ML20245D356
| ML20245D356 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0009, NACNUCLE-T-9, NUDOCS 8904280262 | |
| Download: ML20245D356 (230) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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Working Group of the Advisory)
Committee on Nuclear Waste )
i O Pages: 1 through 188 Place: Bethesda, Maryland Date: April 19, 198 , I g
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'~ O 1- PUBLIC NOTICE BY THE 2 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 3 ADVISORY COMMITTEE ON NUCLEAR. WASTE 4 April 19, 1989 5
'6 7 The contents of this stenographic transcript of 8 the proceedings of the United States Nuclear Regulatory 9 Commission's Advisory Committee on Nuclear Waste (ACNW), as 10 reported herein, is an uncorrected record of the discussions 11 recorded at the meeting held on the above date.
12 No member of the ACNW staff and no participant at 13 this meeting accepts any responsibility for errors or 14 inaccuracies of statement.or data contained in this 15 transcript.
16 17 18 19 20 21 22 23 24 25 O
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: -)
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Working Group of the Advisory )
! Committee on Nuclear Waste )
Wednesday, April 19, 1989 7920 Norfolk Avenue Room 422 Bethesda, Maryland The meeting convened, pursuant to notice, at 8:30-a.m.
BEFORE: DR. DADE W. MOELLER Chairman, ACNW Professor of Engineering in Environmental Health Associate Dean for Continuing Education School of Public Health Harvard University Boston, Massachusetts CONSULTANTS:
WILLIAM J. HINZE MELVIN CARTER JUDITH B. MOODY DONALD ORTH EUGENE E. VOILAND COGNIZANT ACNW STAFF:
S.J.S. PARRY Designated Federal Official 2
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APPEARANCES (cont.)
PRESENTER:
1 ROBERT M BERNERO I
Director, Office of Nuclear Material Safety and Safeguards 1
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(_) 1 PROCEEDINGS 2 DR. MOELLER: The meeting will now come to order.
3 This is a meeting of a working group of the 4 Advisory Committee on Nuclear Waste.
5 I'm Dade Moeller, Chairman of the ACNW.
6 The other members of the ACNW are Martin Steinler 7 and Clifford Smith, neither of whom was able to attend 8 today's session.
9 We have a team of consultants with us, beginning 10 on my left with Eugene Voiland, William Hinze, Donald Orth, 11 Melvin Carter, and on my right, Judith Moody.
12 Today's -- during today's meeting, the committee 13 will hear presentations on the Draft Waste Confidence
() 14 Findings and the status of the preparation of the site 15 characterization analysis by the NRC staff.
i 16 While both topics represent significant actions by 17 the Commission, it is worthy of comment that because of the 18 importance that the committee has placed on the SCA, three 19 additional meetings, including this one, have been scheduled j 20 in the next two months to discuss this matter in more depth.
21 We look forward to a detailed open discussion of 22 the technical concerns of the staff relative to the content 23 of DOE's SCP.
24 Since this is the first working group meeting of 25 the ACNW, perhaps a few words of comment will be in order.
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( 1 Our purpose is to. gather data and to begin to reach initial 2 conclusions.and to formulate suggestions for forwarding to 3 the full committee for their consideration.
4 Another andLequally important purpose of the 5 working group meeting is to give us an opportunity to hear 6 -about a subject, then to return home or wherever and think 7 about it before we have to formulate our final comments.
8 .Often times, if we're given an opportunity to 19t1 9- a topic simmerJon a back burner for a week or two,.certain 10 aspects become more clear, and I believe our advice is, 11 therefore, better.
12 The two topics that we're covering today.are 13 certainly.in this category, and I believe that this approach
() 14 will be beneficial to all of us.
15 The meeting is being conducted in accordance with 16 the provisions of the Federal Advisory Committee Act and the 17 Government in the Sunshine Act. Dr. S.J.S. Parry is the.
18' designated federal official.for the meeting today.
19 The rules for participation in the meeting have 20 been announced as part of the notice that was published in 21 the Federal Register on April 6th, 1989. We have received 22 no written statements or requests to make oral statements 23 from members of the public regarding today's session.
24 A transcript of all the portions of the meeting, 25 except the executive session this afternoon, will be kept,
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5 1 and it is requested that each speaker identify himself or 2 herself and use one of the microphones so we can hear you 3 and speak with sufficient clarity and volume so that the 4 reporter can record your words.
5 Before I move on, Dr. Parry, you have a comment or 1
6 two.
7 DR. PARRY: I just wanted to bring to the 8 attention of the consultants. You have a package and rather 9 than just mailing this out to you, we have provided it here.
10 You can either take it home with you directly or it will be 11 shipped to you in the normal course of events.
12 This package is aimed toward information for next 13 week. The briefing packages for Dr. Smith and Steinier's
() 14 presentations will be given to the Commission on Thursday 15 morning. They're really being provided for your information 16 purposes, not for direct reference or any action of the 17 group.
18 DR. MOELLER: Thank you, Jack.
19 We'll move on then with the meeting. As you'll 20 note from our agenda, this morning we're talking about the 21 waste confidence proceeding findings, and the leader for 22 that will be Robert Bonero, Director of the Office of I
23 Nuclear Materials Safety and Safeguards, 24 Before I turn the floor over to Bob, let me just 25 ask if any of the consultants have questions or comments at
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.O 1 this time.
- . 2 .(No response.)
3 DR. MOELLER: There being none, then, Bob, the 4 floor is yours.
5 MR. BONERO: As a practical matter, I think it 6 will be best if I sit near the microphone and go through 7 these slides. My staff will put them up as we go along --
8 'DR. MOELLER: Fine.
9 MR. BONERO: -- to facilitate attention, and the 10 projected time is a little uncertain to me because I've gone 11 through this presentation. I think the content is here to 12 cover the whole subject and cover it at an appropriate pace 13 and depth. But I'm not sure how long it will take. It
(( ) 14 depends on questions and naturally I welcome questions as we 15' go along.
16 I sent to you, Dr. Moeller, the preliminary draft 17 of the waste confidence review group proposed waste 18 confidence decision, and we're in a delicate balance here 19 because the NRC does operate in a public environment, but we 20 are undertaking here a task for the Commission this year, 21 and we are at the pre-decisional stage.
22 So, I asked you with the draft waste confidence or 23 proposed waste confidence decision to withhold it from 24 public distribution because it is pre-decisional, and it is 25 the draft of what we would submit to the Commission, as I'll Heritage Reporting Corporation t(]) (202) 628-4888
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) 1 talk on the schedule shortly.
2 On the other hand, we prepared slides that you 3 have, and I have no objection to your releasing them, and 4 the fact be known, the content is delineated, and the 5 dialogue will delineate it, so we're sort of on a teeter-6 totter here about how much is pre-decisional and how much 7 isn't.
8 But, in simple terms, the actual text analysis I 9 prefer is not released to the public, and the slides may be.
10 DR. MOELLER: Fine. We'll abide by those -- by 11 that guidance.
i 12 MR. BONERO: Really, what's happening here, if you 13 go back -- go ahead with the next one. The background of O
ts ,j 14 this thing goes back to a petition in the mid-1970s where 15 the argument was made that it was not appropriate to 16 continue licensing reactors or to amend reactor licenses, 17 thus enabling the continued generation of high-level waste, 18 absent a solution to the high-level waste problem.
19 And as we indicate here, there was this Natural 20 Resources Defense Council petition in 1976 that basically 21 said you shouldn't do that. You shouldn't continue to ;
22 license reactors, and in 1976, there were two utility 23 requests involved, this is Prairie Island and Vermont 24 Yankee, and recognized at the outset that that was 25 circumstantial. Two older reactors, those are two of the
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(,)s 1 earlier reactors, that happen to be running into congestion 2 in their spent fuel pools and were requesting amendments to 3 expand spent fuel storage, and the fact that they were on 4 the table drew them in.
5 So, suddenly, the Commission is confronted with 6 the generic issue and the vehicle for considering those two 7 particular cases. Well, the Commission denied the petition 8 and the license amendments were granted to those two cases.
9 Then, a few years later, U.S. Circuit Court of Appeals ruled 10 on the matter. It did not change those amendments. It did 11 not go after the specific cases that the Commission had 12 acted on, namely Prairie Island and Vermont Yankee, but it 13 did say back to the drawing board, Commission, you've got to
() 14 deal with that generic issue, and in dealing with that 15 generic issue, the Court carried this 2007 and 2009 date.
16 It's one year plus or minus one. It's a peculiar 17 precision that happens to coincide to the licensing time 18 table on the record for those two reactors. The, you know, 19 operational expectation and so forth, when the licenses 20 would expire. That's a very important point that you sense 21 that, once again, circumstances in the two cases brought 22 into the court proceeding and into the mandate laid on the 23 Commission by the court, a consideration focused on a very 24 sharply defined date well off into the future, namely 2007 25 to 2009.
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9 1 DR. CARTER: Bob, could I ask you one question?
- 2 When the licenses were amended for additional storage, how 3 'much storage did that include in terms of expected
-4 production of fuel elements for those two reactors?
5 MR. BONERO: Not lifetime. Not lifetime. What has 6 actually happened and l've lost track, we've'got a detailed 7 record if you ever want to look into it, some reactors have 8 modified as many as three times.
9 :The prediction of how much spent fuel storage they 10- would need has not in virtually all cases, has not included 11 life of the plant. Typical PWR in its life, a good sized 12 one, will discharge 2000 spent fuel assemblies. That's far, 13 far more than you can squeeze in, and what they've done is
() 14 they've looked over a planning horizon of'maybe five years 15- or ten years, expecting that either early on the 16 reprocessing' issue would be resolved or the MRS issue would 17 be resolved or the repository itself would be resolved, that 18 somehow or other there would be a place to send the stuff, 19 and, so, I can't tell you offhand what those first 20 amendments were, but they were modest increases.
21 Now, typically, doubling the capacity or two and a 22 half times as much. A few more years. Typically, it just 23 adds relatively a few more years. Not the life of the plant.
24 DR. CARTER: I can see the reason for not wanting 25 to go too far, hoping other things will happen, but what
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\~/' 1 about the NRC now? Would you impose a limit, for example, 2 if they asked for fifteen years storage capacity versus 3 five?
4 MR. BONERO: It gets sticky. basically, you look 5 at the pool. I've been in hundreds -- well, not hundreds of 6 reactors, but many, many dozens of them. Some have big 7 pools, some have little pools. The early expansions were 8 basically just take the margin out and using ordinary 9 stainless steel construction, a little more dense, and 10 getting maybe a fifty percent or a hundred percent increase 11 in capacity.
12 As things got more elegant, we have gotten to the 13 point where people have taken laminated stainless steel with (Q_) 14 borrel strips in the middle and a lot of elegant ways to 15 suppress criticality or other safety hazards, and there is 16 no demarcation of capacity. It's more like a qualitative 17 threshold of complexity in the spent fuel management, 18 getting too complex, too close to the criticality limit, too 19 close to the thermal limit.
20 Fortunately, when you add spent fuel capacity, 21 you're really adding old fuel. Now, the fresh out of pile 22 fuel is still the same quantity, and, so, the heat load 23 you're adding is usually lower, but, still, when you really ,
l 24 start backing it up, how many coolers you have, what's the 25 time constant to warm it up, we have no threshold of actual i
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.e 11' 1 you can't go beyond so many assemblies or beyond such and so 2 capacity. It's qualitative.
3 DR. CARTER: Because the' major thing would be if 4 they actually have to. construct the storage booth.
5 MR. BONERO: Well, as the -- the dry storage, the 6 whole development of dry storage has changed the complexity 7 of it. The technology is now available. We'll be talking 8 about that as we go through. The technology is now available 9 that you've got a much different horizon, and the focus is 10 shifting dramatically from squeeze it into the pool to get 11 another couple of years, a broader horizon, both for us and 12- for the utility.
13 DR. CARTER: Okay. You looked at what they 14 requested and you don't have any absolute limit on it?
15 MR. BONERO: That's right.
16 DR. CARTER: Case-by-case determination?
17 MR. BONERO: Nor do we so far direct them on it.
18 DR. MOELLER: Go ahead, Judith.
19 DR. MOODY: I wanted to go back to the original 20 first slide and just make sure that I understand what you're L 21 saying, and you said here that NRC not grant operating l
22 licenses or amendments until buff finding or safety can be 23 made.
l 24 Does this mean -- let me translate it another way, 25 and say that the NRC was going to agree to let the operating
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(_) 1 plants continue and then resolve this storage problem? Is 2 that the bottom line?
3 MR. BONERO: Well, at the time of the petition, 4 that's a factor. Whether the petition needed to be 5 interpreted as let existing licenses operate but don't add 6 new ones or don't amend existing ones, that certainly is a 7 debatable matter.
8 The NRC never made a decision on whether to 9 distinguish that way from saying just quit permitting the 10 generation of high-level waste, which would imply suspending 11 operating licenses that are in existence and not waiting for 12 the simple peculiarity of the guy that runs out of spent 13 fuel storage.
() 14 See, the amendments in this context were 15 amendments to the license needed because just by 16 circumstance, that reactor was licensed with a spent fuel 17 that could only hold enough spent fuel to permit operation 18 for five years after the receipt of the operating license or 19 some limited time period.
20 It was circumstantial that that particular or 21 those two particular reactors happened to be about to run 22 out of spent fuel storage. It wasn't inherent in being a 23 reactor of that vintage. It's just that when they built, 24 they built the pool that size, and the fundamental thrust of 25 the petition was the NRC is not environmentally responsible
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13 p) j 1 if it permits the generation of high-level waste absent a 2 disposition for high-level waste.
3 That's the essential thrust, and the Commission 4 never came to a decision that would make that distinction of 5 we'll only let you operate as long as an unchanged license 6 - permits it. It would be an artificial distinction.
7 DR. MOODY: Yes, but you interpret that then to 8 mean that the plant can continue operating and the storage 9 of spent fuel is a separate issue or can be handled within 10 that license, is that correct?
11 MR. BONERO: Oh, no, no. The way those licenees.
- 12. were written, the storage of spent fuel was limited to so 13 many slots in a water pool. The license included specified 14 size and capacity of a pool built right into the plant and
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15 the fact of operation was every year, sixty-nine fuel 16 assemblies came out of the reactor and went in that pool, 17 and you could count the years and you'd run out of space in 18 the pool. That's just the way the licenses are written, and 19 the only way out of it then to permit forty years of 20 operation is to -'end the license to say you're permitted to 21 modify the pool, to hold more spent fuel or some other spent 22 fuel storage option on the site.
23 The license always presumed that spent fuel would 24 be shipped away more or less as fast as it was generated.
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3 DR. MOELLER: The comments I had were as follows:
4 all of the amendments to the licenses have been to increase 5 the number of fuel assemblies that can be stored in the 6 existing pool. None of them have been to build added pool 7 space, am I correct?
8 MR. BONERO: Well, the modifications include new 9 racks, but they haven't built new civil structures.
10 DR. MOELLER: Right. No one has built a second 11 pool?
12 MR. BONERO: No, no. No one to date.
13 DR. MOELLER: And the reason that I historically
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E 14 recall, if I'm correct, was that if you built an added pool 15 or, you know, made the existing pool twice as big, you had 16 to file an environmental impact statement; whereas, you 17 could expand or increase the number of assemblies going in 18 to the existing pool and that did not require an 19 environmental impact statement.
20 MR. BONERO: I'm not so sure that that was the 21 driving reason rather than economics.
22 DR. MOELLER: John?
23 MR. ROBERTS: John Roberts.
24 DR. MOELLER: Get near a microphone.
25 MR. ROBERTS: John Roberts, Section Leader,
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2 And, basically, you are not required to do an 3 environmental impact statement for storage under Part 72 at 4 .a reactor site'and if you. built an additional separated pool 5~ at a reactor site, that would come under Part 72.
6 The -- and our lawyer can correct me if I'm wrong 7 here, but, basically, it allows either -- you have to do an-8 environmental-assessment, and it could be basically a 9 finding of no significant impact environmental assessment or 10 something more major there, obviously it would be 11 environmental impact statement.
12 But, to date, also there's a historical divergence 13 here. People are building dry storage on sites rather than
() 14 additional pools, and I think that's largely economic.
- 15. MR. BONERO: Yes._The underlying thing, if you 16 stop, the early attempts to add to spent fuel storage had a 17 short planning horizon, you know, another few years, and 18 when you look at a separate pool and certainly it was 19 envisioned that there was the possibility of a separate 20 pool, the simple capital costs of it suggests that you would 21 only undertake a separate pool investment if you were going 22 to take another few years from a lot of reactors or life of 23 the plant from a set of reactors or something like that, and 24 there just wasn't the incentive to go in that direction.
25 There wasn't an expectation that you needed to do it.
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16 i ) l' ~ DR. MOELLER: Okay. Now, for the dry cask on site 2 _above ground storage of spent fuel. Somebody, I guess, did 3 an environmental assessment and decided no environmental i i
4 impact statement was required or -- 1 5 MR. BONERO: At the reactors, yes, that had been 6 licensed.
7 DR. MOELLER: Okay.
, 8 DR. HINZE: May I speak also to Dr. Moeller's 9 question?
10 At least I believe it's so at Calvert Cliffs. When 11 they put in Unit 2, a second connected pool with the first 12 pool was installed.
13 MR. BONERO: Oh, yeah. A lot of the later model
() 14 reactors saw this problem coming and had design changes. For 15 . instance, the Carolina Power and Light Company, which owns 16 three reactor stations, all of substantially different 17 vintage, H.B. Robinson, a very early one, Brunswick, an 18 intermediate one, and Sharon Harris, a later one, they 19 deliberately built larger capacity into the later units and 20 got a license to move spent fuel from the earlier site to 21 the later site, just to have more room, and they even went 22 out and bought spent fuel casks in order to have the 23 transshipment capability.
24 DR. MOELLER: Okay. Thank you.
25 MR. BONERO: Let me have the findings view-graph
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(_) 1 next.
2 Basically, the Commission, in 1984, came to grips 3 with this by making five findings. Now, these are findings 4 fundamental to the issue of the generation, the storage, and 5 the ultimato disposal of high-level waste, and, in 6 particular, high-level waste in the form of spent fuel, not {
l 7 simply in the old concept of fuel reprocessing or whether or 8 not there should be fuel reprocessing.
9 So, the key findings, the five findings that the 10 Commission made in 1984 are, first and foremost, that it is 11 feasible to dispose of high-level waste, that there is 12 sufficient reason for the Commission to have confidence that 13 sooner or later high-level waste disposal is feasible.
() 14 Secondly, and, here again, we get that peculiar 15 date, the repository, at least one repository, will be 16 available on a time frame commensurate with those two cases, 17 sufficient capacity within thirty years to dispose of all 18 spent fuel and high-level waste generated.
19 So, they're saying not only is a repository 20 feasible, but it's going to be a big enough repository to l 21 gather in and dispose of what's on the plate now. What is 22 committed to now with the generation of reactors the 23 Commission has licensed and, remember, in 1984, we were 24 still licensing at a fair pace. It's only now that we're 25 finally taking the last of the first generation into Heritage Reporting Corporation
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2 DR. MOODY: Bob, can you remember what the 3 Commission's thinking was to come up with-these years, 2007 4 and 2009?
5 MR. BONERO: Oh, the years are tied strictly to 6 the operating licenses of those two cases.
7 DR. MCODY: Okay.
8 MR. BONERO: Yeah, and it's how long on paper 9 those two reactors would operate. That's where that date 10 comes from.
11 And the spent fuel, the third finding, that spent 12 fuel and high-level waste will be safely managed, that it 13 won't be a significant hazard there, that spent fuel can be I) 14 safely stored for up to thirty years.
15 Now, keep in mind the time concepts here. In 1984, 16 it was general opinion that a reactor operating life would ;
i 17 be forty years, that there would be a generation of time i 18 after operating life wherein decommissioning and what have 19 you would be undertaken, and there was associated with spent 20 fuel storage the forty year of operating life span and 21 thirty years afterward for post-operational storage as some 22 sort of time frame, seventy years, associated with the range i
23 of existence for spent fuel and storage, l
24 Now, obviously, if you've got a forty year life 25 and thirty years afterward, the spent fuel ranges in age
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-1 19 qi s_j . 1 from thirty years old to seventy years.old, you know. The 2 first out of pile versus last out of pile.
3 That will come up more as we talk, this finding 4 about the thirty years, and then, fifth, that sufficient on-5 site or off-site storage capacity will be made available if 6 needed.
7 Again, in 1984, the sufficient on-site was baeed 8 on pool modifications in the short range and the possibility 9 of independent spent fuel storage, Part 72 existed then,_and 10 it was'this independent spent fuel storage that was 11 envisioned as picking up the slack.
12 Now, I'believe we furnished you very early on the 13 background book for the 1984 decision, a rather hefty tomb,
(]} 14 some copies of it. We put together what amounts to the 15 bibliography of the 1984 decision, and what we're doing in 16 the present context is the reconsideration.
17 So, I'm going to focus on what's new, what's 18 different.
19 DR. MOELLER: Now, back on Number 2, I and Dr.
20 Moody asked and I understand the 2007 to 2009. Then, 21 sufficient capacity will be available within thirty years.
22 Does it mean that within thirty years after 2007 to 97 23 MR. BONERO: No. The repository is available and 24 the capacity of the repository is thirty years. It's the 25 idea of the repository opens in 2007 and 9. So, you might Heritage Reporting Corporation (202) 628-4888
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-( ) 1 say Prairie Island's fuel goes in the hole, but'the capacity 2 for the fuel generated is~ implied, also, in that finding.
3 DR. MOELLER:- Well, what I don't understand --
4 MR. BONERO: A big enough repository.
5 DR. MOELLER: Right. To handle all the fuel, but 6 what -- where-does the thirty years apply? I don't know 7 where that starts and where it ends.
8 MR. BONERO: It's my understanding, and I welcome 9 comment from staff on it, my understanding is it applies to 10 the 2007 plus thirty or 2007-9 plus thirty.
11 DR.-MOELLER: Okay. So, --
i 12 MR. BONERO: I don't think --
13 DR. MOELLER: -- in 2007 to 9, there will be at
() 14 least one repository ready and taking fuel, and by 2037 to 15 '39 there will be --
16 MR. BONERO: Enough capacity.
17 DR. MOELLER: -- enough. capacity for all the fuel 18 --
19 MR. BONERO: I think that's what --
20 DR. MOELLER: -- and then that ties into Number 4 21 that you can safely store it somewhere for the thirty years.
22 MR. BONERO: Yeah. Rod McDougal might be able to 23 clarify that, I think.
24 MR. McDOUGAL: Yes. The idea was that thirty 25 years beyond the expiration of the current operating Heritage Reporting Corporation
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(/ 1 licenses, that there would be sufficient capacity to dispose 2 of the spent fuel generated in any reactor.
3 Finding 4, which Finding 2 implicitly addresses, 4 says that the Commission finds reasonable assurance that, if 5 necessary, spent fuel generated in any reactor can be stored 6 safely and without significant environmental impacts for at 7 least thirty years beyond the expiration of that reactor's 8 operating license, and Finding 2, you'll notice, has the 9 repository sufficient capacity available within thirty 10 years.
11 DR. MOELLER: Thank you.
12 DR. CARTER: Bob, can I ask you a question about 13 Item 5?
() 14 I presume of those, the one that's really gone off 15 track, in essence, from what was envisioned earlier in '84 16 and earlier than that is the off-site storage aspect rather 17 than the on-site storage.
18 MR. BONERO: To a degree, yes. The MRS was in '84 19 was more of an assured thing and right now we'll talk about 20 that. The MRS now is almost moot. So, that's right, but I 21 think we'll deal with that in the change.
22 DR. MOODY: Well, tied into the storage on-site, 23 is that -- is it inferred that DOE will monitor and pay for 24 the continued storage?
25 MR. BONERO: No, no. The Congress has recognized c.
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22 k_) 1 interim storage as a responsibility of the utility, and 2 that's clear in the Waste Policy Act.
3 The next one, please. The waste confidence rule 4 makings -- remember, the Commission was sitting there making 5 a policy conclusion, really the waste confidence is like a 6 policy statement, and there were attendant rulemakings in 10 7 CFR 5054 and 5123, the environmental reiemaking, and the 8 Commission undertook those rulemakings as a corollary of the 9 waste confidence finding, and they were quite 10 straightforward.
11 It said within five years of your operating 12 license expiration, tell us what you're going to do with the 13 spent fuel, and remember, technically, we don't count spent
() 14 fuel management as part of decommissioning. If you read our 15 decommissioning rules of the NRC, decommissioning involves 16 residual contamination or eradiated material or whatever, 17 activated material, but it does not involve the spent fuel 18 itself. That's handled as a separate discreet entity.
19 The environmental regulation, 5123, then 20 identified what you needed to do for license amendments or 21 independent spent fuel storage. So, those rulemakings were 22 undertaken as a corollary to the '84 decision, and that put 23 us in the position we are today, and the one thing that the 24 Commission committed to, they said, we will be back.
25 This is sort of a looking into the future
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) 1. something in the way.of a prediction, and we will be back 2 and we will revisit this subject every five years, just to
-3 be sure that institutional circumstances, technology or 4 whatever have not substantively' changed and, of. course, voided the decision or made it different in some significant 5
6 . way.
7 So, I'm sure you've seen the copy of the 8 Commission paper that we put together earlier this year, it 9 was last year actually, SECY 88-343 of last fall, and we set 10 out the schedule and here we are right at the front end of 11 the milestones on this schedule.
12 Yes, Judith?
13 DR. MOODY: . Bob, what I wanted to ask is to go
( 14 back to the previous 10 CFR 51. Is the environmental
'15 assessment at the nuclear reactor site for extensive 16 enlargement of the storage, is that. going to be -- that's 17 the responsibility of each reactor site?
MR. BONERO: Well, the rulemaking deals with 18 19 whether that's needed for that sort of a licensing action.
20 DR. MOODY: Are you. alleging it's not needed? Is i
21 that it?
22 MR. BONERO: Yeah. The rulemaking says'in this 23 context it's not needed, and we have issued licenses on 24 that. )
25 Now, keep in mind, up till now, the typical
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()l 1 amendment is to shuffle the racks around so you can get more
- 2. fuel into the pool. In at least one instance, the license 3 amendment was to disassemble the fuel and put all the fuel 4 pins into a can, a square can that fits in a fuel rack, and 5 you get a hundred and fifty percent increase or, no, even 6 more than that, I think, you get a substantial increase 7 along with re-racking.
8 One reactor has that kind of an amendment that I 9 know of. But many who have looked at it, many utilities 10 have examined that, and shy away from it for reasons of 11 practicality. Spent fuel pools are really not an ideal 12 location for pin manipulation and fuel disassembly 13 operations. It can be done and is done, but it's tedious,
() 14 very slow.
15 So, we'll look at this schedule here for the waste 16 confidence. Of course, this working meeting is an antecedent 17 of a meeting next week of your committee, which is the l
18 nominal date here, April 26th. The analysis by staff, the 19 Commission has a working group, inter-office working group, j 20 the general counsel office, NMSS, research and NRR, working 21 together to do the analysis in preparation for the 22 Commission's re-visitation of waste confidence.
23 That work has been done. You see the product.
24 That's the analysis we asked you to hold, and we're now in l
25 this cycle of exposing first for your review and comment and l
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25 E() 1- then_later to the Commission in May and to'the public the 2 proposed _ finding and whatever corollary rulemakings would l 3- derive from'it.
4 In other: words, just redoing five years ago what 5 is the policy, are there any attendant rulemakings, and what 6 are those rulemakings. We_would'get the comments during the 7 ' summer as the schedule indicates'and then, by the fall, we 8 would get the final package together and go to the 9 Commission, and we hope to conclude the thing. So, that's 10 our avowed schedule. We're holding to that schedule.right
'11 now, and I hope we continue to do so.
12 So, let's look at what are the needed findings and 13 issues. We're going right at it and saying'has anything
() 14 substantively changed.
15 Finding Number 1, reasonable assurance that' safe 16- disposal of high-level waste and spent fuel in a mined 17_ geological repository is technically feasible.
18 May I have the next one? Let's start looking at 19 that. We've have a lot of activity, not necessarily 20 progress, but certainly activity in the high-level waste 21 program.
22 The repository program in 1984 was a wide fanned 23 search for sites and looking at all kinds of sites and .
24 environmental assessments and consideration of alternatives 25 and heated policy debates about whether or not the eastern Heritage Reporting Corporation
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26 b L1. United States was a good place for holes in the ground, and l 2 what has happened, we've gone through a major amendment of 3 the 1982 Nuclear Waste Policy Act, and that amendment said 4 narrow it down and put all your eggs in one basket right 5 now.
6 Programmatic decision. That is not a licensing 7 decision, certainly, and the Congress by no means or by no 8 stretch says that site must be licensed. They say give that 9' program priority as the first choice, the most likely 10 alternative, and pursue it. If it works, it works. If it 11 doesn't work, it doesn't work.
12 But the Congress reccgnized and it was explicitly 13 discussed with the Congress that if you have a failure of
() . 14 Yucca Mountain, the selected site for candidate use, it's 15 back to the drawing board with a very long time concept. You 16 go back to the Congress. You get back in to the political 17 system to say, okay, who do we stick next. You know, it's a 18 political barrier and its far different from a program that 19 would have hao, at the time it would have had, three sites 20 being evaluated in parallel, so that you have the 21 programmatic possibility of at least one out of three l 22 panning out to be successful.
23 So, it raises the potential for delay in the 24 repository, certainly doesn't preclude identification of an 25 acceptable site, but we can't make a judgment on the
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.I-rm) 1 suitability until not only -- the slide just says results of 4
- j. 2 the characterization are available, and remember that's a 3 continuing process. We've got to finish the licensing 4 review. 1 l 5 They won't on the present schedule, they, DOE, 6 won't submit an application until 1995. So, it's quite 7 possible that you might find to your abject disappointment 8 that in 1997 or '98, sorry, guys, it's not a good site. You 9 could stretch this whole thing out so long.
10 So,-that is a major programmatic thing. Now, in 11 policy consideration, how does that change the Commission's 12 finding that a repository is feasible? Does it make it less 13 feasible? No. I think you'll see that it reflects on
(). 14 Finding 2 more than anything else.
15 DR. MOODY: Bob, remind us, going back a couple of 16 years, do you think in terms of congressional action to 17 limit us to detailed characterization of one site, was that 18- -- why was that done? Was that done purely on cost?
19 'MR. BONERO: Cost and program focus. Cost and 20 priority, and that was very explicitly in all the 21 congressional hearings, I attended many of them. It was very 22 evidently on the table that the cost of the program for 23 three sites in parallel wasn't evidently three times the 24 cost, but it was substantially higher and there was a 25 significant concern that it diluted the attention of the
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28 If 1 program management at DOE so that they were not giving 2 unswerving priority to timely investigation and development.
3 So, the Congress was quite clear that it was a far 4 more effective thing to go after one site at a time, that.it 5 was a program choice, programmatic decision, and they even 6 -- remember, the Congress has the underlying motive that is !
7 very explicit in the original Nuclear Waste Policy Act and= 'I i
8' in the amendment, the Congress wants orderly progress'to a- l 9 high-level waste repository, and they even took the. pains in 10 the '87. amendment to disembowel the MRS so it: couldn't be -l
-l 11 used as an excuse to delay the high-level waste program. !
i 12 If you look at the-restrictions they put in on the j 13 development and use'of a surface storage facility, namely l
() 14 the MRS, they virtually tied'it to the repository schedule 15 so closely as to make it useless. In fact, that's something i 16 the MRS Commission is trying to deal with now.
17 So, the next one.
18 DR. MOELLER: Well, then, the development of on-19 site dry cask storage certainly impacts, also.
20 MR. BONERO: Oh, that comes in, yeah. We'll be i 21 talking about that, but that's illuminated in the later l 22 findings more than anything else.
23 There are other things that come up, and I'm not i 24 going to go slowly and surely through all of these things.
25 These are more like background considerations. One, the j
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(-) 1 Commission should look at the technology and examine have we 2 learned something or found to our chagrin that we're unable 3 to learn something in waste disposal technology that would 4 change the feasibility finding. So, we need to look at waste 5 package development, waste form and reprocessing, because, 6 remember, part of the high-level waste is the reprocessed 7 waste from Savannah River and from West Valley, New York, 8 and so forth, you know. The material is there. It's a fair 9 quantity, and things like detailed design of repositories, 10 backfill, requirements like that.
11 So, these other slides, sealants, I would like to 12 just carry on for the next one there. The conclusion. If you 13 look at what has gone on and looked, by the way, as we have
() 14 tried to look also at international developments in this 15 field, the staff has no basis for decreased confidence.
16 There's a lot more information known, hot debates about 17 what's the right material, whether or not to use a backfill, 18 how to plug holes, what's the right medium, you know. Many 19 nations are looking at different geologic media, but there's 20 no basis for reduced confidence, and that technical 21 foundation for the Commission is important.
22 The Commission has no reason to believe that it 23 should have less confidence today than it had five years ago 24 in the technical feasibility of a repository.
25 DR. ORTH: Bob, I would like to make one small
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2 You said the argument for which is the right 3 medium, which is the right this, I think it's more a 4 question of which is the best. It turns out that if you set 5 some reasonable goals, there's lots of rights. The reason 6 we've had a lot of delays is people are arguing, shouldn't 7 you try for the best.
8 MR. BONERO: Yeah. The distinction between what is 9 the best site available as against what is an acceptable 10 site is an important one. I agree with you, Don. I would 11 say the crisis in decision and, in a way, it helps the 12 Congress by saying quit fooling around with the salt and the 13 tough site, just get on one site and look at it.
() 14 The real crisis is what does it take to make the 15 finding, this is an acceptable site, and you all know, of 16 course, the heat and light that occasionally comes in the i 17 performance assessment field, making a decision in'a 18 suitable way both deterministically and probablistically and 19 acting for society to say that's no undue risk, and it's not 20 only no undue risk today, it won't be an undue risk for ten 21 thousand years.
22 That's the real thing, and I think in many 23 respects from a program point of view, being forced to look 24 at one site simplifies that, focuses everyone.
25 DR. MOODY: I'd like to make a small comment, too,
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/~\
(_) 1 because of my heavy involvement in the salt program. One 2 thing I can say is we had our waste package material chosen, 3 number one, and, number two, compared to what's going on in 4 the telfacious program are also very much farther ahead in 5 the sealants.
6 So, I'd just like to remind you, yes, that it 7 probably is technically feasible, but the amount of 8 technical work required on these three materials that you're 9 talking about for Yucca Mountain are non-trivial.
10 MR. BONERO: Oh, we recognize that.
11 So, on Finding Number 1, we're saying there's no 12 basic change. Okay. Yeah. '
13 Where did you put the recommended finding?
() 14 Remember, we're focusing on what we're trying to say in 1589 15 and now we're going to get into change, and, so, Finding 16 Number 1 doesn't change, but Finding Number 2 will.
17 Here's the original Finding Number 2. One 18 repository, 2007-2009, sufficient thirty years to dispose of 19 all. Remember, that's the one we discussed just a little 20 while ago.
1
! 21 Now, this is the recommended Finding Number 2, and 22 it has some substantive differences. First of all, within 23 the first quarter of the 21st Century, the first change we l 24 would make is get away from this circumstantially-precise 25 but insignificant focus on a single year plus or minus one,
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() 1 you know, the 2007 to 2009. That was an apparent precision 2 that had no meaning, and we are talking in this context of 3 national matters that occur on time scales of decades, not 4 of even of years, and it's an artificial statement for the 5 Commission to be tieing itself at this stage in 1989 to a 6 precise date twenty years from now implying that twenty-two 7 years from now would be unacceptable but nineteen years from 8 now would be acceptable, you know. It's just wrong.
9 So, the first thing is that the Commission in its 10 policy re-finding or reformulation in 1989 would focus on 11 the time scale of decades, and we would address that as 12 order of a century sort of timing, and then, the thirty 13 years beyond the scheduled expiration of the operating 14 licenses for the bulk of the reactors.
(])
15 We've got a set of over a hundred reactors out 16 there, and I'm sure you're all aware that you've got 17 Lacrosse Boiling Water Reactor, operated for a certain 18 number of years, and it's an only plant. It's the only 19 nuclear plant the utility has, and it's going to go into 20 some kind of shutdown and decommissioning, and then you've 21 got Indian Point 1 that's sharing a site with two big 22 currently operating reactors, and they may have their lives 23 extended and so forth, and, in fact, right now, a very 24 active program, people are saying I've got all that capital 25 investment and at least on the modern more cost-effective
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(). 1 reactors that are. working well, I'm -- you know, utilities 2 are seriously thinking of getting.another, who knows, ten or 3 . twenty or thirty years life extension out of them.
4 So, once again, if you look at it from a policy 5 and technical point of view, is the exact timing of the 6 disposition of spent fuel from Lacrosse or from Indian Point 7 1 or from any individual reactor significant? No. From a 8 national policy point of view, environmental impact and 9 safety, it is the bulk of the population. So, the focus of' 10 this finding really ought to be on the right time scale and 11 the right subject.
'12 So, this is a change in focus, a refinement of
'13 focus that we think is appropriate.
14 Now,-the basis for the original Commission
(])'
15 finding, it was those two licensing cases. That wasn't, you 16 know, the essential character of the finding. It was the 17 circumstance of the finding, and the same thing with the 18 thirty years.
19 So, we think that if you look at the issue and the 20 analysis would purport to do it, you can analyze that and 21 justify this change of focus by the Commission and not 22 unduly dwell on it. We hcVe actually had in our 23 considerations right now, there's no director of the Office 24 of Civilian Radioactive Waste Management, and there's a big 25 hassle about whether or not the experimental shaft facility Heritage Reporting Corporation
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34 k- I will be started in November 1989 as proposed, and it's just 2 myopic for us to be sitting here debating that highly l 3 specific even down to the month date when we're talking 4 about events in the next century, in the next millennium.
5 It's just false precision.
6 DR. CARTER: Bob, let me ask you a question about 7 the Commission's view now on the expected life of reactors.
8 Certainly at one time, you mentioned that it was looked upon 9 as to be forty years. Is that essentially the same or has 10 the Commission considered it in detail and modified its 11 stance or what's the status?
12 MR. BONERO: The original safety review of nuclear 13 reactors by the Commission established a convention that a Y'
(_)\ 14 forty year design life was an appropriate one, and it's a 15 design basis, you know. When people evaluated aging, reactor 16 pressure vessel embrittlement, degradation of cabling or 17 whatever, thermal effects, the time frame of interest was 18 forty years.
19 In the earlier reactors, there was so little 20 difference between the granting of the construction permit 21 and the operating license that the forty year clock started 22 at the date of construction permit. It was only later when 23 the gap, you know, the construction gaps and hearing gaps 24 and so forth controlled, that the Commission openly said we 25 really always understood forty years of life, so that we're
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35 e-(,gj 1 willing to make minor amendments to reactors so that it's 2 forty years of operating life, not lose the first ten years i 3 of the construction cycle, because some plants have had like 1 4 ten years of construction cycle.
5 What's being looked at now by the industry and by ,
6 the NRC is the technical basis to be able to judge continued 7 operation with acceptable safety for further life or 8 whatever changes might be needed to justify that. You know, l 9 is cable aging, projected to be so bad that you've got to 10 rip out all the cables and replace them before you can i
11 extend life or how long should you extend life, and that's 12 part -- the aging program, the ACRS, I know, is looking at 13 that.
() 14 The -- right now, in this context, all we can do 15 is look to that as a likely source of perhaps a substantial 16 number of reactors significantly extending their operating 17 life.
18 Now, from a practical point of view, these trivial 19 amendments that get up to ten years, we assume, are all out 20 of the way. You know, that everyone has a baseline of forty 21 years operation.
22 If extended operation is to be granted with cause, 23 you know, for whatever basis, it might be reasonably 24 considered in blocks of ten years and, so, our thinking here 25 is it could be ten, twenty or thirty years life extension,
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36 im k_) 1 something anywhere over that range, and that the Commission 2 should be sensitive to that in looking at this issue.
3 Now, this is not a commitment that the Commission 4 will extend life, you know. The jury is still out on the 5 technical basis for such a safety finding, but from a 6 finding of policy with respect to the generation of waste, 7 the storage of wasta and the disposal of waste, it is 8 appropriate for the Commission to consider even so 9 substantial a plant life extension, say, another thirty 10 years.
11 DR. MOODY: There's another major issue, though, 12 tied other than the one that you've just mentioned, and that 13 is, as you probably know, the U.S. Geological Survey, along
/~%
(_j 14 with a large other segment of the geologic community, is 15 exceedingly concerned about the detailed site 16 characterization of not only Yucca Mountain, but any other 17 potential site.
18 So, another reason for what you've just stated in 19 terms of Comment 2 in terms of time is certainly to have the 20 time to do the detailed site characterization that is needed 21 for even defining an adequate site.
22 MR. BONERO: Yeah. In fact, if you go to that next 23 slide, I was just about to go into this. In order to 24 recognize such a time horizon change, a broadening of time 25 horizon, we've got to take into account -- we've had delays
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()- 1 in the DOE. program even before the Amendments Act, and right 1
2 now. ;
3 I was just at the site a week ago and there's 4 . literally nothing. going on. Literally. It's idle. Equipment
.5 is sitting at the side of the road. The sample management 6 facility is idle. Nothing on the table. People twiddling 7 their thumbs.
8 There are substantial program delays and, as I 9 .said earlier, this' site, this is not an easy site to 10 license, you know it has issues like seismicity and 11 fracturing and volcanism, and all. sorts of things, and it
- 12. certainly didn't get off to a blazing start.
- 13. We could agonize with this site for the next 14 fifteen years and then throw up our hands and say can't be
(])
15 done. It is not an acceptable site. Not the best site.
16 We're only looking at the one, but not an acceptable site.
17 It's a possibility, and that, if we consume ten or fifteen 18 years and then the DOE has to go to the Congress and then 19 the Congress has to flail at it for a couple of years and 20 somehow or other decide on another site, there's a 21 generation of time, a couple of decades can be just blown 22 out of the way that way.
23 So, this is a basis upon which we have to go.
24 Now, I would point out one other thing. The Congress in the 25 Amendments Act also said that you can't go for the second Heritage Reporting Corporation O. (202) 628-4888
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l 38 l 1 repository. Remember the political heat on the second 2 repository was extremely intense, and they said you come to l 3 us before you go for the second one, and that's l
! -4 substantially delayed.
5 So, one very important aspect of the time' horizon 6 that needs to be considered in waste confidence is how about 7 the timing of the second repository, would it become crucial 8 because it is already evident from technical analysis at 9 Yucca Mountain that Yucca Mountain might be a little bit on
.10 the skimpy size with respect to holding all the waste of 11 this first generation of reactors.
12 Yucca Mountain does have a potential to be 13 geometrically limited by geologic features, and, so, we've
() 14 got that secondary consideration, and I would invite your 15 attention in the materials we've submitted to some 16 parametric analyses of spent fuel accumulation and spent 17 fuel disposition given certain assumptions, and it's 18 important to look at those and I just g you what I 19 consider the ultimate punch line.
20 If an orderly dry storage technology is available 21 and there is a national entrance, that is a significant 22 number of sites have entered into the use of such 23 technology, the punch line is the schedule of availability 24 for a different repository than Yucca Mountain should Yucca 25 Mountain fall through or a second repository to Yucca
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- 1 Mountain if Yucca Mountain goes through but turns out to be 2 sixty-two percent of the needed size, the schedule is not 3 crucial. That's a very important point, and I think the 4 parametric analysis can illustrate that.
5 If the time horizon is as we think appropriately 6 directed toward thinking in these decades, the existence of 7 the dry storage technology with minimal impact on the 8 environment and on safety enables you to deal with that time 9 scale easily and that includes either an alternative to 10 Yucca Mountain or a subsequent repository to Yucca Mountain.
11 DR. CARTER: Bob, let me mention one thing. You 12 made some sort of generic comments about Yucca Mountain. You 13 know, it's got issues of volcanism and seismicity and so
,m
(_-) 14 forth. I think you could make those about any site and 15 obviously that's the reason you've got a site 16 characterization program. So, no matter where that site were 17 potentially picked, you'd have to go through the evaluation 18 to look at those or other issues that people would bring up.
19 MR. BONERO: Yeah. There are a lot of virtues to 20 that site, too. Boy, you know, I stood on Yucca Mountain 21 last week and it's a nice feeling of remoteness, you know, 22 great big block of unsaturated medium with a slab of rock 23 underneath it, you know, that calico hill layer, and you 24 stand there and the closest thing you can see is Death 25 Valley and, you know, it's a pretty good place.
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1 DR. ORTH: As long as we have reached the small 2 philosophical break point here then, would you care to 3 comment on a strictly personal basis, that means you don't 4 have to comment, on why there are all the delays and why 5 there is nothing getting on being done right now?
6 MR. BONERO: Oh, I think part of the reason was 7 the program had too big an agenda, you know, in trying to 8 sort out the -- in the site selection process, I personally 9 think that the Congress helped it by focusing it on one, but 10 then we went through a political watershed with the 11 presidential election, the lack of Department of Energy 12 management, you know, a very simple straightforward reason.
13 For the last two years, there's been no one 14 sitting in the chair with an iron badge, you know. When you
(])
15 see an organization that says acting director for this and 16 acting director for that and posing directcr for something 17 else, you know, you can't expect orderly firm management.
18 There's just no continuity, and it's been two years now that 19 the Office of Civilian Radioactive Waste Management has had 20 an absence of a confirmed director.
21 We've had a lot of turmoil in the Department of 22 Energy, you know, with the whole top layer changing.
23 DR. ORTH: Considering that all of the 24 restrictions, how you gather data, I'm not saying the l l
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,f, i) t l' how you gather data and what you can do and satisfy the QA 2 requirement, could they have done anything even with 3 somebody firmly in command or would we have still been --
4 MR. BONERO: Oh, yes. I think they could have. I 5 would welcome anyone to go through the already-available 6 geological samples from Yucca Mountain that sit box after 7 box of them out there in the sample management facility, and 8 you just go through them and ask yourself, is this 9 trustworthy data. Do I know what I have here? Can I say 10 with confidence this core came from that hole at a depth of 11 X?
- 12. You can't. You can't. That was -- you know, there 13 is an unfortunate culture that I think exists at the Nevada
() 14 test site. Remember, you're on an extremely large 15 reservation that has drilled thousands and thousands of 16 holes, not to find out exactly what the rock is, but to 17 prepare for detonations of test devices in the rock, and the i 18 whole orientation of the way people operate out there is 19 they're not trying to painstakingly analyze the deposit.
l 20 They're going to set off a damn bomb in it, and they, you 21 know, they just don't have the culture in place there, and 22 that reflects in the simple thing like sending a guy out 23 with a drilling rig and what does he do when he drills the 24 ten-foot hole and pulls out the core and it's only eight 25 feet long.
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() 1 Does he really care? Is he going to sweat where 2 the last two feet go? He's going to put some label on it 3 and call it extra core. That's what they did. And pretty 4 soon, he says what's that. Those are some extra core. Where 5 was it? I don't know. Above or below the hole. Some place.
6 That's -- you know, that whole discipline just 7 wasn't there. It wasn't there.
8 DR. ORTH: Well, that's why we didn't get anything 9 useful out of it. But I'm wondering what could we do right 10 now? !
11 MR. BONERO: Well, I'll say personally --
12 DR. ORTH: Tell somebody to drill some more holes 13 under proper control.
/~T 14 MR. BONERO: DOE recognizes the problem. DOE has L) 15 firmly stated and it will be discussed this afternoon when 16 you talk about the site characterization analysis, no work 17 unless you know what you're doing and you're doing it right.
18 That's all quality assurance is. We're not.trying to make 19 reactor hardware out of rocks. Just know what you're doing 20 and know why you did it and have a traceable record.
21 But they have a sample management facility out 22 there that I would assert is a textbook example, perhaps too 23 expensive, if you want to criticize it for anything, it is 24 elegant, and the procedures they have established, the 25 equipment they have established for the control of
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() 1 geological samples, the archiving and the separation of 2 experimental portions of geological samples, the 3 recordkeeping, the control of scientific access to the rock, 4 and to the data and the core relations, it's excellent, 5 really, really excellent.
6 And at least for the geological sampling program, 7 I think that is the right way to do it. It looks like the 8 right way to do it. I think they're prepared to manage that 9 program right now, and then, of course, nature can tell you, 10 if you've got a good core, you don't get a good core,.or the 11 experiments on nature.
12 DR. MOODY: . Well, the problem there is, and you've 13 already stated it, is that certainly means that any work 14 done,.you know, after the site characterization plan was
-({}
15 written will be valid, but it's just geologically speaking 16 that it would certainly have been much better if any of the 17 -
there isn't that much information in the environmental 18 assessment at Yucca Mountain that you can really use in a 19 licensing stage.
20 MR. BONERO: Well, DOE has formally stated that 21 the existing samples, they got them sequestered, they're in 22 a locked cage, they're all as codified and labeled as they 23 can be and boxed, and the sample management facility will, 24 in its first operational mode, be trying to retrospectively 25 validate samples out of that, and, you know, I don't know
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<- 1 k_)s 1 how much they can salvage, you know, reconstruct, and how I 2 much they can't.
1 3 But DOE has said none of that can be used as the 4 basis for licensing absent appropriate re-validation, and, 5 you know, we've had that problem with QA before. You know, ,
6 people build something and they kind of lose track of the i 7 recordkeeping and have to reconstruct it.
8 But I, frankly, doubt ue're going to get much out 9 of that generation of samples.
10 DR. CARTER: Yes, but, Bob, some of this is 11 certainly an over-simplification because of all the holes 12 they've drilled out there, I daresay very few of them 13 actually were used for detonation. A lot of them were used
() 14 by U.S.G.S. and others to characterize various things, 15 looking at hydrology or whatever.
16 MR. BONERO: Yes, but broad range, yes, broad 17 range investigation to understand the behavior of the site 18 for its test purpose, for its test purpose as against what 19 we're talking about here, which is a much more precise, a 20 much more even microscopic look.
21 Now, the next two slides or actually three slides, 22 I'd like to go through these. We've already touched in the 23 dialogue on it. We've had slippage in the DOE date from 1998 24 to 2003. That's in their mission plan amendment, and I 25 wonder if there's a soul that believes 2003.
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() 1 ~But,-again, so.what? Should we be going around 2 hanging our hat of confidence on a peg that's plus or minus 3 one year? The slippage in milestones, the stall in the 4 program, all of these things speak to generational time and 5 the issue is.will a DOE program ultimately proceed in some 6 fashion as against will it be done this' year or next year.
.7 The narrowing of the site, we've'already talked 8' about, and' going back to the Congress. It doesn't hinge on 9 that.
10 The next one. This, in fact, I've even brought-11 this one in.already in the general slide. The 70,000 metric 12 ton limit on the first, that's the Congress set that 13 originally and didn't remove it, you know. The original
() 14 purpose of that was to make sure that there was a sharing of 15 the misery, you know, that there would be a second 16 repository.
17 The only capacity issue that exists now is the ;
18 possibility that Yucca Mountain might not hold 70,000, you 19 know, because of the geometric restraint, but as I spoke to 20 that earlier, that if you look at the parametric analysis, l
21 that does not turn out to be crucial. ]
22 And we would assert that if you really put on your 23 pessimistic hat and say what would happen if we are talking 24 repository availability and it takes the whole darn schemer, 25 the whole process of site investigation and evaluation and Heritage Reporting Corporation
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'x_ 1 the construction application and hearing and everything else 2 and Yucca Mountain is unsuitable and, boy, it took us till 3 the year 2000 to find that out, you know, that we're really 4 way out there before we find it out, and that DOE requires 5 another twenty-five years to progress.from site screening to
~
6 repository operation with the substitute site, whatever it 7 is, that's pretty pessimistic. That's pretty pessimistic.
8 But, again, I think it's appropriate to make that 9 pessimistic estimate as you look at confidence that a 10 repository is available and what is the environmental impact 11 and what are the safety implications of manipulating and 12 storing spent fuel in the meanwhile, given the large 13 population of reactors, given the potential for plant life
_) 14 extension.
15 So, this is the thinking underlying our revision 16 of findings, and, of course, I think you can skip the one 17 about long-term storage. We'll be talking long-term storage 18 more in the other context.
19 Let's go a few slides beyond to Finding Number 3, 20 and let's get into the spent fuel storage because 21 ultimately, as you can see, what we're saying is the pursuit 22 of a repository has not turned up a technical basis to say 23 we're less confident in its feasibility. The pursuit of the 24 repository on a more rational time frame and availability is 25 justified and the key thing is that given the population of
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47 f f( f 1 1 reactors, given the amount of spent fuel that is being 2 generated and can be generated over the next decades, that 3 there are the bases for the Commission confidence that it 4 can be safely managed.
5 So, this finding is again that a Commission saying 6 that high-level radioactive waste and spent fuel will be 7 managed in a safe manner until sufficient repository 8 capacity is available to assure safe disposal. Now, I think 9 it's worthwhile. If you look, we've got Finding 4 along with 10 it, and let's' talk. They overlap a good deal. Reasonable 11 assurance in Finding 4 that spent fuel generated in any 12 reactor.for at least thirty years beyond its operating life
- 13. and this is where you get into the question of plant life
(} 14 extension also, and looking either at the spent fuel storage 15 basin or on-site or off-site independent storage.
16 Well, if we go to the institutional basis, the 17 Commission had a regulatory regime that basically was for 18 the dual-purpose fee. Some sort of facility that might 19 serve a group of reactors, something like Gene used to 20 operate at G.E. Morris. The -- a thoroughly central thing, 21 and we had a licensing framework, inspection enforcement. We 22 had the ability and in particular there was an emphasis on 23 wet storage because there was long experience with that.
24 That institutional basis really was there, and in 25 the 1984, if you turn to that next one, and say, well, what Heritage Reporting Corporation
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() 1 was the waste basis, you know, not the spent fuel, we had 2 the Nuclear Waste Policy Act of 1982 that certainly 3 demonstrated that the Congress meant business, that we were 4 not going to sit here and flail and wave our arms forever.
5 They recognized, and I said this earlier in response to a 6 question Judith raised, the Congress recognized that interim 7 storage is the job of the industry.
8 You know, there's that debate and I'll defer to 9 DOE and the industry for when does DOE take title to the 10 spent fuel and where, you know, FOB your loading dock kind 11 of thing, but the -- I defer to that. The important thing is 12 the interim storage is the utility's responsibility. The 13 ultimate disposition is DOE's responsibility. Congress was r~)
(
14 clear on that, and the Congress wanted two other things.
15 One is very, very clear, and that is they wanted 16 the Department of Energy to get out there and do proactive 17 effort to develop technology or better technology for I 18 storing fuel. More prectical, more cost-effective, more 19 reliable, simpler ways to store spent fuel over this interim 20 haul, and they also wanted the NRC to look at regulatory 21 methods to enable that and not make a mountain out of a 22 molehill and tie up the licensing of anything like this.
23 Now, in '84, the MRS was probably considered a 24 reality. I would say it's fair to say in 1984, every one 25 felt that DOE is going to have an MRS and you remember all
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r 1 the talk about the Clinch River site and so forth, and it 2 was taken by many as a foregone conclusion. It was just a 3 matter of when and whether there would be one MRS or two 4 MRSs or something like that.
5 But it was clearly a potential in 1984.
6 DR. MOELLER: Excuse me a second. In terms of 7 DOE's role in providing a way from reactor storage, I need 8 to be filled in, and I tried reading the material, and I 9 couldn't get answers to my questions, but it seemed to me 10 that three, four or five years ago, that we were told that 11 DOE was writing contracts with each utility and specifying 12 at what time they would take over the fuel and handle it, 13 and are those contracts now voided or where is that?
(') 14 MR. BONERO: That, I can't tell you. I have to 15 defer to DOE. I don't think -- this is limited knowledge 16 because it's a jurisdictional matter entirely outside our 17 purview.
18 The contractual arrangements with DOE and the 19 utilities as to taking title of spent fuel, I think, are 20 still under debate. I don't think they're concluded. I know 21 there is active feeling in the industry that a certain date 22 prior to 2000, 1998 is sometimes mentioned, as a date that 23 they should assume the responsibility, that DOE should 24 assume the responsibility for the fuel, but I don't think 25 such contracts exist or are functioning right now.
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'. <s-() 1 To my knowledge, they do not. The -- in 1984, the i 2 DOE role that I'm referring to is the Congress saying not so 3 much taking the fuel into your possession, but doing 4 technology development and assistance to enable the i
5 utilities to store the fuel in the interim basis in a ]
6 practical, safe, cost-effective and co forth way.
7 MR. VOILAND: These were primarily cooperative ,
8 ventures between the --
9 MR. BONERO: Yes, indeed. Yes, indeed. And what 10 DOE did, DOE had a program out at Nevada, at the old engine, 11 Nerva Engine Test Facility, EMAD. They had holes in the 12 ground. They did tests at Idaho and so forth, and, frankly, 13 what the technology drives you to is it's really applied
. ss f') 14 research. It's a development of what's a cost-effective way i 15 to do it. You know, it's relatively straightforward, you 16 know, benign environment, the stuff is older and older, 17 cooler and cooler fuel. Just the idea, you put in the 18 shield, and at what point do you optimize. Do you optimize ,
1 19 for ten years on a pile or five years on a pile? What's the )
20 best way to package it and set it down for decades of 21 storage.
22 MR. VOILAND: Bob, is Carolina Power and Light 23 Program one of those cooperatives?
l 24 MR. BONERO: Yes, indeed. What DOE did a lot of 25 reactor test stations, you know, Idaho and Nevada testing, Heritage Reporting Corporation f( ) (202) 628-4888
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p,
(_) 1 and then they undertook a prototype, you might call it, 2 program with Virginia Power and with Carolina Power and !
3 Light, and we actually have two dry storage installations 4 now licensed and operating that are forerunners of the dry 5 storage technology, and this week, the third module is being 6 loaded at Carolina Power and Light.
7 I just talked to a guy yesterday downtown, and he 8 wasn't sure whether it was -- it was supposed to go in 9 yesterday. They're loading the thing, but, you know, it's 10 state of the art stuff and very straightforward. I have a 11 couple of pictures if -- color slides, if you wanted to look 12 at that.
13 DR. MOELLER: To back up and be sure I follow
() 14 then, at the moment, DOE has a responsibility not only, of 15 course, to pursue the repository and to try to meet the 16 needs for the handling of the spent fuel, that avenue for 17 final disposal, but they also have a responsibility to 18 assist the utilities in developing on-site dry storage --
19 MR. BONERO: Alternatives, yes.
20 DR. MOELLER: Alternatives.
21 MR. BONERO: Yes. And I might say they have done 22 an excellent job c:aing that.
i 23 DR. PARRY: Bob, excuse me. Have -- in any of 24 your studies or considerations, have you been looking at the 25 longer life fuel? You know, the original calculations were O(_j Heritage Reporting Corporation (202) 628-4888 L_____-_.
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'( ) 1 on 33,000 --
2 MR. BONERO: Yeah, and now they're getting up in 3 close to sixty. Yes, that's being done, too, and, so far, 4 you know, the progress is no big change. Some years ago, I 5 remember people thinking that zirkleloid was going to turn 6 to peanut brittle around 40,000 megawatt vapor per ton, and 7 I saw the other day an assembly just came out of a pile that 8 was 58,500 or something like that megawatt vapor ton average 9 burn-out. That is high. That is a high burn-out.
10 DR. HINZE: If I may, please, I think I understand 11 now the thirty-year period of time, but what's the driver 12 for that decision on thirty years? How critical is that 13 thirty years?
() 14 MR. BONERO: It's really not. It gets into, I'll 15 call them, institutional questions. Lacrosse Boiling Water 16 Reactor. After -- thirty years after it shut down, what sort 17 of management commitment and custody and institution is 18 controlling spent fuel storage on the Lacrosse site as a 19 residue from a generation before operating that little 20 reactor?
21 It gets into some rather fuzzy concepts about l 22 institutional confidence over an indefinite period. What's 23 indefinite, you know? Thirty years was --
24 DR. HINZE: Are technical limitations built into 25 that decision?
() Heritage Reporting Corporation (202) 628-4888 I
53 iv h1 -MR. BONERO: I would.say it's far.more 2 institutional.now. There are no evident technical thresholds 3 that, you know, corrosion rates or degradation rates or 4 anything.like that. It's much more institutional in 5 character. You see, throughout the whole waste thing, and 6 with the MRS itself'in the eyes of the Congress, indefinite 7 storage is not a solution. It's not an acceptable solution.
8 That's one of the reasons the MRS is so beleaguer'ed, because 9 it becomes an excuse not to solve the problem, and the 10 Congress is very explicit in not wanting to risk that, and 11 when you get into the -- clearly, depending on the reactor 12 site, -- when did Indian Point shut down? About '73?
13 Something like that? Indian Point 1. It ceased operation
() 14 about '73 or '74, somewhere in there, and I certainly don't 15 have any institutional qualms about Indian Point 1 fifteen 16 years later because it shares a site with two operating 17- reactors with full oversight and, you know, the nuclear 18 hierarchy in place.
19 You don't have any institutional reservations, and 20 from plant to plant, you will get variations in that. So, 21 the thirty years just has that kind of a flavor. It's a rule 22 of thumb sort of time span to distinguish indefinite from 23- definite period.
24 DR. MOODY: Now, remember, internationally, ,
1 25 England has stated that they will surface storage for a ?
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L 54 1 hundred years'and then reconsider deep storage. So, I mean, 2 there are other ways of thinking about this total problem.
3 MR. BONERO: Oh, yes. Yes, indeed, yes. And, of
-4 course, England is in a reprocessing cycle. They are 5 avowedly reprocessing spent fuel to salvage facile value and 6 at the same time simplify the waste form as best they can, 7 and-other nations are in that same, and the Commission 8 consciously tracks and collaborates with the other programs.
9 I was talking to Dr. Moeller, going to Germany.
I 10 next week. The Germans are looking at the high-level waste 11 repository logic process. What does it take to make the 12 finding of acceptability? Having a seance on that subject 13' in Bonn, and we are -- we collaborate with the foreign
) 14 governments in order to share technology and share this is 15 really national policy and, of course, it has ramifications 16 with respect to reprocessing as well as waste disposal.
17 If you go to the technical basis on 84 reactor 18 pool storage, there's little that I need to add. Benign 19 environment, known mechanisms, many decades of experience, 20 and really no approximate cause for concern, but what you do 21 find with the pool storage is economics start to reflect on 22 you. You say when it's a long time out of pile, I don't 23 really need water to cool it, and I can still have 24 manageable temperatures with air cooling or gas, you know, 25 convection cooling and you get lower and lower in
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's_)/ 1 temperature and then it starts offering alternatives other 2 than the large civil structure with the great pool of water 3 and the demineralizers and so forth.
4 If you look at independent spent fuel storage, at 5 the time in 1984, there was some limited experience on the 6 dry storage, and DOE had some spent fuel research and 7 development work going on, and that was -- there was l 8 certainly feasibility. No question of feasibility, but it 9 was again a question of the Congress telling the DOE, get 10 out there and develop this technology, assist this industry 11 to have a practical set of alternatives for the storage.
12 Now, in 1989, we've got a different institutional 13 basis. We have the Amendment Act, and the MRS is severely
() 14 constrained. I don't need to reviav for you the specific 15 words of the Amendments Act. I'm sure you've seen them and 16 read them, but there is a very, very close linkage of what 17 you can do on an MRS given '5 1t you found the site and all 18 of that, bells and whistles, but given that DOE has a place, 19 they are tightly time-constrained as to the staging of an 20 MRS development and use and capacity, and it's all tied to 21 the institutional activities of the repository itself, and 22 in so many words, when I read that part ef the Amendments 23 Act of 1987, it tells me that the Corp, 's is making very 24 sure that you'll only have an MRS when you don't really need 25 an MRS, that if you look at the timing and you look at the
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() 1 practicality of doing anything with it, it is so strictly 2 limited that it pales in the program for high-level waste 3 management and becomes only a weigh station for waste 4 processing.
5 Ultimately, it is presumed that the high level 1 1
6 waste, the spent fuel, is going to be manipulated and f 7 repackaged in some way. You know, you'll take all the pins 8 out and put them in round cans or something like that, and 9 you have the obvious programmatic question, do you do that 10 at the head end of the repository for all of it and then the 11 repository is an MRS, or do you have an East Coast 12 repackaging facility called an MRS that serves that 13 function. It's a pass-through, and it functions
() 14 realistically only with a functional repository. It's 15 merely a packaging station, and that, as a practical matter, 16 I think, is what you see in that Amendments Act.
17 Now, ~~
18 DR. MOODY: Any comment as to why, you know, why 19 the Amendment was written that way?
20 MR. BONERO: Oh, I think the Congress has been 21 unequivocal from the original Act. They don't want an MRS 22 that's a storehouse. They don't want an excuse to delay or 23 to fail in the development of a repository, and, you know, 24 the British proposition of let's store it for a hundred 2T years and let our great-grandchildren come back and revisit Heritage Reporting Corporation
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(-) - 1 the subject.
2 The U.S. Congress does not want that. No 3 question.
4 DR. MOELLER: Bob, whenever appropriate, we could 5 take a break. So, let us know when's a good time.
6 MR. BONERO: Okay. Let me -- let me just finish 7 this institutional basis here and before we go into the 8 revision of finding for, we can take a break.
9 The institutional basis in '89, we have an MRS 10 rulemaking, Part 72. This fairly new thing. The original 11 Part 72, some of you remember it from back in the late 12 seventies, envisioned this facility-like thing and what we 13 have now is an MRS rulemaking that covers the DOE kind of
) 14 facility, but also we have to deal with the dry storage and 15 rulemaking related to it.
16 Now, there are two steps to that. Given that DOE 17 did a good piece of homework in the technology development, 18 they assisted in the development of practical alternatives 19 that would enable the industry to design, propose and build 20 under appropriate liconse innovative ways or practical ways 21 to dry store spent fuel in a much more modular or simple 22 fashion rather than, you know, great big civil structures 23 full of water.
24 And the NRC in collaboration with that and to 25 satisfy truly the expectations of the Congress had to look 7s)
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() 1 at ways to license such things, satisfying the obligation to 2 preserve public health and safety, but at the same time not
~3 creating unnecessary institutional barriers to this 4 activity, and, so, there~are a couple of steps that are 5 important.
6 Step one is to recognize the different type of 7 storage and the different time scale of storage.than we.
8 envisioned originally. Step two is to recognize the 9 diversity of options where you might store in a dual-purpose
.10 cask. This was a German concept early on, to go out and get 11 modular. cast iron and make a very simple crude cask and 12 stick the fuel in it and then use it as a transport cask, as 13 a storage cask, kind of like a bullet-proof box, and
() 14 whatever.you do, you just move it around, and it's so cheap 15 that you could afford to just dedicate a cask to that one 16 load of fuel.
17' And other alternatives are bunkers and modules and-18 so forth, and, so, what the NRC had to recognize and we 19 developed-in conjunction with Part 72 rulemaking is a review 20 mechanism, a licensing mechanism, whereby we use topical 21 reports and you should be aware that we have a host of 22 topical reports submitted by proposed vendors. They write a 23 technical report, here is an appropriate design to store 24 this kind of spent fuel under these circumstances. We do a 25 technical review of the report, ratify it, and then a l
l
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()" 'l licensee, a reactor owner, can simply'say at my so and so 2 power station, I want to' store spent fuel that.way,'using 3 that design, and I reference that topical report. So, that-4 part of the safety review is already done and all he has to 5 do is plug it into site specifics and you've got an orderly
-6 licensing process that adequately protects public health and 7 safety and is a good way to do it.
8 So, we have that institutional basis now. There's 9 another'one that is just going before the Commission on the 10 next slide. I've got it indicated as April '89. The 11 evolution of dry technology has given us two alternatives.
12' One is a civil structure with holes in it, a bunker, you 13 .might call it,.where you can put spent. fuel cartridges; that
() 14 's, i some kind of can~with a certain number of spent fuel
! 15 assemblies in it, and just slide them in and put a lid on it 16 and that's your storage module, and the other alternative is 17 the dual-purpose cask.
18 Well, the dual-purpose cask has essentially no 19 site interface. It's like a transport cask. Set it down 20 anywhere, and as a result, there is a mechanism possible, 21 recognizing the curie content and potential hazards, 22 appropriate to a sealed spent storage cask, and the 23 surveillance requirements that are not high, you know, 24 occasional surveillance. We have a rulemaking mechanism that 25 would enable a competent authority to merely register for
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p 60 b 1_ use of such'a cask under a' general license.
2 It's very similar to what a utility does with a l
3 shipping cask. We don't-license the shipment as such. We i 4 don't license the cask as such. We review the cask and
'S certify it and then the Type B cask, as long as you are 6 using a currently-certified Type B cask, you are under a 7 general-license that you can ship spent fuel and load it and 8 eliminate it.
9 So, this rulemaking will add another dimension to 10 the administrative process for handling this, and, of 11 course, the qualified user would have to be a reactor 12 licensee, you know, a Part 50 licensee, who inherently has 13 guard forces and security forces and health physicists, you
() 14 know, the appropriate resources, and a place to put it, of 15 course.
16 DR.' CARTER: Bob, what kind of history or record 17 of experience have we got with dry cask storage? What's the 18 oldest installation and that sort of thing?
19 MR. BONERO: Twenty years? Use the microphone.
20 MR. ROBERTS: John Roberts. The -- I guess the 21 earliest, if you want to call the silos at EMAD, would be 22 early seventies in the U.S. Now, of course, the Canadian 23 storage of fuel is also in silos and that predates that.
24 The German program also I guess goes back into the 25 seventies. Their national storage program and away from
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h 61-1 reactor facilities, such as at Gorlaben and, I guess, it 2 will also be at Auhouse, involved the development of modular 3 cast iron casks that they certificated under Type B and also
'4- : approved for storage.
.5 The Spanish program is starting up and it's going
- 6. that same way as the German program.
, 7. . MR. BONERO: But I would say a cap like twenty' 8 years.-
9 DR. CARTER: And all this experience has been good 10 as far as maintenance of integrity and so forth?
11 MR. BONERO: Yes. What it amounts to is the --
12 when you look at.the physics of it and the temperature 13 controls that are built into the design, you're really
() 14 taking the dry fuel, which is substantially cool, putting it 15 into a thermal environment that's under control with a 16 control gas, and then saying, can I rely on that gas over 17 many years of time, and all the physics are controllable.
18- The surveillance need be only occasional to make sure that 19 you don't have seal degradations and so forth, and the 20- failure modes you can analyze quite readily. The failure 21 modes are benign, you know.
22 If you've got a helium-filled cask and you've got 23 a convection cell going on, you can analyze what's the 24 effect of the helium slowly leaks down and you go to in 25 leakage of air and a little bit of oxidation and the
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(f '1' somewhat lesser convection cooling. You've got very 2 manageable parameters, and that's why I say, the technology 3 lends itself and is much more useful as applied, you know.
4 The principles are well established. You're not generating 5 new data. You're looking for innovative,_ effective ways to 6 use the data for storage.
7 Well, I'd like to stop and not go into the 8' proposed revision of Finding 4 and take a break.
9' DR. MOELLER: Okay. Let's take a break.
10 (Break.)
11 DR. MOELLER: Start.
12 MR. BONERO: I'd like to resume with a couple of 13 color pictures and to refresh your memory, I don't.know how
() 14 many of you have seen the materials before, but I've got a 15 color slide here of dry storage application in the program 16 that we. collaborated with Virginia Power Company and the 17 . Carolina Power and Light.
18 This particular scene here is at the Surry 19 Station, Virginia Power, Surry, Virginia, down near 20 Williamsburg, across the river there, and the fundamental 21 character of the device is it is a dry storage cask. I 22 think it holds twenty-one fuel assemblies, twenty-one PWR 23 fuel assemblies, and the white cylinders with the kind of 24 blue lid on them, and, basically, it is a spent fuel cask.
25 It's not certified for shipment, by the way. It's licensed
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(,/ .1 for storage, and there is a topical report on it. So that if 2 some other licensee or prospective licensee wanted to us it, 3 he could refer to the topical report.
4 It's moved by this truck transporter you see, this 5 great big tepee like blue steel structure and simply set 6 down on a pad. Would you put the next picture on? There's a 7 little bit of an aerial perspective here. You see the 8 fundamental character of this is passive storage. You've 9 got fuel assemblies that are relatively long out of pile.
10 They're in a controlled, controlled by engineering 11 parameters environment of temperature, gas environment, 12 simply set on a concrete pad, in a fenced-off area. It's on ,
i 13 the site but not immediately adjacent to the reactor
() 14 building itself or anything like that.
15 That's a rather large site, but this is on the 16 site and fenced so that the security force, the surveillance 17 and so forth, is merely another station to follow. So, 18 there's a minimal impact on the company to provide the 19 necessary surveillance, and obviously with this kind of a 20 passive design, it's too big and robust to hurt, and too 21 heavy to steel, and, so, it really relies simply on setting 22 there and you can set there for years. You can control the 23 parameters by the very design of it, and there's virtually 24 nothing that can happen to it.
25 DR. ORTH: Bob, what's the shielding material?
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k/ 1 MR. BONERO: The shielding material. It's an iron 2 cask, and is there any other shielding material in there, 3 John? I don't remember.
4 MR. ROBERTS: John Roberts. Yes. It's 5 predominantly -- it is the nodular cast iron and since the 6 -- about fourteen inch thick walls, and the cask itself is, 7 I think, ninety-two tons unloaded.
8 Basically, you've got almost three tons of carbon 9 in that nodular cast iron, which contributes neutron 10 shielding. You also have a pattern of shadow shielding, if 11 you will, of concentric polyethylene rods sealed in to the 12 walls there of the nodular cast iron as well for neutron 13 shielding and, of course, the iron itself provides the gamma
() 14 shielding.
15 DR. MOODY: That leads into the question I had.
16 So, the way that you're showing here is that there's no 17 external radiation?
18 MR. BONERO: Oh, there is external radiation, but 19 it's controlled and controlled access. So, there's no -- you 20 don't want public access to it, but the workers can go 21 around it, you know. It's well shielded.
22 MR. ROBERTS: Just as an aside, it calculated 23 thirty millirem per hour on the surface of the cask.
24 Actually, to the older fuel, it's down around fifteen.
25 MR. BONERO: And before going on, I would
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( 1 illustrate when we speak of that prospective rulemaking and 2 Part 72, whereby a certified cask could be used under a 3 general license, this is the sort of thing that is 4 envisioned. There is essentially no site interface to 5 specify here. You'd merely specify a flat place to put it, 6 minimal security boundaries, lighting restricted public 7 access, you know, that sort of thing, and, so, it lends 8 itself very nicely to the sort of licensing mechanism I 9 spoke of earlier.
10 DR. MOELLER: Now, those are carried in what, 11 right beside the spent fuel pool and loaded there?
12 MR. BONERO: Yes. They're more or less just like 13 they were a shipping cask. You bring them in there and load O
(,,< 14 them, and then having loaded, sealed and so forth, you bring 15 them out into this pad which is some distance away from the 16 reactor building, using the transporter, and just set them l 17 there.
18 DR. MOELLER: And these are submerged to load or 19 --
20 MR. BONERO: Oh, in a pool, yes, yeah. That's 21 because of the way the pool works, you know.
22 DR. MOELLER: Okay. They are submerged then.
23 MR. BONERO: Yeah. In theory, if you wished, you 24 know, and, of course, if the equipment enabled it, you could 25 actually pull the fuel out of the water and dry load it into
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(_) 1 the thing, but you end up with a shielding and alara and so j 2 forth, and the pool is designed for wet loading anyway. J l
3 Okay. You actually load the thing and then drain 4 it.
5 Now, Gene Voiland should recognize that. That is a 6 GEIF 300 spent fuel cask. You recall that earlier, I 7 mentioned that Carolina Power and Light Cc.npany with three 8 sites originally resorted to transshipment h, tween sites as 9 a short-term way to deal with spent fuel stoiage or spent 10 fuel accumulation, and they bought one of these casks for 11 their own.
12 They have gone into a system of spent fuel storage 13 using a bunker. It's called Nu Homs, N-U H-O-M-S, and it's a
() 14 sort of a generic approach that's getting a number of 15 applications. The peculiarity with the Carolina Power and 16 Light design is that they built around the existing 17 capability at H.B. Robinson of what you can do and around 18 this cask as an intermediate container.
19 So, basically, what they have here is a 20 conventional older shipping cask with the internals replaced 21 by a cartridge holding seven spent fuel storage assemblies 22 in what amounts to a stainless steel can. It's called the Nu
- 23 Homs 7, and it holds seven fuel assemblies in an insert, a 24 closed insert, and it's put in this shipping cask merely for 25 shielding and handling, and has a tailor-made cap on it or O
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- I 1 lid, and if you go to this other picture, you see how it's 2 -- a transporter moves it acror.s the site in this -- now, 3 the cask is sitting on its side, and it comes up to a 4 concrete bunker or module that has a series of horizontal 5 shafts in it, holes, and if you could see the other side of 6 the horizontal shaft, there is a ram or a pull bar that 7 inserts right through the hole and can reach the cartridge, 8 the Nu Homs 7 cartridge that's in the cask, and simply you 9 butt the thing up, open the doors, like putting a grizzly 10 bear from one cage to the other. You lift the lids and the 11 ram gets ahold of the Nu Homs 7 and pulls it out into the 12 bunker, then you close the doors and you're in a passive 13 mode.
.() 14 Once again, you have a closed environment, 15 regularly accessible for surveillance. It's passively 16 cooled, and here, of course, you have a site interface 17 because you've got a civil structure.
18 Now, that general license technique doesn't 19 readily lend itself to this sort of an approach because of 20 the, you know, civil structure specification, which could be 21 site specific. But this also topical report review, topical 22 report licensing, it is in use at H.B. Robinson and we 23 expect an application from Carolina Power and Light to 24 extend it to Brunswick to use virtually the same design at 25 the Brunswick Station as well in the not too distant future.
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() 1 The Acony Station of Duke Power has an active 2 license review going on right now in which an adaptation of 3 this design is applied for. It's called the Nu Homs 14. Now, 4 what that is is let's take a fresh sheet of paper and not 5 tie it to an IF-300 cask, you know. Let's build a 6 transporter tailor-made to the situation and let's optimize 7 for long out of pile fuel and get more dense packing.
8 So, 24 PWR fuel assemblies. A lot higher number.
9 24 per can or cartridge. Transported out would look 10 essentially like the same operation. I think the only 11 difference is the ram is going to work from the other end.
12 The ram is going to push through rather than pull through.
13 The Nu Homs 24 at Acony is under license review
() 14 now. We have a prospect very near in hand of licensing a 15 virtually identical one at Calvert Cliffs. Baltimore Gas 16 and Electric has expressed their expectation of applying for 17 that, and we think others will follow because it's very 18 efficient and the cost is coming down.
19 I refer you to the DOE spent fuel storage study, l 20 dry cask storage study, that was just published. It has some 1
21 cost data, and really what you see is the technology they've l 22 aided here is optimizing toward much lower costs, j 23 Gene, you had a question?
24 MR. VOILAND: Just a matter of curiosity, Bob. Did 25 they modify the head for this operation or did they use the P)
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(_) 1 original cask head or do you know that information?
2 MR. BONERO: For this cask, I think it's a 3 modified head.
4 MR. ROBERTS: There is a modified insert.
5 MR. VOILAND: They put a guillotine on it or 6 something like that?
7 MR. ROBERTS: If you notice, the insert on the 8 other two modules there. You actually have an extension 9 there, so you keep the shielding and docking up and fasten 10 to it and then you proceed with the hydraulic mass.
11 MR. VOILAND: Sure.
12 DR. MOODY: Another question of curiosity. If you 13 say that the previous cask you showed us that it was
() 14 actually loaded in pool, are these spent fuel wet, dry, 15 intermediate or what?
16 MR. BONERO: Oh, they're wet when they're loaded 17 because the pool is wet, you know. It's all done under 18 shielding, but then, once it's loaded, you evacuate the 19 water and seal it and from here on, you know, like in the 20 way you see it here and the way it's stored, it's dry. It's 21 gas filled, a gas filled can.
22 Yes?
23 DR. PARRY: Helium? Is that right, Bob?
24 MR. BONERO: Yeah. I believe so. So, this is, as 25 I say, a very rapidly developing technology only in the A
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() 1 sense of the' applied parameters. What's the optimum way to 2 do it? Size? Physical handling?. And we've had a lot of 3 examination, a great deal of examination of alara in the 4 operations, you know.
5 We have available in the file what amounts to a 6 time study. How many millirem do you get from each step of 7 the act-and so forth. So, a very good case of applied 8 technology, and I think the important thing for waste 9 confidence is the existence of this technology under 10 controlled conditions to assure benign storage.
11 Now, if I could go back to the recommendation, 12 perhaps the change to revision -- to Finding 4 is important.
13 We're saying the Commission finds reasonable assurance that,
() 14 if necessary, spent fuel generated in any reactor can be 15 stored without significant environmental impact'for at least 16 a hundred years.
17 So, really, this technical conclusion, the hundred-18 years, is getting us somewhat beyond the original forty plus 19 thirty. Remember, I discussed the forty year operating life 20 and this sort of institutional thirty years after the 21 operating life. We see with plant life extension potential 22 of who knows, ten, twenty or thirty years, an additional 23 period of time ruch that we think it appropriate for the i 24 Commission to recognize a time scale as long as this for at 25 least some of the fuel and that ties in with that different
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( )) 1 time horizon statement in Finding Number 2.
2 They go hand in hand. If you're going to talk {
1 i
3 about the next quarter of century, you know, the first j 4 quarter of the next century, if you're going to talk in 5 decades, we should talk in decades, and this technology 6 should be amenable to safe storage in decades and up to ten 7 decades here, and at least a hundred years, we think, is 8 strongly supported.
I 9 We recognize the experience base, as I said was 10 maybe twenty years in dry storage, but the important thing 11 is the physical character of what's involved. Passive 12 controlled environment, little perturbation even with 13 failure modes, and, so, you control your thing. It's like
( 14 distinguishing between a seventy year life for a civil 15 structu.-e and a hundred and twenty year life for a civil 16 structure.
17 As long as you know the failure modes, and, so, 18 this stuff here is very well controlled, I think.
19 DR. MOELLER: In your other ones, you said like a 20 quarter of a century, and you've avoided exact numbers. I 21 guess I'm intrigued that you say here at least a hundred 22 years versus ten decades, nine or ten decades.
23 MR. BONERO: Well, the hundred years is taken to 24 -- and at least a hundred years is taken to signal the 25 presence of an uncertain potential for life extension as
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{) 1 well as the dealing with decades and the repository -
- 2. ' availability.
.3 So, that's why we chose this phrase.
4 MR. VOILAND: It certainly reflects a lot of 5 confidence, too.
6 MR. BONERO: Wall, yeah, and it reflects the-7 physical condition. The -- now, if you go to Finding 5, 8 which lu a 3ro11ary line of finding, safe independent on-9- site spent fuel storage or off-site spent' fuel storage will 10 be made available if such capacity is needed. Those 11 photographs, I inserted them just to illustrate that. That 12 is a piece of cake.
13 The operations, the engineering, the surveillance,
() 14 whatever aspect of it, it's applied technology. The driving 15 feature is you got heavy weights. You obviously have to 16 shield the fuel, but you've got very, very straightforward 17 control over the parameters. There's nothing with the short 18 time constant involved. The engineering is to optimize costs 19 more than to struggle against'some safety hazard.
20 So, it's because of the very nature, the 21 realization of practical, applied dry storage that you can 22 put anywhere. You can set it on a concrete pad. You can put 23 it in some very simple concrete bunker, and there's no tight 24 restriction.
25 The only thing I would alert you to, I mentioned Heritage Reporting Corporation
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73 l() 1 it earlier, the dual-purpose cask. So, visualize the Surry 2 cask as being shippable is not a reality yet. No one yet has 3 chosen-to certify a design which is.both transportable as 4 well as storable. They've got a stored design but not a
.5- transported design.
6 So, the Surry cask, if you wanted to ship that to 7 Yucca Mountain, you couldn't simply take that cask and put 8 it on.a railroad car. What you'd have to do is go back in 9 the pool or similar structure and transfer it to a certified 10 shipping cask, and now we have an application forthcoming 11 for a dual-purpose cask; that is, it would be certified for
-12 shipment as well as for storage, so that you would have the 13 prerogative of it sits on the concrete pad and then, 14 whenever you're ready to ship it some other place, you can
({}
15 just' simply pack it up on a railroad car and do it.
16 DR. PARRY: Bob, you mentioned about Calvert 17 Cliffs. If I remember correctly, John and George and Jerry 18 and I visited Calvert Cliffs. Interesting point there is 19 they're planning on their storage, putting in their older 20 fuel and storing it there in dry cask, and then it will stay L 21 in storage throughout the operating life of the plant, and 22 then the fuel at the end of the plant life that finally goes 23 to the repository -- that's in the pool will be the first to 24 go to the repository. The dry storage fuel will remain where 25 it was and then eventually be the last fuel to leavo the l
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im ,, 1 site, and I think that that comes out to something like 2 sixty years or something like that.
3 DR. MOELLER: What is the current thinking on how i
4 you would transfer the fuel from the storage cask to the 1
5 shipping cask?
6 MR. BONERO: Oh, the same way it got into the 1
7 storage cask.
l 8 DR. MOELLER: Just go back to the --
9 MR. BONERO: Yeah. All the technology is identical 10 handling and rigging. The only thing it presumes is the 11 presence of the existing equipment. In other words, at the 12 end of life, if you have to retransfer the stuff, you have 13 to -- that's why you have the five years before the
() 14 operating license expires. You will rely on that part of the 15 reactor building and equipment to do that, and it's a 16 reversible operation. Very, very well established and 17 understood operation.
18 DR. MOODY: Two points. Well, it would seem from 19 what you're trying to allege here that the --
20 MR. BONERO: I'm merely asserting.
21 DR. MOODY: Asserting. Okay. That the dual-purpose 22 cask would be the one to be moving towards, because other 23 than making two separate activities, you'd come down to one.
24 I mean, is there any --
25 MR. BONERO: On the surface, that's an apparent
(~
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'( m- ) 1 truth. In actuality, consider that a dual-purpose cask would 2 be a shipping 1 cask perhaps only once in its existence. Not a 3 reusable cask. There would be -- it would be stored for 4 decades and then shipped once. It might be that the expense '
5 --
6 DR. MOODY: I was going to say the cost.
7 MR. BONERO: -- of designing and developing the 8 duality is not justified, and I think that's probably why 9 they haven't pursued it yet.
10 You've got to do it on the cheap because, see, the 11 requirements for shipping are more stringent.
12 DR. MOODY: Than the ones for storage?
13 MR. BONERO: Yes. Yeah.
() 14 DR. MOODY: Okay. The second point --
15 MR. BONERO: It's almost reversible. If you could 16 certify it for shipment, you can surely certify it for 17 storage, but it's not the other way around because of all 18 the impacts and fires and, you know, transport accidents.
19 DR. MOODY: Okay. The second point I just wanted 20 to question for curiosity. Is there, from what you know 21 about the engineering, could you remove the spent fuel?
22 MR. BONERO: Remove --
23 DR. MOODY: From the cask?
24 MR. BONERO: Afterwards?
25 DR. MOODY: Yes. Afterwards.
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1 MR. BONERO: Olh , I think there's very high 2 confidence of that. Yeah. You know, I assume you're 3 ' inferring the possibility of --
4 'DR. MOODY: Reprocessing.
5 MR. BONERO: -- corroding and --
6 DR. MOODY: Well, --
7 MR. BONERO: Oh, oh, for reprocessing? Oh. For 8 the fuel cycle,.that is if the national decision were made 9 to reprocess and recover fiselle value.
10 Certainly, in the dry storage, it's a piece of 11 cake. This stuff is readily accessible. The requirements for 12 the repository include a requirement of retrievability for 13 fifty years or other period as approved by the Commission.
() 14 Now, the primary purpose of the retrievability.
15 there is not for reprocessing. It's for safety that you 16 haven't stuck your spent fuel in the wrong hole, you know, 17 and the site turns out to be unverified, but, nevertheless, 18 you've got a period of that scale perhaps fifty years beyond 19 this dry storage technology that you still have reprocessing 20 access to the spent fuel.
21 So, in round numbers, if you look at it, it 22 approaches something akin to the British decision.
23 MR. VOILAND: Bob, in the topical reports, has 24 there been any consideration of the use of over-packs to 25 ship these storage casks?
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( 1 MR. BONERO: We haven't done one yet. Yeah, yeah.
J2 Consideration is there as there always is with shipping, i
3 that you might take a storage cask and'put something around 4 it. Keep in mind, though, you're up at the hairy limit of-5 waiting --
6 MR. VOILAND: Because of weight.
7 MR. BONERO: These are very heavy,'and, again, 8 it's cost optimization. You know, they come out. You get 9 twenty-one fuel assemblies in it and you've got a dry weight 10 of almost a hundred tons without the fuel, and, so, there 11 'are many options there, but, again, I think the cost 12 availability or the cost parameters will drive it.
13 If we could go beyond Finding 5 to the basis in
() 14 1984 then, back in the entire process here, we're talking 15 about a waste confidence. The Congress had the NWPA in 16 place. They had a desire for interim storage. They probably 17 had an MRS. I mean, the way it was written in 1982, the 18 Nuclear Waste Policy Act certainly enabled the MRS, and NRC, 19 in its regulatory regime, had spent fuel storage in the 20 offing, but there was a much more likely MRS to repository 21 transition and, of course, you had a program at the 22 Department of Energy that forecasted that it would realize a 23 repository in a fairly early time. That is, before the turn 24 of the millennium, and the industry, of course, had the 25 commitment to take care of the spent fuel. They were already
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-1 working on amendments to handle it.
2 Now, in 1989, we've got the Amendments Act. Focus.
3 on one site and the essential difference is~all the eggs in 4 one basket. That is only one site is on the table.and, so, 5 you-have the vulnerability of substantial slips in time if 6 that site falls through. The MRS has been, I think, mooted 7 as a factor,.and the NRC has gone from MRS rulemaking and 8 topical report plant specific rulemaking and is now going 9 into storage proposed rulemaking, you know, these individual 10 storage casks as a prospect.
11 The industry is now well established-in what the
-12 prototype. programs and the forthcoming license application
- 13. clearly with on-site storage. The DOE forecast in the dry 14 cask storage study says that something like twenty-five to
(}
15 . thirty-five-sites, depending on a whole bunch of parameters 16 and assumptions, somewhere between twenty-five and thirty-17 five' sites will need additional dry storage of some sort by 18 the year 2000. That's'the forecast in there.
19 Recognizing that it is possible that there might 20 be some off-site storage, you know, pooling of resources'or 21 combined resources rather than this one at a time kind of 22 thing, you know, that is Surry fuel stored on the Surry l
23 site, H.B. Robinson fuel stored on the H.B. Robinson site, 24 that remains to be seen.
25 The important point is that programmatically the
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)- l' technologyLis in hand, the designs are in. hand, the j 2 institutional mechanisms to use the equipment are in hand, 3 ~ and there is an existing program to deal in quantity with 4 either large amounts of spent fuel or large numbers of' 5 sites.
6 So, with that context, we propose and that's what 7 this whole analysis is intended to say to the Commission, 8 this is a sound technical and policy basis for this re-
-9 evaluation, and in a nutshell, the finding is that the 10 Commission still has confidence and we would revise the five 11 findings as indicated to make them more representative or 12 more realistic of the situation and eliminate some of the 13' things I said before.
() 14 This artificial precision associated with the~
15- milestones of two licensing cases, things like that.
16 So, that completes our representation, and I leave 17 the floor open to any questions.
18 DR. MOELLER: Well, thank you, Bob. I'm sure 19 we'll have a few.
20 One that I had was how were the review group 21 members selected?
22 MR. BONERO: Well, basically, we selected senior 23 staff and senior manager from each office. If you look at l 24 the list, now there is a nominal list, I think that for 25 NMSS, you and I -- Julia Corrado is listed as my alternate.
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() 1 I'm the member. I was deputy director then. I was the member 2 and she was the alternate, but Rob McDougal and John Roberts 3 are deeply involved because of the -- that's the nature of 4 their work.
5 We did the same thing in the Office of Research.
6 Danny Ross was the representative. Bob Kornshevicz was his 7 alternate. In the Office of General Counsel, we've lost, by 8 the way, Marty Maltz, is the chairman of the group and has 9 now been sent into exile as of Monday. He is the acting 10 inspector general, and, so, Stuart Treeby has replaced Marty 11 Maltz as the senior general counsel member of the group.
12 But that's basically what we did, and we did Frank 13 Gillespie and Jerry Wermeil in Reactor Regulation, although
,{])
14 other people are clearly involved and have been involved.
15 So, we basically wanted to get a senior manager 16 and a principal staffer as the designated representatives, 17 and each senior manager drew in the resources needed to do 18 the work, and as you know, you're getting questions and 19 answers from Rob and John Roberts because of their 20 involvement necessarily so.
21 DR. MOELLER: Okay. Thank you.
22 What was the argument or proposal at TMI 2 and its 23 wastes and so forth should somehow confuse the issue here?
24 Can you help me with that? One of the things we read said 25 that one, I guess, one of the intervenor groups had raised l
l
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81 1 b 'l the question on what is the role of the waste confidence 2 proceedings relative to the TMI 2 wastes and the clean-up of I 3 the facility.
4 MR. BONERO: Rob, do you -- I don't have any 5 knowledge of that consideration being overtly in this.
6 101. McDOUGAL: Rob McDougal from NMSS.
7 The only connection I can see off the cuff'would-8 be looking at TMI 2 as an example of the prematurely retired 9 reactor, in the case of TMI 2, it still had its original 10 core when the accident happened, so that there wasn't any 11 spent fuel in storage from that facility, from that unit.
12 So, given that there's a theoretical possibility 13 that this could happen again at a reactor that has spent (f 14 fuel on site being stored, that might be an example of 15 'something that we have taken account of in the question 16 about the institutional commitment. Some entity with the 17 will.and the wherewithal to assure safe storage if a reactor 18 shuts down prematurely for that thirty year institutional --
19 MR. BONERO: Yeah. I think Julia called my 20 attention to in the '84 proceeding, at that time, of course, )
21 the battered core, the partially melted core, was still in 22 the pot, and that there was some question about are you 23 confident you can get it out. That kind of thing.
24 But that's the only thing I can think of, other 25 than that, and, of course, that has been done.
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'(_)s 1 DR. MOELLER: Now, does the movement or 2 development of WIP and the transuranic waste and so forth, 3 has that had any influence on your considerations?
4 MR. BONERO: No, it really has not. Only insofar 5 as it might reflect on technical feasibility of a high-level 6 waste repository, but as you know, the NRC is not regulating 7 WIP or the WIP program.
8 DR. MOODY: Who is?
9 MR. BONERO: DOE and EPA. We have a host of waste 10 management prograus in the United States that are so 11 regulated. That's not the only one.
12 DR. MOELLER: In our meeting with the Nevada 13 people when they came in to talk about this site
() 14 characterization plan and so forth that DOE had submitted, 15 they -- one of the ladies, and I've forgotten her name, 16 brought up the question about delays in the collection and 17 interpretation of data.
18 Her conclusion was that if you looked ahead at the 19 data that need to be collected and the length of time that 20 it would take to collect them and then to interpret them and 21 so forth, that the repository will be delayed from any dates 22 currently proposed.
23 I gather you looked into that and you have enough 24 looseness here to take care of it?
25 MR. BONERO: Yes. What -- that's the -- again, I
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() 1 invite your attention to the parametric analysis of spent 2 fuel accumulation.
.3 It's for that very reason that we had pessimistic 4 assumptions like you take it out to 2000, to the year 2000 5 and the whole thing falls through, and so forth. There are 6 people who feel that an application by 1995 is not realistic 7 for that very reason. That by the time you drill the holes e and look at the cores and do what you do and go drill 9 another hole, it's going to take even longer than 1995 to 10 prepare an application, and, so, that's an important 11 consideration for us in program delay, up there with the 12 Findings 1 and 2. Well, Finding 2 really.
13 DR. MOELLER: For purposes of the record, the
/~T 14 lady's name was Dr. Linda Lehman, L-E-H-M-A-N. Okay. Ms.
NJ
! 15 Linda Lehman. Thank you.
16 MR. BONERO: My goodness. Rank elitism in this 17 solemn body.
18 DR. MOELLER: One of our consultants had raised 19 the question, and I'm sure you've raised it yourself, as to 20 whether compliance with the EPA standards, since they are 21 probablistic, could ever be confirmed. Again, I would gather 22 that your response to that is that your proposed degree of 23 confidence has the time spans and so forth to allow for 24 delays.
25 MR. BONERO: Oh, now, if you're talking about the j
(} ~
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() 1 acceptability of the repository for ultimate disposition, 2 and I referred to that, it's not a direct part of waste 3 confidence, but it is part of the Commission's rulemaking on 4 what does it take to find acceptability.
5 You recall our Part 60 goes hand in glove with EPA 6 Part 191. That finding that says in order to judge -- key 7 finding is no undue risk to the health and safety of the 8 public or, put another way, adequate isolation from human 9 kind, that finding is delineated in many ways in the two 10 standards in question, and it includes the quantitative way 11 to force a disciplined look at the ten thousand year time 12 span, at events that one should anticipate or not anticipate 13 to occur during such a long time span, you know, geologic
{} 14 events, volcanism, what have you, and the discipline by 15 which you make a conclusion, not number crunching. Just 16 read those strndards and read their statements of 17 consideration and they track together.
18 It is not proof in the ordinary sense of the word.
19 This is not a quality control line for Coca-Cola cans, you 20 know. It's a systematic, quantitative discipline for the 21 regulatory thought, for performance assessment, and 22 performance conclusion, and that's certainly a difficult 23 matter. I know you had a presentation from DOE on the 24 performance assessment program, and I urge you to continue 25 in that. Very, very important issue, and it is no different
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([]) I
- 2 saw the -- the EPA standard was not quite out and so forth, 3 but, you know, this die was cast then, that this is an 4 appropriate way for society to make such a decision, such a 5 finding, and there still is hot debate.
6 Many other countries are doing performance 7 assessment. There's an extensive international activity ~1n 8 - that field, and I like to joke about it. I say many of the 9 others would rather circle the hole in the ground, casting 10 . performance assessments on it, until they're all happy and 11 then go home and say that's the right hole, but never say I 12 find this hole to be an acceptable hole because of this 13 discipline performance assessment.
14 DR. MOELLER: You said it, but I'm not sure I
(])
15 understood. You're saying that the aspect of deciding 16 whether the repository finally meets acceptance with respect 17 to EPA standards is a matter that's outside the waste 18 confidence proceedings?
19 MR. BONERO: It is outside -- it's a matter of 20 whether this repository is acceptable, and the only way it 21 can enter this proceeding is if one would drive toward a 22 conclusion that there is no way to determine whether a 23 repository is acceptable and that is not the case. In fact, 24 it was on the table even in '84, that the rulemaking 25 activity, the delineation of what information would be Heritage Reporting Corporation
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(_,/ 1 reviewed, how it would be reviewed and how findings would be 2 made, was well established.
3 It's the technical feasibility, and that hasn't 4 essentially changed.
5 Now, you are aware, of course, I didn't go into 6 it, the EPA standard, recall it has the dose demand and the 7 ground water dose is different from the other dose, and 8 then, the real punch line of EPA standard is the appendix 9 table about nuclide limits, which are much more controlling 10 than dose demand.
11 The court remanded the standard for the dose 12 deniand stuff and they have to resolve that, but the 13 essential character of the standard is expected to be the
() 14 same and we're dealing with it that way.
15 DR. MOELLER: Are there other questions or 16 comments, discussion? Gene?
17 MR. VOILAND: When this came up five years ago, 18 there was a tremendous reaction, political reaction, the
! 19 anti-nuclear folk and the interveners got heavily involved. .
1 20 Would you view that this action would receive the 21 same amount of attention as --
22 MR. BONERO: I can't say. ;
23 MR. VOILAND: -- as it did five years ago?
24 MR. BONERO: We had a whole lot. We've made notice l
25 of it and this will go out for public comment. l
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() 1 MR. .VOILAND: I= guess that's when you really find
-2 out.
3 MR. BONERO: This summer should give evidencelaf.
4 whether or not that -- certainly, there's a lot of. clamor 5 that Yucca Mountain isn't the right repository.
6 DR. MOODY: I was going to say that's always --
7 when you've got this, you know, slide that you had, need to 8 ' account for possibility that Yucca Mountain site will prove 9 unsuitable, that will generate a tremendous amount of 10 publicity.:
11 MR. VOILAND: The statement is true of any. site.
12 MR. BONERO: . Yeah, oh, yeah. Any site is going to 13 have that heat.
14- DR. MOODY: But I think what's happened in the
[])
15 last -- since the EA was published in the last three or four 16 years, there's been more of an emphasis with respect to 17 Yucca Mountain as to the' quality of work'that has been done 18 up to this point. That's questionable.
19 Also, another major issue is its close proximity.
20 to the Nevada test site.
21 DR. MOELLER: Are there other comments or 22 questions?
23' (No response.)
24 DR. MOELLER: Well, before we close, what do you 25 need from the committee and when do you need it?
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(_/ 1 MR. BONERO: Well, recall the schedule slide.
2 DR. MOELLER: Right.
3 MR. BONERO: The -- we're -- of course, this 4 working meeting here leads into next_ week where the 5 committee would meet on this, and we have a schedule to 6 submit to the Commission for approval. This package, you 7 know. The final, you know, -- there's a little editing.
8 There's certainly some editing going to go on with the 9 package we sent you for retention.
10 But we want your review so that we can have 11 reasonable confidence that when we send to the Commission 12 the proposed package that your advice to the Commission 13 won't be, oh, my God, this is off the wall or, you know, n
ls,) 14 that the whole thing is poorly undertaken, and, of course, 15 what that involves is do you see the address of issues and 16 the technical bases drawn on as appropriate and sufficient 17 to support the conclusions or the package that we've '
18 proposed to the Commission.
19 The Commission does want to carry on and do this 20 all in 1989. So that the -- if you have some substantial 21 complaint about the content of it, I would really appreciate 22 early audience of it.
23 DR. MOELLER: And, so, after you brief us on the 24 full committee next week, then you would appreciate a letter 25 being prepared --
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1 MR. BONERO: Yes. I would like very much a letter
({ 2 that can be shared with the Commission during the month of 3 May -- 4 DR. MOELLER: Right. 5 MR. BONERO: -- to rebound and say good, bad, 6 indifferent, whatever you see fit to say. 7 DR. MOELLER: Well, that's fine. That's what we 8 need to know, and we this afternoon or maybe even later this 9 morning, the consultants and I can talk a little bit about 10 what we've heard and whether we have any problems with it. 11 Are there other questions? 12 DR. MOODY: Well, I was just going to say that I 13 think it will take a little bit of time and consideration {} 14 because there are several major points that you have made 15 and put in writing more or less, and I don't think it's -- 16 you can say, or at least I cannot say, instantaneously that 17 it's okay. 18 I think we need to sit down and do a little bit of 19 thinking and looking at, as you say, the technical data 20 backing which you've -- conclusions you've come to. 21 MR. BONERO: Excuse me, Doctor. I would remind you 22 that as in the usual proposal and comment kind of a cycle, 23 invisible in the schedule but clearly part of the plan would 24 be that in the post-public comment cycle, there would be an 25 iteration with you. g' Heritage Reporting Corporation (202) 628-4888
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- ( / l- DR. MOELLER: Correct. Sure. Another one at that 2 point.
3 MR. BONERO: Yeah. 4 DR. MOELLER: Okay. Well, thank you very much for 5 taking your time with.us this morning -- 6' MR. BONERO: All part of the service. 7 DR. MOELLER: Well, it's -- you're always very 8 clear in what you say and very knowledgeable and backed up 9 by the staff. It's been a real help to us. 10 I.think at this point, Mel, do you -- would you be 11 agreeable or is it appropriate for you to spend a few 12 minutes and tell us what the technical review board is doing 13 or in terms of your assessment of DOE's operations?
.() 14 DR. PARRY: I'm sorry, Mr. Chairman. I had spoken 15 to Dr. Carter about this.
16 DR. MOELLER: Put it on the record here. 17' DR. PARRY: I had spoken to Dr. Carter about his 18 briefing the committee, and it had been raised by the staff; 19 that is NMSS staff, that they would be interested in 20 . learning more about the committee that Dr. Carter is a 21 member of. 22 I suggested to Dr. Carter that he perhaps make 23 such a presentation when the full committee is present, so 24- that they would have the benefit of his presentation at the 25 same time. Mel indicated, and I'm sure he can comment, that
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91 (G_) 1 actually next week would be a little tough for him because 2 of other commitments to make a fully broad presentation, and 3 I think we had discussed or considered the May lith meeting 4 as a possible time that he could make such a presentation, 5 if that would be all right. 6 DR. MOELLER: Well, we might delay it until then. 7 However, that's a one-day meeting, which could be quite 8 crowded. 9 If you don't -- if you're prepared to offer just 10 even five minutes of comments, I think we'd be interested. 11 if it's inappropriate, just, you know, say so. 12 DR. CARTER: Oh, I can certainly say something in 13 five minutes, but I'd be much better prepared for the lith () 14 to do that, but if you'd like five minutes, I'll be -- 15 DR. MOODY: Please, please. 16 DR. CARTER: Sure. Let me give you a little bit 17 of background. Of course, it's early in the history of the 18 committee. It's only -- in fact, it's not completely formed 19 at the moment. So, let me address a few of the subjects. 20 The committee was established or its godfather, of 21 course, was the Nuclear Waste Policy Act Amendments of 1987. 22 The committee will have eleven members, and the members 23 recommended by tne National Academy of Sciences, and as I 24 understand it, either two or so people are recommended for 25 each of the slots.
/^
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92 f'T 1 Now, at this time, there are currently eight
-V 2 members that have been appointed, and these appointments 3 were made by President Reagan immediately before he left 4 office. Now, I don't know the significance of that, but it 5 occurred, I think, on the 18th of January because he went 6 out of office on the 20th.
7 So, the other three appointments are still in 8 process, and I understand that President Bush because of his 9 interest in conflicts of interest and these sorts of things 10 is almost looking at every member of a board and so forth on 11 a personal basis. I find that a little bit hard to believe 12 because there are, you know, 400 boards and 6,000 members. 13 You know, there are tremendous numbers of people.
/'T G
14 But, on the other hand, since January now, the 15 other three members have not been appointed. I understand 16 one of them is fairly well along in the process, and, of 17 course, they look into not only technical background, 18 records and this sort of thing, but they certainly look into 19 many things that have a bearing on conflict of interest, 20 either technical, financial, things that wouldn't embarrass 21 the President and, you know, these sorts of things. 22 Anyway, there are eight members at present, and 23 let me mention those to you. The chairman is Dr. Don Dare, 24 and he's basically a geologist, rock mechanics, had a major 25 hand in the design of the Metro system here in Atlanta -- in Heritage Reporting Corporation ('/ s
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93 () 1 Atlanta -- in Washington, for example. He taught at the 2 University of Illinois a number of years and he retired from 3 that and moved to Gainesville, Florida. 4 So, he does a lot of cor.sulting at the moment 5' internationally and, again, in the crea of primarily rock 6 mechanics,-locations of power plants and these sorts of 7 things.
- 8. Dr. Clarence Allen from Cal Tech. He's basically a 9 seismologist and geologist.
10 Dr. Don Langier from Colorado State, geologist. 11 Dr. Cantlon from Michigan State, primarily in_the 12 environmental area. 13 A gentleman by the name of Dr. North. He has his ()' 14 own firm in California. He's involved in decision-making, _ 15 risk analysis, and so forth. 16 Dennis Price from the school in Virginia, involved 17 in operations and industrial safety. 18 Dr. Vawick from the University of Florida, who's a 19 metallurgist and involved in material science. 20 Myself, representing, I guess, radiation 21 protection and public health. 22' And the other three members, like I say, are yet 23 to be appointed. 24 So, there will be eleven members. Normally, the 25 terms will be of four year duration. However, the first (]) Heritage Reporting. Corporation (202) 628-4888
94 () 1 eleven on sort of a staggered basis, there are six of us 2 that will have four year terms, the other five will have two 3 year terms initially, and I might add that the Nuclear Waste 4 Amendments, Policy Amendments Act, established this 5 committee and established the terms. 6 Now, since Congress or the President didn't 7 appoint the members at the proper time, these terms are sort 8 of being force fit. For example, I was appointed in January 9 of this year to essentially a four year term. On the other 10 hand, that term expires in April of '92. So, all of them 11 have got that sort of twist to them. 12 Now, we're going to report semi-annually to the 13 Congress and we're also to advise the Secretary of Energy as () 14 far as the high-level waste program is concerned. 15 Now, we've had one meeting and this was in early 16 March. We met for two days in Washington and received a 17 briefing, a rather comprehensive briefing by the Department 18 of Energy on the total program. Secretary Watkins, I guess, 19 had been appointed or confirmed just several days prior to 20 that by Congress. He took time from his schedule to come 21 down and meet the committee on a personal basis and probably 22 spent about thirty minutes, essentially giving us his views 23 of what he hoped would happen as far as the DOE program was 24 concerned during his tenure in office, and certainly one of 25 his priorities is on the safe and effective disposal of (') Heritage Reporting Corporation (202) 628-4888 i
1 1 95 j l) 1 nuclear waste.
'l 2 Now, we're.in the process at the moment, the i i
'3 Executive Director of our board, by the way, it's called the 4 Nuclear' Waste Technical Review Board, will be a gentleman by i
5 the name_of Bill. Coons, C-O-0-N-S. He also is at'the ! 6 University of Florida. He will be moving to Washington in 7 about two weeks to essentially. set up anl office and begin to 8 formulate a. staff. 9 We have~a budget. I don't remember what it is now, 10 but it's on the' order of soveral million dollars. The 11 funding comes from the waste ft.nd. It's directed,.of course, 12 by Congress. As I understand it, we're essentially a 13 separate distinct organization. We will have franking () 14 privileges, for example. We will hire a staff, including 15 some permanent folks, and also consultants and what not. 16 Now, so far, we'have decided to operate by panels, 17 no differently, I guess, than ACNW, ACRS, and we have 18 several of those formed. Undoubtedly, there will be more. 19 Let me just mention several of these and not necessarily all 20 of them.because this certainly will change with time. 21 .But we have a group that will look at performance 22 assessment. One looking at containers and transportation. 23 One in environment and public health. I happen to chair that 24 one and I'm on one of the others. We'll have one on hydro-25 geology, one on geology and so forth. We also have an 4 () Heritage Reporting (202) 628-4888 Corporation i j I -----
96 O1 executive cemmittee. 1 heggen te be e member of thet. 2 That committee will serve in the absence of the 3 chairman, for example, as far as decisions are concerned. It 1 4 will also advise him in various areas as we proceed. l 5 Now, my guess is that ut, will look at certainly 6 broad issues. We've had one performance assessment committee 7 has met recently in Las Vegas at Yucca Mountain, and my 8 guess is not only broad issues, but we'll also get involved 9 in as much detail as the committee feels comfortable with, 10 and my impression of the members of the group, by the way, 11 is that they won't hesitate to do that. 12 For example, if they think a new or different i 13 drilling technique would be preferable to one that's being l O 14 grogeeed by oos, 1 don t think there w111 be eny hee 1tetien
'15 to advocate such a thing or the hole should be here rather 16 than there sort of thing.
17 So, it's a little bit hard to say, other than that 18 general background, you know, exactly how we will operate. 19 Our next meeting, by the way, of the full committee is 20 slated for Nevada, I believe the last week in June, and it's 21 possible that several of these panels will meet prior to 22 that time. 23 Now, that's a very, you know, very short truncated 24 view of the activity, but I'd be glad to respond to any 25 questions if -- and like I say, I'd be happy to go into more ( Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ - - - _ _ _ - -_ a
97 [')
.v 1 detail as more detail becomes available.
2 DR. MOELLER: Thank you. l 3 Dr. Moody, you have a question? l l 4 DR. MOODY: I was just going to say that they ! l 5 don't consider conflict of interest participating in that 6 committee. i 7 DR. CARTER: I'm glad you raised that question. l 8 It's not clear yet whether that's true or not. I've raised f 9 the issue myself, by the way, with Dade and other people 10 here involved with this particular committee. activity, and 11 I've been in discussion with several other people here and 12 also on the Nuclear Waste Technical Review Board, and, by 13 the way, one of the subjects that this executive committee {} 14 of the board will have to wrestle with, and I happen to be a 15 member of it, is issues of conflict of interest and i 16 potential conflict of interest. 17 So, while I'm here these two days, I'll be here 18 tomorrow as well, and I hcpe to talk to Ray Fraley and some 19 other folks about that very thing, and I had requested and 20 hoped I would have received by now a letter from the NRC 21 attorneys addressing that particular issue. 22 So, yeah, it potentially is a problem. So, it will 23 be one that we're concerned not only about actual conflicts, 24 but obviously an appearance of a conflict. So, whether or 25 not I will be able to participate in both activities is moot (' Heritage Reporting Corporation (202) 628-4888
98 () 1 at the moment, but it wil] be addressed as quickly as 2 possible. 3 Good question. I don't know the exact answer to 4 it. 5 DR. PARRY: I might mention, after our phone 6 conversation yesterday, Mel, it was discussed with Mr. 7 Fraley and Dr. Savio, who is in charge or responsible for 8 that. I hoped he did contact you. He was asked to. 9 Our understanding is that there is no conflict of 10 interest perceived on the part of the NRC legal staff. 11 DR. MOELLER: Will the committee's meetings be 12 open to the public? 13 DR. CARTER: That's an early decision we made. em () 14 They will all be opened to the public, yes, and they'll all 15 be recorded and so forth. Very similar to the procedures you 16 use here. 17 DR. MOELLER: Go ahead, Bill. 18 DR. HINZE: As I understand it, you report to 19 Congress. 20 DR. CARTER: Yes. 21 DR. HINZE: Your documents, materials that you 22 prepare, will this go through the ordinary academy review 23 process or does this go directly to Congress? What is your 24 association with the Academy? 25 DR. CARTER: As far as I know, by the way, the () Heritage Reporting (202) 628-4888 Corporation 4 l l i
I ( ( 99 f( ) 1 question you ask, there would be no review by the Academy 2 that I'm aware of. As far as our involvement or relationship 3 with the Academy, again, it's one early on where the Academy 4 was asked to make a recommendation of potential candidates 5 for the board. The selection then was made presumably in the 6 White House, and then, as far as I know, Bill, there's no 7 further contact by design with the Academy, although I'm 8 sure there will be some inter-relationship. l 1 9 DR. HINZE: So, your meeting which was held at the 10 Academy was just a convenience and not because of -- 11 DR. CARTER: No. The meeting was not at the 12 Academy. 13 DR. HINZE: Oh, I saw Clarence there and so forth, I') %s 14 and I thought you were meeting there at that time. 15 DR. CARTER: No, no. 16 DR. HINZE: Pardon me. I misunderstood. 17 DR. CARTER: Okay. No, no. Okay. Let me clarify 18 that. No. We met at the Forestal Building. So, the meeting 19 was there. It turned out that the MRS Commission happened to 20 be in Washington at the same time. So, we interacted at the 21 Academy on a social basis with those folks. So, that may be 22 the connection. 23 DR. HINZE: All right. That's where the confusion 24 is. 25 DR. MOELLER: Any other comments? () Heritage Reporting (202) 628-4888 Corporation i
100 tm,) 1 (No response.) 2 DR. MOELLER: Well, thank you very much, Mal, and j 3 we appreciate being brought up-to-date and learning those 4 insights and details about the operation of the committee. l j 5 I think with that, we will declare the morning session recessed. I would like to go into executive session I 6 1 7 for a few minutes and just talk a little bit about what 8 we've heard this morning, and we will not be reporting the 9 executive session, but it will be open to the public, any 10 members who desire to stay and listen. 11 (Whereupon, at 11:30 a.m., the meeting was 12 recessed, to reconvene this same day, Wednesday, April 19th, 13 1989.) n (,j 14 15 16 17 18 19 20 21 22 23 . i 24 l 25 4 () Heritage Reporting (202) 628-4888 Corporation
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101 C/ 1 AFTERNOON SESSION l i 2 DR. MOELLER: The meeting will resume. This is a ; I 3 continuation of the working group meeting of the Advisory j 4 Committee on Nuclear Waste. And this afternoon, our entire 5 discussion will be devoted to the NRC Staff's review of 6 DOE's site characterization plan. I might mention that Owen l 7 Merrill, a senior staff engineer with the ACNW has joined us 8 for this portion of the meeting and joining with Dr. Parry 9 who is here for the entire day. 10 This afternoon, we're hearing and I think for the 11 people who are new in ehe audience, we're going to be 12 discussing the comments on the site characterization plan. 13 And I want to emphasize that this is a working group () 14 meeting. We're here simply to gather information, to listen 15 and we realize this is pre-decisional or preliminary 16 information that's being presented, and we can't expect the 17 final answers or the final comments of the staff at this 18 time because they haven't reached that stage. 19 However, it's very beneficial to the Committee and 20 to its consultants to hear this discussion and then to have 21 this as a beginning toward the next, I believe we have three 22 more meetings to review this subject trying to make the end 23 of June deadline to have written comments to you from the 24 Committee on this subject. 25 So we have at the table with us, John Linehan and () Heritage Reporting Corporation (202) 628-4888 1 i
102 King.Stablein. Welcome to those two, and we have many other ([ [ 1 2 NRC people here with us, including Bob Browning, the 3 Director of the Division of High Level Waste Management. 4 John, I'll call on you then to lead off. 5 MR. LINEHAN: Okay, thank you, Dr. Moeller. 6 I'd like to give just a brief introduction to our
- 7 briefing'this afternoon. This first sheet here lists the.
8 agenda we're going to be following this afternoon. And as 9 Dr. Moeller has stated, the purpose of today's meeting is to 10 brief you on the status of our review and let you know what 11 our current thinking is. 12 The staff's review to date has progressed to the 13 point where we have identified areas of interest concern (} 14 that we're exploring. We're not at a point now where we're 15 ready to take positions or identify to you what our comments 16 or what our objections will be. And what we hope to achieve 17 today is to get the committee involved early, lat you know 18 w hat our thinking is.
. And in the next meeting we have in 19 May, we will be able to present you with what our major 20 comments are going to be in the site characterization 21 analysis.
22 Between now and then, in addition to the 23 briefings, I think Dr. Parry's involvement in our team 24 meetings will also be a mechanism where he can keep you 25 posted as to what our current thinking is and some of the l
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103 m (_)' 1 discussions we have in there on what our major comments will 2 be. 3 DR. MOELLER: And as you know, John, Dr. Parry 4 prepares written memoranda summarizing what his observations 5 are at each of these meetings. And I would put on the 6 record that those are very helpful'to us, Jack. 7 DR. PARRY: .I think John knew that. 8 DR. MOELLER: Yes. They are usually one or two 9 pages.long but they're very helpful to us. 10 Go ahead. 11 MR. LINEHAN: And from our standpoint, I think 12 it's very helpful having someone from the committee in those 13 meetings. () 14 . What we're going to start with today is the status 15 of the SCP review by King Stablein who's the Senior Project 16 Manager responsible for the NRC staff review of the SCP. 17 Then I'll be talking about items in the quality assurance 18 area. I'll be followed by Joe Bunting who is the Chief of 19 our engineering group who will talk about engineering 20 concerns. And then Ron Ballard, who is the Branch Chief of 21 the Geoscience and Performance Assessment Branch and he'll 22 be talking about concerns in that area. 23 Okay. King? 24 MR. STABLEIN: Good afternoon. Many of you may 25 remember when Robert Johnson and I came down in February to () Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . _ _ __________J
104 1 talk to you about the SCP review plan and the early status ( '] 2 of the SCP review. What I'm going to try to do today is to 3 set the stage for the discussion that follows and for the 4 ACNW review of the SCP by revisiting very briefly what we 5 hope to accomplish in this review, how we plan to go about 6 that and then where we are in the whole SCP review process. 7 So turning first to what we hope to accomplish, 8 I'd like to just mention the purpose, scope and objectives 9 very briefly. And you may recall these words from February, 10 the purpose, scope and objectives are consistent with what 11 you heard then. 12 The purposes of the review are J ofold. First of 13 all, the NRC has an NWPA mandated responsibility to review (~) V 14 DOE's SCP and prepare what is called the Site 15 Characterization Analysis. I'll be talking about that final 16 product a little bit more shortly. 17 And secondly, something we've been engaged in over 18 the past several years with DOE is to continue the pre-19 license application review and consultation process to 20 highlight issues early and begin the process of resolution 21 of potential licensing issues. So both of those are part of 22 the purpose of this review. 23 The scope of our review is of course the parts of 24 the SCP which relate to 10 CFR Part 60. There are sections 25 of the SCP that are not our responsibility but that DOE must ['] IIeritage Reporting Corporation (202) 628-4888
I l 105 l 1 consider. They have their own siting guidelines, 10 CFR (")'i 2 part 960. Those parts of the siting guidelines not relating 3 to NRC concerns would not be in our purview and we would not i 4 be reviewing the document for those things. 5 And other items such as the plans for mitigating 1 6 environmental impacts caused by site characterization 7 activities, if the site is found unsuitable again is not our 8 responsibility. 9 We will be reviewing all the sections of course 10 relating to issues, information needs and performance 11 allocations and the issue resolution process. Specific 12 areas of concern to us, anything related to potential 13 adverse effects on waste isolation or uite characterization, 14 use of radioactive materials in site characterization,
.( }
15 resolution of the concerns that we identified during our 16 review of the Consultation Draft Site Characterization Plan, 17 which I'll be referring to from now on as the CDSCP. Any 18 key technical topics such as vulcanism or faulting that we 19 have known about through our interactions with DOE and the 20 State, or from our own surveying of the literature and so 21 forth. 22 Shaft related issues are of course very important 23 because the shaft is one of the early events to begin, and 24 QA. 25 Now, the objectives were for the acceptance
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106 1 review, we had to determine whether the DOE had provided 2 enough material for us to do a systematic and orderly review 3 of the SCP. Whether they had provided what is called for in 4 60.17, whether they had provided the level of detail that 5 had been agreed upon in meetings between the NRC and.the DOE 6 in 1985 and 1986, and whether DOE had substantively 7 responded to our CDSCP concerns. And based on all that to 8 determine whether the review should continue. 9 We did complete that acceptance review, as you 10 will see again when I get to the schedule and where we are. 11 We did find the document suitable for further review and of 12 course are engaged in that activity. 13 But the objectives for the technical review, which () 14 is what we are into now, were to identify concerns related 15 to DOE's obtaining the information needed for a complete and 16 high quality license application. 17 To identify concerns that might have significant 18 adverse effects on the waste isolation capabilities of the 19 site. 20 Identify concerns that might make it impossible 21 for DOE to adequately characterize a site, if they were to 22 mess up the site in some way that would physically preclude 23 further site characterization. 24 To determine whether any planned use of 25 radioactive materials in testing is necessary for site l O q,j Heritage Reporting Corporation (202) 628-4888
107-l' characterization.
-2 To review the DOE's resolution of our CDSCP 3 concerns. And to document all of this in the site 4 characterization analysis, the SCA.
5 DR. MOELLER: King? One item of course that was 6 considered: essential with the submission of the SCP was the 7 design acceptability analysis for the exploratory' shaft 8 ' facility. Where does the review of that fit into all of 9 this?- 10 MR. STABLEIN: That document, the DAA, was 11 considered essential to the overall review inasmuch as it 12 bears directly upon the Title I design that is presented in 13 the SCP. And we needed that and it had been agreed upon by (} 14 DOE that they would furnish that to establish _the adequacy 15- of the Title I design. We did receive that document. We've 16 reviewed'it and currently the question is whether we need to 17 have an interaction with DOE about the DAA, whether there 18 should be some written interchange. 19 Once again, we're still at the stage that we're in 20 with the rest of the SCP comments where the Staff has 21 completed a technical review but it hasn't gone through the 22 IQA and the management review. We haven't firmed up 23 positions as yet. 24 DR. MOELLER: Well, will your comments on the DAA 25 be in your SCA or not? () Heritage Reporting (202) 628-4888 Corporation
i 108
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(,). 1 MR. STABLEIN: The current plan is that there 2 would be a section in the SCA for DAA comments. 3 DR. MOELLER: Fine. Okay. 4 MR. STABLEIN: Now, as to how we plan to 5 accomplish the objectives that 1 ve just listed, the basic 6 vehicle guiding the Staff in this review is the SCP review 7 plan which Robert Johnson went through for you in February. 8 And I don't propose to go over all of that again, although I 9 would be happy to address any particular concerns that you 10 might have had after having looked at it. 11 I will just briefly mention a few things about~the 12 review plan. It consists of two parts; a technical review 13 plan and a work plan. The technical review plan was () 14 designed to provide guidance to the staff in their technical-15 review. And the work plan is the administrative part of how 16 the review should be carried out, and so that we could 17 actually implement the technical review plan. 18 Now, the technical review plan consists of review 19 guides which provide guidance to the staff. First of all, 20 there are general review guides which parallel DOE's Chapter 21 8 so that there is general guidance material that can be 22 applied by all the disciplines involved in this effort to 23 the various programs in Chapter 8. And then there are the 24 detailed review guides on specific topics that are of 25 concern to the individual disciplines. () Heritage Reporting Corporation (202) 628-4888
!5 l' 109 ()- l' There are six or seven different disciplines 2 involved in this review, and each of them has specific 3 review guides that apply to their area. And wa transmitted 4 to you by your request a list of the key technical' topics 5- which were being covered in those detailed review guides. 6 And that was sent to, I believe, Jack Parry for distribution j 7 to the members of the panel. 8 Now the work plan, Part B of.the SCP review plan, 9 contains things like the schedule which I'm going to' talk 10 about here at the end, the activities and specific 11 responsibilities, the organization that is the team approach 12 where we have members from all the different disciplines on
.13 our review team trying to look at the SCP interactively and 14 in an integrated way so that we can get that broad view of '(J' 15 the DOE program needed to conduct this review properly. And 16 the internal QA requirements, just the description'of the 17 SCA itself, what that final product is going to be. All of 18 these things are in the work plan.
19 I'd like to discuss only one part of that work 20 plan further and that's the SCA itself, to kind of remind 21 you what it is you are eventually going to be looking at for 22 us. And the SCA is going to consist of five parts as 23 currently construed, anyway. There will be some 24 introductory material. Secondly, there will be the 25 Director's comments and recommendations. And these include () Heritage Reporting (202) 628-4888 Corporation
i l 110 () 1 statement of no objection to DOE's program, or statements of 2 specific objections to DOE's program as presented in the 3 SCP. The Director can also make other specific comments as 4 he sees fit. 5 DR. MOELLER: Now who is the Director? 6 MR. STABLEIN: I'm sorry. That's the Office 7 Director, NMSS Office Director, Robert Bonero. 8 The third part of the document will be a summary 9 of the SCP concerns designed to kind of capsulize the Staff 10 concerns in one place for those who don't want to get into 11 the next segment which will be the detailed laying out of 12 the' concerns in the point papers. But there are going to be 13 three or four tables, charts and short summaries that should 14 enable the reader to go and get a feeling for the staff f'J u-T 15 concerns in this summary section. 16 Then, fourthly, is the segment that we've been 17 working on at the Staff level and those are the SCP 18 concerns, the technical concerns. And those will appear 19 again as they did for the CDSCP in the form of point papers, 20 hopefully succinct, clear, precise statements of the 21 concern, the basis for tha concern, and the recommendation. 22 Those concerns will be prioritized in the order of 23 objections, comments and questions, as we did for the CDSCP. 24 And just to remind us what those three categories mean, the 25 NRC Staff considers objections to be those items and () Heritage Reporting Corporation (202) 628-4888
111 e (x)~ 1 concerns serious enough so that DOE or at least that the NRC 2 recommends DOE not begin work until those have been ( 3 resolved. You may recall from our February discussion or 4 your own reading that we had five of those on the CDSCP, 5 including the alternative conceptual models, the QA 6 objection, and three exploratory shaft related objections. 7 And the standards for something to be an 8 objection-, if the activity would have a potentially adverse 9 impact on repository performance or make it impossible to or 10 physically preclude further site characterization activities 11 and therefore jeopardize the site characterization program, 12 or fundamental inadequacies in the QA program, which would 13 mean that the data gathered would not be effectively usable () 14 in the licensing process. Those sorts of concerns would 15 qualify as objections. 16 Comments will also be very significant matters. 17 Everything that we comment upon should meet the standard of 18 being significant enough so that a person who understands 19 the program can read it and say that is significant; we 20 understand why they commented on it. But the comments are 21 concerns that would result in a significant adverse effect 22 on licensing if not resolved. But if DOE chooses to go 23 ahead at its own risk and resolves this later, they may be 24 able to survive doing that. Whereas with the objections, we 25 would see kind of a fatal effect of not resolving those in ] l l () Heri tage Reporting Corporation (202) 628-4888
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112 1 advance. 2 And questions will be concerns with the 3 presentation in the SCP such that the Staff is basically 4 unable to review a certain portion because we can't 5 understand what has been presented. Either there are 6 inconsistencies, ambiguities or missing information. Any of 7 those sorts of things. 8 DR. PARRY: King, excuse me. Will there be any 9 correlation between the CDSCP objections, comments and 10 concerns and what comes out in the SCA? Will you make 11 reference to that or? 12 MR. STABLEIN: We certainly will. The plan is 13 that every single CDSCP concern will be able to be found in () 14 the SCA. In the fifth part of the SCA, which I didn't get 15 to yet -- no, that's fine. Your question is timely but I 16 should have mentioned the fifth part, which is Appendix A, 17 just in case there are later appendices. Appendix A will be 18 a compilation of all of the resolved, totally resolved CDSCP 19 concerns, all brought together in one place with the Staff's 20 evaluation of what DOE did and how that resolved the 21 concern. l 22 For the partially or totally unresolved CDSCP 23 concerns, those wil.1 be folded into SCP point papers. They l 24 will be clearly referenced. If something has been totally 1 25 untouched, it would just go in, it would still receive an () lleritage Reporting Corporation (202) 628-4888 l
l 113 () 1 SCP comment number or whatever, but it could go in whole 2 with the notice that DOE did nothing to resolve this one. 3 If it's partially resolved, which could be the case for a 4 number of them, this will involve referencing the CDSCP 5 concern that this new point paper deals with, with 6 additional bases discussion of what DOE did to attempt to 7 resolve it, wherein they still need to do more. But there 8 will be, as well as the point papers, there will be a 9 summary table showing for every single CDSCP in the paper 10 what its status is. It's a very important part of the 11 document. 12 Are there any other questions on what I've said up 13 'til now? () 14 DR. HINZE: If I may, what kind of interaction 15 have you had with DOE during all this process? 16 MR. STABLEIN: We have not yet had any meetings 17 with DOE on the SCP. We have had a couple of letters go 18 back and forth regarding various references, but I presume 19 that you meant meetings. We haven't had any, yet. I'm 20 going to let John Linehan say something. 21 MR. LINEHAN: We have requested that DOE meet with 22 us in the beginning of May to go over our main concerns on 23 the SCP and the DAA. The purpose of the meeting will be 24 twofold: Number one in a public forum to make everyone 25 aware of what our major concerns are; and also to provide an Heritage Reporting Corporation (-) (202) 628-4888
f 114 () 1 opportunity for the Department, if they wish, to provide any 2 additional clarification to what they have presented in the 3 SCP, And tentatively, I believe, we're scheduled for May 4 9th and 10th for that meeting. 5 DR. HINZE: I presume they'll be aware of your 6 concerns before that meeting? 7 MR. LINEHAN: In general terms, yes, but it's not 8 a -- the purpose of the meeting isn't to debate the 9 concerns; it's mainly just to give them some advance notice. l 10 There may be some areas where they need to start doing 11 additional work, not to wait a couple of months for uu to 12 get the SCA on the street. As far as them providing 13 clarification, we're trying to set up a format for the {} 14 meeting where we'll have initial sessions on one day where 15 we will present these concerns and then give them a half a 16 day or a day where they can caucus before they give us any 17 response if they do want to provide us with any response. 18 One of the problems is the tight time frame we're 19 operating under. We will not have an opportunity to develop 20 comments and send them to them in advance. And it's mainly 21 to keep them notified as to what is going on in areas where 22 we have major problems. 23 DR. MOELLER: So even prior to issuing your SCA, 24 there will be then this opportunity for DOE to further 25 resolve concerns? () Heritage Reporting Corporation (202) 628-4088
g 115 ( 1 MR. LINEHAN: If they could. provide clarification 2' that would. 3 DR. MOELLER: Right. Jack? 4 DR. PARRY: John, you know,.there's been some 5 debate or some question about when DOE is going to' update 6 the SCP. Have-you had any further information on that? 7 MR. LINEHAN: No, I really can't give you anything 8 definite on that at.this point. 9 DR. PARRY: My last understanding was it would be 10 by this year. 11 MR. LINEHAN: That's not absolutely firm as I 12 understand it. If you wanted to ask someone from DOE that's 13_ here. I don't know at this point. (f 14 DR. . PARRY: Ed, do you have any information? 15 MR. RINGE: This is Ed Ringe from DOE. We do have 16 a date. I'm not positive of the precise date but it is 17 somew).ere approximating six months after it was issued which 18 will be I think in the early July time frame. If there's 19 been a change in that, I suppose I might not have heard if 20 there's been a recent change, but I believe that is at least 21 our plans at the current time. 22 DR. PARRY: Thank you. 23 DR. MOELLER: Go ahead. 1 24 MR. STABLEIN: Are there any other questions 25 before I tackle the schedule and where we are in the review i () Heritage Reporting Corporation (202) 628-4888 l l
116 ( 1 process? 2 DR. MOELLER: Well, presumably, although again you 3 are here for a preliminary briefing today, I would hope that 4 the number of concerns that you have perhaps would have 5 decreased, or the level of them may have decreased between 6 the draft and the final. You know, that would be the hope. 7 Now, I can also understand that DOE then did rewrite many ! 8 portions of the SCP. And in the rewriting perhaps new 9 problems inevitably. developed. 10 MR. STABLEIN: I don't think we know yet whether 11 the number will have decreased or not. But we have allotted 12 considerably more time to the technical review this time 13 around. () 14 DR. MOELLER: Than before. 15 MR. STABLEIN:~ Which has allowed us to look at 16 sections that we couldn't look at as thoroughly last time. 17 And your second point about DOE having rewritten large 18 amounts of the material is also true. So we don't really 19 know whether the number will decrease, or not. I guess we 20 could agree with you, the hope would be that there would be 21 a decreased number of concerns. 22 DR. MOELLER: Well, that clarification, though, is 23 very helpful to me. The first point, that you're reviewing 24 it in more depth now and you're reviewing sections which you j 25 really did not have time to look into on the consultation 1 i () Heritage Reporting (202) 628-4888 Corporation
117 m (_) 1 draft. 2 MR. STABLEIN: That's right. 3 I'm going to turn to the schedule, now, and 4 consider where we are in the review process and how today's 5 meeting fits into the overall review process to set the 6 stage for what you're going to hear after my discussion. 7 You should all have my one chart, the schedule 8 chart that I'm holding up. 9 You can see by the triangle on the fourth line 10 that we have moved through the phases of'the Acceptance 11 Review and the Technical Review. And the Technical Review 12 had a 14-week period as opposed to the four- to six-week 13 period we allotted for the CDSCP review. () 14 We're now on the line, Internal QA and Management 15 Review of the SCA. And we're in the second week of that 16 process. It's an eight-week process. Currently the section 17 leaders are looking at the material generated by their staff 18 members and going back and forth with the staff members on 19 that material, assessing it, and helping to refine the 20 concerns as we move closer toward developing what is called 21 the Section Draft by the end of next week. 22 That will be followed, and I'm still talking about 23 that same line, by development of the Branch Draft as the 24 Branch Chiefs interact with the Section Leaders, following 25 the Section Leader Review. That Branch Draft, which is one () Heritage Reporting Corporation (202) 628-4888
118-1 of the drafts that is supposed to come to the ACNW for an
. r(]J.
2 early look,1should be developed by May 5th. And that May o 3 Sth date should precede our interaction with DOE that John-4 discussed, and our next meeting with.you to consider the. 5 status of the SCP review comments.
-6 Following development of the Branch Draft, the 7' Division Draft gets developed. And that will be completed 8 'around May 22nd. And you are also scheduled to get a copy 9 of that one when it's ready. And finally the NMSS Office 10' Draft is supposed to be ready June 2nd and of course 11 available to'you for your formal review. .
i
- 12. As you can see on the second line below that line
- 13. I was just talking about, the ACNW review line, the attempt 14 has been, as shown by the dashed line, to involve you from-(}
15 the beginning in this process. That's why we had the 16 February briefings. DOE came in and briefed you, also. 17 Then we talked to'you a little bit in March. Now, we're 18 back to talk to you and trying to keep you in touch with the 19 review as it develops. 20- Jack Parry's attendance at the team meetings has 21 been useful in this regard, as well as his participation in 22 those meetings. And I think that's a good vehicle week by 23 week to keep in touch for the ACNW to be in touch with where 24 we are, as well as any materials that we make available in 25 those meetings, and so forth. O Heritage Reporting (202) 628-4888 Corporation
119 l) 1 So then the schedule shows that you all would 2 conduct your formal review in June, from June 2nd to June L. 3 30th. And I know that you all have developed an internal 4 schedule that you hope to. follow to meet that deadline. And. 5 then the Commission review of the SCA after we've taken into 6 account your comments, goes from June 30th to July 14th or 7 thereabouts, and then the printing and issuance in time to 8 get the document transmitted to DOE on July 28th. 9 So today, we're in the middle, or near the 10 beginning of the IQA and Management Review of the SCA. The 11 reviewer drafts have been developed. The section leaders 12 are looking at those. .They haven't finished that review, 13 yet. Hence, what we have for you today is very preliminary () 14 information but at least identification of areas in the SCP 15 that we're focusing on that our attention has been drawn to 16 either because of our past reviews and identification'of 17 concerns, or items that we know to be so important in'the 18 DOE program that they need to be looked at because they l 19 could be symptomatic of concerns throughout the program. 20 In other words, as John cast it, areas that you 21 all might want to take a look at because we're certainly 22 getting more and more interested in those particular areas. 23 DR. PARRY: King, two questions come to mind: Are
. 24 you planning to have a similar kind of review on the updated L
25 SCP in a formal on the semi-annual basis? Is it going to be () Heritage Reporting (202) 628-4888 Corporation
V 120 () 1 as formal?'
.2 MR. STABLEIN: Well, our plans to my knowledge on L
3 that' haven't really crystallized yet. We haven't seen one. 4- .And until we do, I think it's going to be difficult to 5 really say what we're going to do.
.6 MR. LINEHAN: We are going to be updating the 7~ review plan to cover how we're going to handle the reviews.
8 And we could brief you on that once that's done. 9 DR.. PARRY: Another point; have you developed.a 10 . mechanism for closure of open items between yourselves and 11 DOE 7 You have a list of concerns, of objections, and how 12 are you going to resolve them or notice indicate that 13 they've been resolved or that you've agreed to disagree, cn: 14' what? ({} 15 MR. STABLEIN: John may want to answer you, but I 16~ have to say that it didn't mention it. In the SCP review 17 plan itself it does detail our plans to track these SCP-18 concerns as open items, each of which will need to be closed. 19 by the DOE. The methods that we have available for closure 20 presently include interactions and meetings, review of the 21 SCP progress reports. DOE may choose to attempt resolution 22 in those reports. Those are the types of mechanisms that we l 23 currently have available for resolution. 24 DR. PARRY: Thank you. , i 25 MR. STABLEIN: That completes my presentation, ( )' Heritage Reporting Corporation (202) 628-4888
121 f) v 1 unless there are any other questions. 2 DR. MOELLER: I hear none, so we'll go ahead. 3 MR. LINEHAN: The next item I'd like to address is 4 the area of quality assurance. And the one handout I have 5 is this schedule that Dr. Parry is handing out right now. 6 First, I'd like to go back to the major QA concern 7 we had on the consultation draft SCP. Our concern was that 8 the Department of Energy had not demonstrated to us that 9 they had QA plans and procedures in place that met the NRC's 10 criteria. And in fact, during audits we had conducted or 11 observed, and during reviews of DOE documents, we had 12 identified a number of areas where they did indeed not meet l 13 the NRC's quality assurance criteria. 14 We were also concerned about the usability in (]) l 15 licensing of data that had already been collected under 16 existing programs that did not meet the NRC QA criteria. 17 And the concern was that it was questionable how, or if at 18 all, the Department could use this in the licensing of the 19 repository. 20 The third concern we expressed was that we felt 1 21 DOE should not start any new site characterization work 22 until they had fully qualified QA programs in place. 23 As a result of these concerns, we had a number of , 24 meetings with DOE where DOE basically responded in an 25 acceptable manner tn all the concerns we laid out. This is I') Ileritage Reporting Corporation (202) 628-4888 1 1
1 1 122 l (cy . (_) 1 prior to the SCP being published. In the SCP, they did - 2 formally commit to submit QA plans to the NRC Staff for 3 review, and also to conduct audits of the DOE headquarters, 4 DOE project office out at Yucca Mountain, and all of the 5 major contractors with NRC participation in those audits. 6 And finally, they agreed that they would not 7 conduct any new site characterization activities until they 8 had fully qualified quality assurance programs in place, and 9 the NRC had accepted those quality assurance programs. 10 We had a meeting last July, July of '88, with DOE 11 where we jointly agreed to a schedule for these various 12 activities that would have to be conducted for the Staff to i 13 review the program and to gain confidence in it. And to () 14 take a position on its final acceptability. 15 Subsequent to the issuance of the SCP, we had 16 another meeting on that same subject in January of this 17 year. And in that meeting, we jointly agreed to a revised 18 schedule, which is the schedule that was just handed out. 19 And the reason for the revised schedule were delays in the 20 Department's development of their quality assurance plan. 21 And if you've got that schedule in front of you, 22 I'd like to touch on the more important points on it. What 23 it does is it lays out to the left there all of the key 24 contractors involved in the Yucca Mountain project. And it 25 lays out the DOE schedule for starting Title II design of ( D) (_ Heritage Reporting Corporation I (202) 628-4888
i u 123' i U n
. (_) 1 the exploratory shaft, starting site preparation work for) o i
2 the exploratory shaft, in May. Sinking a multi-purpose. 3 borehole-in the September time-frame. And finally sinking 4 .the exploratory shaft -- starting to sink the shaft.in 5 November of this year. 6 And what we agreed on was, prior to those 7 activities taking place, that DOE would submit the quality 8 assurance program plans for the two DOE offices and the 9 various contractors on a certain schedule, that there would 10 be qualification audits which are indicated by those boxes 11 with the star in them. And finally within a certain period 12 af t( r that qualification audit, the NRC would make a final 13 call on whether or not we felt the QA program for the () 14. particular contractor or DOE office was acceptable. 15 DR. CARTER: John, why are these all staggered? -I 16 mean, is there any special reason for that? Has it got to 17 do with workload, or? 18 MR. LINEHAN: It's really workload more than 19 anything. 20 DR. CARTER: Because I think a lot of these 21 organizations are certainly almost independent of each 22 other, as far sa the contractor organizations. 23 MR. LINEHAN: I think a lot of it had to do with 24 DOE being able to work with the contractors almost 25 individually to make sure the programs were in place. As () Heritage Reporting (202) 628-4888 Corporation
124 (m,) 1 you can see, the submittal of the QA program plans isn't as 2 staggered and I think they were able to conduct most of 3 those simultaneously. 4 The other matter was, we told DOE that with our 5 limited resources, we could only handle so many of these 6 audits at a time, and that was another factor that results 7 in that staggering. . DR. MOELLER: Is there a logical reason for USGS 8 9 to be ahead of REECO and ahead of Lawrence Livermore? I 10 mean, you've listed them I guess in the sequence in 11 chronological. order, but why ic one ahead of the other? 12 MR. LINEHAN: There's some logic to that. Fenix & 13 Sisson, Holmes and Navare are involved in the exploratory () 14 shafting activity. You've got Sandia and USGS that are 15 highly involved in the shaft the testing that will be done 16 from the shaft. There is a logic there. 17 One of the concerns we did have, though, was the 18 fact that the Yucca Mountain project, that's the DOE Yucca 19 Mountain project, QA program was following so far behind. 20 You know, we saw them at the top of the permit and thought 21 that indeed that program should be audited and qualified, 22 first. DOE, due to various schedule constraints, was not 23 able to fit that in. And we agreed to this schedule but at 24 the same time indicated that may turn out to be a problem. 25 If there are problems found during the review of that () Heritage Reporting Corporation (202) 628-4888
l. l-125 ([ 1 program, they may trickle down to these other programs.
.2 DR. MOODY: Seeing it's now April,Lhave you, it-3 looks'like'from this schedule the first two were going to be 4 in the qualification audit.
5 MR. LINEHAN: Right. 6 DR. MOODY: Are you planning to? 7 MR. LINEHAN: Yes. The next thing I.was going to
.8 do was go into the status of these various things and in 9 fact hit on that.
10 .With respect to the.QA plans, eight of the ten 11 plans that the Department committed to submit have been 12' submitted. Some of them have been behind schedule but we 13 don't really see that as a problem. We will have enough 14 time to review.them prior.to going out on the qualification
-(])
15 audit. 16 To date, we have completed our review on the Fenix 17 and Sisson QA' program plan. And we've told DOE that we find 18 that acceptable,.providing they can resolve two minor 19 comments that we have on the plan. There has been progress 20 on that. 21 DR. CARTER: John, I believe you mentioned ten. i 22 Is that a slip of the tongue? I only see nine listed here 23 MR. LINEHAN: There's -- come up with a good 24 answer, here -- I got asked this question last time I showed j 25 this. For the ARCA one there's two documents involved
'( )- Heritage Reporting Corporation (202) 628-4888
_ _ _ _ _ _ _ - - _ - _ - - _ _ - - - J
- 126
'([ 1 'there. .Ani please don't ask me what the two documents are 2 but there are'two QA documents there.
3 DR. CARTER: No. -You've done well. Go ahead. 4 MR. LINEHAN: Okay. 5 DR. MOELLER: So can I -- the first one has been 6 done. Is the second one underway?
-7 MR. LINEHAN: We have reviews underway now on a 8 number.of those program plans.
9 DR.-MOELLER: Oh, okay. . Excuse me, Bill? 10 DR. HINZE: I'm curious as a result of the review, 11 obviously there's a good chance that there will be some
- 12 modifications. What sort of plan do you have in mind to go 13 back in and look at the (NL problems that may develop as a h 14 result of compromises, as a result of changes'in the SCP?
15: MR. LINEHAN: The schedule we've~got laid out here 16 we see just as a first step and there's going to'have to be-17 a number of follow-up audits, follow up surveillance to 18 look at those things. You know, we do expect changes to be 19 made all throughout the program, really. And we will be 20 constantly auditing, constantly doing surveillance. 21 With respect to the status of the audits, the 22 audit of the Fenix and Sisson program has been completed.
. 23 And we have concluded that, number one, the audit team 24 conducted an acceptable audit, and number two, we concur 25 with the DOE audit team in their conclusion that the Fenix (f Heritage Reporting Corporation (202) 628-4888
__------,----,-._----,---_-_---_---------__------_-------------u_------_-----------_-a----- -_--u----_-- --.------------.-_-------a.----------- a---------------u------a. ---------a.----- --- ---
127 r ( 1 and Sisson program is acceptable in those areas that were 2 audited. 3 And let me just elaborate on that one point, if I l 4 could. When we originally agreed on this schedule, these 5 program plans were going to have been implemented at the 6 same time or before they were submitted to the NRC. 7 Therefore, there would be a period of time when the various 8 contractors would be doing work in accordance with these 9 program plans. So that when it came time for the audit, we 10 would be able to look at both the procedural aspects to make 11 sure they had the proper QA and technical procedures in 12 place, and also how well they were implementing them and 13 whether there was quality work coming out of all of these (]) 14 procedures. 15 On the Fenix & Sisson audit, on the Holmes and 16 Navare audit, and possibly some of the others,. DOE will only 17 be looking at the procedura.1 aspects, and there will have to 18 be another audit to look at implementation. And the reason 19 is there just isn't work going on right now that's being 20 conducted so that you can look for implementation, for the 21 adequacy of implementation. 22 DR. CARTER: Well, in dividing those programs into 23 two parts, you still do a total audit? 24 MR. LINEHAN: Yes. 25 DR. CARTER: So the entire program, it's a () Heritage Reporting Corporation (202) 628-4888 j
128 1 comprehensive audit. 2 MR. LINEHAN: It's the entire program and all of 3 the I believe it's 18 criteria in Part 50 in the Appendix on
- 4. QA-are addressed.
5 DR. MOELLER: And you're also reminding us then 6 that these audits are being'done by DOE and you are 7- observing them? 8 MR. LINEHAN: Yes, we and the State of Nevada are 9 observing them. 10 As far as the rest of the audits, the Holmes and 11 Navare audit.is going to be conducted next week, and to the 12- best of my knowledge, all of the other audits are on 13 schedule right now. () 14- DR. CARTER: They're on schedule but they haven't 15 started. 16 MR. LINEHAN: Well, that's -- okay. As far as I 17 know, I'm told they're going to come off on schedule, but 18 I'm not giving any guarantees on that. 19 DR. MOELLER: Well, and certainly your first one 20 gives you'at least some room for hope. I mean, obviously 21 they had lifted the quality up to a certain level. 22 MR. LINEHAN: The staff that was on the audit was 23 encouraged. It was a definite improvement, there's no
- 24 question, over what we had seen in the past.
25 DR. MOELLER: Now when you finish this series, as I () Heritage Reporting (202) 628-4888 Corporation _ _ _ - ---m..s__.-_m.__-.__..1__.- __._u.__m___ _ ____m. _-...__-m.__________.-._m ..-._ __. - _____.s__m -,--m __. _. m_--.m_.___--_~-.m_--__._____-._.-.______.____m__m_
l 129 () l' Dr. Carter was pointing out, and as you pointed out, the 2 first thing is you look at procedures, and then you'll go 3 back and look at implementation. And what is the frequency 4 of a QA audit? Is it annually or what? 5 MR. LINEHAN: In the future, our tentative plans 6 are to either observe a DOE audit or conduct our own audit 7 in every one of the contractor areas at least once a year. 8 In addition, there will be surveillance which are QA 9 activities where you look at a very narrow area. And look 10 at it in depth. There will be various surveillance that 11 will be conducted by DOE and either Staff from the NRC in 12 Rockville or one of our on-site reps that has a background 13 in QA will be observing those surveillance. (} 14 In addition, we are going to be conducting what we 15 call QA on-site visits. And these are similar to the DOE 16 surveillance, where we will look at each technical area, 17 not necessarily by contractor, but look at a technical 18 activity and look at the various contractors involved in 19 that particular activity. And take an in-depth vertical 20 slice really to try to get at how well the program is 21 actually working and how it's being implemented, what the 22 final product is. Not just whether the procedures and plans 23 are in place, but if they're being implemented effectively. 24 MR. VOILAND: The subcontractors of course have 25 their self-auditing programs built in. Do you review those l () Heritage Reporting Corporation (202) 628-4888
1 l 130 A N) 1 immediately,-or when you go in to do your audit, or how does 2 that work? 3 MR. LINEHAN: The contractors do indeed have their 4 own audit programs. And that's one of the things that DOE 5 looks at when they conduct their audit, and one of the 6 things we will be looking at also as we observe the DOE 7 audit or conduct our own audit. And it's one of the things 8 we are keying in on. In the past there have been a number 9- of audits, I think essentially.every audit that was 10 conducted identified significant deficiencies. And with the i 11 lack of on going work right now, we are focusing on how well 12 they have corrected the deficiencies that were identified in 13 the past. () 14 MR. VOILAND: If they do careful self-audits, it 15 really works out well. 16 MR. LINEHAN: Hopefully that will happen, yes. 17 MR. VOILAND: It should. 18 MR. LINEHAN: Okay. Just to wrap up, from a 19 procedural point, we have indeed agreed with the Department 20 of Energy on what they need to do to resolve our objection 21 in QA. What we have to see is how acceptable these plans 22 are and also the adequacy of the programs, how well they're 23 implemented through these various audits. 24 And as I indicated, based on the review of the 25 Fenix & Sisson QA program plan, we only had two areas and I () Heritage Reporting (202) 628-4888 Corporation b _ - - _ . - - - _ _ _ - - _ - - - - - - _ - - - - - - - - - _ _ - ---__-_---_--_ ----_ _ - _ - _
1 131 .() 1 they were minor comments. That's very encouraging. And the 2 audit that was conducted last week, at least from a ) 1 3 procedural standpoint - .not implementation at all, we have 4 no feel for that, but procedurally it looked very good and 5 DOE has come a long way in that respect. 6 DR. MOELLER: What did that audit permit in the 7 way of work then to begin? I mean, they were not to'do any 8- more site characterization. Now, because of the completion 9 of the first audit, is this particular group now ready to 10 roll? l 11 MR. LINEHAN: I can't give you a definite answer 12 on that. If you look at this schedule I've given you, one , 13 of the earliest activities that was supposed to start in (} 14 early to mid-February was the start of-Title II's design.
.15 Fenix & Sisson are the key player in that design, as I 16 understand it. There are still other problems before that 17 design can start. There's a number of organizations 18 involved. Fenix and Sisson has to implement design 19 requirements that are handed down from the Yucca Mountain 20 Project Office. And I really don't know the status of all 21 of those others right now.
22 Are there any other questions? 23 DR. CARTER: Yes, John, I had one. I wonder if 24 you'd give us some feel. I guess I come away confused, I 25 suspect. We heard Bob Bonero earlier today and we've heard Heritage Reporting Corporation (]) (202) 628-4888 i
L 132-(k 1 other discussions in the past about the samples, the data 2 and so forth that have been collected out there in the past. 3 .You know, that site has,been there since the early .50s-and 4 'there's certainly,been a lot of site characterizations of 5_ one sort or.another done and you know all of it wasn't holes 6 for bombs, for example. A lot of it was done for 7 hydrological purposes or geological purposes, and I can't 8 believe that everything the USGS and others did was sloppler 9 than heck and so forth and so on. 10 And yet=I've got the impression that the general 11 tenor seems to be that.that's the case and certainly.you 12 folks have got procedures now by which they can go back and 13 _take some of the past information and data and presumably ( . 14 qualify it in.accordance with the reasonable quality 15 assurance. And I'd just like some feel, now. Is this just
~16 sort of an Indian rain dance between the two agencies, or 17 what's actually going on now to take some of that 18 information and either qualify it for use or essentially to 19 throw it out? But I come away very confused about.the whole 20 process, and I gather from the smiles in the audience that 21 other people have the same feeling.
22 MR. LINEHAN: As you've indicated, we issued a 23 technical position on what would be needed to qualify 24 existing data that was not collected under a QA program that 25 met the NRC's requirements. We developed that considering () Heritage Reporting Corporation (202) 628-4888 !
i 133
!({f,-l' comments from the State'of' Nevada, the Department'and.other 2 ' parties.- And had a meeting prior to issuing theLfinal TP 3' where alliof the major commentors agreed on the position.
4 DOE incorporated the basic points and criteria in that'- 5 . position;into their upper 'ier goality assurance program
- 6. " documents.
7 To date, though, they have not come to us with any
-8 data and had discussions as to how.they should qualify that 9 data. We know that they have been looking at a good amount' 10 of the data that was collected in the past by GS and other.
11 contractors, specifically core that was collected. And they 12 are going through a process right now to try to determine 13 whether they can even attempt to try to qualify that data. The problem is the records behind a lot of that {} . 14 j 15f data are very sparse or non-existent. Even if the data, 16 even-if the core may have been collected appropriately, the L 17 chain of custody is very poor. And they have instances 18' where the core in a box isn't the core that is supposed to 19- be in that box. And they really don't know what they can do 20 with that situation. 21 I don't know if anyone from DOE would like to 22 elaborate on that further. But that's really all we know at 23 this point. There hasn't been any active program with us to 24 try to qualify that existing data. 25 MR. BROWNING: Bob Browning. I think I might just O Heritage Reporting (202) 628-4888 Corporation
134 () 1 add, I think the thrust of DOE's program has been to try to 2 get their program in place so they could go collect some new l l 3 data. For example, on this schedule, you see the multi- j 4 purpose bore hole. All they're attempts are trying to make 5 sure when they go collect that, we have a frame of reference 6 of what was a good QA program, it was done properly. We 7 look over their shoulder and we all have a high level of 8 confidence that was done right, before they spend a lot of 9 time and effort going back and looking at the old data. 10 They may not need the old data to make the kind of licensing 11 cases they may have to. If they do, then it might make some 12 sense to go back and try to resurrect some of that data. 13 But with our linited resources and their relatively limited (} 14 resources also, I think that's really the thrust of the 15 program right now. 16 My understanding is that when John was out there 17 recently, we had a group of people visit the new core 18 facility that they put in place. And if that was any judge, 19 checking when they go do this particular job, they will have 20 a well thought out well qualified program, and then that 21 would give us a frame of reference that will help decide 22 whether we really need to go back and look at the old data. 23 I don't know whether that helps or not, but I 24 think they haven't really spent a lot of time going back and 25 upgrading the old data to meet the new requirements. Heritage Reporting Corporation (]) (202) 628-4888
1 135 i 1 DR. CARTER: Well, this just seems to be sort of a
-(])
2 sticking point kind of thing or a thing when it's discussed, a 3 people sort of smirk a little bit about, but I would 4 certainly think they could screen a lot of that stuff. You 5 know, obviously if only half the core is there or whatever 6 reason, some of them are fairly obvious and you know, they 7 could toss those out and there wouldn't be a point of 8 consideration or consternation or whatever. 9 DR. MOELLER: I think what Mel is saying also is 10 that you probably could, and I'm sure DOE is doing this, you 11 could go back over the data and figure out what's worth 12 trying to recover and what isn't, and I'm sure someone's 13 doing an assessment of the relative cost and pain of re-14 doing it versus trying to qualify the old data. (]) 15 MR. LINEHAN: DOE indeed is doing that. And with 16 respect to the existing core, I was at a meeting probably a 17 year ago where they gave a presentation on that. And my 18 understanding of the presentation was that there was a good 19 amount of that core, if not the majority, that they did not 20 feel they could qualify in any way. But, there is a study 21 group and I don't know where they stand right now on that. 22 DR. MOODY: This identifies a long existing 23 problem. And that is that when you look at your program 24 guide here, when you look at the organizations that are 25 involved, you know, that's been part of the problem Heritage Reporting Corporation (]) (202) 628-4888 l l
136 () 1 certainly in the past in the sense of trying to meet even 2 minimum QA guidelines. 3 MR. LINEHAN: Okay, that's all I had, Doctor. 4 DR. MOELLER: All right. So the next item then is 5 the engineering? 6 MR. LINEHAN: Yes. And Joe Bunting who is the 7 Chief of our engineering branch in the Division of High 8 Level Waste Management will be giving that presentation. 9 DR. MOELLER: Could you begin by defining what the 10 envelop of engineering concerns covers? Thank you. 11 MR. BUNTING: Yes, I will. 12 My areas of responsibility are the geotechnical 13 engineering, the waste package and the engineering barrier. (} 14 And I thought I would start off with going over a little bit 15 on the status of the engineering issues that were raised in 16 the review of the CDSCP. And then I will get into new areas 17 of potential engineering concerns that we are struggling 18 with now in reviewing the SCP. 19 And I would like to begin by making a few 20 qualifying remarks. Number one, what I'm going to tell you 21 is what we're seeing today doesn't mean this is the way it's 22 going to come out, some of these, the status that I may give 23 you on the comments on the CDSCP may change as a result of 24 the review we're going through. Some of these new areas may 25 not appear, and some that I haven't covered here may show up Heritage Reporting Corporation (]) (202) 628-4888
127 () I when we get through. 2 I would also tell you that this is a new area of l 3 responsibility that was assigned to me along about October, 4 so I did not personally participate in the review of the 5 CDSCP. So much of what I'm going to talk about here in 6 these new areas of concern are, as John and others 7 mentioned, the Branch Chiefs are just now getting involved 8 and looking at the pieces of the puzzles. And these are 9 some of my preliminary thoughts about how these pieces may 10 go together and what they may mean in some overall way. 11 So with that, I'll begin with the status of the 12 CDSCP, We had three objections in the geotechnical area and 13 a number of concerns, one of which was on the borderline () 14 between an objection and a concern. We think at this time 15 that we'd be willing to close out two of those objections 16 and that is the location of the shaft and the penetration of 17 the Calico Hills in the formation. 18 Now, the objection on the location of the shaft 19 was raised principally because of the potential for 20 flooding. But more specifically, when we briefed the 21 Commission last November, we indicated that a lot of these 22 things that we're seeing we characterize more as symptoms of 23 a bigger problem. And we cautioned DOE not to address these 24 things as individual things, but really look at this as a 25 symptom and say, how did these things develop and how did () Heritage Reporting Corporation (202) 628-4888
138-r (_)y 1 they come about. And one of the things we raised was 2 understanding the decision on how you did locate the shaft. 3 So the shaft has been moved. It is on higher 4 ground and it looks like the potential for flooding is not 5 there anymore. 6 And DOE has committed that they will not extend 7 the exploratory shafts to penetrate Calico Hills until 8 they've done a study to assess the impact of that. 9 One of the other objections was the potential for 10 -- 11 Yes, sir? 12 DR. HINZE: Could I interrupt with a question? We 13 were told at a meeting I believe in February that the A (,) 14 location of the shaft was established in 1983. One of the 15 objectives, there are several objectives for the shaft, 16 undoubtedly, one of them is to make certain that we have a 17 representative large sample of the area. I find it rather 18 difficult to understand how the data that has been collected 19 from 1983 onward and the analyses that have been made since 20 then have not brought to focus concerns about moving the 21 shaft to a much more representative site from a geological 22 standpoint. I'm not talking about from an engineering 23 standpoint, so I may be out of line in this question to you. l 24 But I think that I'm very concerned about the l- 25 geological sample and I'm also concerned that once the (n,) Heritage Reporting Corporation (202) 628-4888 ( 1
i l 139 1 ( [) 1 exploratory shaft is in place, that we're going dowil hill. 2 That we're into a situation where it's going to be hard to 3 reverse the procedure. And I'm wondering if the geological 4 concerns have been taken into account in the moving or the 5 locating of the shaft, and if there are some early on site 6 characterization studies that will establish the voracity of 7 that site as being truly representative. 8 MR. BUNTING: Well, I'm going to leave addrecsing 9 your question on the geology issue to Mr. Ballard, who is 10 going to follow me, and I think he has a point that will be 11 directly to the question you are making. 12 I did want to also indicate, I started to tell you 13 the other objection had to do with the potential for 14 interference in the testing in the underground area. We f(]) 15 raised that in the CDSCP. Who.t's been presented in the SCP 16 is a vast improvement but we still find, we',re still 17 struggling to find how it's demonstrated that all this 18 testing can be done and not inderfere with each other. 19 Some of the layout that's been presented for the 20 individual tests we find does not include all the tests that 21 are referenced in the SCP are to be conducted. From that 22 standpoint, we're still struggling to find how this has been 23 demonstrated. 24 DR. CARTER: Does this mean concurrent activities 25 or the scheduling of tests or all of those? () Heritage Reporting Corporation (202) 628-4888
140 () 1 MR. BUNTING: 'These are, for instance, if you look 2 at one case, there's a location of a test. _W ell, the test 3 isn't there, it's really somewhere else. When you draw the 4 zone of influence from that test, it does get into the 5 influence zone of another test. So there's also the 6 potential for a plan for running tests sequentially. And 7 you can't see how this can be done in the time allotted to 8 have these things done. 9 So, again, I want to say at this time, we're 10 struggling to find a demonstration that these can be done as i 11 opposed to telling you that it just can't happen. . 12 The other concern that we raised to the Commission 13 in our briefing in November had to do a little bit with what () 14 Dr. Hinze was just talking about. The representativeness of 15 the drifting that would be done, once the. shaft was down. 16 If you recall looking at the plan for the exploratory shaft, 17 it was all up in one corner of the repository block. We are 18 still struggling to' understand again why that would be 19 adequate. 20 With me today is Dr. Roger who is representing us 21 out in Nevada at the meeting of the President's Technical 22 Review Board. And they nave taken this question up, also. 23 I believe they've gotten some agreement from DOE to change 24 that. So if you like, you can invite him now or later to 25 sit at the table and give you a first hand account of what (). Heritage Reporting Corporation (202) 628-4888 1 i
141 t () I happened. 2 DR. MOELLER: I think we'd like to hear it. Yes, ' 3 that would be nice. Come ahead, then. 4 MR. LINEHAN: If I could just clarify one point. 5 I don't think anything was agreed on. The TRB made 6 recommendations but DOE did not take a position at the 7 meeting. 8 DR. ROGER: I don't know how much detail you would 9 like to hear from me. I attended the meeting last week for 10 two days where the Department of Energy presented to the 11 Technical Review Board information in response to two 12 specific questions that were raised in an earlier meeting 13 that they had brought us, I believe. Actually they raised 14 three questions, but only two questions were raised in this (} 15 particular meeting. l 16 And the two questions were, the first question had 17 to do with the technique of constructing the exploratory 18 shafts, and the second one had to do with the need for a 19 perimeter drift at the site characterization stage. 20 And the bottom line was that the Technical Review 21 Board appeared to be convinced that it is too premature 22 early in this stage to have a perimeter drift as a part of 23 the site characterization plan. Because they still don't 24 know what the boundary of the repository is going to be. So 25 they agreed that it was too early to decide on the perimeter () Ileritage Reporting Corporation (202) 628-4888
o 142 L 1 drift. 2 However, they emphatically stressed the need for 3 additional drifting, more than what has been proposed in the 4 site characterization plan. Specifically, they wanted the 5 drifts to go as far as possible in the east-west direction 6 as from north-south so that the drifts will intersect the 7 Ghost Dance fault at least twice, once on the west and again 8 in the south. That was the recommendation of the TRB. And 9 -the second thing was -- 10 DR. MOELLER: You say, to say that a little bit 11 slower or once again, in terms, you're talking about the 12 exploratory shaft and you're talking about the drifts that 13 are drilled out horizontally from the shaft. () 14 DR. ROGER: Right. There are about 5,000 feet of 15 drifting proposed right now as a part of the site 16 characterization plan which are specifically directed to 17 investigate certain features. Now, in addition to that, the 18 TRB wants more drifting. 19 DR. MOELLER: To intersect the Ghost Dance fault. 20 DR. ROGER: The Ghost Dance fault will be , 21 intersected in the western direction in the current plan. 1 22 But they would like to continue the drifting as far as 23 possible in the western direction more, and also in addition 24 to that, they would like at least the north south drifting 25 to intersect the Ghost Dance fault, again. That's the () Heritage Reporting Corporation (202) 628-4888 l
143 r"; (,) 1 minimum they would like to see, and if possible, more. That 2 is their recommendation. 3 DR. MOELLER: So this is in my opinion quite a 4 detailed recommendation. I mean, this is really getting 5 down into details. 6 DR. ROGER: Yes. And as far as the construction 7 technique of the shafts are concerned, the TRB was of the 8 opinion that at least one of the shafts should be raise 9 bored instead of bored the shafts being drilled and blasted. 10 The current plan is for having two shafts, both of them 11 conventionally drilled and blasted. The TRB recommends 12 that, if possible, both the shafts be raise bored. That is, 13 you start off with a smaller diameter drilled shaft and then () 14 raise bore it as well as the second shaft, which will there 15 will be a boring first and then up-reaming, using a 16 technique which will have minimum disturbance from a 17 mechanical point of view. And also introduce no fluids. 18 The current plan is to account for the 19 disturbances caused by the introduction of fluids and the 20 mechanical disturbances. And the TRB was of the opinion, if 21 you can avoid the disturbance, please do so. Don't try to 22 correct for it later on. 23 DR. HINZE: Excuse me. Is the reaming, the boring j 24 dry or is it with fluids? 25 DR. ROGER: Yes. Reaming will be dry. () Heritage Reporting Corporation (202) 628-4888
144 () 1 DR. HINZE: And the boring will be dry, as well? 2 DR. ROGER: That's not proven yet. They are 3 trying to demonstrate that. 4 DR. MOODY: I was going to ask, down to 1500 feet, 5 is it still feasible that it could be dry? 6 DR. ROGER: They are trying to demonstrate that. 7 They have not been able to do. I think drying is possible 8 if you don't want to do any coring. Drilling will be 9 possible dry if you don't want to do any coring. But if you 10 want to do drilling along with coring, the dry drilling 11 technique is not demonstrated yet for the holes. But up 12 reaming is dry. 13 DR. CARTER: I just wanted to make a comment and () 14 an observation. The comment is that this was one of the 15 panels of the Technical Review Board, not a full meeting of 16 the TRB for one thing. 17 The other one, I think I mentioned a little bit 18 earlier that the TRB would get into as much detail as they 19 felt comfortable with. So I think this is an example of 20 that. 21 DR. MOELLER: And I guess I might comment that 22 when Dr. Carter went over the membership of the TRB this 23 morning and briefed us on it, and I thought I heard a 24 preponderance of academic types on it. j l 25 DR. MOODY: I would just say that is there any () Heritage Reporting Corporation (202) 628-4888
145 l' possibility, even though they've commented on this, I'll put []). 2 it in writing because I think the methodology behind
'3 excavation of the exploratory shaft is not trivial.
4 DR. ROGER: Although the members, as you said, are 5 academics, they are also practitioners. And at least the 6 four members who were there on this subcommittee are all 7 well known for their contributions in underground 8 construction and highly knowledgeable in the area of 9 geotechnical engineering. 10 DR. MOELLER: Very good. That's good to hear. 11 DR. HINZE: If I may, how is.the decision going to 12 'be made about the method of emplacing the shafts, and when 13 is that going to be made? 14 The decision, when and how is the decision going (, } . 15 to be made about putting in the shafts. 16 DR. ROGER: According to the SCP, the decision has 17 been made. 18 DR. MOODY: That raises my whole point. If you 19 have this high level review group state that that decision 20 is not the best decision that should be made or even the 21 most adequate decision, is there a possibility with this 22 question that Dr. Hinze raised, is there a possibility for 23 change? 24 DR. ROGER: I don't think I can answer that 25 question. (} Heritage Reporting Corporation (202) 628-4888
146. () 1 DR. CARTER: Well, I think.one thing will be 2 clear. I think the recommendations or the observations of 3 this Technical Review Board will be given-very careful 4 consideration by DOE. I think I can assure you of that. 5 DR. MOODY: Well, have you already put'something 6 in writing to DOE relating to this particular decision? 7 DR.. CARTER: .Well, I have no idea. The' meeting 8 was only held last week. 9 DR. ROGER: This was on the lith and 12th in Las 10 Vegas. 11 DR. CARTER: I'm sure it will be. 12 MR. BUNTING: Any other questions for Dr. Roger? 13 DR. MOELLER: No, that was very helpful. Thank (} 14 you. 15 Were you finished, or? 16 DR. ROGER: Yes. 17 DR..MOELLER: Okay. Well, thank you. 18 MR. BUNTING: Okay. I'll continue by telling you 19 that in addition to the objections which I just. covered, 20 there were a number of comments and ccacerns and in the 21 geotechnical area it now appears as though about half of 22 those we think we'll be able to say have been fully resolved 23 'as a result of the SCP. And in the area of waste package 24 and engineered barrier, the tentative look-see says that 25 approximately 80 percent of those are resolved. Heritage Reporting Corporation (]) (202) 628-4888
147 (J 1 However, I do want to' indicate to you that 2 importance and the substance aren't reflected in-the numbers 3 count. l
~
4- Getting into the new areas of potential concern -- 5 .DR. CARTER: Let me interrupt, if I might. Let me 6 ask you one question about the location of shafts. How much ! 7 were these actually changed now in elevation'to get away 8 from problems of potential flooding, at-least a greatly 9 reduced problem of flooding. 10 MS. ADAMS: The shaft's been moved up outside of 13 the wash. And is moved up on the slope of the hill in 12' bedrock. , l 13 DR. CARTER: Well, is it changed 50 feet or 100 l
]} 14 feet, or give us some idea?
p '15 DR. ROGER: This is Dr. Roger again. The change 16 did not result-as a result of our cbjection. The location 17 had been already moved to a higher elevation even'before we
-18 made this' objection in the CDSCP. Therefore, I don't know 19 whether I"m answering your question.or not. Originally,
-20 the shaft was located in the middle of the wash, and then it 21 was moved to the site of the wash which is several feet 22 above'the maximum flood elevation. So our concern, we had 23 several other concerns in addition to the flooding. We had 24 erosion concerns and we had concerns about the long term 25 isolation impacts and they have addressed all those issues
() Heritage Reporting (202) 628-4888 Corporation l
148 1 in the current SCP now.
-(])
2 MR. LINEHAN: Rog, how did the actual elevation 3 change though of the shaft? 4 DR. ROGER: I don't have the exact figures.but it i 5 is above the maximum flood level according to the 6 calculations. 7 MR. LINEHAN: Do we know how that compared'with. 8 the original? 9 DR. ROGER: The original was in the wash which was 10- definitely below the maximum flood level. 11 DR. CARTER: So we've gone from.the wash to almost
'12 the top of the mountain, is that --
13 DR. BROWNING: No, no. It's confusing. Because 14 if you look at the slope, it actually moved kind of down the (} 15 hill and up the side. I think is the way to say it. So if 16 you're looking at elevation, I think you'd actually see that 17- it went to a lower elevation above sea level. But it's 18 above the wash. Before, if you went there, you know, if 19 water was draining down the mountain, it would go right down 20 the hole. So they moved it up the side of the wash. 21 DR. CARTER: We put it deeper, in other words. 22 DR. BROWNING: Well, they took it out of the place 23 where you know at least a casual observer would be concerned 24 about the possibility of runoff from a storm on the mountain 25 to a place where it won't. I think in a later presentation, Heritage Reporting Corporation (]) (202) 628-4888
149 1 (J 1 you'll see that.that didn't really necessarily resolve the 2 kinds of questions Mr. Hinze was asking. It was a reaction 3 to certain concerns to fix them but it doesn't necessarily 1 4 resolve the question, is it located in a place where you're 5 going to learn the maximum amount about what the various 1 6 layers are from this first thing where you can actually send 7 a man down and look at what he sees as he goes down. 8 D R ., MOODY: Well, this is tied into my question. 9 In the SCP which came out with the final date on it,. late 10 '88, early '89, is this new location documented in the SCP 11 that you're reviewing? 12 DR. BROWNING: Yes. 13 MR. BUNTING: Okay. I'll move into the new areas 14 that we're struggling with right now. And the first one I (} 15 would like to talk about is what we see as DOE's approach to 16 sealing and the implication that may have to the waste 17 package performance. And I wanted to tell you that we're 18 scheduled to brief you (n1 April 26th on the technical 19 position on sealing, and in that briefing, we will'give you 20 an overview of the concepts DOE intends to use in sealing as 21 they use in the illustrations out of the SCP. 22 The thing I want to convey to-you now is that DOE 23 is saying that they do not need seals and will not allocate 24 any perfo"Ma. ace to seals. But they plan to use them and 25 they'll have them there. They will be sealing both for in Herf.tage Reporting Corporation (]) (202) 628-4888 r . _--____ - - -- - --
150 l() 1 flow of water and outflow of gas at the intersections of the 2 drifts and the vertical shafts. 3 They also show the major sealing techniques are 4 really not sealing but they're-control mechanisms. In other 5 words, they are saying that they don't expect to find water, 6 but if.they do find water in these natural openings that
- 7. they. encounter in the drifts, emplacement rooms, etcetera, 8 they'll use devices and techniques tx) control the. flow of 9 water to try and isolate that from the waste itself.
10 So implicit in that, from what we're seeing is, on 11 the one hand, they plan to. seal.the intersections of manmade 12 openings.for both gas outflow and water inflow, but their-13 only plan to us sealing techniques in natural openings-for () 14 the' inflow of water and the outflow of gases is just not 15 addressed. Which leads us to tentatively conclude that 16 you're not counting on the geologic setting to make much of 17 a contribution in the way of providing any isolation for the 18 outflow of gases that will come off the waste package. 19 And that means then that you have a single barrier 20 for that problem and that is the waste package itself. 21 Because they don't plan to use seals, they did not include 22 the provisions of 60.134 which is design criteria for seals, 23 in the design acceptability analysis with regard to the 24 shaft. And seals of course then would not be included on 25 the Q list. So we're somewhat concerned that on the one () Heritage Reporting Corporation (202) 628-4888
l l L ! ! 151 ( 1 hand, we've got them if we need them, and on the other hand, 2 we don't plan to use them and therefore we don't plan to 3 test them, put them on the Q list, etcetera. 4 The other problem we're struggling with now is the 5 definition of waste package failure as we see it in the SCP. I 6 DOE has defined failure to be a breach of a certain size 7 that would allow airflow of a certain volume. And that 8 definition follows then into their plans to demonstrate 9 compliance with containment in that you'd use a pressure 10 test to test for effective closure. We are thinking of 11 failure aa loss of function. Function is to contain. If 12 you lose that function, no matter how, that constitutes i 13 failure. () 14 We are aware that helium will pass through metal, 15 through green boundary migration. We don't see that DOE has 16 addressed the problem of potential for green boundary 17 migration either in the definition of failure, and therefore 18 consequently not in their plans for testing. 19 We had a comment last time and we have one this 20 time on the DOE's interpretation of the regulatory 21 requirement for substantially complete containment. We, 22 ourselves, are struggling with this. It is a regulatory 23 uncertainty that's been identified by the Center. Of 24 course, we've identified it for some time and we're 25 struggling to come to grips with just exactly what that () Heritage Reporting Corporation (202) 628-4888 i
152 O(,f 1 means. 2 But from our standpoint, we think that at the time 3 of closure when you make your project for how long these 4 canisters are going to last, we need performance 5 conformation program results which would indicate to us the 6 limits on the uncertainty of these projections. Which means 7 some confidence to be built in. 8 We don't see in the program yet as laid out in the j 9 SCP that DOE recognizes this requirement, plans to address 10 the demonstration or the interpretation of substantially 11 complete containment that way. 12 The next issue has to do with Carbon 14. We have 13 been made aware of a paper that identifies the potential for (m 14 Carbon 14 to be generated in the waste package of spent fuel
- (_)
15 now. The paper indicates that through testing that's been 16 done to date, it's been found that there are sufficient 17 impurities in the cladding on the fuel rods such that if 18 only that alone when it's exposed to air, water, whatever, 19 to oxidize the release of carbon 14 would exceed the EPA 20 standard and also exceed the NRC release rate standard of 1 21 part in 10 to 5 by an order of magnitude. 22 So when we couple this problem of the gaseous 23 outflow with waste package testing with the potential for 24 carbon 14 generation, we don't find at this time that 25 there's an adequate recognition of this problem, and how i () Heritage Reporting Corporation (202) 628-4888
153 L . .
]I 1 that's going to be dealt with in the SCP. And that leads !
2 into our next point here which is the potential to lose.the 3 opportunity for ten years of testing. 4 And I don't want this to be interpreted as the l 5 Staff at this point saying that we require full scale in 6 situ testing of the waste package. We're just saying we 7 have a very complex arrangement here. We haven't seen a 8 good demonstration of how DOE is going to'get the test data 9 to derive its competence numbers at the time of closure. 10 And here's an opportunity to get ten more years of test 11 data, which if you're going to develop some confidence 12 numbers, we think would be very important. 13 We would like to see before the shaft is executed (') 14 because in the shaft design at the moment, the hoist would 15 not permit the introduction of a full scale package and a 16 shielding cask down the shaft. So if you proceeded with 17 this design at the moment, you would foreclose the option of 18 getting tests. That's okay with us if you have an 19 alternative plan that shows us that you can get the kind of 20 data you need to generate the kind of confidence you need at 21 the decision point for closure and you can afford not to 22 take advantage of this ten years of in situ testing. 23- DR. PARRY: Bob, excuse me. When I was at 24 Battelle, I looked at this carbon 14 problem previously. As 25 I remember my calculations at that time, it would not have () Heritage Reporting Corporation (202) 628-4888
154 () 1 been in excess of a tenth of one percent in a thousand 2 years, so consequently would not be subject as our 3 interpretation was at that time to the 10 to the minus 5th 4 lease limit. I don't remember about the EPA standard. 5 In you calculations, did you check on its 6 inventory position? l 1 7 MR. BUNTING: What I have I'm quoting is a paper 8 written by DOE's contractor, Sandia Laboratory, dated 1986, 9 presented to the Materials Research Society quoting tests 10 that have been done. And they did a comparison between 11 calculations and test results both for PWR and BWR fuel. 12 And in the PWR, I believe, there was good correlation 13 between the calculations and the actual tests. {< } 14 DR. PARRY: That was on the release rate of carbon 15 14 from the fuel? 16 MR. BUNTING: Correct. And for PWRs, I believe, 17 the test results were in excess of the calculations. And it 18 has to do with getting a good number on the impurities that 19 are in the fuel as constructed. 20 ~ DR. MOODY: That's highly variable. 21 DR. MOELLER: And this assumes the carbon 14 22 migrates up through the overlying soil? 23 MR. BUNTING: The notion here is they're just 24 talking in the paper that once containment is breached. As 25 long as the containment's in place, the waste is surrounded () Heritage Reporting (202) 628-4888 Corporation
, 155 l_ (} 1 by inert gases and you aren't going to get any release. The 2- notion is that because of you don't want all your waste 3 packages to fail at the same time. If you do, then what's 4 coming out of the waste packages is going to exceed the 5- standards. 6 Now, they do point out that there's some evidence 7 that the~ atmosphere in the mountain itself is deficient in 8 natural carbon 14. So some of it would be taken up by that. 9 DR. MOELLER: Yes, exchange. 10 MR. BUNTING: All they're trying to say, and 11 they're not making any conclusions, that all of this is 12 going to migrate and get to the boundary of the repository 13 and exceed the standards. They're just saying it's going to 14' take a very complex transport model to understand what's [} 15 going to happen. I'm just coming at it from the waste 16 package side to say, there's a threat here. You almost have 17 a single barrier now for this potential threat and we're 18 looking for very good confidence to be presented to 19 establish what containment limits are going to be and what 20 the release rates are going to be. 21 And we think that that's going to require some 22 extensive tests, long term tests. I'm just calling 23 attention to the opportunity to get ten year's of testing if 24 you begin in site characterization. 61.40 says that 25 performance confirmation shall have begun during site Heritage Reporting Corporation (]) (202) 628-4888 l i _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ . _w
r, l 156. 1 characterization. That's.one of the regulations that DOE (]).
- 2. says they only qualitatively considered in the design of 3 Title I for the ESF.
4 DR. MOELLER: Then what-you're saying is that if 5 we assume it's ten years before the repository is ready to 6 accept wastes and begin, that they could be doing in situ 7 testing on site with actual or simulated products. Okay. 8 MR. BUNTING: Yes. We're saying that if you take 9 a look at the time gap, between the time you are able to 10 start something during site characterization, site 11 characterization's then completed, license application 12 prepared, it's r'aviewed by the Staff, then you go into 13 construction. By the time you construct a ramp which would 1 {) 14 then be your first opportunity to get a full scale down 15 there, ten years plus I would say. 16 We're not trying to say, again, that full scale 17 testing is required. It's one way we know of you can get 18 the real world. And we're willing to look and listen to any 19 plans in which you show us that it can be done without that. 20 That's all. And we'd like to see those before that 21 opportunity is foreclosed. 22 DR. MOODY: Well, what you're saying is that I 23 don't think they yet have begun Title II design, or am I 24 incorrect on that. Have they begun Title II design for the 25 exploratory shaft? 1 () Heritage Reporting Corporation (202) 628-4888 l i - - - _ _ _ _ = _ - - - _ _ _ _ _ _ _ _ _ _ - - -.
l 157 (O _/ 1 MR. LINEHAN: No, they haven't. We don't know 2 when they will begin. 3 MR. BUNTING: The last point I have here is we're 4 struggling again now to evaluate the adequacy of what DOE 5 has presented to show that they understand and have 6 established what they think would be required to support a 7 construction authorization request in terms of waste package 8 engineered barrier performance. At the time, the Commission 9 also has to make a decision on waste emplacement, and again 10 at closure, and show us how you plan to get that information 11 so that we can understand the way you're going about the 12 ESF, your design, your construction techniques, that these i 13 opportunities will not be foreclosed. () 14 And that concludes my presentation of the major 15 things we are looking at at the moment. 16 DR. MOELLER: Okay. Are there other questions or 17 comments for Mr. Bunting? 18 DR. MOODY: One of the comments I have is is there 19 any thought in NRC with respect to DOE's rejecting sealing? i 20 MR. BUNTING: Well, our position is that the rule 21 certainly does not assign to seals a unique performance 22 requirement as it does to the waste package. It simply says 23 that sealing in conjunction with the engineered barrier and 24 the geologic setting, you have to meet the standard. So 25 we're not in the position of saying that you must allocate m k_) Heritage Reporting Corporation (202) 628-4888 i l u__________ _ _ _
158 h 1 performance.to seals. But we are in the posit' ion, I think, 2 to say that good engineering practice says that you' rely on L 3 it until you find and can demonstrate that you don't need it l 4~ as opposed to saying, I'm going.to bet that I won't need it 5 and therefore I'm not going to go through good engineering 6 practice to have a quality product and also test that seals 7- during site characterization.
.8' DR. MOODY: The thing that you-have to -- or maybe 9 I'm just not'quite sure -- are they going.to not -- when you 10 talk about sealing, you have to look at it in-terms of its 11 total probability and that is not only the potential waste 12 package hole but the areas between all of the different i
13 rooms and getting up to the point of whether or not they're j {} 14 - going to seal the shafts and the core holes that they have 15' drilled. Are you only talking about sealing here with 16 respect to the waste package 17 MR. BUNTING: No,_ma'am. I am talking'about 18 sealing everywhere. There would be the major seals from the 19 surface would be basically plugs, settlement plugs. And 20 these settlement plugs would have a porous straw, if you 21 will, I call them, so if water ponds on the top it'll drain 22 through. The notion seems to be to not let the water find 23 its own path but to provide one for it. So the sealing 24 we're talking about would be if you encounter a natural 25 opening in a drift, then one of the techniques would be to () Heritage Reporting Corporation (202) 628-4888
159 (~}
%j l build dams on either side of the floor of the drift to keep 2 the water from moving laterally or have sumps in the floor 3 of the drift to account for surges and let it flow on 4 through.
5 The notion is, this is my personal notion, now, is 6 that you can't seal it. If you seal where the water's ; 7 running today, you don't know where it may run tomorrow. So 8 better you take the initiative to control the flow of water. 9 I find nrthing wrong with that. 10 But on the other hand, the significance of that is 11 you have not sealed and given any protection for the off 12 gases. That's the point I was trying to make. 13 DR. MOODY: I know but the thing that is not known j 14 at this particular time, and I understand conceptually
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15 exactly what you're saying, but say you have say perhaps an 16 abnormality in the predicted environment in the Yucca 17 Mountain Site. But one thing, say a major series of floods 18 and flows. But I do not think at this point in time that 19 there's that much known about the movement of the potential 20 water at the surface through the sound to the water table. 21 And so I mean I understand the concept of not sealing but at 22 the same time it has in it what I would consider some fatal 23 flaws. 24 MR. BUNTING: Well, I'm going to defer to my 25 cohort here on the hydrology situation you're outlining. l [%- Heritage Reporting Corporation (202) 628-4888 I '
160 1 I'm coming at it strictly from the engineering side about 2 the sealing. And also the effects of water on the waste 3 package. I can't comment on the hydrology. 4 DR. ORTH: I have a question. Has anybody. 5 conceived of any test that can settle the Carbon 14 issue, 6 or is it simply going to be a matter of calculation? 7 MR. BUNTING: The paper that I had indicated that 8 they had done tests on carbon 14 in acrid solutions, in air 9 and in nitrogen. And that the significant amounts of carbon 10 14 evolved from the cladding of the fuel and from the fuel 11 itself. And that just from the exterior surface of the 12 cladding was enough to exceed 1 part 10 to the 5th of that 13 particular. Now I don't know if that. answers your question, _, () 14 or not. I'm relating to you information I've read in the 15 report. 16 DR. ORTH: In other words, people can repeat the 17 tests? 18 .MR. BUNTING: Yes. 19 DR. ORTH: And that's about it. 20 MR. BUNTING: Yes. 21 DR. MOELLER: Now, is this remind me at what stage 22 did this occur or postulated to occur, the leaking of the C-23 14? 24 MR. BUNTING: They're talking about after , 25 containment and assuming that containment does go through () Heritage Reporting (202) 628-4888 Corporation i
161
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( 1 your major heat peak and you're now below the boiling point 2 of water. Envision then that if you had a leakage, if you 3 had a breach, canister failed, and you have an opportunity 4 for oxidation, the carbon 14 will be released. 5 DR. PARRY: Bob, would you kindly send me a copy 6 of that paper, and I'll circulate it. 7 DR. MOELLER: You know, why I was asking when this 8 was postulated to occur, I just wondered like at Savannah 9 River, if you monitor for C14 above your spent fuel pools, I. 10 mean, if you've ever seen it or anything? 11 DR. ORTH: It would be difficult to find, I 12 imagine. 13 DR. PARRY: I believe the C14 comes from the 14 nitrogen cover gas that's within the fuel rods. It's j 15 transmuted by activation and so Savannah River wouldn't see 16 it. They have bonded fuel. 17 MR. BUNTING: The paper indicates three sources, 18 Jack. One is the fuel cladding, the exterior cladding, the 19 interior of the cladding, the boundary of the cladding and 20 the metal. And then the gases trapped in through the 21 manufacturing process of being potential sources of 22 impurities. 23 DR. PARRY: That's dirt cladding or stainless 24 steel. 25 DR. ORTH: We're still going to need the paper in i (} Heritage Reporting (202) 628-4888 Corporation
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'/3 . s_j /1 order.to judge. That's why I'm not asking any more 2 questions.
3 MR. BUNTING: We'll send you the paper. 4 DR. MOELLER: Any other questions for Mr. Bunting? 5 I hear none. I think it's a good time to take a 6 break, and we'll do that. 7 (Whereupon, a brief recess was taken.) 8 DR. MOELLER: The meeting will resume. And we'll 9 pick up with what I gather is the last presentation for the 10 -afternoon on Geoscience and Performance Assessment Concerns 11 by Ronald Ballard.
'12 MR. BALLARD: Okay. I'm Ron Ballard. I'm Chief 13 of'the Geosciences and Systems Performance Branch. And the
() 14' general responsibilities assigned to that branch include the 15 geology, hydrology, which these are sections I have in the 16 group, geology, geophysics, and hydrology geochemistry group l 17 and a systems performance group which primarily is concerned 18 with performance assessment methodologies and that type of 19 thing. 20 The geosciences point papers that were issued last ', 21 year on the preliminary CDF, there were a total of about 83 22 comments, and the comments that have been resolved to date 23 based on the SCP have been about half, I would say. As Joe 24 Bunting mentioned earlier, we're kind of in the preliminary 25 stages of resolving these issues. And the total that we I) Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ - - - - - - - . _ - ._ _ __ - - - _----_-_--2
163 l j (_)s 1 went out with there was only one objection and that was a 2 major objection which was the alternative conceptual models 3 issue which I'm sure you've all heard a great deal about. 4 As a result of meetings with DOE back last year, 5 last Spring on alternative conceptual models, the new SCP 6 came out with a much larger and expanded section on this. 7 It's hard to tell at this stage whether the original concern 8 has been resolved but due to a great deal of added 9 information, it gave new fodder for the Staff, and there are 10 possibly a number of new concerns more of a technical 11 nature, based on the actual procedure. And I'll touch upon 12 a few of those briefly here. 13 DR. MOELLER: Excuse me once again. What was the () 14 origin of the new concerns? 15 MR. BALLARD: I was just mentioning that the 16 original objection resulted in a substantial expansion of 17 the SCP in terms of methodologies and the scope of the 18 program. And a multiplicity of tables which, on close 19 review by the Staff, reflects could very well drive a number 20 of more detailed questions. 21 DR. MOODY: Excuse me. Would you just quickly run 22 through what your major objection was in the CDSCP. 23 MR. BALLARD: Okay. At that time, there was 24 concern that DOE's approach to site characterization was 25 focusing primarily on base case assumption, a base case site
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164 r 1 which has essentially a static site and then out of this
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2 would result the site characterization program. And the 3 concern of the Staff was that there should be a 4 consideration of alternative conceptual models based on 5 knowiedge then known and make sure that the program is ! 6 scoped such as to not only establish what to use in a base 7 case but to make sure that the case selected is the correct 8 one. Make sure there's enough data to reconcile any 9 differences of opinion if possible alternative models. 10 The handout then that you have I list a number of 11 points that I'll cover. I've broken them into two categories 12 somewhat artificially. The first batch which I label as 13 " Concerns Immediate," only means that these are potential 14 problems that the Staff's identified that should perhaps be
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15 considered early on before site characterization in order to 16 make sure that there's no basic problem with the data 17 program. 18 The follow-up, number three on my list, are the 19 more long-term problems which I'll attempt to update you on 20 but you are familiar with most of those, and perhaps even 21 the immediate ones. 22 The first one that I list here, adequacy of ESF 23 design control process, relates to the siting of the ESF. 24 And, when reviewing the documentation, the design 25 acceptability analysis report which was part of the SCP we () Heritage Reporting Corporation (202) 628-4888
l l 165 find that there were design criteria included there for (~ ) . 1 2 which there's no good paper trail that they were 3 implemented. And I refer to a specific case of a number of 4 early reports in the early 80's presented by the USGS that 5 identified based on surface geophysical techniques that 6 identified possible faulting and fracturing in the vicinity 7 of the existing select'ed site. 8 These reports I believe are referenced in the SCP 9 but in the process, the criteria that DOE applied requires 10 reevaluations of sites in the event of potential 11 disturbances, do a detailed study. Well, as best the 12 preliminary results are, these points were-not reflected in 13 the SCP directly, nor were they reflected in the criteria {} 14 15-document that dro'e v their site selection process. In simple words, in moving from Coyote Wash to.the 16 new site out on the' nose of the ridge nearby, there.is a l 17 possibility that there is substantial disturbance faulting 18 in that immediate area which could make it questionable in 19 terms of their own criteria. They have an offset criteria 20 of 100 feet from nearby faults. And maybe they are. I have 21 no idea at this stage. But the facts are that there is 22 evidence of potential faulting right in that immediate 23 vicinity and we don't see at this stage a resolution of the 24 problem. 25 DR. HINZE: Ron, I obviously am concerned about () Heritage Reporting (202) 628-4888 Corporation 4
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L 166 () I the siting of the exploration shaft, and I'm very pleased to 2 hear that the staff is as well. What concerns me is that 3 there are two types of variability that we should be 4 interested in. One is the vertical variability and one is 5 the horizontal variability, if you will. 6 And essentially the drifts are getting at the 7 variability on a horizontal scale and we're going to have 8 5,000 meters? 5,000 feet of those. Yet, there's only 9' going to be one exploratory shaft and that's going down then 10 in a very critical area. It must be a very critical area 11 because there obviously are going to be tests and studies 12 made in that shaft that cannot be done as well-in cores or 13 drill holes of a small diameter. (]) 14 And the site may be very good. I can't say that 15 it's a bad site. But I do have a perception in hearing the 16 comments in previous meetings, as well as now, that what we 17 are looking at is something that has not been in my 18 experience in terms of setting up exploration programs, 19 adequately defined by geophysical techniques in particular 20 and perhaps by some surface or shallow drilling techniques. 21 I can't stress, and I feel that there's also once 22 these measurements are made that they're going to have a 23 very significant influence upon everyone's thinking about 24 Yucca Mountain. So the site is particularly important. And 25 I'm wondering if the Staff has considered what a delay would () Heritage Reporting Corporation (202) 628-4888
J 167 () 1 mean to the program if one waited until we had an increased 2 amount of geological geophysical studies to ascertain that I 3 this is the best site. What would that delay mean to the 4 entire program? i 5 We've heard here this morning that the program is j j i 6 slipping and that we're all interested in seeing that it be i 7 on schedule, but obviously there are overriding concerns to 8 that. Where is your staff going with this? 9 MR. BALLARD: Well, I don't think the Staff has 10 taken any position on slippage as such. 11 And the impact of delays on the investigation from 12 a technical point of view, they tend to raise the concern , 13 that such activities are warranted. And to my knowledge, () 14 DOE may have a lot of information already on that site that 15 we aren't aware of. 16 I also believe I have heard that they're going to 17 have a preliminary bore hole at the ESF location. I'm not 18 certain of that but I think I've heard that. And that would 19 certainly provide a lot of information on potential faulting 20 or fracturing. 21 DR. HINZE: But not necessarily. 22 MR. BALLARD: Not necessarily but at least at the 23 ESF location. And it's true that many of the faults are 24 pretty near vertical and drilling gives you some problems. 25 That's why they I believe have a rather major drifting (^s l (J Heritage Reporting Corporation (202) 628-4888 a_______ -
168 1 program established.
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2 But, no, I don't know, certainly haven't heard 3 officially that there's a slip. I have heard that that may 4 happen. It would give a very good opportwilty to get some 5 further surface exploration. And I know that they were 6 doing more surface exploration at the site. I don't know 7 about specifically at the ESF location. 8 DR. MOODY: Well, I would second Bill in this 9 particular comment, knowing that the sophistication we have 10 with geophysical methodology today that what do you think, 11 Bill? With a year or tow? 12 DR. HINZE: Well, if we're talking about the early 13 80s with the USGS doing the work, I think that we could do 14 tenfold better with present technology. At least a major {} 15 step. 16 MR. BALLARD: Let me refer to Charlotte Abrams 17 here. She's the team lead for the geology program and she 18 may have more information. 19 DR. MOODY: Up to date information, anything 20 that's been done say since '85, '86. In other words, '87, 21 '88, was any ongoing work that maybe hasn't been reported 22 being done? 23 MS. ADAMS: Yes. GS has conducted some 24 preliminary prototype testing down in the Amagroso (ph.) 25 desert which is to the south with respect to geophysical Heritage Peporting Corporation k-(202) 628-4888
169 1 tests. But they. haven't applied these' methods to the
/(~ f l; 2. mountain itself. And as you may realize, it's a different
'3- type area. So they have conducted those tests in the last 4 year and a half.
l 5 DR. HINZE Has there been any modeling, any L 6 seismic modeling, any seismic reflection modeling,.any 7 seismic refraction modeling, any gravity modeling,'any l 8 various electrical methods modeling, based upon the l 9 specification of the physical properties to look at the-10 fault types of structures and other changes? We're not just 11 tulking about faults. We're really talking about the 12 frequency of occurrence of fractures. And I think we're all 13 in the modeling very concerned about the fracturing aspect-14 of it. So modeling would give a handle on the success but () 15 there's nothing like getting in there and doing it, is 16 there? 17 MS. ADAMS: No. And to our knowledge, there 18 hasn't been any recent site-specific directed studies. They 19 have done some field studies of fracturing where they've 20 studied pavement outcrops,....#ured fractures, measured 21 densities of fractures, and so forth. But that in itself 22 may not tell you what is in the subsurface. 23 DR. MOODY: That's where the geophysics is so 24 important. 25 MR. BALLARD: By the way, to fill in on the Heritage Reporting Corporation (202) 628-4888
170 () 1 earlier discussion on the relocation of that exploratory 2 shaft site, I believe it was originally in Coyote Wash. It 3 was moved almost at no elevation change a few meters at most 4 just around to the nose of the hillside, such that if you 5 would take a cross section normal to the flow of water down , 6 the gully, you would find that it is at substantially higher , 7 elevation in terms of flow than it was. Well above even the 8 PMF which is, if you are familiar with probable maximum 9 flow, that's an extremely conservative assumptions that go 10 into determining a worst case flood. And they are I believe 11 now at a location substantially above that. So from a 12 flooding point of view, they did resolve I think that 13 problem. () 14 DR. HINZE: I guess I'm more concerned about the 15 very subtle insidious type of effect of sampling in the 16 wrong place and thinking we have a representative sample, 17 than the catastrophic effect that we might have with 18 flooding. I think that it's very easy to recognize the 19 potential for the catastrophic type of event. It's this 20 very subtle variations that may have a profound effect. 21 MR. BALLARD: Well, we certainly share that 22 concern. That's why that's elevated even at this stage is 23 something that we do hope that DOE can treat very early, 24 That's why it's in my first category there. 25 The next item I had on the list relates to site () Heritage Reporting Corporation (202) 628-4888
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() 1 ' investigations to evaluate total systems performance. And 2 this is,-I think everybody realizes that based on the 3 licensing period we have here that the DOE will have to rely 4 very heavily on this performance assessment process to come 5 up with an evaluation of the adequacy.of the site. 6 The Staff has felt for a long time I believe that 7 performance assessment methodology the process will be an 8 iterative process in that it should be kind of identified 9 early on and as the site characterization proceeds, that 10 it's an iterative process to determine the adequacy of the 11 site. And I think DOE agrees with that completely in 12 principle. 13 I bring this problem on our list because it's
.(]) 14 difficult to determine in the SCP whether this kind of a 15 process will take picce in terms of iterative performance 16 assesament. We would have loved to have seen a performance 17 assessment, even a preliminary one, in the SCP. Well, that 18 didn't happen and there was no requirement for it. But we 19 would hope early on, since this is a primary tool for 20 directing their field studies, that we will be able to get 21 that moving. That is a concern at this stage.
22 Further, there are a number of technical problems 23 I mentioned early on that have evolved based on DOE's very 24 thorough expansion, a very broad expansion of their program. { 25 I would kind of touch on these. () lieritage Reporting (202) 628-4888 Corporation
172 () 1 There's one problem on the methodology whereby the 2 approach would be to combine alternative conceptual model 3 probabilities, a weighting of alternative conceptual models 4 with the scenario probabilities in constructing a CCDF. 5 This is probably a unique approach to CCDFs based on our 6 experience in the reactor program. You generally establish 7 scenarios and treat those in terms of the CCDF. 8 The concern that the Staff has at this stage is 9 that by so doing, the CCDF may have to rely heavily on 10 expert judgment because conceptual models will in themselves 11 be pretty much a debatable issue where expert opinions will 12 form bases for establishing likelihoods of occurrence. We'd 13 like the CCDP to rely more on site specific data. () 14 And if this approach is followed completely for 15 the CCDF, we're concerned that it could affect the site 16 characterization program in that they would rely more and 17 more on expert judgment to satisfy the construct of the 18 curve. 19 That's one concern at this stage. Another 20 technical concern relates to the methodologies for treating 21 scenario classes. There is heavy reliance on a base case 22 scenario that assumes essentially no change in the site. In 23 other words, it's a static site and of course even for a 24 base case, it's pretty well known that for a 10,000 year 25 licensing period, it's a pretty active site. There is some I () lleritage Reporting Corporation (202) 628-4888
173 n ( ), 1 seismicity at some level. And the concern is again a 2 pattern of wanting to be assured that the site 3 characterization will be broad enough in scope to satisfy 4 the alternative conception models. 5 Another point relates to the conceptual model 6 tables. This was one of the positive parts of the SCP. DOE 7 came in with a number of tables, a great many. And they are 8 promising and certainly reflected our concerns at the 9 meeting last year. However, in so doing, and it could be a 10 timing problem, and maybe we don't understand it all 11 completely yet, but there is the problem of basic 12 inconsistencies in the tables. They may be small problems 13 and may be resolved in some appropriate forum. But we want () 14 to be sure that not only do the field studies get the data 15 but that their plan will be able to accommodate all these 16 field studies and meet the purpose of the conceptual 17 performance assessment model. 18 The last point I would mention under this category 19- is human intrusion scenarios. And in this particular case, 20 there seems to be an inconsistency. DOE submitted as part 21 of their SCP a so-called CDSCP resolution package in which 22 they treated all of NRC's concerns, which was very helpful, 23 and tried to shows us where in the document they treated our 24 concerns from the CDSCP. 25 Well, a point that came out I thought loud and fn q,) Heritage Reporting Corporation (202) 628-4888 i
o 174 1 clear in that document'is that human intrusion will not be { 2 considered in their CCDF formulations per se. The SCP 3 itself implies that they would be considered. And we 4 believe that certainly the human intrusion scenarios are 5 going to be a very major factor in the process. And we 6 believe that this needs clarification very early on. Again, 7 this may be easily clarified in correspondence. But at this 8 stage, that's a concern. 9 We would hope that a session could be established 10 in the near future, at least the Staff does, on performance 11 assessment just to try and make sure that we understand 12 where they're coming from in the whole pack. 13 The last point in that section is integration and 14 sequencing of studies. This is a general problem of lack of 15 clarity in the document that the sequencing of the program 16 will achieve the goals intended. There are evidences for 17 example of schedules which would result in determining 18 structural responses of surface facilities to ground motion 19 at a schedule that precedes the results of the field studies 20 that are going to kind of establish what the seismic hazard s 21 is in the area.
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22 That's kind of typical of three or four areas. I 23 believe Joe Bunting mentioned a similar problem of 24 sequencing and those will come out in the detailed SCP 25 comments. (] Ileritage Reporting Corporation V (202) 628-4888
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() 1 Again, that's about all I have to say,about'the 2 immediate concerns other than we have a fairly' substantive 3 list which we hope and expect many will be reconciled when 4 we get into a little more discussion. l 5 DR. CARTER: Could I just mention, I think Mr. 6 Hinze's comment about the knowledge of what's underground 7 before major drilling operations are conducted is an area 8 that's of great interest to me and falls in the category of 9 the concern he just addressed, specifically, are the non-10 destructive tests of what's down there tied in in such a way 11 that when you physically get down there and check can you 12 calibrate and determine the validity of the non-destructive 13 tests -- I should say geophysical tests -- because a lot is () 14 riding on the ability of the geophysical tests to integrate 15 or extrapolate between the hopefully very limited actual 16 penetrations in the site.
-17 So I think one of my concerns is has this concern 18 about the quality assurance aspect so put a hold on 19 everything that some things that might make some sense to be i
20 off doing on kind of an accelerated basis, everything is 21 getting held up simultaneously and maybe we ought to be 22 concentrating all our efforts on trying to free up certain 23 key things that are extremely important and that could be 24 done, say, from the surface without agonizing over whether 25 the hole's in the right place or not, we could just start () Heritage Reporting Corporation (202) 628-4888
1 176 (^T 1 checking to see what the hell's under there. L) 2 So I think your comment is well placed and I would 3 suggest that that might be an area where you folks might 4 want to probe and aee what you think, and then see if it 5 matches up with what's going to come out of our process. 6 MR. BALLARD: Okay. I'll proceed with the longer 7 term problems, many of which are not new. But the first one 8 I have identified, numerical performance measures. These 9 relate in a lot of ways to the potentially adverse i 10 conditions requirements in Part 60.122. 11 And in reviewing part 122, I noted in preparation 12 for this session even that the guidance there is that these 13 issues be resolved and be studied in such a way that we'll 14 avoid any underestimating of the effects. Taking that 15 seriously, the Staff in their reviews to date have indicated 16 a number of areas which I sort of list there, not as major 17 problem areas, but in the document the methodology that DOE 18 intends to follow leans heavily on averaging. And using 19 historical data averaging regional data of historical level 20 to come up with a model that they will impose on the site. 21 That may or may not be all right. But the concern 22 is that this approach may not meet the conservative 23 principles that the Agency, at least the NRC has generally 24 followed. So mentioning there are non-conservative 25 assumptions based on the cumulative slip earthquakes, for l
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B 177 (- 1 example,.that will be used to estimate the maximum 2 earthquake, average the results. We're concerned that'that 3 may not be a reflection of.the actual event. 4 Slip rates.- Slip rate approaches that are used 5 again, if you want to get into more discussion of these,-I 6 can refer to Charlotte here to go into them a.little more, ' 7 but the pattern is that the approaches using average results 8 and the staff will have a number of concerns with that at b 9 this stage. 10 I don't intend to go into any detail on these i 11 unless you all would wish to and we can then maybe in a.
'12 combined way pron-ide you with a feeling of the --
13 DR. HINZE: Well, Ron, I'd just like to very much () 14 support the idea of the current look is a. snapshot look.for I 15 example in seismicity, if you took the period of time around ; 16 January to February of 1811, 1812, we would have thought 17 that there was going to be a seven plus earthquake every 18 month in the new Madrid region. I think that's one of the 19 things coming out of the geosciences today that's so l 1 20 interesting and that is that one has to be extremely careful 21 about the averaging process. And I'm very pleased that your 22 Staff is looking into that. 1 i 23 That's great. l 24 MR. BALLARD: Okay. The next item that I have 25 indicated is representativeness of site characterization
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178 ('T \_) 1 activities. And this is a general problem which is 2 ' reflected by Mr. Bunting also. And our point here is that - 3 - I can't read my writing here. 4 MS ADAMS: Ron? Can I answer here? 5 MR. BALLARD: Sure. Fill in. 6 MS. ADAMS: The representativeness question 7 actually goes back to we'sent a letter originally to the DOE 8 in August, 1987, I believe it was about this problem. We 9 had a CDSCP comment on representativeness. And we do have a 10 preliminary SCP comment on this. And this leads be.ck into 11 what you were asking, Mr. Hinze. It's a question of is the 12 small area that they're going to characterize in the 13 northeast portion of the repository block coupled with their {} 14 15 surface testing program, is that going to provide data that is representative of the entire repository block. 16 And that's the bottom line. And the geologic 17 conditions we see at the site, it appears from the surface 18 work so far that the geologic conditions are enhanced, the 19 detrimental conditions are enhanced in the southern part of 20 the repository area. 21 DR. HINZE: And this is based upon the older data 22 and older data interpretation techniques, so -- 23 MS. ADAMS: This is based on field mapping and 24 studies by USGS personnel predominantly in field work. 25 DR. MOODY: We need to have a true evaluation of ! Heritage Reporting Corporation (~}
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1 'that site, I mean, it's just something that'in all the-
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2 programs you go round and'round about. It's not only the 3 specific location of the repository itself but how that 4 -particular location then fits in the-total regionality of 1
-5 the geology of that particular site. And you need both in 6 order to have a true assessment of that site.
7 MR. BALLARD: I'd mention too that even last year,. 8 the Staff in a separate correspondence with DOE raised-the-9 problem of being sure that the drifting program in site 10 characterization be' expanded. I believe that was mentioned 11 by Mr. Bunting and in all there would be a desire on our l 12 part to see a broader drifting program to. intersect major l 13 problem areas, faults that have been predicted and such. 14 So it's not a new problem; it's certainly not new 15: to DOE and I assume they'll take that seriously. 16 DR. PARRY: Ron, just to provide some ancient 17 history. Back in '77, NRC Waste Management Branch the 18' position was that there would be full perimeter drifting. 19 MR. BALLARD: I wasn't aware of that. t 20 Let me close here with -- well, not close -- the 21 natural resources investigations would have been a good one i 22 to close with because that is a major problem area that was 23 are concerned about and I don't really know how it will be 24 handled effectively. But as you all know, Southern Nevada 25 is loaded with mineral resources. Heritage Reporting Corporation O. (202) 628-4888 i , i 1
180 r% fq ,)1 1 The primary concern at this stage is that the SCP 2 indicates that most of DOE's program for natural resource 3' investigation.would be limited to the tuffs. And that may 4 be a problem also, but there are evidences of mineralization 5 in the Paleyezoics (ph.), nearby evidences, near Lathrop 6 Wells, 1 understand, and there's also a number of evidences 7 in the region of exothermal precious metal deposits which 8- are driven by magmatic forces precipitating of gold and the 9 gold precious metals in the tuff zones. 10 I am informed that a lot of the miners in the 11 region just wait for-the chance to get onto the test site. 12- Sol-they think there's potential there. It's a problem I 13 don't know how we'll handle at this stage but it's one that () 14 we feel ought to be investigated thoroughly. 15 DR. HINZE: I guess we just don't want to limit 16 our thinking either to the mineral resources, the petroleum 17 resources as is evidenced in a recent letter'to the editor 18 of Geotimes brings up some very interesting questions 19 concerning the petroleum potential of the region. 20 MR. BALLARD: Yes, petroleum and of course the 21 water resource in that area itself .'s a natural resource of 22 some value. It's an area that needs detailed investigation. 23 And we will be prepared to comment on that. ; i 24 (Continued on following page.) 25 I () Heritage Reporting Corporation (202) 628-4888 l l~
1 181 , () 1 MR. BALLARD: It was used for evaluating the 2 thermo fax on the ground water on site from body heat ( i 3 sources and waste products and what kinds of effects they 4 would have on ground movement in the geochemical process. 5 One last point as to Calico Hills, the site that 6 will be relied on heavily for isolation from the ground 7 water, that is the major formation that goes from the plant / i 8 down to the ground water and we're in sort of a Catch-22 9 situation here. , I 10 We certainly hate to tell DOE to punch it up and 11 kind of disturb it, but on the other hand, we feel there 12 ought to be a history of an adequate program 13 characterization to define the area and to assure it will 14 accomplish its which pri. nary objective. f( ) 15 I didn't include in here discussions on the paper 16 face transfer whien Mr. Browning brought up. On the one 17 hand I think it could good move toward isolating waste, but 18 on the other hand they have to really investigate this 19 possibility. 20 That is about all I have to say. 21 DR. MOELLER: Any further comments of questions? . 1 l 22 MR. LINEHAN: That pretty much finishes our 23 presentations and as I indicated at the beginning, our 1 24 purpose of meeting with you today was to give you some early 25 indication of where we saw some of the concerns and when we () 11eritage Reporting Corporation (202) 628-4888
182-() 1- meet with you'in the May time frame, I believe it's the 2- second week of May, we will Ima able to lay out specifically. 3 what are the points that we are going to pursue in the SCA' . 4 IN1. MOELLER: Okay. I_think before we close out, 5 we need to discuss what it is you will be coming to us next 6 week to' cover and I understand before the full committee, we 7 will hear a discussion of what is the Branch's technical 8 position on the saft seals and that will tie into what we 9 heard today from Joe and then Bob, we are scheduled to have-10 roughly, you know, some form of a presentation'on this next 11 week. Our other two committee members will be there and 12 many of-thes0' consultants will be there. 13 I think,-personally, what you did this afternoon ()_14 was fine. At this stage it seems quite helpful. 15 MR. LINEHAN: I would like to clarify that. 164 DR. MOELLER: All right. 17 MR. LINEHAN: Our understanding was we would give 18 the presentations on waste confidence and on the status of 19 the SCP to this group today and that when the full committee 20 met, it would be ACNM--someone on the ACNW that is here 21 today that would brief them-- 22 DR. MOELLER: Right. 23 MR. LINEHAN: --and we would just be there to 24 answer questjons. Is that true or were you looking for L 25 another presentation? () Heritage Reporting Corporation (202) 628-4888 l
183 ( )- 1- DR. MOELLER: Well, I'll have to ask Jack. We 2 certainly will summarize for them, you know, what we have 3 heard today and the whole idea, you know, we're not going to 4 . gain much if we ask you to come'down and repeat everything 5 you did this afternoon and we really don't want to do that, 6 but I would think an hour or so, is the least we would need. 7 Jack, what are your thoughts? i 8 DR. PARRY: Well the original hope was that there ; 9 might be more detal]ed presentations available, both today 10 and even further next week. 11 You understand your limitations based on how far 12 alcng you are, but that was our original expectation. It 13 certainly is not of much advantage for you to make the same () 14 presentation over again when it will be minuted for the two 15 members that are not here. 16 DR. MOELLER: Yes. 17 DR. PARRY: And I think, perhaps, the Chairman and ! 18 the consultants will want to talk it over and then I'll be 19 in touch with you. 20 DR. MOELLER: But let's say, at this point that-- 21 again to repea'. what I just said. I do not see us gaining 22 if we ask you to come back and repeat the same thing when 23 most of us will have heard it. 1 24 So allow me aa half hour - 45 minutes and ever 25 some of the consultants to brief each other, to present a O neriteee Regertine (202) 628-4888 cereoretion _ _ _ _ _ _ _ _ _ _ _ _ - -_ l
184 () 1 summary of what happened today and then.be there to answer 2 questions and'o d plan on a half hour to an hour 3 ' presentation. Maybe you don't need to--in fact, you' don't-4 need to~ bring the whole team down. Let's.have an overview 5 next week. 6 DR. MOODY: One of the things, looking at what we 7 went through today, is I just say that I certainly would-8 like would like a bit more detail on both the engineering 9 concerns and the engineering concerns and the geoscience 10 concerns. Those were touched on today, but if there is 11 anything you felt confident about or felt okay about putting 12 in a bit more detail, those are the two items that I-- 13 MR. LINEHAN: I don't think, at this point, we're ( )' 14 in a position where we can go into any more detail. We 15 would be happy, you know, to answer any questions you have. 16 DR. MOODY: Okay. 17 DR.-MOELLER: I think we have to understand the 18 process which is to receive your preliminary written report 19 early next month and then in early June, we'll get whatever 20 you call it, where it has under gone more of a program 21 review within the staff and we know you're working under 22 restraints and we have to live with that. 23 I want to thank you for coming today and sharing 24 your thoughts at this stage. We'll be in touch, but I think 25 it will be roughly as I outlined. () Heritage Reporting (202) 628-4888 Corporation
185 () l' MR. BROWNING: One thing that would be 2 particularly useful to us, if based on the kinds of things 3 that you folks heard, plus your own independent look at the 4 document and concerns from your knowledge, if there are any i 5 other' areas that we didn't touch on in this thing, that 6 based on your reviews, as a general area, something you 7 think it would be worthwhile making sure we did have our ]
- 8. staff focus on this part of the review. The earlier we get 9 that feedback the better, because then we can try and factor f 10 that into the products that you'll be reviewing when we 11 actually provide the words. That would be extremely helpful 12 to us or if there is any areas that we touched on.that you
.13 think, based on your knowledge, don't appear to be that
() 14- important and you could give us some insight there, that 15 would be helpful. 16 Not in the form of a letter to the Commission or 17 anything, but just in terms of iteration back and forth so 18 hopefully when our product comes'out, you will agree that it 19 has been focused on what appears to be pretty significant 20 issues and, you know, we're honing in the things that are of 21 major concern in investigating the site at this particular 22 stage. That would be very helpful to us. 23 DR. MOELLER: Okay. Jack. 24 DR. PARRY: One thing I mention, Bob. The work on 25 the waste package study, concerns about the waste package () Heritage Reporting (202) 628-4888 Corporation
186 pm () 1 program, would be of particular interest to Dr. Steindler. 2 You might be able to expand on that. I MR. BROWNING: 3 If you can give us some insight in 4 the areas that you think it would be worthwhile, to maybe 5 come down and talk about it, focus, you know, what we told 6 here on things that would be of interest to the whole group, 7 that might be something we could work out. 8 DR. PARRY: Certainly waste package would be one. 9 After we talk, I'll be in touch wita you. 10 DR. VOILAND: Is there additional developments or 11 understandings or misunderstandings about vapor face 12 transport that are not covered in the SEP. I haven't looked l 13 at that aspect of the SEP. I~) 14 MR. BALLARD: I'm sorry, would you repeat the V 15 question? ! 16 DR. VOILAND: Yes. Has there been recent 17 developments in the understanding the vapor face transport 18 problem that was discussed today that are not covered in the 19 SEP as it is written at the present time? 20 You see, I'm not very familiar with that, i 21 Mh. BALLARD: I think there are. I was attending 22 a research session last December in Tucson where DOE did 23 have some discussions on that that are not reflected in the 24 SEP, but the SEP really--those kinds of issues will probably l 25 come out in their detailed study plans which we do not yet l () Heritage Reporting Corporation (202) 628-4888
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187 () 1 have. 2 I think it's a little skimpy at this stage. 3 DR. MOELLER: Gene is asking_if perhaps even next'
.4 week, would.there be any chance of hearing a little more on 5 that?
6 DR. VOILAND: Or would there be any merit in at 7 this point in time hearing more about it? 8 MR. BALLARD: I think we couldn't get anything 9 substantive in a week, no. But I think that it certain will 10 be an issue that will be reflected as the documents come out-11 next month. 12 DR.'MOELLER: Very good. 13 DR. VOILAND: Thank you. () 14 DR. MOELLER: Any other questions or comments? l 15 Seeing none, let me once again thank the staff for l 16 coming down. I also want to thank our reporter for his 17 efforts today. 18 And with that, I think we will bring todays 19 meeting, working group meeting to a close. 20 The working group will go into Executive Session 21 for 10 or 15 minutes just simply to talk a little bit about 22 what we have heard this afternoon and whether there are any 23 significant thoughts that we have on the basis of that. 24 This will be open to the public and anyone who 25 desires to remain is certainly free to do so. t () IIeritage Reporting (202) 628-4888 Corporation l
i i 188 l With that then, I declare the meeting adjourned. 2 (Whereupon, at 3:45 p.m. the ACNW meeting was 3 concluded.) 4 5 6 1 7 8 9 10 11 12 13 O 14 15 16 17 18 19 20 21 22 23 i 24
]
25 , i IIeritage Reporting Corporation (202) 628-4888 ) _-_ ._. _ b
.O)li s 1 CERTIFICATE 2 3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the mattar 5 of: 6 , Name: ACNW Working Group 7 8 Docket Number: 9 PJ, ace: Bethesda, Maryland 10 Date: April 19, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, () 14 thereafter reduced to typewriting by me or under the 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing 17 proceedings. 18 /s '~' k Aw hMn52A IRWIN L. FFENB'ERRY 19 (Signature typed) : 20 Official Reporter 21 Heritage Reporting Corporation 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
r 3 O Site Characterization Concerns Preliminary Sunnary - Geosciences & Syst' ems performance
- 1. Status of CDSCP Comments (Preliminary)
'2. Concerns - Immediate
'
- Adequacy of ESF design contro'1 process Site Investigations to evaluate total system performance
- Integration and sequencing of geol / geophysical programs
- 3. Concerns - Long Term-
*' Numerical Performance tieasures - Geological 10Kyr. cumulative slip earthquake Slip rates.for strike-slip faults Erosion rates Volcanism-
- Representativeness of Site Characterization Activities
- Natural Resources Investigations
- Thermal Effects on Groundwater Floor
- Hydrologic Characterization of Calico Hills Formation
.O
l l /~l J l I BRIEFING NOTES l
- 1. STATUS OF CDSCP ENGINEERING ISSUES A. LOCATION OF SHAFTS !
B. PENETRATION OF CALICO HILLS j C. POTENTIAL FOR INTERFERENCE IN TESTING D. ADEQUACY OF DRIFTING TO BE REPRESENTATIVE OF REPOSITORY BLOCK E. 50% OF OTHER GEO-ENGINEERING TECHNICAL ISSUES RESOLVED 1 ( F. 80% OF WASTE PACKAGE / ENGINEERED BARRIER TECHNICAL ISSUES I RESOLVED
- 2. NEW AREAS OF POTENTIAL ENGINEERING CONCERN INCLUDE:
(WE HAVE NOT YET FINALIZED OUR POSITION) A. APPROACH TO SEALING AND IMPLICATION TO WASTE PACKAGE <s PERFORMANCE -- (DETAILED BRIEFING TO ACNW ON STAFF TECHNICAL \_) POSITION ON SEALING SCHEDULED FOR APRIL 26TH WILL PRESENT DETAILED DOE SEALING CONCEPTS) B. DEFINITION OF WASTE PACKAGE FAILURE AND IMPLICATIONS TO DEMONSTRATING COMPLIANCE WITH REGULATORY REQUIREMENT FOR CONTAINMENT C. INTERPRETATION OF THE REGULATORY REQUIREMENT FOR SUBSTANTIALLY COMPLETE CONTAINMENT -- CONFIDENCE D. CARBON 14 E. POTENTIAL TO LOSE OPPORTUNITY FOR 10+ YEARS OF IN SITU FULL SCALE TEST -- WASTE PACKAGE AND SEALS -- IMPLICATIONS TO CONFIDENCE (LIMITS ON UNCERTAINTY) AVAILABLE THRU PERFORMANCE CONFIRMATION TESTING AT NRC DECISION POINT FOR PERMANENT CLOSURE. F. ADEQUACY OF PLANS TO QUANTITATIVELY ESTABLISH DATA NEEDED TO SUPPORT WASTE PACKAGE PERFORMANCE AT: (1) CONSTRUCTION AUTHORIZATION ; (2) WASTE EMPLACEMENT (3) CLOSURE () AND ADEQUACY OF PLANS TO OBTAIN THAT DATA (RELATED TO ITEM 2E ABOVE) SUCH THAT DOE CAN ADEQUATELY DEMONSTRATE THAT THEY CAN AFFORD TO LOSE THE OPPORTUNITY FOR 10 YEARS OF PERFORMANCE CONFIRMATION TESTING.
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- O NRC STAFF PRESENTATION TO THE ACNW i
SUBJECT:
REVIEW OF WASTE CONFIDENCE PROCEEDING FINDINGS , DATE: APRIL 19,1989 l 'O PRESENTER: ROBERT M. BERNERO PRESENTER'S TITLE / BRANCH DIV.: DIRECTOR OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS PRESENTER'S NRC TEL. NO.: (301) 492-3326 O
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