ML20235N460
| ML20235N460 | |
| Person / Time | |
|---|---|
| Issue date: | 02/21/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0007, NACNUCLE-T-7, NUDOCS 8903010225 | |
| Download: ML20235N460 (194) | |
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1 UNITED STATES 9 NUCLEAR REGULATORY COMMISSION c.........................................................-
ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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7th ACNW Meeting )
Day One )
O Pages: 1 through 144 Place: Bethesda,. Maryland Date: February 21, 198 iOE223Of Ye 3)tjr$kg_
.........................................................c HERITAGE REPORTING CORPORATION OficialReporters 1220 L Street, N.W., Suite 600 Washington, D.C. 20005
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1 PUBLIC NOTICE BY THE 2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 ADVISORY COMMITTEE ON NUCLEAR WASTE 4 February 21, 1989 5
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7 The contents of this stenographic transcript of the 8 proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Nuclear Waste (.ACNW) , as 10 reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACNW Staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statements or data contained in this transcript.
g g 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202)628-4888 0
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' UNITED STATES MUCLEAR REGULATORY COMMISSION
' ADVISORY COMMITTEE'ON NUCLEAR WASTE In'the Matter of: )
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7th ACNW' Meeting' )
Day One )
Tuesday, February 21, 1989 Room P-110, Phillips Bldg.
7920 Norfolk Avenue Bethesda, Maryland The meeting convened, pursuant _ to notice,: at 1: 00 p.m.
BEFORE: DR. DADE W. MOELLER Chairman, ACNW Professor of Engineering.
In Environmental Health Associate Dean for Continuing Educatic;n r School of Public Health Harvard University-Boston, Massachusetts ACNW MEMBERS PRESENT:-
DR. MARTIN J. STEINDLER Director, Chemical Technology Division Argonne National Laboratory Argonne, Illinois.
CONSULTANTS:
MELVIN CARTER DONALD ORTH JUDITH B. MOODY WILLIAM J. HINZE DAVID OKRENT EUGENE E. VOILAND Heritage Reporting Corporation (202) 628-4888
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DESIGNATED FEDERAL OFFICIAL:
DR. S.J. PARRY ACNW COGNIZANT STAFF MEMBERS:
R.F.-FARLEY, Executive Director H. STANLEY SCHOFER, Technical Secretary.
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~'T 2 DR. MOELLER: The meeting will now come to order.
3 This is the first day of the Seventh Meeting of the Advisory 4 Committee on Nuclear Waste. I am Dade Moeller, Chairman of 5 the Committee.
6 The other ACNW member here with us today is Dr.
7 Martin Steindler, seated on my left. Dr. Clifford Smith is 8 unable to attend this meeting.
9 We have a team of consultants here with us. Bill 10 Hinze, David Okrent, Eugene Voiland, Mel Carter and Donald 11 Orth. And we anticipate Judith Moody joining us.
12 During today's meeting, the Committee will hear 13 about and discuss the current status of the NRC staff's 14 review of the site characterization plan and related topics. I l
("T 15 Ne will, as you will note from the agenda, be reviewing not V
16 only the plans and the progress of the NRC staff in 17 reviewing the SCP, but also in reviewing the DOE's study j 18 plans, among other things.
19 Topics for consideration on Wednesday and Thursday 20 are listed on the schedule posted on the bulletin board 21 outside this meeting room. The meeting is being conducted 22 in accordance with the provisions of the Federal Advisory 23 Committee Act and the Government in the Sunshine Act.
24 Dr. S. J. Parry is the Designated Federal Official 25 for the initial portion of this meeting, and he is seated to !
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4 1 my right.
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f 2 We have received no written statements or requests 3 to make oral statements from members of the public regarding 4 today's session.
5 A transcript is being kept of this portion of the 6 meeting and it is requested that each speaker identify 7 himself or herself, move to one of the microphones and speak 8 with sufficient clarity and volume so that he or she can be 9 readily heard.
- 10. Before I move on with the technical pertion of the 11 meeting, I want to insert in the record the fact that Morton 12 Lebarken is retiring at the end of this month, is it Mort, 13 .and is it Executive or Deputy Executive Director,'for, and I 14 could say'the ACRS, but I will say the ACNW. And we have r% 15 certainly enjoyed having you, and we hope that this does
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16 not terminate all contact. We are hopeful that we will get 17 to continue to interact with you from time to time. j 18 But on behalf of the Committee, let me publicly 19 express our tremendous appreciation for helping us get 20 started and some day maybe you will look back and say that 21 was your baby. We hope you will want to do that.
! 22 Before I call upon the NRC staff for the
~23 initiation of this afternoon's presentation, let me ask if 24 any members of the consulting staff have any comments or 25 remarks to make, any items specifically you wanted to l
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5 1 mention before we begin?
2 (No response) 3 DR. MOELLER: Okay. There being none -- and I 4 did not mention Dr. Steindler because he had already told me 5 he would pass at this time.
6 So without further ado, then, we will call upon
! 7 John Linehan, who will be emceeing this afternoon's program.
8 John is Director, Repository Licensing and Quality Assurance 9 Project Directorate for the Division of High-Level Waste 10 Management, NRC staff. John?
11 MR. LINEHAM: Thank you, Dr. Moeller.
12 Before we get into the actual presentations, I 13 would just like to say a few words about the agenda. We 14 have a revised agenda that has been passed out to everyone.
15 It is only slightly different from the one that was in the
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16 original handout.
17 With respect to the topics that we have here on 18 the agenda, there are two I would like to focus on just 19 briefly. The second is the SCP review activities.
20 As you are all aware, we are currently reviewing 21 the SCP. We had been requested to give some indication as 22 to how well DOE was responding to our comments on the 23 consultation draft site characterization plan in this 24 meeting.
25 It is too early in the review for us though to go Heritage Reporting Corporation (202) 628-4888
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6' y 1 on the record with any impressions. . And indeed at this
(]) 2 point in time we. don't have any firm impressions. It will 3 become clearer to'you how early we are in the review when
-4 King Stablein goes through the heview schedule.with you.
5 The other item I would like 7to' mention is the 6 third.one down, the Commission's CDSCP concerns. The main 7 reason this is on the agenda is to familiarize the
'8 consultants that.were not present when we gave our original 9 presentation, I believe it was to the ACRS, on our CDSCP 10 concerns.
t 11 And what we are going to be doing is essentially 12 going through that briefing and providing some update on 13 each one of the concerns. We have had interactions with DOE E -14 since we issued'the comments on a number of them.
15 And as we give that presentati'on, we would like ,.
'16 guidance from you whether we are going too deeply into the j 17 concerns. It is really being presented to try to hel'p these l 18 members come up to speed. If you feel we are spending too i
19 much time or not enough, please stop us. Because you j 20 really have to tell us what the right level of detail is on 21 that one.
l 22 DR. MOELLER: And you will emphasize the five 23 objections, I presume? ,
1 24 MR. LINERAM: Yes. Definitely.
l 25 DR. MOELLER: Okay.
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1 MR. LINEHAM: With that, I would like to turn it
)~ 2 over to Robert Johnson, who is a Senior Project Manager in
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4 Among his many activities, Robert was responsible 5 for developing the review plan that guides the staff's 6 review of the site characterization plan. And he will be 7 going through that with you this afternoon. Robert.
8 MR. JOHNSON: Good afternoon. I will be speaking j 9 from this handout that is titled "SCP Review Plan...And 10 Other Review Plans."
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We can begin just on Page 2.
12 As John said, I will be first summarizing the 13 purpose, the organization and the content of the SCP review 14 plan. And. I will be then passing the presentation over to 15- King Stablein, who will talk about the review activities and 16 the schedule and the status of the SCP review.
- 17 Then later on in the afternoon, probably I think 18 the last presentation, I will be talking about the draft 19 study plan review plan and the performance assessment review 20 strategy and the QA review plan, which you asked to hear 21 something about.
22 We could begin on Page 3 then, with some 23 background relative to the SCP review plan. You may recall 24 about a month ago when I presented our program overview to 25 you I mentioned that one of the five year plan and budget Heritage Reporting Corporation (202) 628-4888 j ,
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8 1 activities was the preparation of review plans.
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2 In our FY89 budget we have about 4.7 FTE allocated-3 for various review plan activities. These include the 4 preparation of the SCP review plan, which we have completed 5 and which I will.be talking about today.
6 Later in the year, I will be revising that. review 7 plan to' account for the semiannual progress. report review.
8 We will also later.in the year be revising the draft study 9 plan review plan.
10- We have'also completed the QA review plan, which I l
I 11 .will summarize today, and will be working on, in 1989, the
'12 performance assessment review strategy, which I will talk i
13 about later.
14 And lastly, we will be preparing a work plan for q 15 the preparation.of the license application review plan.
16 So I just wanted to orient all of you to the fact 17' that review plans are an important part of our budget and 18 our program, and today we are really just' focusing on the 19 SCP review plan primarily.
20 DR. MOELLER: To help me on that, are the review 21 plans -- just listening to you,.one could conclude that they 22 are -- developed by this separate group over here and then 23 turned over to someone to. implement?
24 hm. JOHNSON: tio, that is not really the case. It 25 may sound that way. But we use a team approach for most of Heritage Reporting Corporation (202) 628-4888 l
9 1- our work.and the team that would be working or that did work gggg 2 on the review plan is made up of the same people that are .
3 conducting the review in most cases.
4 It is still the staff and'the contractors. We may t
5 assign them a little bit differently here and there, but 6 it's the same team.
7 DR. MOELLER: And the people who do the work are 8 heavily involved in developing the plans to do the work?
9 MR. JOHNSON: That's right.
10 DR. MOELLER: Okay.
11 MR. JOHNSON: As a matter of fact, the plan is a 12 key way to prepare the staff for their review, as I will say 13 later.
14 DR. MOELLER: One item, in reading the material to 15- prepare for this meeting, that I did not fully understand.
16 Several places I read the.words that the review plans are 17 not subject to revision.
18 Now, did I misread that? Are they not a living 19 document, or are they pretty much put in concrete and then 20 you follow them?
21 MR. JOHNSON: Well, as a matter of fact the SCP 22 review plan was revised.
23 DR. MOELLER: Oh, it was.
24 MR. JOHNSON: It was initially issued in December 25 of 1987 as the CDSCP review plan and then after our review Heritage Reporting Corporation (202) 628-4888
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i 1 of the CDSCP we had discussions with the reviewers and
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obtained suggestions from them as to how we could improve the plan. Ar.d then we in . fact did revise it.
4 THE COURT: Could you give us an example of a 5 change you made?-
6 MR. JOHNSON: Well, one of the key changes that I 7 think most everyone recognized the need for was an actual 8 step in our review process for integration of all the 9 technical disciplines, all their products and their 10 comments, so that we could have better consistency across 11 all the disciplines, better consistency with each technical
-12 discipline and let's say the overall view of performance 13 assessment.
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So we felt that we needed more time for that. We 15 needed a separate step to focus everyone's efforts just' on 16 integration after.they had.gotten to a certain extent in 17 their own review and their own discipline area.
18 So that was a key change that we made to the 19 review process.
20 Later on, I will have some other comments to make 21 with regard to how we've changed the plan. But to' address 22 .your. initial question, we do revise it when it is needed and 23 we have provision for that in the. review plan itself.
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24 DR. MOELLER: Okay.
25 MR. JOHNSON: On Page 4, some of you may remember '
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1 that in August 1987 I briefed the ACRS on our SCP review
/'D 2 plan preparation and relevant background on the SCP and SCA (M- )
3 process.
4 A lot has happened since 1987. NWPAA focused the 5 overall program on Yucca Mountain. And also, DOE issued the 6 consultation draft of the SCP. As a result the staff 7 prepared a review plan for the consultation draft SCP in 8 December of 1987. And as I said before, after our review 9 of the CDSCP, we polled the staff on what things we could 10 change in the plan and in December, 1988 we prepared the 11 actual SCP review plan.
l 12 I mentioned already some revisions to the 13 integration, to allow for the integration. But there were a 14 couple other things that were done, too. There was a lot of
./N 15 material on the CDSCP review plan related to Hanford and
\_/ 3 16 Deaf Smith. And of course we removed that material. And I 17 think the major revisions were in the area of the 18 administrative part of the plan.
l 19 As you probably are aware, the SCP review is far l
20 different than the CDSCP review was. The schedule was '
21 different, the product was different in that the SCP 22 requires a site characterization analysis and the CDSOP j 23 review did not. So there are a number of more I 24 administrative things that we had to change. That was the 25 primary change to the plan itself. But the technical parts Heritage Reporting Corporation (202) 628-4888
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'l 12 1 remained virtually the same.
gg g 2 Moving on to Page 5, just for a moment let's talk about the purpose of the SCP review plan, j 3
l 4 In preparing it, I think there is a value in that !
5 it prepares the staff both technically and j
6 administrative 1y, looks ahead and defines really what the I 7 staff will need to do. And in doing so, it provides 8 guidance during the review to the staff along the way as 9 far as the technical critoria they should be using as 10 guidance as well as the activities and the schedule that 11 would help manage the actual review. I 12 By doing this, it helps assure the quality and the 13 consistency, and, as I said, the integration of the overall ;
14 product that comes out of the review.
15 It is also useful to document the staff's review
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16 process to that other people, like the ACNW, can understand 17 how we are going about our review. Later on it may be 18 useful for various parties to refer to-how we did our 19 review. And lastly, it fulfills an internal quality 20 assurance requirement of our division.
21 DR. MOELLER: Could you elaborate on that? In ;
j 22 other words, by having a review plan and carefully checking 23 it and making sure you follow it that helps with the QA? Is 24 that what you are saying? .
25 MR. JOHNSON: That's right. One of our Heritage Reporting Corporation 2 (202) 628-4888 u
13 1 requirements is that for major document reviews we should g 2 have a review plan that the staff can follow, have -hat 3 review plan available prior to the initiation of the review.
4 And we do, part of our requirements, as you would note in 5 the work plan, is that we do check up and follow up on how l 6 that review is implemented.
7 Page 6. I just want to quickly point to the 8 organization of the SCP review plan. It has two parts.
9 Part A is the technical review plan. Obviously that 10 provides the technical guidance to the staff. And Part B we 11 call the work plan. And that provides the administrative 12 guidance to manage the review. Things like activities 13 schedule, responsibilities, budget sort of information. I 14 will go into these in more detail.
p 15 Let's look at the organization first of Part A,
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16 the technical review plan, on Page 7.
17 The technical review plan lays out the purpose, 18 the objectives and the scope of the review, gives guidance 19 on conducting the acceptance review and the technical review 20 itself.
T 21 We have what we call general review guides and 22 detailed review guides within the plan. And each of these 23 review guides has a standard sort of organization. I just 24 want to give you a feel now for the organization.
25 Each review guide consists of a section on l Heritage Reporting Corporation I
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14 1 background and approach so that relevant information is put 2 down for the staff to be aware of, and a general approach.is
(')T 3 laid out for reviewing that part of the SCP. And then 4 specific criteria may also be listed in the review guide.
5 Applicable sections of Part 60 are listed. And 6 then important documents to consider in the review are 7 listed. These things would include summary of technical 8 meetings that we may have had with DOE over the past few 9 years, letters to DOE, NUREG documents or key DOE documents 10 that relate to the particular topic for the review guide.
11 Moving on to Page 8, let's look at the purpose of 12 the review itself.
13 First of all, it is to fulfill our NWPA mandated 14 responsibility to review DOE's SCP and prepare a site 15 characterization analysis.
(~)g 16 And secondly, it is really a continuation of the 17 pre-license application and consultation process that we 18 have with DOE to identify potential licensing issues early-19 in the program and work toward resolution of those issues.
20 Yes, Judith?
21 DR. MOELLER: Judith, can you pull that microphone 22 over?' Thank you.
23 DR. MOODY: Excuse me. Just as a point of 24 information. Was this purpose of the review, the two points 25 you have made here, was that defined by the National Waste Eeritage Reporting Corporation (202) 628-4888
15 1- Policy Act or is that your interpretation of the National
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v 2 Waste Policy Act in terms of your responsibilities?
3 MR. JOHNSON: The first one is a requirement.
4 DR. MOODY: All right. That's what I wanted to 5 know.
6 MR. JOHNSON: Coming from NWPA. The second one is 7 our consultation process which is also laid out in NWPA.
8 And that's how we're interpreting it.
9 DR. MOODY: Thank you.
10 MR. JOHNSON: On Page 9 I would like to focus on 11 the scope of our review. NRC staff are responsible for 12 sections of the SCP and references that are related to 10 13 CFR Part 60. Now, there are sections in the SCP that are 14 not NRC's responsibility. There are DOE siting guidelines
("j 15 that are not related to Part 60, such as those dealing with
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16 cost and nonradiological health and safety to workers.
17 These parts of the SCP are not reviewed by NRC.
18 They are beyond our area of responsibility.
19 DR. MOELLER: Are they reviewed officially by 20 someone else?
21 MR. JOHNSON: I can't speak for the state but they 22 may be reviewed by the state and other parties. ,
23 DR. MOELLER: OSHA doesn't have a staff reviewing 24 it?
25 MR. JOHNSON: Not that I am aware of.
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l' 16 1 DR. MOELLER: Okay. And you don't have a
) 2 responsibility for coordinating --
3 MR. JOHNSON: That's right, we do not.
4 DR. MOELLER: -- Federal reviews? Okay.
5 MR. JOHNSON: Also in the SCP there is a section 6 on plans for mitigating environmental impacts caused by site 7 characterization activities. And this is also an area where 8 NRC is not reviewing because it is beyond NRC's regulatory 9 responsibility.
10 I just wanted to be clear on what is within the 11 scope of our review and what is beyond the scope of our 12 review.
13 DR. MOELLER: I forget the words, but you know, 20 14 years ago there was some famous ruling with Calvert Cliffs (N 15 or something like tnat that the NRC, for nuclear power
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16 plants, had to look at the entire environmental spectrum, or 17 spectra, whatever it is. But you do not have to do this for 18 waste.
19 MR. JOHNSON: I would like to make a careful 20 distinction that where we are involved with the 21 environmental impact of the facility itself, eventually the 22 repository, the distinction he e is that we are not looking 23 at the environmental impacts of site characterization 24 activities. That is different t han the repository itself.
25 We have responsibility for the repository related Heritage Reporting Corporation (202) 628-4888
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17 1 environmer,tal concerns but not the' site characterization 2 activities.
3 DR. MOELLER: And what'you are saying is, I 4 presume -- let me see if I am interpreting it correctly. If 5 you. characterize the site and do damage let's say, using 6 that word loosely, if the DOE does damage by characterizing 7 it ', and then they later build a repository there, then you, 8 NRC would have responsibility for assuring that the total 9 package was' environmentally acceptable, but if they 10 characterized a site which later was found unsuitable and 11 they abandoned it, NRC would not be responsible for 12 restoring that site?
13 MR. JOHNSON: That's right.
14 DR. MOELLER: Okay.
15 MR. JOHNSON: Moving on in scope, another part to 16 understand is that we don't review all sections or all 17 . references in great detail in the SCP, We emphasize certain 18 sections. And consiste.it with.the scope of the SCP which
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19 really is a higher level of plan, we focus our review or we 20 emphasize our review in the areas that are most important to 21 us consistent with the scope of the SCP.
22 What I have listed here are the types of things 23 that our review emphasizes -- issues, information needs, 24 performance allocation and the issue resolution process. We 25 review all the information related to this. This is where i
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18 1 DOE lays out their basic strat( ,les and the rationale for l
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their program, and the information needs that they will be collecting.
4 We also review all the information related to any 5 potential adverse effects on waste isolation or on site 6 characterization. We review information, all information 7 related to any use of radioa.:tive materials that might be 8 proposed.
9 DR. STEINDLER: That particular issue I thought, 10 if I remember right, came up because folks were concerned 11 about tho use of radioactive materials in irretrievable
~12 geologic areas.
13 'Jhe way this thing seems to be written, you don't 14 make that distinction, which means in a sense you are going 15 to review every time somebody does a laboratory experiment 16 with a small amount of tracer. Do you really mean to do 17 that?
18 MR. JOHNSON: We are reviewing whether the use of 19 radioactive materials is important for site 20 characterization. That would be if -- what it's aimed at is 21 really any in situ tests that DOE would be doing using 22 radioactive material. The spirit of what is required I 23 don't think pertains to laboratory experiments.
24 DR. STEINDLER: But the words do not make that 25 distinction. At least I haven't been able to find any.
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19 1 DR. MOODY: There is a strong difference between g 2 doing a laboratory and doing a field study. I'm sure you 3 know that.
4 MR. JOHNSON: Right. I'd have to look at some of 5 the maybe statement of considerations that was related to S this part of the rule that may contain wording on this. But 7 the emphasis is on any radioactive material that is used in 8 the field in in situ experiments.
9 And our role is re ally only to determine whether 10 the use o f that material is needed for site 11 characterization.
12 DR. MOELLER: And I presume you would look at the 13 halflife of it and the quantity to be used and how long it 14 might contaminate an area and so forth? Is that it?
15 MR. JOHNSON: Relative to whether it is needed, 16 whether that amount is needed for site characterization.
17 DR. MOELLER: So first you will say if is needed; 18 then if it is, to be sure that it is ALARA, so to speak?
19 MR. JOHNSON: I'm sorry, I can't address that.
20 But the main emphasis is on is it needed for site 21 characterization. That is the limit of our call.
22 DR. MOELLER: Dr. Okrent.
23 Bend the microphone down, Dave a little bit.
24 Thank you.
25 DR. OKRENT: There are a lot of different issues Heritage Reporting Corporation (202) 628-4888
20 1 involved and I assume multiple reviewers for the staff.
2 How do you manage to have each issue given the
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3 appropriate emphasis in deciding that there is an issue of 4 concern or some important comment or so forth? Because 5 certainly they don't all contribute equally to meeting the 6 ultimate performance objectives.
7 I was wondering if there is some kind of guidance 8 mechanism that you can employ in that regard.
9 MR. JOHNSON: I think the first way we approach 10 that is through the review plan itself, in setting up 11 criteria to help frame the staff's approach. And that helps 12 with consistency.
13 As the review proceeds, though, there are weekly 14 team meetings to discuss certain key observations that the 15 staff is coming up with within the whole team so that there 16 is a chance to exchange information and get a feeling across 17 the board with regards to all the disciplines including 18 performance assessment on how certain concerns are being 19 identified or how they should be expressed in comments.
20 I mentioned earlier the step dealing with 21 integration. There is probably about three weeks or so that 22 we'll be dealing with just how the comments fit together 23 into a package, an integrated package, that would help 24 reflect I think the relative importance of some of the 25 various comments.
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21 1 So a lot of the questions I think that you are 2 bringing up are questions that would be addressed in this 3 integration step as well. l l
4 DR. OKRENT: Well, but even in an it.' .egration 5 step, if I were doing it and I had my choice of supporting 6 information, I think I would like to have the benefit of 7 some probabilistic insights as to what might occur if this 8 were ten times larger or if we had to combine alternative 9 concept B with a certain scenario or so forth and so on, in 10 order to have a better basis for arriving at a judgment that 11 something was of no concern or it might be of considerable 12 concern.
13 Let me ask just one other question. The issue of 14 information needs to resolve an issue or to various 15 purposes. I was wondering if in what the staff does they 16 specifically address the issue as someone identified the 17 information which if it were obtained would resolve the 18 issue? If not, how will the information which is being 19 proposed resolve the issue? And will it be adequate for the 20 purpose? Has any of this been done, or are people just 21 getting information which may help shed light, and go down a 22 scale? But it's harder to go down that scale than just to 23 say please get information or we're going to get 24 information. And I was wondering if in your review process 25 you go through some such hierarchical examination.
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22 1 MR. JOHNSON: I will try to give an answer to
. 2. that.
! 3 As you know, the SCP is a first step in a process 4 that is going to last a number of years, to move toward the 5 answer of how much information is enough. It is beginning
- l. 6 with laying out the issues and the types of information that 7 DOE and others feel is needed. It is also laying out a 8 process and strategies. And DOE is laying out those 9 strategies for obtaining the information or trying to put.a 10 logic process together for answering the question how much 11 of the types of information is enough.
12 Just as DOE's SCP is in the beginning of this 13 process, I think our review plan and our review is in the 14 beginning stages of that same process. Therefore, you will f3 15 look at our review plan, and many of our detailed review U 16 guides list the types of information that we feel are 17 important, that we'll be looking at in DOE's plans.
18 But we don't have specifics in there to answer the 19 question how much of those various types of information is 20 enough. That's a process that we are going to be moving 21 along with DOE on and they've laid out the process, at least 22 the road map in the SCP. And we are reviewing the logic of 23 that road map. And as the program proceeds, we will be 24 using a great sophistication to quantify that interi. ally.
25 As most of you heard last time, in the program Heritage Reporting Corporation (202) 628-4888
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23 1 review we have an effort to develop in-house modeling, staff
) 2 modeling capability. And that capability will help us in 3 future reviews of DOE's programs as data is collected, as 4 analyses are done by DOE, we will be doing our own analyses 5 to help address this question, i But the answer is not here today, I don't think.
7 And the'important thing is that a process is being 8 established that is agreeable to the parties for moving 9 toward that answer.
10 Did that help?
11 DR. OKRENT: Let me pursue it just one more point.
12 I agree a process is being established and I've read a lot 13 about information studies, the site characterization plan.
14 I think in the end there are going to be matters for which 15 it is just not possible to get what you would call the 1
16 necessary and sufficient information. There may be areas 17 where you could get better information if at the beginning 18 one had sought harder what information was really important 19 for a decision. It may not be that all aspects of a 20 phenomenon, corrosion of a canister, or whatever, are 21 equally important. And certainly there are others. I'm j 22 just trying to understand if there is going to be come 1
23 effort, I've heard it once said, to ask the right questions, 24 and then see what information is needed and is possible to I
l 25 get earlier, rather than at the end of the program.
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24 1 MR. JOHNSON: I think we in DOE agree that it is
('%s') 2 important to set up the general goals f the program first.
3 And that is what the SCP is intended to do. The performance 4 allocation part of the SCP is where DOE lays out what they 5 expect from various parts of the system, and what level of 6 confidence they expect. This is a preliminary expectation 7 of how they see the system performing.
8 And then based on that, they identify their l 9 information needs and the investigations from that and the .
10 various studies and tests to support that.
11 So through performance allocation, which I believe 12 DOE will talk more about tomorrow, is the way in which they 13 are establishing a strong road map for their program, so 14 that they will be focusing on the things that initially they ;
15 feal are most important to be addressing the performance 16 requirements in Part 60.
17 The allocation that they have in the SCP reflects 18 for the Yucca Mountain site those parts of the system they 19 expect more or less out of. And we will be reviewing that 20 initial allocation and how well their program ties into 21 that, as well as how well their program deals with 22 alternatives to that.
23 DR. MOELLER: Eugene? Hold the microphone down.
}
24 MR. VOILAND: As the new boy on the block I will 25 not feel crushed if you tell me that these questions have Heritage Reporting Corporation (202) 628-4888 l
l
(',
25 1 ben asked and answered in the past. But the question I had
('^s d
2 really is kind of along the lines of Dr. Okrent's here. And 3 that is, is the plant essentially intended to be or lead to 4 or does their exist a decision tree where you walk through 5 all the steps of what you need to do to get from the top to 6 the bottom, and this then enables you to take a look at each 7 one of these elements and perhaps determine what is 8 necessary, what is nice in a lot of decision Enking. You 9 really have to ask those questions, first of all, what must 10 we know or what must we agree to, to achieve what we are 11 after and what would be nice to, and what would' help and 12 embellish. I guess that's my question.
13 MR. JOHNSON: The SCP does contain you might see a 14 decision tree or a hierarchy, what is called the issues 15 hierarchy. And DOE has identified the issues that need 16 resolution, the information needs associated with those 17 issues and then the various programs, or the more specific 18 parameters that they need to be collecting information on.
19 I think if you look at the SCP and hear DOE's 20 description of it tomorrow, they will lay out the logic of 21 their program and it is a logical organization of goals and 22 objectives and information that they need to collect and 23 then the types of tests associated with that information.
24 And then they tie that into their schedules, you 25 know, related to when they are going to be collecting that 1
Heritage Reporting Corporation (202) 628-4888 0
i 26 l 1 information.
/^^% 2 We have also, over a number of years, asked them kA j
3 to include decision steps in their schedules so that we can 4 see the progression of their whole program. That is part of 5 what we are going to be reviewing. But I think that 6 tomorrow's briefing on the SCP will be helpful to those that 7 need this broad overview. It is a complicated document but 8 it is intended to lay out the logic of their program at this 9 upper level, 10 DR. MOELLER: Let's move ahead, then.
11 MR. JOHNSON: Okay. To move on, on Page 9, I 12 believe I was on this list at the<end of the page. Other 13 parts of the SCP that we emphasize of course would be those 14 sections where DOE is responding to our CDSCP concerns. So 15 we will be looking carefully at how they have resolved our
.O .16 concerns in the SCP.
17 We will also be emphasizing in our review those 18 parts of the SCP that relate to what we call key technical 19 topics. These would be key things related to the 20 performance of the Yucca Mountain site, such as volcanism or 21 faulting. We have a number of these key concerns listed in 22 our detailed review guides. And again this is a way to give 23 the staff a way to emphasize certain parts of their review.
24 The last two things will be reviewing or 25 completing the exploratory shaft facility material as well Heritage Reporting Corporation (202) 628-4888
27 1 as the QA information that is presented in the SCP.
2 DR. MOELLER: Yes, Bill?
)
3 DR. HINZE: Concerning the QA, are you 4 investigating at this point the data chain that is going to 5 deposit these data and to make them available, and who is 6 going to have access, and how will it be handled, and so 7 forth?
8 MR. JOHNSON: Are you referring tc data 9 management, data base?
10 DR. HINZE: Yes. Really from the acquisition 11 through to the analysis processing. Data management, if you 12 will.
13 MR. JOHNSON: Just a moment.
14 MR. LINEHAM: I think first to begin with the 15 chain of custody of samples once you obtain them is a 16 significant part and then any tests that are done on those 17 samples, the data that is obtained from those, that whole 18 chain is covered by the QA program. Yes.
19 But one of the big issues out at the Ramada site 20 was that some of the early testing that was done, the 21 samples themselves, there was not a chain of custody that 22 was very good on those, and because of that they may not be 23 usable in a licensing.
24 DR. HINZE: Has it been specified who was 25 responsible for putting all of this data together in some Heritage Reporting Corporation (202) 628-4888
28 1 kind of appropriate data management form so it is 2 accessible? I'm thinking forward to the integration process
('V) 3 where one might wish to go back and review the quality of 4 the specs on a particular data set, and to evaluate that 5 data set. This is an important topic at this stage in the 6 game.
7 MR. LINEHAM: I was just seeing if there was 8 someone that would add to this.
l 9 DR. MOELLER: Identify yourself. j l
10 MR. HOLONICH: My name is Joe Holonich. I'm NRC 11 Project Manager. And the control of the data is mostly ]
12 specified in the individual procedures for the organization 13 such as the USGS has a procedure on how it will control the 14 data. And in addition, Sandia National Lab has a reference 15 information data base where all of the data is collected in 16 that data base.
17 DR. HINZE: I guess that is one of my concerns.
18 There are a number of different agencies, organizations 19 involved, and it seems to me that there needs to be someone 20 looking at the compatibility of these and the ability to put 21 them together in a proper integrated fashion in a timely 22 manner so that one can get at an iterative process during 23 this integration procedure.
24 DR. MOODY: I would second that in the sense that 25 I, knowing what has been ongoing in these programs for a Heritage Reporting Corporation (202) 628-4888
29 1 long time, I was -- what you would desire would be a central
, ) 2 location for all of that data rather than have Sandia have V'
3 theirs in Albuquerque and USGS have theirs in Denver and DOE 4 have theirs at their major location near the Yucca Mountain 5 site.
6 That is not going to make, have those separate 7 individual parts is not going to help the program because 8 you really need a central location for all that data.
9 MR. HOLONICH: I'm sorry. I wasn't clear. Each 10 individual organization has its own procedures for 11 controlling the data but Sandia has t he reference 12 information data base which it collects all of the data from 13 the participants.
14 DR. MOODY: So Sandia is then going to be the 15 laboratory that has the responsibility for obtaining all the 16 data? Is that correct?
17 MR. HOLONICH: That is my understanding, correct. l 18 DR. HINZE: Dr. Moeller, I think this is an 19 important topic and one that we should very much keep on top 20 of.
21 DR. MOELLER: Okay. When DOE does their ;
I 22 presentation tomorrow perhaps, you will want to pursue it 23 then also. Thank you.
24 DR. STEINDLER: Let me just comment there is such 25 a thing as the licensing support system which I don't know l Heritage Reporting Corporation (202) 628-4888
l 30 l i
whether we'll hear about either today or tomorrow, but there l 1
2 are attempts being made to organize the world of information 3 pertinent to this program, that is the repository program, 4- in a retrievable and quality assured sense. How well that 5 very large data base will succeed in doing all those things 6 remains to be seen but there is a move afoot which is ,
1 7 expensive and complicated, i a
8 DR. CARTER: Let me ask a question that still I
9 seems to me to be fairly fuzzy, now. I presume the large 10 data base that DOE and its contractors have at the site, the 11- past information and data if you will, I presume some of 12 that at least was being negotiated as to its acceptability ;
i 13 with the NRC.
14 Now, is that process still going on or has the 15 decision been made that the clock starts running as of a 16 given day? Or is this still an ongoing process as far as l 17 the suitability of past information and data?
18 MR. LINEHAM: It is still an ongoing process.
19 There has been no decision made to date as to what data 20 collected in the past is acceptable, is not acceptable. i 21 As part of its quality assurance program, DOE has 22 laid out a process for determining whether data that was j i
23 collected in the past is usable in licensing. And the i 24 criteria they are using in that process are similar or the 25 same as those that were published in a technical position by Heritage Reporting Corporation (202) 628-4888
31 1 the NRC staff for qualifying the existing data. But there 2 has been no decision made on any individual data set at this
&(N .
3 point in time.
4 DR. CARTER: Well, I presume then those 5 negotiations are still fairly active, it's not something you 6 hit a lick every two months or something of that sort. Are-7 there groups on both sides that are specifically given that 8 responsibility? I think that is fairly important, because 9 they obviously have a fair amount of information and data.
10 MR. LINEHAM: We have only had interactions with 11 DOE regarding the cores that were collected in the past that 12 were stored at their sample management facility. And they 13 have instituted a process. In fact, they have designed a 14 new sample management facility to make sure there is fT 15 adequate custody of the cores.
U l 16 They have I believe a group that is studying this 17 question right now. We are aware of what they are doing but 18 they have not come to us at this point in. time. They are l
19 still handling it internally. They do deal with our !
20 technical staff and with our on-site reps. And as I said, 21 they do have our technical position that they are following.
22 But they haven't come to us yet with a specific call as to 23 whether data is good or not good.
24 DR. CARTER: Thank you.
l 25 MR. JOHNSON: I would like to move on, then, to I
Heritage Reporting Corporation (202) 628-4888 i
. . _ _ _ . _ _ _ _ _ _ . . _ _ _ _ _ _ _ - H
32 1 focus on the objectives of our acceptance review of the SCP.
2 The first objective of the acceptance review is to
('[
v 3 determine whether the SCP content and level of detail is 4 substantively consistent with the requirements in 60.17 as 5 well as NRC guidance in 4.17, that's our regulatory, reg.
6 guide on the format content of the SCP. And also we have h 7 ad a number of meetings in past years and agreements with j 8 DOE concerning the-level of detail in'the SCP.
9 So we use all these things -- what is required in 10 the regulation, what is in our guidance and what is in 11 agreements -- with regards to what the SCP should look like.
12 And we do our acceptance review against this set of 13 information.
14 We also determine whether DOE has been
(~g 15 substantively responsive to our CDSCP concerns. And
\_)
16 basically, once we have looked over that information, we 17 make a determination as to whether the review should 18 continue. Essentially, that is an internal check to see if 19 the SCP is of sufficient quality to expand our staff 20 resources on. And we do this not just with the SCP but also 21 the study plans, as you will see later on. !
22 DR. STEINDLER: In the case of the second bullet 23 there, to determine whether DOE has responded to the 24 consolidated draft. I'm not sure I fully follow what the 25 quantitative criterion is. They have obviously responded in Heritage Reporting Corporation (202) 628-4888
33 1 the sense that I have seen typed pages that are numbered j l 2 appropriately and cover all the numbers of the objections 3 and comments that you have made.
4 Are you implying by this if you don't like their 5 answer you are going to fire the whole thing back to them?
6 MR. JOHNSON: No, absolutely not. It's just 7 whether they have substantively considered the comment.
8 Whether they agree with it or whether they have resolved it 9 or not to our satisfaction is not what we are reviewing as 10 part of the acceptance review.
11 DR. STEINDLER: So the issue really is have they 12 been flippant or not?
13 MR. JOHNSON: Right. Have they totally ignored us 14 or not. Right.
15 DR. ORTH: Out of curiosity, is there a way to 16 resolve things? For example, the staff takes a position 17 that something needs to be done or modified or something and 18 DOE explains it at great length and comes to the conclusion 19 that gee, we've done everything we can to explain it. And 20 you people say well, we don't care what you say, we want to 21 do it our way, or we need that information.
22 Now, is there any way to resolve that or is it at 23 this point in your court and you just say that's too bad, 24 boys and then you fire it back and you don't approve it?
25 MR. JOHNSON: That is not the point of the Heritage Reporting Corporation (202) 628-4888
i s
34.
l.
g j 2: DR. ORTH: I know. I'm asking the question.
3 MR. JOHNSON: In a technical review we may I
4 disagree with the approach'that DOE has taken if they 5 haven't convinced us and then we would come:back possibly if
, 6 we felt it was necessary with a further comment, or welwould 1
7 identify the need for consultations, some meetings with DOE 8 to maybe better understand each party's point of view.
i' 9 DR. ORTH: Nobody has set up an independent review 10 board, so to speak?
11 MR. LINEHAM: Not yet. We have, to give you some 12 examples in the past, we had a number of outstanding issues 13 on the exploratory shaft in addition to.these on the CDSCP 14 comments, that we went back and forth with DOE-on~for a 15 number of months if not years, to try to reach agreement.
16 And what we ended up doing was setting up a 17 meeting where we went through all of the open issues and 18 tried to hammer out some agreement on how the issue would be 19 handled. And I don't have the exact numbers, but.we were 20 successful on a number of those open issues when we actually 21 sat down and met with DOE with participation by the State of 22 Nevada.
23 We have had this same experience in the QA area 24 where we have pretty much resolved a number of the open QA a
25 issues we had. That doesn't mean that we have accepted f
Heritage Reporting Corporation (202) 628-4888 1
___________- - - Q
35 i
1 DOE's QA program. They still have to develop their !
2 programs and implement them adequately. But there are a lot !
3 of issues as to what they had to do to reach an acceptable 4 program. And we have resolved some of those. ;
i 5 But the intent is to have interactions with the 6 department, once we identify these things. It's not to let 7 them sit out there and have some disagreement over them.
8 And hopefully we will reach agreement.
9 MR. JOHNSON: Moving on to Page 11, looking at the 10 objectives of the technical review now. Again our overall 11 SCP review consists of two steps, an acceptance review and a 12 technical review. The objectives of the technical review 13 are many, 14 One is to identify concerns related to DOE's 15 obtaining the information needed for licensing. A second
- ,-')
16 one is to identify concerns that might have significant 17 adverse effects on the waste isolation capabilities of the 18 site. Third is to identify concerns that might have 19 significant irreversible or unmitigable effects on the 20 ability to adequately characterize the site.
21 For instance, if certain tests interfere with one l
22 another, in a way that might preclude, forever preclude the l 23 collection of a certain amount of data that might be needed i
24 for licensing, then that would be an important thing to
)
25 identify.
j l
Heritage Reporting Corporation l (202) 628-4888
36 1 Another objective would be to determine whether er k
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u.
2 any planned use of radioactive materials is necessary for 3 site characterization. And as I have said before, to review l 4 DOE's resolution of NRC's CDSCP concerns. And then finally, 5 to document the concerns that we have identified in a site 6 characterization analysis, which is required by NWPA.
7 DR. MOELLER: Back to Dr. Okrent's comment, 8 though. This list assumes that the parameters for which you 9 are collecting data or DOE, for which DOE is collecting 10 data, are the correct parameters, are the most important i 11 parameters.
12 It could have been that the first and most 13 important objective of your technical review is to be sure 14 that the key factors have been identified.
15 MR. JOHNSON: That certainly is part of the first 16 objective there.
17 DR. MOELLER: Okay.
18 MR. JOHNSON: It is concerned with obtaining the 19 information needed for licensing.
20 DR. MOELLER: So in that you are including --
21 MR. JOHNSON: That's right.
22 DR. MOELLER: -- the comment. Okay.
23 MR. JOHNSON: The type of information, the quality i
24 of that information, is embodied in that first objective.
25 DR. MOELLER: Okay.
Heritage Reporting Corporation (202) 628-4888 8
37 1 MR. LINERAM: Dr. Moeller, I think it is important j 2 to note that this issue hierarchy process that was referred 3 to earlier, we have gone over that with DOE. We reviewed 4 it with them and we have accepted it. And that lays out 5 what the basic issues are. And that leads to the 6 information needs. And that was done I believe a year or 7 two ago.
8 DR. MOELLER: And indeed you went over it with us.
9 MR. LINERAM: Right. And if we see any problems 10 with that as we review the SCP, we will indeed highlight 11 them. But that is not the focus of our review.
12 DR. MOODY: In other words, you think that 13 previous round that you went through was enough to cay at 14 this point that the issues hierarchy is valid? Correct?
15 MR. JOHNSON: That's right.
16 DR. CARTER: Let me ask you something about the 17 radioactivity, if you are through with that. What sort of 18 process do you go through? Does this include, for example, 19 use of neutrons for moisture determination, this sort of 20 thing, well logging, basically? Any sealed sources, any 21 kind of radioactivity?
22 MR. JOHNSON: It would include those, yes.
23 DR. CARTER: Okay. And your interest is whether 24 or not the testing itself will contaminate the site, is that 25 the concern?
Heritage Reporting Corporation (202) 628-4888
'30 1 MR. JOHNSON: That's-the overall concern, I think.
2 Our part of the responsibility- is just to make sure it is 3 necessary to do. DOE is responsible for again,-impacts on
- l. 4 the-environment.
5 DR. CARTER: But I presume they will be using 6 radioactive sources of one sort or another in their
'7 characterization.
8 MR. JOHNSON: Right. Standard industry-type 9 testing.
10 DR. ORTH: I've been, on several of the things 11 that I've been reading as time goes on with this, I've been 12 continually bothered by that word "necessary." There are 13 a lot of. tests in which use of radioactive materials, 14 tracers under various control conditions, is the fastest, 15 cheapest and best way to get an answer. But I continually 16 run upon this word "necessary" here and:there scattered l I
17 around things.
18 As far as I am concerned, there's other ways to do
}
19 it -- more expensive, slower, not as good data -- but that {
20 word "necessary" just keeps nagging at me every time I see 21 it. So I'm wondering how absolute is the word "necessary"?
22 MR. LINEHAM: I'm not sure what the specific 23 language in the Act is. I believe that "necessary" does 24 come from the Act. What we've laid out here is consistent l 1
25 with what the National Waste Policy Act requires, and Heritage Reporting Corporation (202) 628-4888
39 1 requiresl of the NRC.
r
{ j\ 2 In looking at "necessary," I don't think, if there 3 are other' ways that would cost a lot more, I don't think we 4 would necessarily be recommending to the department that 5 they go out and do those.
6 And the earlier question, Dr. Carter, we're mainly ,
7 concerned about, not sealed sources, but if there is any 8 injection of material. You know, the use of sealed sources 9 is no problem whatsoever.
l l 10 DR. MOELLER: Dr. Parry?
11 DR. PARRY: John, as I remember the Act, I thought.
12 that that referred mainly to insertion of large casks 13 containing spent fuel or glass, irradiated glass. And I 14 thought that was the biggest problem, that people were 15 concerned that this material could come back out, and that
(~}
NJ 16 was the thrust of the Act's provisions or comments.
17 I didn't think that it was the relatively small 18 sources involved with testing, geologic testing.
19 MR. LINEEAM: The interpretation we have of the 20 ACT from our legal staff, who was involved in' preparation of 21 the review plan, was that it included both, and it did 22 specifically address both. )
23 DR. STEINDLER: Before you leave the technical 24 review, I guess I'm a little troubled by t he process. You 25 are going to go through and look at DOE's site Beritage Reporting Corporation (202) 628-4888 i lli
40 1 characterization planning activity. They are gong to tell 2 you, they have told you in 6,000 superb pages, what it is
()N
'w.
3 they plan to do.
4 Let's suppose in fact that you have gone through l 5 this whole exercise of reviewing it and with minor changes 6 in things you substantially give it your blessing. And 7 two years down the line you suddenly find that based on the l 8 information you had in 1989 that blessing was all right, i 9 Based on the information you have in 1991, you really, if 10 you could do it again, you would retract the blessing from 11 Section 8.44, or whatever.
12 Now, the DOE might come to you and say hey, 13 fellows, you already gave this your blessing. We went and 14 did what you said was all right to do and now you are i f- 15 complaining about it.
(
16 How do you solve that problem? There is no 17 mechanism, is there, to force a revision of that plan?
18 MR. JOHNSON: I would like to respond in a couple 19 ways.
20 First of all, we don't really give our blessing to ,
i 21 the SCP. We identify objections or concerns with the SCP.
22 We note that the SCP is only the first step in a process 23 where semiannually the DOE updates the plan, brings to our 24 attention changes in their program. And semiannually we !
25 review that. So there is a chance, and I think that process Heritage Reporting Corporation (202) 628-4888 8
41 1 recognizes the fact that as information is collected or 3
( j 2 analyses are done, parts of the program may change. And our
(_x 3 review may reflect changes also.
4 DR. STEINDLER: That change, however, is initiated 5 by DOE, isn't it?
6 MR. JOHNSON: The changes would be, some changes 7 would be initiated by DOE, that's right. As they get more 8 information, understand the site better or do new analyses, 9 they may, and they should, their process calls for them to 10 be changing their program as they need to, to address the 11 resoJution of the issues for licensing. And we review those 12 changes on a semi-annual basis.
13 So where there are changes in the program, we 14 will review that. If we see a change for some reason,
, 15 maybe, that is contrary to a previous comment we made, I l
16 mean that might occur also, as we understand the site 17 better. That is certainly possible.
18 DR. STEINDLER: Okay. You say you don't approve 19 this thing. Is your process one of being silent or 20 disapproving? Are those the only two options you exercise?
21 MR. JOHNSON: The statute and our regulation calls 22 for the director to either make objections or no objections, l 23 if he is able to make that statement, and then to offer 24 additional comment or recommendations. It does not call for 25 us to approve the plan.
Heritage Reporting Corporation (202) 628-4888
\
__ _ -_D
5:
r 42 1 DR. STEINDLER: I sense that's-splitting hairs,
- 2 but I'll let you go on it.
3 MR. JOHNSON: Finally, on Page 11, we have two 4 types'of technical review guides. We have genera 11 review 5- guides. And these are basically the main headings of 6' Chapter 8 of the SCP, things =like for all site 7 investigations or performance assessment activities or for 8 QA or for the schedule.information in the SCP, we have a 9 generic review guide for each of those broad topics, that i
10 all the disciplines use. There are a set of, as'you'll' note 11 when you~1ook at it, a set of general criteria to. guide the 12 staff's review of any of these sections of the.SCP.
13- .These general review guides are complimented by a 14' set of detailed review guides for certain technical topics.
15 Some of those would be like natural resources, structural 16 geology,~ bore hole and shaft sealing, where the staff lays 17 out in a little more detail the types of information they 18 .w ould be looking for in the SCP or the types of 19 investigations they would expect to see in the SCP. This~is 20 just guidance for the staff to use in review of DOE's 21 program.
23 So there's two levels of guides. General ones 23 th*t all the disciplines apply and then specific ones that 24 maybe just the geologists apply or just the hydrologists 25 apply.
Heritage Reporting Corporation (202) 628-4888 i
i 43 1 DR. MOODY: -Robert, how have you gone about to 2 make the decision as to what is ur.deIgoing -- Part 2, what
-3 will undergo detailed review, seeing there is, as you know, 4 so much in the SCP. You told us- before that you are going 5 to make a decision on what you are going to review in 6 detail. How is that decision made, how has it been done? I 7 MR. JOHNSON: The areas that we would review in 8 most detail and those areas we would s7phasize, as I 9 mentioned before, are those related to our resolution of 10 CDSCP concerns is one; and secondly, we have a number of 11 topics that we have identified as being most important for !
12 the Yucca Mountain site. Those topics are identified in 13 the detailed review guides and those would help focus the 14 staff in doing their most detailed reviews. Those are some '
15 of the key issues that you have heard of before, vulcanism, 16 vein deposits, and various key characteristics or processes I i
17 important to the Yucca Mountain site's performance. I 18 On Page 12, let's look at CDSCP review plan. And 19 this we call our work plan. As I said before, it provides 20 administrative guidance, primarily. I won't go into this in O 21 much detail but I will just point out the basic types of 22 things that are covered by the work plan -- schedule l 23 information, resource, guidance for the staff. >
24 It lays out the organization and general 25 responsibilities for all those involved with the review. It l
Heritage Reporting Corporation (202) 628-4888
44 1 identifies the various activities and the specific 2 responsibilities for conducting those activities. It
{*~))
m.
3 describes the various products, not only the site 4 characterization analysis but there are a number of other 5 products that we need to prepare.
6 It lays out the internal quality assurance 7 requirements that pertain to this review, the records 8 managemer t , open item identification and tracking, and then 9 any procedures that we might use during the course of the 10 review.
11 I'll just highlight on Page 13 two items that 12 might be of greater interest to you.
13 The first is related to the organization and 14 responsibility of this review. We are continuing to use the 15 team concept that we have used for review of the O 16 environmental assessments and the CDSCP. That has worked 17 quite well over the years. We have refined it as we go, but 18 we are continuing to use that same approach.
19 It is important to note that the staff has the 20 lead for conducting the technical review. The contractors 21 do give us support in specific technical areas. Those are 22 very carefully defined areas of input. They do work with 23 the staff in the review and preparation of the comments but 24 the staff has the lead in preparing the product and in fact 25 they do a large bulk of the review.
Heritage Reporting Corporation (202) 628-4888 8
l 45 1~ Moving on, and let's look at the site j 2 characterization analysis itself, and what that document, I% -) \
J 3 what that product is, what we think it should look like, )
I 4 anyhow. And of course that will evolve a little bit as we 1
5 get into the process.
6 But as of right now, I have a general outline 7 listed here. After the introduction there will be a section 8 on the director's comments and recommendations. As I 9 mentioned before, the Act and our regulation requires the 10 director to either make a statement of no objection to DOE's 11 programs or to identify objections and then prepare any j 12 other conclusions or recommendations.
13 So in Section 2 we will have that sort of 14 information.
15 In Section 3 of the SCA, we will have a summary of 16 the SCP concerns. This is not only serving the purpose of 17 an executive summary for various audiences but it is a way 18 to integrate a lot of the specific concerns that we have.
19 For those of you that have looked a.. our CDSCP concerns, the 20 point paper package, they were $ust a whole list of specific 21 concerns. And we felt it would be useful to have a summary 22 of those concerns in a particular section that would tend to 23 integrate those together for each program and make the, give 24 people an overview and help our concerns be more 25 understandable.
Heritage Reporting Corporation (202) 628-4888
46 1 In that summary, we will also have a table of the 2 concerns by programs, so people again can get an overview of
&(T 3 what our principal concerns are. And then we will also have 4 a table that will summarize the status of each CDSCP open 5 item, whether we feel that the item has been resolved or 6 whether we feel there still is a concern that is open.
7 And then Section 4 would be where the bulk of the 8 staff's analysis is and that would be each of the concerns 9 we have with the SCP, either objections, comments or ,
10 questions. I'll define those in a minute.
11 And then Appendix A would be those CDSCP concerns 12 that we feel are resolved. We would identify those and give 13 a short reason for why we feel they have been resolved 14 adequately.
15 DR. MOELLER: Bill, did you have a question?
16 DR. HINZE: Yes. Thank you. Is the concerns the 17 same thing that you referred to previously as key technical 18 topics?
19 MR. JOHNSON: No.
i 20 DR. HINZE: What's the difference here?
21 MR. JOHNSON: Okay. Key technical topics are just 22 characteristics or processes or elements of the repository l 1
23 design or something that we feel for Yucca Mountain are most l I
24 important for us to pay attention to. We may or may not j
)
25 have a concern with how DOE is approaching study of those Heritage Reporting Corporation (202) 628-4888 l Ill
l 47 1 particular topics. So we have topics on the one hand that
(~X)
\_,7 2 might be like vulcanism or faulting. And then we have 3 concerns on the_other hand that relate to specific problems 4 that we have with DOE's program. There's really two areas.
5 DR. HINZE: Do you have a summary of those key 6 ' technical issues?
7 MR. JOHNSON: Right now they are listed in the SCP 8 review plan in the back of each of the review guides, 9 detailed review guides. We could prepare something if you 10 wanted. Right now they are just scattered throughout.
11 DR. HINZE: I think I would find that helpful.
12 DR. MOELLER: Okay. If you could consider that
.13 request.
14 MR. JOHNSON: Moving on to Page 14, we do define 15 and prioritize the concerns that we identify. We feel that 16 prioritization of our concerns is important to focusing the 17 consultations that we might have in the future with DOE, and 18 it is also important for DOE's resolution to know which 19 concerns are most important to NRC.
20 And we have defined three sets of concerns --
21 objections, comments and questions.
22 Objections are defined as concerns with activities 23 which could cause significant irreparable adverse effects on 24 the site or other site characterization activities. They 25 may also be fatal flaws with certain parts of the DOE l l
! Heritage Reporting Corporation (202) 628-4888
48 1 program. Like in our CDSCP review, we had an objection F'S 2 relating to alternative conceptual models. This was a L/
3 pervasive sort of concern that if it wasn't corrected it 4 wotid, DOE's program would be going off in a certain 5 direction and making a change later could cause substantial 6 deJ ays in schedule or perturbations in their overall 7 program.
8 So again, it is major things that we feel that DOE 9 should not start work until they are resolved, things that 10 could not be fixed, or if they would continue, they would 11 real y cause harm to the whole program or significant delay 12 in the schedules.
13 A second type of concern we call comments. Now, 14 these are very important. Don't feel like just because 15 it's not an objection it's not important. As a matter of 16 fact, these are concerns that could significantly affect 17 licensing if they are not resolved by DOE.
18 The important thing here is that we don't feel 19 that they have to be resolved before work starts. They can 20 be resolved later on. They should be resolved in a timely 21 fashion but not necessarily before work begins.
22 In the last category are questions. And of course 23 these are concerns just with the presentation of information 24 in the SCP. Maybe there is an ambiguity, there is a 25 contradiction, or there is missing information that leads to Heritage Reporting Corporation (202) 628-4888
49 1 the staff not being able to understand a certain part of (9) 2 DOE's program. Therefore, we might have a question for them 3 to clarify. And therefore, for these questions, we would 4 recommend that DOE clarify certain parts of their program.
5 This clarification weald likely occur in updates, semi-6 annual updates to the SCP, or maybe through other means, 7 letters or meetings with NRC.
8 These were two principal areas of our SCP work 9 plan that I wanted to highlight. The other information is 10 pretty detailed and I am not sure it is worth going into 11 today except for two other areas. King Stablein will be 12 talking about the activities and the schedule of the SCP 13 review, and then also the status of that review. And his 14 discussion will focus on the next page, Page 15 of this 15 package.
16 DR. MOELLER: Any other questions for Bob Johnson?
17 Go ahead. Dr. Moody.
18 DR. MOODY: Bob, getting back to objections, in 19 terms of prioritization. Knowing the only comment I have 20 with respect to this is that I can think of two or three 21 major geologic, hydrologic issues in which with the 22 information we have at this present time we may not be able 23 to resolve, whether or not it would be an irreparable, 24 adverse, or not, effect.
25 So, in negotiation with DOE, how are you going to
\
Heritage Reporting Corporation (202) 628-4888 8 l 1
50 1 handle a fundamental question that we don't even have enough 2 information at this time to say the extent of a potential j 3 adverse effect?
I 4 Are you just going to agree with DOE that it 5 should undergo detailed work in order to resolve it? In 1
6 other words, I could see where there are a couple things 7 where you could come out still with an objection and DOE can 8 come back and say we just don't have enough information at 9 this time to answer.
10 MR. JOHNSON: Well, objections again are related 11 to where we don't think DOE should start work until that 12 problem is resolved. And if the examples you are referring 13 to need further study, then you have to proceed.
14 DR. MOODY: All right. So then that by definition 15 would go down to a comment level, then?
9 16 MR. JOHNSON: It would go down to a comment, 17 unless there is clear indication from what we know right now 18 that there would be interference maybe with another test 19 that would preclude other information from ever being 20 collected.
21 If we can say that now, then we would say that and 22 that would be an objection.
23 DR. MOELLER: To help me, Dr. Moody, the problems 24 you had in mind you now would conclude could be ranked as 25 comments versus objections?
Heritage Reporting Corporation (202) 628-4888 8
51 1 1 DR. MOODY:. I don't necessarily agree with Robert.
(%r ) . ' :2 But-I can understand why he has responded the way he has.
3 DR. MOELLER: Okay. Any other questions or l 4 comments, before we move to King Stablein?
5 ('o N response) 6 DR. MOELLER: Well, thank you. And we'll move on, i 7 then.
8 MR. LINERAM: The next presentation is on the SCP 9 review activities schedule and status. This is going to be 10 a very brief presentation, given by King Stablein. Dr.
11 Stablein is the Project Manager that coordinates the review 12 team's effort within the Division of Waste Management. He 13 has been the Project Manager for the review of the CDSCP and 14 also the environmental assessment that w as published on the f 15 Yucca Mountain site.
16 DR. STABLEIN: Thank you, John. And good 17 afternoon.
18 Looking at Page 15 is the easiest way that we can 19 chart what is supposed to happen in the SCP review, and what 20 has happened to date.
21 We received the SCP from DOE in late December and 22 had planned to begin the SCP review January 2 as is shown 23 on the chart. The notification of SCP receipt refers to 24 letting the Governor of the State of Nevada, the Nevada 25 Project Office and the counties know that we received the Heritage Reporting Corporation (202) 628-4888 l
52 1 SCP and that_our review is beginning. We also put a notice
['be ) 2 in the Federal Register about that, 3 The first major event that takes place in the 4 review of the SCP is the acceptance review,. Robert talked 5 about the criteria involved in that and pretty much how we 6 would go about it. And that was scheduled to take one month 7 from January 2 to January 27th.
8 You might notice however the footnote to this I
9 chart which indicates that in the second sentence: "If 10 receipt of references (e.g. Design Acceptability Analysis) 11 is delayed, there will be a corresponding delay in the 12' review and SCA issuance."
13 We did not receive from DOE the design 14 acceptability analysis or the study plans which are related 15 to exploratory shaft construction phase testing until 16 February.
17 Hence, it became impossible for us to complete the 18 acceptance review by the January 27th date shown on the 19 chart.
20 However, we did receive the supporting information 21 around February 9 and are currently reviewing those-22 documents preparatory to making a decision and completion on 23 the SCP acceptance review.
24 We expect to complete the acceptance review and 25 have a letter out to DOE with the results of the acceptance J
l l
Heritage Reporting Corporation 1 (202) 628-4888
i 53 1 review by the end of February.
i
) 2 DR. MOELLER: And to help me again, the acceptance 3 review is an indication that you consider the SOP of a 4 quality that you can move forward to do one of the next two 5 steps?
6 DR. STABLEIN: That's right. The information 7 provided is substantive enough, and that was discussed 8 earlier, is substantive enough to enable the staff to do a 9 systematic and orderly technical review of the document.
10 DR. MOELLER: And you will have t hat or you will i 11 reach that decision by the end of February.
12 DR. STABLEIN: We expect to reach that decision 13 and send the letter to DOE at the end of February.
14 The next activity is the technical review of the f"]
'i 15 SCP and this activity Robert has laid out the steps involved 16 and the concerns that we would be dealing with in this 17 technical review. We have a-team consisting of staff 18 members representing seven different disciplines, depending 19 on how you count your disciplines, but the entire spectrum 20 is covered - geology, geophysics, hydrology, performance
'21 assessment, engineering, material science, geochemistry.
22 We have representatives from all the different disciplines 23 on this team and they pursue their individual reviews, but 24 at the same time through the weekly team meetings we get 25 together, exchange ideas and let each other know where we Heritage Reporting Corporation (202) 628-4888
r 54 1 are in the review.
(s)
(j 2 If somebody comes upon a major concern they raise 3 it early in this review period so that the other disciplines 4 can either raise questions about that and challenge it or 5 say that they found similar sorts of concerns in their area.
6 And so you get this integration of the concerns, or, in some 7 cases, refutation of concerns if some people don't see that 8 same problem, even in the same area.
9 And by this method, we are attempting to ensure as 10 integrated and consistent a technical review as possible.
11 We are starting the process of these team meetings and the 12 exchange of ideas early on, even before the written comments 13 start to be developed.
14 The emphasis is on getting the concerns out on the 15 table early so they can be evaluated by the rest of the 1
1 16 team and so the rest of the team can be looking for those 17 concerns in their own area.
18 DR. CARTER: King, are these seven people on the 19 team -- I presume there may be a few more -- but are they 20 dedicated to this full time during this process?
21 DR. STABLEIN: First of all, you're correct that 22 there are more than seven people. I'm not sure of the exact 23 number but it would be closer to 15 to 20 people on the 24 staff involved to some level in the review. Only about five 25 to seven people are dedicated full time during this 14-week Heritage Reporting Corporation (202) 628-4888
55 1 review period allowed for the main technical review. The 7 ~T 2 others are halftime or quarter time or whatever is required
(-
3 for their slice of the review.
I 4 Now, if it is found as they get into the review t 5 hat they would need to devote further time to it, we would 6 have to allocate more of their time to the review. But we 7 have a core group of five to seven people that are full time 8 on it and then others who are supporting.
9 DR. MOELLER: Now, I have noticed in your memos 10 that certain segments of the SCP are assigned to RES to 11 handle and so forth. What percent of the total review is 12 being donc outside of NMSS?
13 DR. STABLEIN: Percentagewise, I might have a 14 'semewhat difficv7t time.
15 DR. MOELLER: Just ballpark it.
/~/)
k- 16 DR. STABLEIN: It is my understanding, but John 17 Linehan here can correct me if I'm off on this slightly, I 18 believe that the Division of High Level Waste Management has 19 the primary responsibility in all the review areas and in 20 some cases we have asked research or the contractors to give 21 us support in specific areas where they might have unusually 22 qualified personnel that could provide us with assistance.
23 DR. MOELLER: So that's small parts, it's not 25 24 percent or anything like that?
25 DR. STABLEIN: I don't believe it would be Heritage Reporting Corporation (202) 628-4888
i 56 1 anywhere near 25 percent, but I defer to John if he has a
('r)'2 U
3 comment on that. He indicates that I am on the mark there.
DR. MOELLER: thank you.
4 DR. STABLEIN: I might say that although it is a 5 relatively small percentage it is going to be a valuable 6 contribution.
7 DR. MOELLER: Sure.
8 DR. STABLEIN: And we appreciate those 9 contributions.
10 DR. MOODY: Those people are still within NRC 11 then, right?
12 DR. STABLEIN: The research I am referring to is 13 the Office of Research in NRC. The contractors would be our 14 people at the Center. So, yes.
15 Moving ahead then with the technical review of the 16 SCP, as originally scheduled, that would run from January 2 17 to April 7, 14 weeks, which we think is a pretty substantial 18 amount of time to let the staff alone to work on analysis of 19 this complicated document.
20 Now, once we reach April 7 that doesn't mean that 21 everything stops as far as the staff looking at the 22 document. But we move to the next phase which is internal 23 QA and management review of SCA. At the end of the 24 technical review, the staff would have developed preliminary 25 comments, something in writing, what would be called the Heritage Reporting Corporation (202) 628-4888 8
j 57
. 1 1 . reviewer draft,'if you are following this in the review
.(
.y 2 plan. And that document will have been looked at already 3 informally by section leaders who are responsible for
'4 supervising their staff's work.
5 Once we move into the internal QA and management 4
6 review section the preliminary comments are going to start
]
7 to take shape, working toward getting the final product and 8 'in fact the SCA evolving toward what it will be when it 9 finally goes to DOE.
10 During that eight week cycle there are several 11 different drafts identified in the review plan as the 12 package moves up the management chain and gets looked at at 13 higher and higher levels of management.
14 The material that will particularly get worked on 15 by management of course will be the director's comments, the
.O 16 more genera 1' material on major concerns and whether in fact 17 we do have objections to the site characterization' plan.
18 And so we have allowed eight. weeks for all of that 19 to go on. At the end of the eight weeks we should have an 20 office draft including the director's comments and the text 21 of the SCA together and ready for further review activities.
22 23 24 25 Heritage Reporting Corporation (202) 628-4888
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58 ,
.)
1 DR. STABLEIN: The next line on this chart is 2 shows the State of Nevada interactions, and you see this 3 dashed line running across the page.
4 Originally we had some milestones on that, but 5 what we are trying to do instead is to keep the State of 6 Nevada and the affected parties informed throughout this 7 review process as perhaps a more efficient of allowing them 8 to get involved when they choose; when they feel that it is 9 the time for them to either find out what we're coming up 10 with in our review, or when they so desire, to let us know 11 what they are finding in their review.
12 And, of course, I mentioned that we contacted them 13 immediately to let them know the review was starting. And 14 we have made the options available of conference calls, of 15 meeting with the staff, whatever way they feel is most 16 efficient for keeping in touch with our review as it's 17 ongoing.
18 Hence, you see the dashed line without any 19 particular time identified for interactions.
20 The next line also takes on that dashed line look 21 and that's the ACNW. And once again, the idea is early 22 involvement, or at least familiarity with what we're about 23 as we conduct the review. There are some milestones 24 indicated on here. And, of course, tomorrow's DOESCP 25 briefing of the ACNW as indicated on here, not quite in the Heritage Reporting Corporation (202) 628-4888
l 59 1 time frame it occurs according to the 30-week layout, but
(%/ ) 2 fairly close.
3 And then we have, for example, Jack Parry of the -
4 ACNW has been attending these team meetings that I referred 5 to on a weekly basis. Other members are welcome to attend 6 any of these meetings which typically occur Wednesday 7 morning at 10:00 over in White Flint, and any other means 8 such as the briefing today of keeping the ACNW plugged into 9 what we are about in this review.
10 Now there is, when we get down to June 2nd on this 11 schedule, a solid line indicating ACNW review of the SCA.
12 And that's indicated because it is there that we hope to 13 turn over the package to you people and give you the 14 opportunity to review it and give us comments back upon that 15 before we go to the next stage, which is going to be the 16 Commission review of the SCA.
17 So we have allotted a month from June 2nd to June 18 30th, according to this schedule, for you to review of SCA 19 and give us feedback. And our hope is that by keeping you 20 in touch with what we are doing from the beginning, we won't 21 get this package cold, wonder what it's about and then we 22 start the interactive process.
23 DR. MOELLER: Now since you are a month behind on 24 the acceptance review, does that mean everything has slipped 25 a month at the end here?
Heritage Reporting Corporation (202) 628-4888
60 1 DR. STABLEIN: Well, that's the big question which
(') 2 I am not going to be able to answer for you today, because V 3 we are still evaluating the impact of the slip in receipt of 4 the materials from the DOE on the overall seven-month review 5 schedule.
6 As I said, by the end of February, we will have 7 that determination. And laying out the schedule for the 8 review is part of that letter that will go to the DOE. And 9 at that time we will be able to tell you pretty 10 definitively, although even then there would likely be some i 11 contingencies, depending on events that transpire in the 12 next few months, but fairly definitively where that month 13 would fall. And I know you need that information.
14 DR. MOELLER: Now somewhere I was reading it said 15 that the ACNW's review would replace the " decision support W 16 system review", or it might?
17 DR. STABLEIN: What's your question about that, 18 Dr. Moeller?
19 DR. MOELLER: Could you tell me what it is and how 20 it replaces it and so forth?
21 DR. STABLEIN: Okay. For the EA, the 22 environmental assessment, we had an independent review group 23 made up of NRC personnel but not personnel involved in the 24 program that were convened to look at what would be j 25 equivalent to the SCA, or similar; the final product before i
Heritage Reporting Corporation (202) 628-4888 lif
61 1 it was sent out. And it was three or four-person committee.
( ) 2 They were given about a month to look at the product and
\_/'
3 give us their comments, which in fact they did, and we got 4 some very good comments from them.
5 And in like manner, it was hoped that you all, as 6 independent of the actual review process, could give us that 7 same kind of review of the SCA. And we didn't see the need 8 for that committee again if you all were willing to provide 9 us with that kind of assistance.
10 DR. MOELLER: I understand. Thank you.
11 Yes, Dave Okrent. l J
12 DR. OKRENT: I didn't notice the word 13 " uncertainties", and " fair review". I missed it. 'No? But 14 they certainly mentioned in the SCP, and some way thought
- 15 about by the NRC.
16 I wondered if you could give me a hint of what 17 kind of philosophical approach you will bring to the whole 18 raft of issues that arise from that.
19 DR. STABLEIN: that's a whale of a question, and 20 I'm not sure that I'll be able to satisfy you with the first 21 cut at it.
22 You are right. Uncertainties permeate the entire 23 understanding of the site. That's why site characterization 24 is being done to narrow the range of uncertainties: To 25 indicate that the staff has been focusing on that.
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I . _ _ _ _ _ _ _ _ __
)
62 l 1 The first objection and the one that Robert
-s 1
\
()
%/
2 referred to on the CDSCP basically was about uncertainty. j i
! 3 He cast it in terms of alternate conceptual models of the l
)
4 site. And I am going to move a little bit ahead of my next 5 presentation here, but the data base as it now exists allows 6 for a lot of uncertainty in interpretation of the processes 7 and conditions at the site. And the staff perceived that 8 DOE was not taking into account the uncertainty in the 9 understanding of the site, and hence, made that the prime 10 technical objection to the CDSCP.
11 As part of the review of the SCP, we will be 12 looking to see how the DOE has attempted to redesign its 13 planning to better account for the uncertainties that now 14 exist in the data base or in the understanding of the site.
15 Perhaps that will help you to at least ask the 16 next question about how we are going to approach 17 uncertainties.
18 DR. OKRENT: Well, I was aware of concern No. 1, 19 and it certainly is of an important concern.
20 Does the staff expect enough to be learned about 21 the site that the uncertainties with regard to what are the 22 possible geo hydraulic logical bases, or characteristics of 23 the site are narrowed down, disappear? Do you think they 24 are still going to be a family of possible interpretations, 25 concepts that are not disproven when they have done what l
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63 1 they can without destroying the site as I understand it.
r'~T 2 And I really don't have a very clear idea, I must say, as to GJ 3 how you would then view this issue of uncertainties. What l
4 will you do? You still have some alternative viable 5 concepts for the hydro geologic site.
6 DR. STABLEIN: I think at this early stage in site 7 characterization it is very difficult to really make an 8 intelligent estimate as to where DOE will end up when they 9 have conducted site characterization. We will have to deal 10 with the remaining uncertainty after they have made their I
l 11 best attempt to reduce it as much as possible with their 12 site characterization program.
13 If you can ask me a more specific question, I will 14 attempt to approach it. But at this stage in site
/' 15 characterization things are wide open as far as t
16 . understanding the site, and I think part of the scientific 17 investigation is to see how much of the uncertainty they can 18 remove during their program.
19 DR. OKRENT: Let me, if I can ask, do you feel 20 that it's necessary that some degree of assurance exists 21 that a concept, whichever one it is that DOE settles down on 22 is the "true concept"; that there be no other viable 23 concepts, or do you have any position in that regard? And 24 have you looked to see whether it is practical to reach a 25 situation where there is only a single viable concept, that Heritage Reporting Corporation (202) 628-4888
64 1 there are not competing concepts for which experts can 2 provide arguments that you'can't refute those principles?
)
3 DR._STABLEIN: I would like to let Seth Coplin, 4 who head the compliance demonstration section, take a crack 5 at this since this is what the area that his people work in. j 6 Seth.
7 MR. COPLIN: Systems performance section actually 8 at this point.
9 Dr. Okrent, you have asked several questions today 10 that I think are in a way all very closely related. And in 11 fact, I think part of what DOE will be presenting tomorrow 12 on performance allocation and this issue resolution process 13 should start to address them.
14 At the risk of jumping the gun somewhat let me try j l 's - 15 to summarize a few points here.
1 16 DR. OKRENT: Let me note that I have read some of l
17 their material on performance allocation. I'm trying to 18 ascertain how the staff expects to go at these difficult 19 issues. And if you are prepared to say their performance 20 allocation method is going to work it all out, I'm willing.
21 to ask questions about that actually. I suspect that's not 22 -rour answen!
23 MR. COPLIN: No. What I would say is that we 24 think that this performance allocation can serve as a kind 25 .of a framework within which a number of the kinds of Heritage Reporting Corporation ;
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l 65 1 questions that you have raised can be dealt with.
('}-
s_,
2 Specifically, if you look at Part 60, there are 3 several numerical requirements that pertain to the post-4 closure time frame, the performance objectives. And they 5 are ultimately going to require what in waste management 6 argot has come to be called performance assessments; namely, 7 these -- you know, these quantitative analyses of the way 8 the repository and certain of its subsystems are going to 9 behave.
10 One of the things that can be done, of course, 11 when you start doing that type of analysis, or uncertainty 12 analyses and sensitivity studies that enable you to get a 13 handle on which of the possibilities that exist within the 14 data are important and which ones are not going to be major 15 contributors. So ideally one would start to apply that tool
/'}
'# 16 even now to ascertain how important some of the staff's 17 concerns are with respect to some of the other concerns.
18 Unfortunately, you have to have a reasonable 19 working data base even to start from. And so what we ended 20 up settling on with the Department of Energy was a kind of 21 semi-subjective semi-quantitative kind of a process that 22 involved the development of this issues hierarchy, and 23 performance allocation as merely a way of establishing a I
24 framework within which to identify what the Department of 25 Energy thinks are going to be the important contributors to I
Heritage Reporting Corporation (202) 628-4888
66 1 success of the repository, and that then we can review and
(#~} 2 see if at least the way they are -- this performance GJ 3 allocation would focus them in terms of site investigations 4 gets them started in a way that in time one can start doing 5 the more detailed performance assessments with uncertainty 6 analyses and sensitivity analyses, and start making some i
7 decisions about whether the uncertainties that remain are l 8 really important, or whether they are inconsequential and it 9 doesn't really matter that you don't know precisely what 10 reality is at that particular stage.
11 DR. OKRENT: If I can think of examples for trying I
12 to develop seismic hazard curves at reactor sites, I am sure 13 you and I, that around the table something like that was )
14 discussed, one not infrequently saw the consultants for a
/
(~ 15 utility show three different seismic hazard curves and say
- 16 we'll chose some weighting scheme and come up with some 17 average, and this is the one we will use.
18 You have a little different situation here, as I 19 understand it, since it may be that some of the alternate i.
20 concepts are not tolerable if you use 1 percent of them, and 21 that they lead to a violation of your -- whether it's how 22 far something can go in a thousand years or 10 years or 23 whatever, i 24 So you may have some concepts that are uncertain 25 which data can't disprove or prove. They may show some i
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67 1 evidence that seems to go one way. And I am just trying to g 2 anticipate what may be a very thorny problem. I mean, you 3 could say, well, we are going to go to expert opinion at 4 that point or something. I don't know.
5 But in the planning document I haven't seen the 6 beginning of the planning approach to this sort of thing, 7 and so that's what I've been probing.
8 MR. COPLIN: I think that to some degree in the 9 SCP the level of detail that would say that we expect to go 10 to expert opinion failing to get the data to resolve, or 11 something like that, that's a level of detail that I think 12 we would expect to see in the study plans that DOE will be 13 doing rather than in the SCP itself.
14 They have made some general statements about using 15 peer reviews and about using expert judgment and that sort 16 of thing, but it's pretty thin on specifics. Ana as I say, 17 I'm not sure that we would really expect the specifics in 18 the SCP.
19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
68 1 DR. MOELLER: Are there other questions?
(\_/ 2 (No response.)
3 DR. MOELLER: All right, King.
4 DR. STABLEIN: Let me continue. I am almost to 5 the bottom of the chart. After we have received your 6 comments and have factored them into the SCA and the other 7 materials, we will be preparing a negative consent paper for 8 the Commission to review. We show two weeks for them to 9 review that, and then we have allowed two weeks for the 10 printing and issuance of the SCA showing from start to 11 finish the seven month review schedule for the SCP.
12 And on this schedule, you will notice it says 13 July 28th. I would like to remind you going back to the 14 footnote at the bottom that we have mentioned that there was 15 a delay in receiving the materials from the DOE, the DAA, 16 and the study plans, and indicated the possibility of a 17 delay therefore in the seven month review, which would cause 18 these states to slip.
19 But I would like to emphasize that we have not 20 decided that there will be a slip. That is not 21 automatically the case. The staff has, of course, been 22 looking at the SCP, and therefore it is not automatic that 23 we would have to slip. And we hope to have that information 24 out in a week or so.
25 DR. STEINDLER: What is a negative consent letter?
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69 1 It sounds like you have already made up your mind that you (m)
%/
2 are not going to like what you have seen.
3 DR. STABLEIN: If I understand it correctly, if 4 the Commission has no negative comment on it, they approve 5 it by j0st not giving us a reaction back.
6 DR. MOELLER: You see, the negative consent is the 7 document from the staff to the Commissioners. It really has l 8 little to do with what the SCA says. It simply says that if l
9 the Commission approves it without change that it moves 10 ahead. j 11 DR. STEINDLER: The English words negative consent 12 implies a lot more.
13 DR. STABLEIN: It is an interesting phrase.
14 DR. STEINDLER: It would help a lot if you guys 15 learned to use English the way that most everybody else 16 does.
17 DR. MOELLER: Jack Parry.
18 DR. PARRY: It is a secretariat term, a developed 19 term, whereby the staff sends a letter to or a finding to 20 the Commission, and the Commission is given so many working 21 days to respond, and any one of the Commissioners can stop 22 it. And usually, it is just a pro forma type of thing.
1 i 23 DR. STEINDLER: The ways of bureaucracy are 1
24 strange indeed.
25 DR. MOELLER: Does that wrap up your portion?
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70 1 DR. STABLEIN: That completes this presentation on 2 the SCP review plan schedule and status, (v-)
3 DR. MOELLER: Okay, Mel Carter.
4 DR. CARTER: Yes, I had a couple of questions.
5 One, are there other groups reviewing the SCP in 6 technical detail other than the NRC and the State of Nevada?
7 DR. STABLEIN: There were comments generated by 8 the utility waste management group on the CDSCP. There were 9 comments generated by the U.S. Geological Survey personnel 10 not involved in the Yucca Mountain project. At least those 11 two groups may be looking at it again, and I do not know who 12 else out there is looking at it.
13 DR. CARTER: Yes, but they just independently 14 proffer comments to whom, the NRC?
15 DOE.
8 DR. STABLEIN:
16 DR. CARTER: Okay.
17 DR. STABLEIN: We do get copies, but the comments
)
18 are directed to the DOE, or they were.
19 DR. CARTER: What about the Western Governors 20 Conference or a group such as that?
)
l 21 DR. STABLEIN: They did generate comments on the 22 CDSCP.
23 DR. PARRY: The State of Nevada commented.
f 24 DR. STABLEIN: Yes, Mel mentioned the State of l
25 Nevada and one other group.
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l i
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i 1 DR. STEINDLER: Does the staff has a specific QA J
('q,/) ' 2 plan to do this exercise; and if so, who reviewed it or who 3 approved it? ,
4 DR. STABLEIN: There is an IQA plan. First of 5 all, the Division of High Level Waste Management has an IQA 6 plan, a general IQA plan. And then there is an IQA plan for 7 the SCP review which is contained within the SCP review 8 plan. Robert did not chose to dwell on that today, although 9 we can answer questions if you would like. The plan was 10 reviewed and discussed with the quality assurance section 11 headed by Jim Kennedy.
12 DR. MOELLER: Are there any other questions or 13 comments?
i 14 (No response.)
15 DR. MOELLER: There being none, why do we not take 16 a ten minute break.
17 (Whereupon, a recess was taken.)
18 DR. MOELLER: The meeting will resume.
19 King, we will call on you once again to continue.
20 DR. STABLEIN: Thank you very much, Dr. Moeller.
21 We are moving on to the next handout. This one is 22 billed as NRC Staff Review of the DOE Consultation Draft 23 Site Characterization Plan for the Yucca Mountain Site.
24 As John Lineham mentioned in his introductory 25 remarks, on April 28th of last year, the NRC staff came and Heritage Reporting Corporation l (202) 628-4888 i 1ll
72 1 gave the ASRS a full day presentation on the CDSCP concerns.
2 And I am not going to attempt to duplicate that for you
(,.)
k/ 3 today. But John also mentioned that depending on the depth 4 that you wanted to go into these major concerns that I am 5 going to talk about that we will be glad to do that.
6 I would also like to mention that should you be 7 interested in greater depth than I am particularly qualified 8 to cover that we have with us today the experts who are 9 responsible for the concerns and for the point papers, and 10 they will be happy to help out answering detailed questions.
11 So I, myself, will move through this package 12 fairly rapidly until you indicate that one or another topic 13 captures your special interest, and then we can stop and 14 dwell on that.
15 DR. MOELLER: Fine. Let us proceed.
()
/m 16 DR. STABLEIN: On page two, you see the results of 17 the NRC staff review of the CDSCP. The letter that we sent 18 on May lith to DOE contained five objections, 110 comments, 19 and 52 questions. I would like to emphasize that each one 20 of those was considered to be something substantive. None 21 of those were throw aways, and the staff was prepared to 22 stand behind each one of those as something worth tracking 23 at least toward its resolution or potential resolution in 24 the SCP.
25 Now Robert has already defined for you objections, Heritage Reporting Corporation I
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73 1 comments and questions which are also my next three slides.
2 So I will not dwell on those, except to remind you that O 3 objectious are ti.ose items of such immediate seriousness 4 that the staff recommends that DOE not go forward without 5 resolving those beforehand. And today, I am going to talk 6 about five objections that the staff raised to the CDSCP.
7 DR. MOELLER: As one ties everything together, you 8 have a number of go/no go points. Like your objections, you 9 are saying are no work until these are resolved. When you 10 review a scudy plan, there are certain steps there that may 11 prohibit work until it is done and so forth.
12 DR. STABLEIN: Well, we recommend that they not 13 start work until those are resolved. And again in reviewing 14 study plans, the start work review, which is the initial 15 review after the acceptance review, we would raise
() 15 objections following.these same definitions if they seemed 17 necessary based on the study plan.
18 DR. MOELLER: And only five study plans are 19 considered to be part of the SCP, all of the others are 20 outside of the scope of the SCP?
21 DR. STABLEIN: All of the study plans are in a
! 22 sense part of the SCP or the next level of detail related to 23 the SCP.
24 OR. "OELLER: There may be only five connected 25 with the approval of the SCP?
Heritage Reporting Corporation (202) 628-4888 A
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74 I 1 DR. STABLEIN: The five study plans that were
. ,-s 2 considered important to receive with the SCP are all the i
i .
3 ones'related to testing during the construction of the 4 exploratory shaft. And hence, they are related to whether 5 the NRC has any objections to DOE proceeding with the start 6 of shaft construction. We could not come to a resolution on 7 that without having these five study plans in hand and 8 having the opportunity to review them.
9 DR. MOODY: Were there not though something on the 10 order of 103 or 105 site study plans that are supposed to be 11 now created by the Department of Energy?
12 DR. STABLEIN: The latest number that I have is 13 107.
14 DR. MOODY: Fine.
15 DR. MOELLER: And indeed, you have a monthly
) 16 schedule which you have outlined, you know, three or four of 17 them a month for the next three or four months. But I guess 18 then that I am still confused. Help me with what is the 19 difference between the five that are crucial that had to be 20 submitted in order to make the SCP complete and the other 21 102 which can come later?
22 DR. STABLEIN: Well, first of all, all of the 23 study plans relate to activities described in the SCP. So in 24 that sense, they are all equal or all very similar.
25 DR. MOELLER: But you can approve the SCP without Heritage Reporting Corporation (202) 628-4888 ,
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75 1 having seen a lot of study plans?
f~ 2 DR. STABLEIN: The level of detail agreement in 3 the May 1986 NRC/ DOE meeting specified what material should 4 be in the SCP and what material could be deferred to study 5 pl.ans. The staff has been instructed to review the SCP in 6 line with'that level of detail that we agreed upon with the 7 DOE. Hence, we cannot require study plan level of detail in 8 or with the SCP.
9 These five study plans relate to whether DOE can 10 start slaft construction or not. And that is why we needed 11 them with the SCP. DOE is pushing to start shaft 12 construction in November. We need to get comments back to 13 them on material relating to shaft construction in time for 14 them to take those comments into account as they continue j 15 their planning.
( 16 DR. MOODY: When are the remainder of the site 17 study plans going to be done?
18 DR. STABLEIN: DOE tomorrow will be better able to 19 answer that question. The schedule that I have only 20 reflects the next twelve or thirteen coming in by June of 21 1989. And after that, we do not have a schedule at this 22 time.
23 DR. STEINDLER: Do you intend to adhere to your 24 maximum six month review schedule for those five study plans 25 that you require to be submitted at the same time that the i Heritage Reporting Corporation (202) 628-4888 O
76 1- SCP was submitted?
2- DR. STABLEIN: That is going'to be part of the SCP 13 schedule which we have not totally worked out yet based on 4 the fact that they came in a month and a half after we 5 received the SCP. And in fact, we are still waiting for 6 another document establishing the technical quality of these 7 study plans. And that may set us back even further.upon the 8 review of the study plans. We'will review them as 9 expeditiously as possible, but the schedule is not set right 10 now.
11 DR. STEINDLER: Well, there is apparently a 12 schedule which I thought that we were going to.take up at 13 least briefly today on_the review of study plans which gives 14 you three specific time lines to operate on.
15 And you are saying that those time lines will not 16 be adhered to in these five, is that right?
17 DR. STABLEIN: Well, inasmuch.as these five are 18 part of the overall SCP review and delays have occurred, it 19 is difficult to predict. I think that it is unlikely that 20 ve will go past the six months once we receive the 21 supporting documents for the study plans. And in general, 22 we have indicated in the study plan meeting that we held 23 with DOE in December that we could get comments back to them 24 in six months on the study plans. In fact, it is three 25 months on the start work review, that is fatal flaw type
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77 1 problems with the study plans.
,4 2 DR. MOELLER: Dr. Parry.
G) 3 DR. PARRY: King, at the last Wednesday 4 coordination meeting, the SCP review meeting, I understood 5 you to say that the study plans, the five for the 6 exploratory shaft facility, were not related and were not to 7 be reviewed in conjunction with the SCP itself. I thought 8 that what you just said --
9 DR. STABLEIN: Did not sound quite the same as 10 that.
11 DR. PARRY: No , it did not.
12 DR. STABLEIN: No. The five study plans were not 13 automatically part of the ECP in the sense that I have 14 described to Dr. Moeller any more than the 107 overall. I 15 mean that all of the study plans relate to the SCP. These 16 five specifically relate to the shaft construction phase 17 ' testing.
18 Our intent and perhaps most efficient would be to 19 review the five study plans in concert with the rest of the 20 SCP materials, and thereby perhaps be able to give comments 21 on the study plans as a separate section or as a part of the i
22 SCA, and kind of keep things packaged most efficiently that 23 way. We are still working out the details of that though, 24 as we work out this schedule for the overall SCP review.
25 Again we expect to have the definitive answers to these Heritage Reporting Corporation (202) 628-4888 O
78 1 questions within a week or so.
2 DR. PARRY: But given the schedule and you waiting 3 for the QA statement on the five study plans, the best that 4 you are going to be able to have for the SCA is probably the 5 drop dead or start work pre-ninety day review completed, is 6 that correct?
7 DR. STABLEIN: That is not necessarily the case.
8 We have the study plans. You know, the staff has seen the 9 study plans. They are familiar with the investigation level 10 from their looking at the SCPs, so they will not be starting 11 these study plans cold when they do review them. And I 12 think that it is impossible to predict at this time what we 13 will have by the SCA. But it is not as if we are going to 14 suddenly start on an unfamiliar document when we do start 15 the review of the study plans.
16 MR. LINEHAM: One other thing is the six month and 17 the three month periods that we have agreed for review of 18 the study plans. Those were the maximum periods of time 19 that we expected it to take. That does not mean that we 20 will take that long for each one of the study plans.
21 On the other hand, when we did agree to that, that l
22 the study plans were going to come in staggered, and it 23 remains to be seen on additional study plans if they all get 24 dumped at one point in timo, that we may not be able to meet 25 that six months if they come in gradually. You know, it may Heritage Reporting Corporation (202) 628-4888 O
79 1 be six months or less much less than on a number of them.
eg 2 DR. STEINDLER: Was that a meeting with DOE in
.g 3' 1986 on the level of detail?
4 MR. LINEHAM: Yes.
5 DR. STEINDLER: And apparently, there was some 6 kind of agreement.
7 Is that a' written document, is that a protocol?
8 MR. LINEHAM: Yes, it is.
9 DR. STEINDLER: Would we.be able to get a look at 10 that?
11 MR. LINEHAM: Surely, yes.
12 DR. STEINDLER: That would be fine.
13 DR. PARRY: Was that a MOU?
14 MR. LINEHAM: No , it was meeting minutes. And I 15 think, and Robert correct me if I am wrong, but was it not
(-
(/ 16 incorporated to the SCP review plan?
17 MR.-JOHNSON: This is Robert Johnson. Some parts 18 of that agreement were incorporated into the review plan.
19 But there is a whole package that contains a summary of the 20 meeting and the agreements that were made in that meeting, 21 and that could be given to you.
22 DR. STEINDLER: I would appreciate it.
23 DR. MOODY: You know, one of the things in this 24 discussion that is on one or two levels a bit discouraging 25 is simply the fact that the site study plans at least in the Heritage Reporting Corporation (202) 628-4888 O
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1 'first round were supposed to be originating from the.SCP.
2 In other words,-there is supposed to be a cross-correlation 3 Letween what is in the SCP and what is in the site study 4 plans.
5 '_ Are you indicating that the Department of Energy 6 is not doing that cross-correlation?
7 DR. STABLEIN: I did not mean to indicate that in 8 my remarks. I would rather that they talk about that 9 tomorrow. I think that they have a time allotted for 10 discussion of the study plans. But I did not mean to l
11 indicate at this point, especially the ones that we just 12 received are not correlated with what is in the SCP. We 13 have not made that determination yet.
14 DR. MOODY: Well, what I am trying to say is that
- 15. I think that determination is important.
16 DR. STABLEIN: I agree with you.
17 DR. MOELLER: Let us move ahead.
18 DR. STABLEIN: All right. Page three, four, and i
19 five talk about definitions which we have already talked 20 about, projections, comments and questions. And page six is 21 old hat, too. The first objection came up at least twice in 22 earlier discussion. This was our fundamental technical 23 objection, that the CDSCP does not recognize a range of i
24 alternative conceptual models that can be supported by the 25 existing limited data base. .
t Heritage Reporting Corporation (202) 628-4888 O
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81 1 'I think that we-have already talked about the 2 importance of that and the significance of it. What I would j 3 like to call-your attention'to is'on page seven. What has-
- 4. happened since'our CDSCP point papers were generated as far 5 as progress toward. addressing objection one.
6 There was an alternative conceptual.models 7 . workshop on April lith.through 14th.of last year at.which, 8 DOE, NRC, the State of Nevada, and other participants got 9 together to discuss the differences in the current 10 conceptual models of the Yucca Mountain site. This, included 11 Jerry-Semanski of. DOE with his model, which was markedly.
12 different from the preferred model presented in the CDSCP.
13 At that workshop, the NRC put forth certain 14 recommendations for the systematic treatment of alternative 15 conceptual models in the SCP, and DOE agreed to consider 16 those as they developed the final SCP.- And as I have 17- indicated, of course, resolution to be determined upon 18 review of the SCP. So there was a workshop devoted 19 specifically to this important topic.
20 If there are no questions, I will move on to 21 objections. Oh, go ahead, u 22 DR. MOODY: Remind me, when you say conceptual L 23 models, which conceptual model are you talking about, the 1
24 total one?
25 DR. STABLEIN: The overall conceptual model of the Heritage Reporting Corporation (202) 628-4888 LO
82 1
1 site.-
rg .2 DR. MOODY: I got you.
U 3 DR. STABLEIN: Okay. Objections two, three'and 4 four'all center upon the exploratory shaft facility. That 5 is what ESF stands for wherever it appears in the handout.
6 .The first objection concerned how far down the exploratory I
7 shaft ES-1 would be drilled into the' subsurface. And there 8 is a typo or an overzealous metric system person. In the 9 first line where it says " Extending the exploratory shaft 10 ES-1 400 meters" should say, "400 feet below the repository 11 horizon into the Calico Hills unit and drifting laterally in 12 that unit may have adverse impacts on the waste isolation 13 capability of the site."
14 The ES-1 is the test shaft. That is where testing 15 is going to take place. In the CDSCP, it was projected to 16 extend down to approximately 1415 to 1500 feet. That would 17 be 400 feet below the repository horizon, and would 18 penetrate the Calico Hills unit'which is an important 19 barrier to the movement of radionuclides from the waste 20 emplacement' area down to the groundwater table. j 21 And the staff was concerned about creating or DOE 22 possibly creating new pathways for quicker release and 23 escape of radionuclides if the Calico Hills was penetrated, 24 and then to compound the problem if drifting took place in 25 that unit.
Heritage Reporting Corporation (202) 628-4888 O
83 1 Now this objection was addressed at a July 1988 2 exploratory shaft meeting, and it was closed at an October 3 1988 shaft meeting as DOE proposed a different site 4 characterization strategy wherein they would not, or they 5 indicated that they had no present plans to take ES-1 down s
6 into the Calico Hills. And of course, the staff will 7 confirm the resolution by review of the SCP and the 8 supporting documents.
9 Objection-three also on the exploratory shaft.
10 DR. MOODY: Hang on a second.
11 What was the reason given in deciding not to, 12 because of entering into the groundwater table?
i 13 DR. STABLEIN: DOE agreed to go back and examine i 14 the relative benefits and risks of penetrating the 15 Calico Hills unit. If they can find other ways of ,
)
(~x 1
16 characterizing the unit without taking the shaft down and I 17 drifting laterally, they will pursue those. If they do not 18 and they conclude that they at a later time need to 19 penetrate the Calico Hills, before they do that they will 20 supply a risk benefit analysis for NRC review and comment.
21 Okay. I am going to move ahead then with ;
22 objection three, which involves test interferences. And the 23 objection as stated was that the CDSCP contains inadequate 24 information on the ESF conceptual design to allow evaluation 25 of potential interference of proposed investigations with Heritage Reporting Corporation (202) 628-4888
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I 84 1 each other or interference of construction' operations in the
('N 2 two shafts-and the long drifts with these investigations.
V 3 And again this goes to the point of whether DOE 4 would physically preclude themselves from obtaining 5 information necessary for licensing when they conduct site 6 characterization. There really was not enough information 7 to assure the staff that that would not be the case. And 8 there were indications that inferences could possibly occur.
I 9 This objection also was discussed at the July 10 shaft meetingi And at the October shaft meeting, there was 11 general agreement between NRC and DOE on an approach for 12 resolution of this objection. And the staff will be 13 reviewing the SCP to see whether the approach was carried i 14 out successfully.
15 In case people are interested in pursuing these 16 objections and their resolution further, I might mention 17 that the minutes of the July and October shaft meetings are 18 available, and the handouts and notes themselves document 19 any of this progress towards resolution that I am referring ,
1 20 to. For example, the approach that DOE proposed and the 21 agreement on that.
22 Objection four was our third shaft related 23 objection. The CDSCP does not adequately consider the 24 potentially adverse impacts on waste isolation capability of i
25 the site, and the ability to characterize the site resulting
- 4 Heritage Reporting Corporation (202) 628-4888 O
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- 1. from the proposed locations of ES-1, ES-2, and other 2 openings in areas that may be susceptible to surface water
- (-
,-w) 3 infiltration and to erosion.
4 The concern was that at the location chosen that 5 surface water during times of flood could run down the 6 shafts and preclude testing. Or in the post-closure phase, 7 that the waste emplacement site could actually get flooded 8 by water going through these openings.
9 DR. ORTH: A slightly idle question. That 10 hypothetical flood that we just talked about, is that a 100 11 year, 1000 year, .or 10,000 year flood.
12 DR. STABLEIN: The probable maximum flood is what 13 DOE's calculations are based on demonstrating or attempting 14 to demonstrate that such an event would'not in fact take 15 place.
I'7
(_/ 16 DR. MOODY: Would it be a 10,000 year flood?
17 DR. STABLEIN: I do not know the time frame on the 18 probable maximum flood time.
19 DR. ORTH: We can ask them tomorrow.
20 DR. STABLEIN: Okay. As far as resolution of this 21 objection, once again there was discussed at the July shaft 22 meeting and again at the October shaft meeting a general 23 agreement on the approach for resolution was reached, and 24 that resolution to be determined upon review of the SCP and 25 some of the critical supporting references to the SCP.
Heritage Reporting Corporation ;
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86 1 Objection five moves to a new topic, and that is 2 quality assurance. The CDSCP references a number of QA
)
3 plans and procedures for DOE and its prime contractors, many 4 of which are undergoing potentially significant revisions or 5 which have NRC staff review comments outstanding, or which 6 have not undergone NRC staff review. Based on NRC staff 7 reviews to date, they do 'St fully comply with NRC's QA 8 criteria.
9 Data collected ender these existing programs may 10 not be usable in licensing. Hence, our concern that makes 11 this an objection, that the data gathered must be 12 successfully challenged during the licensing process and not 13 be accepted.
14 A number of activities have taken place since the 15 CDSCP to address this objection. This is one of our most O 16 interactive areas with DOE in an attempt to have their QA 17 program qualified and accepted by the NRC.
18 A meeting in Ouly of 1988 resulted in a NRC/ DOE 19 agreement on a plan for resolution of the objection. This 20 plan involved a schedule for DOE submittal of their QA plans 21 for DOE and the prime contractors, and series of QA audits 22 at which NRC would observe.
23 The one item of progress that occurred after that 24 meeting was NRC staff review and acceptance of the Yucca 25 Mountain project QA plan in October of 1988. That was the Heritage Reporting Corporation l (202) 628-4888 O
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1 first one that we accepted. ]
2 Did you have a question, Dr. Steindler?
3 DR. STEINDLER: No. Go ahead.
4 DR. STABLEIN: Okay. Also the NRC staff observed 5 eleven DOE audits of project participants. That is eleven 6 out of twenty or twenty-one that were agreed upon at the 7 July 1988 meeting.
8 In yet another development, it became apparent as 9 the DOE and NRC interacted on the shaft that the design 10 control process related to the shaft design, especially the 11 shaft design that the NRC would be' asked to review in the 12 SCP, may not have been done under an accepted design control 13 process, which is essentially another facet of QA.
14 After discussion of this concern at the July and 15 October shaft meetings, an agreement was reached at the 16 November 1988 shaft design meeting for DOE to complete an l 17 ESF Title 1 design acceptability analysis as part of the 18 supporting material for the SCP. When I say ESF Title 1 19 design, that is a DOE terminology, but it refers to the 20 design that is contained in the SCP. !
21 And I am told by the engineers that it is a step 22 past the conceptual design. Whatever it.is that the DOE 23 develops this design acceptability analysis for is the SCP 24 design. And it is necessary for them to provide this for us 25 to be able to go ahead and review the design presented in Heritage Reporting Corporation (202) 628-4888
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88 L
[ 1 the SCP. Hence, the design acceptability analysis. And l
L (~T 2 hence, the delay in our acceptance review, because we had I
V-3 not received this design acceptability analysis.
4 DR. MOELLER: Help me specifically in how that is 5 part of the QA review, the DAA?
6 DR. STABLEIN: Well, you are going to have a 7 complete presentation on the design acceptability analysis.
8 If you would like that question answered now, 9 Joe Hononich is here and can give you a brief answer on it, 10 if you would like to hear it.
11 DR. MOELLER: I think that it would help me, yes, 12 just a brief comment. I mean we are talking about objection 13 number five, and we say that this is one of the most active 14 objections, and we are all familiar with how the design. <
15 acceptability analysis was delayed and so forth. But I 16 suddenly realize that I do not see what that specifically 17 han to do with QA.
18 MR. HOLONICH: Once again, I am Joe Holonich with 19 the NRC. And Dr. Moeller, the design control process that 20 should have been applied to the design of the exploratory 21 shaft would fall under criterion three of Appendix B of 22 10 CFR 50, which would have required DOE to have in place a 23 design control process that laid out the regulations, and 24 the criteria, and design interfaces, and design checks and 25 so forth.
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Not having'that,[it was indicated that:the QA 1.
2 . program. was'not working.as well as it-should-have been,:so-
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3' that is where.it falls out'from criterion three as required-la 4 by QA of' Appendix B.
5' DR. MOELLER: So'it is the QA of the design?
6 MR. HOLONICH: Correct.
7 DR.:MOELLER: Thank you.
8 DR. MOODY: Do you think that that design equals 9 . Title 1 design?
10L DR. STABLEIN: I am not qualified to answer that.
11- But.perhaps' Rick Weller would take a crack at that. Rick, 11 2 ' .do.you want to comment on that?
13- MR.-WELLER: Rick Weller, Division of High Level 14 . Waste Management.
' 15. Are you asking if the ESF,-is it our opinion that;
-16 the ESF ldesig:3 is equivalent to a Title 1 design?
17- DR. MOODY: .That is correct. The. design :that you 18 'are'doing this acceptability study on. I mean is it 19- equivalent.to a' Title 1 design?
20 MR. WELLER: That is exactly what they call it.
21 ,It is~a DAA of the Title 1 design.
22 DR. MOODY: Okay, thank you.
23 MR. WELLER: It is a DOE term.
24 DR. MOELLER: Dr. Moody, could you go back for me 25 and point out what you were seeking earlier when you said is Heritage Reporting Corporation (202) 628-4888 0
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- 1' Ldesign acceptability analysis comparable or equivalent to 2 something else.
3 DR. MOODY: I was just looking at the network that 4 .we have out there. I was concerned as to whether or not the 5 design that was.actually done did meet the Title 1 design
- 6. criteria.
7 DR. MOELLER: Okay.
8- DR. MOODY: And he says that it does.
l l 9 DR. MOELLER: Says that it does. Okay.
10 DR. MOODY: And what I am talking about here, of 11 course, is the extensive activity that I had involved with 12 the SALP program and these designs are key important points.
13- DR. MOELLER: Thank you.
14 -DR.- MOODY: Thank you..
15 MR. LINEHAM: If I could just add, from the NRC's 16 standpoint, Title 1 and Title 2 is DOE terminology. We are 17 not-so much concerned whether the DOE design meets their 18 Title 1 requirements. We are more concerned'with the types 19 'of information that is in there to support the design.
20 DR. MOODY: Those is not DOE terminology. That is 21 . engineering terminology for the status of a particular 22 design, where they are conceptually, Title 1, and Title 2, 23 and final, okay?
24 MR. LINEHAM: Okay. But it still holds true that 25 we are more concerned about the types of information that Heritage Reporting Corporation (202) ~ 628-4888
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I 1 are there, whether or not it is Title 1 or Title 2 is not 2 our main concern. What we would be concerned with if it is
)
3 a preliminary design is what changes would occur to that 1 4 design before they actually go and sink the shaft. And that 5 is som6 thing that we are going to have to be watching, to-6 see if the design that they presented in the ESP does change 7 prior to sinking the shaft.
8 DR. MOELLER: But I also hear Dr. Moody saying 9 that if someone says to her that it meets Title 1 10 requirements or standards, then that carries with it a very 11 significant meaning.
12 DR. MOODY: Engineering-wise, it does.
13 DR. MOELLER: Yes. Thank you.
14 DR. STEINDLER: I am now thoroughly confused. I 15 thought that the objection five dealt with the quality 16 assurance issues. And we have weaved into our discussion-17 Title 1 and Title 2 without any specific reference as to 18 whether or not those processes involved an acceptable to the 19 NRC quality assurance activity.
20 Do I infer correctly that the NRC staff comment 21 concerning whatever the design designations are was that the 22 quality assurance basis for that activity is insufficient or 23 inadequate? !
24 MR. LINEHAM: DOE did not document whether they ~
25 had an adequate QA program that controlled the design.
4 Heritage Reporting Corporation (202) 628-4888
92 1 DR. STEINDLER: And it is this lack of 2 documentation that you objected to in objection five?
(g r-
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l 3 MR. LINERAM: Yes, and it may be more than a lack i
4 of documentation. All we knew was that there was a lack of 1 5 documentation. It was questionable whether they had 6 actually considered some of the elements of Part 60 that 7 should have been considered in the design.
8 DR. MOODY: If they are going to begin working 9 now, DOE on the Title 2 design, have they got their QA 10 requirements in place before they start that design?
1 11 MR. LINEHAM: They do not have all of their QA.
i 12 requirements in place. What they are going is making sure 13 at least from their standpoint that they_are satisfied that 14 they have the necessary QA procedures that would pertain to 15 design of the shaft. That is an open issue that we have 16 identified to them. And we are going to be observing audits 17 or I think rather QA surveillance that they are going to be 18 conducting out at the site and out at the contractor 19 locations where they determine themselves whether they have 20 got adequate quality assurance procedures in place to go 21 ahead with the Title 2 design, but that is an open issue 22 right now. The ideal situation would be to have QA fully in 23 place.
24 DR. MOODY: That is right.
25 DR. MOELLER: Go ahead, King.
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+w 93 1 Dr. Steindler, did that handle you?
DR. STEINDLER: Yes, q- 2 k.) DR. MOELLER: Okay.
3 4 DR. STABLEIN: I introduced that design-5 acceptability analysis on this slide, even though I thought 6 that there might be some momentary confusion as to how it .
.j 7 fit with the objection deliberately because we do view the 8 DAA and that whole area of QA control of the shaft as an j 9 important area, and part of the objection is that DOE does I 10 not have an accepted QA program in place, l 11 12 i-13 14 15 16 17 18 19 20 1 21 22 j i
23 ,
24 25 Heritage Reporting Corporation (202) 628-4888 O
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^ 1 DR. STEINDLER: Let me make a comment on-the sore 2 point with me. -You don't know that there's a problem. All O 3- you know is that the system is so big.that you couldn't see-4 into it to find out what it is that they were actually doing 5 because they'didn't have a plan in place._ It could have 6 been, you know, perfectly sound design. Is that correct?
i 7 MR. LINEHAM: No. What I didn't mention-is we had -
8 observed.over the past few years a number of problems. On 9 the shaft, we've had a number of open issues. And we
- j I
10 treated them as open issues. We-looked at them one by one. '
11 What we came to realize, though, after a point-in time was 12 that we' felt they had all of these issues because.they did 13 notthave a design control process.
14 So there are indeed indications that the process, 15 there was a problem with the process. Since it~, you know,
'[ ) 16 'wasn't documented the way we would want it to be, it's very 17 difficult to r -you know, determine,_you know, how good, how' I 18 bad it was. And hopefully, this design acceptability =
19 analysis will give us a better indication of that.
20 DR. MOELLER: That's helpful. Thank you. .!
- 21 DR. STABLEIN: Finishing up on this slide, the 22 second last bullet is that the DOE schedule slipped for 23 submittal of the various plans that they had agreed to 24 submit on a schedule back in the July, 1988 meeting. So at ;
25 the January 1989 QA meeting, agreement was reached on a Heritage Reporting Corporation (202) 628-4888
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-1 revised schedule for resolution of this objection based on' 2 new submittal dates and new QA audits.
3 So that-means that resolution is to be determined:
4 upon review of DOE and DOE contractor-QA plans, observation 5 of DOE QA audits and review of the DAA and SCP.
6 Those are our five objections. There was no way 7 in the limited time available today, and I wasn't sure there 8 was the-interest in going through all of our comments, but' 9 we provided one further category of'important comment here 10 to briefly. mention, and that's major regulatory comments.
11 This'is where'there seem to be regulatory 12- inconsistency with Part 60 in the'CDSCP. And we had three 13 such comments. Comment 3, substantially complete 14 containment. Comment 64 dealt with seal testing.. And 15 Comment 103 performance confirmation. And I've produced O. 16 those in pages 17, 18 and 19.
17 COMMENT 3: The CDSCP's interpretation of the term 18 "substantially complete containment" and the design 19 objectives for performance of the waste package and for 20 radionuclides release from the engineered barrier system are 21 inconsistent with 10 C.F.R. 60.113 and hence inappropriate 22 to-guide the waste package testing and design program.
23 Here the design objectives did not seem to be 24 consistent with the Commission's meaning of the term 25 "substantially complete containment." And would have led to Heritage Reporting Corporation (202) 628-4888 O
1 96 1
1 an unsatisfactory conclusion to their waste package testing.
J 2 and design program.
(~Jj 3 DR. MOELLER: Well, now that one I would, this is j 4 all in hindsight, but I would have thought it was pretty 5 clear cut. But they did not -- they misinterpreted it or 6 they simp.7 overlooked something? Of course, you shouldn't l
7 speak for L2E. We can ask them tomorrow.
8 DR. STABLEIN: We have Rick Weller can comment on 9 this one for you.
10 DR. MOELLER: Thank you.
11 MR. WELLER: I think we can honestly say that DOE 12 gave themselves a very liberal interpretation of the 13 Commission's regulations.
14 DR. MOELLER: Well, the 300 to 1,000 years I 15 thought was pretty well known.
't' 16 MR. WELLER: Certainly that part of the numerical 17 standard is well understood. It's interpreting what 18 "substantially complete" means. And that's where DOE gave i 19 themselves a much more liberal interpretation. Eighty 20 percent of the waste packages, for example, would remain 21 intact during that period. Twenty percent can fail.
22 The bottom line is that their interpretation would 23 have permitted greater releases in the containment period 24 than in the post-containment period or at least equal to, 25 which seemed incongruous to us and completely inconsistent Heritage Reporting Corporation (202) 628-4888 O
97 1 with the Commission's intent in the containment requirement, 2 'DR. MOELLER: Thank you.
,O.
3' DR. STEINDLER: And it is again in hindsight a bit 4 of a puzzle why that's only a comment. It strikes me as one 5 of the more fundamental aspects of confinement of activity 6 in a repository.
7 Can you give me a rationale as to why that was a 8 relatively mild whack across the wrist rather than --
9 DR. STABLEIN:' 'Actually, we went over this in the !
10 April meeting with the same discussion and I probably won't 11 be any more convincing. But based upon the definition of 12L " objection" which is a matter of such immediate seriousness 13 that DOE needs to fix it now before they start any work.
. I 14 They aren't about to start their waste package testing i 15 program, and hence.it didn't seem in terms of timing that
) '16 they had to fix it right then.
17 This could become an objection. All three of 18 these regulatory comments could readily become objections.
19 We'll have to see what is in the SCP and then make an 20 assessment on this issue.
21 DR. STEINDLER: I've got a sheet of paper in front 22 of me that identifies the DOE response and they have traded 23 the substantially complete containment fuzziness for a 24 statement called " allowing for recognized technological 25 limitations and uncertainties."
Heritage Reporting Corporation (202) 628-4888
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L 98 1 Does that help you folks at all?
2 MR. WELLER: I think it did because the first part 3 of what you didn't read was more important than that which i
4 means, which was their revised design objehtive.
5 DR. STEINDLER: Yes. Well, it says we'll fully 6 contain -- let me read the whole thing, and I do want to be 7 at least reasonably fair. Let's see, the beginning of the 8 sentence says, that I have is, "the revision reflects the 9 understanding that 'substantially complete containment' 10 means that a set of waste packages will fully contain the 11 radionuclides inventory for 300 to 1,000 years following 12 permanent closure, allowing for recognized technological 13 limitations and uncertainties."
14 Now, that does something for you?
15 MR. WELLER: That's certainly a lot better. I can U 16 be honest with you. We're largely in agreement with that 17 design objective.
18 DR. STEINDLER: I see.
19 MR. WELLER: And some of the, you know, the 20 recognized technological uncertainties are that when you're 21 handling for example, when human beings are handling 40,- or 22 50,000 packages, there may be a few that get jostled, 23 bumped, lose their integrity during transport, etcetera.
24 Those are the, you know, the human frailties that one has to 25 consider in that statement or that phrase "a31owable Heritage Reporting Corporation (202) 628-4888
99 l
1 ' recognizable uncertainties."
- 2. DR. STEINDLER: Well, I'm just getting primed up 3 for the SCA review that we're supposed to do.
4 MR. WELLER: But certainly the design objective I 5 'think is the most important aspect of'that phrase. And in 6 .our workshop that we had with the DOE, they originally had 7 three design objectives. And we told them it was our 8 opinion that they would only need one, there could only be 9 one and that is to satisfy the containment requirement. You 10 would have to have as a design objective a requirement which 11 fully contains all the radionuclides to the best of your 12 ability.
13 DR. MOODY: You bring into here the long term 14 problem and that is that even if you're going to say.300 to 15 1,000 years, is the waste package that you're going to place
() 16 into the repository going to have that life time, a minimum 17 life time of 300 years. And that's certainly something that 18 'has to be dealt with better than it has been up to this 19 point with respect to Yucca Mountain.
20 MR. WELLER: Well, that was part of the 21 flexibility in the numerical standard. That is, the time 22 period was intended by the Commission to account for site 23 specific differences between repositories.
24 DR. MOELLER: And you're also saying that once at 25 least you get agreement on what "substantially complete l
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100 1 containment" means, then you can examine their canister and
(')
v 2 decide whether it, you know, their data and decide whether
- 3. their canister's going to meet the -- 1 4 MR. WELLER: Yes. And what you're referring to is 5 really their performance assessment --
6 DR. MOELLER: Right.
7 MR. WELLER: -- of the canister and the Yucca 8 Mountain environment.
9 DR. MOELLER: Go ahead.
10 DR. STABLEIN: Okay. Let's move on to Comment 64.
11 According to a statement in the CDSCP, in situ testing to 12 evaluate seal components and placement methods would not 13 start until after the submission of the license application.
14 That position will result in a lack of sufficient data for 15 evaluating the license application.
Q k> 16 It was the Staff's feeling that it was very 17 important that some in situ seal testing information be 18 available by the time of submittal of the license 19 application, and DOE didn't appear to recognize that, 20 although there was very limited information of any kind on 21 this in the CDSCP, 22 DR. MOELLER: Any questions?
23 (No response.) '
24 DR. MOELLER: Go ahead.
25 DR. STABLEIN: Okay. And the final one again is Beritage Reporting Corporation (202) 628-4888 i
E
J 101
)
1 pz'.marily a lack of information of a critical nature in the 2 CD5dP. There is insufficient information in the CDSCP about
(~)/
t.
3 tuo strategy or plan for the performance confirmation 4 program. 10 CFR 60.140 requires that the performance 5 confirmation program be started during site 6 characterization.
7 There didn't seem to be sufficient recognition of 8 the need to start that during site characterization, and 9 there didn't seem to be a strategy laid out for getting it 10 started. So the Staff felt that that needed to be a 11 comment.
12 Those are the concerns that we chose to highlight 13 for you today from the CDSCP. There were of course other 14 concerns and the ACRS highlighted some of those when they 15 reviewed our CDSCP package.
16 DR. MOELLER: Any other questions or comments on 17 this & nic?
18 (No response. )
19 DR. MOELLER: Well, I think you helped us a lot in 20 terms of being ready for the appearance of the DOE people 21 tomorrow.
22 DR. STABLEIN: Good. Thank you very much.
23 DR. MOELLER: The next item vill be to discuss the 24 design acceptability analysis.
1 25 MR. LINERAM: This presentation will be given Joe Heritage Reporting Corporation (202) 628-4888 i ()
l 1
t - ----_--- -
102 1 Hononich who's a senior project manager in the project 2 directorate.
3 MR. HONONICH: Okay. Thank you, John.
4 I'd like to start by going to page 2 of the 5 presentation and just giving you a little summary of what I 6 intend to discuss today. I'd like to give a little 7 background information on what was the genesis and the need 8 for the DAA. What the purpose and scope of the DAA was.
9 What our effort will do and what it'll cover as we review 10 the DAA. What we've done to date and some of the results 11 that we have. And then finally, what the future actions are 12 and what upcoming activities the Staff has planned.
13 If you go to page 3, we essentially identified a 14 problem with the shaft design at the July, 1988 meeting on 15 the ESF. This is where we first identified that DOE didn't 16 plan to apply any quality assurance until it had actually 17 begun construction of the shaft. And we raised that as a 18 concern. And we started to investigate a little further and 19 found out that that in fact was the case.
20 In October of 1988 when we had an open items 21 meeting on the shaft, we further amplified our position and 22 went through and identified several examples of where we saw 23 a design control process lacking on the shaft. After that 24 meeting, we and DOE got together and we agreed that there 25 needed to be some work done to demonstrate that the Title I Heritage Reporting Corporation (202) 628-4888 O
103 1 design of the shaft was in fact acceptable even though it 2 had not been done under a design control process per g_
L) 3 Appendix B.
4 And we subsequently had three meetings where we 5 established the DAA. On November 3rd, we met with DOE and 6 laid out a nins-step process which identified what the DAA 7 would encompass. i 8 On November 23rd, DOE came in using what we had 9 identified at the previous meeting and outlined its approach 10 for implementing the DAA.
11 And then finally on December 8th, DOE came in and 12 gave us some preliminary results of what they had seen as i
13 they were doing the DAA.
14 DR. MOELLER: Well, now it would appear that they 15 have responded very rapidly to your concerns. I mean, these
() 16 dates are close together and apparently there was 17 significant progress each time?
18 MR. HONONICH: They had responded rapidly. We did 19 have some questions at the December 8th meeting where we 20 thought that they weren't doing all that we believed was 21 necessary in the DAA. They had centered in on three major 22 objectives that we had identified as part of the DAA 23 process, namely, important to waste isolation, important 24 ability to characterize the site, and representativeness of 25 the site. And there was a fourth category of preclosure Heritage Reporting Corporation (202) 628-4888
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l 104 1- radiation protection issues that they in fact didn't look 2 like they were considering in the DAA, and we raised those 3 at the December 8th meeting.
4 So they were responding rapidly but we still found 5 that there were some problems with what they were doing.
6 DR. MOODY: Can I ask you one question?
7 MR. HONONICH: Sure.
8 DR. MOODY: Are you stating to us that even though 9 the Title I design was not done with QA standards defined, c
10 that they could back track and prove to you that those 11 standards had been met?
12 MR. HONONICH: Well, if you go to the next slide, 13 it's an excellent lead-in to my next slide, which goes to 14 the purpose and scope of the design acceptability analysis.
15 You can't go back and incorporate the quality into O
\- 16 the design. So what we had developed here was an 17 opportunity for DOE to dreonstrate to us that the technical 18 quality of the ESF Title I design was the same as the 19 technical quality of one that would have been developed 20 under a design control process. So we laid out some steps I
21 where they could go back and demonstrate that the design 22 would meet the same criteria if it had been developed under I
23 a QA process.
24 In addition, it was to support, as King said 25 earlier, the information provided in the site Heritage Reporting Corporation (202) 628-4888 O
105 1 characterization plan and have ua gain assurance that that fs 2 information was in fact correct. And it is limited to ESF 3 Title I design only. When Title II design starts, we would 4 expect DOE to have incorporated the necessary elements of 5 the QA program to control that design and make sure that 6 that design follows the stringent requirements of quality 7 assurance.
8 Does that answer your' question, Dr. Moody?
9 DR. MOODY: It certainly is interesting. I can 10 hardly wait to see the DAA.
11 MR. HONONICH: The scope of our review, if you go 12 to page 5, is basically we're going to observe surveillance 13 that DOE is conducting or has conducted. We've observed two 14 to date. We don't plan to observe any in the near future 15 but in a little bit after they start Title II, we intend to
() 16 continue to observe the surveillance that they do.
17 Surveillance are quality assurance investigations that 18 aren't as in-depth or as expanded scope as a quality 19 assurance audit. It's more of a small two-day effort 20 instead of a two-week effort.
21 We also will do a headquarters review here in 22 Washington of the DAA. The DAA is four three-inch binders 23 of information along with a little more additional 24 information. We have laid out a DAA review plan which 25 supplements our SCP review plan. The basic general elements Heritage Reporting Corporation (202) 628-4888 O
106 1 for the DAA review were laid out in the SCP review plan. We 2 have in turn amplified those and tailored specific O 3 requirements to the DAA. We just issued our review plan on 4 Friday for the DAA review.
5 And then finally, we' re going to do an on-site 6 visit in the middle of April. And in that on-site visit, we 7 will look at two things: first will be a sample of the DAA 8 activities that DOE conducted so that we can gain assurance 9 that they actually implemented the DAA correctly, and then 10 the second will be our review of DOE's evaluation of its 11 readiness to start Title II design.
12 DR. MOELLER: Did you say how thick DAA is?
13 MR. HONONICH: Well, the DAA is four three inch 14 binders and two more documents so it's probably about a 15 foot, 12 inches thick.
llh 16 DR. MOELLER: It's quite a document.
17 MR. HONONICH: It's quite a document, yes.
18 DR. CARTER: When you indicate you're going to do 19 a headquarters review, what does that mean? You talk about 20 technical reviews and a number of others. What's a 21 headquarters review?
22 MR. HONONICH: Well, the headquarters review would 23 be done here in Washington. And we would take the 24 information that they've submitted, namely those four 25 volumes, and review those four volumes using our plan, our Heritage Reporting Corporation (202) 628-4888 O
107 lL review plan.
-%.s ["} 2 DR. CARTER: I guess most of your reviews are done.
3 here?
4 MR. HONONICH: Yes, absolutely. It's just our 5 standard means of practice. And then we would do an on-site 6 visit which is once again our standard practice to go out 7 and verify implementation.
8 Our results to date is that we've observed two 9 surveillance which DOE has conducted. Overall, the DOE 10 teams found that the DAA was conducted in a disciplined 11 manner in accordance with the plan that DOE had developed to 12 do_it. They did identify some individual issues and issued 13 three significant deficiency reports or SDRs. SDRs are 14 areas where they.have not been meeting something that 15 they're required to meet. It could be one of our
- 16 requirements or it could be a requirement imposed by DOE.
17 And so they've issued three SDRs. In addition, as 18 King said earlier, we're continuing our acceptance review 19 and intend to have it, right now are scheduled to have it 20 done by the end of the month.
21 DR. MOELLER: How far below good quality can it be 22 and you not accept it? Can you accept it with conditions 23 and accept it without conditions? Or is there a range of 24 acceptances?
25 MR. HONONICH: Well, in our review plan, we have Heritage Reporting Corporation (202) 628-4888 7
4
108
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i 1 laid'out eight criteria that we would like to see met for us 2 to be able to accept it. And I would think se'd want a bN 3 fairly high quality document, John, yes.
4 DR. MOELLER: But you'll have that done by the end 5 of February?
6 MR. HONONICH: End of February, correct.
7 DR. STEINDLER: Are you going to be able to arrive 8 at a conclusion on the question of whether or not the more 9 disciplined QA based approach would have produced a better 10 design?
11 MR. HONONICH: Well, --
12 DR. STEINDLER: I think that would be a highly 13 interesting answer which I think somewhere along the line we 14 ought to try and get at.
15 MR. HONONICH: Well, Dr. Steindler, I really am O 16 looking to see if the design they have is acceptable, not if 17 they could have produced a better design.
18 DR. STEINDLER: All right. Well, let me rephrase 19 my question in terms of acceptability.
20 MR. HONONICH: Okay.
21 DR. STEINDLER: I mean, I think the issue in all 22 of the QA machinations we've gone through is quality
)
23 assurance doesn't seem to always assure quality. And it 24 would be I think useful, it seems to me it would be useful 25 to you folks for at least some measure of comfort if nothing Heritage Reporting Corporation (202) 628-4888 q
NJ
d 1
l 109 1 else, to find out whether or not it is possible to produce a 2 perfectly acceptable something or.another, be it a design or O.-
I-3 what'ever have you without in fact-having all the paper work 4 ~in place for example. It seems to me it would be an 5 interesting issue.
6 I mean, you.know, you can't answer the question 7 one way or the other, but I think it would be a worthwhile 8 exercise. That's a comment more than anything else.
9- MR. HONONICH: Okay.
10 11 12 J
13' 14 15 O 1e.
17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 O
110 1 DR. MOODY: Is the same company going to do Title 2 design and Title 1 design?
-O; '2 3- MR. HOLONICH: That is my understanding, yes. I
~
4 think there were two companies involved in the Title 1.
5 Phoenix and Sisson.and Holmes and Narver. Which are both l 6 contractors to the Yucca Mountain Project Office out of 7 Nevada.
8 Okay. Page 7 we discuss our future actions which i
9 we are going to do. The first one is obviously to complete 10 our acceptance review which is the short term activity.
11 We' re gong to start our technical review of the DAA, conduct 12 our on-site review. We'll continue to observe 13 surveillance.- And then in addition we'll observe the 14 Department of Energy Quality Assurance audits. And'these 15 are the audits which they are going to use to qualify their'
) 16 QA plans.
17 And if you turn to the next page, this was the 18- agreed-upon schedule with the January 25th meeting and it 19 lays out those activities that DOE plans to undertake to 20 qualify the programs.
21 If you notice, to the far left there are cues in 22 February for each of the program participants and that's
- 23. when DOE intends to submit its quality assurance program 24 plans.
25 In addition, as you move to the right, staggered Heritage Reporting Corporation (202) 628-4888 O
111 1 every other week or so is a block with a star in it and that L
~N 2 is when DOE intends to do its audit. It is looking at doing (O
3 two audits a month between April and August, and then at the 4 end of that there is a star which would be the NRC's 5 acceptance of the complete program. We would have done the 6 program plan review as well as document the program 7 implementation through observing DOE's audits of the QA 8 program.
9 DR. STEINDLER: Let's see. I guess I'm a little 10 confused by the schedule. Does that mean, do I interpret 11 this correctly if I say that the OCRWM as DOE's headquarters 12 QA plan is the last to be implemented and described and 13 written?
14 MR. HOLONICH: That's correct, Dr. Steindler.
15 DR. STEINDLER: Top is last.
16 MR. HOLONICH: We have raised t his concern. We 17 raised this concern at the meeting.
18 DR. STEINDLER: You bought off on this schedule, 19 right?
20 MR. HOLONICH: Yes, sir.
21 DR. STEINDLER: So you didn't raise it so 22 emphatically as to get anybody to change it.
23 MR. HOLONICH: Well, really our concern was not so 24 much yfth OCRWM, which is the last one, but the one prior to 25 that, the project office, because the project office is the Heritage Reporting Corporation (202) 628-4888 l
()
112 1 'i ntegrating entity out in Nevada that would integrate all of
.. 2 'the previous six plans.
- 3. We did raise this as a concern to DOE. They said 4 that'they just could not get the plan.in place, that the 5 procedures wouldn't be ready to get'the plan'in place.
6 DR. STEINDLER: I thought Yucca Mountain had 7 already gotten its plan.
-8 MR .' HOLONICH: What has been approved is the ,
9 quality-assurance requirements document for the project 10 .cffice and the participants. And so then each of them have 11 to develop a plan which meets that requirements document..
12 What they will be doing, however, is in addition 13 to the qualification audit, DOE and the contractors 14 involved in the program dill do approximately 100 15 surveillance of the QA programs as they are being l() 16 implemented and as work is being done.
17 And so that would be a method for us as we observe 18 these surveillance to see if we are identifying problems.
19 We also raised the point to DOE that by waiting to 20 do the project office last we could identify a problem in 21 our review that would cascade down into the other six 22 participants.
23 DR. STEINDLER: I think when you talk about 100 24 surveillance in the same breath you talk about work being 25- done that's an oxymoron. With that kind of exercise, I'm Heritage Reporting Corporation (202) 628-4888 O
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113 1 not sure much work is going to get done.
I
(~T 2 MR. HOLONICH: Well, the surveillance would be ci 3 done by the QA organization whereas the engineers and the l l
4 designers would continue to do the work. l l
5 DR. STEINDLER: Okay. Did you set the schedule 6 for those 100 audits? l 7 MR. HOLONICH: No, sir. That's DOE's schedule.
8 DR. STEINDLER: So that's DOE's schedule?
9 MR. HOLONICH: Yes. ;
10 DR. STEINDLER: So it's they we should at least 11 ash about that. r 12 MR. HOLONICH: Correct.
13 DR. MOELLER: Even if all goes smoothly, this is 14 still quite a schedule.
15 MR. HOLONICH: Yes. We did note to DOE that we
\# 16 believed this w as a very optimistic schedule.
17 DR. MOELLER: To me, and I presume this is clearly 18 part of DOE's audit, and your overseeing of their audit, and 19 that is to assure yourselves that there isn't just a 20 separate organization here that runs QA, that it actually is 21 blended into the work of the everyday people who are on the 22 firing line, so to speak.
23 MR. HOLONICH: Yes. Our position is that quality 24 does start with the individual technicians and the principal 25 investigators doing the work. QA can only check that you Heritage Reporting Corporation (202) 628-4888 r\
114 1 follow your procedures, but they can't make you do the work r~g 2 correctly. And it's the individuals doing the work that V
3 really are the front line in quality assurance.
4 DR. MOELLER: And would quality review guides, I 5 presume they exist, and do they start at the bottom and come 6 up or what do they recommend?
7 MR. HOLONICH: Quality review guides?
8 DR. MOELLER: I don't mean NRC guides, I mean just ,
I 9 general, does some American Association of Quality Assurance 10 or something, do they have proposed guides on how to review 11 QA programs?
12 MR. HOLONICH: That's a little out of my realm of i 13 expertise. We'd really need somebody from the QA section 14 here for that.
15 DR. MOELLER: Gene, did you have a comment?
16 MR. VOILAND: I might comment about that. I was 17 involved at one time with the development of a quality 18 assurance plan and I might just say that the requirements of 19 10 CFR 50 Appendix B can address 19 general issues within 20 the quality assurance. And it is fundamentally a how to 21 document. It's not a what document. And it says that if 22 you have a quality assurance plan that meets the 23 requirements, it will include these 19 elements and those ;
24 elements range all the way from having the right kind of an 25 organization to the right kind of control over materials, to 1
Heritage Reporting Corporation (202) 628 4888
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1 115 i
1 having a design review kind of a system and all.the-rest.
2 It just says I will have all of those.
> L
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3 Now, quality assurance is nothing but good 4 management. If you had good management, perfect management, 5 I don't think you need any quality assurance. There are l 6 machine shops and so on which produce excellent items that 7 you can. rely on, that absolutely have no quality assurance 8 plan. i 9 DR. MOELLER: No formal one.
10 MR. VOILAND: No formal one. But they look at 11 what is needed to determine the quality of that piece of 12 equipment that they are producing and they put those 13 elements into it.
14 For example, you could have a quality assurance 15 plan for analytical, chemical analysis, which says I will do
() 16 a lot of things. I will calibrate my balances, I will buy-17 the right kind of chemicals, I will do all of those good 18 things, I will train my people and all the rest.
19 DR. MOELLER: And run duplicates and all that.
20 MR. VOILAND: Do all of that. Or you can say, 21 before I analyze an unknown sample, I will analyze the 22 standard, and if I get the right answer on the standard I 23 can make the assumption that all of the other elements of 24 that system are working okay.
25 .So there is the formality of having the plan. And Heritage Reporting Corporation (202) 628-4888 l
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116 1 I might say that a quality assurance plan doesn't guarantee 2 you good quality. All it says is you will do it the way you 3 said you will. It requires you to say I will do it in such 4 and such a fashion and you do it that way and you may get a 5 clinker. But it's right on the plan.
6 So there is quality and there is quality assurance 7 planning and all the rest. But I think the really good 8 thing about quality assurance plans is that it makes you 9 consider those elements in there and you cannot claim .
10 ignorance, you have to say I either did or I didn't or if I 11 did this is how I did it, and so on. If that's any help.
12 DR. MOELLER: Thank you. Does that finish you, 13 Joe, on your presentation?
14 MR. HOLONICH: Yes, it does. Thank you.
15 DR. MOELLER: Any other questions on that?
() 16 (No response) 17 DR. MOELLER: Thank you. And we will move then 18 back to Bob Johnson.
19 MR. JOHNSON: I would like to finish this 20 afternoon's presentations by briefly summarizing three 21 documents. And I will use the handout that I started with 22 earlier this afternoon. That's the one titled "SCP Review 23 ... and Other ... Plans." And I will be speaking starting 24 with Page 16 in that package.
25 I will be summarizing the draft review plan for s
Heritage Reporting Corporation (202) 628-4888 O
117 1 study plans, the QA review plan and finally the performance 2 assessment review strategy.
O 3 Starting with the draft plan for study plans, I 4 would like to first mention some important background. We 5 have already touched upon it a bit but as most people know 6 the SCP is a higher-level plan and the study plans are 7 detailed plans that implement the SCP.
8 We already mentioned that there are about 107 9 study plans that DOE will prepare and submit to NRC for 10 review. We also mentioned that five of these are related 11 to the exploratory shaft and they are now available to us, 12 and about 12 more will be available over the next six months 13 and then we are soon to receive a schedule from DOE that 14 would lay out when we would receive the other study plans.
15 Going back a little bit more, over the past few lh 16 years we have had discussions and agreements between NRC and 17 DOE on the contents of the study plans, that is, the level 18 of detail in the SCP a nd the level of detail in study 19 plans. And we can send you a package of the meeting summary 20 and the agreements for your information and review.
21 But we have agreements regarding the content of 22 the study plan as well as agreements on review of the study 23 plans. And basically the original agreements stated that 24 DOE would provide us the exploratory shaft and ongoing study 25 plans with the SCP, and then thereafter they would provide Heritage Reporting Corporation (202) 628-4888 9
i 118 1 study plans six months before the work would start.
2 NRC agreed that we would provide our major
)
3 concerns within three months of submittal and we would 4 provide other comments or concerns within six months. As 5 John mentioned earlier, these are maximum times. Or intent 6 is to get, particularly get these major concerns or 7 objections, as we would call them, out to DOE as soon as 8 possible. But that's the first set that would be coming out 9 within a three-month time period.
10 To help us review the study plans, a draft study i 11 plan review plan was issued in December of 1987. And it is 12 important to note right upfront, this is a generic review ;
13 plan that will guide the staff in our review of all the i
14 study plans that are provided. .
15 DR. MOODY: Robert? ;
16 MR. JOHNSON: Yes.
17 DR. MOODY: What is DOE's response in terms of the 18 time constraint, seeing they have identified these 107, they 19 have done five, why is it taking them so long to get the 20 detailed plans out? Do they have an explanation for that?
21 MR. JOHNSON: I think you should ask DOE that. I 22 don't have the explanation for it. We just are interested 23 in the schedule, their schedule so that we can plan our work 24 and respond to them as quickly as possible.
25 On the next page I would like to go over the Heritage Reporting Corporation (202) 628-4888 O
1 1 119 l
1 approach to our review. And it is important to note here
~
2 that it's a three-stage review process that we have laid'out i 3 in the review plan.
4 Now, the first stage is, and these terms are 5 similar to what you have heard from the SCP review, the 6 first stage is the acceptance review. And we will review 7 all the study plans issued by DOE, and do our acceptance 8 review on all of them.
9 The criteria that we would use here'again is 10 consistency with the NRC-DOE study plan content agreement, 11 and to make sure that we have all the references that are 12 listed in that study plan.
13 And again, this is just like for the SCP. We are 14 not reviewing the technical merit, the material in the study 15 plan. Again, it is an internal check to make sure that l
l Q
ks 16 there is sufficient information in that study plan to l
17 warrant the allocation of resources, staff resources to 18 continue a review.
19 DR. STEINDLER: I had a problem with the 20 references. I'm trying to find my notes here.
21 The implication at least of the --
I have the 22 draft in front of me -- the implication is that you expect 23 the study plan to be a fairly substantive literature review 24 of what the world has done prior to the problem at hand.
25 Is that correct?
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120 1 MR. JOHNSON: I'm not sure where you are getting l 2 that impression.
3 DR. STEINDLER: Well, why would you have any 4 rnferences at all, in a study plan for example?
5 MR. JOHNSON: One of the things, for example, that 6 the study plan would do, would be to lay out the different 7 testing methods or the analytical methods that would be 8 used, and consider or discuss some of the principal 9 alternatives that the DOE considered in coming up with those 10 preferred testing methods.
11 So likely they can reference the literature on 12 acceptable testing methods if they want. And so it is that 13 sort of thing that they could put in the list of references 14 to support their selection of certain testing methods.
15 DR. STEINDLER: I guess I have to go back a notch.
16 You are telling me that if DOE wants to do an experiment in 17 the laboratory to get a particular answer, they have to 18 justify the methodology that they are using?
19 MR. JOHNSON: We ask them to discuss and give the 20 rationale for the methodology that they are proposing to 21 use.
22 DR. STEINDLER: And that means that they have to 23 look at all the alternatives or some of the alternatives or 24 most of the alternatives?
25 MR. JOHNSON: The most important alternatives. We Heritage Reporting Corporation (202) 628-4888 O
k 121 I J
1 haveLnot said all the alternat'ives, exhaustive. Maybe' l
( 2 that's where you got your impression. But we are careful-3 not to.say.all. Bot the principal ones that they consider 4 to be likely candidates to the preferred one. That's'all 1 5 in a section in the study plan that relates to the rationale 6 for their particular study. This is decidedly more detail 7 than you will find in the SCP, where a study might be q 8 summarized or the tests that they will use will be listed 9 as opposed to described'and rationales given. l
- 10. The second stage of our review considering, if we 11 accept a study plan, the second stage then would be a start
,12 work review. And again, all the study plans that we have i
13 accepted would be reviewed for start work.
14 The criteria that we would use here would be to 15 identify any potential adverse effects on isolation of a
.O 16 study, any potential adverse effects on the ability to 17 characterize the site.
18 These are familiar criteria., I think, and these 19 would lead to objections to DOE starting that particular 20 study. And these are the objections that we would get to 21 them within three months of issuance.
22 Also, part of the start work review would be to, 23 for the staff to determine whether additional review would 24 be needed. That additional review would be a Stage 3
-25 detailed technical review. That's what Stage 3 is called.
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I 122 1 As we have said before, we would only be doing a
(~3 2 detailed technical review on a sample of the study plans, O
3 and for our FY89 budget, we are budgeted for a 20 percent 4 sample. The criteria that we use or that help us decide if 5 additional detailed technical review is needed are the ones 6 that I have listed here. If the study plan is related to an 7 SCP concern, then we may want to follow up and do a more 8 thorough review of the study plan.
9 Similarly, if it is related to the key technical 10 topics that we talked about earlier, then we might want to 1
11 follow up on the study plan in that case. Other areas would 12 be unique, nonstandard or controversial test or analysis 13 methods. These are areas of high uncertainty that might j 14 also be considered. l 15 DR. OKRENT: Wouldn't there be a lot of those?
! ?
16 MR. JOHNSON: I said high uncertainty. There 17 would be a lot of those, you are right, that are uncertain.
18 But it's a judgment case in here as to the ones that might l
19 be highest, in the staff's opinion, therefore worthy of more i 20 emphasis and therefore more detailed review. It will be a 21 tough call to cut down to 20 percent based on these. And 22 the consequences are significance to performance. Correct.
23 DR. MOELLER: I would nave thought that a large 24 percentage of them would be related to SCP concerns.
25 MR. JOHNSON: The initial screening that we did, Heritage Reporting Corporation (202) 628-4888 O
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i 123 1 l
1 granted it was' preliminary and it was based on CDSCP
(~ 2 concerns, indicated about 50 percent of the study plans were 3 related in some way either to the CDSCP concerns or these 4- other criteria that I have listed here. So that would be l 5 about 50 or so study plans. l l
6 DR. MOELLER: Right. But if you are only gong to ]
7 do 20 percent in terms of detailed technical review, then "l 8 these are just simply, this list is just simply the l
9 considerations that you apply.
10 MR. JOHNSON: That's right. These are the !
11- considerations that the staff would go over in making a 12 decision.
13 DR. MOELLER: Okay.
14 l 15 k 16 17 18 19 20 21 22 23 1 24 25 i
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124 L
1 MR. JOHNSON: Now, it's not our intent to lay out 2 every study plan we are going to review. I have another 3 category here, it's others. unspecified. And since our 4- review is an audit approach we will be free to just pick and 5 choose ar.y study plan even though they fall outside of this 6 category. Because we do want to check here since it's a 7 sample approach. We are really checking to see how DOE's.
8 plans are implemented-at a detailed level.
9 So we will pick some based on these criterion and 10 we'will pick others that are just, maybe just off the top of 11 our head, just pick one and see how it looks.
12 DR. STEINDLER: What's the product of your three 13- levels of review? You've got some kind of a form letter 14 'that you're going to fire off to these guys if everything is 15 all right and I couldn't figure out what that is.
16 MR. JOHNSON: That's right. I believe the review 17 _ plan indicates the different types of products. But for the 18 start work review we-would indicate to DOE that either we 19 had objections or we had no objections.
20 And it's the.same idea as the SCA, we would list 21 specific objections that we might have and pass those along 22 to DOE in a letter form.
23 DR. STEINDLER: I want to go back to the same 24 issue I raised before. If you have no objections you claim 25 that that does not'mean you approve.
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l 125 1 MR. JOHNSON: It doesn't mean -- I think-you were I 2 using the term, the program isn't acceptable totally or
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\_ i 3 completely acceptable. It's just that we have no objection I 4 to them starting work based on the criteria that we have 3 i
5 identified here. ]
6 DR. STEINDLER: You presumably also have no 7 problem or you have no objections to the protocol that's 8 contained in this plan.
9 MR. JOHNSON: Could you explain that, your j 10 question.
11 DR. STEINDLER: Well, somebody has a methodology 12 for evaluating the ED of groundwater and that's a 13 controversial subject and you've gone through whatever is 14 necessary to review it. And your geology folks have looked 15 at it. And you have gone back and forth and the thing
' 16 finally ends up in a document to which you have no 17 objections.
18 MR. JOHNSON: I think it's careful to understand 19 that the criteria for determining an objection or the 20 criteria for the start work review is rather limited to the 21 items that are listed there. Any testing that would 22 adversely affect the s2te itself or other testing.
23 So the example that you have just chosen could 24 fall into just a category of a technical comment based on 25 how DOE is doing their work in a particular area. And that l Heritage Reporting Corporation (202) 628-4888 l
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126 1 may not be reviewed under the start work review. However --
^ 2 DR. STEINDLER: I think you're trying to get away 3 from my question.-
4 MR. JOHNSON: I'm not trying -- I'm trying to get 5 your question.
6 DR. STEINDLER: Let me simply say, supposing you 7 had a detailed technical review of this particular procedure 8 and you go through this whole thing and you fire off a 9 document to somebody and I assume DOE, saying we have no 10 objections.
11 Now, I guess what I'm trying to find out, what 12 does that really mean? Does that mean that you approve the 13 protocol that they have got in there?
14 MR. JOHNSON: If we did a detailed technical 15 review.
( 16 DR. STEINDLER: Yes.
17 MR. JOHNSON: We would provide DOE comments and 18 concerns of whatever they had in their program.
19 DR. STEINDLER: Assume they have all be taken care 20 of. It's a beautiful document like you havo never seen 21 before.
22 MR. JOHNSON: All we're providing DOE is a set of 23 our concerns for that document. We don't conclude that we 24 find that acceptable or approve it. We provide them with 25 our concerns for that study plan.
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127 1 DR. STEINDLER: But supposing there are no f- - 2 concerns?
( '
3 MR. JOHNSON: Well, then we would state that we 4 have reviewed the' document and we have no concerns.
5 DR. STEINDLER: You have no concerns.
6 MR. JOHNSON: Right.
7 DR. PARRY: Robert --
8 DR. STEINDLER: I'm not a whole lot smarter than I 9 was about three minutes ago.
10 DR. PARRY: But you might also tell them that the 11 analytical method that they're going to use isn't worth a 12 damn.
13 DR. STEINDLER: Well, sure, that's fine. But 14 that's not what I'm driving at. What I'm driving at 15 obviously is, I'm trying to find out what the product of the
( 16 NRC review is in relation to what~is going to come down the 17 line eventually. Because if they approve the protocol now, 18 that's my same question as I had before, how can they later 19 on come by and say, hey, that's not right.
20 MR. JOHNSON: Maybe it sounds like splitting 21 hairs, but whether it's for the start work review or the 22 detailed technical review, if we from our review did not 23 identify concerns we would send a letter back saying, we 24 have no objections or we have no concerns.
25 I guess to me that's different than approving, 1
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128 1 caying we approve of your whole program. Because based on a
2 review we Lave either identified problems or we don't.
3 DR. STEINDLER: I'll back off because I don't want 4 to get embroil in a legal question, but that was an issue 5 that was raised for us by Jack and among other people.
6 DR. PARRY: Robert, excuse me, you can mean, what 7 I interpreted you to say which would be that, if there was a 8 technical approach that was presented that didn't affect the 9 site and wasn't going to affect other measurements, but 10 wasn't valid or wasn't going to reduce your uncertainties or 11 was going to be so uncertain as to be absurd, you can't mean 12 that you were not going to say anything about that.
13 MR. JOHNSON: That would be a basis for continuing 14 and doing a detailed technical review. Unless we had a 15 common enough that we could pass it along to DOE right at
( 16 that time. Does that make sense?
17 DR. PARRY: Well, not really, because --
18 MR. JOHNSON: And the need for additional review, 19 if the reviewer found something like you described, okay, 20 that may be a basis for doing additional detailed technical 21 review.
22 DR. PARRY: But that may come out very quickly. I 23 mean, you may get that in the first time you take a look at 24 it.
25 MR. JOHNSON: That's true.
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129 1 DR.-PARRY:' .In the EH measurement you may come up.
.'2. with;some. absurdity that you should know immediately.
3 '- MR.' JOHNSON:- That's true.
4- DR. MOELLER: Let's see, Gene and then Dr. Moody.
1 5- MR.' VOILAND: M,dne is very quick. I would think 6~ that tho' quality assurance program would call out who are-7 authorized to review; who are authorized to approve; and all o the rest of that. It's usually very. formally spelled out.
9 So I think I. concur with the position that NRC has 10 .unless it's called out and I don't see how it would, that 11 their's would be a review and comments and somebody else 12 would perhaps act-on that.
- 13 DR. MOELLER:- Dr. Moody.
l 14 DR. MOODY: I'll pass.
15- MR. YOUNGBLOOD: My name is Joe Youngblood, I'm 16 Deputy-Director of'the Division of High Level Waste 17' Eanagement.
18 We're quibbling over words here'and you're trying R19 to pin us down. DOE says we're in the consultative process.
L 20 We' re not ar, applicant. We' re not a licensee. We don't
-21 want you approving our things, but we would like for you to 22 find them acceptable.
23 So, gentlemen, if you want to argue over 24 acceptable or approve it doesn't make much difference. But 25 that's their preference is that we find things acceptable as Beritage Reporting Corporation (202) 628-4888 O-
i 130 1 opposed to approving.
2 DR. STEINDLER: So this proces- that you're going 3 through has really nothing to do with the licensing 4 exercise; is that what you're telling me? At which l 5 point --
6 MR. YOUNGBLOOD: It certainly has to do with the 7 pre-licensing exercise, if you like.
8 DR. STEINDLP.R: Well, that's a continuum --
9 MR. YOUNGBLOOD: Whenever they come in with data 10 and information at the licensing stage they have to be able 11 to show that it's qualified data and information. And if 12 someone is running a laboratory test and mess it up, that's 13 not like messing up the site and you can't go be.ck and do 14 it. You've spent an extra analysis in the laboratory or 15 something like that, Dr. Steindler, which is not nearly 16 severe as going out on site activities and doing something 17 wrong.
18 DR. STEINDLER: So your focus th3n is on the 19 things that look like they're irreversible to you if 20 somebody screws up the site.
11 MR. YOUNGBLOOD: Yes.
22 DR. STEINDLER: That's fine. And I accept that.
23 MR. YOUNGBLOOD: So far as urgency is concerned.
24 DR. STEINDLER: Absolutely.
25 MR. YOUPGBLOOD: But if DOE wants to do something Heritage Reporting Corporation (202) 628-4888 O
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131 1 a certain way and their contractor wants to do something a 2 certain way, they're free to do it if they want to. If i 3 that's the way they want to do it. We're in a consultative 4 stage _with them.
5 DR. STEINDLER: Do those 107 plus plans include 6 .non-site related activities?
7 MR. JOHNSON: I believe there are some waste 8 package environment testing.
9 DR. MOODY: DOE is also doing analog studies were 10 are non-site. The interesting thing about this whole issue 11 that we've just discussed is, I agree with Martin in the 12 sense that, you know, saying going ahead that is indirectly 13 indicating that the procedure or the analytical study or 14 whatever is in that particular site study plan is approved.
15 Or are you going to say indirectly that knowing what we know
} 16- now in terms of techniques and technologies, et cetera, it's 17 okay.
18 But, you know, it's a very difficult problem just 19 simply because of the proposed test and the amount of time 20 and effort it takes to gathering the data. And of course 21 .the interpretation of the data is the key thing in terms of 22 performance assessment.
23 So it's, you knew, if you say go -- if NRC says 24 move forward to DOE that is indirectly, I think whether you 25 like it or not, an indication that what they have justified
)
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L 132 1 doing should be done.
2 DR. MOELLER: Well, there is, of course, a
}
3 similarity, I would think, in the nuclear power plant 4 licensing arena. Again, we have heard that we're pre-5 licensing here. But in that arena, if I'm not comparing 6 apples and oranges, the staff through the regulatory guides 7 not only says to an applicant what's acceptable,,they give 8 them an example, you know, if you do it this way we'll 9 consider it acceptable.
10 Here at least the staff is not writing the 11 procedure; they're taking the applicant - pre-applicant's 12 procedure and saying we have no objection.
13 You are correct, then, if they gather data -- I 14 guess down the road honest mistakes can be made. But what.
15 is the specific problem? In other words, this procedure has 16 been in essence given the stamp of approval of the NRC 17 -staff. It's used by DOE --
18 DR. STEINDLER: That's precisely the problem. And 19 the comment is, they have not been given the approval of the 20 staff because you're in a consulting mode. I hope everybody 21 understands that.
22 DR. MOELLER: They have been given no objection.
23 DR. STEINDLER: Well, that's exactly the issue.
24 No objection does not mean approval in this particular 25 arena.
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133 1 DR. MOELLER: Now what is it, DOE then.uses this
.f si, 2 procedure and now what is the problem they get into, I mean
\/>
3 hypothetical?
4 DR. STEINDLER: The only hypothetical problem that 5 I was raising is that at'some time down the line, for one 6 reason or another, if the next generation of NRG folks comes 7 back to DOE.and says, hey, that might have been a great 8 procedure when you guys got it approved, but it isn't worth 9 a peck of sore apples now.
10 Then I think they can legitimately say, well, 11 folks, you should have thought of it back then because we 12 have just spent three irreversible years, et cetera, et 13 cetera, et cetera.
14 DR. MOELLER: Well, is it clearly spelled out --
15 MR. YOUNGBLOOD: I'm trying to understand what 16 you're trying to prove by that. If it's wrong it's wrong; 17 if it's right it's right.
18 DR. STEINDLER: I'm not trying to prove anything.
19 All I'm saying is that'the folks may --
20 MR. YOUNGBLOOD: Because we approved it doesn't 21 mean forever more it's right, whether somebody says it's 22 wrong or not. Does it have an impact on the licensing l
23 activities?
24 DR. STEINDLER: Does it have an impact on your !
25 review of the second time around?
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134 1 MR. YOUNGBLOOD: We would hope that we're unbiased 2 individuals that are looking at these things.
3 DR. STEINDLER: Well, having dealt with the Office 4 of General Counsel they don't hope. They need something 5 more substantial than that.
i 6 DR. MOELLER: Well, do you have anywhere in your l
7 agreements with DOE a statement that gives you loopholes?
8 Not that you need them, but is it clearly spelled out 9 somewhere?
10 MR. YOUNGBLOOD: Well, do they have loopholes with 11 us? You know, are they going to tell us that -- they know 12 they're going to change things. ,
13 Let's have our lawyer come here and tell us what
^
14 it means to be a regulator and how much we're wed to all of 15 these things and so forth once we state them.
16 MR. WOLF: I'm Jim Wolf, Office of General 17 Counsel. On the loophole question there's a very specific 18 answer to that and the answer is, yes, there is a loophole.
19 The loophole is a provision of the regulations in 20 60.18. It's actually 60.18 (L) which concludes a general 21 discussion of the site characterization program and 22 describes it as informal conference between the prospective 23 applicant and the staff.
24 It goes on to say: "Neither the issuance of a 25 site characterization analysis nor any comments of the Heritage Reporting Corporation (202) 628-4888 O
l 135 1~ director made under this section constitutes a commitment to 2 issue any authorization or license or in any way affect the
/C 3' authority of the Commission, the Atomic. Safetyfand Licensing L
I 4 Appeal Board, Atomic Safety and Licensing Boards, other 5 presiding officers, or the director in any such proceeding." ,
l 6 So that clearly provides that it's a loophole if 'l 7 you want to characterize it that way.
8 DR. MOELLER: Dr. Steindler, do you have --
9 DR. STEINDLER: No.
10 DR. MOELLER: Dr. Moody, anything?
11 DR. MOODY: Sounds like it's a loophole.
12 DR. MOELLER: Well, thank you, sir, that's very 13 helpful.
14 DR. MOODY: The thing that keeps coming back for 15 any of us that have done hands-on field laboratory work is 16 fthat something you may say, fine go ahead in February of 17 1989. May -- because of the evolution in scientific 18 instrumentation, et cetera, may in September of 1990 prove
-19 defective because we now have this new technique, this new 20 instrumentation, et cetera, et cetera.
21 So anything you then say it's okay or go ahsad, 22 you are using what information perhaps is available today.
23 But what's going to be available two or three years from 24 now.
25 But you're trying to say then, Richard, is that Heritage Reporting Corporation (202) 628-4888 O
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136 1 it's in the pipe that you can then re-evaluate or DOE can
,A _ ,
2 re-evaluate and every six months you get these changes.
i ' /
3 That's how that is covered, right.
4 MR. LINEHAM: Everything we do under the pre-5 consultation licensing program it's based on us making 6 decisions, based on what we know today, and what the 7 technology is today. That comes out in many of the things 8 we put out. And we recognize that these things are going to 9 be changing.
10 We mentioned earlier in the presentation these SCP 11 updates, one of the reasons is to look at the existing data 12 and see how that affects the program that was laid out 13 overall as you start collecting data.
14 Another thing it's supposed to be doing is if 15 technology changes. I think the whole program recognizes
/
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(~) 16 that things probably are going to change significantly.
17 DR. MOELLER: Robert, go ahead.
18 MR. JOHNSON: Okay. Moving on to page 18 the 19 technical review criteria. In the third stage the technical 20 review the staff would be looking at adequacy of the study 21 to provide the information for licensing. That's certainly 22 a general criterion.
23 But before each study plan review would begin the 24 team that's assigned to review that study plan would 25 identify more specific criteria for that study to help them Heritage Reporting Corporation (202) 628-4888 O
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l 137 1 in their review.
[g 2 Now any comments that would come out of this
{ %/ :
l 3 review again would be passed along to DOE in the form of a i
4 letter so that there would be ccmments or questions, the l l
5 same approach would be used for the types of concerns that 6 we have. And those would be passed along to DOE within the 7 six month time frame.
8 Now lastly our plan for FY '89 is to, after we 9 have reviewed a certain number of study plans this year it's 10 based again on the experience that we have had with the 11 reviaw is to revise the draft that we have right now. i 12 If there are nc Further questions on the study 13 plan, review plan I can move en and give you a very quick 14 summary of the QA review plan.
15 The QA review plan was first issued in June of 16 1984 and it was revised recently in December 1988. Juus the 17 purpose of it is really to provide guidance to the staff 18 reviewers to use in evaluating DOE's QA plans. Or I should 19 say the plans of the various QA DOE organizations. The 20 staff is using that right now in our reviews.
21 And basically, the plan contains specific 22 criteria. It contains guidance on how to use the reactor I i
23 program, QA regulations. And it incorporates by reference l 24 the existing QA technical positions that the staff has 25 prepared.
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i 1 Lastly on page 20 with respect to the performance g_ 2- assessment review strategy, again under a different name
.%/
3 this document was issued in'1984 as the modeling strategy 4 document. Some of you may remember that. And I guess it 5 was the subject of one presentation to ACRS.
6 The purpose of this document is to determine the 7 approach for the staff's review of DOE's performance 8 assessments. That is the extent of independent modeling.
9 It will also therefore give a rationale for the 10 development of the staff's capability to use either 11 available models or develop independent models.
.12 We had a discussion, I think, about a month ago 13 that the staff's primary emphasis in reviewing DOE's 14 performance assessment program is to review their documents 15 and their program, but in selected areas, you know, we will
. O, . 16 be doing our own independent modeling.
17 And in far fewer areas we may even consider 18 developing independent modeling. And one of the purposes of 19 this document here is to determine what areas we should be 20 developing our capability and provide a rationale for that.
21 Therefore this revision will more explicitly state 22 the staff's rationale for the review approach that it's 23 taking. And this was one of the suggestions that the ACRS 24 made when they reviewed the modeling strategy document.
25 The revision will also be consistent with any Heritage Reporting Corporation (202) 628-4888 O
139-1-' unique characteristics or processes at the Yucca Mountain
(-)
v 2 site.
3 And for your information the post-closure strategy 4 will be prepared in FY '89 and then the pre-closure strategy 5 will be prepared in FY ' 90.
6 Unless there are questions on this or other topics 7 that I have covered that concludes my presentation today.
8 DR. STEINDLER: On this performance assessment 9 review strategy document, do you intend to, in a sense, 10 discuss this with DOE before you issue your first version of 11 it or draft version or whatever the process is?
12 MR. JOHNSON: I don't believe we have decided that 13 yet. We, you know, it depends on what other things we might 14 be consulting with DOE on and the schedule and so forth.
15 DR. MOELLER: Other questions for Robert?
16 DR. MOODY: The only thing that I would comment on 17 only and you probably know this but I would like to remind 18 you, if you talk about preparing new models, given the time ]
19 period you have and the data that we're talking about that's 20 not even here to put in those models, that's a little bit 21 op Imistic just in terms of the sheer time it takes to 22 de.alop something from scratch.
23 MR. JOHNSON: Thank you, Dr. Moody, we're aware of
, 24 that and that's consistent with our thinking.
1 25 DR. MOELLER: These would primarily be dono ay Heritage Reporting Corporation (202) 628-4888 >
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140 1 contractors somewhere, I guess?
k 7q 2 MR. JOHNSON: No, a great emphasis is on the NRC b'
3 staff having that capability supported by contractors, but 4 having an in-house -- when I say in-house I mean staff 5 capability.
6 DR. MOELLER: Other questions or comments?
7 Yes, Dr. Okrent.
8 DR. OKRENT: We are about half way through FY '89 9 I guess, does that mean there's some partial formation of 10 this post-closure strategy?
11 MR. JOHNSON: Work has started. We have 12 contractor reports that are being worked on. Maybe, Sith 13 Coplan, would you like to add to that.
14 MR. COPLAN: Yes. Sith Coplan, NRC staff. I 15 think that one area -- really two areas that we have some
'\ 16 significant amount of activity going. As Robert mentioned 17 one of the things that motivated us to redo the document was 18 an ACNW or ACRS comment, actually,-last time around, that 19 the logic for the choices that we made about whether we'were 20 going to independently develop a model or use third party 21 . codes or what have you for different parts of different l
22 analyses weren't very clear.
23 One of the things that we're doing now is that 24 we're trying to formulate a set of criteria that we can use 25 so that we can be fairly sure that we can lay out an Heritage Reporting Corporation (202) 628-4888 O
l, 141-1 explicit statement of why we're making the choices that p- s _ 2 we're making and be able to articulate a rationale clearly.
V 3_ We are focusing on that at this point.
4 The other thing that we are putting a fair amount 5 of effort in, and this is primarily at this point through 6 one of our contractors Sandia National Laboratory, is to 7 give fairly good definition to what the various elements of 8 performance assessments ought to be.
I 9 In other words, what are the specific analyses l 10 that we ought to expect to see in performance assessments 11 that DOE is doing. The thought being, okay, then we'll take-12 these criteria that we're developing, apply them to these 13 .different elements, and on that basis decide which aspects-14 of which analyses we would be reviewing with what tools.
15 DR. OKRENT: Can I understand it a little bit 16 more. There are a very considerable number involved before 17 you get through the whole business of estimating whether you 18 meet or exceed the EPA. It's not a draft standard and it's 19 not a final standard, a core suspended standard.
20 And if you're going _to try yourself to evaluate ,
l 21 what other people said, and the uncertainty, the assumptions 22 that they make, the certain things to be used for the model ;
23 and so forth.
24 My experience is that to do this sort of thing you 25 almost need the kind of sophistication that you develop in Heritage Reporting Corporation (202) 628-4888 {
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142 1 writing, the original codes and trying to use them and learn C- 2' what they don't do so far.
C's l.
3 What I'm hearing suggests to me, perhaps 4 indirectly, that-body of knowledge is not going to decide 5 for the NRC staff. It makes me wonder then how you're going 6 to go ahead and perform the evaluation or whatever it is 7 that DOE does hand you.
.8 MR. COPLAN: I have to say at the outset that to a 9 large degree, my experience is the same as your's, you do 10 have to have an understanding of modeling of the phenomena 11 that's good enough to be able to develop the model yourself 12 in order to make those kinds of calls.
13 At the same time we're confronted with a situation 14 we're really very resource limited relative to what the 15 Department of Energy can and will really need to invest in 16 order to do the performance assessments. Just for a feel of 17 relative amounts.
18 My understanding is that this Fiscal Year DOE is 19 going to spend roughly $20 million on performance 20 assessments. We're more in the neighborhood of a couple of 21 million.
22 And we're dealing also with a situation where this 23 iu a one shot deal. We don't expect to be doing license i 24 reviews on a number of repositories.
25 So I think we've really got to examine very Heritage Reporting Corporation (202) 628-4888 l
O t
143 1 carefully how we can do reviews in the situation that you're I
/~A 2 describing and do it without having to expend the same level C1 3 of resources that the Department of Energy is doing.
4 The given is that~in the end we've got to do the
.5 review in a way that we're assuring that our regs are met, 6 that public health and safety is protected. We will do what 7 it takes to do that. But we're going to try to do it in a 8 way that's most conservative of resources.
. i 9 DR. MOELLER: Other questions or comments? !
10 (No response. )
11 DR. MOELLER: Well, not hearing any I think that 12 does wrap up the program for today. Let me thank the NRC 13 staff for spending the time with us and for responding to 14 the questions that we had.
15 I believe in terms of the committee that we
?~3 t
\d 16 csrtainly want,-obviously, to keep in mind what we have 17 heard today.
18 But particularly to keep it in mind tomorrow when 19 we are listening to DOE and try to follow up on some of the 20 key questions and concerns and items and so forth that we 21 have heard today.
22 With that I think we will declare today's session 23 recessed, I presume is the right word, and we will be 24 reassembling at 8:30 tomorrow morning.
25 Thank you.
Heritage Reporting Corporation (202) 628-4888 l
144 1- (Whereupon, at 5:00 p.m. the committee was 2 adjourned to reconvene tomorrow morning at 8:30 a.m.,
3 Wednesday, February 22, 1989 at the same place.)
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20.
21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 4
1 CERTIFICATE
('J J 2 3 This is to certify that the attached proceedings before the ,
4 United States Nuclear Regulatory Commission in the matter 5 of: ADVISORY COMMITTEE ON NUCLEAR FASTE 7th ACNW Meeting Day One 6 Name:
7 8 Docket Number:
9 Place: .Bethesda, Maryland j 10 Date: February 21, 1989 , ,
11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings.
r]'
18 /s/ OA M .,
19 (Signature typed) : JOAN ROSE 20 Official Reporter 21 Heritage Reporting Corporation 22 23 24 25 Heritage Reporting Corporation f (202) 628-4888
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