ML20150E380

Forwards Comments Developed by Five Technical Review Branch Sections Re DOE QA Program.Supplemental Comments Also Provided

ML20150E380
Person / Time
Issue date:	03/02/1988
From:	Ballard R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Youngblood B NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-1 NUDOCS 8803310133
Download: ML20150E380 (11)

Text

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QA PESPONSES fdAR 2 1988 MEMORANDUM FOR: B. J. Youngblood, Chief Operations Branch, HLWM FROM: Ronald L. Ballard, Chief Technical Review Branch, HLWM *

SUBJECT:

OUALITYASS6RANCERECORDS As requested in your November 9,1987 remorandum, attached are coments developed by the five Technical Review Branch sections relative to the DOE quality assurance program as described in the four attachments to your

memorandum. In addition to addressing the specific items highlighted in the memorandum, a few supplemental coments on related 0A niatters are being provided.

Ronald L. Ballard, Chief Technical Review Branch, HLWM

Enclosures:

As stated 8803310133 880302 PDR WASTE

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QA RESPONSES MAR 2 BBB 0FFICIAL CONCURRENCE AND DISTRIBUTION RECORD MEMORANDUM FOR: B. J. Youngblood, Chief Operations Branch, HLWM FROM: Ronald L. Ballard, Chief Technical Review Branch, HLWM

SUBJECT:

QUALITY ASSURANCE RECORDS DATE: March 2, 1988 DISTRIBUTION 1(.?ndeca g k m NMSS RF RBrowning, HLWM MB511', H .W - ' JBunting, HLSE BYoungblood, HLOB RBallard, HLTR HLefevre, HLTR JLinehan, HLOB JKennedy, HLOB HLOB/cf ABender, HLSE LRiddle, HLOB FXCameron, OGC SCoplan, HLOB HLTR, r/f JDonnelly, FLOB NVoltura, HLOB RJohr. son, HLOB KStablein, HLOB PDR ADun en, HLOB BBelke, HLOB DBrooks, HLTR DChery, HLTR PJustus, HLTR RNataraja,HLTR RWeller, HLTR CONCURRENCES ORGANIZATION /CONCUREE INITIALS DATE CONCURRED HLWM/HLefevre M M,o 88/03/g.

HLWM/CBrooks W. 88/03/(

HLWM/0Chery AMLP - 88/03/ 2 HL'4H/PJustus ~~ tvV 88/03/o7.-

HL'4M/RNa taraja F./ 88/03/ L -

HLWM/PVeller /P nw 88/03/ 2.

HLWM/RBallard //j /7 08/03/ps

r QUALITY ASSURANCE RECORD GE0 LOGY SE0 PHYSICS SECTION TECHNICAL REVIEW BRANCH DIVISION OF HIGH-LEVEL WASTE MANAGEMENT QUALITY ASSURANCE RECORD 5 Operations Branch has requested that the Technical Review Branch respond to the following four items:

1. Are the record types to be retained sufficient?

2. Are the criteria accurate?

3. The identification of additional post-closure or lifetice record for possible inclusion in Sections 5.5 and 5.6 of Enclosure 1 of the Noverober 9,1987 OB memorar.dum.

4. A determination as to whether post-closure records should be classified as lifetime records.

The Geology-Geophysics Section responses follow:

ITEM N0.1 "Are the record type to be retained sufficient?"

Response Yes, ITEM NO. 2 "Are the criteria accurate?"

. Response: Yes, but with reservations. We do agree with the selection of criteria identifying the types of documents suitable for "lifetime records."

However, with respect to the suggested retention time (300-1,000 years) for post-closure ret.ords, we propose that the retention time be not tied to the expected lifetime of the specific waste package, but rather to the longevity of

dangerous radionuclides. The longevity criteria for post-closure records would therefore be. increased from 300 to 1,000 years to that of the longest lived of the dangerous radionuclides.

Likewise, many records (such as those identified in Enclosure 3 to the above OB l

memo) classified presently as lifetime (e.g. geophysical, groundwater, and i hydrologic data) should be reclassified as post-closure, with the attendant l increased longevity as suggested above.

ITEM NO. 3 "The identification of additional post-closure or lifetime records for possible inclusion in the Sections 5.5 and 5.6 of Enclosure 1 of

, the memo."

l Response: Suggested additives to the types of lifetime records:

! Environmental test results

! Instrumental - installation and calibration records l

Selected samples of rock, water (?) and waste package materials on l

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QUALITY ASSURANCE RECORD

-2 which critical tests were based Amendment of a Section 5.6.1 category from "Drill hole logs and samples" to "Drill hole logs and samples (core and chip samples)"

Surface rock samples Suggestion: Removal of certain categories of records from the list of typical lifetime records.

The existing list (Enclosure 1, Section 5.6.1, page 5) includes "Geophysical logs and data" as well as specific types of geophysical logs such as:

self-potential, caliper and radioactive. Rather than include the generic "geophysical logs" as well as specific citation of individual types of geophysical logs, we suggest that the generic category be retained and specific categories be removed from the typical list. It is possible that certain types of geophysical logs may not be included in the "lifetime" category because of their omission from the typical list.

ITEM NO. 4: - "A determination as to whether post-closure records should be classified as lifetime records."

Response: No. Because of our strong feeling that the retention time period for quality assurance records (both lifetime and post-closure) is not sufficiently long, we would suggest that the post-closure classification of records be retained and that lifetime records be re-classified as post-closure records.

We would further suggest that the retention period of post-closure records be redefined from the present 300-1,000 years to several thousands of years.

ADDITIONAL COMMENTS:

Lack of Internal Consistency of Quality Assurance Records - For example, two of the OB memo enclosures (No. I and No. 4) are of DOE origin. Enclosure 1, dated July,1986, page 3, describes three classifications of records (post-closure, lifetime,andnonpermanent.) On the other hand, Enclosure 4 (NNWSI Project QA Plan, dated March 9, 1987, page E-1) has a single retention period - lifetime.

Suggestion: Since only NNWSI is being considered as a repository site, a single, comprehensive, site-specific QA document should represent DOE's positior, rather than the present two documents.

Comprehensive List of QA Records - Enclosure 4, page E-1, of the OB memo, does not (but should) include wasts package in its data reduction, evaluations, analyses ind reports.

NOTE WELLER 3/2 -

1 NOTE T0: Parold Lefevre Geology / Geophysics Section FROM: Richard Weller Materials Eroineerino Section

SUBJECT:

OUALITY ASSURANCE RECORDS As reluested in your March 1, 1988 note regarding DOE quality assurance recor (s, I am providing you with the following cornrents on the DOE Suppl mental Quality Assurance Requirer.ents.

Commer t: Section 5.5, List of Typical Post-closure Records This section lists the"stored waste inventory and location" cs a typical post-closure record. Stored waste inventory should be described with more specificity and definition. For example, is the inventnry per borehole or drift? Is the location specified per borehole or drift? Is the waste form (e.g. glass, spent fuel, or other) specified?

Concent: Section 5.6, List of Typical Lifetime Records This section does not include any waste emplacement records which will identify waste form or type, inventory, borehole and drift icoation. This information should be provided if it is not included elsewhere, c c: A C&

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Geochemistry Section Comments On DOE Draft Document "Supplemental Quality Assurance Requirements" Question 1- Are the Criteria Accurate?

• The longevity criteria for post-closure records (Section 5.4.1) should be based en long term radionuclide hazard not waste package lifetime.

• The criterie for lifetime records ISection 5.4.2) are sufficient.

Question 2- Are the record types to be retained sufficient?

The record types listed in section 5.6 do not specifically address geochemistry. However, this is only a listing of

"... typical types..." of records that would be retained if the criteria were applied. We consider that eventhough geochemistry records do not specifically appear on the list, they would be retained based on the criteria.

Question 3- Identification of additional post-closure or lifetime records for possible inclusion in Section 5.5. and 5.6.

• As a "catagory." geochemistry records have not been listed.

While it is felt they would be included based on the criteria, consideration should be given to expanding the list to

, specifically include geochemical records.

Question 4- A determination as to whether post-closure records should be classified as lifetims records?

• Both lifetime and post-closure records should be retained for as long as waste radionuclides are a hazard (See Question 1).

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GUPTA 2/29 DRAFT

. DESIGN / ROCK MECHANICS Comments on DOE's Supplemental 0A Requirements (Supplement No. 4, July 1986)

QA Records

Contact:

Dinesh Gupta X20547 1

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9 GUPTA 2/29 DRAFT '

1. Comments on Section E.5: List of Typical Post-Closure Records It is not clear if the list of records included in Section 5.5 would satisfy the requirements of 10 CFR 60.51 (a)(2). The contents of the listed records in Section 5.5 are not sufficiently described; this makes it difficult to review the adequacy of the contents of the list. For example, it is not clear if the "Underground Facility Configuration" item in the list includes detailed as-built drawings of the underground facility, shafts, boreholes and their seals. Also, contents of the records entitled "Licensino Reports" and "Site Characterizatien Reports" are not clearly defined.

The list in Section 5.5 should be revised to meet the requirements of 10 CFR 60.51 (a)(2).

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GUPTA 2/29 DRAFT .

2. Comments on Section 5.6: List of Typical lifetime Records The list of records identified in Section 5.6 does not appear to meet the requirements of 10 CFR 60.71 and 10 CFR 60.72. For example, the list does not include the following items for lifetime record keeping that are reauired by 10 CFR 60:

(i) complete history of the movement of the waste from the shipper throuch all phases of storace and disposal, (ii) details of records of construction, including locations and amount of seepage; progress and sequence of construction work; instrument locations, reading and analysis; and location and description of dewatering systems, etc.

The list in Section 5.6 should be revised to meet the requirements of 10 CF,, 60.71 and 10 CFR 60.72.

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3. Comments on Section 5.4.3: Nonpermanent Records Although a category of "Nonpermanent Records" has been identified, examples for these records have not been provided. Without specific examples, it is not clear as to what types of records can be discarded after 3 years of the initiation of repository operations. Examples of such records should be included in the DOE's QA requirements, i

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s COMMENTS VERMA 3/1 .

Hydrology Section's Comments on "Quality Assurance Records"

1. Record types to be retained are not sufficient from a hydroloaic point of view. The records to be retained should include the following:

(a) A complete listing of the codes used to demonstrate compliance with the regulatory requirements of 10 CFR 60 (b) A complete listing of the data used in validation of these codes (c) Results of validation for each of these codes (d) Hydrologic data and analyses.

2. Criteria is satisfactory.

3. Hydrologic data and analyses and performance assessment codes and their validation results should be added to the list in Section 5.5 and 5.6.

4 Hydrologic data and analyses should be classified as lifetime records.

5. A minor editorial chance on page 5 of the Enclosure 1, "Hydrologic test results and data' should be changed to "Hydroceoloaic test data and analyses".

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