ML20151W125
| ML20151W125 | |
| Person / Time | |
|---|---|
| Issue date: | 08/16/1988 |
| From: | Ballard R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Linehan J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-1 NUDOCS 8808230313 | |
| Download: ML20151W125 (67) | |
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HLTR TA on TP's AUG 161988
. MEMORANDUM FOR: John J. Linehan, Acting Chief Operations Branch, HLWM FROM: Ronald L. Ballard, Chief Technical Review Branch, HLWM
SUBJECT:
HLTR ASSISTANCE ON TECHNICAL POSITIONS: ANNOTATED OUTLINES The information requested in your August 8, 1988, memorandum to me for-annotated outlines of each of the 29 HLTR technical positions submitted in the budget has been completed by the TR staff with several exceptions noted in attachment A. As I indicated in my August 10, 1988 note to you, some of 'the information could not be completed in the time allotted because of the scope of input requested and due to absences.
A total of 25 outlines are being submitted of which 3 outlines, numbers 13, 14, and15,haveincompleteschedules(seeattachmentB). Three of the subreitted outlines, numbers 8,11, and 16, are the subject of rulemaking and are still likely to be issued in a form and with a scope to be determined at a later decision point.
Of the remaining 4 outlines, 2 outlines, numbers 4 and 6, will be completed by COB, August 17th and submitted separately. One outline, number 7 is now considered unnecessary because the boundary condition for the EBS has already been defined (letter from J. Linehan, NRC to J. Knight, DOE, dated Septenber 26,1986), and one outline, number 29, cannot be developed until progress is made on a closely related rulemaking.
The schedules are, of course, preliminary and have not yet been coordinated among the various sections. It will be necessary to work with OB and with the Center as it develops a program architecture to avoid potential conflict as firm schedules are developed.
2Y 8 Ronald L.-Sallard, Chief g Technical Review Branch, HLUM C$ Attachment A': Staff Technical Positions gp Attachment B: Annotated Outlines #1 29 m2
$, cc: R. Johnson NI J. Holonich h , ll OFC : HLIR : HLT : HLTR %tM HLTR : HLTR : HLTR :J
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DATE : 8////88 : 8/lle/88 : 8//h88 : -8 /88 : / /88 : / /88 : 8//4/88
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1 ' Central Files REBrowning, HLWM , . BJYoungblood, HLWM , RLBallard, HLTR J0 Bunting, HLSE. JLinehan,:itLOB ' HLTR r/f. NMSS r/f-TCardone, HLTR PJustus, HLTR DChery. HLTR' DBrooks,_HLTR
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ATTACHMENT A
-. '.' STAFF TECHNICAL POSITIONS Task Title Remarks c
DESIGN
- 1. Technical Position on Post-Closure Seals Complete in an Unsaturated Medium
- 2. Extrapolation of Short-Term Data to Complete Long-Term Results Geomechanical Mechanical Geochemistry
- 3. Design, Construction and Monitor'ng Complete i of ESF
- 4. Waste Retrievability This outline will be completed by COB, Wednesday, August 17, 1988
- 5. Level of Retrieval Demonstration Needed Complete During Site Characterization
- 6. Repository Design This outline will be completed by COB, Wednesday, August 17, 1988' MATERIALS
- 7. Boundary Conditions for EBS Analysis We are proposing that this TP is unnecessary -
i because the boundary condition for the EBS. ,
has already been defined as that w*nich does i
. not include a portion of the host rock (see .-
enclosed letter from J. Linehan, NRC"to J. Knight.. DOE dated September 26,1986)
- 8. Substantially Complete Containment Complete (Subject of Rulemaking) -
1 STAFF TECHNICAL POSITIONS
(0 - I. - STAFF TECHNICAL POSITIONS Task Title Remarks
- 9. Acceptable Scope for Waste / Package EBS Complete Testing Program
- 10. Waste Package Reliability (Revision) Complete HYDROLOGY ~
- 11. Pre-emplacement GWTT Complete (Subject of Rulemaking)
- 12. Information Needs for Developing an Adequate Complete Description of the Groundwater Flow System GE0 CHEMISTRY
- 13. Environment of EBS Package Reliability This outline is complete, except that the schedules will be completed by COB, Thursday, August 18, 1988.
It is included in the package of TP's being submitted
- 14. Radionuclide Transport This outline is complete, except that the I schedules will be completed by COB, Thursday, August 18, 1988. It is included in the package of TP's being submitted
- 15. Rock / Water Chemical Interactions This outline is complete, except that the schedules will be completed by COB, Thursday, August 18, 1988. It is included in the package of TP's -
being submitted '
2 STAFF TECHNICAL POSITIONS
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STAFF TECHNICAL POSITIONS Task Title Remarks i
GEOLOGY -
- 16. Guidance fr 7etermination of Anticipated Complete (Subject of Rulemaking)
Processes air . vents and Unanticipated Processes and Events
- 17. Pre-closure Earthquake Hazard Evaluation Complete i Methods ,
- 18. Guidance for Performing Probabilistic Complete Seisriic Hazard Analysis for High-Level Waste Repository
- 19. Volcanic Hazard Analysis Complete ,
- 20. The use of Tectonic Models Under 10 CFR 60 Complete
- 21. Natural Resources Assessment Methods Complete
- 22. Geologic ;-tapping of Shafts / Drifts Complete
- 23. Geomorphic Analysis. Complete-COMPLIANCE DEMONSTRATION -
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! 24. Implementation of EPA Containment Requirement Complete
- 25. Scenario Identification and Screening Complete
- 26. Verific3 tion and Validation of Performance Complete Assessment Models i 27 Data and Parameter Uncertainty Complete j 28. Formal Use of Expert Judgement Complete 4
3 STAFF TECHNICAL POSITIONS -
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- . I- STAFF TECHNICAL POSITIONS Task Title Remarks
- 29. Pre-Closure Performance Assessment The requested information for this TP cannot be developed until progress is made on a closely related rulemaking dealing with design basis accident dose limits for pre-closure repository performance l
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1 ANNOTATED-0UTLINE TP
Title:
' Technical Position on Post-closure seals in an Unsaturated Medium Lead Technical
Contact:
'Dinesh Gupta y 1.0 RegulatoryEvjluation The NRCofregulatory consists the followingframework for 1sealing)and three parts: ' drainage in2)unsaturated design considerations, site media characterization and performance confirmation considerations, and 3) performance analysis considerations. The applicable Part 60 regulations are listed below. ,
l 1.1 Applicable Regulations: Design Section 60.152 and criterion III of Appendix B, 10 CFR 50 require that if seals are determined to be important to waste isolation then the 00E should establish measures to assure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions.
Section 60.134 of 10 CFR 60 addresses the following requirements for the design of seals: i
$60.134 Design of seals for shafts and boreholes (a) General design criterion (b) Selection of materials and-placement methods 1.2 Applicable Regulations: Site Characterization and Performance Confirmation Section 60,15 of 10 CFR Part 60 addresses the site characterization requirements. In addition, Sections 60.140, 60,141, and 60,142 address the g performance confirmiition program requirements.
I 660.15 Site Characterization 3
$60.140 General requirements
$60.141 Confirmation of geotechnical and design parameters
$60.142 Design testing 1.3 Applicable Regulations: Performance Analysis Section 60,112 of 10 CFR 60 addresses the requirements for selection of the geologic setting and design of the engineered barrier system and the shafts, boreholes and their seals to meet the overall system performance objective for the geologic repository after permanent closure.
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2.0 Sumary of Guidance In evaluating the need for seals in an unsaturated uedium, the principal design goal should be to prevent significant amounts of surface or ground weter from reaching the waste emplacement area. In addition, a goal;should be to maintain the needed rate of drainage below the repository horizon level to allow water to percolate down through the rock mass without contacting waste packages. Seals for shafts and boreholes must be designed so that they do not become pathways that compromise the geologic repository's ability to meet the performance objectives.
A successful design goal should determine what mechanism, or combination of i mechanisms of sealing and drainage would defronstrate compliance with respect to meeting long-term performance requirements. The role and contribution of factors affecting the performance of the seal system should be assessed. The assessment should be made with respect to the potential for water to contact the waste packages and consequent radionuclides release to the accessible environment. An assessment should also consider escape of gaseous radionuclides through the shafts and boreholes to the accessible environment. If drainage is to be incorporated as a basic strategy to preclude water inflow to the emplaced waste, then the uncertainties in predicting and extrapolating the long-term behavior of the contributing factors (e.g., infiltration and effectiveness of drainage) should be considered in evaluating the post-closure performance of seals and drainage.
3.0 Justification for staff Effort The United States Nuclear Regulatory Comission (NRC) Generic Technical Position (GTP) on Borehole and Shaft Sealing of High-level Nuclear Waste Repositories (USNRC, 1986) focusses mainly on issues related to repositories in saturated media. The guidance provided in that GTP is applicable for repsitories in unsaturated medium as well. However, the Department of Energy (DM/ is currently investigating the unsaturated Yucca Mountain site for detailed characterization. DOE's current design concepts consider a combination of sealing and free drainage, and the NRC staff position on this concept is not adequately discussed in the existing GTP. Therefore, additional guidance is considered desirable to clarify the NRC staff position on sealing and drainage for a repository in an unsaturated medium.
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TP SCHEDULE for POST-CLO3URE SEALS IN AN UNSATURATED MEDIUM Milestene ElapsedTime(wk) AccumTime(wk) Date Initiate neco for TP 0 0 4/1/88 Obtain PPSAS Number 1 1 4/1/88 Preliminary Outline Complete 2 3 4/1/88 Internal Draft 16 19 5/4/88 Internal NRC Coments 4 23 8/15/88 Public-Coment Draf t 8 31 10/10/88 Federal Register Notice / , 3 34 10/31/88 Transmittal to ACNW Public Coment Period Closed 8 42 12/26/88 Public Meeting on disposition of coments 8 50 2/19/89 ACNW Meeting 2 52 3/15/89 Final TP 8 60 4/30/89 j l
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Title:
Extrapolation of Short-Term Data to long-Term Results (ESTD)
Lead Technical
Contact:
John W. Bradbury Additional Technical Contacts: CharlesPeterson,DinekhGupta l 1.0 Regulatory Evaluation
- 1 This TP will address aspects of 10 CFR Part 60 license applications 60.21(c)(1)(ii (F), technical criteria 60.101(a)(2), siting criteria 60.122(b)(3-4))and60,122(c)(7-9),andperformanceobjectives60,112and )
60.113. 1 2.0 Sumary of Guidance This TP will provide guidance concerning the information the NRC will need to l evaluate the experimental results of processes and mechanisms expected in the geologic repository. Extrapolation of experimental results to long times will be required. The use of natural analogues willsbe recomended to bridge the gap between the short term studies and the long term processes going on in the geologic environment. It is of interest that a parallel effort is underway '
through ASTM Subcommittee C26.13 to develop a national concensus standard on ESTD.
3.0 Justification for Staff Effort This TP is needed to direct DOE in acceptable methods of extrapolation of short-term tests to long-term performance. These extrapolations can involve waste package performance, rock / water interactions and hydrologic system analysis at Yucca Mountain. So far there is no evidence for a basis for the length of time short-term experiments are run. This TP will provide a basis for establishing the duration of experiments.
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U, SCHEDULE FOR,ESTD Elapsed Accumulated ,
, Milestone , Time (wk) Time (wk) Date ;
l Initiate need for TP 0 0 -
Obtain PPSAS Number 1 1 - a Preliminary Outline Done l l 2 3 - !
Internal Draft Done 1/01/91' Internal NRC Comments 5/06/91 !
Public Comment Draft Done 8 7/01/91 l l
Federal Register Notice / !
Transmittal to.ACNW 3 7/22/91 l
Public Coment Period Ends 8 9/16/91 Public Meeting on Dispos-ition of Comments 8 11/11/91 1 1
ACNW Meeting Ends 2 11/25/91 ,
Final TP Issued 8 1/20/92 l l
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"' 3 Y 1-ANNOTATED-0UTLINE TP.
Title:
Technical Position on Design and Construction of the Exploratory Shaft Facility Lead Technical
Contact:
John Peshel 1.0 Regulatory Evaluation The NRC regulatory framework for design and construction of the ESF consists of the following four parts: 1)designconsiderations,2).
constructionconsiderations,3)sitecharacterizationandperformance confirmation considerations, 4) repository performance considerations.
The applicable Part 60 regulations are listed below and the text of these regulations is provided in Appendix B of this document.
1.1 Applicable-Regualtion:-Design Criterion III of Appendix B, 10 CFT 50 requires that the DOE establish measur6s to assure that applicable regulatory requirements and design bases are correctly translated into specifications, drawings, procedures, and instructions.
Sections 60.131, 60.133 arid 60.134 of 10 CFR Part 60 address the design criteria for the geologic repository operations area. Since the ESF may become part of the future repository area these sections are also applicable to the ESF design:
660,131 General design criteria for the geologic repository operations area.
(a)Radiologicalprotection (b) Structures, systems and components important to safety 660.133 Additional design criteria for the underground facility.
(a General Criteria for the underground facility (b Flexibility of design r) c Retrieval of waste
/ d Control of water and gas e Underground openings (f Rock excavation (g Underground facility ventilation (h Engineered bariers (i)Thermalloads
$60.134 Design of seals for shafts and boreholes (a)Generaldesigncriterion (b) Selection of materials and placement methods l
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! 1.2 Applicable Regulations: Construction ,
j Subpart G of 10 CFR 60 requires that the DOE' establishes a Quality '
I Assurance Program which includes quality control. The section 60.151 addresses the applicability: "The quality assurance program applies to all ,
systems, structures and components important to safety, to design and characterization of barriers important to waste isolation and to activities related thereto. These activities include; site charac-terization, facility and equipment construction, facility operation, performance confirmation, permanent closure, and decontamination and dismantling of surface facilities."
1.3 Applicable Regulations: Site Characterization and Performance Confirmation ]
Section 60.15 of 10 CRF Part 60 addresses the site characterization requirements. In addition, Sections 60,140, 60.141, and 60.142 address the performance confirmation program requirements. The performance ;
confirmation testing will be initiated during site characterization. l I
located within the ESF.
660.15 Site Characterization ,
1 660.140 General requirements
$60.142 Design testing 1.4 Applicable Regulations: Repository Performance Section 60,112 of 10 CRF 60 addresses the requirements for selection of i the geologic setting and design of the engineered barrier system and the l shafts, boreholes and their seals to meet the overall system performance objective for the geologic repository after permanent closure.
2.0 Summary of Guidance This technical position provides guidance and clarifies NRC Staff position regarding design and construction considerations for the Exploratory Shaft Facility. The existing NRC Staff generic technical positions on Design Information Needs in the SCP, on In Situ Testing, and i on Borehole and Shaft Sealing address many technical issues related to l the design and construction of the ESF. However, the DOE is currently focussing on the unsaturated Yucca Mountain Sitt: for the detailed subsurface characterization. DOE's current repository design concepts l consider a combination of sealing and free drainage to maintain i unsaturated repository conditions throughout the post-closure period. ,
Therefore, the NRC staff position which addresses more specifically th?
design and construction of ESF in an unsaturated medium is needed.
3.0 Justification for Staff Effort l It is evident from ' current DOE's design information in the CDSCP and from I the 50% Title I design review that additional guidance is noeded to clarify NRC staff position on design and construction of the ESF. The purpose of the proposed Technical position document is to provide this guidance.
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'TP PESHEL 3-Generic ,
TP Schedule Milestone Elapsed Time (wk) AccumTime(wk) Date Initiate need for TP 0 0 6/30/88 Obtain PPSAS Number. I 1 8/17/88 Preliminary Outline Complete 2 3 7/20/88 Internal Draft 16 19 11/9/88 Internal NRC Coments 4 23 12/7/88 Public-Coment Draft 8 31 2/1/89 Federal Register Notice / 3 34 2/22/89 Transmittal to ACNW ;
Public Coment Period Closed 8 42 4/19/89 Public Meeting on disposition of coments 8 50 6/14/89 ACNW Meeting 2 52 6/28/89 l Final TP 8 60 8/23/89 .
i (1) To be completed by individual author for each TP. This should be the date j that work on the TP will actually begin, j 1
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Title:
Technical Position on Level of Retrieval Demonstration Needed During Site Characterization.
Lead Technical
Contact:
Naiem S. Tanious Additional Technical Contract: None 1.0 Regulatory Evaluations First and foremost, retrieval of waste is one of the two pre-closure performance objectives for the geologic repository operations area. This is coveredin10CFR60,111(b). Furthermore retrieval is explicitly r quired underdesigncriteriacoveredunder120CFR60.133(c)and(e).
l 2.0 Sumary of Guidance j This TP will contain guidance on the level of demonstration that would be I needed to provide the necessary assurance that the license application design l does not preclude retrieval of waste. Guidancewillbegivenon(1)thetype i of host rock data that pertains to retrieval and which would be collected !
in the in situ testing underground equipment proof of(plan, (2) principle the type demos, of physical mock-up demonstration and full-scale demos, (s) ojl etc.). This guidance is new and is not contained in the regulations or the i DOE documents. l 3.0 Justification for Staff Effort There is urgent need for a TP on retrieval demonstration. Retrieval and !
retrievability have been a subject of discussions with the DOE for several years, and despite the issuance of a DOE position on retrievability, there is no clear guidance on the level of retrieval demonstration during the SCP, the period during which the LA design will be co6pleted, and which may be used for construction of the repository. Furthermore there is an apparent belief among l the DOE staff that etrieval need not be addressed now, and can be addressed later.
i ANNOTATED OUTLINE /TR Enclosure 3 Generic TP Schedule Elapsed ' Accumulated Milstone Time (wk) Time (wk) Date Initiate need for TP 0 0 9/1/88 Obtain PPSAS Number 1 1 9/1/68 Prelimiiiary Outline Complete 2 3 9/1/88 1 Internal Draft 16* 19 12/31/89 !
l Internal NRC Coments 4 23 1/31/89 l Public-Coment Draf t 8 31 3/31/89 I
Federal Register Notice /
Transmittal to ACNW 3 34 4/21/89 Public Comment Period i Closed 8 42 6/21/89 !
Public Meeting on Disposition of Coments 8 50 8/21/89 ACNW Meeting 2 52 9/15/89 1
Final TP 8 60 11/15/89
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i (1) To be completed by individual author for each TP. This should be the date that work on the TP will actually begin.
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8 08/12/88 TECHNICAL POSITIONS TP
Title:
SUBSTANTIALLY COMPLETE CONTAINMENT (SCC)
Lead Technical
Contact:
Charles H. Peterson Additional Tech. Contacts: None 1.0 Regulatory Evaluation As part of the performance requirements of the engineered barrier system, 10CFRPart60.113(a)(1)(i) states:
"The engineered barrier system shall be designed so that assuming anticipated processes and events: (A)ContainmentofHLWwillbe substantially complete during the period when radiation and thermal conditions in the engineered barrier systen are dominated by fission product decay. .."
Part60.113(a)(1)(ii) states:
"In satisfying the preceding requirement, the engineered barrier system shall be designed, assuming anticipated processes and events, so that:
(A) "Containment of HLW within the waste packages will be substantially complete for a period to be determined by the Comission taking into account the factors specified in 560.113(b)provided,thatsuch period shall be not less than 300 years nor more than 1000 years after permanent closure of the geologic repository..."
Other statements relating to SCC are in Part 60.113(b).
2.0 Sumary of Guidance The TP will first sumarize the background for the exists statements in Part 60, make clear what the problem is, and provide a clarification of the SCC. The TP will also be useful in pursuing work on SCC rule-making.
3.0 Justification for Staff Effort The need for clarification of the phrase "SCC" became clear when the DOE proposed its own interpretation, which in effect would have permitted 20%
of the waste packages to fail within the containment period. The DOE needs a performance criterion from which they will be able to develop a design basis for the containers. Consideration of the question thus far has revealed that even so "obvious" a concept as "'otal containment" needs to be converted to a quantitative engineering equivalent.
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SCHEDULE FOR SCC l
Elapsed Accumulated Milestone Time (wk) Time (wk) Date ,
Initiate need for TP 0 0 ;
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Preliminary Outline Done 2 3 11/17/88 j Internal Draft Done 16 19 3/09/89 Internal NRC Coments 4 23 4/06/89 Public coment Draf t Done 8 31 6/01/89 1
Federal Register Notice / '
l Transmittal to ACNW 3 34 6/22/89 j Public Coment Period Ends 8 42 8/17/89 Public Meeting on Dispos-ition of Coments 8 50 10/12/89 ACNW Meeting Ends 2 52 10/26/89 Final TP Issued 8 60 12/21/89 I
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9 08/12/88 SCHEDULE FOR ASTP Elapsed Accumulated Milestone Time (wk) Time (wk) Date Initiate need for TP 0 0 -
Obtain PPSAS Number 1 1 l
Preliminary Outline Done 2 3 -
Internal Draft Done I l
Internal NRC Coments l l
Public coment Draft Done 8 7/01/89 i I
Federal Register Notice /
Transmittal to ACNW 3 7/22/89 I l
Public Coment Period Ends 8 9/16/89 j Public Meeting on Dispos-ition of Coments 8 11/11/89 ACNW Meeting Ends 2 11/25/89 Final TP Issued 8 1/20/90
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08/12/88 TP
Title:
ACCEPTABLE SCOPE FOR WASTE PACKAGE /EBS TESTING
~ l PROGRAM (ASTP)
Lead Technical
Contact:
Charles H. Peterson Additional Tech. Contacts: None 1.0 Regulatory Evaluation the requirement for testing occur, in several contexts in the regulations.
Nrexample,10CFRPart60.143(a) states:
"A program shall be established at the geologic repository operations area for monitoring the conditions of the waste packages."
Paragraph (c) of the same section continues:
"The waste package monitoring program shall include laboratory experiments which focus on the internal condition of the waste packages."
Other sections cover required testing of natural and engineered systems required for repository operation.
2.0 Summary of Guidance The TP will review and summarize specific requirements for testing to satisfy the provisions of Part 60. The guidance will include minimums for what information is needed, what has to be tested, how much testin,g should be done, what kinds of testing should be considered, and how long testing should continue.
3.0 yustificationforStaffEffort The TP is needed to elaborate on testing requirements mentioned in various sections of 10 CFR Part 60. This will provide guidance to the DOE with respect to their test programs to avoid unnecessary testing and to make clear certain minimum requirements, 1
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Title:
Waste Package Reliability Lead Technical
Contact:
K. Chang Additional technical Contacts: C. Peterson
. 1.0 Regulatory Evaluation 10 CFR Part 60.113 establishes specific performance objectives for particular barriers of the repository including the engineered barrier system. The engineered barrier system is defined as the waste packages andtheundergroundfacility(60.2). The waste package consists of the waste form and any containers, shielding, packing and other absorbent materials irrnediately surrounding an individual waste container. Specific d sign criteria for the waste package are set forth in 10 CFR 60.135.
DOE will be required to demonstrate that containment of the waste within the waste package must be substantially complete for a period of 300 to ,
1000 years.
2.0 Sumary of Guidance The purpose of this technical position is to provide guidance for an acceptable method of analysis for demonstrating reasonable assurance that the waste package designs proposed by DOE will meet the performance objectives of Section 60.113 and design criteria of 10 CFR Part 60.135.
I 3.0 Justification for Staff Effort l 1
In their license application for the geologic repository, ~the DOE must l provide analyses which demonstrate with reasonable assurance that the !
proposed waste package designs will meet the performance objectives of 10 1 CFR 60,113 and the design criteria of 10 CFR 60.135. There does not exist eny guidance which would indicate to the DOE the essential elements of waste package analyses.
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Internal Draft 16 19 8/1/89 Internal NRC Comments 4 23 9/1/89 Public-Comment Draft 8 31 11/1/89 Federal Register Notice / 3 34 11/22/89 Transmittal to ACNW Public Comment Period Closed 8 42 1/22/90 Public Meeting on disposition of comments 8 50 3/22/90 ACNW Meeting 2 52 4/7/90 Final TP 8 60 6/7/90 l 1
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Title:
Pre-Waste-Emplacement Groundwater Travel Time Lead Technical
Contact:
Fred Ross i Additional Technical Contacts: Donald Chery 1.0 Regulartory Evaluation 10CFR60.113(a)(2),theperformanceobjectiveforthehigh-levelwaste repository geologic setting, commonly known as "groundwater travel
'ime."
2.0 Sunnary of Guidance The purpose of this rulemaking is to establish a position on the groundwater travel time performance objective that is consistent with the 10 CFR Part 60 rulemaking recotd, or, if necessary, to modify the performance objective so that it serves its function of contributing to the multiple barrier philosphy.
The 10 CFR Part 60 rulemaking record will be carefully examined and all pertinent information on groundwater travel time collated to form the basis for a position consistent with the rulemaking record. The position will provide guidance on the meaning of the three key terms: fastest path of likely radionuclide travel; travel time velocity; and pre-waste emplacement conditions.
This position will be used to support rulemaking on clarifying the meaning of 10 CFR 60.113 (a)(2) but will not address an acceptable groundwater travel time methodology once D inal rule on the subject is issued.
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-2 TECHNICAL POSITION SCHEDULE Hilestone Elapsed Time (wk) Accu Time (wk) Date Develop Preliminary 16 16 (1) I Technical Position; Receive EPO Approval for Rulemaking Further Development of TP 26 42 j basisandIssueProposedEule i Issue Final Rule 78 120 l
(1) Actual starting date for developing preliminary TP pending identification j of regulatory uncertainties in GWTT regulatory requirement by CNhRA in program i architechture. l l
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12 Annotated Outline TP
Title:
Information Needs for Developing an Adequate Description of the Groundwater Flow System Lead Technical
Contact:
J. Pohle/ Hydrology Section/HLTR Additional Technical Contacts: D. Chery/ Hydrology Section/HLTR 1.0 Regulatory Evaluation In reviewing a license application for a geologic, high-level waste repository, the NRC staff will evaluate compliance assessments relative to the numerical performance objectives and the qualitative siting and design criteria of 10 CFR 60, Subpart E. Because groundwater is the primary transporting agent of radionuclides migrating from a geologic, high-level repository, knowledge of the components of the groundwater system is necessary for DOE to demonstrate compliance with 10 CFR 60, Subpart E and for NRC staff to assess that demonstration of compliance.
I' 2.0 Sumary of Guidance Tho scope of this product includes the delineation of the components, elements and/or sub-elements that comprise a description of the present day groundwater flow system. This includes all related technical disciplines such as geology, hydrochemistry, meteorology and/or climatology. Specifically excluded are future processes / events whether anticipated or unanticipated. An important aspect of the scope is the l approach to be used to discretize the description of the groundwater I flow system. The components, elements or su)-elements of the flow system description will be developed using a top-down approach. This approach will allow delineation of a consistent set of information need categories necessary to evaluate each component, element and/or sub-element. For example, categories or information needs at a broad i level (component / element)couldincludethepresentinterpretationof l active processes, alternative interpretations, relevant investigations, 1 areasofuncertainty,resultsofinvestigations(longerterm)and I interpretations to be used in licensing (longer term). In this manner the product will be of value through the characterization period as well as through license application review. More detailed information, such a:, specific flow parameters, would enter into the framework at a sub-element level. It is uncertain at this stage of the scoping process as to how far to carry the top-down approach in this individual product.
Furthur, there are other uncertainties with respect to the potential scope. The relational database being developed by the CHWRA includes a data field for information requirements (for each specific section orpartof10CFR60). The proposed TP was ariginally envisioned to
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be a comprehensive consideration of groundwater information needs (similar to a standard format and content type guide) applicable generally to all of Subpart E rather than a more detailed ' regulatory analysis".
3.0 Justification for Staff Effort The NRC staff needs this guidance for the following reasons: (1)tobe
'able to asses the completeness of DOE's proposed hydrology investigation programpresentedintheSCP;(2)tobeabletoassesstheprogressof 00E.s characterization program in providing the information needed to describe the groundwater flow system; and (3) to be able to make a final evaluation of the adequacy of the description of the groundwater flow ,
system provided'by DOE in a license application and used by DOE to demonstrate compliance with 10 CFR 60, Subpart E.
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i Enclosure 3 Generic TP Schedule Elapsed Accumulated Date Milestone Time (wk) Time (wk)
Initiate need for TP 0 0 (1)ld b Obtain PPSAS Number (T40) 1 -1 ? gi h te 2 3 3 I Internal Draft 16 19
%isT i dSbWt Internal NRC Comments 4 23 Public-Comment Draft 8 31 Federal Register Notice /
Transmittal to ACNW 3 34 Public Comment Period Closed 8 42 Public Meeting on disposition of comments 8 50 ACNW Meeting 2 52 Final TP 8 60 (1) To be completed by individual author for each TP. This should be the date that work on the TP will actually begin.
13 TP
Title:
Environment of EBS Package Lead Technical
Contact:
John W. Bradbury Additional Technical Contacts:
1.0 Regulatory Ev'aluation This TP will address aspects of 10 CFR Part 60 performance objectives 60.112 and60.113,andsitingcriteria60.122(b)(4)and60,122(c)(7-9).
?.0 Summary of Guidance This TP will provide guidance concerning NRC requirements for information on the effects of waste packages on the equilibria and kinetics of geochemical reactions in the EBS. Also discussed will be requirements for consideration of alternative conceputal models relating to mechanisms of transport in the thermally and geochemically disturbed environment.
3.0 Justification for Staff Effort This TP is needed to direct the DOE to adequately characterize the processes that occur in the EBS. This guidance will impact corrosion testing, leaching experiments, grout and seal performance, in the MOV between NMSS and RES on Compliance Demonstration, staff time and effort has been concitted to characterizing the source term. The results of this effort may be used as supporting evidence for the TP. Finally, the guidance provided in this TP may influence the approach the NRC is taking on ruiemaking for.the disturbed zone.
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ENVIRONMENT OF EBS/ PACKAGE TPSCHEDULE(1)
Milestone ElapsedTime(uk) Accum Time (wk) Date !
Initiate need for TP 0 0 Obtain PPSAS Number 1 1 Preliminary Outline Complete 2 3 'l Internal Draft 16 19 1/1/90 Internal NRC Coments 4 23 Public-Coment Draf t 8 31 9/1/90 j Federal Register Notice / 3 34 Transmittal to ACNW Public Coment Period Closed 8 42 Public Meeting on disposition of coments 8 50 ACNW Meeting 2 52 Final TP 8 60 (1) To be completed by individual author for each TP. This should be the date that work on the TP will actually begin.
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TP TITLE: RADIONUCLIDE TRANSPORT LEAD TECHNICAL CONTACT: John W. Bradbury ADDITIONAL TECHNICAL CONTACTS:
l 1.0 Regulatory Evaluation ThisTPwilladdressaspectsof10CFRPart60sitingcriteria60.122(b)and 60.122(c), and performance objectives 60.112 and 60.113.
2.0 Sumary of Guidance ,
This TP will provide guidance concerning the NRC requirements for information on radionuclide transport from the repository to the accessible environment. ,
Current plans for site characterization do not include consideration of I adsorptive retardation 1.- fractures. If matrix flow is as slow as is presently {
envisioned, retardation will probably not be required to meet regulatory j criteria. However, if fracture flow contributes significantly to the flux through the repository, retardation in fractures will be needed to isolate radionuclides. This TP could also impact the calculation of ground water ages l and the determination of pre-emplacement ground water travel time.
3.0 Justification for Staff Effort This TP is needed to direct the DOE to adequately consider alternative mechanisms to radionuclide transport in the geologic environment. The geochemistry staff considers that DOE has not addressed all possible conceptual models that pertain to radionuclide transport. This guidance would identify some plausible mechanisms of transport as of yet unaddressed by ODE. As part of this effort the geochemistry staff is involved in the INTRAVAL Project. The purpose of this effort is to allow the NRC staff to become familiar with performance assessment codes to be used in licensing.
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TPSchedule(1)
Elapsed Accumulated Milestone Time (wk) Time (wk) Date Initiate need for TP 0 0 Obtain PPSAS Number 1 1 Preliminary Outline Complete 2 3 Internal Draft 16 19 1/1/91 Internal NRC Coments 4 23 Public-Coment Draf t 8 31 9/1/91 Federal Register Notice /
Transmittal to ACNW 3 34 Public Coment Period Closed 8 42 Public Meeting on disposition of coments 8 50 ACNW Meeting 2 52 Final TP 8 60 (1) To be completed by individual author for each TP. This should be the date that work on the TP will actually begir,.
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. 15 TP
Title:
Rock / Water Chemical Interactions Lead Technical
Contact:
John W. Bradbury Additional Technical Contacts:
1.0 Regulatory Evaluation ThisTPwilladdressaspectsof10CFRPart60sitingcriteria60.122(b)(3-4) and60.122(c)(7-9)andperformanceobjectives60.112and60.113.
2.0 Summary of Guidance This TP will provide guidance concerning the information the NRC will need to evaluate the mineral stability and sorption and precipitation / dissolution reactions expected at Yucca Mountain. This document might be closely tied to the TP on Extrapolation of Short-Term Experiments to Long-Term Performance Assessment.
3.0 Justification for Staff Effort This TP is needed to direct DOE in determination of rock / water interactions at Yucca Mountain. So far there is no evidence for a basis for the length of time experiments are run. This TP will provide a basis for establishing the duration of experiments.
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ROCK-WATER CHEMICAL INTERACTIONS TPSCHEDULE(1)
Milestone Elap'ed s Time (wk) AccumTime(wk) Date Initiate need for TP 0 0 Obtain PPSAS Number 1 1 Preliminary Outline Complete 2 3 Internal Draft 16 19 5/1/90 Internal NRC Coments 4 23 Public-Coment Draf t 8 31 9/1/90 Federal Register Notice / 3 34 Transmittal to ACHW Public Coment Feriod Closed 8 42 Public Meeting on disposition of coments 8 50 ACNW Meeting 2 52 Final TP 8 60 (1) To be corrpleted by individual author for each TP. This should be the date that work on the TP will actually begin.
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16 TP
Title:
Guidance for Determination of Anticipated Processes and Events and Unanticipated Processes and Events.
Lead Technical
Contact:
Trapp Additional Technical Contacts:
1.0 Regulatory Evaluation (A) Main Areas of Rule
- 660.2 Definition of Anticipated Processes and Events and Unanticipated Processes and Events.
-960.21(c)(ii)(C)Evaluationsrequiredinlicenseapplication, Safety Analysis Report, using Anticipated Processes and Events and Unanticipated Processes and Events.
- $60,112 Function of Anticipated Processes and Events and l Unanticipated Processes and Events as related to determining if overall system performance objective has been met. ;
- 660.113(a) Function of Anticipated Processes and Events as related !
to determining if performance objective related to individual !
barriers has been met.
- 660.113(c) Function of Unanticipated Processes and Events as related to additional requirements imposed.
(B) Ancillary areas of rule
- 660.2 Definition of geologic setting, j
-660.121(b)Additionallandcontrolsrequired.
- $160.122(c)(17) Natural resources unfavorable condition, j (C)OtherFederalRegulations !
-40CFR191(EPAStandard) l l
2.0 Sunnary of Guidance l TATFain guidance
- Clarify meaning and intent of definitions of Anticipated Processes and Events and Unanticipated Processes and Events.
- Clarify information r.eeded to assure that Safety Analysis Report contains analysis needed as related to Anticipated Processes and Events and Unanticipated Processes and Events.
- Clarify how to determine which processes and events must be included in resolving overall system performance objectives and relationship to EPA standard.
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- Clarify how to determine which processes and events must be included in determining if individual barrier performance objectives have been met.
- Provide preliminary guidance on potential relationship of Anticipated Processes and Events and Unanticipated Processes and Events to additional requirements.
(B)AncillaryGuidance
- Clarify or revise definition of geologic setting.
- Provide additional guidance on use of Anticipated Processes and Events and Unanticipated Processes and Events in evaluating need for additional controls.
- (i) Provide guidance on relationship of human intrusion and natural resources to the use of Anticipated Processes and Events and Unanticipated Processes and Events. (ii) Provide guidance on the relationship of other human activities to Anticipated Processes and Events and Unanticipated Processes and Events. l (C) Other federal regulations
- Clarify, to the extent possible with vacated EPA standard, the relationship of Anticipated Processes and Events and Unanticipated i Processes and Events to EPA terminology.
3.0 Justification for Staff Effort
- Neither the staft nor DOE have agreement on the meaning or intent of the definitions of Anticipated Processes and Events and Unanticipated l Processes and Events.
- Neither the staff nor DOE understand the extent of the information l i
needed in the Safety Analysis Report or the level of investigations needed l to gather this information.
- Neither the staff nor DOE have come to agreement as to; how Anticipated Processes and Events and Unanticipated Processes and Events will be used in determining if the overall system performance objective has been met and, what processes and events must be considered in complying with overall systems performance objective.
- Neither the staff nor DOE understand; what process and events must be used in performing analysis to determine compliance with the individual :
barrier performance objectives and, the relationship of Anticipated !
Processes and Events to the analysis. l
- Neither the staff nor DOE have thought about what additional requirements may be required due to Unanticipated Processes and Events.
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- Neither the staff nor DOE fully agree on what the definitions of geologic setting means or implies, i,
- Neither the staff nor DOE have given much thought on potential j, additional land controls outside the controlled area.
- Neither the staff nor' DOE understand how to evaluate the unfavorable condition 160.122(c)(17)orhowhumanintrusionwillbefactoredinto.the system performance assessment.
- neither the staff nor DOE have come to agreement on how other human activities will be factored into the post closure performance analysis.
- Neither the staff nor DOE have come to an understanding on how the EPA standard will be implemented and the function of Anticipated Processes and Events and Unanticipated Processes and Events in doing the implementation.
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1 4.0 Schedule I Elapsed time Accumulated time Milestone (weeks) (weeks) Date Initiate need for TP Completed Obtain PPSAS Number Completed Preliminary outline Completed Internal Draft Completed Internal NRC coments Completed Public coment draf t Completed Federal Register Notice completed Transmittal to ANCW Completed End comment period completed Request for additional 0 0 Aug 15, 1988 coments Reciept additional 5 5 Sept 16, 1988 coments Draft coments 4 9 Oct 14, 1988 resolution document Prepare rulemaking 4 13 Nov 11, 1988 options 4
EDO approval 39 52 Aug, 1989 Proposed rule 26 78 Feb. 1990 Publish final rule 78 156 Aug. 1991 l
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1 Assumes a budget for anticipated processes and events and unanticipated processes and events. Draf t budget contains no time or money for TP, but .
contains budget for rulemaking..
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PRE-CLOSURE EARTHQUAKE HAZARD EVALVATION METHODS ANNOTATED OUTLINE TP
Title:
Pre-Closure Earthquake Hazard Evaluation Methods Lead Technical
Contact:
Michael Blackford Additional Technical
Contact:
Philip Justus 1.0 Regulatory Evaluation o Primary section of 10 CFR 60 addressed: 660,131 General design criteria ,
for the geologic repository operations area - (b) Structures, systems, ,and ;
components important,do safety - (1) Protection against natural phennmena and environments 1 conditions; section is a part of the Design Criteria for the Geologic 7epository Operations Araa, an element of Subpart E -
Technical Cricer10.
o Primary section of 10 CFR 100 addressed: Appendix A Seismic and Geologic Siting Criteria for Nuclear Power Plants;'an appendix to 10 CFR 100 Reactor Site Criteria, o Other section of 10 CFR 60 requiring technical information regarding i earthquake hazard: $60.21 Content of application - (c) Safety Analysis 1.
Report - (3) Description and analysis of the design and performance ,
requirements for structures, systens, and components of the geologic repository which are important to safety; section is a part of the License Application element of Subpart B - Licenses.
o Other sections of 10 CFR 60 affected by this position: 560,122 Siting !
2 criteria - (c) Potentially adverse conditions - (3) natural phenomena '
affecting groundwater flow, (4) structural deformation affecting groundwater repeated historical flow, (11) structural earthquakes affectin deformation 13)during(the increase of Quaternary, (1 earthquake frequency or magnitude, and (g the site,14) earthquake frequency or magnitude greater than typical; these conditions are a part of the siting criteria for the long-term performance of the geologic repository, an element of Subpart E - Technical Criteria.
o Welevant performance objective: 560,111 Performance of the '
repository operations area through permanent closure - (a) geologic Protection 4 m,.
against radiation exposures and releases of radioactive material - and - $
(b) Retrievab111ty of waste; this performance objective is an element of -
Subpart E - Teci1nical Criteria. !
1 2.0 Sumary of Guidance o Investigatory methodologie* prescribed in 10 CFR 100, Appendix A, or in
- Regulatory Guides, Standard Format and Content Guides, or Standard Review Plans supporting the appendix, may be utilized to respond to information ,
needs arising from the regulatory requirements of 10 CFR 60 with due
- consideration of the differences between the performance objectives of 10 . .-
CFR 100 and those of 10 CFR 60.
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o The surpose of the seismic investigations is to determine one design basis eart1 quake, which may be applied'to the engineering requirements of both the pre-closure and post-closurc periods of performance of the geologic repository. -
o In order to address the uncertainties arising from the nature of the design bases determined, the degree of conservatism required, and the ,
applicability of the alternate hypotheses, techniques of probabilistic risk assessment may be employed.
3.0 Justification for Staff Effort o Confusion concerning t'elationship of 10 CFR 100, Appandix A to 10 CFR 60; options: 1) respond to Part 60 seismic information needs independent of Part 100, Appendix A, 2) defer totally to Part 100, Appendix A, 3) use Part 100, Appendix A with modifications appropriate for Part 60; DOE has requested staff guidance in this area o Need to address role of probabilistic techniques in utilization of l deterministically derived design basis earthquake; analytical methodologies to be addressed in separate sosition, "Probabilistic Seismic Hazard Analysis," developed by Abou-Bakr I)rahim !
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PRE-CLOSURE EARTHQUAKE HAZARD EVALUATION METHODS TECHNICAL POSITION SCHEDULE 1
Elapsed Accumulated M_ilestone Time (wk) Time (wk) Date Initiate need for TP 0 0 Complete Obtain PPSAS Number 1 1 Complete Preliminary Outline Complete 2 3 Complete Internal Draft 16 19 08-18-88 Internal NRC Coments 4 23 09-15-88 ,
Public-Comment Draft 8 31 11-10-88 l Federal Register Notice / )
Transmittal to ACNW 3 34 12-01-88 Public Coment Period Closed 8 42 01-26-89 Public Heeting on l Disposition of Coments 8 50 03-23-89 j ACNW lieeting 2 52 04-06-89 l l
Final TP 8 60 06-01-89 l I
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f TP
Title:
GUIDANCE FOR PERFORMING PROBABILISTIC SEISMIC HAZARD ANALYSIS FOR HIGH-LEVEL WASTE REPOSITORY Lead Technical
Contact:
A. K. Ibrahim 4
- 1. Regulatory Evaluation Main areas to be addressed under T.P. are:
60.111 Performance of the geologic repository operations area through performance closure 60.112 Overall system performance objective for the geologic repository after permanent closure 60.113 Performance of particular barrier after permanent closure 40 CFR 191.13 EPA rt:quirements
- 2. Sumary of Guidance Purpose The purpose of this report is to establish at least one acceptable method for providing a probabilistic assessment of the seismic hazard ground motion and differential fault displacement at a high-level waste repository site.
Objective BasedontheneedtosupportEPArequirements(40CFR191.13),' Disposal systens for spent fuel or high-level or transuranic radioactive waste shall be designed to provide reasonable expectation, based upon performance ,
assessment, that the cumulative releases of radienuclides to the accessible l environment for 10,000 years after disposal from all significant processes and events that may affect the dispostil system shall:
- a. Have a likelihood of less than one chance in 10 of exceeding the quantities I calculated according to table 1 (Appendix A); and
- b. Have A likelihood of less than one chance in 1,000 of exceeding ten times the quantities calculated according to table 1 (Appendix A),"
The Technical Review Branch is developing this report with the following
]~ objectives in mind:
- a. To sumarize a methodology to calculate a seismic hazard function for a high-level waste repository,
- b. To insure that necessary and sufficient information has been obtained for use in the hazard analysis, I
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- c. To compute the seismic hazard at the site of interest in a for suitable for use in assessing the implication of the results on the health and safety of the public, and
- d. To identify procedures that could assist in allowing improved specification and integration of seismic hazard and fragility functions.
- 3. Justification for Staff Effort The results from the seismic hazard assessment will be used to calculate frequencies of mechanical and structural failure and to estimate frequencies of consequences of such failure for the pre-closure and post-closure period 4 of the facility. For the post-closure period of the facility, these calculations will be combined with other processes and events calculations to form an overall complementary cumulative distribution function (CCDF) that should display that the likelihood of radioactive material released to the environment for the 10,000 years after disposal for all significant processes and events will not exceed specified EPA values. Compliance with these EPA release requirements is necessary for the commission to issue a license to the applicant todisposeofhigh-levelradioactivewaste(NRC,10CFP,60,SectionII, Proposed '
Rule, June 1986).
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TECHNICAL POSITION SCHEDULE ,
Elapsed Accumulated Time (wk) Time (wk) Date Milestone Initiate need for TP 0 0 8/01/88 Obtain PPSAS Number 1 1 8/07/88 Preliminary Outline Complete 2 3 5/27/89 Internal Draft 16 19 9/16/89
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Internal NRC Coments 4 23 10/14/89 Public-Connent Draf t 8 31 12/09/89 Federal Register Notice /
Transmittal to ACNW 3 34 2/03/90 Public Comment Period Closed 8 42 2/24/90 f
1 Public Meeting on Disposition of Coments 8 50 4/21/90 ACNW Meeting 2 52 5/05/90 Final TP 8 60 6/30/90 i J
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VOLCANIC HAZARDS ANALYSIS ,
I ANNOTATED OUTLINE TITLE: VOLCANIC HAZARDS ANALYSIS LEAD TECHNICAL CONTACT: Charlotte Abrams ADDITIONAL TECHNICAL CONTACTS: Philip Justus, John Trapp Keith McConnell
1.0 REGULATORY EVALUATION
1.1 Related Perforrance Objectives 10 CFR Part 60,111 provides for "performance of the geologic repository operations area through permanent closure." 10 CFR Part 60,112 provides for the "overall system performance... for the geologic repository after permanent closure." 10 CFR Part 60,113 deals with the "performance of particular barriers after permanent closure."
1.2 Other Appropriate Parts of 10 CFR Part 60 Other parts of 10 CFR Part 60 that require technical information and evaluation regarding the identification of volcanic hazards at and near the proposed HLW repository site are: under Content of Application,(60.21 (c)(1) "a description and assessment 60.21(c)(1)1)(A)descriptionof"theorientation, of the site...,"
distribution....
andoriginof...discontintinuities,"(ii)(A)"ananalysisofthe geology... of the site," (B) "anelyses to determine the degree to which each of the favorable and potentially adverse conditions... has beencharacterized,"and(C)"anevaluationoftheperformanceofthe proposed geologic repository for the period af ter permanent closure...;"
underSitingCriteria,favorablecondition60.122(b)(1)"thenature and rates of tectonic... processes operating within the geologic setting during the Quaternary Period...would not affect or would t
iavorably the waste;"affect the abilityadverse and potentially of the geologic repository conditions 60.122 (c)o isolate (3)"potential for naturel phenomena such as... volcanic activity... " and 60,122 (c)(15) "evidence of igneous activity since the start of the quaternary Period."
2.0
SUMMARY
OF GilIDANCE Both deterministic and probabilistic analyses of volcanic hazards are necessary for site characterization. Probabilistic analysis is called for under EPA Guidelines. In order to undertake an analysis it is necessary to first identify potential volcanic hazard scenarios in light of what is known about the volcanic history of the geologic setting. Guidance on identification of potential volcanic hazards should include the need for DOE to ascertain information such as the
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age of most recent events, recurrence intervals of volcanic events, associated hydrovolcanic events, presence of subsurface magma, and potential structural controls on volcanism (NRC, 1987). This information should then be integrated with information on hydrologic and geo:hemical processes.
3.0 JUSTIFICATION FOR STAFF EFFORT The potential volcanic hazards which exist within the geologic setting must be identified prior to any probabilistic analysis. Based on CDSCP Coments 51 and 95 and Question 20 (NRC,1988) the NRC staff does not believe that adequate consideration has been given by the DOE to the identification of potential volcanic hazards or the integration of volcanic processes and events with other tectonic processes and the other disciplines of hydrology and geochemistry.
4.0 REFERENCES
NRC, 1987, Draft technical review plan for NRC staff review of DOE's site characterization plans: Division of High-level Waste Management. .
NRC,1988, NRC staff review of the Department of Energy's January 8,1988, Consultation Draft Site Characterization Plan for the Yucca Mountain Site, Final point papers: Division of i High-level Waste Management.
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IDENTIFICATION OF VOLCANIC HAZARDS SCHEDULE Milestone elapsed accumulated date time (wk) time (wk)
Initiate need 0 0 complete Obtain PPSAS Number 1 1 8 25 88 Preliminary Outline 2 3 9 1-88 complete ,
Internal Draft 17 20 12 29-88 Internal NRC Comments 5 25 2-2-89 Public-Comment Draft 8 33 3-30-89 Federal Register hotice/
Transmittal to ACNW 3 36 4 20 89 Public Comment Period Closed 8 44 6-15 89 Public Meeting on f Disposition of Comments 8 52 8 10 88 ACNW Heeting 2 54 8 24 89 Final Document 8 62 10-19-89 l
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i 20 TP
Title:
The Use of Tectonic Models Under 10 CFR 60 lead Technical
Contact:
Keith McConnell Additional Technical contacts: Philip Justus 1.0 Regulatory Evaluation 10CFR60.2 rtquires that the program of exploration and research undertaken during site characterization should establish the geologic conditions and the ranges of those parameters at a particular site. More specifically, 10 CFR 60.122(a)(1) states that the D h must demonstrate that:
" The potentially adverse... natural condition [s] has been adequately investigated, including the extent to which the condition may be present and still be undetected taking into account the degree of resolution achieved by the investigations" and that "The effect of the potentially adverse ... natural condition on the site has been evaluated using analyses which are sensitive to the potentially adverse ... natural condition and assumptions which are not likely to underestimate its effect."
To achieve the regulatory requirements specified in 10 CFR 60 and outlined above, the use of conceptual models is required. Recognition of the obligation to use models for determinin0 the long term performance of a repository is recognized in 60,101 which states that:
Demonstration of corpliance with long-term performance objectives and criteria will "involve the use of data from accelerated tests and predictive models that are supported by such measures as field and laboratory tests, monitoring data and natural analog studies" (60,101 (a)(2).
In addition, because conceptual tectonic models will be used to aid in j defining which processes and events are anticipated and unanticipated processes and events, tectonic models will play a large role in the development of scenarios used to assess the long term performance of the repository under i 60.112 & 60.113. For example, the EPA containment requirements of 40CFR191.13 l requires that the sum of the cumulative releases be assessed from all l significantprocessandevents(draftTP, Scenarios). In order to develop a t l
J complete list of mutually exclusive scenarios for tectonics at the Yucca Mountain site, a comprehensive tectonic model m st be available on which to base the selection. The NRC staff emphasized this requirement for the use of l
conceptual models in the development of scenarios in the DOE-NRC Conceptual
' Nodelsmeeting(April,1988). In that meeting, the NRC staff stated that I conceptual cedels: l l
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20 "if confirmed, be used to calculate releases for all scenarios needed to show compliance with the EPA standard" (NRC comments, DOE-NRC Conceptual
, Models Meeting, April, 1988).
2.0 Summary of Guidance The analysis of the use of tectonic models under 10 CFR 60 presented in this report is undertaken to highlight the NRC staff's position on what is required in the construction and use of alternative conceptual tectonic models in performance allocation and performance assessment. The objective of this analysis is to suggest the types of information required and the steps involved in defining a preferred tectonic model. Adherence to this analysis will ensure the completeness of the information provided and will aid in shortening the time needed for review.
3.0 Justification for Staff Effort In its review of the CDSCP the NRC staff noted that the performance allocation process in the CDSCP did not address the investigations that would be needed to characterize the site with respect to the full range of alternative conceptual models and associated boundary conditions. The NRC staff also indicated that the program of investigation outlined in the CDSCP m Mht favor providing data that would confirm the "preferred" model rather than allecting data to determine what the "preferred" model and boundary conditions should be. The NRC staff recomended that the full range of alternative conceptual models supported by available evidence from the Yucca Mountain area should be identified and form the basis for preliminary performance allocation.
In addition, the NRC staff indicated that Conceptual models should:
- 1) form the basis for the predictive performance assessments of repository systems and subsystems, and
- 2) if confirmed, be used to calculate releases for all scenarios needed to show compliance with the EPA standard (NRC coments, DOE-NRC Conceptual Models Meeting, April,1988). I In the April, 1988, meeting on Alternative Conceptual Models, the DOE agreed that they would provide in the statutory SCP a table listing the full range of conceptual models for all major disciplines. This was confirmed in a 00E presentation before the ACNW (June 28,1986) in which the DOE presented their intentions to provide tabular listings of conceptual models for hydrology, tectonics and other major disciplines.
The guidance presented in this TP on tectonic models will provide the DOE and the NRC reviewer with a regulatory perspective and inforniation template to assure that during site characterization the DOE:
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- 1) presents all alternative conceptual tectonic models supported by existing geologic data,
- 2) provides an assessment of the possible effects on repository design and ability to meet the performance objectives under each conceptual model
- 3) provides a list of investigations and information necds to address each conceptual model, and I
- 4) provides the sources of and estimates of the magnitudes of uncertainty associated with each conceptual tectonic model.
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20 TECTONIC MODELS TP SCHEDULE Elapsed Accumulated Milestone Time (wk) Time (wk) Datt Initiate need for TP 0 0 08/29/88 Obtain PPSAS Number 1 1 09/05/88 Preliminary Outline Complete 2 3 09/19/88 Internal Draft 16 19 01/09/89 Internal NRC Comments 4 23 02/13/89 Public Comment Draft 8 31 04/10/89 Federal Register Notice /
Transmittal to ACNW 3 34 05/01/89 Public Comment Period Closed 8 42 06/26/89 Public Meeting on disposi-tion of comments 8 50 08/21/89 ACNW Meeting 2 52 09/04/89 Final TP 8 60 10/30/89
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21 TP
Title:
Natural Resources Assessment Methods Lead Technical
Contact:
H. Lefevre l Additional Technical
Contact:
C. Abrams 1.0 Regulatory Evaluation Clarification of NRC's regulatory requirements constitute the initial I step to be taken by the staff in the development of guidance enabling i the DOE to facilitate demonstration of compliance with the natural )
resources assessment provisions of 10 CFR Part 60. The provisions center on (1) information, data and. evaluations to be included in the I Safety analysis Report portion of the License Application (10 CFR Part i 60.21(c)(13), (2) the identification of favorable siting conditions (10 CFR Part 60.122(4)(b),(3)theidentificationof siting conditions (10 CFR Part 60.122(c)(17), and (4)potentially adverse demonstrating, giving the presence of potentially adverse conditions, that performance objectives relating to waste isolation (10 CFR Part 60.111(a) [ protection !
against radiation exposures and releases of radioactive material] and 10 CFR Part 60.112 [overall system performance objective for the geologic repositor afterpermanentclosure]willnotbecompromised(10CFRPart 60.122(a)y(1).
2.0 Summary of Guidance I Compliance with the NRC's regulatory requirements is dependent upon the I DOE's utilization of a methodology or, more than likely, a combination !
of methodologies, designed to assess the natural resources of the geologic setting and to submit such information in the Safety Analysis Report (10 CFR Part 60.21(c)(13) as a portion of the license application.
Information derived through utilization of the natural resources assessment methodology (or methodologies) is to not only demonstrate conclusively the absence of natural resources, if such is the case, but is to identify potentially adverse conditions, should such exist, relative to the presence of naturally occurring materials characteristic of the controlled area or possibly affecting isolation within the controlled area (10CFR60.122(c)(17).
Clarification of the regulatory requirements hinges, in part, upon the ,
definition of a number of insufficiently-defined terms and phrases i that the natural resources-related provisions of the rule Along with I the definition itself, illustrei. ions or diagrams depicting the staff's I position on the minimal geographic limits to be included by the DOE in its' assessment of the natural resources. 1 l
Further clarification of the rule may be undertaken by the NRC staff by i providing appropriate example (s) of how particular pMentially adverse l conditions can be "compensated by the presence of a combination of l favorablecharacteristics",or"remedied"(10CFR60.122(a)(2)(111)(B) I and(c),respectively.) !
21 3.0 Justification for Staff Effort It is clear that timely NRC direction of the natural resources assessment progran is needed. This has been demonstrated by staff concerns transmitted to the DOE as part of the 1986 Final Environmental Assessment (FEA)commentsandin1988as Characterization Plan (CDSCP) part of the Consultation Draft SiteBased upon the 19 comments.
content, it is apparent that the NRC FEA comments of 1986 have had minimal impact on changing the direction of the DOE's natural resources assessment program. Additional clarification and direction, in the form of an acceptable natural resources assessment methodology including a concise identification of the means for demonstrating compliance with NRC regulatory requirements is a necessity.
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Technical Position ;
for NATURAL RESOURCES ASSESSHENT METHODS Elapsed- Accumulated Date -
l Milestone Time (wk) Time (wk) 0 Completed Initiate need for TP 0 0 0 Not Completed Obtain PPSAS Number Preliminary Outline 0 0 Completed Complete ;
Internal Draft 9 9 17 Oct 1988 Internal NRC Comments 12 21 9 Jan 1989 20(1) 41 29 May 1989 Public Coment Draf t Federal Register Notice / ,
19 Jun 1989 44 Transmittal to ACHW 3 Public Comment Period 8 52 14 Aug 1989 Closed Public Meeting on !
Disposition of Coments 8 60 9 Oct 1989 ACNW Meeting 2 62 23 Oct 1989 8 70 18 Dec 1989 Final TP (1) Assuming 12 weeks devoted to SCP review. No activity of TP is anticipated during this time period.
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-y 22 TP
Title:
Geologic Mapping of Shafts / Drifts Lead Technical
Contact:
A.T. Cardone 1.0 Regulatory-Evaluation The TP Geologic Mapping of Shafts / Drifts addresses the following sections of regulations:
(A) 560.72 Construction Records
-60.72 (b)(1) Surveys of the underground facility excavations, shafts, and boreholes referenced to readily identifiable surface features or monuments
-60.72 (b)(2) A description of the materials encountered
-60.72 (b)(3) Geologic maps and geologic cross sections
-60.72(b)(4)Locationsandamountofseepage
-60.72(b)(7)Anamalousconditionsencountered (B) 560.140 General Requirements
-60.140 (a)(1) Actual subsurface conditions encountered and changes in those conditions during construction and waste emplacement l operations are within the limits assumed in the licensing review l (C) -960.141 Confirmation of geotechnical and design parameters. I
-60.141 (a) During repository construction and operation, a continuing program of surveillance, measurement, testing, and gealogic mapping shall be conducted to ensure that geotechnical and design parameters are confirmed...
-60.141 (c) As a minimum, e. suremei.ts shall be made of rock deformations and displacement, changes in rock strss and strain, rate and location of water inflow into subsurface areas, changes in groundwater conditions, and rock pore water pressures including those along fractures and joints...
-60,141 (d) These measurements and observations shall be compared .
with the original design bases and assumptions... l l
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1.1 Related performance Objectives i
10.CFR Part 60.111 provides for "performance of the geologic repository l operations area through permanent closure." 10 CFR Part 60.112 provides for the "overall system performance... for the geologic repository after permanent I closure." 10 CFR Part 60,113 deals with the "performance of particular '
barriers after permanent closure."
2.0 Sumary of Guidance l
-Provide a sumary of state-of-the-art procedures presently employed in !
underground, geologic mapping and propose a means of comparing that with !
the new mapping prodecures to be employed by DOE. ;
-Discuss the geologic information obtained from the ground surface, boreholes, and geophysical methods that will be required by the mapping party before underground geologic mapping is begun.
-Propose methodology for identifying anomalousand unanticipated conditions by the mapping party
-Establish a means of developing an acceptable model of anticipated structural, stratigraphic, lithologic, and hydrologic conditions at the repository horizon needed by the mapping party for comparison with conditions to be encountered to permit identification of anomalous or unanticipated conditions.
3.0 Justification for Staff Effort
-New, unproven procedures are to be employed by DOE in mapping the shafts and drifts
-Need to estabitsh standards and procedures to provide a means of establishing product acceptability by the staff.
-Need to establish criteria to permit staff evaluation of the adequacy of the mapping program in identifying structural and stratigraphic anomalies.
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22 TP SCHEDULE FOR GEOLOGIC MAPPING OF SHAFTS / DRIFTS Milestone Elapsed Time (wk) Accum Time (wk) Date Initiate need for TP 0 0 1/20/89 Obtain PPSAS Number 1 1 1/27/89 Preliminary Outline Complete 2 3 2/10/89 Internal Draft 16 19 6/2/89 Internal NRC Comments 4 23 6/30/89 Public-Comment Draft 8 31 8/25/89 Federal Register Notice / 3 34 9/15/89 Transmittal to ACNW Public Comment Period Closed 8 42 11/10/89 Public Meeting on disposition of comments 8 50 1/5/90 ACNW Meeting 2 52 1/19/90 Final TP 8 60 3/16/90 i
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i ANNOTATED OUTLINE j TITLE: GEOMORPHIC ANALYSIS LEAD TECHNICAL CONTACT: Harold Lefevre l ADDITIONAL TECHNICAL CONTACTS: Philip Justus, Charlotte Abrams i
1.0 REGULATORY EVALUATION
1.1 Related Performance Objectives 1
10 CFR Part 60.111 provides for "performance of the geologic repository operations area through permanent closure." 10 CFR Part 60,112 ;
provides for the "overall system performance ... for the geologic ;
repository after permanent closure." ,
10 CFR Part 60.113 deals with the "performance of particular barriers after permanent closure."
1.2 Other 'ppropriate Parts of 10 CFR Part 60 Other parts of 10 CFR Part 60 that rt,uire technical information and si evaluation under regarding Content geomorphic of Application, 60.21 analy(c)s (1) "a of the proposed description and HLW site are:
assessmentofthesite["60.21(c)(1)(ii)(A)"ananalysisofthe geology...," 60.21 (c) 1)(ii)(B) "analyses to determine the degree to which each of '.he favorable and potentially adverse conditions...has ,
been characteri.ed," 60.21 (c)(1)(C) "an evaluation of the performance 1 of the proposed geologic repository...," 60.21 (c)(1)(ii)(F)(2) "a description and discussion of the design... of the geologic repository...;" under Siting Criteria, favorable conditions 60.122 i (b)(1) "the nature and rates of... geomorphic processes operating within the geologic setting during the Quaternary Period... would not affect or would favorably affect the ability of the geologic repository l to isolate the waste and 60.122 (b)(5) "Conditions that permit the emplacement of waste at a minimum depth of 300 meters from the ground surface;" and potentially adversi conditions 60.122 (c)(1) "potential for flooding of the underground facility," 60.122 (c)(3) "potential for natural phenomena such as landslides, subsidence... " and 60.122 (c)(16) "evidence of extreme arosion during the Quaternary Period."
2.0~
SUMMARY
OF GUIDANCE )
Geomorphic guidance is contained in NUREG/CR-3276', Geomorphic Controls on the Management of Nuclear Waste (Schura and Chorley, 1983). In addition, guidance in the form of Standard Review Plans, Standard Format and and Content Guides, and letter reports should be formulated l
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and made available to the 00E. Examples of existing letter reports include reports on potential erosion at the Yucca Mountain site (Purcell,1986) and geomorphic evaluation of shaft and ramp locations (Purcell, 1988). Guidance should be available to the DOE early in the design and siting phases of all underground openings, spoil and muck piles, and other surface facilities.
The purpose of geomorphic evaluation and assessment is to identify parameters related to geomorphology, physiography, and topography which should provide an adequate consideration of geomorphic processes such as erosion and mass wasting which would have an impact on the geologic setting and location of repository facilities. Geomorphic studies should also provide information on the location, nature, and extent of geomorphic features which may impact the performance of the repository.
A listing of criteria for DOE's geomorphic evaluation of the proposed site is contained in draft technical review plans for DOE's SCP (NRC, 1987).
3.0 JUSTIFICATION FOR STAFF EFFORT Confusion appears to exist within the DOE as to the appropriate scope of geomorphic studies. Proposed studies are directed primarily to the overall site, based on regional data, without emphasis toward specific locations and/or processes. For example, with respect to locations of shafts and portals, muck and spoil piles, and other surface facilities an assessment of each location needs to be made by the DOE. NRC staff's CDSCP comments 34 and 35 and questions 18, 19, and 29 (NRC, 1988) demonstrate a need to provide appropriate guidance to the DOE during the period of site characterization studies. Reevaluation of proposed guidance should be undertaken upon receipt of the SCP and at that time a determination should be made as to the continuation and Jegree to which appropriate guidance should be delivered.
4.0 REFERENCES
NRC, 1987,. Draft technical review plan for NRC staff review of DOE's site characterization plans: Division of High-Level Waste Management.
NRC,1988, NRC staff review of the Department of Energy's January 8, 1988, Consultation Draft Site Characterization Plan for the Yucca Mountain Site, Final point papers: Division of High-Level Waste Management.
Purcell, C. 1986, Potential erosion at the Yucca Mountain nuclear waste site: letter report from LLNL to NRC.
Purcell, C., 1988, Geomorphic evaluation of proposed shaft and ramp locations, Yucca Mountain High Level Waste Site: Lawrence Livermore National Laboratory draf t report no.
LLNL/NRC-NNWSI-CRP-87/88-YMI.
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f Schurnm, S. A. , and Chorley, R.J.,1983, Geomorphic controls on the Management of nuclear waste: USNRC NUREG.CR-3276.
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SCHEDULE Technical Position 8
for
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GE0 MORPHIC HAZARDS A'NALYSIS Elapsed Accumulated Time (wk) Date Milstone Time (wk) 0 Completed Initiate need for TP 0 ,
Obtain PPSAS Number 1 1 8/29/88 Acquisition of Beckground Information 5 6 10/3/88 Preliminary Outline ,
Complete 8 14 11/28/88 Internal Draft 27(1) 41 6/5/89 l
Internal NRC Coments 8 49 7/31/89 Public-Coment Draf t 8 57 9/25/89 Federal Register Notice /
Transmittal to ACNW 3 60 10/16/89 Public Coment Period Closed 8 68 12/11/89 Public Meeting on Disposition of Coments 8 76 2/13/90 ACNW Meeting 2 78 2/27/90 Final TP 8 86 4/24/90 (1) Assuming 12 weeks devoted to SCP review. No activity of TP is anticipated during this time period.
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Title:
Implementation of EPA Containment Requirement Lead Technical
Contact:
Fehringer Additional Technical Contacts:
1.0 Regulatory Evaluation 10 CFR Part 60,112, Overall system performance objective for the geologic repository after permanent closure.
2.0 Summary of Guidance This technical position will discuss the NRC staff's views regarding one or more of several issues regarding implementation of the EPA containment requirement. Issues that might be discussed include:
--Determination of probabilities of potentially disruptive processes or events.
--Elaboration on the flRC's previous conditions regarding consideration of the effects of human-induced disruptions on repository performance.
--Use of "bounding" or "worst-case" analyses for estimating the consequences of potentially disruptive processes or events.
--Procedures for' combining scenario analyses into an overall probability distribution, and circumstances obviating the need for such a combination.
--Alternative means (other than probabilistic risk analyses) acceptable to the staff for demonstrating compliance withLthe containment requirement.
--NRC staff endorsement or repudiation of EPA's "guidance.for implementation" of its standards.
3.0 Justification for Staff Effort Both DOE and Nevada can be expected to have widely differing views regarding the proper means for implementing the EPA containment requirement, and the NRC staff needs advance preparation to be able to evaluate the merits of the conflicting arguments that will be presented.
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, I 4 l Schedule Elapsed Accumulated Date l Milestone Time (wk) Time (wk) ;
1 Initiate need for TP 0 0 11/1/90 >
Obtain PPSAS Number 1 1 11/8/90 Preliminary Outline Complete 2 3 11/21/90 l
Internal Draft 16 19 4/1/91 ;
1 Internal NRC Connents 4 23 5/1/91 Public-Comment Draft 8 31 7/1/91 Feuaral Register Notice / l Transmittal to ACNW 3 34 7/22/91 Public Comment Period Closed 8 42 9/22/91 Public Meeting on disposition of comments 8 50 11/15/91 !
l ACHW Meeting 2 52 12/1/91 1 Final TP 8 60 2/1/92 i
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' I 25 1 1 -l TP
Title:
Scenario Identification and Screening Lead Technical
Contact:
Fehringer
, Additional Technical Contacts. '
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1.0 Regulatory Evaluation 10 CFR Part 60,112, Overall system performance objective for the geologic' repository after permanent closure.
2.0 Summary of Guidance This TP will contain the staff's collected wisdom regarding acceptable means for identifying scenarios that could potentially disrupt a repository, and for screening those scenarios to determine which require additional analysis to evaluate compliance with the various provisions of Part 60 (principally the overall performance objective of: 5 60,112).
3.0 Justification for Staff Effort Identification and screening of potentially disruptive scenarios will be a major and controversial step in evaluating the acceptability of a repository. DOE can be expected to minimize the number of scenarios to be included in its analyses of facility performance, while Nevada will argue that additional scenarios should be included. Both sides can be expected to use creative arguments. Development of NRC staff guidance will help to prepare for evaluating the merits of these arguments. ,
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i Schedule Elapsed '
Accumulated Date Milestone Time (wk) Time (wk)
,, Initiate need for TP 0 0 9/1/89 Obtain PPSAS Number 1 'I h/8/89 Preliminary Outline ,
Complete 2 3 9/22/89 Internal Draft 16 19 '2/1/90 <
- Internal NRC Comments 4 23 3/1/90 Public-Comment Draft 8 31 5/1/90 i
Federal Register Notice /
Transmittal to ACNW 3 34 5/22/90 Public Comment Period Closed 8 42 7/22/90 3
Public Meeting on disposition of comments 8 50 9/15/90 ACNW Meeting 2 52 10/1/90 Final TP 8 60 12/1/90 he
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q TP. DOC 8/12/83 1 j 2d l rs l 0 ,
Title:
Verification and Validation of Performance Assessment Models Lead' Technical
Contact:
Richard B. Codell, Compliance'0emonstration Section AdditionalFTechnical Contacts:
1.0 Regulatory Evaluation The IAEA defines model verification and validation in the following way:
"A computer code is ' verified' when it is confirmed that the conceptual model of the real system is adequately represented by the, mathematical solution." y "A conceptual.lmodel and the computer code derived from it are a validated when it is confirmed that the conceptual model and the derived computer code provide a good representation of the actual s processes occurring in the real system."
Model verification and validation are not mentioned explicitly in the regulations, but can be implied as adding'to the finding of "Reasonable Assurance" (e.g., 60.31(a)(2), 60.101) that the site and design comply with the overall performance criteria of 10CFR60.112 and the performance of specific barriers of 10CFR60.113. Model verification is a key part of ,
the documentation and quality assurance of computer codes used in the licensing assessments.
2.0 Summary of Guidance This TP will discuss the NRC staff's position on what constitutes adequite verification and validation of computer programs used to make findings of
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compliance with the performance objectives of 10CFR60 sections 112 and 113. Issues to be discussed include, but are not limited to:
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- Development of software (programs and data) under good quality j assurance practices
- Verification of models with the results from simplified analytical ,
models
- Benchmarking models to other models where no analytical results are available
- Validation of models with actual field and laboratory data, including natural analogs
- Validation of models witn realistic synthetic data sets
- What to do when no model validation can be reasonably expected before licensing of the repository; e.g., long term behavior cannot be forecast in the limited time available, or inadequate data exist.
3.0 Justification for Staff Effort Mathematical models, usually implemented as computer programs, will be used extensively for all phases o' site; characterization and licensing, both to guide the site characterization efforts and make determinaticns of compliance with the performance objectives. Model verification and validation are key to the determination of reasonable assurance.
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Schedule Milestone Elapsed- Accumulated Date
, Time (wk) _ Time (wk)
,1.
Initiate need/for TP 0 0 2
2/1/89 Obtain PPAS Number .l' 1 .I/2/8/89 - \.-
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- - Preliminary Outline 2 3 2/22/89.
Internal Draft '
29 32 9/1/89 PublicCommentOrift 24 56 , 3/1/90 Federal Register Notice / 8 i
Transmittal to ACNW i
Public Comment Period 8 Closed ,
Public Meeting on 8 disposition of comments ACNW Meeting 2 Final TP 8 ,
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Title:
Boundary Conditions for EBS Analysis ,
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Note: We are proposing that this TP is unnecessary because the '
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, boundary condition for the EBS has already been defined as that !
which does not include a portion of the best rock (see enclosed i ,
letter from J. Linehan, NRC to J. Knight', DOE, dated September.
s 26,1986).
?
Memorandum of September 26, 1986 - following i
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RE3rovning JCtarratanaf ,
MJBell ACarcia (0) _'
3 JBunting *PDR fI} 2 7 JCreeves PJustus Mer/9 gg,g Mr. James Knight, Director ,
k Y g y$ 6 ,de, Licensing and Regulatory Olvis 4n scoplan Office of Geologic Repositori r; '
dy U Department of Ene'rgy ,,
PHildenbrand Washington,.0C 20585 KStablein' l j
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Dear Mr. Knight:
PPrestholt l Tverma Discussions with our on-site representatives and with the Department of Energy
.(00E) staff and contractors (e.g. Salt Waste Package Workshop in Columbus,, *'
January 1986) indicate that DOE contractors and staff are continuing to debate whether the definition of the engineered barrier system (10 CFR 60.2) should be interpreted to include a portion of the host rock.
Since work is in progress on Site Characterization Plans (SCPs), we consider it 4 appropslate to point out that our interpretation of the engineered barrier system boundary remains unchanged from that provided in our responses to public.
comments on the proposed Rule. That Is, the engineered barrier system does not '
include a portion of the host rock.
Specifically, in commenting on the propo' sed rule, 10 CFR Part 6'0, the DOE stated:
If the intended concept is "engineered. barrier system", that term should be used with a clarification in the concept section. However, note that i the control of release requirement which is placed on the engineered l i
system would, in fact, become a requirement on the waste package.,.00E would recommend that some acknowledgement be made of the isolation, capabilities of the host rock. The extent of the rock, or rocks, which will be included in the engineered system will be proposed in the license 1 application related to a specific site. i In response, the NRC staff stated:
The commenter's recommendation that a portion of the host rock be included in the definition of the engineered barrier system has not been adopted.
The engineered barrier system is intended to include only man-made components, which is consistent with the provisions of the Nuclear Waste Policy Act of 1982 (Pub. L.97-425). The provisions of 10 CFR 60.113(b),
however, allow consideration by the Commission of the characteristics of the host rock in approving cent.sinment times for the waste package and release rates from the engineered barrier system. Tne staff considers plWbWE l
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that this provision accommodates DOE's underl (Staff Analysis of Public Comments on Proposed 10 CFR Rule'ying concern.
Part 60, "Disposal of High-cevel Radioactive Wastes in Geologic Repositories," NUREG.0804, 1983, pp 181-182).
l It is still our belief that strict separation of engineering and geologic features is in keeping with the multiple barrier concept incorporated into the Nuclear Waste Policy Act and 10 CFR Part 60. Continuing discussion and debate about the definition of the engineered barrier system imply that additional -
clarification may be necessary to resolve a potential problem well before fonnal review of Site Characterization Plans. We will be happy to meet with you to discuss the issue should you have any questions.
Sincerely, l
M @ !' $*t*.ed 3v: !
John J. Linehan, Acting Chief Repository Projects Branch ;
Division of Waste Management -l Office of Nuclear Material Safety and Safeguards 1
- See previous concurrence
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