ML20040H258

Review Plan for Site Characterization Rept

ML20040H258
Person / Time
Issue date:	01/29/1982
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20040H256	List: ML20040H255 ML20040H258
References
REF-WM-1 NUDOCS 8202180016
Download: ML20040H258 (30)

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I 3107.1/RU/BB/82/01/21/0/1/0/1 REVIEW PLAN FOR SITE CHARACTERIZATION REPORT 4 i INTRODUCTION OBJECTIVES APPROACH TO REVIEW AND ANALYSIS SITE SELECTION SITE CHARACTERIZATION PROGRAM REVIEW PROCEDURE DEFINITIONS STEPS IN SCR ANALYSIS A. ORGANIZATION OF REVIEW B. DEVELOPMENT OF M0CK SCRA C. PREPARATION OF DRAFT SCRA D. PREPARATION OF FINAL SCRA SCHEDULE OF ACTIVITIES FOR BWIP APPENDIX A - SITE ISSUE ANALYSIS FORM APPENDIX B - TOPICAL OUTLINE OF SCRA t L 1 E e

3107.1/RU/BB/82/01/21/0/1/D/1 INTRODUCTION The purpose of this review plan is to indicate how NRC will review each Site Characterization Report (SCR) submitted by DOE and develop a Site Characterization Report Analysis (SCRA). The SCRA will be a critique and comment on DOE's site selection process and proposed site characterization program. This review plan is developed for use by NRC staff and NRC contractors and consultants who will be directly involved in the SCR review. 'This plan provides a set of procedures developed specifically for the geologic repository program. It will be applied to each site for which DOE intends to submit an SCR. The plan is not intended to be a rigid set of procedures; it will be updated and amended as necessary to reflect unique project-specific conditions and the overall evolution of the repository program. The effective implementation of this review plan depen'ds heavily on obtaining up to date information prior to receipt of the SCR. This will derive from a variety of activities that both precede and are concurrent with each SCR review. These include extensive and continuing interactions with DOE, site visits, topical and programmatic discussions, and other technical interchange among all involved parties. l 9 2

a 3107.1/RU/BB/82/01/21/0/1/0/1 OBJECTIVES Site Characterization The objectives of site characterization (SC) are: 1. 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 required by 10 CFR 60, namely a meaningful analysis of (a) the suitability of the site to isolate radionuclides and (b) the acceptability of the repository design at the site. 2. To collect necessary data from alternative sites and media to permit the NRC to make a National Environmental Policy Acty (NEPA) finding on the site proposed in DOE's license application for construction authorization. Site Characterization Report On February 25, 1981, the Nuclear Regulatory Commission (NRC) promulgated the licensing procedures for the disposal of high-level waste in 10 CFR 60 - " Disposal of High-Level Radioactive Wastes in Geologic Repositories" (46 FR 13971). As part of the pre-licensing procedures set fcrth in the final rule, the Department of Energy (00E) is required to submit a Site Characterization Report (SCR) to the NRC as early as possible after commencement of planning for a particular geologic repository operations area and prior to starting site characterization. Types of information to be provided in the SCR and a uniform format for presenting the information are detailed in the NRC " Standard Format and Content of Site Characterization Reports for High-Level Waste Geologic Repositories." It is anticipated that each SCR will be an extensive document (or set of documents, possibly thousands of pages), covering the many technical and institutional aspects of licensing a high-level waste repository. However, the basic purposes of the SCR are simple: to provide a mechanism for identifying and delimiting the specific issues at a proposed repository site and the-plans for resolving those issues at an early time in order to avoid delays in the licensing process. The SCR, as reflected in the logic sequence and organization of the Standard Format and Content Guide, should accomplish the following: 3

3107.1/RU/BB/82/01/21/0/1/0/1 1. Establish what is known about a site from site exploration activities completed to date, 2. Describe the issues that DOE has identified at a site in light of the results of investigations to date, and 3. Describe the detailed plans to resolve the issues identified. The objectiva of the SCR is to expedite the licensing process by providing a vehicle for early NRC, State Indian Tribal and public input on the data gathering and development work so as to avoid postponing issues to the point where modifications in the program would involve major delays or disruptions in the program. Site Characterization Report Analysis This review plan for the SCR indicates how NRC dill review each SCR - including " advance work" prior to actual receipt of the SCR - and develop A Site Characterization Report Analysis (SCRA) from the Office of the Director of NMSS. Because of the short turnaround timgj(NRC emphasis will be placed on several months) from receipt of the SCR to issuance of the draft SCRA, - " advance work" prior to receipt of the SCR, this advance work will consist of activities such as: developing a preliminary analysis for all issues applicable to the site; developing all technical background work; establishing contact with all necessary DOE staff., DOE contractors, State agencies, and other individuals and organizations who are likely to be involved in the preparation / review of the SCRA; and obtaining and reviewing DOE draft chapters of the SCR. Continuing interaction with DOE and other interested parties is essential to NRC's development of a technically sound and practicable SCRA in.the short time that will be available. i 1' Elapsed time between receipt of the SCR and publication of the SCR is expected to be 8 to 10 months, depending in part on the extent of public comment. 4 (

3107.1/RU/BB/82/01/21/0/1/0/1 1 The NRC analysis of the DOE SCR has two main objectives: 1. To examine information on the alternative sites, and to determine adequacy of the screening process for the geologic mer4um of the site. 2. To review DOE's presentation of the site characterization program, including the identification of unresolved issues and the appropriateness of plans to resolve those issues during the characterization. NRC will look for answers to the following questions: a. Have the important information needs and unresolved issues been identified? b. Does the SCR specifically address these information needs and discuss the program plans to obtain the needed information? c. Are the methods of testing and analysis propased for the planned site characterization program appropriate? d. Have alternative methods of testing and analysis been identified and evaluated, and has an adequate basis been provided for the selection of the methods to be used? e. Will the data to be collected and the reliability of the collection methods and analyses be of adequate quality to support a future construction authorization application? The site characterization program is the most critical section of the SCR. Therefore, the SCR review should be directed primarily towards evaluation of DOE's plan for site character'zation. 'The NRC review should ensure that attention is focused on those aspects of siting, development of waste form and packaging, and of the conceptual design of a repository which require the most effort in the site characterization program. While the SCR must be complete in developing the issues of site characterization, it is important particularly in initial planning phases - that those issues considered critical or most important to licensing be identified and given highest priority in the site characterization plans. j NRC recognizes that the DOE program of site characterization will be a phased process. NRC expects that data included in the SCR may be better defined and more detailed for early phases of site characterization i i I 5

+ 3107.1/RU/BB/82/01/21/0/1/D/1 (e.g., testing in the exploratory shaft) and less detailed for later phases (e.g., testing in an underground facility with two shafts). As-00E finalizes plans for later phases of site characterization, additional data can be submitted to NRC in periodic updates to the SCR, as provided in 10 CFR 60. In any event, the NRC review must encompass all site characterization plans for gathering information needed to conduct the full 10 CFR 60 evaluation of site suitability and acceptability of design that will accompany the license application. These site characterization plans must be addressed by DOE in the SCR for each site and thoroughly' analyzed by NRC in the SCRA. ? O 6

3107.1/RU/BB/82/01/21/0/1/0/1 APPROACH TO REVIEW AND ANALYSIS The NRC review of the SCR will concentrate on (1) technical matters related to site selection and (2) the site characterization program. NRC review of policy, political and other non-technical matters, such as the adequacy of public involvement in the siting process, will be limited. This is expected to be complemented by comments presented by the states on the SCR and SCRA. A full evaluation of these comments will be addressed in the final SCRA. Since DOE is taking the approach of advancing site-spec {yic information to NRC prior to SCR submittal, each NRC topic reviewer - will be responsible for understanding what information may be available from 00E, obtaining it from DOE, and performing a preliminary review of the information as it relates to the SCR to be submitted by DOE. There follows a description of the material expected to be contained within the SCR and a discussion of the objectives in the analysis. Site Selection Type of Material for Review Descriptive material, largely taken from earlier site selection-documents. Many documents may be referenced. As specified in 10 CFR 60, the information will deal with (a) criteria used.in selection, (b) method of selection, (c) identification and location of alternative sites in the same and other media, and (d) the decision process by which the site was chosen for characterization. Nature of Analysis a) Examine selection criteria for validity and completeness. b) Determine reasonableness of site selection method and decision process. 1 For explanation of " topic reviewer" see " Definitions" in following section " Review-Procedure." ~ 7 m

3107.1/RU/88/82/01/21/0/1/D/l c) Examine descriptions of other sites and media for validity as alternatives. Comments Through NRC's site visits and other interactions with DOE the geotechnical basis for site selection will be known in advance of the SCR. (It is.known now for BWIP and NTS). However, there may be institutional, socio-econcmic, and environmental matters which will } require review. Site Characterization Program Type of Material for Review (a) Site conditions: (1) reports which describe existing properties of the site, (2) reports on the interpretation of the geologic history of the site, (3) data summaries such as core logs, and (4) scientific literature relevant to understanding properties or processes which may impact the site. Other data will be available in advance from DOE at the specific site. (b) Conceptual repository design: design assumptions, conceptual drawings. (c) Waste form and package: design concepts, al.ternatives. (d) Identification and discussion of plans for resolution of 1ssues in siting, design, waste form and performance assessment. (e) Site characterization program. Final design of underground test facility: design assumptions, criteria, drawings, specifications. Description of each test to be conducted underground, at surface and in laboratory: objective, selected method and technique, application, alternative methods / techniques. Schedule of activities with milestones, decision points, outputs (reports). (f) Description of the quality assurance (QA) program for SC at the selected site, supported (perhaps) by QA reports and documents from other sites. Description should include QA programs of DOE's principal contractors at the selected site. 8

3101.1/RU/BB/82/01/21/0/1/D/1 Nature of Analysis -(a) Determine' adequacy of technical information coverage and quality based on 10 CFR 60 requirements. Judge applicability and suitability of QA program: determine acceptability of Q-list (activities to be covered under QA). Determine suitability of QA procedures. (b) Evaluate development of each issue: (i) identification; (ii) applicability to' site, (iii) degree of resolution; (iv) information i needs for resolution; and (v) SC investigations needed to develop information for resolation. Analyze data in SCR and at site to determine whether all relevant issues have been recognized and developed. (c) Determine whether proposed investigations to address outstanding issues are properly conceived. Determine whether appropriate tests, test methods and investigative strategies are proposed. Evaluate appropriateness and reasonableness of program. schedule mileposts and plans. (d) Examine validity of design assumptions. Analyze integration and compatibility of underground test facility with repository. (e) Check DOE's modeling (if available) of groundwater flow /radionuclide migration. Do preliminary modeling based on existing, limited data. Establish importance cf site-specific variables through sensitivity studios. Comments Through site visits, meetings with DOE, and review of advanced sections of the SCR, NRC and its contractor should be reasonably familiar with much of this material and have completed preliminary analyses at the time the SCR is submitted for review. The review and analysis will require considerable assistance from outside contractors and consultants. Guidance will be provided by NRC on (1) method and completeness of review, (2) form of output, and (3) timing of all review activities. e 9

t 3107.1/RU/88/82/01/21/0/1/0/1 g REVIEW PROCEDURE 1 7 u Definitions Review topic means one of the five main areas of interest in licensing, viz.: f 1. Geologic isolation and stability geochemistry, geomorphology, hydrogeology, site exploration, structural geology, tectonics. 2. Radionuclide transport geochemistry, hydrogeology, performance assessment, structural geology. 3. Geomechanical considerations - engineering geology, repository design, thermomechanical considerations. 4. Engineered barriers geochemistry, borehole and shaft seals, underground facility backfill, waste form and package. 5. Social and environmental considerations - ecology, institutional relations, site selection, socio-economic and demographic concerns. Site issue means an unanswered, or partly answered, question about a site that is critical to determination of site suitability at the Construction Authorization stage. The review issues represent a breakdown of review topics into key elements. There may be about 25 review issues at a site. Prime issue means an important site issue that is of high priority during SC and is addressed in the SCRA. There may be about 10 prime issues at a site. Licensing issues means the total body of performance objectives, geologic requirements, favorable conditions, unfavorable conditions, design requirements, and waste form requirements in 10 CFR 60. There may be about 80 licensing issues. Review team means the NRC individuals named by management to participate in review of the SCR for a site. Topic reviewer means a member of the review team that has been assigned to a review topic. All topic reviewers are NRC personnel. 10

s t c N 4 g ~f 3107.1/f.U/BB/82/01/21/0/1/0/1 s. s .s-y - 4 $9 , 6 '* ~ Topic review aroup means the review team members that are assigned to a s e p s particular review topict y

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IssuereviewermeansAnindividualthathasbeenassigned. responsibility by a-topic reviewer for review of a site issue. The individual may be an NRC employee or an NRC contractor or an NRC consultant. Site issue analysis means the analysis of a site issue that is prepared by an issue reviewer and presented in the standard, two page summary form. The form is ettached as Appendix A. The completed form may be accompanied by one or more pages of supporting material prepared by the issue reviewer. t i I l i a / T N L l t r e 11 I e

3107.1/RU/BB/82/01/21/0/1/0/1. Steps in SCR Analysis The SCR analysis involves four main steps: A. Organization of review B. . Development of mock SCRA C. Preparation of draft SCRA D. Preparation of final SCRA On the following pages, each of the four steps is divided into a sequence of activities, presented both in tabu?ar and illustrative form. The activities described herein are mainly those to be undertaken by the NRC, its contractors and consultants. These activities depend heavily on an aggressive exchange of site specific information between DOE, NRC and various contractors working on site specific issues. The interactions with DOE include site visits, topical discussions and programmatic discussions, all representing a thorough technical interchange to facilitate the review process. 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, and the National Academy of Sciences. While these activities are of necessity somewhat ad hoc in nature and cannot be specifically worked into the review plan, they are an essential part of the review process. In fact, it is only because of these activities that it will be possible to complete a review of the SCR and prepare an SCRA in the limited time that will.be available. 9 9 12

3107.1/RU/88/82/01/21/0/1/D/1 A. Organization of Review (1) Topic review group convenes with project manager (PM) to (a)- identify site issues to be handled by the group and (b) assign each site issue to a topic reviewer. Site issues will be identified mainly from trip reports,. project reviews and other documents already in hand. (2) PM provides topic reviewer with licensing issues relevant to each review issue. (3) Topic reviewer in consultation with PM (a) sets priority among assigned site issues; (b) determines person days to be spent on each issue (1) in preparation for'SCR review and (ii) in SCR review; (c) identifies site issue reviewers; and (d) prepares review schedule for each site issue. (4) PM integrates all issue plans into a review schedule that sets (a) priorities among all site issues (b) level of effort, in person days, for preparation and for SCR review and (c) identity of site issue reviewers. 1 d a 13

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' 3107.1/RU/BB/82/01/21/0/1/D/1 B. Development of Hock SCRA (1) ;SCR workshop is held.in Siver Spring.to (a) inform all issue reviewers of review plans, procedures and policies (b) identify information needs of reviewers (c) plan development of mock issue analyses and mock SCRA, and (d) review latest DOE: input on each issue. (2) Each issue revieverfprepares a mockup of each issue analysis on the " Analysis of Site Issue" form and delivers same to the topic ' reviewer. (3) Topic reviewer (a) edits review mockups for clarity, consist'ency-and' relevance to topic and (b) transmits these to_PM. (4) With input from (3) PM determines prime issues and addresses these in a mock $CRA. Frequent contact witti 00E and its contractors will 'ime required to satisfy information needs. J. 4 CD c 4 i -15

3107.1/Rd/BB/82/01/21/0/1/0/1 B. Development of Mock SCRA ~ (1) SCR workshop'is held in SiverLSpring to (a) inform all issue reviewers of review plans, procedures and policies (b). identify information needs of reviewers (c) plan development of. mock issue analyses and mock SCPA, and (d) review latest DOE input on each issue. (2) Each issue reviewer prepares a rockup of each issue analysis on the " Analysis of Site -Isrue" form and delivers same to the topic reviewer. (3) Topic reviewer (a) edits review mockups for clarity, consistency and relevance to topic and (b) transmits these to PM. (4) With input from (3) PM determines prime issues and addresses these in a mock SCRA. Frequent contact with DOE and its contractors will be required to satisfy -information needs. 4 O + i t t i a I e - e 15 t t t,.__s ,e g n

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~ l i 3107.1/RU/88/82/01/21/0/1/0/1 C. Preparation of Draft SCRA (1) Upon receipt of the SCR, each topic reviewer (a) provides each issue reviewer with a copy and (b) identifies portions of the SCR for which each issue reviewer is responsible. (2) Each issue reviewer prepares a site issue analysis (based on work prepared in advance of SCR receipt) for each assigned issue and delivers same to the topic reviewer. (3) Each topic reviewer (a) edits the site issue. analyses for clarity, consistency and relevance to review topic,'(b) combines appropriate site issue analyses into analyses of prime issues and (c) delivers all analyses to PM. (4) PM (a) prepares draft SCRA based upon prime issue analyses and (b) combines all site analyses. (5) Draft SCRA is reviewed (revised) by WMHT and WMHL. (6) Draft SCRA is reviewed (revised) by WM. (7) Draft SCRA is reviewed (revised) by NMSS. (8), Simultaneously with (7) draft SCRA is discussed with the Commission. and site analyses are docketed. (9) Draft SCRA is published and all site. analyses are provided in public document room. 4 .e O k 17 ) \\

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4 3107.1/RU/BB/82/01/21/0/1/D/1 D. Preparation of final SCRA (1) During 90 day public comment period, each comment, as received, is assigned by PM to topic reviewer. (2) Topic reviewer (a) prepares a response to the comment (b) prepares any needed change in draft SCRA and (c) delivers both the PM. (3) Aft'er all comments have been handled, NRC consults with DOE about proposed changes in the draft SCRA. (4) PM develops final SCRA. (5) Assigned review team member prepares document covering the response ~ to public comments. (6) Document in (5) is presented to Commission. (7) Final SCRA is reviewed (revised) by WMHT and OMHL. (8) Final-SCRA is reviewed (revised) by WM. (9) Draft SCRA is reviewed (revised) by NMSS. (10) Simultaneously with (9) SCRA is discussed with the Commission. (11) SCRA is published. N S 19

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3107.1/RU/BB/82/01/21/0/1'/D/1 SCHEDULE OF ACTIVITIES. In this section, the review schedule of the SCR for BWIP is used as an example to illustrate: -(1) the interaction between DOE and NRC as an integral part of *.he review process and (2) the approximate timing of;the activities described in the previous section. Successful completion of the SCRA within-the time frame provided will depend heavily-on a great deal of advance preparation, which will involve an extensive, ongoing interchange with DOE on major issues to be investigated during SC. Only the more significant. interactions are indicated in the schedule below. Other interactions are expected to include advance looks at draft sections of the SCR, technical meetings on selected topics, and continuing contacts between the BWIP review members and technical pecple of RHO and DOE. The schedule is ordered so as to reflect the general sequence of the activities. However, this is no more than an approximation, because many activities run concurrently and the order of some may be changed. The schedule is based on the premise that the SCR will be delivered in September 1982 and the draft SCRA'is due four months later. 9 E P J 21

t 3107.1/RU/BB/82/01/21/0/1/0/1 Date Activity. i 1981 December: Project manager and review team are nominated. '1982 January - March: SCR review is orgarized, as discussed'(previous section) under step A. At the conclusion of-step'A, the site issues and their priority are discussed with DOE. . April-June April-SCR workshop is held to kick off Development of mock SCRA (step B). April-Issue reviewers prepare mock issue analyses. 1 -May-Topic reviewers' prepare issue analyses in final form. June-PM prepares mock SCRA, which is distributed to all issue reviewers. July-Sept July-NRC position on site issues is discussed with DOE. August Issue reviewers visit site to collect data, as needed. + 4 9 6 i e 22

3107.1/RU/BB/82/01/21/0/1/0/1 WEEKS AFTER SCR RECEIPT Activity 1 Topic reviewers screen SCR for t materials relative to site-issue reviews. 2 Relevant material is distributed to site issue reviewers by topic reviewers. 3-4 Site ~ issue reviewers develop review and analyses of assigned issues, using site issue analysis form. 5 Issue reviewers deliver completed site issue, analysis forms, and supporting documentatior., to responsible topic reviewers. 6 Project Manager, in consultation with review team, develops priorities for, and analysis of, prime issues. 7-8 Project Manager prepares draft SCRA; review team members finalize site issue analyses, with supporting documentation. 9 Draft SCRA is reviewed at branch level'and revised as necessary; draft SCRA is submitted, for review, to the Office of Executive Legal Director. 10 Draft SCRA is reviewed at division level and revised as necessary. 4 23

l 3137.1/RU/BB/82/01/21/0/1/0/1 t WEEKS AFTER SCR RECEIPT (cont'd) Activity 11 Draft SCRA is reviewed at NMSS office level and revised as necessary. 12 Draft SCRA is published for public comment; site issue analysis, with supporting documentation, are delivered to Public Document Room.for docketing. It is expected that.the draft SCRA will be published three months after receipt of the SCR. Thereafter, with the beginning of the 90 day public comment period, NRC attention will shift to the processing-of public comments and preparation of the final SCRA. The final SCRA is expected to be published two months after the close of the public comment period, following the sequence of activities described in step D (previous section). The general schedule is as follows. 4 e ~ 24 - _. _ - _ _. b

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l Weeks after close of public comment period Activity 1-2 Topic reviewers complete-processing of public comments.

3-4 PM prepares final.SCRA. 4 Proposed' changes in SCRA are discussed with DOE. 5-8 Final SCRA goes through NRC + review chain. 8 Final SCRA is published. 1 N e T 4 J e f 25

3107.1/RU/BB/82/01/21/0/1/0/1 APPENDIX A SITE ISSUES ANALYSIS i - (1). Name of the-site: t l' (2) Statement of the issue (in form of a question): 1 1 1 j (3) Portions of 10 CFR 60 that are directly connected to the issue: 1 L (4) J Summary of the present state of knowledge: i. i k 4 x 4 26 .,-.c..

'~ j - 3107.1/RU/BB/82/01/21/0/1/D/l (5) Summary of the. information needed.to close out the issue by the mine of construction authorization application: F W (6) Summary of-the investigations-pl. inned during site characterization to provide the information needs of (5): h i L t 9 (7) Analysis of the invest:igations of (6) as to tests, test methods, completeness, practicality and likelihood of success: I N l t h e f 't 27 L .,,r.-

3107.1/RU/8B/82/01/21/0/1/0/1 APPENDIX B TOPICAL OUTLINE OF SCRA Executive Summary . Director's Opinion Chapter 1. Introduction Purpose'of SC end SCR Overview of Licensing Process Description of Material Submitted in DOE's SCR Attention to Prime Issues 2. Site Selection Process Technical Basis State Interaction Other Sites in Same Medium 3. Geologic Isolation and Stability Issues Plans for Resolution 4. Conceptual Repository Design Issues ^ Plans for Resolution 5. Waste Form and Package Issues Plans for Resolution 6. Radionuclide Migration Issues Plans for Resolution ~ 28

O 3107.1/RU/BB/82/01/21/0/1/D/1 7. Site Characterization Program Analysis e i e a9 9 29 -}}