ML20151Y344
| ML20151Y344 | |
| Person / Time | |
|---|---|
| Issue date: | 04/28/1988 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1663, NUDOCS 8805040428 | |
| Download: ML20151Y344 (169) | |
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O UNITED STATES NUCLEAR REGULATORY COMMISSION
.__________________________________________________________c In the Matter of:
WASTE MANAGEMENT O
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Pages:
1 through 122
,Il. (^ ' m Place:
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.,,.,---y Date:
April 28, 1988 l
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7-1 PUBLIC NOTICE BY THE k_)j
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2-UNITED STATES NUCLEAR REGULATORY COMMISSION'S
'n 3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5-6 7
The contents of this stenographic transcript of the 8
proceedings of th'e United States Nuclear Regulatory 9'
Commission's Advisory Committee on Reactor Safeguards (ACRS),
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
i 12 No member of the ACRS Staff and no participant at 13 this meeting accepts any responsibility for errors or
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inaccuracies of statement or data contained in this transcript.
14 15 16 4
17 18 19 20 21 22 23 24 25
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 3
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4 In the-Matter of:
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SUBCOMMITTEE ON WASTE
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6 MANAGEMENT
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- Thursday, 8
April 28, 1988
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Room 1046 1717 H Street, N.W.
10 Washington, D.C.
20555 11 The above-entitled matter came on for hearing, 12 pursuant to notice, at 8:30 a.m.
s 13 BEFORE:
DR. DADE W.
MOELLER Professor of Engineering in Environmental 14 Health and Associate Dean for Continuing Education, School of Public 15 Health, Harvard University, Boston, Massachusetts 16 ACRS MEMBERS PRES E!!T:
17 DR. MARTIN J.
STEINDLER 18 Director, Chemical Technology Division Argonne National Laboratory 19 Argonne, Illinois 20 DR. PAUL G.
SHEWMON Professor, Metallurgical Engineering Department 21 Ohio State University.
i Columbus, Ohio 22 ACRS COGNIZANT STAFF MEMBER:
l 23 Owen S.
Merrill 24 r
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2 CHA7"MAN MOELLER:
The meeting will now come to 3
order.
4 This is a meeting of the ACRS Subcommittee on Waste 5
Management.
- I am Dave Moeller, the-Subcommittee Chairman.
6 The other ACRS members in attendance, at the moment there is 7
only one, Paul Shewmon.
We anticipate shortly that Dr. Martin 8
Steindler will be joining us. -We have with us or we 9
anticipate again having with us one of our consultants, Dr.
J.
10 Maxwell, and we have with us Carson Mark as an invited expert.
11 Our objective today is to review and discuss the NRC 12 di' aft comments on the Yucca Mountain consultation draft site
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13 characterization plan, the so-called CDSCP.
Although we 14 cannot be expected to review the plan in detail, certainly not 15 at this meeting, and I doubt if very many of us could ever 16 hope to read every page of the report, my hope is that today
'17 we can cover the highlights particularly of the NRC's comments 18 on the draft, and by the end of the day, have reached 19 consensus on the identification of any major items that the 20 NRC staff may have failed to identify, any major problem 21 areas.
22 In this regard, and without the Subcommittee having l
23 met and without me having had an opportunity to even discuss r
l 24 some personal observations with other members of the
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1 25 Subcommittee, I would like to offer several.
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The NRC staff has raised its five or it has listed I
2 its criticisms in various categories, and'they have listed s
3
-five of what they call to be their objections.
Now these are 4
the most important or the more important comments that they 5
have based upon their review of the document, and I personally 6
think the five objections are fairly well stated.
7 In looking them over, though, and in looking at 8
their other comments and whatever the third category is, I 9
found that several items came to my attention that might have 10 been worthy of raising to the level of objections or meaning 11 they are rather important things, and not only in reading 12 their comments did I come up with some ideas, but I also found 13 that in reading the site characterization plan itself, I had a
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14 few items that I might have suggested be listed as objections.
15 For. example, in the comments of the NRC staff, they 16 state that the positions or approaches taken by DOE on that 17 particular matter do not comply either with the standards for 18 a high-level waste repository as promulgated by the EPA, or f
19 with the regulations specified by the NRC.
20 Well, I would think any item within the repository
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21 that didn't comply with the standards of the regulations would 22 be a fairly important point.
Now maybe these are not j
t 23 important in that the staff felt that down the road they could t
24 easily be resolved, and if that's true, then I think that's 1
25 what we need to hear.
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A second item that was of interest to me was the 4
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2 shole matter of radon, and the staff.has, well, more 3
particularly let me say the DOE site characterization plan 4
says that we realize there is a potentia'. lor radon down under 5
the ground, and they point out that they will assure us that, 6
NRC and the world, that none of the workers will be exposed to 7
any, they used particular words like significant hazard due to 8
natural radiation sources, and then they go even further which 9
I think is nice, they go further and say that they will assure 10 that none of the workers are exposed to excencive levels of 11 radon, and they will also assure us that the ruck as they call 12 it--I would say the tailings--whatever it is they dig out of i
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13 the ground and pile up on the surface, they assure us that the t
14 racon releases from those piles will not unduly exposo any 15 member of the public.
16 And I guess the questions I had there were the 17 following--they say well, we can't answer these things until 18 we have done some emanation tests of the TUFF medium itself, e
19 and I guess that would be a very key issue at soue point is to 20 get those data because we may very well end up with a 21 situation, and I have no knowledge whatsoever on how much 22 radium is in the TUFF material, but we could readily end up 23 with a situation where the major source of exposure from this 24 whole repository is not the spent fuel or the waste, but is
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25 the radon to the workers down there and the emanations from i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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the pilings up on the surface,-and I would like to hear from
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2 DOE or the NRC staff today on what.are the applicable 3
regulations for tailings from a non-uranium mine?
Do the 4
uranium mine and milling laws apply here, or are there OSHA 5
' Health'and Safety Acts or Mine Safety and Health Acts that 6
apply and so forth?
7 I found it very intriguing.
It is not a major 8
objection, but if, if tnere is a question about what 9
regulations apply to this situation, then that could be a l
10 major factor in our review of the proposed repository.
6 11 DR. MARK:
Dade, you referred to having, someone 12 having said they would do an emanation test.
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13 CHAIRMAN MOELLER:
Yes.
14 DR. MARK:
Well, they must know what the uranium 15 content of the soil is.
They don't have to wait for that.
16 They had drills down.
17 CHAIRM)N MOELLER:
Yes.
Well, we will get them to i
18 talk on that.
Sure, they ought to know the uranium and then 19
'therefore know the radium content.
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20 DR. MARK:
And know if there is a problem.
f 21 CHAIRMAN MOELLER:
There may be no problem at all.
22 That whole section of the SCP needn't even be there.
Surely 23 s:meone could juct do a surface emanation rate, you know, and 24 get seme 6stimation of what is down there.
25 Okay.
A third point, not neceocarily a, something
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1' that' should be an objection, it certainly'would not be, is
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.that the staff-has said that some porticas of the_SCP have not l
3 been reviewed in detail, and I would hope today that we can' l
4 find out what those are, and even indeed how the staff decided.
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5 what portions to review first and what portions perhaps to 1
6 review later.
7 I hope, too, today that we can have time to quiz the
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' NIO: and the DOE, and Ralph Stein from DOE is here and he will 9
be here until noon, and he has offered to help us in any way 10 he can, and we appreciate that, so if we have questions and'if 11 any member of the NRC staff in making a presentation or anyone 12 else making a presentation this morning believes that Ralph
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i 13 Stein can contribute then let's call on him, or Ralph, if you 14 see a point where you can help clarify a matter, just raisa i
15 your hand or interrupt and we will welcome your comments.
i-16 MR. STEIN:
Thank you.
t 17 CHAIRMAN MOELLER:
One of the objectives today l
18 certainly will be to identify or clarify for ourselves any i
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19 areas where DOE and the NRC are at odds on some major point; l
20 then not only to identify those areas, but to find out from l
l 21 the two groups whether this particular point as they see it l
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~22 can be brought to closure at some future time, f
I 23 Even if it is a major point, but they both believe V
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24 with a little more work it can be brought to closure, then the
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25 significance of it somcwhat decreases.
If it is a major point i
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_1 that neither one'of them see any way of resolving it, then we 20 {^g<
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-need to know about it.
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'3 Our cognizant ACRS staff member,-ACRS staff member l
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4 for today's meeting is Owen Merrill seated on my right.
The 5
rules for participation in today's meeting have been announced 5
as part of the notice that was published in the. Federal
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7 Register on April 22, 1988.
The meeting is being conducted in 8
accordance with the provisions of the Federal Advisory 9
Committee Act and the government in the Sunshine Act.
10' We have received no written or oral comments from l
11 members of the public.
To assure that we have a proper record 12 of the meeting, it is requested that each speaker first
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13 identify himself or herself and speak with sufficient clarity 14 and volume--in fact, go to a microphone--so that we can hear
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15 what is being said.
i 16 Before we call on the first formai presentation, let 17 me ask Paul, do you have any comments at this point?
18 DR. SHEWMON:
No.
i 19 CHAIRMiN HOELLER:
Carson?
Do you?
i 20 DR. MARK:
I think not.
l 21 CHAIRMAN HCELLER:
Dr. !!axwell, we welcome you.
Do i
i 22 you have any comments at this point?
23 DR. MAXWF /
No.
L 24 CHAIRMAl-3LLER:
We will move on then, and John l
r 25 Linehan and Joe Youngblood are here to introduce us to this o
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subject, or Bob Browning is here to discuss it.
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2 MR.:YOUNGBLOOD:
John and I were'a contingency in i
3 case Bob couldn't be here.
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4-CHAIRMAN MOELLER:
Bob Browning will introduce the i
5 subject this morning.
6 MR. BROWNING:
In order.to provide a brief 7
perspective of where we are on the overall process thet will 8
ultimately lead to a license application by the Department of 9
Energy for a high-level waste repository, I would like to 10 point out that the focus of your partf?ular session is our l
11 comments on a document called the draft consultative draft l
12 site characterization plan.
This draft is not a document that i
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13 is required either by law or by our regulations for the 14 department to issue to us for comment.
The law and our 15 regulations require a site characterization plan to be A
16 developed which we would then review and comment and DOE would 17 have to take those comments into consideration in conducting f
18 their overall site characterization work.
19 DOE decided on their own initiative to get early l
1 20 involvement on the part of particularly NRC and the states, r
21 and at the time they decided this there were thiee sites--the 22 Hanford site, the kevada site, and the Texas site.
- Congrese, 23 of course, passed an amendment laut year that narrowed the 24 protest down to one site, namely, the Nevada site, and I nust
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25 admit every morning I give a prayer of thanks that we only r
HERITAGE REPORTING CORPORATION -- (202)628-4888
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have one to. deal with ra*cher than three in parallel.because'I 2
think' you can: see fre n the sheer-volume of - one project, I
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namely, the Nevada-project, 4 series of some eight volumes of 4
detailed information lating out what has been done before and I
5 what they are planning to do to understand that site 6
thoroughly enough that every reasonable person would agree 7
that it either is or is not an acceptable site for a 8
high-level waste repository.
9 This is a significant undertaking to first of all I
10 develop, and I think DOE deserves a lot of credit for pulling i
11 all-that stuff together in a form that anybody can even begin 12 to start revicwing in a logical, coherent manner, but it is
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13 eren a greater challenge to take it and in a very short 14 turn-around time provide some focused comments that hopefully 15 will result in a more defensible site characterization f
l 16 program.
That's clearly the intent of our providing comments 17 on the draft.
So the next step is for DOE to take our draft 18 or our final comments--we will be finalizing our comments, I
L19 sending them to DOE.
DOE will take those into consideration r
20 in developing their final site characteri=ation plan or other 21 doeurcents that are related to the ongoing investigations of t
22 the Nevada site, f
23 CHAIRMAN MOELLER:
When you said, Bob, that your 24 comments on the draft were not required, you are required to
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25 comment on the final SCP, is that correct?
HERITAGE REPORTING CORPORATION -- (202)628-4888 j
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L1 MR. BROWNING:
Yes.
In fact, our regulation j
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2 requires the SCP or the site characterization plan, and 3
imbedded in our schedules and DOE's production schedules is a i
4 six-month timeframe for us to review and comment on that 5
document, so what--the end result of the process we are in now _
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is that we have been given an advanced look at what they were 7
planning to do.
We have had some chance to comment on that, l
8 and our comments can be factored into the final plan, so I 9
think from my standpoint, the focus of our ongoing interface 10 with DOE is to take our comments and work closely enough with 11 DOE to make sure that our comments are understood and we are, 12 they are getting resolved one way or the other before the i
13 final SCP comes in, and if it works the way I would hope it 14 would, when the SCP comes out, we will have relatively few 15 comments, if any, and then the thrust of the investigation i
16 will be are they carrying out the plan plus have they L
17 adequately resolved our comments?
18 I haven't been able to put in words to my own i
19 satisfaction yet what the significance of our comments are 20 with regard to all of that.
It looks like there is a i
21 tremendous volume of work there and information, and when you 22 look at our comments, it is a relatively small document.
33 Whether that should imply that that's in general a 24 very good document, and we have relatively few comments, I i
l 25 personally haven't yet been able to put that in a proper L
I HERITAGE REPORTING CORPORATION -- (202)628-4888
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perspective to help focus you on where we think the.overall' O(,j 2-
. program is going.
3 Several of the objections are very fundamental 4
objections.
The quality assurance program is one we have been 5
working.with the Department of Energy for sometime now to try-6 to make sure'that the department and their contractors, some 7
of whom are not used to an NRC licensing kind of process, 8
understand and appreciate and.put into effect a QA program
'9 that not only is good, but the documentation shows it is good.
10 And that's the thrust of that comment, that before they get 11 into a site characterization program, start' spending large 12 amounts of money collecting data, we want to make sure a very 13 good framework is there thuc we are comfortable with, they are
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14 comfortable with if it gets challenged later on in the 15 process, we dealt with that right up front before the program 16 really gets underway to a large extent, so that kind of 17 comment I think has a pervasive effect throughout that whole 18 document, and there may be other, too, that the staff will 19 comment on, giving a more detailed discussion about our 20 comments and the significance of our comments, but I think the 21 point that, for you folks to keep in mind is that this isn't 22 the end of the process, and whether our comment is on the mark 23 or not will probably get worked out by that dialogue that goes 24 on between us and DOE in terms of trying to resolve our 25 comment.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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DOE may very well convince us that our comment isn't
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2 correct, that in the ongoing process that may not be quite the 3
right way to say it, but we may come together.
May go their 4
way.
They may go our way, so this ongoing process of how our i
5 comments get resolved is yet to be. determined.
It won't be 6
determined in this meeting because DOE still is, you know, I
7 attempting ~to see how they would deal with our comments, but 8
the focal point will be it really has to get on a track for 9
resolution so we are.all comfortable, or getting resolved by 10 the time the final site characterization plan comes out.
11 When the final site characterization plan comes out, 12 it is open to comnent by everyone.
DOE is going to have 13 public meetings.
The public will be commenting on it, and
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14 they will probably have 2 million comments to try to deal 15 with.
Hopefully ours will be either out of the way or will be 16 well on their way to getting resolved at that point in time.
p 17 CHAIRMAN MOELLER:
Well, you, through this process, i
l 18 you and DOE have made a matter now of the public, made a 19 matter of a, of the public record your iterative interactions 20 and process with them, and I think that is very helpful.
l 21 MR. BROWNING:
The meetings we have are noticed.
i l
l 22 The public is invited to attend.
The State of Nevada is not l
l 23 only invited, they are invited as a participant.
24 CHAIRMAN MOELLER:
Back on my comment that where the O
1 25 site characterization plan or the approach being taken by DOE HERITAGE REPORTING CORPORATION -- (202)628-4888
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1 violates an NRC regulation, is that a major issue?
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2 MR. BROWNING:
Yes, it would be.
It would be 3
something that would have to be resolved one way or the other; i
4 either conform with the regulation or point.out where our c
5 regulation isn't right.
6 6
CHAIRMAN MOELLER:
But you-did not list that-as a 7
general objection primarily because you thought none of these 8
were so large that they couldn't be resolved?
9 MR. BROWNING:
I think any case where we detected a, 10 a deviation from our regulation, we thought we had identified 11 those.
6 12 CHAIRMAN MOELLER:
Why, you did.
()
13 MR. BROWNING:
If there are any there that you see 14 that we haven't identified, I would like to know about it.
15 CHAIRMAN MOELLER:
You did, but you didn't call it 16 an objection.
You called it a comment or whatever the third 17 category was.
18 MR. YOUNGBLOOD:
Dr. Moeller, we highlighted it, 19 said that it was very significant, but it didn't meet the 20 criteria for an objection, that they couldn't start site 21 studies without resolving that issue.
22 MR. BROWNING:
It is something that could be 23 resolved later in the milestones of DOE's production schedule.
I 24 I think perhaps another perspective would be helpful for you
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f 25 folks in looking at this, these comments, and the ongoing l
HERITAGE REPORTING CORPORATION -- (202)628-4888
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process.
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2 One of the key ateps in terms of the getting a 3
detailed understanding of this particular site appears to be 4
sinking the exploratory shaft.to get down to depth and see 5
what is actually going on at depth as opposed to extensive 6
investigations from the surface prior to that step.
7 DOE's current production schedule as we understand 8
it is that they would like to start constructing the first 9
exploratory shaft in June of next year and therefore, to the 10 degree to which we can stay-off their production schedule, we 11 need to have a process working with them to try to make sure 12 that technical issues that are related to sinking the
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13 exploratory shaft are resolved on a timeframe consistent with 14 that proposed production schedule which leaves us roughly a 15 year to work out some of the questions such as where should 16 the first exploratory shaft be located?
11 We think that's sufficient time to resolve them.
I 18.
think another key perspective to keep in mind is that because 19 of the nature of this particular site, the site f
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20 characterization steps, including sinking exploratory shafts, 21 getting people down to the repository horizon and then 22 projecting horizontal tunnels to investigate the site, is 23 probably going to end up being an integral part of the 24 ultimate repository, and therefore, it demands a lot of, a log 25 of trying to make sure that in the process of investigating i
HERITAGE REPORTING CORPORATION -- (202)628-4888
16 i
1
'the site something isn't done inadvertently that would 2
preclude its being used for repository later on, and some of r
3 the comments that the staff has baca making up to this point 4
in time and some of the comments on this particular document 5
are focused on that particular concern.
6 Another broad concern is that.in the process of 7
sinking shafts and drilling holes, and'looking at the site 8
from the standpoint of multiple different kind of disciplines 9
that are interested in their particular aspect of the site, 10-that one test that you are running doesn't preclude your f
11 ability to get information from another test, and that has 12 been a big problem.
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13 You can imagine with all the disciplines that are 14 required to understand that site, to feed data into the 15 machine that helps design the repository and helps do 16 long-range predictions of how that repository and all the d
17 engineered barriers and the natural barriers are going to 18 perform over 10,000 years into the future is a tremendous i
19 integration job.
The Department of Energy really has a r
20 tremendous job on their hand trying to make sure all of those i
'21 disciplines are integrated and the whole thing is well thought 22 out as you could end up having a situation where everybody 23 goes, investigates the site for their particular purposes, and
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24 it may or may not have any bearing at all in terms of the 25 ultimate need to predict how this site is going to perform.
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We all have a problem in that the technical' l
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2 disciplines that are interested in looking at this site if l
3 left without that kind of integration and what does it really 4
mean in terms of in this site any good for a repository, or 5
how is it going to perform in the long term, that it is 6
focused on those kind of questions, not trying to answer 7
questions everybody has always been interested in for the last f
8 20 years.
Here is an opportunity to study them, and it really l
9 doesn't have any bearing on the purpose of this particular 10 investigation in making a licensing case that this site is a 11 good site and that it is going to perform well over the long 12 term.
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15 We have that problem, and the DOE has that problem 14 in spades, so I think you will keep hearing words like an 15 integrated program.
That's really what we mean, trying to 16 make sure that the disciplines are being--geology, hydrology, 17 geochemistry, that they are all focused on that long-range 18 objective of performing, assessing how well that site is going 19 to perform.
20 CHAIRMAN HOELLER:
Where do you look for that in the 21 site characterization plan?
Where do you look to see that DOE 22 is taking an integrated approach?
23 MR. BROWNING:
I would like to defer that if I can
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24 to the sessions of the detailed staff.
I don't want to take 25 the staff's thunder, but one way and one of our objections was i
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the whole idea of conceptualizing how that site is functioning
'2 now and how it is going to function into the future given-3 various scenarios that you could postulate, and I think that 4
the terminology alternative conceptual models is used.
That's 5
one way of doing it.
6' The other way is to keep focused on what it takes to 7
make a performance assessment, to say you are going to meet 8
the EPA standard over the long-term once the site is closed 9
down and the natural barriers and the engineered barriers are 10 just left to function without intervention by man.
11 It is a first of a kind undertaking.
We don't 12 necessarily have all the answers now.
That's why, where it is
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13 kind of an iterative process that has been set up, and in all 14 humbleness, I would like to say we may very well have to 15 change some of our regulation requirements to fit the r
16 particular situation.
We may not have been smart enough when 17 we developed the regulations several years ego to make sure 18 that we are right on the mark, so it is an iterative process i
19 that we are undergoing right now.
20-CHAIRMAN HOELLER:
Paul Shewmon has a question.
21 DR. SHEWHON:
Two questions--one, in trying to get a 22 grasp on all of this stuff, the idea of performance allocation j
23 sounds attractive.
24 Though it is referenced in here, could you tell me
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25 where in there I could read a summary of how they plan to use i
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performance allocation or what, how they distribute this
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2 amongst the different components?
Or is it like the French 3
gentleman that spoke prose all his life?
It is all 4
performance allocation or something.
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5 HR. GALSON:
Dan Galson, High-Level Waste Division, 6
Operations Branch--if you are looking for a general 7
introduction in the, as to how it has'been used in the 8
CDSCP--is that your question?
I 9
DR. SHEWHON:
I think so, yes.
10-MR. GALSON:
You will find that in the beginning of 11 Chapter 8, Chapter 811 and 812 all are kind of summarizing 12 the, first of all, the general level, what performance 13 allocation is, and then how it has been implemented, how it 14 should be implemented in the CDSCP.
15 DR. SHEWMON:
How it should be, or how it was?
16 There is an awful lot of things that should be done.
This is 17 much less of how it will be done, or indeed what nunbers they 18 put someplace.
19 MR. GALSON:
Are you asking about technical 20 justification for specific numbers and for allocations charts?
21 DR. SHEWMON:
I am asking about have they assigned 22 numbers to performance allocation, meaning the various 23 components?
24 HR. GALSON:
What was the basis for doing that?
Is 25 that your question.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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-20 l'
DR. SHEWMCN:
That is described in Chapter 8 or m
2 Section 8?
3 MR. GALSON:
Yes.
4 DR. SHEWHON:
A different question then--this site 5
characterization, is there a separate package on the waste 6
package, or is it some place in'here, too, that I have missed?
7 MR. BROWNING:
That--one of the staff can tell you 8
the exact place in the document to look, but that is an 0
9 important part.
It is called a site characterization plan, 10 but it is much broader than.just investigating the site for 11 natural features of the site, pulls out all the interrelated 12 investigations such as waste package performance, engineered i
13 design of the repository, because of the whole thing has to s' } -
14 fit together.
15 HR. CHANG:
Chang, Technical Review Branch--the i
16 waste package is described in the Chapter 7.
However, you 17 will find it doesn't give you all the details you require.
18 Rather they defer, you know, all the details in the conceptual 19 design review.
However, I think probably for your purpose, 20 you know, you can get enough information from Chapter 7.
21 DR. SHEWMON:
Fine.
Thank you.
22 MR. BROWNING:
Keep in mind, the other thing to keep 23 in mind is behind these eight volumes, there are a tremendous 24 number of reference documents, and the, in the basement of our 25 building, we have one whole section of the library for all tha HERITAGE REPORTING CORPORATION -- (202)628-4888
'i
21 T'
1 reference documents which feed into this document, the 2
conceptual design.
3 DR. SHEWMON:
Owen, is what is over there the same 4
thing as this foot and a half box I got the other day?
5 MR. MERRILL:
That is correct.
There are two sets 6
there on this table.
7 DR. SHEWMON:
Fine.
8 MR. WELLER:
Let me add one additional thing.
Rick 9
Weller, I am in the Engineering Section.
10 The question you asked about the waste package, the 11 specific discussion of performance allocation for the waste 12 package-is in Section 8-3510.
It is in the document, and it
()
13 is discussed.
14 DR. SHEWMON:
There are some things in Chapter 7 15 apparently, and now you are pointing me to 8-3?
16 MR. WELLER:
The whole discussion of performance 17 assessment is in Chapter 8.
That's where you will find the 18 discussion of performance allocation for the waste package 19 components.
20 DR. SHEWMON:
Okay.
21 MR. BROWNING:
I think you are beginning to see why 22 one of the first work sessions we had with DOE, DOE tried to 23 explain how the site characterization plan is organized and i
24 how.you can use it.
At this point, if I can, I would like to 25 introduce !!r. King Stanlein, who will discuss an aspect that I HERITAGE REPORTING CORPORATION -- (202)628-4888
22 1
think will help answer some of your questions and what the
( ).
2 scope of.this document is and how we' organized our staff to 3
review it with the attempt to try to get both looks, by 4
specific disciplines, and then some kind of an integrated kind 5
of look to make sure one discipline wasn't getting out of i
1 6
control with respect to another discipline.
7 CHAIRMAN MOELLER:
Yes, Carson?
8 DR. MARK:
This doesn't come from what you were just 9
saying, telling us, but a month ago you wrote to Mr. Cale I 10 believe?
11-MR. BROWNING:
Yes, sir.
i 12 DR. MARK:
And I wonder if you could just in a word f
13 or two help me understand what you were saying.
Your most
[
14 fundamental concern it says is failure to recognize the range j
15 of alternative conceptual models of the site.
16 Now the site is the site, and I don't think that 17 getting a model of it is terribly esoterie.
hit may be you l
18 have to work hard to get all the corners filled in.
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i 19 What is the--then you say they have worked with that 20 conceptual model, whatever that is, and they don't think of L
i 21 six others which you wish they would because that would lead 22 to six more volumes.
23 MR. BROWNING:
I don't think we used the number six.
i 24 In fact, we didn't put any quantification on it because that f
1 25 really is the Department of Energy's job.
That will be one of t
I HERITAGE REPORTING CORPORATION -- (202)628-4888
23 t
1 the points that is going to be discussed in detail, but let me
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2 just give you an example which is over--
3 DR. MARK:
What I need is a feeling that I 4'
understand what do you have in mind when you say conceptual t
5 model of the site?
I it a bunch of codes?
6 MR. BROWNING:
No.
7 DR. MARK:
Is it a bunch of layers of properties of
-j 8
the earth?
9 MR. GALSON:
Can I--
10
-HR.
BROWNING:
No.
You will have your chance.
This 11 particular aspect of our comments will be discussed by'the 12 staff.
If I could defer it until then, I would like to do it 13 because if in fact you are not satisfied at that point, I 14 would be glad to get up and try to explain it in further 15 detail, but one of the things we wanted to do was to make sure f
16 that the detailed technical staff that came up with these 17 comments that got focused in my letter, had a chance to talk t
18 with you folks directly so you can get below that general kind 19 of comment and get the thrust of exactly what you are focusing 2
20 in on right now, and I would like to give them a chance to, to j
I 21 do their particular presentation, and then I will be glad to 22 stay until the end.
If you are not satisfied at that point, I 23 would be glad to try to explain it further.
And if in fact it i
24 needs clarification, that is something we can clarify in our
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25 final letter to them because keep in mind that letter was
?
HERITAGE REPORTING CORPORATION -- (202)628-4888 j
-24 I
1 forwarding a here is our draft comments.
We need to have a
-()
2 dialogue to make sure we got a common understanding of what we 3
are talking about because that's very fundamental.
If we are 4
-off base, we need to get that feedback from DOE, and that's 5
part of.this ongoing iterative process I am talking about.
6 Is that acceptable to you?
f 7
DR. MARK:
Absolutely.
8 CHAIRMAN MOELLER:
Thank you, Carson, for raising 9
that question because in essence that and QA are their two f
10 fundamental, the two fundamental questions the staff has 11 raised, so we all need to understand it.
I did not from 12 reading what you were quoting.
13 MR. STABLEIN:
Good morning.
Since I don't--my name
(}
14 is King Stablein with the NRC, and since I don't have 15 vugraphs, would you prefer me to sit at the table or do you 16 want me up at the podium?
17 CHAIRMAN MOELLER:
You are heard better from the I
i 18 podium, please.
19 MR. STABLEIN:
I guess this is set automatically, so i
20 that you can hear me well?
l 21 CHAIRMAN MOELLER:
Yes.
22 MR. STABLEIN:
Good morning again.
My name is King i
23 Stablein.
I am the project manager for the Yucca Mountain 24 site, and I coordinated the review of the CDSCP and will
(
I 25 present to you an overview of how we went about this today I
t t
HERITAGE REPORTING CORPORATION -- (202)628-4888
125 1
-before we get to the technical experts that can answer some of
).
2 the questions that you have already been raising, in 3
particular QA and performance assessment alternative 4
conceptual models and the like will be dealt with very early 4
5 on.
6 CHAIRMAN MOELLER:
Did you also play a major role in 7
that you know, your, the development of-your review plan 8
itself, how you were to approach it?
i 9
MR. STABLEIN:
I did, yes.
Many of us did.
It 10 wasn't just me, but I was involved in it.
And in fact, I have-11 brought a copy of that in case we needed to refer to it today.
12 Does everybody have a set of my handouts because I
(
13 am going to be speaking from these?
14 I would like to start out by just giving you the 15 time line of our review.
We received the CDSCP January 8th.
16 We commenced our review shortly thereafter, issued the draft 17 point papers on March 7th to the DOE and to the State of 18 Nevada.
We had workshops on the draft point papers and on 19 alternative conceptual models in late March and in mid-April.
20 On April 22nd, which is just a week ago, we internally reached 21 final agreement on the point papers, final point papers.
22 CHAIRMAN MOELLER:
You mean within the NRC?
23 MR. STABLEIN:
Within the NRC staff; we went back 24 and looked at them to see if they needed any revisions in 25 light of the workshops and further review of the CDSCP.
We HERITAGE REPORTING CORPORATION -- (202)628-4888
i' 26 1
are here today to brief you all on the 28th.
Next week will 2
be a' Commission briefing on the final point papers, and after
[
3 that, hopefully in May, we will issue-the final point papers 4
to the DOE and to the State of Nevada.
f e
5-CHAIRMAN MOELLER:
Where does the word point papers, i
6:
or those words, where do they come from?
l f
7 MR. STABLEIN:
They are defined in the review plan.
8 They came from an idea we had to try to get these out to DOE 9
sooner, and to minimize the word engineering and to maximize f
i 10 the effort on substantive technical review of the document, so i
8-11 they are not written with full text the way our earlier 12 comments on the draft did and the final EA were written.
They
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13 were an attempt to flush out bullets going with the concern 1
s 14 stated up front in a sentence or two, the basis for it, and J
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15 then a recommendation, and the term point paper was as close j
i 16 as we could come to trying to capture that particular means of 17 communicating the concern clearly and crisply to the DOE.
I 18 It was a departure for us from earlier efforts, and i
19 we have gotten some good responses to that approach.
You all 4
20 have had a chance to look at these and you may have some views i
21 on how effective that approach is, but that's where the term i
4 22 came from.
l i
t 23 The purpose of the NRC staff CDSCP review was to j
f
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identify concerns with the site characterization program as 24 j
25 DOE presented it in the CDSCP for consideration by them as j
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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l' they prepare their statutory SCP.
()
2 So that's why we made this effort'to-review that 3
document.
The scope of the review--just a glance at the 4
document indicates that you cannot read every word in detail 5
and analyze it and put out comments on it.
Of necessity, l
l 6
given the constraints of time and resources and the desire to l
7 get timely remarks back to the DOE, we had to do a limited 8
review, limited in the sense that we didn't review every word i
9 in great depth and all the references in great depth.
i 10 We consider it to be a review that focused on the l'
11 logic and structure of the program that was presented in the 12 CDSCP, okay.
We weren't looking for nitpicks.
We weren't
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13 looking for every fine point.
We wanted to analyze the 14 overall program as it was preset ted, how it fit together.
Was 15 it constructed logically?
So we didn't review the entire 1
4 L
i 16 CDSCP in detail.
r 17 DR. MARK:
When the statutory SCP appears, will the
[
18 Waste Policy Act or waste whatever it is Act not require that i
19 you review every word of the final SCP and it won't be any i
20 shorter than this I'm sure?
[
i i
21 MR. STABLEIN:
No, it probably won't be any shorter, 22 and the NWPA as I recall it doesn't say read every word, but
[
i 23 it does require, of course, a thorough review, and we will l
i 24 give it a thorough review with more time allotted to it than 25 to the CDSCP.
I don't know if Bob or Joe want to--
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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t 1L DR.-HARK:
The time is six months I believe.
l
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2 HR..STABLEIN:
.Yes, six months to produce it.
[
t 3
MR. BROWNING:
The analysis.
4 4
CHAIRMAN HOELLER:
Well, could you, though, give us l
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5 an. idea, a little better idea?
You say you didn't review it j
t 6-all in detail and we can-understand, you know, the necessity.
7 of rapid turnaround and so forth, but did you, were there
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8 complete subsections that you just totally didn't look at?-
i 9
MR. STABLEIN:
Every portion of the CDSCP received I
10 some attention.
I 11 CHAIRMAN HOELLER:
Okay.
12 MR. STABLEIN:
And every portion was assigned as a i
i i
( )-
13 responsibility of some technical discipline.
We have seven 14 disciplines represented on the team, and you will hear from i
15
.all of them today.
Should you be interested in particular t
i 16 areas in their discipline, did you look in detail at such and l
17 so, they could answer for you what they were able to do and
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18 why they chose to emphasize a particular portion.
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19 CHAIRMAN MOELLER:
And certainly they scanned every
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f 20 page to look for some key, important issue?
f 21 MR. STABLEIN:
We tried to characterize our review l
t 22 of the document as complete in the broad sense and then in j
i 23 more depth in certain selected areas.
l 24 CHAIRMAN MOELLER:
Okay.
I think I understand what
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25 you did.
I HERITAGE REPORTING CORPORATION -- (202)628-4888
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MR. STABLEIN:
It is difficult to capture that.
()
2 When you say a lot of limited review, it makes some people i
3 worried that a thorough review wasn't done to, to analyze the
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4 main points and to pick up the main criticism that we might 5
have had, and that's not what we did and not'the intent, but
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6 it is just to not claim at this point that we have identified
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7 every single thing in that document that we might find a j
8 problem with.
I am going to come back to this a little bit l
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9 when I talk about objections, comments and questions, and I am i
10 going to attempt to deal with the question you have asked l
l 11 about this, too.
12 CHAIRMAN MOELLER:
Fine.
i 13 MR. STABLEIN:
In fact, on the same slide, I make 14 the point which we have emphasized to DOE in the workshops 15 that the concerns we have raised should be considered as t
16 potentially applicable to other portions of the CDSCP, That
[
i i
17 is, they, DOE, as they read our concerns, should be looking f
j 18 for that same sort of concern with other portions of the 19 CDSCP.
20 In all the concerns we have produced of whatever l
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22 DOE's attention, even though we do have three levels, and I l
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23 will go into those shortly, There is nothing there that is of 24 very limited narrow and relatively unimportant value, and l
25 hence we think that these concerns can give DOE guidance as i
f i-HERITAGE REPORTING CORPORATION -- (202)628-4888 j
?$T 30 1
they revise the entire document.
That was a deliberate part 2
of'our strategy.
i
'3 The foundation of the NRC staff review was_the 4
review plan that Robert Johnson and I came down here and
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5 briefed-you on several months ago.
We have'a draft technical l
6 review plan'for review, for staff review of DOE's site 7
characterization plans, and that was based on agreements from 8
meetings we have had with DOE over the past three years, f
9 meetings on performance allocation, issues hierarchy, issue 10 resolution strategy, level of detail in the SCP.
11 That technical review plan is also based on NRC reg 12 Guide 417, our standard format and content of site
()
13 characterization plans for high-level waste repositories as 14 revised, and on DOE's annotated outline for site 15 characterization plan, which was concurred in by the NRC.
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16 We also had, a second part of our review plan-was l
l 17 the administrative plan and procedures for our review, 18 specifically of the CDSCP, and that will be different for I
19 review of the SCP in some respect.
Since it will be the i
20 statutory SCP, we will be producing a site characterization l
21 analysis which will be a different document and will be 22 described in the administrative plan and procedures for the 1
23 SCP.
4 24 I would like to move on to the results of our i
25 review.
On March 7th of this year, we sent the draft point 4
4 HERITAG2 REPORTING CORPORATION -- (202)628-48S8
r 31 1
papers to the DOE with tha letter from Mr. Browning in which
()
2 we identified the 161 staff concerns, and the letter 3
highlighted two points cbout the concerns--that these concerns 4
need to be resolved on a timely basis analysis.
By that we 5
mean preferably prior to start of new site characterization.
6 activities, and secondly, that these concerns should be 7
considered in development of the statutory SCP.
8 We have continued to review the CDSCP since that 9
date, and we have not produced additional major concerns for 10 the final point papers.
There has been some modification of_a 11 relatively minor nature, but no new burning issues that we 12 would need to bring, for example, to your attention at tnis 13 time.
14 CHAIRMAN MOELLER:
Well, now among the objections, 15 comments and questions, were you able or did you as a practice 16 include all that the different reviewers brought up, or were 17 there an equal number that you through mutual discussion cast 18 aside and decided not to include?
19 MR. STABLEIN:
We have maintained an internal QA 20 record of the process from the first draft that the team 21 members submitted to what you received and what the DOE 22 received, and some comments, some of the concerns were 23 deferred until later as not being appropriate, for example, to 24 the SCP.
25 I think probably the most prevalent sort of concern HERITAGE REPORTING CORPORATION -- (202)628-4888
32 1
would be'something on a study that is mentioned in the SCP i
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2
. which according to our agreement with DOE on level of detail, s
3 should not be fully described there, but should be described f
4 in the study plans which are yet.to come, and'although the
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concern is perhaps valid, we need to wait until we receive the f
6 study plan that should deal with that concern before we render 7
a comment upon it, and those we did defer.
We haven't thrown i
8 them away, but they are held in abeyance.
f 9
_ CHAIRMAN MOELLER:
But in general, the bulk of the 10 comments, questions, concerns, of the staff, they were I
t 11 included?
In other words, a person didn't have, a staff l
12 member didn't have to wage a major battle to get their h
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13 particular item in the list?
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r 14 MR. STABLEIN:
He didn't or she didn't have to wage l
15 a major battle.
There was intensive internal discussion.
16 CHAIRMAN MOELLER:
And there should be.
l 17 MR. STABLEIN:
e,out these to make sure that the l
18 concern raised met the definition of objection, comment or l
i 19 question.
I l
20 CHAIRMAN MOELLER:
Was legitimate and could be i
21 backed up.
22 MR. STABLEIN:
Because we wanted this particular set f
l l
23 of concerns to be worthy of DOE's attention; we didn't want i
24 things that anyone could point to and say why in the world did
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25 they make that comment?
I mean that just wastes everybody's l
I HERITAGE REPORTING CORPORATION -- (202)623-4888
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33 l
1 time and clutters the record.
These things we wanted to be 2
substantive and relevant to the CDSCP.
3 CHAIRMAN HOELLER:
Were there, and I'm probing i
I 4
mainly to get a better handle on things, but were there some 5
items that'were objections which later then slipped and became l
6 a comment or a question and vice-versa?
Well, surely I guess 7
everybody started out just as a concern and then you 8
categorized them, but what were some key items that some 9
people thought should have been objections and you later f
10 lowered their rank so to speak?
4 r
11 HR. STABLEIN:
Joe Youngblood is pointing out you 4
4 12 happened upon the category that was proposed as objections.
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13 There were three comments which are highlighted in the 1
14 introduction to the package which were proposed as objections.
15 The ones concerning regulatory inconsistencies--
L I
16 CHAIRMAN MOELLER:
Oh, okay.
t 17 MR. STABLEIN:
They were proposed as objections.
i 18 There was intense icternal discussion about those, and as I
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d 19 address the definition of these three categories, I will j
i 20 devote some attenti3n to why those eventually became comments, 21 and they are very serious, and the fact that they were f
I 22 relegated to comments is no reflection on their level of 23 seriousness.
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24 The definition of objection was very specific, as
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25 specific as you can be.
I mean we are still dealing with l
1 HERITAGE REPORTING CORPORATION -- (202)628-4888
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34 l
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1 3
meant to downplay those three, but those were three of the 7
4 ones that were proposed as objections and became comments in 5
ths package.
l 6
CHAIRMAN MOELLER:
And then it seemed to me, and I 7
need to hear more, but that if, and I am using it as an I
i 8
example, if the radon issue has no applicable regulatory 9
statute, then to me that could be a quite important issue.
?
i MR. STABLEIN:
I have talked to the lawyers about 10 4
P 11 this, and can give you some preliminary feedback.
I think i
f 12 also that DOE might likely have some very useful comment on 1
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13 this point.
They probably have thought about it more at this 14 stage than we have.
l 4
l 15 CHAIRMAN MOELLER:
Sure.
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16 HR. STABLEIN:
But I did approach the, our lawyers i
17 about this to get a preliminary reading and not anything final j
18 at this stage, but according to them, the NRC will not have i
19 jurisdiction in this. matter during site characterization or f
20 during construction.
Until DOE becomes a licensee, their i
i 21 interpretation of the regulations as they understand them is i
l 22 that we won't have jurisdiction.
Once they become a licensee, j
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23 once it is in the operational phase, then our charge is to be
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I 24 ca'ceful to ensure that the workers do not receive, you know, 25 large doses of radiation from any source during their, in f
I 4
HERITAGE REPORTING CORPORATION -- (202)628-4888 i
i
- c 35 1
their working environment.
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2 CHAIRMAN MOELLER:
And where do you, how do you come 3
to that?
What regulation applies to that?
4 MR. STABLEIN:
The' lawyer was' referring me to Part 5
20, 10 CFR Part 20, and--
-6 CHAIRMAN MOELLER:
Part 20 I. thought, and let me 7
just contment and then we can go on, but I haven't' read it in 8
sometime, but as I recall, it says these limits, the 1
9.
occupational limits, apply exclusive of the purposeful 10 application of radiation in the heliards and natural sources, 11
' natural background.
Maybe it doesn't say natural technically 12 enhanced sources, but it certainly says natural background is,
()
13 does not apply or is not to be included in these dose limits.
14 MR. STABLEIN:
The lawyer was aware of that.
Now 15 I'm sure you realize I'm not an expert on Part 20 of the--
16 CHAIRMAN MOELLER:
Neither am I.
17 MR. STABLEIN:
But in an attempt to get some, some 18 material on this, I talked to Mr. Wolfe, and he was aware of 19 the fineness of the points with regard to this.
It is not a 20 straightforward question.
And what you raise is pertinent, 21-but in the way he read it, and he went back and looked at it 22 and talked to his fellow lawyers, it appeared that we would 23 have an interest in the doses received by the workers once DOE
/N 24 was a licensee.
b.
25 CHAIRMAN MOELLER:
All right.
HERITAGE REPORTING CORPORATION -- (202)628-4888
36 1
MR..STABLEIN:
I think perhaps DOE has thought about r( )j.
2 this and would be able to comment upon it.
I don't know.
h 3
CHAIRMAN MOELLER:
Well, it probably is not an issue 4
since DOE clearly states that they-are going to control the 5
doses regardless of where they come from, but I have found it 6
just an intriguing point.
7 Well, go ahead.
8 MR. STABLEIN:
Okay.
As we have mentioned here 9
already, there are three levels of concerns chat we presented 10 in our draft point papers--objections, comments, and 11 questions, and objections were defined as concerns of such 12 immediate seriousness that the NRC would recommend DOE not 13 start work on that particular part of the program prior to
{
14 resolution, so you can see, it is important, of such immediate 15 seriousness that you can't allow work to start, and this is 16 the distinction which caused us to set the three regulatory 17-inconsistencies aside as objections while highlighting them as 18 major comments in the introduction, and I admit there was l
l 19 considerable discussion about this, but we attempted to adhere 20 to this definition so that DOE would get a clear message from l
l 21 us about these as objections, and that's why we did that.
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22 Our criteria for objections, if an activity would i
23 cause potential adverse effects on repository performance, if l
l 24 they threatened to compromise the isolation capability of the 1
25 site, this is grounds for an objection.
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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37 1
If'the activities would have significant and w_)
2 irreversible effects on characterization, that.would 3
physically preclude obtaining some information that is going 4
to be necessary for licensing, this is of immedia'te 5
seriousness and they should not start that activity until it 6
is cleared up.
7 And finally, fundamental inadequacies in the QA 8
programs, because it could happen that tne data that you 9
collect would not be usable for licensing if these 10 inadequacies were allowed to remain, so those were our 11 criteria.
12 Comments, concerns that would result in a
()
13 r'cnificant adverse effect on licensing if not resolved, but I
14 m,.ch would not cause irreparable damage if site 15 characterization did start before resclution.
16 And finally the third category, questions, are 17 concerns with presentation of an important part of the program 18 in the CDSCP which precludes understanding well enough to be 19 able to evaluate that part, and this is important.
If there i
20 was missing information that should be in the SCP or 21 inconsistencies or ambiguities which actually kept us from l
i 22 being able to comment on some potentially very important part i
j 23 of that document, we wanted to highlight those because the i
24 answer to those questions could lead us to comments or 1
l 25 objections down the road, so the questions, although the third l
l I
l HERITAGE REPORTING CORPORATION -- (202)628-4888
38 1
category we have-emphasized ~, are also extremely important.
- (~)/.
'2-The next page gives you a summary of the five s-3
-objections, and I have put this here for your convenience, but 4
I' don't propose to discuss these because I would be stealing 5
the thunder of the people who are coming after me.
6 We have one objection.
Objection one is on the 7
alternative conceptual models, so very shortly we will be 8
hearing, you know, a thorough discussion of that.
9 Objections 2, 3 and t center around the shaft, the 10 exploratory shaft, and objection 5 is the QA objection, so 11 when those disciplines come up, and those will be the first 12 three, we will get into an interesting and detailed discussion
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13 of those objections, so I also would prepose deferring those, V
14 but you are getting close to when you will get to hear about 15 those.
16 CHAIRMAN MOELLER:
Fine.
17 MR. STABLEIN:
Now after we sent out the point paper 18 or during this process of reviewing the CDSCP, we have had a 19 number of interactions with the DOE.
After they issued the 20 CDSCP, they had a plenary session where they sat down with the 21 state and with the NRC to explain portions of the CDSCP, how 22 the document fit together, how it was constructed, in an 23 effort to aid timely review of the document, and that was 24 J a n u a r y 2 8 t h a n d 2 S".. h o f t h i s y e a r.
25 In March 21st to 24th, the NRC hosted a CDSCP point HERITAGE REPORTING CORPORATION -- (202)628-4888
i 39' s
1 papers workshop here in Washington, D.C.,
and I am going to f s-
. - (_) _
2 talk about that workshop in the next, next page.
An 3
alternative conceptual models workshop took place earlier this 4
month, and there is a workshop scheduled for DOE response to 5
NRC CDSCP final point papers in the June-July timeframe.
6 The draft point papers workshop was aimed at 7
reaching a common understanding with DOE of the NRC 8
objections, comments, and questions.
Among the results of 9
that workshop were the DOE indicated they did understand our 10 concerns and would respond to them in the SCP.
11 Furthermore, there were commitments by DOE relative 12 to the QA objection.
I will briefly mention them here, and f{ )
' 13 Jim Kennedy may amplify upon these when he talks about QA, but 14 DOE agreed not to start new wottk until NRC has reviewed the QA 15 plan for that program area, and observed its implementation 16 through audits.
17 The Nevada project office QA plan is to be submitted 18 for NRC review very shortly.
At the time it was within two to 19 three weeks, and I understand that that is likely to be in our 20 hands within the next week or so, and DOE will meet with NRC 21 in May to resolve open items of the last few years and to 22 provide schedule for the submittal of DOE contractor QA plans, 23 the plans from Los Alamos and Lawrence Livermore and so forth.
24 An additional result of this workshop was the O.
25 identification of topics where further interactions between HERITAGE REPORTING CORPORATION -- (202)628-4888
a' 40 1
.NRC and DOE technical staffs appear necessary~, and to answer.
}
2 one of y'~r questions, Dr. Moeller, part of the point of these 3
interactions is part of the process toward resolution of these 4
concerns, and I am going to address that as my final page here 5-shortly.
6 CHAIRMAN MOELLER:
Have there been subsequent 7
meetings with Los Alamos if you know?
We heard two or three 8
months ago from the staff the results of the first preliminary 9
audit at Los Alamos.
Have there been follow-up workshops to 10 resolve the questions that were raised?
11 MR. STABLEIN:
I think Jim is going to cover that in 12 his presentation which comes right after mine.
()
13 CHAIRMAN MOELLER:
We will wait.
14 MR. STABLEIN:
So I think if you can wait just a 15 couple of minutes, I will let him handle that rather than 16 going into it now.
17 Now the alternative conceptual models workshop, 18 April lith to the 14th, was prompted by our objection 1 and i
19 our letter highlighting the alternative conceptual models l-l 20 objection.
We pointed out the necessity of considering the 21 range of conceptual models currently supportable by the 22 limited existing data base as they develop their testing 23 program, and the purpose of the workshop was to assemble 24 investigators who have different conceptual models of the site
(}
25 to discuss those differences and what those differences mean i
HERITAGE REPORTING CORPORATION -- (202)628-4888
+
41 1
in terms of' designing a testing program.
(,)-
2 The workshop did bring these people together.
DOE 3
agreed to consider information presented and the staff 4.
recommendation for dealing with alternative conceptual models 5
and hypotheses as they developed the SCP.
The State of Nevada 6
fully participated in this particular workshop, and Jerry 7
Szymanski of the DOE Nevada project office in particular 8
presented his conceptual model which is a different concept of 9
the site than the model which is put forward by the DOE in the 10 CDSCP, different in some respects, and when we get to the 11 performance assessment area, Dan Galson John Trapp can address 12 this topic in much more detail.
13 CHAIRMAN MOELLER:
Carson, do you want to, or should
{^s} -
~
14 we hold off?
15 MR. STABLEIN:
If you can hold off, I think it will 16 flow smoother if Dan and John pick this up together, and give 17 you an in-depth treatment of that area.
18 DR. MOELLER:
I was looking for it here.
In the NRC 19 weekly report for the week ending April the 1st, it told about 20 the National Academy of Sciences meeting.
Now how does 21 that--did you have a person over there?
22 MR. STABLEIN:
We had several people, including 23 myself, in attendance when DOE presented its model, and then 24 Mr. Szymanski presented his, and there was considerable 25 discussion at that meeting on his model.
HERITAGE REPORTING CORFORATION -- (202)628-4888
[..
42 1
CHAIRMAN MOELLER:
Fine..Okay.
I'm happy.
Paul?
k.
2 DR. SHEWMON:
Back on objections, ESF 1 to 400-3 meters I could imagine is experimental shaft one, is that--
4 MR. STABLEIN:
Exploratory shaft one, right; that is 5
going to be the test shaft.
6 DR. SHEWMON:
What is an ESF?
7 MR. STABLEIN:
Exploratory shaft facility.
8 MR. YOUNGBLOOD:
Engineered safety features as you 9
are perfectly used to.
10 DR. SHEWHON:
That is what I was trying to make it, 11 too.
Okay.
Thank you.
12 MR. STABLEIN:
I was cautioned not to use the ESF
()
13 too often for just that reason, and I'm sorry.
I probably
%)
14 have used it throughout at least in my handout here, so 15 exploratory shaft facility is how that is used in my 16 presentation.
17 My last page offers a little information on 18 resolution of the NRC concerns.
This, of course, is the 19 bottom line.
We feel that all of these need to be addressed 20 in a timely manner, and this is, shows you the steps that 21 could be involved.
l 22 The workshop on DOE response to NRC CDS final point 23 papers June or July will provide DOE with the opportunity to
(~}
24 show us how they would propose to address these, and probably
%)
25 many of the items can be addressed by changes to the CDSCP as l
HERITAGE REPORTING CORPORATION -- (202)628-4888
43 1.
they develop the statutory'SCP.
1( /
2 Some things won't go away quite that readily, and
-3 the NRC has proposed interactions with DOE on key areas of 4
concern, and of course, we have already had, for example,.the 5
workshop on alternative conceptual models.
QA has been 6
addressed in one workshop to some extent and will be addressed 7
in future meetings, and then finally, the staff will be 8
reviewing the SCP to see whether the concerns have been 9
resolved, and if they haven't, we will, of course, pursue them 10 until such time as they are put to rest.
11 That completes what I have to say, but I am 12 avtilable for questions.
({}
13 CHAIRMAN MOELLER:
Any additional questions for 14 King?
Well, I'm sure we will have an opport.nity as you 15 mentioned in the subsequent presentations to go into depth 16 into the various issues.
I should also mention or I'm 17 reminded I shoula mention that at the Jilne 7th and 8th 18 Subcommittee meeting, this waste management, meeting of the 19 Waste Management Subcommittee, we are going to have another 20 opportunity for an in-depth review of the alternative 21 conceptual models.
22 Okay.
Well, thank you then, and I notice if I am 23 reading this right that the next item on the agenda is a 24 break, and so we will take a break.
CT J
25 (A brief recess was taken.)
HERITAGE REPORTING CORPORATION -- (702)628-4883 4
44 1
CHAIRMAN MOELLER:
The meeting will resume, and A_/
2 rather than follow our agenda for just a brief moment, Jim, we 3
wanted to call upon Ralph Stein to comment for the record on 4
the questions I raised on radon.
5 This will only take five minutes or so, Jim.
6 MR. STEIN:
Do yor. want me at the table?
7 CHAIRMAN MOFLLER:
Or can you stand at the 8
microphone there will be fine?
This is Ralph Stein from the 9
DOE.
10 HR. STEIN:
Ralph Stein, the Associate Director of 11 Systems Integration and Regulation; Dr. Moeller, with your 12 indulgence, perhaps you will give me a moment or two to say a
(~)
13 few other things before we talk about--
v 14 CHAIRMAN MOELLER:
Fine.
15 MR. STEIN:
Radon, if you don't mind.
16 CHAIRMAN MOELLER:
Any comments you have.
17 MR. STEIN:
First, I do appreciate the opportunity 18 of being here this morning, and appearing before this 19 Committee to comment a little bit about the activities i
20 associated with the site characterization plan.
21 I think that it is important that we maintain some 22 sort of an ongoing continuing interface with you, and the 23 group that will follow on, I understand that there will be a 24 follow-on to the ACRS under your leadership, and as you know,
{'
25 we do have another group that is forming a Congressionally HERITAGE REPORTING CORPORATION -- (202)628-4888
4 45 1
mandated group, that is technical review committee which wa
(.
'(_)
2 will also be appearing before from time to time, and this 3
particular Committee has provided us with a number of insights 4
in the past, and we do appreciate the opportunity of 5'
interacting with you.
6 I think that you can get a feel for the magnitude of 7
the site characterization plan perhaps by merely looking at 8
the volumes that make up the site characterization plan, but I 9
also am under the impression as I listen to some of the 10-interaction that it might be worthwhile if you consider it, if 11 you consider it such for DOE to give you a, perhaps an hour or 12 two overview of how the site characterization plan was put
()
13 together.
In particular we would like to tell you what its 14 structure is and why we have an issues hierarchy and why we 15 have an issue resolution and performance allocation and how 16 they relate to our site characterization plan.
17 Of course, it is at your option, but we would be 18 prepared and happy to provide that to you.
Let me just say I 19 chatted a moment with Bob Browning to be sure that that was 20 okay from the staff point of view, and he felt that would be 21 worthwhile, too, if the Committee so decided.
22 CHAIRMAN MOELLER:
Well, thank you.
We will 23 certainly keep that in mind.
24 MR. STEIN:
Just a couple of comments--I think that
)
25 the staff has done a very thorough job of reviewing the site HERITAGE REPORTING CORPORATION -- (202)628-4888
46 1
characterization plan consultation draft, and they have n_
b-2 provided us with a number of comments.
As you know, they are e,.
3 divided up into three different sections, and they have helped
~
4 us quite a bit to focus our thoughts, and what it is that we 5
need to focus on during the next several months as we prepare 6
the statutory SCP.
- /
In that regard, I would like to mention to you that 8
our current plans are to take the comments, for example, from 9
the recent workshop that we had on alternative conceptual 10 model, and we had a complete transcript appear of that 11 particular meeting, and we will factor that into our thinking 12 along with the comments of the states and other participants,
()
13 and of course, the comments that we are receiving and expect 14 to receive over the next several months.
15 Sometime in July or August we are going to have to 16 start to focus our attention on the preparation of the 17 statutory SCP if we hope to get it out by the end of the 18 calendar year 1988.
This is our current plan to issue that 19 document, and it will be issued for a 90-day public review and 20 comment period.
At the end of that 90 days, we will, of 21 course, review the input, the comments, and just adjust the 22 program accordingly.
23 There is no requirement for another SCP.
That is, 24 once the SCP is released, the atatutory SCP, then that
{}
25 constitutes what we call the snapshot in time of what the HERITAGE REPORTING CORPORATION -- (202)628-4888
47 1
program is at that instant, and then subsequent from that (h
(-)
2 point on,. we will be making adjustments in the program to 3
reflect the comments that we have received from the NRC, the 4
state, and others, as part of our six-month progress report.
5 We-have elected to use that as the vehicle for reporting on 6
any changes.
7 Now it was not the only vehicle for interaction.
We 8
will have a continuing dialogue with NRC and the state and 9
there will be people that will observe the testing and we will 10 provide information on the test program as we gather the data.
11 Of course, the state is planning on having its own independent 12 overview and testing on the site, so we expect to start the
(~D 13 exploratory shaft in June of 1989.
We will actually start x/
14 surface work earlier than that, but we will not sink the 15 exploratory shaft until after the site characterization plan 16 has gone out and we have had an opportunity to review the 17 comments from the NRC state and public.
18 One other point that I would like to make, and in 19 going through the initial paper, under the section that talks i
20 about foundation of NRC staff review, I just wanted to comment 21 that we did receive when we submitted the site j
22 characterization plan consultation draft, the NRC acceptance l
23.
of that draft.
They have a process where they first decide 24 whether they will accept the document or not.
If they accept
/}
25 it, that meane they go ahead and start to review.
It doesn't HERITAGE REPORTING CORPORATION -- (202)628-4288
p 48 l'
mean it'is a good document or bad document.
It just means (mf 2
that it has met all of the requirements that have been i
3 established for the NRC'to start to review the document, and 4
we did receive notification that the document was satisfactory 5
from their, that standpoint, so at least I think we understand 6
what the process is ano what needs to be in that document to 7
meet the requirements that have been established by the staff.
8 Other than those few comments, I would like to just 9
turn briefly if we can to your questions concerning radon, 10 By way of introduction, we looked quite extensively 11 at the radon question more than a year ago while we were 12 preparing the consultation draft, and arrived at certain 13 conclusions relative to the treatment or how we are going to 14 deal with radon during the pre-licensing and the 15 post-licensing period.
16 I would like to introduce Ed Regnier, who is the 17 acting licensing branch chief in my office, to give you a 18 brief summary of what it is that we had considered and what 19 rules and regulations we are going to follow in our treatment 20 of the radon problem.
Let me just say that there is radon 21 underground, and it is something that we are going to have to 22 deal with.
So let me turn the microphone over to Ed Regnier.
23 CHAIRMAN MOELLER:
All right.
24 MR. REGNIER:
Thank you.
I am Edward Regnier of the 25 DOE Licensing Branch, and it was about a year ago when we HERITAGE REPORTING CORPORATION -- (202)628-4888
b
'49 undertook a fairly detailed review of the regulatory 7 _
k/
2 requirements and of the site problem with the radon in the 3
mine and emissions from it.
4 I have not refreshed my recollections as to the 5
particular. statutes and regulation numbers, so I will not 6
attempt to give a detailed overview of that.
'7 However, the thrust of it I think agrees with what 8
the NRC staff has' discussed earlier, is that if, as Mr. Stein 9
mentioned, there is a potential for radon build-up 10 underground, the questions that would arise or did arise will 11 be what regulations would apply to that particularly--would it 12 be included within the dose limits in Part 20 for exposure to (em) 13 the workers in the mine?
14 As Dr. Moeller pointed out, that the Part 20 15 exposures are limited or let's say are, exclude natural 16 background.
Now we have not really had a general counsel 17 opinion by DOE, and as far as we know, there is no official 18 legal view by NRC, but our belief or our, our operating 19 assumptions that we are working under in our plans would 20 include the radon within the limits of Part 20 after we are a 21 licensee, that the radon in the mine we will not consider or 22 let's say we are currently not considering to be part of the 23 natural background, and thus excluded.
{} ~
24 CHAIRMAN MOELLER:
It would be certainly 25 technologically enhanced, and if the same statutes that apply HERITAGE REPORTING CORPORATION -- (202)628-4888
50 1
to the' uranium mine apply here, then you know,'you would have
()
2 to act accordingly.
3-MR. REGNIER:
Yes.
And again.this, we believe that 4
before the time we are a licensee, the Part 20 limits in NRC 5-
-jurisdiction would not, would not be legally binding.
After 6
that, they would be.
7 In both cases, we would be voluntarily complying 8
with the MSHA regulation.
We have a Memorandum of 9
Understanding with MSHA which specifies that according to law, 10 we are not bound by law to follow them, but we are going to 11
' voluntarily follow the MSHA ragulations which regulate control 12 of radon levels in mines.
13 We also, of course, have our own internal DOE health
{
14 and safety orders which regulate the same items, and we will I
15 be complying with the DOE orders and MSHA regulations before 16 we are a licensee and will continue to comply with those after i-17 we are a licensee, and we believe compliance with those will 18 keep us well within the limits of Part 20 when added to the L
19 other exposures.
t l
20 CHAIRMAN MOELLER:
Carson?
l l
21 DR. MARK:
MSHA, that is the Mine Safety Act?
22 MR. REGNIER:
Right.
23 DR. MARK:
Now there are lots of fairly deep mines 24 around the world, and you must know how much uranium is in 25 this setting.
HERITAGE REPORTING CORPORATION -- (202)628-4888
51-1 Where do you stand?
Are you up at the top?
Are you Ef 2
down at the bottom where there is a problem, or isn't there a 3
problem?
4 MR. REGNIER:
I don't recall-the precise. numbers.
5
.There.have been significant levels of radon measured on the 6
Nevada test site in unventilated areas.
With proper 7
ventilation, which would be required for any occupied area, 8
the levels are minimal, but there is a, there is a source of 9
radon in the TUFF 10 DR. MARK:
Well, that comes from uranium, and the 11 average around the world is 4 parts per million.
How is it in 12 this setting?
Is it high or low?
Is it higher or lower than I'T 13 other mines that do or don't have a problem?
U 14 MR. REGNIER:
I'm not certain what the, what the 15 content is.
Based on my understanding of some of the readings 16 in unventilated areas, it is probably somewhat above average.
17 I don't think it is exceedingly high.
18 DR. MARK:
You need ventilation, of course, for 19 other reasons, too, and that, I was just trying to get a feel 20 for what kind of a problem this is, whether it is worse than 21 other hard rock mine scenes or better.
And you have got 22 experience even with some mines in Nevada where--in stuff 23 which is perhaps not just at your place.
(~
24 MR. BROWNING:
It clearly isn't any worse than V) 25 uranium mine, that we deal with uranium mines.
I think--
HERITAGE REPORTING CORPORATION -- (202)628-4888
52 1
.DR.
MARK:
Hardly; you couldn't sell it as a gs
(.__.)
2 repository if it were--
3 MR. BROWNING:
In terms of operation, just a matter.
4 of ventilating properly.
i 5
DR. SHEWMON:
He has told you everything he knows.
6 MR. STEIN:
I think that Paul Browning is correct.
7 Let me say that we have not, we have not excavated at the 8
Yucca Mountain site.
We have at the--what Ed Regnier was 9
referring to was information that is at least 20 to 30 miles 10 away from the Yucca Mountain site, so we do not have.the 11 specific information that you are asking about relative to 12 this site.
()
13 DR. MARK:
You have bore holes.
14 MR. STEIN:
we have bore holes, but that is part of 15 the process that we are going to be undertaking in the future.
16 We have a limited number of bore holes, and that wasn't high 17 on our list of things that we wanted to find out from the bore 18 holes.
19 CHAIRMAN MOELLER:
I think this is adequate for now 20 because we don't want to eat too much into Jim Kennedy's time.
21
'The only thing I would add, Bob Browning has brought to our 22 attention that 10 CFR, part of it doss cover this, saying that j
23 to the extent that DOE is not subject to the Federal Mine 24 Safety and Health Acts of 1977, the design of the repository 25 shall nevertheless include provisions for worker protection HERITAGE' REPORTING CORPORATION -- (202)628-4888
E 53 1
and so forth.
-N.
/
2 I think the only other question I would have, or s
3 comment--I don't want to, us to spend more time on-it--is 4
whether the tailings and ';hether NRC will cover the tailings.
5 Yes?
Go ahead; one more_ comment.
6 MR. REGNIER:
The tailings requirements are 7
somewhat, are somewhat diffuse.
That is an item where we 8
again have'not, we have not really resolved what regulations 9
or what that would come under.
That hasn't been such a high 10 priority for us because our initial analysis do indicate that 11 the surface emissions from the tailings piles would be 12 exceedingly low.
I do not have the numbers, but they are such
. ()
13 that they are low enough that we haven't really been concerned 14 about which regulation it is going to fall under.
15 CHAIRMAN MOELLER:
It was helpful.
16 MR. REGNIER:
Technically or legally that does need 17 to be resolved about where that's, about where compliance with 18 that is established--much smaller problem.
19 CHAIRMAN MOELLER:
Okay.
Thank you.
Let's move 20 then on to Jim Kennedy, and we will be hearing about QA, 21 specifically quality assurance concerns, which you will 22 remember is one of the major objections.
23 MR. KENNEDY:
Thank you, Dr. Moeller.
My name is 24 Jim Kennedy.
I am a section leader in the Division of
[
25 High-Level Waste Management, and I would like to talk to you HERITAGE REPORTING CORPORATION -- (202)628-4888
54 1
today about the quality assurance concerns in particular, and-2 most of the time about the objection that we had on the CDSCP 3
that was given to us back in January by DOE.
4 First, let me put our CDSCP review into some kind of-5 content.- As all of you or most of you know by now, DOE is 6
about to embark on an extensive site characterization program 7
for the next seven years or so to collect data and perform 8
analyses that will be used to suppor t its license application 9
to the NRC in 1995.
10 Now in order to help assure that the data that they 11 collect and that the analyses performed, they perform, are 12.
valid and defensible in licensing, DOE is required to
( )-
13 implement a quality assurance program in accordance with Part 14 60 requirements.
15 Now our objective on the staff is to have performed 16 enough review of that program that we have confidence that it 17 meets our regulations before they go off and collect most of 18 the site characterization data over the next seven years.
19 What I would like to do today is talk about the 20 objection in that context and in particular what we are doing 21 to develop this confidence, and to have some assurance that 22 the program is satisfactory for licenaing before we get to 23 licensing.
24 (Slide) 25 HR. KENNEDY:
This is the objection, and now I am HERITAGE REPORTING CORPORATION -- (202)628-4888
55 1
paraphrasing it.
Basically it says that the CDSCP references p)
(-
2 a number of QA plans and procedures for DOE and the 3
organizations participating in the program, many of which or 4
most of which have not undergone staff review or if they have 5
undergone staff review, we have outstanding comments.
That 6
is, they don't fully comply with the NRC's regulations-yet and 7
we don't know that, and that as a result, there is a potential 8
for data collecting under those programs will not be useful in 9
licensing.
10 Before I get to the recommendations, I would like to 11 put up a vugraph of, or an overhead rather of--
12 CHAIRMAN MOELLER:
Why don't we move that table
()
13 closer to your screen?
There you go.
Thank you.
Great!
14 MR. KENNEDY:
Now the objection got to the facts 15 that we haven't done enough review of this program here.
What 16 I would like to do is describe the program, the organizations 17 in the program, and give you some feel for what we expect from 18 DOE and what we feel we have to do.
19 Did you focus that, Owen?
i 20 MR. MERRILL:
It focused on top but not on the j
l 21 bottom.
22 MR. YOUNGBLOOD:
I think everybody can read it from l
l 23 our slides anyway, Jim.
I I
24 MR. KENNEDY:
I hope this isn't too complicated, but
{}
l l
25 these are the major organizations, and at the top is the l
HERITAGE REPORTING CORPORATION -- (202)628-4888 m
56 1
_ Office of Civilian Radioactive Waste Management at DOE
)
2 headquarters, and reporting to it was OGR.
I came down on the 3
auvway with Ralph Stein today.
He tells me that OGR no longer 4
exists.
DOE has just finished its reorganization, and there 5
are actually three divisions here now I think that report to 6
the director of OCRWM.
7 I don't want to get into the details.
The point is 8
there are a headquarters organization at DOE which is 9
responsible for providing programmatic policy guidance, QA 10 guidance, QA overview, to the DOE Nevada project office.
11 That's headquarters.
Headquarters has some organizations 12 doing work for it, namely, a defense waste processing facility
/~T 13 in West Valley, demonstration project.
West Valley reports to
- V 14 NE within DOE, and Savannah River to Defense, but they will 15 both be supplying glass vetrified high-level waste to the 16 repository program, and I know OCRWM is laying QA requirements 17 and other performance requirements on those organizations.
18 Headquarters also has a materials characterization 19 center, Pacific Northwest haboratory, providing some work 20 furnishing data for TUFF, and they have got Brookhaven 21 National Lab performing performance assessments.
The heart of 22 the work or the detailed technical work rather, site 23 characterization work and engineering work, is occurring down 24 here at the waste management project office at Las Vegas.
25 They have a contractor who provides technical support, SAIC,
~
HERITAGE REPORTING CORPORATION -- (202)628-4888
57 1
and of course they have the major participating organizations
( ))
?
2 who are national labs--Los Alamos, Livermore, Sandia, and also s
3 the USGS and also some of the site contractors.
4 DR. MARK:
I notice USGS is there.
Now in years 5
past, USGS has given advice and opinions, and I have forgotten 6
what they call their main official papers, paper No. 742 7
anyway.
It comes out with the imprimatur of the director of 8
the USGS, been done by the staff.
9 Are they going to have--and then it has been 10 accepted as established fact.
They then changed it, of 11 course, in five years or so, but still they have an official 12 position on frequency of earthquakes up where the pipeline is, I
()
13 things like that.
1 14 Are they going to have to change their way of 15 working and putting out considered opinions because of NRC's 16 QA criteria?
Are they going to have to hire a bunch of 17 lawyers and paperworkers and bookkeepers in addition to the 18 technical people?
19 MR. KENNEDY:
Well, I understand they have made some l
20 changes.
I believe you were referring to the USGS providing 21 information to the NRC in advice and opinions.
t l
l 22 DR. MARK:
To the world and the NRC.
l 23 HR. KENNEDY:
They have made some changes in recent l
24 years.
They have put into place a quality assurance program
[}
25 that is designed to meet the Part 60 requirements.
They have HERITAGE REPORTING CORPORATION -- (202)628-4888 c--g N-
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hired I understand some quality assurance individuals and they
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2 have other USGS-individuals who have been working there for 3
some time, working in quality assurance, to provide the 4
record, to provide.the system of control and chacks that are 5
needed or that are required by Part 60, so there have been 6
some changes, yes.
7 DR. MARK:
Well, they have made these changes.
Are 8
'your criteria consistent with the way they expect to work or 9
not?
10 MR. KENNEDY:
Today?
In the repository program?
11 DR. MARK:
USGS.
12 MR. KENNEDY:
Our criteria are I would say generally a()
13 consistent with the way that they are working today on the 14 repository program, providing information to that program.
15 I doubt that that system of controls is the same 16 that they were using before.
I think it is more, I know it is 17 more.
18 DR. MARK:
It seems to me of interest if they are 19 short of money and have to hire QA people instead of 20 geologists, that's sounds a little bit doubtful, in the public 21 interest.
22 MR. YOUNGBLOOD:
Ralph can talk with you about the 23 contract, where that money comes from to them.
Ralph has to e
24 pay on it for that QA to get it through his licensing process.
25 CHAIRMAN MOELLER:
So apparently we will hear about HERITAGE REPORTING CORPORATION -- (202)628-4888
~
f 59
~
1 it,'but apparently it is not diverting funds from other
()
2 operations.
This is a supplement to USGS' work.
3 MR. YOUNGBLOOD:
It would be like at Los Alamos.
We
~
1:
'4 don't lay QA on the whole Los. Alamos Laboratory.
It is'only 5
that work that they are doing for DOE on the repository.
6 That's the only thing we touch at Los Alamos.
7 MR. KENNEDY:
Maybe one point to make is that past 8
histories isn't always a good guide for the future, and with 9
respect to QA, that is, because this is a controversial 10 program.
There are going to be controversial decisions, and 11 the QA program needs to provide, you know, the record of how 12 decisions were made, and the evidence of data collection 13 techniques, so that independent judgments can be made by 14 outsiders, namely tt.' NRC, licensing boards, the State of 4
15 Nevada, et cetera.
16 DR. STEINDLER:
You did indicate that the way the 17 USGS qualified the results of their research it; the past would 7
18 not have met or would not meet the current QA requirements of 19 high-level waste repository program, is that right?
f 20 MR. KENNEDY:
Let me tell you what I know.
I'm not 21 familiar with the details of how they did their work in the i
22 past.
I do know from talking to people at the USGS and people 23 at WMPO that they have had to do extra work to put in a 24 program that meets our requirements in Part 60.
25 DR. STEINDLER:
Can you tell whether or not that's
{
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.1 because of the~ paper trail requirements.or something more
/,
~( )
2 substantive related to the actual work and its output?
3 MR.' KENNEDY:
'I can't make a judgment on that.
I am 4
just not familiar with what they did in the past.
5.
MR. YOUNGBLOOD:
Part of it is the calibration of-6 instrumentation and such things as that.. That gets it.to the 7
quality assurance program.
8 DR. STEINDLER:
I guess I would be surprised if that 9-were the significant issue from what the USGS has done in the 10 past 2n terms of the quality of their work.
11 MR. YOUNGBLOOD:
You asked for an example and I just 12 gave you one.
13 CHAIRMAN MOELLER:
Go ahead, Jim.
)
14 MR. KENNEDY:
Okay.
So this is basically the 15 program here, and our strategy for reviewing this program is 16 to look at the plans for each of these organizations, that is,
'17 the paper, and we have to 1cok at that and we have to make a e
t' 18 finding on that.
QA plans, review them, generally we review 19 them.
We have a number of questions that we formally submit 20 to DOE and we resolve those over a period of time.
21 We also intend to look at, observe, monitor, audit, 22 the implementation of the program, which is, of course, the 23 most important part, and we have just begun in the last six 24 months or so getting out to these organizations more often and t
25 observing--in particular what we have done in the last few HERITAGE REPORTING CORPORATION -- (202)628-4888
~1 61-1 months is observe'three audits that DOE has conducted, this 2
project office, of its prime contractors.
We have been to 3
Holmes and Harver, read the USGS this week.
We were at Fennix 4
and Scission back in February.
Actually we also-observed _the 5
DOE headquarters audit back, of MCC back in February.
6 CHAIRMAN MOELLER:
Excuse me.
These are not like 7
the Los Alamos review?
These are observations of DOE's 8
audits?
9 MR. KENNEDY:
What we are calling observation audits 10 where DOE, the project office is conducting an audit or 11 headquarters conducting an audit of MCC.
They will send out a 12 team of generally four or five or six people to audit the
()
13 implementation of the program.
r 14 One efficient and effective thing we are doing is l
15 sending out a team of two or three observers consisting of a 16 technical person from our Technical Review branch, quality 17 assurance person and project manager to see how well DOE is 18 conducting an audit of its contractors, and what it does is it 19 is an efficient way for us to get a lot of information on the E
I 20 program and if things are going well, to develop confidence.
^
21 Now the important thing is we feel that DOE be out 22 there, identifying problems, auditing, getting problems
[
23 corrected, and if we can see that process working effectively, 4
24 that's going to give us a lot of confidence that things are
{}
25 working well.
It is a lot more efficient than the team audit, i
i HERITAGE REPORTING CORPORATION -- (202)628-4888
62
'l for example, that we had at Los Alamos.
What--we will be
().
2
- getting back'to team audits, but those, they are an effort to 3
put together an eight-man team and do all the planning and 4
coordinating with DOE, and it takes, I think took us on the 5
order of what, three quarters of a sti.ff year.311 together to 6
do that.
7 CHAIRMAN MOELLER:
Does DOE have a procedure, a 8
procedural manual for their conduct of these audits?
9 HR. KENNEDY:
Oh, yes, absolutely.
10 CHAIRMAN MOELLER:
You have reviewed that and 11 critiqued it?
12 MR. KENNEDY:
We have reviewed that in connection 13 with our review of this QA plan right here, yes.
And it, you 14 know, it is developed in accordance with the nuclear quality 15 assurance requirement, and QA one, yes.
16 CHAIRMAN HOELLER:
Okay.
17 MR. BROWNING:
I might just add that what Mr.
18 Kennedy is just referring to is actually a lesson learned 19 flowing out of the reactor experience that we are trying to 20 draw on.
We were trying to make sure--in the reactor case, 21 for example, it is, it is essential that the utility or the 22 plant operator have a good program and not be dependent on 23 NRC's QA to feed him problems, so we are not filling a vacuum 24 on the licensee, in that case, the licensee staff, so that the 25 earliest stages of the program before DOE is even a licensee, t
HERITAGE REPORTING CORPORATION -- (202)628-4888
J O
I 63 st T j
k 1-the emphasis is on' making ~sure DOE's own program is working i
2 offective'and then we_are a lot more comfortable in a
+
3 monitoring, sampling, auditing mode, which is the only thing 4
we cat. do with our limited budget compared to the budget DOE' 5
has to make this whole thing work, so I think that's what we l
6 are trying to keep in the back of our minds.
7 The only way this program is going to work is if DOE 8
does a good job.
There is no way in which'NRC with its l
9 limited budget and its limited staff can make the thing work.
10 LAll we can do is audit, _make sure that we have got a 11 confidence that it is in fact working.
I think you will see 12 that in every area of our particular regulatory program.
)
13 MR. KENNEDY:
Okay.
A couple of other points
.T 14 mentioned the observation audits.
We have got observation 15 audits now scheduled through the end of the 'i. scal year.
We 16 will be going to USGS Denver in April.
I mean in May.
We are 17 at USGS Henlow Park, California, this week.
After that, I 18 think it is Sandia in June.
It is Livermore in June, Sandia i
19 in July, Reeco in August, Los Alamos in September, and then we
(
20 will be scheduling some more after that.
21 v..e other point is that we are starting, our 22 principal focus of our review right now is from this point on 23 down.
WMPO or waste management project office rather, is 24 writing the site characterization plan.
They are coordinating 25 the study plans and investigations at the site, and of course, t
HERITAGE REPORTING CORPORATION -- (202)628-4888
64 1
overseeing all of the major participants.
(
-2 Our-focus right now is from here on down, we are 3
close to reaching agreement with DOE on the QA plan for this 4
organization, which I will talk a little bit more about, talk 5
about a little bit more later, and~the headquarters 6
organization will be reviewing that after we review this and 7
perhaps some of this, and if we identify anything up here that 8
needs to be fixed, we will make sure that it gets incorporated l
9 appropriately down :.ere, but right now, we are focusing here 10.
on down.
11 Okay.
Let me come back to the objection and tell r
12 you what our recommendations are.
First, the DOE sh the
()
i 13 latest revisions of the plans of participating orgm stions.
14 These were the bottom six, eight, seven, seven organizations, 15 the national labs, et cetera.
We do not have all the latest
[
16 revisions.
We do not have approved plans that have been i
17 formally sent to us by DOE headquarters, so we need those so 18 we can begin our review.
19 We recommended that DOE respond to outstanding staff 1
2C comments.
That comment in particular refers to a staff review 21 of the waste management project office plan that we had 22 conducted, and DOE--Dr. Moeller, you were at that meeting on 23 March 18th where they didn't respond to us formally but we met 24 and discussed all the detailed comments we have, we had
[
l 25 rather, and we are exp.: ting to get that revised plan l
HERITAGE REPORTING CORPORATION -- (202)628-4888
65
+
1
. addressing our comments.within.a week'or two, something like (m_)
?
that.-
So it is imminent.
3 We are recommending that DOE facilitate NRC's staff 4
verification reviews, on-site reviews such as audits, and that 5
has been put into place.
WL have gone in a number of 6
observation audits recently.
DOE and headquarters is 7
encouraging us to comment on others.
We are scheduled right 8
now through September and will be doing more later.
9 And finally, we recommended that' DOE not start work f
10 until additional confidence in the program is obtained by the 11 staff, and they have agreed to that.
12 DR. STEINDLER:
I have a question on the general 13 tone of those.
If you look ac the four, those four comments
[
14 and recognize that this is one of five major issues that you 15 guys.have raised, when you look at the wording of the 108 16 general comments that follow that, I don't see the compelling 17 nature of these four recommendations that would warrant making 18 this thing a major issue such as an objection.
19 It struck me as I was plowing through there that DOE 20 to respond to outstanding comments and effects says hey, guys, l
21 you are behind schedule, and not a whole lot, not a whole lot 22 more than that; DOE to furnish the latest revisions, that is, 23 tell us what you are planning to do, and bring things up to 24 date.
That's a,
again, a scheduling issue more than anything i
25 else.
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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66 1
What is it that1I am missing that drove you to take s_/
2 that collective four and raise it to the level of an 3
objection?
4 MR. KENNEDY:
Well, I mean the fact is they are 5
about to embark <nt a big, big program for collecting the data I
6 that-is going to be used in the license application in'1995 7:
consisting of study plans and translation of study plans into 8
test plans and procedures, and that data needs to have 9-quality, a quality assurance program applied to it in order to 10 be, to help it become valid, accurate, and particularly 11 defensible in licensing.
12 The risk is that without qualified programs in place
()
13 or programs in place that meet our criteria, DOE could spend 14 lots of money, collect lots of. data that would not be usable 15 and would jeopardize their getting a license frcm the NRC in 16 1995.
17 DR. STEINDLER:
That message over the last five 18 years surely has been said so many times that I would be and 19 perhaps you would be also surprised that DOE would not 20 understand that, set that aside in the sense that it is a 21 message which has been given many times, and I'm still 22 grasping for something that looks at this particular issue and i
23 says boy, that's, that's a, really an important issue, 24 objection level.
25 Let me simply add that there is, there may well be a 4
HERITAGE REPORTING CORPORATION -- (202)628-4888
jg4 67 1
.significant amount of information data from the literature 2
that will have to be used which will not have undergone the 3
kind of scrutiny or in fact being generated by under a JA 4
program that is currently being devised, yet there are 5
procedures for accepting that kind of information.
[
i 6
MR. KENNEDY:
There are.
7 DR. STEINDLER:
So it isn't au though under 8
absoi
,'ly no conditions can you take data that do not follow 9
the QA plan.
10 MR. KENNEDY:
Oh, that's absolutely right.
The risk 11 is, you know, presumably the data that they are collecting 12 during their cite characterization phase being collected by
()
13 their organizations is going to be primary data that they at 14 least feel at this point is going to be needed for licensing, 15 or most of it anyway, and data that you are referring to can 16 be qualified.
You don't know that for sure.
You have to look 17 at it and go through a process of wus.lif ying it, and it will 18 be, you know, risky for them to g, off and not have a program 19 that they had pretty good confidence met our regulations for 20 taiu primary data that they are collecting themselves.
21 MR. STABLEIN:
Could I interject for a moment?
22 CHAIRMAN MOELLER:
Go ahead.
23 MR. STBLEIN:
This is King Stablein again.
In my 24 earlier talk, which Dr. Steindler couldn't be here for, I 25 discussed the subject and I just would like to revisit it for i
L HERITAG3 REPORTING CORPORATION -- (202)628-4888
68 1
one moment for his benefit, this matter of' objections, because
)
2 the distinction can be difficult, and remember that we 3
considered al.1 of our concerns to be very important.
There 4
are no nits in there.
-5 The distinction on objections is these are concerns 6
of such immediate seriousness that the NRC would recommend 7
that the DOE not start new work until they are resolved, and 8
it=is that immediate seriousness and the impact on the program 9
that separates these from other very serious concerns which 10 are in the level of comments.
The QA fundamental inadequacies 11 in the QA program is one of the three types of objections that 12 we defined.
('}
13 DR. STEINDLER:
That is precisely my problem.
I 14 look at those four things and I look at them and I say do they 15 really represent fundamental inadequacies?
And what I see is, i
16 as I said before--I don't want to belabor this issue.
In 17 fact, I will shut up shortly.
What I see is hey, guys, you 18 are behind schedule.
And now that doesn't constitute to me a 19 fundamental inadequacy.
It isn't as though they are going off 20 into left field totally out of synch with what it is you fo'.s 21 are interested in.
22 Let me just leave it there, and I don't think that's 23 an irresolvable issue I think.
24 CHAIRMAN MOELLER:
This came up this morning, too.
25 If the potentiality for closure is obvicus, or is good, then s
HERITAGE REPORTING CORPORATION -- (202)628-4888
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it'is of lesser concern. -And your: remarks are in your opinion
()
2 and mine, too, that potentiality for closure here is good.
~
3 MR. STABLEIN:
I think that-what maybe we are not 4
getting across, and I would ask Jim to perhaps if.he has any 5
to give a~ couple of examples, that we don't just have problems 6
with their schedule, but we perceive that there'are some F
7 weaknesses in their QA program which if they don't get after 8
them right now, before they start their work, will lead to 9
data that may not be use usable in' licensing.
We are not 10 talking about peripheral types of things, if I understand i
11 correctly.
12 HR. KENNEDY:
Well, yes.
For example, I guess maybe
(}
13 take the example of the Holmes, I mean the Fennis and Scission 14 audit that we observed back in February, and there were some 15 problems that the DOS audit team found, some significant 16 problems that need to be corrected and need to be corrected 17
.soon* but you are seeing it more as a schedule issue.
18 DR. STEINDLER:
Well, look, I am trying to read the 19 words without having a great deal, without bringing in a great 20 deal more information, and the words at least don't give me 21 that sense of urgency which I thought was, seemed to be 22 associated with the objection level concerns.
But let it go.
23 CHAIRMAN MOELLER:
Well, the last one, though, the 24 lest item certainly is rather compelling.
They cannot, you O
i 25 know, do any more work or do any work with.>ut it.
Ralph Stein i
i HERITAGE REPORTING CORPORATION -- (202)628-4888
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70~
1 has a comment.
Let's pull it in and see if we can resolve
[D Tm/
2 this.
-3 MR. STEIN:
I think that there should have been a 4
' word modifying the preposition in that last word.
It is new 5
work.
It should be new work.
We have ongoing work at the 6
site, and there is certainly a lot of risk associated with it 7
rolstive to our QA plans and procedures regarding that new, 8
the regarding the old work, the ongoing old work, but 9
nevertheless, we are proceeding with work currently, and it is 10 the new work that will not be undertaken until such-time as~we 11 have a qualified QA program in place to support-that new work.
12 MR. KENNEDY:
Yes.
That's right.
We recognize
()
13 that, for example, there is some ongoing coismic data 14 collection where DOE feels, and I guess we agree, that it is-15 better to have data, some data with QA than no data at all, 16 for example, for seismic monitoring at the site.
And there is 17 a risk at that.
I mean they are collecting it.
Tney do have 18 some QA on it.
We don't know that it meets all our 19 requirements, but they may be able to use it later on.
20 DR. MARK:
How do you view the QA on the seismic 21 disturbances that have happened ever since 18807 22 MR. KENUEld:
Right.
Well, that's--
23 DR. MARK:
Are you going to accept that or are you 24 going to say it can't be used in licensing?
25 DR. MAPK:
Well, what we have said is there is a r
HERITAGE REPORTING CORPORATION -- (202)628-4888
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f 71 1
technical' position that we published called qualification of 2
existing data which has in it four techniques for looking at 3
existing data and making a judgment whether'it has got enough, 4
you know, validity to use in licensing.
5 That would, of course, be outside tne subpart G QA 1
6 program, but it is a process that can be gone through to 7
qualify that data.
Obviously you would have to use that data.-
8 I don't know whether you have seen that or not, but I think we 9
briefed the ACRS subcommittee on that about a year ago or so.
10 CHAIRMAN MOELLER:
Yes, you did.
11 MR. BROWNING:
The think this perspective is we have 12 been talking about needing to have a qualified QA program in
()
13 place before site characterization starts.
Site 14 characterization in earnest starts when you sink the shaft.
15 DOE wants to start that in June of next year.
I 16 When you look at where we are in the process of 17 coming to closure, where they think they have got a good QA l
18 program and we have looked at it enough that we can agree that 19 it is a good QA program, we are still too far apart.
We have 20 got one year to close that gap.
We cannot afford to let that 21 gap continue and continue.
Otherwise it is going to go 22 through the whole program and we are going to repeat the 23 lessons learned in the past where you go in, trying to improve i
24 your case, and it is thrown out because you have got a good
(
}
25 data but you can't prove it through a good QA program.
t l
l HERITAGE REPORTING CORPORATION -- (202)628-4888
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Now is the time.-
This is a milestone.
A' sinking
'us9 2
that shaft, starting the site characterization program, is the c
3 point where that has got to come to closure.
We cannot allow 4
this thing to keep dribbling along.
That's where we are r
5 coming from.
Tie don't have any regulatory authority to tell 6
them to stop, but we are saying hey, you keep going, we are 7
not sure we are going to be able to use this stuff, and in 8
fact I am almost at a mind to say if it keeps going on, say we 9
are not evqn going to review your program.
Whether the 10 commission will back me on that or not, I will know come May 11 4th or shortly thereafter, when we brief them en it, but we 12 have been letteng this thing dribble along for long enough.
()
13 The recommendations are not really the findings.
14 The finding is that the paperwork is all inconsistent, so the 15 framework that you always lay your case on in a licensing 16 hearing, is the paperwork okay, first of all?
And it is not.
17 Doesn't mean the work isn't any good, but the paperwork that 18 supports it isn't in place.
We think it can be done if you 19 follow the process we are going, p.ick the Nevada project, get 20 that in shape.
Then make sure all the rest are consistent 21 with that.
Thea get on with it.
But if you keep letting the 22 process dribble along, we are going to have done all the work 23 and we will still have these things outstanding, and we cannot 24 afford it.
And now is the time to draw the line.
Don't start 25 until you get it fixed, because we have been making this point i
1 HERITAGE REPORTING CORPORATION -- (202)628-4888
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through three or four years now and we are still not there.
l("}
s_/
2 MR. KENNEDY:
And another part of that is, and we 3
agree that it is fixed, that we, you know, sign up to it.
4 MR. BROWNING:
You can look at this as sort of a 5
concept of readiness review.
They are about to go into the 6
next phase, spend a-lot of money collecting data.
It should 7
be good data.
We are putting our souls on the line saying we 8
want to be in a position to say we agree you are ready to go, 9
and that takes them producing the paper, getting it to us, us 10 looking at it, reviewing it, saying we are okay, but we are 11 going to be on the-line saying we think that's a good starting 12 point.
()
13 Then the program will be neat and clean.
It won't 14 have all these arguments like you know, well, was the seismic 15 data done under approved QA?
Say yes, the QA program Rev. 6 16 was approved by DOE, and NRC reviewed it.
We have an audit of 17 it.
We are confident it is okay.
That's not an issue in the 18 licensing hearing.
It has got to get under control, and it j
19 isn't under adequate control yet.
l 20 MR. YOUNGBLOOD:
This is not just new to the SCP.
21 This has been an agreement with DOE over the last several 22 years.
23 MR. BROWNING:
There is no disagreement.
24 MR. YOUNGBLOOD:
They will have a qualified QA t
25 program prior to start:ng any new site activities, so it is HERITAGE REPORTING CORPORATION -- (202)628-4888
. _..=_
74
~
'l i
1 not-anything that flushed out from, fro;n the review of the
~)
.r. (,j 2
SCn.
3 MR. BROWNING:
It-is a scheduler thing,-but the 4
thing.that is driving it is a schedule that says we want to 5
sink a shaft as of this date, and that date has come closer 6
and closer.
As every day goes by, that date comes closer.
We 7
have got to get it r : solved.
It takes a lot od work on our 8
part and a-lot of work on their part.
9 MR. KENNEDY:
Another way of saying what you said, 10 we all agree that good QA is, DOE wants you to put in good a 11 QA program, but what we want to try to do here is to reach 12 agreement on what the specifics of that look like, so that we
(}
13 are not coming at them over the next seven years with new 14 issues.
15 MR. BROWNING:
Sending them after the fact, that's 16 what we want to avoid.
17 MB. KENNEDY:
There has got to be some of that, or 18 we will minimize that, that is to have us know and reach 19 agreement with DOE on what the QA program is, and to have 20 confidence in its being carried out well.
21 Anymore on that?
22 (Slide) 23 MR. KENNEDY:
Okay.
We had some other comments.
We 24 had, of course, the one objection.
We had five other comments 25 which I have briefly summarized here.
They are nowhere near HERITAGE REPORTING CORPORATION -- (202)628-4888
75 1
as important as the other one, as the objection, but first
(
2 qualification of data not collected under part 60 QA program, 3
they briefly described a process in the SCP Chapter 8.6 which 4
looks like it may not be rigorous enough.
5 What we have asked is that they formally submit to 6
us their procedure for qualifying existing data such as that, 7
which you mentioned earlier, Dr. Mark.
8 Another one was on the Q list, they had a summary of 9
their Q list analyses, analysis rather, and the SCP.
They 10 also had a large conceptual design record as one of the 11 references to the SCP, and we found that our, the analyses 12 were non-conservative in some areas.
For example, they were
(}
13 using ten-year old spent fuel instead of five-year old spent 14 fuel, which the repository can accept.
That was for closure 15 phase.
They provided an activity list which had only two 16 categories of site characterization activities that were 1
17 covered by the QA program.
The first was blastitig of the i
18 exploratory shaft, drilling and blasting rather, and the 19 second was a general description of something like activities 20 which would provide primary data for licensing.
21 What we have asked for here to resolve that is 22 either, for example, provide us the classification of the 22 study plans that implement the SCP, or give us a little bit 24 more detail on the words that describe wnich site 25 characterization activities are covered under the QA program.
HERITAGE REPORTING CORPORATION -- (202)628-4888 1
A
-76 1
We are not looking for a long thousand page document
(_f-2 of every single activity.
That's for sure, but more' detail 3'
than-just two items.
4 DR. SHEWHON:
Would it violate some federal-law if 5
DOE came back and said we will institute administrative 6
controls which will' assure that no fuel less than ten years 7
old will go underground?
8 MR. KENNEDY:
Not as far as I know, no.
The 9
five-year old spent fuel requirement was an internal DOE 10 requirement that we were aware ef.
The analyses that they did 11 for the SCP for determining the Q list, however, used ten-year-12 old spent fuel, so it was a contradiction with one of their 13 internal requirements.
[
- ()
14 There is no NRC regulation that requires five-year 15 old spent fuel.
16 DR. SHEWHON:
I have heard this number, and it seems 17 to me I have heard even shorter number before used in 18 planning, and certainly many of the package concerns, the 19 temperature concerns in the media drop off rapidly, and why
'hemselves with this was not clear to me.
20 are people flogging c
L
(
21 Thank you.
22 MR. KENNEDY:
Let me say--
l l
23 DR. SHEWMON:
We self-imposed apparently.
i 24 MR. KENNEDY:
Yes.
Okay.
The next one, this is a 25 familiar one--they proposed or they mentioned rather in the HERITAGE REPORTING CORPORATION -- (202)628-4888
77 1
conceptual! design report that they were using a ten to the
_ A(-)
2 minus 5th probability per year as a cutoff for examining 3
pre-closure events.
That was or rather appeared to be 4
inconsistent with the language in the SKM, i
5-
_The language in the SCP was something that we liked, 6
It was to the effect that they would look at accidents that 7
were suf ficiently likely to be considered credible,: that they 8
would look at other accidents not considered credible but with-9-
high consequences.
That is the kind of high risk that also 10 ought to be considered, and they would include all of those in 11 design basis accidents.
12 I was talking to DOE yesterday, and that's an old
()~
13 number, and it got into the CDR, and apparently they, 14 internally they are thinking of changing that, too, so it is, 15 looks like it is an internal inconsistency between the SCP and 16 the CDR.
17 CHAIRMAN HOELLER:
Then to help me, what number 18 would you prefer?
You would prefer a lower number?
19 MR. KENNEDY:
A lower number, yes.
We talked about 20 this some in connection with the Q list GTP, and the reactor i
21 program I know has used numbers for say external events of ten 22 to the minus, ten to the minus 6.
I guess the EPA standard 23 for post-closure uses ten to the minus Sth, so we haven't set 24 on the precise number, but it is somewhere in that l
'5 neighborhood I would suspect.
i HERITAGE REPORTING CORPORATION -- (202)628-4888
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78 1
CHAIRMAN MOELLER:
Okay.
Thank you.
You say NRC, (3
f
_)
2 or NRC/ DOE is reconsidering this recognizing their 3
inconsistency?
Okay.
4 DR. SHEWHON:
You realize that as you go from ten to 5
the minus 5 which is the number of probability, you can almost 6
believe that ten to the minus 8, which hasn't occurred once 7
since Cro-Magnon days or something, the uncertainty gets so 8
large as to make the numbers of dubious value?
9 MR. KENNEDY:
That, yes, I'm--all I can say is ten 10 to the minus 8th is a value that is in the EPA standard I 11 think for post-closure, and ten to the minus 6, ten to the 12 minus 8th are values that have been used in the reactor I~)
13 program for external events.
.V 14 DR. SHEWHON:
I repeat the uncertainty on those is 15 such to make them very dubious value, though people do quote 16 them and put them in.
17 MR. KENNEDY:
Yes.
18 DR. MARK:
Didn't add QA.
19 MR. KENNEDY:
Okay, and the last one on the Q list 20 was that there was some language that indicated and some 21 analyses that indicated what looked like some essential 22 mitigation features for events.
Initiating events were not l
23 included on the Q list.
I don't know how to better describe 24 that, but they had fault trees.
They had event trees.
We 25 looked at those.
We looked at the probabilities, and it i
HERITAGE REPORTING CORPORATION -- (202)628-4888
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looked like for events of'I think it was ten to the minus'5th p)-
(_
2.
or higher with greater than half a rem or five, I don't--it t
3 looked like that there were mitigating features that were 4
needed to keep within those bounds that were not included on P
5 the Q list.
In fact, they came up with no Q list.
They did
'6 the analysis and they said at this point, there is nothing i
7 that they firmly believe that is on the Q list.
They had some 8
items that are potentially there, but not on the Q list that 9
were pre-closure at this point in time, and that's it.
That i
10 concludes my presentation.
11 CHAIRMAN MOELLER:
Any other questions or comments 12 for Jim Kennedy?
Well, thank you.
()
13 MR. FENNEDY:
Okay.
14 CHAIRMAN MOELLER:
We will move on then.
Does the 15 DOE, Ralph, do you people have any comments before we go to i
16 the next speaker?'
17 MR. REGNIER:
Ralph had to leave.
Ed Regnier, DOE--
18 we don't have any comments to make at this time.
Thank you.
19 CHAIRMAN HOELLER:
Thank you.
Okay.
The next item 20 on the agenda is the performance assessment concerns, and this 21 will be--you are Dan Galson?
22 MR. GALSON:
Yes.
23 CHAIRMAN MOELLER:
Thank you.
24 MR. GALSON:
Does everyone have a copy of the 25 handout?
I would prefer not to use the vugraphs if you all i
f HERITAGE REPORTING CORPORATION -- (202)628-4888
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'l haveicopies of the handout, unless~anyone in particular would
,M L) 2 like to see.
o
~3 CHAIRMAN MOELLER:- Have copies been provided?
4
-MEMBER OF THE AUDIENCE:
No.
5 CHAIRMAN MOELLER:
Sure.
Let's turn on.the lights.
'6 MR. GALSON:
I have no particularly scintilating 7
figures to show.
8 CHAIRMAN MOELLER:
That's fine.
9 MR. GALSON:
Perhaps we need any, if I need to use 10-any of the~back-up figures, I will put them on the vugraph.
11 CHAIRMAN MOELLER:
Go ahead.
I think enough people 12 will have them by the time you start.
()
13 MR. GALSON:
Thank you.
I'm Dan Galson.
I'm a 14 staff member in the Compliance Demonstration _section of the 15 Operations Branch in the Division of High-Level Waste 16 Management.
17 The, the staff's objection, objection, first 18 objection on the CDSCP has already been referred to by a 19 number of the speakers, and the associated workshop that the 20 NRC and DOE held earlier in April has been referred to, and I 21 would like to focus on this objection in my presentation.
22 Before coming to that, however, I would like to just 23 give you a general overview of the Compliance Demonstration 24 Section's review of the CDSCP and very briefly summarize some 25 of the other concerns.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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1 On the.first page, I have indicated the general
[
(
2 scope of the CDSCP review conducted by the Compliance 3_
Demonstration Section and you see it was principally in two 4
areas.
One, the issues,.information needs and performance 5
allocation, just general. aspects associated with them in the 6
CDSCP;_the details were reviewed in each particular area by l
7 the other technical sections.
f 8
.And secondly, performance assessment activities, and i
9 this covers a whole host of areas, as you can see--scenario 10 development and screcning, anticipated processes and events f
i 11 and unanticipated processes and events, estimation of scenario l
12 probabilities, modeling and model uncertainty, data i
{)
13 uncertainty, sensitivity analysis, the formal use of expert 14 judgment, compliance assessment with the EPA's containment i
15 requirement, which is the requirement that ~ limits releases to r
16 the accessible environment for 10,000 years after disposal; 17 pre-closure analysis, and finally, performance confirmation.
t 18 The Compliance Demonstration Section developed
(
19 review, general review criteria in all of these areas.
They 20 led the team review in these areas, in the individual i
21 technical disciplines, and they also had the lead role for
(
.2 review of several key issues, in particular this issue 1.1 in j
2 1
23 the CDSCP, which is concerned with the DOE's plans to collect I
24 data needed to demonstrate, to demonstrate compliance with tht:
25 EPA standard.
l i
f HERITAGE REPORTING CORPORATION -- (202)628-4888
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Turning to the next page, I've just indicated the 2
names of the people in this section involved with the CDfCP 3
. review.
I was the lead reviewer for post-closure performance j
4
. assessment.
Bob Heal led the review for pre-closure 5
performance assessment.
Pauline Brooks had the lead role for
~
i 6
review of performance allocation, and finally Seth Coplan is
-7 the section leader of this section.
He conducted a quality 8
assurance review of all the comments generated by his staff.
l 9
Turning to the next page, the Compliance 10 Demonstration Section generated one objection on the CDSCP, 11 seven comments, and fivo questiona.
It has already been i
12 remarked that all of the objections, the comments and the
()
13 questions are all important.
I do want to focus on the key t
14 concern, which is the objection, and was the focus of a i
15 workshop between the NRC and DOE, but very briefly, the other i
16 comments and questions were concerned with the, in general 4
17 with the DOE's plans to demonstrate compliance with the EPA 18 standard and development of the CDS needed to evaluate f
19 compliance with the standard, and they concerned such areas as i
j 20 the development of scenarios, and scenario probabilities and 21 the use of subjective methods, f
22 There are no significant changes that have been made l
23 in these comments from the package that you have, the f
i 24 preliminary draft point paper package, and I will be pleased 25 at the end to answer any questions you may have on some of the
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r HERITAGE REPORTING CORPORATION -- (202)628-4808
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other comments or questions that were raised by the compliance
(
2 Demonstration Section staff.
l 3
Briefly on this page, you can see the first 4
objection was concerned principally with how alternative 5
conceptual models were dealt with in the performance 6
allocation process in the CDSCP.
If you turn to the next page 7
now, I have laid out a general overview of what I want to say 8
with regard to this objection, and this is in general-very 9
.similar to what was presented at the workshop held in, earlier 10 this month in Las Vegas.
11 I plan to give some general background to the issue 12 of performance allocation and how it should be used in the
()
13.
sito characterization process, and in order to help you better 14 understand the objection, provide you with a working 15 definition of the term conceptual model, and tell you a little 16 bit why conceptual models are so important in the site 17 characterization process.
18 I will then provide you with a summary of the 19 staff's objection in this area to the DOE CDSCP, and finally, 20-I will conclude with the staff's recommendations on dealing 21 with alternative conceptual models in the statutory site 22 characterization plan.
23 This presentation will be followed by a presentation 24 by John Trapp of the staff, and he is going to--my
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l 84 1
presentation will focus on specific staff comments on the (q -
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2 CDSCP that, with regard to alternative conceptual models, and
-3 he will conclude his presentation-with the conclusions of this
'4 liRC/ DOE workshop on alternative conceptual models, so it may 5
be best if questions on this objection are held over to after 6
John has given his presentation, but I would be pleased to
.7 entertain questions at any point if you so wish.
)
8 Turning to the next page now, it is entitled 9
performance allocation and site characterization process.
t 10 Just briefly, I can summarize what performance allocation is j
11 by saying that it is a systematic method to lay out the 12 investigations for, required to demonstrate compliance with i
13 the NRC's crit'eria in 10 CFR Part 60.
Conceptual models are i
14 an integral component of performance allocation in that they 15 are part of the basis for establishing the performance l
[
16 allocation.
I 17 The staff considers that alternative conceptual 18 models should be used to set bounds on the performance 19 allocation and that the range of uncertainty associated with f
20 existing data on the site should be reflected in performance 21 allocation.
So as you can see from this page, I have laid out 22 all the interactions that the llRC and DOE have had on
(
I i
23 nerformance allocation, and it dates back to an August 1983 l
24 liRC/ DOE technical management meeting.
The staff raised a
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25 concern on the DOE's draft mission plan in 1984.
There were HERITAGE REPORTING CORPORATIOff -- (202)628-4888
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_two meetings held in 1985 that where performance allocation
()
2 was discussed.
These were technical. meetings.
There were 3
subsequently two meetings in 1987 prior to issuance of the 4'
CDSCP.which discussed how performance allocation was being l
5 implemented in the SCP, discussed generally what the issues 6
hierarchy was with.particular reference in the second meeting l
7 to the' Nevada site.
8 In March of this year, we sent staff comments, draft 9
comments I should say on the CDSCP to the DOE in which again 10 this objection was highlighted, and finally, we have'this 11 workshop on alternative conceptual models in April of this 12 year which is, which was a follow-up to the draft point
()
13 papers.
14 If you turn to the next page now, I am providing you b
15 here with a working definition of the term conceptual model, t
16 primarily to help you understand NRC comments on the CDSCP.
17 DR. SHEWMON:
Let me go back to performance 18 allocation.
19 What I understood you to say is that performance j
20 allocation is what test we have to do to make it good enough, n.
21 to make our goal for this particular component.
22 It seems to me that there is implicit someplace 23 before that a decision of which components do we want to rely 24 on first?
And if I think of it as a tradeoff between studies
[}
25 of hydrology and studies of materials, you car. do as the l
HERITAGE REPORTING CORPORATION -- (202)628-4888
86 L
1 Swedes have done and said we will put-it in a package that I
2 isn't going to dissolve ever and we don't care much about 3
whether'or not there is water running around it in granite, or 4
you can go to the other extreme and we will put it out in the l
5 desert and we don't care much about what is around it as long
[
6.
as it doesn't oxidize at room temperature in the next 300 7
years because there'is no water running around or there will 8
be very little water running around, not enough to do any 9
harm.
10 Now you haven't said anything about where that 11 decision has been made, that you have said once that decision f
?
12 has been made, we will say how good something has to be.
}
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13 Where have I missed it?
14 HR. GALSON:
You have missed it because I have given 15 you a very brief summary of the performance allocation 16 process.
You are correct in saying that's one of the first a
17 steps in the process that needs to be carried out, that this 18 preliminary decision has to be made on which repository i
F 19 systems or sub-systems you intend to rely on, in order to meet
[
20 whatever the criteria in question is.
That is definitely an i
21 initial part, an initial decision that has to be made.
r 22 DR. SHEWHON:
And what chapter do I go to to find
[
t 23 that?
l l
24 HR. GALSON:
It is summarized for all the
}
l' 25 performance issues in Chapter 8.2.
It is kind of a lengthy
[
r HERITAGE REPORTING CORPORATION -- (202)628-4888 j
87 n
1 chapter which gives you--correct me, DOE representatives, if
()
f 2
I'm wrong about that, but I believe that's where it is 3
summarized for all the performance issues.
There is general 4
discussion of whatLperformance allocations, what the issues 5
hierarchy is, the issues resolution strategy in 8.1 in,- I 6
think primarily_it-is also even in a more general level in l
7 Chapter 8 or Section 8.0 I-should say.
l 8
DR. SHEWHON:
Thank you.
9 CHAIRMAN MOELLER:
Did you define a conceptual j
I 10 model?
11 DR. SHEWHON:
He was about to I think when I
[
12 interrupted him.
()
13 CHAIRMAN HOELLER:
I think Carson should come in at 14 that point, but I would like to know what it is, and it must 15 have a fence around it whereas I could visualize a ec ;eptual 16 model that covered everything in your mind.
It must have a I
17 fence.
There can be several conceptual models side by side.
[
l 18 HR. GALSON:
That is correct.
The working l
19 definition that was agreed to by the staff for the term
[
20 conceptual model is a pictorial and/or narrative description I
L 21 of the repository system or sub-system that is intended to j
22 represent one or more of the following--either relative l
9 23 components of a system and/or sub-system, or two, interactions 24 between various components and/or sub-systems and/or systems.
j 25 I have underlined for you the key part of the i
HERITAGE REPORTING CORPORATION -- (202)628-4888 f
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88 i
i definition.
It is basically a description of repository (s
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2 components or of interactions between those components.
3 If you would like, you may also think of a 6
1 4
conceptual model as a set of working hypotheses for whatever 5
the component or system or sub-system being discussed is.
6 The staff also has developed a definition of the l
7 term scenario.
There is often confusion between what a 8
scenario is and what a conceptual model is, and briefly a 9
scenario is defined as a counter sequence of a projected 10 course of action or events, and is applied to high-level waste
[
11 disposal.
This means actions or events that could lead to i
12 release and transport of radionuclides from the repository to f
()
13 the accessible environment.
John Trapp will be referring to t
14 this issue in a little more detail in his presentation, i
15 Are there any questions at this point?
Carson Mark 16 or--
L 3
l 17 DR. MARK:
No.
It is better to wait as you had 18 suggested earlier.
We might have something we can put our 19 teeth in as we don't yet.
t 20 CHAIRMAN HOELLER:
Okay.
Continue.
21 HR. GALSON:
If I can continue now, if you turn to j
22 the next page, I am asking the question here why are I
23 conceptual models important?
And first of all, conceptual j
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24 models form the basis for the predictive performance j
25 assessments of repository systems and sub-systems that are HF"ITAGE REPORTING CORPORATION -- (202)628-4888
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Lrequired by 10-CFR Part 60.
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-Secondly, as'you all know, the EPA standard i
3 implicitly requires"the development of scenarios in order to l
4
'show compliance with the release limits'therein for 10,000 l
l
.5
. years after disposal of the waste, so conceptual models must l
t i
6 be developed and confirmed.with reasonable assurance in order l
l 7
to calculate releases for all scenarios needed to show 8
compliance with the EPA standard.
9 Therefore, the staff considers that the SCP and t
10 performance allocation therein must consider a full range of j
11 alternative conceptual models or if you like, you can think of
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I 12 these as sets of alternative working hypotheses where i.()
13 uncertainty exists, and uncertainty can be said to exist in f
14 this instance where the existing data base for the site or the 15 repository element, whatever it is, does not lead to a single I
t 16 defensible conceptual model, l
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17 If you turn now to the next page--
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18 DR. STEINDLER:
Would you say that again?
[
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19 HR. GALSON:
Uncertainty in this particular 20 instance, in the senso of where it exists in performance, in l
21 how performance allocation should be done, can be said to l
1 22 exist where the existing data do not lead to a single i
i l
23 defensible conceptual model, where there is uncertainty, where l
l 24 there is still existing uncertainty as to which the correct
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j 25 conceptual model is.
For example, at the hydrologic system, l
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how does water flow through the site?
Is it primarily flowing
(_]y.
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through the matrix of the rock or is it primarily flowing I
3 through the fractures?
4 CHAIRMAN HOELLER:
Couldn't you have a model that 5
would account for both?
l 4
6 HR. GALSON:
You could.
{
7 CHAIRMAN HOELLER:
I guess what I don't understand, I
8 what you said, there is no single conceptual model.
There is 9
a range of them, and you want to hear about all of them, and 10 yet you define a conceptual model as applying to a single i
t t
11 system or a sub-system.
j f
12 I would think that if you got down small enough in.
()
13 sub-systems, there would only be about one model that could 14 describe how that tiny little piece could behave, i
10 MR. GALSON:
Let me give you a little more 16 explanation here.
I 17 A conceptual model--I have tried to get to this 18 point on the figure we just turned from.
Conceptual models
]
i 19 are going to form the base for predictive performance i
20 assessments, and in that sense, at some stage in the process, j
21 hopefully as early as possible, the conceptual model is going t
22 to have to be translated into some kind of mathematical i
l 23 description of whatever the system is, and that will have to i
24 be translated most likely into some kind of computer ecle for
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HERITAGE REPORTING CORPORATION -- (202)628-4888
91 1
you can-use that mode.1 to make predictions.
- 3(f 2
And I think the conceptual model has to be specified 3
in such a way that it is amenable to this mathematical 4
characterization and then to implementation in a computer 5
code.
I think that's something that is important to keep in 6
mind.
The more you consider, if you like, the more you think 7
your conceptual model is going to embrace, the more difficult 8
it is going to be-to actually come to the point where you can 9
develop a mathematical model for that, for that system.
10 CHAIRMAti MOELLER:
To help me now, and I read in the 11 SCP some of the m.terial on the models, and I gather that the 12 HYDROCOIN would be, is that a conceptual model?
What kind of
()
13 a model is it?
14 MR. GALSON:
HYDROCOIN?
HYDROCOIN is an 15 international effort designed to understand the uncertainty 16 associated with, primarily with computer codes that 17 individuals and different countries are using to model 18 systems.
19 CHAIRMAN MOELLER:
Right.
20 MR. GALSON:
It is prirarily hydrologic, and I think
'l perhaps radionuclied transport model.
i 22 CHAIRMAN MOELLER:
Is that a conceptual model?
23 MR. GALSON:
People will have, in order to come up 24 with these codes, I think people will have to have a
}
2L conceptual model of what they are trying to model.
There is a
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HERITAGE REPORTING CORPORATION -- (202)628-4888
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coordinating group.that-set up what the. boundary conditions on
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2 the model are, what the-initial conditions are, and then they 3
say to the participants take your model, presuming they have a 4
model that they can treat that system, take your model now and 5-predict.the, predict the performance of whatever you want to 6
- predict.
Let's say it is ground water travel time.
'And then 7
they compare the predictions of different models that the 8
people have, and in that rense, it is a verification exercise.
9 That's what the purpose of, one purpose of HYDROCOIN is.
They 10 specify the conceptual model.
11 CHAIRMAN MOELLER:
My presumption was if HYDROCOIN, 12 well, if--it is an international effort.
It is a cooperative
()
13 effort.
And therefore, if any model could be judged to be 14 acceptable worldwide by anyone, it must be HYDROCOIN.
15 DR. SHEWMON:
You are talking about a model it 16 sounds to me looks like a very large number of models used in 17 different countries.
18 MR. GALSON:
The problem here is HYDROCOIN specifies 19 hypothetical models if you like.
They are not real sites that 20 they are looking at.
They are hypothetical systems, greatly 21 simplified, one dimensional, and it is really just to test at 22 a very elementary level some of the codes that have been 23 developed.
24 MR. STABLEIN:
Excuse me.
This is King Stablein
}
25 again with the NRC.
HERITAGE REPORTING CORPORATION -- (202)628-4888
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We are dealing-here with a very difficult concept, S
q T_/
2 the alternative conceptual'models, and that's why we have two 3
presentations on it today.
Before we get to:the objection 4-which Dan is drawing near to, we think that to, in an effort 0
5 to communicate better what a conceptual model is and what we 6
are so concerned about, I would like to bring John Trapp's 7
presentation on, let him cover.this so you can provide the' 8
meat that was being called for before, and then have Dan come 9
back and give the objection in light of some of the material 10 that John Trapp has.
It may clarify this a little bit.
There 11-is no point in moving on to the objection without our setting 12 the stage properly for everyone to understand this.
()
13 CHAIRMAN.MOELLER:
I think that could be helpful.
I' L
14 guess at the moment--well, I know at the moment I am confused.
15 I thought we were going to model the repository, and by that I-16 realize we would model systems and sub-systems, and sit 17 through some sort of a process, those models would be 18 validated or at least there would be general agreement th a t-19 they gave pretty good predictions, you know, so people accept l
20 them and then would you apply them, but I know here we are 21 going to have conceptual models to evaluate the models or 22 something.
23 DR. SHEWHON:
To base them on.
24 CHAIRMAN MOELLER:
Okay.
I could understand that.
25 MR. TRAPP:
I think one of the things that might be l
HERITAGE REPORTING CORPORATION -- (202)628-4888
. - ~
94
-1 worthwhile, I believe it was Winston Churchill who made a
/
\\'
i 2
statement that the.American and British are one people m
3 separated by a common language.
I think that's the point we 4
are in right now.
5 My name is John Trapp.
I am not in the Compliance 6
Demonstration Section, and I am in the Technical Review 7
Branch.
One of the functions that I am supposed to serve is 8
kind of aa a liaison or coordinator within the Technical 9
Review-Bianch and basically talk to the Compliance 10 Demonstration Section.
11 Now as we started the basic review of the CDSCP, we 12 came up with a series of types of concerns, types of
()
13 questions, that all seemed to fall in a general, a general 14 area that somehow we decided to lump as quote, concerns with 15 conceptual model.
Now it seemed 2'ke a very logical thing to 16 do because everybody seemed to understand what a conceptual 17 model was.
c 18 Well, we started doing a little bit more talking in 19 inhouse and while we were talking in-heuse, one of the 20 problems we had is we realized we are kind of talking by une 21 another.
We weren't discussing the technical concerns.
We 22 reemed to be discussing semantics.
To attenpt to alleviate 23 part of this problem, we went back and said let's make sure 24 that we have got our definition straight, and we came up with 25 this definition of conceptual model which Dan has presented.
HERITAGE REPORTING CORPORATION -- (202)528-4088
4 4
95 1
Previously we came up with this definition of rn
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~2
' scenario.
Now in one form or the other these have been-3
'precented in previous NRC documents so we felt fairly good 4-with these definit' ion.
5 As we were going through this, however, we 6
discovered that we still had problems.
We were not resclving 7
the concern.
We romehow seem to be dividing ourselves into 8
two camps.
Is that in focus from back there?
9 DR. SHEWMON:
The top part isn't.
The bottom part 10 is.
11 CHAIRMAN MOELLER:
That's good.
12 MR. TRAPP:
Basically, you could break it down into
()
13 the group that says hey, there is only one conceptual model at 14 the site.
When va are talking about anything else, everything 15 else is a boundary condition change.
16 You have got the other people that are sitting 17 saying well, conceptual model should be synonomous with the 18 term multiple working hypothesis.
In general, most of the 19 people in the Technical Review Branch were talking about it 20 from that aspect.
Most of the people in the Compliance 21 Demonstration were talking from this aspect.
We started and 22 ended up with some relatively interesting discussions which 23 had absolutely nothing to do with the subject, and it is q
)
really if we are talking about this change, are we changing to 24 l
25 a new model?
Are we changing to a new boundary condition?
HERITAGE REPORTING CORPORATION -- (203)628-4888
96 1
How many changes can you have to a model before it is a new f
2 model, or the whole thing?
And this one was really a touchy l
3 one--can there even be a conceptual model for a scenario and 4
how does a scenario fit in the whole sequence?
5 As we were getting ready for the meeting with DOE on 6
alternative conceptual model, we really wanted to make sure 7
that as we went through this meeting, they understood what our 8
concern was and we weren't lost in terminology.
9 (Slide) 10 MR. TRAPP:
So in simplest form, I think this 11 underlays the basic concern that the conceptual model comment 12 is dealing with.
The staff is concerned that the program of
()
13 investigations as presented in the CDSCP may not detect 14 relevant features present, relevant processes that we have 15 both to worry about and events which may have acted, are 16 acting, or could act on the repository system.
17 We were concerned that the program may have been 18 biased to look at what DOE knew was out there without looking 19 at things that may be out there, and as such, they would not 20 determine some of these feature process events which could be 21 important.
l 22 To put this into a regulatory standpoint, one of my 23 favorite sections of th'. rule of Part 60 is 10 CFT 6122A.
Now 24 when you talk to the lawyers, basically they will tell you
/ }
25 this part of the Part 60 is nothing more than a redundancy to HERITAGE REFORTING CORPORATION -- (202)628-4888
97 1
other parts of the rule that have to be followed under 2-licensing, and I agree with them.
The thing is that I don't 3
know any other place in Part 60 where it so clearly states 4
what has to be accomplished at the'end of site 5
characterization.
6 DOE must demonstrate potential adverse conditions 7
have been adequately investigated, including the extent to 8
which condition may be present still undetected.
If you go 9
back to, say to any hearing that you have had on any nuclear 10 power plant, an applicant would not come in and make a 11 statement to the effect there are to faults at the site.
He 12 would be shot down totally, and rightfully so.
He would make
([
13 a statement that according to our investigations, we have not 14 detected any faults at the site, and if faults are present, 15 they cannot have a displacement greater than X amount, and 16 this is based on the resolution of our geophysics, our boring, 17 our trenching, all the regional work.
18 We expect DOE when they are coming in on those 19 studies on the repository to use similar logic.
In addition, l
20 DOE must take a mok at these adverse conditions and make sure l
they are adequately investigated using the assumptions l-21 that l
22 which will not underestimate the effects.
23 Very simply, if you have got some parameter that you l
24 are dealing with, say the range in this parameter goes from 10
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25 to 20, 10 is good, 20 is bad, if DOE is making their case on HERITAGE REPORTING CORPORATION -- (202)628-4888
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o 98 10, it is really not going to fly during the licensing
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process.
If the parameter goes up to 20, they can't make 3
their case during the investigations, they better focus some 4
of their investigation on bringing this parameter value down 5
or proving the parameter value is lower so they can run this 6
thing through. Licensing and meet the performance objective.
7 After you go through these, then you have'got to
'8 show the last things, basically yes, it is not significant.
9 In other words, you have values that are less than the 10 performance objectives or.the requirements'of the rule, or-11 they--you may be talking about ground water travel time that 12 say is a little bit faster than you want.
If you have got
(
13 geochemical retardation which is much greater, you can 14 compensate-for it, or the condition can be remedied.
15 Now if you go into specific comments that were made 16 by the staff,-we can start seeing the flavor of.different 17 types of concerns.
18 (Slide) 19 MR. TRAPP:
Now these comments were simply picked to e
20 show that the tyoes of concerns that we have got range 21 throughout the SCP.
I could have picked out another 20 in 22 other areas, but I just picked out representative ones.
23 For instance, one of the concerns we have is on
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24 timing.
If you take a look at this comment, one of the 25 concerns that is raised in this comment is that some of these HERITAGE REPORTING CORPORATION -- (202)628-4888 Y
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tests are not being proposed to be conducted early in the 2
program.
The staff' felt that in this case, maybe if theso
.3
' tests were conducted early in the program, it would help 4
better direct the program.
5 (Slide) 6 DR. SHEWMON:
Sir, to go back to that other one,,one 7
of the fundamental questions at least from tha waste package 8
viewpoint is whether the water that comes into the surface 9
occasionally runs through this formation like the drain of the 10 second flush toilet, or whether it stays there in contact with 4
11 the container.
12 And if I look at the previous slide of how you know
()
13 if you don't know, does it make a difference if it doesn't 14 know?
Is that, how the water travels through here, part of 15 what this thing is talking about?
16 MR. TRAPP:
This specific comment wasn't directed 17 exactly at that, but the concerns that you raised are raised 18 in the other comments, yes.
What is the resident time around 19 the package?
How much is the flux distributed through the 20 mound?
These types of comments are very directly raised An 21 all our comments.
22 DR. SHEWMON:
Thank you.
Is "characterizatic" a new 23 word that I haven't seen, or is that a spelling error?
24 MR. TRAPP:
I probably typed this and my typing is
}
25 known to be tremendously erroneous at times!
HERITAGE REPORTING CORPORATION -- (202)628-4888
100 1
DR. SHEWHON:
I wonder if it was in your spell f'\\ --
-(_/.
2 checker now and I should put it in minel 3
MR. TRAPP:
I-wouldn't recommend you put it in.
The 4
previous one was in hydrology.
Here is another comment that 5
was hydrology, and the concern here was that the boundary 6
conditions that'need to be analyzed and characterized did not 7
appear to be totally covered.
8 Like I said, if you have got specific technical 9
concerns, most of these will be raised or better covered on 10 these technical concerns here when the geologists, 11 hydrologists, et cetera, are talking about their comments 12 Bring this out--here is one that was raised Dy the
()
13 geochemists.
Talking about the importance of kinetics, et 14 cetera; the main problem nere was that, the concern that DOE 15 may not be recognizing that the effect of gamma radiation or 16 the products of gamma radiation may last a lot longer than the 17 actual gamma radiation field.
As such, these products, et 18
_ cetera, need to be carried and discussed in their analysis.
19 If we take a look at pre-closure tectonic, rock 20 tectonics, et cetera, one of the concerns, and this was one 21 that is going to come out a lot all the way through the 22 various staff presentations, is the integration of data, aad 23 in addition, on the integration of data, there is quite a few 24 concerns that fall right out of this that says you are doing a
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25 bunch of investigations on the specific fault, for instance, HERITAGE REPORTING CORPORATION -- (202)628-4888
101 1
but are you doing investigations which will detect the other
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faults in the area or the like?
3 (Slide)-
'4 MR. TRAPP:
There is'one that was in climatology p
5 talking about paleoclimatology.
The comment it makes is 6
~relatively self-explanatory.
There are another series of 7
theories which didn't appear to be discussed and considered 8
while they were going through the planning for site 9
characterization.
10 DR. STEINDLER:
In that last one, for example, if 11 they had, if the Department of Energy had considered or 12 mentioned every literature cited theory, and had said the (f
13 following 35'we have rejected because they are not applicable, 14 valid, et cetera, but we are picking on number 36, then you 15 would have been happy?
16 MR. TRAPP:
Yes.
17 DR. STEINDLER:
Regardless of whether or not that 18 rejection of the 35 could be clearly demonstrated in the 19 document?
20 MR. TRAPP:
You are right.
The rejection of the 35 21 would have to be somehow demonstrated, but if they could show 22 how they rejected or 'he basis of rejection--
23 DR. STEINDLER:
What you were looking for is in this
/~T 24 case, and I an exaggerating obviously because I feel I know
'V 25 nothing about it, but you were, what you were really looking HERITAGE REPORTING CORPORATION -- (202)628-4888
~ -_...
102 1
'for is a discussion of everything that is in the current 2
literature and an analysis of its applicability to the problem 3
at hand?
4-MR. TRAPP:
Yes.
5 D R ~. STEINDLER:
Don't you expect if you had gotten 6
that, that set of seven volumes would have grown to 70?
7 MR. TRAPP:
Not quite, and as we get to the--
8 DR. STEINDLER:
If you expect the same thing from 9
all of the model configurations that are likely to be 10 involved, that might be more than a modest undertaking.
11 MR. TRAPP:
It is going to require some expansion, 12 yes, but we are not asking for every one.
We are asking for I'T 13 the one that is, may be significant and can be supported, at V-14 least not rejected, by the present data base, so if you go 15 through preliminary performance analysis, and you go through 16 the preliminary performance allocation, you say you are going 17 to count on some feature, and you are going to count very 18 heavily on some feature, then you better state what you know 19
.about that feature, what is the range of significant 20 parameters that you are dealing with?
How can these affect my 21 analysis, and what do I have to do under the site 22 characterization program?
23 Now Yucca Mountain, for instance, one of the things 24 that is going to be important is the potential of 25 paleoclimate, return to paleoclimate greatly increasing the i
l HERITAGE REPORTING CORPORATION -- (202)628-4888
103 1
amount of water that may go through the system.
That becomes kq
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2 relatively important to have really considered this in detail.
3 This one.is relatively, relatively self-explanatory.
4 We are in natural resources.
As we go down here,.the main 5
thrust of this comment gets right down to here, the 6
consideration of potential natural resources and natural 7
resource models, again not considering all the different ways, 8
especially with the, lots of the latter or late literature 9
that we have got on the site and in the area which shows that 10 some of the deposits that are presently being discovered in 11 Nevada and are looking like they are quite good economic 12 deposits, that the theory of the development of these deposits
(~))
13 has not been fully explained and brought into the Yucca 14 Mountain site.
15 DR. SHEWHON:
What do you assume in that or allow 16 DOE to assume abott the intelligence of these geologists the 17 thousand years from now who are smart enough to see things of 18 value that we don't?
That they are also dumb enough not to l
19 know radiation when they see it or what?
20 MR. TRAPP:
You are getting into an area which there 21 could be quite a bit of debate.
You basically have to assume 22 that you lose the record, but you have a civilization which 23 has got approximately the same knowledge base that we do.
In 24 other wor ds, you have forgotten about the site.
Nobody knows
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25 it is there, but people still have the ability to detect gamma HERITAGE REPORTING CORPORATION -- (202)628-4888
104-1 radiation.
They have the ability to drill holes, et cetera,
/~T is) 2 this type of thing, so civilization is about the same, but
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3 everybody had amnesia.
4 HR. BROWNING:
I might point out this is an area 5
where our regulation had a kind of a broad conceptual thing 4
6 that sounded like it made sense at the time we wrote the 7
regulation.
8 Then when you start trying to deal with it on a case 9
specific basis, you need to start narrowing down what your 10 range of possibilities are.
That's the process we refer to as 11 our proactive approach and trying to come to regulatory guides 12 or rule changes, to start narrowing down the degree of
()
13 flexibility because you don't want to get into a licensing 14 hearing and is that right, argue that kind of question.
You 15 like to put that to bed early.
And one of our proactive 16 projects for trying to narrow this process down is that very 17 question.
How do you deal with this question of natural 18 resources?
19 We may very well conclude that you can't do it and 20 we may need a law change.
I mean that's the flexibility of 21 this whole process.
The thing driving that particular 22 requirement, for exanple, is an EPA requirement that says you 23 have got to presume you lose institutional control a hundred 24 years after the site closes.
A 1.ot of people think that 25 doesn't make sense, but that's what the existing regulatory HERITAGE REPORTING CORPORATION -- (202)628-4888
105 1
framework _is, and it is driving this kind of requirerent and 1
(/
2 those kinds of analyses.
3 If you can't work it on a pragmatic basis that you 4
can get a technical consensus, then'you have got to go to what 5-is it that is driving this and is there something in the 6
regulatory framework of either EPA's or ours that is laying 7
out a process that the technical community isn't going to be 8
able to deal with?
And get a legitimate technical consensus, 9
but I think our first step is try to lay out what we think is 10 a reason, rational pragmatic way to deal with that problem, 11 and see if we can solve it that way before we go to any more 12 extreme bases like changing our regulation or getting Congress
(')
13 to say we are going to have perpetual maintenance at the 14 Nevada site for other reasons completely beyond the 15 repository, you know, as a matter of law, just don't worry 16 about that, guys.
That's the flexibility with which this 17 dialectic on how these issues are going to come to closure is, 18 and it is not something we are going to resolve now, not 19 comething we are going to resolve really by the time the SCP 20 comes in.
21 It is going to be an ongoing process, and if it 22 doesn't come at closure, we have got to highlight that.
It is 23 not coming to closure, we have got something we just can't
~'N 24 deal with.
And what is the option?
I don't want to presume (d
25 how this one is going to come out.
I just wanted to give you HERITAGE REPORTING CORPORATION -- (202)628-4888
106 1
a flavor for how broad', and trying to come to. grips with some w)
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2
'of these technical regulatory kind of requirements, that it is 3
not something that is going to be easy and it may turn out not 4
to be workable in a technical arena and you have got to go 5
back to the political arena.
6 DR. SHEWHON:
Some of us resen't the thought'our 7
great grandchildren'are going to be a lot more stupid than we 8
are.
9 MR. BROWNING:
You have got to put in perspective is 10 there anything potentially there that is going to be more 11 valuable than the spent fuel that we are putting there?
The 12 way the requirements are written,'you don't take that into
()
13 account.
Just take a look at what is there before you go hone 14 in on that site, and the idea was don't pick a site that has 15 something under it that 20, 30 years from now somebody is 16 going to want to go mine it, but then you can get outside the 17 normal pragmatism as you start getting into these kind of 18 questions.
That has to be narrowed down through our process 19 of either coming up with the reg guide or the rule or 20 something, try to eliminate that kind of argument from 21 distracting everybody's attention to the important issues that 22 will b addressed to the licensing bureau.
We are not there 23 yet.
24 MR. TRAPP:
Okay.
To continue on, if we take a 25 look, for instance, again in another area, we are talking HERITAGE REPORTING CORPORATION -- (202)628-4888
107-1 about shafts and bore holes, seals, the basic. comment that we
(
2 are dealing with~here that brings out the point I am trying to 3
get across is that when they are looking at the performance on 4
?.he design goals for the sealing system, it doesn't appear 5
they had looked at a complete set of what we considered 6
relevant anticipated process and events and unanticipated 7
processes and events.
8 (Slide) 9 MR. TRAPP:
This also showed up in the area of the 10 waste package, and the waste package, it is barically a 11 requirement that you are designing assuming anticipated 12 processes and events, and it didn't appear that their design
'( )
13 and perf ormance goals wher. they were dealing with the waste 14 package considered a complete range of anticipated process and 15 events.
16 (Slide) t 17 MR. TRAF?:
Just going back into ground water travel 18 time, the point that this comment was mainly trying to get 19 across was the fact that while you are dealing with this 20 ccaceptual model and whatever you want to call these terms, 21 you need some type of systematic way of going through this.
22 You need to I think Jeff calls it discratize the whole system.
23 You have got the conceptual model of the site.
How, for 24 instance, do the structures fit into, in each individual
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25 structure?
How does the porosity fit?
How are you going to HERITAGE REPORTING CORPORATION -- (202)628-4888
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work the various components into getting the total conceptual
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2 model on this site together, and how are you going to manage 3
this whole study?
4 And then here is another one which is basically 5-saying it didn't look like they had looked at all the 6
significant scenario classes that we needed to, we felt'needed tNisstage.
7 to be at least addressed at 8
(Slide) 9 MR. TRAPP:
If we kind of put this into a cartoon 10 form, what we are dealing with is we have got a real world out 11
.there which is Yucca Mountain.
There is no way possible that 12 DOE or anybody else is ever going to.be able to tell you
()
13 everything that you know about Yucca. Mountain.
There is a I
14 filter there that is never going to come through because it is 15 either impossible or impractical to get this data base, but 16 there is a certain amount of data right now.
17 From this data, you have got to sit down and sit and 18 say okay, what are the'important elements, et cetera, we are 19 dealing with, and what is the hypothesis or model as to how 20 this thing is going to be operating?
What is the range, 21 especially when we are talking about the significant ones?
f 22 From this, as you have got the range, you can go 23 through your mathematical assessments, mathematical model, and l
24 say okay, does it make a difference when I am doing
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i 25 performance allocation or not?
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l HERITAGE REPORTING CORPORATION -- (202)628-4888
109 1
If it'does make a difference,-I am going to have to P
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go back, get-the data for this, that basically allows me to 3.
find out if-I can meet this, and.this data may drive me back 4-into this area where.I change my'model because I have been 5-totally wrong to start with, or I may be able to narrow this 6
model as I get a little bit smarter along the line and make'a 7
better guess, estimate as to what is coming on out of this 8
system.
9 Again, eventually we have got to get through the 10 performance assessment, through the mathematical modeling and 11 show we have met the performance objectivea, primarily 40 CFR 12 191 EPA standard.
i
^ ()
13 Now the question was raised earlier, what do we 14 really expect from the DOE?
15 (Slide) 16 MR. TRAPP:
We talked a little bit about the meeting 17 we had on alternative conceptual model.
I honestly think it 18 as one of the best, I know it is one of the best meetings I 19 have ever had or participated with.
20 MR. STABLEIN:
Could we put Dan back on now to 21 present the objection and let this come after that?
4 22 MR. TRAPP:
No problem.
23 MR, STABLEIN:
I think that would be the best flow, 24 make sure everyone is on board with conceptual models, then
}
25 the objection, and then move into this material.
HERITAGE REPORTING CORPORATION -- (202)628-4888
110 1
MR. BROWNING:
Could I ask if we are starting to get 7
2-
- an understanding that Dr. Marks was-looking for?
(_/
3 DR. MARK:
Yes.
Look, this is just' great.
I think 4
I understand everything if you would pull out that goofy 5
phrase conceptual model and just say you will have a model and 6
you haven't made it wide enough and you haven't considered 7
this, but you should consider in it,-and you should, do need 8
to add a way of handling travel time for ground water because 9
you didn't have it in before, but it is just a model they are 10 working on and they shouldn't be working on three of them at 11 once.
Should just be working on the different spigots, 12 putting in things, and until they find they don't work, then
()
13 take them out.
14 But it sounded to me in reading the latter when they 15 start the new program they ought to have some new things in 16 which water flows uphill instead of downhill.
17 MR. YOUNGBLOOD:
That has been spoken about.
18 MR. BROWNING:
There does happen to be a report that 19 says the ground water is going to move up into the process.
20 DR. SHEWHON:
I hope that is in your handout!
21 MR. GALSON:
That's why I am not using the vugraphs, 22 because I know these aren't very visible at the back of the 23 room.
24 Turning back to the handout that I gave you
{}
25 initially, the NRC staff's objection on alternative conceptual HERITAGE REPORTING CORPORATION -- (202)628-4888
111.
1
- models' consists of a series of four' statements that really are
(')T 2
'together a statement of the concern.
3 First of all, the performance allocation process in 4
the CDSCP does not directly address the investigations that 5'
would be needed to. characterize the site with respect to the 6
full range of alternative conceptual models and associated 7
boundary conditions, and you are more than welcome to throw 8
'out.that terminology and use your own understanding of what it 9
means--that are consistent with the existing data; and 10 therefore, all the investigations tha' are significant.to the 11 characterization of the site are not necessarily considered.
12 I would like to point out at this point that the NRC
()
13 staff have not identified any extremely critical 14 investigations that are lacking in the CDSCP.
Rather I think 15 from your--I don't know if you have got this picture of how P
16 the CDSCP is set up, but Chapters 1 througn 7 are basically a 17 description of what is known about the site, and conceptual, 18 conceptual model of the site and of the waste package and 19 repository are developed in those chapters,.and it more or i
20 less follows what was in the environmental assessment.
That 21 wasn't the focus of the staff's review.
r r
22 The staff focused on Chapter 8 which is concerned l
t 23 with the site characterization investigations.
They are laid t
24 out by technical area in Chapter 8, and in addition, the
)
25 performance allocation which is tied into the key issues which L
l HERITAGE REPORTING CORPORATION -- (202)628-4888
112 1
are in turn tied into the NRC regulatory criteria.
That's s) 2 also laid out in Chapter 8,~and so what I can say here is that 3
it doesn't appear that the performance allocation in Chapter 4
8--let me change this--performance allocation developed in 5
Chapter 8 appears to have relied on the whole primarily on a 6
preferred. conceptual, preferred conceptual model, whether it 7
was of the site or of whatever the process being considered 8
is.
9 And so the linkage between what is laid out in 10 Chapter 8 and what is laid out in Chapters 1 through 7 is 11 inadequate basically.
12 On the other hand, elsewhere in Chapter 8, what
()
13 appears to be a reasonably complete array of investigations in 14 most of the technical areas have been described so what we 15 have here may be only a documentation problem.
We don't know 16 that, though.
The point is that the documentation ir r i t.. ' ':e 17 in the CDSCP for the staff to be able to evaluate in any kind 18 of systematic way the adequacy of the characterization 19 program.
20 John Trapp provided you with a number of examples, 21 so if I turn now to the central point--
22 DR. STEINDLER:
Excuse me.
In your first bullet, 23 the second line, the word full range, the words full range
(~T 24 appear.
O 25 I assume that those words were chosen carefully so HERITAGE REPORTING CORPORATION -- (202)62..-4888
113 1
that the term full is precisely what you mean?
Is that g
- (,/
2 correct?
3-MR. GALSON:
I think again we-can debate words here, 4
but I would say a dictionary definition of full means that you 5
have got, you have laid out everything that could possibly be 6
considered.
I don't think that's necessary.
7 What we are looking for is a range of conceptual 8
models that are consistent with existing uncertainty about the 9
site, or a range of data.
10 MR. COPLAN:
Seth Coplan, Compliance Demonstration 11 Section--you are right, Dr. Steindler.
The words were very 12 carefully chosen, and the intent was to pick up on the concern
()
13 that you raised earlier of if they, if DOE had to address say 14 35 paleoclimate models, each one in some kind of gory detail, 15 and satisfy us on each and every one of them that we have 16 taken them into account in the program, that that document 17 would fill the room rather than just the table.
18 What we were trying to get at was that we wanted 19 them to address a range of conceptualizations of the site and 20 the design that tends to encompass what, what the 21 possibilities were, not necessarily address each one in 22 detail.
23 DR. MAXWELL:
May I ask a question?
How do you 24 determine the range available?
As a geologist, I am very much 25 uncertain about how you go about that.
HERITAGE REPORTING CORPORATION -- (202)628-4888
114 1
MR. COPLAN:
In geology, I think that may be a
)
2 difficult question to answer.
Let me take a crack at it and I 3
will defer to' John Trapp, who is a geologist, but I think you 4
know what you would be figuring is that any investigatory 5
process like site characterization is going to involve a 6
certain amount of iteration, that there is some data that you 7
have.
8 Now you make some inferences about the site based on 9
the data that you have.
You have some sense of what the 10 uncertainty in those data are and what possibilities the 11 uncertainty still admits, and frame your program around that, 12 and as you get farther into it, I think you will find that
-(])
13 maybe you are going to need to make some adjustments one way 14 or the other.
15 Our thought was to try to encompass as much of what 16 might be the case with the site in the program of 17 investigations as we can.
18 Do you want to add anything to that?
19 HR. TRAPP:
I think about the, I think about the 20 only thing I would like to add to that is very honestly, the 21 only way that you are going to get at this is through 22 professional judgment.
You can talk about all these things l
23 and everything that you want, but it is going to take the i
- 4 professionals in the field to be able to discuss the various I
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25 hypotheses, narrow these down to those which are reasonabic to i
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HERITAGE REPORTING CORPORATION -- (202)628-4888 l
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be considered to go from that point.
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2 DR. MAXWELL:
But will these be arrived at through i
3 discussions between you and your staff and DOE or by.the USGS 4
or as a regulator?
As a concept, I can understand it.
As a 5
regulation, it frightens the hell out of me.
I don't see how 6
You can go about it.
7 MR. TRAPP:
Very honestly, in this program, as 8
political as the program is, it is' basically a discussion 9
between almost everybody and their brother.
In reality, when 10 you carry it into how it works in the practice, the meetingr.
11 like the ones that we did have in Nevada on alternative 12 conceptual model where we had DOE, USGS with many other
()
13 subcontractors sitting there, the investigators that were 14 concerned with the specific concerns we had raised, the NRC 15 staff, the state and the state statf, we had a discussion 16 which really covered just about all the major parties that 17 would have input into this program.
i 18 DR. MAXWELL:
How do you eliminate the fringe t
19 element on here?
l 20 MR. TRAPP:
I'm sorry.
I'm not sure exactly how you l
21 eliminate that except by discussion, and judgment.
22 DR. MAXWELL:
Okay.
23
!!R. GALSON:
Okay.
If I car. return to this 24 objection, I think you should particularly take note of this
}
25 third point nere because it is the point really that makes 1
HERITAGE REPORTING CORPORATION -- (202)628-4888
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116 1
this' concern an objection as opposed to a comment, r%(..)
2 The consequence of these first two bullets that I 3
described to you is that it cannot be determined whether 4-conducting one inves*.igation would interfere with, possibly to 5-the point of precluding that and should really be-underlined 6
in your minds, conducting another investigation needed to 7
obtain information for licensing.
8 This is a, potentially a real concern.
It was a 9
concern at the BWIP site where a large-scale hydrologic pump i
10
-test was going to be conducted, and if that test wasn't 11 conducted prior to sink of the shaft, the results obtained 12 from that test would have been virtually meaningless.
That
'( )
13 example isn't necessarily applicable to the Yucca Mountain l
14 site, but it is an example of the kind of thing that can occur 15 if the full range of investigations needed to investigate the l
16 site aren't laid out at the start of the characterization i
17 program.
18 And another concern is that the program may favor 19 providing data, confirm the preferred model and boundary 20 conditions, rather than the data needed to determine what the 21 preferred model and boundary conditions should be.
t 22 I think John Trapp touched upon that in his 23 presentation.
l 7
24 DR. STEINDLER:
If you had to choose between those
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25 last two bullets as the more important driving force to raise HERITAGE REPORTING CORPORATION -- (202)628-4888 j
-117 1
these concerns to the objection level, which would you pick?
O s/
2 MR. GALSON:
Well, I thin): if you look,.if you look 3
at'the definition of objection, this is the concern that 4
raised it to an objection.
t 5
DR..SHEWMON:
Objection is you can't proceed.
6 HR. GALSON:
Okay.
Perhaps I will leave that on 7
there.
Briefly on the next page, the next page--
l 8
(Slide) 9 MR. GALSON:
These are the recommendations that the 10 staff have provided to the DOE in this point paper.
These l
l 11 have been slightly modified from the copy that was distributed 12 to you with preliminary draft point papers.
()
13 First, the staff should clearly identify--excuse me.
14 First, the DOE should clearly identify a full range of 15 alternative conceptual model and associated boundary 16 conditions in the context of Chapter 8 and the performance 17 allocation process in that chapter.
18 We have discussed what he we mean by full range of 19 alternative conceptual models just a moment ago.
20 Secondly, the DOE should identify a full array of 21 information needs and associated investigations in 22 consideration of these conceptual models, that is, the 23 information needs and investigations needed to study those 24 models.
The investigations should be integrated across all
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25 disciplines, that that point was touched upon as well by an HERITAGE REPORTING CORPORATION -- (202)628-4888 l
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earlier speaker, and I know it will be brought up again.
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The DOE should determine which investigations would 2
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4 important to the characterization program and they should be t,
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5 sequenced appropriately.
l l
6 The DOE should specify investigations and 7
information needs through performance allocation that will 8
distinguish between those alternative conceptual models that l
9 have been identified up here.
10 And finally, the DOE should accord high priority to 11 investigations having the greatest potential for resolving 12 issues that could lead either to the site being considered
.()
13 unlicencable, or to substantial changes in the 14 charactorization program, but only insofar as conducting those 15 investigations would not significantly interfere with or 16 preclude conducting some other investigation that was 17 important to licensing.
18 I think at this point, it would be appropriate to 19 turn to the conclusions of the work, the workshop we had, and 20 John, do you want to present them, or do you want me to?
21 MR. TRAPP:
I'm not sure it makes too much of a i
22 difference.
23 MR. GALSUN:
This also now is part of the objection 24 that we are sending to DOE in the final point papers.
{
25 DR. SHEWMON:
That one we don't have.
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l HERITAGE REPORTING CORPORATION -- (202)628-4888
119 1
MR. GALSON:
That's in John's
,J 2
MR. TRAPP:
That is the very last slide in the 3
presentatica I have.
4 CHAIRMAN MOELLER:
And this is t
'/NRC workshop?
5 MR. TRAPP:
This basicelly was one of the major, one 6
of the major, this was the major point that came out of the 7
DOE /NRC workshop on a'.ternative conceptual raodels.
8 In the comments--not the comment--the objection that 9
you have got in the draft point papers, one of the very 10 significant changes to this objection is at the very end.
11 What it is basically saying is okay, we have talked about 12 these alternctive conceptual models, we have raised the f
13 objection.
How can we solve it?
d 14 A way to solve it, and this was talked through in 15 the meeting, it really was one that DOE themselves brought up 16 very soon in the meeting as a way of trying to get across our 17 concern, is to put certain information in e. tabular form so 18 that we can underste.nd exa.tly what is going on with their 19 program and then make a judgment on tLe program.
20 What do we want?
Well, we want a deceription of 21 what do you think that you know about the site, about the present and future conditions of the site?
This is _ath the natural and the engineered systems, i
At What is the uncertainty and what assumptions did you iA have to make to detiac what you knew about the site?
As you HERITAGE REPORTING CORPORATIO*i -- (202)628-4888
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120 AV 1
are coming _through here, what alternatives-'could you have on l
2 these assumptions and what is the significance?
If there is 3
really no significance to any of these thiugs, it is not that 4
important.
5 If you have got significant differences, TJgnificant 6
ranges, et cetera, okay, now we have talked about the ranges 7-and rodels, the different concern, the different hypotheses.
8'
'How are you going to test this?
How are you going to make 9
sure that these things that have been determined significant 10 through your performance allocation because you have *aken-11' some credit for some certain part of the, part of the system 12 and you have determined that some component of the system is
()
13 sensitive, how are you going to test this?-
14 How are you going to make sure that you have a good 15 idea of what is happening with this portion of the site or 16 this portion of the engineered system, the waste package, et 17 cetera, whatever we are talking about?
18 And finally, prioritize these things.
How do they 19 fit together?
Could they intar:9re with other tests?
How can on they help us resolve key issues.trd this type of thing?
I 21 This type of cable we feel will resolvo our concerns 22 or at least be able for us to address the points where our 23 concerns actually exist.
It's not going to be that easy i
24 because by the time you go through the various disciolines and 25 integrate it, it is a pretty large job fcr DOE.
DOE knows it, l
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HERITAGE REPORTING CORPORATION -- (202)628-4888 l
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121 1-But weg feel-itLis one that is needed.
It really can be put 2
together in a series of different ways.
We are saying Chapter-3' 8.
Yod may come out on the back of say Chapter 1 and say,here 4
.is the important things-in geology, arid then carry that into 5
Chapter 8 and in Chapter 8 say okay, here is how it affects 6
different-things.
There are different ways things can-be
'7 brought across, but here is one acceptable way *. hat appears to 8
be also acceptable to DOE where we can get resolution on this 9
issue.
10 Are there--
11 CHAIRMAN MOELLER:
Any more questions or commentc on y
12 this subject?
I'm not sure it is totally laid to rest, but
()
13 certainly many questions have been concluded.
Many questions 14 have been clarified.
15 MR. TRAPP:
It is comi.1g up on noon.
I am sure that 16 might have something to do vith it, toc!
i 17 CHAIRMAN MOELLER:
Okay.
We are a little bit past 18 noon.
We are one presentation behind.
What is the--does the 19 staff have any druthers about breaking now or going ahead and i
20 hearing the next presentati t?
If there is no objection, I i
21-would just as soon break now.
Is trere any problem with that?
[
22 MR. BROWNING:
I'm sorry?
23 CHAIRMAN MOELLER:
Is ic okay to break now for 24 lunch?
We are one presentation behind.
I 25 MR. BROWNING:
Sure.
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CHAIRMAN HOELLER:
Okay.
Let's take a lunch break, j
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come back at 1:10.
l-3 (Whereupon, at 12:10 p.m.,
the' meeting was recessed, l-4 to reconvene at 1:10 p.m.
the same day.)
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HERITAGE REPORTING COT PORATION -- (202)628-4888 i- -
1 CERTIFICATE
(}
2 3
This is to certify that the attached proceedings before the 4
United States Nuclear Regulatory Commission in the matter of:
5 Names ACRS--Subcommit. tee on Waste Management 6
7 Docket Number 8
Places Washington, D C, 9
Date:
April 28, 1988 10 were hel1 as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the transcript is a O
1s erme and accurate record of the fere,eine ore edines.
16
/S/
b/
Y 17 (Signature typed): Catherine S, Boyd 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
.6 O
O O
I CONCEPTUAL MODEL A PICTORIAL AND/OR NARRATIVE DESCRIPTION OF THE j
REPOSITORY SYSTEM OR SUBSYSTEM THAT IS INTENDED TO FEPRESENT ONE OR MORE OF THE FOLE.OWING:
l
- 1. RELEVANT COMPONENTS OF A SYSTEM AND/OR SUBSYSTEM 1
i
- 2. INTERACTICNS BET *NEEN THE VARIOUS COMPONENTS AND/OR SUBSYSTEMS AND/OR SYSTEMS I
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SCENARIO AN ACCOUNT OR SEQUENCE OF A PROJECTED COURSE OF j
ACTIONS OR EVENTS.
(HLW GLOSSARY AND NUREG 0906)
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d THERE IS ONLY ONE CONCEPTUAL MODEL, ALL OTHERS ARE ONLY CHANGES IN BOUNDARY CONDITt"ONS J
THE TERM CONCEPTUAL MODEL SHOULD BE SYNONYMOL'S WITH
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MULTIPLE WORKING HYPOTHESIS IS THIS CHANGE A NEW MODEL OR ONLY A CHANGE IN i
BOUNDARY CONDITIONS?
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HOW MANY CHANGES CAN YOU MAKE IN A MODEL BEFORE IT IS A NEW MODEL7 l
i IS THERE (OR CAN THERE B E) A CONCEPTUAL MODEL FOR A SCENARIO?
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NRC CONCERN UNDERLYING OBJECTION THE PROGRAM OF INVESTIGATIONS AS PRESENTED IN THE CDSCP MAY NOT DETECT FEATURES PRESENT, j
RELEVENT PROCESSES AND EVENTS WHICH MAY HAVE ACTED, i
ARE ACTING, OR COULD ACT ON THE REPOSITORY SYSTEM
)
I i
PROGRAM MAY HAVE BEEN BIASED TO EXAMINE 1
i FEATURES, PROCESSES AND EVENTS CONSIDERED IMPORTANT i
j AND, AS SUCfi NOT DETERK!/NE j
FEATURES PROCESSES AND EVENTS WHICH ARE OR MAY BE IMPORTANT i
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lg_ CFR 60.122(A)
DOE MUST DEMONSTRATE THAT POTENTIALLY ADVERSE CONDITIONS HAVE BEEN ADEQUATELY INVESTIGATED INCLUDING EXTENT TO WHICH CONDITION MAY BE PRESENT AND STILL BE UNDETECTED AND l
CONDITION MUST BE ADEOUATELY EVALUATED USING ASSUMPTION WHICH WILL NOT UNDERESTIMATE THE EFFECT l
AND MUST SHOW THAT l
CONDITIONS WILL NOT SIGNIFICANTLY AFFECT WASTE ISOLATION i
CONDITION CAN BE REMEDIED l
t 4
4 I
O EXAMPLES SECTION 8.3.1.2.2.4 CHARACTERIZATION OF YUCCA MOUNTAIN PERCOLATION IN THE UNSATURATED-ZONE EXPLORATORY SHAFT FACILITY STUDY ComENT 11 O
N0 TAB 0aAT0ai Oa FIElo TESTS TO CONFlaM TsE CuaaENT CONCEaT OF MOISTi'aE CHARACTERIZATIC RELATIONS FOR FRACTURE / MATRIX FLOW IN UNSATURATED FRACTURCD ROCKS, WHICH FORM A MAJOR PART OF THE YUCCA MOUNTAIN HYDROLOGIC CONCEPTUAL MODEL, ARE SCHEDULED TO BE COP' DUCTED EARLY IN THE SITE CHARACTERIZATION PROGRAM.
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SECTici? 8.3.1.2.3.1 STUDY: CHARACTERIZATION OF THE SITE SATURATED ZONE GROUND-WATER FLOW $YSTEM f
ComENT 13 f
ACT!Y! TIES PRESENTED FOR THIS STUDY 00 NOT APPEAR TO BE ADE0VATE FOR l
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CHARACTERIZING SATURATED ZONE HYDROLOGIC BOUNDARY C0t'DITIONS, FLOW DIRECTIONS I
AND MAGNITUDES.
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9; SECTION 8.3.1.3.1 INVESTIGATION: STUDIES TO PROVIDE THE INFORMATION REQUIRED ON RADIONUCLIDE RETARDATION BY PRECIPITATION PROCESSES ALONG FLOW PATHS TO THE ACCESSIBLE ENVIRONMENT WATER.
COMMENT 16 IT IS STATED THAT GAMMA RADIATION WILL NOT BE IMPORTANT IN THE SOLUBILITY O
ExeERisENTS AS IT witt sE REtATIvEtv 8INO, OvER TnE ti E Or TsE Rer0SiTORv.
THIS IGNORES THE POTENTIAL IMPORTANCE OF KINETICS.
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' 0 SECTION 8.3.1.4 ROCK CHARACTERISTICS SECTION 8.3.1.17 PRECLOSURE TECTONICS C0fmENT 26 EXISTIdG GEOPHYSICAL DATA SUPPLEMENTED BY EXISTING 3E0 LOGICAL. DATA DO NOT APPEAR TO HAVE PEEN INTEGRATED FOR THE FURPOSE OF DEVELOPING A COHERENT PLAN FOR FUTURE GEOPHYSICAL INVESTIGATIONS.
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['o SECTION 8.3.1.5.1.5.1 ACTIVITY: PALE 0 CLIMATE-PALE 0ENV!NONFENT SYNTHESIS i
COMMENT 32 f
I THE DIVERSE NUMBERS OF THEORIES ON THE NATURE OF LATE PLEISTOCENE AND HOLOCENE CLIMATES DERIVED FROM VARIOUS PALE 0 VEGETATION DATA PAVE NOT BEEN ADDRESSES IN THIS SECTION.
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1 SECTION 8.3.1.9.2.1 NATURAL RESOURCE ASSESSMENT OF YUCCA MOUNTAIN i
SECTION 8.3.1.9.2.1.1 GEOCHEMICAL ASSESSMENT OF YUC0A MOUNTAIN IN RELATION
[
TO THE POTENTIAL FOR MINERALIZATION i
SECTION 8.3.1.9.2.1.4 ASSES' MENT OF HYDROCARBON RESOURCES AT AND NEAR THE SITE.
f o
COMENT 38
- THE PROGRAM OF INVESTIGATIONS AS PRESENTED IN THE CDSOP APPEARS TO BE INADEQUATE FOR CONSIDERATION OF POTENTIAL NATURAL RESOURCES AND NATURAL j
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RESOURCE MODELS AT THE SITE AND APPEARS INADEQUATE TO ASSESS THE PERFORMANCE OF THE REPOSITORY WITH RESPECT TO HUMAN INTRUSION.
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SECTION 8.3.3.2 ISSUE RESOLUTION STRATEGY FOR ISSUE 1.12: HAVE THE CHARACTERISTICS AND CONFIGURATIONS OF THE SHAFT AND BOREHOLE SEALS BEEN ADEQUATELY ESTABLISHED T0 (A) SHOW COMPLIANCE WITH THE POSTCLOSURE DESIGN CRITERIA 0F 10 CFR 60.134 AND (B) PROVIDE INFORMATION FOR THE RESOLUTION OF THE PERFORMANCE ISSUES, PAGE 8.3.3,2-24 to 27 STEP D: PERFORMANCE AND DESIGN GOALS
()
COMMENT 69 THE PERFORKANCE AtJD DESIGN GOALS FOR THE SEALING SUBSYSTEM 00 NOT CONSIDER A COMPREHENSIVE SET OF ANTICIPATED PROCESSES AND EVENTS AND UNANTICIPATED PROCESSES AND EVENTS.
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SECTION 8.3.5.9 CONTAINMENT BY WASTE PACKAGE SECTION 8.3.5.10 ENGINEERED BARRIER SYSTEM RELEASE RATES COMMENT 73 THE ISSUE RESOLUTION STPATEGIES AND TESTING PROGRAMS FOR DESIGN OF THE WASTE O
eACKAGE (SECTION 8.3.5.9 Or THE CDSCP) Ano ENGINEERED 8ARRiFn Sv5 TEM (SECTION 8.3.5.10 0F THE CDSCP) 00 NOT TAKE INTO ACCOUNT THE FULL RANGE OF REASONAELY LIKELY NATUPAL CONDITIONS ("ANTICIPATED PROCESSES AND EVENTS") THAT, WITH CURRENT UNDERSTANDING OF THE SITE, MIGHT BE EXPECTED TO AFFECT PERFORMANCE OF i
THESE BARRIERS.
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P SECTION 8.3.5.12 GROUND-WATER TRAVEL TIME C0f94ENT 88 NO PLAN INCORPORATING TECHNICAL OR MANAGEMENT ACTIVITIES IS PRESENTED TO TPACK PROGRESS IN PROVIDING AND CLOSING OUT INFORMATION NEED 1.6.1 WITH RESPECT TO VALIDATING FLOW MODEL CONCEPTS AS k'tS DONE FOR MATHEMATICAL PODEL VALIDATION IN SECTION 8.3.5.12.1 AS A CONSEQUENCE, THE ARILITY TO RESOLVE A POTENTIALLY 4
l SIGNIFICANT TECHNICAL CONCERN RELATED DIRECTLY TO THE PERF0PMANCE ISSUE ON D
GROUNDWATER TRAVEL TIME IS REDUCED.
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SECTION 8.3.5.13 TOTAL SYSTEM PERFORMANCE (PAGES 17-50)
COMENT 94 SEVERAL POTENTIALLY SIGNIFICANT SCENARIO CLASSES HAVE NOT BEEN FPESENTED UNDER THE SUB-SECTION ENTITLED "TECHNICAL DISCUSSION OF THE RELEASE-SCENARIO CLASSES": THUS, THE PERFORMANCE ALLOCATION PROVIDED INADE0VATELY ADDRESSES O
ISSUE 1.1, AND THE SITE CHARACTEPIZATION PROGRAM MAY HAVE SUBSTANTIAL GAPS.
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(1) A DESCRIPTION OF WHAT IS KNOWN OR THOUGHT TO BE THE CASE ABOUT THE PRESENT AND FUTURE STATES OF EACH ELEMENT OF THE NATURAL AND ENGINEERED
- SYSTEMS, (2) FOR EACH SUCH ELEMENT, A DISCUSSION OF THE UNCERTAINTIES, INCLUDING IDENTIFICATION AND INFLUENCE OF ANY ASSUMPTIONS MADE IN THE DESCRIPTION, (3) FOR EACH SUCH UNCERTAINTY, IDENTIFICATION OF AND ASSESSMENT OF THE SIGNIFICANCE OF THE ALTERNATIVE HYPOTHESES, INTERPRETATIONS, OR ASSUMPTIONS THAT ARE CONSISTENT WITH THE EXISTING DATA AND THE UNCERTAINTY ASSOCIATED WITH THE EXISTING DATA, (4) FOR EACH SUCH HYPOTHESIS, INFORMATION NEEDS AND INVESTIGATIONS TO DISCRIMINATE BETWEEN THE ALTERNATIVES, AND (5) PRIORITIZATION OF THE INVESTIGATIONS BASED ON AVOIDANCE OF INTERFERENCE BETWEEN TESTS AND THE NEED TO RESOLVE KEY ISSUES EARLY.
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QUALITY ASSURANCE CONCERNS ON CDSCP
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SACKGROUNO DOE A800T TO BEGIN EXTENSIVE SITE CHARACTERIZATION PROGRAM TO COLLECT DATA FOR LICEN I
IN ORDER 10 HELP ASSURE THAT DATA AND ANALYSES ARE VALID AND DEFENSIBLE IN LICENSING, L
QUALITY ASSURANCE PROGRAMS NEEDS 10 RE IMPLEMENTED BY DOE AND ITS CONTRACTORS, STAFF DBJECTIVE 15 To HAVE CONFIDENCE THAT DOE QA PROGRAMS ARE ACCEPTABLE BEFORE NEW l
i CHARACTERIZATION WORK IS BEGUN.
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OBJECTION NO. 5 THE CDSCP REFERENCES A NUMBER OF QA PLANS AND PROCEDURES FOR DOE AND ITS PRIME CONTRA UNDERGOING POTENTIALLY SIGNIFICANT REVISIONS, OR WHICH HAVE OUTSTANDING STAFF REVIEW COMENTS, ON WICH HAVE NOT UNDERGONE STAFF REVIEW.
BASED ON STAFF REVIEWS TO DATE, THEY 00 NOT FULLY COMPLY WITH NRC'S QA CRITERIA.
DATA COLLECTED UNDER THESE EXISTING PROGRAMS MAY NOT BE USA 81E IN LICENSING.
RECOMENDATIONS DOE TO FURNISH LATEST REVISIONS OF PLANS OF PARTICIPATING ORGANIZATIONS DOE TO RESPOND TO OUTSTANDING STAFF COMENTS DOE SHOULD FACILITATE NRC STAFF VERIFICATION REVIEWS SUCH AS AUDITS STAFF RECOMENDS DOE NOT START WORK UNTIL ADDITIONAL CONFIDENCE IN FROGRAM IS 08TAINED BY ST l
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Asso,-e BNL MCC R. 4ensatAe for Techn. cal and SA Meimgement Support f'.nWws Materials Performs Preclosure Corresawe Rate Date Performance to NNWSI AssesM I
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j FORMAL QUALIFICATION PROCEDURES TO BE SUBMITTED TO STAFF l
3 Q-LIST ANALYSES NON-CONSERVATIVE IN SOME AREAS FOR PRECLOSURE PHASE ACTIVITIES LIST TOO GENERAL
-5 10 PROBABILIT'l CUT OFF FOR PRECLOSURE EVENTS NOT JUSTIFIED ESSENTIAL PRECLOSURE MITIGATION FEATURES MAY NOT BE INCLUDED ON Q-LIST
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COMPLIANCE DEMONSTRATION SECTION:
SCOPE OF CDSCP REVIEW
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ISSUES, INFORMATION NEEDS, AND PERFORMANCE ALLOCATION i
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CDSCP REVIEWERS-
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1 DANIEL A. GALSON - POSTCLOSURE PERFORMANCE ASSESSMENT 1
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ROBrAT B. NEEL - PRECLOSURE PERFORMANCE ASSESSP'ENT
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PAULINE P.
BROOKS - PERFORMANCE ALLOCATION
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RESULTS OF CDSCP REVIEW
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QUESTIONS 1
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CONCERNED WITH HOW ALTERNATIVE CONCEPTUAL MODELS WERE DEALT WIT 5I IN PERFORMANCE ALLOCATION PROCESS IN TJIE CDSCP 1
o WAS THE FOCUS OF NRC/ DOE WORKSHOP IN APRIL 1988 4
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PERFORMANCE ALLOCATION IN THE SITE CHARACTERIZATION PROCESS AUGUST 4-5, 1983 NRC/ DOE TECHNICAL MANAGEMENT MEETING JULY 31, 1984 OBJECTION 4 ON THE DOE'S DRAFT MISSION PLAN (LETTER FROM N. J.
PALLADINO TO B...C.
RUSCHE)
AUGUST 17, 1985 NRC/ DOE MEETING ON PERFORMANCE ALLOCATION SEPTEMBER 25-26, 1985 NRC/ DOE MEETING ON SUBSYSTEM PERFORMANCE ALLOCATION MARCH 3-4, 1987 NRC/ DOE MEETING ON SCP ISSUES HIERARCHY / PERFORMANCE ALLOCATION OCTOBER 8-9, 1987 NRC/ DOE MEETING ON ISSUES HIERARCHY / PERFORMANCE ALLOCATION /NNWSI PROJECT SCP MARCH 7, 1988 DRAFf NRC STAFF COMMENTS ON DOE'S CDSCP FOR YUCCA MOUNTAIN SITE (LETTER FROM R. E. BROWNING TO S. H. KALE)
APRIL 11-14, 1988 NRC/ DOE MEETING ON ALTERNATIVE CONCEPTUAL MODELS
O O
C.
A WORKING DEFINITION CONCEPTUAL MODEL:
A PICTORIAL'AND/OR NARRATIVE DESCRIPTION OF THE REPOSITORY SYSTEM OR SUBSYSTEM THAT IS INTENDED TO REPRESENT ONE OR MORE OF THE FOLLOWING:
RELEVANT COMPONENTS OF A SYSTEM AND/OR SUBSYSTEM INTERACTIONS BETWEEN THE VARIOUS COMPONENTS AND/OR SUBSYSTEMS AND/OR SYSTEMS' I
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o CONCEPTUAL MODELS FORM THE BASIS FOR THE PREDICTIVE PERFORMANCE ASSESSMENTS OF
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REPOSITORY SYSTEMS AND SUBSYSTEMS THAT ARE REQUIRED BY 10 CFR PART 60 o
CONCEPTUAL MODELS MUST BE DEVELOP:ED AND CONFIRMED, WITH REASONABLE ASSURANCE, TO CALCULATE RELEASES FOR ALL SCENARIOS NEEDED TO SHOW COMPLIA*1CE WITH THE EPA STANDARD o
THE SCP AND PERFORMANCE ALLOCATION MUST CONSIDER A FULL RANGE OF ALTERNATIVE CONCEPTUAL MODELS (ALTERNATIVE WORKING HYPOTHESES) WHERE UNCERTAINTY EXISTS
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OBJECTION 1 U
o THE PERFORMANCE ALLOCATION PROCESS IN THE CDSCP DOES NOT DIRECTLY ADDRESS THE INVESTIGATIONS TilAT WOULD BE NEEDED TO CllRRACTERIZE THE SITE WITH RESPECT TO THE FULL RANGE OF ALTERNATIVE CONCEPTUAL MODELS AND ASSOCIATED BOUNDARY CONDITIONS THAT ARE CONSISTENT WITH THE EXISTING DATA.
j i
o TilEREFORE, ALL TIIE INVESTIGATIONS THAT ARE SIGNIFICANT TO THE CHARACTERIZATION OF THE SITE ARE NOT NECESSARILY CONSIDERED.
i 1
o AN IMPORTANT CONSEQu.:,1,'C IS THAT IT CANNOT BE DETERMINED WHETHER CONDUCTING ONE INVESTI-1 GATION WOULD INTERFERE WITil, POSSIBLY TO THE POINT OF PRECLUDING, CONDUCTING ANOTHER I
INVESTIGATION NEEDED TO OBTAIN INFORMATION FOR LICENSING.
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o IN ADDITION, Tile PROGRAM MAY FAVOR PROVIDING DATA THAT CONFIRM THE "PREFERRED" MODEL AND i
j BOUNDARY CONDITIONS, RATHER TIIAN THE DATA NEEDED TO DETERMINE WHAT THE "PREFERRED" MODEL i
AND BOUNDARY CONDITIONS SHOULD BE.
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o IDENTIFY A FULL RANGE OF ALTERNATIVE CONCEPTUAL MODELS AND ASSOCIATED BOUNDARY CONOITIONS o
IDENTIFY A FULL ARRAY OF INFORMhTION NEEDS AND ASSOCIATED 17?ESTIGATIONS IN CONSIDERATION OF TilESE CONCEPTUAL MODELS o
INTEGRATE INVESTIGATIONS ACROSS ALL DISCIPLINES o
DETERMINE WHICII INVESTIGATIONS WOULD INTERFERE WIT 11 OR PRECUJDE CONDUCTING OTHER INVESTI-GATIONS IMPORTANT TO TIIE CHARACTERIZATION PROGRAM, AND SEQUENCE APPROPRIATELY o
SPECIFY ItNESTIGATIONS AND INFORMATION NEEDS, THROUGH PERFORMANCE ALLOCATION, THAT WILL DISTINGUISH BETWEEN ALTERNATIVE CONCEPTUAL MODELS o
ACCORD IIIGIl PRIORITY TO INVESTIGATIONS HAVING THE GREATEST POTENTI AL FOR RESOLVING ISSUES THAT COULD LEAD TO:
THE SITE BEING CONSIDERED l'NLICENSABLE SUBSTANTIAL CHANGES IN THE CHARACTERIZATION PROGRAM
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b BRIEFING ON THE NRC STAFF REVIEW OF THE DOE CONSULTATION DRAFT SITE CHARACTERIZATION oLAN (CDSCP)
FOR THE YUCCA MOUNTAIN, NEVADA SITE FOR THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON WASTE MANAGEMENT B.
J0E YOUNGBLOOD, NMSS/DHLWM/HLOB KING STABLEIN, NMSS/DHLWM/HLOB APRIL 28, 1988
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l NRC REVIEW 0F YUCCA MOUNTAIN CDSCP i
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CDSCP CDSCP DRAFT WORKSHOP ON ALTERNATIVE FINAL ACRS COMMISSION ' ISSUE.
l-ISSUED POINT PAPERS DRAFT POINT CONCEPTUAL POINT BRIEFING' BRIEFING FINAL ISSUED PAPERS MODELS PAPERS POINT i
WORKSHOP PAPERS:
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s PURPOSE OF NRC_ STAFF CDSCP REVIEW b
IDENTIFICATION OF CONCERNS WITH THE SITE CHARACTERIZATION L
PROGRAM AS PRESENTED IN THE CDSCP FOR CONSIDERATION BY DOE IN PREPARING THE STATUTORY SCP l
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SCOPE OF NRC STAFF CDSCP REVIEW
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- FOCUS ON LOGIC AND STRUCTURE OF PROGRAM PRESENTED IN THE CDSCP i'
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- CONCERNS SHOULD BE CONSIDERED AS i
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PORTIONS OF THE CDSCP l
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FOUNDATION OF NRC STAFF REVIEW i
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DRAFT TECHNICAL REVIEW PLAN FOR NRC STAFF REVIEW OF DOE'S SITE j
CHARACTERIZATION PLANS (DTRP-SCP), WHICH IS BASED ON:-
AGREEMENTS FROM NRC/ DOE MEETINGS OVER PAST THREE YEARS USNRC REGULATORY GUIDE'4.17, STANDARD FORMAT AND CONTENT OF SITE j
CHARACTERIZATION PLANS FOR HIGH-LEVEL WASTE REPOSITORIES, REVISION 1 h
USDOE ANNOTATED OUTLINE FOR SITE CHARACTERIZATION PLAN, CONCURRED IN BY NRC t
0 ADMINISTRATIVE PLAN AND PROCEDURES FOR NRC STAFF REVIEW OF DOE'S i
CONSULTATION DRAFT SITE CHARACTERIZATION PLANS (APP-CDSCP) i l
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O RESULTS OF NRC STAFF REVIEW o
LETTER OF MARCH 7, 1988 TRANSMITTING DRAFT POINT PAPERS TO DOE IDENTIFIED 161 NRC STAFF CONCERNS
- INDIVIDUAL CONCERNS SHOULD BE RESOLVED ON A TIMELY BASIS, I.E.,
PRIOR TO START OF NEW SITE CHARACTERIZATION ACTIVITIES:
- CONCERNS SHOULD BE CONSIDERED IN THE DEVELOPMENT OF THE STATUTORY SCP o
FURTHER REVIEW HAS NOT RESULTED IN ADDITIONAL MAJOR CONCERNS FOR FINAL POINT PAPERS
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O THREE LEVELS OF CONCERtG o
OBJECTIONS o
COMMENTS o
QUESTIONS L
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- RECOMMEND THAT DOE NOT START WORK PRIOR TO RESOLUTION
-- POTENTIAL ADVERSE EFFECTS ON REPOSITORY PERFORMANCE
-- SIGNIFICANT AND IRREVERSIBLE /UNMITIGABLE EFFECTS ON CHARACTERIZATION THAT WOULD PHYSICALLY PRECLUDE OBTAINING INFORMATION NECESSARY FOR LICENSING
-- FUNDAMENTAL INADEQUACIES IN QUALITY ASSURANCE (QA)
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COMMENTS CONCERNS THAT WOULD RESULT IN A SIGNIFICANT ADVERSE EFFECT ON LICENSING IF NOT RESOLVED BUT WHICH WOULD NOT CAUSE IRREPARABLE DAMAGE IF SITE CHARACTERIZATION STARTED BEFORE RESOLUTION
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90ESTIONS CONCERNS WITH PRESENTATION OF AN IMPORTANT PART OF THE PROGRAM IN THE CDSCP WHICH PRECLUDES UNDERSTANDING s
IT WELL EN0 UGH TO BE ABLE TO EVALUATE THAT PART 1
-- MISSING INFORMATION THAT SHOULD BE IN THE CDSCP
-- INCONSISTENCIES l
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OF OBJECTIONS OBJECTION 1:
THE CDSCP DOES NOT RECOGNIZE THE RANGE OF ALTERNATIVE CONCEPTUAL MODELS OF THE YUCCA MOUNTAIN SITE THAT CAN BE SUPPORTED BY THE EXISTING LIMITED DATA BASE.
OBJECTION 2:
EXTENDING THE EXPLORATORY SHAFT ES-1 400M BELOW THE REPOSITORY HORIZON INTO THE CALICO HILLS UNIT AND DRIFTING LATERALLY IN THAT UNIT MAY HAVE ADVERSE IMPACTS ON THE WASTE ISOLATION CAPABILITY OF THE SITE.
OBJECTION 3:
THE CDSCP CONTAINS INADEQUATE INFORMATION ON THE ESF CONCEPTUAL DESIGN TO ALLOW EVALUATION OF (1) POTENTIAL INTERFERENCE OF PROPOSED INVESTI-GATIONS WITH EACH OTHER AND (2) INTERFERENCE OF CONSTRUCTION OPERATIONS IN THE TWO SHAFTS AND LONG DRIFTS WITH THESE INVESTIGATIONS.
OBJECTION 4:
THE CDSCP DOES NOT ADEQUATELY CONSIDER THE POTENTIALLY ADVERSE IMPACTS-ON WASTE ISOLATION CAPABILITY OF THE SITE AND THE ABILITY TO CHARAC-TERIZE THE SITE RESULTING FROM PROPOSED LOCATIONS OF ES-1, ES-2, AND OTHER OPENINGS IN AREAS THAT MAY BE SUSCEPTIBLE TO SURFACE WATER INFILTRATION AND TO EROSION.
OBJECTION 5:
THE CDSCP REFERENCES A NUMBER OF QA PLANS AND PROCEDURES FOR DOE AND ITS PRIME CONTRACTORS, MANY OF WHICH ARE UNDERGOING POTENTIALLY SIGNIFICANT REVISIONS, OR WHICH HAVE NRC STAFF REVIEW CGMMENTS OUT-STANDING, OR WHICH HAVE NOT UNDERGONE NRC STAFF REVIEW.
BASED ON NRC STAFF REVIEWS TO DATE, THEY DO NOT FULLY COMPLY WITH NRC'S QA CRITERIA.
DATA COLLECTED UNDER THESE EXISTING PROGRAMS MAY NOT BE USABLE IN LICENSING.
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CDSCP-RELATED WORKSHOPS o
PLENARY SESSION FOR DOE TO EXPLAIN CDSCP JANUARY 28-29, 1988 o
CDSCP POINT PAPERS WORKSHOP MARCH 21-24, 1988 o
ALTERNATIVE CONCEPTUAL MODELS WORKSHOP APRIL 11-14, 1988 o
WORKSHOP ON DOE RESPONSE TO NRC CDSCP FINAL POINT PAPERS JUNE / JULY (TENTATIVE)
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0 CDSCP DRAFT POINT PAPERS WORKSHOP MARCH 21-24. 1988 o
PURPOSE WAS TO REACH COMMON UNDERSTANDING WITH DOE OF THE NRC OBJECTIONS, j
COMMENTS, AND QUESTIONS
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DOE INDICATED THEY UNDERST0OD NRC CONCERNS AND WOULD RESPOND TO THEM IN SCP o
o RESULTS INCLUDED COMMITMENTS BY DOE RELATIVE TO OBJECTION 5 ON QA:
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DOE WILL NOT START NEW WORK UNTIL NRC HAS REVIEWED THE QA PLAN FOR THAT j
PROGRAM AREA AND OBSERVED ITS IMPLEMENTATION THROUGH AUDITS (2)
THE NEVADA PROJECT OFFICE QA PLAN IS TO BE SUBMITTED FOR NRC REVIEW j
WITHIN TWO TO THREE WEEKS i
(3)
DOE WILL MEET WITH NRC IN MAY TO RESOLVE OPEN ITEMS OF LAST FEW YEARS AND TO PROVIDE SCHEDULE FOR FORMAL SUBMITTAL OF DOE CONTRACTOR QA PLANS o
ADDITIONAL RESULT WAS IDENTIFICATION OF TOPICS WHERE FURTHER INTERACTIONS BETWEEN NRC AND DOE TECHNICAL STAFFS APPEAR NECESSARY I
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O ALTERNATIVE CONCEPTUAL MODELS WORKSHOP APRIL 11-114. 1988 o
LETTER TO DOE DATED MARCH 7, 1988 STATES POSITIONS o
OBJECTION 1 POINTED OUT TO DOE THE NECESSITY OF CONSIDERING THE RANGE Oc CONCEPTUAL MODELS CURRENTLY SUPPORTABLE BY THE LIMITED EXISTING DATA BASE WHEN DEVELOPING THEIR TESTING PROGRAM o
PURPOSE OF THE WORKSHOP WAS TO ASSEMBLE THOSE INVESTIGATORS WHO HAVE CONCEPTUAL MODELS OF THE YUCCA MOUNTAIN SITE TO DISCUSS DIFFERENCES IN THOSE MODELS AND THE SIGNIFICANCE OF THESE DIFFERENCES IN DEVELOPING TESTING PROGRAMS TO CHARAC-TERIZE THE SITE o
WORKSHOP WAS SUCCESSFUL IN MEETING OBJECTIVES.
DOE AGREED TO CONSIDER INFORMATION PRESENTED AND NRC STAFF RECOMMENDATIONS FOR DEALING WITH ALTERNATIVE CONCEPTUAL MODELS AND HYPOTHESES IN DEVELOPMENT OF SCP o
STATE OF NEVADA PARTICIPATED IN WORKSHOP o
J. SZYMANSKI 0F THE DOE NEVADA PROJECT OFFICE PRESENTED HIS MODEL N
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REVIEW 0F SCP
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