ML20126C079
| ML20126C079 | |
| Person / Time | |
|---|---|
| Issue date: | 12/17/1992 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0067, NACNUCLE-T-67, NUDOCS 9212220343 | |
| Download: ML20126C079 (250) | |
Text
_ _ _ . _ . . -- . -_ - - - _ . .- -. -_ _ -- QQ h W~b f O OFFICIAL TRANSCRIPT OF PROCEEDINGS ACNW CFFiOE COPY - RETM! FOR THE UFE OF THE COMMiiTES AgeDCy; Nuclear Regulatory Conur.ission Advisory Committee on Nuclear Waste , IICIC: 49th ACNW Meeting TR08 (ACNW) Delete B. White seturn risinal to n. White Docket No. ACRS-P-315
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1 O PUBLIC NOTICE BY THE UNITED STATE NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE.ON NUCLEAR WASTE t
-DATE: December 17. 1992 l
l l
/ The contents of this transcript of the proceedings ;
of the United States Nuclear Regulatory Commission's Advisory Committee on Nuclear Waste, (date) December 17-1992 , as Reported herein, are a record of the discussions recorded at the meeting held on i the above'date. This transcript has not been reviewed, corrected or edited, and it may contain inaccuracies. l l l i l O ANN RlLEY & ASSOCIATES, Ltd. 1 Court Reporters j 1812 K. Street, N.W., Suite 300 ; Washington, D. C. 20006 I l i (202) 293
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h 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION L 3 *** 4 ADVISORY COMMITTEE ON NUCLEAR WASTE 5 6 49th ACNW Meeting 7 8 U.S. Nuclear Regulatory Commission 9 7920 Norfolk Avenue 10 Conference Room P-110 11 Bethesda, Maryland 12 13 Thursday, December 17, 1992 O 24 l 15 The above-entitled proceedings commenced at 8:30
, 16 o' clock a.m., pursuant to notice, Dade W. Moeller, chairman, E 17 presiding.
18 19 PRESENT FOR *HE ACNW FULL COMMITTEE: 20 D. Moel la" M. Steindler 21 W. HinM P. Pomeroy 22 23 24 25 O ANN t. EY & ASSOCIATES, Ltd. Court Reporters f 1612 K. Street, N.W., Suite 300 j Washington, D. C. 20006 (202) 293-3950 a
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PARTICIPANTS.- 2 i ! 3 R. Major G. Gnugnoli l 4 L. Daering M. Nataraja ! 5 C. Abrams S. Schofer j 6 R. Ballard J. Linehan i l 7 S. Young K. McConnell i j 8 G. Stirewalt i 9 ! 10 l 11 - I j 12 i 13 'O , 14 l l 15 16 l 17 18 , 19 i j 20 i 21 l l 22
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24 i 25 O l ANN RILEY- & ASSOCIATES, Ltd. l- Court Reporters
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l l ) 3 l ]m/ i (, 1 PROCEEDINGS j 2 MR. MOELLER: Good morning. The meeting will now 1 j 3 come to order. This is the first day of the 49th meeting of 4 the Advisory Committee on Nuclear Waste. ! 5 During today's meeting, the committee will be 2 6 briefed by the staff on their evaluation of DOE's requested 7 resolution of SCP Objection No. 1. We will be briefed by 8 NMSS on the results of the geological cross-section l 9 balancing activities. We will hear a report by ACNW Senior i i 10 Fellow Steven Mays on the November 18-19, 1992 DOE Workshop 11 on the Use of Expert Judgment. We will hear a report by the i 12 Chairman of the ACNW working group on Total System - 13 Performance Assessment. We will review upcoming committee , 14 activities and future meeting agenda, and we will discuss 15 and try to draft and complete several proposed ACNW reports. l 16 The-Designated Federal Official for the initial 17 portion of this meeting is Richard Major, who is seated to
- 18 my right. The meeting is being conducted in accordance with 19 the provisions of the Federal Advisory Committee Act. We 20 have no written _ statement nor have we received any requests 21 from members of the public to make oral statements at 22 today's meeting, other than those previously mentioned.
23 However, if there are people here-who desire to 24 make a statement, please simply check with one of us, and we. ; q 25 will provide time to you to make such a statement. If you l
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O ANN RILEY & ASSOCIATES, Ltd. Court Reporters , 1612 K. Street, N.W., Suite 300_ ' Washington, D. C. 20006 i (202) 293-3950--
4 O (_j 1 do make a statement, please go to one of the microphones, 2 identify yourself, and speak with sufficient clarify and 3 volume, so that you can be readily heard, l 4 Before proceeding with the first agenda item, we ! 5 would like to cover several brief items of possible 6 interest. Ms. Sertia Sanders is on a three-month rotational a I 7 assignment to the ACNW ACRS Office as part of her intern 8 program as a new NRC employee. She will be introduced 9 later. 10 Another item of general interest is that the 11 average collective radiation dose per nuclear powerplant of 12 those licensed by the NRC showed a 24-percent decrease 13 during calendar year 1991 as compared to 1990. The average 7_ s 14 collective dose per plant was 253 person REM, which is down 15 from 333 from the previous year and represents a lowest 16 average in 22 years. 17 KR. POMEROY: Dade, I read that, and I wondered. 18 Do you know if there is some specific reason why that should 19 change, or is that a slightly abnormal fluctuation? 20 MR. MOELLER: No. At least my observations of the 21 trends have been that they have been decreasing quite 22 continuously, year by year, and if you go back to the years 23 immediately following the TMI accident, when all the 24 backfits and so forth were required, that raised the dose 25 tremendously. O ANN RILEY & ASSOCMTES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
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i i 5-1 MR. POMEROY: Right. 2 MR. MOELLER: Then, since then, there have been i 3 fewer backfits. . i j 4 But, also, they have extended the life between ] 5 refueling outages. I mean, it used to be regularly, what, 6 12 months or so? Now it is 18 or more months. 1 i 7 MR. STEINDLER: Is that number normalized to-the i
- 8 number of megawatts generated?-
9 MR. MOELLER: No. This is simply per plant.
- 10 MR. STEINDLER: Just per plant?
j 11 MR. MOELLER: Yes. l 12 MR. STEINDLER: So you don't-know whether or not j -13 they are functioning? h 14 MR. MOELLER: Oh, they do have the other data, l 15 which are available and are calculated, and perhaps we could
- 16 look up those data. But, yes, the doses-have been coming i
l- 17 down. 18 Organizations such as INPO sets targets or. goals, - 19 and it-is part of their policy of seeking. excellence, and 20 there-is a lot of push -- constant' push -- to-have the
- 21- utilities do a better -job, do better planning, and so forth. . 1 l
22 Other items of possible interest, you have'been 23' provided with a list ~. .On'No. 2, we were provided with a. I 24 report'from-the Board on rad waste management of the l 25 National Research Council, and it was entitled " Review of_ -l I 'O ANN RILEY & ASSOCIATES, Ltd. (- .: -Court Reporters - l 1612 K. Street,1N.W., Suite 300 l Washington, D. C. 20006 j- (202) 293-3950-
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h i-a f l 6 ( 1 Analyses by the U.S. Department of Energy of Selected 2 Technical-Issues in the Environmental Protection Agency's i 3 Standards for High-Level Radioactive Waste," 40 CFR 191. j 4 This was a review of the WIPP standards, as : understand it,
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5 and I have not yet read it, but you are being provided with 6 copies. 7 There was a memorandum of November 6, 1992 from 8 the LSS Administrator on the status report of the_ work of l 9 the Center for Nuclear Waste Regulatory Analyses to help
- 10 establish a priority. loading schedule for backlog licensing 1
l 11 support system material. The committee may want to learn
- 12 more about this.
! 13 On the basis of the Administrator's review of the j 14 Center's report, _he has concluded that this may not be,the 15 best method for determining priority categories, the method i . 16 that the Center proposed. As I say, I know members of the 17 committee are very much interested in this databank, and we j- 18 may want to discuss that more, t 19 Item No. 6 on my list is one that we have 20 discussed before,_this repository operational-criteria 21 analysis. At this point, I would simply ask if the 22 committee wants a briefing on_that, just to think about_it. 12 3 On-the third page of the list, Item No.-7,- 24 regulation of major materials licensees, the NRC staff is-l 25 preparing a staff action plan for regulating _ major materials O ANN RlLEY & ASSOCIATES, Ltd. l Cout Repoders
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( ,/ 1 licensees, and they initially were looking at whether l 2 materials licensees, NMSS licensees, might in a sense l 3 self-regulate themselves or self-evaluate themselves, much 4 the same as INPO does for the nuclear powerplants. i 5 Then, having made that suggestion, as I read the 6 report, it said that the NMSS licensees are so diverse, and 7 many of them are small in number; that it might not be . 8 possible for them to set up an independent evaluation group. 9 MR. STEINDLER: Let me just comment. If you 10 recall, one of the problems that was faced when the near 11 criticality incident happened at the GE Plant is that there 12 was a difference in the viewpoint between the licensee and 73 13 the NRC people whether this was a significant incident or
- 14 not, if that is an example of the difficulties that exist in 15 communicating the same set of regulations to people.
16 I think it might be quite premature to have those 17 folks regulate themselves. 18 MR. MOELLER: We will talk about this more later. 19 I really don't know where it fits in or what approach we 20 should use. But if you look at some of the data reported, 21 say, for 1991, it shows that -- and don't hold me to this 22 number -- but there was something like 31 overexposure among 23 licensees during that year. Not one occurred at a nuclear 24 powerplant. They all occurred at NMSS licensees. 25 We have distributed it. There was a death, i
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ANN RILEY & ASSOCIATES, Ltd. i Coud Repoders 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950
8 1 several weeks ago, in Pennsylvania due to a i 2 misadministration of radiation in a medical facility. So, ! 3 again, it is not rad waste, but it is certainly NMSS. l 4 Other things. Item No. 9, residual contamination 5 limits, there have been several reports recently issued, and 6 the committee may want to follow up on these. 7 The Health Physics Society has a committee on 8 scientific and public issues, and they have issued a draft. 9 position statement on standards for permissible radioactive 10 contamination limits for site cleanup or restoration.
- 11 Offhand, I thought it was a very well-thought-out 12 statement. It is only three pages long. We may want to 13 discuss that with them or the-staff may want to.
jd 14 What kind of rulemaking is it? , 15 MR. MAJOR: Enhanced participatory rulemaking. 16 MR. MOELLER: Enhanced. As the enhanced I 17 participatory rulemaking proceeds.
- 18 Then, one of the staff, NRC staff, published this 19 paper. It is John L. Minz, who published this paper on 20 disposal of slightly contaminated rad waste from nuclear 21 powerplants. We have also distributed that to you.
l 4 22 Then, we were provided, six months ago, with this i 23 RES RAD code, which is-a code for calculating or for 24 implementing residual radioactive material guidelines, f 25 Dr. Okrent,'I. guess, yesterday was sayinglto the O ANN RILEY & ASSOCIATES, Ltd. Court Reporters I 2 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 4 1
l 2 9 () 1 staff when we were talking about performance assessment to l 2 the DOE staff how confident are you in moving from i 3 radionuclide release limits over to dose. q 4 Now, I am sure -- or I-am almost sure, a part of ) 5 this code, probably, would be directly applicable. They use i j 6 the Ditty Code. Again, I don't know the degree to-which the i 7 committee wants to get into it, but we could have someone j 8 come in for an hour some day and review with us the Ditty ,! 9 Code. I don't know anything about it, i ! 10 I think I know something about it, but I am not ! 11 personally familiar. Maybe'we ought to have them come in i f 12 and tell us about the Ditty Code. 1 13 The U.S. Council on Energy Awareness, Item No. 11, 0 14 in late 1991 created a communications. network for the 15 nation's low-level radioactive waste generators. I don't 16 know much more than what it says here. It says they will i
- 17 serve as a clearinghouse for information and is a focal
-18 point for an industry-wide network through which waste
! 19 generators can share material strategies and techniques.- i l 20 Now, that would mainly be,-I think, nuclear l'
-21 powerplant licensees, because that is what the council does, l
f 22 .But maybe we ought to find out what they'are'doing.- i' 23 NR. POMEROY: There=is also a citing of low-level-j 24 waste disposal facilities. 1 j 25 MR. MOELLER: Yes. So flag that as a possible. LO ANN: FilLEY & . ASSOCIATES, Ltd. .
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1 ) 2 10 () 1 follow-up item. 2 Item No. 12 simply was my attempt in reading these i 2 3 reports of recent weeks about the different states 4 abandoning proposed low-level ~or suggested low-level waste
- 5 sites. We have heard from Connecticut and Illinois. -
Are 1 l 6 these lessons to be learned? Perhaps the NRC staff is f 7 following that. 8 Under Item No. 14, these are just miscellaneous ! 9 that I do hope tomorrow morning we can come back and discuss ! 10 some of these. i i 11 .Yes.
- 12 MR. STEINDLER
- Let me just make a comment. Is it i
3 13 worth our while to talk about the Zero Release concept and '( 14 what implications there are for ever being able to implement 15 this? Clearly, if you follow the words and you extrapolate i 16 it, then the answer is you can't do that. I 17 On the other hand, I don't have a good reading on i 18 whether or not things that are labeled Zero Release are, 19 number one, that and, number two, whether they have a time l 20 limit associated with it. 21 It is unlikely'to go'away. It'is certainly a 22 -populist, albeit, unscientific and irrational-view. On the ' 23 other= hand, I think the Commissioners'need to deal with it. l 24 I would not be too startled to have one of the 25 Commissioners point their finger at this committee and say
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4 I 11 1 tell me what it is and tell me what we ought to do about it. 2 My view is that I think we ought to look at it and 3 become sufficiently knowledgeable, one, and understand what 4 the various states are saying and, two, identify potential l l 5 strategies within the licensing framework, ignoring the fact 6 that some of these are agreement states; that one might be ! 7 able to use to at least overcome that aspect of it. I think . 8 it is a topic we ought to look at. i j 9 MR. HINZE: Is there a scientific rationale given 1 ! 10 by any of the states for this that would give us some meat i 11 and potatoes to chew on? i 12 MR. STEINDLER: I don't know. I would guess that i 13 the scientific rationale is the one that says any radiation 'O 14 is bad for you. 15 MR. HINZE: It is very hard to investigate that 16 kind of thing. I 17 MR. STEINDLER: I will leave that to the Chairman 18 whose business it has been for years to do this, i 19 MR. MOELLER: I think that is a. good suggestion. 20 We have flagged it, and let's come back to it. 21 on page 7 under miscellaneous items, I just wanted-22 to be sure you realized that the ACRS'in a letter to.the. 23 Chairman on revised regulatory analysis guidelines -- this 24 was a letter or report of November the 12th -- has l 25 challenged the $1,000 per person REM. So, cercainly, we 'O ' ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300
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i 12 1 should keep up with that. l 2 -Then Item C, the DOE has given these four research i } 3 grants to develop the application of robots'or robotic i j 4 technology to radioactive and hazardous waste management. I 5 would be interested in what those people do or.what they 6 propose to do. i 7 The Item D that I flagged, the NRC staff 8 cccompanied the Conference of Radiation Control Program-l 9 directors when the directors went out and reviewed the I
- 10 Alaska RAD Protection Program. That was new to.me. .
11 We have been briefed on how the NRC goes to the , [ 3- 12 agreement _ states and_ evaluates them, but the Conference of-13 Radiation Control Program directors'goes, and the staff goes [. 1
- - 14 with them.
1 15 I would-like to know more about that. It was l l 16 totally new to me. l 17 On the last page, Item No. 15(b), the NWTRB is j 18 meeting on January the 5th and=6th on the systems {- 19- implications of interim: storage of spent fuel,-which-Marty i j .20 has talked about many times. 21 _You would'have been-pleased, Marty,-on either- ! 22 Monday or Tuesday when the question was raised. I forgoti 23 'who raised it',1but.-it was what do we know about spent fuel, 24 do we know its chemistry, do we:know the integrity of fuel-i 25- that has been stored in a poolifor six years and so forth. LO ANN RlLEY &. ASSOCIATES, Ltd.
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1 We should have thought of something like that at one time.
- 2 For (d), I don't think this an audience 3 necessarily that we should attempt to appear before, but the 4 university campus radiation safety officers, my guess is 5 there are several hundred of them. But they-meet every.two 6 years, and their fourteenth meeting is in Nebraska in June.
7 I flagged it, because I was just saying to myself 8 is there anything that we would have to say to them should
- 9 we offer to appear on the program. Offhand, I would I
j 10 question it. j 11 Then, I gather, Item (e) has been delayed from 12 what I wrote, Item (e) being the briefing on the RES 13 High-Level Waste Research Program, which I now gather is iO
- 14 delayed.
15 Let's plan to come back to those things later. 16 MR. STEINDLER: May I add one or two~ things? 17 You all may have noted the action taken by the
- 18 Commission on approving the Fort St. Vrain D&D.
19 MR. MOELLER: Right.
- 20 MR. STEINDLER
- The interesting thing to us, I 21 think, is that process is going to-generate two kinds of
[ 4 22 what I call' interesting waste. Obviously, the D&D waste is 23 one, and the tritium and the liquid waste,-which is going to 24 get diluted and dumped, is~the other.
- 25 I have read very briefly by the second document i
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4 i 14 1 that, I guess, was the basis of the Commission action, and I 2 find it a little bit surprising, because I guess I was
- 3 operating under the general notion that dilution, in order 4 to meet EPA or other criteria, was not a policy that was 5 going to be allowed.
6 Unless I have misread it, which is certainly l 7 possible because I didn't have the whole decommissioning 8 plan, that seems to be what they are planning on doing. I_ l 9 am wondering whether to not that is Tn issue we at least ! 10 ought to look at to inform ourselves as to what the staff's 11 policy currently is. l 12 The other issue, eventually, I want to talk about 13 is lack of progress of getting at the bibliography from the O 14 Center, which we requested three months ago. 15 I want to point out that, eventually, we ought to 16 tormulate as a new item some thoughts on how to-approach a 17 risk-based regulation principle for the disposal of waste in 18 order.to be able to have some. input to a discussion between 19 ourselves and the staff.that, ultimately, will be. translated 20 into a position of the NRC through the National. Academy in 21 response to the requirements of.the Energy Policy Act. That i 22 is going to require some study on our part in pulling 23- together, I'would say, the past five years or so of 24 literature that we have, to say nothing of what has been 1 25 printed elsewhere in the area on the topic o'f risk-based l l O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters e 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
l i d 15 () 1 regulations. i 2 That is basically all I have. 3 MR. MOELLER: With respect to that last item, and 4 I will have to search for it, the staff or the commission,
, 5 whoever it is, has put out something on risk-based, and it
, + , 6 says specific attention will be directed to waste management t ! 7 activities. It is comewhere here in this stack. I have it 4 8 flagged. It is another item. It is part of this thing that $ 9 we need to talk about. 10 Any other comments? Bill or Paul, do you have I j 11 any? 12 [No response.]
- 13 MR. MOELLER: Then we will r9ve ahead with the l- 14 first item on the agenda for this morning, and that is the l 15 NRC Staff evaluation of DOE's Requested Resolution of Site f 16 Characterization Plan Objection No. 1.
i l 17 We have with us Charlotte Abrams and-Dr. Mysore l 18 Nataraja. I gather Ms. Abrams will lead off. 19 Charlotte, welcome back. It is a pleasure to have ! 20 you. 1 21 MS. ABRAMS: Since everybody has a copy of our , 22 Vugraph, is it all right that we sit at the table? i 4 23 As Dr. Moeller said, I am Charlotte Abrams. I am l 24 _ going to-lead off and do a little bit of' introductory 25 material, and then Raj here is going to actually give you () ANN RlLEY & ASSOCIATES, Ltd. l Coud- Repoders 1612 K. Street,- N.W., Suite 300 Washington,- D. C. 20006 l (202) 293-3950
1 i ' 16-() 1 the main meat of the matter.
- i. 2 We are here to discuss our resolution or lifting i
j 3 of Objection 1 from our SCA. l 4 MR. MOELLER: Excuse me. I have noticed in the 4
- 5 recent staff writings that they now do, very 6 straightforwardly, talk about closure
- This item has been 7 closed or closed out.
f l 8 MS. ABRAMS: We are not using that term anymore, 9 because the state actually objected to that term. So we are
- 10 using " resolution." It is a matter'of semantics, probably.
i 11 I would also like to clarify that this is just i 12 resolution at the staff level. This does not resolve i 13 anything at the-time of licensing. 14 MR. HINZE: Excuse me, Charlotte. What does-that 15 mean? 4 16 MS. ABRAMS: That means that it was a staff 17 concern, and it is resolved at the staff level. It is not 18 something that we could-hold the Commission to or the 19 Licensing Board to. So, in other words, things like this 20 could-come up again at licensing. { 1 21 MR. HINZE: I understand. In other words,.there 22 has been no joining of hands with the doe; that there is no 23 problem here. 24 MP. MoELLER: I guess, too, it is not'a legal, 25 because they are not'a licensee. They are not an applicant.
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i 4 17 '(O q_j 1 MS. ABRAMS: That is correct. 2 In the second Vugraph here, page 2, I will just 3 start with that. I wanted to give you and reiterate the t 4 definition of an objection, as we defined it when we wrote 5 the SCA, t 6 Essentially, an objection is a concern of such 7 immediate seriousness to a particular area of the site 8 characterization program that NRC would recommend that DOE l 9 not start work in that particular area until that objection 10 is satisfactorily resolved. 4 11 DOE did commit to resolve objection-level concerns ~ 12 prior to proceeding with related site characterization work. 13 Now, I want to emphasize that the lifting of an !f 1 % 14 objection means that concerns related to that objection at { 15 this particular point in time are considered to be resolved. 16 The staff is also obligated to continue to evaluate 17 activities related to an objection. 4 18 If we see that it is warranted to reopen an 4 4 19 objection based on new information_or analyses, we-will 20 reopen an objection. 21 I would also like to mention that Part 60 required 22 that the SCP include a conceptual design of the geologica]. 23 repository operations area and the extent of planned 24 excavations for the characterization of the site. 25 DOE still has that commitment on the books and () ANN RILEY-& ASSOCIATES, Ltd. Coud Repoders l 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 , (202) 293-3950 j
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i 1 4 18 (
/~)\ 1 owes NRC a final design. This can be presented either in a
! 2 progress report or the progress report can contain 3 3 information on a referenced document that would have 1 4 information on the design. i l 5 MR. HINZE: In view of this, would that be 6 reviewed and comments made back to DOE? 7 MS. ABRAMS: Yes. We expect to review their ESP 8 design. In their discussion, we expect to see how the I 9 design is going to tie into their testing program. We would 10 want to see a discussion of the potential impacts of waste 11 isolation and a discussion of the design of a repository and 12 how it would tie in, j 13 MR. HINZE: Aren't we getting very much locked 4 's 14 into a design, though, by the very fact that they are
- 15 starting to cut rock and prepare portals?
I 16 MS. ABRAMS: We are reviewing incrementally their i 17 design. For example, the staff has attended a 50-percent
- 18 design' review and a 90-percent design review of the-portal.
19 So the staff does attend -- ) 20 MR. STEINDLER: I am sorry. Of what? . 21 -MS. ABRAMS: The portal. 22 MR.~POMEROY: The portal?- 23 MS. ABRAMS: Yes. 24 MR. POMEROY: Does that mean when you have 25 attended these briefings that you have signed off on those i () ANN RILEY & ASSOCIATES, Ltd. Coud Reponers i 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
i I a l-l i 19 1 points? 2 MS. ABRAMS: There is not a signing off, no. We 4 3 do review them. Technical staff attend these. The QA 4 staff, the Quality Assurance staff, is also reviewing our
! 5 observing DOE audits of the implementation of DOE's design-6 control process. So we do have different mechanisms for ;
i
- 7 looking at how they are dealing with it.
j 8 I will go into some of the chronology. [! 9 MR. HINZE: If it isn't out of place, I would i" - 10 assume from what you are saying then and the fact that they l 11 are proceeding that you have no objection in terms of the 12 review that you have done so far and what they are doing at 13 the portal and in the design.
- 14 MS. ABRAMS: That is correct.
15 MR. HINZE: Does-that include the staff? l 16 MS. ABRAMS: They are doing fault investigations 17 at the portal, and we would expect that.. 18 MR..HINZE: You would expect them -- l 19 MS. ABRAMS: We would sxpect that they would'do 20 the fault investigations, and you are right, at this time, f 21 they have identified potential faults in the area of the 22 portal. 2J MR. HINZE: How close are you staying to that, so 4 24 they_ don't waste money? I am sure that they are very much
-25 concerned.
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l 20 ( 1 KR. STEINDLER: That is not the function of the 2 staff. 3 MR. HINZE: No, but they certainly want to make 4 certain that they shouldn't proceed with the development of 5 ESF, without the NRC's review of it. 6 MS. ABRAMS: We held a site visit to look at their 7 trenching activities in the area of the portal and the 8 potential surface facilities in September of this year. At 9 that time, we did look at the portal area, too. 10 Our on-site representatives maintain, really, a 11 day-to-day update on what is going on at the site. So we do 12 maintain a constant vigilance. 13 MR. HINZE: Great. 14 MS. ABRAMS: I am going to go en and into some of 15 the chronology behind Objection 1. I will go through this 16 pretty quickly, unless somebody has a question. 17 In December of 1988, DOE issued their Sito-18 Characterization Plan. In July 1989, the NRC issued their 19 Site Characterization Analysis, which Objection 1 was one of 20 our concerns. 21 Also, not on this list, but in July 1989, there 22 was a meeting between NRC, DOE, and the State of-Nevada also 23 intended, and it was a meeting to discuss-what NRC expected 24 with respect to the ESF design. The discussion included 25 applicable regulations and NRC's approach to the review of
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21 () 1 the design process at that time. : 2 In December of 1990, the NRC received DOE's 3 responses to our SCA, but at that time they did not request 4 closure of Objection 1. 5 In January 1991, the DOE issued the Calico Hills 6 Risk Benefit Analysis, which discussed in some way the 7 analyses on the penetration of Calico Hills. This was 8 really not a technical report. It, more or less, consisted 9 of a multi-attribute utility analysis. 10 In July 1991, DOE issued the exploratory study 11 facility alternatives, and in that they listed 34 4 12 alternatives. I will discuss those. 13 In September of 1991, NRC issued a letter l 14 requesting information on how the CHRBA, which is Calico 15 Hills Risk Benefit Analysis, and the Exploratory Studies 16 Facilities Alternatives Report address SCA open items. 17 Previously, we had received these two documents 18 without a request to review them from DOE. 19 MR. MOELLER: When did DOE request that Objection 20 No. 2 be resolved? It won, and I just wondered what -- 21 MS. ABRAMS: I think it goes back the July 1989 22 meeting, but Ken Hooks, the section leader of our QA staff, 23 may have a better date on that. 24 There was discussion of the resolution of that QA 25 objection, actually, in July 1989. It was lifted in March O v ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
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() 1 of 1992. 2 MR. MOELLER: Like in the December 1990 DOE 3 responses, you say they did not ask for closure of Objection 4 1. Did they ask at that time for closure of Objection 2? 5 MS. ABRAMS: No. 6 MR. MOELLER: No?- Okay. 7 MS. ABRAMS: I think Ken is looking to see if he 8 can give you an exact date. I don't know if we can give you i 9 an exact date on that, because there were a lot of pieces to 10 that. I j 11 MR. MOELLER: Right. 1 12 MS. ABRAMS: In September of 1991, there was a 13 DOE /NRC technical exchange on the exploratory studies 14 facility. At that time, DOE explained their design control 15 process, and they provided samples of how they plan to 16 implement it. They also presented some milestones for the 1
- 17 exploratory studies facility work.
18 In November of 1991, DOE requested closure of 19 Gbjection 1. But, at that time, we didn't feel there was 20 sufficient information, and, in March 1991, DOE-provided the 21 additional information to support closure of Objection 1.
- 22 That was in the form of a letter, and there was also what we 23 would call a walkthrough that directed the staff.to 24 particular portions of the CHRBA and the exploratory studies 25 facility alternatives-that would address our concerns in ANN RILEY- & ASSOCIATES, Ltd.
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23 () 1 Objection 1. 2 So the staff initiated a review of those sections-3 of those report and the supplementary information provided 4 in the March 1992 transmittal. d 5 In November 1992, the NRC staff concluded that 6 Objection 1 was resolved based on the review of that i ! 7 information and also the information in the ESF report and 8 CHRBA. At that time, they also determined not to review the 9 entire Exploratory Studies Facility Alternatives Report and j 10 the CHRBA, as information in those reports with regard to . 11 the design and alternatives W>as really influx. The DOE is i 12 still revising their design. 13 At that time, they tentatively had a preferred l 14 alternative, but we had not seen officially what their i 15 alternative was. 4 16 MR. MOELLER: Excuse me. Help me with that. A 17 few minutes ago, you said there were 34 alternatives? 18 MS. ABRAMS: That is correct. ( 19 MR. MOELLER: Then you are saying now they 20 narrowed it down to a No. 1 and No. 2 or an A and B7 21 MS. ABRAMS: They narrowed it down to, I believe' 4 22 it was, Alternative 30, the preferred alternative. l 23 MR. MOELLER: Of the 34, they chose 30. j 24 MS. ABRAMS: Of the 34, they chose Alternative 30. 25 MR. MOELLER: As No. 1 -- ANN RlLEY & ASSOCIATES, Ltd. I Court Reporters j 1812 K. Street,- N.W., Suite 300 ' ! Washington, D. C. 20006 , (202) 293-3950
24 1 MS. ABRAMS: As their No. 1 -- 2 MR. MOELLER: -- choice? 3 MS. ABRAMS: -- choice. 4 Now, actually, they have modified that alternative 5 somewhat at this time. 6 MR. MOELLER: Thank you. 7 MS. ABRAMS: But we have not officially seen it. 8 I would like to also emphasize that we plan to 9 really remain abreast of what design changes DOE is 10 conducting through a review of the progress reports, where 11 they should be providing us that information and our 12 participation in these design reviews. 13 The NRC staff will also participate at DOE audits O V 14 of the ESF design review process to determine that DOE 15 continues to implement its design control process. 16 We also plan to request to review DOE's selected 17 design options and_the rationale for the ESF layout, and we 18 would expect DOE to have this information to us in a timely 19 fashion, so that we can get our feedback back to them in a 20 timely way. 21 MR. HINZE: Charlotte, has there been any change 22 of the study plans or do you perceive any change or revision 23 of the study plans as a result of the new ESF and 24 modifications that are being made to the one that was 25 selected?' ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1812 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
i 25 1 () 1 MS. ABRAMS: Originally, the first five study l 2 plans with the NRC received were plans for work within the 4 ! 3 ESF, and they were based on the conceptual design that was 4 presented in the SCP, and the NRC staff at that time elected 5 not to review those, because that design was being changed. 6 We would presume that they would be changing those 7 study plans to reflect their new design in the tests that 1 l 8 they would be conducting in their new designed facility 9 before they transmitted those study plans to us. l j 10 MR. HINZE: Do you have any idea when you are
! 11 going to be seeing those study plans? Is that in that 12 September schedule? ]
! 13 MS. ABRAMS: We saw a tentative schedule, and some !i\b) 14 of those will be coming to us in mid-1993, and I think there } 15 may be one coming in early 1993. i l 16 I also would like to add that one of them, we did 17 get a revision of already, and we are electing not to
, 18 continue to review that one, because it still does not 19 reflect the-new design.
20 MR. HINZE:. -I wonder if this is the place to ask: f 21 Is the staff satisfied that the tunnel-boring-machine 22 approach is going to provide the kind of_ geological
- 23 information that was anticipated from the more conventional 24 drill'and blast -- I shouldn't say " conventional" -- the 25 more classic drill and blast procedures? Has that I-( )
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26 O) ( 1 evaluation been made on any review process or is this an ad 2 hoc decision? 3 MS. ABRAMS: It has been discussed at length by d 4 the staff. We don't want to tell DOE how to conduct their 5 excavation. At the same time, we do want to see them be 6 able to gather the information that is needed. 7 I don't want to speak for the technical staff. 8 here, but there are tradeoffs with each method. 9 MR. HINZE: Sure. As I recall at our Las Vegas 10 meeting, there was a discussion about this, and there was 11 some talk of a report. Subsequently, we have received 12 communication that there is no formal report by DOE on that 13 topic. [s
\-) 14 I was wondering if you had a report from them that 15 you were using to evaluate. Perhaps I am asking the wrong 16 person.
17 MS. ABRAMS: We have seen no formal report, no. 18 MR. HINZE: Are you asking for one, so that you 19 can make an evaluation on these study plans? 20 MS. ABRAMS: No, we have not requested one. 21 MR. MoELLER: Following up the comment by Dr. 22 Hinze, time and tim again, we will see these statements that 23 the study plans still talk about an exploratory shaft 24 facility, and they have not been updated and so forth. I 25 guess I don't have enough appreciation of how difficult a ) C'i V ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 16'.2 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
1 I 27 I (~N 1 task this is or how many people DOE has working on it. () 2 How long ago was it that they shifted their idea 3 from a shaft facility to the studies facility? 4 MS. ABRAMS: To the ramp concept? 5 MR. MOELLER: Right. 6 MS. ABRAMS: It has been a couple of years. 7 MR. MOELLER: Yes. Have you -- I know you have. 8 In fact, they now say -- maybe it was in this material -- 9 that we now have this statement that DOE will give you a
- 10 monthly accounting or status report on all the study plans.
11 MS. ABRAMS: Yes. 12 MR. MOELLER: So, supposedly, maybe we will get a 13 handle on this, l'h (-) 14 MR. HINZE: Might I request, as the staff proceeds 15 with this concern about geological mapping that we be kept 16 informed if you receive a report or you make some kind of 17 review of the situation. 18 I think that Keith would like to make a statement, 19 Dr. Moeller. 20 MR. McCONNELL: Keith McConnell, NRC staff.
- 21 There are two forms for our discussions in this I
22 area. One is the study plan on structural features within 23 the site area, which we have inhouse. We actually have, I 24 think, Rev 1 inhouse. But it addresses a shaft and l i 25 drill-and-blast type of technology. r (,,) s-ANN RILEY & ASSOCIATES, Ltd. Coud Reponers l 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 l (202) 293-3950
1 28 1 We have decided tentatively not to review that 2 study, because there are indications from DOE that they are 1
- 3 going to revise that study to reflect the tunnel boring i l j 4 machine. Therefore, they will be providing some level of i l
- 5 detail about their methodologies for mapping in that revised t
6 Rev 2 of that study plan. 7 In addition, we have had internal discussions and i 8 also informal discussions about the pros and cons of tunnel j 9 boring machine versus drill and blast, and I think the 10 conclusion that we came to is that both provide, I think, j 11 ample opportunity to collect the necessary data, but we are 12 waiting on DOE's revised study plan to make a formal 13 judgment on that. 14 MR. HINZE: Sorry for the tangent. 15 (Laughter.] ! 16 MS. ABRAMS: That is fine. 17 MR. STEINDLER: Let me continue to walk down that 18 tangent for just a little bit more. I 19 Is it clear.to the DOE what criteria you would use 20 to make comments about the acceptability of either a tunnel 21 boring machine or the thing that.is, I guess, called 22 conventional mining engineering, drilling and blasting?'.In 23 other words, what would_you base your comments on?
'24 MR. NATARAJA: Let me address that. I think the 25 criteria, basically, depends on the waste isolation issues, 'O ANN RILEY & ASSOCIATES, Ltd.
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29 1 which we have raised earlier. 2 So the one that creates the least amount of 3 disturbance and provides the required information is the 4 preferred option. Su that would be the basis for making 5 comments. 6 MR. STEINDLER: Is that compatible with Dr. 7 Hinze's question; namely, is that the mechanism that is 8 suitable for getting optimized geologic-related information? 9 MR.-NATARAJA: The preferred option, the 30 1 10 option, which 3e going to be modified, also has an I l 11 additional shaft, if required, which can be added at a later i 12 stage. So, t aatisfy the needs for the information that 13 may not be obtained by the TBM method, they would have.an 14 additional shaft'to gather the data. i 15 So what we understand is there are going to be two ! 16 ramps and optional shaft, which may be included at a later i j 17 date, if necessary. 4 18 So, if there is some information that will not-be-19 gathered by one method, that will be supplemented by an 20 additional shaft at a later date. But I don't-think'they l l 21 have made a' final decision on whether.they will have'two '. 22 ramps and a shaft in the ESF or_.not. 7 [ 23 MR. STEINDLER: Is it clear-then that this kind of 24 strange three-dimensional tradeoff is going to maximize 4
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25 rather than minimize the amount of holes that are drilled lO ANN ' RiLEY & ASSOCIATES, Ltd.
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30 e 1 into the repository? 2 MR. NATARAJA: These holes will eventually be 3 integrated into the holes that will have to be done for the 4 repository. 5 MR. STEINDLER: I see. 6 MR. HINZE That allows you to get off the hook, I 7 think. 8 MR. BALLARD: I am Ron Ballard. 9 I would also add that I believe DOE is considering 10 drill and blast techniques for some of their testing areas. 11 They aren't just relying on tunnel boring all the way. So 12 they will have alternatives in their plan. 13 MS. ABRAMS: That concludes my part of the 14 presentation, unless you have any more questions. I will 15 turn it over. 16 MR. NATARAJA: I am Mysore Nataraja, the Section l ! 17 Leader for the Geotechnical Engineering Section. 18 My presentation starts from Vugraph No. 6. I will 19 be covering summary of concerns, expressing the SCA 20 objection 1, along with the bases for those concerns. I 21 will also cover the NRC staff's evaluation of-DOE's response 22 to SCA Objection _l. I will briefly summarize what we intend 23 to do in the future in regards to following up on the open 24' items related te this article objection. 25 I will go to Vugraph No. 7. This is basically the ANN -RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K.- Street, N.W., Suite 300 Washington, D. C. 20006 (202). 293-3950'
l l l 31 . ) 1 summary of Objection 1. As for the DOE's proposed design l 2 presented in the site Characterization Plan, the exploratory 3 shaft facility -- I will have to clarify one thing here. 4 The acronym ESP stood for exploratory shaft facility and now I 5 has been changed to exploratory studies facility in order to ) ' 6 make sure that not all documents will have to be changed. j 7 They kept the same acronym.
- 8 So, if I talk about SCP or SCA, that stands for 9 the exploratory shaft, and if we talk about the current l
10 activities of the future activities, that refers to the 11 exploratory studies facility. Even if you are a little 12 inconsistent in the terminology, it won't make any j 13 difference to tr.3 discussions today, i ! 14 The exploratory shaft facility, according to the 15 designs presented in the SCP, would become a part of the i 16 repository. Therefore, one has to be very careful in 17 designing the exploratory shaft facility, keeping in mind l 18 the design of the repository of which this ESF would . 19 eventually become a-part. 20 However, our review found two major concerns with 21 the ESF, and they are. summarized on Vugraph No. 7. No. 1, 22 the SCP and its references did not make a convincing case 23 that the design control process under which the Title I 24 design of the ESF was performed was adequate. No. 2, the 25 SCP didn't convince us that they had an adequate Title 1 0 - ANN RlLEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202)-293 3950
J 32 1 design for the ESF either. i 2 Let me explain. For example, since the I 3 exploratory shaft becomes a part of the repository, all the , 4 regulations considered applicable to the repository should l J} l
; 5 be considered applicable to ESF, also. But we found there G were a number of regulations that were not considered in the
( 7 design of the ESP. 4 ! 8 We also found that the design control process i 9 allowed some of the critical technical data to be ignored,
- 10 which led us to suspect that the process suffered from CDS 1 11 deficiencies.
12 In addition, the design itself had some serious l 13 limitations in that the proposed facility could impose 1 14 serious restrictions to gathering sufficient data for site l 15 characterization and also for the repository design. ! 16 So it appeared to us that the ESP layout would I j 17 require some major revisions to satisfactorily address the 18 staff's concerns raised in the SCp. f. ' 19 MR. MoELLER: Now you are going to show us that 20 these particular problems have been resolved? 4 21 MR. NATARAJAt Have been addressed adequately. 22 AR. MoELLER: or have been adequately addressed, 23 okay. l 24 MR. NATARAJA: The next Vugraph No. .8, I'will very 25 quickly go over this one. There is no reason to spend a lot o. !D-ANN RILEY- & ASSOCIATE?., Ltd.
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1 i j 1 q 33 I ) 1 of time on this particular Yugraph, because I am going to go
- 2 over each one of these.
I 3
- 3 As you can see, there were a total of six bases.
4 We also had a number of comments and questions that i 5 supported these six bases points. We are not going into 6 that level of detail in today's presentation. We are only 7 going at a broad level to say how these six bases points are 8 addressed in the resolution. 9 Vugraph No. 9 talks about the first basis point. ] 10 This deals with the Performance confirmation Program, the 10 l 11 CFR 60(f), which deals with the Performance Conformation 12 Program, and alludes to the possibility of conducting in i 4 13 situ risk package testing and in situ seal testing. l 1 14 There is a need for considering some early inputs 4 15 to the license application from such testing, but the staff 4 16 review showed that the ESP design, as presented in the SCP, 17 did not address these issues adequately. That was our first i 18 basis point. 19 Vugraph No. 10 talks about the second basis point. { 20 MR. STEINDLER: Excuse me.- Can I go back to No. 9 21 for a minute? 22 MR. NATARAJA: Sure. 23 MR. STEINDLER: One of the interesting aspects of 24- the relationship between the site characterization program 25 and plan and the DOE objections is that, as the site 'O ANN RILEY & - ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950-
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! ) 1 1 ! 34 1 characterization plan changes and not by just renaming 2 things from shaft to study, but also actually doing things [ j 3 differently, the objections of the staff don't seem to keep - l 4 track. l 5 For example, has the staff thought about whether ; 1 6 or not in situ seal testing remains a valid commentary, when { the whole geometry of this exercise has been shifted? 7 l lj 8 MR. NATARAJA: Yes. The seal question will remain i 9 whether the entry openir.g is vertical or-inclined. That ! 10 will not change. I 11 MR. STEIl*DLER: bot ! AL 33 .sn shown that doing 1 i 12 the kind of in situ seal tectJ ..;, is oven a sensible thing to ! 13 do?
-14 MR. NATARAJA: The question of in situ seal 15 testing has to do with the selection of materials and the 16 long-term impacts of seal performance.
17 MR. STEINOLER: Right. 18 MR. NATARAJA: And that is a question that will be 19 valid regardless of what geometry we have for the ESF. ' 20 MR. STEINDLER: That is almost exactly my point.
-21 Why is it that the staff' required in situ testing in the 1
- 22 first place?
- 23 MR. NATARAJA
- Either theylhave to perform in situ 24 testing or demonstrate and-make a case that is not required.
I 25 We did not see either one of those in the SCP.- O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, _ N.W., . Suite 300 , Washington, D. C. 20006 l(202): 293-3950 :-
35 1 MR. STEINDLER: You gave them the option? l 2 MR. NATARAJAt They have the option. 3 MR. STEINDLER: They do? 4 MR. NATARAJA: We don't have to give it. l 5 MR. IIINZEt Raj, my recollection from these items 6 is that there was a concern raised regarding the possibility ' 7 of gullying as a result of crosion on the east side of Exile 8 Hill, as it might affect the portal and the sealing of a 9 portal. lias that been adequately taken care of in your 10 view? 11 MR. NATARAJA: The location of the shaft has been 12 changed. 13 MR. HINZE: This wasn't a shaft. This was a im 14 portal that was on the east side of Exile Hill. 15 MR. NATARAJA: I don't know. We only raised that 16 question with respect to the shaft location in the SCP. We 17 didn't have a comment related to that. 18 MR. HINZEt in the original design, there was the 19 possibility of a portal on the east side of Exile Hill, and , 20 my recollection was that you were concerned about it at that 21 time. 22 MR. NATARAJA: Was that part of the repository you 23 are talking about or the ESF? 24 MR. HINZEt Yes, the part of the repository. 25 MR. NATARAJA: This was confined to the ESP, the O) L. ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C, 20006 (202) 293-3950
l j 36 1 objection was, and not talking about the repository. f 2 MR. HINZE: I see. But if it was a concern in the i j 3 repository, why isn't it a concern in the ESF? 4 MR. NATARAJA: The objection was on the ESF and 5 not on the repository, but if that question has been raised, i 6 that will be an open question that would be looked at again. f 7 There are a number of comments and questions, which are ! 8 still open. The one that you just mentioned might be one of 1 9 those. l i 10 I have to go back and look at that. Do you have . ) i 11 the number? 12 MS. ABRAMS: Seventy-two. It is Comment 72. i 13 MR. NATARAJA: Yes. That is probably still open, O 14 anyway. 4 15 MR. HINZE: No, that-is resolved. , 16 MS. ABRAMS: It is resolved. 17 MR. NATARAJA: It is resolved?- 18 MR. HINZE I guess I~am concerned about why it
- 19 was a concern regarding the repository and then resolved for i 20 the ESP with a portal design. >
4 ) 21 MR. NATARAJA: We have not reviewed the portal 22 - design or the Title II design of the ESF. So it might come I 23 back again. We have not reviewed the ESF Title II design-in l 24 resolving lifting this objection. 25 MS. ABRAMS: We can.also reopen any comments based O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters i , 1612 K. Street, N.W., Suite 300 . Washington, D. C. 20006 (202) 293 3950
4 ] 37 on new information. 1 i 2 MR. HINZEt There was a concern about gullying on j 1 l 3 the east side of Exile Hill. That seems to be very 1
- 4 appropriate to continue that unless it has been taken care 5 of somehow or another in their design procedures.
j 6 MR. NATARAJAt Now we are on No. 10. 7 In response to the staff's earlier criticism of 8 the ESF Title I design, the' doe presented a document known 9 as DAA, Design Acceptability Analysis. 1 10 The purpose of this document was to explain why 11 the Title.I design as presented in the ScP was acceptable. 12 However, the DAA, both the document itself and the process
- 13 used for its preparation, either did not adequately address j 14 the staff concerns or raise some new concerns, i
j 15 For example, some of the technical reviewers who 16 performed the peer reviews were themselves involved in the 17 preparation of the documents. . So this raised some questions i 18 about the independence of these reviewers. 19 We also found some deficiencies in the 20 thoroughness of the reviews. For example, we picked up some
- 21 of the reports that_were reviewed by the peer reviewers and 2 2__ _found that some errors were left there unchecked, and we 23 also found that the 10 CFR 60.21(c) (1) (ii) (D) -- that is the 24 adequate for alternatives -- we found that there was not an 25 ader;aate consideration of these comparative evaluations of
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! 38 1 alternatives to major design features that are important to ! 2 waste isolation.
I
- 3 We also found that a known anomaly, which existed 4 close to the proposed shaft location, was not considered in 5 their design. So these were some of the concerns either
] 6 which were new concerns raised when we looked at the DAA or j 7 some of the existing concerns which were not addressed i 8 adequately. i j 9 MR. HINZE Raj, if I may ask, the last item i l j 10 there, does this mean that this is acceptable now because - 11 the shaft is no longer a part of the ESF, or is it because 12 the staff has accepted the -- l 13 MR. NATARAJA: We are looking at how they address i + 14 these concerns. If they detect something, what do they do 15 about it? How do they follow it? Do they have a process to f 16 take into account these anomalies? That is all we are 17 looking at right now, and we are convinced tht.b they do. i 18 MR. HINZE: Does this, in any way, indicate that l 3 19 there is not a fault at the shaft location? Does it 20 indicate that at all? 21 MR. NATARAJA: No, we are not talking about that I 22 at all. 23 MR. HINZE: I just wanted to make that clear. 24 okay. 25 MR. NATARAJA: We are now on Vugraph No. 11, the 4
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u i ! 39
) 1 Basis Point 3.
i( 1 2 An important consideration in planning the 3 underground test facility is to make sure that there is I i 4 enough space to conduct all the required tests for the i j 5 durations of interest and that these tests do not interfere 6 among themselves or with the construction activities. 1 7 However, the ESF, as presented, in the SCP raised j 8 numerous questions regarding these issues. Most of these j 9 questions were either not addressed or_ insufficiently 1 10 addressed. i 11 For example, the calculations showing thermal l l 12 zones of influence did not account for appropriate test I 13 durations. Some of these tests would potentially continue i 14 into performance confirmation periods, but they only looked j 15 at maybe, like, 12 months or 18 months, some limited
- 16 durations in calculating the zones of influences.
- 17 Also, the uncertainties coming from some of those 18 numerical models and calculations were not factored in 1
- 19 appropriately. They took the same test space and proposed i
20 this space to be used for different tests that would be 21 performed in some sort of a sequence, but the SCP did not 22 provide the rationale behind these decisions, how they-would j 23 be able to do these tests in-the same space. 24 They did not list some of the required tests, and 25 the information was quite sketchy in many areas. So we () ANN RILEY_ & ASSOCIATES, Ltd. Coud. Reponers 1612 K. Street, N.W., Suite 300 Washington, Di C. 20006
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.i i thought that there was inadequate consideration of some of l 2 these requirements. I i { 3 We are on page 12. We have already discussed this 4 question of this in situ waste package and the seal testing 5 and the potential impacts. Again, it is a repeat of the i { 6 previous concern in a different context. The SCP did not go
! 7 into some of these details. They did not show that the l 8 testing was not required, and if that testing was required, 9 they didn't show what the impacts might be.
4 10 No. 13, Basis Point 5, this was another sort of a . 11 detailed comment related to designs. Some of the ESF design 12 criteria were not sufficiently addressed. One of the { 13 examples was the seismic design basis, and there were 14 calculations of the quantity of water in the bottom of the 15 shaft, the assumptions, and some of the other details there i 16 were questionable, because there was a lot of liability on i 17 the long-term performance of these drainage, where we had 18 several questions about where they would be clogged, whether l 19 they would perform the way they are assumed. ! 20 Also, there was insufficient details about the
- 21 liner removal from the shafts and what they might do to 22 long-term performance.
1 23 The last Basis Point No. 6 was, of course, sort of 24 a very broad concern. The layout of the underground testing 25 and the drifting as presented in the SCP, in our view, did .O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 _(202) 293-3950
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i ) !f ] 41 1 not show much promise for adequate site characterization, l 2 and there remained a potential for gathering insufficient ! 3 data. 4 In summary, although most of these concerns j 5 expressed in the bases points, all the supporting comments ! 6 and questions by themselves may not be very serious as 1 7 individual comments or questions, but when combined and I 8 viewed as a whole, they indicated a trend, and trend of a j 9 flawed process that could lead to an acceptable design 1 j 10 product. That was our overall concern regarding this ESF as i { 11 presented in the SCP. j 12 After the staff posed this objection, a number of
- 13 things have happened. DOE prepared the exploratory studies 14 facilities alternate study, ESFAS, and they have also i 15 prepared the CHRBA, the Calico Hills Risk Benefit Analysis, i
16 but that was in response to an earlier CDSCP objection, the 17 consultation draft objection. l 18 DOE prepared sort of a cross-walk that Charlotte 19 . nentioned in which they showed us how the staff concerns 20 were being addressed in different documents, where and how ] 21 they were being addressed, and we were invited to observe i 22 DOE audits and surveillances. , 23 We were also invited to observe their design 24 reviews at different stages; 50 percent, 90 percent, and so 25 forth.
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i i l J 42 1 We were also invited to participate in the DOE l 2 NWTRB, the Nuclear Waste Technical Review Board meetings, i 3 and during these meetings, ESF design issues were d.acussed 2 4 in great detail. DOE explained during some technical i 5 exchanges how the regulatory requirements were being
) 6 considered and how technical assessment reviews were being j 7 conducted by DOE.
8 So let's now look at the Vugraph 15, which is the 9 staff evaluation of DOE's responses. The staff has l I 10 evaluated the DOE responses to the objection looking at both 11 aspects; the two main concerns, the one related to the
- 12 process, the other one related to the adequacy of the 13 design.
14 So let's first look at the process part. Since 1 15 the objection was posed, the staff has had a number of ) 16 opportunities to observe DOE's surveillances and audits, as 17 I mentioned earlier. During these audits'and surveillances, 18 sometimes the QA staff have been accompanied by technical 19 staff, if the particular topic was appropriate for technical 20 surveillance. 5 21 In general,.the staff found that these audits and 22 surveillances were conducted properly and were approved QA 23 procedures and found them to be acceptable. 24 I am continuing with the design control. process on 25 No. 16. During a technical exchange that was held on O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite - 300 Washington, D. C. 20006 l (202) 293-3950
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i f 43 1 September 16, 1991 that Charlotte mentioned in the j 2 chronology, DOE explained its modified design control 3 process. We found that DOE had in place, documented, and l 4 approved procedures for considering specific design i l 5 requirements. i l 6 For example, the staff had pointed out that 11 j 7 regulatory requirements had not been considered during the
; 8 ESF Title I design. Now, DOE presented the response. They 9 responded by revising the requirements documents to include 10 these 11 additional regulatory requirements.
l 11 In their Waste Management Systems Requirements, i j 12 Volume 4, which is WMSR, one of the acronyms for another QA i 4
- 13 document, these are umbrella-type QA documents which govern l; 14 all the participants of the project, and they also revised l 15 the project level requirements document and the ESF 16 requirements document. All these missing regulations were j 17 now included as applicable for the ESF.
18 The staff's concern regarding the lack of l 19 integration of technical data was also addressed during the I 20 technical exchange. DOE explained how that technical 21 support document management plan, what they call TSDMP, and 22 the RIB, reference information base, addressed this 23 particular concern, and DOE provided examples of how this 24 particular process is supposed to work. ! 25 The concern relating to the geophysical anomaly O ANN RILEY & ASSOCIATES, Ltd. Court Reporters . 1612 K. Street, N.W., Suite ' 300 Washington, D. C. 20006 (202) 293-3950 { .. ._
44 1 near the location of the shaft was addressed by performing l 2 an assessment review as per quality management procedures, j 3 and recommendations were entered into what they call CRS, i 4 the common response status relation database. 5 Technical assessment review, recommendations were-6 also entered into the ESF design requirements. So the staff
- 7 found these actions to adequately address our concerns as i
4 8 far as the design control process was concerned. It does 9 not mean that what they have done is good or bad or 10 anything, but we do know that there is a process. 1. j 11 Earlier we had a suspicion that the process was i 12 not working, but now we don't have that suspicion any more 13 about the process. l i 14 Vugraph 17 basically concludes saying that we are l 15 satisfied that the Title II design activities are now being l l 16 performed under an NRC-approved QA program. 17 Now let's look at the second part of the concern, l l 18 which has to do with the acceptability of the Title II l 19 design. So we are on No. 18 now. l l 20 As a result of our limited review of the pertinent ! 21 portions of the exploratory shaft facilities alternative 22 study, the-CHRBA, and particularly looking at the current l l 23 preferred-option, the staff has found that the doe has , 24 addressed most of the concerns raised by us in the SCA 25 objection, at least -in a conceptual way. I I O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612. K. Street, N.W., Suite 300 Washington, D. C. 20006
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i ! 45 1 One of the major issues raised by us related to i 2 the consideration of alternatives. This was a big, big 3 deal. We were making a big issue about the fact that they J i 4 did not look at the alternatives. 5 Now, the current approach explicitly considers
- 6 alternatives; for example, alternative modes of entry such 1
7 as shafts and ramps; alternative excavation techniques, such l 8 as boring machines; and several other mechanical excavation 4 l 9 techniques; plus the conventional drill-and-blast 10 techniques. 3 11 DOE also considered alternative locations for 12 entry. Alternative repository design concepts were 13 associated with each given option of the ESF. So, for a 14 given ESF, there was an associated conceptual design of the 15 repository. So, in other words, they looked at a number of 16 possible options. 17 They Lise looked at a number of different test . 18 strategies, like different levels of testing, two or four 19 different levels of repositories, and how to gather data, 20 and different layouts for the drifting, and different 21 extents of drifting. 2.2 So, with the new approach, the proposed approach, 23 we also see that the in situ waste package testing as well 24 as the early seals testing can be conducted, if they-so 25 desire. They are not precluded. O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1812 K. Street, N.W;, Suite 300 Washington, D. C. 20006
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4 I 46 f 1 If you remember, I mentioned that, in the previous l 2 approach, N9 had many concerns that such in situ tests might 1 l 3 have been totally precluded because of some other design 4 ' 4 deficiencies and limitations. I 5 We will go to No. 19. We also found that the I 6 proposed option has a better potential for gathering ! 7 adequate date for site characterization and repository 8 design. f 9 As you can see, there is an increased stage of l 10 drifting. Now we have something like seven out of eight 11 times the originally proposed drifting. It used to be about 12 10,000 feet. Now it is about 76,000 feet. 13 These drifts will intersect major geologic i 14 features and provide data on these,-and we hope this
- 15 information will be available in the license application.
4 16 The concern related te the test interference was J 17 one of the big concerns in the design limitation. There 18 were tests which were too close to each other, and there . 19 vere tests which were located too close to'the construction 20 activities, and, thereby, which might impact the tests and 21 the test data. 22 Now, they address this concern by practically 23 doubling the main test level area from 400,000 to about , 24 800,000 square feet. 25 The final point there is that-the preferred option iO ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K.~ Street, N.W., Suite 300
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j i 47 1 has a phased approach. So there is a lot of flexibility as j 2 to which way you want to proceed. You can do as much or as 3 little as necessary. You don't have to overdo it, or you i a 4 don't have to underdo it. You can do it in phases, and you i j 5 can design it in such a way that you can proceed in any j 6 preferable option, in any preferred speed, to gather the 1 7 required data. f 8 So this flexibility was one of the questions that 9 we had raised, and I think the phased approach addresses l 10 that particular concern. 4 ! 11 In summary, we have concluded that the design I 1 12 control process under which the Title II design ESP is being 1 13 carried out is an acceptable one to the staff. ,O 14 Also, we have concluded that most of the bases 15 points discussed earlier during my briefing have been 16 satisfactorily addressed. In other words, the preferred ESP 17 option addr6.2ses in a conceptual manner most of the l 18 important consents raised by the staff in SCA Objection 1. 19 This is based on our review of portions of ESFAS l 20 -- that is the alternative study -- and the risk benefit I 21 analysis and the cross-walk, and we have taken into account 22 the information and knowledge that we-have gained during 23 technical exchanges, observation audits, surveillances, and ! 24 observation of DOE-designed reviews, and also out attendance i 25 at the NWTRB meetings. L LO , ANN RILEY & ASSOCIATES, Ltd. l Court Reporters 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006
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l 3 i 48 1 I an on the last Vugraph now, No. 21. Finally, I j 2 would like to conclude my presentation briefly by mentioning l 3 about our intended future activities related to the review ! 4 of ESF Title II design. f 1 5 As I mentioned earlier, there are some open items ? 6 related to the comments and questions that supported the 4 , 7 bases for SCA Objection 1. We will continue to monitor 8 these open items and continue to evaluate DOE's responses to - 1 j 9 them as and when they become available to us. i 10 Perhaps some of these might be done during a i 11 review of the study plans. i 12 We will also review major design reports that i 13 would be prepared by DOE in support of the ESF activities. l 14 We will provide comments to DOE as appropriate. 1 15 We will continue to observe DOE's design reviews , 16 of different design packages, the 50-percent and 90-percent 17 design reviews. l 18 We will, of course, have a number of audits and i 19 surveillances, and both from the QA point of view as well as 20 from a technical point of view. 21 That is.where my presentation is going to be l 22 concluded. Unless you have any further questions, I will 23 hand you over to charlotte for wrapping up. I 24 MR. MOELLER: Dr. Hinze? i 25 MR. HINZE: Raja, as I look back on our initial i LO
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49 () 1 view of the exploratory shaft facility, it seemed to me that 2 the emphasis there was a study not only of the repository 3 horizon, but there, very definitely, was a major concern 4 regarding wha remains to be a fundamental problem for 5 matrix versus the fracture flow, particularly in the 4 6 overlying horizons. 7 In that ESP, there were breakout zones and 8 critical areas, and there were provisions made for a test to 9 be made as the shaft proceeded down. 10 Does your resolving of this objection indicate 11 that the NRC staff is satisfied that the portal, which 12 obviously has a vertical component as well as a horizontal 13 component, which is primarily a horizontal component, is (O x 14 going to provide sufficient opportunity to evaluate the 2 15 characteristics, the geotechnical, hydrologic 16 characteristics of the overlying horizons, so we can answer 17 some of these very critical questions that remain? 18 MR. NATARAJA: I think this is probably too 19 delicate a question for me, and I can refer to hydrology's 20 staff here. 21 Bill, wculd you like to take a shot at it? l 22 MR. HINZE let me ask a question before you i 23 refer. Is this a proper question at this point in time? We 24 have not heard from the staff on the ESF. l 25 MR. NATARAJA: What I would say is any sort of l() l ANN RILEY & ASSOCIATES, Ltd. Coud Repoders l 1612 K. Street, N.W., Suite 300 , Washington, D. C. 20006 (202) 293-3950
50 1 investigation is not ruled out by this approach. We do not 2 have answers to the questions. But I am saying, using this 3 approach, if somebody wants to do a detailed hydrologic 4 investigation, it is possible to do it, but we don't know 5 the details yet unless we review not only the ESF Title II 6 design, but also their test plan. , 7 MR. HINZEt I was pleased,-and I think most of the 8 ACNW was very pleased with the analysis that was performed 9 by the staff on the SCP. 10 We have seen some major modifications of that, and 11 rightly so, and perhaps the most important is in the change 12 from ESP 1 to ESF 2. 13 I am wondering if the staff is going to take this 14 opportunity to look at whether there should be objections, 15 comments, or questions related to that. Are we proceeding 16 in a fashion, so that we do have the opportunity to provide 17 the same type of analysis that we had in_the SCA, as we have la now with these revisions? 19 one of the cases in point is this one of , 20 evaluating the characteristics of the overlying horizons. L i 21 MS. ABRAMS: We maintain-the ability to provide an j 22 objection to doe at any time,-and we expect to see 23 information in the progress reports that would update the 24 information in the SCP. We expect-to see this at six-month , 25 intervals. l l ' O 1U i ANN RlLEY- & ASSOCIATES, Ltd. - i Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D, C. 20006 r (202) 293 3950
b 4 l 4 51 1 If we see information in a progress report that i j 2 requires an objection, we certainly would make an objection. ) 3 MR. HINZE Or a question. j 4 MS. ABRAMS: Or a question or a comment, yes. j 5 MR. HINZE Are they being reviewed in a timely j 6 and detailed enough fashion, so that that can really be ] 7 done? You spend a lot of time and a lot of effort on the 8 SCA. It was great work. l . 9 MS. ABRAMS: We have a commitment to turn around-10 our reviews on the progress reports within three months i
- 11 Now, the problem in the past has been we haven't received i 12 progress reports in a timely fashion.
13 The DOE is working to improve that situation. In i 14 fact, we have just received Progress Report No. 6, and close i 15 on the heels of that, we are going to get Progress Report 16 No. 7. So they are working to improve their turnaround j 17 time, i 18 MR. HINZE: It raises some red flags to me that I 19 see no objections, that I see no comments. I see no 20 questions, at least that I know of, that come out of these ! 21 updates of the SCP. To me, the break from ESF 1 to ESP 2 is 22 a major break,-and a lot of attributes have been gained by-4 23 that. 24 But it seems to me that my question really is: 25 Has there been sufficient analysis that we can feel ANN RILEY & ASSOCIATES, Ltd.
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52 O g 1 comfortable with the ESP 2? 2 MR. NATARAJA: Excuse me. Charlotte. I might also 3 add that, in our review plan for the review of study plans, 4 also it provides us opportunities for raising comments, 5 questions, and objections. So there are a number of stages 6 in which we can raise an objection if we have a big problem. 7 Of course, comments and questions can be raised at 8 many, many stages. 9 MR. HINZE: If that takes care of the process, 10 could we move on to the question that I asked then regarding 11 does the resolving of Objection 1 tell DOE that you as an 12 NRC staff are pleased with the analysis of the 13 characteristics, the geological, hydrological 14 characteristics of the overlying rock formations? 15 MS. ABRAMS: No. I mean, that is not what the 16 objection really dealt with. 17 The objection dealt with did they have a design 18 control process in place. 39 MR. HINZE: Charlotte, there are some places where 20 there really are questions regarding the studies. I refer 21 you on page 4-2, Item (g). It states that there are other 22 tests that have not been yet completely defined, et cetera. 23 Information has not yet been presented to indicate if any of 24 these undefined tests would be the main test. l l 25 MS. ABRAMS: That got to the test interference f\ b l ANN RILEY & ASSOCIATES, Ltd. ; l Court Reporters 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950
i f 53 1 () 1 question that Raj was talking about. i j 2 MR. NATARAJA: Without knowing what the tests are, 3 it is hard for us to say whether there will be interference 4 or not. It was in that context that we raised that. 1 5 But I don't think the SCP would go into the level i j 6 of detail. The level of detail was only at the 7 investigation level, but to go into the level of detail of j 8 study plans would be inappropriate according to the guidance 9 that we have given to DOE. So we couldn't be criticizing
- 10 them for not giving that level of detail.
11 But the reason for raising that, as Charlotte 12 said, was to make a broader level finding whether or not - 13 there will be some interference. But, certainly, we need
- O 14 those kinds of detail, and we will definitely review those.
15 MR. STEINDLER: I was going to go back to the 16 process, but go ahead, John.
- 17 MR. LINEHAN
- John Linehan.
i i 18 I just wanted to go back over this. We are 19 lifting the ESP objection for two reasons. They have got an i 20 adequate design control process. In a very broad sense, wa 21 are satisfied with the way they are proceeding with the ESF l
- 22 options that they have narrowed down to.
23 There is still a lot of specific questions out 24 there. We have recognized we need to send a letter to DOE; 25 in fact, to tell them, hey, while you have satisfied.our iA l V i ANN RlLEY & ASSOCIATES, Ltd. l Coud Repoders 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293 3950
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~( ) 1 concerns at the general level, we have lifted the objection.
i 2 You are heading in the right direction. There are still a i 3 lot of details that we have to worry about and we have to i 4 look at. l 5 In July of 1989,-doe indicated that, as they i 1 6 proceeded, they were going to be sending to us packages for 7 the various designs. While we want to see those and we want 8 to review them, we have recognized that we will need a 9 revised conceptual design, like we had in the SCP to make j 10 sure that we can answer all of these various questions, like ' 11 the ones we had on the original SCP. I 12 The SCP is a living document, and through the 13 progress reports referencing a document, they can get_us or 1 l 14 revise conceptual design that addresses a lot of these
- 15 questions.
l 16 With respect to things about the hydrology of-the l 17 overlying material, there should be study plans, and those i 1 18 should be integrated with this conceptual designing. There I i 19 is still somewhat of a void there. We have lifted the l 20 objection, but they haven't made -- I would probably term 21 it, they haven't made the SCP totally well, and they still ! 22 need to get this information to us. i '23 MR. HINZE Thank you. This discussion has been ! 24 helpful, and I really wanted to see it put in the proper 25 framework, and I think you have done an excellent job of O ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders l 1612 K. Street, N.W., _ Suite 300 Washington, D C. 20006 (202) 293 3950
55 () 1 doing that for me now. I4t me raise a couple of issues. 2 MR. STEINDLIR: 3 First, Charlotte, you indicated that you maintain the option 4 of issuing additional objections; presumably, based not on 5 the original site characterization plan and its 6,000 pages, 6 but presumably based on the progress reports that are 7 supposed to come every three months on time. 8 MS. ABRAMS: Six months. I l 9 MR. STEINDLER: Six months, yes. l 10 I guess I have a couple of comments. The progress 11 reports that I have seen contain significantly less detail 12 by what I consider to be an important amount than the 13 original format and content of the site characterization O) \_ 14 plan issued ey doe, and perhaps that is appropriate, but it 15 gives me a little pause when that is the document against 16 which you are now going to raise objections, because your 17 ability to analyze the details of why you raise objections 18 and whether or not now is the time to raise it in the 19 particular issue seems to me has been significantly fuzzed 20 out to be able to do that with the same kind of precision as 21 you did in the SCA. 22 The second point that I would raise is that the 23 original Objection 2 dealt, in part, with the quality 24 assurance issue. It was a process that you objected to that 25 either wasn't there or it was inadequate. Yet, the quality Q V ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
56 1 assurance program objection, one, was closed out as being 2 apparently satisfactorily resolved by DOE's QA program. < 3 If that is, in fact, the right interpretation, I 4 draw the simplistic conclusion that you folks closed out 5 Objection 1 too fast. Is that the right conclusion to draw? i 6 MS. ABRAMS: We would agree, there has not been 7 sufficient information in the progress reports, and we are 8 on record as telling DOE that. 9 They don't have to include all the information and 10 data in the progress report itself. They can do it by 11 reference to other reports. We haven't seen that, and we do 12 agree with you on that. 13 We also expect to see a certain level of detail 14 and study plans, and we, as Raj said earlier, can issue 15 objections on the information in the study plans. 16 MR. NATARAJA: I was going to say that the QA 17 objection when it was closed, we gave them three reasons. l l 18 There were three bullets. 19 One of the bases for lifting the objection was j 20 that we were satisfied that there was a design control 21- process in place. So the part of this objection ~was sort of 22 subsumed or contained in the other objection,'also. It-is ! 23 related, except that we were monitoring this particular 24 objection separately, because it was related to the' design l 25 control, because the two were so closely related. 1 O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 . (202) 293-3950
J l l 1 i l 57 .r
- \ 1 We had a problem with the design, and we thought i
2 that this might be the result of a-poor process, which was j 3 also being mentioned in the QA. They looked at the overall -
- 4 QA program, and they were satisfied that there was a QA i
i C program in place. l 6 They also looked at the design control process as t 4 7 a part of both the objections. So, even though
- 8 timetable-wise it came earlier in the calendar, the design 9 control process part was being looked at even as a part of l 10 the lifting of quality assurance objection.
- 11 MS. ABRAMS
- The QA staff through the observation 12 of DOE audits will be looking at the implementation of the-
,, 13 design control process, and, in fact, so far through one
\- 14 audit, they have seen examples of that implementation.
15 I don't know if that gets to your concern or not i 16 about your comment about resolution too soon, but -- 17 MR. STEINDLER: It is more an observation tha". l 18 anything elso, because I think the point may now be 19 academic. 20 The notion, however, that you accept a quality j 21 assurance program that is adequate for the purposes that l
- 22 you, as a practitioner or as a practicing reviewer have to i.
23 use, is-based on a large amount of faith, which it turned 24 out in this case was not quite well -- at least not timely 25 enough taken. That was my only point.- O ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
A 58 ( O) 1 The other issue that I would just raise by way of 2 a comment is that, in the last Progress Report No. 6, which 3 is sitting in front of me here, I tried to extract out of . 1 4 that in a fairly straightforward and simple way what they ! 5 are doing in the ESF, and let me tell you it is scattered 6 throughout this document, and I am not sure that I cr als 7 pull it all together without being a specialist in tho 8 business, which I am not, which may be ckay for you folks 9 who live with this thing every day who know eaxctly what you 10 are looking for, but I found it a difficult reading 11 exercise. 12 It seems to me that, coupled with the lack of _ 13 detail, ought to prompt you to, again, raise the issue a kl 14 little more vociferously with the DOE, perhaps identifying 15 for them the kind of thing they ought to be putting into 16 these progress reports. 17 MR. MOELLER: Dr. Pomeroy? 18 MR. POMEROY: Help me out a little bit. Your 19 Basis No. 5 for the objection, your first bullet says that 20 some ESF design criteria are not adequately addressed, 21 including the first sub-bullet, which is seismic design 22 basis. 23 I understand, I think, that what you have said 24 here is that, based on some process -- you haven't said 25 anything about the seismic design baGis. All you have said s (<~'J ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
59 () 1 is that the criteria for establishing those design bases are-2 now adequate, and it is on that basis that you have said 3 that this -- I think you have said all of these bases, 4 including No. 5, are now resolved. 5 MR. NATARAJA: No. Actually, the seismic design 6 comment is still open. Some of these comments have been 7 pushed to another side. But the seismic design basis is 8 still open. 9 MR. POMEROY: What comment is that? Do you have
'10 that offhand?
11 MR. HINZE: Question 58. 12 MR. POMEROY: Fifty-eight. 13 MS. ABRAMS: Actually, there is a Comment 121, i 14 too. SCA Comment 121 remains open. 15 MR. POMEROY: I will accept that, but I still have 16 a problem. You are saying that this has not then been 17 adequately addressed, because you are holding open the 18 issue, and, yet, you say that you have resolved the basis?. 19 MR. NATARAJA: What we did was when we pulled up 20 this objection together, we not only looked at the broad 21 concerns, but we also looked at any supporting comments and 22 conclusions that might go to enhance or make a bigger case 23 for us to be able to pose the objection. 24 So, in doing so, we put1together any comment that 25 had anything to do with the-ESF. It so happened that the O ANN RILEY & - ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 ; Washington, D. C. 20006 (202) 293-3950
1 i. I i 60. j a () 1 seismic design criteria was also related to the ESF. I You know, 2 would say this, by itself, is not a big deal. l j 3 that is something that can be handled by making this ] 4 comment, and they can go back'and give us the seismic design I i 5 criteria, and we can review it, and that will be-the end of 1 l 6 the story, I i 7 But I was trying to explain to you how we got that; i l 8 as one of the bases points. 9 MR. POMEROY: Yes. 10 MR.-NATARAJA: There were a number of little j 11 things that added up and said, hey,-here is something. When 12 you put it altogether,'it shows a very big concern. l-13 There could be several opportunities for us to l_
- E U- 14 review this particular issue later on.
15 MR. POMEROY: Certainly, I agree with that. I
- 16 I-guess I am concerned, have you received any 1
17 information from DOE that would help you.in addressing that [ 18 particular question? l i, 19 MR.-NATARAJA: No, not really. I don't think.the 20 ESF design has gone to that level yet, i 21 MR. POMEROY: No,.I' don't either. In fact, I know l
- 22 they haven't.
23 Thank you.
- 24 - MR . MOELLER
- I wanted to-comment on several 25 things, because I find the process troubling. l O ANN RILEY & ASSOCIATES, Ltd.
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i 61 () 1 John Linehan has said to us that, on the basis of $ 2 NRC's observations of the broad approach being used by DOE, 3 you feel confident that objection No. 1 can be resolved or i j 4 is withdrawn and is resolved. 5 Then, though, when we look back on what the two of 6 you have said to us this morning, you find that your 7 confidence that the comments and questions and so forth 8 underlying objection No. 1 -- your confidence that those 9 things have been resolved is-based on audits, observations, i 10 surveillance, and so forth. It is not really based on 11 written documentation, or that is the impression I receive. 12 Let's just look at a few here that I read, which 13 trouble me. I say trouble me in the sense of the lack of 14 thorough documentation of what you are doing. ] ! 15 Comment No. 57 says, and I am quoting, "NRC's 16 review of DOE's response to the SCA recommended that 17 progress toward resolution of this comment would require DOE 18 to submit study plan 8.3, et cetera. This study plan _has i l 19 not been submitted. The NRC staff considers this comment < 20 resolved." 1 21 I have trouble with that. It is contingent upon i l 22 them submitting it. They didn't submit it, but it is.
- 23 resolved.
24 ELet me just go on.. Go to-Comment 72. It says, 25 "The SCB did not include analyses to evaluate the need for [()
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i I 62
!O 'd 1 seals and repository shafts and ramps. The NRC staff j 2 recommended DOE plan at sealing program on the basis that
, 3 seals will be needed." ) 4 Then the second bullet says, "Although no details 5 of the seal tests are provided in the ESF FAS, the 6 information provided by DOE indicates that DOE considers 7 that seals may be required." So they have sort of hinted 8 they may be required, so this comment is resolved. ] i 9 See, I don't hear them saying positively they will 10 be used or not, but I hear a bottom line that the comment is l 11 resolved. 12 MR. NATARAJA: Can I address that? That made an i l 13 assumption that it is not required in the original SCP. I 14 mean, at least that is the impression we got is that the 15 seals are not required. l 16 But now that I am reading that seals may be 17 required and then they have provisions for performing seals 18 tests if they are necessary, in the original plan, we had 19 the question whether they would even perform seals tests.
- 20 Now, we don't have that question anymore, because 21 they have been listed as required tests that can be 22 conducted. They have the space to conduct it. Their scheme 23 allows them to conduct it. There is a' recognition-that it 24 may be necessary. That is what we are looking for.
25 Now, we will~1ook at whether or.not.they are going ANN RlLEY & ASSOCIATES,.Ltd. l Court Reporters 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 i (202)_293-3950
1 . i 63 1 to do it when we review the actua) test plan. 2 MR. MOELLER: Okay. That didn't come through to j i 3 me. l j
- 4 Comment No. 128 says that several applicable Part i
1 l 5 20 requirements have not been considered in the ESF Title I i j 6 design. Then you resolve it by saying the NRC staff j 7 proposes to evaluate whether or not design criteria based on , 8 Part 60 requirements have been developed when you review the 9 Title II design. l j 10 So you are postponing it from Title I to Title II? 11 MR. NATARAJA: Again, it is the same situation. b 12 They had not even included them as applicable to ESF. Now 13 all the requirements documents list them as applicable to 14 the ESF, and, therefore, we sort of trust that they are 15 going to include this in their concentration of the detail . 16 of Title II design, and that is what we are going to verify i 17 when we actually review the Title II design. 18 MR. MOELLER:' Actually, you have, in a sense,
- 19 resolved Comment 128 by moving it to Comment 130.
, 20 MR. NATARAJA: Right. j 21 MR. MOELLER: It would have helped me to have had 22 -- and maybe-it was somewhere and I missed it -- to have had-23 a chart that said 56, 57, listed each one, and then told me-
- i. 24 exactly _the cases in which the resolution was accomplished 25 by shifting ~it somewhere else.
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2 i 4 a l 64 1 Now, to go to your last bullet under 128, and I-l 2 just couldn't understand the English, "The NRC staff 3 recognizes that this comment is a special case of comment l
! 4 130. Therefore, it will be tracked together with more of 1
8 5 that general comment." Obviously, some words or something i 6 were left out. 7 But now, one that really troubled me'is Comment-l 8 132, and it says, "The requirements of 10_CFR 60," and so i ! 9 forth, "in particular, have not been adequately addressed in i 10 the Title I design." l 11 Then your second bullet of your response, the 12 second sentence says, "The original SCA comment noted that 13 the-requirements..were not adequately addressed. However, 14 the consideration, description, and evaluation of major l 15 design features" -- probably should have said - "are i l 16 contained in the ESFAS." i 17 In other words,-the way.I read-it is you are l_ 18 almost like a teacher, and-I see myself doing this as a I have a student that I know is smart, but'he or-
~
19 teacher. l 20 she didn't really do-too well.on this exam. So I-sort of i- 21 hunt for the right answers to-.give-them_ credit for_it. l l 22 You say doe didn't respond, but by_ hunting around,
- .23 you-have.found what-you are.looking for, and_so you are 24 going to give them. credit _for it. That is the way-I read I -
25 it. O ANN RILEY & ASSOCIATES, Ltd. Court - Reporters: 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 l _(202) 293-3950-
1 j 65 () 1 MR. NATARAJA: They also provided a cross-walk, as
- 2 we explained earlier, how each particular NRC comment was 4
l 3 addressed and where it was addressed. So we really didn't 1 4 have to hunt that much, because they told us where it was, i 5 So we could go to that particular -- ! 6 MR. MOELLER: See, I think if I looked only at the 7 written word, I would be unhappy, but having heard about the 8 audits, the surveillances, your technical exchanges, which
- 9 backed this up, then it is a little better.
10 SCA Question 61, your second bullet said procedure 11 PPO 317 appears to be sufficient. So you are going to l 12 resolve it. It appears to be sufficient. It either is or 1 13 it isn't. 14 So my problem, to repeat, and I am fortunately -- I j 15 or unfortunately, I am not involved in that, but if I were l 16 a lawyer or a technical reviewer looking for a good solid l 17 documented written case to back up your action, I can't find ! 18 it. That is my problem. l 19 MS. ABRAMS: Keep in mind, too, this objection was 20 a very difficult one to deal with by virtue of the fact that l 21 we did reference comments and question as bases. 22 Many of the comments and questions alone would not i 23 make an objection by any means. The two major points that 24 make the objection are really in Comment 127 and-the concern 25 about the design control process. The other things were i o (f ANN RlLEY & ASSOCIATES, Ltd. l Coud Repoders 1612 K. Street, - N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950
_ _ - _ . _. . . . - ~ . l 1 66 l 1 added information to document problems with their procecs. ! 2 So, in a lot of cases, we have left the comment open. l 3 Again, if doe shows that they are going to address 4 these requirements, then we have to assume they are at this ] ! 5 time, but we maintain the option if we see they are not, we 6 can produce another corrett. 7 MR. LINEHAN: Dr. Moeller? l l 8 MR. MOELLER: Yes. i 9 MR..LINEHAN: You make some very good points, and l-
- 10 I think what we need to do in the future is, even though 11 some of these things are somewhat open-ended and there has 12 to be follow-up, I think we have to more clearly state why
- 13 at a particular point in time, to-document why we are IO 14 satisfied and why even with the follow-up we can take the 15 action we are taking at this point in time.
l 16 MR. MOELLER: I would accept a statement that says 17 we have had many technical exchanges, observations, audits, i 18 surveillances, and so forth, and also that we have carefully ( 19 reviewed the DOE plan or their program, and we have come to 20 accept their broad goals and the broad way in which they are 21 doing it. On the basis of that, we are withdrawing the i 22 objection. 23 I wouldn't object to that. But you have indicated , 24 to me you are documenting the withdrawal'and that the l 25 withdrawal was based upon documented evaluations of separate O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 ! (202) 293-3950
i 67 l () 1 comments and so forth, and I am not happy with them as they-2 are done. l 3 MR. POMEROY: Could I just follow that concern? I 5 4 think it is very, very real. I guess I am specifically i 5 concerned, for example, if you attended a technical exchange 6 where you have no transcript, where you have no written 7 record, where although other people could attend, they don't i ! 8 necessarily attend, and they can't recover what was said. 1 ] 9 Could you use that as a basis to assist you in closing? j 10 MR. LINEHAN: One of the things that does exist is 1 l 11 when there is a technical exchange, there is a record of the 12 meeting. ! 13 MR. POMEROY: It is not a verbatim record, John. !t 14 MR. LINEHAN: No, it is not a verbatim record. 15 MR. MOELLER: No, but it is written adn signed by i 16 both groups. 17 MR. LINEHAN: It is a written summary. J 18 What I was going to explain is that, if we are i 19 relying on something like this, we would document very well 20 exactly what we felt happened and why we were or were not
- 21 satisfied.
22 It is more of a case of observation of QA audits l 23 and design reviews. Particularly, with the QA audits where 24 they have looked at the implementation of_the design control
~25 process, we write fairly detailed audit reports that support ANN RILEY & ASSOCIATES, Ltd.-
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i 68 1 those. Those, I think, would very well document any l 2 conclusions, any findings we were making. 3 But, again, to someone that is just looking at ! 4 this letter, I can understand without seeing those attached. 4 5 It is not transparent enough what the total record is.
- 6 I think this problem is really confused because of i
d 7 the fact that the ESF has changed. 8 MR. HINZE: That really complicates the situation, l 9 because it is very difficult. It was really critiqued on 10 the basis of a design, which would present in the SCP, and 11 now that design is no longer valid. , 12 MR. STEINDLER: It is altogether different. 13 MR. HINZE: That is right, and that confuses the 14 issue. Right. 15 MR. MOELLER: . I hope I fully appreciate the 16 multitude of comments, questions, subparts that you had to l 17 consider and try to put it altogether. I + 18 I have something else that is confusing, and it is i 19 not your responsibility. But the NRC letters will say we j 20 consider such and such resolved, and DOE will come back, and 21 they will list a whole_ bunch of things. They say we i 22 consider all of these resolved. 23 Good for them. It is confusing for me. { 24 MS. ABRAMS: With respect to that concern, we i 25 intend to inform DOE that the decision on resolution of our 'O V i ANN RILEY & ASSOCIATES, Ltd. l Court Reporters
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a i i 69 l () 1 comments and questions is on our part. That would help 2 MR. MoELLER: Right. Thank you. i 3 a lot. 4 MR. STEINDLER: Can I comment? Perhaps I don't l 5 appreciate the importance attached to this whole process. j 6 Let me rattle off for you some issues that we have raised i 7 from time to time. i 8 You folks went through and analyzed this i i 9 6,000-paged document that was laid in front of you and did, 10 I think, a very commendable marvelous job. There are' lots 11 of open issues and questions -- well, used to be questions, l 12 and heaven knows how else you call them, that were initiated 13 and gradually attacked, or, shall we say, resolved anymore. { 14 What has never been made very clear is who cares, 15 and that sounds a little callous, but let me translate that. 16 I have not seen a sheet of paper from anybody that says it 17 is necessary for the licensing process to have an applicant 18 that has no outstanding comments, objections, or questions. , 19 It isn't even very clear-to me whether or not DOE ? l 20 must, compelled by something, answer all'of these things. , 21 We have raised that question from time to time, but that 22 issue, I think, remains open in some fashion or another. ! 23 So I guess I view'that in the same category as I 24 view the general notion of mandatory filing and approval by I 25 the staff of study plans. It seems to me that the process l
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4 I 70 () 1 is a lot more permissive than that. It seems to me that DOE l 2 has the option of proceeding.without a resolution of i
- 3 objections, of proceeding without the filing of a study 4 plan, of proceeding, having filed a study plan, without 5 resolution of any objections you might have to the study 1
6 plan at DOE's own peril; namely, you can come back later in j 7 the licensing process and say, " Fellows, you didn't do it j 8 right. You didn't do what we asked you to do. We told you ! 9 it was bad, and now it is really bad." i 10 Now, if that is correct, what that does is it 11 throws the burden of technical analysis of their action back 12 on DOE. If all of that makes sense,-and I haven't strayed i 13 from the correct path, then I view the resolution of 14 objections as useful for trying to minimize the twists.and 15 turns of a scientific or technical investigation that really 16 plows new ground; namely, more heads are better than fewer, 17 but that is it. That is the only important I can attach to 18 this with'an eye toward the licensing process. l 19 It is a risk that DOE, it_seems to me, has the 20 opportunity to'take if they so elect. That risk, if they 21 come out'right, is fine, and it doesn't have any' negative 22 consequences. If.they screw it up because you, in fact, had ! 23- a valid point here or there, then they have to take their 24 lumps in 1998 or 2001. i i i 25 MS. ABRAMS: 20004. I lG\- t ANN RILEY & ASSOCIATES, Ltd. l Court Reporters l - 1612 K. Street, N.W.=, Suite 300 l Washington, D. C. 20006 l (202) 293-3950
71 4 O) (, 1 MR. STEINDLER: Is that a rational interpretation? 2 MS. ABRAMS: We are on record as saying that the
- 3 comments and questions, if not resolved, may result in a 4 less-than-complete license application. So DOE does run 5 that risk if they do not resolve our comments and respond to 6 our questions.
7 Now, DOE did commit, as I said, to resolve their i 8 objections prior to starting work in that particular area. 9 That is not true for comments and questions, but, again, 10 they do run a risk. 11 MR. STEINDLER: The point I would be driving at is 12 while it would be useful to have a reasonably coherent 13 recoverable record, independent of the persons who wrote it, 14 of what actions you folks took and what conclusions you came 15 to, that somebody 10 years from now might be able to 16 recover, it isn't obvious to me that that is a compelling 17 aspect of the licensing process. 18 If it is, then I think John is exactly right, and i l 19 Dade's point is very important. One really needs to have a 20 complete and recoverable record, if the resolution of your 21 questions and objections can become a part of the licensing 22 process. 23 MS. ABRAMS: We are putting in place what we call 24 an open item tracking system. This is a computerized system 25 in which all the SCA comments, questions, objections will go l l (~'r iV ANN RlLEY & ASSOCIATES, Ltd. I Coud Reponers 1612 K. Street, N.W., Suite 300 ( Washington, D. C. 20006 l (202) 293-3950
.i i. 72 1 and, actually, are being put into as I speak, and also all 2 study plan concerns and any other comments, questions, or 3 objections that we would have on any DOE report in the 4 future.
- 5 The system requires that the staff track these
- 6 concerns and give the various milestones on how we are 7 dealing with these. So there should be a trackable record 8 for all of these items.
9 MR. LINEHAN: The important thing, though, is the 10 tracking system, while it does give us this status, say, how l 11 we close something out, I am not sure it gets to this 12 question of documentation as far as clearly laying out what i 13 you looked at, what you reviewed, why you chose to close it iO l 14 out, what the technical basis was. 15 We are recognizing this in the program. We just t i 16 took action recently to revise a procedure we have for trip 17 reports. We had folks going out into the field, and, in 18 some cases, we would get a two- or three-paged report.that 19 said we went to all these' locations, observed a number of i i 20 things, and then, six months later, they would say, hey, we 21 -are going-to close out this partly based on what we saw. j- 22 We are trying to get them to lay out very clearly 23 where they went on the trip, what they saw, what the i 24 significance of it was to our open items. These are points 25 that I think we are better appreciating ourselves within the lO L ANN RILEY & ASSOCIATES, Ltd. i Court Reporters
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73 1 division, and we are trying to take actions to make sure 2 that documentation is there, because, indeed, if this is 3 going to be relied on -- in the licensing process, anyone 4 can open up these issues again, and if there is not a clear 5 record of exactly what we did and why we did it, it is 6 questionable what the ultimate benefit of this whole 7 relicensing will be then. 8 MS. ABRAMS: Dr. Steindler, I would also say that, 9 in our study plan reviews, we go back. The staff goes back j 10 and look at what SCA concerns are applicable to that 11 particular study plan. 12 MR. STEINDLER: Sure. 13 MS. ABRAMS: So there is a follow-up there, too. 14 MR. STEINDLER: Thank you. , 15 MR. HINZE: Then the technical review is performed I l 16 on those study plans? . 17 MS. ABRAMS: The technical review is performed on 18 those study plans. Now, we do not close those comments or 19 questions unless DOE particularly requests closure. They l 20 have to request and direct us to where the information would 21 be provided. We do still look to see which ones are 22 pertinent. l 23 MR. MoELLER: Paul or Bill, did you want to ask 24 about the fact that it is not clear in NRC's review why the 1 25 setback distance from faults was not considered important? ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
f 74 1 MR. POMEROY: I think we do know the answer to i 2 that. 3 MR. MOELLER: Fine. b . ! 4 MR. POMEROY: We have a separate setback technical 5 position, which says that there isn't a setback required. 6 You can, in fact, site the repository on faults at your own 7 risk, if you satisfy certain conditions. ! 8 MR. STEINDLER: At whose risk? j 9 MR. POMEROY: At DOE's risk. l 10 MR. STEINDLER: That is a strange way to put it, 11 isn't it? 12 MR. POMEROY: No. l 13 MR. STEINDLER: No? 14 MR. HINZE: The ESF is really designed and a very 15 major part to it. I 16 MR. POMEROY: It is really there. 17 MR. MOELLER: What do you need from us? Is this i 18 just a discussion or do you need a letter? l i 19 MS. ABRAMS: We don't need a letter. This was for i
- l 20 your information to update you on what we are doing.
4 21 MR. MOELLER: Are there any other comments or.
- 22 questions from anyone on this topic?
p 23 (No response.] 24 MR. MOELLER: Hearing none, then-let me thank you 25 for coming down and meeting with us. ; l .O ANN RlLEY & ASSOCIATES, Ltd. 1 Court Reporters , 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 l
j 75 () 1 With that, I will declare a 15-minute break. 2 (Recess taken from 10:30 a.m. to 10:47 a.m.) 3 MR. MOELLER: The meeting will resume. l 4 The next topic on our agenda is the results of the i 5 geological cross-section balancing activities. i
- 6 Bill, did you want to comment?
7 MR. HINZE: No. ! 8 MR. MOELLER: All right. We are going to have a j 9 briefing on this, and I see we have a team here, Ron Ballard i and Keith McConnell. 10 4 11 Ron, will you be introducing it?- 12 MR. BALLARD: Yes. ! 13 I am Ron Ballard, Chief of the Geology and i./"3
- k-) 14 Engineering Branch, and in keeping with a pattern we have 15 established, I will briefly introduce the presentations by 16 describing in general terms how this modeling effort fits
- 17 into our program.
1 ! 18 I will be followed up by Steve Young of the 19 Center, who is the technical lead in adopting geometric ! 20 modeling techniques to Yucca Mountain repository block. 21 I would like to add-that Gary Stirewalt has been 22 working very closely with Steve, to my understanding, on 23 that, and I am sure Steve will cover that.- 24 Also, though the name isn't on the handout 25 package,~Keith McConnell, next to me, is Section Leader of O ANN R! LEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, - N.W., Suite 300 - l- Washington, D. C. 20006 l o (202) 293-3950
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i i 76 1 the Geology and Geophysics Section and is the key staff 2 2 player in the program that supports this particular effort. 3 If we could go to the objectives Vugraph, I would i 4 like to say that today's briefing -- l 5 MR. MOELLER: Do we have this? 6 MR. BALLARD: Don't you? I assumed a~ handout had i 7 vent to you. I will stand by for a second. 8 MR. MOELLER: Thank you. 9 [ Pause.] 10 MR. MoELLER: You might note that this delay is a 11 clear indication of our need-for additional staff, i 12 (Laughter.] , 13 MR. BALLARD: We will go on to the objectives C 14 Vugraph that is in your handout. 15 This briefing is somewhat different than those 16 that I have been introducing to you during the last year. 17 It is designed to give you some perspective on the work that i 18 the Center-is doing for us in the program area ~of analysis, i 19 methods, and development. i 20 The primary purpose of this program is to develop. 21 analytical tools that can be used by-the staff to' address 22 licensing-issues for which key technical uncertainties, as 23 identified by the staff, exist. 24 As you are all aware, the Yucca Mountain site has 25 evidence of substantial structural deformation, and the 'O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
i a i l 77 1 geometric model that will be described today by Steve is an i 2 early step in developing our capability to test the validity 3 of structural deformation assumptions that are being 4 developed by DOE at this time and will be coming in on their 1 5 licensing application. ! 6 Another important objective of the program is to 7 develop methods of forward modeling of structure deformation 1 8 in the repository block for incorporation in the performance i 9 assessment models. } 10 We believe that this effort will also be useful in 11 characterizing the repository block for purposes of 12 evaluating the design of safety-related structures, an issue 13 which Raj Nataraja will be participating in. i O 14 If we could then go to the last Vugraph, the 15 planned objectives or planned activities. This is intended i 16 to give the committee an idea of where we are-in the terms 17- of modeling. 18 Prototype testing of the computerized 2D geometric f j 19 modeling approach was completed-back in September of 1990. 20 I believe.that Steve may be able to follow up on this. I i 21 believe this is sort of oil industry techniques that he was l 22 reviewing, and then the initial phase of the application of 23 this prototype work to Yucca Mountain was completed in a l 24 report, I believe, in November of this year. 25 That report, essentially, reflects the material.
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4 I 78 '( 1 that will be presented here today by Steve. 2 Furthermore, this material was presented at the l
, 3 AFCE meeting in August in San Francisco, and I believe Dr.
4 Pomeroy was at that one. So he will be hearing some of l I 5 this, much of it for the second time. J ^ 6 I would like to emphasize, though, that this 1 7 modeling effort is not intended at this stage, anyway, to i i 8 reflect an evaluation of the Yucca Mountain site. It is 1 l 9 primarily a demonstration of a modeling tool that can be 10 used by the staff in evaluating DOE submittals.
- l j 11 To go on, there has also been some work done-in
! 12 this program on developing a geologic framework model of e 13 Yucca Mountain that was applied in the total systems . I
- 14 modeling work, i
i 15 We also plan to evaluate several rock mechanic 16 models in the near future. You will probably notice, as ! 17 Steve goes-through his presentation, that_ geometric modeling l 18 that he will be describing can be useful, certainly, in ] 19 attempting to decipher past processes, but it has some l 20 limitations for purposes of projections into the future. So
- 21 we plan to evaluate these rock mechanics models in the next j 22 year in an attempt to-apply more mechanistic principles to
- 23 deformation processes.
24 Of course, our longer-term projection is for , 1 l 25 three-dimensional models, deformation models, that would be i ANN RILEY & ASSOCIATES, Ltd. I < Court Reporters l 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950'
i i 79 1 most beneficial for performance assessments. That is an < 2 objective, we indicate in the Vugraph in the out years, and 3 it has to await a little more development of the work we 4 have ongoing right now. 5 MR. STEINDLER: Ron, can you, in three sentences, i 6 identify the problem you are solving here? l 7 MR. BALIARD: There are multiple problems. First i 8 of all, DOE is trying to characterize the block, and from 9 that characterization of past quaternary faulting how they l 10 expect this block to perform in the future, at least how the i 11 repository will perform in that block as it undergoes l 12 whatever geologic processes they come up with, i 13 We will have to be reviewing that, adn this is one l 14 of the tools that we are trying to develop in this ! 15 particular program to help us to get a feel for it and an 16 independent view, if you will,-.and then to be able to judge f i 17 DOE's assumptions. j 18 The other aspect of it is we do have the rule, as
- 19 you know, which is a performance objective-structure rule.
j 20 When the rule is developed, I don't think people had in hand 21 just what we really mean by performance assessments, and 22 that, as I believe you have certainly heard Phase-I work on 23 total systems analysis, and those need modules that a 24 represent the block, q 25 So this kind of. work fits directly into that . ANN RILEY & ASSOCIATES, Ltd. l- _ Court Reporters 1612 K. Street, N.W., Suite 300 Washington, _ D. C. 20006
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80 1 activity, too. 2 I didn't attend it, but there was a committee 3 working group meeting yesterday that so.t in on and heard a 4 lot of those things. Some of this work, we have some 5 preliminary inputs that went into that from Steve to form 6 the basis assumptions there, and it is more to refine that 7 approach, too. 8 So, I guess, that is generally the best way I can 9 describe it. 10 MR. STEINDLER: I don't want to delay this thing. 11 But can I assume that what you are looking at is some way to 12 determine the physical properties of the repository area 13 from limited data either from on-site data or obtained in 14 some other fashion or that this is an extrapolation proLlem? 15 MR. BALLARD: Yes, I would say so. Everything 16 that we have done to date, and what you will see to date has 17 been produced by_ DOE data on the site, and that is why I say 18 it is not really an evaluation of Yucca Mountain because 19 they have very preliminary data. 20 It is a system that is set up to be able to 21 accommodate more data as DOE gets it, and we could get into 22 the technical parts of it. I would rather defer to the 23 technical staff for that. 24 MR. McCONNELL: Keith McConnell. 25 Maybe I could add. There are two aspects of the O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950
4 i ! 81 ( 1 problem we are attempting to address with this effort. One { 2 is within the 18-month period that the staff will have to i 3 review the license application. We will have to make 4 judgments about the validity of the conceptual models on 5 structural deformation that the DOE is going to present to
- 6 us. That is one of the efforts.
4 7 The geometric modeling effort that we are 8 attempting to develop will test those models and attempt to 9 validate what DOE presents to us, so that the staff can gain { 4 10 the confidence that DOE is presenting an accurate picture of 11 the deformation. 12 Second, we will also have to judge the scenarios 4 13 that DOE presents to us with respect to the potential for O 2 14 fault displacement or structural deformation within the 15 repository blocks and the consequences of that displacement,
- 16 and that is the second, the more mechanistic modeling 17 activity that we are now starting into is to develop _the 18 methodology to test what DOE provides to us as far as its 19 accuracy of what may happen in the repository and what the 20 consequences might be.
21 MR. STEINDLER: Thank you very_much. That-helps. l 22 MR. MOELLER: It helped very much. 1 23 Could you, though, go back and tie the title of 24
~
this discussion into what you just explained? Where did the 25 title, " Geological Cross-Section Balancing Activities" -- I M
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82
- 1 must admit, that means nothing to me, but what you said 4
2 means a whole lot. 3 MR. BALLARD: I guess I would have to apologize. 4 The title was an early submission to the committee staff, I 5 think, that we probably should have corrected. 6 If you go to the planned activities Vugraph, it 7 reflects the underlying title there under activity, which is 8 the geometric modeling of faulting at Yucca Mountain, and 9 that is the relationship between the two. They are 10 essentially synonymous. 11 MR. MOELLER: You are developing this model 12 yourself independently? g 13 MR. BALLARD: We are developing the methodology. 14 The model itself, the data, is all from DOE. 15 MR. McCONNELL: Could I just follow up? The model 16 we are developing, the data is from DOE. Yes. 17 MR. MOELLER: So, presumably, DOE is doing their 18 own model or something? 19 MR. BALLARD: They are developing a methodology, 20 also. We haven't discussed it with them formally. 21 MR. POMEROY: But, Keith, that is really my 22 question. As we go along here, can Steve or you tie in what 23 DOE is doing, to the best of your knowledge? In other 24 words, I am concerned that we don't -- no one can fault the 25 need for a tool for review. () v ANN RILEY & ASSOCIATES, Ltd. , Court Reporters l 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 . (202) 293-3950 l
1 83 O 1 What I am concerned about is we are not redoing ( ,/ i 2 something that DOE has done in a way that we would judge i 3 adequate and that our efforts are important to us for the
- 4 review process and, at the same time, complimentary and not 4-j 5 necessarily duplicating what DOE is doing.
l 6 So, to whatever extent you or Steve or Gary 7 understand what is happening at DOE, could you leave that l ! 8 into the presentation? 4 9 MR. BALLARD: Yes. I would just add that, first I
- 10 of all, the independent assessment capability is much like 11 performance assessment.
! 12 DOE is doing performance assessments, too. We
- 13 didn't really know. They have just come out recently with j
14 some total systems performance models, but the staff went l i 15 ahead there, too, because we feel that it isn't just worry i 16 about duplicating DOE's effort. We have a rule that we l 17 developed, and we really do need to have some comfort that ! 18 the rule, as written, is an enforceable rule ~and there is a j 19 method available. So we, certainly, do try to avoid any 1 I 20 duplication with DOE, but it is an independent effort at 21 this stage, too. 22 MR.-BALLARD: As I indicated, this is a November- l 23 report. We are=really very early in this effort, and:we 24 will certainly be working with DOE in the form of technical 25 exchanges and all cn1 these issues as they develop a little O ANN RILEY & ASSOCIATES, Ltd.- 4 Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006
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84 () 1 more substantive reports. 2 MR. POMEROY: You might mention where, when, and 3 so forth this might be peer-reviewed or published as well. 4 MR. BALLARD: Steve may be able to comment on that S- on peer review. 6 Oh, I would add one more thing in the form of an 7 apology. The handout that you will get for Steve's 8 presentation, we had every-intent to have color photographs 9 in it. There were production problems, and, unfortunately, 10 the handout you have won't have those in it, but they are 11 essentially in process, and we will be getting them to you 12 very quickly. His presentation will have the photographs, 13 though, for the screen. 14 MR. RUSSELL: I am John Russell with the Center. 15 I want to make it very explicit that the model we 16 are using here are models which have been developed 17 primarily for use in the petroleum industry, and we have not 18 developed a new model in the sense of a numerical code. 19 We have been using data which has come from the 1 20 DOE or any other sources. As-we develop this further, it 21 may be necessary to develop some numeric modeling in 22 addition to what is commercially available. 23 That is not to say-that we haven't developed some 24 different conceptual models. 25 MR. POMEROY: This is a direct use, John? You O ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street,- N.W., Suite 300-Washington, D. C. 20006 (202) 293-3950
85 1 haven't modified that code in any way? 2 hR. RUSSELL: No. It is direct use. 3 MR. POMEROY: Thank you. 4 MR. BALLARD: If there are no more general 5 questions, Steve, go ahead. 6 MR. YOUNG: My name is Steve Young. I am a 7 Geologist at the Center for Nuclear Waste Regulatory 8 Analyses. 9 I want to do a couple of things up front. First, 10 I want to introduce our structural geology group Dr. Gary 11 Stir > walt, who is here in our Washington office, and Dr. 12 Alan Morris, who is Associate Professor of Geology at the 13 University of Texas at San Antonio, and works with us on a 14 consulting basis. 15 In addition to that, I want to apologize that you 16 don't b e copies of the color Vugraphs. I wasn't able to 17 get the made in time. We had to make up a bunch of 18 originals to reshoot. aem. So we will get them shot as 19 quickly as possible a wi get you a package of those things. 20 MR. HINZE: There are more copiec of the report 21 that can be rade available to the committee? l 22 _MR. YOUNG: Are there more copies of-that? We 23 have used-up all of those, all of those reports. We can 24 print some more. l 25 Did each one of you get one of those?. O ANN RlLEY & ASSOCIATES, Ltd.. Court Reporters i 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 i (202)-293 3950--
l 86 1 MR. HINZE No. As I understand it, the totality 2 of the committee just received one. 3 MR. YOUNG: You guys got cne together? You got 4 two? 5 MR. McCONNELL: We will try to get you copies of 6 the report itself, Dr. Hinze. 7 MR. HINZE That would be great. Thank you. 8 MR. YOUNG: We will print some more of those, too, 9 as well. 10 Some of the Vugraphs that I..will show you today 11 are not in that report in exactly the same form. n'e change 12 them, depending on new work, new ideas, that go into that. 13 What I want to talk to you about today is an 14 approach, and this is partially in answer to some of the 15 questions of what are you doing and why are you doing it and 16 why do you use the terminology, why are we using the 17 terminology that we do. 18 You are going to make me hold two things. Good. 19 What we are engaged in here primarily is the i 20 development of sets of methods and an cpproach to
- 21 essentially critically review tectonic models produced in i
22 support of DOE's high-level waste program. 23 In particular, the reason that we are doing that 24 is because we believe at this time that assessments'of 25 geologic hazards, in particular, assessment of eartnquake, O ANN RILEY & ASSOCIATES, Ltd. l I Court Reporters
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87 1 hazards due to earthquake seismicity, ground rupturo, 2 magmatic intrusion and volcanic eruption, distortional 3 strain as a result of fault slip and potential result in ' 4 changes in groundwater flow patterns to the extent that they 5 are related to fracture fabric, we think that interpretation 6 and assessment and conclusions that are related to all of 7 those things are going to be strongly fundamentally based on e tectonic models. 9 Now, some of which will have-a strong conceptual 10 component to them and may not be directly te. stable, there Il are models of deep subsurface faulting. It is very 12 difficult to gather data to prove or to validate those 13 things. O 14 As a matter of fact, there really are only two 15 methods that ere proven to gain you any substantial 16 information at all in those processes, and those are l 17 reflection seismic and drilling. For the most part, key 18 parts of the subsurface fault aystem are outside the l ! 19 drilling range _as well. j 20 But just because some of these key parts of the 21 fault system are deep, it doesn't mean that they don't have i 22 a substantial effect on what goes on at a shallow crustal j 23 level as well. 24 So the reason that we are doing this is to be able 25 to critically review and assess tectonic models produced by lO ANN RlLEY & ASSOCIATES, Ltd. I Court Reporters 7 1612 ' K. Street,' N.W., Suite 300 l Washington, D.- C. 20006 (202) 293 3950
88 1 the Department of Energy, because we ballove that those 2 tectonic models will serve as the foundation for hazard ; I 3 assessment of processes related to tectonics; in particular, 4 volcanism, fault rupture, and earthquake seismicity. 5 Thie u summary of the purpose of the task. 6 Initially, a development of methods for review and 7 assessment was the primary driver. 8 We realized fairly early on that, in order to 9 determine the value or the utility of these modeling methods 10 to asseasment of tectonic models at Yucca Mountain that we 11 are actually going to have to go a little ways down the road 12 of producing some models. 13 So one of the early purposes was to produce somu 14 preliminary models. Ultimately, we want to determine the 15 implications of the geometric models for performance 16 assessment. We have not contributed substantially to 17 performance assessment so far, but we think that, when we 18 get the models to the point where we have some supporting 19 deformation mechanics work done, then we can start and have l 20 enough confidence to contribute in an important way to 21 performance assessment. 4 22 MR. MOELLER: Perhaps you are going to-explain-it 23 later, but earlier we heard from John Russell that you are 24 using these models that were developed by the petroleum 25 industry. O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) -293-3950
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89 ( 1 Now, I don't know cuch about the petroleum 2 industry, but I presume they are not projecting out 3 thousands a year. They are looking at the hear and now. 4 MR. YOUNG: That is correct. But the oil industry 5 throughout its history, depending on how you define this, 6 has been in the prediction business in the biggest way , 7 possible. 8 I will tell you, basically, the problem that we 9 are setting out to solve -- somebody-said this earlier. -It 10 is an extrapolation problem. It is a blank paper problem, 11 and I will show you an illustration of that. 12 We have relatively detailed geologic maps of Yucca 13 Mountain and some pretty good geologic _ cross-sections that 14 have been made of Yucca Mountain. However, the depth to 15 which you can extrapolate information that you measureLat 16 the surface, it is uncertain how far you can ago with that 17 and still be credible and still'have confidence in what you 18 have done. 19 What we have intended 1to do here is to use the 20 methods that have been in use to solve the blank paper 21 problem, to use what we know anout the structural geometries 22 that are measured directly.at tae surface,-to extrapolate 23 fault geometries deeper in the crust. 24 Now, I want to reiterate that-the main' reason for ; l 25 .this is to develop approaches andimethods to review existing i O ANN- RlLEY & ASSOCIATES, Ltd. -
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90 , () 1 models. Our primary focus is not to develop an inhouse 2 model, is not to develop a model that we would say this is 3 it, this is the way things are at Yucca Mountain. We do not 4 intend to do that. 5 However, we must study Yucca Mountain to do these 6 problems. In order to exercise the modeling methods, we 7 have to use the data from that particular site. 8 MR. HINZE: Steve, before you go on, I would like 9 to note that many of us are very interested in how your 10 results were really used in the performance assessment, the 11 IPA II, and what yot have learned, indood, from that. As 12 you go through, if you can give us specific instances of how 13 you were involved - quito specific -- that would be very O \ssI 14 helpful to us in evaluating the IPA. 15 MR. YOUNG: We have not supplied substantial 16 direct input to IPA to the extent that we have said the 17 probability of a certain event is this. We have not given 18 them quantitative answers. We do not have quantitative 19 answers with respect to any of the stuff right now. 20 However, what we do have is some pretty good 21 working conceptual models, some of which have some 22 quantitative aspects, componants to them, and we are pretty 23 far down the road on a good three-dimensional geologic 24 framework model that is tied directly to the structural 25 models. (~l V ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
91 () 1 Now, that model is being overviewed and used by 2 the performance assessment people. I mean, they are looking 3 at that effort to determine exactly what they have to do to 4 distribute subsurface rock properties, et cetera, and things 5 like saturation porosity, hydraulic conductivity, and things 6 like that. 7 The model that we produce will be essentially the 8 tank for that. It will be at least an initial step on how 9 to model. 10 But I will point out specifically what we think l 11 the implications are for performance assessment. 12 MR. HINZE: Have you received anything back from 13 the performance assessment in terms of helping you to p_
-) 14 clarify, to modify your models?
15 MR. YOUNG: Not directly, no. 16 MR. POMEROY: Let me follow up just a little bit, 17 Steve, on that. One thing I think you might do for the 18 benefit of the people, we are talking about models and 19 models and models here. John was talking about some 20 cross-section codes and the extrapolation codes and also 21 used the terri "models" in doing that. 22 You are talking about constructing a model. You 23 are talking about bringing in a geometric model of the site. 24 Your geometric model doesn't necessarily come from the 25 cross-section codes; does it or doesn't it?
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92 O) (, 1 My only point there is just, if we are talking 2 about lots of different models here, let's distinguish them 3 somehow. l 4 MR. YOUNG: I will show you picturos of those. 5 MR. POMEROY: But then I understand you to say 6 that your one constructed model was then used as the basis 7 for IPA? 8 KR. YOUNG: No, no. It is not used as the basis 9 for IPA. I don't even know that it is our intent to have 10 our models used as the basis for IPA. 11 Our intent is to provide the performance 12 assessment effort with a good geologic framework model, and
- 13 that is the critical stratigraphy, the faults, and the
\- 14 proper structural configu'.ation of the units. That is what 15 we want to provide t.o them to performance assessment most 16 directly. 17 The 3-0 model is what we want to provide directly, 18 However, there are other things that we want to provide as 19 well, and those are things like guidance on the comparative 20 risk assessment with respect to earthquake seismicity on the 21 Yucca Mountain faults with respect to faults that might be 22 nearby. 23 I mean, one of the things that you realize right 24 away in reviewing the literature on earthquake seismicity 25 and faulting in the Great Basin and the Basin and Range ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
1 i
; 93
() 1 region is that fault geometry matters when it conca time to , i 2 assess. 1 3 The relative seismic hazard of a fault system -- i j 4 the basic question is some fault systems are a seismic. 5 Some are seismic. Seismic slip is periodic. We want to try { 6 to learn something about Yucca Mountain in those areas, so l 7 that we could use that to provide some guidance to the two i 8 performance assessments as well. So we want something 9 quantitative about that. i 10 MR. POMEROY: Excuse me. My point was narrower 11 than that. . 12 MR. YOUNG: Okay, i 13 MR. POMEROY: You are providing one model. You 14 want to provide what you consider to be the correct model. f 15 I don't think that that is the concept that some of the j 16 staff people worked with in terms of alternate. ! 17 MR. YOUNG: The 3-D model that we provide them ! 18 with is basically going to be the best pass that we can make i 4 19 at it, right off the bat.- 4 20 However, anything that comes out of PA or that is 21 learned at the mountain subsequently, we can feed back into ] 22 that. 23 Now, with respect to alternatives, we are looking 24- at alternatives very actively, and we had a specific task to 25 do that, to look at alternatives.
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94 () i Now, we have identified a slightly different 2 approach to what the alternatives may actually be, and I 3 will talk some about that, how we approach that issue of 4 looking at alternatives. 5 MR. McCoHNELL: If I could break in here, there 6 are three different types of models that we are looking at 7 in developing methodology to evaluate. One is to look at 8 models or the methodology to assess the hazard. In other 9 words, the geometric models that Steve will be talking about 10 are looking at the hazards and what implications the 11 existing data has with respect to the hazard. 12 The second are the framework models that Steve is
,s 13 talking about, which basically are a 3-D depiction of the Al 14 data that exists, the stratigraphy, the faults, where they 15 are, and how they are oriented.
16 Finally, we are looking at the mechanistic models 17 to start talking about how we can directly input into 18 performance assessment calculations by providing some 19 estimate of the risk involved should fault displacement 20 occur. 21 So we need to keep them straight. As Dr. Pomeroy 22 mentioned, we have models going all over everywhere. 23 MR. PoMERoY: Thank you. 24 MR. YOUNG: Let me just set the stage for you a 25 little bit. This is a topographic map of the Yucca Mountain O (_/ ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
1 1 i 95 1 area.
- 2 Yucca Mountain is here. It is basically a 3 fault-controlled set of ridges; that is, a volcanic outflow
! 4 apron from a large area to the north. But the important 5 things to note here are the Yucca Mountain ridge system
- 6 itself with respect to the valley, Crater Flat Valley 7 adjacent to it, Bear Mountain over here, and there is a
) 8 little valley system over here with Fortymile Wash. The 9 drainage that runs through this valley is called Fortymile l 10 Wash. j 11 All of the topography that is in this area is l 12 controlled by or strongly influenced by regional and local 13 scale tectonic and structural features. These elongated l 14 valleys are probably fault-controlled. The location of all i d 15 the ridges are fault-controlled. There are faults in front 16 of most of the mountain ranges, and there are faults that ! 17 cut through Yucca Mountain. 18 Our intent at this time is to'take existing
- 19 cross-sections of Yucca Mountain and, first, to evaluate 20 those cross-sections to see how geologically reasonable they 21 are, ar.d we will show you'some of the assumptions and the 22 constraints and the limitations of-that procedure.
4 23 - But as part of that procedure, we have computed or 24 modeled fault trajectories based on the structural geology 25 at the surface at Yucca Mountain. O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters , -1612 K. Street, N.W., Suite 300
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l l f ) 96 1 Here is a geologic map of Yucca Mountain. Yucca l
- 2 Mountain is comprised primarily by fault-bounded ridges, 1
3 most of them east dipping. The faults are west dipping. So l i~ 4 most of the outcrop areas that you see here are discrete 1 ! 5 fault blocks. j 6 There are the hanging wall blocks or, basically, 7 the downward displaced side of these major normal faults, 8 and the proposed repository block would sit right in this
- 9 area. These are lines of cross-section that follow the
( 10 cross-section lines that were produced at the time that Bob
- 11 Scott was doing some mapping in here, and these are the 12 lines of the cross-section that Bob constructed.
13 This is the basic database that we have used to do O 14 the first round of models, and that basic data are: the l 15 dips of these faults that you see in here, which are west 16 dipping; the dips at the surface; and the stratigraphic ! 17 information; basically, the contacts of the formations that 18 we can pick off here. 19 The major ridges over here we think are also fault 20 bounded. Some of the models indicate there may be some 21 faulting out here, and I'll show you that. 22 (Slide.) i 23 MR. YOUNG: Now, I'm showing this to address the 24 issue that came up earlier, the,t of the extrapolation 25 problem or the so-called blank paper problem, mapping at O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006
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97 () 1 Yucca Mountain yields information that's about at this depth 2 right here. Depending on where you are on the mountain and 3 how deeply the drainage has incised into the existing 4 ridges, you can map these geologic formations. Virtually 5 everything that is below these has to either be extrapolated 6 between bore holes that are drilled, and these are the bore 7 holes, USWH-5, USWG-4, the UE25A-1. There are a fair number 8 of bore holes at Yucca Mountain, but you see also the depth 9 extent of the bore hole control. It's also no more than a 10 littic over a kilometer or kilometer-and-a-half or so deep. 11 What we're really interested in are what do these 12 faults do as they go deeper. Up until just recently, there 13 really have been two main fault models at Yucca Mountain. (- '- 14 People have suggested that Yucca Mountain is part of a so-15 called low angle detachment system, which is a system of 16 faults that basically curve and they flatten as they go 17 deeper, so that the mountain essentially rides on a very low 18 angle, or an almost sub-horizontal fault. 19 The alternative model has been that the faults at 20 Yucca Mountain are essentially planer, and they're planer to 21 depth. They go all the way down to the brittle ductile 22 transition. It's probably -- it's good to keep in mind at 23 this point that it's important what those faults do. It's 24 important for hazard assessment and probably even for a lot 25 of aspects of performance assessment to figure out what f (_)) ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
98 () 1 those faults are doing. 2 Now, I want to point out an important limitation, 3 and I'll point this out in a few other areas as well, and 4 that is that what we're modeling, when we model, the deeper 5 level default trajectories based on these shallow 6 structures, we're modeling a snapshot of the net accumulated 7 deformation at Yucca Mountain. However, what we-want to be 8 able to do is predict. We want to be able to tell what's 9 going to happen to the mountain if those faults slip in the 10 future. What's the deformation going to look like? We want 11 to be able to critically review tectonic models that the DOE 12 would use to base those kinds of conclusions on. 13 MR. STEINDLER: Can you give me a three sentence i 14 description of what the difference is between the faults 15 that level out at some depth and those that go down to the l 16 brittle ductile transition? I mean, why do you care?- ! 17 MR. YOUNG: Seismic capability. Empirically, in i i 18 the great basin, large earthquakes seem to occur almost j 19 exclusively on large planer faults that extend to depth. ! 20 Most of the large dip slip and oblique slip main shocks in l 21 the Great Basin have focal mechanism depths, focal depths, 22 or 15 kilometers plus, and in addition to that, may cause i 23 ground rupture at the surface. 24 on a global basis, fault systems that are 25 interpreted to be, based on fairly strong evidence, or fault l() ANN RILEY ' ASSOCIATES, Ltd. l l
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99 1 systems that are known to be low angle, to have dips of less 2 than about 20 degrees are generally aseismic. Now, that is , 3 not -- it is not a conclusion on our part at this time that 4 the faults at Yucca Mountain won't support a large main 5 shock. However, it is important to be able to assess models 6 that will emerge that show Yucca Mountain as one type of 7 fault or the other. We've gone a substantial way down the 8 road towards taking the existing data and developing it in a 9 way that we can use to tell the difference between those two 10 faults, right now, the important difference I see is as 11 seismic risk. 12 MR. STEINDLER: Do one or the other of those fault c 13 related earthquakes have a reasonable -- does it have a 14 definable impact on the repository horizon? In other words, l 15 would you expect to get damage at the repository horizon, or 4 l 16 if you wcnt the surface, from one kind of quake, I mean from i 17 the low angle fault in comparison to the faults that are at 18 depth. Is there a difference between those? 19 MR. YOUNG: Perhaps, but it's more in the so-f l 20 called seismic capability of the fault. If the-low angle l 21 detachment systems are aseismic, then the deformation near
- 1. .
4 22 the surface may be better characterized as creep.--If-the 23 faults are planer and they extend to depth, then the groun'd - 24 rupture is seismic. So, that's a substantial difference in 25 the deformation-at'the surface. In other words, another way. O ANN RlLEY & ASSOCIATES, Ltd.- Court Reporters 1612 K. Street, N.W., Suite 300
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i i } 3 loo 1 1 to say that as in general, fault scarps are believed to be l 2 almost exclusively related to seismic slip. Fault scarps i j 3 are not generally accepted to be due to creep mechanisms. i 4 You have to be a little bit careful with that because 5 erosion rates play into that some, too, if erosion can keep i 6 up with the fault slip or not. 7 MR. McCONNELL It may be more important with l
- 8 respect to preclosure and determining the dehazard two 9 facilities important to safety. -Seismic hazard will
- 10 probably be most important under those-circumstances.
11 MR. STEINDLER: Thank you. Steve, on one of your 12 cross sections, will you treat any fault you might think of a
- 13 as the site of the mountain earthquake?
14 MR. YOUNG: Yes -- 15 MR. STEINDLER: Since that's the largest -- ! 16 MR. YOUNG: Yeah. I will say something about 17 that, and I have some slides where we can talk about that. {. 18- MR. STEINDLER: Okay, fine. l 19 MR. YOUNG: The approach, then, that we have'taken
- 20 to first, assessing the geologic validity of the cross L 21 section, and the way that.we do that is we retro-deform the-l 22 section~to see=if it will.go back-to anlundeformed state 23 with no substantial-inconsistencies.- In order to do thati 24 we've also had to compute fault trajectories based on the i 25 Hanging Wall deformation up here. The-general process that G ANN- RlLEY. & ASSOCIATES, Ltd.. .
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101 1 -- the framework within which we do that is couched in terms 2 of structural balance. 1 3 The fundamental assumptions and the underlying 4 thesis here is that geologically, the real world balances. 5 Undeformed rocks can be deformed. They go from undefaulted 6 states to faulted states, and our thesis here is that we 7 should be able to recover the undeformed states, the pre-8 deformation states, and that if a particular geologic 9 interpretation, a particular tectonic or structural model, 10 if that model cannot be retro-deformed to a pre-deformation 11 state, then something is wrong. You don't necessarily know 12 what's wrong where it is. It could actually be in the 13 method. However, it is a flag to look for something. The 14 Hanging Wall -- I'll show you this a little bit later, but 15 the stratigraphic units that are offset across the faults, 16 if you remove the slip on the faults, those should fit back 17 together again. If they don't fit back together again, 18 something's wrong. 19 Some of the assumptions -- I'll show you some of 20 the assumptions that you have to make in order to do this, 21 particularly in two dimensions, but what it involves is 22 retro-deforming, or undeforming the deformed state to see if 23 it will go back to a geologically reasonable pre-deformation 24 state. of all of these things that you can do, what we have 25 mostly focused on is removal of fault displacements, removal
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i 102 l l 1 of fault slip. We essentially havo been -- we first compute l 2 fault trajectories, and then we run those faults backwards 3 to see if the undeformed r,tates are gesingically reasonable. I 4 At some point, we can start to pay a little bit j 5 more attention to these other things, to the extent that 6 folding exists at Yucca Mountain in the shallow rocks, we 7 think we have that handled within the fault models. We have 8 not dealt with compaction-, erosion, obtrusion, or we have 9 not dealt with so-called growth sedimentation, which is 10 sedimentation that occurs while the fault is slipping. We 1 11 also have not dealt with distortional strain yet, but we { i 12 have a plan to do that. 13 (Slide.) 14 MR. YOUNG: This is an important assumption or 15 constraint on the cross sections that you have to use to do 16 this work. Since the-methods that we use are based on an i 17 assumption of plain strain, which means that in order to 18 subtract the slip or the displacement from the cross 19 sections, the line of section has to contain the slip 20 factor. To the extent that the line of section does not 21 contain the total slip vector their error is built into'it, 22 and this is an interpretation problem. Geology involves a 23 lot of interpretation. How do you know what the slip vector 24 was? It's based mostly on attempting to orient the cross 25 sections such that it is a true dip section that contains O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 , (202) 293-3950-ww-- ,c- w w , - ._ p r--- -*- - ~ -'w,
i 4 l j 103 1 the maximum dips, and based also on any indication in the 2 field of what the slip was in the faults. There are slick } 3 insides, or slip lines, that also occur. 1 ] 4 So, we have taken the cross sections that are 5 oriented such that they contain the slip vector, or at least ]
- 6 our interpretation that they contain the slip vector, and j 7 we're working primarily with normal faults. To the extent 8 that we deal with strike slip faults at Yucca Mountain or in i 9 the Yucca Mountain area, we'll have to expand our approach, 10 but right at the moment, we think that the faults that we're f.
i 11 dealing with havo evolved primarily in a dip slip mode, and i
- 12 that we have at least two cross sections that are pretty 13 close to true dip.
! 14 (Slide.) 15 MR. YOUNG: The basic assumptions involve here, 16 the basic assumption that we have worked primarily with is 17 conservation of area, and that is that between the 18 undeformed state and the deformed state as the fault system 19 evolves, if the cross section is a true dip section and if 20 it contains the slip vector, then the area of the deformed 21 state should be the same as the area of the undeformed 22 state. In other words, no material should be lost or gained 4 23 in there. 24 (Slide.) 25- MR. YOUNG: Now, the fundamental principles here 4 O ANN RILEY & ASSOCIATES, Ltd.- Court Reporters
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104 () 1 are these. For movement along a normal fault, basically you ; 2 have a situation where you essentially pull the hanging wall 3 away from the foot wall. The foot wall is on what will be 4 the so-called upside of the fault. The hanging wall is on 5 the so-called down side of the fault. So, if you pull the 6 hanging wall away, if no deformation occurred in the hanging 7 vall, a gap would form. We know that in the crust, the 8 crust will not support gaps like this. So, what happens is 9 that the hanging wall collapses on to the fault or onto the 10 foot wall, and the deformation mechanism, the mechanism by 11 which the hanging wall accomplishes this collapse, is the 12 connection between the deformed state hanging wall and the 13 underlying fault. 14 So, the key to this method is that the deformation 15 mechanism, which is something that also has some 16 interpretation to it, that the deformation mechanism gives 17 you a direct connection between the structural geometries in 18 the shallow rocks and the underlying faults. That's how we I 19 predict -- not predict -- model the underlying faults. It's 20 an interpretation of the deformation mechanism, and then we l 21 can compute the fault trajectories directly from that. 22 In general, our approach is to use generalized 23 incline shear. However, most of the models that I'll show 24 you today were used -- were developed using vertical shear, 25 and basically the deformation mecnanism geometrically mimics Lr k ANN RlLEY & ASSOCIATES, Ltd.. l Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950-
l I 1 105 1 a kind of a deck of cards model, such that as the hanging i ! 2 wall is pulled off of the fault, pulled along the fault and l l 3 off of the foot wall, it collapses back on to the foot wall f 4 along tht, slip surfaces. I j 5 (Slide.) 6 MR. YOUNG: This is a geologic cross section of i 7 Yucca Mountain produced by Bob Scott. The things that are 1 l 8 important to notice in here are first off, the west dipping ; i 9 major normal faults, the east dipping hanging wall blocks, 10 and perhaps most important' 1 y and what are the physical basis l 11 for the kinds of models-that we do, are these relatively j 12 closely spaced small fault systems that are primarily 13 clustered in the hanging walls of these fault blocks. l 14 These may be the deformation mechanism for the I 15 major fault blocks at Yucca Mountain. To the extent that ! 16 the small fault fabric at Yucca Mountain is the deformation I l 17 mechanism, and to the extent that we can learn something { 18 about the geometry of these small faults, we can use that to i 19 take the deformed state of the hanging wall and model, l -20 directly model, the underlying fault trajectory. ! 21 MR. HINZE: Is there'some reason, Steve, why some 22- of the deformation 'is taken up by a single fault as i ! 23 indicated there, and-in other cases by the multiple faults? 24 MR. YOUNG: Yes. The difference between the 25 deformation on the entire fault block system is that the 'O i ANN RlLEY & ASSOCIATES, Ltd. Court Reporters
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i l 1 i i 106 1 major slip is localized along a main fault trend. That also j 2 can be a zone, but there's a lot of slip localized along ] 3 that zone. These small faults up here are not directly
. b
! 4 accommodating the slip on the main fault system. These 4 5 things are simply allowing the hanging wall block to conform 6 to the shape of the underlying fault, and that is a key 7 difference. 8 MR. HINZE And wouldn't we expect those small i 9 faults to occur at each one of those major faults? ! 10 MR. YOUNG: Yes. The question is do they? 1 I 11 MR. POMEROY: And what's the depth scale? 1 12 MR. YOUNG: There is no depth scale. Why? How 13 come there's no depth scale on these cross sections? Here's j 14 one over here, but these are very general. They don't know. j 15 This is the depth scale right here. The answer is -- how , 16 deep are they? I don't know. 17 MR. McCONNELL: You could also start to 18 conceptualize, I think, the risk to the repository whether 19 you have a single fault like a Ghost Dance Plain cutting 20 through the repository or an anastomosing sequence of 21 smaller faults cutting through the repository and'the 22 implications with respect to risk that you would get from 23 that. 24 MR. HINZE: Are they anastomosing, or are they 25 imbricate? O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612. K. Street, N.W., Suite 300 -
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107 1 MR. YOUNG: They're anastomosing. The imbricate 2 was a simplified. The imbricate picture was simplified. 3 Bob Scott and the people that are doing the mapping out 4 there now, John Whitney and Rick Spangler, have said they 5 look like this. They're not just tabular. They're not just 6 simple slip surfaces all lined up. They're complex. 7 They're complex in map view, and they're likely to be 8 complex in cross section. Of course, we don't have very 9 much of the cross section view of them. 10 MR. HINZEt Yeah, that was my next question. 11 What's the evidence for it? 12 MR. YOUNG: The evidence is simple, and that is 13 that the anastomosing character, the anastomosing fabric of O 14 these things is evident in outcrop, and the conclusion that 15 they are anastomosing at depth is an interpretation based on 16 that. 17 MR. HINZE So, that cross section would really be 18 a plainer section as well? 19 MR. YOUNG: If you stood up on top of the outcrop 20 and looked across it, it would look just like that. 21 MR. POMEROY: And would you expect the snapping 22 and-the Ghost Dance -- 23 MR. YOUNG: Yep. 24 MR. POMERoY: Where you've got a finite width will 25 show the same thing? O ANN RILEY & ASSOCIATES, Ltd. Coud RepOncrs . 1612 .K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
108 1 MR. YOUNG: Yes, it is, as a matter of fact. This 2 is critical. The point that Keith brought up is perhaps 3 very important, and that is that these things, these 4 relatively closely spaced small fault systems, if they are 5 the deformation mechanism for the hanging wall block, they 6 are going to be highly concentrated in the regions where the 7 fault is curved. Those things drop off rapidly in areas 8 where the fault goes flat. The hanging wall block is moving 9 across that fault. It-doesn't have anything to conform to. 10 It doesn't have any shape. It doesn't have to change shape 11 to move across that piece of the fault. However, it has to 12 change shape to move. If this fault moves, the hanging wall ( 13 block has got to change shape, and when it changes shape, 14 that's a deformation process, and that is a reflection -- 15 our interpretation is that that's a reflection of the 16 mechanism. That's the mechanism that the hanging wall block 17 is using to change shape as it moves across the fault. 18 If you get additional movement on these faults, 19 can those things grow? Can the zone get wider? Yep, the 20 zone can get wider. The mode would suggest that the zone 21 can get wider. What's the Ghost Dance? Is the Ghost Dance 22 really one of these things? The implication here is that 23 the Ghost Dance is one of the bounding faults, but there's 24 no deformation in the hanging wall, or is there? Spangler 25 says yes, there is, and there's a lot more than what was O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006
1 l 109 1 () 1 mapped. d 2 We did not model -- I'll show you this in the 3 models. We didn't model the Ghost Dance fault, and that's 4 the reason right there. The first reason is it didn't have 5 very much displacement on it in the location that our cross 6 sections were, so he said well, it's too small. We're not 7 going to model it. In addition to that, it didn't have any 8 well developed rollover geometry on it. He said okay, no 9 rollover, couldn't model it anyway. Let's not. So, wo 10 didn't. So, we didn't. 11 However, it's very important to interpret what the 12 Ghost Dance is, and the key questions, for example, would be 13 this. If the Ghost Dance is actually an element of one of 14 these, if it's one of the internal slip systems that's just 15 a little bit farther out on the block, can it grow into one 16 of the major bounding faults, is it one of the major 17 bounding -- there's an interpretation now, Spangler and 18 Whitney and even Scott think that this is possible -- that l 19 the Ghost Dance is the northern terminus, the northern 20 propagating tip of one of the major bounding faults that 21 exists to the south. It's the abandoned wash in particular. 22 That's possible. 23 The implications there are that deformation with 24 future slip on the Ghost Dance system that the zone of l 25 deformation in the hanging wall must grow into the hanging l ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
1 + i 110 1 vall, and there's good evidence now from Spangler's work, i 2 that there is a wide z'ne of deformation. I 3 Now, I don't want to spend too much time on this. j 4 There's also some deformation behind it. So, the situation 5 is not simple, but at the very least, clip on the Ghost 6 Dance would suggest that deformation in the hanging wall 4 7 will propagate into what would be the repository block, and- ] 8 that would be important. 9 MR. HINZE Steve, for the record, your 1 (i 10 conservation of area does not permit you to predict the ! 11 location and the extent of those anastomosive faults, is 12 that correct? 13 MR. YOUNG: Yeah, that's a safe way to put it. We 14 actually have tc assume the geometry of those things. We 15 can -- after a fashion, we can model the extent that those l 16 things may have to exist. We can model the aerial extent
- 17 through the block. However, we can't predict their 18 existence. We have to measure that in the field and use 19 that as data in the model. Is that safe? You guys feel 20 free to speak up if you don't like what I just said.
21 (Slide.] 22 MR. YOUNG: I need to set a couple of terms for 23 you here so that I can explain how we generate these models. 24 Foot wall, hanging wall,.and what do we knew and what do we 25 want-to know? For a normal fault system, I said this once O ANN RILEY & ASSOCIATES, Ltd. Court Reporters - 1612 K. Street, N.W., Suite 300 4 Washington, D. C. 20006 (202) 293-3950
l 111 l () 1 already, the foot vall is on -- here's the normal fault, 2 here's the upside, there's the down side. This is the 3 offset, or the displaced horizon. At Yucca Mountain, here's , 4 what we know. We know that right there. We know the so-5 called foot wall cut-off, which is where a specific 6 streitigraphic horizon in the foot wall is cut by the fault. 7 We know or can reasonably interpret the hanging wall cut-8 off. There's some leeway, some interpretation that has to 9 be done there, and we can get good estimates of the initial 10 dip of these faults. 11 What do we want to know? We want to know the rest 12 of that fault, and the way that we do that is that we use 13 measurements of the deformed state of the hanging wall 14 block. We use an interpretation of the deformation 15 mechanism, and that allows us to directly determine the 16 shape of the underlying fault, the point being that the 17 shape of the hanging wall is directly tied to_the shape of 18 the fault. I'll point this out later. 19 You can also go in the other direction with that. 20 The forward modeling part of that is that if you know the 21 fault shape, you can model a future deformed state for the i 22 hanging wall using basically the same approach. 23 (Slide.) 24 MR. YOUNG: This is one of the models. This is a 25 composite model of two of the cross sections, and it is O ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612.K. Street, N.W., Suite 300
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i 112
) 1 built to be basically the longest true depth section in 2 there. We had to put two cross sections together to get 3 this, but this is what we think is the best representation j
- 4 of a true depth cross section or a cross section that 5 contains the dip slip vector.
I 6 Now, again, what you know at Yucca Mountain is 4 i 7 this, and to a somewhat lesser extent, that. Just simply as i ! 8 deep as the bore holes will go. The control drops off 1 i 9 naturally because you have wider spaced control points at i 10 depth, but these are the structural geometries at the j 11 surface that we use to do the model. So, for this 12 particular model, wa use the vertical shear deformation 13 mechanism, and we used the deformed state shape of the 14 hanging wall block at the level of the Topopah Springs. We i 15 used the initial dip of the fault and all of the rest of the i 16 fault trajectory is modeled based on the shape of the
- 17 henging wall blocks.
18 MR. POMEROY: Steve, could you show me where a ! 19 nine kilometers depth is? 1 20 MR. YOUNG: Nine kilometers depth. Here's minus 21 six elevation. There's another kilometer above-sea level, 22 so that is seven kilometers deep here. So, 7, 8, 9 is at 23 the black mark at the bottom of the screen. 4 24 MR. POMEROY: Thank you. l 25 MR. YOUNG:' That's nine right there. l
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113 ] () 1 MR. STIREWALT: You might point out the Ghost 2 Dance on there, too, just for the Committee's sake. 3 MR. YOUNG: That's a good point. . The Ghost-Dance 4 fault is right here, and again, as I say, we didn't model 5 that -- this is just a generalized depiction of the small 6 fault fabric. We took most ei that off of the cross 7 section. However, most of these blocks have a fairly wide 8 zone of those closely spaced small faults. 9 Now, _in creating these fault models and' attempting 10 to come up with a balanced solution, if you. restore all of 11 these blocks to their pre-deformation shape, you can see 12 that there is some residual east dip left in the entire 13 model. Our interpretation currently is that that eact dip 14 is supported by a fault or a zone of faulting-that is east 15 of Fran Ridge, basically east of the Yucca Mountain fault-16 system, and that would lie in the sub-surface _somewhere out 17 here. 18 This fault is the Paintbrush Canyon fault. The 19 Paintbrush Canyon fault is a major fault in the Yucca 20 Mountain system. However, if the only thing that_you did i 21- was restore all of the slip on- all' of these faults ty) to the 1
-)
22 Paintbrush Canyon, you would still have substantial east dip 23 built into the section. In order to account-for that east. 24 dip in a way that is consistent geologically with what we 25 _see in the field, we've interpreted.that there's a fault O ANN RILEY & ASSOCIATES, Ltd. i ! Court Reporters 1612 K. - Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
114 () 1 east -- this is Fran Ridge -- east of Fran Ridge. We have 2 variably referred to that as a 40-Mile Wash fault. It may 3 or may not lie directly in 40-Mile Wash. There has to be a 4 slip system out here somewhere that accounts for that, but - 5 - 6 MR. HINZE: Could that also be associated with 7 some doming, perhaps if Crater Flat were a Caldara? 8 MR. YOUNG: If Crater Flat were a Caldera, it is 9 possible that some doming on that scale could be associated 10 with it. However, we don't interpret Crate Flat in that 11 way. We don't think Crater Flat Valley is a Caldera. We 12 don't think Crater Flat is a Caldera. In addition to that, 13 our key mapping unit, the Topopah Springs, which-is mapped (. N_) 14 here in Fran Ridge and Busted Butte and also throughout the 15 south part of Yucca Mountain, that unit is encountered in a 16 bore hole here in 40-Mile Wash. I believe that's J13, but 17 it comes back to the surface here. There's also another 18 bore hole sitting out here. I believe that's J11, isn't it? 19 Or is it 12? It's 11 or 12, 20 There's another bore hole sitting right out here 21 that encounters the Topopah Spring at about the same 22 elevation chat it exists here and only a little bit lower 23 than here. So, with substantial east dip up to 15 or 20 24 degrees of east dip from Fran Ridge, it's back to the 25 surface again here. There is a structure in between here kj ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
~- . . - -
115 () 1 and here, maybe more. There are structures between here and 2 here that allow all of this east dip to be brought back to 3 the surface to essentially be taken out, and the Topopah 4 Springs come right back to the surface again. 5 I don't want to hit this point too hard right at 6 the moment, but what happened at Little Skull Mountain? 4 7 What's going on there? We don't know, but early on when we 8 were putting some of these regional models together, we 9 projected some of the faults from farther north through here 10 in order -- and I'll show you this in just a minute -- in 11 order to connect them to a seismic reflection line that is 12 sitting out here in the Amargosa Desert with some 13 substantial structureu on it. There it is. 14 On the west end of the Amargosa Valley 1 seismic 15 reflection line, there are some large structures that appear 16 to be normal fault related structures, major basin bounding 17 fault system out there. There's very little evidence on the 18 AV-1 line of sideswipe or defraction, and so it looks like l 19 that the AV-1 line is crossing the structure at a fairly 20 high angle. In other words, the structure that is crossing 21 this reflection line is not coming in at a highly oblique 22 angle. It's crossing it at about right angles. It's about 23 orthogonal to it. 24 You might see some similarities between these 25 interpretations and what we just showed for Yucca Mountain, j m l ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 i l Washington, D. C. 20006 I (202) 293-3950 j
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116 1 Let me point out again what we know about -- from this 2 seismic line. Here's what can be reasonably determined. ! 3 These fault block dips in here and the fault dips 4 themselves, everything else on the line has to be modeled, 5 except for this major structure on the far west end of the 6 line. This is also an indication that there are large fault. 7 systems on the east side of the 40-Mile Wash Valley. Let me 8 have that -- 9 MR. POMEROY: Steve, you might just point out in 4 10 the depth of that section for the benefit of the committee. 11 MR. YOUNG: Okay. Let me show you this, and then 12 I'll show you the depth scale.
-13 [ Slide.)
14 MR. YOUNG: So, some structure crosses the west l 15 end of this line, and the focus of.the earthquake at Little
- 16 Skull Mountain was at around about 9 to 12 kilometers below 17 here. The focal mechanism, which is an indication of what-i 18 the slip direction was and what the depth of the faults may l . .
l 19 be, has the two focal _ plain solutions, which are choices for 20 the faults that could have caused that slip. One of the 21 focal plains projects to the surface about right here. The 22 sther focal plain projects to the surface over here in the l 23 Rock Valley area. 24 So, there's a low angle focal plain and there's a 25 high angle focal plain. One of them c ses to the surface l 'O i ANN RILEY & ASSOCIATES, Ltd. l Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
_.- _ _ ~ - .- . _- . _. - _ - . -- - - -.- l 1 i 117 1 here. The other one comes to the surface here. 2 MR. POMEROY: And what's that sense of motion, 3 Steve? 4 MR. YOUNG: It's a dip slip main shock, and so 5 this focal plain, the focal plain -- I don't want to 6 indicate that we think that's the fault necessarily. That , 7 is an interpretation. However, the focal plain that 8 projects to the surface at that particular location dips 9 about 60 degrees east, and the other one that projects to 10 the surface over here in rock valley, it dips around about j 11 30 degrees west. ! 12 Now, what I wanted to indicate here before we go 13 too much farther is how Yucca Mountain, how the fault style O 14 at Yucca Mountain might be a little bit different from some
- 15 of the other fault systems around it and how we might be 1
16 able to fit that together-into a reasonable regional model. l 17 So, what we've done is we've interpreted the AV-1 line in 18 _ order to get some additional feel for how to include 19 reflection data in Yucca Mountain-interpretation, but we've 1 20 also found this structure on here, which may project 21 northward along the eastern plank of 40-Mile Wash. 22 Then we've constructed a regional-model across 23 here that shows the relationship between the Yucca-Mountain l 24 fault system, Crater Flat Valley, Bare Mountain, and the 25 Bullfrog Hills extended region. We have developed, in O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 j (202) 293-3950
118 () 1 reference to the earlier discussion on alternatives, the --
!! it looks to us at this time that the alternatives are not 3 just strictly are they planer or are they curved. There are 4 also alternatives that are variations on the curved fault 5 detachment model.
6 (Slide.] 7 MR. YOUNG: One of those models, one of the 8 alternatives, came directly from interpretation of the AV-1 4 9 reflection seismic data. This is an interpretation. We . 10 intend to use it to further examine and investigate Yucca 11 Mountain, to further model the Yucca Mor'tain fault systems. 4 12 However, what's interesting on here is that the AV-1 line
- 13 shows first a relatively large east dipping half grabin, 14 basically a large grounding fault here, where we could not i
15 create good, balanced solutions for these smaller fault 4 16 blocks that would sole into the deeper one. l 17 Basically, these are all balanced fault 18 trajectories. This model will go back together -- if you 19 run it backward, the entire model will go back together 20 again to an undeformed state, i
- 21 MR. POMEROY: Steve, let me ask my question again.
22 Now will you tell me what the depth scale is and what the l 23 horizontal scale is? I can't read them from here~.- < 24 MR. YOUNG: On here?' 4 25 MR. POMEROY: Yes. ANN RlLEY & ASSOCIATES, Ltd. Coud RepOders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
119 f
) 1 MR. YOUNG: Yeah. The initial model, as we 2 digitized it straight from the seismic section, is in two 3 way travel time, and the two way travel time, this is three 4 seconds to here. So, it's basically the datum, which is 5 rear the surface, one, two, and three seconds of two-way 6 travel time, and we've converted that to depth using the 7 velocities from the coincident refraction survey. We've 8 used these interval velocities and converted it to a depth 9 section, and we're at the bottom of this model is at minus 10 six kilometers elevation. So, what is that, roughly that's 11 almost seven kilometers deep.
12 It's interesting, too. One of the things that we 13 did initially on the AV-1 reflection line is to simply model (/ ) 14 this fault trajectory using the same deformation mechanism 15 that we used at Yucca Mountain, and a very direct and simple 16 interpretation of the hanging wall geometry of this block 17 and the detachment depth for this big fault system came out 18 pretty close to the Yucca Mountain detachment depth. It 19 came out pretty close to the detachment that we had modeled 20 at Yucca Mountain. 21 Now, further to the inconsistency of these small j2 blocks with that deeper detachment, we computed some balance
'33 fault trajectories on these things, and a best 24 interpretation at this time is that they would sole out 25 around about here. one of Alan's very innovative s
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120-1 interpretations is that the structure that is on the west 2 end of that line is essentially a hanging wall syncline. -It 3 is related to the ramp that connects the two detachment-4 systems. This is a fundamentally new model for the Yucca 5 V,suntain system. .It's one that hasn't been exercised at all. 6' to explain that anything at Yucca Mountain. 7 Our thoughts currently are that perhaps crater-8 Flat Valley _could be worked into the hanging wall syncline 9 model. So, this is a good indication of how you can use 10 information-from nearby.to gain-additional. insight on how to 11 interpret structures in the Yucca Mountain area. So, this - 12 -
. 13 MR. McCONNELL:- Steve, can I interrupt just a 14 second?
15 MR. YOUNG: Uh-huh. 16 MR. McCONNELL: We've been going about an hour-17 and-a-half, and I'll= leave:it to the Committee to decide ' 18 whether we need to speed this up or-what, if-that's okay. . I 19 don't know what your schedules are. 20 MR. MOELLER: Well, we're flexible, but what do 21- you fellows -- 22 MR. POMEROY: I'd like to hear it. 23 MR. MOELLER: Let's go ahead and hear it. 24 .MR. HINZE: My problem is that I think we can go 25 here for the rest of the day,.but we won't. O ANN RILEY & ASSOCIATES, Ltd. Court Reporters. 1612 K. Street, N.W., Suite 300 R Washington, D. C. 20006
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l 1 121 1 MR. YOUNG: I speed through them a little bit 2 quicker. 3 MR. MOELLER: Could we aim at 12:30? Is that too 4 soon? 5 MR. YOUNG: Fine. 6 MR. MOELLER: Let's aim at 12:30. 7 MR. YOUNG: 12:30 Is good. Okay, so at any rate, 8 we have a new -- but this is the direction that the 9 alternatives are going in. We're finding alternatives that 10 we didn't anticipate initially through this modeling effort. 11 (Slide.] 12 MR. YOUNG: Now, on the other side, west of Yucca 13 Mountain, here's a model -- gee, he's going to ask me about 14 the depth scale again. There's no depth scale on here. Oh, 15 it's one to one. Okay, good, it's one to one. 16 Here's the Yucca Mountain system here. This 17 entire model is basically forward modeled, and the intent 18 here is to show the relationship between the strongly i 19 extended Bullfrog Hills area, and this interpretation is 20 based on the work of Florian Maldinado, the USGS, and to 21 show how Bare Mountain fits in and what the potential 22 difference in structural style is at Yucca Mountain. [ 23 So, here's Yucca Mountain-interpreted as the 24 detachment system vith the detachment system persisting 25 eastward. We haven't modeled what's going on over here yet. 1O ANN. RILEY & ASSOCIATES, Ltd. Court Reporters :
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122 1 We intend to do some work on that, but the interpretation 2 here is that the Bare Mountain fault is one of those high ! 3 angle faults, that it does extend to depth, and that some of 4 4 the uplift at Bare Mountain is isostatic uplift associsted 5 with development of the Bare Mountain fault, f 6 (Slide.] 7 MR. YOUNG: Now, one of the things that we wanted 8 to do originally as well is to take the balance structural 9 interpretations to take good base case or well controlled 10 structural models, and to use those as the basis-for the-11 development of-three dimensional solid geologic framework 12 mc.lels, and what I mean by solid is that each one of the 13 units or the layers in here-is a solid block. Therefore, 14 the model can be sliced through in virtually any 15 orientation. Any of these layers can be stripped from the 16 model so that you could look at the layer underneath. 17 Furthermore, within each one of these layers, rock 18 properties, any kind-of parametric data can be gridded in 3-19 D and displayed within these layers. So, this. tool which we j 20 envision to be an important performance assessment tool, 21 this is going to be the tool that is going to allow the 22 performance assessment people to have a' picture of what the 23 mountain looks like under the ground, based on virtually any 24 kind of data that can be acquired can be built into this. 25 Currently, we have it as solid stratigraphy. We O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
b 123 () -1 haven't gridded any of the rock property data into it, but 2 the intent is to use this as a framework model. 3 [ Slide.] 4 MR. YOUNG: What I wanted to show with this is 5 that one of the real values of these 3-D framework models, ! and you run into it all of the time, is when one person will 6 come in and say gee, we think the faults are doing this and 7 J 8 that the fault log goes that way and it dips this way, and 9 everybody is left with hmm, I wonder exactly _what that looks
- 10 like. Even if you draw maps and cross sections, it's still 11 difficult for people'in a group to have a common vision or a 12 common view of what you mean. What does it look like?
13 Well,_what we'd like to see out of this tool is i i 14 the ability to show someone what you mean. When you say the l 15 faults do this, the fault blocks do_that, a certain ! 16 stratigraphic unit goes this way or that, you can show a 17 picture of it directly. Then everybody can either-agree, 18 disagree, or determine how to proceed from there. In this i 19 particular case, this is our current interpretation of the 20 geometry of the Solitario canyon fault within this 21 particular model. So, we've left the surface one. We've 22 left the Tiva Canyon unit on here.- We've taken out the 23 Topopah Springs, all the way down to I think the Bullfrog i 24 Hills, and you can actually see the fault surface in there. 4 25 So, that's what we think the major value of this i ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 1 (202) 293-3950
1 124 ]( ) 1 is going to be. It's going to be in distribution of rock 2 properties, a tank to hold the performance assessment model, 3 and a communication tool. Okay, we can skip that one. I 4 (Slide.] 5 MR. YOUNG: Overall,_we see the results as being 6 basically that we have a reasonably good interpretation of ! 7 Yucca Mountain, and it is overall a detachment model. That j 8 doesn't mean that there aren't alternatives. We are { 9 exploring alternatives, and the interpretation from the AV- ! 10 1 line is an example of that. The alternatives seem to be 11 clustering in the detachment style. We have probably tested 12 -a planer fault model in more detail and with more rigor than i 13 anybody else has done. l 14 We did a task to go in and test the so-called 15 domino style of faulting, which is basically whero you would 16 envision a stack of dominos just laid over. Planer faults, i 17 all the way to the brittle ductile transition, and there _ 18 really in no -- as far as we can tell, there's no 19 combination of-deformation mechanisms that we can use for l 20 modeling that will result in the. geologic structures that
- 21 are mapped at Yucca Mountain, and in particular, the 22 features that we're-interested in are the rollover
~
! 23 geometries, which are the folds that are developed in the 24 hanging walls of the faults, and the relative -- the L 25 variation in the fault block dip. None of the domino models l LO ANN RlLEY & ASSOCIATES, Ltd. Coud Reponers , 1612 - K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
125 1 () I will account for that, so from the point of view of 2 alternatives, we're moving towards looking at variations in i 3 the detachment style as being probably more productive. 4 The existing cross sections, in particular the 5 ones by Scott and Bonk, can be reasonably well balanced.
- 6 They can be balanced pretty easily. In other words, they
) 7 did a good job of mapping. Those things will go back 1 l 8 together pretty well. They're reasonably good geologic l 9 interpretations. You can retro deform the sections based on 10 computed fault trajectories, and they'll go back together i 11 fairly easily.
- 12 The interpretation in the fault models from the
- 13 AV-1 seismic line suggest that wa should be looking at l- 14 multiple detachment models at Yucca Mountain. We didn't do 15 that. We started out to produce the simplest model that we -
l 16 could using most of the geologic information that was
~
, 17 available. I think we would now subsequently go back and l ! 18 look at that again and see if one of these nested or , 19 multiple detachment models might be appropriate at Yucca. 20 Mountain. l , 21 Furthermore, there's indication from the models I 22 that what we would refer-to as the Yucca Mountain fault 23 system, which is that fault system that comprises the local 24 curved fault and detachment system, persists somewhat 25- eastward into the 40-Mile Wash Jackass Flats area. How far l lO ANN RlLEY & ASSOCIATES, Ltd. l- Coud Repoders 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950
126 ( 1 eastward does it persist? We don't know. We haven't done 2 any models out there at all, and we don't have very much 3 information on that. 4 MR. POMEROY: Let's go back to two things. First 5 of all, the Little Skull Mountain earthquake which occurred 6 at 9 to 12 kilometers in depth. On your cross sections or 7 the AV-1 line, I saw nothing going down to that level. Are 1 8 you assuming that there is some other kind of faulting 9 taking place at greater depth associated with the Little 10 Skull Mountain? 11 The second part of the question is, consider the 12 fault plain mechanisms, fault mechanisms, of the micro 13 earthquakes, admittedly of limited number in the Yucca O k-) 14 Mountain vicinity, fairly large vicinity, and could you 15 speak to the character of those solutions relative to the 16 basic assumption here? 17 MR. YOUNG: Yeah. Question number one is on the 18 interpretation of the AV-1 line that I showed, we didn't 19 show any faults going down to the focal depth of the Little 20 Skull Mountain earthquake. We do have several 21 interpretations with those faults on them. The reason I i 22 didn't show those here today is I wanted something that 23 pertained more directly to alternatives at Yucca Mountain. 24 However, we do have interpretations that show deep planer 25 faults on the west end of the line, f \ 4 b ANN RILEY & ASSOCIATES, Ltd. : Coud RepOders I 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
127 1 MR. POMEROY: Excuse me, is this the preferred
- 2 solution?
! 3 MR. YOUNG: Boy. Is that our preferred solution? 4 It's not -- no, it's not. What is really is is a pointer to i ! 5 go back and look for such a thing-at Yucca Mountain. The 6 deformation on the far west end of the AV-1 line, that last 7 big normal fault, there's not enough hanging wall to model a j 8 fault, nnd the deformation that we showed, those little i 9 dipping horizons that were in there on the west end of that 10 line, those are all forward modeled.- The fault on the west 4 11 end of_the line is not modelable. However, it looks planer. 12 Why did we do the multiple detachment model? 13 Because the small fault blocks would not reasonably detach ] l 14 as deep as the large fault block. So, basically, there are 15 like two characteristic fault block wave lengths on that 16 line. One is this great long half grabin, and it detaches 17 deep. The other are these little small blocks. It's very l } 18 difficult to get those to detach at the'same depth, so the 19 implication wac gee, we should look for a multiple
- 20 detachment model of some sort, so'we did. Alan forward 1
l 21 modeled one. So, do we have interpretations that do have 22 faults going down to seismic depths? Yes, for that line. 23 Now, to speak to the other issue, what is the , -l
; 24 compatibility,-what-is the relationship between 25 interpretations of detachment faulting at_ Yucca Mountain'and l
l i ANN RILEY & ASSOCIATES, Ltd.
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1 l 128 () 1 seismicity that is deeper than that where the focal 2 mechanisms range from dip to oblique to strike slip? i 3 MR. POMEROY: With a lot of strike slip. 4 MR. YOUNG: Well -- 5 MR. POMEROY: That's arguable.
- 6 MR. YOUNG
- Yeah, because you don't know what the
; 7 slip is, because they're all pretty small events, and the 8 focal mechanisms are not wr?1 constrained. There are a few 9 good focal mechanisms under Yucca Mountain. However, the
[ 10 point is how can you reconcile deep seismicity-below Yucca 11 Mountain with an-interpretation that Yucca Mountain evolved l 12 as a low angle detachment system. That is a problem all 13 over the basin and range. The answer is I don't know. I 14 don't know how to do that right at the moment. 15 MR. McCONNELL: One of the solutions to that is 1 16 what they're modeling is a miocene series of structure 17 that's being overprinted by the quaternary tectonic regime 18 that might be substantially different than I think, if 19 ni - '.ing else, this modeling activity is starting to point-20 that out, that what we may see at the surface may not-be a 21 good indication necessarily as far as tectonic models are 22 concerned. It's what may happen in the future. l 23 MR. STIREWALT: I think that point is well taken. l
-I 24 What we've shown you, in fact, is the genesis of the 25 features and not necessarily what could occur X thousands of )
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1 129
- 1 years from now, so I'll reinforce the point that Pete just 4
2 made. 1 3 MR. POMEROY: Right. What I'm concerned about 4 getting to the bottom line is the first set of bullets on 5 this_ slide, because you're talking about evaluation of 6 earthquake seismic hazard, and yet the model you showed us 7 doesn't deal with the largest earthquake that perhaps has 2 8 occurred there in numbers like 100,000 years. 9 MR. YOUNG: Yeah. The fault that the Little Skull 10 Mountain earthquake occurred on, my interpretation at this 11 time would be that fault is not part of the Yucca Mountain. 12 It is not part of that detachment system that comprises i
- 13 Yucca Mountain. It is something else. It is like Bare 1
d 14 Mountain. It's one of those kinds of features. It is one 15 of the genuinely planer, deep cutting faults that definitely 16 exists in the basin and range. They exist along with the 17
- detachment systems.
18 Now, I do not want to dowraplay the importance of 19 reconciling modern seismicity with the observed extensional-20 strain history of the basin and range. That is an important 21 -- it's a paradox. There's a big inconsistency there. i 22 However, there is one thing I'd like to reinforce, and that 23 is that everything that we see at Yucca Mountain in.the - 24 structural geology of the mountain is consistent with these ) 25 lystric detachment models. O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
I 130 () 1 In addition to that, the same faults, from faults 2 that we've modeled, which almost certainly began to form in i 3 the miocene, the late miocene, those faults have quaternary 4 slip on them. Not only that, but Spangler says they have a 5 holocene slip on them. Now, you're left with making some 6 interpretations or some decisions or some choices here. 7 Have new faults cut through the system that took exact 8 advantage of the surface trace of the old detachment i 9 strands? I don't know. 10 Is it possible that the detachment system is 11 active in creep and that the lower crust is seismically 12 active? We talked about this the other day. Alan has i 13 suggested that there's some strain rate dependence on that.
\) 14 Both mechanisms can be working. However, all of the 15 geological.-- in all of the structural geometries at Yucca 16 Mountain, they do nothing but point at these detachment 17 models. That does not mean that there's not something else 18 going on. There demonstrably are deep planer faults l
l 19 directly adjacent to.the mountain. It just doesn't look l l 20 like the ones at Yucca Mountain are of that type. 21 Bare Mountain is an excellent example of one of 22 these deep planer faults. So, really there's no good answer l 23 for that. We're up in the air on that issue right now.- l 24 MR. PoMEROY: Right. Don't take any of my remarks 25 in a critical sense, Steve, because I have great admiration-
\ l
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131 () 1 for this work. I'm just confused myself about -- 2 MR. YOUNG: We're just as critical about it. I 3 mean, we almost every day talk about that. How do you solve 4 this problem? What are we going to_do about it? Don't i 5 know. What are we going to do to approach it? We don't. l , 6 know-yet. Some of what we're going to do to' approach this: i 7 is going to have to be done on a regional scale.- We do have j 8 some models that are regional models'that_ speak to the-i f 9 potential relationships between~ faults like the Northern 10 Death Valley Furnace Creek fault zone. We have some pull-l 11 apart models put togethnr for_ Yucca Mountain that may be' i 12 able to address that issue, but what we need to'do is we !_ 13 need to make good, detailed maps and cross sections of the 14 seismicity. We need to run cross sections _through with the 15 seismicity on it. We have not done that. We haven't-done I
- 16 any of that stuff yet.
17 MR. POMEROY: What I'm thinking of~also there is { ( 18 -you might be able to delineate fairly clearly what you think l l 19 -is needed in terms of-data to more accurately constrain what 20 __ i f 21 MR. YOUNG: Yeah, and a good example of'that is 22 those small fault systems. 23 MR. POMEROY: Yes. l l 24. MR. YOUNG: If anything can be done'to improve the
- 25- information-or our knowledge about what those things are i
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4 132 1 doing, what their distribution is, what the geometry is, 2 what the overall fabric is, to the extent that anything can 3 be done to improve that, we can improve our modeling effort. 4 We can improve the way that we examine those models. J 5 MR. POMEROY: Can you get that kind of information
-6 back into the system?
7 MR. YOUNG: Oh, sure, sure. Yeah, we can do that. 8 We can rerun the entire model with a new mechanism, in short 9 order, just like that. But yeah, that does addrese these 10 issues. , 11 There are some choices to be made, some 12 interpretations to be done, and some important assessments 1 l 13 to be done with respect to fault style. I'm not sure how to 14 sum that up other than to say that fall geometry is 15 important. With respect to a lot of these hazards, fault I 16 geometry matters. It matters what shape the thing is. The 17 ground rupture hazard is related to the seismic hazard. In 18 that ground rupture is probably, in this area, would be more 19 likely to be associated with a seismic event. 20 Now, there is -- and you've seen these. You've 21 seen some of these trenches. There's some basaltic ash in 22 some of the-fault zones. That's an indication that those 23 fault zones were open. That's rupture. That's ground 24 rupture. What happened? It's hard to say. We're working 25 on a pull-apart model, a regional pull-apart model, whereby O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
i 133 1 response of the Yucca Mountain fault system to large ! 2 earthquakes on the Furnace Creek fault would be examined. !
- 3 If Yucca Mountain is a pull-apart system, if it is inside of 4 the Furnace Creek fault zone pull-apart region, then a big 5 event on Furnace Creek would be expected to pull it apart, 6 and it might have done.
7 An example of that is the Landers event, is the 8 recent Landers earthquake in southern California in the . 9 Mojave Desert. We plan on watching the literature on that
- 10 very carefully to see what the pull-apart effects were on s
11 that fault. The volcanic hazard, what's the relationship f 12 between faults at Yucca Mountain and the location near the j 13 ascent and the location of erupted vents. 14 If it is a detachment system, it seems unlikely 15 that that detachment system has a substantial influence on 16 magma ascent from the depths that the magma would be ! 17 generated from, the genesis depths of the magma. The best i
- 18 estimates are that the depths that these-erupted magmas are 19 coming fron are.20--to 30 to as much as 50 kilometers. We 20 don't think'these faults go that deep. Some other crustal 21 scale structure is controlling that.
I-22 However, it seems equally likely that the shallow
- 23 location, the surface location of some of these vents is 24 related to the. fault system. So, there's'a coupling. There 25 are deep crustal scale structures that somehow influence 4
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134 1- tapping of the magma in its source region, control the 2 ascent up to a certain depth, at which point the shallow l j 3 fault system exerts some influence, may be a strong j 4 influence. 5 (Slide.)
- 6 MR. YOUNG: Here's what we're going to do. We ,
1 7 want to do some forward modeling, and the purpose of the 8 forward modeling is an attempt to predict what's going to l 9 happen to the hanging wall.bl'ock that holds the potential 10 repository. Our approach to that currently is that we want j 11 to do forward models based on what we know about the fault l 12 geometries currently in order to predict potential zones of 13 distributed deformation. Those are the small fault fabrics, l 14 to specify we're going to use the existing models, the 15 existing geometric models to help specify displacement
- 16 boundary conditions for-the deformation mechanics, and l
17 ultimately what we want to do is we want to map stress and 4 18 strain due to the fault -- due to potential fault slip i 19 itself, and that basically is an effort to superpose 20 stresses and strains that are due to fault slip on to the in-21 situ stress state in order to assess the effects of fault 22 slip on the major bounding faults on those faults that may 23 be closer in to the repository, specifically the Ghost 24 Dance. 25 The question is if some slip occurs on the O ANN RILEY & ASSOCIATES, Ltd. Court Reporters i 1612 K. Street, N.W.,- Suite 300 Washington, D. C. 20006 l (202) 293-3950 l
135 () 1 Paintbrush, the Boundary Ridge, the Solitario canyon, what 2 will be the response? In the repository block on a
- 3 distributed basis, and what will happen to the Ghost Dance
- 4 fault? That's the intent. That's the main intent of the l 5 forward modeling effort.
l 6 Now, the forward modeling is not going to be 7 restricted simply to the detachment models. We'll do the f 8 full range of domino models, just as we've done with the 9 geometry to see what the effects are there as well. Then-i 10 ultimately, we want to do -- es soon as possible, we want to 11 do the dynamic models that-parallel the two-dimensional l 12 geometric models. We're going to continue with construction I 13 of the 3-D framework model. That's a display. We call that { 14 a model. It is a model. It's a geometric model, but it's l 15 built up of the other structural models-and other 1 16 stratigraphic models. It's built up as a display, a. l 17 communication, and a performance assessment tool. L 18 We want to conduct research on the 3-D geometric l j 19 methods. Probably.the single most-important or significant 20 criticism of the models we've done is that they're plain l 21 strain. They're 2-D. What if they're1 strike slip? Can't l 22 handle it. We cannot-do that. We don't have any methods l 23 for doing that. So, we're going to pursue that some. 24 The 2-D dynamic models we're going to pursue that t f- 25 straight away. We have codes lined up to start that work as ,O ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite .300
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,---,,,-------r-,------,-------- - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - ----
13G 1 soon as possible, and then from here, from the 2-D dynamic 2 models, then we want to do some plate models. We'll try to 3 look at maps of stress and strain and three dimensions. 4 MR. HINZE: These kinematic models, and 5 particularly in the 3-D area, are these off the shelf models 6 that you're going to purchase? Where do they come from? 7 MR. YOUNG: The modeling system that we're using 8 right now is a system that was originally developed by a 9 company called geologic systems. It's now being run by 10 cognicized development, primarily in support of oil and gas 11 exploration work. That's an existing supported package. 12 It's an existing supported system. 13 We're not sure what we're going to do about this 14 yet. We're either going to do research on our own -- we do 15 not have the resources to build these things from the ground 16 up. 17 MR. POMEROY: Major problem. 18 MR. YOUNG: That's right. We are thinking about 19 some way to either start to get a collaborative effort. going 20 with an existing development company or to watch their 21 development efforts and to take advantage of that as soon aus 22 they're advanced enough to be useable, or to do some 23 combination, to do some in house work and watch their work, 24 et cetera, and try to decide when the best time to do~that 25 would be. O ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
137 1 MR. HINZE: Where is the USGS in this case? 2 MR. YOUNG: USGS is not very far in this area. 3 That's not a criticism either. If detailed assessment, 4 kinematic assessment of tectonic models is not something 5 that you do all of the time, you wouldn't necessarily have 6 the systems in house. They're sometimes expensive to 7 support. They're expensive to buy. The USGS is starting to 8 do some of the two dimensional balancing work. They talked 9 to -- I guess Keith mentioned that they are going to buy 10 some sort of system to do that in house, but they've not 11 done yet really. They've not done very much work in this 12 area. 13 MR. HINZE: I really like your regional models. 3 14 Are any of those going to be regional models? I think these 15 are extremely important. Are the deformational models, are 16 they going to be regional? 17 MR. YOUNG: The models that we think are easiest 18 to take on to a regional scale are these, the kinematic 19 models, both the 2-D and the 3-D kinematic models. To do - 20 - see, there's always a problem when you try to do the 21 dynamics. When you try to do the dynamics, when you try to 22 do deformation mechanics on a regional basis, because then 23 you've got grid cell sizes that are so large you have to 24 really wonder to what extent you are reliably or credibly 25 representing the actual conditions. / ~ N. U ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
4 138 1 MR. HINZE Is the model system that you're using 2 requiring that you use large grid size? ) , 3 MR. YOUNG: The system that we're using right now l 4 to do the geometric and the kinematic work is not grid l 1 5 based. However, all of the systems we would use to do the i 6 dynamic work are all finite elements. 7 MR. HINZE: And so there should really be no limit i 8 to what -- 9 MR. YOUNG: No, no, except for the practical 10 limits, the computational limits. That's right. It's 11 machine and computation efficiency are the limits at that 12 point. l , 13 MR. POMEROY: Steve, you must have talked some to l 14 the oil companies. l , 15 MR. YOUNG: Problem definition is,_too. j 16 MR. POMEROY: I know some people in'the oil-17 companies arguing some of this kind of work, and-it's r 18 probably proprietary, but have you talked to them at all and 19 determined _whether or not you might be able to work-l 20 something out with them with regard to the 3-D modeling? 21 MR. YOUNG: We've-thought about that, too. 22 Cognicize is -- I don't know if I'm supposed to say this or 23 not. Cognicize is actively working-on.a'3-D modeling 24 system, and it'is possible that we can take advantage of 25 some of that, that we can either become involved in-it or D ANN RlLEY & ASSOCIATES, Ltd. l I Court Reporters 1612 K. Street, N.W., Suite _300 i Washington, D. C. 20006
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139 ( 1 watch it very closely, but you know, they hold that stuff
- 2 pretty tight sometimes. So, I don't know. I'm not sure 3 what we can do there yet, but there are some possibilities 4 that would be really helpful to us.
. 5 MR. STEINDLER: Is this work supported by research 6 or by TA? j 7 MR. YOUNG: Both. It's primarily to this point , '8 been technical assistance, but when it's going into a 9 developmental mode, it's going probably to be funded mostly l 10 by research. The TA work will take a different direction. 11 One, it's more directly tied to design and performance 12 concerns. j 13 MR. STEINDLER: And what has been the size of the I 14 effort? 15 MR. YOUNG: The size of the' effort to date has 16 been the expenditure of probably in the neighborhood, I 17 would say, of -- and this 10 just an off the top of my head 18 guess, of several hundred thousand dollars at this point,- l 19 and this is over a period of approximately-three years. 20 I would like to clarify one thing and get back to l 21 the question I think Dr. Pomeroy asked, and that is the j i 22 potential for duplicating work that the DOE is doing at this { 23 time. The staff.has taken the position that in some cases- . 24 there may need - -they may need the ability to do 25 independent modeling, and this independent modeling and the (~/
)
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140 1 judgment that leads to that decision is based on our 2 identification of what are called key technical 3 uncertainties in the systematic regulatory analyses. This 4 effort is tied to key technical uncertainties that have been 5 identified in the.Sha process. So, while we may be 6 duplicating DOE's effort, there is a recognition that in , 7 some areas, particularly when the uncertainty is very 8 inattractable, that we may need an independent modeling i 9 capability. 10 MR. POMEROY: Do you keep track, though, of where l 11 DOE is? I mean, does Steve talk with -- 12 MR. YOUNG: I do. I watch him real close. I'm 13 interested in what they're doing, and they're not. 14 MR. HINZE: Let me ask, Keith,-what's going to
- 15 happen to this?
16 MR. McCONNELL: Basically, we consider that report i l 17 to be input, again to our analyses with respect to helping l 18 refine the key technical uncertainties. Right now as far as l 19 the staff is concerned, there probably will be nothing done 20 to that report-in particular. We're using it as a stepping 21 stone to go further. 22 The center staff is free to submit the results of 23 their working efforts in that report to journals or ; 24 conferences like international high level waste conference, y
- u l 25 MR. HINZE: Is the seismic line that is suggested )
i l
- 1. .
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141 1 here pretty much a duplicate of what the USGS is currently 2 receiving proposals on? 3 MR. McCONNELLt The seismic line that we -- 4 MR. HINZEt I have not read this report. I have 5 just been handed it. You suggest that you want a seismic 6 line across Yucca Mountain. Is that being taken care of.by 7 the USGS line that is now being proposed? 8 MR. YOUNG: Spangler says they are looking pretty 9 closo in the regions that we would think would be 10 appropriate for those kinds of lines. 11 MR. HINZEt The crust has created a flat in Yucca 12 Mountain -- , 13 MR. YOUNG: Crater Flat right between Red Cone and I O 14 Black Cone and right up against solitario Canyon just to the 15 south of the mountain where the Aluvium goes up in thero, 16 over the mountain and then right out into Fortymile Wash. 17 That's the -- I think what we resolved to do in that report 18 is to first look carefully at existing and emerging study 19 plans on the seismic reflection program, and then to look 20 again at that blue cover report ca the results of the 21 existing work, and to just keep a close eye on it and to 22- take as quick advantage as we can.- We'll try to do some 23 modeling work on it. 24 HR. POMEROY: Steve, just for the committee, could 25 you comment, as Keith points out, you're free to publish O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suhe 300 Washington, D. C. 2000F (202) 293 3950
i i 142 1 this material. Could you point out what you have done and j 2 what you are doing in terms of publishing the material other i j 3 than in that form? 4 MR. YOUNG: Yaah. We've been putting this -- most 5 of this is going into the high level waste conference. l 6 However, we have been chatting about putting something 7 together for something like GSA or JGR. i
- - 8 MR. POMERoY
- I think that would be really useful, 4
9 and also it would get it to a wider -- expose it to a wider j 10 review. ! ) 11 MR. YOUNG: Get a bigger group to hammer on it, 12 it's true. Yeah, we have plans in that area. The very 13 first thing we're going to do is put another little paper in 14 the high level waste symposium on the alternatives work. 15 This is going to go directly towards gee, how come the 16 domino models don't work? Well, this is how come. That's 17 what we're going after right now. i j 18 MR. McCONNELL: I would also, I guess', try to
- 19 prepare you because I think you'll be getting more of these 4
20 center reports like this one. These are intermediate 21 milestones generally that are used to monitor the contract ! 22 to make sure that the staff is getting basically-what it i 23 wants, but we also don't want our center contractors to 1 24 parrot back what we want-to hear. Therefore, they era 25 independent contractors and there is independence in their O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
- 143 1 work, so we would expect to see conclusions made in theen 2 reports that the staff may not necessarily totally agree l 3 with. There is a disclaimer in the report that notes that
~
4 it is an independent product of the center, and if sometime-l ! 5 in the future we intend to adopt it,-than we would come out 4 6 with our own, a staff report on these activities. j 7 MR. MOELLER: Other comments or questions? Well, I { 8 let me close out, then, by thanking Steve and the center I . 9 staff as well as the NRC staff for being here with us and 1 l 10 providing this briefing. You've certainly clarified many i 11 things for me, and I'm sure for all of the Committee l 12 members. We'll take a one hour lunch break, and then we'll ! 13 resume with the briefing on expert judgment, followed by the 1 14 report of the chairman of the working group for total l 15 systems performance assessment. ! 16 Thank you. 17 (Whereupon, at 12:43 p.m., the hearing was l 18 recessed for lunch, to reconvene this same day.) 19 20 21 , 22 4 23 j 24 l 25 O su ANN- RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. _C. 20006 (202) 293 3950
144 1 A-F-T-E-R-N-0-0-N S-E-S-S-I-0-N 2 (1:50 p.m.) 3 MR. MOELLER: The meeting will resume. The next 4 item on our agenda is a report by Senior Fellow Steven Mays 5 on the November 18, 1992 DOE Workshop on Use of Expert 6 Judgment. 7 Steve, it's a pleasure to welcome you, and we 8 appreciate the written report which you have submitted and l 9 which we have seen. 10 MR. MAYS Thank you. I guess what I would like l 11 to do is just give a real brief summary of my impressions of 12 the DOE Workshop on Expert Judgment, and then try to answer 13 any questions you may have about any specifics or things I 14 wasn't necessarily able to put in the memo about the 15 workshop. 16 As I noted in the memo I wrote to you, there were 17 two very fundamental impressions I came away with on the ! 18 workshop that I think were important. One of them has to do l 19 with the issue of the entire dincipline of decision making _ 20 under uncertainty, and that involves both decision analysis , 21 and the use_of uncertainties, and determining the best l 22 courses of actions to take in a process. And the other 23 concerns the elicitation of expert judgment in order to 24 determine what those uncertainties.will be when there's an-l 25 absence of data. O ANN RlLEY & ASSOCIATES, Ltd. L Court Reporters 1612 K. - Street, N.W., Suito --300 Washington, D. C. 20006 _(202) 293-3950
- - _ . - . - - - _ - . ~ . . . - - - - - - - - - . . - - - -
k 145 . 1 There is an obviously growing and continuing l 2 discipline of decision making under uncertainty that has
- 3 been a remarkable progress, and the presentations from the i
4 workshop on those particular areas in that field I was 5 impressed with. 6 There were several people in the presentation list I 7 who were also major contributors to the process that l 8 started, as far as the NRC is concerned, with the expert ! 9 elicitation and expert judgment of NUREG-1150, and some of 1 { 10 those applications have been followed on in other areas with l 11 the DOE as well. l l 12 There was also another aspect of the meeting which 13 was entirely appropriate but was less technical, and that 14 was the issue of the political / legal / social implications of 15 using that kind of a methodology. And that particular 16 aspect of the meeting carried over in almost all of the i 17 presentations, especially in the legal aspects. l 18 I was impressed with Dr. North from the Nuclear 19 Waste Technical Review Board's presentation and his f , 20 presenting of the issues that Dr. Pomeroy wrote to him-in 21 his letter, since he was unable to attend the meeting. 22 I think there is a general consensus among all the 4 23 people there, both the_ DOE, the decision analysis people, l 24 the expert-judgment people, the State of Nevada, the other 2b people; that the tey element in this whole process-is the
- O
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l 4 146 ( 1 legal, social, and public acceptance of how you go about 2 doing expert judgment and what processes and decisions you 1 j 3 apply it to. 4 That is a bigger hurdle to be overcome than the 4 5 particular technical hurdles of how do you combine 4 6 differences in probability distributions derived by various 7 expert judgments and expert panels. ] j 8 So those were the key highlights, as far as I was ] 9 concerned, from the meeting. 10 I noted in the memo, in particular, that Dr. Hora 11 made a compelling discussion about how he has applied 4 12 decision analysis and expert judgment in the commercial i 13 field for corporations. And he noted that the successful
- O.
14 application of expert judgment and decision analysis in his I 15 fields was almost always dependent on what he called a l 16 commitment to action, and that there was actually two tracks 17 of responsibility and decision making that apply. 18 one was the body or persons who had both the
- 19 resources and the commitment to action to make something 20 happen, and the second track was the people involved in 21 eliciting and determining expert judgment and making the 1 22 decision analysis.
! 23 He indicated that he was impressed with some of 24 the decision analysis people at the conference, but he was 25 wondering where the commitment to action was and who was ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
147 () 1 going to be making those decisions. And I think that was a 1 2 very key point in the process that we've seen so far. 3 In addition, there were some very good i 4 presentations about some of the legal aspects of the 5 conference. In particular, there was a paper that was 6 presented, and is in the package that I sent to you, by a 7 gentleman by the name of McGarry, who I believe was with 8 Winston & Strawn, a law firm, who talked in great length 9 about the Atomic Safety Licensing Board process and how they ' 10 tended to view export panels; not just expert witnesses but 11 expert panels at licensing proceedings and what the 12 difficulties and problems that they encountered with that 13 process were. I (_) 14 I'm not sure that anything was conclusively 15 decided at the meeting other than that a lot more work on 16 this whole area needs to be done. But it was a free 17 exchange of ideas, and I think it was good from that 18 standpoint, that it brought a lot of people together so they 19 could talk about different aspects of what they had been 20 doing. 21 MR. MoELLER: Was the NRC staff represented? 22 MR. MAYS: Yes, sir. Dan Fehringer, in fact, gave 23 a presentation which was similar to the one he gave 24 yesterday to your working group. I noted that I saw Lee 25 Abramson, who is a statistician with Research, was at the ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
148 1 meeting, and there were some others there as well. 2 MR. HINZE Steve, were there any ideas presented 3 on how one can achieve the legal, social, and public 4 acceptance of expert judgment? Can you expand on that? 5 MR. MAYS: There were a few. I would say the one 6 that was most addressed to that question which was raised by 7 Dr. Pomeroy and Dr. North at the meeting was a gentleman who 8 had some experience in the low level waste licensing arena. 9 And he presented -- it's in the slides there, I've forgotten 10 his name now. 11 But he indicated that a good portion of the legal 12 problems that have been experienced in the low level waste 13 would be where the developer of a site would create a set of 14 models and assumptions and analyses, and come to a 15 conclusion and would follow that train. 16 The regulator would go out and develop a set of 17 analysis assumptions and solutions and como up with an 18 answer from that train. And an intervenor or an opposer 19 would come up with a set of analysis assumptions and come up 20 the thing, and when they came to the end and none of the 21 answers agreed, they would go to court. And that was the 22 model for which those things were being cited. 23 And he indicated that he thought probably a better 24 way to go about the process was to get all the parties 25 involved at the start, and have the parties decide what were ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
i l 149 ( 1 going to be the models, the assumptions, and the processes. 2 So that when you came down to the bottom there 3 would be one set of analysis, or a group of analysis, that 4 people had gone through the experience and the trouble of 5 agreeing to, so that when the case came to litigation or the 6 case came to a decision maker it would be less 7 confrontational and perhaps more amenable to the process. 8 There are a lot of issues involved with that kind 9 of approach as well. I'm not sure which is the best way to 10 do it. I think there are -- from my standpoint, there were 11 two fundamental issues from a technical standpoint about 12 this whole process. 13 one is the whole concept of decision making under O k/ 14 uncertainty is a relatively new discipline in our society. 15 It's no more than about 30 or 40 years old in terms of 16 active use and commercial and governmental processes. It's 17 not something that people are fundamentally, intuitively 18 attuned to. It follows more of the subjectivist, Baysean 19 type of approach to looking at and analyzing problems. 20 And as the decision analysis people will tell you, 21 their paradyne in decision analysis is to maximize utility. 22 We are often involved in the regulatory business of trying 23 to regulate individual outcomes. And so there's a 24 fundamental difference in that mentality that I think 25 contributes to the problem of dealing with decision making 1
~h
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I i i l I 150 1 under uncertainty. l , 2 over and above that, there is also the problem .i ! 3 that if you accept decision making under uncertainty in the i 4 decision analysis framework, what information goes into the i 5 models. And that's where the expert judgment problem comes 6 in, when you have a sparsity of data and you have to rely on- } 7 degree of belief or subjective probabilities as your. input 4 L
- 8 models, as opposed to, say, rolling dice where you can i
j 9 construct a very nice distribution for what the I 10 probabilities of the individual outcomes of rolling the dice 4 11 would be. i j 12 So there are two issues there that I think are j 13 fundamental problems and that with respect-to taking that-l 14 discipline and gaining the kind of public legal acceptance i l 15 that we would have to have in order to make that process 16 work. l 17 MR. STEINDLER: You are making the assumption that l 18 if everybody got together and agreed in advance that they 19 would by definition come up with the same. answer? ' i i 20 MR. MAYST No, sir. I wouldn't make that i l 21 assumption. I.think that's the fundamental problem with the j 22 approach I just described with respect to trying to get 23 .everybody together and come up with one approach. That was l 24 the cnly novel approach I heard at the meeting towards [ 25 trying to solve the public. legal problem in terms-of the O
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- 151 1 technical answer situation.
l 2 My personal belief is that it's more fundamental ) 3 than that and it goes to getting people to the point wherc 4 the acceptance of decision making under uncertainty and i 5 making a policy as to whether or not you want to really l 6 maximize utility or regulate outcomes. That's a fundamental i j 7 policy issue that I think has not been resolved at the i j 8 levels that would be required to make this process work one j 9 Way or the other. 10 MR. STEINDLER: On a more detailed level, were 11 there any discussions evident of how to reconcile a j 12 quantitatively disparate outcomes of collections of expert 13 judgment? l 14 MR. MAYS: Yes, there were some. The predominant 15 philosophy that I came away with, or at least my 16 interpretation was that most of the people who were experts 17 in soliciting these kinds of things felt that bi-model 18 outcomes, or that kind of result from expert elicitation was 19 usually the result of either poor training ahead of time or l 20 a lack of feedback mechanism within the training and l- ! 21 solicitation, to go back and say here's what the results 22 are; now go back and see if these make sense based on what 23 things we may know or may be able to test. l- 24 During the presentations at the meeting I noticed l 25 a distinct absence of direct reference to this iterative V
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152 () 1 feedback mechanism in the elicitation process. And I spoke 2 to several of the practitioners during breaks and said I 3 think there's a serious issue here. 4 They all indicated to me that they really believed 5 strongly in the iterative feedbacks let's test the 6 hypothesis that we've now come up with as a result of this 7 distribution that we've solicited. And they all believed 8 that that was an appropriate and proper thing to do. 9 But I don't think it gets talked about as much as 10 the more theoretical things, such as what kinds of biases 11 are there and how can you measure them and how can you 12 hopefully try to adjust for them. But I do think that's an 13 important problem. k- 14 Now, there is one international program that's 15 going to go on that Steve Hora is involved with, with the 16 European community, where they're going to try two different 17 methods of soliciting some of this judgment, and they're 18 going to look at different ways of either weighting or not 19 weighting and combining distributions; whether they're going 20 to strive for consensus or they're going to strive for 21 individual inputs that will somehow be put into a model and 22 averaged. 23 So there may be something that comes out of that 24 in the next year or two, but there is still no hard and fast 25 rule for how to do that, coming out of the decision analysis t s ANN RlLEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
153 1 people. 2 MR. POMEROY: The operative word was " averaged." 3 And we've argued at length as to whether that's even a 4 sensible approach. 5 HR. STEINDLER: And the other one was trying to G achieve consensus, which is not my conception of how you - 7 - 8 HR. POMEROY: That's not an adversarial 9 methodology that's normally applied to intervenors. 10 MR. MAYS: There was a considerable amount of 11 discussion on the consensus issue. It seemed to me that 12 most of the decision analysis professionals and elicitors 13 seemed to think that rather than striving for consensus, 14 what you should be striving for in your e11 citation is the 15 broadest possible representation of what the uncertainties 16 are, rather than the narrowest possible agreement for which ! 17 everybody would agree. t , 18 In other words, they wanted to categorize the l 19 uncertainties of the expert population as best they could to 20 its largest degree rather than get the most narrow i,
- 21 distribution for which everyone would agree to. That seemed l
22 to be something that was underlying a lot of the 23 discussions, but it wasn't something that you could nail 24 down firmly. I 25 MR. STEINDLER: Are you saying that people were () ANN RILEY & ASSOCIATES, Ltd. ; Coud Repoders i 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 l (202) 293 3950 l _ _
i l 154 i () 1 more interested in the uncertainty than the answer? j 2 MR. MAYS Yes. a 3 MR. STEINDLER: That's a fine "how do you do." 4 MR. MAYS As a matter of fact, a lot of the -- 1 ! 5 MR. STEINDLER: Is it because it's easier to get? i i 6 MR. MAYS: No. I don't think it was because it's 7 easier to get. I think it was because some of the studies 4 8 resulting on biases indicated that one of the most ,
; 9 significant problems they had with expert elicitation was an j 10 over-confidence problem with experts who tended to think 1
11 they knew the bounds of a problem more closely than they 12 did. 13 They found this in terms of asking people in their i 14 almanac sessions or in their generalized training and 4 l 15 probability sessions to estimate specific values, and they j 16 also asked them to estimate ranges. And what they found 17 often was that people who knew something about a subject j 18 were usually pretty good at getting close to what the value l l 19 was, but were often -- had very, very narrow ranges applied t l 20 to their estimates. ! 21 I qaess you could look at that as either a i ! 22 confidence =in their knowledge of the subject or you can look i 23 at it as some of them do as over-confidence in the subject. 24 There are some very interesting formal processes 25 that they go through to try to determine how people are () ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 - , L . Washington, D. C. 20006 - l (202) 293-3950
i 1 i ] 155 3 1 biased one way or the other with respect to confidence, and i 2 it has to do with both asking them to estimate the single or l 3 the mean value of a parameter and asking them also to j 4 determine what the bounds, or a range in which their 90 l 5 percent confidence, the real answer lies. 6 And so there were several discussions of that at 4 7 the conference. 8 MR. MOELLER: Paul, is it appropriate to move into 9 and discuss at this time some of your plans, or you had 10 talked about a workshop -- 11 MR. POMEROY: I think so. I think he should lead 12 us right into those. 1 13 MR. MOELLER: Fine. Thank you. 1 j 0 14 MR. HINZE: Could I ask one more question of 15 Steve? Steve, in discussing the legal aspects of this, was l 16 there any consideration that one might go to all kinds of 17 lengths in terms of having scientific engineering and 18 technological acceptance of the expert judgment, and having l 19 this fail at the legal level? 20 MR. MAYS: Absolutely. As a matter of fact, as I
- 21 mentioned, Mr. McGarry's discussion of how licensing boards l
22 have proceeded in the past and what one might consider to be 23 if the past is an indicator of the future, that there was no 24 guarantee; that even with a consensus of the expert 25 community and people going into a proceeding, that that was O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D._ C. 20006
IS6 () 1 going to be necessarily acceptable to the licensing board. 2 And, in fact, one of the key points he pointed 3 out, and is in the paper, is that his experience with 4 licensing boards was that expert witnesses and expert panels 5 were extensively and gruelingly examined at these meetings, 6 and that the licensing boards tended to, rather than sit in 7 judgment of the cross-examination of one side and the other, 4 8 tended to be the more grueling of the examiners; and that 9 their examinations tended to go more towards process and 10 What they thought of the people's integrity and their 11 competency to make a decision, rather than on any specific 12 outcome of a specific set of judgments; and that the 13 licensing boards, in his opinion, tended to be sometimes 14 more critical than either of the parties, and that they, the 15 licensing boards, would not rely solely on the counsel 16 cross-examination as their basis for deciding whether to 17 accept the expert panel's judgment or not. 18 MR. HINZE: I suspect that's because of several b 19 reasons. But lack of precedence, the distrust of the 20 scientific bureaucracy, technological technocrats? 21 MR. MAYS: He didn't give any particular reasons 22 or offer any judgments as to why he thought that they did it 23 that way, other than to say that this is the way the 24 experience was and it would be reasonable to expect that 25 experience to continue. A V ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
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' 157 1 MR. STEINDLER Well, you know, in the cold light 2 of morning, if you think about it, how else is credibility 3 as far as the three-man panel is concerned, or three-person 4 panel, how else is credibility established? Certainly not 5 by the color of the tie the person is wearing. And that's 6 the only mechanism that that panel has, I can tell you from 7 limited experience.
8 MR. MoELLER: Well, thank-you, Steve. And we'll 9 hear now frnm Dr. Pomeroy. Stay with us, so you probably 10 will have him -- 11 MR. POMERoY: Right. This certainly ties directly 12 into the meeting that Steve was at and it ties in, to a 13 certain extent, our next topic this afternoon as well. O 14 You have, I think, a copy of a letter that I wrote 15 to Warner North that he, as Steve indicated, summarized in 16 the meeting and, in fact, distributed half of, I believe, 17 after the meeting. 18 In that letter I cited some personal views, 19 although two aspects were aspects that we had discussed 20 before, namely getting some guidance issued on the question 21 of methodology or extraction of expert opinion, and 22 ultimately, perhaps, more than that. 1 23 And the second one was simply that I thought both 24 the Department of Energy and the Nuclear Regulatory 25 Commiss' ion should pick one particular area, not necessarily O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D, C. 20006 (202) 293-3950
158 () 1 the same one, and investigate it in great detail, as we have 2 a commitment from the staff to do in Phase 2.5 of IPA. 3 I quoted extensively from Judge Mims' 7th circuit 4 Court ruling on a case that was rather straightforward, I 5 thought. But he had done an excellent job of summarizing 6 the court's feelings about expert opinion. And so I wanted 7 to bring those to Warner and I wanted to suggest to him that 8 this could be potentially a very serious problem. 9 I'm not sure, in fact I have great confidence in 10 the Hearing Board within the commission and I have great 11 confidence, of course, in the commission itself in making 12 decisions in the face of a largo degree of uncertainty that 13 is support in some way by expert judgment. 14 I am concerned that in this particular instance, 15 in the repository situation, this will certainly be fought 16 not only through the hearing process and through the 17 Commission, but it will be fought in the legal system where 18 we get to the strict application of Federal Rules of 19 Evidence and other doctrines that were cited in the 7th 20 Circuit Court. 21 MR. STEINDLER: I'd like to get back to this 22 question of the Federal Rules of Evidence sometime. 23 MR. POMEROY: Right. I'd be glad -- 24 MR. STEINDLER: Whenever you want. 25 MR. POMEROY: Let me go through this and then I'll O ANN RILEY & ASSOCIATES, Ltd. ! Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
159 1 do that. Remind me. 2 I wrote to Warner that I thought that perhaps -- 3 and I'll try to find it. I thought we should try -- 4 consider the possibility of having a meeting between 5 representatives of the interested parties, the overview 6 people and legal specialists in the area of expert judgment, 7 and plan for the use of expert judgment in the legal 8 framework of the licensing process. 9 What I'm concerned about there is not reaching a 10 consensus on how it will be used, but rather getting -- 11 transferring information from the legal community to the 12 technical community and some sense as to what they're going 13 to face when we get to this situation in court. 14 It seems to me that's a first -- one possible 15 first step as an ongoing -- in an ongoing discussion of the 16 expert judgment question. ! 17 This meeting that Steve went to, I might say, went i 18 on for three solid days. So it was an extensive set of 19 presentations. t 20 I did get a letter back from Warner North, and I i 21 believe you have copies of that also. He indicates the i 22 ! following, and let-me just read a few sentences here. "I l l 23 would like to invite your suggestions on how we," that is l 24 ACNW, NWTRB, NRC, and/or. DOE, "might proceed further in this 25 area." O V ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington,_ D. C. 20006 (202) 293-3950
J t 160 1 And then he goes on to discuss one route might be ! 2 to involve-legal scholars in carrying out a review of 3 relative legal principles, but he doesn't think that's a ! 4 very good idea, and I agree with him. I don't think we have J l 5 the expertise or the time to develop expertise in the legal i 6 areas. i 7 "It certainly, however, is within all of our ; l l 8 charters," this is Warner speaking,- "to point out the need i l 9 for this expertise. Second, it is my impression from the i j 10 workshop that relatively few of the scientists or managers .
- 11 on the DOE program have had substantial experience as expert
! 12 witnesses." i 13 NRC staff have had extensive experience, and j 14 perhaps expensive also, extensive experience in adjudicatory 15 hearings on complex scientific issues. While some > l 16 presentations at the workshop provided an indication of l 17 lessons learned from such experience, much more could be i 18 done to familiarize the DOE program with the situation they i 19 will face in the licensing hearings. 20 And I wondered what the Committee's thoughts would ! 21 be to the idea of pursuing jointly or separauely, as the 22 political and legal considerations dictate, . tith Warner i; -
- -23 convening a working group, in essence, or a subcommittee t
]- 24 meeting, in their case, a combination of the key technical 25 people and some key legal people; involving not only legal Lo ANN RILEY & ASSOCIATES, Ltd. . Court Reporters l 1612 ~ K. Street, N.W.,_ Suite 300 l Washington, D. C. 20006 (202)-293 3950 _._, -__ _ _ ~ . _ _ _ _ _ _ _ _ _ . . - . - _ _ _ __ a
i l 161 1 people from our -- say, somebody representative from our OGC 2 and the DOE's OGC, but also a legal representative of the { 5 l 3 State of Nevada, a legal representative of one of the 1
- 4 counties or other interested parties out there, as well as, i
; 5 perhaps, Dan Riker from the natural resources group.
l 6 I think it would have some merit in assembling and 7 transferring their feelings with regard to what's going to i i 8 be faced and how we might proceed in the most effective 9 manner. i 10 I'd like to think that we're getting to the point i 11 where we could evaluate what we're going to face before we i j 12 get into the actual licensing process. I have brought that j 13 question up, and Warner's response simply was, " Learning by 14 doing in the first ever licensing proceedings for a high j 15 level nuclear waste repository could be very expensive for l l 16 our country." And I certainly agree with that. i 17 I would like to hear any comments you have on that j 18 subject. I 19 MR. MOELLER: Well, let me begin with a question. l 20 Have the NRC and DOE staffs had a technical exchange on this 21 subject or any type of -- between the two staffs? 22 MR. POMEROY: As far as I know, and perhaps we. l 23 could ask Margaret back there, there has b'een no technical 24 exchange other than this workshop on the legal aspects of l 25 the. problem. Margaret? lO ANN RILEY & ASSOCIATES, Ltd. l Court Reporters 1812 K. Street, N.W., -Suite 300 l ' Washington, D. C. 20006 l (202) 293-3950
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- 162 1 MS. FEDERLINE: That's correct, to my knowledge.
f 2 Any discussion -- 1 3 MR. MOELLER: The recorder can't hear you. The 4 microphone there is working. 1 1 5 MS. FEDERLINE: Margaret Federline, NRC staff.
- 6 To my knowledge, there have been no formal l 7 exchanges between the legal staff of -- discussions have i 8 primarily focused as a subset of performance assessment i
- 9 discussions between the technical staff. l
). 10 MR. POMEROY: Right. 11 MR. MOELLER: Well -- so that was just a question i i 12 in my mind. The second comment I would have is several 13 times we have discussed joint NWTRB/ACNW meetings and
- 14 generally have concluded that's not the way to go. Not that
, 15 it wouldn't be useful, but it apparently is very difficult. i 16 So I presume that says we should either encourage them to do 17 it and we would sit as observers, or vice versa. 18 MR. POMEROY: Right. I would like to try it one j 19 more time. We've certainly been encouraged -- 20 MR. MOELLER: We probably should.
- 21 MR. POMEROY: -- to try to do that, and by an
- 22 earlier chairman. I think now there is a different ,
23 chairperson at the NWTRB who_might be more receptive to that 24 kind of interaction. But it's certainly possible to do it 25 by either one of us and have the others simply as active O ANN : RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
163 1 participants. 2 MR. STEINDLER Well, I've got a lot of problems 3 with what I guess I just heard. First of all, let me get to 4 this question of Federal Rules of Evidence. 5 It is presumed by bringing the situation up at all 6 that the results of an expert solicitation -- solicitation j 7 of a group of experts for a value for a concept, or for 8 whatever, is definable as evidence in the context of the 9 Federal Rules of Evidence. 10 It isn't at all clear to me that that's 11 necessarily true. In fact, if you look at the definition of 12 the Federal Rules of Evidence in those two documents that 13 define it, which blissfully are not very big, I think the 14 results of expert -- solicitation of expert judgment are 15 almost by definition excluded from being called rules of -- 16 from being called evidence in that context. 17 I have no training in this field, so you know what 18 that's worth. ' 19 The other. issue, though, that I'm concerned about 20 is that I think somehow or other we're confusing a number of 21 significant points here. one is the methodology of the 22 process and the other one is the ability to apply it. And 23 the ability to apply it comes again in two groups. 24 One is, is it allowed or is it going to be allowed 25 and, two, does it fit into the particular technical-issue O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D,_ C, 20006 (202) 293 3950
1 l 164 1 that we're currently talking about, and does it fit; can l 2 you adjudicate two disparating views, et cetera, et cetera. i I j 3 The major uncertainty that I have is that I can't 4 see my way clear through that first question; namely, is 4 5 this a methodology that people are going tn accept. And I i j 6 don't know what I mean by " people." The Atomic Safety and
- 7 Licensing Board or the commission has experience in this 8 business and I would guess are more comfortable with it than 9 a lot of other people I can think of.
{ l 10 And so I would expect in the Commission circle the' i l 11 notion of accepting the outcome of an expert solicitation 12 process to be not a very difficult issue. I think that l 13 would probably fly. 14 It's not at all clear that, to me at least, the ) l 15 court system, if we are to pay attention to them, are going i
- 16 to view that with the same level of charity. That is the 17 driving force, it seems to me, because at the moment there l 18 are no backups to that system.
l 19 If we can't use expert judgment to arrive at some ! 20 parameters, to arrive at some information that we can't get 21 any other way, at the moment there.is no other way that I'm 22 aware of that is likely to fly. 23 So the court, then, it seems to me, if the court 24 elected to throw out this whole methodology and say, no, 25 folks, you can't use this process for one reason or another, 4 O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters - 1612 K. Street, N.W., Suite 300 Washington,- D. C. 20006 !- (202) 293 3950
1 i t () 1 no matter how well couched; if the court throws that out, i 2 then the court in effect is saying that the process that
- 3 we're trying to do, namely license a repository, can't go
) 4 forward, j 5 I don't know how that's going to play out. But l 6 before we spend an enormous amount of time worrying about ] 7 sharpening up the process of expert solicitation and all the 8 nuances and socio-psychological issues that are involved in a 9 getting six people in a room together, or whatever, it seems l 10 to me we ought to determine first whether -- get somebody to 11 determine first whether this whole thing is going to be ! 12 worthwhile. 13 If we can urge anybody to do anything, that
- 14 strikes me as the number one issue that is necessary to be 15 resolved, but not sufficient. And then we can move further.
i 16 I don't, quite frankly, see what we can gain at 17 this juncture for having a group of folks from the Technical 18 Review Board meet with us and talk about this. It isn't l 19 clear what the outcome would be that would move the ball 20 forward. ! 21 We've had a session, we've had two sessions of l . 22 significance. Transcripts are long and we can get useful 23 information out of that, the process, the methodology, the 24 quality of the outcome, et cetera. I don't think that's
- 25 where the problem is.
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l l 3 166 1 MR. POMEROY: Maybe I didn't make myself clear i
- 2 there. There are people over at the PRB, namely Warner, at 1
4 3 least, that are concerned about this particular problem. We 1 4 are -- I, at least, am concerned about this particular l 5 problem and I know you are also. 6 What I was hoping was that we could have not only
- 7 a few of the Overview Committee people, but that's sort of l 8 almost secondary to having a few of the key technical people i-j 9 from the -- some of the people that we could identify, 10 namely DOE, NRC, the State of Nevada, and any other 11 potential intervenors, talk with and hear presentations by,
{ i 12 for example, somebody from our OGC saying what is acceptable i 13 from the standpoint of the NRC's. legal system as to expert 14 judgment, and what is my opinion of what is acceptable ! 15 outside of the framework of the NRC. i 16 And I'd like to hear -- you know, the concept here 17 is a set of -- small set of lawyers talking to a small set 18 of technical people, not necessarily talking to a few 19 overview people who might be sitting there. l 20 MR. HINZE: I'm confused about what you really } l 21 want to accomplish._ Is this training of the technical 22 people in NRC and the DOE bringing them up to speed on this, > 23 or is it trying-to reach some generalities that we can move . 24 forward? 25 MR. POMEROY: In essence, it's the first, a Lo ANN _ RlLEY & ASSOCIATES, Ltd. i Court Reporters 1612 K Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
I 167 1 modification of the first, Bill. It's not in any way trying 2 to reach any sort of consensus. We'll never do that. It's 3 an education process to ensure that all the parties that are 4 going to eventually be involved in this are going to be
; 5 aware of the positions of the individual agencies involved l 6 with regard to the acceptability of expert judgment.
u l 7 MR. STEINDLER: But it's all very well and good i a for a few lawyers to talk to a few technical people, but i j 9 none of those parties are decision makers. Decision makers, i 10 either the court in D.C. or Supreme Court, that's where it's j 11 going to end up. ] 12 MR. POMEROY: That's right. And all we can do - 13 - 14 MR. HINZE: And we're not going to be able to ask 15 them. i 16 MR. POMEROY: No. And all you can do is get 17 information -- as far as the courts are concerned, all you 18 can do is get any thoughts that the lawyers for the various 19 groups have in respect to such questions as under the 20 Federal Rules of Evidence or under the Frye Doctrine what is l 21 allowable; what is their expert judgment, if you will, on 22 what is all'owable within that court system that's going to 23 make that decision. 24 Certainly, you're not-going to -- I'm assuming 25 that our lawyers, for example, will advise the Commission on . O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 ~
l q 168 1 what they feel is acceptable in terms of expert judgment. 2 So I don't think -- 3 MR. STEINDLER: As far as I know -- i' 4 MR. POMEROY: -- you need to involve decision i 5 makers within the agencies. 3 6 MR. STEINDLER: I agree. But, again, I would go j 7 back to Margaret. As far as I know, our -- that is, legal 4 8 counsel of NRC has not addressed this issue, is that 9 correct, as far as you know? Or Dan, or whoever has looked i 10 into it? { 11 MS. FEDERLINE: Dan is really the best one to ask
- 12 because he's been working directly. But he's been working 13 very closely with cur general-counsel in comparing --
l 14 they've been reviewing any material that we've been 15 developing, and reviewed his presentation that he did at the i 16 expert judgment workshop. I j 17 MR. STEINDLER: Okay. The question I would pose 18 to you-is, supposing we address a question to the General l 19 Counsel and say give us your judgment on two questions. One 20 is the results of -- are the results of expert judgment 21 likely to be allowed in a licensing board hearing, and if l 22 the answer is yes, please answer the same question regarding 23 the federal courts.
- 24 And if the answer is no, then give us an j 25 alternative on how to introduce -- you know, what's the lO l ANN RlLEY & ASSOCIATES, Ltd.
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I j 169 1 mechanism that we need to develop. Is it rule making, for 2 example? 3 And I can perceive of Section 2 where procedures 4 are out?ined, in 10 CFR 2, have a section in which it says 5 rule making will be a process that's allowed if it follows a 6 particular protocol. And we've been talking about having i 7 the staff develop a protocol that would go along with that. 8 And if the answer, which is ~m e likely than 9 anything else, "I don't know," then our question ought to
- 10 be, how can we find out.
11 MR. HINZE: Haven't we been using expert judgment 12 all along with these boards? It's.the -- 13 MR. STEINDLER: Well, except for the two cases - I 14 ~ l 15 MR. HINZE: Well, we've been using -- 16 MR. POMEROY: Excuse me. I -- i 17 MR. HINZE: -- individual expert judgment. This 18 happens all the time. 19 MR. POMEROY Right, absolutely. There is a 20 significant amount of case law in the McGarry paper that 21 Steve cited. -There are hundreds, literally hundreds of NRC 22 cases where expert judgment has been involved, we've been 23 involved; certainly has been used in various ways. 4 l- 24 It's been used in various ways. It's been used as 4 25 individuals testifying, with a group of other experts O ANN RILEY & ASSOCIATES, Ltd. L Court Reporters 1612 K. Stres.t, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
i j i 170 1 standing or sitting beside theta without being sworn in and 4 ' 2 without being irciclved in any way, but simply counseling the 3 person who's testifying. 4 And I don't -- what I don't think we've done is, 5 I don't think we've gone Lnrough the process of looking at 6 large panels of experts testifying in a given area with 7 exactly the same technical basis; that is, all of the 8 material that has been developed in the cite
- 9 characterization program, coming to some og c
- ent conclusion i 10 of this one-group and'having three or four other people, 11 three or four other panels, rather, who base their opinion 12 on the same set of evidence and who get to a different 13 conclusion.
- O 14 I think that's where the real problems are going 15 to lie, and I don't think that that's been really addressed.
16 MR. HINZE: In dealing as we have with expert . 17 judgment and being involved in the firing line, my concern 18 was the experts on expert judgment controlling my decisions 19 -and weighting those decisions. And it's not-tha experts l 20 that I worry about, but it's a concern about how the 21 elicitation is performed and how it is weighted and 22 presented. 23 So we're really putting a group here between the 24 experts, like we have for centuries, and trying to come up 25 with some commonality, some -- as'you put it, a large group I - ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. . C. 20006 (202) 293-3950
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i 4 4 l 171-i i coming together and having that brought as a decision. 2 MR. POMEROY: Right. And I don't knod how the
- - 3 courts -- the courts will say that -- one of the things that i 4 Jim Wolfe, I believe, would say is we'll take each -
5 individual panel, one person at a time and find out -- go 6 through the whole process and find out the process by which i 7 he reached a conclusion; what the conclusion was, and j 8 whether it's based adequately on the acceptable scientific l 9 principles of.the day, basically what the Federal Rules of l
- 10 Evidence try to say.
i j 11 I think the Federal Rules of Evidence are very ! 12 reasonable, in fact. l ! 13 MR. STEINDLER: For evidence. j O 14 MR. POMEROY: For evidence, yes. 15 MR. MOELLER: -Dan, I'm sure, has some remarks, but ! 16 I guess the part I find myself confused on is that we had a l
- 17 working group meeting on expert judgment. DOE has spent, l 18 obviously, a lot of money. Remember Bonanno was in here and-1 l 19 had what I call, or what to me is-the bible on expert 20- judgment. I' guess that was -- was that a NUREG document?
~
21 MR. POMEROY: That was a-NUREG document that 22 somebody had contracted. 23 MR. MOELLER: The NRC paid for that. And doesn't 24 even Part 60 have words about expert judgment? Am~I , 25 dreaming? 00 ANN RlLEY_ &- ASSOCIATES, Ltd. Court Reporters
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) 1 MR. POMEROY: Dan?
2 MR. FEHRINGER: Dan Fehringer of the NRC staff.- 3 Part 60 does have some words talking about reasonable 4 assurance and recognizing that uncertainties will exist in 5 any demonstration of compliance. I think that infers that 6 judgement will be a major part of the demonstration of 7 safety. 8 MR. POMEROY: Right. I think the problem goes 9 beyond that, however, though. Those were good wordo, and I 10 think they are good words. But the whole question of the 11 identification of those uncertainties and what'is actually 12 going to be allowed in:the court system is another question. 13 Bill's question really relates to Marty's first 14 point, mainly the methodology needs to be out there. We 15 certainly need to encourage that to happen. 16 MR. MOELLER: Where I was confused, I.though I was 17 hearing the basic question as to whether expert judgement-
.18 will be used and whether-it will be allowed.
19 MR. STEINDLER: You mean by licensing. board 20 or -- 21 MR. POMEROY: My suspicion-is that individual 22 expert judgement will be allowed by the licensing boards. 23 because it has been. There's a great deal of precedent, and 24 the legal profession lives on precedent. 25 I'm not sure how they might deal with-the question O ANN = RILEY & ASSOCIATES, Ltd. Coud -Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
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}, l 173 1 of panels of experts -- t 2 W. MOELLER: Okay, sure. ' 3 MR, POMEROY: -- because we've often been told i 4 here in the meetings you cite that after all, we'll look at ' i i 5 the underlying scientific basis, the technical data that i l 6 underlies the decision, and then we'll make a decision. 7 This is the staff speaking. l i 8 That's a good statement, but if it's the same set 1 j 9 of technical data that underlies a number of different j 10 opinions that all diametrically opposed from one another, a 11 the decision-making process is thrown to the next step, it ! 12 seems to me. I don't know how that's going to happen. t i 13 I think it's worthwhile trying,-using some ! 14 methodology, to communicate in a straight-forward-way to the-l
- 15 Department of Energy what kind of-obstacles they're going to 16 run into at an early point in time.
l 17 In fact, we've talked about other. methods ofl jump j 18 simply running through a whole mock system to try to go i ! 19 through the whole system once with expert' panels, with , 20 people sitting as adjudicators to see what might transpire. 21 This alternative is another way to try to do that, 22 I'm looking for alternatives, though, gentlemen.- I'm f j 23 certainly not advocating more work here for myself.. {. 24 MR. MOELLER: Let's-hear from Dan again. You're l l 25 correct. - Then I think we need to decide what is our-
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! 174 1 objectiva. What do we want to do?
2 Dan? 3 MR. POMEROY: Let me just say that I think we 1 - 4 could ponder that question for a month also, as an 5 alternative. 6 MR. MoELLER: Sure, sure. ! 7 MR. FEHRINGER: In preparing the talk I gave to ! 8 you yesterday, I was lead to believe that it's very 9 important to distinguish between the admissibility of ! 10 evidence on the one hand versus the weight that.a particular 11 item of-evidence will carry in formulating a decision on the j 12 other hand, i i 13 The standards for admitting evidence to the NRC O O 14 hearing are not really great. They're the two that I 15 described yesterday -- show that an expert truly has-l 16 expertise and show that the evidence he wants to offer;is 17 relevant to the issue that's being discussed. f f 18 Whether or not the board will place. great weight l 19 un-that particular evidence, it remains to be seen. It 20 -depends on the quality of evidence and the reasoning that 21 underlies it. 22 I've been lead to believe that the reasoning is 23 really what is important and that the process by which 24 evidence is developed is largely irrelevant. So, a formal i 25 elicitation process would be of value to the extent that it O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
175 1 helps an expert identify his reasoning, document it, and 2 articulate it as he presents his evidence. 3 The process by itself probably has no real value 4 in convincing a board to accept the particular evidence 5 that's offered. 6 So those are a couple of thoughts that you might 7 vant to pursue with actual legal counsel rather than a 8 member of the technical staff if you develop this kind of 9 workshop that Dr. Pomeroy is suggesting. 10 oh, one other point that I wanted to offer, I've 11 -also been lead to believe that the Federal courts-will not 12 review an NRC licensing decision on the basis of its 13 technical merits. There's supposed to be a precedent by the 14 Supreme Court telling the appeals courts to stop doing that, 15 that the purpose of the NRC is to make those technical 16 findir.gs and the court should defer to- the NRC's technical-
-17 expertise.
18 of course, creative lawyers can always dress up a 19 technical argument in legal grounds and get it reviewed in 20 the courts. But that again might be an area for you to. 21 investigate with legal counsel just what are.the limits of 22 the' Federal court's ability to delve into technical matters-23 -versus sticking with strictly legal or procedural matters.if 24' a decision is appealed to the courts. 25 MR. POMEROY: Could I just speak to that for a O ANN - Rit EY. & ASSOCIATES, Ltd.. Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. - C. 20006 (202) 293-3950
l 176 I () 1 second? Of course, as you are well aware, more than I am, 4 2 the real purpose of the formal elicitation of expert 3 judgement is to clearly delineate and document the thought i
- 4 process that goes into there. I stress the word " document."
l 5 I believe we should utilize some sort of formal 6 elicitation of expert judgement every time we make an insert 7 of expert judgement. We're tempting to do it implicitly. I
! 8 think we should do that explicitly. I think we should i
i 9 document that very carefully. j 10 So, that would be my rationale for agreeing on i 11 some methodology that meets some sort of current consensus ! 12 in the community, but would provide a sort of uniform basis 13 for inserting expert judgement into the system. 7-s I 14 This is a non-lawyer talking to a non-lawyer, now, i 15 I do agree that courts don't. tend, as far as I understand i 16 it, to turn over technical decisions based on technical 17 issues. f 18 However, I think, as I said yesterday cnr whenever, l,
- 19 the courts could be persuaded, I.think, relatively easily if 20 the Federal rules of evidence have not been utilized by the f 21 Commission to reconsider the Commission's decision-based on l
L 22 the fact that the evidence that was introduced was faulty. 23 It would not qualify as evidence in a Federal court. i . 24 That's not a technical issue. That's a matter of l-l 25 law. () ANN RILEY & . ASSOCIATES, Ltd. l- Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-39501
4 1 177 ( ) 1 MR. FEHRINGER: Yeah. I think that's an area 2 where legal counsel is really needed. 3 MR. POMEROY: Right. But I think somehow this 4 needs to get conveyed in some way. This whole set of i
- 5 arguments needs to get conveyed in some way to all of us, 6 but particularly to the Department of Energy because it 7 seems to me, as Marty said, before we go too far down the
} i 8 primrose path, we should find out whether or not this is a 9 potential showstopper or not. 10 MR. MOELLER: Steve Mays. ! 11 MR. MAYS: I would suggest on that issue of i 12 reviewability of technical decisions that we have a recent i 13 example that might tend to make you think about it again and 14 that is the recent court decision in which the Federal 15 courts overturned an EPA decision on asbestos, primarily on i 16 the basis of subsequent expert testimony, the basic legal 17 argument being that the-decision of the Administrator at the i ! 18 time was capricious. l l 19 So, there was an example in where the technical 20 judgement of the legally-appointed body at the time was 21 subsequently challenged in a court, not on'the basis of l [ 22 procedural error, but on the' basis of fact. ! 23 MR. POMEROY: Why don't I suggest that we think 24 about it for a month? We don't have to make a decision. 25 Sooner or later I-would like to get back to Warner and talk-O ANN RILEY & ASSOCIATES, Ltd. L Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202)-293-3950-
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3 i 178 1 with him more and perhaps I will in an informal way. 2 MR. MOELLER: Sure. We may even have time 3 tomorrow. We'll see. 4 MR. HINZE Would it also be reasonable to see [ 5 whether our OGC has the resources, the interest, whatever, 6 to conduct this kind of a study-that we might suggest to the 7 Commission? Before we get too far along the process, what
- 8 kind of interest is there in the OGC?
1 9 MR. POMEROY: Again, Dan can probably speak a 10 little more to that. I would think there would be a great I 11 deal-of intterest in the OGC simply because I'm sure that Jim ! 12 Wolfe knows. He'll be faced with these issues. He's been l _ 13 faithful in attendance at some of these meetingc to l 14 recognize he issues that'we're discussing. l 15 MR, STEINDLER: Yes, but he's also no spring 2 16 chicken. Remember this is a very slow process. l 17 [ Laughter.] 18 MR. POMEROY: Are you speaking for yourself? ) 19' MR.-STEINDLER: Yeah, I-am speaking!for myself. l l 20 MR. FEHRINGER: I-would just say-that if-you do ) i 21 make a request to general' counsel, it's probably better to ; i 22 go to the hearings attorneys rather than the rule-making 23 attorneys. They-have a little more experience in the proper i'
-24 areas. Jim Wolfe is-a-regulations lawyer rather than a-25 hearings lawyer.
i i ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 j Washington, D. C. 20006 i .(202) 293-3950
I i i 179 () 1 MR. POMEROY: Thank you. That's a good point.
; 2 MR. STEINDLER: Is it likely that if-you got-a 3 whole bunch of folks together in a room -- well, that's 1 4 almost biasing the case -- but to address the question:
5 What is the optimized methodology for eliciting expert 6 judgement -- is it likely that the staff, for example, could g 7 write a set of ground rules to do this and not get an 8 enormous amount of flack from the rest of the community on 9 that process?
- 10 MR. POMEROY
- I suspect if you limit the 1
11 discussion to people within the United States, that there is l l 12 a pretty good unanimity at this point in time simply because 4 13 there is only one predominant met'ncdology since allaof the j 14 practitioners have gone to the same school, _in essence, and ,
- 15' have been trained by the same professor.
i 16 That's not necessarily the best methodology. On l 17 the other hand, Dan of course, is quite correct that it's l 18 not the methodology that does anything for you in this game, 19 it's simply a matter'of making it simpler in the licensing 20 process to identify what's happening. L 21 MR. STEINDLER: Bill raised, I think, some 22 interesting points which ought to be raised by_almost every. ! 23 expert who's been asked to participate on panels. What is 24 this methodology-going to do to my ability to make stick my , 25 view? That's a very good point. l LO ANN RlLEY & ASSOCIATES, Ltd.- l Coud Reponers
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180 () 1 The other question I would ask is whether we ought 2 not to be thinking about back-up methods. Suppose this 3 whole thing falls apart for one reason or another and 4 conflicts can't be resolved between the European model and 5 the American model, as is true in the case of the weather 6 forecasting, do we have another way to get at the kind of 7 answers without flipping coins? 8 MR. POMEROY: I don't know. My feeling is that 9 you can get at the answer either way there. I think it 10 would be very nice to have consistent rethodology. 11 MR. STEINDLER: Do you get the same answer? 12 MR. POMERoY: Well, we never get the same answer. 13 You know that. b Nl 14 MR. MOELLER: Okay, we'll certainly return to ~ 15 this. The discussicn has been helpful to me in beginning to 16 have a broader view of the subject and some better 17 -understanding. 18 The next item on our agenda, and the final formal 19 discussion this afternoon, is the Working Group Chairman's 20 report on the meeting on total system performance 21 assessment. We will go ahead with that then, now, Paul. 22 MR. PCHEROY: Dave, what I thought I would,- if 23 it's acceptable to you, is I thought I would review some of 24 my impressions of our meeting yesterday. I've talked 25 informally with a few of the other members of the committee. O ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 ! (202) 293-3950
l 4 181 ,
) 1 They have, of course, their own perspectives. I'd like to 2 try to gather all the perspectives of the Committee 3 together.
4 Then, I will listen while other people talk. From 5 my perspective, this was a very important meeting in that it i 6 allowed us the opportunity to do a side-by-side evaluation 7 of both the NRC and DOE programs in performance assessment. 8 1 don't think we are going to have an opportunity like that, 9 unless we force it, for at least a period of another two 10 years. That is, I don't think there will be TSPA-2, or even 11 an Iterative Performance Assessment Phase III completed 12 before a period like two years.
; cs 13 My first statement is a laudatory statement. Both kJ 14 of these programs have made major significant progress since
}5 _y{ng}y{gua}3asgyeviews,andourlastreview, m
and both of 16 them deserve a great deal of commendation. 17 My second point is, that with regard to what they 18 said they were going to do, in general, they have 19 accomplished the purposes that they set out before they 20 began. They have done that work, and we are going to have a 21 lot of comment on that shortly, but they have also laid out 22 reasonable goals for themselves, although extremely 23 ambitious goals for themselves in the next iteration of 24 their performance assessment. 25 The third point that I want to make is that I
~ /N L)
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182 () e's 1 believe, in particular, the NRC Staff should continued to be 2 provided the resources necessary to continue their PA work. 3 Enhanced computer capability is on its way, I understand, 4 and other appropriate resources should be considered. 5 However, I am concerned about the totality of what 6 is being done by the NRC Staff, and I believe that a careful 7 evaluation of NRC's need to develop codes, models, should be 8 carried out and, where possible, codes developed elsewhere 9 in the community, be it national or international, should be 10 utilized. There are economies to be realized. It is not, 11 in my mind, necessary that NRC develop every one of its own 12 codes. s 13 My fourth point, and perhaps my most important t point is, my principal concerns, and they are generally 14 15 shared by our consultants as well, involve two things that 16 this committee has been inv_olved with for a long time, 17 namely the treatment of uncertainty by both groups, and 18 secondly the use of expert judgment. 19 Let's not belabor the question of expert judgment, 20 although I think it is perhaps even more important. We have 21 discussed it to some extent, and we can do more, if you 22 would like to do so. I have great difficulty, when I sit 23 through three days of performance assessment and listen to 24 both groups, to get a clear picture of the totality of the 25 uncertainty that exists in any given result, or even any r~T U ANN RiLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950 i
d i 183 () 1 'given set of models. Why is that? 2 Well, the models are certainly difficult in { 3 themselves, but they are not impossible. I believe that i 4 there are a number of problems, one is that you have a 5 simple variable uncertainty that where you have data you can 6 get different people to provide you a distribution on the
- 7 data. When you step outside that range, and that, of 8 course, is primarily where we are right at the present time, 9 because we have so little data, then you get into this
] 10 question that Steve brought up, and that I have brought up 11 before this committee before, namely the degree of belief 12 probabilities. 13 And if you ask six experts, you may get six l 14 different ranges of a variable distribution with little or 4 15 no overlap. That should be documentable, however. 4 16 What I am concerned about is that there are 17 conceptual uncertainties underlying many of the calculations 18 that we have looked at in the past several dayc, and let me 19 offer you one example of-that, which may.or may not be car 20 important example. 21 The flow and transport models of both groups are 22 bounded by some physical boundaries, and both of them tend 23 to exclude-any possibility of feed, for example, from the 24 Solitario Canyon. Linda Lehman, who works for the State of 25 Nevada, has prepared a paper based on-what I think is a
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184 ( 1 reasonable dataset, although I haven't had a chance to 2 review this in great detail, offering an interesting 3 hypothesis that there could be a focusing of flux into the 4 repository system from the West. That is precluded by the 5 models because of the choice of boundary conditions and so 6 forth. 7 Her statement, which was made very carefully, I 8 believe, was, that might-involve three to five orders of 9 magnitude difference in what you consider, and she asked 10 simply that that be considered. 11 I think that is a reasonable request. I think 12 that three to five to orders of magnitude uncertainty, and 13 those calculations ought to be considered and assigned some 14 probability. 15 I can't identify, in critical areas, where there 16 are similar types of uncertainty from the presentations that
-17 we-have had, and-from what I have read. I think that the-18 two problems of uncertainty and expert judgment are 19 extrnmely di_fficult problems that we really need to continue 20 to investigate at some significant level or detail.
21 You know of the SECY documents'that have been 22 prepared on the treatment of uncertainty by the NRC Staff. 23 I don't believe that adequately addresses the problem. I 24 certainly don't know what the Commission thinks about that. 25 I think we should continue to pursue uncertainty and find ANN RILEY'& AS3OCIATES, Ltd. Coun Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
185 a
) 1 where these sources of uncertainty are.
2 I have a number of other comments, Dade, and I 3 would like to run through them. None of them, perhaps are 4 as potentially dangerous as those two items, namely the 5 uncertainty and the use of expert judgment. 6 The next one is, neither the NRC nor the DOE 7 provided many examples of the changes in performance 1 8 assessment brought out by other groups within the same 9 agency, nor changes in actions of other groups resulting 10 from the PA. We got lists of those. A lot of those lists, 11 at least from the NRC's perspective, were changes in models 12 one way or another. Those aren't the types of changes that 13 I was thinking about, at least when I posed the question.
\/ 14 As Felton Bingham pointed out, there was a rather 15 communality of interest and results in the lessons learned.
16 By and large, DOE could concur with many of the lessons 17 learned by the NRC Staff, and hopefully from Felton's 18 comments, they have learned some of the same lessons. 19 There are some fundamental problems-in definitions 20 of scenarios, and CCDFs, that the staffs have agreed to work 21 on. However, it is somewhat dicconcerting -- I gue_ss that 1 22 is a good word -- that this late in the performance i 1 l 23 assessment process there are differences in the NRC's l 24 concept of those issues versus the DOE's concepts of those l 25 issues. D (V ANN RILEY & ASSOCIATES, Ltd. Coud RepOners 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
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4 i 4 186 l 1 It isn't clear to me that other priorities within 1 ! 2 DOE, as they were outlined by Dr. Boek, will allow a timely ] 3 completion of the TSPA-2. In fact, I believe, from what he 4 said, that it had the lowest priority of a number of other 5 issues. I understand that, and I am concerned that portions ] 6 of performance assessment within DOE will be -- I am not 7 concerned that they will be used in other areas, but I am l. ! 8 concerned that that use will detract from a continuing i 9 systems performance evaluation. j 10 Both groups should be encouraged to maximize their l 11 input to the Academy of Sciences Committee that is in the. 12 process of being formed. Particularly, the staff, in the 4 13 past, has conveyed their ideas on-a risk-based-assessment, l 14 as you brought up this morning, I believe, Marty, they 15 should certainly continue to express those views to the l ! 16 Academy. 17 I think most people would like to see the word ] 18 " validation" go away. It is a terminology that is i 19 preferred, certainly by the Europeans, but many people would t 20 like to see it replaced by something like, adequate to the 1 21 purpose or intended use. 22 Because T am concerned about uncertainty, I am 23 concerned about the use of a " turnkey" sensitivity and 24 uncertainty capability. That is the development of a code 25 that you plug in certain parameters at one end., and you LO ANN RILEY & ASSOCIATES, Ltd. 4 Court Reporters 1612 K. Street, N.W., Suite . 300 Wye # Won, D. _ C. 20006 i OD2) 293-3950
f 187 1- inject the sensitivity, I am not as concerned about that. I 1
- 2 am concerned that the right numbers come out in the terms of 3 uncertainty at the other end.
4 Although I didn't ask that question during the 1 5 presentations, I think that that is something that I am
; I j 6 personally going to look into in some detail as far as the 7 staff is concerned.
j 8 Margaret Federline brought out a point at the end i 9 of our discussion that the NRC IPAA, if I understood her i 10 correctly, will produce, to paraphrase, a group of good PA ! 11 analysis, and it is importance as a training tool certainly l 12 should be continually emphasized and encouraged. i i 13 Individual dose calculations should be encouraged a 14 by all of the groups involved. Certainly, the concept has u ! 15 been around now for a significant period of time, yet what j 16 we have seen to date in terms of individual dose j 17 calculations is certainly minimum, and-we should be seeing -
- 18 more of that.
19 There are a large number of. comments that I could' i j 20 make about codes. Let me just make a'few. One is that the 21- NRC developed a modified codes. If we are going to develop 22 codes within the NRC,-we should try to achieve some sort of' 23' a peer review, a formalized peer review of some of-those 24 codes to make sure that we have {dentified all of the 4 25 possible holes in their-construction and, in fact, of j l . O ANN RILEY & ASSOCIATES, Ltd. 1 Court Reporters
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i t j 188 () 1 course, as always, their use should be peer reviewed also, i l 2 One thing that was very useful to me yesterday was j 3 the tree models that Felton Bingham used to map out the PA 4 modelling efforts. I know NRC does-some of that, but I i 5 think that these road maps of the modelling structures i 6 certainly might be considered by NRC as we develop any of i 7 our own codes, j 8 I also have about ten pages of comments from one l l 9 of our consultants, Dade, which I need to review further i i 10 before I present them, and-I would like-to simply _ask that I i i 11 have the. opportunity to do that before we talk about that, i 12 Let me stop there. I do have some thoughts about 13 where we should go from here, but I would_like to hear what lO j 14 the other members have to say. i 15 MR. MOELLER: Bill. l-l 16 MR. HINZE: Could I ask a question, as~you were 17 talking about your two. key things, uncertainty and expert 18 judgment, I.wasn't able to be here the first two days of it, , 19 was-anything said-about the use of fractiles in_trying~to l ! 20 minimize the uncertainties in physical-hydrological-
- 21 parameters, has anyone approached that?
l 22 It seems to me there is a piecemeal-of indefinite l l 23 detail that one might be able to-use to try to get at the 24 scaling problems here, and I am certainly not an expert on j 25 fractiles. I have sat with Don Turcotte and tried to f !O ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders
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i l i-189 i 1 understand them, but I wonder if anyone has touched up on l' 2 that? i~ 3 The fact of the matter is, we were going to have a 4 working group on fractiles at one point in time, and it 5 seems to me that there are better statisticians than I would 6 want to be in the room, and I would be interested in whether . 7 there are some approaches here, or perhaps we could be 8 thinking about a working group meeting that might help us to 9 find out what the proper role of fractiles are. 10 MR. POMEROY: First, let me say I agree with you 11 100 parcent. There is a great deal that we might learn out l 12 of that process, but certainly not in the last three days, ! 13 nor in my associations with the performance assessment 14 groups have I heard of people actively considering l 15 applications of fractiles-to this, but perhaps Georgio has 16 another thought. l 17 MR. GNUGNOLI: If I recall correctly, I believe, I l 18 can't remember whether it was Mike Wilson or Eslinger, l 19 discussed that they did use fractiles in terms.of looking at l l 20 the fracture flow, and I was curious _that that is what stuck l- 21 to me, but they did, and there was a very short mention of i-22 it. I do believe that DOE, either at PNL or Sandia are 23 looking at fractiles for that purpose. l-24 MR. HINZE: We are seeing a lot of papers on that i 25 topic now in terms of fracture, what might lead to fracture ANN RILEY_ & ASSOCIATES, Ltd. l Court Reporters i 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 (202) 293-3950
4 ) 190 3 1 flow using fractiles. 2 MR. POMEROY: I certainly missed that reference. i 3 MR. STEINDLER: Fractiles won't qualify under'the i j- 4 Federal Rules of Evidence. ! 5 MR. POMEROY: Yes, sir. I.am aware of that. 6 Chaos might. 4 ! 7 [ Laughter.) i ! 8 MR. HINZE: Some of the problems in seismic 9 prediction are not too different_than what we are dealing 10 with here in a small sample' determination of properties-of a , 11 block of ground, and fractiles are being uced in that area, j t 12 not notably successfully, but they are coming along. ! 13 MR. MOELLER: Paul,-1 have a few comments, but let i'
- - 14 me begin, though, by complimenting you on your summary, and
- 15 I was think,_you know, if the committee, and I don't think i
l -16 we are headed this way, but if we were to write _a letterion l 17 this, it would certainly be a long letter,_not-that;itfis l l 18 negative, but it is just.that there are so many. things to l ! 19 comment on. 20 I would begin by repeating your compliments to-
~
21 both-the DOE and NRC Staffs,-and what really ' impressed-me ,- 22 was:the way they communicate. They are all seeking the-very f 23 best scientific effort that they'can accomplish'. It almost
- 24 reminds me of the neighbors where the-children play and_get L
25 along well but the_ parents don't. l-l () ANN RILEY & ASSOCIATES, Ltd. L . Coud Repoders t 1612 K. Street, N.W., Suite 300 ! ! Washington, D. C. 20006 !~ (202) 293-3950
} 191 l 1 At this level in the staff, the communication is 4 2 obviously there, and either they are good actors -- and I 3 don't believe that, I think it is sincere. There is no t j 4 holding back. They really open up, they lay their cards on 5 the table.
, 6 I believe, in line with that, again, Margaret 7 Federline is to be complimented on organizing it, and on i
- 8 this strategic plan that she is having them develop. That l
l 9 is excellent. i l 10 I would repeat your comment that, in terms of 11 defending the NRC effort, don't forget training and 12 education of the staff, and getting their hands and feet i 13 dirty so that they know what it is all about. That, to me, l 14 is as important as almost any other aspect. l 15 Let me just zip through a number of things, most i
- 16 all of which will reveal my ignorance. First of all~, we 17 heard that they will be publishing this in NUREG-1464'. -I j
18 presume, and they can answer it later, that they will hold , 19 up NUREG-1464 until they can do some' runs. I don't know 20 that I heard that, but I hope that is crue because'they said 4' 21 the-runs were imminent. 22 Again, taking these in no set sequence, just the i 23 way I put them down, they showed that they had the'four-by-24 four matrix.for the scenarios, and they showed that 12 of 25 the 16 classes that you end up with in the four-by-four ANN RILEY & - ASSOCIATES, Ltd. Court- Reporters 1612 K. Street, N.W., Suite. 300 Washington, D. C. 20006 , (202) 293-3950
1 l 192
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( ,T/ 1 matrix have probabilities of occurrence below this rationale . 2 that even EPA requires that it be considered. 3 So my immediate response was, then are only four 4 scenarios survive, so you need to go back and create a new 5 set. Then they said, those that are thrown out, or that 6 would be rejected have subclasses that wouldn't be rejected. 7 That is fine, but if there is some step in the 8 total scenario that rejects it, then I still -- I don't 9 understand why I wouldn't throw the whole thing out. So 10 that is where I need education. 11 To hit a key point, this one leaves me troubled, 12 and I don't know how to address it, and I hope I am not 13 misquoting either the DOE or NRC Staff, but DOE said, at the 7-(
\> 14 moment we are not following QA practices, we will work those 15 in later when we get over the hump and are really getting 16 into the real final production stages.
17 Then the NRC said, again, revealing my total 18 ignorance, said, whereas DOE must follow QA procedures, the 19 NRC Staff doesn't have to. Someone said, well, they met 20 only QA-1. Again, that doesn't help me too much. 21 So I think we need to ask or have clarification on 22 that. The DOE asked -- and, again, Margaret Federline, 23 throughout the meeting was making a list of major topics for 24 further or for new forthcoming technical exchanges, but DOE 25 did request several times for guidance or criteria for n V ANN RILEY & ASSOCIATES, Ltd. Coud Reponers 1812 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
1 4 193 ( 1 developing scenarios, and apparently they do not, although 2 they seemed in the exchange to better understand, but they l 3 did have questions. i 4 One thing of interest to me was the fact that 5 several of the DOE groups showed that they, in order to ].
- 6 overcome this problem, if we go to a dose limit for 7 individuals, in order to overcome the problem of a dry site 8 giving too high a dose, one group was going to assume a 1 9 million gallon per day consumption of water, and that would 10 be for everything, ated factored into the DITTY Code and come 11 out with doses.
i 12 Then, as I recall, another proposal we had was to 13 put limits on the aquifer in which the release would be 14 diluted, and assume that that is a standard biosphere 15 aquifer. Others can explain more about that. 16 This one troubled me somewhat. I heard and I 17 guess this obviously was DOE. They said although plutonium 18 dominates the estimates of the dose they are not going to 19 .give it any special treatment or they have not. A more 20 accurate way of saying it is they have not up to-this point 21 given it any special treatment. In other words, they just 22 treat it like anything else, I guess, and I would think.if 23 plutonium does indeed dominate the dose then, over whatever. 24 else dominates it, then those nuclides should receive 25 special treatment. O O ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
i l 194 () 1 MR. STEINDLER: What do you mean?
- 2 MR. MOELLER
- Well, I mean apply solubility 3 factors or transport factors or release limit -- you know, 4 treat it separately to define as carefully as you can the i
5 behavior of that particular nuclide. 6 They pointed out, I guess it was DOE, and I found 7 this interesting, that again if you look at human intrusion 4 l 8 and want to keep the dose to a minimum, you want the 4 j 9 repository to leak as much as possible to spread and 10 uniformly spread out the waste so that when you drill into 11 it you don't hit a hot-spot. That'was facetious but it is, 12 you know, it gives you pause for thought. 13 They are, they did define or list lessons learned. l( l 14 They do appear to be using their performance assessment to 15 help plan site characterization. Stevo Frischman of course, i i 16 from Nevada, urged that they get on and devote more time to i 17 data collection and less to PA. I don't necessarily agree l 18 but it is in line with certainly using-the PA to determine l 19 what your data needs are.. 20 I, too, shared the question and again it's my area 21 of, one of my many areas of ignorance but David;Okrent asked 4 l 22 them time and time again, you-know, how-are you dealing with 23 uncertainties? Are you quantifying the uncertainties, and 24 so forth, and I think at this point they are really not 25 doing too much in it but then in the very end on Tuesday 1 . 1 () ANN RlLEY & ASSOCIATES, Ltd. ; Coud Repoders i 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006
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- ( 1 afternoon we see that they have a computer code, as you
! 2 mentioned. You just plug everything in there and it tells ! 3 you all the uncertainties. You don't need to know anything. l 4 Well -- you know -- 5 MR. POMEROY: That's what I am concerned about. l 6 MR. MOELLER: They also raised severe 1 times how ! 7 useful or valid is the Kd concept and of course I don't 8 know. Other people will have to consider that. j 9 Oh -- they did show that in the CCDFs that whereas ! 10 in the main the individual ones comply with the standards, 11 they did show that this 10 to the minus fifth, Part 60, 12 release, violates I think the CCDP or, you know,-the EPA l 13 standards in several instances, which is interesting. ) 14 Then their bottom line of course of the technical 15 conclusions, those are very interesting. Even if qualified, , 16 they are beginning to give us perspective, so I think with
- 17 that I'll quit.
i 18 MR. POMEROY: Can I add one thing in there that I h 19 did forget? It bears some again on this uncertainty. 20 question and that is the process of abstraction concerns me 21 as part of the uncertainty problem. 22 We see-a-pyramid of very detailed discussions and 23 there may-be a careful consideration even of the ranges of 24 uncertainty down at that bottom level where-the detailed 25 calculations are carried out,-but my uncomfortable feeling ("% A_). 4 ANN _ RlLEY & ASSOCIATES, Ltd. Coud Reponers 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
4 4 ' 196 1 comes from the fact that when you abstract and what I call i 2 simplify that process that those ranges of uncertainty don't 3 get adequately translated into the abstracted or simplified 4 calculations that you are doing -- at least I can't see l 5 where they are carried through in their entirety. 6 Somehow that should be a process that is clear in 7 the process of abstraction. Excuse me, Marty.
- 8 MR. STEINDLER
- I don't know why I'm next. You i
- 9 know, all the things that have been said about the first two 10 days I guess I'm sorry I didn't, I couldn't get here.
11- Sounded like it would have been quite useful. 12 However, you know, I have already basically made 13 some of the comments. One of the things that we keep 14 addressing indirectly is the whole issue and expert judgment 15 is a good example of what is going to be acceptable, not so 16 much to the technical community but this thing has to be
- 17 palatable to the world-at-large.
18 I have some real problems with the way codes are l 19 currently assembled. They are fundamentally opaque. They 20 are even opaque to the ur.er, which troubles me probably most
- 21 of all and when somebody says, oh, gee, I have discovered 22 this great way of compressing this code so I can run it in i 23 two minutes of Craig time instead of 20 hours, you know, i
24 it's mandatory to know what that does. 25 In *-hat same vein I think it is important to make
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197 1 sure that the experimental data that served as the 2 underpinning to a model or a code are in fact relevant to 3 the scenarios that are being described by that code. That 4 is not always the case. In fact in many instances it is not 5 the case and, as you know, we have made comments to the 6 commission concerning repository relevant experimentation, 7 which is quite scarce. 8 I suppose during the first two days somebody 9 addressed this issue and I don't know whether that is true 10 or not but I hope somebody talked about the question of when l 11 are the answers good enough. That comes perhaps under the l 12 heading of the treatment of uncertainties but at some point
- 13 refining the model, for example, to look at the impact of U-t 14 238 decay daughters on the dose at 10 to the fifth and 10 to 15 the sixth years out strikes me as rearranging the dock 16 chairs on the Titanic. I don't think that is a very useful 17 exercise and it all comes under the heading of what is it 18 you really want to know from the PA results? When should 19 you quit?
20 I am troubled by the general notion that if we 21 can't make sense out of what goes on we are going to try and 22 arrive at a fundamental understanding of the mechanism of 23 whatever the process is, and it seems to me by now it should 24 De evident that we don't have the time or the resources to 25 get at the mechanistic underpinning of that complicated ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
.g 198
() 1 system called the Yucca Mountain area -- or for that matter 2 any other repository, yet I keep hearing it as being the 3 target, the goal. I think thet's a mistake. 4 I am not very charitable about the impact of the 5 answers from performance assessment exeicises on research 6 and development. It wasn't clear yesterday that that was a 7 significant issue. How it may have been for the first two 8 days when people talked about details but I couldn't see 9 where the results of performance assessment influenced the 10 start or the stop of research into new or old areas. 11 I thought at one time there was a general 12 agreement that PA ought to be in fact driving the direction 13 of the programs. I didn't see that. If it was thero, I 14 would be pleased to hear about it, but I didn't see it. 15 You know, that and the other things I have 16 mentioned before, that's basically it. 17 MR. POMERoY: Could you comment though on the 18 Carbon-14 issue? 19 MR. STEINDLER: Yes. The Carbon-14 discussion was 20 interesting in several ways. In one case the detailed steps 21 that were followed were quite instructive and I thought they 22 were reasonably well done until we got to the end discussion 23 and then it turned out that a fundamental difference between 24 the two models -- remember the one-that somebody commented 25 on the fact that the drying out process of a heated waste O ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950-
i 199 () 1 emplacement forms a layer of essentially fully saturated 2 rock impermeable to gas which ought to totally bar 3 transport. That's auch an obvious fundamental issue that I 4 was a little bit surprised that the first group didn't 5 consider it. 6 Now what does that tell you? If you are willing 7 to extrapolate, it tells you that there are some real 8 problems in scenario definition that need to be done first , 9 and ought to be in fact the subject of a lot of internal 10 discussion between DOE and HRC and whoever else is involved. 11 So once the scenarios are outlined, then models 12 can be constructed by arithmetic issues that everybody has 13 their own way to attack. But at least the fundamental 14 generic issues of a model can be outlined and perhaps agreed 15 to. 4 16 I looked at the chemistry and all the other things 17 that were going on in that carbon 14, there are some 18 fundamental assumptions that are probably okay, but they are 19 not demonstrably okay. 20 I have no idea whether or not carben 14 and circ 21 alloy comes out as carbon dioxide. .In fact, I have some 4 22 doubts about it. Circ carbide, for example, is a fairly 23 stable material. I would expect to sit in there as a 24 carbide rather than something that can be easily leashed as 25 carbon dioxide. O ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
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_ _s 200 1 But it may not make any difference. So, you know, 4 l 2 tnat's not that big a deal. But I thought it was a good i ! 3 example of some difficulties. 1 j 4 I have trouble with a linear model. As I 5 mentioned, my intuition somehow or another got bent out of f ] j 6 shape when somebody said that the travel time from a 1,200 1 7 foot repository depth to the surface is only measured in i ! 8 tens of years by a process of breathing due to the fairly 3 , l 9 small delta T between the waste itself and the surface. 10 Somehow I would have guessed, to show you how l 11 little I 1.now about it, that would have taken in units of
- 12 hundreds of years or longer. But, you know, I can't verify '
13 the thing one way or the other.
- l. 14 MR. POMEROY: Thank you.
l 15 MR. MOELLER: A quick question on that. You know-
- 16 Steve Hershman mentioned that the heat from the-waste would l 17 be a driving force .o send radon out. As you talk, or as I 18 am thinking as I talk, radon, of course, has only a four-l 39 day or_whatever it is, half-life. So, radon very deep in is l
! 20 never going to-reach it. So, it would only be if it l 21 influences'the upper meter or_so of the soil that it's' going 22 to be of any consequence. 23 MR. HINZE: -Well, it's hard to. add to those
- 24 profound and excellent statements. But I would like to add 25 a few comments based upon my own perspective. I guess it's O ANN __ RlLEY & _ ASSOCIATES, Ltd.
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l 201 () I time that I came out of the closet. 2 I really have been very concerned about PA because 3 I've been concerned that the quantification that one gives 4 to it lends a respectability to the result that perhaps may 5 not be justified for a number of reasons. 6 From that aspect, I was pleased with both the 7 reports that I heard from the doe and the NRC in that they 8 caveated their results and tried to specify the assumptions, 9 although I guess everyone could sit back and think of many 10 more assumptions that should be taken into account. 11 I agree with Paul that the groups have come a long 12 way, but as I said here and looked at the trees and the lack 13 of inter-mixing of the trees, and the number of problems 14 that really needed to be developed, I think we have a long 15 way to go. I think there's a long way to go, and perhaps 16 longer than we think even at this time. I think vith that 17 in mind the whole idea of resources is terribly inportant. 18 The question that I have and asking myself is what 19 is the role of the PA analyst. I had a perception about 20 that and I'm going to try to answer that qv3stion, but I 21 think we ought to be thinking about it because what I heard 22 in yesterday's session was -- dependent upon the group, even 23 to the point of lip service -- in terms of the interaction 24 with the scientific community, that are directly involved. 25 I think this goes back to some of Marty's
~~
t ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293-3950
( e l l ! ! 202 1 statements regarding the opaqueness of codes. I think that 1 2 the only people that really can deal with.that properly are ] 3 people that are experienced in the science that those codes ] 4 are trying to deal with. 5 They have to, if you will, properly cull and 6 cxercise them. They have to play with them. They have to { 7 exercise them. Gosh, I became very concerned when we hear
- 8 statements such as, "Well, we're not going to take this out 9 and show out results to the hydrologists."
l [ 10 It seems to me that the PA analysts have really 11 had is the PA analyst is the person that provides an 12 interface with the computer expertise, and also interfacing j 13 different disciplines because,-to me, the PA analyst _should l 14 not be running the hydrology codes. The hydrologists ought
- 15 to be doing that.
! 16 What the PA analyst should be doing is making j 17 certain that we have the coupling of these processes. I , 18 hate to use_the word " coupled" process because-it's perhaps l. 19 a little overused. 20 But I truly believe that in this process ~that one i '. 21 plus one can equal three or 300. I think as we kept.our t . 22 eyes open yesterday, we could see where that interplayed, i 23 where the vulcanology and the dykes and_the orientation of 24 the_ dykes could have a swamping out-effect upon the
- 25 hydrologic characteristics.-
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i i 203 1 Who cares what the uncertainty is because you're 2 going to flood it, depending upon the orientation of where 1 4 3 that dyke might be. - I So, it seems to me that there needs to be a pretty 4 i 5 clear definition of the PA analysts role. I, for one, am i 6 reluctant to give that person the role of what I call the i l 7 working scientists in the field. i
! 8 I thought the carbon 14 results of the NRC were 1
9 very interesting, but I would have very much liked to have ]
- 10 seen how'they compared with the doe. I mean, I thought that 11 was what it was all about.
4 12 I think that there needs to be much more critical j . 13 consideration of the comparisons of the results and how they 14 got there. I guess that goes to even results that come out l 15 the same. Just because they come out the same, as we heard l i , 16 yesterday, doesn't mean that they're going to be right. 17 But if they come up the same way -- use different i 18 codes, it's telling-us a very great deal. There must be 19 something in that modeling, in that analysis, that we can
- 20 gain knowledge that we can gain by that kind of comparison.
i 21 I think as various iterations are performed, we-22 really have to understand why we're getting different
- 23 results. Sometimes I think that's rather opaque.
24 Nothing new to modeler is the problem of the 25 density of grid size to cells in a spacial way. That very O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. - Street, N.W., Suite 37 Washington, D. C. 20006
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i i j 204 () d 1 auch enters into thu uncertainty problem and can be really l 2 minimized with that, if you approach it from one way. , 3 Certainly there's the spacial density. But there's the l 4 temporal density. l 5 My own students do a lit of modeling. They l 6 wouldn't be permitted to start with a modeling procedure 7 until they had defined what kinds of density that they j 8 needed in their models. l 9 Also, the boundary conditions. How far out do j 10 they have to go? You mentioned Linda Lehman's concern about j 11 leakage from west. Do we go out beyond the Solitario e ] 12 Canyon? Do we go out beyond Bare Mountain? Does Bare } 13 Mountain fault make that contact? 14 Well, I think there needs to be evaluation of 4
- j. 15 those things. I guess that really leads to-the next point.
} 16 I heard this particularly from NRC from Norm about i 17- simplify 3ng the codes and speeding up the codes. i 18 Maybe it's my lack of understanding, but it seems !. 19 to me that the codes are going to get much more-complex. If i f 20 they don't, we're all in serious trouble. What we shouidn't F i 21 be talking about is speed of. codes,.but simply the 22 efficiency of codes. ( 23 Can these be run on a smaller machine and.run for l 24 a week? Some of the things we do, we handle that way. We 4 , 25 don't have a huge machine, but you can-let it run for'a L , ANN RlLEY & ASSOCIATES, Ltd. l Coud Repodersr . 1612 K. Street, N.W., Suite 300 Washingtoni- D. C. 20006 (202) 293-3950
i i j 205 1 period of time. I guess I'm kind of concerned about that. 5 2 The expert judgement sounds really interesting i 3 -- the 2.5, I guess it's called. I would like to learn more , 4 about that because we're thinking a lot about expert 5 judgement. I would like to have a better feeling of how the
; 6 staff -- and this may be helpful to us -- of how the staff 7 is going to take this elicitation of global change and put j 8 that into trying to reach a decision regarding any guidance.
i j 9 It's important to carry that through with one 10 process. That was, after all, our suggestion, I guess. But i 11 there have been a lot of other approaches to this. I'm sure 4 12 that they're going to take those into account. They need to 13 be, certainly. l 14 Well, those are some of my comments. l 15 MR. STEINDLER: Let me make a couple of comments 16 on one of them I forgot. 17 You know, you asked the question as to whether or l 18 not we should send a letter or we should communicate with l 19 somebody about it. I think the one short-term issue that I 20 think we might raise is to perhaps address a letter to i 21 somebody within the NRC to ensure that continued support is 22 provided for the folks here -- You know, to give resources 23 and funds for people but as well as the -- you know, make 24 sure that their computer needs and their interactions needs 25 are not set in the second level, down below someplace. That 'O ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 [ (202) 293-3950-
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4 1 2' 206 4 1 may bo it. j 2 MR. HINZE Could I add to that? A major resource 3 is access to the working scientific groups within the t 4 Agency. Maybe they have that but the PA people have to have 5 that. 6 MR. STEINDLER: That would be I think one of the 7 few reasons I would think that it would be worthwhile to at 8 least communicate in some fashion or another and I would 9 assume we'd have to do this by letter. I guess that's it. j 10 MR. POMEROY: Dade, one of the things that we j 11 talked a little bit informally about might be worthwhile l 12 bringing up here. We have discussed the possibility of 13 writing a le'.ter but I believe it was Marty's suggestion l 14 that one thing that could come out of this -- two things 15 should come out of this. l 16 One is that there should be some documentation in 17 addition to the transcript of our lessons learned out of l 18 this working group but the second is -- and could be 19 contained in that document -- some list of the critical [ 20 issues and I see about four or five here that could be 21 really critical issues to the entire process. l 22 One suggestion may be that we might want to r
- 23 consider actually a working group on each one of those i
24 issues and again I am not looking for work but I think 25 those, there are several of these issues that need to be O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K. Street, .N.W., Suite 300 Washington, D. C. 2r406 (202) 293 3950
i i l 207 1 pursued further than we could in a one day review session of f 2 two major programs. a ' 3 MR. MOELLER: Are those different than Margaret's
- 4 list? ;
i l 5 MR. POMEROY They are somewhat. Bill's issue and 1 t j 6 concern about the analyst's role -- 1 l 7 MR. MOELLER: Okay. s j 8 MR. POMEROY: -- what we do wich that. There were 4 l 9 a number of concerns triat he citea in there. The expart { 10 judgment and the uncertain qua.ction I think is one that we . 11 really would like to pu'caue, we should pursue becautia if f
- 12 indeed there is a problem, a significant problem, with
! 13 clearly defining t N uncertainties in this, that is another 'O j 14 very dangerous aspect, one could make very short statements ! ! 15 about the usefulness of performance ascessment if those i 16 can_'t be adequately addressed. l l 17 MR. MOELLER: Back on your list and I meant to ask
- 18 it earlier, Paul, when Linda Lehman made the presentation j 19_ about focus flux, I thought I understood it but I then found -
i l 20 I was l'ft with a question. j l _ 21 If you could somehow because of, you know, l_ 22 rainfall coming down and then going'into streams and 23 puddling or pooling in a< lake, if that lake were on top of 24- Yucca Mountain then I would be concerned. I saw the lake as l 25 being down in the valley so how does it then affect the 1 O ANN RlLEY & - ASSOCIATES, Ltd. l- Court Reporters l 1612 K. Street, N.W., Suite 300 l Washington, D. C. 20006 - - - - -
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1 I 1 I j 4 208 1 repository horizon if it is well below that horizon? Or l 2 could it be above that horizon? 4 3 MR. POMEBoVI Lot me say one thing first. This is j 4 an episodic kind of treatment. j i 5 MR. MOELLER: Correct. I 6 MR. POMEROY: Most of the treatments that you saw 7 yesterday and the previous two days are steady state 8 treatments and so any way of treating her hypothesis or her j 9 assumptions would have to be treated in an episodic way and 4 10 that isn't readily available right at the moment but it can , 11 be done. } 12 There could be flow -- this would involve some 13 almost, some sort of a floeding concept but you could O 14 conceive of flow into the west side of the mountain from 15 Solitario Canyon. That could horizontally-flow. l 16 I haven't read her paper so -- l 17 MR. MOELLER: Is that below the horizon though? l 18 MR. POMEROY: That could be below, partially below i l 19 and partially above the horizon. ] 20 MR. M3ELLER: Okay -- 21 MR. HINZE: But you can get ponding above. 22 MR. POMEROY: Yes. ) 23 MR. HINZE: There are a lot of opportunities and i 24 the fact of the matter is that Alan Flint I think it was 25 that made a pts entation to the TRB a couple of years ago O ANN RlLEY & ASSOCIATES, Ltd.
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9 l i l 209 1 that I sat in on that was talking about some of these high 4 2 flux times when you have the storm activity and the backup l , 3 and the net result. l 4 I mean if you look at percolation, water flux into l 5 the earth, anyplace it's on a very episodic basis. I mean i 6 there are only a couple of periods of the year when it
- 7 really happens.
1 ! 8 MR. POMEROY: But you can have the purged water 9 situation under certain circumstances and I would like to j 10 read her paper. I think she's going to submit that for 11 publication in the normal process. She's used totalled data 12 for the past 20 years. I think it bears looking at but I j 13 used it only as an example of the-boundary conditions that 1 14 you choose affecting the outcome of the problem, perhaps 15 making it an artificial outcome. 16 MR. HINZE: Are we each going to get a copy of her l 17 paper incidentally? j 18 MR. PoMEROY: We have a copy.
- 19 MR. HINZE: Okay, it will-be distributed then.
t
- 20 Linda Lehman, 21 MR. MOELLER
- - Yes, it was' distributed, if not
) 22 yesterday maybe it was the day before.. i j 22 -Okay, well, does the Staff have any comments 24 before we wrap this up? 25 Do you have any comments? O ANN RILEY & ASSOCIATES, Ltd. Court Reporters-1612 K. Street, N.W., Suite 300. Washington, D. C. 20006 (202) 293-3950
i l i 210 l( ) 1 (No response.]
- 2 MR. MOELLER: Okay, the Staff has no comments.
- 3 Well, then, we are reaching the conclusion that we may write
.I j: 4 a letter. The letter would have a paragraph saying this is 5 important work, please support it, and then it might even i 6 say in addition to the list that the Staff is compiling we l 7 have this list of topics that may be worthy of consideration j 8 for future working group meetings or even DOE / j 9 HRC technical exchanges. 10 Okay, we can say something like that. l 11 MR. POMEROY: I think there should also be a 12 paragraph in there however, somehow -- we don't always have i l 13 to compliment the Staff but they have done an extremely
/'
3 14 large amount of work in a very short period of time, 15 relatively speaking and I would like to see something i 16 commending their efforts. l l- 17 MR. HINZE: But let's also say that there is a ! 18 long way to go. l 19 MR. POMEROY: There's a long way to go, I 20 certainly agree with that. 21 MR. MOELLER: Giorgio? 22 MR. GNUGNOLI: I guess in that first part about 23 the importance,of the work is.where you would address the 24 fact that they should get more resources or maintain the l 25 resources. I Q ANN RlLEY & ASSOCIATES, Ltd. Coud RepOders
- 1612 K. Street, N.W., Suite 300 L -
Washington, D. C. 20006 i _(202) 293-3950 t
1 i i 211 1 MR. POMEROY: Right. 4 l 2 MR. MOELLER: Okay. I think then with that we'll 3 wrap up, to repeat, the formal portion of today's meeting ! 4 and in fact this concludes the recorded portion of the day's 1 5 meeting and we will now have a break and after the break the
- 6 Committee will plan our January agenda, future working group 7 meetings and begin to prepare some of the reports that we l 8 have been talking about.
1 l 9 Let me express again our appreciation to Steve May l 10 and the NRC Staff for being with us this afternoon and 11 helping us to recollect what we've heard over the past three l 12 days. 13 Thank you. 14 (Whereupon, at 3:46 o' clock p.m., the recorded l 15 portion of the meeting was concluded.)- l 16 a l 17 ! 18 i 19 1 20 j 21 j 22 23 24 25
- O
' ANN RILEY & ASSOCIATES, Ltd.
Court Reporters 1612 K. Street, N.W., Suite 300 Washington, D. C. 20006 (202) 293 3950
REPORTER'S CERTIFICATE , O Thir is to certify that the attached proceedings before ' the United States Nuclear Regulatory Commission In the Matter of , NAME OF PROCEEDINGt 49th ACNW Meeting i i DOCKET NUMBER: ,, PU CE OF PROCEEDING: Bethesda, Maryland were held as herein appears, and that this is the original transcript thereof for the file of the United-States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the O transcript is a true and accurate record of the foregoing proceedings.
/ T All u 3y Official Reporter Ann Riley & Associates, Ltd.
O
1 O O O i PRESENTATION TO THE ADVISORY COMMITTEE ON NUCLEAR WASTE DECEMBER 17,1992 i NOVEMBER 1992 RESOLUTION OF , ! SITE CHARACTERIZATION. ANALYSIS OBJECTION 1 -, i l DIVISION OF HIGH-LEVEL WASTE MANAGEMENT, NMSS i i i
._.____.--_-____m_._____ __ ____- .m a- : J- ma '+ -m _ . - ' - _ _ _
O- O O j SCA OBJECTION 1 2 INTRODUCTION Charlotte E. Abrams, Senior Project Manager I Repository Licensing and 4 ) Quality Assurance Directorate ! (301) 504-3403 1 STAFF'S REVIEW OF OBJECTION 1 4 ! Mysore S. Nataraja, Geotechnical Engineering Section Leader Geology and Engineering Branch (301) 504-3459 4 l 4 r
O O O SCA OBJECTION 1 OBJECTION: Concern of such immediate seriousness to a particular area of the site characterization program that NRC would recommend DOE not start work in that area until it is satisfactorily resolved. DOE committed to resolve objection-level concerns prior to proceeding with related site characterization work. 2
~ ~
! O O O i SCA OBJECTION 1 Lifting of an objection means that concerns related to that objection have been resolved at that particular . [ point in time. I Staff is obligated to continue to evaluate activities j
- related to an objection.
i i Staff has an obligation to reopen any objection when warranted by new information or analyses. i' l I 4 3
l: O O O CHRONOLOGY OF OBJECTION 1 DECEMBER 1988 - SITE CHARACTERIZATION PLAN ISSUED
- JULY 1989 - SITE CHARACTERZATION ANALYSIS ISSUED DECEMBER 1990 - DOE RESPONSES TO SCA (CLOSURE OF .
? OBJECTION 1 IS NOT REQUESTED) . JANUARY 1991 - CALICO HILLS RISK BENEFIT ANALYSIS ! ISSUED l JULY 1991 - EXPLORATORY STUDIES FACILITY ALTERNATIVES
- STUDYISSUED I SEPTEMBER 1991 - NRC LETTER REQUESTING INFORMATION l ON HOW CHRBA AND ESFAS ADDRESS SCA OPEN ITEMS i
4 l i
CHRONOLOGY (Continued) ( ! SEPTEMBER 1991 - DOE /NRC TECHNICAL EXCHANGE ON ESF , NOVEMBER 1991 - DOE REQUESTS CLOSURE OF OBJECTION 1 MARCH 1992 - DOE PROVIDES ADDITIONAL INFORMATION TO SUPPORT CLOSURE OF OBJECTION 1 1
- NOVEMBER 1992 - NRC STAFF CONCLUDES OBJECTION 1 IS RESOLVED BASED ON REVIEW OF INFORMATION PROVIDED BY DOE RELATED TO THE REVISED ESF DESIGN AND DESIGN CONTROL PROCESS AND OBSERVATIONS OF QUALITY ASSURANCE AUDITS l
- 5 r
i i i 6 IO SCA OBJECTION 1 1 1
- Concerns l
- Bases I
- NRC Evaluation of DOE's Response i
!O i
- Future NRC Activities O
1 - - - . .- - _ _
7
- O SCA OBJECTION 1 j
4
- ESF to become part of the repository
- SCP & references do not demonstrate
- The adequacy of the ESF design control process ,
o Not all applicable 10 CFR 60 regulations 4 O- considered o inadequate integration of technical data The adequacy of the ESF Title I design o As designed, ESF may not permit needed - 4 tests for sufficient duration o Design and site characterization activities may need significant revisions to resolve the identified problems O
i 8 !O l THE 6 BASES OF OBJECTION 1
- CONCERN l
l 1. Early performance confirmation and ! seals tests
- 2. The Design Acceptability Analysis and how it addresses NRC concerns l
! 3. Test interference in the test area O i-
- 4. Potential Impacts of long term I performance confirmation testing
- 5. Design criteria - seismic, drainage, and slaft liner
- 6. Data requirements for site characterization and the repository l design O
L .. _ -
i ! 9 iO
- BASES FOR SCA OBJECTION 1 i
t Basis 1 i l
- SCP design of the ESF does-not 4
adequately address the issues of l
- Need to consider starting confirmation testing
- as early as practicable during site characterization. (Example
- possible early O weste package testing) l j
- Preliminary data on in situ seals tests as input to the License Application l
l l O l t l
! l l l 10 .O : BASES FOR SCA OBJECTION 1
- (CONT'DD
. Basis 2 l s !
- Design Acceptability Analysis did not address many NRC concerns, such as
- Independence of technical reviewers O + Regulatory considerations in the ESF Title I design and the Design Acceptability Analysis Adequate consideration of starting performance confirmation testing during site characterization
- Consideration of alternatives to major design features important to waste isolation (10 CFR 60.21(c)(1)(ii)(D))
- Thoroughness of document and data reviews
- Consideration of a known anomaly in the vicinity of the proposed shaft location O 9
- - , - . - ..n_ .. ~. . . . . - . , , _ _
11 O BASES FOR SCA OBJECTION 1 (CONT'D) Basis 3
- SCP does not adequately address whether tests can be accommodated without interference
- Incompatibility of tests with adjacent construction and operation activities Q +
Thermal zones of influence were underestimated because of insufficient time considerations Lack of rationale for sequencing of some tests Lack of consideration of uncertainties in the calculation of the zones of influence Lack of identification of needed tests Lack of information on coupled testing Lack of sufficient underground space for testing Lack of consideration of existing boreholes O
12 9 BASES FOR SCA OBJECTION 1 (CONT'D) Basis 4
* "c antial impacts of long-term
- performance confirmation testing are not adequately addressed. '
$ +
Insufficient demonstration that in situ waste package testing is not needt : i3 such tests are needed, their impacts are not addressed i O
, _ ~, . - .
13 O BASES FOR SCA OBJECTION 1 (CONT'D) Basis 5
- Some ESF design criteria are not adequately addressed, including x )
Ik
- Seismic design basis Drainage volume and drainage reliability Effect of shaft liner removal 0
) 14 O j BASES FOR SCA OBJECTION 1 4 (CONT'D)
- Basis 6 4
f
- The ESF in the SCP may not provide sufficient data for
- site characterization O ' repository design i
r i 1 l i i 4 t i i !O i l
l-i ' 15 l0 STAFF EVALUATION OF DOE'S ! RESPONSE i i ! Design Control Process i
- Observed surveillances and audits
! conducted by DOE and found them j acceptable 1 !O 4 l i j l l (
- O
16 O STAFF EVALUATION OF DOE'S . RESPONSE Design Control Process . (Cont'd) l Reviewed DOE's modified design control process, and found the following to be acceptable
- DOE's process for considering specific design O requirements I
- Revisions of DOE's ' Requirements Documents'
, so that they address applicable regulations (Systems Requirements, Waste Management l Systems Requirements, and ESF Design i Requirements)
- DOE's process for integrating technical data
- DOE presentations on examples of how the ;
design control process is being implemented l
- The process for technical assessment reviews ;
I for proposed design changes O i l
1 i i ! 17 !O l STAFF EVALUATION OF DOE'S j RESPONSE
- l Design Control Process !
(Cont'd) i The NRC staff is satisfied that the I current ESF Title ll design activities are being performed under the NRC ! approved QA program O 4 !O
18 O STAFF EVALUATION OF DOE'S
RESPONSE
Title 11 Design Staff found that DOE analyzed alternative design features important to waste isolation
- Both ramps and shafts are considered
- TBM's and mechanical excavation; not all drill-and-blast Considered alternative portal locations-Considered altemative repository design concepts Considered alternative test locations and strategies In situ waste package and seals tests are
. not precluded O
! 19 iO
- STAFF EVALUATION OF DOE'S
RESPONSE
Title ll Design l (Cont'd? 4 ! Staff found that The preferred ESF option has the potential to gather adequate data for site characterization and repository design lO j
- More drifting; 76,000 ft vs.10,000 ft i
l There is less potential for test l interference and more space for l additional tests r
- Larger Main Test Level; 800,000 vs. 400,000 ft2 There is flexibility because of the ESF phased design approach l
O
. .=.._._ ._ _ . _. _ . . . . . - - , _ .
1
- O
SUMMARY
OF NRC EVALUATION OF l DOE RESPONSES l l Based on ;
- Reviews of pertinent portions of the ESFAS and CHRBA
- A review of DOE's ' cross-walk' that addressed the SCA open items
- Consideration of previous DOE responses, technical exchanges, observation audits, and S"rv*i" " **
O
- NRC concluded that 4
- There is an acceptable design control process
- The majority of the bases for Objection 1, and the
, supporting comments and questions related to
- Objection 1 are acceptably addressed
- The preferred ESF option addresses conceptually most of the SCA concerns O
l 4 21 O FUTLIRE NRC ACTIVITIES RELATED TO ! THE ESF ! e Evaluate DOE responses to remaining
- open items l
- Review major design reports O
- Review the Title ll design and design control process
- Observation of 50% & 90% reviews
- Observation audits l
l I -
-FMd.#** dea 2 4 J@ W hade . M e a5 A b rW Ah4 4 me L J eM -_44 e ,44ud. e4 22 . -mLtl RL---,.a--*s--E 4 s as b.aa 4a q&s 1 5 &J.4+ A4 -e4 e M.atsp__da dAs-- de d+4,h.L-4 4 dd 44m.,W 1
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o O O ]. GEOMETRIC ANALYSES OF FAULTS AT YUCCA MOUNTAIN - AOPUCATK)NS TO THE HIGH-LEVEL WASTE REGULATORY PROGRAM A PRESENTATION TO: THE U.S. NUCLEAR REGULATORY COMMISSION -
- ADVISORY COMMITTES ON NUCLEAR WASTE by Stephen R. Young
- Center for Nuclear Waste Regulatory Analyses San Antonio, Texas i Decenter 17,1992 1
l i
A
O O O l PURPOSE OF THE TASK: I DEVELOP METHODS FOR REVIEW AND ASSESSMENT OF STRUCTURAL GEOLOGIC MODELS OF A POTENTIAL HIGH-LEVEL WASTE REPOSITORY SITE AT YUCCA MOUNTAIN, NEVADA i il DETERMINE IMPUCATIONS OF ALTERNATIVE GEOMETRIC MODELS OF EXTENSIONAL FAULTS FOR PERcORMANCE ASSESSMENT iii USE EXISTING REFLECTION SBSMC DATA TO ASSESS STRUCTURAL GEOLOGC MODELS OF THE YUCCA MOUNTAIN REGION
O O O OBJECTIVES:
- TEST EXISTING STRUCTURAL CROSS SECTIONS OF YUXA MOUNTAIN FOR GEOLOGICAL BALANCE (RETRO DEFORMABluTY)
- CONSTRUCT A WELL INTEGRATED SET OF FAULT TRAJECTORY MODELS OF YUCCA MOUNTAIN (A BASE CASE)
- CONSTRUCT ALTERNATIVE GEOMETRIC MODELS OF FAULTS AND ASSOCIATED DEFORMAT1)ON
- MODEL FAULT TRAJECTORIES DIRECTLY FROM EXISTING REFLECTION l SEISMIC DATA l
e USE BALANCED 2-DIMENSIONAL STRUCTURAL CROSS SECTIONS TO ! CONSTRUCT 3-DIMENSIONAL SOUD GEOLOGIC FRAMEWORK MODELS i OF YUCCA MOUNTAIN I l
l 0 O O ;! l l l RESULTS i e YUCCA MOUNTAIN IS UNDERLAIN BY A UNKED, LISTRIC NORMAL FAULT SYSTEM ' THAT MERGES INTO A SUB-HORIZONTAL DtiTACHMENT FAULT (OR ZONE) AT
- DEPTHS OF 6 TO 7 krn (-5 to 4 krn olev.).
e ALTERNATWE GEOMETRIC MODELS OF FAULTING AT YUCCA MOUNTAIN l. SHOW THAT PLANAR (DOMINO) FAULT GEOMETRIES ARE NOT CONSISTENT WHN ' ROLLOVER' FOLDS MAPPED IN THE MAJOR HANGINGWALL BLOCKS. l e EXISTING GEOLOGIC CROSS SECTIONS (Scott and Book, IS84; Scott,1990) . l ARE REASONABLY WELL BALANCED - THAT IS, THEY WILL RETRCOEFORM i- ALONG BALANCED FAULT TRAJECTOR!ES. i i
- e INTERPRETATION AND FAULT MODELS OF THE AV-1 REFLECTION SEISMK
- UNE '
i SUGGEST MULTIPLE DETACHMENT MODELS SHOULD BE CONSIDERED AS A POSSIBLE PARADIGM FOR FAULT GEOMETRIES AT YUCCA MOUNTAIN. !
- THE YUCCA MOUNTAIN FAULT SYSTEM PERSISTS EASTWARD INTO THE j i
FORTYMILE WASH -JACKASS FLATS AREA. i ]. {.
O. O O . IMPLICATIONS EARTHQUAKE SEISMIC HAZARD
- DETACHMENT FAULT SYSTEMS ARE GENERALLY NTERPREVED TO BE ASOSMIC. ,
- N CoarARISON, SBSASC SUP IN TM 6.0+ RANGE MAY BE MORE UKELY ON THE l BAE MOUNTAN FAULT OR ON FAULTS PROJECTED ALONG TM EAST FLANK ;
OF TE FORTYMt.E WASH - TOPOPAH WASH VALLEY. GROUND RUPTURE HAZPRD !
- SUP ON THE MOCELED UNKED, USTFUC SYSTEM S LNCELY TO BE DISTHBUTED.
VOLCANIC HAZARD ,
- MODELED USTRIC-DETACt90ENT SYSTEM MAY lifuJENCE TM LOCATION OF SURFACE VENTC, BtJT DOES NOT NFLUENCE DEEP-SEATED MAGE 4A ASCENT.
FORWARD MODEUNG 1 i
- PREDICT POTENTIAL SHAPE CHANGES OF REPOSfTORY FAULT BLOCK
) DUE TO FUTURE FAULT SUP. I I
- PMDitT POTENTIAL 2DNES OF DISTRSUTED DEPORbtATON. -
a r i
- SPECtFY DISPLACEhENT BOUPE)ARY CONDITIONS FOR DEFORMAT10N MODELS.
l
- MAP STMSS AND STRAM PATTEPNS DUE TO PO11NTW, FUTUM DEFORMATION. .
j I
m.4 a, sR'- b 4.Ah.4a gr am4*,... Eg= *.et aea44sq.-4m ,ea... Muaa- .. Tw- -aus. O v-4h_.4m-u_um 4 44L M ma+au L..Ah iL..-A.-- 44-..&4mm aa A eamsei e, u . .m - as t-m _mam.am*ma-mmam_w.a.sw _5m .g. ,a er a.A s 4s.s.
~
O O O . FUTURE WORK 3-DIMENS40NAL STRUCTURAUSTRAT1 GRAPHIC FRAMEWORK MODEL OF YUCCA MT. RESEARCH ON 3-DIMENSIONAL GEOMETRIC /10NEFATIC MODEUNG METHODS. 2-DIMENSIONAL DYNAMIC (DEFORMATION MECHANOS) MODELS OF YUCCA MT. a 3-OfMENSIONAL DYNAMIC (DEFORMATION MECHANICS) MODELS OF YUCCA MT. i i 1
^
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O O O 1 PRESENTATION TO THE ADVISORY COMMITTEE ON NUCLEAR WASTE 1 AR req
& 47
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DEVELOPMENT OF METHODS TO ADDRESS STRUCTURAL DEFORMATION IN CHARACTERIZATION AND PERFORMANCE OF A GEOLOGIC REPOSITORY J
O O LO
'PRESENTA~10N'TO THE ADVISORY COMMITTEE ON NUCLEAR WASTE DECEMBER 17,1992 1
DEVELOPMENT OF METHODS TO ADDRESS STRUCTURAL DEFORMATION IN CHARACTERIZATION AND PERFORMANCE OF A' GEOLOGIC REPOSITORY Geology and Engineering Branch Division of High-Level Waste Management, NMSS
O O O OUTLINE OF PRESENTATION Introductory Remarks Ronald L. Ballard, Chief Geology and Engineering Branch HLWM (504-3462) Geometric Modelling of Faulting Steve Young, Geologist Center for Nuclear Waste Regulatory Analyses (210-522-5247) AC N W 17 D EC 92 4 m -- _ . _ _
O O O
- OBJECTIVES k
2
. TO DEVELOP METHODS TO TEST THE VALIDITY OF GEOLOGIC CROSS SECTIONS SUBMITTED IN ASSOCIATION l WITH A LICENSE APPLICATION i
!
- TO DEVELOP METHODS WHEREBY FORWARD MODELING OF STRUCTURAL DEFORMATION IN THE REPOSITORY l BLOCK CAN BE CONSIDERED FOR INCORPORATION
- lNTO ASSESSEMENTS OF REPOSITORY DESIGN AND j PERFORMANCE l
c ACNW 17DEC92 . l i .
PLANNED ACTIVITIES Activity:. Status: Prototype Testing of Computer Completed - September 1990 l l- Assisted Geometric Modelling
-(2D)
Geometric Modellina of Faultina Initial Phase Completed - , _at Yucca Mountain (2D) November,1992 Iterative Ef forts Based on Data Provided by DOE Geologic Framework Models of TBD FY93/94 Yucca Mountain Mechanistic Modelling of Defor- Planned FY94/95 mation at Yucca Mountain at Repository Scale ! True' 3D Models of Deformation Under Consideration FY95-97 2 at Yucca Mour:tain AC N W 17DEC92
. _ _ _ _ - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _}}