ML20206G217
| ML20206G217 | |
| Person / Time | |
|---|---|
| Issue date: | 11/16/1988 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| References | |
| REF-10CFR9.7 NUDOCS 8811220152 | |
| Download: ML20206G217 (72) | |
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r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION i
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Title:
BRIEFING ON STATUS OF LOCATION OF EXPLORATOR'.'
SHAFT AT YUCCA MOUNTAIN 1 OCatlOn: ONE WHITE FLINT NORTH, ROCKVILLE, MARYLAND Date: WEDNESDAY, NOVEMBER 16, 1988 C >
, Pages: 1-57 .
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! Ann Riley & AsNclates Court Reporten 1625 i Street, N.W., Sutto 921 !
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5 DISCLAIMER :
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7 This is an unofficial transcript of a meeting 8 of the United stdtes Nuclear Regulatory Commission held 9 on ,11-16-88 in the commission's office at one 10' White Flint North, Rockville, Maryland. The! meeting was 11 open to public attendance and observation. This transcript 12 has : lot been reviewed, corrected, or edited, ' and it may 13 contrin inaccuracies.
14 The transcript is intended solely for general 15 informational purposes. As provided by 10 CFR 9.103, it is 16 not part of the fornal or intornal record of decision of the 17 matters discussed. Expressions of opinion in this transcript 18 do not necessarily reflect final determination or beliefs.
19 No pleading or other paper may be filed with the commission 20 in any proceeding as the result of, or addressed to, any 21 statement or argument contained herein, except as the 22 commission may authorize.
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. 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ***
4 BRIEFING ON STATUS OF LOCATION OF EXPLORATORY v 4
5 SHAFT AT YUCCA MOUNTAIN 6 ***
7 PUBLIC MEETING 8 ***
j 9 Nuclear Regulatory Commission 10 One White Flint North 11 Rockville, Maryland 12
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13 Wednesday, November 16, 1988 14 15 The Cemnission met in open session, pursuant to 16 notice, at 10:00 o' clock, a.m., the Honorable LANDO W. ZECH, l i.
17 Chairman of the Commission, prosjding.
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18 COMMISSIONERS PRESENT: l 19 LANDO W. ZECH, Chairman of the commission f 20 KENNETH CARR, Member of the Commission i
21 KENNETH C. ROGERS, Member of the Commission [
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) 22 JAMES R. CURTISS, Member of the Commission !
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'n g 1 STAFF AND PRESENTERS SEATED AT THE COMMISSION TABLE:
2 3 V. STELLO, EDO 4 S. CHILK, SE0Y 5 J. GUTTMAN, SECY 6 W. PARLER, OGC 7 J. KENNEDY 9
8 D. GUPTA 9 J. BUNTING 10 H. THOMPSON 11 12 AUDIENCE SPEAKERS l 13 R. BROWNING 8
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! 15 l- 16 17 18 19 20 21 22 23 24 25
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1 PROCEEDINGS 2 (10:00 a.m.)
3 CHAIRMAN ZECH: Good morning, 1 ad gentlemon.
4 Mr. Roberts will not be with us ;nis morning.
5 Today, the commission will be briefod by the office 6 of Nuclear Material Safety and Safeguards on the regulatory 7 concerns regarding the exploratory shaft facility for the Yucca 8 Mountain sito.
9 As you are avaro, the Nuclear Waste Policy Act, as 10 amended in 1987, requires the Department of Energy to develop a 11 site characterization plan for a high-level radioactive waste 12 repository. The exploratory shaft facility is an integral part i
13 of that plan.
14 The exploratory shaft facility is an integral part of 15 that plan. The exploratory shaft facility will be utilized by 16 the Departmont of Enorgy to conduct various tests and 17 oxperiments to gather vital information for charactoriza*. ion of 18 the Yucca Mountain sito.
19 Earlier this year, the Staff reviewed the 20 consultation draft site charactorization plan, identified NRC's
?1 concerns, and formally transmitted major exploratory shaft 22 facility issues to the Departmont of Energy.
23 Today, the Staff will inform the Commission on the 24 status of those exploratory shaft facility issues and outlino 25 the approach tentatively agrood upon by the Department of
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1 Energy to resolve these issues. ,
2 I understand that the Staff has kept the State of 3 Nevada and affected counties and Indian tribes informed of the ,
4 current activities of this program. This is an information 5 briefing this morning, and copies of the presentation should be !
6 available at the entrance of the meeting room.
7 Do any of my fellow Commissioners have opening 8 comments to make before we begin?
9 (No response.)
10 CHAIRMAN ZECH: If not, Mr. Stello, you may proceed.
11 MR. STELLO: Thank you, Mr. Chairman.
12 Our briefing this morning will be a follow-up of the 13 May 4th meeting that we had with the Commission on the point le papers commenting on the consultation draft site 15 characterization plan. We will be concentrating in the 16 briefing on some of the issues and problems that we see that 17 need to be resolved before DOE goes forward with their 18 exploratory shaft, and that will be the major element of the !
l 19 briefing this morning, which we think is important for the j 20 Commission to understand what those issues and what our views ;
i 21 of them are. ;
22 I will ask Hugh Thompson now to introduce the other ,
23 speakers at the table and get into the briefing. ;
24 MR. THOMPSON: Thank you, F. Stello.
25 Mr. Chairman, Mr. Commissioners, as you know, the !
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5 1 exploratory shaft is the first key technical issue that we've
' 2 had to face in resolving the proposed site characterization ;
l 3 activities with DOE, and it's been one that we have been 4 identifying our concerns with for some time. This particular L
5 one, since we had the meeting with the Commission in May of 6 last year, we've had four meetings with the Department of 7 Energy spanning the May, June, July, October, November i 8 timeframe, in there, where we've been identifying our j 9 approaches. We've essentially resolved and focused the issues ;
- 10 down from 128 down to 53, so there are still some significant 11 issues that we have to address with DOE in resolving our 12 concerns, and some of these aspects will be addressed today.
- t 13 Joe Bunting, who is the Chief of the Engine; ring i 14 Branch, will begin today's briefing, and he will be assisted by i
1 15 Dinesh Gupta, who is the geotechnical team leader for the Yucca 1
j 16 Mountain project, and Jim Kennedy, who is the quality ausurance
- 17 section leader.
l 18 CHAIRMAN ZECH: Thank you very much. You may i
j 19 proceed.
i t 20 MR. BUNTING: Thank you, sir, i l i l
21 Would you turn to Chart I, please? We will use Chart ;
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- 22 I for the purpose of an overview. !
23 The first purpose of the briefing is to gave you the j {
. t j 24 factual information on these major issues regarding the j i
25 exploratory shaft, and they are shown on this chart, and they -
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- a. _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - _ .
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1 will be discussed in detail during the presentation, and Dr.
I 2 Gupta will use the scale model to further explain these when he 3 begins his part of the presentation.
4 However, I would like to briefly touch on each of 5 these issues now.
6 Number one is the location of the shaft, and the ;
7 focus here is on the demonstrated criteria used by DOE for ;
8 selecting the siting of these shafts and the potential for test l
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9 interference, and here we're talking about the potential for 10 interference between the tests themselves and between the test ,
11 and the construction activities associated with the exploratory 12 facility. ;
i 13 Second, the DOE plans to penetrate the barrier ;
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14 between the repository and the groundwater below the repository 15 by continuing one of the 12-foot diameter shafts down through 5
j 16 that barrier.
17 And throo, the extent of the proposed underground i f
I 18 exploration. The question is, how representativo will that 19 exploration be of the entire site at Nevada? l J
20 Now these have boon briefed to you previously. The
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j 21 last one, number four, is a new insight in design control, 22 which is one of the criteria that's contained in our 10 CFR 60 !
23 QA requirements. This is a new insight that we've gained over !
24 the past six nonths, which we want to relate to you here today. !
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25 Since wo briofod you in May, we've given further l l
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7 1 consideration to the significance of the objections, concerns, 2 and the 128 open items that were identified by the Staff during i
3 the review. We've come to the conclusion that these issues 4 ident.*ied by the Staf f must be considered as just the symptoms ;
I 5 of a major problem and not be confused with the problem itself, ;
I 6 and we suspect the problem includes an inadequate design 7 control process.
8 In our briefing to you in May, we did not make the f
9 connection between the multitude of issues raised by our 10 comments and the questionable adequacy of the design control 11 process. Our initial realization of a major problem came about :
12 during our observation of DOE's 50 percent design review, and ;
13 there it became obvious to the NRC Staff that DOE's architects
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14 and engineers were "orking to rather rigid requirements given i
15 to them by DOE, and the requirements did not seem to adequately 16 incorporate 10 CFR 60 regulatory requirements.
i 17 Also, there seemed to be a clear lack of interface l
18 control between the various DOE contractor design and
! 19 construction organizations who were present at the meeting. We '
20 have brought this to DOE's attention, and they have indicated .
21 their commitment to implement a design control process that 1
22 meets regulatory requirements for future activities. We still ;
23 have to deal with past activities and specifically the adequacy 24 of the design to be presented in the site characterization plan l
25 for the exploratory shaft facility.
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8 1 Although we are proceeding to resolve these 2 individual open items, and the numbers now have been reduced by 3 over 50 percent, we must be careful that we adopt an approach 4 that is sufficiently comprehensive to address the problem and 5 not just the symptoms.
t 6 It is well to understand that on this first-of-a-kind 7 undertaking, the NRC Staff is not a* ale to catch every DOE 8 omission or inadequacy, and we must rely to large extent on the 9 adequacy of DOE's engineering process and specifically the 4 10 design control process.
11 The second purpose of the briefing, as highlighted on a
12 your chart, is to make you awa.re of the approach that we are
\ 13 pursuing to resolve this problem. We will first familiarize 14 you with the extent or the facility itself, and then we'll 1 15 identify the pertinent regulatory requirements, so that you can 16 appreciate both the importance and the timeliness of the 17 material we're presenting here today.
l 18 Then Dr. Gupta and Mr. Kennedy will present tee 1
4 19 issues in some detail, and I will follow up with the resolution 1
j 20 approach and a summary.
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21 Turn to Chart II, please. What is the ESF, the 4
22 exploratory shaft facility?
23 Some people may think that this is just the vertical
- 24 shafts that provide access to the underground test area of tho
- 25 site characterization.
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9 4 1 Could you put up Figure 1, please?
4 2 This diagram illustrates the major features of the 3 exploratory shaft facility. This is as related in DOE's draft 4 site characterization plan. Here you see the three hr'.d frames 5 on the surface, the two 12-foot diameter shafts .t;s feet apart, 6 the main underground test area. The dotted lines illustrate i
7 the long exploratory drifts at the repository horizon, and the j 8 cutout at the bottom represents the DOE plans to penetrate the 9 barrier below the repository level with one of these 12-foot 10 shafts.
11 So when we talk about the exploratory shaft facility 12 here today, we're talking about all that you see in this 13 diagram, and these features will be further highlighted by Dr.
14 Gupta, using his scale model, when he makes his presentation. ;
} if If you would turn to Chart III, why is the ESF
- 16 important?
17 One of the regulatory requirements we wish to focus l 18 on here today is contained in 10 CFR 60.21, which requires -- r
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l 19 and I'm going to quote this - "a comparative evaluation of l 20 alternatives to the major design features that are important to f
! 21 waste isolation with particular attention to those alternatives I i 22 that provide longer radionuclide containment and isolation. ;
- i 23 Now there are three important features of this l l
24 requirement I'd like to focus on. -
I 25 Number one, major design features important to waste (
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1 isolation; two, comparative evaluation of alternatives; and 2 three, alternatives that would provide for a longer ,
3 containment.
i 4 From a regulatory viewpoint, the Commission has (
5 expressed in its statement of Considerations the position that !
6 shafts were considered a major design feature important to 7 waste isolation. From a technical viowpoint, this facility is 8 a major design feature important to waste isolation for the 9 following reasons:
10 It is the interface for any future repocitory ,
11 expansion and will become part of the repository itself, if the 12 site is found suitable and developed by DOE. How this facility '
15 is sited, designed, and constructed could impact on the !
14 validity of the data derived from the site characterization .
15 tests themselves, and how effectively it can be sealed will r 16 impact on long-term waste isolation and repository performance. I 17 Now in contrast with these regulatory requirements, i
18 the documentation provided to date by DOE to support its siting i
19 and design of the facility does not include waste isolation as ,
t 20 a criterion. Instead, it focused on cost and constructability. I 21 Furthermore, the required comparative evaluations i l
22 were not provided. For example, we could have looked at (
i 23 alternativo locations, alternative designs of the shafts, (
l 24 alternative underground exploration plans that would have {
25 listed the major uncertainties and the ability of various l
J 11 1 alternatives to resolve those uncertainties.
2 Now I want to point out, I cite these examples just 3 for illustrative purposes, and I don't mean to imply that DOE 4 must consider these alternatives.
5 Now the documentation provided by DOE also did not 6 comonstrate the process nor the criteria that were used to 7 translate these various regulatory requi.rements into their 8 subsystem requirements document. Now this document became one .
, 9 of the principal inputs into the design process they had in l
10 place, and this is one of the documonts that contained the -
11 rigid requirements that I referred to in relating the
} 12 observation of the 50 percent design review.
13 If you vill turn to Chart IV, turn now to why is this l
l 14 subject important now. In the first instance, it is timely, 15 because DOE wants to begin construction in November of 1989.
+ 16 However, from a regulatory perepective, both the las and NRC's 17 rules require the DOE to defer nink of the shafts until it has 18 received and considered comments from the Commission.
19 Furthermors, 10 CFR 60.18(d) requires the Director, NMSS, to 20 provide DOE with NRC's site characterization analysis, and this 1 21 analysis shall include a statement of no objection or we have
.i j 22 to list the specific objections with respect to DOE's program ,
23 for characterization.
i 24 Because this exploratory shaft facility is more than l'
25 just the access shafts, and it includes the site l
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12 1 characterization areas itself, the exploratory shaft facility 2 concerns cannot be viewed in isolatio from the site 3 characterization plan and NRC's site .naracterization analysis.
i 4 Now no hearing or construction authorization is i
5 required at this time before they begin construction of the i
6 exploratory shaft facility; however, should the site be found ,
l 7 suitable and DOE submits an application, we will have to make a l c
8 compliance determinatiot with respect to 60.21, and a
9 particularly those parts pertaining to the shafts at the time 10 of the repository construction authorization, after the shaft ,
11 has already Seen constructed.
I 12 Now I want to poinc out that a "no objection" reading :
<. l 13 from the Commission at tho *:ime of the site characterization --
14 at the time of the ESF construction does not prejudico the l 15 Commission or the Staff in this review of the construction i
16 application. However, if ve want to uinimize the potential for i
! 17 impediments to the licensing process in the future, we have to l 18 be sensitive to raising significant concerns now and being sura 19 that DOE adequately addresses those before we give our 1
] 20 objection.
I 21 Dr. Gupta will now preuent this detailed ESF i i
- 22 technical issues and will be followed by Mr. Kennedy. !
1 23 COMMISSIONER CARR Could I ask a question first? [
24 CHAIRMAN ZECH: Suro, go ahoad. !
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l 25 COMMISSIONER CARRt If we don't give them a "no !
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'l objection a finding, can they go ahead? l 2 MR. BUNTING: Yes, sir.
3 COMMISSIONER CARR: So all we do is go on record, and 4 then they can do what they want to do. !
5 MR. BUNTING: Yes, sir. This is a possession 6 license, not a facility license, so our ultimate --
7 COMMISSIONER CARP- But they are required to get our 8 comments before they can go ahead.
9 MR. BUNTING: That's correct.
10 COMMISSIONER CARR: So what if we don't send our 11 comments?
12 MR. BUNTING: Then I guess they can't go ahead.
i t 13 COMMISSIONER CARk: Oh, okay.. t
! l 14 CHAIRMAN EECH: All right. Let's proceed.
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15 MR. GUPTA: Thank you, Mr. Chairnan, Commissioners. '
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- 16 In January of this year, DOE submittod the f
i 17 consultation draft site characterization plan that contained !
4 18 the exploratory shaft design. We reviewed that design, (
19 recognizing the fact that if the site is found suitable for {
20 repository development, the ESP facility would be incorporated i i
, 21 in the repository. It will become a part of the repository i 22 itself. And I will illustrate that point with this scale model 1
23 here. !
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I 24 What we have here is a scale model of the repository
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l 25 that shows the terrsin at the Yucca Mountain. The blue surface ;
0 14 1 here is the groundwater table, which is about 1700, 1800 feet 2 below the ground aurface. The repository would be developed 3 about 1000 feet below the ground surface. The final 4 repository, there will be surface facilities here from which 5 the waste would be transported through a ramp that would come 6 from the surface down to 1000 feet below ground at this 7 location.
8 The excavated rock material would be carried out 9 through another ramp that would be coming out just about in 10 this area to thic stockpilo here.
11 The final repository would have four shaftc. Two of 12 those would be what wo now know as exploratory shafts. Those 13 two shafts vould be come ventilation shafts in the final 14 repository. There would be two additional shafts, the 15 emplacement exhaust shaft and men-and-materials shaft that
> 16 would be built lator en as part of the repository.
17 So the overall design would have four shafts and two 18 ramps as surface openings.
19 CHAIRMAN ZECH: How far is the bottom of the shaft 20 above the water table?
21 MR. GUPTA: It's about 400 foot -- 700 foot. .
1 22 CHAIRMAN ZECH: 700 foot?
23 MR. GU PTA: Yes.
24 CHAIRMAN ZECH: All right. Thank you. You may 25 continue.
15 1 MR. GUPTAs Okalt. The lines here on this side show 2 the rock formations, and EOE has concluded that the topographic 3 member is the rock formation in which the repository can be 4 built.
5 Now as I just stated here, the two shafts, the 6 exploratory shafts, ES-1 and ES-2, will become ventilation 7 shafts. The long drifts that DOE is planning to expose, some 8 specific geologic features, will also become access drifts in 9 the final repository. So when we reviewed the ESF design, we 10 reviewed it from the point of view, using the same criteria as 11 if we would be reviewing the repository.
12 Wo identified three objections, and we made a number 13 of comments ar.d questions on the ESF design.
14 If I could have the photograph of the Coyote wach 15 arna?
16 Our objections included cur concern on the propose 17 shaft locations that are close to a wash area that could be 18 subject to ficoding and erosion. The picture here shows a view 19 of the coyote wash area where the two shafts are proposed to be 20 located.
21 Prior to April 1987, DOE has proposed to put the two 22 shafte in the middle of the wash. Those locations are 23 indicktod by red dots up there. You can see at this 1ccation 24 two drrinage channels that feed into the wash and convergo at 25 this particular location.
16 1 We made comments on this, and there are concerns that 2 this could be subject to flooding and erosion, and in response 3 to those concerns in April '87, DOE decided to move those two l I l 4 shafts and put it on the side of the wash, indicated by black 5 dots up there.
6 This location is definitely bottor then what was 7 previously proposed by the DOE; however, DOE at this time is 8 still evaluating whether there could be any concern with f
9 respect to flooding and erosion at the new locations, and DOE 10 has indicated that they plan to provide us with their analysis f 11 with respect to flooding and erosion with the SEP for the now l 12 location.
13 CHAIRMAN ZECH: When are they going to do that? What i
14 is their schedule for providing you that analysis?
15 MR. CUPTA: With the SEP, that should be coming in 16 next nonth.
17 CHAIRMAN ZECH: Next month?
18 MR. THOMPSON: At the end of next month, the end of 19 December.
20 MR. GUPTA: The end of next month.
21 CHAIRMAN ZECH: Proceed.
22 MR. GUPTA: May 2 have the next figure?
23 In addition to the flooding and erosion issue, there 24 are intericrence concerns with respect to relative distances 25 within the two dhafts. Also within the two shafts in the
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17 1 underground test areas and between the shafts and the future 2 waste emplacement areas. The two shafts are located 300 feet 3 apart. Sone of the testing would be conducted with 200 feet of 4 these two shafts, and the plan is to place the waste within, 5 say, 500 feet of these openings.
6 We have raised this concern that there might be 7 potential interferer.ce concerns with respect to this opening 8 and the underground testing that DOE is planning. These
- 9 interference concerns are not related to he locations of the [
10 two shafts in the wash area. They are strictly related to how 1 11 the overall design of the ESP fits in together.
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12 in two previous bore holes at the site, water from i
! 13 one bore hole founds its way into the other bore hole, and our [
I 14 concern is that by locating the two shafts so close to each
- 15 othel, since ES-1 would be primarily used for conducting a J
16 number of inportant tests, would be instrumented heavily, that 17 by locating thc other shaft so close to ES-1, there might be
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6 18 some interference possibility.
19 A similar concern is with respect to the testing that 20 would be conducted at the main test lab, which is 1000 feet 21 below the ground surface, f 22 DOE also needs to evaluate the effect of locating the
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- 23 two shafts so close to the future vacte emplacement areas.
! 24 In addition, the DOE did not include sufficient j 25 details on test locations and their zone of influence j' the i
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4 18 1 consultation draft site characterization plan. Therefore, we l 2 cannot evaluate at this time whether the tests could interfere ;
3 with each other. Some of the tests were not identified at all. :
4 For example, seal tests and performance confirmation tests were 5 not identified at all.
6 In our meetings with the DOE, they have indicated ,
7 that they are considering these concerns, and they plan to 8 address them in the SEP also.
9 COMMISSIONER CARR: What drives the 300-foot figure?
I 10 MR. CUPTA: It is an old design where the two shafts i
11 are not 12 foot in diameter. One shaft was six foot in i
- 12 dlameter, and the distance had to be of that order for safety
\ i 10 reasons. '
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i 14 Now -- and for ventilation reasons -- now they have i 1
15 increased the diameter of the two shafts, and there is no real -
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16 reason to keep them so close. (
i 17 COMMISSIONER CARR: So they can move them apart I a i i 18 without any design objectives or it doesn't -- I mean, they !
I t 1 i 19 didn't put them close together, so they could use comy :
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20 facilities for drilling or -- [
l l 21 MR. GUPTA: Well, there are some advantages in doing !
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22 it this way, as you've just illustrated, but we don't see any 23 real reasons to locate them so close to each other.
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l 24 MR. THOMPSON: But I must admit, I believe DOE, on ;
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! 25 the other hand, believes that the 300 foot is an appropriate I
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. 19 1 area, and they are now evaluating that distance in response to 2 our concernt and will either justify their position or that t 3 distance or will be coming forth with a new distance.
4 CHAIRMAN ZECH: All right. Thank you. ,
5 COMMISSIONER CARR: It seems like if it had some ;
I 6 design basis, it would be 343.6 feet or something. i 7 MR. THOMPSON: I think it was sonewhat arbitrary.
. 8 COMMISSIONER CARR: Okay. I i
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1 9 CHAIRMAN ZECH: All right. Let's proceed.
i 10 MR. GUPTA: May I have Vu-graph No. 6, please? l l
11 The third of our objections is related to the DOE's I
- 12 plan to penetrate ES-1 below repository horizon level into an 5 13 important rock barrier between the repository level and the L
14 groundwater table. !
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! 15 In response to this objection, DOE stated that they !
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l 16 are further analyzing the need for this penetration. By [
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17 penetrating ES-1 below the repository horizon level, they I
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18 wanted to verify that indeed the barrier is an important l f
1' 19 barcier between the rapository and the groundwater level, and i
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- 20 also they wanted to do some testing regarding the flow [
j f i 21 chr.cacteristics of the rock interf.9ces. I i !
l 22 However, in response to our concerns, DOE is now l l
i 23 planning to perform a damage versus benefit analysis bafore l L
24 deciding about the penetration.
, i 2$ COMMISSIONER CARR: Are they going to get data from I t i !
20 1 that that they couldn't get from smaller diameter bore holes, 2 they think?
3 MR. GUPTA: That's what they're evaluating right now 4 MR. THOMPSON: or they may be able to get data from 5 another place that's not specifically located on the site. So 6 I think that's the -- the key area is, is this the only place 7 to get the data with respect to that barrier and what's 8 happening underneath there?
9 KR. GUPTA: Their current position, illustrated in 10 the draft mission plan amendment, is not to penetrate into that 11 barrier and terminate the two shafts at 1100 feet.
12 May I have the sketch on the extent of exploration, 13 please?
14 In addition to the three objections on the EST I just ,
15 talked about, we identified many other concerns on the ESF 16 design. An examplo of these comments would be the proposel 17 limited extent of exploration.
18 As you can see, the main test area is located in the .
19 northeast corner of the repository block, which is colored in 20 greer.. The three long grcups are indicated in red. And we 21 considere$. that that much testing would not provide sufficient
.2 information about the southern portion of th6 repository block.
23 There is no underground drifting planned to the south, as 24 indicated here.
25 COMMISSIONER CAPR: Is that rag going to penetrate
21 1 the perimeter like that sketch shows, one of the drift shafts?
2 MR. GUPTA: In the final design of the repository, 3 there veuld be a perimeter drift, but for exploration purposes 4 --
5 COMMISSIONER CARR: They want to go beyond the 6 perimeter?
7 MR. GUPTA: No. They are doing the testing and the 8 exploration only in the northeast corner.
j 9 COMMISSIONER CARR: But I'm looking at your red line
} 10 that goes past the area.
j 11 MR. GUPTA: Oh, yeah, they are going beyond that.
l 12 Actually there is a feature there, the drill hole wash that l /
i 13 they want to see if there could be any potential conflict. And 14 it would also be a ramp, a portion of the ramp in the future i 15 repository.
16 May I have th7 cross-section of the repository,
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- 17 please?
18 This cross-cection here shows that there are many
) 19 features -- it's an east / west cross-section -- shows that there 20 are many parts and sactions that go through the repository, and 21 the repository shape is bounded by many faults, and it's 22 important to explore whether there would be sufficient room in 23 the south and that area is suitable for repository development 24 or not.
25 May I have the next Vu-graph, please.
D 22 1 COMMISSIONER CARR: And the concern is over the area?
2 Do they have enough aren for it?
3 MR. GUPTA: Yes, that is correct. And also it has 4 different geologic features than the north. By just exploring 5 the northern block, you don't get sufficient information about 6 the southern portion.
7 DOE plans to supplement the exploration by separate 8 bore holes in the southern portion of the block. We have 9 raised this concern that bore holes alone may not be suitable 10 for exploration of this portion of the block, and that the DOE 11 should consider additional drifting to the southern portion.
12 As previously mentioned by Mr. Bunting, we considered
\ 13 that the objections and the other comments and questions that 14 we have raised appear to be a symptom of a major problem. What 15 we suspect is that it may be a problem related to DOE's design 16 process.
17 Mr. Kennedy is going to talk about that aspect.
18 CHAIRMAN ZECH: All right. Thank you. You may 19 proceed.
20 MR. KENNEDY: Good morning.
21 Before I begin on design control, I would like to put 22 this issue into some kind of perspective with our objection on 23 the consultation draft site characterization plan.
24 As you know, when we commented on DOE's on 25 consultation draft site characterization plan last May, one of
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23 1 our five objections was on quality assurance. We stated that 2 we didn't have confidence in the QA program at that time. We 3 reconnended thSt DOE not start new site work until the program l 4 was qualifit.~ ind we, on 'the NRC Staff, had conducted 5 sufficient re,<5+ oan c%$lis to agree that it was qualifted.
6 Now .- r'.aded sithii that new site work, of course, is 7 the sinking of te spis gr shaft.
8 Mike, t ,).d I iW u the organization chart?
9 This isn't in your package, by the way. This is an ;
)
10 organization chart of the DOE program, beginning with i
j 11 Headquarters, the DOE Project Offica in Nevada, and the prime i j
12 contr6cters.
i 13 Last June, we met with DOE after issuing our l 14 objection on the consultation draft SEP. We agreed -- we I 15 rather discussed -- what we needed to do to agree that their f j 16 program was qualified. We identified all the specific review [
i l 17 actions we need to take to review their QA program, and if it, [
j 18 in fact, is qualified, to agree that it is so. [
I 19 Now this chart depicts all of the major organizations (
20 in the repository program. It starts at DOE Headquarters at t i
- 21 the top, the Office of civilian Radioactive Waste Management. f
! 22 The next block is the Nevada Project Office, now called the <
1 l 1 1 23 Yucca Mountain Project Office, and underneath that are the I
1 24 major participants in the program -- tha three national labs, j 25 the three Nevada test site contractors, and the USGS.
i
24 -
1 Does that cover them all? I think so.
1 2 Now what we did in June was, we identified all the i
3 specific actions that we need to take with respect to each of 4 those organizations. Now that involves reviewing the OA plans 8 and procedures. It involves observing at least two DOE audits !
i 6 of each of those organizations, and if the programs, in fact, 7 are developed sufficiently, we feel we would have enough ;
8 confidence, based on those actions, to agree that the program 0 was qualified, and that they could go ahead and begin new site 10 work. !
11 Now there's a lot of work to do by us. There's a lot a
12 of work --
1 i f 13 MR. THOMPSON: You might note, Jim, that we have
- 14 reviewed one of the QA programs for the Nevada office of the
! 15 Yucca Mountain and have approved that with certajn, I guess, d i
- t 16 conditions that need to be addressed. So we have taken some !
1 j 17 and have made some specific progress in approving the DOE QA l 18 programs.
I i 19 MR. KENNEDY: I didn't say this, but we also have [
f 20 schedules laid out for all of these review actions, when DOE 1 !
21 needs to submit plans to us and when DOE needs to conduct j l audits, et cetera.
j 22 ,
i j 23 Some of those initial schedules have slipped, so i 24 we're not -- the program is not on schedule right now, although l I
j 25 the recent slip in the schedule for the construction of the l
25 1 exploratory shaft may accommodate the sche 6ule slips we've had 2 so far.
3 COMMISSIONER CURTISS: Is that because of DOE's 4 timing in submission of the plans or our review of those plans?
5 MR. KENNEDY: Both. We've completed one review of 6 the first plan, and it took a little bit longer than ve 7 exp6cted because, first, we didn't resolve all the issues that 8 we expected to in the meeting that we had in July, and second, ,
9 because it wa.s a first. It just didn't go as quickly as we 10 thought. We put dcwn a real ambitious schedule, 30 days for 11 preparing a safety evaluation and getting it through all tto I
12 Staff and OGC. We didn't make it on the first one. We're inuch 13 more optimistic on later ones.
14 But also DOE is slipping on submission of QA plans.
15 A number of t!.cse are overdue.
16 1 was about to nention that we have a number of 17 review actions, and all of those have been identified, and 18 they're on a naster plan.
19 DOE has many more actions to take to make the program 20 ready to review. Nov they have made some real progress in the 21 last ten months or so in upgrading their QA program and getting 22 it closer to where it needs to be. As we've reported in the 23 quarterly progress reports to the Commission, they've 2 i 24 accomplished the following in the recent past:
25 First, they elevated the positien of QA Manager for
26 1 Headquarters -- that is, the office of Civilian Radioactive 2 Waste Management -- to report to the Director of OCRWM. This 3 has been a long-outstanding Staff issue. It's one that we 4 identified three or four years ago. And finally, I believe, 5 back around the middle of this year, they elevated that 6 position.
7 COMMISSIONER CARR Did they fill it?
8 MR. KENNEDY: I was about to say, they just filled 9 it, too. I think back in July. And they filled it with an 10 individual who has extencive management and NRC licensing 11 experience, so we're happy about that.
12 They also got accepted b/ the Staff, as Mr. Thompson 13 vas just referring to. The Yucca Mountain project QA plan.
14 This is the first QA document that's been accepted by the Staff 15 in this program, and it's a major accomplishment for them.
16 What this plan does is lay out the general 17 requirements that each of the organizations, each of the prime 18 contractors in the organization chart, need to meet in their QA 19 programs. So it's a big accomplishment for them.
20 They've also conducted ten audits of their prime 21 contractors in the last ten months or so, and they have become 22 much more effective in identifying problems with their 23 contractors.
24 One thing we're doing now is, instead of our going 25 out and independently auditing at this point, we're going out
27 1 and observing DOE audits, and we're putting the burden on DOE 2 to conduct good audits to find the problems with their 3 contractors and get them corrected, and we've noticed a big 4 improvement in the way they've cond".cted audits in the last ten 5 months.
6 MR. THOMPSON: It's not that we won't conduct our own 7 independent audits. It's just that we can get a more effective 8 view of what DOE is doing in their QA program by actually 9 observing their QA audits and making sure they do the program 10 right, and that's, you know -- they have the primary burden on 11 that. So we think this is a very effective way to use the 12 resources that we have in improving the QA program.
13 MR. KENNEDY: Now there's still a long wcy to go for 14 them, and I don't want to imply by listing off these 15 accomplishments that the objection is close to being resolved, 16 because it isn't.
17 Some of the early milestones have been missed, and 18 there are quite a few review actions yet to be taken by the 19 Staff. But there is progress being made, and I've been 20 involved in this for five years now, and progress is being made 21 at a faster rate than it ever has in the last five years.
22 Now I mentioned this broad concern, because design 23 control is -- the design control is an issue, is one that's a 24 subset of the overall QA program concerns that we have. We are 25 working on design control in resolving the overall QA objection
s 28 1 in parallel, and our plan is to resolve both before the sinking l 2 of the exploratory shaft. J 3 The design control is particularly important now, {
4 because it affects our ability to comment on the site S characterization plan, which is due to be submitted at the end 6 of next month. I'll talk about this a little bit more later. l i
7 CHAIRMAN ZECH: Excuse me. Let me interrupt you for !
8 a second.
- l
! I 9 You say the site characterization plan is scheduled ,
4 .
4 10 to be issued next month. !
11 MR. KENNEDY: At the end of next month, right.
[
1 12 CHAIRMAN ZECH: What you've commented on already, as 13 I understand it, is the consultation draft site i 14 characterization plan; is that correct?
I l 15 MR. KENNEDY: That's right.
- 16 CHAIRMAN ZECH
- And there's where you've given your ,
}
17 concerns. l
[
l 18 MR. KENFEDY: Exactly. r 1
i 19 CHAIRMAN ZECH: And they've been working on these Can we then expect that those concerns that you have 20 concerns. [
f
]
i 21 already voiced will be incorporated in the plan that will be l
\ l 22 $ssued by the end of December, next month?
{
r i
! 23 MR. KENNEDY: Only in a general way, because the site j
l
- 24 characterization plan, especially for quality assurance, has l
! l 25 only a relatively small chapter on quality assurance. l i !
t I
29
.' 1 CHAIRMAN ZECH: Well, then, --
[
t 2 MR. KENNEDY: It will be addressed, but in ordt.r for !
l 3 us to resolve the objection -- i 4 CHAIRMAN ZECH: Well, as I understand what you're f
5 saying, though, it may not be addressed sufficiently; is that 6 correct? ;
] 7 MR. KENNEDY: There will not be enough infr,rmation in l
8 the plan. l i
! 9 MR. THOMPSON: I think we'll get to that, Mr. i 10 Chairman, because there's a kind of parallel process that will {
l 11 be ongoing. The site characterization plan which will be I
12 submitted for review, it will - it's been developed in response i i t 13 to our previous comments, and as we said earlier, the focus on l l
l 14 the QA problem and the design control problem was done -- was l 15 kind of concluded after they probably put a lot of the site l j 16 characterization plan together. f i
1 .
I 17 So they've got a re-review process that's in j
[ t i>
18 progress, and I think we'll talk about exactly how we're going !
l j !
19 to be addressing this in parallel.
) 20 But you're right, Mr. Chairman, we've got to address l 21 both of these in parallel, and there is some risk that the site ;
1 1 22 characterization plan may have to be revised to reflect any J i 23 changes that may come out of this parallel review. [
CHAIRMAN ZECH: Well, if I understand what you're f
)l 24
! 25 saying -- and I don't want to interrupt your briefing to any l
}
i
30 4
1 degree -- but you've indicated previously that you see an ;
2 inadequate design control problem in the DOE process.
3 You've been concerned about the adequacy of the i
4 design. Those are clearly fundamental, it seems to me, and 5 you've talked about addressing problems, not the symptons, 6 again rather fundamental in my judgment Those are kind of 7 fundamental concerns.
t 8 So therefore, if what you're telling us is that l
9 they're going to issue a site characterization plan late next 10 month that still has those concerns involved in them, how will 11 you be able to review that plan? Do you have confidence that 12 you will be able to review the plan at the end of next month, i l 13 recognizing already that it has perhaps those deficiencies? t 14 Mk. THOMPSON: I think we will address that, Mr.
15 Chairnan.
16 KR. KENNEDY: That's the heart of the issue, in fact.
i 17 CHAIRMAN ZECH: Please do. ,
18 MR. THOMPSON: That's why we all want to make sure 19 that you understand hov ve're going about that process. l 20 CHAIRMAN ZECH: I think we understand it, but I'd ;
f 21 appreciate your addressing those as you go on. !
22 You may proceed. !
23 MR. KENNEDY: Okay. Now thus far today, Dr. Gupta I r
24 has talked about a number of specific concerns related to the [
25 exploratory shaft. As he said, we believe these may be
. _ _ _ _ _ - - - - - - - - . ~ __. .- _ _ _ _ _ .-_ _.
31 i symptoms of a larger problem, and that needs to be corrected by 2 DOE, and that problem is design control.
3 This is important to us as a regulatory agency, 4 because we can't review all the work that DOE performs with 5 respect to the shaft or any other activity, for that matter.
6 It is not enough for DOE to just address the specific issues 7 that we raise, because we have not, will not, and cannot look 8 at everything. They and we need to rely on a program of 9 controls implemented by them to give us confidence that work is 10 performed adequately, and this program is a quality assurance 11 progran of which design control is a part.
12 Now the scope of the design control progran is
% 13 activities affecting the public health and safety, and for the 14 repository, this is activities which are either important to i 15 safety or waste isolation, terms which are defined in Part 60.
16 Now it's the Staff's position that the exploratory 17 shaft facility is important to waste isolation. The ESF
! 18 activities, therefore, need to be performed under a design i 19 control program which meets our QA requirements in Part 60.
1 20 Now let me define the problem that we see in the DOE 21 design control program. We have design requirements in 10 CFR l 4
22 Part 60. DOE has design requirements in a document called its 23 Subsystems Design Requirements Document. This is a detailed i
) 24 assign requirements document which is used by the various l l .
?! - aanizations within the DOE program.
i I
32 1 The problem is that there's no docu.nented design 2 control process that clearly shows how DOE considered all t'to r
3 Part 60 requirements in developing its detailed design ,
4 documents. In fact, there are at least three areas, as t
5 mentioned by Dr. Gupta, where it appears that these l 6 requirements were not addressed or were not addressed 7 adequately.
I 8 Tailure to adequately these Part 60 requirements nov 9 could jeopardige the ability to license the repository in the 10 1990s, but what makes this particularly important right now is 11 that DOE is scheduled to submit their site characterization 12 plan next month. As Joe Bunting mentioned earlier, under the
! 13 Nuclear Waste Policy Act and under 10 CFR Part 60, we are 14 required to review and comment on that plan, and DOE is 1
15 required to consider our comments, particularly on the l 16 exploratory shaft.
17 However, DOE hasn't demonstrated to date that the 18 design, as presented in the site characterization plan, is l 19 adequate, and thus our ability to give valid comments on the ;
20 site characterization is in question and vill remain so until ,
21 our concern is resolved.
22 That's the heart of the issue that you were bringing ;
23 up earlier.
l 24 CHAIRMAN ZECH Right. Well, when is that going to ;
! 25 be? You going to got a plan, and then how are you going to I
r t
~
33
< . 1 resolve these issues? Do you have any --
^
i 2 MR. KENNEDY: That's what Joe Bunting is going to I 3 talk about. [
4 CHAIRMAN ZECH: All right. Is that next? [
5 MR. THOMPSON: The grand finale. Now, Joe, you've 6 been built up so will now --
I 7 (Imughter. ) ;
]
l i
8 COMMISSIONER CARRt Let me make sure I understand l 1
, 9 this design control problem. Is it basically the rationale a
j 10 behind the design, and then the rationale behind any changes to j 11 the design that you're missing? !
12 MR. KENNEDY: It's really the rationale, right, the 13 design input. That is, taking the basic requirements, design (
14 requirements of Part 60 and incorporating them into their f
) 15 design.
l 16 COM:!ISSIONER CARRt You mean, why you pick this l 17 design over any other design?
q 18 MR. BUNTING: The question you raid:d Earliert Why l
l 19 12 feet? Why 300 feet apart?
j 20 COMMISSIONER CARRt Some substantiation for that.
i l 21 MT.. CUPTA: Some of the requirements were very 22 specific, like the two shafts shall be located at thesti 23 coordinates at the site. They shall be 300 feet apart. They I
- 24 will be 12 foot in diameter.
i j 25 COMMISSIONER CARRt The question is why.
I
l 4
i
, 34 !
, l 1 MR. GUPTA: Why, yes. We didn't see any ,
2 documentation to justify that.
3 COMMISSIONER CARRt Does the program also, then, once P
. 4 you get the initial design agreed to, all the changes have to r
I
- 5 be explained in the same manner?
6 MR. KENNEDY: Absolutely, absolutely.
7 COMMISSIONER CARRt And so that's lacking in both j 8 cases right now. :
l i 9 MR. THOMPSON: There are two aspects about it. There i l l 10 are some things that may not be safety-related with respect to 11 the design of the exploratory shaft. Right now, the approach, [
! 12 the conservative approach, that we're saying is. treat it as l
13 it's all important to waste isolation, quote, safety-related.
14 And if there were other things later on, you can demonstrate, l f
15 you know, the elevator operations, et cetera. There may not be
, {
16 a need for all activities associated with the exploratory shaft I
j 17 to be under this design control QA program for NRC [
i t 6
! 18 requirenents, but until we can identify those parts that are (
l 19 not, we believe that the best approach is to take this approach .
t 20 that everything ic safety-related or important to waste )
f I
l 21 isolation. !
l !
22 COMMISSIONER CARR: It might break out to subsurface l
23 or --
j 24 MR. THOMPSON: There may be some aspects associated l l
j 25 with it. L i I
- i i
! l
35 1 CHAIRMAN ZECH: Have you addressed all these concerns 2 to the appropriate DOE officials?
3 MR. THOMPSON: Yes, sir.
4 CHAIRMAN ZECH: You have?
5 MR. THOMPSON: That was those meetings that we've had 6 with them --
7 CHAIF00di ZECH: I hope so.
8 KR. THOMPSOP: -- back in May and July and October 9 and Novenbor.
10 CHAIRMAN ZECH: Well, there should be no surprises as 11 to what we're expecting to get from DOE; is that correct?
12 MR. BUNTING: That's correct.
i 13 CHAIRMAN ZECH: All right. You may proceed.
14 MR. BUNTING: If you would turn to Chart IX, please, 15 this is the resolution approach, which has been tentatively l
16 agreed to by the Staff. As stated by Mr. Kennedy, DOE has 17 agreed to impler.ent a design control process for future 18 activities, but it will not be applied to design data that will 1
19 be presented in the site characterization plan on which DOE t 20 expects the Staff and the Commission to review and render our i
21 "no objection" or list our specific objections.
22 The Staff has taken the position that DOE's 23 resolution approach for the siting and design information 4
24 presented in the plan -- this is the site characterization plan
) i 25 -- must include a denonstration that they have included 10 CFR
36 t 1 60 regulatory requirements in their siting and design criteriar 2 for example, vaste isolation. We have to see that. I 3 They must also demonstrate that they have included in !
4 their decision criteria the appropriate interface requirements 5 between construction, the exploratory facility, and other [
I 6 ongoing activities -- testing, for example. And for future !
7 activities, the Staff has taken the position that the design I
l 8 control process that meets 10 CTR 60 requirements must be in l place before beginning to sink the shafts, j 9 f
10 Now the Staff has tentatively agreed to this multi-
]
.1 ;
j 11 step process which is summarized on this chart. The first four i t
j 12 bullets that you see on the chart relate to analyzing the f
- 2 r
13 acceptability of the design as it's presented in the site !
)
j 14 characterization plan. j
- t 15 The fifth and sixth bullets have to do with approving j
{
) '
l 16 the design control process before beginning to sink shafts.
j 17 This is future activities.
18 The last bullet indicates that the results of our i
i l 19 evaluation of the design acceptability analysis, which is the 4
i 20 first four steps, will be reported in and as part of the NRC's
, 21 site characterization analysis.
I 22 Now the opportunity for interaction with DOE during 23 their conduct of this acceptability analysis is uncertain [
i 24 because of the prediction pressures for the site l l
1 f l 25 characterization plan next month. Nov DOE has indicated that !
1 i !
i ;
i 37
] 1 they do want to meet with us on this process next week.
2 The acceptability analysis is planned to be submitted
, i 3 as part of the site characterization plan itself, but the f
- 4 concurrency of this approach has some risk, which can probably l i
5 be best illustrated from this next and last chart.
l 6 Turn to Chart X, please. [
7 The first area of risk is in the NRC's schedule for !
) !
l 8 review of the site characterization plan. One month has been !
i j 9 added to this schedule to accommodate the review by the new
! l l 10 Advisory Committee on Nuclear Waste and also by review by you, l l 11 the Commissioners.
) 12 Now assuming that DOE's acceptability analysis is f
' t
% 13 submitted with the site characterization next month, the Staff f 4 i i L
- 14 will be required to review this additional documentation during [
L j 15 this same intense review period and reach and independent
- 16 judgment on its adequacy. f
\
l 17 In addition, we have to also review all the I
18 documentation which they will be submitting to close out these
' i j 19 numerous action items that are still open. We do not yet have r
{
20 a feel for what this will entail, but if past is prologue, we ;
a ?
1 l 21 can expect a substantial additional volume of information.
! 22 CHAIRMAN ZECH: Is that what that question mark up
! 23 there means?
I I l 24 MR. BUNTING: Yes, sir.
j 25 CHAIRMAN ZECH: All right.
I I
- t
38 j 1 MR. BUNTING: The question mark up there means, for l L
2 the next part, will they actually submit it then or not, and 3 I'll speak to that next.
a 4 CHAIRMAN ZECH: All right.
5 MR. BUNTINGt The second area of -- well, to finish !
6 up the first one, the notion on the first one is, we have an f
7 additional workload to be performed in the same time period 8 we've already laid out, and that additional workload is this j i
9 new design acceptability analysis, as well as the close-out of l l 10 open items, and that's assuming it's submitted on time. l l i j 11 MR. THOMPSON: That is a slight change of the l 1 12 approach that we had before. At one time, DOE was wanting l
, o ?
13 quick comments on the exploratory shaft, in a three-month !
! l 1 14 timeframe. Now, you know, it's an integrated part, and I think i 1 :
r 15 it's a sounder approach to do it as a full part of the l l
16 Commission's comments and reviews on the site characterization {.
I
! 17 plan. It just fits together better with our ability and the 1
18 fact that the exploratory shaft design information is not being 6
i I
19 made available to us earlier. So there is a change, I think, !
l !
j 20 from what we may have told the Commission in some earlier 1
- 21 reports on the review schedule there.
1 I
22 COMMISSIONER CARR: As I read this, you're not 73 looking, then, for the best design; you're 1 coking for an 24 acceptable design.
]
I .
- 25 MR. BUNTING
- Yes, sir. j i
l 1 i
39 1 COMMISSIONER CARR So you're not really looking to 2 generate the design control that you'd like ta have a a basis.
3 I'm just trying to make sure the original start point is a 4 workable one.
5 MR. BUNTING: Yes, sir.
6 COMMISSIONER CARR Okay. i 7 NR. THOMPSON: But we are looking for, you know, the 8 aspect of a full QA program, such that we believe that this is 9 an important issue that DOE ought to start those site 10 characterization activities, you know, in a first-rate way.
11 COMMISSIONER CARR: But they don't have to prove that 12 the ESP is being built --
11 KR. THOMPSON: Oh, that's correct.
14 CHAIRMAN ZECH: But it has to be acceptable, and it 15 has to be, you know, it has to give us the confidence that it 16 truly ir ,;ceptable. So it just -- I hope'it's not going to be 17 something that's right at the margin where there's a concern 18 about it. It should be acceptable in every sense of the word.
19 MR. THOMPSON: And certainly technically sound and 20 acceptable as part of eventually being a part of the repository 21 at the site for a long period of time.
22 CHAIRMAN ZECH: All right.
23 MR. BUNTING: If we could put the chart back up, 24 please, the second area of risk is the DOE schedule, which is 25 shown on this bottom lower line, and I want to talk to the
40 1 question mark that you raised earlier.
2 Although this schedule does reflect a five or six-3 month slip in the start of construction of the facility, there a 4 is no slip in the planned December submittal of the site 5 characterization plan, and there is very little time remaining 4
6 between now and the scheduled time for that plan's submittal.
7 Now the longer the delay -- and that's what the a 8 question mark is supposed to illustrate -- the longer the delay l 9 between the submittal of the site characterization plan and the J
10 submittal of the design acceptability assessment, the more 11 uncertainty there vill be that we will be able to complote the I 12 site characterizati analysis within the scheduled time. If 1
j 13 we get a bunch of information duwped somewhere in the middle, of i
j 14 our review process, it may impact on things wu've already j
l 15 looked at. So that's just a risk.
I i
1 16 CHAIRMAN ZECH It may impact on the effectiveness of
)
17 your review process; is that what you're saying?
i 18 MR. BUNTING: Yes, sir.
19 CHAIRMAN 2ECHt Well, then I think it's important
} 20 that you take the time you need to do it right, i
21 MR. BUNTING: Yes, sir.
i l 22 CHAIRMAN ZECH: If it lengthens the process, so be 1 23 it, as far as I'm concerned. You've simply got to have the 1
l 24 time to have the confidence that you're doing it properly.
l 25 MR. BUNTING: Yes, sir.
4
41 1 COMMISSIONER CARR: Do you have to finish that before 2 they can start site preparation?
3 MR. BUNTING: No, sir.
4 COMMISSIONER CARR: So really you have to finish it 5 before they can commence with the construction. So you've got 6 a four-month hole in there right now.
7 MR. BUNTING: Yes. I'm going to speak to that.
8 COMMISSIONER CARR Okay.
9 MR. BUNTING: Now the third area of risk is in the 10 outcome of the acceptability analysis itself. If DOE finds 11 some significant omission or if we, the Staff, have a l
12 significant problem with the justification they submit, it's
\ 13 likely going to take time to resolve that problem. That's just 14 another risk that I point o",t to you.
15 I want ta tu quick to point out that there is a four-16 month difference now on this schedule between our scheduled 17 issuance of the site characterization analysis and the start of 18 construction of the facility in November. We don't know how 19 nuch slip, it eny, DOE could tolerate in the issuance of our 20 report and still hold to their start-construction schedule.
21 But as stated earlier, both t:. Act and our rules require that 22 they defer sinking the shafts until they have considered the 23 Commission's comments.
24 Now to summarize, we presented you today with the 25 factual information, together with the new irsights we've
I 42 l j 1 gained, on the significance of the multitude of issues raised e i
2 on our review of the consultative draft site characterization i 3 plan.
4 And remember, we've only discussed five of these
{
, L 5 issues here today. We've also presented you with this j 6 tentative approach to resolve the issues of design control, [
7 both for the future and for past activitius, and have outlined 8 the associated risks. We've had numerous interactions with }
l 9 DOE, and progress is being made in resolving many of these
- i
]
10 individual open items, and we have made DOE aware of our l
{ 11 concerns regarding the larger problem of d oign control. {
i f 12 In clositig, we want to state that we are well aware 13 that DOE is responsible to meet and to demonstrate that it has :
$ (
j 14 met the regulatory requirements, which in this instance are l:
J !
15 quite clear. We have related to DOE those conceptual steps we l l
j 16 believe must be included in any attempt to validate past [
' i j 17 actionu. We are ever mindful that responsibility rests with
! 18 them to implement a successful approach to resolve this !
) i 19 problem. The decision on the soecific approach and the l
{
20 implementation is DOE's. We do not consider that our efforts f
]
f 21 to suggest certain conceptual concepts would prejudice our :
]
22 evaluation of the adequacy of the approach, its implementation, 23 or its outcome.
24 This concludes our presentation. Thank you, Mr. l l
J !
l 25 Chairman. l l i
- t
f 43 -
1 CKAIRMAN ZECH All right. Thank you very much. ;
i i'
2 Questions from my fellow Commissioners?
3 Commissioner Carr? ,
4 COMMISSIONER CARRt Yes. This thing is designed .
L 5 already, isn't it? So you've already got the -- ,
6 CHAIRMAN 2ECH Excuse me. Answer when you nod your t 7 head. please give us a yes or no. i l
- 8 MR. BUNTING I'm sorry. I want to say that one J l
9 phase of the design is done already, a preliminary design. [
J 10 They will go three reiterations of the design. l 11 COMMISSIONER CARR We have that already, and so -- I
)'
(
1 12 assume? !
i r
! \ 13 MR. GUPTA: We are getting copies of it. We do not ,
l I
l 14 have a full set of the design yet.
l i 15 COMMISSIONER CARRt We can get them. l I !
I i 16 MR. GUPTA: We can get them.
17 COMMISSIONER CARRt So we can get ahead of the 18 problem and the design analysis. We'll know pretty much what 3
19 areas we're worried about, so when the analysis comes in, we i 20 can focus on those first, I would assume. .
I I
l 21 MR. GUPTA: That is correct, yes. j J
r i 22 COMMISSIONER CARRt Okay. I'm a little worried about l l I J
23 management problems. They're playing musical chairs over ;
1 i
! 24 there. Since I've been here, we've had a lot of different guys l 4
i i j 25 in charge over there, and I can't figure out, how do you feel '
i
._._________________]
b 44 H\t 1 about -- have you gea somebody to work with over there that
- 2 feels like he's ping to be there long enough to get it done?
I l 3 MR. THOMPSON: Well, that is an issue, Mr. Chairman, j 4 that is one that we do face. They have certain individuals, I
} 5 think, who have a continuity in the licensing process. Some of 6 their, you know, key managers have changed and moved on. That 7 certainly could be part of the symptom of why some of the 8 design control issues themselves kind of fell apart, because l
- 9 that is ene tool where you can -- management can use to assure 10 themselves that the process is working as ynu have changes in li 11 managers.
f 12 So that's one of the reasons that we think this is so 1 .
13 important.
14 COMMISSIONER CARRt I guess my concern is, are they 15 making decision, or are they waiting for somebody to come in 16 who can make them?
17 MR. THOMPSON: They are making decisions. At least l 18 our experience in the last six to eight months is, you know, 19 the previous set of managers were making decisions, and we were 20 able to make progress, and I think, as Jim Kennedy said, we've 21 ande more progress, I believe, in tha last year than we had in 22 the previous four years in getting issues resolved.
23 So I see the DOE people making decision. Obviously, 24 there vill be a new change, and we will be observing it, and 25 ve'll report back w you any time we see a problem with them
. . h' ,
45 1 making decisions.
2 C 'ISSIONER CARR: Okay. You mentioned that we 3 . missed , _ i lay goal. How far did we miss it?
4 KENNEDY: I think -- it gets a little confused, 5 because Enere are some assumptions about --
6 COMMISSIONER CARR: Was it an order of magnitude, or 7 another 30 days, or --
8 MR. KENNEDY: Two weeks or 30 days, something on that 9 order.
10 CCMMISSIONER CARR: Is that going to -- are you 11 reevaluating that? Do we need to put more resources and 12 manpower into it?
c
+
13 MR. KENNEDY: Our strategy is right now, we've got 14 another one due in shortly, and after the first one is done, wo 15 think the others are going to go much smoother, and the first 16 one ve get after that will be the test.
17 MR. THOMPSON: I'll be watching that very carefully, le Commissioner, because one of the things we are looking at is 19 the staffing levels in order to be able to do our reviews in a i
20 timely fashion, and QA is a key area right nsw.
l 21 CHAIRMAN ZECH: Commissioner Rogers?
22 COMMISSIONER ROGERS: In the whole process, as you 23 see it, is there the mechanin7 for identifying any really 24 serious sticking points with respect to our ultimate ability to 25 -- that could be identified as early on as possible? In other
46 I words, what are we doing to avoid making a final decision on
\.
2 this -- waiting until we have to make a final decision on this 3 site before identifying any really killer problems with respect 4 to the suitability of the site?
5 lt's an issue that obviously is, you know, out there, 6 and we're talking about a fairly long overall process before we 7 start to render our decisions, and I know we're working 8 together with the DOE on this, but have we got some way of 9 really trying to make sure that very serious questions about 10 the suitability of the site are looked at as early as possible?
11 MR. THOMPSON: Well, certainly that's our key 12 underpinning, the looking at it, because, you know, if we E 13 ddentify a fatal flaw, we're going to call it as ; con s we 14 find it.
15 But let me see if Bob Browning may want to address 16 that in a little more detail, because I think that's a key 17 issue, both from resources of the U.S. Government, as well as 18 the indust 19 MR. BROWNING: I think the key issue with regard to 20 your question is sinking the sift, getting down to depth, and 21 finding out what's going on down there. I think there's a 22 consensus on our technical staff, at any rate, that that's 23 going to be the key question as to what's going on at that 24 site. Therefore, there is a legitimate reason for keeping 25 production pressure on getting down to depth. Whether this is
47 1 exactly the r',ght way to get down there or not is a question, 2 but there's absolutely no question that it's important to get 3 down to depth and start drifting, start exploring, start 4 running the tests at depth. That's the key to the answer to 5 the question.
6 Until we do that, we can do a lot more stuff from the 7 surface, but my impression from talking with my staff, at any 8 rate, is that we've about exhausted our ability to investigate 9 this thing from the surface.
10 COMMISSIONER CARR: So anything from a surface 11 evaluatior standpoint that would say this is an unsuitable site 12 has been done, then?
13 MR. BROWNING: That's my impression; yes, sir. ;
14 CHAIRMAN ZECH: All right. Anything else?
15 Commissioner Curtiss?
16 COMMISSIONER CURTISS: I had just one quick question, 17 going back to the point that Mr. Thompson made.
18 As I understood the way you articulated the point, wo 19 are assuming, as an agency, that all of the DOE design l 20 requirements are safc ty-relatr.d, unless DOE can establish that !
21 they aren't. And I wonder '.n the context -- well, I guess I 22 have two questions. l I
i 23 One, were we -- what was this agency's involvement in 24 the preparation of DOE's subsystem design requirements? Were ,
{ 25 we involved in that stage? i
$ 48 1 MR. GUPTA: No, we were not involved in that project 2 at all.
1 3 COMMISSIONER CURTISS: I'd be interested in what the 4 premise is for assuming that all of the design requirements are !
5 safety-related and whether the time necessary to complete the 6 work on the parallel review of the SEP and the design 7 acceptability analysis may, in part, be minimized if there's 8 some kind of prima facia showing that some of these 9 requirements can be disregarded, lest we get into the situation 10 where we're trying to prove the negative on every single DCE 11 design requirement.
12 MR. THOMPSON: I was talking about the design i
13 requirements related to these exploratory shafts, because they, f
14 in fact, do become part of the repository, if, you know, the t
15 plan proceeds as we currently understand it.
16 I don't know --
17 MR. BUNTING: I think we'll defer to Mr. Kennedy, 18 because that's a fundamental premise in the QA and how you 19 approach QA. You can't go back and --
l 20 MR. KENNEDY: I think it gets to how does DOE show 21 that some of these things are not important to waste isolation, 22 and some of them, I think, are going to be obvious. We are i
23 starting with the premise that everything is important to waste 24 isolation until they can show otherwise.
l 25 Some, I think, are going to go away fairly i o
49 1 straightforwardly, like the hoist that's used to lower men 2 materials down the shaft.
3 CHAIRMAN ZECH: Would you speak up just a little 4 louder, please, for the reporter and also the audience. Thank 5 you.
6 MR. KENNEDY: Some are going to go away fairly 7 quickly, like the hoist for example. That's fairly obvious 8 that that's not going to be something that affects waste 9 isolation.
10 Others may be more difficult to show that they are 11 not important to waste isolation. For example, drilling and 12 blaating of the shaft. Blasting will create cracks in the 13 rock. It will create pathways for water, and that's likely to 14 be one that's going to be an activity that is going to be 15 important to waste isolation.
16 Does that answer your question?
17 CHAIRMAN ZECH: Yes. Commissioner Rogers, you had 18 another question?
19 COMMISSIONER ROGERS: Yes. What's your thought on 20 the expected time to sink these shafts of about 18 months? How 21 does that look?
22 MR. GUPTA: That seems to be realistic, yes.
23 COMMISSIONER ROGERS: Is that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven 24 days a week operation?
25 MR. GUPTA: Yes, three shifts. And it would be
50 l 1 interrupted with the testing and all those requirements. We ;
2 consider that to be an appropriate estimate.
3 CHAIRMAN ZECH: Has the Department of Energy 4 indicated a willingness, in our view, to resolve these concerns 5 that you have for the exploratory shaft facility?
6 MR. BUNTING: Yes. They have indicated a willingness 7 to -- at least a tentative agreement on these -- the seven 8 multi-step approach that's been laid out here. We are 9 interpreting that to mean yes.
10 CHAIRMAN ZECH: All right. Then you consider that 11 you are making satisfactory progress?
12 MR. GUPTA: Yes. As a matter of fact, we have 13 already planned a meeting with the DOE next week, discussing 14 the first stop of this process.
15 MR. THOMPSON: I think, Mr. Chairman, in the November 16 mooting, we really reached that area where I think we were in 17 agreement that there's a plan to be put in place to resolve the 18 technical concerns that we had, and we were satisfied that if 19 DOE did the steps that we we agreed to in the November meeting, !
20 that that would be appropriate in resolving the --
21 CHAIRMAN ZECH: But it's my understanding that yoa're 22 going to get the site characterization plan in December, and 23 all of your concerns will not be resolved. I think that's what l
24 you're telling us.
25 MR. THOMPSON: That's correct. But we have the
51 1 parallel path that they will submit that design acceptability 2 document. Right now, DOE is trying to submit it at the samt 3 time, which should address most of the technical concerns.
4 CHAIRMAN ZECH: I guess my concern about this is, you 5 already know you're going to get a site characterization plan 6 that you're going to have concerns in, and my concern, then, 7 really is the effectiveness of your review.
8 So what you're going to be doing apparently will be 9 repeating some of your concerns as you review this site 10 characterization plan; is that correct?
11 MR. THOMPSON: That would be correct for those 12 aspects -- remember they weren't addressed in the site 13 characterization plan.
14 COMMISSIONER CARR: Is it the plan itself or the 15 details that come with it.
16 MR. THOMPSON: The details that are going to be in 17 acceptability should address the questions that we raised 18 previously with respect to the design adequacy. So we won't be 19 reviewing anything in the site characterization plan that 20 addressed the waste isolation issue, as I understand it.
21 CHAIRMAN ZECH: And in those areas, then -- and on 22 that specific issue -- DOE already knows your concerns, and 23 even though they haven't been finally addressed, they will be 24 addressed eventually; is that correct?
25 MR. THOMPSON: They are addressing that in the
l 52 l 1 parallel document.
s 2 CHAIRMAN ZECH: All right.
3 MR. THOMPSON: So it's kind of like a supplement, you 4 might want to say. It's the first e:.pplement to the site 5 characterization plan.
6 CHAIRMAN ZECH: I must say, I think it could have 7 been done a little bit better. It would have been nicer to get 8 the site characterization plan with all of our concerns l 9 addressed. And what you're telling us, I guess, is that since 10 that's not the case, that you have, or DOE has, a parallel I 11 initiative to eventually address these plans in a supplementary 12 way or something like that; is that correct?
13 MR. THOMPSON: We believe we'can do it in this 14 approach. Unless the Commission directs, you know, otherwise, 15 .we plan to go this way.
1 16 CHAIRMAN ZECH: But do you need the Commission to get 17 involved?
18 MR. THOMPSON: Not at this time.
19 CHAIRMAN ZECH: Or are you satisfied --
r 20 MR. THOMPSON: We're satisfied at this time that the !
I 21 program is working.
22 MR. STELLO: Let me try to make a point that maybe 23 will help. I understand the problem you're describing, and I I
24 agree, it is a problem. But there is one aspect of this that I !
25 think mitigates a great deal. And that is, those particular l
l
53
, 1 design issues that were significant in our m'nd and we're very g
2 important, we've already told you about them, and those will be 3 addreased.
4 Now the broader implication of the problems of lack 5 of design control, as it may have affected some other things, ;
6 they clearly by definition are not the major, significant !
7 issues that would have caused us to say, no, we can't go 8 forward; we don't agree.
9 So those that are important are already on the table.
10 Those will be addressed. To the extent -- and I'm not trying 11 to say we aren't going to have a problem, because every time 12 you go about doing a review like this, it's difficult -- but I
( 13 think that the big isaues are at least on the table, and they 14 are aware of them, and.they will be addressed.
15 CHAIRMAN ZECH: All right, fine.
16 COMMISSIONER CARR: Mr. Chairman, I nocice that DOE 17 is going to come over and brief us on this on the 9th of !
18 December, according to my current schedule. i 19 CHAIRMAN ZECH: Yes, I think that's correct.
20 COMMISSIONER CARR: I would hope that you have 21 relayed to them that we want some answers to some of theso l 22 questions we're asking today before they got here, because j
23 obviously their plan is going to come after they get here.
24 MR. STELLO: I assume they're in the audience, and I 25 think you can count on their being aware of the .ssues that tho
1 j
54 1 Commission is ir'.orested in.
2 COMMISSIONER CARR; I hope your assumption is 3 correct.
4 MR. THOMPSON: I'll verify that. I'll be seeing Mr.
5 Russo this Friday.
6 CHAIRMAN ZECH: All right, f ilio . Well, let me just 7 say, I would like to commend the Staff for the efforts that 8 they've taken in this regard. This is a very important issue.
9 I think the High-Level Waste Division has dono an excellent 10 job.
11 I would also join Commissioner Carr's concern about 12 the management changes that we've had at DOE. I think we've 13 had some fino people involved in it, in this whole important 14 issue in DOE, but when they have as many changes that havo 15 taken place, it does -- the continuity has to have somo kind of 16 an impact.
17 So I would encourage the Staff to continuo working on 18 this issue, continuo making known your concerns to DOE, 19 watching very carefully that you have the timo to review the 20 whole plan and take the time you nood to review it with 21 confidenco.
22 I'd also ask that you continue working closely with 23 the State of Nevada, the affected countics and Indian tribes 24 that might be affected, and I look forward -- I know that lay 25 colleagues do, too -- when we hear from DOE, to hear their
55 1 presentation.
2 I can't help but have the feeling that even though we 3 are talking about something that's going to happen in the 4 future, that the decisions and the questions that we're raising S now are extremely insortant, and we must have confidence that 6 the experts we havs in the reviewing of this whole technical 7 issue will be able to proceed one step at a time, ca:efully, 8 conservatively, but with confidence that we're making the right 9 regulatory decisions.
10 But I do think the Staff is acting responsibly. I 11 would ask you to continue an energetic approach. Continue 12 raising concerns. This is a very unique and important national e
13 issue, and we have the special trust and confidence of the 14 public in this regard. I hope all of you will keep that in 15 mind.
16 Our fellow citizens are indeed counting on us to make 17 the right decisions, and it is a large responsibility. So wo 18 need to take the time we need, in my judgment, and we need to 19 be careful, conservative in our scientific and engineering 20 judgments, and I think that we're doing that so far. But I 21 just can't emphasize the importance of it, even at this stage 22 this now, that we continue to keep this high on our priority 23 list.
24 And I hope, Mr. Stello, that you will give the Staff 25 overy support that they need, and I hope also that you will
56 o 1 continue to keep the Commission informed and ask for any
~1 2 specific help that you feel that is necessary.
3 MR. STELLO: Yes, sir.
4 CHAIRMAN ZECH: Commissioner Rogers?
5 COMMISSIONER ROGERS: Yes. To what extent have we 6 used to date our advisory center at Southwest Research 7 Institute in anything that we've been hearing about today?
8 MR. THOMPSON: On the exploratory shaft?
9 COMMISSIONER ROGERS: Yes.
10 MR. THOMPSON: I don't believe we've used them too 11 much in this area. Joe?
12 MR. BUNTING: No, sir, we have not. We have received 13 one report on the potential for flooding, but it was really 14 done by our subcontractor, the center's subcontractor. They
] 15 just didn't have the capacity to do that at this time.
16 But that was a conscious effort on our part, that f 17 during this first year, there would be a plan, and we 18 consciously decided to rely on an existing contractor to 19 support this review.
20 COMMISSIONER ROGERS: Well, are they following --
21 MR. BUNTING: Yes, sir, they are.
22 COMMISSIONER ROGERS: -- thir whole thing in great 23 detail? !
24 MR. BUNTING: Absolutely, absolutely.
25 COMMISSIONER ROGERS: So they can see how the aystems i
6 57 1 that they've been putting together for assisting us would work?
2 MR. BUNTING: Yes, sir. Mr. Patrick, the Technical 3 Director, was with us and supported us in our review in October 4 at the Forrestal Building with DOE where we laid out these 5 problems, particularly design control.
6 COMMISSIONER ROGERS: I think it's very important to 7 make sure that they are part of this, even if we're not relying 8 on then for consultation, that at least they are finding out 9 what the problems are, so that they can develop their own 10 systems for future assistance to us.
11 CHAIRMAN ZECH: Is there another comment?
12 MR. KENNEDY: Yes. I should add that just recently l
13 they started assisting i on observing DOE audits, including 14 some of the audits of the DOE contractors that are working on 45 the shaft design.
16 CHAIRMAN ZECH: Very good.
17 Are there any comments from my fellow commissioners.
18 (No response.)
19 CHAIRMAN ZECH: If not, thank you for an excellent 20 presentation.
21 We stand adjourned.
22 (Whereupon, at 11:12 o' clock, a.m, the Commission 23 meeting was adjourned.)
24 25
CERTIFICATE OF TRANSCRIBER This is to cirtify that the attached events of a meeting of the U.S. Nuclear Regulatory Commission entitled:
TITLE OF AEETING: BRIEFING ON STATUS OF LOCATION OF EXPLORATORY SHAFT AT YUCCA MOUNTAIN PLACE OF MEETING: Washington, D.C.
DATE OF MEETING: WEDNESDAY, NOVEMBER 16, 1988 i
were transcribed by me. I further certify that said transcription is accurate and complete, to the best
. of my ability, and that the transcript is a true and I
accurate record of the foregoing events.
'h lb
( d ,t o I-I Ann Riley & Associates, Ltd.
9
~-
COM:41SS10N BRIEFING ON THE REGULATORY CONCERNS REGARDING Tile EXPLORATORY SHAFT F AClllTY (ESF)
FOR THE YUCCA MOUNTAIN SITE NOVEMBER 16, 1988 Cor: TACT:
J. O. But T!t:G X23394 4
- e 4
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5 h
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PURPOSE:
- 1. TO INFORM THE COMMISSION OF MAJOR ESF ISSUES, STATUS. -
SHAFT LOCATIONS / INTERFERENCE ,
BETWEEN TESTS SHAFT PENETRATION INTO BARRIER ;
4 BELOW REPOSITORY !
i
- EXTENT OF EXPLORATION !
i
- OA (DESIGN CONTROL)
- 2. MAKE COMMISSIONERS AWARE OF t l RESOLUTION APPROACH, 1-
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- I
k FHAT IS THE_f3E?
- TWO 12 FT. DI AMETER SHAFTS, 300 FT.
APART SURFACE FACILITIES DEDICATED UNDERGROUND TESTING AREA 900 FT. X 1100 FT. WITH 3000 FT.
OF DRIFTING S000 FT. OF ADDIT 10flAL DRIFTS FOR EXPLORAT!0ft 2-
I WHY IS THE ESF IMPORTAf!T7 MAJOR DESIGN FEATURE IMPORTAf1T TO WASTE ISOLATION INTERFACE FOR REPOSITORY EXPAflSION VAllD SITE CHARACTERIZAT10ft TESTS L0t4G TERM PERFORI1ANCE 3-M
1 l
l 1
WHY IS IT IMPORTANT f10V?
MAJOR DECIS10fl LEADING TO PARTIAL CONSTRUCTION OF REPOSITORY fi0 CONSTRUCTION AUTHORIZATION NEEDED NOT A LICENSING ACT10ft
- IF SITE FOUf:D SUITABLE, COMPLIANCE DETERMlllAT10fl MADE AT LICENSING HEARING 4
4 1
ESF ISSUES SBfl_1D. CATIONS /lNTERFERENCE BETUEEN TESTS FLOODING AND EROSION liiTERFERENCE WITH ES-1 TESTING BECAUSE OF PR0XIMITY TO ES-2 INTERFEREhCE WITH UNDERGROUflD TESTlf;G EECAUSE OF PROXIMITY OF THE Idill TEST AREA TO ES-1 AND ES-2 IMTERFERENCE BETWEEfl TESTS CANNOT BE EVALUATED WITH EXISTiflG IFFORMATION 5-M
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ESF ISSDES ES-1 PINETRATION INTO BARRIER BELOW REPOSITORY 1
DOE HAS COMMITTED TO ANALYZE NEED FOR PENTRATION OF ES-1 INTO MAJOR ROCK BARRIER BETWEEN REPOSITORY LEVEL AND UNDERLYlNG WATER TABLE.
6-9
ESF ISSUES EXTENT OF EXPLORATION PROPOSED TEST AREA SMALL COMPARED 10 REPOSITORY SIZE DOE PLANS TO SUPPLEMENT WITH SURFACE BOREfiOLES BOREHOLES ALONE MAY NOT EE SUITABLE FOR EXPLORATION
.y.
DESIGtt CONTROL THE EXPLORATORY SHAFT FACILITY (ESF)
IS IMPORTAtlT TO WASTE ISOLATION ESF DEslGil ACTIVITIES IMPORTAlli TO WASTE ISCLATION ESF ISSUES !!iDICATE PROBLEM IN DOE'S DESIGN CONTROL 8-l 4
,3 RESOLtITION APPROACH
' GENERATE OR REEVALUATE DESIGN CRITERIA
- ANALYZE CURRENT DESIGN
- SUBMIT DESIGN ACCEPTABillTY ANALYSIS
- IDENTIFY IMPACT OF DEFICIENCIES
- INDEPENDENT ONSITE DOE REVIEW 0F
- DESIGN PROCESS
- NRC OBSERVATION OF DOE ANALYSIS AND ONSITE REVIEW
- NRC COMMENTS ON SITE CHARACTERIZATION PLAN
_g.
o M 14 E g ESF RESOLUTION APPROACH l
a' s RECEIPT OF SCP ISSUE SCA 12/M 07/89 l
- SCP REVIEW PROCESS I
I RECEIPT OF DESIGN ACCEPTABILITY ANALYSIS -
12/M a._ _ _ _ 7 10/88 11/M 12/M a ; a a MEETINGS ON ESF SITE PREPARATION CL,MMENCE ESF l
DESIGN CONTROL I 05/89 CONSTRUCTION 11/89 ESFRELATED ACTIVITIES I I I I I I I I I I I I I I I SEPT OCT NOV DEC ,JAN FEB MAR APR MAY JUN JUL AUG SEPT OCT NOV 1988 l 1989
1 M MEWWdWdjdddfW6WAfWd%ffff'g(ddfffgfgygggg g g,,g i TPAH5MITTAL TO:
Document Control Oesk, 016 Phillips
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- SECY Correspondence & Records Branch 5 FROM:
I Attached are copies of a Comission meeting transcript and related steeting 1:
i document (s). They are being forwarded for entry on the Daily Accession List and ll' placement in the Public Document Room. No other distribution is requested or
':' required.
!, Meeting Titie: dui/. <% - MM.J #7 c(Jm J e,/
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