ISSUE RATINGS, AND CORRELATION WITH DOE ISSUES............................
C-1 ADDITIONAL
'0EVELOPED AS NECESSARY TO SUPFORT ANALYSES IN CHAPTERS APPENDICES 3 THROUGH 11
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SRP APP 4.'
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SCA CHAPTERS 3-10 FOR OUTLINE
.1 Introduction
-1.1 Types of Material Presented in the SCP
-1.2.Re. levant Sections of Proposed 10CFR60
-.2 Background (Principal Issues in SCP)
Potential licensing issues identified in the SCP
.3 Analysis of Issues NRC criticisms / concerns / comments about the adequacy of the SCP characterization of issue status
-3.1 Relationships Among Issues
- Has DOE identified adequately the potential licensing issues in the SCP?
N S
-3.2 Issue A o-:
-s
-3.3 Issue B 4
-3.4 Issue C
- 4 Analysis of the Site Characterization Plans NRC's. criticism of the adequacy of DOE plans for obtaining the information needed to resolve the issues.
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-4.1 Issue A
' -4.2 Issue B
-4.3 Issue C
.5 NRC Comments and Conclusions
, Clear summary of the criticisms in the previous sections p
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83/08/15' 4 4
SRP APP 8 O
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l REVIEW QUESTIONS FOR SCA CHAPTERS 3-10
.1 Introduction '
s What ty~p'es of materlal are presented in the SCP?
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What are the relevant sections for 10 CFR 607 f
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'- 2 Background (Principal Issues in the SCP) t s
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,fhat are the potential licensing issues presented in the SCP?
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'.3. Analysis of Issue {
1 ob Has DOE adecuately identified the potential licensing issues in the J
'SCP?
What are the NRC criticisms / concerns / comments about the adequacy of a.
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the SCP characterization of issue status?
o Are NRC concerns c1carly defined?
What counterarguments' may be raised by DOE?
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o Have all significant problems in the SCP been covered in the NRC analysis?
.c o
Are uncertainties adequately characterized in the SCP?
.4 Analysis of the Site Characterization Plans o
What/are the NRC's criticisms of the adequacy of the plans'for obtaining the information needed to resolve the issues?
o Where are DOE programs deficient?
o What are the minimum steps that should be taken by DOE to resolve the deficiency?
o What 'specifically does the NRC want?
l
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o Are proposed schedules, including logic and sequencing diagrams, realistic?
.5 NRC Comments and Conclusions o
Are the NRC conclusions and comments clearly stated?
o Have the conclusions and comments been coordinated with other
. technical areas?
J hl3/08/15 5
SRP APP B
~
OUTLINE FOR SITE TECHNICAL POSITION (STP)
Title:
Includes Topic Addressed and an Identifying Number (Number Soquentially by Site)
Backaround:
Clear Statement of Scope of the position.
Discussion of Issue including its Relationship to 10 CFR Part 60 and the Need for a Timely Staff Position.
Technical Position:
Statement of the Staff's Position.
piscussion:
Discussion of the technical basis for the Position.
References:
As necessary to support the Position.
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83/08/15 6
SRP APP B
t,_..
T REVIEW QUESTIONS FOR STPs BACKGROUND o
What is the issue?
What is the importance of the issue to repository performance?
o o
How does the issue relate to 10 CFR 60?
o Why is a staff position needed now?
TECHNICAL POSITION (At least one of the following questions should be answered)
What approaches to testing, test methods, investigations or data o
analysis are adequate to provide the information needed to resolve the issue for licensing?
o What additional information, testing, or data collection is needed to resolve the issue?
DISCUSSION o
What is the technical basis for the position?~
o What is the current state of knowledge of this issue?
o What uncertainties are associated with the issue?
l i
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83/08/15' 7
SRP APP B
T o
7 OUTLINE FOR GENERIC TECHNICAL POSITION (GTP)
Executive Summary
- 1. 0 Introduction
$ Y;p _
1.1 Background
NWPA of 1982/NRC Role Purpose and Scope of GTP J2 Position f
1.2 Regulatory Framework EPA /NRC/ DOE Roles Relationship of GTP to licensing decisions Relationship to 10 CFR 60 2.0 Area of Concern 2.1 Statement of Concern 2.2 Discussion
- 2. 3
Conclusion:
Guidance to DOE 3.0 Area of Concern 3.1 Statement of Concern 3.2 Discussion 4
3.3
Conclusions:
Guidance to DOE 4.0 Summary i
4.1 Summary of Concerns 4.2 Technical Position:
Summarize Guidance to DOE l
References Appendices as necessary to support GTP.
i i
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83/08/15 8
SRP APP B l
WORKSHOP MEETING MINUTES BACKGROUND / FACTS 1.
What information was reviewed, exchanged and discussed (Summary listing fashion) 2.
What agenda of discussion was OBSERVATIONS 1.
NRC questions, suggestion or comments on scope and direction of DOE technical program.
(Best attempt made to identify all important matters) 2.
DOE observations AGREEMENTS OPEN ITEMS 1.
Technical questions for further discussion 2.
Specific responsibilities for information exchange and commitment on other business matter fl
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SRP APP B
- s OUTLINE FOR KEY ISSUE POINTS PAPER t
1.
Statement of Issue j
What is the subject of the disagreement?
o 2.
What is the significance of the issue?
How sensitive is repository performance to the substance of the o
disagreement?
3.
Statement of DOE's Position o
What is the positon?
What is the technical basis for the position?
o 4.
Why Does the Staff Disagree?
5 What is the staff's technical basis for disagreement with DOE?
o 5.
What does the staff recommend?
83/08/15 10 SRP APP B
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s APPENDIX C
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ROUTINE DOCUMENT REVIEWS t
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ROUTINE DOCUMENT REVIEWS All documents received from the various DOE projects are screened by the appropriate Branch Chief to determine their applicability to the HLW Management Program.
Each document is logged in the Branch Log and circulated to the staff for their information when no staff review is required.
If technical review is required, then the document is routed through the appropriate project manager for his information to the appropriate section leader.
The designated section leader in conjunction with tne appropriate group coordinator assigns a technical review to a staff member or contractor with an agreed on completion date.
The scope and effort of the review depends on the importance or signifi-cance of the document.
Questions about scope, including the involvement of other staff in the review, are sssessed by the section leader and/or branch chief. The Document Review Sheet shown in Figure 1 may be used in many cases to document the review.
While many documents are not assigned for formal review, it is incumbent upon the staff to identify information in these documents which is important to the HLW program.
The staff should be careful to identify documents requiring review which were not originally recognized as such.
4 I
83/08/15 2
SRP APP C
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9 WMHT DOCUMENT REVIEW SHEET v
FILE:
3001.5/
DOCUMENT:
REVIEWER:
DATE REVIEW COMPLETE :
BRIEF
SUMMARY
OF DOCUMENTS:
DATE APPROVED:
SIGNIFICANCE TO NRC WASTE MANAGEMENT PROGRAM:
e i
' ACTION TAKEN:
FOLLOW-UP ACTIVITY:
4 (Figure 1: Standard form for reviews of technical reports) 83/08/15 3
SRP APP C
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