ML20050B509
| ML20050B509 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1982 |
| From: | Wright R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Miller H NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-1 NUDOCS 8204050417 | |
| Download: ML20050B509 (6) | |
Text
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3104.1 MAR 171982 r/ f jf CF JBMARTIN REBROWNING MEMORANDUM FOR:
Hubert J. Miller, Chief MJBELL High-Level Waste Technical PALT0 MARE Development Branch HJMILLER Division of Waste Management RJWIRGHT & r/f 1@f FROM:
Robert J. Wright
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s Senior Technical Advisor a n-High-Level Waste Technical
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Development Branch
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Division of Waste Management El
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SUBJECT:
DOE SITE CHARACTERIZATION PLANS v:/
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_7 Several questions about site characterization have been u'nder' discussion, of recent weeks: what level of detail does NRC need on DOE's'SC p_lans,'
methods and procedures? when is the material needed - pre-SCR or in the SCR? what topics should be covered by NRC in technical positions?
Much of this is related to our perception of the role and responsibility of NRC, as compared with that of DOE.
In the following pages I wish to present some observations on this subject, organized around the steps in the logic train of SC:
o Site issues o
Information needs o
Test methods and plans o
Test procedures and techniques Site issues A site issue is used here in the same sense as in the SCR Review Plan:
a question about a site that is critical to site suitability at the construction authorization stage.
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3104.1/RJW/82/03/11/0 Both DOE and NRC are interested in early identification of the issues to be resolved at a site.
DOE needs to recognize the site issues in order to develop an effective SC program and to prepare a useful SCR.
NRC's interest is to ensure that the proper issues are addressed during SC so that there will be no licensing delays.
Issue identification begins early->n at each site.
Interactions between NRC and DOE take place through site visits and other technical interchanges.
By the time of SCR development, there should be no substantive difference between the viewpoints of DOE and NRC.
Information needs The SCR program is beamed toward producing the body of information needed to support a construction authorization application by DOE.
NRC's interest is that the information be adequate for a finding, "with resonable assurance", of radiological safety (or lack thereof).
Clearly, it is in the interest of both DOE and NRC to have a common viewpoint, in advance, of the minimum information needs for licensing.
In 10CFR60, NRC has discussed the main concerns that need to be settled for licensing.
This is, of course, a generic document.
At a given site, the specific information needs depend on a number of variables, such as:
the kind of candidate host rock and its geotechnical particulars; the amount of data already in hand from earlier studies by others; the prior knowledge gained through exploration for groundwater, oil and minerals; the extent of mining experience in the candidate host rock, near the site and elsewhere.
Information needs, therefore, differ greatly from site to site.
Ideally, NRC should be as specific as possible, as far ahead as possible, on information needs.
In real life, however, this poses not only some problems but also some risks.
By its nature, the course of site exploration is studded with uncertainties.
Each new borehole is intended to increase the level of confidence, but the unexpected can always happen. For example, the unexpected brine flow in WIPP 12 retarded the increase in confidence in the WIPP site.
Almost always, the results from each successive drill hole af'ect the judgement on the remaining, unsatisfied information needs for licensing.
Also, it should be remembered that the " reasonable assurance" finding will be based not only on geotechnical testing but also on progress and DIST:
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3104.1/RJW/82/03/11/0 developments in such related areas as waste form, engineered barriers, and performance assessment technology. Hence, it is difficult to set, in advance of SC, the minimum information needs in any one technical area because of the impact of unanticipated developments in other areas.
Somewhat similar would be a pre-trial onestion to a jury member in the Wayne Williams case in Atlanta:
what are the information needs for you to make a finding of guilty beyond resonable doubt? The answer would be that it is the responsiblity of the prosecution to select the approach, collect the evidence and develop the argument in a way to best convince the jury.
Similiarly, it is DOE's responsibility to develop the case for site suitability. Without knowledge of the evidence, it is difficult for NRC to define, in advance, what is enough for " reasonable assurance."
Thus, at a given site, the general kinds of information needs are provided by, first, the rule - 10CFR60, and second, the site issues.
To be more specific as to kind or amount of information needed for licensing would be tantemount to prejudging the results of site characterization.
Also, there is a risk that emphasis on the information needs could lead to the mistaken impression that the thrust of SC is to collect information rather than to resolve issues; or that once the required information is collected, a favorable finding is automatic.
Test methods and plans Many of the questions to be answered during SC are similar to the questions asked during site screening; therefore, the kinds and methods of investigation used in site screening are reflected in the investigations of SC.
Many investigations are simply carried out on a smaller scale and in a greater level of detail during SC, although there are, of course, some investigations that are represented only in SC, such as in situ testing. DOE's responsibilty is to select the optimum mix of investigation methods and develop a testing plan that is appropriate to the site and its suitability issues.
NRC reviews the methods as part of its review of project documents and its site visits. Comments on methodology and plans are presented to DOE through trip reports and other communications.
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o 3104.1/RJW/82/03/11/0 The SCR provides the formal mechanism for expression by DOE of SC methods and plans.
It also provides the vehicle for the formal NRC review and analysis of SC.
What level of detail is needed in the SCR? The answer comes from the judgements called for in the NRC analysis of the SCR.
As taken from the SCR Review Plan, these are:
o Does the SCR discuss the program to develop the information needed to resolve site issues?
o Are the proposed methods of testing and analysis appropriate to the site characterization program?
o 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?
o Will the data and the data collection method and analyses be of adequate quality and reliability to support a future construction authorization application?
The only way to ensure adeqtate presentation in the SCR is to have prior, in-depth interactions on the subject with 00E.
Test procedures and techniques To implement a given test method, a range of techniques is available.
Two examples can be given, one in hydrology and one in rock mechanics.
To drill a well for hydrologic testing, a wide variety of drills, muds, and procedures can be used.
To complete the well, a number of approaches are available.
To test the well, a number of pump, slug, and other tests can be used.
Finally, to log the well, a munber of down-hole geophysical tools can be employed.
The measurement of rock stress provides another example of multiple available techniques.
In its review of rock mechanics research requirements, a panel of the National Research Council observed that about 100 different techniques have been used to measure in situ stress!
The selection, by DOE, of effective investigative techniques for SC depends on the specific problems to be solved, the peculiarities of the site, constraints of time and money, availability of services and DIST:
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e 3104.1/RJW/82/03/11/0 equipment, physical contraints (as for in situ testing), and the like.
Commonly, the procedures evolve as SC progresses, through trial-and-error, as it becomes apparent what works and what doesn't at a particular location.
As with test methods, the role of DOE is to select the procedures and to make them available for review and comment by NRC.
The reviews take the form of (1) document reviews, (2) site visits and (3) SCR analysis.
Technical positions Reactor licensing procedures have demonstrated the usefulness of developed NRC technical positons.
The same benefits should be sought in repository licensing.
In practice, though, difficulties soon emerge, particularly in providing advance guidance for SC.
For one thing, determination of site suitability is many times more complex for a repository than for a reactor:
the technologies are more numerous; the size of the rock mass to be understood is much greater (particularly in the third dimension); the time e, pan of licensing concern is much greater; therefore, the number of choices is much greater.
For another thing, the benefit of technical licensing positions will be limited to one site for licensing and three sites for site characterization.
This makes its important to determine whether the considerable investment required of NRC to do creditable job in development of a technical position is justified by future benefits.
Finally, NRC has no prior experience in repository licensing to provide the basis for guidance to 00E.
In fact, through its extensive programs, DOE may be ahead in the understanding of some technical problems.
Conclusions In the absence of prior repository licensing experience, NRC's technical capabilities are developed and used mainly in critical review and analysis of the DOE program.
This type of activity is probably the main role of NRC during SC.
A major effort, prior to the SCR, is the development of site suitability issues and the rationalization of these with DOE.
This should pave the way for an SCR that effectively addresses the resolution of the issues during SC.
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e 3104.1/RJW/82/03/11/0 Due to the many, inherent uncertainties in SC, it appears impracticable to attempt to specify, in advance, the kinds of information needed, or the level-of-detail and timing therefor.
Care is needed in the selection of topics for technical positions to ensure that (1) the topics are suitable for such treatment and. (2) the benefits, of limited applicability (to 3 sites, or less), justify the NRC resources to do a creditable job.
Topics that involve laboratory or office investigations are more tractable than those that call for field investigations.
_GtIGINAI,STm n Robert J. Wright Senior Technical Advisor High-Level Waste Technical Development Branch Division of Waste Management 4
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