ML20245B162
| ML20245B162 | |
| Person / Time | |
|---|---|
| Issue date: | 06/13/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0012, NACNUCLE-T-12, NUDOCS 8906230056 | |
| Download: ML20245B162 (222) | |
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In the Matter of:
llth ACNW MEETING )
DAY ONE NbfYh OEI2[Ob COPY ---
Pages: 1 through 210 Place: Bethesda, Maryland Date: . June 13, 1989 a -- --- -- - ----- . - ---- ----- --- - -==
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-PUBLIC NOTICE BY THE 2 !
UNITED STATES' NUCLEAR REGULATORY COMMISSION'S -
'3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
5 6
7 The contents of'this stenographic transcript o>f the' =-
8 proceedings of the. United. States Nuclear Regulatory -l 1 9
Commission's Advisory Committee-on Reactor Safeguards (ACRS),.
10 as reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date, i
12 ~
No member of the ACRS St,aff and no. participant at 13 this meeting accepts any responsibility for errors or.
14 O inaccuracies of statement or data contained in this-transcript.
15 16 17 18 l 19 20 21 22 23 24 25 O Heritage g*Portin (202) 628-4888 l
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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lith ACNW Meeting )
Day One )
Tuesday, June 13, 1989 Room P-110 7920 Norfolk Avenue Bethesda, Maryland The meeting convened, pursuant to notice, at 8:30 a.m.
BEFORE: DADE W. MOELLER Chairman, ACNW Professor of Engineering in Environmental Health O Associate Dean for Continuing Education School of Public Health Harvard University Boston, Massachusetts ACNW MEMBERS PRESENT:
MARTIN J. STEINDLER CLIFFORD SMITH WILLIAM HINZE ACNW CONSULTANTS PRESENT:
JUDITH MOODY MEL CARTER DON ORTH PAUL POMEROY GENE VOILAND PAUL SHEWMON, ACRS DESIGNATED FEDERAL EMPLOYEE:
SIDNEY PARRY Heritage Reporting Corporation (202) 628-4888
2-( 1 PR.OCEEDINGS 2 MR. MOELLER: The meeting will now come to order.
3 This is the lith meeting of the Advisory ~ Committee on 4 Nuclear Waste. . I am Dade.Moeller, chairman of.the 5 committee. The other ACNW members present-today are '
6 Martin Steindler, Clifford Smith, and Bill Hinze. The ACNW 7 consultants in attendance a.re Mel Carter, Judith Moody, 8 Don Orth, Paul Pomeroy,.and Gene Voiland.-
9 Dr. Paul Shewmon from the ACRS will also be assisting us 10 today.
11 During today's meeting, the committee will address 12 and review the NRC staff's site characterization analysis 13 which is the report that tbay are preparing on the basis of 14 their review of the DOE site characterization plan.
(])
15 Before I move into the formal portions of the i 16 meeting, I had mentioned Bill Hinze as a member of the.
17 committee and we certainly want~to mark and observe that 18 point in our history. And I have here a. certificate, Bill, 19 which we want to present to you. And it says and it is high 20 level wording, " Reposing special trust and confidence in the !
21 integrity and the ability of William J. Hinze, the United c 22 States Nuclear Regulatory Commission does appoint this- '! 1 23 person as a member of the Advisory Committee on Nuclear 24 Waste and does authorize and empower this person to execute 25 the duties of that office according to the law and Heritage Reporting Corporation (202) 628-4888
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1 regulations of the Commission." And this is' signed by 2 Lando W. Zech, Jr. -
1 3 MR. HINZE: Thank you very much.
4 (Applause.) !
5 MR. MOELLER: Our objectives today are to continue )
I 6 our ongoing discussions of the NRC staff review and to begin I 1
7 to zero in on the comments that the committee.make chose to- fj 8 make on the subject of the SCA. 'As~ background to'this -
9 discussion, we have initial drafts of portions of the NRC I
10 staff's SCA. And their comments, I am sure that all of.you 11 have noticed, are beginning to come into focus and are being l
12 organized and presented in a systematic manner. )
i 13 We also have comments of a group of consultants.-to 14 the ACNW who have studied specific portions of'the SCP and' 15 the SCA and have met with relevant NRC staff members for in j 1
16 depth discussions on the various components'of their SCA. l 17 And for matters of the record, let me point out that. )
i 18 Bill Hinze has covered geology and geophysics.
19 Judith Moody has covered hydrology and geochemistry.
20 Gene voiland has covered quality assurance'and geotechnical ;
21 engineering. Paul Shewmon has-covered materials. And 22 Paul Pomeroy has covered performance assessment. We will' 23 cover each of these topics today with the various l 12 4 consultants summarizing for us their key thoughts and so )
25 forth.
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4 I) 1 In our discussions, I want to remind the committee i 2 that we have certain. guidelines to keep in mind. These have 3 been written down and let me share them with.you. Indeed if j 1
4 there are desires to change any of these, we should of i 5 course put our. thoughts on the table and' discuss it. But'we- l 6 have agreed that since time will not' permit us to review all
- 7. portions of the SCP in detail,;we will concentrate our 8 attention on the SCA prepared by the NRC staff. And.we.
9 will concentrate on their approach in defining their 10 concerns.
11 Number two, in line with the memorandum provided-4 12 to us by Martin Steindler, we have also agreed to attempt 1to j 13 address the following questions and to evaluate the SCA with 14 the following thoughts in mind. (a) Are the objectionsfthat
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15 the staff has raised, are they related to topics that are 16 obviously critical to site qualification or 17 disqualification. (b) If the objections are not resolved, j 1
18 is it reasonable that subsequent pursuit by DOE of site i 19 characterization activities will yield invalid or ,
1 20 unsubstantiable data or conclusions or will result in J 21 permanent damage to waste isolation capability. j 22 (c) Can the substance of the objections be 23 overcome, and if so by methods or procedures'other than what' !
24 is proposed in or can be inferred from the SCA. (d) Are the !
25 objections to the use of radioactive methods or materials- l
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1 for site characterization.likely to result in unnecessary 2 measures in expense and/or time without a corresponding )
3 benefit. And that particular item has been addressed by the 4 staff in their latest SCA. And (e) Are the technical bases 5 for the objections valid. And (f) Similar questions.should
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6 be addressed to the comments,-but in the context of what'may 7 be a less important topic.
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8 Now having said that and having reviewed what we 9 considered to be good guidelines for looking at the 10 objections,'I think that we also though have to be sure that 11 we understand the context in which the staff is developing 12 their objections. And their objections are defined. I 13 differently in the way in which I just. reviewed them.or said 14 that they should be evaluated.
15 For example, they have defined an objection as a 16 matter of such immediate seriousness to a particular portion 17 of the SCP that the NRC would recommend DOE not start work 18 in that area until the objection is satisfactorily resolved.
19 So indeed that is a little bit different than what I just 20 read. And they have comments or similar' definitions for ,
21 comments and questions, a comment being a concern with a 22 particular part of the program that would result in a I
23 significant adverse effect on licensing if'not resolved but l
4 24 which would not cause irreparable damage if.that part of 25 the site characterization were started prior to Heritage Reporting Corporation (202) 628-4888
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() 1 resolution.
2 And then their lowest level of concern which.are 3 the questions are defined as a major concern with'the-4 presentation of the program in the SCP such as missing 5 information or an inconsistency or ambiguity which precludes 6 understanding an important part of the program well enough 7 for the NRC staff to be able to evaluate that part. So as I 8 say, we need to keep in mind our thoughts a;s well.as theirs.
9 And I do not think-that the two are not reconcilable, but 10 nonetheless it is important that we keep this straight.
11 You have been provided a multitude of papers and-12 so forth. And before I go on, let me call upon' 13 Jack Parry to summarize what it is that you have.
(} 14 MR. PARRY: To ease the load on you coming to the 15 meeting, we have provided a set of the point papers. These 16 are assembled as they will be published. And also a set of 17 the point papers divided up by technical discipline.. They 18 are there for your reference tore, tet they can be sent to 19 you after the meeting if you ce desire.
20 In addition you have in the briefing books the 21 present draft of the introduction to the SCA, the director's 22 comments and recommendations, and reports by Dr. Shewmon and 23 Dr. Pomeroy. We have also handed out to you a series of -;
I 24 viewgraphs by Dr. Moody, and Mr. Voiland's draft comments on 25 the DAA and quality assurance. l l
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() 1 Also in your briefing book are the State of Nevada 2 preliminary comments which the staff very kindly provided.
3 And they refer to some of the more recent spectacular 4 headlines in newspapers, publications that we have seen.
5 MR. MOELLER: Thank you.
6 MR. HINZE: If I could ask a question regarding '
7 that.
8 MR. MOELLER: Sure.
9 MR. HINZE: Jack, are there any differences 30 between what we have in front of us here and what we 11 received at our home bases dated 6/2?
12 MR. PARRY: As a matter of fact no, Bill. You 13 received both of them and they are the same thing. But I 14 have them set up here for you so you did not have to carry
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15 tnem back and forth.
16 MR. HINZE: Thank you.
17 MR. MOELLER: Thank you, Jack.
18 This meeting is being conducted in accordance with 19 the provisions of the Federal Advisory Committee Act and the 20 Government in the Sunshine Act. Dr. Sidney J.S. Parry is 21 the designated federal official for the initial portion of 22 the meeting. The rules for participation in today's meeting 23 has been announced as part of the notice that was published 24 in the Federal Register.
25 We have received no written statements or requests
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I) l' to-make oral statements from members of the public regarding:
2 today's session. A transcript of portions of-theLmeeting. d
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'I 3 will be kept, and it is requested that each speaker.use.one. -
.q 4 of the microphones, identify herself or himself, and speak '
5 with sufficient clarity.and volume so that heLor she can be.
6 readily heard. ;l l 7 Before I go on, let me'ask'if any'of.the members E
8 have comments, or any comments from any of the' consultants' 9 before'we move on?
i 10 (No response. ) . !
11 MR. MOELLER: All-right. We have an agenda before'.
12 us and our plan is to take up each of the subjects that'I I 13 have named with the consultant taking the lead on helping ~to j
() 14 guide us into discussion. 'And.then we have'a multitude of 15 members of the NRC staff here with' whom we can interact and ' l 16 gain further information. So the'first. item is SCA-module 17 number one on geophysics, seismology, volcanism,Tt ectonics, 18 and natural resources. And Bill-Hinze will-take the' lead l )
19- for us on that. Bill.
I 20 MR. .HINZE: Thank you,very much, Dade.
3 21 MR. MOELLER: Excuse'me. Jack. '!
22 MR. PARRY:
.Yes, I would like to introduce the i 23 staff representatives, the senior people who.will be here',
24 John Linehan a.A King'Stablein, who will lead the i
25 discussion.
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( 1 MR. HINZE': First of all, I would like to thank l 2 the staff for their cooperation as I have tried to weave my 3 way through all of the mass of this material. They have 4 added more material as I have asked for it. Sometimes that 5 has been helpfu] and sometimes it is just added to the mass 6 of material. But I do want to thank Ron Ballard, and 7 Phil Justice, Charlotte, Buck and the rest of the group.
l 8 They have been extremely helpful and candid as we have 1
9 approached these problems.
l 10 I think that my overall statement is that the l
l 11 staff has done an excellent job. I would rate that as an 12 excellent job. And I think that reflects their concern and 13 abilities, but I think that it also reflects the interaction
() 14 that we have had in the preceding meetings where we have 15 isolated areas in which the committee and some of its 16 consultants may have had concerns. Perhaps this has helped 17 to focus some of the activities of the staff. So it has 18 been an excellent interaction.
19 There are a few things that I have noted that I 20 would like to ask further questions on and raise for the 21 staff. And I think that the proper place is to start with 22 the first point paper of the staff in the geology and 23 geophysics area, because it is number one but also it is an 24 objection that is raised and really the only objection that 25 is raised by the staff.
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() 1 And this concerns the exploratory shaft facility 2 and its purpose in terms of the characterization of the site 3 and how that is going to be achieved. There has been a 4 concern on my part in the fact that this decision was made 5 in 1982 really on the basis of criteria that in some ways 6 are no longer valid. For example, one of the major concerns 7 was that this should be accomplished, that the site 8 characterization should be accomplished by virtue of 9 horizontal drill holes that had a maximum length of 10 2000 feet. And therefore the exploratory shaft, really the 11 first pass was based upon that criterion. This is no longer 12 valid, because as I understand it the horizonal drill holes 13 although they may be used are really superceded by the 14 drifts.
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15 As I read the materials regarding the shaft 16 location, it is not apparent to me that there is consistency 17 and whether we are using the shaft, whether the shaft would 18 be used for testing the vertical variability of the site as 19 well as its horizontal variable. If the vertical 20 variability is important to study, and for example the only 21 work plan that we have reviewed, Dr. Moeller, has related to 22 chlorine-36 which is being done in the shaft and studying 23 the variation of that, then the location of that shaft is 24 important, very important.
25 If one uses the shaft only to get to the
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( ). 1 repository level and to study the horizontal variations,.
2 then the shaft location is not important. You can put in 3 the place where it can be constructed'the easiest. I think 4 that there is not aLclear. statement,Jat least I have'not 5 seen a clear statement, that says that the characterization 6 is both on a horizontal which we all assume as well'as a 1
I 7 vertical variability,.and that needs to be.taken into f 8 account.
9 The report.back in~1982 of the technical 10 integration group which made'the recommendation regarding. ,
J 11 the site carried several caveats. Two of those~ caveats are I
12 very important. One was that each one of the five sites' 13 which were then under consideration should be the subject of 1
14 detailed geological. mapping, mapping on.a scale of one'to
(~} 1 15 two thousand. And the second was regarding~ geophysical 16 studies to study indirectly these sites at depth.
17 This immediately means to me that there was 18 ambivalence or concern on the part'cf the: selection 19 committee in terms of the geology and in1 terms of their 20 representative nature, et cetera of the sites. 'I think thatE
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21 it would be prudent to see in the. point paper-that deals 22 with this some' reference to.the fact that those caveats were 23 put in there. And that to the best of my. ability to1 find 1
24 out, and we chatted'briefly about this this' morning and we 25 had little time, that this has not been carried out since Heritage Reporting. Corporation (202) 628-4888 i
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( 1 1982 despite the fact that those caveats were presented in 2 the TIG report to DOE. I 3 That certainly supports the staff in their 4 recommendation that the location is of concern. And I 5 frankly think that there is nothing more important to us in l
6 the SCP than this shaft because of its immediacy and because 7 of the impact that it is going to have upon the future 8' thinking regarding the. characterization. )
9 Apparently just to go back for a moment, .
10 apparently there was mapping done, but the U.S. Geological 11 Survey had a scale of one to two thousand on the five 12 original sites, but it is not clear that this was done at' 13 the new site which was where the Coyote Wash site was moved 14 in about 1987. But what we have heard and I have not seen .
15 the reports, but what one reads in the SCP is that there are 16 fracture zones in that area, and one wonders whether this is 17 really representative. l 18 In addition eo that, the comment made on 19 page 56 of the Kinerk report dated December 21, 1988 20 referring to the geophysical activities, later geophysical '
21 activities were conducted by the USGS, later and there is 22 really no clear statement of when that was done, in the 23 drill hole and throughout the Yucca Mountain area. That is )
i 24 a very broad statement, and it really does not tell you very l 1
l 25 much.
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() 1 In addition to that, and this I was very pleased 2 to see the staff report on, that as a consequence published 3 interpretations of geophysical data becan.e available, et 4 cetern, but all of those are regional reports and do not 5 specify the geophysical of the immediate location.
6 Well, the point that I am trying to make is that !
7 there are concerns about the location. And they are aptly 8 stated in the first point paper on geology and geophysics. ;
9 They have several very strong recommendations. They 10 recommend that the present shaft location should be i 11 reevaluated based on an assessment of available technical l
l 12 data. From what I can gather, that will be very limited, 1
13 because there is very limited data. There is one electrical l
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14 survey which indicates an anomalous area in the one survey 15 that has been conducted.
16 Secondly, it is consider conducting further tests.
17 I do not think that that is really strong enough, but it is 18 getting to words where it should be, consider conducting 19 further tests, geophysical entrenching in the vicinity of 20 the proposed shaft. That probably would be a good idea just l 21 engineering-wise from the standpoint of construction to say 22 nothing about getting at this point of representativeness.
1 l 23 Furthermore and I do not know if I can find it 24 right now but the comment that comes out. And Charlotte or 25 Bill, if you can help me here. I would like to find the i
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() 1 place in Section 2 of the report that we have where there is 2 the comment regarding the shaft location. And what I am 3 leading to is that I think that the summary comments on this j 4 are insufficiently strong considering the recommendations of
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5 the point paper of the staff. Now wait, I have it here. It )
1 6 is an objection, good show.
7 When we get to the recommendation in the 8 objection, that is 8.. 2.3.1, in the recommendation, and let i
9 me back up for a moment. The first paragraph of the 10 objection states in the fourth sentence very prominently, 11 "Also the process used to integrate currently available j 12 technical data into decisions regarding shaft location l
13 appears to have overlooked the evidence of a potential fault l
(} 14 near the location of the exploratory shafts."
i 15 That statement is based upon I gather on the basis l
l 16 of the anomalous electrical work as well as the fracturing 17 in the area. But it does concern the whole location a 18 problem. Now when we get to the recommendations, I cannot 19 really see in the recommendations of the objection that I 20 there is any thrust or any focus upon the location problem.
21 The only possibility is in the very last statement H 22 on page 5 of objection one, " Based on these considerations, 23 the SF Title II design should recognize the potential need 24 for an additional underground testing area." No , that is 25 not it. "And demonstrate sufficient flexibility to l
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() 1 accommodate likely contingencies." No, that is not really-2 it. Charlotte, help me, or whoever.
3 MS. ABRAMS: This is Charlotte Abrams.of the 4 geology staff. You are referring to'the geology staff 5 original objection one which is no longer an objection. It 6 is comment referred to in an objection that the engineers 7 have done.
8 Now you are referring to the new cbjection,'is 9 that correct?
10 MR. HINZE: I am referring to comment one I guess 11 of the geology.
12 MS. ABRAMS: All right.
13 MR. HINZE: Then I assume that this was 14 incorporated into the objection, am I correct?-
15 MS. ABRAMS: It is incorporated as one of the' 16 bases for the objection, and then the comment is: referenced 17 in that new objection. But all of the recommendations 18 that are in the comment ~are not brought'forth into the-19 objection.
20 MR. HINZE:' Sure, understandably. I! understand 21 that. What I am concerned aboutfis that in'the 22 recommendations that there is no fol3cw-up to the location-23 problem.
24 MS. ABRAMS: And you would like to.see ---
25 MR. HINZE: I have.got ihe last copy this'rorning, O s tie e- ee ti 9 co ver eie=
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() 1 so I am not, an expert on it. But if you look at the 2 recommendations at the bottom of page 4 and on page 5, if 3 indeed location is a problem as it is stated very 4 prominently in objection one, that is the most recent copy ._
5 that I have here.
6 Where is the recommendation?
7 MS. ABRAMS: I think that this is something that 8 we may have to discuss with you later. There may have to be 9 something added to the recommendation in the objection. I r 10 think basically what you would like to see is something like 11 our recommendations about the present shaft locations.being 12 reevaluated based on the existing data and also consider new 13 data.
14 MR. HINZE: That would be my hope, but I am not 15 trying to micro-manage here. I think that the point here is 16 that the location of the exploratory shaft if it is not just 17 a means of getting down to the repository level, and 18 everything that I hear now is that it is not a matter of 19 just getting down to the repository level, but it is 20 important in terms of testing, possible horizontal drill 21 holes from it and the like. That it would take a minimal 22 amount of effort for a group that is as knowledgeable as i
l 23 possible on this site and on the variability that one might 24 encounter in those types of welded tuffs where the shaft-25 will be to take a look at this whole problem again of the
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i' 2 Because the criteria that were used as I 3 understand it from 1982 are by and large no longer valid, 4 many of the criteria are no longer valid. That is what I am I
5 trying to be across.
6 MR. MOELLER: Bill, just as a comment. On 7 page 14 in our notebooks of the first introduction section 1
8 which is new of course, but which summarizes and begins to l 9 focus and high13 ght their comments, on page 14 the approach i
10 that you are concerned about in that top paragraph.
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11 MR. HINZE: Yes, I have it here. The sentence 12 beginning with "also".
l l 13 MR. MOELLER: Right. And then the next to last l ]
/ 14 sentence in the paragraph says, "The decision making process 15 appears to have allowed key information about the 16 suitability of the shaft locations to be overlooked." Now j 17 they are talking through not so much about gathering 18 information and representativeness, but they are talking 19 about the nearest to the fault. But it could be 20 incorporated there maybe.
21 MR. HINZE: Yes. And you bring up an excellent 22 point, Dade. Because as you point out on page 14, that top i
23 paragraph does recognize the problem. It is when I get to l
24 the recommendations and oojections that do not seem to 25 mentica it.
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1 MR. MOELLER: Right.
2 MS. ABRAMS: Dr. Hinze, page 5 of that objection, 3 the one that you just got this morning, .at the top of the i 4 page, the first recommendation there, "The Title II design-5 should ensure that- ". This may partially answer your 6 problem. "The Title II design should encure that the design.
7 process which appears to have overlooked key regulatory 8 requirements and information about the suitability of the. i 9 shaft locations during Title I design is adequate in that 10 the number of shafts and their locations in the final-l 1
11 repository contribute to reduce uncertainty'with~ respect to -
12 waste isolation."
13 Would that answer part of your concern?
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MR. HINZE: With all due respect to my engineering 15 colleagues, I read that as an engineering statement and not- ,
16 as a geologic statement. And there were concerns here. I 17 do not know what the term final repository means for 18 example, what is the significance of final. I do not think l 19 that to my colleagues in the geological or geophysical i
20 profession that this would have the meaning that -I' think .
21 that you are putting upon it, or the;importance'that you are j 22
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putting upon it. I would encourage the staff to look at l 23 this problem again. I'do not want to beat it into the l 24 ground.
25 MS. ABRAMS: Okay.
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() 1 MR. HINZE: I also think that there is a real 2 problem here in terms that this is really going to be the 3 first hard information that we get on the subsurface in any 4 large quantity. And I cannot help to feel that that is 5 going to have a tremendous impact upon the psychological 6 viewpoints regarding tha whole repository. And my approach 7 here is not to detract from the Yucca Mountain site. I want 8 to see that it has its fair day in court.
9 And if this is placed incorrectly, it could well 10 cause I do not know if you want to call it a fatal flaw, but 11 such serious objections so early in the game would cause a 12 great concern to the entire community. I think that this 13 is the most important thing that we are going to be
(} 14 doing.
15 MR. MOELLER: Another comment, Bill, and I am sure 16 that you are familiar with it, the top paragraph on 17 page 16 in the opening portion of our notebook discusses 18 again the location of the ESF but the concerns are not the 19 concerns that you are citing.
20 MR. HINZE: That is right. They are concerns 21 regarding flooding.
22 MR. MOELLER: Correct, and faults.
23 MR. HINZE: And concerns regarding construction.
24 Engineers to not like to put shafts into faults. They are 25 not the easiest things to put shafts into. And there are
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) 1 flooding problems there. There are several other criteria 2 that were used in flooding for example.
3 HR. MOELLER: So we have.the key-point very_ clear 4 that you are saying one that the location of the shaft, that 5 some of the criteria used in the location'of the shaft' 6 should include whether the data that you obtained are 7 representative.and what else, I know that you had come 8 others?
9 MR. HINZE: Well, representative from'the vertical 10 variability standpoint. That I think is very important.
11 There is also the problem of-just the representativeness, is 12 it in the fault area. I had a discussion with Dr. Parry a 13 couple of weeks ago that perhaps what we should be doing is 14 putting the shaft down in the worst possible area. That
(]) j 15 this is going to be a boundary condition and a constraining 16 condition, that maybe we ought to put that down. And-I'was l
17 very pleased to see in the report that that was one of-the-18 considerations that was actually made at one' point. But what 19 I read between the lines for engineering reasons and j i
20 construction purposes, that was changed.. .;
~l 21 MR. STEINDLER: Excuse me, Bill. Does that mean-- o 22 that that area, the fractured area, might be unsatisfactory ,
l 23 for construction purposes in the future, I mean even putting 24 a drift throuf.?
25 MR. HINZE: It could. It would certainly make the j
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(_) 1 problem a lot more difficult. I am not a mining engineer, 2 but I have worked in enough mines that wh'.never you have a 3 drift in a fault area that you will have continual problems, 4 and this is a tectonically active area. So we can expect to 5 see continual problems. This does not mean that you cannot j l
6 drift through.
7 MR. STEINDLER: But it might mean that that l 8 portion of the site might not be suitable for placement.
l 9 MR. HINZE: That is right. It is the degree of 10 faulting and the movement on the faults.
11 MR. SMITH: Dade, I wonder if someone from the 12 staff could explain to me again what the process is for 13 resolution of these concerns that NRC has with respect to
() 14 where DOE would propose to locate the shaft. I remember in 15 prior discussions that getting NRC approval if you will was 16 extremely important, and timing was important for the whole 17 DOE program with respect to sinking the shaft. And from 18 what I hear this morning there is still a great deal of 19 concern about indeed where to even locate it. And I would 20 like to have someone review very briefly how do we come to 21 closure on this issue.
22 MR. LINEHAN: I think that if you look at the 23 objection that we have on the shaft and the recommendation 24 there that we lay out a number of these things that have to 25 be done through the Title II phase of the design of the Heritage Reporting Corporation (202) 628-4888
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() 1 shaft which is ongoing right'now. And if you look in 2 Section 2 of the director's comments, we point out'that for )
3 the department.to reach resolution with-the.NRC staff on !
1 4 this that.they are going tolhave to lay out.some type of a 5 process-whereby they can demonstrate to us where they need 6 to involve us as they go through this design, as'they 1 7 respond to the specific concerns that we have outlined, l I
8 If it be some things as modifying their. design l 9 criteria, they'need to have consultations with us as they go-10 through this process rather than go through the whole. design 11 and then present us with the results of Title II -design,.
12 because are could be back- in the same place that we are -
13 today. What we feel is that we need interactions as they go 14 about doing this. That is the only way that we can get it 15 resolved.
16 MR. MOELLER: Okay, Marty.
17 MR. STEINDLER: I hate to replow some of the 18 places that you have already touched on. If you'would help 19 me clear up a confusion, that might help a lot. We have 20 apparently an objection to some aspect of the exploratory 21 shaft facility process.
22 Bill, you indicated that one of the concerns that l
23 you had was the representativeness of the location or the 1
24 representativeness of the shaft and namely the locatien of l 1
25 it is in question and that is part of the objection if not )
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() Beritage Reporting Corporation (202) 628-4888 j
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( 1 raised explicitly should be raised. And I go through here 2 and I look at the recommendations and I am not sure that the 3 word representativeness at least in this thing that I have 4 here labeled point papers, that representativeness does not 5 seem to even be mentioned. -
6 Are you telling the staff in the course of your 7 analysis that they should have in fact paid more attention 8 to that point in the document that they are ultimately going 9 to hand DOE?
10 MR. HINZE: Yes. But I also will say that the 11 staff in our discussions has pointed this representativeness 12 problem out to me. It is one that they are very cognizant 13 of. It is not a point of any contention between us.
() 14 MR. STEINDLER: In the course of your d!.scussion 15 with the staff, did you get the impression that the 16 recommendations were issues of principle _ ther than how to 17 or the other way around. What I am driving at is that it 18 seems to me that the NRC staff can address DOE in a half a l 19 dozen different ways, and one of them is to outline what it 20 is that they wanted to have done in detail, and another way 21 is to say hey, guys, here is a set of criteria on what your 22 final product ought to look like and we do not care how you 23 do it.
24 We do not care that you convince us that your 25 shaft location is correct by relying on somebody elae's
() Heritage Reporting Corporation (202) 628-4888
24'
() 1 data, or getting your.own drill holes, and;doing whatever.
2 you,want to. My assumption has been that it is the latt'er.
3' approach that the NRC staff should be using, namely they.can 4 tell DOE what it is that they want and leave it up to' DOE to 5 figure out a way to get that.
6 Is that your impression?
7 MR. HINZE:- It certsinly is.
8 MR. STEINDLER: Okay. So presumably then the 9 recommendations would come under the general heading of 10 identifying the general things that are missing in' terms.of 11 principles leaving it to DOE to determine how they are.about 12 to get that information.
13 MR. HINZE: They may not just be missing,-but the, 14 manner in which you arrive,at them also determines the 15 credibility of them.
16 MR. STEINDLER: You see, that'is-the fine i
17 distinction that I am trying to get to.. 1
-l 18 MR.-HINZE: I understand.- j i
19 MR. STEINDLER: If it becomes prescriptive, then ]
i 20 the burden on the staff is much larger than I.think it j 21 should be.
]
22 MR. HINZE: Let me give you a case in point.that I 23 might help with this, and perhaps the staff ought to be 24 speaking for themselves on this. But for example the' 25 volcanic problem is a problem that 19 of great concern.to l
() Heritage Reporting Corporation (202) 628-4888 i
25 1 everyone in this room. I.think that the staff has shown 2 admirable restraint in not trying to micro-manage how the 3 DOE should go about solving the volcanic problem.
4 We have had discussions regarding certain type of 5 geophysical analyses at depth which might help to decide-the 6 credibility of the decision. The staff in my conversations 7 with them and from I read here always has taken the position
~
8 of not trying to tell DOE how to do it, but to set the.
9 standards, and in doing that they have to give some 10 examples. And I think that in their discussions"that they 11 have given some examples, but when it comes to 12 recommendations that is the critical element.
~
13 MR. MOELLER: You were just talking about j
() 14 volcanism. I read and we have numerous items here and it is j 1
15 hard to know what you are reading from, but.this is in 16 Part.3, the summary of the SCP concerns. And in 17 Section 3.2.6, item 6, it says that, "The tentative. goal
.8 with respect to the probability of basaltic volcanism - )
15 appears to be set such that if met that.the site will not 20 meet the EPA standard, 40 CFR 191.1.3. To me that.is a 4 21 major statement, and ye'c I never found that statement again- l l
22 highlighted anywhere. It is here onco. I I
23 And is that not a fatal flaw?
i 24 MR. HINZE: To my viewpoint, I believe that it is 25 a potential fatal flaw, and it is of concern. And this Heritage Reporting Corporation l (202) 628-4888 i l
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26 1 really goes back to what I was commenting upon in the 2 exploratory shaft', that it does not fit into the 3 recommendation area. And you have to have a pretty good 4 expert system or AI system to'be able to reference back each 5 time to these critical elements, and there.is a chance of 6 them not only getting lost in the SCP but getting lost in l
7 our response to it.
l 8 MS. ABRAMS: Dr. Moeller, that does appearLin one 9 of our comments. We have an entire comment on that problem.
10 MR. MOELLER: Okay. It. appears then as.a comment.
11 MS. ABRAMS: As'a point paper.
12 MR. MOELLER: Is it not though a potential fatal' 13 flaw?
14 MS. ABRAMS: It is something that they need to 15 address soon and quickly, but it is not-comething that.
16 should stop the work..
17 MR. MOELLER: Okay. That'is why we have to keep 18 separate your definitions versus ours. Back on'your earlier 19 comment. In Section 3.2.3 of the' summary of SCP concerns, 20
~
3.2.3, paragraph one under it says quite' distinctly what you-21 have been saying. The last sentence says,."Therefore the 22 NRC staff is concerned that data collected in the proposed ,
23 exploratory shafts, drill holes and drifts will not be: -
24 representative of conditions throughout the repository 25- block." !
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() 1 Now even though that sentence is there to you, j 2 Bill, it is not strong enough, or it is not in the right i
3 place, or what?
4 MR. HINZE: Well, representativeness was not j 5 necessarily my concern about the objection. My concern 1
6 about the objectin- is that in the recommendation that the 7 location problem is not really remarked upon and emphasized l 8 as would be indicated by the other statements in the point j 9 papers as well as in Section 2. I 10 MR. MOELLER: Judith Moody had mentioned that she 11 had some comments on this subject, and why do we not go !
12 ahead and ask you Judith to comment at this time.
13 MS. MOODY: All right. Everybody has copies of my 14 transparencies. So all I can tell you that this is the last 15 one. And the reason that I want to show this for 16 presentation today is to just look at the summary SCA papers 17 and I have of course some specific comments in addition on 18 the hydrology and geochemistry. What I have done here is I 19 can just say that I do agree with my colleague in the sense 20 that I have said here that the exploratory shaft location is 21 exceedingly critical in terms of the repository itself. And 22 basically it needs to be chosen because of the use that it 23 will generate with the geology and geophysical data.
24 So basically Hinze and Moody agree that the 25 location of the exploratory shafte is exceedingly critical
() Heritage Reporting Corporation (202) 628-4888
28 1 for the repository itself. And of course'here I am number j 2 one knowing that I did not know that the Title II design has 3 already begun. And I think that that is something that 4 could be heavily criticized just simply because the 5 requirements that are needed have not been met in the 6 Title I design but that the Title II design has begun.
i 7 So I think that that is a point that is valid and 8 I do not know how you are going to deal _with'it, except say 9 thnt all of the NRC requirements will be met in the i
10 Title II design. But the fact that it'has begun and the l
l 11 Title I design has not met NRC requirements I think;is '
I 12 something that can be highly qu%tioned.
13 And of course this'last point that I-make here is 14 something that we all know, both.the geologists and the _
15 engineers, because of the heterogeneity.of that particular 16 rock that the design and drift excavation that-is being l
17 proposed and adjacent to the ESF locations does.in some 18 respects need to be done, but again it has got to be well 19 planned and integrated with all the additional work that l
l 20 needs to be done in terms of geology, geophysics, 21 geochemistry, engineering geology and hydrology.
22 So all I can say is Hinze has-brought'up some very 23 valid points which I agree with and'I bring up some 24 additional ones. I am concerned because of the work that I ;
25 have done and was responsible at one time in the design of a-l Heritage Reporting Corporation (202) 628-4888 a
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() 1 repository that that is a concern of validity with my other ]
i 2 major points that I made. .
J 3 MR. .MOELLER: Dr. Moody, of course Gene Voiland ,
l 4 will be discussing the Title I and Title II design later. I 5 But in the summary, the NRC staff summary of their comments, 6 they do very clearly include the statement that the Title II 1 I
7 design should not be a Title I design in which.you have j 8 corrected all of the' errors in the Title I design,.that it 9 should be cleanly a Title II design. And this in a sense is I
.)
10 exactly what you are saying, that.you should finish the 11 Title I design and get it complete and then go on with tLe 12 Title II.
13 Does that comment of the' staff adequatel'y address 14 your concern with respect to that. subject?
[}
12- MS. MOODY: Again I think partly that Hinze has i i
16 already commented to you that there is some information that 17 is in all of those statements that have been made that some 18 of it needs to be emphasized or brought out into a special 19 category if you will in terms of a strong recommendation as >
20 an area that the Pepertment of Energy should have-explicit 21 concern.
22 MR. MOELLER: And one place where this obviously 2 23 will be done, not necessarily the same topics, but'where the 24 staff will clecrly highlight their major concerns will-be in-t 25 the transmittal-letter or whatever you call it. Thank you.
I Heritage Reporting Corporation O (202) 628-4888 t .-a
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()- 1 MR. HINZE: One of the ground rules that I try to 2 operate on is whether or not the remediation that is either 3 implicit or directly suggested to the department is doable, 4 and I guess that I am a little confused. The exploratory 5 shaft has as its first word exploratory, and I did not 6 understand yet how the recognized heterogeneous nature of 7 the geologic environment can be precisely determined so that 8 you sink your shaft in the right place if you have not sunk 9 your shaft. Is that too simplistic? Being a 10 non geologist, I could easily claim that.
11 MR. STEINDLER: No. I think that that is the 12 reason for those caveats that were mentioned in the TIG 13 report, because they do recognize the fact that more
() 14 information is needed about the subsurface before this 15 exploratory shaft goes in and that can be done by two 16 methods. And that means surface mapping of a detailed type 17 and detailed geophysics on the area. This is not going to 18 guarantee it, but you are putting your odds where they 19 should be.
20 MR. HINZE: In the extreme is there a suggestion 21 that if you have a large enough surface mapping in the 22 geophysics program that you may not need the exploratory 23 shaft because you have done all of the work?
24 MR. STEINDLER: Oh, very definitely not, every ,
1 25 definitely not.
() Eeritage Reporting Corporation (202.) 628-4888
31 1 MR. HINZE: 'Okay.
2 MR. MOELLER: I think the other comment and
}- 3 everything that you say, Martin, is correct. And yet we 4 know that the " exploratory shaft" will become a permanent 5 part of the final repository, so its location in that sense.
6 MR. STEINDLER: I do not have any. problem 7 understanding that. I am trying to see whether or not the 8 geology, for the exploratory geology portion of the 9 exploratory shaft, can in fact be accomplished in some-10 reasonable method.
11 MR. HINZE: If I.may, Martin, I feel that the term 12 exploratory shaft is really a misnomer here, and I have 13 really been concerned about this. Because the major
{} 14 emphasis really is not:in the shaft at all but'is upon the 15 drifts. And the exploratory nature of it, and.this was one 16 of the questions that I raised a few moments ago, what does 17 final mean, the use of these in the final repository. I 16 th irft that you are raising an exce13ent point that we should 19 recommend to the staff that something be done about this 20 terminology because it is misleading unless you have got all 21 of the caveats in mind. 1 22 MS. ABRAMS: Dr. Steindler, we do have'a-comment. =
l 23 that 'is a comment cut the representativeness of the E
- 24 exploratory shaft and the subsurf9.ce work that they are. , ;
25 doing. coupled with the surface ' exploration program, will the ;
o
() >
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() 1 data gathered be represenu +ive of what you would gather-in .
l 2 the entire repository area. So we.do have a comment that .)
3 reflects on that.
4 MR. MOELLER: Go ahead, Bill. l 5 MR. HINZE: Well, _just a few more things. But 6 before leaving your comments regarding the volcanic problem, 7 I just have.a sense that the point paper is not strong l
8 enough in terms of its concern about the volcanic problem.. j 9 I think that this it is, as we have heard from our Nevada 10 colleagues, that it is going to be a very prominent. topic. 1 11 And I think that there could be a little stronger emphasis 12 in that area.
13 I will take a few moments to bring up.a couple of
{} 14 15 other items. One of the discussions here that is prominent c from the staff.in both the CSDP and the SEP is the well.
1 16 integrated and logically sequenced aspects of;the 17 characterization of the site,,and that is certainly a' point i 18 well taken.
19
~
As I ref)ected upon this more recently, it seems 20 to me that one of the things that is part and parcel of that 21 is the fact that there is not a good specification of the' 22 physical properties of the rocks involved in the Yucca 23 Mountain site. There are geophysical studies to a very 24 large degree that are dependent upon the contrast in the.
]
i 25 physical properties. And those physical properties have not l
() ' Heritage Reporting Corporation. ,
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33 !
'l been brought together into the SCP or are they really j 2 referenced as far as I have been able to tell in the SCP.-
3 And they form the basis upon which one makes 4 judgments of the applicability of the geophysical methods.
5 And it seems that there is a real flaw in the logic here, i
6 and one of our concerns is that we do not waste a lot of .i 7 time and a lot of money. What we have seen here in the SCP-8 is throwing the high school textbook on geophysics at this 9 site. It has not been discriminatory and the way'that one 10 gets at that point is be experiences And.if you do not have- i 11 good experience in the area which apparently they cannot get 12 is to look at the physical properties.
13 And incidently I am personally aware that that 14 information and those data are available. That information 15 is available to a very large degree from the in' situ 16gging 16 as well as the sample studies. And.I think that.we'might '
17 ask the staff to consider encouraging that-this logic -
18 pattern also include really looking at the" physical 19 properties as they develop the programs..
. i 20 There is another point that is danced around and 21 that is the drilling, and the staff has done a good-job'in 22 stating that the drilling does not seem to-be integrated 23 into the geophysical stddies and in the characterization. '!
24 But I do not think that it is micro-managing'to go one' step
> i ll 25 further and say that the anomalous areas that a sufficient l-Heritage Reporting Corporation (202) 628-4888
I 34
,3
(/I
_ 1 amount of drilling and monies be retained to investigate 2 anomalous areas that are encountered in the geophysical 3 observations.
4 This is a very important part of the 5 interpretation procedure, to be able to use the geophysics 6 to extrapolate from known information. And it does not seem 7 to me that the physical properties and the follow up 8 drilling integrated with the geophysics are really hard 9 enough.
t 10 I want to commend the staff on recognizing what l l
l k
11 appears to be a very important point in the characterization !
4 l 12 of the site. The site characterization plan just gives 13 enough information about the locaticn of the geophysical i
/_3 14 observations to indicate that these will not be of a '
K/ i 15 comprehensive nature of a blanket study of the area. I 16 think that Buck's word is gridded pattern or something of 17 that nature. i 18 I think that it would be helpful here to comment 19 in the comment area of the point papers that what is being 20 attemptea here is a 3-D representation of the site as if we 21 know the physical properties on a 3-D grid like a 3-D 22 checker board. And there will be no credibility to those 23 results unless there is a comprehensive geophysical survey.
24 That does not mean that all of the surveys have to be 25 comprehensive. But those that work and those that do the
,28
(_) Heritage Reporting Corporation (P O.2) 628-4888 i
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i 35 I r
( )s 1 job need to be comprehensive. And the staff has done well.
2 They have been told what the station spacing might be or the l 1
3 observation spacing. l 4 There is another point that I know again that the i
5 staff has been concerned about, and that is the regional ]
I 6 nature of the geoscience investigations around Yucca j 7 Mountain. My reading of this material indicates that the 8 seismicity, the certigraphy, and some of these other 9 characteristics are going to go out to a radius of two 10 hundred miles. Yet my reading of the SCP indicates that the j 4
l 11 structural analysis is not going out that far.
12 If I am correct, perhaps that is a point that the {
1
)
i 13 staff should consider broadening. In order to understand !
l I
14 the faulting in this area which is very critical, we have to l [}
15 understand the mechanics of that we have to have a 1
16 reasonably good idea of what is causing that. And you are i
17 not going to get that by looking at the first few tens of l 1
18 kilometers around the site. And it seems to me that there 19 is a lack of consistency in the size of the area.
20 I am concerned about another problem that may fall 1
21 in the crack between geohydrology and geology and ;
22 geophysics, and that is the use of the Calico Hills unit as 23 a barrier. The Calico Hills unit as a barrier is very i
24 important to the whole philosophy of the site. I know that 25 the geohydrologists are concerned about getting sufficient
,m
( Heritage Reporting Corporation (202) 628-4888
36 1 information on that for their hydrological studies.- The 2 geology group is interested in getting information about 3 characterizing that.
4 And it is not clear to me that there is a.
5 sufficient amount of attention being paid to the 6 characterization of Calico Hills, and that is particularly
_7 critical in view of the fact that.the exploratory shaft'has 8 been raised and the bottom of that has been taken out of the 9 unwelded tuff, and if a few sentences could be inserted to 10 emphasize this and make certain that it does noN fall 11 between and that we also do not have an integration problem.
12 I think that that would be helpful.
13 MR. MOELLER: In that regard I must say in reading 14 the material that if I were DOE'that'I would be frustrated-15 in terms of Calico Hills, because there are statementa you d
16 know do you not dare touch it and we do not want you to 17 penetrate it but we want you to know all about it.
18 Can you know a lot about it from the surface or 19 maybe.once you drill the shaft to go down and do something?
20 MR. HINZE: Again this is micro-managing. But for 21 example I can conceive that there very well may be=some' 22 geophysical studies that one could perform in the drifts. :
23 Ycu are sitting right on top of it and your resolution is i 24 best when you ere closest. So I think that there are some 25 interesting things that could be done.
Heritage Reporting Corporation (202) 628-4888
37 k 1 I think that this is a challenge to us, a 2 challenge to the whole progran to provide the hydrogeologist 3 with the right kind of information for their modeling and 4 for really coming to grips with the barrier problem without 5 destroying it in the process. And I do not get the sense of 6 that when I read these documents.
7 MR. MOELLER: And I think that is what the staff 8 is saying, the NRC staffc that you simply have not spelled 9 out how you are going to do this in a general sense.
10 MR. HINZE: That is right.
11 MS. MOODY: Dade, there is another important point 12 that Bill has hit. And that is that the exploratory shaft 13 is in itself a potential point of sampling the rock. And I 14 ll) hate to say this except it is a point that I am going to 15 bring up when I speak myself, that every potential sample 16 that you can get, in other words I can see where you can 17 pre-drill the location once the location is decided upon, 18 that you can pre-drill that location with say a three inch 19 diameter hole or maybe a multiplicity of holes before you 20 blast out the total diameter of the shaft that the engineers 21 would like, but use that occasion as collecting decent rock 22 samples for detailed analysis for not only in their 23 petrology and geochemistry but also making samples available ]
24 for rock mechanics testing. l 25 MR. MOELLER: Go ahead. ,
l Heritage Reporting Corporation (202) 628-4888
38 1 'MR. SMITH: I guess that after list'ening to you 2 that I am a little disturbed- . Let me ask you a couple'of 3 questions and see whether or not this is your view and the 4 staff's. I detect that there is some concern, and I am 5 being modest here now, some concern that the shaft is 1 6 located in the right place.
7 And what I hear you saying is that we would be 8 much better c'f to do a thorough surface mapping job and 9 geophysics study to the best of our ability to locate that 10 shaft in the right place, is that correct?
11 MR. HINSE: I am sorry, I am not making myself 12 clear. Let me try it once more.
13 MR. SMITH: Let me just give you my broad concern.
lll 14 That this is the only repository site that is under 15 consideration at the present time. The American taxpayers 16 ere about ready to spend millions of dollars to try to 17 characterize this site as to whether or not this is the 18 proper place for a deep geologic repository. If there are 19 doubts about whether or not we even are going to fir;t drill 20 the holes in the right place, I think that there is a_ great 21 deal of concern for all of it.
22 And then if you are best able to figure out where 23 to do down, then it seems to me that there is a question of 24 how best to characterize this area that you think is the 25 best area to locate the repository. One way I suppose-is to Heritage Reporting Corporation (202) 628-4888
_ _ - _ _ _ _ _ _ _ _ _ _ i
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,39 1~ sink drill hills'around and the other one is to go Jout.
2 horizontally in the drifts:if.you:will. .I am trying.to'get?
3 a feel for.tha magnitude'and the dimension of concern here.-
4 5
6-7 8
,9 10 11 12 13 O 14 15 16 17 18 19 20 21 ,
22 23 l 24 25 l
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40 1 MR. HINZE: The present location analysis is based 2 upon the criteria and what I.am suggesting--
3 MR. SMITH: The criteria for the present location 4 are not valid today.
5 MR. MINZE: Does the staff agree with you on that?
6 MR. SMITH: I don't know.
7 MS. ABRAMS: Part 'f our problem with the location 8 analysis was that they didn't integrate coma of the data 9 that was available at the time, at least it doesn't appear 10 that they did and maybe they should step back and gather 11 more data.
12 DR. STEINDLER: The question is, beyond the 13 shaft, the major shaft, what else do you do to try and
() 14 characterize that, what is your strategy going to be?
15 MS. ABRAMS: The limited drifting and the drifting 16 they had prcposed is in the northeast corner of the 17 repository block. It's in an area where, based on the drill 18 hole data--
19 DR. STEINDLER: Then your objection really is to 20 the limited drifting and the lack of extensive information--
21 MS. ABRAMS: We have a concern there, yes. Based 22 on statements that they have made in the CPSEP and the SEP, 23 they make statements such as the core recovery is poor in 24 the unsaturated zone and based on the differences in the 25 knowledge that perhaps you cannot extrapolate from one area Heritage Reporting Corporation (202) 628-4888 j I
41 1 to another, then we would question that, their ability to do 2 that.
3 DR. STEINDLER: So if I could just characterize 4 the staff's feelings, two points. One, you're not convf.nced 5 at this point in time that the shaft is in the right place.
6 You're not totylly satisfied with that?
7 MS. ABRAMS: We're not really saying that. We 8 don't think the shaft is in the wrong place, but they need 9 to do further studios in that area or at least integrate 10 what has already been done.
11 DR. STEINDLER: To put it another way, you're not 12 convinced that beyond that, the way they intend to 13 characterize this area is sufficient?
gg) 14 MS. ABRAMS: Well, we question it and again it 15 brings in the--
16 DR. STEINDLER: Can I go back to the Calico Hills 17 and the barrier and whatever information is required, from a 18 combination of surface measu. cements and measurements in 19 drifts--
20 MR. HINZE: I think there will be other studies 21 that are needed. I don't think those studies will be 22 definitive enough, in terms of the types of information the 23 geohydrologists will need.
24 DR. STEINDLER: Is there any indication that 'hb j 25 Calico Hills barrier can be sufficiently characterized Heritage Reporting Corporation (202) 628-4888
42 1 without penetration? l 2 DR. MOODY: You need much better geophysics than 3 has been done. ]
4 MR. HINZE: But to believe that geophysics, excuse l 5 me--
6 DR. MOODY: Sure. !
I 7 MR. HINZE: But the blue bed geophysics, we also 8 have to have some very good grounds with information and I f 1
9 don't think that is going to be accomplished without f i
10 drilling, without going in there and getting some samples. I 11 DR. STEINDLER: Okay. There are all kinds of ways 12 one can approach this in terms of looking at variability and 13 looking at it in the all crop and drilling off the site and
( 14 looking at variability, whether this might' extend j 15 underneath. There are some options there that need to be 16 explored, but I suspect that the final gun will show that we 17 have to get in and sample the site.
18 But I think a lot could done in the perimeter area 19 and--
20 DR. MOODY: Rather than the repository area. 'l I
21 DR. HINZE: Rather than the repository itself. We l 22 should know that Calico Hills as good as we can know any 23 geological formation, not only in terms of its 24 characteristics but the RMS values and so forth.
25 DR. STEINDLER: So the role of the Calico Hills Heritage Reporting Corporation (202) 628-4888
i 43 1
1 I) t 1 Barrier and the qualification of the site can be at least j 2 reasonably approached by studies done off site?
3 The problem that we have always had here is that, 4 you know, we really would like the department to focus in on 5 the question, is this site going to fly, just as rapidly as ]
i 6 they can without expending, you know, the treasury.
7 And, I am trying to see what kind of information 8 is to be transmitted to the department by the staff in that 1 9 particular regard. ,
1 10 MR. HINZE: I feel that the whole emphasis on the j 11 Calico Hills needs be checked in terms of perimeter studies 12 and from all other geological information that we can put 13 together. l l
(~ 14 DR. STEINDLER: Thank you. l
%-}/ '
15 MR. HINZE: My time is up. There is one point in 16 terms of the natural resources that I would like to touch on 17 and that is the paleozoics beneath the tertiary volcanics 18 are mentioned in the point paper and the recommendations.
19 I don't think this is ever mentioned really with 20 respect to the petroleum aspects. I think there is going to i
21 be concerns in the community regarding the Petroleum aspects 22 and so, I would like to see that mentioned specifically.
23 I would also think there are certain flags that l
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- 24 one looks for in terms of mineral exploration and it is not l 25 clear to me nor is it clear to the staff, but I don't think t
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44 llh 1 that is strong enough again, that those flags will be 2 identified with the types of studies that are currently 3 planned.
4 You can go and do a lot of geophysical studies, 5 but the point is that you really have to go in there and 6 look for certain types of specific signatures or flags.
7 DR. MOELLER: Okay and I am sure we'll be coming 8 back to a number of these things as'we go on today.
9 We didn't have a break scheduled for awhile, but 10 I--
11 MS. ABRAMS: May I say something else?
12 DR. MOELLER: Sure, go ahead.
13 MS. AERAMS: We do have a statement in the summary 14 with respect to geophysical and geological activities and 15 data gathering. It relates to--let me just read it.
16 There also appears to be some situations where 17 geophysical and geological activities intended to gather 18 data required as input to assessments may not be completed 19 until well after those assessments have been initiated.
20 And, in general, this is from the Director's summary, "In 21 general, it would be prudent for DOE to cc. duct non 22 interested geophysical activities that will provide 23 information neuded to optimize the location of proposed 24 drill holes and trenches designed to investigate potentially 25 adverse conditions prior to those activities."
lll Heritage Reporting Corporation (202) 628-4888
45, 1 I'didn't know if you had seen that.
2 MR. HINZE:. That's.in Section-2,'right?:
3 MS. ABRAMS: Right.
4 DR. MOELLER: Other comments from.the' staff?
5 Okay, back to the--
6 MR. HINZE: 'I think that we have a problem here in 7 that there are the director's comments- and ' then the' point '
8 papers and.let's not pull an SEP on us. Let's have1them--1 9 let's not have to go back from the-point paper to the 10 Director's comments to make certain that all'the' points are I
11 made and I would.like to see the pointLpapers be totally j L
l 12 self contained and I think that is the direction of some of.
13 them. i
() 14 DR. MOELLER: Okay.. Paul Shewmon is next, but I am l 15 looking at-the clock. We've been here quite' awhile.
16 Paul, if it's.all right with you, we'll.take:10 17 minutes.
18 DR. SHEWMON: All right.
19 DR. MOELLER: Okay. Take a break.
20 (A short recess was taken.).
21 DR. MOELLER: The meeting will resume.
22 Next will be a discussion of materials' engineering 23 and Paul Shewmon be leading that for us. Paul.
24 DR. SHEWMON: With reference'to the. staff 25 ~ comments, there are several comments in question. There is Heritage Reporting Corporation (202) 628-4888
l 46 l (~)
(/ 1 one basic question that I will get to later and that has to 2 do with what is really meant by essentially complete 3 containment and how we would we recognize it to start.
l 4 The package will consist of an outside canister 5 which will be leak tight. The main question has to do, they 6 don't address the abuser when they put it in.
1 7 One of the mildly frustrating things about this is I i
8 this is still a black box and there is no specification as )
i 9 to how it will be made up, so that makes it more difficult. i I
10 A multiple barrier comes from the fact that a j
! 11 waste form inside the hemisphere--there may well be fuel 12 pellets which are in cladding and one can't be sure that j l
13 these claddings is always--
() 14 DR. MOELLER: Excuse me, Paul, can you put the I l
15 microphone in front of you. J 16 DR. STEINDLER: One question, Paul. I have seen l
17 documents relating to how they do their welding--part of the i 18 problem here is the frustration and I will work with Jack to i l
19 sort this out. )
20 I feel like I am being asked to grade an I
21 examination, the questions which I haven't seen, but only 22 the answers. I am not quite sure what is and what isn't.
23 Some water does accumulate in the bottom of either 24 dissimilar metals there which would set the cells or if you 25 have got a spacer, what about that?
Heritage Reporting Corporation (202) 628-4888
47 1 DR. SHEWMON: Being more mechanistically inclined 2 then the people who write these things are, I would like to 3 see some discussion on what does happens if you perforate 4 this. If you are above ground level, it is very difficult 5 to imagine a failure process that does involve either 6 mechanical deformation or at most a small perforation from 7 dripping salty water or something of that sert. The other 8 thing is that if enough of these things perforate then it is 9 hard to demonstrate that indeed you would not violate as to 10 the number of curies of Carbon-14. If you have questions, 11 I am sure that the staff can tell you more about it than I 12 can.
13 DR. STEINDLER: One comment. The source of lll 14 Carbon-14, the largest source seems to be the cladding.
15 Maybe it was in your commentary. Carbon-14 is in the 16 cladding. You would not expect an easy release as it is 17 basically stabilized. If that is the case, then it is in 18 fact not mobile. So before somebody gets carried away about 19 whether or not you have a real problem, I think that 20 somebody ought to work a lot harder trying to get at the 21 real issue. l 22 DR. SHEWMON: Did I not see in a report something j 23 that talked about the amount of C-14 in the gas outside of 24 the zircaloid or not?
25 MR. CHANG: The DOE report on Carbon-14 in the Heritage Reporting Corporation (202) 628-4888
1) q d
48
'O 1 c1 aat=9 -
2, DR. SHEWMON: How-much is in the gas state and how j 3 much is in the cladding?
4 MR. CHANG: Okay. They have some' idea but they do 5 not know how much Carbon-14 is gas.. That should be the
]
6 easiest way.
7 DR. SHEWMON: That would not be easy at'all,.
8 because you have to defuse it.
9 But there'has not been a study where people have' 10 shown anything about how much did come out or was on the 11 outside?
12 MR. WELLER: Yes, there was, Dr. Shewmon- l i
13 It is embodied in the matrix. I think that it is primarily '
14 from contamination during fuel fabrication and operation and 15 it is less than ten percent. at least-from the. limited !
16 studies that have been done. The problem that you point out 17 is if you have enough waste packages of fuels that you could 18 have a release in any given year, and then you have a limit 19 over a 5000 or 10,000 year period. So that is a concern.
20 It is primarily a release rate. And it is a DOE problem and 21 an EPA problem.
22 DR. SHEWMON: But a central question is the 23 zircaloid. DOE might be able to react. I want to'be clear 24 on what evidence they had seen. l l
25 MR. WELLER: People did some releases, but'I .)
l Heritage Reporting Corporation (202) 628-4888 i i
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49 1 cannot tell you exactly-what the release studies were. The 2 DOE has a very comprehensive study for C-14 on the 3 differences in the inventory between PWR fuel and BWR fuel, 4 the nature of its location, its availability for conversion 5 to CO2 to the gaseous form. I think that it is a fairly 6 comprehensive program that we see in the SEP.
7 DR. SHEWMON: So we are not talking about any 8 contamination that got to the surface when the fue?. was in 9 the core. But since it is formed from nitrogen that may 10 have been in the water, it could be surface or interior:
11 water. !
12 DR. PARRY: In the inert gas too, Paul. .
13 DR. SHEWMON: Why do we not both check on that.
14 DR. MOELLER: CO2 as a problem in the repository, 15 would we not see it in spent fuel pools, I mean how bad is ~
16 the C-14 and CO2 in spent fuels?
17 MR. VOILAND: I do not think that anybody has ever i
l 18 looked at it. l l
19 MR. WELLER: Dr. Moeller, let me address that.-
20 This is something that you see, and you see it from PWR.
21 DR. MOELLER: I have read and seen the 22 measurements, but I am talking about who has sampled the air l 23 above the spent fuel pool.
24 Is there something in the water that would prevent 25 the CO2 coming off?
Heritage Reporting Corporation (202) 628-4888 )
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(-)/ 1 DR. MOODY: It can be CO3 or H2CO3 depending on 2 the ph in the water.
3 MR. WELLER: Dr. Moeller, the other point is the 4 source. It is relatively small so you could have a 5 sensitivity problem.
6 DR. SHEWMON: This is something that is ;1ard to 7 nail down.
8 DR. MOELLER: I would think that it would be in a 9 manner analogous to radon.
10 DR. STEINDLER: If there is time for one more 11 comment. It would tend to convert that. I would be 12 interested in that paper that talks about that, because you 13 have a completely different situation. Again when you get
() 14 back to the specifics what kind of release mechanism are you 15 talking about. I feel like you, I have a hard time 16 speculating.
17 MR. VOILAND: You are saying the hot water that 18 was on the surface, that that is your feeling.
19 DR. STEINDLER: I would think so.
20 DR. SHEWMON: Let me dwell a little bit on and I 21 will read from 60-113, performance of particular '
l 22 barriers after permanent closure. The engineers say that it 23 will be designed so HLW will be substantially complete 24 during the period of radiation and product of decay. And 25 then there is reference back that it will be substantially
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51 llh I complete for periods to be determined by the Commission, and 2 it goes on and talks about the-300 to 1000. years.
3 But what the staff is currently concerned about is 4 what should be meant by substantially complete containment 5 and how they will look at that. DOE apparently in the first 6 package came back with something which was closer to their 7 liking. I do not know that I want to read these. Most of 8 these have to do when you come down to the bottom line of 9 each of these comments is regulatory uncertainty. These I 10 think are the only two or at least two of the main ones 11' where there is some regulatory uncertainty. And at least-12 part of the complaint was that DOE was now postulating some 13 failure rates.
. 14 They are in a sense on the horns of a dilemma, DOE 15 that is. They postulate that there is never going to be a 16 leak in anything that they have put in, but how do you do a 17 QA package that says that you have an absolutely perfect 18 package that you are putting in. On the other hand if you 19 postulate at a tenth of one percent that have leaks, the 20 staff behind me askss ree whiz, if you are inspecting it is 21 your leak tech so bad that you cannot detect a tenth of a 22 percent, and if you detect a tenth of a percent why do you 23 not fix it and not put them in that way. So what will be 24 sssumed as a failure, as the number that will go in that are 25 initially perforated is somewhat up in the air. I l
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52 lh 1 One would expect it to be quite low given the leak 2 checking and handling provisions which they have, and they 3 are still discussing what that will be. I do not know to 4 what extent, but there a set of waste package comments that 5 you have seen. There is also a set of waste package 6 questions which have to do with things like the quality of 7 the water that will be assumed, and what reliance they want 8 to put on cladding, and some others on the state of the 9 level of undetected defective closures which will be shown 10 to be less than one percent. That is what I alluded to a 11 minute ago.
12 Leak rates have a different criteria and assigned 13 goals which I maybe can answer questions on or the staff car.
gg 14 if you have questions, but I do not really want to try to 15 summarize and list then. I think that probably is much of 16 what I had.
17 The research program that I have heard of other times has to 18 do with can you find some way in which you could corrode a 19 hole through this stuff under some set of conditions which 20 comes up in here some. The thing which I do not see 21 discussed though may be that if you did perform a small 22 perforation in it does it make any difference or can you 23 take crodit for it for the next several hundred years when 24 that is your only mode and it is still above the water 25 table. I do not quite know why I cannot see anything on h Heritage Reporting Corporation (202) 628-4888
53 1 that, but maybe I was not looking into the right place, or 2 maybe for sume reason they do not want to take credit for 3 it. I do not know. That is all I had.
4 5
6 7
8 9
10 11 12 13 g 14 15 16 17 18 19 20 21 22 23 24 25 l 1
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54 llh 1 MR. MOELLER: Questions or comments?
2 MR. STEINDLER: I had a general question. I 3 understand, I think I understand most of the issues or 4 comments that are raised. What I don't understand is how
\ 5 they relate to the characterization of the site as a 6 suitable place for a repository.
7 They tend to focus in on the material issues on 8 what does the material look like once you have picked the 9 repository and you are about to emplace or you are about to I
10 tell somebody that this is what you want to do.
11 It is not very clear to me that the site 12 characterization portion of this magnus opus that DOE has 13 turned out even needs to have a section on the waste package 14 per se.
15 MR. SHEWMON: Yes. But I think in a sense, I mean 16 you are right, but I would accuse you of semantic quibbling, 17 or the problems of inadequacies of the language or 18 something, because if you think that it is important indeed 19 isolate this waste, and the canister and waste package as a 20 part of this, then it ought to be reviewed adequately and if 21 I take you literally then either they ought to have another 22 opus on the package or we end up saying well, that is a no 23 never mind for now. Maybe later we will worry about it and 24 that makes me uneasy, too.
25 MR. ORTH: Let me say that the specific place llf Heritage Reporting Corporation (202) 628-4888
55 lll 1 where the waste packaging does enter into it is as a source 2 term.
3 MR. WELLER: Dr. Steindler, let me add something 4 to that, because the waste package will have an effect on 5 the environment, and vice versa. This is an interface
! 6 there that you can't neglect.
7 There may well be peroxides, for example, produced 8 from radiation effects alone which will in turn'have an 9 effect on other waste packages surrounding. There will be a 1
10 thermal effect. So there is that interface, that 11 interactive effect that I think is rightfully a portion of 12 the site characterization program. I don't think you can 13 view the waste package as something in isolation which you 14 can go off and do in a laboratory and just come back and 15 stick it in the repository you have just characterized.
16 MR. STEINDLER: I agree. And that is basically 17 Don's point. It is a source term. But your commentary goes 18 well beyond source terms. I mean, you are concerned that 19 DOE may not know how to scale corrosion results from coupons 20 to the full blown canister.
21 MR. WELLER: That's a part of it.
22 MR. STEINDLER: But I mean, isn't that a detail 23 which is well beyond the characterization of the site and 24 the influence?
25 MR. WELLER: We view generic site characterization l Heritage Reporting Corporation (202) 628-4888
56 lll 1 programs including laboratory testing, including laboratory 2 testing on the geochemistry and other aspects, outside of 3 waste package.
4 MR. STEINDLER: It's a different story. I 5 understand that. Okay. I accept Paul's commentary that I 6 am quibbling.
7 MR. MOELLER: Other comments or questions on this?
8 MS. MOODY: I have a slide on waste package.
9 MR. MOELLER: Fine. Go ahead. We have time.
L 10 MS. MOODY: Sure.
11 MR. MOELLER: While Judith is going to the podium, 12 back to Dr. Steindler's comment. Of course, if you had a 13 perfect waste package I guess you could say any site would 14 be acceptable.
g 15 MR. ORTH: I will disagree with that, too, because 16 there's all those criteria which are completely packaged 17 independently.
18 MR. SHEWMON: Yes, that's true. You are right.
19 MR. ORTH: There's a whole bunch of disqualifying 20 things, no matter what you put down there.
21 MR. SHEWMON: Can you explain that?
22 MR. ORTH: Sure. Such things as vulcanism, just 23 to pick something not completely at random. They don't care 24 what you add. You're disqualified. There are some ground 25 water restrictions, there's various other restrictions.
llh Heritage Reporting Corporation (202) 628-4888
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5" l )- 1 MR. MOELLER: Your ground water travel time 2 applies regardless of tha package, sure.
3 MR. ORTH: So even if you-put nothing down there 4 you still could not use the sites.
5 MR. SHEWMON: And don't ask why it.is a danger to~ 'l 1'
6 the public. It is our policy.
7 (Laughter) i 8 MR. SHEWMON: Okay.
9 MR. MOELLER: Dr. Moody, go ahead. ,
10 MS. MOODY: I have made four points with respect l
11 to the waste package program.
12 As you can see here, the first one I say is'that I 13 don't think, not only in the SCP but in their' site-study l (} 14 plans, that there needs to be further consideration of what 15 they expect the waste package performance to.be. And of 16 course tied to the waste package performance we get back i 17 into things that we have just talked about very briefly, and ;
18 that is what is the waste package material composition' going 19 to be. I 20 And it needs, in terms of its definition, both 21 laboratory and in situ testing, short and long term.
22 In other words, I think that there is, regardless 23 of what you can say geologically, about the site, I'think 24 the waste package still should be in terms of the engineered i
25 barrier system, should be an important component part of the Heritage Reporting Corporation (202) 628-4888 i
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-i 1 repository itself. j 2 And this is the reason why we can talk also about 3 where the waste packages are. going to be emplaced either j 4 horizontally.or vertically. There has been no decision.of 1 i
5 course made on that. I l
6 Going to the site itself, the critical thing with !
7 respect to the waste package is any water that could be j 8 present in the repository coupled with heat and radiation 1
9 vill have an effect on the long term _ stability of'the waste 10 package itself.
11 So we get back to this classic thing that the 12 decision on what the waste package is going to be composed 13 of has not yet been made but it is important in terms of the ;
i 14 long term stability of the waste-package itself as an l 15 individual part of the total repository.
16 So that is what my emphasis is in terms of the 17 waste package.
18 Go ahead.
19 MR. SHEWMON: In your next to the last point there 20 you are saying that there could be chemistry in which the j 21 corrosion products of the waste package would influence the i 22 behavior of the rock in some essential way?
23 MS. MOODY: No. What I was trying to say here is 24 what is going to be the longterm stability of this material 25 that composes the waste package in term" of the short and Heritage Repo.rting Corporation (202) 628-4888
59 .i 1
)' l' the long term.
2 And the long term of course I guess we can say is' j l
3 300 to 1,000 years. . That is the only point I was trying to 4 make.
1 5 MR. SHEWMON: Well, my guess is they can find one ]
6 but I share'your frustration of not knowing which one they-7 are going to find yet. )
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8 MS. MOODY: That'= correct.
9 MR. MOELLER: Any other questions or comments on j I
10 the waste package? i 11 Pault 12 MR. SHEWMON: Dade, Jack pointed out, you have my 13 -memo of May 19 here and one thing that I had not gotten
~
14 into, the staff feels that there must be, what I'have called 15 there a confirmation testing program-that goes on after the j 16 package is in place. And they also would like to do some- l l
17 observations on the full scale package. (
18 I think at least in my somewhat hazy memory these l 19 merge into one. It again reflects Judith's comment some 20 that you do not know what the package is so it is hard to 21 say what kinds of interactions it is that are likely to 22 occur.
23 MS. MOODY: That is right.
24 MR. ST9INDLER: I guess I have at least a couple 25 questions.
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l In one of the comments thereLie some concern about' 1
2 not being able to understand what the DOE means by fill the 3 standing water.- And Ifassume they'are talking about the
)
4 bore hole.
5 MR. SHEWMON: Yes.
6- MR. STEINDLER: . Which' leads to'two questions. )
7 One, in the geology.section, if I have permission 8 to go back a little -- j 9 FR. MOELLER: Sure.
10 MR. STEINDLER: -- the issue of fracture flow 11 versus non-fracture flow seems underplayed from what little j 12 I have read. And I don't know whether_that matches your i 1
13 concern. It' strikes me-that that is a critical issue if.you l l () 14 insist on describing this thing as an unsaturated site.
15 Even if that cannot be resolve. dearly, or is' going 16 to take a little doing, were you able to make any sense, i
17 Paul, out of this question of how much water can you get j l 18 into a bore hole and does it make any. difference whether it l 19 is 5 liters, which has been assumed or 10 liters,.which it l
20 might be, or 20 CCs which it could be if.you push the drain 21 hole in?
22 Does any of that really make any difference as far 23 as you can tell?
24 MR. SHEWMON: You mean to the corrosion 25 possibilities? ,
Heritage Reporting Corporation (202) 628-4888
f 61' O 1 an srsruotsa: re , to cae corro so=
1 possibilities. - 1 3 MR..SHEWMON:' It gets back to, can you tell me- .;
.4 what the package is, and I will make a guess on that.
]I 5 MR. STEINDLER: Okay.
6 MR. SHEWMON: I think the staff's concern -- you 7 know, you cannot prove absolutely that it would.not if you .
8 do not'know.what the package isi is part of it. And though 9 it is above the water table, whatever the geologists call .
)
10 this, I forget right now, you used it a minute ago --
11 MS. MOODY: Above the saturated zone. d 12 MR. SHEWMON: Thank you. Then there is perched 13 water and inhomogeneities of f.ber; and no design execution
. 14 is ever executed perfectly, and so yes, it is unlikely, but .
15 it is not absolutely -- If water can perch up'there it can ]
16 perch down here someplace,'I guess is the concern.
l:
17 I think it is very improbable and would be a small i
18 fraction. Your question of does it.make any difference -- ;
19 probably not. But that depends on what they end up with as.
20 a design.
21 MR. WELLER: Dr. Steindler, let me add something 22 in that, because we do have a point paper which addresses 23 waterline effects, a package in which.a portion of it would i 24 be submerged and the other portion in air or steam 25 environment. So although we, I think we took out'the point.
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(_) 1 paper which asked them to define what they meant by filled 2 with standing' water, I am not sure it makes any difference 3 no matter what answer we would have gotten, because we do, 4 we are concerned about waterline effects, though, and that 5 is the important point.
6 MR. STEINDLER: Yes, you also had some commentary 7 in the thing that I looked at about heterogeneous attack by )
8 water across a cylinder, for example, which struck me quite 9 frankly as being awfully nitpicky.
10 It may be an important issue but I simply could 11 not follow that, j
{
12 MR. WELLER: The point paper about the term, the )
13 use of uniform corrosion?
() 14 MR. STEINDLER: No, not uniform versus -- the 15 uniform corrosion issue I think, Paul, is addressed 16 adequately. Somewhere in here, and I am not sure I want to 17 take the time to try and find it, you had a concern that a 18 portion of the --
19 MR. $HEWMON: If you look at the first item of the 20 waste package, at least Comment 1, there are questions about 21 homogeneous environment when you are probably going to have 22 at best wet spots, if you have any water on it at all.
23 MR. STEINDLER: Yes, right. And whether or not 24 the fact that you have wet spots in spots and not 25 homogeneously around say a cylinder surface, I frankly could I () Heritage Reporting Corporation (202) 628-4888
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() 1 not understand why that should make that much difference to 2 raise it to an important level of comment.
3 MR. WELLER: I think the point of the comment is 4 that we saw the DOE viewing thu characteristics of the !
5 repository as some homogeneous entity.
6 MR. STEINDLER: Yes. Yes.
7 MR. WELLER: And that is the essence of the point 8 paper. We disagreed with that.
9 MR. STEINDLER: Okay. Well, I guess what I was 10 looking for, and by the way, I was looking for that in a 11 number of the things that I have read, is some measure of j 12 how important that is to uite characterization.
I 13 My contention is, my reading is that this is a 14 fourth order effect at best. Whether you agree with that or 15 not is maybe a separate issue. But I somehow could not 16 figure it was a very important issue.
17 MR. SHEWMON: You do me a mild injustice. l 18 MR. STEINDLER: I'm nitpicking.
19 MR. SHEWMON: Because if you don't have water, 20 there is no crap game in town, is my impression. In moist 21 air, homogeneous corrosion, or uniform or whatever the words 22 are, probably the stuff will last for 10,000 years perhaps, 23 certainly for a few hundred.
24 So if you are going to find any corrosion effects 25 at all you have to put water there is my guess.
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64 j 1 MR. STEINDLER: When_somebody.says' unsaturated,
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2 they'od not necessarily I:think mean that there is no liquid 3 water and for example --
4 MS. MOODY: That's correct.
5 MR. STEINDLER: -- I know the interim testing that 6- is being done.right now is'done in a nominallyLaveraged 7 unsaturated _ system that has periodic episodes of' liquid-l 8 ' water impinging upon whatever you are testing, be it a-metal j 9 sample or a glass sample, or UO2 or whatever it is.
10 And the scenario that you pick on what'happens in 11 detail, and then you transfer that-into the lab to try and I 1:2 get a handle on the phenomenon.
13 It is reasonably important' . But I think the-
)
() 14 unsaturated system does have' liquid water, does have 15 opportunities for periodic transport and periodic corrosion 16 by whatever the mechanisms are.
17 MR. SHEWMON: The liquid water that I have heard 18 about at previous meetings here, and you have attended more q
19 than I have, is in the pores of rock and sort of maintains a 20 certain vapor pressure that doesn't run around.
21 One can hear about rainstorms periodically, but if 22 you are down 1,000 feet I at least haven't got the 23 impression that the geologists thought that this ever came, 24 you know, the 100 year rainstorm ever penetrated down that 25 far, or if it did, it was 100 years, that there was these Heritage Reporting Corporation (202) 628-4888 e_______________-.__-_---- -- - - - - . - - - - - - - -
65 r b
(_) 1 questions of stopping, how it flowed, what re-evaporated, 2 and a whole bunch of other questions.
3 MR. STEINDLER: I don't have any answer either, 4 Let me make two comments.
)
5 One, when we visited the Nevada site, and we 6 climbed around the mine shafts, we got our feet wet. That's 7 Point 1.
8 Point 2, there is the unopened, the unresolved l l
9 question of fracture flow, or the extent to which fracture l
l 10 flow is important.
11 MR. SHEWMON: But you are down a couple of strata.
1 12 It's a question certainly to be looked at. I l
l 13 MR. MOELLER: On the fracture versus matrix flow, r- 14 could the staff remind me what you said about that?
(_ j 15 It is not in the -- or I don't recall seeing it in i 16 the summary, in the Director's summary. It was lost, or I 17 just can't remember. J 18 MR. POHLE: My name is Jeff Pohle, hydrogeologist 19 on the staff.
20 No, we did not address that directly because it 21 really wasn't our objective to debate everything about the 22 site right now but to review the plans to get the 23 information to make those determinations. '
24 MR. STEINDLER: Paul would accuse you of 25 nitpicking.
() Heritage Reporting Corporation (202) 628-4888
66 )
1 MR. POHLE: But that is an issue that DOE is
'l 2 looking into to address, and particularly the conditions.on ;
1 3 looking at the point where under what conditions there is a: !
l 4 transition from matrix to fracture flow and that is the j S . thing they want to get a handle on, and then base their 6 predictions on'that or' analyses on that.
I 7 MR. MOELLER: But you did not comment on that even 8 in terms of ground water'. travel time? ,
- 1 9 MR. POHLE: No. Our comments would be directed on I
10 the adequacy of the studies to what issues are going'to be 11 looked at or to gather the information to'try to answer.
12 those types of questions.
13 MR. STEINDLER: I found that the absence of the 14 topic, particularly in light of an explicit. ground _ water 15 travel time restriction, to be puzzling. .'And I was going to 16 make that in a summary, but we might as well.--
l 17 (Simultaneous voices)
I 18 MR. STEINDLER: -- understand why you left it out.
]
, 19 (Simultaneous voices) l l
20 MR. POHLE: -- unless we consider that in a gap ir 21 their program.
22 MR. CHERRY: I am Don Cherry, Section Leader of 23 the Hydrology and Geochemistry Section.
24 I think the point is that we reviewed this for 25 inadequacies and so what you are hearing is that we ,
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'l; 67' 1 inferred, there is an inference.here that they have proposed !
(f L: -
l 2 in our estimation' adequate studies, or have a' study. plan for j 3 that. {
-I 4 Now, in your review-of'the SCP, you think that j 1
5 that is not adequate. But that -- So you are looking at a I 6 very limited review here, only for inadequacies.
7 MR. STEINDLER: Okay.
8 MR. HINZE: But Don, the second' paragraph of 221, 9 the second general concern is that some of the plan field 10 studies and activities may not be sufficient for a' test 'l 11 hypothesis. I 12 MS. MOODY: Yeo.
13 MR. HINZE: That is your statement in the summary. d 14 MR. CHERRY: Yes, that is true. But we looked at 15 and we have in our point comments some areas where we think 16 they are not getting adequate infonnation.
17 But other than that, they've planned a rather 18 comprehensive program, but we are getting down to some 19 details, you know, areas that aren't being sampled and such.
20 And also, we have to discriminate between what is 21 going to be proposed in the study plans versus what is in-22 the site characterization plan, and we had to-make a choice-23 of details that we thought we need to then look at in the' 24 study plans.
25 MR. MOELLER: So, throwing this back at you, you O a ri e- eerei 9 cereer eie-(202) 628-4888
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'11 are saying that in terms offground water travel. time, l
2 whether it is matrix orLfracture flow,-is indeed important; 3 however, either one, you believe that the DOE staff, their I
4 plan is adequate to address this question or two,. it is.
5' going to be covered in.a study plan which you will later ;
6 . review and you will be happy to do it at that time. I 7 Is that what I am hearing?.
8 MR. CHERRY: Yes.
9 MR. MOELLER: . Okay.. j 10 MR. CHERRY: I think that is a proper 11 interpretation.
12 MR. MOELLER: Okay. Thank you.
13 MR. ORTH: -A small observation.
-j
() 14 MR. MOELLER. -Yes.
15 MR. ORTH: We have mentioned several times or q l
16 questioned several times what is the relationship:between 17 site characterization and materials, getting back.to Paul's 18 issue.
19 One of them is that fundamental question of what l 20 is in the water. All waters are not the same. And if there-21 are variations in water, with episodic variations, that is 22 going to affect how the materials behave.
1 23 A little bit of water getting on the canister and 24 then drying out later on. Is the canister still warm? You 25 leave a deposit. If you have a humid atmosphere, there is
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() 1 some more attack goes on.
2 So somewhere in there we do have to have some more 3 fundamental information on what kinds of water at various 4 times people are going to be exposed to before you can 5 select the materials in essence, but you need the materials 6 also early on. So I am not sure how you quite resolve that.
7 But very soon in the business you need the water, 8 before you need the materials completely.
9 MR. SHEWMON: Let me ask one other question of the 10 geologists or geophysicists, or whatever.
11 When we were back under water, on some of the 12 other sites, one could talk about a finite amount of oxygen 13 and probably oxygen exhaustion, without replenishment.
14 I have the impression that this mountain breathes 15 a good deal more than - -
16 (Simultaneous voices) 17 MS. MOODY: Well, you have to, it is going to be 18 an oxidizing environment. You cannot postulate.
19 MR. SHEWMON: It's no question of exhaustion, it i 20 is air in effect which is down there. Is that -- ?
21 MS. MOODY: Most probably, unless you start 22 reacting the water with the material itself and then in the 23 production produce hydrogen, or methane.
24 MR. SHEWMON: No, my concern or question right nor 25 is only about the oxygen potential. And you are saying that
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(_) 1 will stay about -- there is enough breathing so that the air 2 will move in and out. We haven't got much of a sink, so I i
3 am not -- ,
4 MS. MOODY: That's right. Yes.
a 5 MR. SHEWMON: Okay, 1
6 MS. MOODY: Most probably. j 7 MR. MOELLER: Yes. Gene?
8 MR. VOILAND: Don mentioned that one could j l
9 consider that the waste package is really the source term. 1 10 There are some places I think in some of the very many j
11 papers received that it may be that what you put around 12 that, a barrier that you had around that, may contribute by 13 reducing the diffusion of air and so on. Some clays are
() 14 pretty impermeable.
15 MS. MOODY: That's correct.
i 16 MR. VOILAND: And I don't know what happens. i 17 Maybe if you pack that with swelling clays and it gets 18 moist, it gets tighter.
19 In my discussion with Quality Assurance thin 20 afternoon I am using that as a bully pulpit to talk.
21 MR. MOELLER: Okay. Well, sa we sort of wrap this 22 up, I guess I was left with a concern on the discussion of 23 the matrix versus fracture flow in that the staff says they 24 are willing to accept it -- this is one of their points --
25 because it will be covered in a study plan.
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f)- 1 I wonder how many other key: issues ~maybe are not-2 -being'addresed at this time because they are going.to be !
t 3 handled later?
1.
4 Are there other key items that are in that ~ I i
5 category?
'l 6 MR. WELLER: I would like'to address this point 7 again.
8 MR. MOELLER: Okay.
9 MR. WELLER: I still- don't quite understand what
~
10 the concern is. That in the-SCP they have failed to 11 recognizo the potential for water flowing'through' fractures, ,
12 d is that the concern be.ng expressed'here?-
13 Because the} ilave certainly hypothesized. in that, i
,)
14 and all the permutations andicombinations of all fracture
]
15 flow, episodic fracture flow, all matrix flow,Rhas been 16 discussed in there, and they are trying to put together a~
17 program to ascertain what is the most appropriate 18 hypothesis.
19 And even if the truth is understood, they are 20 still evaluating the potential of making certain simplifying l
-l 21 assumptions as potentially justifiable in a performance-22 analysis.
23 So there is another perspective there. And it is 24 not clear that the deficiencies in the --
25 MS. MOODY: I think that is the major point when ,
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(_) 1 you look at performance assessment, and you look at trying 2 to model the water movement in the Yucca Mountain site, that 3 their basic first line methodology is just to consider 4 homogeneous flow, which really, given this particular rock, 5 is not valid.
6 So I think part of the problem looking at the SCP 7 and your comments in the SCP, that is one area where I would 8 say that there should be a little bit more strength and 9 issue that the development of the hydrologic modeling given 10 the high probability of both types of flow is non-trivial.
11 MR. WELLER: We certainly agree. And in our point 12 papers we have addresed the need to justify these 13 assumptions, identify them and certainly justify them, in
() 14 two or three locations. -This is essentially the same' point.
15 MR. HINZE: Dr. Moeller?
16 MR. MOELLER: Yes.
17 MR. HINZE: When I read this Section 221, the 18 summary of the geohydrology program, I immediately read into 19 it fracture versus matrix flow. I think a geoscientist 20 reading this would, and knowing the site, would immediately 21 read that in.
22 I think this is a matter of emphasis --
l 23 MS. MOODY: Yes, that's right.
24 MR. HINZE: -- of whether one mentions some of {
a 25 these topics such as the chemistry of the water and the
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1 fracture' flow.-
i 2 If we deem it.necessary, I'think that it might 3 help the totality of the readers to provide examples related- )
d 4' to some of these topics. j 5 MR. MOELLERi Fine. Another comment from the i l
6 staff. Go' ahead.
7 MR. CHERRY:- Don Cherry again.
8 I just want to also clarify another thing. It is
]
~ ~1 9 not that we are~ going to pick up things in the' study plans j 10 that.aren't covered here.
11 What they have-laid out is their overall program, 12 and then details.will be provided in the study plans. :What 13 we were saying in the hydrology aspect is that there is-a
() 14 rather extensive program.- We have commented on some details 15 that we found insufficient maybe. But you are talking about 16 the fracture' flow versus matrix flow. They have laid out a L
17 program that is going to investigate that. And then the I i
18 details are going to be picked up in the study plans. 4 19 MR. MOELLER: Don, I think 'you have: justified your 20 position. If indeed you are happy with the manner.in which 21 they are going to address it, then fine.
22 I am reminded though that you are only going to 23 review 20 percent of the study plans. So again, we have to j 24 keep that in mind.
25 Well, then let's move on to the last item for the Heritage Reporting Corporation l
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) .1 morning. We will turn the floor over to Gene voiland, and.
'l 2 it will be talking, he'will be leading us in'our discussion j 3 of the geotechnical engineering.
4 Gene?T 5' MR. VOILAND: Thank you. ;
6 Well, when I first volunteered for this !
7 . assignment, I was somewhat at sea as to what geotechnical l
8 engineering was, so I asked a few questions and I guess I- ;
9 found out what it wasn't. But I didn't get very many !
10 specific answers exactly what it was.
I 11 But I tend to think of any engineering in terms of j 12 some sort of engineering project.
)
13 MS. MOODY: One of the. things that is very. l
.I 14 critical is rock mechanics. One area'thatLis.very critical.
(]}
15 for geo-engineering is rock mechanics.
16 MR. VOILAND: Sure. And anyway, in'the conduct of l
17 most engineered projects, there is a. formalization that one .;
18 goes through. ;
l 19 Usually you come up with some sort of conceptual i 1 -
20 design in the development of criteria, go through a Title I )
21 design, and then a Title II design.
22 And that is fairly general all the way through.
23 And in this discuscion, the only thing that I am really j 24 addressing here is the ESF Title I. I don't think we have 25 any other nearing design effort of that magnitude, and I
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75-(f 1 besides thatLis what is most'important-rightLnow.
2 So:in considering-the ESF,'I. guess'the first 3 question.that one has in mind is'will it do'the job.
4 We have specifically to look t some questions as.
5 radiolc 71 cal safety, . the preservation of the isolation 6~ characteristics of the utility,. evaluation of test. programs:
7 and so on.
8 And when one thinks of that, I guess you really-9 - have to think of the test facility as doing two jobs. It-l 10 doesn't do just one job.
11 The first job it does is to provide the test-bed 12 for the development of information which is thought
.13 important to the ultimate project, the description of the 14 repository itself.
15 And so from that point;of view, one then 16 subdivides a little further'and says will the.information 17 coming out of that be adequate, will'it serve the needs of 18 the program.
19 Also, ask, you have to ask the question will the 20 tests interfere with each other. And these have all been 21 brought up.
22 And will this test facility impact'on the 23 repository itself? That is thinking as a complete-separate, 24 individual kind of a thing. It is an experimental shaft 25 that is looking to testing.
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() 1 Now, its number tw9 job is that it is part of the -
2 repository or will be at some point in time. It will deal j 1
3 with the question of the ventilation and other matters. We 4 are not sure what its function is there.
i l 5 But then again you have to ask the question, will ;
\
l 6 it perform that appropriate function and will the safety i l
7 requirements and the regulatory requirements and all of l 8 those things be met?
9 So there are those two kinds of things. 1 l
10 Now, when I looked through and looked at the j 11 concerns, and the various discussions, and reviewed the I
12 various discussions that we have had, talked about all of 13 that, the question that seems to keep coming up all the
]
14 time, is it adequate in determining the kind of information 15 that we are ai'ter.
16 So that is really from the test facility's side of 17 things. '
18 Its role in terms of its being part of the l 19 repository is probably received -- and I think this is the l
l 20 consideration that NRC has had, looking at this thing. j 21 Now, I have asked some questions about what is the 22 Title I design, what kind of paper governed that? Is there 23 a definition someplace of Title I, and do we have a 24 conceptual design, do we have criteria, and so on?
25 And that is a question I would like, and I have
() Heritage Reporting Corporation (202) 628-4888 :
,77' h 1 talked with NRC, and I have gotten'some elaboration,. but I 2 think it would be useful for everybody here to hear how they 3 feel about that aspect of it, because'so much of this kind 4 of depends upon definitions of terms, and.upon' expectations.
5 If somebody expects a certain thing out~of!the 6 Title I and the person who is designing it has a different 7 idea there is going to be certainly conflicts.
8 So I think I would like to ask somebody from NRC L 9 .to give us their view of this design process for Title I.
10 how it went. And we can interrupt and.do that now if'they 11 are willing to do that, or leave that for later.
12 MR. MOELLER: They are nodding that they are 13 ready. Let's go ahead and hear that.
14 MR. GUPTA: I have some handouts.
15 I am Dinesh Gupta, geotechnical engineer, of the 16 staff.
17 MR. MOELLER: Pick up a microphone up_there, 18 please.
19 MR. GUPTA: I have a couple of definitions of 20 Title I and Title II certifying DOE's definitions.
21 MR. MOELLER: Thank you, Judith.
22 MR. GUPTA: Thanks.
23 This is the first definition here of Title I, and 24 there is a reference to some DOE documents here.
25 I will just read it, because it is a definition O rie 9- 9erei - c rer et -
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) I that is DOE's definition, utilizing the design concepts or i
2 criteria that have been prepared in the conceptual design l l
3 phase.
4 Sufficient design needs to be performed in Title I 5 to firmly fix the project scope and features.
5 6 The understanding here is that DOE first would 7 undergo a conceptual design phase in which the concepts 8 would be developed and then proceed with a Title I design 9 that would fix the project scope and features.
10 11 (Continued on the next page) 12 13 15 1
16 j 17 18 i 19 20 21 22 23 24 ,
4 25
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( 1- MR. GUPTA: The second viewgraph I have here
- 2 further clarifies the difference between Title I and Title 3 II. This is from an Atomic Energy Commission procurement 4 regulation. In back it is really described as a written 5 statement which gives the extent to which the services of 6 the architect / engineer services are included.
7 In defining the Title I, it provides the - .it 8 asks the A/E to provide the necessary topographical and 9 other field surveys, test borings, sub-surface 10 investigations, preliminary studies, sketches, layout plans, 11 outline of specifications. Prepare reports including 12 estimates of cost of the proposed project and all other 13 structures utilities and the pertinence is there too. So
(} 14 basically it's a preliminary design effort which is done 15 subsequent to the conceptual design.
16 The Title II part fixes the design further. It's 17 really a process in which you finalize the design effort and 18 issue the drawings for bids, and get your costs and also the 19 --
20 Title II is defined as provide complete design of 21 the work, including preparation of all required l preliminary 22 and final working drawings, specifications, estimates'and-23 contract documents. Assist in securing, analyzing and 24 evaluating bids or proposals for construction. . So, I hope 25 that' clarifies the distinction between Title.I, Title II,-
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() 1 'and before that the conceptual design phase.. R 2 MR. MOELLER: . Wellanow, what did you find wrong
~3 'with the Title I?- You know, you said it was incomplete, 4 that it was --- it' needed to be . corrected. And you were #
5 saying that you should -- or-several people have.said we 6 should complete those corrections before we do Title II. . )
7 I'm nLt sure I see the difference, nor do I' understand' fully.
-i 8 what your criticism was of Title I.
9 MR. GUPTA: Well, the basic' concern that we have-10 identified in our point papers is that based on these 11 definitions we would expect DOE to proceed with Title II )
12 design as an extension of Titio I. You'just:fillLin the 13 details, fill in the blanks, elaborate on the design work' 14 that you have completed. Based on our review, we are not 15 certain if DOE can and would be Male to do' that.
16 Or would it be a design effort that would be l
17 written to correct deficiencies in Title I design? {
1 18 MS. MOODY: That was the point of my whole l l
19 comment, is about the design itself and the sense that Title 20 II is supposed to engineering-wise follow Title I. iAnd when ;
21 Title I itself hat had' strong criticism for-valid reasons,- :j 22 how can you move from Title I to Title II? !
i 23 MR. GUPTA: Are there'any other questions on~this? !
24 MR. SLEWMAN: Is the document we are reviewing now I 25 supposed to fulfill the requirements for Title I or Title
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81' O 1 112 4 2 MR. GUPTA: There-is clearly a regulatory 3 uncertainty on that.
4 MR. NATARAJA: I'm Mysore Natarel1, section j 5 leader, Geotechblical Engineering.
6 I would like to elaborate =on this point. We have 7 to remember that the site characterization plan is based on-8 the Title I. design, and that's what we are reviewing right 9 now.
10 MR. SHEWMAN: I don't understand. When you say 11 it's based on, you mean Title I is complete and this is 12 part of Title II, or not?
13 MR. NATARAJA: No, the descriptions provided in p/
14 the SEP are from the Title I design. We have not seen 15 anything from Title II.
16 MS. MOODY: I know, but that's my. point. How can 17 they start Title II when they have not -- when you, NRC, 18 have not evaluated completely what was done in Title I?
19 MR. GUPTA: If Title II were to-be an extension of l
20 Title I, then there would be no problem. You are just 21 looking at additional details.that DOE wouldffill-in in 1 22 Title II design. The concern here is that Title II may not 23 be just that. It may have to be something to correct the 24 deficiencies in Title I. That's what the concern is all I 25 about. l l
8 i
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..i 82 l' MS. MOODY: That's the point.of my question too, 2 is that they have-to take into. consideration the'. f 3 deficiencies'in Title I to move to Title II.
4 .MR. GUPTA: Yes.
5 ' MR . MOELLER: What would be wrong -- what's wrong 6 with correcting the deficiencies in Title I as'you' move 7 ahead with. Title II?
8 MR. GUPTA: Okay.. It's something to do with our 9 regulations. When we review the SEP, that's where we get 10 the opportunity to make a statement of objections, comments I 11 and concerns to DOE's program on site characterization.
12 There's nothing wrong, but the question is whether NRC gets 13 to comment on those revisions in a timely fashion and in an 14 appropriate manner.
(])
15 MR. MOELLER: When you do Title II.and finish.it, 16 do you in a sense throw away. Title I, because Title II is 17 the one most people would want to see'I presume, or not?
18 MR. GUPTA: Title I would be would be sort of-19 meaningless.
20 MR. MOELLER: Right. ;
21 MR. GUPTA: As DOE is proceeding with Title II' j 22 right now, they would be doing the work on say, for example, i
23 subsystem design requirements document. They have a new !
I 24 package for Title II design. Title I would definitely -- I 25 the work would become obsolete.
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() 1 Now, if it were to be just an extension, the Title 2 II work would be an extension of Title I, then you wouldn't 3 have all these issues.
4 MR. VOILAND: But, if I could just add, the basic 5 problem we have is everything in the SEP is based on Title 6 I. It's not just the shaft, its the testing that is 7 associated with the shaft, it's the breakout they do down 8 below. If those assumptions in Title I aren't valid, then 9 there's a ripple effect through a good portion of the SEP.
10 MS. MOODY: That's the whole point.
11 MR. VOITsAND : It questions a lot of what we are 12 reviewing.
13 MR. SMITH: Or to put it another way, if you em 14 foreuee it in the -- at least most of the engineering d
15 projects that I have been associated with proceed into Title 16 II, you really haven't answered everything in Title I, then 17 you run into a real problem sometimes. Then you have got to 18 correct it in how you approach that design in Title II. And 19 indeed, you may not be able to correct it.
20 MR. GUPTA: Yeah. In this particular case we are 21 further dealing with a problem here that DOE did not undergo 22 the conceptual design phase that you would normally do --
23 MS. MOODY: That's right.
24 MR. GUPTA: -- before Title I designs.
25 MR. MOELLER: Gene Voiland. !
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) 1 MR. VOILAND: My question was, you'know, you have 2 shown us some definitions here, which is helpful. But now -;
3 when DOE undertook the Title I study, it undertook-it ;j 4 through a series of contractors. And when we go back and-5 try to reconstruct what kind of quality governed the 6 performance of those contractors we have troublo. So my-7 question would be, fine, we know what should have been done, 8 what was done? Did'they adequately do a. conceptual design?
9 Did the Title I that they do really do this?
10 Also, we say that the Title I-is supposed.to 11 develop the design to firmly fix the project's scope and 12 features. And on the other hand, what we are facing here is 13 a real catch-22. We are designing a facility which is
() 14 designed to gather information for the use in designing the 15 facility.
16 If we knew all that information that somebody else 17 mentioned, I think Don over here, then we would know 18 precisely how to do this. We would know precisely where-the 19 drifting should go. We should know exactly everything. But 20 we don't do that.
21 So, I guess, thank you. I think you have answered 22 my question.
23 MR. MOELLER: When will Title III be done?
i 24 MR. GUPTA: Title III is after the construction as 25 built. That's really a checking of what was done.
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() 1 MR. MOELLER: Okay, a back check.
2 Okay, thank you.
3 MS. MOODY: I know, but that's getting to what has t
]
i 4 been said already. It's a' major problem with the program 5 that if no conceptual design was done, and then Title I-has. a 6 been done in a rather imperfect manner, then now-you-are --
7 what's going to happen in Title II? l 8 MR. VOILAND: I guess my_ reaction would be that's 9 one of looking at it. On the other hand, you could look at l 10 it another way. And that is that we know that there is a-11 lot of data that's not available that we would like to-have.
I 12 If somebody had started out and said, hey, we're going to do j 13 Title I and then we are going to conduct a peer review, and 14 then from that peer review, in depth, we'are going to revise 15 and update Title I and then be ready to go ahead with our j 16 Title II. l l
17 So in a sense, this is what has been happening.
l 18 NRC has been conducting that kind of review. So you can !
19 either look at Title I as being sort of a failure because it 20 hasn't addressed everything that it should, hasn't given us. I 21 exactly what we want. Or we can look at it as a success, j 22 because it has produced a point of departure based on upon 23 what was available to the designers of that Title I.
24 Now we can proceed ahead to fix it if it requires 25 fixing. We can do the things that you do when you have non-
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() 1 conforming items. You can reject it or you can compare it 2 or use it as it is or whatever.
3 So, I think we've gotten a lot of information 4 here. Most of the concerns have been sort of related to 5 what data do we use? Have we used the right data? Bob, do 6 we need to gather new data?
7 MR. STEINDLER: Gene, I'm still a little confused.
8 Why is it not possible, albeit expensive, time consuming and 9 inefficient, but why is it not possible to make corrections 10 in the system at the Title II stage, and run through Title 11 II, having been told.that, hey, your Title I isn't any good 12 and you should have done this, that and the other thing, and 13 sum all those comments and' changes and corrections in Title 14 II? Is there any reason why that can't be done?
15 MR. VOILAND: No, I think you can probably do it i
16 any way you want. What you have got to do is identify those 17 things. But, as you say, it could be inefficient. Because 18 as you go down the course of Title II, you may have found 19 that you are off on a trail here which fails, because you 20 needed something --
21 MR. STEINDLER: Yes, I understand that. But, I I 22 guess I am going back to the original point that I was 23 trying to make before. Why be prescriptive to DOE and say, 24 hey, now you guys can't start Title II until you complete 25 Title I? What for?
l
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() 1 MR. VOILAND: Well, to take the position of NRC 2 is, I think, maybe their position is let's get their 3 attention on this. We feel very strongly.about the 4 importance of having the appropriate point of departure for- !
1 5 Title II. l 1
6 MR. MOELLER: The Staff wants to speak, Cliff. )
7 MR. SMITH: I just was going to say one thing,'and 8 maybe this is what Joe is going to say. I'm not talking _
I 9 about the repository now. I'm talking about most-engineered.
10 structures. Let's take a building in which in the Title I.
11 phase you are doing a lot of exploration, soil analysis and 12 so forth so you know how to do the foundation engineering 13 and so that you know how to -- so that that building is 14 going to stand once you build it in Title II.
[}
15 Now that's something that is darn important that 16 you get right in Title I, because otherwise when you get in-17 Title II and it starts slipping on you, then you have got a 18 major repair job if indeed you can. repair it. Now, there I
i l 19 are other things that you can perhaps not do as good a job 20 in Title I and you can catch and fix it in Title II. Now, 21 when we get to this repository, quite frankly it's unclear- ,
22 to me -- Joan, I'm look at you -- as to whether or not the l i
23 Staff feels that we've got the major issues in Title I that. j 1 24 would lead us to go to Title II. And the others that we 25 don't have, we can incorporate as we move ahead.
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( ). .1 MR . BUNTING: I'm' Joe' Bunting, Branch Chief.
2 I think unfortunately we've gotten off in a l
3 semantics struggle with. Title I and Title II. We were .;
i 4 coming at it from the standpoint that we expected in'the SEP 1 5 to be looking at the design that DOE would'use to construct i
6 the exploratory shaft facility. That's the point we are -J 7 trying to get at. , -)
8 If you read our point' paper you will see that we 9 .have a host of discrepancies going back to not even all of 10 ,the requirements of Part 60, have been reflected in that 11 design, such as performance confirmation.. We don't see no- 'l j
12 long term in situ tests for waste package,' seals. So,.you-13 know, we are not sure what that impact would be on a design.
14 So, we are coming at it from the standpoint that 15 we don't think that the design we are looking at is 16 sufficient for the Commission to have signed-off on its-17 regulatory obligation to make statements of objections or no j 18 objections. So, somehow or another we need to see how this 19 is going to be accommodated. And we need to see what's it 20 going to look like. l l
21 Now, earlier on Mr. Linehan, John indicated that 22 in order to get resolution, we have to become involved in a 23 process. l 24 MR. MOELLER: In order to get rid of what?
25 MR. BUNTING: Get resolution of this issue.
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() 1 MR. MOELLER: Resolution, okay.
2 MR. BUNTING: We would need to become involved in 3 this design fix, if you call it that. Ignoring Title I, 4 Title II or whatever. But the fix we envision means going 5 all the way back to looking at what are the requirements in 6 the regulation that need to be incorporated in the design.
7 Do you have the data you need? What's the decision criteria 8 leading to each step of the way? l 9 Now, whether DOE would choose to re-do Title I and 10 document all these things and then move on to Title II, we ;
i 11 didn't try to prescribe those steps. But quite clearly, if 12 the answer is going to be new Title II, we expect to go all 13 the way back to the baseline looking at the data itself and '
(} 14 the requirements itself leading up to a satisfactory Title 15 II. We want to be a part of that process and be able to see 16 what the criteria are for these decisions.
17 We may have messed things up by trying to say fix q 18 it in Title II. In doing that, in no way do we mean to say 19 that Title II is a logical extension of Title I as you have 20 seen from these definitions. Our point paper makes the 21 point that we don't think it is. We don't think it is a 22 logical extension. We think some major re-work has to be :
23 done. Whether you need to re-do a whole Title I or not, we 24 didn't try to specify that.
25 MR. VOILAND: I may find myself in the enviable
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() 1 position of agreeing with the NRC and DOE at the same time.
2 I certainly concur with the statement that was just made. I 3 think that embodies my own ideas.
1 4 On the other hand, what it does say is that you' 5 cannot do an appropriate Title I until you have described 6 what you want that facility to do. I think what has 7 happened is that there has been an evolutionary change in 8 the requirements. I think that the Title I was based upon 9 some sets and see -- I think, Bill, you made some comments, 10 criteria of change. I think that's the case. )
11 I'm not sure until you actually see, for example, l
12 some of the more detailed documents, what are the test plans I 13 that are coming up. We haven't seen very many of those.
14 Can you really determine whether this initial design is what
(~}
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15 it is, the placement of tests, the interrelationship 16 interferences, the zone of interference, until you have a 17 pretty good idea in fair detail of what you're going to do.
18 Those are very difficult. It's just not easy.
19 Again, in the afternoon we talked about quality 20 assurance. There may be some other ways of doing things.
21 MR. MOELLER: Don.
22 MR. ORTH: I guess the problem I've had for quite 23 some time, is trying to separate Title I, or conceptual 24 design or whatever semantically we want to call these l 25 things, for the repository, from Title I for the exploiatary
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1 shafts. About half of two-thirds of things we've said, 2 we're talking about, are talking about'the' repository, not-3 the exploratory shaft.
4 The. purpose of the'exp1' oratory shaft is. exactly.
5 that. There are a great many things we.have to find out-6 when we go.down there. 'And, yes,;there are things we have-7 to know going back to'that part.of it, before wefget'into 8 the design of the repository itself.
l 9 But we haven't been separating those things..
10 We've'been overlapping these you need to have,for what I'd
- 11. call Title I, in terms of not having in'the sense'that Cliff' 12 was talking about. 'You want to know what you're doing. You 13 want to get down-there and have the base data. You have to 14 have that data before you build your edifice.
15 But that's what you need for Title I, if you will, 16 of the repository. The exploratoryLshaft'is a separate 17 category. And I think we've been confusing.these 18 MR. SMITH: Except for one thing.
19 MS. MOODY: No. Because the. problem that you have 20 with that is that the exploratory shaft still has to meet 21 NRC regulations, because the~ conception is that the shaft 22- becomes a permanent part'of the repository.
23 MR. ORT!!: That may be absolutely true.
24 MR. SMITH: That's what I was going to say.. If 25 the shaft is intended to become an integral part of.the O eritaee aeroreine correraeien (202)' 628-4888 p
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() 1 repository, then I submit.that you're really'into a'first 2- phase of the design of the repository.
3 MR. ORTH: I agree. ~But you don't need quite as 4 much as you do for the complete repository. And I think:if- 2 4
s 5 we're going to go'that route, we'll end up -- personal 6 opinion -- in the little catch-22. You can't build a 7 repository without the shaft, but you can't build'the shaft 8 until you know how to build the repository.
9 MR. SMITH: Well, I don't think anyone's raising-10 that. At least from what I heard this morning, what you-11 were saying, Bill, now Gene is coming back,.is there's a 12 feeling about whether or not we have approached this problem 13 properly, or all of the data is in to say how and where we
(} 14 ought to sink the ship. That's what I keep hearing over and.
15 over again. And, indeed, NRC is saying that~there are a lot 1 I
16 of questions that they would like to see answered. I don't' 17 see it as a catch-22. ,
18 MR. VOILAND: Maybe, one way of approaching it, 19 again, is just to ask ourselves or-somebody should ask 20 themselves a question. If we are going to build this as 21 part of the repository, this ventilation shaft, independent 22 of any test characteristics, what would we ask of them.
23 We would go through this same process. We would i
24 get some kind of definition of -- that facility, go through 1 25 a conceptual design. We' d do all of that. And I think that i
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s,/ 1. that is probably not been dealt with as strongly as it .)
i 2 should. Because it seems that many of the concerns have to l 3 do -- while it'didn't address 10CRF60. As a test facility 4 it doesn't have to. As a part of the repository, it 5 certainly.
6 So I don't know whether-if one went'back into the 7 history and the documentation, one would find those kinds of.
8 evaluation. It might be something to think.about.
9 MR. SMITH: I think there's another thing here 10 that's -- we haven't talked about it. But to.what extent isi 11 the schedule pushed, driving this thing? We put it-right on
.I 12 the table and --
13 MR. VOILAND: l That does not fall under~ '
(} 14 geotechnical engineering.
15 MR. SMITH: I know. But if that were not such an 16 overwhelming thing, I dare say that we might have a 5
17 different environment and atmosphere in which we were ]
{
18 approaching this.
j 19 MR. VOILAND: Well, the waste confidence finding 20 has addressed that issue in a way.
21 MR. MOELLER: Other topics? Gene?
22 MR. VOILAND: Well, yes. The other thing that I $
23 elected to do is to take a look again, at this-part of-the i
24 volunteer process,.the design acceptability analysis of DAA,-
25 and there were lots of people who have looked at the DAA
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() 1 from a kind of~ technical point of view. And the people who 2- conducted the DAA, for many a number, I felt that I, first- j 3 of all, was unable to -- anything of that sort. But I 4 -thought I would review it in terms of the process that 5 design acceptability analysis, and-I'went'through 6 fundamentally the DOE memorandum, review record memorandum, .]
7 on that. And these are just some thoughts about that. l
)
8 First of all --
l 9 MR. MOELLER:- Back,.the DOE review report i
10 memoran --
1 11 MR. VOILAND: Review record memorandum, 12 MR. MOELLER: -- record memorandum. -Is that a -:
13 common terminology, or why is it called it?.
{} 14 MR. VOILAND: I think that's the kind of I 15 documentation that is used to document a technical review --
16 MR. MOELLER: Okay. l e
17 MR. VOILAND: It's a formal kind of a document l 18 transmitted from DOE to NRC. And the purpose was, again, to 19 go back and try to qualify Title I. This' interest stemmed 20 from the fact that I've been trying to determine what kind !
- 21. of quality was applied in Title I. I guess I could make a 22 comment on that. And I met with an entity and learned about 23 some of the documents, and they're reported on in this 24 memorandum, documents that went back to try to assess what-25 kind of OA was being applied. This is a retro fitting. I
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5 95 l 1 guess it was this January that this particular report, I~
2 -can't give you its name right now,'the intent was to try.
3' - reconstruct and see if various contractors had 4 participated -- what kind of control, d 'esign. control, and )
5 what kind of quality assurance program they had..
. 4 i 6' 'As a'resalt, they ment out questionnaires'and they) 7 did interviews and=so on. I took a quick skim'of.that-8 yesterday. LWhat'it does is simply-ask people did you'do 1 9 certain things in terms.of control of this project. . And the i 10 responses.were -- or we didn't do it or we did.this or-we.
11 followed this or whatever'it was.
12 But the sum and substance of it was there.wasunot 13 a lot of formality. There were a couple of things in there.
() 14 The one that caught my eye was that -- did use something 15 called Project Control Manual. The quality assurance people 16 at NRC are chasing that down. But to me that' suggests that j i
17 there may be some fairly decent quality embodied in the !
1 18 process they use. These are things you do.- And design' 19 control, that suggests. quality.
20 The result of the DAA was that' they found that the 21 Title I was acceptable for the purposes they had. So-l 22 someplace, somebody, must have been using some kind process ?
23 control. Besides they're an architect engineer firm'and !
24 know how to do things. They don't know how to deal with the 1 25 NRC, but-you learn that in a hurry. -l Heritage . Reporting Corporation (202) 628-4888-I
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) l' So I think that's an aspect that's-being followed
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2 up. But when I looked at the-DAA here, it. appeared that j 3 that study itself was involved in control activity.- They.
4 classified this, as analysis project, as a level 1. They ,
5 developed a plan for the conduct ofLthe program. They put <
j 6 their own document control procedures'in. It's all' spelled 7 out in'this memorandum,. authorized appropriately,' set up an 8 administrative committee to overview it.- Did all'the right 9 things, and'their records and so.on' looked like they were 4 10 appropriate. .
11 To give you a quick summary of.what was done.
12 There were 27 engineers. This was done in a very short 13 period of time. It was done in a period of about two 14 months, an intensive effort. On the other hand, because it
{ ] 1 15 was done in a short period of time, it is likely that they- .] 16 didn't do everything, and they may have missed some things 1 17 and so on. 18 But there were 27 people, engineers and~ scientist,- i i 19 and then others were brought in as the need was felt. And 20 they divided themselves into three subcommittees. And what 21 they did was one of-the subcommittees established an' .j i 22 independent list of criteria. They went back, in a' sense,- ! 23 to the start, where one hoped that somebody did in terms.of 1 24 the originally Title I. They're trying to simulate what you 25 might do if you undertook the project. Those criteria were () Heritage Reporting Corporation (202) 628-4888
~ _ r 97 () 1 based on 10CFR60 and NRC comments one, two and three, 2 primarily. . 3 A second committee, at the adequacy of the - - And 4 the third addressed thefquestion of the patient. .They used' 5 a number of documents lto develop their~ criteria and'they
~
6 felt a lot of them, 282. When they_got through with their 7 evaluation, they' thought 93 had been fully addressed, 127 8 partially, and 63 not at all. It kind of catches your eye. 9 on the other hand, they did point out, again, this 10 gets back to function, that the_ design was an engineering 11 functional design. It was really aimed at the regulatory 1 12 aspects of it. This, again, goes back to the double nature 13 of the utility. And I think emphasis on the design was from 14 the first part rather than on regulatory. 15 But I felt that when they looked at.the-adequacy 16 of the data, they looked at it for the reasonableness of it, 17 appropriateness of the -- by which the data was produced, 18 the frequent uncertainties and the appropriateness of the 19 unit with the Title I design. 20 I'm not going to get into any of_the details. I 21 guess I viewed this from an overall. point of view. -I did 22 not want to get mired down in details. 23 MR. STEINDLER: I'm confused. You indicated the 24 process that was done by the contractor and the DAA. And 25 then I'm looking at page 13 of our section 2'in our book and O a rie se a rorei=9 (202) 628-4888 correr ei -
98-1 't i said part of the objections foremost isithe treatment'of 2 the applicable 10CFR60 requirements in DAA. .And they're
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3 objecting to the way the contractor.did that.. You just 4 described a fairly complete process. 5 MR. VOILAND: -What I'm describing la what the 6 people who did the DAA did. 7 MR. STEINDLER:- Hell, somewhere there's a' 8 disconnect between what -- 9 MR. VOILAND: Title I design still does not -- 10 MR. STEINDLER: That's ' not what ' this ' says. Maybe, 11 the staff will have to correct'that. 12 MR. VOILAND: Let me just continue. 'I' thought the 13 analysis was a pretty' good analysis. It appears to be quite (} 14 comprehensive. I-think it provides_some additional 15 confidences. I thought they did a fairly good job. ) 16 MR. MOELLER: Excuse'me a second. Now, of the 282 17 criteria, you know, you went over that 93 were fully q i 18 addressed and 63 not at all. How do those relate to Title l 19 10 part 60, which the staff said was not properly-addressed. 20 Is there a connect there? 21 MR. VOILAND: I do not know how important those 22 various criteria were. I suspect that this is'the basis for j l 23 the NRC staff. concern. They don't feel that the i 24 requirements of 10CFR60 have been well enough met. That's 25 an implication. And there are a whole lot of 4 Heritage Reporting Corporation-(202) 628-4888 ' I
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99' 1 recommendations that indicate -- ; 2 MR. STEINDLER: That's not what-they said, i 3 however. . That's the key difference. What they said was, -i
- i 4 'they're talking about the treatment of the applicable l l
5 10CFR60. And so there seems to.be, if I get this-right, - 6 your analysis of what you saw differs from what the staff-7 claimed they saw. That's an important distinction that 8 somewhere needs to be -- 9 MR. VOILAND: What are you looking at? - 10 MR. STEINDLER: I'm looking at -- remember that 11 black notebook that we got shipped to us at the hotel. 12 MS. MOODY: What page is that? 13 MR. STEINDLER: It's page 13 of section.2, the 14 last paragraph about the fifth line'-- or the fourth line. l 15 And I hope I'm talking apples and apples.and not apples and { i 16 oranges.
]
17 MR. MOELLER: What you're reading says that they l 18 did not address part 60? ) 19 MR. STEINDLER: The staff said that they didn't 20 like the treatment of the applicable 10CFR60. j l 21 MR. MOELLER: And yet in the in Gene's review --
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I 22 MR. STEINDLER: His analysis said they did. 23 MR. MOELLER: He said a group of 27 engineers.and-24 scientists, they were in three subcommittees, and the first j 1 25 subcommittee had as its task, " establish an independent list O eritage Regerein, corgeraeio. (202) 628-4888 _ _ _ - _ _ ____--__-_________ - a
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(,T) 1 of criteria responsive to the requirements 10CFR60." Well, l 2 then, they didn't do a good job, or at least the staff is 1 3 saying they didn't. 4 MR. VOILAND: You have a different opinion. On ) S the other hand, when you read the recommendations, you see 1 6 the -- recommendations they addressed. 1 1 7 MR. SMITH: But, Gene, as I read the Director's j 8 report, which is what this is, they're flat out saying that 9 there is an objection to; DOE starting construction of the 10 EASF, then they go on to talk about the whole adequacy of l l 11 the design control process. l l 12 MR. MOELLER: Okay. The staff has comments. Go l l 13 ahead. 14 MR. NATARAJA: If I may just clarify it. I think (^)) m 15 Dr. Voiland is probably talking about the adequacy of the i 16 design acceptability and the process itself, rather than the 17 results of the design acceptability. As I hear him, the way 18 he's describing the process itself, was done under a 19 adequate QA program, although we have found some 20 deficiencies in that, too. But the finding as to the 21 outcome of that work, whether that resulted in an acceptable 22 analysis of the Title I design is another matter. 23 MR. STEINDLER: There continues to be significant 24 confusion, I think, among the staff between quality 25 assurance programs and the assurance of quality. And I
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() 1~ think whatsI' hear Gene saying is that he's' looked at.the 2 ~ product and it's.a reasonable quality.in spitesof the fact' j q
-3 that may meetuall the. nits and picks of quality assurance. 1 4- program. In your judgment, this~is made the other way.
5 HR.'VOILAND: When they developed the ~ independent-6 criteria, obviously they made some judgments about that. 1 7 Whether those judgments were' correct er.not, I'm not sure. . _ I 8 I think that the staff.has looked at that.
.9 To continue on, Icindicated that the: staff has 10 reviewed itEin considerable detail, and they have. problems-11 with it. One deficiency is that?it appears that five --
-1 12 were not independent. Now, maybe they had some' involvement, 13 but not in the area of certainty. And they're quite proper-() 14 in bringing that out.
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102 (-) 1 MR. MOELLER: Absolutely. 2 MR. VOILAND: And the concern that Title 2 might I i 3 just be a kind of a rework of Title 1 and not a real 4 substantive study, and I think there is a concern -- I
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5 believe instruction on Title 2 clearly defines what is 6 expected. 7 MS. MOODY: Well, Dade,. can the ACNW request that 8 resolution of Title 1 be done before they start Title 27 9 MR. MOELLER: We can certainly suggest that to the j 10 staff, yes. ) 11 MR. VOILAND: I think, again, it gets back to that 12 fundamental question to Dade with what we know and what are 13 we asking. I believe that criteria have changed. (} 14 Certainly, the test program at tha' time was a gleam in the 15 eye -- 16 MR. MOELLER: Well, I need to hear some more on 17 the real reasons why you cannot correct deficiencies in the 18 Title 1 while you're doing the Title 2. I 19 Now I heard Cliff, and you know, that was I 20 thought a very good example that if you finish Title 1 to 21 construct this building and you're moving ahead with the i 22 pouring of the foundation and so forth, and you then you 23 later find that, you know, your analysis of the 24 understructure, the soil and all was incorrect or 25 inadequate; and therefore, the whole building's going to () Heritage Reporting Corporation (202) 628-4888
103 (_) 1 slip, well then there is no way to go back and correct that. 2 Now, am I to presume that exactly the same 3 conditions, or analogous conditions, apply here to the 4 repository. And if they do, then, indeed, they do have to 5 correct Title 1 first. 6 HR. VOILAND: I think, again, it gets back to the 7 question, what is important. I guess from the viewpoint of 8 engineering, I tend to think that the amount of experience 9 on the coal mining, offsite mines, so they're the kind of 10 mines we have in which we need to be able to tell the 11 engineers -- what you want it to do. I'm not telling him to 12 build me a coal mine, but build us an exploratory facility 13 that is also going to be part of the depository. He hasn't l l 14 done too good of a job. Maybe -- (')S w_ 15 MR. MOELLER: Jack. 16 MR. PARRY: I think one of the points we want to 17 keep in mind, that this is not a structure in and of itself. l 18 It's a laboratory, really, an underground laboratory. It 19 seems likely to me that if, in fact, sufficient care has not 20 been taken, the fine purpose of the laboratory, dissipation l 21 of the Title 1, then you might well be in difficulty in 22 Title 2. This comes up again in the staff's other comments 23 about test interaction and scheduling of the tests and so 1 24 forth. 25 MR. VOILAND: I think it's even more than that, Beritage Reporting Corporation j (202) 628-4888 J l
104 1 Jack, because it's an experiment in itself. Because you're 2' gathering information'as you dig the facility. You're 1 3 looking'for illogical stuff and other kinds of things as you 4 dig it. So it's a combination of many things. 5' MR. SMITH: I guess the thing that bothers me,. 6 Gene, is it's a little different than most. things we've 7 dealt with in a sense that here you're really seeking 8 through this exploratory shaft and what you do, to convince 9 an awful lot of people that if you decide to build a 10 repository here, that that's the right decision; that you've J 11 done what you should do. It's going to be open to scrutiny 12 for everyone. And it just seems to me you have to be very- > 13 careful to document everything and to make sure that when 14 you do go down, that your experimental plan is right and 15 everything leads to a logical connection and you can then 16 move ahead to your Title 2 design, and you don't have to q 17 back up. j 18 MR. ROILAND: I think that that's exactly why it's 19 NRC. They know that they got a licensed facility and have 20 to be in a position that they are just like Caesar's wife. I 21 MR. SMITH: The other side of the coin -- I'm not I 22 trying to get on a soapbox, but not engineers decide, but 23 the Congress of the United States decides that this is what 24 we want to do. This is the place we want to look at.- And 25 DOE is under incredible pressure on a schedule. So I would l Beritage Reporting Corporation (202) 628-4808
105 O 1 h ve to re 111 s v, eive er de of x v1=s to hoth the f 2 staffs of DOE and NRC, because they're both embarked on a 3 mission which is very, very difficult. 4 One is moving as rapidly as they can to 5 demonstrate to the American people that we can deal with 6 this problem, and the oth9r one is charged with-checking 7 everything they do to the T, that you can defend it, et 8 cetera, et cetera. It's a tough job. 9 MR. VOILAND: When you tell people you have to do 10 all of these things, they'll say, " Gee, it's frightfully 11 dangerous." 12 MR. MOELLER: Let's see, the staff has been 13 patiently waiting to speak. 14 MR. VOILAND: I would also say that I agree with 15 you. I think the staff has done well. They're operating at 16 about a ten million -- 17 MR. MOELLER: Go ahead. 18 MR. GUPTKA: If I just take a minut'e here to 19 clarify the recommendation that we have to this concern. ) 1 20 These are looking to the future, and the ) i 21 recommendation is forward looking that when the DOE starts ! 22 and goes ahead with the Title 2 design, the design process 23 that was at fault during Title 1 design,.is not sort of j 1 24 repeated. During Title 2 design, the staff would like to 25 ensure that the DOE uses a design process which does not
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106 () l' have the kind of deficiencies that we have identified during 2 Title 1 design. Our recommendation is sort of forward 3 looking, and not to look back as to what was in~the past. 4 MR. MOELLER: I don't. remember, but a quick-5 question. Did you point out the corrective action they need' 6 to take for this situation like you did in, essentially, all-7 the other situations? 8 MR. GUPTKA: Yes. 9 MR. MOELLER: You fairly clearly spelled out what 10 needs to be done. 11 MR. GUPTKA: Absolutely, yes. 12 MR. HINZE: Just very briefly, I reached into one-13 of these documents for a term, ADTF, at depth test facility. (} 14 And as I hear the conversation here, I really don't hear 15 objection to ADTF test facility. But it's more in 16 relationship to the exploratory shaft. And that's the 17 comment that I made previously, that we should start to 18 separate the underground workings from.getting down there. 19 And I'm not totally convinced that we should be more 20 concerned about the ADTF. That's going to be the horizontal 21 aspect of it, is going to be more important than the 22 vertical aspect, and particularly since that vertical aspect 23 is presumably on spot with the shaft. l 24 Perhaps, we can reach a consensus here that we-25 should get down there and really do the Title 1, which is O erita,e Re ,ereine co geraeien (202)' 628-4888
107 m (_) 1 doing the testing at the repository level. 2 MR. GUPTKA: Could.I just clarify one thing here. 3 MR. MOELLER; Yes. 4 MR. GUPTKA: When we talk about shaft, we talk 5 about the exploratory shaft facility which includes the 6 shaft, then the ground test area and then the entire 7 drifting. So our concern is with the entire facility, not 8 just the shaft. 9 MR. HINZE: I think it would be helpful if we 10 could separate those. 11 MR. MOELLER: Elaborate on that, Bill. I heard 12 you, but what you're saying, of course, they'll drill the 13 shaft. Then they'll go out sideways with the drifts, and {} 14 , from those drifts, within those drifts, they'll do a lot of 15 at depth testing. And you want those separated. 16 MR. HINZE: That's right. I really don't hear -- 17 we're not really discussing. We're in the position of the 18 drifts are, or how far they're going. We're not getting 19 into that. What we're really discussing is exploratory 20 shaft, the vertical aspect of it. And I think that's where 21 we're becoming, at least, I'm becoming confused. 22 MR. VOILAND: Bill, can you do that? 23 MR. HINEE: Can you do what? Can you separate -- 24 MR. VOILAND: Can you define that the underground 25 testing? There have been concerns about how much space you t~ (,s) Heritage Reporting Corporation (202) 628-4888 l 2
108 () 1 need to conduct your test.. o 2 MR. HINZE: The discussion that I've seen from 3 their work is that the interference problems have not all
-4 been taken into account, the contingency area and'so forth.
l 5 MR. MOELLER: Joe. 6 MR. BUNTING: I'm Joe Bunting. I don't want to 1 7 take' issue with the goal for which Dr. Hinze appears to be i B driving, but I do have to take issue with the way he i 9 characterizes the information in the report. We have-10 numerous examples in there in which we take~ issue with not-l 11 just a vertical shaft, but with the engineered facility. 12 underground. The size of the facility'is very cramped. The 13 tests are on top of each other. A lot of the tests would (} 14 take up a lot of the space have not been defined yet. We 15 don't know where this is going to be. 16' So we're very, very concerned with the facility. 17 Most of our write-up has to do with the underground portion 18 of that facility itself. So we're concerned about the I 19 location, and we're concerned about the vertical shaft. I 20 don't want you to take the view away from here that we have 21 not looked into the underground facility. And that's where, 1 , 22 really, the bulk of our comments are. ) l 23 MR. HINZE I stand corrected, Joe. .You're 24 speaking about it really from an engineering standpoint. 25 MR. BUNTING: Yes, sir, I am. ! l () Heritage Reporting Corporation (202) 628-4888
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109 () l' MR. HINZE: . And I was speaking about it from a 2- site characterization. We do have to make certain that we 3 cover both of those aspects. 4 MR. BUNTING: 'Yes, but even with respect to the 5 site characterization part of ourLeomments on the 6 underground have to with the extent of the drifting, the 7 direction in which the drift goes, .the features that are 8 going to be characterized, and is the program of 9 characterization underground really satisfactory. And so we 10 try to cover it all. 11 While I got the floor, if I could-take one more 12 minute, there's a prospectua here which hasn't come out. 13 It's been talked about; Dr. Voiland talked about the dual (} 14 purpose of the exploratory shaft facility. That is one-15 being experimental and the other being a portion of the 16 ultimate repository. 17 When we did.our review on the consultative draft, 18 we pointed out the fact that' DOE had not considered that 19 second role of the ESF, that is the role being a permanent 20 repository. 21 Part of the job of the DAA was to look at and show 22 that when you consider those requirements in part 60, they 23 had to do with waste isolation, that the design was 24 adequate. When you look at the regulation and you look at 25 the requirements in part 60, they pertain both to the () Heritage Reporting Corporation (202)' 628-4888 i
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'( ) 1 testing that would be performance confirmation testing, and 2 do-you have the design and adequate space to-carry those-out i
3 as well as waste isolation, getting into the location of the 4 shaft itself. i 5 That's where, when they went back'and'did the 6 design acceptability analysis, we're saying that, based on 7 the process and based on the results of~the deficiencies 8 that we have identified, we don't think you'made_the case, i 9 MR. VOILAND: Gene, is this the place to recess 10 for lunch? 11 MR. MOELLER: Why don't we break for~ lunch and 12 come back in an hour. 13 (Whereupon, the hearing was recessed to reconvene () 14 in one hour, this same day,-Tuesday, June 13,-1898.) 15 l 16 1 17 18 19 l 20 .l . 21 l 22 23 24 :< 25 O nerieaee gorein, correraeio. (202) 628-4888
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( l' A F T'E R N O O N SESSION 2 . 1:10 p.m.. 3 HR. MOELLER: The meeting will resume. 4 The next item is the coverage of hydrology and
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i 5 geochemistry and Dr. Moody.wil1 be leading that discussion.. 6 MS. MOODY: I have comments on other parts of the 7 program, but what I think we can d.o is we'll start out'with 'l 8 hydrology and geochemistry and if we have time, we can come ; 9 back and cover'the others. Is that okay? 10 MR. MOELLER: Yes, let's go with that. 11 MS. MOODY: Some of my comments will.be a repeat 12 of some of the key issues that Bill Hinze raised and some of 13 it will be perhaps new and different. (} 14 All right. My first point up here, notice that 15 geo-hydrology preclosure hydrology programs-and here we have 16 my first comment being made on post-closure because the 17 thermal effects, of course, of the waste. emplacement is 18 post-closure. But it, of course, is critically important in 19 terms of the total repository and the Yucca Mountain system 20 in itself. And I included here, then, this comment about 21 the subsurface hydrology of the Yucca Mountain site. 22 Now, one of the key points that.has already been
)
23 raised, but let me comment on it again, and that is that the l 24 key thing about Yucca Mountain, of course, is that the 25 repository is going to be placed in what'is called the' ) i I () Heritage Reporting (202) 628-4888 Corporation j __________________A
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-112 (l 1- unsaturated zone. And.the water table, then, of course, is
-2 the saturated zone. But one of_the' things that'I think most' 3 of you realize is that as'we go down the stratigraphic 4 column towards the saturated zone --'in other words, the 5 -water table -- the amount of fluid, the amount of water in 6 the rock increases as you go down the. stratigraphic column 7 until, of course, once you get to the saturated zone. The 8 rock then completely has the total amount of water that'it 9 is going to hold.
10 So that we have a rr.nge.then in the total rock 11 sistem, a rock in the water composition, just depending upon 12 where it is in the stratigraphic column. 13 We come to a point that I think has been raised, () 14 but it is one that I have always with me. And-that is that 15 the total number of drill holes needed for all the different 16 work that needs to be done, that is hydrology, geology, 17 geochemistry, geophysics, needs further identification for 18 integrated work to be complete. And also another. major 19 problem is, again, we come up to something that there can be 20 technical differences on and that is: What is'the allowable 21 geologically speaking total number of holes. 22 Now, I am not that much as concerned about the 23 holes that are drilled to 100 or 200 feet from the surface. 24 The number of holes that we' re particularly concerned about 25 hydrologically, geochemically and geophysics and geology is. l Heritage Reporting Corporation (202) 628-4888
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'I holes that'go right through the repository horizon down to~ l 2 underlying hard rock. .
3 And so the total number of holes that you drill; 'I. l 4 think for that purpose, all these different purposes, needs 5 to be fully evaluated in terms of the integrated work. 6 In other words, if you have a hole that you are j i 7 , going to get the rock from and that's the geology aspect of 8 it, but you also need that hole for continuous hydrologic 9 testing which then, of course, would be tied.into the _ 10 geochemistry in the sense that you could collect a fluid 11 over a period of time for geochemical analysis from that 12 particular location. ' 13 So, this is in my view a very, very critical and. 14 important issue for the site, not only in the short term,. 15 but in the long term in terms of total. stability of the 16 site. And I, of course, exaggerated-here because I said the 3 17 next million years. But, again, it depends on how you .] 18 choose to think about the site, though regulations -- EPA 19 regulations say 10,000 years, and one understands what those 20 regulations are. I even heard 100,000 years in one in terms 21 of continual monitoring potential seismic or earthquake . I 22 activity. 23 So, this is a question that leads to the ; j 24 possibility that ties into this. That you don't need-25 necessarily to consider or you should censider from a i O aerieaee erereine cergeraesen (202) 628-4888
'114
() 'l technical point of view the minimum of the total number of-2 holes that are needed and that you can just look at in terms 3 of the total stability of the site. 4 Now, this is another major problem and that is, 5 and we have talked about it already to some extent. And 6 that is hydrologic data. The best data that can be obtained 7 in terms of the Yucca Mountain site is from holes that have 8 been drilled specifically in the site itself. And, so, the 9 problem that you have, of course, is that you want to'use 10 the information that you are going to get from these holes 11 to develop hydrologic model. 12 And, so, we get tied into knots up here because if 13 you would think about the total number of holes that you 14 would like to have with all that available collected
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15 hydrologic information, you could think of a large number in 16 terms to get the "best" model both local and regional model 17 of the Yucca Mountain site. But it is a difficult number to 18 come up with to give what you consider to be a reasonable 19 amount of hydrologic data both locally -- and when I say 20 " local" here, we simply mean then it's within the repository 21 versus the area outside the repository site, itself. 22 Of course, there are some that would say that_in q 23 terms of the exterior to the repository site, you certainly i 24 can have a larger number of geophysics and hydrologic holes 25 external to the repository. And then there is the j i i () Heritage Reporting Corporation (202) 628-4888
115-( 1 discussion: Well, how many can we do exactly within the. s . 2 repository itself? 3 MR. CARTER: Judith, I wonder if I could ask you a l 4 question about the second part, the number of holes. I F presume what you wou]d like to see is' consideration given to-6 minimizing the number of holes that are drilled to obtain 7 all the information that's needed. Is that correct? 8 MS. MOODY: That is correct, yes. 9 MR. CARTER: The other thing, how would you put 10 anything quantitative on that? What's too many holes or too 11 few? I mean is it a dozen or 2217 You're not going to tell' 12 me, I bet you. 13 M3. MOODY: No , I'm not going to-try. I think-14 that that is a very valid question and I think one of the [} 15 things that I would say that when I talk about a minimum. 16 number with respect to locally being within the repository 17 site, I certainly would say that that should be less than 20 18 and maybe even less than 15. In other words, a minimum 19 number. But exterior to the site, itself, is something that 20 can be highly questioned and talked about. So, I think the 21 more difficult question, though I have put down here on:this 22 last point, both within and exterior to the repository, I 23 think the most difficult one in terms of decision making is 24 the number that's interior. 25 MR. SMITH: Judith -- Heritage Reporting Corporation (202) 628-4888
116 ("% (,) 1 MS. MOODY: Hydrology colleagues, what is the 2 number that is being postulated now for within the 3 repository? 4 MR. GUPTA: I am trying to recall the figure for 5 the systematic drilling program. I think both those holes 6 that are already completed and those planned, we'rs looking 7 in the neighborhood -- I can't be precise. I'm within, you 8 know, two or three, but a dozen at most. Maybe a couple 9 less, maybe a few less than that within the conceptual 10 parameter drift boundary. 11 MR. MOELLER: Dr. Smith? 12 MR. SMITH: Judith, I just want to make sure I 13 understand something. These are your comments on NRC's 14 comments on summary site characterization analysis. [} 15 MS. MOODY: That's correct. 16 MR. SMITH: Okay, these four points now are you in 17 effect saying that you don't think there is enough 18 discussion of this by NRC in their site characterization 19 analysis? 20 The reason I ask the question is because your 21 first one there on the thermal effects is captured in the 22 director's report. 23 MR. MOELLER: Yes. 24 MR. SMITH: And so I'm not sure whether you have a 25 disagreement with NFsC's approach or thoroughness on this or l () Heritage Reporting Corporation (202) 628-4888 i - -- - _ _ _ _ _ _
-117 I 1 what.
1 2 MS. MOODY: No. My purpose in citing these is 3' just basically the key points that I think are.very 4 important. And.you-are right that some of them -- see', I-5 did not have a copy of that director's letter. 6 MR. SMITH: I see. 7 MS. MOODY: So, I couldn't.tell you -- so~, what 8 you're saying here I guess with this first one is that I 9 agree with them. And, of course, this one is again emphasis 10 on the importance of the number of drill holes. So,.there 11 are a couple of comments in addition that I'll make that I-12 just put down because I think they are important for the 13 total program. 14 MR. SMITH: Sure. I understand. Jack just !
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15 explained to me that the information we have in'these black 16 notebooks was really not delivered until the other day, so 17 you hadn't had a chance to look at it. 18 MS. MOODY: Yes. I had my transparencies made 19 Monday morning. Monday evening, I get the -- , l 20 MR. SMITH: Right. 21 MR. HINZE: If I may, when does someone maks the j 22 decision about the minimum number being recommended by the j 23 staff? 1 24 MS. MOODY: The question is: When are the total l 25 number of drill holes decision going to be made or has it j
'O erieaee aegerein , cergeraeien (202)-628-4888 1
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.(_) 11 already been made in the SCP? I know, as you say, that 2- there-is a number that is quoted in the SCP, but is that 3 final?
4 MR. GUPTA:. Well, mostLof these things in the SCP 5 'are open-ended. You know, they always have the statement,- 6 "If additional information is needed,. we'll.go back in there 7 and put in additional facilities." So, I can't say it's a 8 closed issue. 9 Now, that. number was derived based on a number of 10 criteria. One of the objectives was.ta provide aerial 11' coverage within the conceptual parameter drift boundary. 12 That was one of the criteria that come up with'x-number of 13 holes. The distance becween the holes was based on some 14 work from hand samples from the Calico Hills unit, an
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15 outcrop. And looking at porosity and air permeability, one 16 reference wasn't available, but that work was done and 17 trying to find -- to be precise here -- the maximum 18 correlation range for those two parameters which was roughly 19 3,000 feet. So, that maximum correlation range I think was 20 used to setup the minimum number of holes required to 21 provide the aerial coverage within that unit. 22 Now, there are a lot of questions could be. raised 23 as to whether that is appropriate or not, but we haven't had 24 the reference. Okay, it's not available. And there are t
- 25 some other logical questions one could raise. Since that's l
l () Heritage Reporting Corporation (202) 628-4888
119 () 1 based on samples from the Calico Hills,_what about all thel
;2 other units, et cetera, that we've penetrated, will that be 3 representative, et cetera. And on and on and on you can 4 start generating questions on getting down to this level of 5 detail. 'But I think that's the logical process'where they 6 try to come up with the number of holes for this area.
7 MR. HINZE: When do you anticipate being involved 8 in those kinds of decisions? At the study plan level? 9 MR. GUPTA: That would certainly be a big item to 10 get in on that study plan. Absolutely. It's pretty 11 fundamental. 12 MS. MOODY: It certainly is. That's what I 13 assumed: That the finalization of the total number would be {} 14 15 done through the site study plans. Just a point of information for me, when the site 16 study plans come out,_does that mean that DOE is going to 17 begin the work before they've had NRC review or does it have 18 to go through the review? 19 MR, GUPTA: I am probably not the best person to 20 speak to this. 21 MR. LINEHAM: DOE is committed to get us the study 22 plans in a certain period of time. I don't know if it's 23 three or six months before they start the activity. And as 24 has been mentioned earlicr, we won't be reviewing all of 25 them, but we will have them far enough in advance if we do Heritage Reporting Corporation (202) 628-4888
120' () l' want to do a review.on them. 2 MS. MOODY: Do youithink'that one is important? 3 MR. GUPTA: As far as I'm concerned, if I had an' f 4 open it se in hydrology, based on:SCP comment, that would be j 5 one of my criteria for which study plans to choose.to do a l 6 detailed review on. .j 7' MS. MOODY: Now, what I did in this slide is just 8 combine into -- you can see these numbers come straight off .j 9 the comment sheets. And, so, what I have done here is just 10 simply again come back to individual comments on' hydrology. 11 And some of them, we have already talked about'in the sense i 12 we have talked about this in terms of drill holes, but it 13 also is tied to water and rock samples that are necessary 1 {} 14 for a multiplicity of laboratory work as well as in situ 15 testing. 16 And, of course, this is important in terms of the
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17 geology and the rock mechanics, for example. Of' course, the i i 18 rock mechanics people want to squeeze the rock and the 19 geologists, of course, would like to identify the petrology 20 of the sample and even the geochemist, of course, would like 21 to do some analyses of the rocks themselves. And so to try 22 to integrate if you have only got a finite number of drill l 23 holes in which you actually obtain rock and then potentially l 24 water as well, who gets what samples for what analyses and 25 what use -- let me tell you, in making this one, I know the O serie ee gortine correr eien (202)- 628-4888
i i l 1211 ') () 1 problem from allithe effort I put'into the salt program, but 2' it has to be planned and integration of how you are: going to 1 3 use the samples that you do en11ect. l a
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4 Of course, the water ones are the most simple in 5 some ways because you know.that the hydrologist and the 6 geochemist need those samples. ) 1 7 And I have said this here: Cross-correlation'of-8 rock and water sampling needs must be defined between'all' 9 people'before the new field work begins. , 1 10 This is ideal, I know, but at the same time, if 11 all the camples that are needed by geochemists as well.as 12 hydrologists,-geologists, rock mechanics, geophysics-and 13 engineering geology, there has to be some sort of agreement ('l 14 as to how these, which samples,are going to be used for v 15 what. And, of course, we get back to this problem that we 16 already talked about earlier this year and that is about 17 contamination of a particular water er rock sample in terms , 18 of the kind of analyses that is going to want to be done 19 with it. l 20 Some samples, that's not necessarily a difficult 21 point, but other samples for geochemical analyses, it is a 22 very valid point and needs planning in order to reach l I 23 certain minimum standards. 24 MR. STEINDLER: Are you saying that by citing 25 those hydrology comments and not making any particular note 1 Heritage Reporting Corporation (202)~ 628-4888 , i i l
122 () 1- of any one of them that you' agree with the' general' comment, 2 the bases and the recommendations that are found in those 3 seven comments that you've cited up there? 4 MS._ MOODY: Yes, I do for the most part.
- 5. MR. STEINDLER: Okay.
6 MS. MOODY: And what I am doing is just 7 essentially here identifying key things that applies to all' 8 those individual comments in different ways. -But I should 9 ssy this. I should have started out and said this that 10 certainly the hydrology section which I've gone through,. 11 read the whole thing, is very well put together.
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12 I have, obviously, some specific comments to make 13 about it, but well put together. {} 14 MR. CARTER: Judith, let me just see if I 15 understand the concern about the number of holes that are 16 used for site characterization. I presume there is also a 37 program now to, when the work on those holes are finished, j 18 that those would all be pingged or sealed or whatever. And 19
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I assume if you can seal the shafts, that you can seal those 20 kinds of holes reasonably effectively. Is that a bad 21 assumption or a good one? 22 MS. MOODY: Well, believe it or not, I have some 23 comments on the sealing program. I do not think at least i 24 our present knowledge of the site that that is not a 25 overwhelming problem. And it is not just simply because the O emieaee Reeereine correraeien (202) 628-4888 ] _______-_________-______________________.___________.__m_ . _ _ _ _ _ _ . . _ _ _ _ _ _ _
l 1 123 j
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() 1 total amount of rainfall, for example, that occurs in that 2 area is minor compared to some other sites that were j j 3 considered at one time. So that it can be handled I think ) 4 technically, but it must be considered and handled 5 technically. 6 We come back to, as you see, this is a specific I 7 comment on one of the comments in the pile. And that is q i 8 that again we come back to sampling because there is, of 9 cource, the request made that to get down with a certain l 10 number of holes to the ground water table, itself. And, so, ) 11 all I am stating here is that to collect as many samples as l I 12 you can, I said every 50 or 100 feet, but collecting those 13 camples with good criteria set up is important in termc of 14 doing geochemical analysis of the water, itself. And also
}
15 certain measurements that could possibly be made in the 16 field like temperature, pH, EH. 17 MR. MOELLER: Dr. Moody, can you do that sampling 18 external to the repository zone? You know, would you drill 19 down through the Calico out beyond the repository for them? 20 MS. MOODY: You have to drill below the repository 21 level in order to get samples -- you can continue to sample, 22 but your sample size may be very limited until you get down 23 into the more saturated zones, themselves. 24 And, so one of the reasons it is discussed that 25 sampling is important in a saturated zonc is to get some n () Heritage Reporting Corporation (202)' 628-4888
124 o 1 real hands-on-data as to whether or not the water is () 2 changing composition, geochemical composition because.we 3 know something about the surface waters and surface waters, 4 at least the data we have so far is that they are very 5 dilute waters that by themselves would not be inherently 6 much of a problem for any of the materials that will be used 7 in the repository, itself, including the waste package. 8 MR. SMITH: Judith, can that sampling be done 9 outside of the projected boundary of the repository and be 10 meaningful? 11 MS. MOODY: I think that it should be done, but 12 the only problem we have, Jack, is how much variation will 13 there be in the water in the saturated zone. So, all I can 14 tell you right now is I don't know.
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15 Any comments about variation in water composition? 16 MR. GUPTA: I think it is going to depend on what 17 the objective of the particular sample is, for example. Some 18 of the things could be just a quick look at some basic 19 natural tracers to get a handle on what ground water travel 20 time is and if the presumed flow path is strainht down from 21 the repository to the water table, you know, perhaps real l 22 close to the parameter of the boundary, I'd say a negative 23 finding would be good. Or if you actually found a natural l 24 tracer that Evans rapid flow, that certainly would be good 25 enough, being a very kind of negative piece of data. 1 (,-) Heritage Reporting Corporation (202) 628-4888
125 , _O 1 ^=d =ow eetei 9 1=ee whet ve= =eed fer the 2 geochemical transport: considerations, that'is a whole 3 'nother world in itself. 4 MR. SMITH: Well, can I ask a question? 5 MR. GUPTA: Sure. .I 6 HR. SMITH: I'm a little confused. I mean we all 7 agree the saturated zone is considerably below the bottom of 8 where we are talking about having this aquifer. So, I am a 9 little at a loss as to why you would want to have a great 10 deal of background on the geochemistry.of that water if'it ! 11 is considerably below the aquifer unless you are getting-12 that as background so that you might look at that with l 13 respect to the water up above that might penetrate. I'm a i 14 little -- maybe someone can straighten me out here. 15 And then that raises another question: 'if you. 16 start drilling holes all around the place between the 17 unsaturated zone and right down into the saturated zone, 18 then you obviously are opening up a direct path. 19 But forgetting that for a minute, other than -- ) 20 what is so important about sampling in the saturated zone 21 other than for determining the direction of that flow and 22 the rate of movement of that flow perhaps? 23 MS. MOODY: I think to a certain extent, you are 24 absolutely right. I mean_in terms of knowing the -- 25 collecting the water sample and testing it will provide O rie e rerei e cereer tie-(202) 628-4888
a 126 I) 1 additional information needed.for the hydrologic modelling 2 activity. ! 3 MR. GUPTA: .If you are going to do any geochemical { 4 modelling, you had best know the rock water chemistry. 5 That's the medium-that transport is occurring and -- 6 MS. MOODY: That's correct. 7 MR. SMITH: Yes, but I'm.just saying aboutithe 8 saturated zone, we all agree is considerably below the 9 bottom of where your aquifer is going to be-located. 10 MR. MOELLER: 'You mean the repository. , 1 11 MR. SMITH: The repository. Below where the 12 repository is. The repository is going to be built in an- . I 13 unsaturated zone.- " l {} 14 MR. GUPTA: Well, if you~are assuming zero release ; 15 now and forever, then no assessment of cumulate release is 16 necessary. That precludes the need for information, .I j i 17 guess. ! 18 MR. SMITH: Well, that is what I am.trying to get 19 at. Then the only reason that you want it-is primarily for 26 background at this point in time. 21 MR. GUPTA: Well, that and any prediction on 22 transport prediction you care to make. 23 MR. SMITH: In case there was a break, in case it l 24 did get into it? 25 MS. MOODY: That's absolutely correct. I Heritage Reporting Corporation (202) 628-4888
127. 1 MR. MOELLER: Paul? 2 MR. SHEWMON: What,are you going to do about 3 transfer from a ruptured. canister'down to the water table? 4 ' MR . MOELLER: .'Yes,..how does'it' move?' 5 MR. SHEWMON:. It seems to me'that is much more
'l 6 important than -- once ittgets down there,.it's much harder !
- 7. to study, so, you.may not be studying it. Or maybe you are-8 and you'll tell me about it. .
9 There are a lot of studies on the unsaturated. 10 flow. All we're looking at is one comment on'here where we' 11 asked for looking right at the water chemistry right at the 12 interface of the saturated zone.for the natural tracers, 13 basically. 14 Now, the point is you have got to take the 15 transport all the way from the repository, down-to the 16 saturated table and then add 5. kilometers to the accessible 17 environment. So, you have to look at that total' pathway. ; 18 And this is just one little~ comment on the system: ) 19 And there is a lot of - -again, a very extensive program to
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20 look at hydrologic flow and transport from the repository 21 out to the accessible environment. . 1 22 MS. MOODY: That's very true. 100 percent'right ) 23 on . - In the sense that you have to know and understand the 24 unsaturated zone, but also the saturated zone because that's-25 it, being able to have a predictive capability of if.there Beritage Reporting Corporation (202) 628-4888-
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(_) 1 is a breach in a container and not very far away we've got 2 this problem of the high fracture system and perhaps more 1 1 3 potential accessibility to the underground ground water than 4 normally might be the case because of the' fracture fault 5 system at Yucca Mountain. 6 But you have to be able to predict how the radio 7 nuclides are going to behave in that water if in fact there 8 is breaching of a waste package and some gets into the 9 underlying ground water. How is that key elements going to 10 behave in that water? Are they going to precipitate as 11 calites? Are they going to be soluble so that they could 12 begin to be transported? Those are some of the questions 13 that have to be dealt with. {} 14 MR. SHEWMON: If I look at another part of the 15 report, will I find anything approaching a mechanism for how 16 it gets down to the water table? Or do you postulate an 17 occasional deluge in which everything gets washed down? Or 18 do we know? 19 MS. MOODY: That's a very sometimes difficult 20 question. 21 MR. GUPTA: What is the preferred hypothesis is 22 that given some source term that some amount, that some rate 23 is released from the waste package and through the EBS, 24 which is not a great distance. The preferred or the current 25 preferred hypothesis based on currently available () Heritage Reporting Corporation (202) 628-4888 1 1 ll 1 _ _ _ _ _ _ _ _ _ _ - - - - - _ _ _ _ - . - - - - _ - - - - - - - - - . - - - - - - - - 2
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2 state, that the water essentially is flowing through a. l 3 porous material, that -- i 4 MR. SHEWMON: Is this flow by gas phased 3 1 5' transport? I q
-6 MR. GUPTA: I'm dealing with the liquid phase. j 1
J 7 pathway. 8 MR. SHEWMON: The porosity is continuous. 9 NR. GUPTA: That would be the most simplistic, 10 yes. And essentially that continuity is maintained. You 11 know, mass is conserved and the. amount of flux flowing ] 12 through --
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13 MR. SHEWMON: Can you look at the rocks to see if-14 it's continuous?' 15 MR. GUPTA: That's part of the program. 16 MR. MOELLER: Gene has a question. 17 MR. SMITH: This is just an information question. 18 I guess I tend to view this underground aquifer as a' sort of 19 a river that is meandering around down underground at some i 20 rate. And that whatever comes into it is like a little , 4 21 stream. And is there much'known about the movement of that i 22 underground river? 23 (Continued on next page.)
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130L 1 MR. STEINDLER: Through'whatever mechanism the 2 water comes down and enters it. If that is'a.large dilution'- j 3 factor, I think that that'is probably-'somewhat important. 'I' l '4 know a little_ bit about the underground water in Illinois, 5 that it ten'ds, some of the aquifers tend to start a'long way
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6 away and the composition changes slowly, slowly, slowly.. So~ 7 that is a curiosity. question. 1 8 MR. POHLE: The saturated tuffs or the1 aquifer-9 underneath the repository, in'and around the site, is a very-10 productive aquifer. So if you are thinking in terms of some , 11 dilution factor, I would say that would be considerable, j 1 12 But on the other hand, the fact would be that it 13 would have the capability of moving very quickly, at a 1 14 higher velocity, because of just essentially such high 15 porosity, that any induced gradient would make it move 16 quickly. 17 So if you are dealing with the accumulated mass, 18 you've got at any given point, I guess, dilution would be 19 advantageous to an individual. But in terms of accumulating 20 a release of mass over a fairly long time period, a higher 21 velocity would be working against you. So there are these 22 counter things you have to keep considering. 23 MR. VOILAND: It works against you only if there 24 is a fair amount of material. 25 MR. POHLE: Well, that depends on your source Heritage Reporting Corporation (202) 628-4888
131 ( 1 term. That is what it boils down to. That is very 2 important. 3 MR. CHERRY: Let me comment on your idea of it 4 being a river, though. I would not look at it as a river. 5 It is big lake. Okay. We have to look at the relative -- I 6 mean, it is not moving like a river. 7 MR. MOELLER: Paul Pomeroy. 8 MR. POMEROY: I just wanted to pose a question to 9 the staff for my own interest. 10 It seemed as though in Chapter 8 there was a 11 general hydrogeologic cross section presented that shows 12 essentially vertical flow through the unsaturated zone. And 13 that was taken from SINIC.
/~N 14 And yet in Chapter 3 of the SCP, which shows a
(-) 15 generalized East-West section quote "through Yucca Mountain 16 showing conceptual moisture flow systems under natural 17 conditions" close the quotes, and that is modified from 18 another source -- 19 MR. POHLE: It is from a lateral component? 20 MR. POMEROY: There is -- In Chapter 3 they show a 21 large number of conceptually horizontal arrows or 22 essentially horizontal arrows showing motion in the 23 horizontal plane or subhorizontal, in the various 4 24 unsaturated zone formations, the Tiva Canycn and the 25 Paintbrush, in the Paintbrush, at tne boundary of the () Heritage Roporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ - _ ~
132 () 'l Towanapaw' Springs and tho' Calico Hillsiu nit and in the. 2 Calico Hills unit. . l 3 Recognizing'that this is not a well known' subject,.
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5 'MR. POHLE: It is a hypothesis. 6 MR. POMEROY: That is one hypothesis.C-7 MR. POHLE:: Correct. , 8 MR. POMEROY: -And is the.other an equal 9 hypothesis, where there is just vertical flow? 10 MR. POHLE: I guess, based on - .The. judgment-I-11' would have to make, to me they would be equal. 12 Now, in the SCP, on that particular item, whether 13 that permeability contrast.in these higher layers results in (} 14 a lateral component of flow, I know of no hard physical data 15 -- 16 MS. MOODY: To back that up? 17 MR. POHLE: -- or observation.to back that 18 hypothesis up. That is part.of the plans to look at that.- 19 MR. POMEROY: Well, is the purpose of showing 20 those two' illustrations in Chapter 3'and Chapter 8 with a 21 great deal of difference simply to illustrate the 22 uncertainty then? 23 MR. POHLE: In a sense. Essentially.it is trying. 24 -- I guess one of our points on the CVSCP was just to lay. 25 out what you can discussion the text, what information you O rite R gorei , corror eion (202) 628-4888
133 e ( 1 have. 2 But it reaches a point where it becomes 3 interpretive and you are hypothesizing things. 4 Just literally lay out for us item by item what 5 have you hypothesized, and if you are leaning in a given 6 direction, and like this hypothesis more, that is all right. 7 You are starting to make judgments. 8 But the important part is to look at the testing 9 programs that will assess those hypotheses. 10 MR. CHERRY: Also, my comment on that figure that 11 shows the flowdown and across the boundaries and so forth is 12 a highly distorted schematic, too, and I would say might 13 work it against one of the more representative cross 14 sections that is a lot greater horizontal dimension versus a
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15 vertical dimension. 16 MR. POMEROY: Thank you. 17 MR. MOELLER: Dr. Moody, we have interrupted you 18 continuously. 19 If, though, looking at the clock, if you can 20 finish in 15-20 minutes, it would be helpful. 21 M5 MOODY: I don't think we will have any 22 problem. 23 MR. MOELLER: Thank you. 24 MS. MOODY: But again, this whole problem of 25 hydrology is exceedingly important. And one of the things () Heritage Reporting Corporation (202) 628-4888
134 () I that we have talked about briefly that needs -- well, all we 2 can say in that is how we can combine hydrologically 3 speaking the vertical plus horizontal flow, plus the 4 geochemical modeling capability. 5 So there is a series of very complex problems in 6 the modeling of the hydrologic flow in the Yucca Mountain 7 site. 8 All right. Let's get into geochemistry comments. 9 MR. HINZE: Judith? 10 MS. MOODY: Yes. 11 MR. HINZE: Before you do that, are you satisfied 12 with where we are in terms of the plans for proportioning 13 the fracture versus matrix flow? r~ ()g 14 MS. MOODY: You mean in terms of model assessment, 15 or what? 16 MR. HINZE: In terms of determining the proportion 17 of fracture versus matrix flow. Are you satisfied with 18 that? i i 19 MS. MOODY: That is a hard question to answer. 20 I am glad that it is recognized. I think that it i l 21 could be studied to a greater detail than is presently being 22 postulated, but maybe that will -- Because again, the i 23 hydrology section was one of those sections in which there 24 was a constant saying site study plans. So that came up, 25 will be addressed again, or will be addressed hopefully in 1 () Heritage Reporting Corporation (202) 628-4888
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135 /^\ i,,_) 1 the site study plans. 2 MR. HINZE: Thank you. 3 MS. MOODY: Okay. Moving into geochemistry. 4 Wha. I stated here is just I thought that a better 5 definition is needed for what minerals should have their 6 thermodynamic properties determined and-how will they be 7 used in non-equilibrium conditions, non-equilibrium 8 calculations. I 9 Most of the discussion is just stating that 10 information is needed on zeolites in particular,'but there ] 1 11 is a wide family of zeolitic minerals. And it would be a 12 little bit in terms of werk that needs to be done, a little l 13 bit better definition here of just is it only one or two of 1
/~S 14 them that NRC thinks should be done or should 12 be done or j 91 15 whatever.
4 16 But that is one problem. But the other problem 17 is, if in fact, for the most part, is certainly in the first 18 life history of the repository. 19 When I say that I mean the first 100, 10,000 20 years, whethee or not you are going to be under equilibrium 21 conditions is an open question. And this is information 22 that is important to have, but the calculations that are 23 usually done assume equilibrium. 24 Here is another series of comments on geochemistry l 25 from the summary SCA document. And I have just more or less () Heritage Reporting Corporation (202) 628-4888
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-() 1 stated some. key points from the summary itself. 2 And' clearly this-is something that I think '{ L3 everybody instinctively knows and that is a lot of the 4 different studies that'are being proposed to be done are. 5 tied besides to the longterm stability of the rock and-6 changing water compositions, is the impact that rcdionuclide 7 migration could possibly have. 8 So in order to determine whether or not-a given 9 radionuclides will migrate in the water in the saturated zone 10 means that you have to do some -- Mainly the work that has 11 been done in the past has been laboratory testing, given a 12 given water, ground water composition. 13 This is something that we know, that the Yucca 14 Mountain site has a great degree of heterogeneity in the 15 rocks, water and soils and of course those need to be 16 determined, and we get back to the question of samples that 17 we will have from core. But we also need in terms of the ! 18 waste package emplacement what effects that will have on the 19 host rock itself, that thermal effect. 20 And of course we have alluded to this next one ) 21 already. 1 22 That is, the radionuclides must be evaluated for 23 its potential migration properties given the specific Yucca j 24 Mountain site geochemistry after waste emplacement. 1 25 And the reason that I keep repeating this is I i () Heritage Reporting Corporation (202) 628-4888 j j i
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() 1 because we can certainly study the ambient conditions that 2 now exist in the Yucca Mountain, but the program demands 3 also that we have to have a better understanding of, given 4 the thermal heat load that is going to be involved in terms 5~ of emplacement of the waste package, we have to also. 6 evaluate as best.we can what is going to happen to that-7 site, and its effects in particular on radionuclides 8 migration. 9 And of course this is an old one that I-have 10 discussed in a publication called ONWE 321, and. that is that: 11 I do not think that KDs in the short term possibly are -- 12 Well, they are now presently being used and I understand why 13 the hydrologists like to use KDs. But I think for each () 14 given radioactive element or toxic element that we are 15 interested in in terms of radionuclides, each one of those j 16 is going to have to be individually better understood as to 17 how they are going to behave and potentially behave in the. 18 Yucca Mountain groundwater. 19 We also have this other major problem. And that 20 is the coupling of the hydrologic with the geochemical 21 models. And that is a major problem and I think from my !
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22 understanding of what is going on in the program, all you 23 can say at this point in time is it is being worked ,on. 24 Performance assessment of the site will require at l 25 some time trying to couple hydrology and geochemical models ! ) () Beritage Reporting Corporation
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m 138 () 1. to answer the question of potential radionuclides migration. . 2 This gets to a point that we have a bit alluded to 3 already and that is that it is-very hard to talk-about 4 whether or not the waste package can survive any potential 5 proposed conditions when the waste package container 6 material'has not yet been chosen, and that is a key point in 7 terms of the waste package itself.
- 8 And this is the point that we need in terms of why 9 do we need to test what the' ground water composition will 10 be, while this is part of it in terms of being able to give 11 a better prediction from say a long term laboratory 12 experiment.plus there has been some consideration given in 13 the exploratory shaft testing that a waste package or 14 perhaps container material could be tested in situ as well,
[} 15 which of course will need to be done in the long. term. 16 Yes. 17 MR. SHEWMON: Do we know or is it possible that 18 once this cools off some that minerals will plate out on 19 these canisters in the way that they do inside piping and 20 public water systems and so on? 21 MS. MOODY: I have to say that it is probable that 22 that could very well happen. 23 MR. SHEWMON: I have had some people that know 24 more about it than I do say that is the only reason-the l 25 steel pipes survive, not because of any particular I
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139 () 1. properties of the pi pe. 2 MS. MOODY: That is true. In other words, for 3 steel pipes I can tell'you they form probably an iron oxide, 4 it might even be magnetite, just depending upon what the -- 5 MR. SHEWMON: I think there was also t'alk about 6 calcium or other minerals coming out, not just an iron 7 oxide. 8 MS. MOODY: Oh, sure, it the tufaceous rock,- 9 absolutely certain. 10 And of course this one, this last one should not' 11 surprise you because I don't, in terms of the individual 12 radionuclides, there is only, batch sorption studies only 13 give you a certain amount of information'on maybe two or 14 three elements, but they certainly don't cover all the [" } 15 radionuclides that potentially could be leached out of the 16 spent fuel. 17 I think this is it, at least for the hydrology. 18 MR. PARRY: Judith? 19 MS. MOODY: Yes, sir. 20 MR. PARRY: One other point. 21' .You have been mentioning the radionuclides but 22 what about the corrosion products from the canister system 23 itself and in the case of the spent fuel zirconium? I mean, 24 won't.there be a tertiary effect possible from the presence 25 of those materials? () Heritage Reporting Corporation (202) .628-4888
p 140 llh 1 MS. MOODY: The waste package material? Yes. 2 Plus zirconium? Yes, absolutely. And that is why I keep 3 coming back, Jack, and saying what is the waste package 4 container material going to be, because it will have an 5 influence on the radionuclides. 6 MR. PARRY: Has that been addresed anywhere in the 7 SCP, the presence of canister byproducts? 8 MR. WELLER: Rick Weller. 9 Yes, we have a point paper that addresses the 10 issue of corrosion products from the canister interaction 11 itself affecting the local geochemistry. And perhaps then 12 in affecting in some fashion corrosion of other packages 13 nearby. 14 It is the issue of not only the environment having ggg 15 an effect on waste package but the waste package having an 16 effect on the environment. 17 MS. MOODY: That's right. You have to think of 18 both, or evaluate both, excuse me. Yes. 19 MR. SHEWMON: Now, that is the NRC staff. If you 20 read through the document here, they agree with what Marty 21 said earlier and say that materials, compatibility and 22 handlir.g is not related to site characterization as defined 23 by the Nuclear Waste Policy Act. 24 So these are addressed in future documents. 25 MR. HINZE: There is, in the U.S. Geological lll Heritage Reporting Corporation (202) 628-4883 i
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1 Survey response to the'CSDP statement that there is no 2 discussion in that document of the sorption of the 3 radionuclides on the manganese and iron oxides, and I am 4 wondering, that certainly apparently is a factor in other 5 areas in the Southwest. I 6 Is this concern taken care of in the SCP? I 7 FDI. BRADBURY: John Bradbury from the NRC. 8 Yes, it is. 9 MS. MOODY: Okay. My las't point here is irr l 10 geochemistry, is something that I have already talked.about-11 in terms of usage of KDs. 12 And basically I have stated before, in stating it 13 is inherently incorrect. J 14 You can do it, or it has been used in the past and [} 15 probably will be used in the future for a bit of a while, 16 but I guess one can say quite characteristically that the 17 individual radionuclides have to be studied in terms of this 18 reality in the real world. 19 And I think that is about all I have to say at 20 this point. 21 MR. MOELLER: Okay. Are there other questions or-22 comments on this area? 23 MR. ORTH: One small comment, or question, as the 24 case may be. 25 As you have worded it, Judith, system performance _( ) Heritage Reporting Corporation (202) 628-4888
1 4 ! 142 () 1 assessment modeling using KD is inherently incorrect for 2 many key elements. . 3 Don't you really mean that it is incorrect if you l 4 do it wrong? 5 If the KDs are properly defined and put in in i 6 terms of equilibrium rates and relative flows, the modeling j 7 is absolutely correct, isn't it? 8 MS. MOODY: I think it depends upon how you choose 9 to define KD, then, in order for it to be correct. 10 For example, if you have an element that is 11 completely soluble, well, you can handle that by saying KD I 12 is zero. 13 But it is possible that it could be done correctly (} 14 as long as you did it element by element. 15 MR. ORTH: Okay. 16 MS. MOODY: It could be done. It is just how you 17 choose to define KD. 18 MR. CARTER: If they are not doing it by 19 individual nuclide, how are they doing it? 20 I mean, are they taking one representative of each 21 chemical group, or something of that sort? They are 22 certainly not going it on a gross basis, are they, with 23 mixed fission products or something? 24 MS. MOODY: Any comment on that? l 25 MR. CARTER: I would think it would be very much l A (,,) Heritage Reporting Corporation (202) 628-4888 '
143 (). I radionuclides-specific. ( 2 MR. WELLER: Yes,.they are doing'it individually,. l 3 radionuclides by radionuclides. 4- MR. CARTER: This is Los Alamos, isn't it? 5 MR. WELLER: 'Yes. But I think the problem is that 4 6 they cannot simulate all the conditions that could be 7 expected at'the repository and there is no way that they 8 could experimentally do all of those things. 9 I think what Dr. Moody is bringing up though is 10 that if you assume the KD approach, that that approach, if 11 it is done without, as Dr. Orth points out, if it is done 12 incorrectly, it can lead to an over-estimation of 1 13 retardation. 14 MR. ORTH: That is fundamental. Anything you do [} 15 incorrectly will come out incorrect. I 16 (Laughter) 17 MS. MOODY: That is correct. 18 MR. ORTHi In overestimating.the retardation. ,
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19 MR. CARTER: Yes, but I assume there.is an l 20 implication here that it is being done incorrectly, and I j 21 don't think that is true. 1 22 The implication of what I am hearing is that it is ' 23 being done incorrectly at the moment. ! 24 MS. MOODY: What I have observed, and I record it 25 on ONWE 321, is that there has not been as much experimental () Heritage Reporting Corporation (202) 628-4888
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1 144 1 work done on the behavior of the key; radionuclides in which 2 you would define as the real. testing conditions that it may. J 3 or may.not have in the real environment. ( 4 And that is the main basis.of what I have had to . 5 say is that there has been too much emphasis in the past put- ., 6 on determining whether or not a given element is going to 7 form sorption. 8 There are elements in which that is not going to 9 happen, so'are you going to test to see how that element 10 actually does behave, in projected repository environment? l j 11 MR. CARTER: I guess your report dealt with BWIP ] 12 or something that you looked at on a generic basis, didn't i 13 deal specifically with'a program at Yucca Mountain and Los 14 Alamos? 15 MS. MOODY: It did not deal specifically with any - 16 rock type, no. It was just a general, overall view of 17 radionuclides migration? 18 MR. CARTER: Okay. Thank you. j l 19 MR. MOELLER: Gene. l 20 MR. VOILAND: If the DOE staff has-not done so, j 1 21 they might, want to investigate the Illinois Geological j 22 Survey. I 23 Kyros Cartright, who is currently-the director i 24 there, a number of years ago was involved with the work of 25 movement of a number of ions with respect to normal waste, O aerit ee Regereine correlation (202) 628-4888
145 ( () 1 not radioactive waste, sites, but garbage dumps and such. 2 They did a lot of quite sophisticated work. They 1 3 even looked at the aerobic versus anaerobic character of the i 4 sorption process, and they did it with actual soilsLand what 5 have you. 6 There may be-something of interest there. 7 MR. MOELLER: Martin? I 8 MR. STEINDLER: I will just make a comment. )i 9 First off, the reference that you have had up 10 there, JWB-13, does not make the statement that the systems 11 perform an assessment modeling using KDs is inherently l 12 incor.srect, at least I do not see it in the copy that I have. I 13 So I have to assume that that was a conclusion 14 that you came to from what you read in that comment. I 15 MS. MOODY: It was the Moody interpretation of it. 16 MR. STEINDLER: Okay. I guess I have a problem 17 leaving that on the record. I think that statement in fact 18 may not be quite right. 19 As Don correctly pointed out, if you know what you 20 are doing, and you define your KDs right, you can use KDs as 21 a method for performance assessment. 22 So the inherent, my problem is with the statement 23 of inherent, because I would not want somebody to talk away 24 from this meeting thinking that it cannot be done. 25 MR. MOELLER: I think it is again a matter of () Heritage Repo,rting Corporation (202) 628-4888
l i 146 I () 1. interpretation. If you want to cross that out, cross it l l 2 out. . l l 3 MR. STEINDLER: I am not crossing it, I am simply 4 making a comment. 5 The other point is, I think there are sufficient
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6 literature reports on the use of both KDs in obtaining, the 7 methodology used to obtain KDs, that the DOE folks are aware 8 of not only at Los Alamos but elsewhere, so that I really 9 don't think it profits them a whole lot for us'to refer them 10 either to the Illinois Geological Survey or some other i 11 places. < l 12 I was trying to determine whether or not there was j 13 anything in this JWB-13 commentary that one ought to i {} 14 highlight for DOE, but it seems to me it is a fairly 15 straightforward comment that says hey guys, make sure that I 16 the method that you are using is applicable to the Yucca 17 Mountain system. 18 We cannot very well fault them for that comment. 19 They make a number of -- they have a number of bases for 20 running up flags. And I think the bases are correct. But 7 21 think they tend to be more deficiencies in the writing of 22 the SCP, which is precisely what they should be commenting 23 on. 24 MR. ORTH: I would like to make one more little l 25 comment, if possible. () Heritage Reporting Corporation (202) 628-4888
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) 1 MR -. MOELLER: Fine, Don..
2 MR. ORTH: There is also'some history of people 3 3 going into deep rocks where you have nothing but a flow
- 4. through, what amounted to slightly crackled. granite, for 5 example, to determine sach things as over broad areas of 1
expanse the relative flows and relative ages of-the water in 6 7 their compositions so that what is being asked in terms of 'I I 8 let's say drilling dri11 holes, let's say upstream and j 9 downstream of the repository and the flow horizon, and 10 . determining things like compos'itions and changes in i 11 compositions from one'end to.the other,'again, there.is a
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12 history of how to do things like that. 13 It has been done, for example, in all of the 14 bedrock underneath the Savannah River plant, in terms of-15 deciding where the granite got charged and where'it. finally 16 ended up with and what the ages all were. There were- j 17 others. 'l i 18 MR. MOELLER: Thank you. ] 19 Any other comments?. Yes. 20 Paul. 21 MR. VOILAND: Just one quick question, again. l 22 I have seen the table of ground water travel times- ; 23 or estimated ground water travel times in Chapter 8. I 24 I just wonder if you, Judith, and separately the 25 NRC staff, are in general agreement with at least the order Heritage Reporting Corporation (202) 628-4888
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(f 1 of magnitude of;the numbers-that are contained in those 2 ground ~ water. travel time tables for the individual ) 3 ' geological units. 4 MS. MOODY: Go ahead. Incompletely defined is I l 5 what I would say. Go ahead. ! 6 MR. POHLE: I cannot remember the year that we
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7 reviewed the draft environmental assessment and eventually: l 8 the final environmental assessment for Yucca Mountain,.but i 9 we actually essentially reviewed that analysis in those 10 docuraents and we made a number' of points related to it -that ) 11 could all be summed up into: I cannot debate this' number-1 12 with you because essentia11y'your data base is insufficient. 13 MS. MOODY: That's right. {} 14 15 MR..POHLE: And I don't see where the status has changed.that significantly since we made.those comments. 16 And it certainly did not warrant getting into that here and 17 trying to review this characterization plan. 18 MR. POMEROY: And I guess you would say the same - 19 thing then about the percolation flux that was used in that j 20 tabulation also? 21 MR. POHLE: The .05 I believe? l 22 MR. POMEROY: 0.5. 23 MR. POHLE: 0.5. 24 MS. MOODY: That was the only. thing I was going to l i 25 say was that the information that is presently available I () Heritage Reporting Corporation (202) 628-4888 l i i
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(_) 1 think is incomplete and it is hard to say .res or no I think l 2 at this point with the numbers that have been sort of j 1 3 postulated as possibilities. j 1 4 MR. POMEROY: But there are not any actual l 5 measurements either in small samples or otherwise? i 6 MR. POHLE: In certain areas, like I don't think, 7 there are no direct measurements of effective processes that 8 I recall. 9 I think there is essentially a data base of zero 10 and essentially some judgments were made looking at porosity 11 and this or that or the other to come up with a number, look 12 at a potential range. But again, those are judgments. 13 There is much, much judgment in there. {} 14 MR. MOELLER: Okay. Let's move along. Bob. Bob 15 Browning. 16 MR. BROWNING: One point. 17 I thought I detected a couple of comments in Dr. 18 Moody's charts to the effect that in our comments in the 19 point papers we should be more precise and specific about 20 what our recommendation entails. 21 I think one example was we should tell them what 22 re.dionuclides to consider in a particular comment or what 23 groundwater they should be testing the package in. 24 I wanted to emphasize that that is the kind of l 25 thing we try to avoid doing, to put the burden on them to f 6 () Heritage Reporting Corporation (202) 628-4888
150 lh 1 lay out a plan or rationale for what they are doing, rather 2 than tell them. 3 Otherwise, then, we have to end up defending the 4 position as opposed to challenging it and making sure it 5 withstands scrutiny. 6 MS. MOODY: I understand that very well. It is 7 just, again, it comes up time and time again. So it is how 8 you wish to comment back to DOE. I understand. 9 MR. BROWNING: I think this is where the concept 10 of the iterative technical approach to try to resolve some 11 of these outstanding concerns is extremely important because 12 the earlier we have that iteration, the more likely we will 13 reach agreement. ggg 14 You know they will propose, we will dispose and 15 then the program will go on. 16 Whereas, if we do not hear for a long time and 17 they go do it, then we are in the position of bring me 18 another rock after the work has already been done. 19 So I think where we think there is a key technical 20 concern that warrants early on an iterative frequency, for 21 example, like how we are going to resolve what substantially 22 complete containment really means in a concrete, specific 23 example for this particular site, those iterative things are 24 extremely important in our mind in reaching a consensus and 25 drawing other parties such as the State of Nevada into the l lh Heritage Reporting Corporation (202) 628-4888 i
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;. -1 process as we'do it. ,
.2 MR.'MOELLER: Any.other comments?-
3 (No response) + 4 MR. MOELLER: Okay..
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152 () 1 MR. MOELLER: Paul Pomeroy is going to lead'the 2 discussion on that. - 3 MR. POM3ROY:. Dr. Moeller, I'd like to say first, 4 I don't. suspect -- unless something unexpected happens -- 5 I'll need an hourLand a half t'o reach through my comments. 6 Although, I can talk easily for an hour-and-a-half. 7 In my letter to my Chairman, which I believe the 8 Committee and the consultants have, I. identified seven 9 specific areas of concern,.that were of concern-to me 10 regarding the performance assessment program. 11' I'd say at the outset that all of. those seven were 12 treated to a greater or lesser degree in the point papers of 13 the NRO staff, and at least the specific citations that Sal (} 14 referred to in carrying the discussion through, will be, -I 15 am essentially in agreement with that commentary. And;I 16 also have to say, as my colleague Bill did this morning, 17 that I think the NRC staff in evaluating the performance 18 assessment program did an outstanding job, particularly in-19 view of some of the problems that we'll strike through here. 20 I'd like to go through~those seven concerns. I 21 don't want to spend a lot of the Committee's time on those, 22 because you can certainly read my comments in the letter 23 itself. 24 What I would like to ask is that you would think 25 just a little bit as I'm going through, regarding two I () Heritage Reporting (202) 628-4888 Corporation
153 , O 1 asgects: y 2 One is the totality of the concerns. That is you 3 will hear a number of different elements repeated perhaps, ;
-4 if I.can get through everything, and it's the overall number
-1 5 of concerns that have me somewhat worried at this point in .
6 time. 7 The second point is that I also received the j
.1 8 Director's comments this morning, and I haven't had time.to l 9 fully evaluate them. But'I have read them,'and I am not .
10 certain that all of the concern that I identify as critical 11 in the point papers are brought forward succinctly to'the 12 Director's comments. 13 MR. MOELLER: Well, you did pretty well. 14 MR. POMEROY: Yes. 15 MR. MOELLER: Like scenarios, alternative 16 conceptual models, the human intrusion, a number ~of them. 17 MR. POMEROY: I think that's right. I think I l 18 perhaps when I get to the end, I can clarify that comment a ' 19 little bit more. 20 I also have one other little housekeeping problem: ) l 21 that I envisioned a slightly different format for this 'l 22 meeting today, not knowing what the format would be. And I 23 would like with the Committee's approval to conduct this 24 particular section in a little more interactive format with 25 the NRC staff, if that's acceptable. Heritage Reporting Corporation (202) 628-4888 1 i i
i i! 154 ; (). 1 MR. MORLLER:' That's okay. 2 MR. POMEROY: The performance assessment can be l
.3- defined in many different ways. One of them is on page 5 of i
4 the material that is in the black notebook; and that is, j l
-5 that the performance assessment program uses the data 6 obtained d
'uring site characterization,to help resolve the 7 regulatory issues identified by the issue of resolution 8 process. And in particular,.and we're going to come back to 9 this in particular, to. quantitatively' evaluate whether the 10 site meets the numerical criteria of part 60 performance. j J
11 objects. 12 Just so we-all start in the same place, perhaps. 13 everybody here is fully familiar with the performance 14 assessment steps, and particularly the complementary
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15 cumulative distribution function. But that's going to enter 16 in at the end of our discussion also. 17 So I wonder if I could just ask somebody from the 18 NRC staff to briefly expand on the performance assessment J 19 fit into the overall issue resolution strategy, and in l 20 particular, to nonmathematically and briefly describe the
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21 complementary cumulative distribution functions so'that 'j i 22 we're all starting from the same point. ! I 23 MR. MOELLER: I think that's a good idea. Go ) 24 ahead. 25 MR. POMEROY: Ah, indecision. l () Heritage Reporting Corporation (202) 628-4888 l i _ _ _ - - _ _ _ _ _ _ _ _ _ - _ _ - . _ _ _ _ _ _ _ _ _ _ - - - _ _ - - _ - _ - _ _ _ _ _ _ . _ _ _ _ - . - . . .__- - _ . -___-____.A
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.( ) 1 MR. COPELAND: It's a difficult concept to try to 2 convey. But. essentially - ,
3 Yes, I'm Seth Copeland. I'm section leader for 4 the system performance assessment.section. 5 MR. MOELLER: If we had a tape of your previous 6 presentations, we could have just played it. 7' MR. COPELAND: I'm not sure how clear some of 8 those earlier ones were. I'll try again. 9 MR. COPELAND: Essentially,.the CCDF is a graph 10 that' relates the probability that the accumulative release i i 11 from the repository.will exceed some given release. And the 12 EPA standard that is in -- actually will be brought'into 13 60.112, but right now is simply referred to in 60.112, will {} 14 15 essentially define a upper bound for such a curve or such a graph that would be calculated for the repository at Yucca 16 Mountain. 17 Essentially, that's the job that the Department of 18 Energy would have to do in terms of showing compliance with 19 the EPA standard, just calculate this curve and show that it 20 falls below this limit that would be set by the EPA. ! 21 It might help to just very briefly describe some 22 of the steps that one would go through in actually doing 23 this to give you a feel for what's represented-by the curve.- i 24 Essentially, you go through a step of looking at j 25 the things that could happen to a repository, call them () Beritage Reporting Corporation (202) 628-4888 l
156 r 1 scenarios. Starting with, that you would figure to be the 2 just kind of nominal behavior of the repository and then 3 looking at the variety of kinds of disruptive scenarios. 4 For each of those scenarios that would appear to be 5 significant, either because of the possible consequences or 6 because it's likely enough to occur, you would evaluate what 7 the consequences of this scenario would be. And you would 8 also determine what the probability of the scenario is. 9 Given that raw information, probability of the 10 scenario and consequences of the scenario, you're then in a 11 position to put together this curve that I was talking about 12 earlier. Basically, it's just a way of displaying that 13 information. {} 14 MR. POMEROY: And then could you juct clarify it 15 for us, how the EPPMs come in relative to the scenarios. 16 Perhaps that's an unfair question. Let me read one of your 17 comments which I happen to agree with. This is PPB /3.6/ PPA: 18 " Scenario classes used in the performance 19 allocation, which is part of the performance assessment for 20 total system performance, do not meet the formal definitions 21 stated in the SEP" -- I put in that SEP -- "and are 22 inconsistent with the performance measured used," which are 23 the EPPMs. 24 So it's not clear to me, and as we'll see in a 25 minute, presumably you're in agreement with that comme.nt how () Heritage Reporting Corporation (202) 628-4888
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-157-1 the CCDF is actually going to be handled. 'I'd like you to 2 just clarify that for me a little bit.
3 MR. EISENBERG: I'm Norman Eisenberg from the NRC. 4 The idea behind the EPPMs, the expected partial- ( 5 performance. measure is not a bad one. Basically, for each 4 I 6 class of scenarios, the text defines a scenario class as j 7 some combination of a particular set of events. 8 So, for example, if you have earthquakes and-9 volcanoes occurring simultaneously and no other disruptive 10 events, that would be roughly a scenario class. For each l 11 such scenario class, one could define some average expected 12 performance. And by multiplying the expected consequences, 13 the performance, by the likelihood, one gets a measure that () 14 can be related to the basic EPA standard. 15 And so it was an attempt to look at a variety of I 16 scenarios in a quantitative mathematical way, and to use it l 17 to help guide the tite characterization program, i 18 Unfortunately, it's our belief that the l 19 mathematical development which very carefully defined what a 20 scenario was and very carefully developed limits for this 21 EPPM in terms of the behavior, the mathematical behavior of , 1 22 the CCDF and EPA standard, that the scenario' classes'that 23 were actually.used, if we can call them that, really didn't 24 correspond to the formal definition. And, therefore, we 25' cannot be assured, and we don't think the DOE can be Heritage Reporting Corporation (202) 628-4888 : l
158 () 1 assured, that the program that developed based on these 2 measures will be complete and will be successful. 3 MR. POMEROY: Right. In fact, those five scenario 4 classes, as they defined them, were not mutually exclusive. 5 MR. EISENBERG:- That's correct. 6 MR. POMEROY: And you don't consider'them 7 appropriate for development of the CCDF. 8 MR. EISENBERG: That's right. After this careful 9 mathematical development in which there seemed to be very_ 10 close correspondence between these EPPMs and the CCDF -- in 11 fact, if you replaced the EPPM with the actual performance, 12 you could use the same mathematic construct to obtain-the 13 CCDF to then kind of go to a different set of mathematical {} 14 objects to define the program, seemed to be somewhat of a 15 dislocation. 16 MR. POMEROY: Could you also give us your staff 17 view on the usefulness and significance c f the nominal 18 scenario class as it's defined in the-SEP? 19 MR. EISENBERG: Well, the nom!.nal scenario class 20 is defined in several different places. In.one table, it 21 essentially is defined as a situation where all the barriers 22 perform as expected. And it's kind of a current performance 23 projected into the future. 24 However, later on in the development of the 1 25 discussion of scenario screening which then feeds into the () Heritage Reporting Corporation (202) 628-4888
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() 1 site characterization program, the test indicates that a 2 number of other types of objects will be placed in with.the 3 nominal scenario, such things as undiscovered features, such 4 . things as waste improperly in place, which we feel does not- ] 5 belong as a scenario anyway; that that's an initial J 6 condition. 7 So there is this rather' comprehensive, nominal 8 scenario which seems to cover a' lot of ground. And it 9 doesn't seem entirely reasonable that 'all of the performance 10 measures that are set for that, and all the. contributing _j 11 parameters, would be appropriate, considering the wide range i 12- of different types of events that are included in it. That I 13 seems to be a problem, also. {} 14 15 MR. POMEROY: I would like to just read two comments that I'm also in agreement with, I think both of 16 them written by'the gentleman that just spoke: 17 "As soon as practical, document the performance I 18 assessment program and its relationship to tho site l 19 characterization investigation in enough dete.il to ensure 20 correction of the apparent programmatic deficiencies which 21 resulted in several specific examples that were cited . 22 earlier in the comment." That's in the recommendation ; 23 section. 1 24 I certainly agree with that,'because it's very 25 difficult to look'at the performance assessment program and
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160 () 1 relate'it in a clear-cut way to the site characterization. 2 -In another comment, the approach to scenario 3 analysis and how it's being employed to guide the site 4 characterization program -- and that's an important function 5 of the performance assessment program -- must be clarified 6 or redone. And that seems to'be a major statement that says 7 redo that entire section. 8 There are many other comments that one.could make 9 about scenarios, and many of them.are contained in the staff 10 papers. I think the bottom line is that the way it's 11 spelled right now in the SEP, and the staff has correctly 12 identified it, the whole question of scenario analysis and 13 the relationship of the performance assessment program to {} 14 15 the site characterization program really need to be-documented or redone in some way. We'll come back to that. 16 I don't have a good place for this last question 17 that relates to scenario and scenario-class selection. But 18 I'm still bothered by.a statement in the SEP with regard 19 to -- at some point, we're going to introduce the 20 probabilistic risk analysis in addition to performance 21 assessment. And I asked for some help with this last time 22 from the staff, and I'd like to ask just a little bit more 23 to get your opinion. 24 MR. EISENBERG: Where do they say that? 25 MR. POMEROY: There's a whole section. I don't Heritage Reporting Corporation (202) 628-4888
l 1 161 () 1 have a specific reference here, but.there's a whole 2 section -- talk about preparing probably risk analysis. 3 MR. MOELLER: Paul, you'can't be heard, I'm 4 afraid. 5 MR. POMEROY: I believe that reference is in 6- 8.3.5.17. But let me pose that question later to the. 7 staff. 8 I'd like to turn to the second point'that I'd like 9 to hit here. And this is a point that has been brought up-10 also very clearly in ' the Director's comments, and that deals 11 with an alternate conceptual models. Alternate conceptual 12 models, it's stated, form a part of the issue identification 13 process. They certainly do. {} 14 Could you, as a staff, just briefly tell us how 15 those alternate conceptual models are used in the hypothesis 16 testing tables. 17 MR. EISENBERG: You know,.in the issue resolution j 18 strategy, the idea is to layout a program based the 19 performance measures which are defined by the regulations, 20 and then to try to define a set of parameters that are 21 needed in order to estimate those performance measures. And I 22 then to try to define goals and confidences for those 23 parameters so that the~ site characterization program will be 24 guided by these goals. 25 One of the ideas behind the whole process is that !l () Heritage Reporting Corporation (202) 628-4888 k
162 () 1 if one can go out and define, or find that the goals are 2 met, then one can resolve that particular issue. There is, 3 however, an assumption, and the text in the.CEP does discuss 4 it. 5 However,-one of our concerns is that the program 6 that's articulated may not affect it in.the way that it 7 should. And that is that in addition to. measuring the 8 parameters and demonstrating that you meet'the goals, you 9 have to confirm that your initial estimate.of what. 10 parameters are.important t'o the performance, are the correct 11 ones. 12 What this means is that you have to confirm 13 whatever conceptual models you started out with. And'that (} l 14 is, in essence, the entire purpose behind the hypothesis 15 testing table. It is a formalism for articulating 16 alternatives to the current concept of the performance of 17 the site and its various barriers, and then to identify a 18 program that will test these various hypothesis so that one ) i 19 can either confirm the correctness of the current hypothesis 20 or choose a different one for the ultimate issue resolution. i 21 MR. POMEROY: Expanding on that then, simply.to : 1 22 say that there are many examples where the alternative j l 23 hypotheses are missing, or certainly not complete, those 24 have been identified in practically every area that we're j 25 looking at, whether it's hydrology or climate, geophysics or i Beritage Reporting Corporation (202) 628-4888
163 1 whatever. 2' So there are a large number of missing models 3 here. What perhaps the significance of the lack of those 4 models is, we may not-get adequate testing.to do.that. y 5 There is a comment, however, in the -- 6 MR. STEINDLER: May I inject:a question. 7 MR. POMEROY: Sure. 8 MR. STEINDLER: I would guess that altr,rnatives 9 can be injected until you've run out of idess. Is there i 10 some measure of evaluation of those that somebody could ! 11 dream up, that are not in the site characterization plan 12 and relate them to their potential importance, so that the 13 alternatives are'not simply swamping the rest of the (} 14 activity? 15 MR. POMEROY: I think one could rate their 16 importance to some degree even if you use expert judgment, 17 which we're going to get to in a minute. 18 But, for example, in the climate section,'there's 19 no alternative model that I was aware of in my reading for 20 an increase in precipitation. There are, sort of, only 21 three of them. It either stays kind of the way it is, or it 22 decreases or it increases. Now, one would think that'all 23 three of those might be considered, but one of them is 24 missing as far as I'm aware. 25 MR. EISENBERG: I think that's correct. Heritage Reporting Corporation (202) 628-4888
164 l jm i (,) 1 MR. POMEROY: So they are certainly important-2 alternative conceptual models that are missing in the SEP. 3 And I really only want to make the point that the staff has 4 correctly identified that lack and carried it forward here. 5 MR. STEINDLER: The little reading I have done ; 6 indicating missing alternative conceptual models, the word ) 1 7 "important" was never found where I could see it. And so ) 8 the conclusion I came to was that there was a general l 9 prescription that alternatives are missing, period. And I 10 guess my view is that that's not good enough prod to DOE. i 11 There ought to'be some kind of recognition that surely some i 12 alternatives ought not to be even bothered with. 13 MR. POMEROY: Certainly. I fully agree with that. {} 14 MR. EISENBERG: Another comment that I'd like to 15 just call to your attention in one of the comments in the 16 geology-geophysics section, which has just come back to us, 17 incidentally, this noon time, relates to the following. 18 It's stated that the alternative conceptual models do not 19 appear to be fully integrated into the site characterization 20 plan; and as a result, alternates are apparently considered 21 in the preliminary performance allocations. That's just a 22 restatement of the same problem from another area, and I 23 would fully agree that we should say important comments 24 there. 25 MR. POMEROY: I would like to turn briefly to the
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i 165 (-)- 1 use of expert judgment. I think we all recognize that ) 2 expert judgment is used throughout the scientific and ) 3 engineering process. And in most cases, that judgement is l i 4 used correctly in both probablistic and deterministic 5 studies. 6 There is a little bit of difference between expert 7 judgment and formal use of expert judgment, which I 8 initially didn't understand, and which I'd just like to 9 bring out here. And I'd like to address that question to 10 the staff to sort of distinguish between expert judgment 11 with small letters, and formal use of expert judgment in 12 capital letters. , l 13 MR. EISENBERG: Can I read you the definition of {} 14 formal use of expert. judgment from the Review Guide? 15 MR. POMEROY: Certainly. 16 MR. EISENBERG: "The formal use of expert judgment ) 17 is the systematic documented technique for eliciting and I l 1 18 reporting the opinions of panels of experts who have been 19 selected and who have worked according to methods that are 20 generally accepted in the scientific literature on 21 subjective judgment. 22 "The formal use of expert judgment is highly 23 structured and it is intended to be a way of drawing 24 inferences form sparse data and assessing the uncertainty of 25 those inferences. () Heritage Reporting Corporation (202) 628-4888
166
) l' "It is not the same as the' routine-use of expert 2 judgment that is part of anyiscientific or engineering
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3 investigation or design process. The formal use of expert' 4 judgment should also be distinguished from the formal use of-5 peer review, another process in which expert panels are 6 used. 7 "The formal use of expert judgment is directed 9 towards drawing inferences where hard data and facts are 9 few, whereas peer review is an independent cr.tique of the 10 way data and information are analyzed or conclusions drawn 11 from those analysis. 12 "Thus a peer review of an application or formal-13 use of expert judgment is possible, and even likely in some (} 14 instances. As in peer review, the_ formal solicitation and 15 use of expert judgment should be a documented process." 16 MR. POMEROY: Then in one of your comments you'say 17 the formal use of expert judgment is proposed to incorporate 18 uncertainty about alternative conceptual models into the 19 CCDF. Is there anything wrong with that approach, based on . I 20 that definition that you just read? j 1 21 MR. EISENBERG: Well, I think so. I think we feel l I 22 that it is inappropriate, or not inappropriate, but would l l 23 make licensing decisions more difficult, because the 24 likelihood that one or another of alternative concepts is 25 valid, is not the same as the probability of some future Heritage Reporting Corporation (202) 628-4888 t
167 O) (_ 1 event. And it's not the same type of uncertainty as the 2 value of a parameter based-on a limited number of samples. ; 3 And by putting these various alternative conceptual models 4 together in a single CCDF, I think it would make it more ! 5 difficult for the staff and the Licensing Board to evaluate i 6 what the effect of the various alternative concepts are, and i 7 how to make their decision. 8 I'm not sure that that explains it fully. But i' 9 it's a difficult thing to explain without a blackboard. 10 But, basically, I think in nuclear regulation, 11 people are used to seeing concept A and some performance 12 curve for that, and concept B and a performance curve for 13 that. And then it's up to the reviewers of the particular (~) 14 application to decide which model they would choose. And if V 15 they can't choose between the two, what the relative risks 16 of choosing one or the other are, or how much confidence 17 they would put in them, or whether it's appropriate at that 18 point in the process to allow that degree of uncertainty, or 19 whether it would be more appropriate to ask the applicant to 20 go out, acquire more data and resolve the question of which 21 is the valid concept. 22 MR. POMEROY: I think we'd all agree that the 23 formal use of expert judgment shouldn't be substituted 24 for -- There's an example, by the way, also in FWR-7, that 25 constructing CCDFs for groundwater travel time by waiting () Heritage Reporting Corporation (202) 628-4888
168 () I the alternative conceptual models will not provide a 2 complete assessment of groundwater travel time. That 3 certainly seems to be something of an understatement to 4 make. 5 I' d like to turn briefly to the use of -- 6 MS. MOODY: Paul. 7 MR. POMEROY: Yes. 8 MS. MOODY: In your letter that you have here, I 9 just want to bring under the use of expert judgment. Your 10 last sentence says, "One could envision a later point in 11 site characterization where, for expedience, the use of 12 expert judgment will be put forth as a substitute for 13 additional experimental data." 14 MR. POMEROY: I certainly, in my mind, can see [} 15 that situation arising at some point because of the time 16 pressures that we all are keenly aware of. That some key 17 piece of data would not be available and we would be down at 18 the 1994 time frame, and what do we do at that point? Do we 19 say stop and go back and get the additional data, or because 20 we're in a time frame that's rather fixed, should we say, 21 well, use the formal use of expert judgment and substitute 22 for that data. 23 We've seen a good example. Dr. Hinze and I 24 attended a meeting the other day that was to characterize 25 motion on the -- fault. And one envisions that as being a () Heritage Reporting Corporation (202) 628-4888 l l
169 r~x 1 geological investigation of some sort. At that point it was d 2 purely a use of expert. judgment. That's an early point in 3 the game, and certainly not very critical, because there 4 will be a lot of investigations done later. 5 One could see the same kind of thing occurring 6 several years down the line at a time when we no longer have 7 the option of going back and getting additional data. 8 MR. MOELLER: I read your sentence as a word of 9 caution. 10 MR. POMEROY: Exactly, as a word of caution. 11 MS. MOODY: Well, Paul, then, are you saying if 12 it's a word of caution that there's not real substitute for 13 real data? 14 MR. POMEROY: There's absolutely no substitute for O 15 real data. If you don't have it, however, if there's no way 16 of defining it, and there are many, many instances where 17 you're not going to have that data, all you can do is use 18 formal use of expert judgment, unless you want to stop cold 19 in the engineering process. Very few people want to do 20 that. 21 MR. MOELLER: Paul, your next one on the "me of 22 waiting times for initiating events, is one that I must 23 confess I did not understand. So I' d appreciate a little 24 elaboration. 25 MR. POMEROY: I had several questions that I l (~' Heritage Reporting Corporation N (202) 628-4888
l. 170 i ('} 1 wanted to pose in this interrogatory format to the sta'ff, l
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2 and I wondered if we could start'by just defining waiting I 1 3 time. l 1 4 MR. EISENBERG: Basically, it's a way of I i, 5 estimating performance by allowing a certain time before the i 1 6 start of a particular event, so that if, for example, an d l 7 increased pulluvial period is going to cause increased flux { 8 to the repository. There may be some time period before 9 that ste.rts. And if it's a thousand years or five thousand 10 years, then one would not necessarily want for a accurate 11 representation of the consequences of such an event to begin 12 at a time equal zero. So it's the insertion in equations, 13 including the decay and transport of the radionuclides of a 14 time that measures the initiation of the event. O 15 Perhaps a better example would be, say, volcanism 16 where some of the waste is ejected from the repository, or 17 an earthquake where hydrologic conditions have changed. 18 MR. POMEROY: There is, in fact, a example in one 19 of the performance assessment comments in number 13. To 20 quote: "The evidence appears to indicate that the site is j 21 in a state of incipient faulting." 22 The appropriate waiting time in that instance 23 should be zero. Because we just don't know -- we shouldn't l 24 take credit for the 10,000 year earthquake, zero starting at I 25 the time of closure of the particular event. I Heritage Reporting Corporation
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() r' 1 MR. MOELLER: Now, for an earthquake, then, it 1
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1 2 could be zero. But for volcanism, could it be a thousand 3 years or ten thousand or something? Reasonably, it would be l i 4 some thousands of years. i 5 MR. POMEROY: I would defer that to -- 6 MR. STEINDLER: You would end up using expert 7 judgment to determine the waiting time? 8 MR. MOELLER: I guess I need to go back then to 9 even -- 10 MR. STEINDLER: My problem is it sounds like we're 11 compounding the uncertainties by squaring it. If you don't J 12 have enough data for an expert judgment to determine what 13 your wait!.ng time is, and you guess at both of them, you now 14 have t.wo guesses that are compounding the problem. d 15 MR. HINZE: I guess the point is that are -- l l 16 MS. MOODY: It's just not instantaneous data. It 17 has to be collected. 18 MR. POMEROY: Well, I'm not sure. I think it's a 1 19 very good point. I'm not at all clear in my own mind. I'm 20 very clear in the case of the earthquake. 21 MR. MOELLER: Well, that's clear. But, to me, I 22 thought volcanism meant you waited until a volcano developed 23 beneath the repository and came up through it. Now, that 24 can't happen tomorrow. 25 MR. POMEROY: Well, you could envision a situation l Heritage Reporting Corporation (202) 628-4888
172 I) 11 where you had a major faulting occurrence with magmatic -- 2 MR. MOELLER: Oh, okay. And it did happen-
-- 3 tomorrow.
4 MR. POMEROY: It did happen within a very short 5 time frame. I'm not saying a waiting-time zero -- 6 MR. MOELLER: 'Zero, okay.- 7 MR.-POMEROY: -- but a short amount of time.- One 8 can only envision that. 9 MR. MOELLER: Now, I guess, flooding of the area, 10 you could say that's ten thousand years away. What's 11 something that has a long waiting time? I'm thinking of the 12 next glacier -- I presume that's ten thousand, or five or 13 something, away. 14 [} 15 16 17 18 19 J 20 21 t 22 23 24 , i I () ~ Heritage Reporting Corporation (202)' 628-4888 1 l
173 ( j) 1 DR. POMEROY: A certain amount of inertia that one 2 has to overcome to develop a. period of glaciers in.the 3 initiation period. And I presume that is in the form of the 4 waiting time. 5 DR. MOELLER: And I think that would be 6 appropriate to, say, five thousand years. 7 DR. HINZE: But I don't think that would apply to 8 volcanism or to earthquakes. 9 DR. MOELLER: Or flooding. I guess they could 10 have a thousand year rain tomorrow or something, okay. 11 DR. POMEROY: That's right. 12 DR. MOELLER: Okay. Well, that's helping me some. 13 DR. POMEROY: My problem here with the waiting 14 times is also though that the waiting times do enter into
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15 the SEP very specifically and I gueas just to elucidate 16 that, I'd like to just ask again the staff to comment 17 regarding the use of waiting times inappropriately in the 18 performance allocation or elsewhere. At least I've seen the 19 use of numbers like 100--well, 100 years I believe. Taking 20 credit for a waiting time inappropriately. 21 MR. EISENBERG: I think basically that there is 22 nothing wrong with the concept of waiting time, but what has 23 happened is that perhaps not the same people familiar with 24 the particular subject area have been using them 25 inappropriately. So that the comment was directed more () Heritage Reporting Corporation (202) 628-4888
1 1 174 l I 1 towards the idea that if a waiting time were being used, 2 that it should be consistent,with the knowledge about the 1 3 geologic processes involved.
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I 4 And that, for example, if you were to assume a I i 6 Poissan process, then it might be appropriate to say that 6 the waiting time for faulting would be five thousand years. 7 However, from what is known about the site currently, it's 8 not appropriate to describe faulting by a Poissan process if 9 it's in an incipient state of faulting. I 10 So I think it's more of a question of the 11 application of the concept and the use of current geo- i 12 science reasoning to identify what an appropriate estimate 13 at this time is and I think they have used it 14 inappropriately in some areas to estimate some of the 1 15 parameters or to set the goals for them, i 1 16 DR. POMEROY: Right. In fact my last sentence in 17 my letter in that particular paragraph really is, again, 18 just a cautionary note with regard to that. 19 I'd like skip over my comments on the models for 20 water pathway release because we've talked some about them. 21 And just look quickly at the problem of human intrusion. 22 This is really a subject that I wasn't aware of going into 23 this study. But it seems to me that it's a very serious 24 situation and again I'd like to ask, since again this is in 25 NAE 18 and LRA 7 on the commentary. O h Heritage Reporting Corporation (202) 628-4888
1 175
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(' 1 I'm going to let Seth Copeland off easily and ask 2 his compatriot here to just outline briefly the content of 3 your comment in NAE 18 regarding the inclusion or non-4 inclusion of human intrusion scenarios in the calculation of 5 the CCDF. 6 MR. EISENBERG: Well, there was a CD SEP comment 7 related to the inclusion of human intrusion in the CCDF> 8 The current NRC staff interpretation of the EPA standard is 9 that human intrusion is to be included in the calculation of 1 10 the CCDF. There are some guidelines for certain kinds of 11 human intrusion included in the EPA standard which the NRC 12 staff has not yet adopted, but there are some guidelines 13 available. s 14 In the response to the CD SCP comment, the DOE is l b 15 very ambivalent in the text of the SCP regarding whether the 16 human intrusion scenarios will be used. Perhaps "very 17 ambivalent" is the wrong word. The way I read it, it in 18 ambivalent as to whether human intrusion scenarios will be 19 used in the calculation of the CCDF. 20 In the response to the comments on the CD SCP that 21 was prepared by the DOE, they are very explicit and say they 22 will use a separate calculation to estimate the effects of 23 human intrusion on the CCDF. And the argument given is that 24 they don't want the human intrusion aspects to 25 inappropriately steer the Site Characterization Program. Heritage Reporting Corporation j f~} (202) 628-4888
p -- 176 () 1 'Certainly that'is something that one would est want to 2 happen. However, there is a. concern that ultimately the 3~ approach taken by the DOE may'not be acceptable because we^ 4 believe that the CCDF calculation must include these human 5 intrusion. events. 6 .DR. MOELLER: Now, you said^that same thing, did
- 7. you not, on the consultation draft?
8 MR. EISENBERG: Yes. 9 DR. POMEROY: .And so DOE is somewhat--well, they 10 are resisting you. Now, what will be the resolution? I 11 guess if you say this again in your SCA, it'll be almost 12 mandatory, will it not, that-they respond and include it? 13 MR. EISENBERG: Well, in addition,Eas I' understand 14 it, we have under preparation a. rule implementing or
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15 describing compliance with the EPA standard, and certainly 16 it would be covered in there. 17 DR. MOELLER: Okay. 18 DR. POMEROY: And, again, I think I'd just close 19 that particular issue off by quoting again from that Comment 20 No. 18, NAE 18. And we develop a consistent rational-21 approach to the resolution of Issue 1.1, such that human 22 intrusion scenarios are included in the calculation of the 23 CCDF. Or such that these scenarios are excluded in such a 24 way that compliance with the EPA standard can be 25 demonstrated. I don't know given the statements that have () Heritage Reporting Corporation (202) 628-4888
177 () 1 just been made whether that latter situation is possible, :
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2 but it certainly seems reasonable to include those human 3 intrusion scenarios. 4 DR. STEINDLER: Did the staff give you the 5 impression that they were going to exclude the human 6 scenarios in the CCDFs, only in the Site Characterization ! 7 Plan? What was DOE's intent as people extracted it out of 8 the six-foot book shelf? ! 9 MR. EISENBERG: It's really not clear. 10 DR. STEINDLER: Did you engage in a discussion on ! 11 the subject in any of your public meetings? You did not? 12 MR. EISENBERG: This was brought up in the one , I 13 meeting. p~ 14 MR. COPELAND: It was brought up at a meeting I
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15 guess last July, but there has really been no opportunity ) 16 for discussion with DOE. We haven't had interactions in 17 this area. 18 DR. STEINDLER: Well, on the surface- you know, 19 your last comment, as you described what DOE's done, seems 20 en,inently reasonable. Maybe people have problems with it 21 for other reasons, but if they wanted to pull out the human 22 intrusion because, as you say, it dominates the calculation 23 and it doesn't directly affect the Site Characterization 24 activities per se, and they were going to treat it 25 separately, on the surface, doesn't that seem perfectly I'd
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178 1 -reasonable? I mean it does to me, just what you have here.
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2 I haven't looked at it in more detail that than. l 3 DR. POMEROY: It seemed to me from my reading, and 4 I admittedly haven't done all the reading either, that the 5 ultimate question is whether or not you conform to an 6 interpretation of the EPA standard. And either the site 7 does do that or it doesn't. 8 DR. STEINDLER: Well, human intrusion seems to me 9 is a lot less site dependent than-- I mean if a guy is going ( 10 to drill a hole, he's going to drill a hole, you know, 11 whether it's tough and it's easy to go or granite and it's 12 hard to go. You have to make that assumption someplace. 13 DR. MOELLER: Marty, though thi'2 last sentence of 14 what Paul has written, you know, it says any such O 15 separation, meaning separating out human intrusion could 16 call into question the qualification of the site. 17 DR. STEINDLER: Well, that's what I'm having 18 trouble with. I'm not sure I understand that. 19 DR. MOELLER: Oh, okay. 20 DR. POMEROY: The point is well taken. If you can 21 do--if you can exclude the human intrusion scenarios from l 22 the CCDF and still qualify and meet the EPA standards, then l l 23 essentially you are home free and that's the second part of l 24 what I was saying there before. I don't see how it can be 25 done but if there's a w;y of doing it-- l O Heritage Reporting Corporation (202) 628-4888 M
a.' 179
) 1 DR. SMITH: I guess.I don't>see'howfyou factor 2' that in, the human intrusion into.theLequation.' .Because if
] i 3 youLlook at-Yucca Mountain to begin-'with,LI presume in the:
4 terms of an overall performance assessment, the. reason we're -l
~ 'l 5 even doing.anything there is at least based on what weJknow~ i 6- now it looks good.
And human intrusion-has always beenLa-7 possibility there. 8 Now,.which gets me to what you are going to talk 9 about. I think one;of the most~important things here-- 10 DR. POMEROY: I do too. 11 DR. SMITH: Is the performance assessment and , 12 doing it on a sequential basis as the information comes in- .) 13 so that as soon as we know that there#s something that's-not-l 1 14 right there we can stop rather than. waiting five'or six; [} 15
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years.- 16 But I mean no matter where you go the human i 17 intrusion issue is there. 7 18 DR. POMEROY: I agree with that. . ; 19 DR. HINZE: I would have to disagree with that. 20 DR. MOODY: If we want to include the n&tural-21 resources. 22 DR. MOELLER: Well, as an incentive. 23 DR. SMITH: You mean as an incentive'in terms of 24- maybe there's oil underneath? 25 DR. HINZE: That's right. Heritage Reporting Corporation (202) 628-4888
180 ; e~' ( )s 1 DR. MOODY: And that makes the human intrusion. 2 DR. SMITH: All right. I guess I perhaps wrongly 3 assumed that there wasn't gold underneath Yucca Mountain. 4 There wasn't oil under it. 5 DR. HINZE: You can throw a rock to the-- 6 DR. MOELLER: The staff wants to speak. Let's , I 7 give them a chance. 1 I 8 All right. Gene first. j t 9 MR. VOILAND: If we use massive copper as our j 1 10 container, we may create the greatest copper ore body in the l 11 whole world. It may become very attractive. 12 DR. MOODY: You are talking about the Swedes, 13 Gene. 1 (~h 14 MR. CARTER: The fuel also has inherent value.
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15 You don't need to look for anything else. 16 DR. MOELLER: Okay. The staff-- 17 MR. EISENBERG: Yes. I think there's at least two 18 ways that human intrusion would have an effect on the Site 19 Characterization Program. One is the one that Dr. Hinze has 20 brought up which is that one of the requirements of the Site 21 Characterization Program is to evaluate the potential for 22 mineral resources. 23 DR. MOODY: Oil and gas too. 24 MR. EISENBERG: As a way of deciding the 25 likelihood of having certain kinds of human intrusion. l () Heritagn Reporting (202) 628-4888 Corporation I
l 181 ,
;i ) 1 The other aspect,.however, is.that an evaluation 2 of the site based on no human intrusion'would consider 3 certain kinds of aspects of the hydrology and the l 4 geochemistry. It is entirely possible that a variety of 1 1
5 human-' intrusion could cause you to investigate some things l 6 that you wouldn't otherwise, so that you can estimate what 7 the consequences of that kind of human intrusion would be. 8 Such as drilling for resources. 9 DR. MOELLER: Well, I think this is a topic on 10 which we need to try to reach consensus and I must say, I I 11 don't know what the consensus is. 12 DR. POMEROY: I must confess that I don't either. 13 I find myself agreement more with Dr. Smith than the others. {} 14 I was just thinking, you know, I know that I've read a lot. 15 I remember ten years ago, fifteen years.ago, you and I were 16 on a committee looking at this and we talked about markers. 17 And how do you mark these things so that some character 18 doesn't come along and drill a hole right down through it. 19 Well, then this gets you into the problem of how 20 do you design markers that may be there 10,000 years from 21 now. I mean there's just no end to it. 22 DR. POMEROY: I think that's probably correct. I 23 understand that that question was brought up, in fact, 24 during the performance assessment review also, and it was 25 solved simply by a lawyer saying, "Well,- the markers will be () Heritage Reporting Corporation (202) 628-4888
182 1 there 10,000 years from now." (~)) 2 (Laughter.) + 3 DR. MOELLER: Well, everybody think about this. 4 DR. POMEROY: One of the most key issues, and Dr. i 5 Smith has correctly pointed this out, is the question of the 6 timing of the performance assessment. That is, the SCP l 7 clearly commits to an iterative performance assessment 1 8 program and as far as I.can tell, that must mean a partial j 9 assessment because in the schedules. The first total system i l 10 performance assessment is going to be carried out in 1993 ; i 11 according to the SCP. And there I can only say, and I think i 12 it's been said before actually, although I'm not privy to ! 13 the CD SCP comments and so forth. I haven't gone back to f 14 read those. But the total system performance assessment, as i 15 I say, should be carried out several times during the Site l 16 Characterization Program to determine at the earliest 17 possible time any required design changes, any possible site 18 disqualifies, and/or required changes or additions to the 19 Site Characterization Program. 20 And my feeling is that the performance assessment 21 should guide the Site Characterization Program rather than 22 or in addition to being the final step in the Site 23 Characterization Program. 24 DR. STEINDLER: Well, having said that, can I 25 infer that you don't find that use of performance assessment l Heritage Reporting Corporation f] (202) 628-4888
183 () 1 as,-for example, a guide anywhere in any of the writings-2 that you've seen'and is that also-true for the staff? 3 DR. POMEROY: No. The staff has.I think. 4 identified that as a concern also. i 5 DR. STEINDLER: As a missing item. q 6 DR. POMEROY: Yes. ! 7 MR. EISENBERG: It's on ' a' page in the Director's 1 8 Report. I think it's page 12, Section 2.6.1. They are very 9 clear on that. There's a point that if you don't do this 10 until 1993, that's only two years before subnittal for the 11 license application. ; 12 -DR. POMEROY: Yes. And that's far too late. 13 There's a final word I'd like taa make on (} 14 performance assessment. I'd like to say first, of. course, 15 there are several other areas of concern as there are in all- 1 16 of these fields that have been expressed by the staff. I've 17 tried to highlight those concerns that appear to me to be 18 the most significant. And not all of which do appear'in the I 19 Director's comments in a clear-cut way. , 20 But I wanted to give the staff the opportunity to , 21 comment to the committee on any special concern that they 22 might have that I haven't covered in these seven points. L 23 MR. EISENBERG: Okay. I think we have a few. 24 Could I just add one thing to this discussion of the l l 25 iterative nature of the performance assessments. Heritage Reporting Corporation (202) 628-4888
184 1 1 The SCP does indicate that performance assessment 2 for the sub-system requirements, the fractional release from 3 .the'EBS, and the container lifetime, and groundwater travel
- 4. time, those will be done in an iterative fashion, but the-I 5 total system performance assessment which, because of some .j 6 of the synergisms involved,'may require different aspects of ;
1 7 site characterization is'not planned as indicated until very .l
;l 8 close to the end of the program.
9 So I just wanted to be. careful that you dori't 10 think that they are not. proposing any type of iterative 11 assessments, but the total system' performance assessment j
'l 12 does not appear to be iterative.
13 DR. POMEROY: Do you think that's--oh, excuse.me. 14 DR.. SMITH: I guess I brought this up once before, 15 and maybe we're too far down the road, but isn't there some 16 approach to performance assessment that'one could use where 17 you would scope out what really the major areas of concern-18 are? Those that if something is wrong you just--you 19 wouldn't even look at the site? And then as you move down, 20 you begin to refine it and refine it, and maybe then at some-21 point you do have a problem, but it's a problem that you can , 22 deal with. It's not a problem that would say that you could 23 not use this site. 24 I'm not sure the right words to try to describe 25 the process I want to talk about. I guess I get a little O rie e- verei-e cerrer tie-(202) 628-4888
185 () 'l bothe :d if all of these things are going on in different 2 places and we are not going _to put it all together and know-3 something until we are way down at the end. It seems to me l 4 we need a process--or should have a process where we look.at 5 this in a macro way and then we' keep refining.it and 6 refining.it and refining it. And if we start out properly, 7 then we'll-know at some point earlier in the game whether or 8 not there's some really major problems. If there.aren't,: 9 what's going to pop up with some minor problem. 10 I'm not sure what we'd call that process. 11 MR. EISENBERG: I would certainly agree that'one 12 should be able to start out with relatively' crude models of 13 performance and then refine them as you get more data. 14 DR. SMITH: That's what I think. (} 15 MR. EISENBERG: Perhaps part of the pieces of 16 puzzle which is more difficult to get at is that some.of the. 17 information that could conceivably fail the site would cause 18 you not to have a different value of a, parameter in your 19 model, but would cause you to have a completely different 20 model. And in that sense, it's less of a refinement 21 process. It's more a process, again, of ruling out these 22 alternative concepts. And that is more of a digital process 23 rather than a continued evolution. 24 DR. POMEROY: But since we've begun this 25 discussion, I think I've--I' d just ask permission. I'd just () Heritage Reporting Corporation (202) 628-4888
186 () 1 _like to make one final comment. And with regard to 2 performance assessment. . 3 Because I think you are right. What I know about 4 performance assessment tells me very clearly that you can do 5 that. You can proceed in a proper fashion. 6 And, again, I'd like to quote from one of the 7 staff's comments. "That as a practical matter, it does not 8 appear that the DOE will be able to generate the joint 9 distribution function." And my comment. And therefore the 10 CCDF. "Or-that the Site Characterization Program will-11 provide any input to that process." And we've discussed the 12 reason for that with regard to the scenario classes. 13 That seems to me to be almost a fatal flaw. If as {} 14 a practical matter-they cannot generate a CCDF to-15 demonstrate compliance.with the EPA standard, and that 16 happens in 1993, late in 1993, what do we do? 17 I'd like to just direct the staff's attention to 18 that and to ask them what is the bottom line there? What do 19 you mean as a practical matter? What does it result in if 20 as a practical matter you can't generate the CCDF? 21 MR. EISENBERG: I don't see how they can 22 demonstrate compliance. I don't think we could suggest that 23 they would have a licensable site. 24 DR. POMEROY: And my conclusion from that is 25 essentially the one that Dr. Smith made, that what.we should () Heritage Reporting ' Corporation (202) 628-4888
187 ()- 1 look for is a rewrite, at'least of' sections of this, t'o 2 provide a clear' indication that the process is well thought 3 out and that we'are considering all'the alternatives and a 4 process that can result in compliance or a possible 5 compliance with the EPA standards. 6 DR. MOELLER: Paul, was the statement you just 7 read in the Director's summary or you're reading'from where? 8 DR. POMEROY: No. That was in the poirt papers. 9 DR. MOELLER: All right. 10 DR. POMEROY: NAE Comment 4. The sixth bullet 11 under that comment. 12 Would the staff care to add anything to the 13 context of that quote? 14 MR. EISENBERG: I don't think so. I think Seth I} 15 would like to add a few words if he could.. 16 DR. POMEROY: I have two general comments after 17 that. But I'm essentially finished with the performance 18 assessment. 19 DR. MOELLER: Go ahead, Heth. 20 MR. COPELAND: This goes back to the discussion 21 that went on a little while ago about human intrusion. 22 There are a couple of points I'd like to add to that. 23 The interpretation that the staff is making that l 24 human intrusion has to be considered in'the context of l 25 developing the CCDF. That's an interpretation that we l Heritage Reporting Corporation (202)~ 628-4888
L l 188 l () 1 checked.out with the EPA and they are in agreement with that 2 interpretation. In fact, that was their intention. 3 The second point is that we think that'in the l 4 definition of unanticipated processes and events in 60.2, 5 there are constraints that are laid out on consideration of 6 human intrusion types of events, scenarios, that we think l 7 serve to limit the degree of speculation'that one could get 8 into in trying to address human intrusion. So. hopefully l 9 that makes the Department of Energy's job somewhat more l
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10 tractab.'s in that regard, i 11 DR. MOELLER: That's helpful. 12 DR. POMEROY: I think the staff has a few words to j i 13 say. I think we've still got like four minutes. {} 1 14 DR. MOELLER: Well, you want to cover your last 15 two general comments. 16 DR. POMEROY: Right. 17 DR. MOELLER: Okay. Go ahead. 18 MR. EISENBERG: I guess one other area of concern 19 is the program for validation. Clearly in attempting to 20 demonstrate compliance with the standard which is based 21 essentially entirely on predictive modeling, validation is 22 going to be a very important issue. And it appears to us ! l 23 that the program that was laid out in the SCP for validation 24 does not seem to be tied in very tightly with these 25 extensive hypothesis testing tables. () Heritage Reporting Corporation (202) 628-4888
189-1 Nor is it clear that some of the validation 2 testing that one might envision that should be started at an 3 early date so that information will be.available at the time 4 that site characterization is concluded and the license 5 application is submitted because some degree of validation 6 will be needed at that time, that those programs are not. 7- proposed. And.that this is another general concern 8 regarding their performance assessment- strategy. 9 DR. POMEROY: I would just like to make.the two 10 general comments. And the committee can read those comments 11 but I'd just like -to say that as a relative newcomer to this 12 particular review process, I went back and_I did try to read 13 much of the pertinent parts of the SCP as well as-the' draft 14 SCA and the point papers. And I simply wanted to identify. 15 again two points, which I understand have come before_you 16 before with regard to the integration question and the: 1 17 question of priorities of investigations. 18 Wiv.h regard to integration, I recognize the 19 integration function that's been added into the SCP as a 20 result of the earlier concerns that were expressed by the 21 staff and I believe by the committee also. < l 22 But in spite of that integration. function, a plan 23 for an overall integration of the characterization studies i 24 was not very apparent to me in reading the SCP. 25 -And at the same time it does seem clear that there 1 b Beritage Reporting Corporation l [ (202) 628-4888 l l l l i I
190 I) 1 are.several-management entities-in the system that might 2 indeed competitively want to perform the integration 3 function, and I believe that the plan should somehow spell 4 -out where the responsibility and authority for the 5 integration function lies as well~as a detailed plan for the 6 performance of that function so that.we can identify that 7 clearly. 8 You've heard the question of priority probably . 9 again and again and I suspect we'll hear it again in the 10 future, but it's certainly cogently expressed again in a 11 recommendation that's contained in KIM Comment 1 in the 12 geology geophysics section which states, " Consideration 13 should be given to prioritizing investigations giving high' (} 14 priority to those investigations associated with tectonic 15 features, events or processes that could lead to the site 16 being considered unlicensable. Or to a substantial change 17 in the Site Characterization Program." 18 As I say here, I believe that statement could 19 apply not only to the tectonics and tectonic events, but it 20 could apply probably to every area that we are looking at. ; i 21 Finally, I'd just like to say that one should have ; 22 the feeling after, as an intelligent layman', after reading 23 the SCP that you've read a document which clearly outlines. ] 24 what is going to be done and how it's going to be done and 25 when it's going to be done. And you should come away with Beritage Reporting Corporation (202) 628-4888 q I
191 1 it with a feeling that this is a plan that, yes, if it's 2 carried out it will answer the questions that will result in 3 the best possible Site Characterization Plan and I for one 4 'did not come away from reading the performance assessment 5~ sections with that feeling. 6 And so I'd like the committee to consider at a 7 later point today or in our later meeting the question cf 8 how, if you agree, how we might proceed to ensure a program l 9 that would provide the residents of the State of Nevada and l 10 the other American citizens that you referred to earlier, 11 Dr. Smith, that assurance. 12 That's all I have, Dade. 13 DR. MOELLER: Well, thank you, Paul. 14 We are at the time for a break. Gene still has QA I,_h
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15 to review. I think though, even though we haven't heard 16 that yet, I do want to make a general comment and that is 17 that the system is working quite well. I've found that the l 18 individual consultant reports to be extremely helpful in 19 helping the committee to focus on what the issues are and , 20 what's important and so forth. And I certainly want to l l 21 compliment each of you on your--thank you for your hard work 22 and compliment you on your reports. 23 DR. MOODY: Dade, I'd just like to say if you are 24 interested in--I only showed about one half of my 25 transparencies, so if you are interested in my comments on
/' Heritage Reporting Corporation ks} (202) 628-4888
.192 i ;(}; l' other parts of the program, you've.got it in the handout. J 2 DR.. MOELLER: Thank you. Let's.take a break. q 3 (Whereupon,'there was a short recess.)
4 DR. MOELLER: Could-we resume please. 5 Gene Voiland will cover Quality Assurance.in forty. j 6 - minutes and what I would:suggest we do is here'from Gene ; 7 Voiland, and then we ought to-take a few minutes for wrap-up 8 items with the staff and then quickly try to.go into 9 Executive Session and try to do any. housecleaning items. 10 Okay. Well, why don't you go ahead, Gene,.then. 11 -with your presentation. 12 MR. VOILAND: Okay. A couple of comments before I 13 get into what I want to do. In fact,.I'll tell you what.I 14 want to do in this review. O 15 First of all, I have a very great interest in 16 Quality Assurance. Because it is an important item and 17 important in itself. s 18 DR. MOELLER: Pull your. mike over.toward you, 19 Gene. 20 MR. VOILAND: I say it's an important item and 21 important in itself in order to get the kind of product,- 22 particularly when you have a very complicated process that 23 has many, many elements and they've got to somehow be ; l 24 organized and integrated. 1 25 MR. VOILAND: Secondly, the NRC, the staff has l Heritage Reporting Corporation j (202) 628-4888 i l i I l i
=, j 193 1 expressed a great deal of interest in this and concern about 2 it. 3 The third thing is that we'know from the 4 discussions of the ESF Title I Program that there is an 5 inordinate amount of concern about perceived efficiencies 6 and quality which has cant questions upon the validity-of 7 this study and the competence of the study. 8 We also know from the reactor business with the 9 sad situation at Brown's Ferry, that if you don't have a 10 good Quality Assurance Program you can get into serious i 11 financial trouble and a lot of difficulty. 12 In getting ready for.this, I reviewed some 13 documents, Chapter 8.6 of the SCP which is the Quality 14 Assurance Plan. I looked at the Yucca Mountain-Quality Plan O 15 88-9 and with the fine cooperation of the Quality-Assurance 16 people in NRC, I looked at the Phoenix and Sisson Plan and 17 their tier of supporting procedures. The purpose of that is 18 to get some idea now of what the Quality Assurance Plan is ; i 19 they will be operating under for Title II. And also asking ! 20 some questions atout what they operated under at Title I. 21 I looked at the Director's Comments which we j 22 recently received and found really that in narrative form 23 they simply addressed the same objections in the comments i 24 that we had before. 25 What I want to do is take a look at the objection, Heritage Reporting Corporation j (202) 628-4888 i
194 i (} 1 'the single Quality Assurance objection, make some comment 2 about that, and look at the comments and'then a general sort i 3 of discussion, if we have time for it, on classification. 1 4 The classification of objects under the' Quality Assurance-1 5 system. 6 The objection, objection QA-1, is an issue because' 7 at one time the-DOE and NRC agreed that there was a need to 8 have in place a Quality Assurance Plan for all participants, 9' Quality Assurance Plans for all participants,' programs,. 10 before the onset of' characterization test studies. 11 And that was agreed on in July of 1988 and then - J 12 there was an affirmation of that in January of 1989. And ! 13 substantial progress has been made in achieving the 14 objectives, but at.the present. time the staff is concerned 1 O. 15 about these perceived deficiencies. l 16 None of the participating organizations has yet-in 17 place an approved Quality Assurance Program and I don't know 18 whether that means that they haven't got something'in-place. 19 that just hasn't been approved or what has been looked at is ; 20 inadequate. And we might have a comment from'the staff on 21 that. 22 The second item was two important QA management 23 positions remain unfilled. And then the third item is.there 24 are QA concerns with the ESF Title I design acceptability 25 analysis that have not been resolved and we discussed those Heritage Roporting Corporation (202) 628-4888
a 195 .; () 1 Lthis morning. 2 NRC's recommendation is that DOE' address these 3 items and bring them to a conclusion in some timely fashion.
. i 4 The staff feels this is important because I don't think-you j
5 can proceed effectively until that's done. And that it will i 6 lindeed effect the quality of the Title.II program. 7 And I believe that the staff position is 8 defensible. They recognize.the importance of having a { 9 program, a QA program in place. That it is an important 10 thing.. They have not however completely tied the hands of 11 Title II development. They have said that for' elements of 12 the Title II program where a case can be made, QA program
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13 elements are in place, they can proceed ahead with that. ; (} 14 And I think that they deal with that on an issue-by-issue, 15 subject-by-subject situation. ! 16 DR. STEINDLER: When~you say you think the staff l 17 " position is defensible, you mean both parts of it? i 18 MR. VOILAND: Yeah. ) 19 DR. STEINDLER: Including the notion that DOE , 20 should fill those positions? 21 MR. VOILAND: Yes. 22 DR. STEINDLER: I guess I have a problem with 23 that. And let me lay it on you just as a matter of comment. 24 MR. VOILAND: I was going to comment a little more i ? I 25 on it. () Heritage Reporting Corporation (202) 628-4888
196 l' DR. STEINDLER: Well, I think the problem I have ]} 2 'is that it isn't very clear to me that it isn't the role of 3 the NRC staff to tell the DOE to fill a particular position. 4 It is, in my judgment, the role of the NRC staff saying that
.5 "You are not doing this right."- And by "this," I mean
- 6. getting the'QA plan in place and executiny it, you know, l 7 executing the program. ;
8 MR. VOILAND: Well-- 9 DR. STEINDLER: But it isn't at all clear to me 10 that it's really the function of the staff to insist in a , i 11 fairly strident tone, as I see it here, about filling a-12 position. 13 MR. VOILAND: Well, I'm not sure--I guess my 14 interpretation was that this is a direction in which the DOE j O 15 had embarked and had intended to do. l j 16 DR. STEINDLER: Uh-huh. : l 17 MR. VOILAND: And essentially agreed to' fill'their 18 roster with appropriate people. 19 DR. STEINDLER: Yeah. 20 MR. VOILAND: Now, if this was NRC coming out and 21 saying, "Do this additional or do that additional" I'd agree 22 with you. But I think that this is probably--I think it's , 23 important for two reasons. First of all, I think they need 24 to have appropriate people. If DOE didn't want those slots, 25 they wouldn't have put them in their organization. They Heritage Reporting Corporation (202) 628-4888
a i i 197 j {} .1 2 called them out in:their organization apparently.
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And then in addition to that, I think it's also an j 3 expression of the concern that DOE has for the program. .] 1 4 DR. STEINDLER: Well, okay,' fine. That's in 5 inferential second order effect. I guess what I'm looking 6 at--my view is that'we.should be judging those folks by what' 7 it is that they- you know, their actual performance in the-8 technical arena. 9 MR. VOILAND: Right. 10 DR .' STEINDLER: The filling or non-filling of 11 slots is a managerial decision which may in fact indicate a 12 kind of lasse faire attitude toward QA, but that's.only a-13 secondary issue. The issue is what kind of performance do q 14 we have? O 15 MR. VOILAND: I think this whole thing'about, you 16 know, the people and the function of DOE with respect. Now, 17 what is their role with respect to QA? And I addressed that l 18 a little bit otherwise, but I'll just'maybe do it,right now. .s 19 DR. STEINDLER: -I made my point, Gene. 20 MR. VOILAND: And that is that the QA--I. suppose l 1 21 the DOE can adopt the position that_we will control-this 22 whole project by a tight QA program and we will require all 23 of our contractors to keep their nose to the grindstone and ')
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24 so on and do that. I think that's the wrong way to go. 25 I think what. DOE needs to do is to provide f Heritage O. Reporting Corporation ! (202) 628-4888 -j l
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'( ) 1 leadership in that~ area. If they've got a whole bunch of 2 contractors working, what I think they have to do is 3 essential provide guidelines so that in quality areas'these 4 . people are all marching to the same drummer. And I think )
J 5 they need to do that. 6 One of-the reasons I looked at the F&S Program
- 7. plan is because just to see what had happened, where they l l
8 stood. And I was very well impressed with the QA plan. I 9 looked at the plan and I looked at the first tier of 10 procedures, and I thought it was an excellent plan. I'would ! i 11 only have one comment I think about maybe improving it and j 12 that is to use flow charts to show how the flow of-work goes . I 13 through the quality system. Something kind of graphic. 14 It's easy to get your eye on and your hands on. (} 15 But in fact, I felt that the F&S Quality Assurance 16 Plan was far better than the Yucca Mountain plan. 17 So I don't know if DOE has been advising F&N or 18 F&S. Or better they ought to advise themselves. 1 19 DR. STEINDLER: Have you plowed through the Yucca i 20 Mountain QAP? 21 MR. VOILAND: What? 22 DR. STEINDLER: Have you plowed through that 23 Quality Assurance Plan of Yucca Mountain? 24~ MR. VOILAND: Yes. I plowed through it. I've got 25 to say I came close to the surface at times. ()- Heritage Reporting Corporation (202) 628-4888 ___________________m-_.___m____
I 199 1 DR. STEINDLER: Congratulations. 2 MR. VOILAND: But I did plow through it, right. 3 And one of the questions that came to my mind is 4 why is this F&S plan as good as it is, and maybe Jim or l 5 somebody could maybe give us some insight. l 6 DR. KENNEDY: You are talking about the F&S plan 7 and procedures? 8 MR. VOILAND: Yes. 9 DR. KENNEDY: Well, the Yucca Mountain plan that 10 you are talking about is the General Requirements document. 11 Actually, it's not that general. It's kind of thick. I 11 2 guess it's about one hundred pages long, something on that 13 order. An F&S QA plan was made up by the designers, by the 14 QA engineers working down in the Phoenix and Sisson 0 15 organization. And I guess they are the ones that have to do 16 it. They are the cnes who know the organization. Who know 17 design control and how to produce designs. And they are the 18 ones who have to use it. And I imagine did a good job as a 19 result of that. l 20 MR. VOILAND: I think that's important. I mean 21 you can go out and hire people to come in and give you a 22 system and they'll give you a generic system which may or 23 may not apply very much. But the people that really do good 24 jobs on procedures and plans are the people that have to 25 live with them and carry them out, and particularly if O Heritage Reporting Corporation (202) 628-4888
200 () 1 they've had some experience and they find out what works and 2 what doesn't work. - 3 So again, it follows the principle of going as far 4 back in the process as you possibly can. And I'm hoping l 5 going back into the process that when we look at the Title i \ l 6 II design, that the Title II designers are going to talk to l 7 the operators of this facility and find out, you know, how l 8 operable it's going to be. It's all nice to have something 1 1 9 that's been neatly designed and so on, but when the 10 architect engineer is done, he goes away and the operating 11 people get to live with it the rest of their lives. And the 12 rest of their life is very long in this case. 13 So I've been in the position myself of dealing
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14 with projects where we would end up owning the facility and 15 be the operators, and I speak in behalf of the operators. 16 I've digressed here. 17 But at any rate, I think it's very important again 18 to have the management committed to good quality. I think 19 almost everybody agrees that you will not have a good 20 quality program no matter what you have on paper if you 21 don't have the commitment of your high management and the 22 commitment of management all down through the line. 23 So I think that's an important thing. 24 We did discover that there was an F&S Process 25 Control Manual which we believe has had some good quality () Heritage Reporting Corporation (202) 628-4888
i 201 ! 1 features that control Title I, so maybe in retrospect' Title ( 2 I can be qualified from the point of view there were quality 3 elements that applied to it. 4 And I'm pleased to be able to say that NRC is s q i 5 auditing the Quality Assurance. - I did talk briefly with 1 Dr. 6 Kennedy about an' audit he attended out at Livermore, was it? 1 i 7 DR. KENNEDY: Lawrence Livermore. .. 8 MR. VOILAND: Lawrence Livermore. And.that's 9 helpful because now we're getting a view from the workers 10 side. 1 11 So anyway, I guess to conclude from that, I see 12 nothing wrong with the objective 1 and I feel that that's j 13 appropriate. 14 Now, in terms of the three comments, there were O 15 three comments that I took a brief look at. One has to do 16 with the qualification of data which might be important to -; 17 safety or to waste isolation, and that fundamentally gets k l 18 back to what I call classification. How do'you classify l 19 these projects, and defer that to a little bit later. 20 The staff suggested there that DOE-should make a 21 list of all engineered items and barriers associated with 22 handling and isolating high-level waste. And then items j i l 23 could be removed from the list as reliable data and suitable l 24 analyses show that a' low level of or no QA is required. 25 What remains is in the list, but at any given time be the Q 4 i l Heritage Reporting Corporation O- (202) 628-4888
202 l l 1 list. So that'says we will take the' universe and assign it. 2 and then chip'away at it. And that's what bothers me a 3 little bit because by that. approach'I see a very large 4 universe of system elements. ; 5 And you know, is that'an effective way of really i
'6 looking at it, or is better.to do some sort of an approach 7 where we can--some kind of a hazards pathway or -
l 8 environmental pathway probabilistic risk assessment:to- l 9 narrow down to those elements which would appear on the t 10 basis of knowledge that we have now to be important to 11 safety and isolation and then work on those. 1 12- All day long we have heard about the difficulties i f 13 of qualifying this site and it just seems that if in 1993, 14 for example, if we find out the site can't be qualified, I-15 would think that a probabilistic risk assessment would be 16 something you'd like to have in your hip pocket.- Because 17 you may have to change the direction of how you do it. 18 We've talked about the DAA. And I would like to 19 spend a little time talking about this question of 20 classification. By classification I mean is what quality 21 level do you assign to the work or the element that you have 22 in the program? 23 And I've probably spent a little more time because i 24 there seems to be a difference of opinion between DOE.and 25 NRC on just how to go about that and to make that real Heritage Reporting Corporation (202) 628-4888
203 () 1 oversimplified, I think NRC-feels you ought.to apply high.
;2 levels of quality, a Quality. Level I, to about everything 3 and then back off.from it.
4 And DOE, on the other hand, says, no, that's not 5 what we want'to do. We don't want'to apply it to anything 6 except the few things that come along. I suspect somewhere 7 in between is the ground. 8 But in reviewEng SP 861, which is the. Quality 9 Program, and I'm not going to read-these words--they simply 10 define the Quality Level 1 will be assigned to safety or to 11 waste isolation. 12 And then they go on and describe a little more. 13 And they come up with essentially six items, six paragraphs, (} 14 where they think application of Quality Assurance Level 1 is 15 appropriate. And I'm just going to try to read.these 16 because then we'll have them. 17 The first one is items relating to the public's 18 radiological health and safety during the pre-closure ! 19 period. And that's straightforward, and as other people ! 20
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have said, there's a lot of precedence for that. Those
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21 activities involved in the pre-closure period, the fuel
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22 handling, cask lifting, fuel transfers, all of that stuff, .j 23 has been done. 24 I recently received the ANS, the standard on the 25 design criteria for an independent spent fuel storage a i g Heritage Repo,rting Corporation (202) 628-4888
204 (') V 1 installation. And I would recommend looking at that because 2 it addresses these very issues and it does indicate in here 3 that there just are not very many hazardous things that can 4 happen or occasions that can release a fair amount of 5 radioactivity. 6 And I was talking with Dr. Moeller about that and 7 he reminded me that--well, no, he didn't remind me because I i 8 didn't know about it.. But he commented that ACRS had 9 written a letter concerning this and it is worth--I think it 10 is worth transmittal to the people involved. Just again, as 11 a reminder of the fact that so much of our concern with 12 radioactive safety comes from that reactor heritage. Where 13 a lot of things can happen fast. Witness Chernobyl, 14 Witness Three Mile Island. 15 But when you get down to these kinds of 16 operations, you don't have any event that brings about 17 instantaneous chaos. And you have time to do things and you 18 have time to deal with them in this pre-closure kind of 19 business. 20 And so I think that's important. 21 DR. MOODY: An earthquake can generate 22 instantaneous reaction. 23 MR. VOILAND: Maybe, maybe not. It may just shift 24 things around. I lived in Seattle. We used t6 have them. 25 It depends, again, on what's the consequences of whatever. (~T Heritage Reporting Corporation (_/ (202) 628-4888 ____ d
205. i 1 (f 1: ' DR. MOODY:- Right. 2 MR. VOILAND: The second item was activities that
-J 3 provide data to assure design that will meet performance 4 objectives of the repository, and I've paraphrased this a 5 little bit.
J 6 Third-is that activities that could adversely 7 impact the. isolation capabilities'have engineered natural j j 8 barriers.- 9 ' Items that are-relied on to' meet the post-closure 10 performance objectives ~of theLengineered barriers of the 11 repository system. And this'gets back into your 12 probabilistic risk assessment. What are those items? But 13 we've said now they are almost everything, i 14 Items which if they failLcould cause a failureLin 15 a QA Level 1 item or irretrievable loss-of QA Level 1-data, 16 and so that's a secondary kind of a thing that would happen. 1 17 And the last of the six items is-the' detailed 18 design of engineered items or systems important to safety or 19 waste isolation will be assigned a QA Level 1 l 20 classification. As the design proceeds, system elements { 21 within the detailed designLwill be classified appropriately. 22 And that's I think what we've heard, is probably:the basis 23 for the NRC position.
- 24 And then these things were addressed in the SCP l
25 CRD. That's the Consultant document. And they've been O erie e- a go.rei e corror eio-(202) 628-4888 o
206 () 1 under consideration and haven't particularly been resolved. 2 But I think the thing that is apparent when you 3 look at those kinds of items that it's really--there's a 4 variety of things there. We have the traditional 5 application of quality. And that traditional application of 6 quality is usually to equipment, buildings, whatever they 7 may be. That they perform the way you want and engineers 8 know how to do that. 9 In the second area, on the other hand, we've got 10 it applying to the gathering of data to test experiments, 11 and research, or whatever you want to call it. And what we 12 are doing there when we qualify a program, one of those 13 kinds of programs, is we simply want to assure that the rs 14 knowledge that we get from those programs is true. Or true V 15 enough. However we define true. That's fundamentally what j l 16 we want to do. l l 17 So we've got two out of those six items where it j 18 has been dictated in a sense through that Quality Assurance 19 Plan that we'll use the term Quality Assurance Level 1 which 20 fall to the non-traditional approach. Actually three of 21 them. 22 And I'm not going to belabor that point. But what 23 this suggests to me is that--and what I perceive also being 24 missing in this classification program is the quality 25 requirements that you tend to associate with the Quality I l () Heritage Reporting Corporation (202) 628-4888
r i 207. I () 1 Assurance levels. In plans that I'have seen or implementing 2 documents, it's customary tovassign a-level to those things 3 that you want to pay a lot of quality attention to. And-4 then on the other-end are those items that you buy from your i
- 5. local hardware store whereLyou really don't care very much" -j 6 about them because they are not very important.
7- And then someplace in the middle you use selective 8 application of quality to get-what.you need. 9 And so I think there needs to be some guidance in' !) 1 10 the requirements.that go along with this. And very
- t :,
11 frequently what's done is you'll make a requirements matrix;
, : i 12 where you look at the various levels that you are going to' i 13 apply.and suggest certain things lthat need to be done.
14 And in the case, for example, of--I've got'a' list' l 15 here for myself. someplace in-here--that relates in the 16 question, say, of equipment design, you have controls on the 17 design. They are very. serious with overchecks and reviews 18 &nd all of that stuff. Procurement--there's a lot of tests, 19 non-destructive tests--a whole lot of things are applied. 20 And I think that the kind of a list of 21 requirements'for that kind of application is very. simple. 22 Now, when you get into this area ofEdata r yI think 23 you need a different kind of a' list. But I think you'also i 24 need to address, and maybe scientists or engineers should 25 get together and what I think DOE ought.to be doingfis ' q l O rie 9- ec **-9 c r (202) 628-4888' tie- >I I i l
208 1 providing guidance to their various contractors. They've f] 2 got'a dozen' contractors or so. Help them in terms of how 3 you classify these things'so that you have an appropriate j 4 classification. 5 I'm a. firm believer, you know, that all sin is.by 6 excess or deficiency. And you. don't want to'overclassify 7 nor do you want to underclassify. .You pay a big price for 8 overclassifying in terms of what you impose.upon'yourself. j 1 9 So I think that, you know, that's worth f i 10 considering, is some kind of guidance or expanded 1 11 consideration of the classification system. I think it's i 12 missing right now because the requirements or suggested 13 requirements are not particularly-- 14 I think also--I'm going to kind of just jump ahead 15 without much basis for-- 16 DR. MOELLER: Yes, we'd better begin to wrap it up i 17 because we do have to do a few of the- . ' 18 MR. VOILAND: I would just speak again with 19 respect to the importance of having some kind of a ; I 20 probabilistic risk evaluation. j 21 When I went through the various parts of the plan, l 22 the SCP, I saw lots of limits that were put on there, anti 23 some of those limits were ridiculously high. And I kind of-l 24 went through in my head and I decided, gee, if we.are on the 25 bounding conditions of all of these things, a thousand Heritage Reporting Corporation (202) 628-4888 l
209 (} 1 percent of the fuel has. failed in ten years, and that is not 2 realistic. And I just asked a few questions here. You 3 know, is the ability of the cladding of-the fuel rods been 4 given sufficient credit in containment of the fuel material? 5 We've got tens of millions of fuel rods that have 6 survived very well for three or fcur years at 500 F. and 7 1,000 or 2,000 PSI water or steam. And that should be 8 considered. 9 You've got the Ocla situation, where some 10 seventeen nuclides remain in the vicinity of this natural
- L1 reactor. The comment that I read was that these'were'found 12 in the ore. You know, maybe we should not think_of that as 13 ore, but that was the fuel, the fuel for that reactor.
14 Maybe what we need to do is redefine something and say that 15 the fuel we put in the repository becomes ore and see if we j 16 think about it differently. l 17 But at any rate, I think one needs to look at { 18 that. ; 19 There was a reference to a defined breach of being
~4 20 1 X 10 atmospheres per cubic' centimeter per second. And 21 that's generally a definition because of reactor operation.
22 What does it mean in terms of storage? I know that in fuel 23 storage in water basins, that's a meaningless thing. It 24- doesn't have any meaning at all. 25 So I think that one has to kind of really look at () Heritage Reporting Corporation (202) 628-4888
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210 ! 1 those things very, very carefully, ,and I don't see any f( ) 2 better way than probabilistic risk assessment. 3 And with that, I think I'will say nothing more 4 except that after being here today and listening to all the l 5 fine comments, I'm going to revise my written data'to the 6 extent--I have good things to say about--I certainly i 1 7 appreciate the cooperation from Dr. Kennedy's organization. 8 DR. MOELLER: Okay. I think perhaps we'll go 9 ahead and stay on the record. We do have to quickly do a ; 10 few things to wrap up before certain people have to depart. 11 At the next meeting, Jack, we have one-- 12 Yes, let's continue on the record for a few I 13 minutes.
.J 14 But at the next meeting we have one day to 15 continue this review.
16 DR. PARRY: We have a tentative schedule here. 17 DR. MOELLER: All right. Well, maybe we'd better 18 go off the record. Why don't we-- 19 DR. PARRY: Excuse me. For writing of the minutes 20 and so forth like that, I think the staff-- 21 DR. MOELLER: It helps. Okay. Stay on the 22 record. 23 Okay. What is it that we're going to do in terms 1 24 of the next meeting because that's rather important to know ! 25 how we're going to approach it, how much more discussion () Heritage Reporting Corporation (202) 628-4888 i
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211 l' we.'re going to have and so forth? I know the first day we 2 have the morning in which we're--now, there seems to be 3 -missing a_10:15 to 12:00 time. I presume that will be 4 continuation of the discussion'with the staff. 5 DR. STEINDLER: Or a long break. 6 DR. MOELLER: Or a long break.
-7 Okay. According to the schedule then, the morning j 8 to continue meeting with the staff for continued discussion 9 of the SCA. And then the afternoon we'11 discuss in
)
J 10 Executive Session what it is we're going to say and try to 11 begin to zero in on our letter. 12 Does that seem reasonable? 13 DR. SMITH: It looks like from about 10:15 to ( 14 lunch and then'all afternoon you have time-to discuss, 15 because--unless we're going to continue-- 16 DR. MOELLER: Okay. I think we'll-- 17 DR. STEINDLER: I would recommend that we see 18 whether we cannot or should not revisit each of the topics 19 we've talked about today. 20 DR. MOELLER: Right. 21 DR. STEINDLER: Plus some issues that I think Bob 22 Browning might want to talk about, and that is the approach 23 to whatever Director's Comments, forwarding letter,.whatever 24 that final package looks like if it's going to be ready by 25 then. Heritage Reporting Corporation (202) 628-4888
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() 1 DR. MOELLER: 'I'would endorse that and say..that' ; i 2- the staff I would hope would be available from 8:30 to noon. , 3 And obviously to stay in the' afternoon. But we'11' start l 4 preparing.;our material. l 5 Now,. Jack, you also had'down assignments of c 16 writing. Well, I am not too enamored with'that approach. - 7 I'll be glad to try.to begin'to draft a first letter-on the j 8 basis of what's been said today.
'l 9 Now, another question is, the staff has heard our. l 10 comments today. Will you consider those--in other words, 11 how much more--are you going to redraft what you've already .j j
12 given us and indeed if you do, will our comments be factored j I 13 in to whatever degree you accept them? ! (} 14 15
.MR. LINEHAN: We're still going through the' final stages of polishing the SCA, the point papers, and Sections 16 II and TII. And indeed we will go through and exercise 17 where we consider.the comments that were made today.
18 DR. MOELLER: And I'm not saying it in the light. 19 that you must accept all of them, but at least you'll be 20 considering_them as you polish. : 21 MR. LINEHAN: Indeed'we will. 22 DR. MOSLLER: Fine. l 23 MR. LINEHAN: The other thing,'I would-a3k if any 24 of the members or consultants come up with any other. major 25 concerns, if they could be passed on to us prior to the next () Heritage Reporting Corporation (202) 628-4888- _ - _ - - - - - _ - _ _ _ _ _ _ - _ _ _ - __A
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- l' meeting.
2 DR. MOELLBR: All right. 3 MR. LINERAN: Because our schedule,is'to try'to
'4 get the SCA to the Commission I believe by the'30th of June.
5 .DR. MOELLER: Right. 'And that's why we scheduled
-6 again our meeting the first day of our three-day--I mean 7 this subject the'first daysof the'three. days. And I-don't 8 imagine we're going to come at you with any. additional:
9 shockers, so to speak. 10 MR. BROWNING: If I could just generally summarize 11 what I think I heard. 12 DR. MOELLER: Yes. 13 MR. BROWNING: What I think I heard'is no basic 14 disagreement with the kinds of comments we've'made. It's O 15 more a matter of the emphasis. i 16 DR. MOELLER: Right. 17 MR. BROWNING: Of the comments. And basically j 18 that's the purpose of the Director's Comments, I think at 19 Section II, is to try to sort through that pile of detailed 20 comments that came out of the individual staffer's reviews 21 and try to put that in some kind of.overall perspective that 22 will make sense to the DOE management people that have to' 23 take this pile of comments and deal with it. 24 I would like to just clarify.one point. Under the 25 law and under the regulation, all DOE has to do is to 6 Heritage Reporting ' Corporation (202) 628-4888
214 1 consider.our comments before starting the characterization 2 program, and typically starting the characterization program 3 is' equated by sinking the shaft, even though there are a lot 4 of other pieces of the site characterization that are also 5 important. 6 The kind.of-flavor that's going to'come.out of. 7 those Chapter II-comments, any insight that you as a-8 committee could give us in advance of your meeting as to 9 what you think that ought to be like, we would appreciate it 10 so that we~can try to factor that into our comments. 11 What we'd like' to do is by the time you .have your 12 meeting and finalize your comments, our final paper comes 13 out and we've thoroughly integrated your comments so that-- 14 kind of like we've been doing. We've been doing it in O 15 parallel. It's not the most efficient use of your resources 16 because you are basically having to look at things two, 17 three, maybe four times as they wind their way through our 18 system, but I think it's given you a good idea of the 19 process that we go through to try to come up with comments 20 for DOE. 21 DR. MOELLER: I think that's fine. And I again 22 hesitate about having individuals call you with additional-23 insights. It should be--maybe call me and let me know if
- 24 you come up with something and then I can feed it on.
L 25 I believe today you've heard the flavor of what we Heritage Reporting Corporation N - (202) 628-4888
215 {} 1 have to say. j 2 I had a couple of quickies. The NUREG 1168 was 3 cited as an outstanding example of Low to develop a Q' list. 4 Could someone explain to me how it is this outstanding. 5 example? l t 6 MR. BROWNING: Mr. Kennedy was prepare.to doLthat 7 but I think he's-left. When given that assignment,'he left. 8 MR. TRAPP: The comment that you were referring to J 9 actually wasn't generated by the QA section. It was , 1 1 10 generated by a geologist. Myself. This is John Trapp. I 11 That is not listed or stated as a comment which is 12 an outstanding example of how to generate a Q list. The 13 comment basically specifically is referring to system- , i 14 structures and components important to safety. And is :
'~
15 referring as an analogy the similarities between the MRS and 16 the pre-closure facilities, especially the surface 17 facilities. And basically suggesting that taking a look at 18 this NUREG would give you an idea of which items.should 19 probably be on the Q list. I 20 DR. MOELLER: Okay. You might read carefully what ' 21 you said so that dumb people such as myself in reading it 22 don't misinterpret it. ; 23 MR. TRAPF: Well, I'll admit that in writing it I-24 went from A to C and I skipped the B step and I'll put'in'a 1 25 . sentence to make sure B is there. ' A]
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1 216 (} 1 DR. MOELLER: Okay. Cliff or Marty, do you 2 either--Bill, you'll be here. Do you have any quick I 3 questions? 4 DR. STEINDLER: I have one comment. I think the j I 5 issue that you brought up, Gene, on the approach to the QA j 6 list. The really quite severe difference between DOE and 7 NRC ought to be highlighted someplace as an existing major 8 issue. It's going to continue to perpetuate through the 9 system. It's going to be an ongoing dialogue, to put it 10 kindly as to how to work this system. And it sure would be 11 nice if some agreed compromise could be reached on how to do 12 this period. ! 13 MR. VOILAND: I kind of like this additional g 14 guideline that will help people make these de sions. \_) 15 DR. STEINDLER: Clearly they are all there. ,
\
16 MR. VOILAND: Yes, but there are some words there l 17 in the Quality Assurance Plan that say they will put all of 18 these on and then take them off later. And I really think 19 that's very difficult, because it's hard to reduce the 20 quality plan. 21 DR. SiIINDLER: I don't think you can do it. 22 MR. VOILAND: It's very dffficult to do. 23 DR. MOELLER: Okay. All right. Thank you. 24 A comment which I asked this morning and I guess I 25 don't remember the answer or it didn't register and that was
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Heritage Reporting Corporation (b} (202) 628-488P
1 217-1 in Section 3.2.6 where it said that the goal for the ( 2 probability of the saltic volcanism is set such that if met 3 the site will not meet the EPA standard. 4 Juud I mentioned that I considered that perhaps a.
~
5 fatal flaw. .Now, what was the response? Or why is it not I 6 mentioned ever again? 7 MR. TRAPP: I guess there's some reason why I did. 8 stick around for the rest of the day. 9 Specifically, that comment is not referring 10 directly to what the staff's thought's on the abilities of - 11 the site are to isolate waste. What that' comment is 12 referring to is a. performance allocation process. And it's-13 ' basically a case where the staff feels that the goals that 14 have been allocated by DOE are set too low. That the way 15 the goals are set, if those themselves are met, the site { l 16 will be failed. 17 What we are suggesting is that in this specific 18 case, in this comment, that they need to reexamine the goals 19 so that therefore the various investigations which are 1 20 designed to meet these goals are adequately stated. 1 21 So that the investigations which are designed to 22 gather the information to meet these goals are adequately ] 23 organized and addressed. 1 24 DR. MOELLER: All right. ; 25 Do we have any other technical questions or 'l I Eeritage Reporting Corporation I (202) 628-4888 i i i i
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1 subjects for discussion with the staff? (' } 2 Okay. Not hearing.any I think then, Jack, with 3 your. concurrence we could bring the formal portion of the 4 - meeting to a close. l 5 We'll go into Executive Session just very briefly 6 to talk. 7 Let me put on the record our appreciation to the-8 Reporter for bearing with us today and our thanks to the NRC 9 staff for what I'm sure is a long day. And it's undoubtedly 10 one that's repetition for you because I'm sure you've gone 11 over these same things with other people. But it's been 12 very helpful to us. 13 And I think we are zeroing in on what we consider 14 to be the major issues. And I hope it's been helpful to 15 you. 16 Thank you. 17 (Whereupon, at 4:30 p.m., the proceedings were 18 concluded.) 19 20 21 22 23 24 25
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Q 1 CERTIFICATE 2 3 This is to certify that the attached proceedings before.the 1 4 United States Nuclear Regulatory. Commission in the matter 5 of: q 1 6 Name: lith ACNW Meeting 1 7 8 Docket Number: 9 oloce: Bethesda, Maryland 10 Date: June 13, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof frr 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 l 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing i 17 proceedings. , 18 /a/ p tan Y /28// 19 (Signature typed) : Irwin Co;Ionberry y, ; l 20 Official Reporter l 21 Heritage Reporting Corporation 22 23 24 I 25 O Heritage Reporting Corporation f (202) 628-4888 i j l l __ _ _ _ _ _ - _ _ -}}