ML20246B394
| ML20246B394 | |
| Person / Time | |
|---|---|
| Issue date: | 06/28/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0013, NACNUCLE-T-13, NUDOCS 8907070320 | |
| Download: ML20246B394 (319) | |
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O UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE l
In.the Matter of: )
)
)
12th ACNW Meeting )
Day One )
LO Pages: 1 through 228 Place: Bethesda, Maryland June 28, 1989 Date:
OMTf0FFHE~0~dPFMsTAIN Fdn THE LIFE OF THE C0MMITTEE .,
HERITAGE REPORTING CORPORATION O onk*IRewten 1220 L Street, N.W., Suke 600 Washingtm, D.C. 20005 8907070320 e90628 (202) 6M PDR ADVCM NACNUCLE PNV T-0013
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PUBLIC MOTICE BY THE
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.L.s UNITED STATES NUCLEAR REGULATORY col @iISSION'S ADVISORY COMMITTEE ON NUCLEAR WASTE June 28, 1989 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's. Advisory Committee on Nuclear Waste (ACNW), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACNW staff and no participant at this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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' UNITED, STATES NUCLEAR REGULATORY COMMISSION.
ADVISORY-COMMITTEE ON NUCLEAR WASTE p.
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-In'the Matter of:- )
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)
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12th-ACNW Meeting -
)
Day one )
L i Wednesday,
- June 28,-.1988 at Room P-110-EP ,
7920' Norfolk Avenue g Bethesda, Maryland
- g. The: meeting; convened, pursuant to notice, at 8:30 a.m.
L
, ' BEFORE:- DADE W.'MOELLER Chairman,'ACNW
[ .' .
Professor of Engineering.
- i. .
t in Environmental Health 1, Associate Dean'for Continuing Education School of Public Health h Harvard University
-Boston, Massachusetts e
ACNW - tgSMBERS - PRESENT :
p.
L- . WILLIAM J. HINZE MARTIN J. STEINDLER Director, Chemical Technology Division Argonne_ National Laboratory
'Argonne,' Illinois ACNW CONSULTANTS PRESENT: .
DAVID OKRENT DONALD ORTH P. W. POMEROY EUGENE VOILAND JUDITH B. MOODY PAUL SHEWMON (ACRS)
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4 DESIGNATED FEDERAL OFFICIAL:
SIDNEY J.'S, PARRY TECHNICAL SECRETARY:
H. STANLEY SCHOFFER l-
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l' E. B'-Q R E E R 1 E G a 2 MR. MOELLER: The' meeting will now come to order.
3 This is the 12th meeting of the Advisory Committee on ,
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l 4 Nuclear Waste.
5 I am;Dade Moeller, Chairman of the committee.
6 The other ACNW member present is Bill Hinze. We anticipate 7 that Dr. Steindler will join us later today, and Dr.
8 Clifford Smith will join us tomorrow morning and Friday.
9 We have a group of consultants here to assist us, 10 consisting of Donald Orth and Gene Voiland, and we also have 11 Dr. Paul Shewmon from the ACRS, who will be assisting us 12' today.. We anticipate that David Okrent and Judith Moody 12L 'will be. joining us later this morning. And I missed, I
(} 14 guess, Paul Pomeroy, who is with us as a consultant this 15 morning and for the remainder of the meeting.
16 During today's meeting the committee will 17 complete the review of the NRC staff's site characterization 18 analynis. And prior to the conclusion of the meeting we 19 will want to have prepared and approved a letter with o'ur 20 comments which we will forward to the Chairman of the 21 Commission. l 22 In the way of background for this meeting, we 23 have received a number of additional items, or I will 24 mention a couple of older items, which are very pertinent to 25 the discussions that we have.
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, -l' Of course one of the most important items is.the; L 2 draftLof Section 2 of the SCA which' consists of the l
3 Director's summary comments of the findings and observations 4 and so forth of the NRC staff.
51 -Another item that I found particularly helpful-b '6~ was;what many are calling the Ross Report. That is, quote:
1 .. .
7 "A first survey of disruption scenarios for a high-level.
l EL waste repository at. Yucca Mountain, Nevada." And in this, l 9 the author examines each of.the possible pathways and 10 . combinations of pathways and groups them in what to me was a 11 very helpful manner.
12- Then we also have the comments of the State of:
13 Nevada. And those are from, of course, their agency for 14 ~ nuclear projects, the Nuclear Waste Project Office. And the
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15 copy'I am referring to is dated May 30 of 1989.
16 And then I found particularly significant as a 17 . third group of comments, or fourth group I guess it is, the 18 comments from the Edison Electric Institute and the Utility 19 Nuclear Waste and Transportation Program. Those were dated' 20 June 1, 1989.
21 MR. SHEWMON: Are they all in the notebook?
22 MR. MOELLER: No. Yes. I'll take it back. EEIs 23 are in the notebook.
24 And those, to repeat, I found were particularly 25 significant and helpful.
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(,) 1 We also have been provided, at least it was new 2 to me, since we last met, the two reports from the Center 3 for Nuclear Waste Regulatory Analyses, and that was their
'4 quote " Analysis of Regulatory Uncertainties Related to the 5 Site Characterization. Plan and the Exploratory Shaft 6 Facility" and quote " Analysis and Evaluation of Regulatory 7 Uncertainties in 10 CFR 60 Subparts (d) and (e) . "
8 And undoubtedly there are other things that I 9 probably should have mentioned, but those were certainly on 10 my reading list for this particular meeting.
11 Topics for the other days of the meeting are 12 posted at the back of the room and you will see that we are 13 taking up tomorrow the reporting of mishaps in the (N 14 management of low-level waste, and also a status report on
'd 15 the use of cement to stabilize low-level waste.
16 And tomorrow morning we will be talking about 17 performance assessment for the high-level waste repository.
18 Then on Friday we will be covering and meeting 19 for the first time I guess as the ACNW with the Office of
, 20 Nuclear Regulatory Research to hear about their plans for l
21 high-level waste research and low-level waste research.
22 And included in that will be a discussion of what 23 the Center for Nuclear Waste Regulatory Analyses is doing.
l 24 Again, summary preliminary reports on the 25 research program are in your notebooks. And I have found at l
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>"e 3 L- 11 -least organizational 1y that they are taking~what-I. 'l 2 considered a fresh approach and hopefully ~it will lead'to a 3 , program that assigns priorities to the different projects to-
'4 be-undertaken and certainly directs the program.toward-
-:5 getting. answers to the questions that confront us.
6 Before I go on, there were several announcements 7 that I wanted.to make.
8 First,-President Bush has selected Commissioner.
9 Kenneth Carr.to succeed Lando Zech as Chairman of'the-10 Nuclear Regulatory Commission.
11 Number two, Victor Stello, the Executive Director 12 for Operations, has been nominated, I gather by the k
13 ' President, to be Assistant Secretary of, Energy for Defense
'14 . Programs within the. Department of Energy.
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15 And thirdly, Guy Arlotto has been appointed as
- 16. Deputy Director for the Office of Nuclear Material Safety 17' and Safeguards.
18 And lastly, fourth, I might mention that tomorrow 19 evening there will be a farewell reception for Chairman Zech 20 at the Bethesda Naval Officers Club.
21 The meeting today is being conducted in 22 accordance with the provisions of the Federal Advisory 23 Committee Act and the Government in the Sunshine Act.
- 24 Dr. S. J. S. Parry is the Designated Federal 25 Official-for the initial portion of the meeting.
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7 1 .The rules'for participation in today's meeting 2.. have.been announced'as part of the notice that was published 3 in the Federal Register.
4 We have received no written statements or 5 requests to make oral statements from members of the public 6 regarding today's session.
7 A transcript of portions of the meeting will be 8 kept and it is requested therefore that each speaker use one j 9 of the microphones, identify himself or herself and speak 10 with sufficient clarity and volume so that'she or he can be 11 readily heard.
12 We will move on with the meeting, then. And the 13 initial discussions, in fact until Noon today, will be on
- 14. the site characterization plan and the site characterization 15 analysis, and we will take up the various sub-units of that, 16_ one at a time, as our consultants once again lead us in the 17 discussions on this subject.
18 And I think then we will move ahead. And Bill 19 Hinze, I believe you will be first then to lead us through a 20 discussion of geophysics, seismology, vulcanism, tectonics, 21 'and natural resources.
22 And Bill, as you begin, let me offer a few 23 comments. And perhaps these are my own, and they are 24 undoubtedly yet subject to review and discussion by the 25 committee.
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k/ 1 But it seems that a number of us have begun to 2 realize that one of the most important points, at least to <
3' us, and I was telling Jack Parry this morning, I had a long 4 conversation with Clifford Smith over the weekend on this.
'5 And one of the most important goals that all of us should be 6 seeking is'to uncover any fatal flaws that may exist in the 7 Yucca Mountain site.
8 And in your area, as I read, I forget which one 9 of these reports that I mentioned just briefly a few minutes 10 ago, as I read those, in fact it was the Draft Director's 11 Comments, he points out the extensive uncertainties in each 12 one of these areas that you are covering, and that they 13 could be very significant. And indeed then, if they are all 14 this powerful, I am beginning to wonder, should not they be 15 brought up the top of the heap in terms of discussion.
16 So with that, I'll hush and listen to what you 17 have to say.
18 MR. HINZE: Thank you, Dade.
19 Actually what I have brightened here in my first 20 comments are the words " fatal flaws," and I would like to 21 come back to that in a moment, building upon what you have 22 said. I think we are all on the same wavelength.
23 We have talked a great deal about geology and 24 geophysics. And most of the comments have been excellent, 25 in response to the committee's questions.
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., 1 There are a few other questions that I would like
- 2. to bring to the staff and'perhaps put our mind at ease. And-3 I'will go through these relatively rapidly and perhaps
'4 comment.
5 One of our major concerns is that we have a 6- minimal amount of direct-intrusion into the repository site.
7 That is by way of drill holes. Presumably thatLis to 8 minimize any movement, rapid movement of high velocity 9 movement of water into the site from the surface.
10 I wonder, though, if the staff has considered the 11' timeliness of determining the longitudinal permeability, 12 'that is, the vertical permeability in the faults, that we 13 know exists in the site, and if we can determine that the 14 permeability in those faults is great enough in a vertical
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15 . manner that we could thus eliminate some of our concern 16 about drilling into the site. Because although I am very l
l 17 much enamored with indirect means of studying hunks of-l l 18 ground, there is no better way that direct investigation.
19 My question, therefore, is, is the determination, 20 the measurement of the vertical permeability in the faults 21 going to be done at an early enough stage that we can 22- consider more or less drilling into the site.
23 MR. McCONNELL: Keith McConnell, NRC staff.
l 24 I think that perhaps the hydrologists would be in r
I 25 a better position to answer that than I am.
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10 l 1 4 MR. POHLE: I don't know the exact schedule.
2 MR. HOELLER: Would you identify yourself, 3 please? j 4 MR. POHLE: Jeff Pohle with the NRC staff.
5 I do not recall the precise schedule for those 6 activities to study the faults and where they lie with 7 ' respect to'the other 20-some odd studies in hydrogeology.
8 MR. HINZE: Well, isn't it true that if the.
9 . vertical permeability in the' faults is high that our major 10 concern about drilling into the site will be somewhat 11 minimized?
-12 MR. POHLE:- The logic of that in my own 13 discussions with the.other people I work with, what would 14- concern us:at this site with respect to hydrogeology, about 15 putting.any holes in the ground, looking at it just from the 16 logical point of view, what we do know about it, the welded
- 17. tuffs are presumably fractured, lots of fractures.
y 18 I would anticipate that the bulk permeability of 19 those types of units is relatively high, as evidenced by the 20 production rate let us say in J-13 which is, at that area, 21 the Topapaw Springs is saturated, so the rock media per se 22 already had a large bulk permeability to begin with.
23 And I guess the logic in our minds t,ould be that, 24 what would we be doing by drilling.another hole in there, is 25 that really significant in terms of increasing the Heritage Reporting Corporation O. (2o2) 628-4888
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d f 11 1 permeability at least of the welding units?
2 But then we have to think of the non-welded units t 3 like the' Calico Hills.
!v l 4 Well, the hypothesis posed in the SCP is that 5 really you can't distinguish between flow in a normal matrix 6 of the Calico Hills or in a fracture of the Calico Hills and 7 indeed the fault zones in t.he Calico Hills, although there 8 haven't'been any specific studies to address that 9 hypothesis.
10' So then he could raise the question, but he would 11 have to look at it with respect to welded tuff or non-welded 12 tuff or where you are at.
13 Now, with respect to the faults, I think we had a 14 comment or two about those studies. I think I can recall, I 15 think there is essentially going to be one hole drilled to 16 assess a fault; whether it is in the unsaturated zone or the 17 saturated zone, it's addressed in both areas.
18 And if you are interested in the longitudinal 19 variation and permeability over some distances of the site, ij4 can one he.le give you that type of information, we tho,u 21 ' that was a bit un5ik . And so on and so forth. "k 22 MR. HINZE: Well, thank you. I think the concern 23 here is that the geologists and the geophysicists get a 24 sufficient amount of drilling so that they can do their job 25 without in any way jeopardizing the groundwater conditions Heritage Reporting Corporation O (2o2) 828-4888 i___.__________ ._
3 12 73 kl 1 of the site and the movement. And I think that that problem ;
c- i 2 still,.in terms of how much drilling is feasible, is still a l
3 concern-to me. '
4 Thanks very much. i i
5~ Let me try another question. And this I guess 6 again borders on the groundwater aspect.
i 7 But the groundwater aspect has been emphasized in -
8 the borehole logging, But the geophysical logging is very i
9 important to geology and the geophysics of the site, the 10 characterization of the site, and the groundwater aspects.
11 I have seen nothing in terms of the comments 12 regarding the geophysical logging in the hole or the surface 13 to hole or hole to surface measurements.
{} 14 15 Are the statements, and I guess I am directing this to you, Buck, are the statements regarding geophysics i.
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16 in terms of integration all-inclusive of all geophysical 17 methods or are they simply surface geophysical measurements?
18 And why shouldn't we also see parenthetically concern about 19 the borehole geophysical techniques?
20 MR. IBRAHIM: Buck Ibrahim, NRC.
i 21 The integration program of the geophysics 1
22 includes all aspects of geophysics, including well-logs 23 also.
24 When I said integration of geophysics, I consider 25 well-logs as a part of geophysics. So I would like to see, Heritage Reporting Corporation
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'1 and as mentioned-also in the.SCPs, it will be some well-1 2 loggings ~on some of the holes they will be drilling. So I 3I would think'they:would consider that in the integration of
[4' all geophysics.
5 MR. HINZE:- My concern about the' scheduling of' 6l the. geophysics, surface geophysics,.also applies very much 7~ 'to the scheduling of the borehole work and that does not 8 'come through as strong as I think it needs to in the 9 comment.
10 MR. IBRAHIM: As you know, we have a question-11 raised about the sequence of the geophysical activity. And 12 in'the SCPs, they didn't commit themselves at all to any
-13 specific date when they are going to do this program or that 14 program.
15 So in one of our questione, our comments, I am 16 sorry, we asked them to give us what kind of sequence they
- 17. .are going to do this geophysical work because some of that l
18 geophysical work would be preferable to do one step before 19 the other.
L 20 MR. HINZE: Thank you very much.
l 21 I think, Dade, that it was at the 6th or 7th 22 meeting of the committee that we heard abort do,a, data 1
1 23 sets, data management. And there as been, as far as I am 24 concerned, a void of discussion regarding this topic. And I 25 cannot seem to find much discussion of it in terms of data Heritage Reporting Corporation
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((d . 1 management in the SCP.'
- 2 Yet data. management, and' maintaining the' quality'
- 3 and integrity of,that data, is extremely important.
4 Are we failing here to remind the DOE that in the 5 long run that these data sets from the' integration 6 standpoint as well as other aspects, just the monitoring of 7 the site baseline data and the:like, are extremely 8 important? We have!had no discussion of data base as data 9 management. Where do we stand with that?
10 MR. LINEHAN: John Linehan.
11 We have had a number of discussions with DOE 12 recently on data management, how they are going to manage' 13 it, how they are going to provide access to people,
{} 14 15 including us, quality assurance aspects of data menagement.
And that.is being conducted separately from the 16 SCP.
17 MR. HINZE: Why?
18 MR. LINEHAN: The SCP was to addrees the studies 19 to be done. And we had already been discussing ths' with 20 the department outside of the SCP.
21 I am not saying it is not linxed, i 22 MR. HINZE: Yes, right.
23 MR. LINEHAN: But that is why it is not covered 24 in our comments.
25 MR. HINZE: Well, I am concerned about something Heritage Reporting Corporation
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l 1 It is the area of the SCP that j j
2 is receiving the public scrutiny, it is the one area that we i 1
3 really~have a chance to hold DOE to a plan and I think that-4 some consideration should be_given to that problem.
5 My notes reflect that there was supposed to be a 6 white paper on that topic prepared sometime early this year 7 on the data management. I think that was Bob Johnson that 8 made those comments according to my notes.
9 If anyone has any informa; ion on that, I would be 10 very appreciative of having it. But I think if we go back 11 in the minutes to the January meeting that we will find 12 that. 4 1
13 Yes, sir.
/~) 14 MR. PARRY: You may well be going to raise it,
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15 but I thought it might be apprc.pr.*. ate at this time to 16 mention or Dring up the fact that during our discussions 17 with the staff, they, on several occasions, discussed slant 18 drilling. And I see in going through the Director's 19 comments, or draft commente, no discussion of that.
20 Are you planning to raise that point?
21 MR. HINZE: Well, I think anyone with a 22 geological background looking at the vertical nature of the 23 faults and the importance of these in terms of the integrity 24 of the site in terms of the regulatory effects has to be 25 concerned about slant drilling. And I know that the staff l
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- l' has talked about that. And the fact of the matter is the-r 2- -shaft.was~even thoughfat one time to be a possibility, that'-
3 .the slant shaft wouldfdo a better job of mapping geology. 4 4' That just reflects the importance.of.the' drilling.
.I think this'is a good example though, Jack, of
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-6 -this no man's land that starts to develop.between the study
'7 plans.and the SCP.
'8 ~ Despite sitting here and listening for many hours 9 on this,whole problem, I am very concerned about what we are.
10 .just casually' leaving to the study plans. And this is 11 reinforced'by'the fact that according to my notes only 20 12 percent.of the study plans will be reviewed.
13; I don't-really understand the criteria under
{} 14 which'those selections will1be made. And I am:very, I think'
'15 we should be very concerned =that we are missing out. We say 16~ it is going to be in-the study plan. Well, the slant holes 17 presumably would be in the study plan.
18 But then if they are not, then where are we? We 19- have okayed, we have given our blessing to a plan which does 20 not go far enough.
21 MR. LINEHAN: If I could just respond to that.
22 We do, and I am not sure you are familiar with it, we do 23 have a review plan, to not only guide the reviewer of study 24 plans but the criteria under which we are going to determine 25 those we will review.
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-21 o will be 'ne.of the-study. plans we do select.
- . 3/ MR. HINZE:. I see. So that will be. flagged, L
4 then.
,5 MR.--LINEHAN: Yes.
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, '6 i MR. HINZE: One'of my comments here. involves this
- 7 whole problem of,:as many of the study plans you have 8 received; many of them are'either in' draft form or being 9 prepared. jYet, they are being. prepared and have been I ,
10t prepared in the vacuum of'the response to the SCP.
'll 'And I am wondering'what types of provisions have
'1:2 .been'made'for a' feedback mechanism to these study plans so-
-13 .that they will take into effect the concerns that are raise 14 Lregarding SCPs.
15 MR. LINEHAN: Me have raised that to'the 16 Department of Energy. I am not sure how they are going to 17 make sure it happens. They are committed.to make sure that 18 that does' occur. But it is something they are going to have-19 to do internally.
-20 What we are going to be doing is we are going to
.21 be tracking all of the comments we have on the SCP.
22 When we get a study plan in, every one of the 23 study plans, 100 percent, we are going to do a very 24 preliminary review. And we are going to use criteria such I
- 25 as was in an SCP comment to determine whether we do an 1 Heritage Reporting Corporation iq .
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18 1- ' detailed' technical review.
21 :That will be-our way of assuring that comething 3- does not . fa)". through.the cracks.
4 One of the things that is called for in the 5' detailed review is to make sure it does consider the 6 comments'we have made on the SCP.
7 MR. ~HINZE: It is a problem.
8 .MR. LINEHAN: Yes.
'9 MR. HINZE: And it is one that I think the 10 committee should address itself to, 11 MR. MOELLER:- Thank you. And incidentally, Bill, 12 as .you cp> over these, I am sure that.the Department of-
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.13 Energy this afternoon, when they speak at 1:00, will respond
- 14. to some of_your; comments.
15 MR. HINZE: Moving to these items that fall in 16 the geology geophysics area, that are potential so-called 17 fatal; flaws, the comments by the. Edison Electric Institute 18 are very germane and'very appropriate, that these be 19 isolated in'a timely fashion, so if there are fatal flaws 20 that we do not waste any more time and effort on Yucca 21 Mountain.
22 I wonder, Keith, I guess I perhaps should be 23 addressing that to you or Bob, I don't know which. What do 24 you consider to be the potential fatal flaws in the geology-25 geophysics area and do you have any feeling for the 1
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I' 19-(_) 1 scheduling of the appropriate studies to determine if they 2 are fatal flaws? And if so, I haven't seen this in the SCP l
- 3 and I am wondering why this hasn't been brought out in the 4 report of the staff.
5 MR. McCONNELL: Keith McConnell, NRC staff.
6 I think it may be a difference in the terminology 7 or the wording that is being used. We have identified areas 8 which we consider to be, or which we feel would have a 9 distinct impact on the repository and the performance of the 10 repository.
11 And I think those have been highlighted both in 12 our comments and in the Director's comments. And I think we 13 have phrased it in those words.
14 And the one that comes to mind specifically is 15 vulcanism, and the aspects of vulcanism that have been dealt 16 with in our comments I think.
17 MR. HINZE: I guess one of the key words there, 18 Keith, is that they are isolated, and we come to closure on 19 them early in the process.
20 That, in two or three of your point papers, or 21 your comments, you deal with vulcanism. Back has one and 22 you have one, Carla has one, as I recall. But there is 23 never anything regarding the early, getting at these early 24 in the game so that we can really come to grips with Yucca 25 Mountain being a viable site without spending a lot of Heritage Reporting Corporation
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2 And I cannot help but feel that even though SCP 3 is supposed to be the strategy, part of the strategy has to.
4 'be the timeliness, has to be timing. And I don't think we 5 can afford to leave that go to the study plans.
6 MR. LINEHAN: One of the things we are bringing 7 out in the cover letter which is not available at this point 8 in time, we are still working on it, is we are using the 9 tectonics issue overall as an example. And we talk about 10 the need for DOE to determine early in the program the 11 impacts of things such as tectonics. We don't call them 12 fatal flaws.
13 (Laughter)
'~' 14 MR. LINEHAN: We talk in terms of the various 15 issues that could have a significant effect on the 16 performance of the site. And we do point out that those 17 need to be resolved early in the program. They need to be 18 addressed and then resolved early.
19 one of the things we are trying not to do is we i 20 are trying to play our regulatory role and it is not to tell 21 DOE how to run the program the best way, cost effectiveness, 22 to carry out the site characterization. And we are trying 23 to avoid doing that, stepping over that line.
24 MR. HINZE: I'm sure that is not a very clear 25 line, however. Very fuzzy. Good luck.
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kJL 'l MR. MOELLER: And yet,-for-every' concern that you
- 2 raise, you state quite clearly one possible approach for
- . 3 resolving it, which I find maybe contradictory to what you 4 just said.
5 I mean, I.am all for it, but right, it is a thin-6L line you are trying to walk. And.it is hard.
-7 MR. HINZE: I-don'.t want to take too much time, 8 Dade. There are a couple of other items I would like to 9 touch on.
10 MR'. MOELLER: Go ahead. We have the time.
- 11. MR. HINZE: We've discussed over and over again 12 the exploration shaft and location of that shaft. And I 13 think we all know the problems there. I am not going to
( 14 recite them.
15 But I am wondering, Dr. McConnell, do you have 16- .any new information that might help us in terms of coming to
~17 grips with the shaft problem, and.that might alleviate some 18 of our concerns of why you have not, why the NRC staff has 19 not made the shaft, the exploratory shaft, an objection 20 rather than just a comment, in terms of its location?
21 MR. McCONNELL: Well, the shaft issue is included 22 within one of the engineering objections. We originally had 23 it as a self-contained, or objection on its own. But it was 24 included in the engineering objection. And so we are happy 25 with that resolution. So we still consider it is being Heritage Reporting Corporation 4
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4: 2 We.have'gotten recently,from the DOE the 3 technical assessment review documentation that they>are
'4 ' going'to;use I guess to review the problem,-and we are still 5 ' waiting'for~a little bit more additional-information on the 6 scope, I think,. of;the review, as far as shaft location is 7 concerned.
8 My initial impression is that maybe some 9 - additional references should be viewed when considering the 10' shaft' location issue..
11 MR. HINZE: One more item on that point, Keith.
12 In the comment,.the SCP Yucca TC COM 1, which
- 13. deals with the problems concerning major and minor faults, L
14 this is perhaps a minor point, but one of the bases of
]}
15- stressing the importance'of so-called minor faults, that is, 16 mapping of minor faults in the workings from the shaft is 17 the fact that there is a concern about the location of l
18 earthquake epicenters on minor. faults.
19 As I think most of us know, not all the.
20 earthquakes occur on major faults. In fact, they seem to 21 try to avoid them. And so the minor faults become extremely 22 important. And yet that is not stated as a basis. And I i3 would suggest that perhaps that could be considered.
24- I would like to review here some things regarding i 25 the geophysical program. I think we have all learned from Heritage Reporting Corporation
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. . , 23 l' the pointjpapers and from the comments the lack of 2- integration, the fact that there are no geophysical programs 3 which are designed.particularly for the natural resource 4- investigations. And that is well stated.
5 But-the lack of a defined program, and I guess I 6 am plowing old ground, really, the lack of a defined program 7- in terms'of the methodology, suggests-that there really is 8 no program.
- 9 It essentially is leaving all of the decisions 10 regarding.the geophysical program to the study plan. So !
11- therefore, there is, looking at the SCP from a geophysical 12 . eye, there is not much to evaluate, because it is all, 13 everything is being done. There is no critica1 ness, there
~14 is no prioritizing. But again, I am very concernad that we
)
'15. have'a no man's land here between the study plans and the 16 geophysical programs as discussed in Chapter 8.
17 MR. McCONNELL: Keith McConnell again, j
'18 We share your concern. And I think it comes 19 across or at least tries to come across in several of our f
20 comments, that without knowing the specifics, and also some 21- of the activities are basically conceptualizing the .
t 22 technique or making sure the technique works. And yet those 23 techniques will then provide input into a lot of the other 24 activities.
25 So we share your concern that if these Heritage Reporting Corporation
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i A- t 1: geophysical activities are carried out or for some reason 2 are found'to be infeasible, then we are going to have ,
13 problems on down the line, too, .in some of the other s l
4 activities. -l J
5 MR. HINZE: The logic pattern there in terms of a 6 strategy seems to be lacking in the fact that one, if one J/ carries, designs a program such as'this, you develop a 8 conceptual geological model, which we have several of 9 hopefully;-we define physical properties, the critical 10 physical properties. There are horizontal and vertical 11 variations. .You do forward modeling of some type to 12 determine what methods are going.to work and also how to 13 carry out those methods, the survey procedures, et cetera.
{} 14 15 I see none of that looking at the physical properties, looking at this forward modeling as an early 16 etage. I don't see that in the SCP. And although that may 17 be implied in your comments, that does not come through 18 strong.
19 In addition to that, what I think is missing from 20 the SCP is a statement that there will be a sufficient 21 amount of drilling resources left after the geophysical 22 programs, whatever they may be, are conducted, to test 23 critical areas defined by the geophysical program.
24 There has to be a proper logic flow here in that 25 the geophysics always produces ambiguous results and we have l
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. ("N . I (s I' 1 to, we should be, and I would like to see that included, 2 that sufficient drilling resources be retained in the 3 program and staged properly with respect to the geophysical 4 interpretations.
5 I don't mean to be on a soapbox on that, but it 6 is very important.
7 There is another topic related to this, to the 1
8 geophysical area. And that is, many of the programs are l l
9- extending their studies out for a 300-kilometer radius 10 around the Yucca Mountain site. Yet the geophysics is not l 11 going out to those distances in a proper manner, in a 12 detailed enough manner. It is more of the nature of 70 13 kilometers, if my reading of the document is right.
("N 14 I wonder, Keith, as I recall the comments, there
\-)
15 is not a statement regarding the distance that one needs to 16 extend the study for regional tectonics structure studies as 17 well as the vulcanicity problem.
18 MR. McCONNELL: We do have a comment on physical 19 domain, and the definition that the DOE has used as far as 20 the area.
21 And also there are specific comments, one that we 22 talked about this morning on vulcanism, and the 70-kilometer 23 limit on vulcanism studies, which seems to imply that areas 24 like lunar crater would be excluded from consideration.
25 So we have commented on that I think several Heritage Reporting Corporation
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1, 2 'MR. HINZE: Dr.:Moeller, I think.I will stop at-3 that point and come back with any further questions-that-I' 4- might have.
1 5 MR.JMOELLER: .-Okay. One comment. When you were' 6 : mentioning natural-resources, and of course this is beyond:
7- my. area of knowledge,.but it seemed to me over the last-8; couple meetings we heard more and more about the need for.
9 more carefu1~ review of potential natural resources in the 10 area. And'yet when I read the Ross Report, as I' recall, one 11 place they said, since' petroleum will absolutely never be- '
12 found anywhere around there, we can forget this particular 13 point.
/~ 14 HR. HINZE: Well, I think that that is a 15 statement that would be hard to back up. There is petroleum.
16 production in two places, in Nevada, a couple places in-17 Nevada. The Railroad Valley, they are producing from welded 18 tuffs,. I think they are welded tuffs. And the comments 19 regarding, for example, the lack of source rock in the SCP 20 is commented on by the USGS in their review of the CDSCP.
21 Certainly one has to get into those rocks to 22 evaluate them and not just by drilling. And this could be 23 done without jeopardizing the site, by moving off a bit from 24 the site itself.
25 But it is going to require some direct Heritage Reporting Corporation
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\' 1 exploration, and as I have indicated several times, I think I
2 that one of the very best ways of doing this is to bring in 3 some of the people in the resource industry, perhaps through 4 an academy committee or a professional committee,
.I 5 professional society committee, which would provide an j 6 oversight role in this regard.
7 They might not do any better job than is 8 currently being planned. But it would give the whole 9 situation a credibility that we would all appreciate.
10 MR. MOELLER: Okay. Thank you.
11 Any other comments or questions from consultants 12 on this matter?
13 Yes, Gene? Pull your mike up, please.
14 MR. VOILAND: Even if you found petroleum under
("}
v 15 there, would that pose much of a problem? Oil wells are not 16 spotted very close together. They put them in on angles and 1i what have you.
18 I can't see the need of having to go right ;
i 19 directly onto the site.
20 MR. HINZE: The problem is intrusion at some 21 later time. If we have the favorable situation for 22 petroleum in the area, it very well may be without any 23 record of the site that there may be drilling in the site.
24 MR. VOILAND: What do you mean by intrusion in 25 this instance, Bill?
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,: 28 L1- .MR . HINZE:- By drilling,.by people that may not
'I 2 know the location of the repository.-
'3 MR. SHEWMON: -People who do not recognize 4 radioactivity or danger when they dig into it. Which-I find-5 preposterous.
6 MR. HINZE:- I think by the time you've drilled
.7 into it to find out that it'is radioactive, that you would 8 be in serious trouble.
9 There is a great deal of concern about drilling m
10 into radioactive materials, not just in terms of 11 repositories but for example, there are some states that
'12 will not even allow you to leave granite samples on the 13 ground, granite samples that contain very minute amounts of 14 radioactive materials.
15 I'm not to judge'that.
16' HR. MOELLER: Gene,. continue, if you had.more.
17 MR. VOILAND: No, that'was really.what I wanted 18 .to'say, is that it just did not seem to me that that would 19 be a serious problem anyway.
20 MR. MOELLER: Okay. Jack and then Don.
21 MR. PARRY: I believe that there are certain 22 regulatory bars and disqualifies, and I think natural 23' resources is a disqualified.
24 The presence of natural resources at or near the 25 site would be considered regulatory bars, either in Part 60 Heritage Reporting Corporation
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1 or 960. So it does ont necessarily relate to the risk, it l 2 is just a fact.
3 MR. MOELLER: Okay. Don. f i
4 MR. ORTH: Just one idle thought, on reading the {
t 5 things that have been written and listening to the j 6 discussion.
7 The problem is that the site is guilty until 8 proven innocent, rather than innocent until proven guilty.
9 It doesn't do any good to say that there is no evidence of 10 natural resources. Sooner or later the way the things are 11 written and in the adversarial climate that we have, they 12 have to prove that there are no natural resources.
13 One of those things.
r- 14 MR. MOELLER: Gene.
(
15 MR. VOILAND: With respect to these disqualifying 16 features, otherwise known a fatal faults, it does state in 17 10 CFR 60.113 that there can be, that the NRC has the powers 18 to make some kind of changes.
19 They can change -- where is that -- it says NRC 20 may alter discharge weights or water flows depending on 21 standards on the H&H or the wastes, and those kinds of 22 things. And I think in dealing with that issue of fatal 23 flaws, one should think of them in terms of two categories, 24 one category being the natural attributes of the site.
25 If we know there is going to be a volcano in 100 Heritage Reporting Corporation (202) 628-4888 fa'T
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1 years, I think we would goisome otheriplace.
- 2. On the other hand, those kinds of fatal flaws
~
3 . which mightLdepend upon.the regulations'as they stand'today, 4 which.could be modified,-I think should be distinguished.
5 MR. MOELLER: Okay. Let's more on then to the-6 'next topic, which is materials engineering.
7 And Paul, that'is your area.
8 MR. SHEWMON: Okay. I have, since our last 9 meeting, gone back and read'over the site characterization 10 plan in some detail in the materials area.
11- And I guess I come backLthat in this area one 12 cannot really. judge whether the plan will meet the 13 regulatory criteria or not.
(} 14- It. consists of a series of assertions .cn: promises 15 about what they will do. They will choose a material of 16 construction that will be corrosion resistant. They will
- 17. design a package that will be leaktight. The package will 18 provide essentially complete containment for 1,000 years.
19 They will develop a model that will protect the performance 20 of the package under corrosion, interaction of the container i'
21 with shifting rock and release rate of the waste form for 22 the period of 1,000 or 10,000 years.
23 However, none of these things have been done yet. I 1
24 One can say that this is just a site 25 characterization plan and the waste package has nothing to Heritage Reporting Corporation O- (202) 628-4888 I
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31 1 1 l '. 'do with characterizing the site. But I feel this is playing i
2- games, since the aim of the exercise is to see if there is a 3 reasonable. assurance that Yucca Mountain repository will 4 provide satisfactory isolation for 10,000. years,,and the 5 waste package performance is an essential feature in this. i 6 So we get down to if the goal is to say there are.
7 no obvious faults, then I would agree with this - .there are 8 no obvious faults.
9 If the goal is to say is this a satisfactory 10 , answer, then I have to come down on the other side of it and 11 say no, it is not a satisfactory answer because I do not 12 know what the answer is that they are giving.
13 In a sense it comes down almost to a matter of---
14 we won't get into theology, but -- if you are a believer, f-) -
(d' 15 it is great; if you tend to be an' atheist, it is bad.
16 If we go back and look at these things again, 17 most of the work has been done on corrosion. And my guess 18 is that they.can pick a material which indeed will be 19 corrosion resistant under the materials. Section 7 talks to 20 this in some detail, and I think in a reasonably convincing 21 way.
22 Canister corrosion is probably in better shape 23 than anything else. They have done a fair amount of work 24 on the waste form. There have been a lot of studies of the 25 glass and how it would interact with water; somewhat less, Heritage Reporting Corporation
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h- t 'I 32 j 1 'but a reasonable amount, on the fuel.
2 The criteria for and-probability of failure that i
'3 will_go into the modeling I think is largely undetermined.
4 I was interested for example at this meeting'last-5 ' time, there was talk of what kind of deformation will there 6 be in the rock and will this likely be homogeneous or 7 localized on shear planes. And I thought well, let's see 8 how they treat this and what the interaction of that would 9 be in the package.
10 And all I could find was about three sentences
-11 that say we will develop a model which will take care of all 12 of these things. It'will be a computer code so you can get 13 out of it all kinds of probabilities.
14 My guess is that they feel the mechanical design 15 and construction is something so simple that they can 16 certainly do it and they will do it someday later. But as I 17 said earlier, it just is not there yet.
18 MR. MOELLER: And they have not laid out a 19 testing program to gather the data they need to answer these 20 questions?
21 MR. SHEWMON: Well, they do, but a testing 22 program does not give you a design. And a testing program 23 does not give you a process for fabrication and testing. 1 24 Basically what they are going to come down to is for the I 25 first 300 years, if there are not any leaks in it when it Heritage Reporting Corporation l
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1 4 c;(p 33' Ih 1 ~ goes in, there probably will not be any leaks'in it at 300 2 years.
3 And so on that basis, the quality of how well 4 they make it, no matter which'of these reasonably 5 -satisfactory materials they make it out of, the process of 6- the fabrication and checking that to me is more important 7 than what they make it out of.
8: Go ahead.
9 MR. MOELLER: Excuse me. At some point we will
'give the staff a. chance to offer some comments.
~
10 11 MR. SHEWMON: What the staff has for their 12 points, I have no objections to. They have gone through and
- 13. talked about particular aspects of the corrosion,
'14 homogeneous versus inhomogeneous, saturated moisture versus 15 water, effect of stress on the corrosion rate.
16 The one area which the staff calls out as an 17 issue of regulatory concern is how they will demonstrate 18 essentially complete or substantially complete containment, 19 and whether there are' quantitative measures for this.
L 20 And I think that is always going to have to be 21 -done some on a matter of reasonableness because inherent in 22 these corrosion problems are questions of whether or not you I
23 can ever reach certain extreme conditions which might lead 24 to failure, that under the average or most credible 25 conditions, everything will be satisfactory, and that they Heritage Reporting Corporation
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l(~)L o . 1 can prove'.
l 1 , 2- So I.think the staff has a reasonable set of. l O 3 ' points. But it does not get back to me at least as -- And-
^
3 4i in a~ sense this may not be the forum for when are they going
- 5. _to.'give a package.we can evaluate and programs that we can 6 . evaluate. But'until you do get to that point, you.cannot 7 'really_say that-there is a basis for saying yes, this is a 8 satisfactory process or product, or something, at least from 9 the materials viewpoint.
10 ,
That is'all I had.
11 1 MR. MOELLER: John, does the' staff have any 12 comments on these remarks?
13 MR. WELLER: My name is Rick Weller, NRC staff.
~. -
~14 Dr. Shewmon is correct. All this is is a )
15 characterization plan. It is not the answer.
16 The evaluations of the assessment of how well the 17- waste package will perform will be provided in the license 18- application which is currently scheduled for early 1995; so 19- there is a long time in the interim for waste package 20 ' development.
i 21 It is going to be a phased process. All that 22 exists right now is a conceptual design. The next phase in 23 the evolution of the waste package will be an advanced
- 24 conceptual design which the DOE intends to initiate. It was 25 supposed to be this Fall, but I understand it is now going Heritage Reporting Corporation
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. U 1.' -to be slipped to 1990.
2 The DOE was also-supposed to select the material'
.3 _this coming Fall,. container material. 'That, too, has been 4 slipped until 1990.
5 We do not-really have major concerns with the -
6 waste' package development program as described in the SCP 7' that cannot be fixed,.and the issues we have been focusing 8 on are the need for in situ waste package testing, a 9 performance confirmation program for the waste package, and 10 then there is-another problem which Dr. Shewmon mentioned, 11 which is just as much ours as the DOE's, and that is the
-12 interpretation of the meaning of substantially complete 13 containment.
14 And in that regard, we have a planned rulemaking
-[ }
15 in. progress which will either change the words themselves, 16- in other words, a full new rulemaking, or if we decide that 17 the words are fine we will just try to better explain what 18 they mean. But I think the DOE was responsive to our 19 comments on the CDSCP related to the meaning of 20 substantially complete containment. We have a closer 21 understanding of that meaning.
22 One of the comments we focused on in the SCA is 23 further understanding an interaction of the meanings of 24 those words and how the DOE will comply, demonstrate 25 compliance in the license application.
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l 1- - MR. MOELLER: I gather in the SCA application,-
2- the statutory SCP, DOE did come around to a more, come 3 around to a definition of substantially complete containment-4 that was-nearer to yours, but they put that qualifying 5 phrase.in on the end.-
6 ML WELLER: Yes. And'I can't fault the DOE for 7 'their response =because we had a little bit of a change in
~
8 . thinking in the interim from the CDSCP.
9 We told the DOE when we met with them in our 10- workshop that we had no intention at that time of assigning 11 a numerical value to the word "substantially." The purpose 12 of the rule was to focus on period, and there was 13 flexibility injected.in the final rule by allowing for a
() 14 period of 300 to 1,000 years for containment.
The emphasis in the final rule was not supposed
.15' 16 to be on the word "substantially."
17- The intent,is that the DOE does provide 18 containment, and that means no release. But we well 19 recognize that things can go wrong despite your best 20 efforts.
21 So despite the fact that there is no absolute 22 requirement for zero release during the containment period, 23 nevertheless, it is our feeling that the DOE has to design 24 at least for no releases during the containment period.
25 And as I say, with our change in thinking, with Heritage Reporting Corporation O- (202) 628-4888
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k-)\ I this rulemaking effort, we may well try to assign some kind 2 of numerical value. I know that the DOE posed this to us.
3 They questioned us about that when we met with them in the 4 workshops after the CDSCP review.
5 So that is'something we still have to work out 6 and we have a schedule laid out and hopefully within a year 7 we will come to some assessment that we either change the 8 language or better explain what substantially complete 9 containment means in an engineering or a macroscopic sense, 10 some reasonable interpretation.
11 MR. MOELLER: So what you are saying is that 12 later on you may find that you want or need to quantify what 13 substantially complete containment means. I
{} 14 15 MR. WELLER:
MR. MOELIER:
Yes.
Now, how does it relate to EPA's 16 standards, which permit a certain release?
17 MR. WELLER: It is designed to support and 18 implement the EPA rule, much like Appendix I to Part 50 19 supports and implements the general EPA standard for 20 radiation in the environment.
21 MR. MOELLER: And if DOE and you resolve the 22 differences in this definition, then would the rulemaking 23 just be terminated? Is that the way it goes?
24 MR. WELLER: We will certainly interact with the ,
25 DOE in the interim to come to a better understanding of what l
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(> 1 thej mean by the additional words they have tacked on to 2 thetir interpretation, the caveat, the recognizable 3 limitations and uncertainties as they describe them.
4 But in the next year we are really going to have 5 a parallel approach. -We are going to pursue interpretive 6 cu?.emaking which would not change the language but simply 7 be tter explain it.
8 As I see it, it is kind of a bolstering of a 9 statement of considerations, if you want to look at it that 10 way.
11 The other way to do it is so, since there is so 12 much misunderstanding about the language, is to simply 13 change the language and come up with some kind of different
(~T 14 structure for containment requirement, perhaps with some (l
15 numerical criteria much as we did with Appendix I to Part 16 50, in explaining what the words ALARA meant. Because prior 17 to Appendix I, all you had was this qualitative requirement 18 to minimize releases to the environment.
19 And Appendix I provided some numerical definition 20 to that.
21 As I see it, this is a similar problem, trying to 22 provide some kind of numerical interpretation to the words 23 substantially complete.
24 MR. LINEHAN: Dr. Moeller?
25 MR. MOELLER: Yes.
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l 39 1 MR. LINEHAN: On the regulatory uncertainties 1
2 that we are considering potential rulemakings on, like 'I I
3 substantially complete, the concern is not just coming to' .
l l 4- resolution-with DOE. It is resolving this uncertainty and 1
5 getting that on the record so that-it is something that is 6 not challenged at the time of the licensing hearing.
1 7 So on most-of these, reaching agreement with DOE 8 would not be reason to preclude the rulemaking.
9 MR. MOELLER: Dr. Okrent.
10 MR. OKRENT: Let's'see. If I could try to cover 11 two or three points, briefly.
12 It seems to me on the topic just being discussed 13 it might be worth looking at the history and discussion that 14 took place when a statutory committee reviewed the proposed 15 EPA draft standard and made a recommendation that there be 16 some protection for five generations or so, so that people, 17 if there were people living in the near vicinity, they would 18 feel that they -- and this far forward one usually thinks in 19 a family way -- would not be threatened.
20 And I sort of have a fear that a social concept 21 is being stretched into a rigid and high hurdle perhaps, 22 much more than was the thought that this review committee 23 was.trying to get across, and which then appeared in the EPA 24 as a zero release in fact, and not as a fixed time.
25 A different point. If I could ask Shewmon a Heritage Reporting Corporation
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2 Since I read some people at least think there are 3 lots of questions, too many questions to ever have them all-4 answered without big uncertainties about the hydrology and 5 geology and seismicity, and let me leave vulcanism outside 6 for the moment, in your opinion, if it were an acceptable 7 path in the regulatory sense, could a much better container 8 -- and what I mean by much better container is one that has 9 a rather reasonably good assurance of staying intact for 10 thousands of years, I won't say 10,000 -- be imp?.emented?
11 And not at costs that are prohibitive.
12 MR. SHEWMON: No, I don't think so. I think the 13 general corrosion, the most credible and the part that is
./ 14 unavailable of this, is very good. They talk in terms of 15 tenths of microns per year or something which is down at a 16 rate where it is very difficult to measure and where it is 17 certainly difficult to extrapolate, that won't even go even 18 slower in longer times for different scenarios that we can 19 think of.
20 And so in that sense, they have a good material.
21 What you have to end up with if you are going to 22 postulate a credible failure mechanism or any mechanism, not 23 necessarily too credible, in these periods, is some very 24 unlikely occurrence, and what they talk about then are 25 possible concentrations of salts which might lead to local Heritage Reporting Corporation
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(_) 1 corrosion. The corrosion people, so that they will have ;
2 something to study, usually study things under wtter because !
3 they can find even less to study if it is in moist air.
4 There is talk about shifts in the rock which !
5 would apply local stresses that might open it up.
6 I think if you look at what people overseas have 7 done, the Swedes resolved this issue technically to their 8 satisfaction five years ago roughly. And what they did in 9 addition to having a corrosion layer or a good canister 10 outside is to take powdered copper and completely surround 11 the waste form with it and decide that they would put a 12 centered copper layer around it. So they've got this 13 monolith of copper which in granitic waters does quite well.
14 And we have not gone to that sort of a package.
15 We have just said we will rely on the canister, put helium 16 in there so that it will not corrode or change the fuel 17 form.
18 So I think -- that is a long answer to the 19 question. No , I think they've got a concept that is good.
20 It is much better, for example, than what we were arguing 21 about in some quarters a few years ago where we were going 22 to put it in salt which is moist and they were saying well, 23 we will put enough steel around it so that the corrosion 24 rate will corrode six inches of steel in 10,000 years, and 25 we think we are okay on that. Then you got into inches per Heritage Reporting Corporation
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$_) 1 eon corrosion rates, and inches per 1,000 years.
2 So I think it is in quite credible shape, 3 actually.-
4 MR. OKRENT: With the environment either that is 5 present in the current site or that is postulated might 6 arise due to some untoward event, let me leave vulcanism 7 aside, is there an approach of the sort that the Swedes did 8 that would give assurance or is the water, if it is there, 9 enough different that that does not --
10 MR. SHEWMON: Well, if water came up, basically I 11 think what people have talked about is will water come up 12 and cover this.
13 MR. OKRENT: Yes.
(^} 14 MR. SHEWMON: For the first 100 years, to get U
15 back to your five generations, they can argue that heat 16 generation will tend to keep water out and probably the 17 water table will not shift that much in a couple hundred 18 years, though I am getting out of my own field at this 19 point.
20 And then you have your 300 years, which is the 21 first barrier.
22 MR. OKPENT: I am looking to see whether one can 23 get thousands of years, and if the resolution of the
! 24 longterm hydrogeology is -- There are lots of uncertainties.
25 MR. SHEWMON: If the water table rises, you are l
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i a 1 'still' exposed to oxygen and you have water there. And I
- 2. think that is satisfactory,.too.
3 If you now alternately wet and dry it over times, 4 you can talk about salt concentrations and you can go at.one 5- extreme where my friends tell me that the only reason that 6 city water systems survive is.that you really lay out enough 7 minerals on them so.that the steel does not see'the water at 8 all, at one extreme,'.to peoples who say well, I can boil off 9 and concentrate chlorides there and chlorides on warm 10 stainless steel are bad, and that might give me a local
.11' failure criteria.
12 MR. OKRENT: But you are still talking in terms p 13 'of stainless steel.
14 MR. SHEWMON: Yes.
15 MR. OKRENT: And I was wondering if alternate 16 materials would handle that or other, as well.
17 MR. SHEWMON: I am not sure what the case is for 16 copper at this point. I am not that much of a corrosion 1.4 person.
20 There is a cickel base alloy, 825'or 800 and 21 something, which the DOE people say is somewhat better under 22 some conditions of water and air. Maybe it has less stress 23 corrosion cracking.
'24 MR. OKRENT: I'm still interested in the 25 question.
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44 k._) 1 MR. SHEWMONi Okay.
2 MR. WELLER: Dr. Moeller?
3 MR. MOELLER: Yes.
4 MR. WELLER: Could I clarify something? Because 5 you asked a question about the containment requirement or 6 the requirements of 60.113 in relation to the EPA standard.
7 And as I mentioned, it supports the meeting of 8 the EPA standard but it is a little bit like comparing 9 apples and oranges because they de not have the same 10 boundary conditions.
11 The containment requirements and the release rate 12 requirements apply to the waste package and (ngtoaered 13 barrier system to the geologic setting the releeses from the 14 engineered barrier system, whereas the EPC containment 15 requirement is at the accessible environment.
16 So you do have the geologic setting to do 17 something for you. So it bulps to support, but that is it.
18 MR. MOELLER: Thank you for Jeminding us of that.
19 That is important.
20 Any other comments?
21 (No response) 22 MR. MOELLER: Let's move on then to the final 23 item of the first three, which is geotechnical engineering.
24 And Gene Voiland will be covering that.
25 MR. VOILAND: Would I would like to do this Heritage Reporting Corporation j
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) l' morning is; sort of perhaps maybe repeat a little of what I 2 .said-last time and maybe extend some comments from that.
3 When we are talking about the Title I design we 4 rea21y are talking about an engineering study. And that 5- ' engineering. study is aimed at a facility. It is not u-6 .particularly aimed at a plan or_ program or experiments or 7 what have you._ It is.to' construct, to provide the first 8 stage of the engineering for a facility and that facility is-9 the ESF. And it is defined in the' plan as the surface 10 buildings,fsurface installation, the shafts, the drifts, 11 particularly the drifts for the' underground experimental 12 area and a couple of long drifts which are aimed for other 13 purposes. So.it is clearly defined in what it is.
14 And in~ thinking about this, I am reminded a 115 little bit about the story of the blind people and the 16 elephant. And I think the experimental shaft is a little 17 like that. It depends on what.your perspective is as to how 18 it looks.
19- It has three functions:
20 To provide underground test area for a large 21 number of scientific and engineering tests aimed at 22- characterizing the geographical site. And that is the 23 primary purpose in my judgm.ent of ESF.
24 A second function that it has, it provides an 25 opportunity for investigating the geological and related Heritage Reporting Corporation
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properties of thefrock'as you go down through this side.
~
1 2- And the third item. If the site turns out to be 3 okay, it'would become an integral part of the repository 4 system.
5 So if one thinks about the Title I. design in 6 terms of these three functions, I think this is the kind of 7 conclusion-that you~come up with.
8- The Title I design for the underground test area 9 is to some extent and quite a large extent in my judgment, 10 : separated from the other two functions.
11 Conceivably, if you.had similar underground 12 terrain -- subterrain I guess would be the term - you.could 13 do these cests in an area which was completely independent 14 of the repository and as such you would not be very
-(}
15 concerned about 10 CFR 60.
l
- 16. It is only becauce of that relationship with the ;
1 17 repository I think that we get into this discussion at all.
18 Looking over.what has been done, I have not 19 looked at the Title I design, but it presumably is reflected 20 in the SCP. And it states that on a number of occasions, so 21 I.think in looking at the SCP, you are sort of looking in 4
22 the mirror, looking in the looking glass at the Title I 23; design. j i
24 And I guess my reaction there is that it 25 responds, as I mentioned last time we talked about this, to l ,
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(> 1 the input information. There is a whole lot of information 2 that went into that, particularly with respect to the kinds 3 of experimental program.
4 And in my judgment, I think the designers did a 5 good job, because they took what they had and it looks like 6 they did a good job in designing to that.
7 If you take a look at everything they have done, 8 if you look at the attention they have given to such things 9 as the various tests, and you have to keep in mind that in 10 the meantime we have learned new things. When they started 11 that design we had some different perspectives I think on 12 the nature of the characterization program.
13 We have perhaps decided that we need different
{} 14 15 things, and there are references, a number of references, and I will mention those a bit later, which are kind of 16 speculative.
17 In other words, they didn't design to this. A 18 speculative kind of thing. And I will talk about that 19 briefly.
20 So with respect to the underground test area, as 21 that facility, I think it is pretty good. And I think in 22 the DAA they addresed it very much from the same point of 23 view. They were looking at it as a facility in which to 24 undertake a large number of experiments.
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- 1 than any particular part of it and it looks quite' integrated 2 and quite satisfactory.
3 Now, when you look at it from the point of view !
4 of the investigations of the subterrain there that you are 5 going to carry out, as you put the shafts down, I think that 6 is another kind of a problem because here we are asking the 7 data that comes out of that investigation to-be. pertinent to-8 the repository. And this I think leads to the question is 9 the hole in the right place, is it going to give us the 10 right kind of information we have?
11 And that is not a judgment I think that the 12 architect engineers can make. The architect engineers can 13 design this facility only on the basis of what they know and 14 what they are told.
15 If I hire somebody to build me a house, I think I 16 ought to tell them whether I want a basement or not or 17 whether i want five rooms or 12. I don't just say hey, go 18 out'and design me a house.
19 And I think that is kind of the way the 20 architect-engineers were. They took all that input 21 information and I think they digested it and did what 22 _ architect-engineers do real well, probably produced a 23 mountain of drawings and specifications and what have you. .
24 So that is kind of scientific judgment that I 25 think has to come into it.
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49 S 1 MR. OKRENT: Excuse me. Is there a single right 2 place to doLthe job?
3 MR. VOILAND: According to the DAA where they .
4 looked at that and looked at five alternate places, their 5 conclusion was thet one.was probably about as good as 6 another. And I am not.in a position to judge that, David.
7 MR. OKRENT: That's not my question.
8 MR. VOILAND: I think that's the glesbion that 9 Bill was bringing up here earlier.
10 MR. OKRENT: From issues raised let's say by the !
11 State of Nevada and others, the question was raised, could 12- you got enough detailed information about the site from a
-l 13 single hole, however optimally placed? .;
l
{} 14 HR. VOILAND: Well, it is only part I guess of '
15 the whole plan. And I think Dr. Hinze here addressed some 16 of the other aspects of it. Maybe we ought to be putting 17 .more boreholes for investigation of the site to get some 18 idea of the degree of homogeneity to the entire site.
19 MR. OKRENT: Would it destroy perhaps certain 20 aspects of the site? l 21 MR. VOILAND: Well, i guess that is a risk 22 benefit analysis.
23 MR. OKRENT: I suspect it is a problem that would 24 face any sit 1 25 MR. VOILAND: I think if you were going to do Heritage Reporting Corporation O (202) 628-4888
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(_)T 1 some exploration say for mining for any sort of material, I 2 think, and Bill can probably help me out here, that they put 3 down lots of boreholes to find out the size of the potential 4 ore body, the thickness of the veins, the extent that they 5 run out, all that kind of stuff. And they are not too 6 concerned I guess with the holes they leave behind, although 7 they fill them I think in general in those kinds of 8 situations.
9 I know that in petroleum exportation they fill 10 the holes that they drill generally.
11 But anyway, I guess there is a catch-22 there.
12 You can't argue that you can't make the holes because you 13 will affect the sites, but I don't know whether the site is r- 14 any good until I drill some holes. There has to be a V) 15 resolution to that particular paradox that we find ourselves 16 in.
17 MR. ORTH: Can I make a comment at this point?
18 MR. MOELLER: Yes.
19 MR. ORTH: Generated from all the stuff we have 20 been reading, this seems like a pertinent point.
21 If we can't assume that a satisfactory method of 22 plugging boreholes in shafts will be found, no waste l 23 repository will ever be satisfactory.
24 Of course the assumption is going to be 25 challenged, so obviously how you plug it is going to have to Heritage Reporting Corporation
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51 1 fs 1 k- 1 have a high priority in terms of demos at some point.
2 But I think we have to assume that people
- ill be f
3 able to plug some reasonable number of boreholes or we will {
4 never, ever, ever bury waste. '
5 MR. VOILAND: Or you certainly might be able to ,
6 plug them so that the leakage through them isn't much 7 different than the neighboring rock and that was the point I 6 think that Dr. Hinto was trying to make earlier today. !
9 MR. HINZE: If the vertical permeability is so 10 high from the faults and the fracture permeability, the 11 drill holes may be inconsequential in terms of the overall 12 effect. And that is something that should be determined 13 very early on in the game for getting at this point. ;
14 MR. MOELLER: That was one of your first points.
}
15 And Bill, you have also, or certainly I am !
j 16 learning by listening to you, you have also pointed out to 17 us that you have to combine or you should plan a program i
18 where you combine the proper amount of surface exploration 19 with underground investigations.
20 MS. MOODY: Remember, Dade, that is an issue that 21 I think is very important, and have talked about, mentioned 22 comments several times, as Bill knows too. And that is that 23 we do know already Gene that the rock is heterogeneous, it 24 is not homogeneous.
25 That is point number one.
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(,) 1 The second point is that we do have a paradox, 2 that has already been mentioned by our colleague Orth, and 3 that is, you still, given how the repository is going to be 4 used, try to reach an agreement in terms of the total number 5 of drill toles that you actually implement in the repository 6 area itself. Just aimply not.only the prcblem of sealing 7 but also of trying to minimize the anount of water that 8 might reach the repository horizon itrelf.
9 So we keep coming around and around to that. But 10 that is important.
11 MR. VOILAND: I agree with that. But I think in 12 terms of the engineering and the Title I, if we are going to 13 put any sort of 12-foot hole down there, that I doubt very 14- much if the engineering is going to be very different with (m\]
15 respect to that, whether you put it in Point A or B or C or 16 Point N.
17 And this is what I am looking at as essentially 18 the engineering, divorcing it if at all possible from the 19 plan and the studies and the tests.
20 I think there is a lot of confusion in here.
21 When I look at the comments and all the rest, I see concerns 22 registered with respect to the SDRD; I see concerns with 23 respect to SCP, that really don't have anything to do with 24 the engineering of this particular test facility.
25 And now if we have decided from the time that the Heritage Reporting Corporation
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[ 1 Title I" study was started and ended that we want the 2 ' facility to look somewhat different, that is perfectly all 3 right and that is'guite realistic, because that-is what 4 happens-as knowledge evolves and you learn more.. You.are 5 not satisfied with the original. I don't think anybody has 6 done any experimental program that-at the endLof it.they 7 could not have done it better than when they started.out.
8- So anyway that is the second part of it. And I~ ;
'9 guess as far as the engineering is concerned, there'is a-10' . question of where you put it'. It is a scientific decision
- 11. that has to be made by other people, and the architect-12 engineer is to be a form for this Title II study.
13 Now, the third part of it then is as.an integral
- 14 part of the repository system. And this is the area that 15 has not been very explicitly discussed in the SCP, but it 16 has been implicitly discussed there.
17 In examining that, again.I have tried to look at 18 it as a separate activity. If I were going to put thosc
-19 shafts down as part of a repository, if I were designing the 20 repository, I would design shafts that go into that and 1 21 would consider them in the light of the requirements, 22 whether they would impact or they had whatever impact that 23 10 CFR 60 calls out.
24 So you have 10 CFR 60 relating to the repository 25 and really nothing relating to the test facility.
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() 1 But you want to be-sure that nothing that you do 2 with respect to using those shafts and drifts and designing 3 those shafts and drifts, that you do for the test facility, 4 will make it unqualified for use in the repository. So you 5 have kind of negative norms I think at this point in time.
6 And I think those have been addressed reasonably 7 well. The writeup that I gave you, there is a reference to 8 that.
9 I don't see that the whole test facility, the 10 whole ESF, is ever going to be incorporated in the 11 repository.
12 The only thing that is really going to be 13 incorporated in the repository are those elements which
,r ]
14 pertain to the repository activity, and those are the shafts NJ 15 and the drifts.
16 It abuts the repository. The interaction area is 17 not going to be very large. Most of the facility is fairly 18 far removed in hundreds of feet or at least certainly tens 19 and 20s of feet.
20 So this gets back again to a sermon I preached I 21 think last time, the importance of looking at the system and 22 identifying or classifying that system in terms of how it 23 fits in, whether it fits in in terms of the safety aspect, 24 the 10 CFR 60 aspects, and so on.
25 I think that is really very important because I f Heritage Reporting Corporation l
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( 1 think if you look at that fairly carefully, you will find 2
i that a number of the comments which have been made really i 3 refer to repository design. And I would see that the only 4
4 thing after you are done with this test program or while it 5 is going on, you will have a certain set of equinment that l l
6 serves that purpose. You will have ventilation equipment !
7 and pumps and water removal equipment, whatever you have in >
8 there. It doesn't necessarily mean at all that is has 9 anything to do with what will be in there for the 10 repository. i 11 In fact, they say that most of the buildings are 12 going to be temporary during this design of I guess the ESF.
13 And once that is in place, then you start thinking about 14 what do I do in terms of the operational aspects. And the f-)
LJ 15 designers operated on a couple of assumptions which 16 apparently they were told to use.
17 One, you aren't going to have any waste emplaced 18 in there. So at this point in time you really aren't very 19 concerned with all of those aspects of 10 CFR 60 that relate i 20 to the safety, release of radioactivity and so on.
21 They also said that in terms of its use as a 22 ventilation system and so on, that it is not a critical item 23 because there are many other accesses.
24 It is one of four major accesses. So its failure l 25 would not result in a very serious effect. And again, I l
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56 l'\') 1 can't really understand how you would design a shaft very 2 differently from one that you were using as a repository, 3 part of a repository, or as part of a test facility. I 4 think mining people build good shafts.
5 So if I look at it from that point of view I 6 don't see a large involvement with the repository. And 7 again, looking at the SCP, it looks like they have 8 considered those interactions reasonably well, recognizing 9 that you do not have a design repository, so you do not have 10 much guidance on how you should be designing the parts of 11 this test facility.
12 A number of the comments really kind of relate to 13 that.
(} 14 I was looking at comment one here again. It has 15 to do with, the design should be capable of obtaining 16 information necessary to evaluate factors which bear upon 17 the time during which thermal pulses and so on, geochemical 18 characteristics of rocks. I think it is designed in there 19 to do that.
20 Now whether it is a question, is it as complete 21 as it should be, that again is a technical question and 22 relates back to me more to the design of the experiments or 23 the tests rather than the facility.
24 I am sure that you can build that facility to i 25 accommodate whatever tests you have. And it simply means g Heritage Reporting Corporation
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\; 5 57 j: I' 1 again, which is~one of the comments at'our last meeting, 2 that it is very important to try to define those' testo as 3 well as can be'done for Title II because that is where'you 4 are going to get the detail layout for that.
5 Again, here was another comment. This l 6 requirement is applicable because it; imposes requirements on 7 all components of the ventilation systems.
8 'And this again tends to think of this particular 9 facility as being designed for the repository. And when the-10 repository is designed, it is going to address those issues.
11 And all I think in the Title II design is you 12 want to be.sure that you don't preclude the use of those by 13 some dumb thing. I don't know what that dumb thing could 14 be.
15 Another one of these comments requires i 16 coordination of the subsurface excavation with the 17 geological operation area design and construction.
18 There again, you are presupposing design of the 19 repository.
20 Now what the architect-engineer did was, he used 21 the conceptual design for the repository and tried to make 22 the ESF conform with that in terms of its design. And that's 23 all he had to work with. He couldn't do anything more.
24 It talks about the general design criteria for 25 the repository operations in the area of instrumentation and Heritage Reporting Corporation
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I'T I k/ 1 control systems. And they say this requirement is l 2 applicable because it could impact ESF design by requiring 3 allowances for instrumentation and control systems.
4 This again gets back in my judgment to the design 1 5 of the repository. And what you put in there for the test 6 does not necessarily have anything to do with what you will 7 do later on.
8 So I guess the point is, and I don't want to )
9 belabor this issue, but I think you just have to be very j 10 careful in thinking about the functions of this facility and 11 then looking back. So it mhy be that even though there is 12 an appearance that a number of the 10 CFR 60 requirements 13 have not been considered, maybe at this point in time they
{} 14 don't have to be considered. And I believe that is the 15 position of the people that conducted the DAA.
16 These are all good precautions I think in terms 17 of Title II.
18 In going through, I am going to read something 19 here, because I want to get it right. And I am_not going
- 20 to, I think, spend any more time on this at this moment.
21 But in ganeral I do not believe that the staff's 22 objection and comment should be construed as criticism of 23 the authors of the Title I design.
24 Rather, staff's review has pointed out perceived 25 shortcomings which stem from a variety of sources:
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A 1[we O' u; A 59 1: .knowlddge available;now, but not when the design criteria 2 : were established; recognition of new characterization plan 3 needs; improved understanding of the test requirements; 4 desire to make provision for speculative activities; and of 5 course the inevitable + errors that do show up when'you get 6 into'a Title I design activity of this complexity.
7 The perceived' deficiencies in the Title I design 8- as it stands today probably reflect a change.in the rules of 9 the-game, rather than how the game was played. Through this 10 review process and that of the NRC and this' organization 11 here perhaps, these shortcomings have been identified for 12 consideration and correction where appropriate in the Title 13 II process.
( 14 So again, getting back to the blind men and the 15 elephant, it depends on what.you are grabbing ahold of, how 16 you look at the critter.
17 And don't put too much emphasis on the blind part 18 of it. The consultant is sensitive about things like that.
19 MR. MOELLER: In terms of the design 20 acceptability' analysis, and I guess the two are intertwined 21 of course.
22 MR. VOILAND: Yes.
23 MR. MOELLER: Now in the staff's comments, and 24 they had made these earlier, they point out that 11 of the 25 regulations in 10 CFR Part 60 were not even considered.
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k 60 L Now, what was your reaction to that?
(_jl 1 2 MR. VOILAND: I went back and looked at a number i
l 3 of those and to be real blunt I did not think they should 4 have been. I think you could read them and dismiss them.
5 MR. MOELLER: And this again, it ties into your 6 statement that this is really not a crucial part of the 7 repository?
8 MR. VOILAND: I think any of the 10 CFR 60 9 requirements, for example, that relate to radiation safety, 10 or radioactive safety, don't really apply, except that in 11 their consideration, the staff had said if it turns out that 12 you want to emplace waste down there, then these apply. And 13 that is perfectly legitimate. But that is speculative and g- 14 it does not go back to the original, one of the original b
15 criteria for the Title I, namely that we aren't going to put 16 canisters of waste down there. It addresses that 17 specifically. It says the only radioactive material we are 18 going to put in there are the test devices for well logging 19 or for logging the boreholes.
20 MR. MOELLER: What you are saying to me is the 21 shaft itself will not be used as a passageway for the 22 emplacement of the waste. Is that right? I mean, we know 23 that.
24 MR. VOILAND: Yes. That is speculative if it is.
25 MR. MOELLER: Yes.
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1: . MR. VOILAND: It wasn't'part'of the-Title I y s 2 Edesign as I look.into that.
3 MR. MOELLER: 'Well, maybe we should'let the staff 4 . comment-on this. Because what.you are saying, what you have 5 said may have's'ome-importance.
6 MR. VOILAND: I~think their points they_make are 7 good. 'But itLdoes not necessarily go back to the Title I 8 design as it stands and what: its intent was. And again-it L 9., may'be my. narrow approach to-that.
10 MR. MOELLER: Or interpretation.
11 MR. VOILAND: 'Yes.
12 MR. MOELLER: Well, I think we need to have this 13 clarified.
,14. MR. PARRY: Gene, I think you might want to 15: _ mention too, I thought'the etaff made a comment that showed 16 some concern in the area of the waste package testing that
- 17. in fact they thought it would be a good idea that they would 18 have full scale, that DOE would have full scale waste 19 -packages down there to test.
20 That would certainly override or put a different l 21 . view on your formula.
! MR. VOILAND: Well, it certainly would. Anything l 23 that you suggest that is different from the design basis for L
24 ,the Title I is grist for the Title II mill. There is no 25- question about it.
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(_) 1 If in the meantims we have changed the rules of 1
2 the game and said we are indeed going to put waste in, then 3 I think the comments are very much a point.
I 4 MR. MOELLER: Let's give the staff a chance to ) 1 5 help us maybe better understand this, f 1
6 MR. BUNTING: I am Joe Bunting. I am Chief of 7 the Engineering Branch.
8 I am going to make just a few clarifying remarks 9 maybe to help with the perspective, and then I will turn it I i
10 over to Dr. Gupta who is the team lead.
11 When we commented on the CDSCP and then met with ,
1 12 DOE, it became apparent then when we called out the 60.21 as 1 13 being one of the requirements for this consideration of the
,r] 14 design of the ESF -- And by the way, we are limited in our ,
R./ l 15 review to complying with 60.21. We don't have the j 1
16 flexibility to say we don't think it is important and I l
17 therefore dispense with it. j i
18 The 60.21 implies that there should be design 19 alternatives or alternatives to major design features 20 important to waste isolation, and the statement of 21 consideration goes on to explicitly state that openings to 22 the repository are considered major design features. j I
23 At that time, DOE acknowledged that they had not f i
24 considered the ESF as being subject to that and having any 25 bearing on importance of waste isolation.
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, if The importance of, the purpose therefore of the
>2' DAA, was to go back and show that even though they hadn't u,,
3 'done.it,-it would be okay.
1
-4 So that is the perception and thatLis-the 8
L :5' _ perspective in which I want you to look at our. review of the' L ~
L -6 SCP.and the' points that we have raised. We have held Part 7 f60 as the criteria to,which we evaluated and.our comments 8' .are very' appropriately, every case, directly-tied to a
- 9. section of Part 60.
10 With that, I am going to turn it over to Dr.
11 Gupta'to'take on any particular comment.
12 MR. MOELLER: Thank you, Joe..
13: MR. GUPTA: Dinesh Gupta, Engineering Branch, NRC 14' staff.
O.
15 I agree with Dr. Voiland that~many of-our 1Ei comments are based on the premise that exploratory shaft 1"7 - facility will eventually become a part of the repository.
18 And that is the angle we have taken in making many of these 19- comments in the SCP.
20 I will just read a basis for our making that 21 assertion from the Rule 60.15 which deals directly with. site 22 characterization.
23 60.15 (D) (4) particularly reads that the 4 24 subsurface exploratory drilling, excavation and in situ 25 testing, before and during construction, shall be planned Heritage Reporting Corporation
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k- 1 and coordinated with geologic repository operations, area 2 design and construction.
3 So that is the basis we are coming from. The DOE 4 has to consider that the exploratory shaft facility should 5- be planned and coordinated with the repository as it will be 6 eventually designed and built. And that is where we are 7 coming from, that is the basis that we have used for making 6 many of these comments. !
9 In several of our meetings with DOE in the past, 10 we have given DOE two basic guidance points as to how we 11 will be evaluating the exploratory shaft facility design.
12 Two broad objectives DOE should keep in mind are 13 that in constructing the exploratory shaft facility, the 14 waste isolation capability of the site should not be (v')
15 compromised.
16 And the second objective of course is to gather 17 all the data that is necessary to show that the site is 18 suitable and to be able to design the repository as it would 19 be found later on.
20 So those are the two broad objectives.
21 We have used the guiding criteria in our review 22 for the exploratory shaft facility.
23 With respect to the specific requirements, the 11 24 requirements. DOE has not considered Part 60 requirements.
25 I will just mention a couple of them for you, to give Heritage Reporting Corporation (e) j (202) 628-4888 i
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( l examples.
2 60.134, design of seals for shafts and boreholes.
3 DOE has not used that requirement as a basis for developing.
4 criteria for the shaft design. The requirement is obviously 5 applicable. DOE should be thinking in terms of longterm 6 sealing requirements, where to locate the shaft, whether 7 there are any features that they need to worry about in the 8 vicinity of the shaft facility, and how the ultimate sealing 9 testing might be required in the underground facility to 10 gather the necessary data for seals.
11 The other requirements, for example, the siting 12 criteria, 122. Those requirements have not been considered.
13 There are descriptions in 60.122 that deal with 14 basically the kind of information DOE should be developing 15 to show that certain adverse conditions are present or not 16 present.
17 And those requirements we consider to be 18 applicable for the ESF design.
19 And on and on we can go on to justify why they 20 should all be considered.
21 Now, I would agree with Dr. Voiland that after 22 looking at many of these requirements, DOE may come to this 23 conclusion, that we have considered these requirements and 24 our design would not be affected if we had considered these 25 requirements.
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()- 1 But our concern comes from the fact.that DOE has 2 not laid out these as basic requirements to start with, has 3 not' developed design criteria, and if they are already 4 incorporated in the current design, we would have no.
5 problem.
6 I think an analysis needs to be made to show us 7 that those criteria would not affect the design in any 8 significant way.
9 MR. MOELLER: Thank you.
10 MR. VOILAND: I really don't think we are very 11 far apart on this. It is just a question again of deciding 12 what you are going to do.
13 For example, all of these 60.131 items that are 14 listed in the comment are predicated upon putting waste
~
15 ' canisters in there.
16 If we decide that that is what is going to 17 happen, then that will affect the design.
18 So I think it is important though, in terms of 19 the ESF, to make some judgment as to what is really going to 20 affect the repository or how does it interact with the 21 repository.
22 They are what, 5,000 feet of drifts which are 23 going to be full of test and what have you. And I guess in 24 looking at that, I certainly agree with the importance of 25 knowing something about seals, because if at the end of this Heritage Reporting Corporation
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67 E - 1 , exploratory program.you want to now seal this all up, and 5 ~
2 essentially ~ isolate it as so it acts.as if it never existed,-
3 .you should probably know how to do that.
- 4 And I'certainly am not stating'thatLall of these 15- particular.10 CFR 60 requirements don't apply. 'Certainly 6 some do.
7 .Again, I would like.to get back to that idea of l 8 trying to classify.those items as to whether they are 1
9 important to safety or whether they are important to the !
10 repository or whatever rather than say the whole ESF isLpart 11 of this big ball of wax, part of the repository. I don't i
12 believe'that for a minute, don't believe it is going to be.
13 for a minute.
14 MR. GUPTA: Dr. Voiland, DOE has'taken a position
[
15 that the ESF facility will become a part of the repository.
16- These two shafts are shown in the conceptual l17. design for the repository as ventilation shafts. The long 18 drifts that DOE plans to excavate in different directions 19 will ultimately become access drifts. That has been shown j 20 in their conceptual design.
21 So we are not making that assumption. That comes 22 from DOE documentation.
23 MR. VOILAND: And I understand that. And that is 24 certainly addressed and very carefully I think, as much as 25 can'be, not knowing exactly what the repository is going to Heritage Reporting Corporation O. (202) 628-4888 ;
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2 But there are a whole lot of drifts that are 3 going to be used purely for experiments, that I don't think 3
4~ necessarily will become part of the repository.
5 I guess maybe my point is' single out that which' 6 is important, address that., rather than say that the whole
- 7. ball of wax is part of the repository.
8 MR. GUPTA: We also have to consider how the 9 testing area would interact with the repository, even though 10 the testing area itself may be used, and we don't know at 11 this time, for some of the tests that may be for performance 12 confirmation at a later date.
13 But how that area would interact with the 14 repository design, that has to be considered.
15 So when we say it will become part of the 16 repository, any penetration has to be considered as a part 17 of the repository, because it would in some way or the other 18 eventually interact with the repository.
19 The waste packages are proposed to be within 300 20 feet of the test area, within 500 feet of the shaft. So you l 21 cannot ignore that the repository would be placed in the 22 vicinity of the shaft or that the waste packages would be 23 placed so close to the shaft. And it is all eventually one 24 part of the whole thing.
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(.-) 1 proposed could change. So you have to consider that there 2 could be just a hole in the ground at this location.
3 And based on that assumption, you have to make 4 those comments based on what DOE has documented with respect 5 to the conceptual design at this time.
l l 6 MR. MOELLER: Okay. Any other comments on this 7 subject?
8 We will have time, of course, to come back.
9 Paul, did you have a comment?
10 MR. SHEWMON: Well, just for my information, I 11 guess I have a question of Gene.
12 In part of the words you used, which may not have 13 had ragulatory significance, you were talking about parts of 14 the plants that were essential for safety and parts of the
}
15 site, and parts that were not.
16 As you know, in the reactor business, this is a 17 sharp distinction they make. And I wondered whether any 18 such distinction was made here, that certain drifts or 19 certain parts would be essential to safety and others could 20 meet a lesser criteria.
21 MR. VOILAND: I guess that is kind of the gist, 22 Paul, of my comments, that I did not see that in there. It 23 was just a sort of total reference to the whole ESF as being 24 important, falling under 10 CFR 60.
25 MR. SHEWMON: But it is a matter partly of how Heritage Reporting Corporation O (202) 628-4888
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, ' j N- 1 J(ad 1- .the-regulations'are written. And my question is'do they ?
2 make~that distinction in the regulations now?
3- MR. VOILAND: Well, the only' distinction.that you 4 have is that you have a classification' process in. terms'of
.2
.5. the kind of goality assurance that.you apply whether you 6 classify these as level 1, 2 or 3. -And the architect- 1 7 engineers, the Title I designers,.apparently looked at this
-8 as not being sufficiently important c.o safety in general to 9 classify it as level 1.
10 If you look in the quality assurance manual, it k 11 has some general words_in there about what you: classify as 12 level 1, and, that is kind of the basis 12 my comments.
13 I don't read'into that that eve.y single item 14 down in that underground facility has to be cler,sified.in 15 ~that fashion.
l 16 And that again is why I am kind of insistent 1
17 about the idea of going-through and classifying these 18 things. At least you know where they stand. isenerally in 19 your reactor syste:4, I think, Paul, they go through 20 component by component and classify these as important to 21 safety or safety related, whatever ti..e term is. This is 22 also done in the kind of facility I was involved with, a 23 spent fuel storage facility, although thure are very few 24 things there because the risk potential is very small, as it 25 is again in the repository.
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71' n i l1 - -MR. MOELLER: - This, though,-lit is in a state of' 2~ flux with this facility because one of the basic arguments 3 is what goes on the Q list.
4 Well, things that are important to safety. But I~
b .5 no one has defined it. So it would help a lot of an answer 6 could be provided.
-7 John?
8 MR. GUPTA: Dr. Voiland, we have requirerants for 1-
[
9 .QA for < example that any' item that'is important te .v.fety or 10 importtant to waste isolation or any activities that are.
11 alluded to should be under a QA program that complies with 12 Appendix B.
13 Any penetration that is made at thic site could 14 be considered potentially important to waste isolation 15 unless shown otherwise by DOE by an analysis.
16 And that is the view we are taking at this time, 17 that unless DOE makes a case that these shafts and the 18 facility will not be important to waste isolation, they .j 19 should be treated as such.
20 MR. MOELLER: Well, and Paul, another difference, 21- and you have read it too, I am sure, another area of 22 controversy is to et, and I am paraphrasing this, but NRC 23 staff says put everfthing on the Q list, then prove that it 24 is not important to safety and you can withdraw it.
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(_,) ' 1 to safety before you put it on the list.
2 MR. VOILAND: I get the theme. Thank you.
3 MR. MOELLER: Okay. I think, Gene, one last 4 comment.
5 MR. VOILAND: I guess I would again go back to 6 the point of view that if one does a very kind of careful 7 and detailed safety analysis, or the probabilistic risk 8- assessment or something, this again will tend to identify 9 those items that really are.
10 There is some subjectivity here. What is the 11 penetration? The penetration is the penetration simply of 12 the shaft that goes from the surface, from outside down into 13 the repository area? Or is it every other darn thing down ew 14 underneath there?
N-]
15 MR. MOELLER: And I might mention, since Dr.
16 Okrent is here,, that subsequent to his raising the question 17 about a scoping study PRA three or four months ago, we have i
18 explored that and as what Gene just said, we think such a 19 study could be very useful in helping us identify what is 20 important and what is not important, what is crucial, et 21 cetera.
22 Dave?
23 MR. OKRENT: Since you mentioned --
24 MR. MOELLER: Move closer to the microphone if 25 you will, please.
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b 73 f ' 'd, 1- ' MR . OKRENT: Since you mentioned'the subject,
{b , 2 somewhere, and I am not sure where, I seem to.have gathered i . .
P 3: the-opinion that.the, staff may'think it is difficult to 4 develop a CrlDF'of this site.
S- is-that right?
6 MR. MOELLER: 'Yes.
7 MR. OKRENT: Have they said that, as'part of i[ 8 -testimony?
9 MR. MOELLER: 'I will let them repeat-it. Eut I 10 : understand they have.
11' Here we go again on the CCDF. Seth will comment.
12 MR. COPELAND: Seth Copeland, section leader for l,
13- Performance Assessment.
,q 14 I am not sure what particular statement you might
%)
15 be referring to, Dr. Okrent. I think that in general'we see 16 it being difficult to develop the CCDF really for any site.
17 It.is a difficult kind'of a standard to implement, the EPA 18 standnrd.
-19 I don't think that we see any more difficulty in 20 trying to develop the CCDF for the Yucca Flountain site than l 2:L other sites, at least at this point.
22 MR. OKRENT: Could I follow that up, then?
23 MR. MOELLER: Please.
24 MR. OKRENT: Again, looking back in history, when 25 the statutory review committee wns reviewing the draft EPA fs Heritage Enporting Corporation
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- 1~ standard,'one of.its very specific recommendations was that 1
'2 EPA should not employ the quantitative standard with'some I 3 probability,.some confidence of meeting the standard, unless F
4- it was prepared to show that this was a practical standard.
5 I guess the assumption is since EPA maintained 6 the standard in some form, with some minor chang 6s, either 7 that'it ignored this recommendation or that it thought in 1
'8- fact the standard could be implemented in_a practical way.
9 This question was raised to the NRC staff as'a-1 10 possible tangible roadblock toward getting approval. Not
.11 -that.one might not be able to develop a CCDF, but to get one 12 that al] agreed on,'is really, you could hire ten different-13 consultants and they will guarantee to come up with a CCDF.
14 That is not I think a problem.
15 But this was specifically raised to tl.r- NRC staff 16 some years ago when I was still a member of sor.ething called-17 the'ACRS, not this' illustrious committee. And the staff at
-16 that time assured the Commission, I believe, that this was a 19 do-able thing.
20 I in fact agree with what we just heard from the 21 staff that it is a difficult thing in particular to do it in 22 a way where you have some semblance of agrsement rather than 23 disparate assessmcats and I guess I was werdering if the 24 staff is moving tcward concern about this problem, whether 25 there is any way out. Or are you in the end at an Heritage Reporting Corporation
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(,) 1, impenetrable place with the current regulations, at or 2 almost, how much money DOE spends as carefully as they can f 3 to what the NRC thinks it wants them to do.
4 MR. COPELAND: I guess, as you've pointed out, 5 there is quite a bit of history associated with the EPA !
I 6 ecandard and some back and fokth between the two agencies.
7 In fact, when the proposed standard was issued 8 the etaff did question the implementability of the standard 9 from the standpoint of requiring a degree of quantification <
10 that we did not think would be practicable in real life.
11 The EPA put lenguage into the standard as a 12 result that in part came from Parc 60. I can't remember 13 exact language. But it is from I think 60.1t1, having to do g~) 14 with that proof that a reposit,ry meeta the standard is not
%)
15 going to be had in the ordinary sense of the word, that 16 because of the long time periods and the nature of the kinds 17 of processes and so forth, that you -just were not going to 18 have that kind of proof.
10 The other thing is that the standard put words in 20 that said "to the extent practicable" things should be 21 folded into a CCDF.
22 We thought that because of those two additions 23 that it probably could be implemented. And I guess in a !
24 sense we sort of saw the burden of proof as falling on us, 25 that we would have to show that it could not be. And the Heritage Reporting Corporation
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),/ 1 situation I think is that we would be able to implement it,
., '_ 2 recognizing that thers are going to be differences, that i
3 ;those are differences that I think would exist in any case 4 in attempting to' license a repository.
5 And I thirsk that the. staff considers that they 6 are not really exacerbated by the-standard or the way it-is 7 written.
8 451. MOELLER: Paul.
9 MR. OKRENT: If I could pursue it. If I 10 understood it correctly, you might be able to accept some 11 things where some scenarios were --
12' -MR. COPELAND: I think that it would have to be 13 dealt with more, a little bit different than what you are 14 describing, because you end up that you do have to make a-15 test-against the requirement that cumulative releases fall 16 below the limits that EPA specified.
17 But I think what you do get out of the wording 18 "to the. extent practicable" these things be folded into the 19 CCDF is a greater latitude in being able to show and 20 consider certain subjective aspects of scenarios in making 21 the showing that you would meet the standard.
22 MR. OKRENT: I get little solace from the 23 illustration I think -- The need doesn't help very much in 24 meeting the otandard, and that will occur time after time, 25 I'm afraid. And I don't see how you will be able to argue Heritage Reporting Corporation
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[ I well,..I'm going'to just allow a particular-scenario --'an'd'
'2L .'so forth'and so on. g
~3: It doesn'.t'have to be flat, I'm just taking an- i i
r t 4 eas'ily. visualized mathematical. representation.
5 MR. MOELLER: Paul Pomeroy.
6 MR.' POMEROY: I just wanted to say that I wanted 7 to go into this in some greater detail in a performance 8 assessment.
9 MR. OKRENT: I hope we come back to the topic
.10 more than once.
11 . MR. MOELLER: Surely. l 8
12 MR. OKRENT: It is not the first time I have 13 raised the topic around'this table. And I hope it is not 14 too late to get either the NRC or EPA changed, or both.
15 MR. MOELLER: Okay. With that thought, let's 16 take a'15-minute break.
17 (Whereupon, a brief recess was taken.)
18 19 20 -
21 22 23 24 25 Heritage Reporting Corporation O (202) 628-4888
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17 8 1 MR. MOELLER: The meeting will resume.. The next 1
- 2- item for discussion, and in fact we have three items between' w .,
Lg 3 now and-12:00, the next one will be' hydrology and geology. ~ l 4- Then we will take up performance assessment and finally QA. !
.x j't! ,
5 Dr. . Judith Moody will-be leading us in the discussion of 6: ' hydrology and geochemistry.
7- MS. MOODY: One thing I would'like'to know 8 whether or not the. critical things that I thought were a..
9 important in geohydrology and geochemistry, some key t 'U 10' particulars I was very concerned about. One of them of-11 course was the thermal, effects after' water emplacement must 12 .be evaluated for the total repository plus rock system 13 including,the subsurface hydrology of the Yucca Mountain
(~% 14 ~s ite. Let's go through these four things that I have got V
15' that are very important.
Let's start with the first one 16 that I have already mentioned.
17 What comment do you have in response to this 18 issue that I raised?
19 MR. POHLE: On thermal effects. Jeff Pohle of 20 the NRC staff. We do have a comment about the thermal 21 effects to the effect that it is an area that was not 22 directly addressed in the site programs through this 23 hypothesis testing table, et cetera, et cetera, and it was
- 24 an area that we thought needed to be put in there. So we 25 commented on that as an important topic or as an omission in Heritage Reporting Corporation
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(-) 1 the plan. It is the one item that I have heard you mention 2 so far. I do not know what the other three are. {
3' MS. MOODY: What are you doing about this one 4 then?
5 MR. POHLE: We do have a comment on that in our 6 package.
7 MS. MOODY: Can you remember what your response 8 was?
9 MR. POHLE: Essentially that it is important and j 10 it should be factored into the characterization plan. That 11 is the bottom line.
12 MS. MOODY: So that is what you are going to 13 recommend?
/~ ' 14 MR. POHLE: Yes.
15 MS. MOODY: The total number of drill holes 16 needed for the hydrology, geology, geochemistry and 17 geophysics still needs further identification for integrated 18 work to be complete.
19 Is there any comment on that?
20 (No response. )
21 MS. MOODY: In other words, this is something 22 that I have come up with several times. And that is exactly 23 how this work is to be done on the samples. The rock itself 24 and also fluid, how is the decision going to be made exactly 25 for each drill hole that you agree upon, how all of that Heritage Reporting Corporation l s) (202) 628-4888 )
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(f l' - 'different' material both rock and water is going to be used 2 by.the key people who need access for a multiplicity of 3- different things, especially the rock itself.-
, 4 tel. POHLE: I know in general that was discussed 5' by the geologists and they can discuss that in a minute. But 6 beyond what they have said, I generated an additional 7 comment that wo included in the package that dealt with'the 8 approach or the criteria that was used to determine the 1
9 number of drill holes to put within the conceptual perimeter 10 drift boundary.
11 And I think that there-were two points that I 12 raised in'this comment. First that based on some work that 13 was done and referenced, and that reference was not 14 available to the staff at this time, that it was determined 15 that for.at least two parameters, I_ guess taking some 16 samp19s from I forget which unit but I think that it might 17 have been the Calico Hills unit, that a correlation link was 18 derived presumably about 3000 feet, and that was based on 19 the data from those samples on porosity and air 20 permeability.
l L 21 So one point we raised is that we certainly need 22 to see the reference where that number came up. That would 23 be a basis for deciding how many holes, I think the total 24 number of drill holes needed, et cetera, et cetera. One 25 could take the point should that decision be made based on Heritage Reporting Corporation
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(-) 1 porosity or air permeability alone given all of the other f 2 types, again as you referred to the multi-discipline needs 3 from information from these various holes and samples 4 whether it is for rock strength or whatever, the program 5 areas.
6 I do raise a point related to that issue in that 7 a point was made in the SCP that those two parameters once ;
8 the spatial variability about those parameters was known 9 that in some way that that would serve as a surrogate for 10 estimating the spatial variability for whatever other 11 parameters are of interest. And I gather that that is not 12 an untried methodology, but I did raise the point that 13 somehow some type of a cross-correlation is going to have to
(~] 14 be demonstrated to defend that assumption, that the spatial C/
15 variability of other parameters, et cetera, et cetera would 16 be basically of the same nature as those.
17 I believe the logic behind that assumption was 18 that the tuff was laid down by the same process, 19 et cetera, et cetera, and that the variability of one 20 parameter dealing with a rock characteristic should be 21 somewhat similar to any other parameter. That was again 22 raised as a point as something that we would have to look 23 into in more detail and some work would have to be done.
24 Now that kind of leads you into that type of an 25 area dealing with the multi-disciplinary needs from data g~g Heritage Reporting Corporation
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(_)s i from the various bore holes, and the ultimate decision of 2 how many bore holes you need to satisfy each and every group !
3 for the various information, et cetera.
4 MS. MOODY: Go ahead.
5 MR. MCCONNELL: Keith McConnell from the NRC i 6 staff.
7 MR. MOELLER: Use the microphone. Some of the 8 people are saying that they cannot hear.
9 MR. MCCONNELL: Keith McConnell, NRC staff. I 10 think that we do have two comments in the package that 11 address your concern. One is the comment on the integrated 12 drilling program.
13 MS. MOODY: Right. That is very important.
(] 14 MR. MCCONNELL: Which does discuss the importance kJ 15 of a multi-disciplinary approach. And also there is a 16 comment which has been given a title of representativeness 17 or how many drill holes. It does not really address how 18 many drill holes is enough, but it does address the fact 19 that the SCP does not appear to put out a plan that will l 20 provide all of the information that is necessary.
1 21 MS. MOODY: That is very valid. I am glad to 22 hear that, because it does cover one of my other major
, 23 points that I have made in terms of the need for that.
1 24 MR. MOELLER: I guess, Dr. Moody, that you had 25 also asked at one point I believe last time for them Heritage Reporting Corporation
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(_/ 1 somewhere to state the maximum total number of drill holes 2 that they might consider or am I misinterpreting?
3 MS. MOODY: No. That is another way of 4 interpreting one of the key points that I made. I came back 5 when we were talking about geochemistry and said that 6 integration of all sampling by the hydrologist, geologists, 7 rock mechanics, geophysicists and engineering is required in 8 order to get the Yucca Mountain worked on in a timely and 9 good fashion.
10 In other words I do think, and this is just my 11 professional opinion, that you should try to minimize as 22 much as possible the total number of drill holes that you i 13 make especially the ones that are deep, that is as they go 14 through their repository horizon and right down to one of 15 the key units, in other words 3000 feet. And you have to in 16 terms of them being within the exact outline of what is i 17 going to be the repository area, that should be kept at as 18 much a minimum as possible.
19 And certainly the point that we have made that 20 further work needs to be done on the whole 200 miles outside 21 just the repository site itself. Because when you start 22 talking about the hydrology, you do have to have not only 23 considered the local, that is the repository area itself, 24 but you also in terms of putting it together in a reasonable 25 performance assessment you have to also know how the water
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So.you have to have ];
2 both; regional ~and local analysis of the site.and the area 3: surrounding the site in order to be able to get a reasonable ;.
4 assessment of what.the water is~doing both' surface and of 3
5 course: subsurface is very important.
6' And that.was my last point in hydrology. It was 7 that the. hydrology data should be collected both locally and' 8 regionally for the required ~ hydrologic modeling within-and 9 exterior to the repository site. At this' point in time I
- 10 did not think that.there was enough work being proposed in. l 11 terms of the total regional hydrology of the site. And you !
12 are going to'need that in order to be able to do a 13 performance assessment that means anything I think.
14 ' MR . POMEROY: Could I-ask a question?
15 MS. MOODY: Sure, go ahead.-
16 MR.-POMEROY: Just as a point of information, 17 there is of course a large body of drill hole information ,
l 18 available from the test site, and I wonder whether or not 19 all of that information particularly in terms ~of the 20' heterogenous nature of certain tuffs in the area is 21 available to the NRC staff and is it available to the DOE 7 22 MS. MOODY: Yes.
23 MR. POHLE: We do not necessarily have in our 24- possession at this time whatever drill records exist for 25 hundreds of kilometers away but looking at the regional Heritage Reporting Corporation O (202) 628-4888 i
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'l -modeling that has been done, the survey has done well 2 inventories and there are quite a few drill holes that are 3 certainly not only off the Yucca Mountain site into the test 4 site but outside of the test site itself. So that type of 5 work has been done and that information incorporated in what 6 regional modeling studies have been published.
7 MR. POMEROY: Thank you.
8 MS. MOODY: Have you gotten access to the L 9 information from the Nevada test site itself?
10 MR. POHLE: I think that John can speak to the !
11 prograss of that. We certainly have all published 12' materials. But one of the things that we have been working 13 on is gathering access to the various types of electronic 14 data bases that are going to be developed through the 15 program and that type of thing. That is something that is 16 in progress.
17 MS. MOODY: Because last time we talked as far as 18 I can remember, you had not gotten access to all of the 19 data. You were in the process of trying to get that access.
20 MR. LINEHAN: We have been told by DOE that all 21 of that data is available in the public reading room out in 22 Las Vegas at the DOE headquarters and it is available there.
23 It is a matter of us deciding exactly what types of 24 information we need to pursue getting.
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L(,) 1- -out and get some of the hydrology staff and.the geochemists t
2 out.to the site next month. And it relates to
.= 3 Dr. Hinze's interest in data management systems, who'is l
4 trying'to get some of our staff the first opportunity to go 5 out in the field and look at the chain of the data.when it 6 ,was collected at a given bore-hole and how it is transmitted 7? through'the system, just to observe that and have some 8 reconnaissance there to see how we could look into things 9 like that.
10 MR. HINZE: That sounds great.
11 Are you also-going to evaluate how much of the 12 log data is in digital form and,is into some type of a l 13 repository?
14 MR. POHLE: We are just trying to find out things 15 like;that by asking questions, just getting our feet on the 16 ground.
17 MR. HINZE: While we are on this point, I would 18 like to make certain that I understand. This 3000 feet 19- between the deep drill holes into the Tonapah Springs is 20 based upon a correlation parameter between some rock outcrop 21 investigations of porosity and permeability. I 22 MR. POHLE: Correct, in one formation.
23 MR. HINZE: In one formation in the Tonapah 24 Springs?
25 MR. POHLE: I am loose on that. It is either Heritage Reporting Corporation i
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0 87 h : 1 Calico Hills or the Tonapah Springs.
2 MR. LINERAN: Calico Hills.
3 MR. HINZE: It is the Calico Hills. It is really 4
more-important in. terms of the Tonapah Springs.
5 MR.JPOHLE: It depends on the type of information 6 ;that'youLare'after. From.our point of view, Calico Hills 7 may be more important. For the rock mechanics people, 8 Tonapah. Springs may be more.important.
.9 MR. HINZE: This 3000 foot separation are the 10 deeper holes that will pre.sumably go through the 11'- Tonapah Springs. That was my understanding of it.
12 Has anyone evaluated, I have heard several 13 references to this correlation study, has anyone evaluated 14 this from a statistical viewpoint within the NRC 15 organization? It:seems'to me that we are placing'a lot of
~
'16 emphasis on this information, and I am wondering about the 17 validity of it and the comprehensiveness of it, et cetera.
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18 MR. POHLE: Essentially what I said is the sum 19 total of.information available to us at this time. The name 20 and title was in the SCP but we do not have a copy of that 21 at this time.
22 MR. HINZE: Is it an open file USGS report? i I
23 MR. POHLE: I cannot honestly recall whether it 24 is a survey or a Sandia report. I will not even speculate, 25 because I cannot be precise.
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k,) 1 MR. POMEROY: I think that this is a place that I 2 would like to make one additional comment. We talked a 3 little bit last time about ground water time estimates based 4 on matrix flow. And there is a comment in the Edison 5 Electric Institute report that suggests that DOE address l 6 special attention to linking the site geohydrologic data to 7 the ground water travel time evaluation as soon as in as 8 much detail as possible to identify certain key issues.
9 And in regard to that, it seems to me that there !
10 are some experiments that have been inadvertently done in i 11 the course of drilling, particularly the USW-G1 drilling 12 fluid flowing to USW -- well, I do not know what the note 13 is -- I think that it is OZ-1 here. Anyway the second well 14 is some 300 meters away. That flow took place over a course b(~'
15 of a few years I believe. There does not seem to be any 16 relationship in the SCP of this kind of data to some of the 17 models that have been talked about. And I wondered if you 18 had noted that and also the drilling fluid loss from USW-G4.
19 Is that something that seems significant to you 20 in light of the EEI comment which I happen to agree with of 3 1
21 looking at the data that is around however poor it might be 22 to identify key issues at an early point in time?
23 MR. POHLE: There are a number of points that I 24 can make. I think that our primary concern in the drilling ]
25 fluid loss was first could it affect other plan testing, 1
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) 1 ' changing the in-situ state. Now in terms of the ground
.2- water travel time and'how that information would be useful,.
3: it is difficult to say. . We are trying to figure out. The 4 . ground water travel-time should be.a measure of the goodness 5 of the~ site as it exists. In that particular situation, 6 something like a third of.a million gallons of water was 7 introduced in<the system which is not normal.
8 . Clearly if you look at a well like J-13 and areas 9 to the east where let's say Tonapah Springs actually is in 10 the water table, and it is a very productive aquifer. If a 11 you could induce a tremendous amount of water, clearly it is 12 going to flow' rapidly. But probably the information that 13 would be more useful in trying to determine what the natural l 14 travel time is would be to look at natural isotopes right at 15 the water. table. And we do have a comment in this area l 16 saying that_is something that a natural tracer could give ;
17 you a better indication perhaps of what the true nature of 18 the time of travel is for water. And I think that is 19 probably'the type of information to deal with such an issue. j 20 MR. POMEROY: And I presume that there are 21 specific plans to do that kind of natural tracer study.
22 MR. POHLE: Correct.
23 MR. POMEROY: Between the existing wells perhaps, 24- is that correct?
25 MR. POHLE: Well, given the hypothesis that water I
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([ 1 2- place, it is easiest to take samples right at the water i 3 table. And if you see'the tracer in there that certainly
-4 tells you that there if there is something that was let's .
5 say generated based-on the testing thirty-years ago or forty 6 years ago, that'gives you the indication that obviously this 7 particular element has travelvd down'there in forty years, 8 and the conclusion is pretty obvicus. And the next question 9 is.how much mass is moving and take that in relationship to 10 the release' standards given that one part of 113'that was 11 referenced earlier by Dr. Voiland I believe.
-12 MR. POHLE: Those items that will be considered.
13- Certainly in'the unsaturated zone too trying to establish 7p? L14 techniques to get water out of an unsaturated rock. And
\m/ ~
15 then'once you have that, to try to do various chemical 16 analyses on it, on what the chemical constituents in thel 17- Ewater are.
18 MR..POMEROY: What about the alternative model of 19 horizontal flow, significant horizontal flow?
20- MR. POHLE: Other than the obvious if you came 21 across the perched water zone, where if you have that 22 clearly is going to be a horizontal component, it is hard to 23 see what one could observe there that would tell you that ,
i l 24 there is a large horizontal component other than an attempt j I
25 to do it through a calculation or a modeling simulation.
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1 MR. POMEROY: Well, presumably if you did not 2 penetrate the saturated zone with a drill hole in any case 3 and you observed drilling fluid in some other well at some 4 distance away, that would be a measure of the horizontal 5 flow.
6 MR. POHLE: That is certainly an observation that 7 given certain conditions that you can get significant 8 movement laterally, if you can induce some given amount of 9 water.
10 MR. POMEROY: Thank you.
11 MR. MOELLER: Go ahead, Dr. Moody.
12 MS. MOODY: That is no problem at all, because 13 those are key questions at this point in time. There is no i
(~s 14 easy answer even how to actually measure them in the field.
G]
15 It certainly is non-trivial. I also made a comment about 16 the fact that if in fact and this is true that some of your 17 major holes, although we may not agree as to how many are ;
l 18 actually going to be down to 3000 feet below the repository 19 horizon, but it is certainly true that if that in fact is 20 going to occur that you need to sample your water as well of 21 course as your rock as you go below the horizon, the water 22 table itself. ,
1 23 So I made that comment as something that needs to 24 be done and the question is do you think that it will be !
25 done for those drill holes that are quite deep below the Heritage Reporting Corporation t7_s) s- (202) 628-4888
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k/ l : repository horizon, are the water samples going to be:
2 collected?
- 3. MR. POHLE: Yes. We made a comment that normally 4 we probably would not have.made as being'a little
'5' -technically too detailed. I think that we were thinking.
6 along the: lines that you drill a hole and you hit the water 7 table and' start collecting, samples during the drilling 8 operation rather than waiting until the hole is completed 9 'and going back in there and packing off, you know, doing 10 something like that'in. addition to because of the problems 11 1 of packer leakage. Just more experimental or field =
12 techniques that may be helpful in putting together a better 13 quality. data base.
(~ 14 .The only reason that we made that comment should
(>g
.15 ' the. holes all be drilled before having an opportunity to 16 review a study plan, it.was appropriate to get that little 17 suggestion out.
18 MS. MOODY: Well, given that we come back to 19 another fundamental issue that I raised, and that is what 20 kind of methodology or is DOE stuck with the methodology 21 that they were using to actually drill the samples, has 22 there been any change or are they going to stick with the 23 dynamite and water. You know, what is important is how do 24 you get a relatively clean sample or natural sample of the 25 water that has not been contaminated by the drilling process Heritage Reporting Corporation
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( j' 1 itself, or is that a comment that you have made and it is 2 still there or what?
3 MR. POHLE: Well, that particular construction 4 methodology would have been for the shaft. In terms of 5 drilling the normal well, I do believe that there may be 6 some comments made by the engineers. They are going to 7 attempt to do dry drilling and they are also going to do 8 some prototype experiments on dry drilling. In fact some of 9 those may have started in Utah already I have heard. I do 10 not have anything on paper on that. No matter what you do 11 there is going to be a price to pay.
12 Now back some years ago, perhaps as many as four 13 years ago, we discussed with DOE the problems of all of this 14 drilling fluid that was lost. And it was wetting everything
\()g 15 up and you are trying to find out what the in situ 16 properties of the area were. And that led to trying to find 17 some other way, changing the drilling technology and not to 18 use so much fluid. And that gets them into the dry drilling 19 mode. But now when you talk of dry drilling, you will have i 20 a new group of people concerned that that is going to dry 21 the core out.
l 22 So part of this technology I believe in some 23 presentation that may be given to the ACNW or back when it 24 was ACRS about putting the plastic on the core when it comes 25 out and all of this to try to not let it dehydrate. So the Heritage Reporting Corporation
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(_) 1 piper is going to have to be paid one way of the other.
2 Nothing is going to be perfect on this thing. I see no 3 other alternative.
4 MS. MOODY: Let us move on. Is there anyone who 5 wants to comment on the hydrology of the site?
6 (:No response.)
7 MS. MOODY: We will address it further in 8 performance assessment.
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We.will address it further in 2- performance assessment. Of course it is a very key and I
..E 3 importrant point.
4 i MR. POHLE: I would like to make one' point before i
'5 the subject.
6 MS. MOODY: Go ahead, sure.
7 MR. POHLE: That is perhaps in the future if 4
8 Doctor'Hinze way have an interest in getting to the 9 statistical analysis parameters'and that, but there bares a 10 relationship to that when one seeks to deal with the
- 11. statistical variation of these parameters across the site.
- 12. Couple that with the issue raised by the geologist that the 13 number of drill holes, that the decisions need to be 14 integrated based on the information needec* by all of the 15 disciplines, and couple that with the concern about the 16 number penetrations at'the site, i
17 That is another problematic area of catch-22. To 18- recommend a rigorous statistical approach in determining the 19 number of sample locations that you need for each and every 20 parameter, inevitably is going to drive you to more and more 21 holes, the application of that methodology, so be prepared 22 if that is a particular item of interGet to be recommended.
23 That is where that recommendation leavee you. I have 24 nothing, no more.
25 MS. MOODY: I know a meeting that is non-trivial, Heritage Reporting Corporation (202) 628-4888
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. 1 and there is no easy answer to that at this point. If I i 2 remember correctly, we know have planned within the 3 repository itself what is a nine or an eleven holes that, 4 you know, penetrate, go all the way down, and can be used l 5 hydrologically for testing. So some would say that is more 6 than adequate.
7 MR. MOELLER: Yes.
8 MS. MOODY: But we don't know until we actually, 9 you know, drill the holes and start trying to sample whether 10 or.not it will be adequate, and how do you collect 11 uncontaminated samples, non-trivial bo'.h in the unsaturated 12 and the saturated zone. Anything more in the hydrology, any 13 other questions that anybody wants to address?
r 14 MR. MOELLER: Apparently not, go ahead.
15 MS. MOODY: Okay, let's move on to Geochemistry 16 then. I had several points that I made - presented last 17 time, and one of them is the possibility or the probability 18 that we already know, is that the Yucca Mountain site is 19 itself heterogeneous, therefore DTL work is going to need to 20 be done on every core sample, hopefully you'll have a bit 21 more success that it has been in the past.
22 In terms of getting an actual rock sample, 23 because there had been an actual practice, I know, some very 24 difficult problems at different times, so that heterogeneity 25 we know is there, but actually demonstrating with real Heritage Reporting Corporation
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2 water samples, especially in the unsaturated zone. It is 3 non-trivial, very difficult, I know. Paul, did you have any q 4 questions?
5 MR. SHEWMON: Yes, I just wondered on what scale 6 are you talking about when you say the heterogeneity? Is l 7 this the fact that there is different strata, or the fact 8 that under a microscope, or what?
9 MS. MOODY: All of the abmre.
10 (Laughter.)
11 MR. SHEWMON: Okay.
12 MS. MOODY: And it is not that unusual for 13 volcanic rocks to have that heterogeneity.
14 MR. SHEWMON: The strata stratigraphy and how it 15 affects water flow down through the site, I can understand 16 why that heterogeneity would be of interest, but what is 17 under a microscope, why do we care about that heterogeneity, 18 or I would think there would be some cutoff size below which 19 it would be just as easy to call it homogenous and quit.
20 MS. MOODY: Well I think what you are seeing from 21 Judith Moody, is my prejudice, because I have such a strong 22 background in mineralogy and petrology, and so what you 23 would call homngenous, I would probably wouldn't, but I can 24 understand engineering wise why somebody might consider 25 something to be homogenous, whic.h in 'ny view it isn't. It Heritage Reporting Corporation
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) 1 is how you wish to define'the rock itself.
l 2 MR. SHEWMON: Well you are right, I would 3 approach it as an engineer, and say when does this g 4 heterogeneity bother me, and if it doesn't influence what I 5 am.trying to do, then-I can assume it is homogeneous, and if i
6 I have -- you know, if I want to know what ions are going to I 7 be in the water when it comes past my waste container, then 8 probably microscopic heterogeneity doesn't influence.
9 I can put it into a beaker and see or they can, 10 and see what comes out. Whether the water comes down there 11 or flows by quickly, or something else, that kind if 12 heterogeneity would impact the performance.
13 MS. MOODY: Yes it will. See the other thing is,
~S - 14 and it is one of the suggestions that was made through even J
15 DOE is the fact that we not only got the primary minerals, 16 but we also have secondary mincrals which are zeolite, and 17 certainly that needs to be looked at in greater detail that 18 it has in the past, and they have completely differ at 19 mechanical thermal properties out in comparison to the 20 volcanic material itself.
21 So moving on with other aspects of geochemistry, 22 is we certainly -- one thing that has been talked about just 23 a bit, but you have to consider the site itself when you 24 talk about waste in placement, you are definitely going to 25 have thermal effects which we can talk about gas release Heritage Reporting Corporation
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l 1 with a couple of important gases that might potentially be i 2 released, and which are going to have to be looked at in 1,
l 3 terms of the maximum temperature that you propose in the 4 repository itself.
5 So this has an effect also on the radio nuclide I 6 migration, the potential radio nuclide migration. It is the l 7 thermal effect that you are going to have once the waste is 8 in place itself.
9 Of course another major point that I made is that 10 each radio nuclide must evaluated for its potential 11 migration properties, given a specific mountain site 12 geoc hemistry after waste emplacement.
13 There are key radio nuclides -- each one has to f- 14 be looked at individually as to how it's going to react to
(/
15 .the geochemistry and the thermal effects that we can expect.
16 Then one of the other issues that I made, and this is again, 17 something that can be argued. i 18 Usage of KD's, because of modeling is not valid 19 from any radio nuclides, and that is when I said each 20 element must be determined individually for coupling input 21 into the hydrologic and geochemical models, so element by 22 element you are going to have to sit down and figure out how 23 that element is going to behave through potential release 24 from the spent fuel rod itself.
25 One issue that was also raised at one time is Heritage Reporting Corporation
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t 100 fa () 1 thermal dynamic properties of specific. minerals need to be
,2 defined, and that is especially true'for the zeolite, 3- minerals of themselves, but then you can't -- most thermal-4 dynamic data is used in the geochemical modeling, ascoming 5 that equilibrium or you can use EQ-6 which has a reactive.
6 progress.
7 It'is certainly true that in the site itself, you 8 are not going to have equilibrium, just simply because you-9 can look at it just as the effect that in placing the spent. l 10 fuel, and its temperature, and potential corrosion of the 11 waste package itself, and some potential release of the
- 12- radio nuclides.
13- 'In order to give an assessment of the radio 14 nuclides themselves, in case there is cracking or water, O 15 gas, whatever, to get out, that is a fundamental problem. .I 16 mean there is some occasions where because the waste-l 17 emplacement _is above the saturated zone, that to discuss 18 radio nuclide migration in terms of EPA standards -- meeting 19 EPA standards, there is a certain number of people in the 20 program that say, you know, the. packages are not going to be 21 penetrated because.there is very little fluid, therefore we 22 really don't have to worry about radio nuclide migration.
23 But you can not assume it. You are going to have 24 to try and address it as best you can. And of course 25 something that we have already talked about is you can't Heritage Reporting Corporation
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(_/ 1 really talk about corrosion and possible penetration until 2 we know what the waste package container -- what kind of 3 material it is going to be. ,
I 4 So until that is actually chosen, it is difficult. '
5 to address this problem of potential radio nuclide migration 6 unless you do it just in a general sense. Then we get back 7 again to the KD issue, and just how much information you get 8 from batch absorption studies.
9 I said that batch absorption studies are i
10 inadequate, and that is just my opinion. You can -- if you 11 actually do all of the potential component parts, I know 12 that there is a theoretical model that you can define for i 13 the KD that is composed of nine or ten individual parts, but
~N 14 whether or not each one of those individual component parts (d
15 will be determined element by element is, you know, a major 16 issue in terms of the absorption studies.
17 So it becemes very important, and radio nuclide 18 migration is, and I think that we address later on is how 19 you can then combine the hydrologic and geochemical computer 20 codes to get perform an assessment, an important assessment 21 component to the total systems performance assessment.
22 So those are very difficult areas, and there 23 isn't any necessarily easy, straight forward answer to how 24 you are going to actually model the potentially radio 25 nuclide migration. It is something that is going to have to
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1 be done, but it is not an easy task.
2 MR. MOELLER: Okay, thank you. I think you have 3 set the stage to smoothly move into performance assessment, 4 and Paul, why don't we do that, and have you report on it.
5 MR. POMER7;: Fine, Mr. Chairman. I would like 6 to make a few specific comments, but I would like to spend 7 the majority of my time looking at the question of whether 8 or not, given the plan as outlined in the SEP, whether or 9 not one can qualify under the EPA standard.
10 I will make two comments while the NRC staff in 11 being seated. One, I would like to echo Doctor Hinze's 12 comment this morning with regard the question of data 13 acquisition and data utilization, and the possibility that
,- 14 data or certain information is going to fall somewhere t
15 between the cracks I believe. Between the study plans and 16 the site characterization plan.
17 Again, quoting from the EEI comments, the data 18 utilization phase which will be the more difficult, and that 19 certainly is an understatement, has not been given adequate 20 attention, and that is reference to the SEP, and I believe 21 that both of those particular clauses are pertinent here.
22 It simply has not -- the data utilization phase 23 has not received the attention that it should have in the 24 SEP. I don't know whether that is covered by the study 25 plans or not.
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1 1 The second comment that I wanted to make was in
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2 regard to timing, and~again I would like to quote from the 3 EEI. That is any possibility, however remote, that the site 4 could be found unsuitable are unlicenseable, should be 5- addressed'as early as4 possible and not after years of-6 characterization work in the expenditure of billions of 7 dollars.
8 To guard against such an outcome, DOE should 9 conduct its. site characterization program in a way so as to 10 provide an early warning of any factor or set of factors 11 indicative of fundamental site unsuitability.
12 It is that priority question and the timing of 13 performance assessment that arising again and again with 14 practically everybody who reviews this work. With that as a O 15 background, and with the idea that performance assessment is 16 after all the fundamental tool for determining the 17 suitability, I would like to turn to that question.
18 I would like to address a question to the staff 19 in the context of the SEP. A plan is outlined in the SEP, 20 Could you outline again your concerns and the reasons for 21 your concern in more than one area that led you to the 22 statement that DOE may not be able to qualify the site?
23 MR. EISENBERG: Well perhaps one of the first 24 concerns is the linkage of poor performance assessment to 25 ongoing site characterization, and the fact that for total Heritage Reporting Corporation
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) 1- system performance, the first performance assessment would 2 take. place in 1993, very close the time that the final 3 ' phases of- site characterization, and preparation of license 4 application.
5L It is not clear that at that point there1would be 6' sufficient time for feedback from the analysis and from the
'7 performance assessment to help guide the final acquisition 8 of data required to have a successful license application.
9 That is certainly one concern. There were 10' concerns with regard to the scenario analysis. The
~11 ~ scenarios proposed in the SEP as a guide to site 12 characterization had some problems because the scenario 13 classes that were defined to be used in performance 14 allocation did not correspond to the mathematical-
~0 15 definitions of scenarios and scenario classes used in the 16 development of the methodology by which DOE proposes to 17 demonstrate compliance with the EPA standard.
18 So there is certainly the potential that the data 19 that would be gathered during site characterization would 20 not fit in with methodology that is going to be used. There 21 was some other problems scenario-analysis.
22 Another problem was that human intrusion was 23 indicated as not being included in the CCDF where as the 24 standard as it stands.now, and the NRC staff interpretation 25 of it is that human intrusion should be included in the
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() 1 CCDF.
2 There were problem with the treatment of 3 alternative conceptual models. One of the concerns that DOE 4 obviously spent a great deal of effort in thinking in 5 responding to a CDSEP comment was to have a more aggressive 1'
6 clear treatment of alternative concepts to the preferred 7 concept for the performance at the site.
8 They have developed a set of hypothesis testing 9 tables in which they articulate the current representation 10 and alternatives to that representation, and then identify 11 tests that will help differentiate between the current 12 representation and the alternatives.
13 However, there were a number of -- a great many 14 of different kinds of anomalies, and what appear to be O 15 unclear places in those tables, running anywhere from what 16 appears to be, although it may not be, but it appears to be 17 some degree of inconsistency in the progression from 18 information presented in the tables to the conclusion as to 19 the importance of the studies that are proposed to 20 differentiate between alternative conceptual models.
21 Other problems are that some important 22 alternatives have not been proposed or treated in the 23 tables, and in some cases it appears that the studies that 24 are proposed to differentiate among alternatives will not be 25 able to do so.
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() 1 They will just not gather the kinds of data that j I
2 will permit that. There are problems in the performance l I
3 allocation, especially for total system performance, and for !
4 some other of the performance requirements.
5 In the case of total system performance, the big 6 problem is that the confidences and the parameters, and the ;
7 confidences for them chosen in the performance allocation 8 tables did not appear to be consistent with the mathematical 9 development for the CCDF, and again it is not clear that the 10 testing strategy based on the performance allocation will 11 permit resolution of the issue and construction of the CCDF.
12 MR. POMEROY: It certainly isn't clear to me 13 either. It is in the totality of all of these concerns that 14 led you to the statement that basically they may not be able 15 to construct a CCDF in a total system, is that correct?
16 MR. EISENBERG: That is in general correct, 17 although I think some concerns are more important than 18 others.
19 MR. POMEROY: Right, and could you just point 20 those out to us, or to reiterate them?
21 MR. EISENBERG: One concern in particular is that 22 the formulation used for the CCDF proposes a joint 23 distribution function which is to describe the behavior of 24 the parameters which describe the state of the system for 25 all time, and these joint distribution functions are to be Heritage Reporting Corporation
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's) 1 developed based on site characterization data.
2 It is not clear to me that this is a practicable 3 way of approaching the problem, in that one will be able to-4 develop these joint distribution functions based on the 5 kinds of data that I would anticipate would be obtained 6 during site characterization.
7 However, let me try to make very clear that this 8 does not mean that it is impossible to generate a CCDF based 9 on site characterization data, that there are other 10 approaches.
11 There are approaches based on defining scenario 12 classes which are mutually exclusive and obtaining 13 probabilities for those scenario classes, generating
(^T 14 parameters that describe the behavior of the system for V
15 those classes, and then combining those, one can get a CCDF.
16 The NRC contractors have used that approach in a trial way 17 to demonstrate a generation of CCDF's for hypothetical 18 sites.
19 MR. POMEROY: Right, that was really the point 20 that I wanted to emphasis in fact, that it is certainly 21 possible to generate a CCDF. It seems to be or appears to 22 be very difficult within the framework of the SEP.
23 I believe that one of your comments dealt with 24 the question specifically that the DOE should consider a 25 reevaluation of the scenario analysis, and in fact, I Heritage Reporting Corporation
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([ il believe you'said it should be redone,-and I concur with that 2 whole heartedly.
3 I think it is a very important thing that we have
~
4 a site characterization plan that is usable for determining 5 the suitability of the site. . I believe that -- I hope the 6- committee will note that it is extremely important to make 7 that point that --
8 MR. OKRENT: May I ask a question?
>t 9 MR. POMEROY: Surely, go ahead.
10 MR. OKRENT: Does the staff think that there is a; 11 practical test program that can provide adequate information 12 concerning the significance characteristics of the site to 1
13 the point that expert judgement becomes a minimal thing, and 14 you have an evaluation based on empirical information-and a O' 15 fairly well grounded equations and so forth.
16 It may not be what the DOE is proposing, you 17 know, it could be something that the staff is proposing, or 18 your center is proposing. Could anyone do is what I am 19 asking, in the, let's say in the next seven years with the 20 resources -- or twice the resources that we are talking 21 .about?
22 MR. EISENBERG: I believe that one can obtain a 23 very large amount of objective data that can be used to 24 define the site and its behavior and to describe the rates 25 of ongoing geologic processes, and the probability of Heritage Reporting Corporation l
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~2 I believe that information can then be used, and 3 this subject has been discussed before this committee 4 before, and maybe it gives me an opportunity to maybe 5 restate what I-meant to say before.
6 I believe that expert judgement will be used in 7 the interpretation of.the data and certainly in the 8 obtaining of the data, but I believe that there will be --
9 there is an opportunity to obtain objective data which will 10 form the basis for the application of the information to
,i 11 generate a CCDF which will describe the performance of the 12 site.
13 MR. OKRENT: Well, I am a little bit skeptical 14 about your statement getting data that will enable the
'O 15 generation of a.CCDF that describes the performance at the 16 site.
17 You earlier indicated in the discussion with 18 Doctor Pomeroy, that there was a need for more scenarios, 19 and between the two of you, suggested that maybe if one had 20 these scenarios that one could then orient the -- to test 21 the program so that it would help - provide more 22 information on the scenarios. Those are my words.
23 Do you think that in. fact, it is possible to ever L 24 have a complete set of scenarios, in other words, that you f
25 can generate a set that no one other person cannot challenge Heritage Reporting Corporation
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r-( ,/ _ 1 and say here is one at the moment that yours is equally 2 likely or unlikely as the case maybe, and secondly, do you 3 really think that with any test program you.can get enough 4 information that in the end it isn't expert judgement that 5 is playing the key role on most scenarios?
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() 1 MR. EISENBERG: Well, I think that as an axiom of 2 risk analysis that it is impossible to assure that all 3 scenarios are included in the analysis, because human beings
-4 are not capable of predicting the future. So I believe that 5 one ennnot assure that you have them all. I think that what 6 you can do however is provide a reasonable level of 7 assurance that knowledgeable persons have examined a set of 8 events and processes and from them have derived what appears 9 to be a complete set of scenarios. This does not mean that 10 some future event might not lead to some other scenario, or 11 in all likelihood many sets of scenarios.
12 But that is the limitation of a risk based 13 approach and in fact any kind of approach I believe that 14 would try to describe the performance of a system that has 15 to operate for ten thousand years into the future. It is 16 just beyond the capability to provide absolute assurance 17 that everything has been considered. I think that we can 18 however provide a reasonable level of assurance so that for 19 the purposes of making a regulatory decision that one can 20 decide one way or the other.
21 MR. POMEROY: I think just to add to that. I 22 think that I agree with what Norm said, but I disagree with 23 what I read in the SCP. That the final definition of the 24 five scenario classes in the SCP does not give me the 25 confidence that we have begun to address all of the possible Heritage Reporting Corporation
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, ~1 scenarios. And I would like to see that much more 2 explicitly stated if we are going to utilize this 3 methodology.
4_ MR. EISENBERG: In terms of your second question,
~
5 I believe that there are two kinds of data that need to be 6 gathered from the site characterization program relative to 7 the generation of the CCDF. One type of data relates to the:
8 ' occurrence of ongoing geologic processes as evidenced by the 9 . geologic record and the frequency of events that have'
'P 10 occurred in geologic time. And this information will be i 11 used not alone but in association with various theories of 12' how these geologic processes occur to develop the rates and 13 the frequencies for the occurrence of various kinds of 14 scenarios. That is one kind of information.
15 The other kind of information that is needed is 16' parameters that describe the behavior of the system. What 17 the existing hydrologic regimen is and information that 18 would enable to conclude for example given a certain size 19 fault in a certain area what changes would that induce in 20 the hydrologic system, because it is that information that 21' is needed to determine the consequences of the various 22 scenarios.
23' I believe that both kinds of information can be 24 obtained and that the level of expert judgment or the 25 involvement of expert judgment cannot be eliminated, but I t
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(j 1 believe that the range of argument or the range of 2 discussion over what the evidence means can be greatly 3 narrowed over what exists today. And I guess that I also 4 believe that this is exactly the kind of discussion about 5 interpretation of facts that has occurred in the licensing l 6 of nuclear facilities for years.
7 MR. POMEROY: I think that we are probably 8 running out of time here. So I would like to cut this 9 discussion short. But I would just like to say that I do 10 not see this concern raised in Section 2 of the director's 11 comments. And it seems to me that it is not a fatal flaw of 12 the site, but rather it is a serious flaw in the plan and I 13 would like to see that emphasized.
14 MR. MOELLER: For evaluation?
\
15 MR. POMEROY: Exactly.
16 MR. MOELLER: Thank you, Paul.
17 MR. POMEROY: Can I make one final point?
18 MR. MOELLER: Sure.
19 MR. POMEROY: I believe that performance 20 assessment is going to assume a greater and greater 21 importance as we move further into this entire evaluation. ;
22 I think that the NRC staff recognizes that and I think that 23 they are moving according to the MOU that we have to 24 establish an in-house capability in areas where there might 25 be potential conflicts of interest outside. I would hope Heritage Reporting Corporation
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4 believe performance assessment is going to require. '
5 I am not optimistic about changing the EPA 6 standard immediately, although I may be wrong about that.
7 So I believe that we should move ahead thinking that we are 8 going to have to conform to that. And it seems to me a 9 development of enhanced capability in-house with the NRC 10 staff would be important in that role. Thank you.
11 MR. MOELLER: Thenk you. I appreciate, Paul, you 12 shortening your presentation. As we note by the clock, we 13 are running behind. We have however only one topic 14 remaining before the lunch break and that is quality f-)
(J 15 assurance.
.16 I think, Gene, that I would say go ahead with 17 your presentation, but keep in mind to highlight I think 18 areas of disagreement.
19 MR. VOILAND: It will be brief, because I do not 20 really have much to add to what was said at our least 21 discussion of this. We looked at the quality assurance 22 objection, and I generally concurred with the staff's 23 position on that, that they should follow that. And maybe 24 they have some further information about filling the 25 positions that are associated with quality assurance.
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() 1 MR. KENNEDY: Jim Kennedy. I am in the QA 2 section with the NRC staff. In the past couple of weeks, 3 DOE, the Nevada project office, the Yucca Mountain project 4 office, has appointed the former deputy director of the 5 project office at Wilmont to be acting QA director for the 6 indefinite future. They do have a posting I understand at 7 Wilmont, but he has taken over that position and is expected 8 to be there for six months or something like that at least.
9 MR. MOELLER: Excuse me, be there within six 10 months?
11 MR. KENNEDY: Something on the order of six 12 months I understand.
13 MR. MOELLER: Thank you.
- 14 MR. KENNEDY: He has also made a number of 15 changes already. He has only been on the job a couple of 16 weeks but he has reorganized and has just made a lot of 17 changes.
18 MR. VOILAND: Has there been any solution to the 19 problem of filling the job permanently? I know that when we 20 discussed this before that there seemed to be some general 21 difficulties about getting somebody to the site under the 22 present circumstances of position and what have you and 23 salary.
24 MR. KENNEDY: They do have a posting I 25 understand. It has been raised a grade. It is a Grade 15
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() 1 position now out at the site which is a very high grade for !
2 that kind of job, and they are looking for someone.
3 MR. MOELLER: In this regard, of course we have ;
4 discussed and we did it last time whether we should, and in 5 fact we have even said to the NRC staff that instead of 6 looking at whether the positions are filled that you ought 7 to look at whether the program is adequate. And yet I am 8 not so sure that we are correct in that approach, and it is 9 obviously something that we can discuss this afternoon.
10 Several of us referred to the EEI report, r.nd I think that 11 anyone who has read it would be very impressed with it. And 12 they emphasize the importance of filling these key 13 positions.
14 And I guess with Paul Shewmon here if you look at ]
15 a nuclear power plant, you could say we do not care whether 16 are any operators in the room or not as long as the plant 17 operates, you know hums along and produces electricity.
18 Well, we do care about the people. And in fact we even not 19 only care about how many are there but their training and 20 qualifications, et cetera. So it could be, and I do not 21 want to say that we were off base in what we have said i
22 previously, but it could be that we did not really say what 23 we meant or something. But we certainly will discuss that 24 this afternoon. Go ahead, Gene.
25 MR. VOILAND: I think that is fundamentally Heritage Reporting Corporation O (202) 628-4888 1
'l J 117 1 important and'I think that it is worth di'scussing. I would 2 agree.with that. On the comments, I did not have anything 3 different'to say than I did in the past. I took another j 4 look at the design' acceptability analysis, particularly the 't 5- QA comment to that. And I guess that I generally keep j 6 coming back'to this issue. I guess that I am like Cato with 7 respect to Carthage about the importance of classifying '
_l 8 things. I just think that unless you get that sort of- ]
9 straightened out that you are always going to run into these 10 kinds of conflicto.
11 And I do believe that it is important for o
12 guidance to come out with respect to all of these different 13 contractors to be sure that they are all moving in the 14 quality program in the same way. It is probably less 15 important I think for the office to have a big super plan of 16 its own than to be able to give guidance to the people so 17 that they are marching. Everybody wants to do the right 18 thing. But lots of times you have to have some advice and 19 guidance about that.
20 MR. MOELLER: Well, one of your key points, and 21 you are probably getting ready to cover it, was that NRC has 22 now agreed that DOE can qualify components or the QA program 23 for certain facets of the overall effort.
24 MR. VOILAND: Yes, that was included originally.
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) -1 to be able to approve the going ahead with certain things.
2 And I think that these are realistic kinds of things.
3 MR. MOELLER: Sure.
4 MR. VOILAND: Again I would certainly emphasize j 5 the importance of trying to determine in advance how much 6 quality is needed. I am a great believer in the belief thar.
l 7 all sin is by excess or deficiency, and I think that it 8 applies to quality assurance as well as it does to morality.
9 You want to be sure that you have an adequate amount of QA, 10 but you do not want to QA yourself to death.
11 When we talked about this at our last meeting, we 12 applied some quality assurance terms to different kinds of 13 things. We are generally all familiar with the idea of 14 applying it to structures, facilities, and equipment. So we 15 are less familiar with the idea of applying it to the 16 acquisition of data and so on. At the last meeting that we 17 had, I recommended, that we pretty much know how to do the 18 construction and those things, but to draw up some specific 19 guidelines as to the application of quality assurance to 20 scientific endeavor.
21 Now generally if scientists do their job real 22 well, we do not particularly need that. But again if 23 managers do their job real well, you generally do not need 24 to have quality assurance. But on complex programs where 25 there are lots of pieces, it helps to have formalization to Heritage Reporting Corporation O (202) 628-4888
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1 all of that. -And.so maybe'in terms of the guides for
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2: applying quality to the acquisition of information, vna need 3 .to have a big check list of things like you have for these 4 others.
5 . Generally in quality programs you look at the 6 various levels that you have from the highest quality to the :
7 lowest and you specify some examples of the kind of quality 8 that.you apply at each level. Maybe something needs to be 9 done about that same thing with respect to the acquisition 10 of scientific and engineering information.
11 MR. OKRENT: I had in mind the data after it was 12 acquired, when I used it for performance assessment. Right
~ 13 now I'must confess that except for_some fairly I will use 14 the word simplistic concepts that it is not obvious to me 15 how one does quality assurance in that. What do I mean by 16 simplistic. The ASME may ask that a stress analysis for a 17 reactor vessel be independently kept or something. But one l
18 is' going through hordes of calculations and data analyses 19 and so forth.
20 MR. VOILAND: I guess that if I were to speculate 21 about that that I would kind of approach it the same way 22 that I do for a piece of equipment. First of all, I would
'23 ask myself how am I going to use these data that I am going 24 to acquire, and then essentially that criteria would be the 12 5 use of it. And this will define for me I guess the degree Heritage Reporting Corporation
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(_) 1- of accuracy I have to have and the uncertainties that I 2 would have to have, and a logical conclusion would be to lay 3 out a plan.
4 So presumably that sort of thing is.done in the 5 study plans, and that is why I think that it is very 6 important in terms of design of the test facility and design 7 of the repository and all of the rest in the long term to 8 have those study plans which again will formally look at the 9 ure of the data that you expect to get out of them as much 10 as you can.
11 It is not common. Scientists get mad usually 12 when you tell them that you are going to look over their 13 shoulder and nit pick their beloved plans. As a once 14 working scientist, I understand how that works. But 15 nonetheless if you are very serious about it, you want to be 16 sitre that the work is done on behalf of the project, not 17 because the particular scientist or engineer likes to do 18 that kind of work, and I think that you always have to worry 19 about that.
20 MR. OKRENT: Well, reactors PRAs are not aware of 21 quality assurance in the sense that you are referring to it.
22 MR. ?O' ?.J.:;D : But you do assess the uncertainties 23 associated with the data that is used in the PRA, is that 24 not all part of that?
25 MR. OKRENT: An effort may be made, but that is a Heritage Reporting Corporation
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( 1 ' wide open topic of discussion right now, let me put it that 2 way.
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3 MR. VO1 LAND: But in this instance we are getting 4 specific data looking toward.the' future use of it. So you 5- have a chance at least to put some kind of strings on it to 6 make it hopefully be better rather than to take material 7 which has.come out of the academic world or something and 8 apply it.
9 MR. OKRENT: I hope'that I did not create a 10 monster with that quick yes answer that I got.
11 -MR.'VOILAND: No. That is really about all that l
12 I have got. l l
13 MR. MOELLER: Are there any other questions or 14 comments before we break for lunch; does the staff have 15 anything, Jim, anything more?
16 MR. KENNEDY: Yes. I wanted to address a point 17 that Dr. Hinze brought up earlier in the morning about data 18 management and data control. And you are right that there 19 is not'much in the SCP on that. There is just a brief 20' section on quality assurance. I think that it is only 21 around thirty pages in Section 8.6. But the QA program does 22 have a number of controls for managing and controlling data, 23 and DOE has been in the process of developing it for years.
24 There are a lot of QA manuals and procedures for data 25 collection and data analysis.
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2 122 1 I know that-Sandia for example has a fairly 2- elaborate system that I am not aware of in great detail, but 3 it consists of a reference'information base and all kinds of 4 review committees to manage and control' data. So there is L ~5 something there and it is much more than what you have seen 6 in the SCP.
7 MR. POMEROY: Am I wrong or is there currently an 8 objection that is stopping the DOE from doing certain 9 characterization work at the site pending implementation of 10 QA7 11 MR._ KENNEDY: Pending full implementation of it 12 and acceptance of it by the staff. But they have been 13 working on'that program for years. There is a lot in place 4
14 already. It is just not one hundred percent there yet.
15 MR POMEROY: Do you have any idea when that 16 might be in place and approved?
17 MR. KENNEDY: Well, actually we have just 18 recently in the past couple of months started accepting the 19 first portions of the program, the plans and procedures for 20 Phoenix, the Title II design engineers. We were out at 21 Livermore a month ago and we accepted where they are right 22 now. Everything that they have in place is adequate to keep 23 on going and keep on implementing the program.
24 You know, it starts small. All of the plans and 25 procedures are in place. And now what they are doing is )
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(,) 1 implementing in the line. Different organizations in the 2 .line are beginning to implement it in different sections of 3 their work. So it just does not happen overnight. It is a 4 step by step process.
5 MR. MOELLER: Gene.
6 MR. VOILAND: One last comment. It is my 7 understanding from a brief conversation that I had earlier 8 with Jim Kennedy here that they pretty well accepted the DAA 9 results. On the other hand as you may recall, that was one 10 of the techniques, technical evaluation, to qualify the 11 Title I program or. design. I think that it might be 12 worthwhile to continue looking at what they used, what the 13 various contractors used in terms of their internal
(+ 14 controls.
35 Not that it is essential, but at some point in 16 time in the licensing process that somebody is going to I 17 think emphasize that. And if you could come in with some 16 credit due to the kinds of controls. Whether they had a 19 formal program that corresponded to the requirements of 20 10 CFR, Appendix B is another matter. But if you could say 21 yes that they had some controls in this general area, and I 22 am convinced from the results that there must have been. So 23 I would still encourage them to take a look at that. It 24 does not have to be a super effort, but see if they could go 25 back and look at some of that stuff.
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'1- l MR. KENNEDY: Gene, if.I could clarify one thing 2 real' quick. What we did was-we eliminated our comment on ,
3 the Title.I design. controls. We had a comment.there asking 4 them'how much they relied on the previous design controls 5 -and t' hat has been eliminated. We still have some problems
'6 with the DAA, particularly the technical staff, 4
7 Dr. Gupta and Mr. Browning.
8- MR. MOELLER: With that I think that we'better 9 recess for lunch. We will-take one hour. And then right 10 after lunch, we have allocated an hour and a half for DOE to 11 come in with additional thoughts.
12 (Whereupon, at 12:20 p.m., the meeting was 13 recessed, to reconvene at 1:20 p.m., this same day.)
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l 125 1 AFTERNOON SESSION 2 1:20 p.m.
3 MR. MOELLER: The meeting will resume.
4 For the next hour and a half to two hours, what 5 we are going to be covering or what we're going to be doing 6 is to be providing the U.S. Department of Energy an 7 opportunity to respond to the variety of comments which they 8 have heard not only from us but from the NRC Staff.
9 In leading off with that presentation will be 10 Ralph Stein who is Associate Director, Office of Systems 11 Integration and Regulation, for the Office of Civilian 12 Radioactive Waste Management at the U.S. Department of 13 Energy.
14 Ralph, it is a pleasure to have you with us.
' 15 MR. STEIN: I would like to thaak you, 16 Dr. Moeller, for giving us the opportunity to appear today.
17 In the two hours that we have, an hour and a half to two ;
18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, it is, of course, not possible to cover a document 19 that is 6,000 pages long and has over 100,000 additional 20 pages of references. But we thought that maybe it would be 21 worthwhile if we could talk in general terms answering 22 specific questions about the program that we have put in 23 place relative to three key areas.
24 So, with that as an introduction, let me just say 25 that here is the agenda that we intend to follow today.
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1f And, of course, we are more than happy, willing and ready'to
. 3 ;2 answer whatever questions that are asked by.the ACNW.
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.3 There will be three presenters after me: Mike
'4 ; Voegele, who will talk about the ESF design issues, Jeff
.5 Kimball, who will talk about the ESF location issues and Don 6 Alexander who will talk-about the performance assessment.
- 7. What I would like to cover is, first, cover 8 background, programmatic considerations, quality _ assurance, 9 _ exploratory shaft facility, performance assessment and then 10 s u m m a r i z e' i t '. And, of course, that is.a very large amount 11 of information to try to cover in my 10 minutes; but, 12 nevertheless, we have people who will continue to talk about 13- it. The technical folks who have been involved in
'14 developing the site characterization plan and the technical O. ' 15 topics.
16 I would like to now turn to background just to 17 give us a reference point and note that last December, the
'18 Department of Energy submitted its site characterization 19 plan to the Nuclear Regulatory Commission. And that plan 20 was based on the requirements of the Nuclear Waste Policy 21 Act, the NRC's Reg Guide 417 and an annotated outline that 22 the Department of Energy put together in concert with the 23 NRC that we used for the development of the site 24 characterization plan.
25 Now, about a year before we issued the site
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r~s s ) I characterization plan, we put out a consultation draft that 2 the NRC reviewed and commented on extensively. And we used 3 their comments plus a number of subsequent interactions 4 during the past year with the NRC to develop the cite 5 characterization. Let me separate that from the 6 consultation draft by calling the document that we have just !
7 put out last December as the statutory SCP. That gives a 8 separation of the two documents.
9 Currently, as we all know, and one of the reasons 10 we are here is that NRC is finalizing a site 11 characterization analysis. And we have had a certain amount 12 of opportunity to listen to the presentations of the NRC 13 Staff on some of their views relative to the site
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, 14 characterization plan.
(_) 15 In particular, on May 9th and 10th, the NRC Staff 16 presented their views in a preliminary fashion of the site 17 characterization plan and we had an opportunity to ask 18 clarifying questions at that point. And, additionally, we 19 attended some of the meetings that the Staff had with the 20 ACNW and heard the presentations to the ACNW and the 21 questions that the consultants and the members asked.
22 MR. MOELLER: Excuse me. Could I interrupt at 23 this point. And I realize the material you are going to 24 cover, but in reading in an attempt to acquaint you with one 25 of the main concerns or questions that has developed within Heritage Reporting Corporation t
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128 1 .this' committee, if you read it, it says.here that'the site
- 2 -characterization-plan should be-designed to obtain the! {
3 information necessary. to determine the suitability of the i J~
4 Yucca Mountain site for a repository, unquote. -
5 Now, obviously, you are seeking to do that. And 6 I have heard DOELspeakers: time and time again say in public 7- that'as you move forward with the site characterization, 8 should you uncover a fatal flaw, quote / unquote, that negates 9 the use of Yucca Mountain, DOE will promptly tell the'world 10 about this discovery and move on to other things.
11 Now, back to what the committee's concern is: In 12 reviewing your site characterization plan and in reviewing-13 the Staff's SCA and their comments on your plan, we do.not 14 see' written into the SCP any emphasis on attempting as early
'15 as possible to uncover any major fatal flaws within the 16 -Yucca Mountain site.
17 Now, is that part of your goal? And if so, why 18 isn't it put in there more prominently?
19 MR. STEIN: Probably, I can answer the question 20 best by talking about a different site for a moment. The l
21 Hanford site was a site that lended itself very readily to 22 identification of what might be considered a fatal flaw 23 relative to it's being essentially a water site and whether 24 or not the intervening aquifers between the surface and the 25 repoeitory horizon had connections and there was some way of Heritage Reporting Corporation
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'( [ 'l radio isotopes.that might be released at the horizon finding 2' its.way back up to the surface.
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l 3 So, it was relatively easy for us to *tefine a 4 ' process to' focus in on what might be a fatal. flaw. We have 5 spent a-lot' of time looking at the site, the Yucca Mountain l
6 site, and a fatal flaw doesn't just jump up'at us -- I'mean l' 7 we have fatal flaws, don't get me wrong; but there isn't a 8 single test or program that we have been able to identify l
9 that would enable us to go through a process that- would 30 result in our early on identifying a fatal flaw.
11 Having said that, that doesn't mean that we don't
'12 have a great deal of attention being paid to the need to 13 look for those characteristics of the site that might need 14 to have additional focus on them.
O 15 For example, and I don't know whether this is a 16 good example, but'it is one that I like: We have found 17 calcite-silica at the top and whether that is pedogenic or 18 not is a very important characteristic of that site. So, we 19 have a lot of work that is associated with identifying 20 whether that calcite silica deposit are pedogenic or not.
21 And if it is not pedogenic, we want to know about it and we 22 have plans to look early on in our testing program to see 23 whether there is some body of that material be down deep 24 that would suggest something other than surface procuting.
25 So, we think that our program, we think is Heritage Reporting Corporation
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- 130 k 1. structured to Snable us to~quickly get on things that are 2, ano.nalies, but we' don't have a single program that would 3 .say, "This is our fatal flaw program."
'4- .MR. MOELLER: Okay. What you are saying is that 5 the SCP as designed would rather systematically uncover them-6 if they are~there. I.think then it would help a lot if you 7 said that in the._ opening paragraph. But go ahead.
8 MR. STEIN: Again, on the background -- let me 9 return to that if I can -- I would like to note that from 10 the discussions that we have had, the discussions that we 11 have heard, there have been a number of instances where the 12 Staff'and the ACNW has focused on the DOE quality assurance 13 program, the exploratory shaft facilities, performance 14 assessments and several others which include hydrology, 15 geology and engineering. And because of the somewhat 16 limited time that we have available, we would like to focus 17- the presentations today on the first three concerns: the 18 quality assurance,.the exploratory shaft facility, and 19 performance assessment.
20 Now, in terms of programmatic considerations, the 21 Department recognizes, clearly recognizes that there are 22 very many large significant challenging demands that have 23 been placed on it and that we have an unprecedented 24 regulatory process that we must comply with in all respects.
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() 1 towards meeting the mandate that has been provided to us by 2 Congress and the Nuclear Waste Policy Act as amended. We 3 have put out a number of documents that express our program ,
4 and our thinking. We have prepared environmental 5 assessments. We, as I noted earlier, have put together a 6 consultation draft and we have prepared a site 7 characterization plan, the topic today. And as I had 8 indicated, this is a plan that has over 6,000 pages i
9 assoulated with it, over 100,000 pages of references and l 10 numerous supporting documents. It is a very comprehensive 11 document that represents the-dedicated work, if you will, of 12 more than 200 people for probably on the order of close to 13 two years.
- 14 MR. MOELLER: Dr. Okrent has a question.
\'/
15 MR. OKRENT: Can I ask about a different kind of 16 fatal flaw. You mentioned challenging demands. It is 17 conceivable to me at least that the standard, itself, as it 18 is currently or at least in the form that was approved and 19 subject to question was written in the form that made it 20 highly unlikely that one could satisfy the standard at any 21 site because of the requirements or very stringent 22 performance with a high degree of confidence and so forth.
23 I wonder whether the Department of Energy has 24 done enough assessment work that it can conclude that with a 25 practical amount of resources and time it can gather enough 7s Her4 tige Reporting Corporation
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r 132-Ih 1 Information'and do enough: analyses;and develop enough 2l technology that it can meet the previously approved EPA 3 standard. And,.if so, is there someplace where we can read.
'4 the study that gives you this assurance?
5 MR. STEIN: I would have to answer'the question 6 yes, that we believe we will be able to comply with the 7 standard. We have no reason at this point to feel 8 . differently. We had the standard available to us'in a 9 variety of different forms for a number of years until it 10 was recently remanded -- not recently, but a couple of three 11 years -- remanded back to EPA for development.
12 We have addressed the standard in the 13 environmental assessment. We have looked at-the performance 14 of a variety of the sites that we'have looked at that also 15 considered the standard as part of the multi-attribute 16 utility method that was published. Both of these documents 17 are published and are available. But I can't say at this 18 point that we have completed the analyses that we need to 19 maka, which we haven't, because we have a lot more work to l 20 do. But I believe that the program that we currently have 21 defined will lead us to gathering the information that we 22 need in order to, I hope, be able to demonstrate our 23 compliance with the standard in whatever form it is finally 24 released by the EPA. But I would refer you to the two 25 documents that I have identified: the environmental Heritage Reporting Corporation l
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(). -1 assessment and'the multi-attribute utility analysis.
2 MR. OKRENTi 7 must say.I don't thit.h either of y .3~ those could serve as the ,cument that'made the case for any
.A, lnd 4 'particular site. In other words,'they are not sufficiently l 5 deep in their analysis of what may occur, the probabilities, 1:
6 the uncertainties and so forth, 7; So, you may have talked about the standard, but 8 you certainly did not address.it in the sense that one of 9 your DOE's - reactor operators may not have to do a PRA to try
.c 10 to address whetherior not it is meeting the DOE's proposed 11 risk standards.
12 So, I conclude there is no document at the moment-13 if those are they, and I still am left with the question 14 whether DOE or NRC -- because I asked them in fact the same 15- question -- know whether that standard in fact can be met as 16 av was drafted before going to the core. And if I may add a 17 personal-comment, Mr. Chairmen, it seems to me that if there.
18 are reasons for at least serious questions along this line 19 in either or both of the agencies, something should be done, 20 perhaps together with the EA to see whether in fact there 21 does exist a standard which is capable of being met. A 22 standard which one cannot meet is in effect either something 23 which forbids something or valid, I have to assume. I will 24 leave that as a thought for the moment, but not one I intend 25 myself to drop.
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2 consideration, as I mentioned earlier, the DOE has produced -
j 3 under the requirements of NWPA and Reg Guide 417 a site )
I 4 characterization plan and I would hasten to say that this is t 5 a testing plan and it is not an analysis report. It was 6 meant to provide at this point in time the Department's best 7 view.9, if you will, as to what the test program needs to be 8 in order to proceed to gather the data that we need in order i 9 to prepare some of the regulatory documents that will 10 subsequently be required, such as'the SRAs.
11 So, we look at the SCP as basically a testing 1
12 plan. It is our view that as a testing plan, it will '
13 provide us with the data that will be sufficient and
,_ 14 necessary to enable us to make an evaluation of site
(') 15 suitability.
16 We also believe that at this point in time, based 17 on our experience in the past, based on the experience that 18 we expect to have with the NRC Staff, the state, the local 19 governments in the future, that there will be ample time for 20 interactions, particularly with the NRC, under the 21 pre-licensing informal conference mode of interaction that 22 is called out in NRC's 10 CFR Part 60.18.
23 We expect this will continue on throughout the 24 entire period of time, up to the period that we submit the 25 license application.
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() 1 Now, I would like to just for a moment turn to 2 the quality assurance and this is basically what I would j i
3 like to say about quality assurance, what we would like to 4 say.today in the presentation.
5 DOE has firmly and completely and as strongly as 6 we can committed to have in place a fully qualified quality 7 assurance program prior to the start of any new site )
8 characterization activities. We said it in writing and in 9 testimony and I say it again today: We had a number of 10 interactions over the past year with the Staff, in fact, 11 over the past few years on our QA program plans. The Staff 12 has participated with us in some of the surveillance that 13 we have had and audits that we have had directed by DOE 14 headquarters, as well as the DOE project office or its 15 contractors in other parts of the program.
16 We have gone through a number of iterations. We 17 think that we are moving towards a position where we will 18 have a fully qualified program for all the participants 19 before the end of tna year.
20 And we think it is important that we recognize 21 that there has been substantial progress in this area. You 22 probably have all read in the newspaper that the new 23 secretary has talked about a different culture, that DOE 24 must have a different culture.
25 Well, I can assure you that we in the program Heritage Reporting Corporation O (202) 628-4888
136 (f l' have been leading the power curve, if you will, on the 2 different culture in order to gain the ability that we.need, 3 the competence, the understanding, and the implementation of 4 a fully qualified program. And it will be in place before 5 the end of the year for all the elements of the year.
6 The exploratory shaft facility, again, the 7 Department has had numerous interactions with the NRC Staff:
8 concerning the exploratory shaft facility issues and you 9 will hear some of that in a moment.
10 The site characterization plan, Section 8.4, was R 11 extensively rewritten to address the issues that have been 12 raised by the Staff, including shaft location, testing 13 interferences and others. And, as I say, we will talk about 14 that more in a moment.
O 15 We did write a technical assessment review to 16 evaluate the acceptability of the exploratory shaft Title I 17 design, including the shaft location, did a rather 10 comprehensive review in that area. And in accordance.with
-19 our normal design process, under appropriate QA control, we 20 are now proceeding into the Title II design.
21 Let me back up for just one moment. Many people 22 sometimes have difficulty understanding what Title I and 23 Title II design is.
24 In the DOE parlance, Title I design is the 25 preliminary design. We have conceptual, we have preliminary Heritage Reporting Corporation
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2 The detailed design is the design that when 3 completed is translated into construction drawings. In 4 other words, we do the detailed design, we then take the 5 detailed design, change them into construction packages and 6 give them_to a constructor to build something from that 7 detailed design.
8 Again, we anticipate and expect and seek the 9 continued presence and involvement of the NRC Staff as we go 10 through our Title II design.
11 In performance assessment, again, this is an area 12 that we will talk about more in a few moments. The 13 performance assessment as you know has been incorporated as I
14 an integral part of site characterization. Performance (j"s 15 assessment, for some reason, people think it is going to be 16 done just once; it is going to be done continually. The 17 fact is we have a rather extensive program that is planned 18 for next year that we are going to do: perform aucessments, 19 sensitivity studies, so that we can get a better 20 understanding of the site via performance assessment. And 21 that is planned as part of our program next year.
22 In the site characterization plan, itself, it is 23 not a performance assessme.nt plan. These are separate 24 documents that are currently being developed that describes 25 the performance assessment as a strategy plan. It describes l
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(')I 2 assessment. And these are going to be issued in the coming 3 year. The fact is these two documents that I just described j
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4 ought to be available by the end of the year -- this year.
5 And again, let me repeat: performance assessment i
6 will be used throughout the program, the site ;
7 characterization program as a means to continually evaluate 8 the data as it is obtained.
9 MR. MOELLER: Do you have a publication or a 10 report at the present time which would show us an example of 11 the application of performance assessment in your work?
12 MR. STEIN: We have our performance assessment
-13 management plan. We do have a number of activities and 14 performance assessment where performance assessment was used 15 to make evaluation. Dr. Moeller, let me defer if I can for 16 a moment, until I get a better handle on what documents 17 might meet that question and I will submit those for the 18 record, if that is all right with you.
19 MR. MOELLER: Fine, thank you.
20 MR. STEIN: You might ask the same question of 21 Don Alexander when he gets up. He may have the answer at 22 the top of his head.
23 MR. MOELLER: Paul?
24 MR. POMEROY: I just would like to ask, when you 25 speak of performance assessment, are you speaking of partial Heritage Reporting Corporation
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) 1 system performance assessment? Are you speaking of total'
-2 ' system performance assessment?
.3 1GR. STEIN: 1[ am speaking of both.
4 MR. POMEROY: And you planned, based on the way 5 it is outlined"infthe-SCP, to do total system performance 6 lteratively.throughout the program?
7 MR. STEIN: As we acquire: data, we will do
'S iterative performance assessment. Again, let me say that we 9 will do it not only for the subsystems, we will do it for 10 the total systems, too.
11 MR. POMEROY: Thank you.
12' HR. . ' STEIN: So, in summary, the efforts need to 13 be focused on. obtaining site data which are necessary to 14 determine the suitability of the site without impacting the 15 ability of the site to isolate waste. That is a very 16 important point. You can make the site a Swiss cheese and.
17 'you have. Swiss' cheese, you don't have the site. So, we have 11 8 to make some, effort to assure that when we need to do 19 something or want to do something, that it is the right 20 thing to do and'we need to proceed on it.
21 First, this point though is that we believe that 22 if we are going to be able to determine suitability of site, 23 we need to proceed to gather data.
24 We don't believe that at this point that doing 25 additional evaluations and analysis will contribute Heritage Reporting Corporation O' - (202) 628-4888
L rr 140 I' 1 significantly-to our understanding of the site. We think
.( )'-
2 that we need to get site data in order to get'a better 3 understanding'of what that site can do in terms of potential 4 for1 isolating waste.
5 And we also believe that we have performed, as I 6 said, over the past two years with more than 200 dedicated 7 people' -- :there are people that, you know, we have drawn 8 lots of people from a number of different areas, but about 9 200 dedicated people have done-extensive evaluations and we 10 are confident that those extensive evaluations are adequate 11 to permit us to proceed with the site characterization and 12 gather the data that we think that we need.
13 I guess that would probably be a good way to 14 conclude by just referring back to the agenda and introduce, O 15 Dr. Moeller, with your permission --
16 MR. MOELLER: Go ahead.
17 MR. STEIN: Introduce the next speaker and that's
'1B Mike Voegele. Mike is from SAIC, who has been working on 19 this program for a number of years. And he will talk about 20 the ESF design issues.
21 MR. POMEROY: Can I ask one quick question, 22 Mr. Stein?
23 MR. STEIN: Yes.
24 MR. POMEROY: You said the continued evaluations 25 and analysis at this time are not likely to contribute Heritage Reporting Corporation
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-(J- :1~ significantly,tocyour understanding of the site. Would you 2- include a scoping PRA in that statement?
3 MR.-STEIN: I would, yes.
4 MR. POMEROY: Thank you.
5 MR. STEIN: I would include that.
6 Our program is geared, we believe to uncovering 7 fatal flaws if they were to pop up or at least we believe EI that~if there is some anomaly that occurs, our program is 9 designed to focus in en:that anomaly immediately. We will 10 not let that anomaly drag on until we got back to it a year 11 or two: we are going to focus in on it completely.
12- We don't know of any fatal flaws, if you will, on 13 the Yucca Mountain site. But we certainly plan to address
.g 14 anything that might turn up that needs attention V '
15 immediately.-
16 MR. MOELLER: Well, I think we are referring to 17- it also in the sense of what priority you place upon that.
18 We believe it should.be high in your priorities.
19 MR. OKRENT: Can I ask a question.
20 MR. MOELLER: Use a microphone, Dave.
21 MR. OKRENT: Roughly, what is the estimated cost 22 of the DOE program up to the point of starting operations, 23 assuming your current plan goes according to schedule, and 24 you are approved on schedule and so forth?
25 MR. STEIN: Our current estimate up through the f.
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(y) 1 issuance of the license application, submittal of license 2 application is between 1 and 1.5 billion dollars.
3 I might also add one other item and then I really 4 will leave. If I didn't say this before, I was asked at the 5 break if we had a schedule for the progress report. And our 6 current schedule for the progress report is that it will be 7 issued by July 15th.
8 MR. MOELLER: We had expressed interest in it 9 and, obviously, we look forward to receiving it. However, 10 in a sense, as far as I am personally concerned, it is good 11 it is not being issued prior to the completion of this round 12 of exchanges.
13 I think it would tend to confuse things.
14 MR. HINZE: If I may, before Mr. Stein retires, 7~s
\
15 momentarily, anyhow, I don't want to beat this into the 16 ground, but I can't help but catch on a couple of your words 17 here regarding fatal flaws and that's the term " pop up".
18 There is a segment of the community that is well aware of 19 potential fatal flaws. And I am sure you are as well.
20 I think our concern that we are expressing here 21 is that some immediate attention be directed to these 22 acknowledged potential fatal flaws, realizing that there may 23 be other fatal flaws that pop up along the line. And that 24 is really where the concern comes from, that we have already 25 identified potential fatal flaws.
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1 MR. VOEGELE: Good afternoon. As Ralph said, my 2' name is Michael Voegele. I am with SAIC in Los. Vegas and 1
3 support the DOE program.
.4 I'have been asked to speak this afternoon about 5' three particular sets of issues that we believe have -- are 6 part of the Staff's concerns on the SCP-. And I would like 7 to apologize to the Staff in advance of this presentation
(
8 for ~any misinterpretations I may have made of the intent of 9- their concerns. We have not had an opportunity to actually 10 view the text of thu concerns that the Staff has prepared.
i 11 Our impressions have been gained from sitting through two or 12 three meetings, one with the Staff and two of them with'you.
13 So, if I misquote something, feel free to correct me because 14 it is not intentional.-
\- 15 The three particular topics that I mn going to 16 address are design control, the design acceptability
-17: analysis and the general question of test interference. I 18 will try to indicate as we are going along which particular 19 Staff concerns that we are trying to provide information to 20 help clarify or to help you understand.
21 First, with the design control process, I think 22 it is very clear that the Staff has raised numerous concerns 23 about the design control process and we would like to 24 indicate to you some of the steps that DOE has taken to 25 insure that we have a subpart G design control process in Heritage Reporting Corporation
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() 1 place for the Title II design.
2 And, so, first of all, we note that the Title II 3 design will be performed in accordance with subpart G QA 4 requirements and of particular interest to the Staff is more 5 explicit incorporation of the regulatory guidance which 6 would be in fact criteria derived from the different parts 7 of 10 CFR Part 60.
8 We have prepared numerous plans and procedures to 9 help us guide this design control process through the Title 10 II design and the plans, procedures and the process that 11 we're describing is in fact consistent with the QA 12 requirements presented in our QA plan which goes by the 13 acronym and designator of NMWSI 88-9.
14 Of particular interest are QA requirements 15 related to the development of the design inputs, change 16 control, interface control, design verification and design 17 reviews.
18 How, the subject of the middle portion of this 19 discussion is in fact the design acceptability analysis. In 20 the interests of a complete presentation on the concerns 21 related to design control, we would like to point out that 22 the recommendations from that design acceptability analysis 23 are being incorporated into the Title II design inputs. In 24 particular, the exploratory shaft facility subsystem design 25 requirements document and the reference information base.
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[x )' 1 As one of the consultants to you this morning mentioned the 2 reference -- in fact, it may have been Jim Kennedy, I 3 apologize -- the reference information base is our control 4 data base of design input values that we use, so, we do have 5 controlled design data base that we use for Title II design.
6 Okay. And the resolution of the recommendations 7 out of the design acceptability analysis will be tracked as 8 part of the normal Title II design control process.
9 Now, there have been concerns raised in the past 10 that the Title I design was not necessarily as sensitive as 11 it should have been to the construction aspects of the 12 design. And, so, we have specifically expanded the design 13 inputs, again, things like the SDRD to incorporate input 14 from the construction interfaces. And where we have said 7s ij 15 other such interfaces here, that is a tacit acknowledgement 16 that the regulatory aspects of the subsystem design 17 requirements design for Title II design are significantly 18 improved from what they were in Title I design.
19 We note that in fact DOE is proceeding with 20 selected aspects of the ESF Title II design.
21 Now, as a transition between this first third of 22 the presentation and the second third, I would like to show 23 you a simple diagram to make sure that everybody in the room 24 has a feeling for what the DAA actually was in terms of the 25 normal DOE design process.
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) 1 The normal DOE design process would have a 2 requirements design for the Title I-design, create a Title I 3 design to address those design requirements and then there 4 would be a design review, which is. basically a design to 5 insure -- a-review to insure that this design' meets the 6 requirements specified in the requirements document. It 7 would then move on to a Title II requirements document and 8 basically a Title II design and on through the process.
-9 Now, what we did in response to a specific NRC 10 concern in last fall /early winter was to take a separate l
11 assessment which we called the design acceptability 12 analysis, I call it the DAA. A lot of people call it the 13 DA, and look at the Title I SDRD, the Title I design and 14 selected portions of the design review documentation and O 15- within this design analysis we developed our own criteria 16 that we felt the Title I design should meet to be in 17 compliance with 10 CFR Part 60.
18 Now, what I told you in the previous slide and 19 what this diagram indicates is the results of that design 20 acceptability analysis have been factored into the Title II 21 SDRD. So, the work that we did over the past few months --
22 in fact, it was almost six months ago now, on the design 23 acceptability analysis has already found its way into the 24 Title II SDRD, the requirements document for Title II 25 design.
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): :1 MR. MOELLER: Now, the NRC Staff, though, has 2 stated that in the DAA.you failed to incorporate a multitude g 3 of 10 CFR Part 60 regulatory requirements. How did that 4 happen?
5 MR. VOEGELE: Okay, I mn prepared to address 6 that.
< MR. MOELLER: Fine, I'll wait.
8 MR. VOEGELE: In about two slides.
9 MR. MOELLER: Thank you.
10 MR. VOEGELE: So, we will move into the design 11 acceptability analysis, and I would like to talk about the 12 scope of the design acceptability analysis and a little bit 13 about the recommendations coming out of that document.
14 As preliminary information relative to the scope 0<s .'
15 of the DAA, we would like to point out that the DAA was in 16 ' fact part of what we called the technical assessment review.
17 And that technical assessment review also included a 18 comparative evaluation of alternative ESF locations.
19 The next speaker, Jeff Kimball is prepared to 20 discuss that portion of the DAA. My comraents will really be 21 ' limited to -- excuse me -- that portion of the technical 22 assessment review. My comments will limited to the DAA.
23 Now, the DAA was conducted under subpart G 24 controls. In fact, it was done in response to a specific 25 quality management procedure which goes by the designator 7s Heritage Reporting Corporation i
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() _ 1- 0208.within the program.
'2' Now, to do that, we developed the management plan
.3- and there is formal documentation through the process of the 4- ' management: plan.- And what I would like to emphasize is that 5 it' includes the documentation relative to the qualification
- 6. of the team members.
7 We have heard a comment variously and I don't 8 want to. misquote this, but the way I've heard it is the DAA 9 is flawed because we didn't demonstrate the independence of 10 the team members.
11 What I would like to point out is that our 12 documentation will show you that there were 27 individuals 13 who met criteria for the technical disciplines that they
,- 14- were representing as well as independents. Now, there
(_)g 15- certainly to my knowledge not absolute definitions of what 16 is independent. Our definitions of independence were that 17 'the team member not be a principal contributor to the ESF 1
18- Title I design and that the team member not be a principal 19- contributor to the ESF Title I SDRD.
20 We believe the documentation is in place that 21 will demonstrate that those 27 individuals met those 22 criteria.
23 MR. HINZE: Do you have any indication whether or 24 not those definitions will be accepted? Those two that you ;
I 25- have there?
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149 1 MR. VOEGELE: Accepted by the Staff?
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2 MR. HINZE: Yes.
3 MR. VOEGELE: My suspicion is they are not 4 accepted by the Staff. That's the only conclusion I can 5 come to if they say we have not demonstrated independence.
I 6 I point out that the 0208 review, the technical 7 assessment review was never intended to be an independent 8 external peer review. It was intended to be an independent, 9 from this concept of not a principal participant in the 10 design or the SDRD development, a team comprised of members 11 from within the project who were knowledgeable of the 12 exploratory shaft so that they could do a credible review.
13 MR. MOELLER: And that information, the last two 14 justifications for independence, that information was made 15 available to the NRC Staff prior to their reaching the 16 judgment --
17 MR. VOEGELE: Each of the 27 team members filled 18 out a questionnaire with four questions: two related to 19 this and two related --
20 MR. MOELLER: What I am saying is the NRC Staff 21 knew all of this and even so, they still ruled that --
22 MR. VOEGELE: Okay. I can't answer that 23 question. I can say it was made available to them. This 24 information is in an appendix to the DAA report, the 25 technical review memorandum.
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[s_/') 1 MR. MOELLER: So, then it must have been {
i 2 available.
1 3 MR. VOEGELE: It was available. I don't know 4 that they read that appendix.
5 MR. MOELLER: Thank you.
6 MR. VOEGELE: Okay, moving on to the scope of the 7 DAA, there are really three things we would like to 8 emphasize within the scope of the DAA. The first one is i
9 that we did do a relatively detailed evaluation of Title I 10 design acceptability with respect to criteria that were 11 derived from the applicable 10 CFR Part 60 requirements i 12 related to waste isolation, ability to characterize the site 13 and representatives of the data.
14 Now, these three topics were mutually agreed to O 15 in meetings between the DOE and the NRC that these are the l
16 ones that we need to look at in the most detail.
17 Now, Dr. Moeller asked a question earlier about i
18 what really the definition of applicable came from. And I 19 will address that on the very next viewgraph.
20 Okay. Now, we took what we considered the other l
21 applicable Part 60 requirements, things like preclosure 22 radiological health and safety and evaluated the design 23 against them. The difference between these two bullets is 24 that in this detailed evaluation against those three topics, 25 waste isolation, characterize the site and Heritage Reporting Corporation
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il representativeness, we developed specific criteria to aid us .;
p '2 in the evaluation of our compliance with the regulatory-
- 3 requirement.
-4 Within this bullet where we are looking at the .j
.5 other applicable'Part.60 requirements we did our evaluations 6 somewhat more qualitatively against the requirements 7 themselves, without the intermediate step of developing 8 ' specific criteria to show compliance.
9- The DAA also considered an assessment of the 10 reasonableness of-the data used to support the Title'I
-11 design. Let me move on.
12 Okay. Relative to the question of applicablo:
13 The set of applicable requirements that were addressed in 14 the DAA were determined by a DOE technical review group.
- 0. 15 Now,.that review group did a comprehensive evaluation of all 16 part 60 requirements and prepared a report which was shared 17 with the NRC Staff I believe on December 8th.
18 Incidentally, and this is by no means meant to 19 indicate that the Staff had adequate time to react to th'at 20 presentation on December 8th, but their initial reaction was 21 that there were four pieces of the regulation that we had
'22 missed in that flowdown. And I bring that out only to note 23 that and perhaps drive home the point that there is a lot of 24 new information coming up to all of us in this program. And 25 the more we get into it, the more we find that there are Heritage Reporting Corporation O (202) 628-4888
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-( )' 1 other things that should have been looked at or there are 2 things that should have been looked.at in different ways.
3 And I believe it was Dr. Voiland that pointed that out this-4 morning, and I couldn't agree with it more.
5 And in fact, I have tried to highlight that same 6 type of concern in our next bullet. We recognize the Staff !
7 has raised concerns regarding the applicability of other 8 requirements, but we point out that there is no precedent i
9 for application of this regulation. Dasically, that 10 precedent will not exist until somebody has been through a 11 license application.
12 There was an indication earlier that the NRC 13 Staff had their center working on an evaluation of the 14 applicability of the Part 60 requirements. We have not seen O 15 that. We don't know if the Staff has that yet, but I think 16 the saving grace is in our bottom bullet, within about a 17 week from tomorrow we are meeting with the NRC Staff to 18 discuss in fact their comments on the DAA and we hope tnat 19 that will initiate a dialogue that will help us to begin to 20 understand why our rationale for why a particular piece of 21 the regulation is not applicable is unacceptable to the 22 Staff and maybe give them a chance to hear why their 23 arguments for why a particular piece of the regulation is 24 acceptable may be unacceptable to us. And I think that 25 basically there will be a fair bit of interaction on that.
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2 this is rather misleading to have the title recommendations 3 on this viewgraph and then to give you the conclusion of the 4 Title I design. It's my mistake. I changed the title 5 without realizing what I was doing.
6 We concluded that the Title I design provided an 7 acceptable basis to begin the Title II design and for the 8 ESF related site characterization activities described in 9 the SCP.
10 I believe that is consistent with what we heard 11 this morning from Dr. Voiland regarding his impressions 12 about whether or not the design was in fact adequate to 13 support the testing program.
14 There were several comments and recommendations 15 generated as a result of the DAA and these will be addressed 16 during or in conjunction with the Title II design. In 17 actual fact, there are nearly 54 of them and they generally 18 point out specific design related analyses or performance 19 type calculations that could be used to demonstrate in fact ;
20 the suitability of the design with respect to some of the 21 Part 60 requirements. They point out to the designers 22 additional information that they will have to develop for 23 Title II design such as detail specifications on blasting, 24 fluid material control, things of that nature.
25 Now, those things as I pointed out before have l
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[) 1 been rolled directly -- the criteria that developed the 2 comments have been rolled directly into the SDRD. The l
l 3 recommendations, themselves, we are currently undergoing an l l
4 activity where we are working with the designers to make 5 sure that the intent of our recommendations is in fact 6 captured-in the requirements document so that the final 7 product will be satisfactory with respect to the types of 8 evaluation we did on the Title I design.
9 Okay, and finally, it is very important for us to 10 point out that these types of recommendations, together with 11 considerations arising from other-interactions with the NRC 12 Staff, particularly relative to their comments on the DAA 13 will be treated in the Title II design process. And we 14 would .like to eqphasize that process is subject to charge
(./
15 control. So, we fully intend that we will have a good track 16 record that will tie the SCP and the Title I design to the 17 Title II design.
18 There will be a rationale for why something may 19 have changed between the Title I design and the eventual i 20 Title II design, that change control process will take care 21 of that.
22 I would like to briefly touch upon the subject of 23 test interference and as often happens when you put together 24 a presentation, I think the focus of these viewgraphs is --
25 MS. MOODY: Michael?
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( j. 1 NR. VOEGELE: Certainly, Judith.
2 MS. MOODY: Will you be pretty straightforward?
3 Has Title II started?
4 MR. VOEGELE: Title II design --
5 MS. MOODY:, Title II design, has it started?
6 MR. VOEGELE: -Title II design has started on 7 selected aspects of the design. There are quality assurance 8 level assignments that need to be made before the pieces 9 that you are most concerned about can begin. It is 10 . basically on the things that are not important to waste 11 isolation.
12 MR. MOELLER: Gene?
13 MR. VOILAND: The parts that you are starting on, j 14 I presume you have a quality assurance plan in place that O 15 covers those?
16 MR. VOEGELE: Yes. In fact, we heard from 17 Mr. Kennedy this morning that the NRC Staff has in fact been 18 out and reviewed the FNS --
19 MR. VOILAND: You are really following the 20 procedure that you have agreed upon?
21 MR. VOEGELE: Yes. I would give Jim a chance to 22 react to that.
23 MR. KENNEDY: Jim Kennedy --
24 MR. MOELLER: Jim, could you use a mike, please?
25 MR. KENNEDY: That's correct. We have reviewed Heritage Reporting Corporation
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. () 1 the plans and procedures for Holmes and Narver and Phoenix 2 and Sisson. My understanding is, though, that DOE hasn't 3 started any level 1 work.
4 MR. VOEGELE: That is correct.
5 MR. KENNEDY: Just level 3, I think, which is not 6 important to waste isolation or safety.
7 MR. VOEGELE: Right.
8 MR. KENNEDY: You are still in the process of 9 classifying level 1 activities?
10 MR. VOEGELE: Yes, sir.
11 As I was saying, with respect to this viewgraph, 12 these viewgraphs tend to be a little bit focused on the 13 contents of Cnapter 8.4 and I want to point out that I 3 14 recognized that the comments that I'm trying to respond to
'\')
15 are not really explicitly directed at things like, the test )
i 16 descriptions, and the operations descriptions, and our l 17- evaluation of interference, but the only way I can respond 18 to them is in the context of this type of information.
I 19 And particularly the comment that I would like to ]
1 20 respond to are the concerns about schedule delays and things '
21 of that nature and not having all of the ESF test 22 description completely finished within the SCPR, the two 23 particular topics I would like to spend the time. And, so, i l
24 I would like to do that, as I said, in the context of the 25 Section -- of SCP Section 8.4 wherein those of you who have Heritage Reporting Corporation
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) 'l' taken a moment l and scanned through it, know.that.there is a 2 description of the Title I design, description of each'of j,,
I' 3 .the tests to thefdegree that they have been defined at this-4 point in time, and most importantly, an analysis of the
! 5 types of constraints that a particular test would place on 6 the ESF' layout. And generally those things have to'do with n 7: having to'be isolated from other tests,'having to be done in 8 an area where there is no-traffic, having to be done in an 9 area where you can tolerate water being placed in the 10 facility.
11 There are descriptions of the operations and 12- those pieces of information are rolled together into 13 evaluations about the interference and particularly there 14 are evaluations of whether tests interfere with one another O 15 and whether the construction and operations interfere with 16 the tests.
)
17 Now, the information that is in Section 8.4 is 18 based upon as we noted before the design information and the 19 . tests descriptions. We would like to emphasize that much of 1 20 it is in fact based upon experience that the principal 21 investigators and other program participants have gained I
22 while working on in G Tunnel which is the facility in welded ;
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23 tuff on the northern portion of the test site. And that
'24 played a very large role in our understanding of what types i
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(_) 1 facility-, what types of spacing you would have to have 2 between' tests, how sensitive'the tests were to traffic and i
3 things of that nature.
4 So, a lot of that type of information was 5 factored in almost implicitly from the experience of the 6 people on the program. So, as we noted, each defined tenc 7 activity was evaluated with regard to constraints and zones 8 of influence. We established stand-off requirements. We 9 evaluated the layout of the tests to make sure that we would !
10 not have significant test-to-test interference.
11 Also, we evaluated it to insure that we would not 12 have construction-related effects in the testing program.
13 And the point I am trying to make through this is that we r 14 believe flexibility still exists for relocation of the w
15 tests.
16 MR. STEINDLER: Is there some reason why long-17 term isolation was missing from that last list of potential 18 interferences that you looked at or is it buried in 19 operations?
20 MR. VOEGELE: No.
21 MR. STEINDLER: You've got a fourth line there.
22 MR. VOEGELE: I understand. There were 23 evaluations. In fact, the bulk of Chapter 8.4 was devoted 24 to whether there would be impacts from the testing program 25 on either the ability to successfully build a repository or (3 Heritage Reporting Corporation
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b I,) 1 on the subsequently ability of that repository to isolate 2' the waste from the environment.
3 I am only focusing on the earlier part of the 4 program which seems -- the comments I've heard seem to be 5 concerned with the testing and sequencing of the testing and 6 delays in the testing.
t 7 Okay. The figure that 1 would like to show you 8 is in fact a interface control drawing from between the 9 repository and the exploratory shaft facility and that will 10 explain a lot of the labels which really are not pertinent 11 to what we are talking about here.
12 I would like to emphasize that this is the 13 conceptual repository layout. And within that conceptual fg 14. repository layout, we have tried to design for the
'u) l 15 incorporation of an exploratory shaft facility up in this ,
I 16 corner.
17 Now, within the current repository layout, 18 conceptual repository layout, there is an area basically 19 like that which within the requirements documents is 20 designated as a dedicated testing area.
21 Now, as you will note, we have laid out a test 22 facility which does not fully fill this area. We have set )
l 23 aside literally an equivalent amount of odditional area to ]
i 24 accommodate different testing prcgrams like the performance !
25 confirmation program if it should turn out that there are l
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.(m,) . 1 additional. tests in a subsurface that-would be part of the l 2 performance confirmation program.
1 3 I would like to make a couple of points on this' l 4 viewgraph if I may. First of all, this design is relatively 5 more advanced than the repository conceptual design. And if
{
6 it would turn out in fact that we would need additional area 7 over and above what's down here for the dedicated testing .
1 8 area, it would be a relatively more simple task to change l 9 the repository interfaces and say, for instance, we have 10 additional area up in here within the training area that 11 would not be used for waste emplacement perhaps. That would 12 form yet another piece of real estate that could be made 1 13 available to testing.
g 14 Now, the comment as I understand it that was made 15 by the Staff had to do with the sequencing of tests such 16 that we had proposed in several instances in the SCP that 17 certain tests not be given their own dedicated piece of real 18 estate, but rather that they be used -- they be fielded in 19 areas where other tests have already taken place.
20 A prime candidate, the first test that is going 21 to be undertaken when we get underground, the demonstration 22 breakout room, or the sequential drift mining experiments.
23 After those experiments have taken place and we get 24 information about what kind of support we're going to use 25 underground, what the optJmum layout is for the underground l g Heritage Reporting Corporation t (202) 628-4888
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c 1 drifts, there is no reason we couldn't go back into those (J) u 2 drifts and run a plate loading test, for instance, or some 3 sort of a flat jack rock mass strength test.
4 And that is what we had meant by using areas that 5 have been previously used for testing. And the Staff's 6 concern as I understand it is that if in fact there is some 7 delay in the completion of this test, that could delay the 8 fielding of another test and taken to its logical 9 conclusion, that would mean that some tests could be delayed 10 .so long that they wouldn't be finished by the time site l
11 characterization is supposed to be finished. '
12 And I think what we would like to say in response 13 to that is, first of all, point out once again that we do :
14 have additional flexibility underground. We are sensitive 15 to the scheduling problems. There are schedules that are
-16 published and created for this program, but I think it is 17 also fair to point out that it would be imprudent for DOE to 18 try to go for a license application before they had 19 adequately characterized the site.
20 So, we have to trade those two things off. And 21 if it means we have to find some more real estate 22 underground, then we have to find some more real estate l l
23 underground to run those tests so that we can get them all l 2t completed in time so that we have the data that we need to 25 complete our license application.
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() 1 Now, the other point I need to make is basically 2 this is our understanding of a test facility which would 3 support our proposed testing program and provide the types 4 of information that we believe necessary to characterize the 5 site.
6 I think if we are open-minded about that, we have 7 to recognize that we could be no more than halfway down the 8 shaft before we discovered something that was different 9 about our fundamental assumptions about the physics of the 10 site that might lead us to re-think some of the aspects of 11 our test program.
12 And, so, we also have to be sensitive to the fact 13 that this could change. Hopefully, not significantly.
f- 14 Hopefully, we have a good enough understanding of the site
(_g) 15 that we have done a pretty good job of laying out the test 16 program, but there is a possibility that that could change 17 as well. And, so, we have to provide for that change 18 control process of the Title II design and ultimately for 19 the interfaces with the repositcry design to insure that we 20 can accommodate that.
21 I think I have probably said everything that is 22 worth saying on the summary review graph at that point in 23 time, In fact, the three bullet" on the viewgraph are 1 24 relatively obvious. We believe that the test layouts will 25 preclude significant interference between the tests.
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.\f l' We know we have deliberately set out to. build a i
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~3 construction-related interferences with the testing program'
4 and I would like to also point out that we do have in mind 5- monitoring activitiet during the ' characterization program !
6 that will help us refine-the' type of calculations that.we i.
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'7 use as'the basis'for our interference calculations and, if-8 necessary,, refine those interference calculations which 9 could also lead to a rearrangement of that underground 10 facility.
11 , So, that,is all I had to say. If there are J
12' questions, I' d be happy to try to answer them.
13 MR. MOELLER: An additional questions for n 14 Dr. Voegele? j k l 15
'(No responso.)
- 16. MR. MOELLER: I hear none. We'thank you.
17 MR. VOEGELE: Thank yeu. It is probably 18 appropriate for me to introduce the next speaker. !
- 19. MR. MOELLER: Fine.
k '
20 PR. VOEGELE: This le Jeff Kimball from the 21 Department of Energy in Washington.
22 MR. KIMBALL: As Mike stated, my name is Jeff 23 Kimball. I am a seismologist in the Office of Facility 24 Siting and Development in the Siting and Geosciences Branch.
25 I would start off by saying basically the same Heritage Reporting Corporation
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f .1- thing:.that Mike did is that:- This talk is basically ~
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?2 structured around issues and' concerns.that we have heard 3 : raised both!by the Staff and the ACNW during May'and' June.
4 And we really haven't had the opportunity to read the exact-5 , wording-that goes along with this issue. And, so, if.there i
16 is a misperception as part of this talk, that should be.
7' brought.out. i 8 The presentation will try to address the.four i
.9 issues which are shown on the first viewgraph. 'And these j E10 four_are basically that the-shaft location decision should 11' be based on current data. It is not clear whether the-12 recommendations that were made by what's commonly termed the- -l 13 Bertram Report, particularly regarding the geologic mapping 14 and the geophysics evaluation were implemented, o 15 The Staff has pointed out that there is a 16 geophysical report which identifies an inferred fault and
. i; 17 they cannot find whether that was evaluated or not. And 18 basically that in adding up those issues, there is a concern 19 that'the shaft location may need to be reevaluated after j 20 additional surface-based testing.
21 MR. MOELLER: Mr. Kimball, on your first item 22 -- and I realize you are going to take each one up -- but 23 the first bullet, I have heard even members of our committee 24 and consultants say that the data on which the ESF location 25 is based, those data are out of date. You are going to Heritage Reporting Corporation
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2'1 . MR. KIMBALL: bc, I think so, I
r
'3. MR. MOELLER ' Thank you.
10 4 , MR. KIMBALL: he decided to put the conclusions 5 both as:a second viewgraph and the last one just to see' i
6- . where we are going to go in terms of the presentation, j l
7 itself. -)
- 8. The first bullet may address your comment, _-
S Dr. Moeller, but.in reviewing what has happened from 1982 !
10 :until'now, we'found that the best.available information has y 11 been used to make the location' assessments and decisions 12 from 1982 until present. And the various decisions were 13- made atldifferent times, but at each time those were made, I
.14 the:information available had changed and there was a j
~, / 1
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15 recognition'what additional information had or had not 16 become available. l 1
17.- And I will point out during the presentation at ,
18 what points in time those. changes were made. 4 19 In also reviewing what's happened over the past' 20 several years, we believe that the sequence of actions and J 21 decisions are appropriate. 4 22 And I would point out that as recently as late 3 23 1988 and published just this year in February that the shaft 24 locations were again evaluated and here particularly 25 regarding issues that the Staff had with respect to waste Heritage Reporting Corporation
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2 to L be : adequate'.
qp 3 And, finally to_ point out here at thei ottom, b and'
]<
4 I will; touch on this in some detail, is that the-results of J
'5 the part; geophysical'workethat were done in 1979'were 6 available to the geologists who completed the mapping at the 7 shaft, location and in fact who completed the mapping
?'n ' 8. throughout the whole site. -l 9 And that the surface mapping has continually, a-4
.'. 0 number of times, identified no evidence of faulting within 13 several hundred feet of this exploratory shaft.
12' MR. STEINDLER: Let me ask a question about'the 13 first bullet there. If I remember right, and I may not, but-14- 'if I' remember right, the initial location was declared an.
O. 15; unhappy one because of potential flooding.
16 Are you telling me that the data that was used to 17 locate that shaft :regarding - flooding was not available until 18 the issue was raisod?
19 MR. KIMBALL: No. There was information 20 available. In fact, in one of the criteria in the original 21 Bertram study when they screened the area to pick a shaft 22 location, one of the subcriteria was flooding. It happened
.. 23 to be in that report a criteria that didn't receive a y 24 significant amount of weight. Once the shaft sites were 25 selected, I think the Department became more aware of the l>
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() 1 significance of the concern from the Staff and as a result 2 of that and looking more at the flooding issue and becoming 3 more aware of that that the location changes were made. And 4 that will be brought up as part of going chrough the talk as 5 to what time was that-change made.
6 MR. PARRY: Excuse me. Will you also be 7 addressing the question of shaft location when the 8 repository was originally planned to be in the saturated 9- zone?
10 MR. KIMBALL: No. It will essentially -- what I 11 am going to try to do is address both the comments that are 12 on the first viewgraphs and then leading to the conclusions 13 by going through the first one, it would be the historical s 14 perspective, but the point at which we will start the 15 historical perspective starts with the Bertram report.
16 Now, in that report, they did consider the type 17 of construction that was going to be made, you know, whether 18 it should be a ramp or a shaft, for example. And I believe 19 there was also at that time a decision made essentially that 20 the evaluation should consider or should heavily consider a 21 site in the unsaturated zone. So, I won't really go back to 22 what led to picking of Yucca Mountain per se or picking of 23 Yucca Mountain and the unsaturated zone. It kicks off with 24 what happened at the Bertram time frane, particularly what 25 was done with the recommendations since that has been an
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2 The other two points in addition to the 3 historical perspective will be to summarize the role of what 4 the most recent evaluation, the comparative evaluation which 5 was part of that technical assessment review which Dr.
6 Voegele had mentioned and, finally, to spend some time 7 talking about the e ~ ent assessment of the inferred fault 8 from the 1979 geophysical survey and to give a snapshot of 9 the ongeing technical assessment review that is going on now 11 0 to address that.
11 (Continued on next page.)
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1- , MR. KIMBALL:-. Going through the chronology, in
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2: the next.several viewgraphs, I am going to try to go through 1
3~ it relatively fast,.and it is.probably a lot to handle in a
^
4 short amount of time. We wanted to make sure that we got it Si down'so that you'could refer back to it if you need to in 6 terms of'what' happened when. But if I go-too fast, just 7' .give a holler and I will try to slow down and tcy to answer 8 any questions.
9 The story basically starts in March of 1982 when
- 10. there was a working group formed to identify the preferred 11 areas for an exploratory shaft. Although the work started 12 in 1982, it was nott published until 1984, and it was 13 published as what is commonly referred to as the Bertram 14 report.
15 That working group using screening criteria and 16 'exclusionary criteria and identified five exploratory shaft' 17 preferred areas. It you could put the next slide up. This L _18 is a figure from the comparative evaluation and the only 19 reason that I chose this instead of something right out of l 20 the Bertram report-is that the drafting is a little nicer.
21 It shows bacically a rectangular area, the current perimeter 22 drift, and the five preferred areas selected by the Bertram 23 team. Area four is the area where the shaft is located, was 24 and is located.
25 MR. MOELLER: I find it curious that none of them Heritage Reporting Corporation (202) 628-4888
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1 iwere-really at the middle.of the area.-
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' MR . KIMBALL: Yes.= When they originally did the
-3 ' study and they. looked at.the block around the site, the.
-4 southern part of the repository was essentially eliminated 5 from detailed consideration. It was a part of the original -I
[> 6 consideration. .One of the. issues of the comparative .,
l n' 7 evaluation was to' compare the five areas with the entire .]
8' repository to gain some understanding that if waste '
.9- isolation had been.an explicit consideration how would that 10' 'have fared in terms of.looking at the whole block of rock 11' that is down at the south end. And I will address that'when l 12 I talk about the comparative evaluation.
13 MR. MOELLER: Okay.
'~
If MR. KIMBALL: One of the criteria that has come
.t 5 up a number of times in discussion and the reason that we 16 pulled it out of the Bertram study, and there were a number 17 of criteria, but the one that has generated some interest 18 particularly because of the geophysical anomaly and the
, 19- interpretation of that anomaly has to do with set back 20 . distance'from potential adverse structures.
21 Two things to point out is one going back and 22 looking at the Bertram report and talking to the people who 23 participated in it that the term potentially adverse 24 structures is not particularly well defined. They did use
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t, 171 1' Leoncern was.the constructability. issue.
IF They. thought.that it was impossible to construct
?* 3 in a zone that might.have some fracturing or faulting, but 4- they' wanted to make their job somewhat easier by setting 5 back from anything that they considered to be a zone of less 6 stable rock that they would avoid a constructability issue, 71 to simply make sure that they were in good rock.
8 The report actually used the exclusion distance 9 of only 100; feet. However in looking at the screening 10 criteria, they had a preferred set back in the end.of 11 =1000 feet. And when that was applied to the screening down 12 to the five sites, the 1000 feet was essentially used in an 13 exclusionary sense, although it was not in the report as an
'14 exclusion criteria. However in generating the map that I 15 previously show with the five sites, they actually applied
- 16 'it essentially.as an exclusion criteria. So they did set 17 .back 1000 feet from potentially adverse structures.
18- TheLway that they did it was assume that they-19 structures that they see on the surface had a simple dip to 20 them. And they picked depths of 1600 feet and 3200 feet and i
21 .then measured back 1000 feet from that, and basically 22 excluded any area within a 1000 foot distance.
23 As I stated previously, that when you talk to the 24 people and when you read the report, the basic reason that 25 they chose the set back distance was a constructability Is Heritage Reporting Corporation (f (202) 628-4888 o
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1(j) 1 issue. I would point out that it was not a waste isolation i
2 issue. And that is one of the concerns that led to the 3 comparative evaluation. And back in that time frame, it was 4 assumed that there would be only one exploratory shaft.
5 In June of 1982 of that year, the Bertram group 6 or the working group did make recommendations to DOE 7 management. Those recommendations were that the USGS in 8 particular map each of the five preferred areas in detail 9 and implement a geophysical evaluation.
10 This map is put in here also to show you again 11 the same rectangular area with the five preferred areas and 12 the perimeter drift and the surface map of geological 13 structures that were assumed to exist. On the surface this
- s 14 boundary here I believe is about 800 or so feet from the l \
- 15 surface expression of the fault. They assumed this fault 16 dipped to the west, so it dipped away from the preferred l
17 area. And based on the dip that they assumed and the levels l
l 18 of 1632 feet, this ends up being about 1200 feet away from 19 it.
20 One point to make here when we go through the 21 sequence of the mapping, and I will probably make it one 22 more time, is that the map of the surface expressions and 23 structures was provided by the USGS. Drafts of the map 24 which were eventually published in 1984 were provided to the 25 Bertram working group. And the map that was provided was l Heritage Reporting Corporation (202) 628-4888 l l, L___________ _ _ _ _ _ _
173 j 1 completed by the geologist who did the field mapping who in 2 each of the sequence of actions was the same geologist. So 3 there was consistency in who did the mapping and who 4 provided the mapping to the working group.
5 In July of'1982, the USGS wrote a letter 6 transmitting the results of the detailed geologic mapping.
7 That is referred to maybe in some of the conversations that 8 you have heard as the Dixon letter. I would like to point 9 out that in this letter that there was no explicit 10 discussion of the geophysics of or the geophysical anomaly.
- 11. Although as a part of the ongoing technical 12 assessment review, and we have gone back and asked the 13 geologist who completed the mapping and he was aware that 14 the geophysical surveys had been done in the Coyote Wash and 15 knew of the geophysical anomaly and the interpretation that 16 was made, he chose not to honor essentially that 17 interpretation based on his geologic mapping.
18 I would point out here that the mapping was 19' completed by Bob Scott of the USGS using basically the same 20 information as that that was eventually used to develop the 21 site geologic map. The site geologic map was published in 22 1984.
23 If you would go on to the next viewgraph and I 24 will come back to this one in a second. You probably need 1 1
25 to rotate. Well, it is probably better to turn it over. I l
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l 2 To orient you north is to the side, and Coyote 3 Wash comes up this way. And there is a little ridge down i 4 here and the wash bends around like this. This is the map 5 reproduced exactly from the Dixon letter that was done by 6 the USGS. You can see that the information given at that 7 time are simply hand drawn maps. It was done on a scale of 8 1 to 12,000. And some of the features to point out on this 9 map are the Ghost Stance Fault which shows up on the other 10 map that I showed you with the rectangular block. It is the 11 long fault that goes through essentially the middle of the 12 repository.
13 MR. MOELLER: Where is it again?
s 14 MR. KIMBALL: The Ghost Stance Fault runs right 15 across the top.
16 MR. MOELLER: It is the line across the top.
17 MR. KIMBALL: It is the line across the top.
18 MR. MOELLER: Thank you.
19 MR. KIMBALL: Showing a dipping to the west it 20 would be. A hand drawn location by Mr. Scott of where 21 roughly the shaft site would be at that time. And some of 22 the features that were mapped along the side of Coyote Wash.
23 As the staff may have pointed out to you, if you 24 now plot the current location of the shaft, they would fit 25 slightly off of this figure. Given the scale of this Heritage Reporting Corporation
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]( ): 1- _ figure,..the-first: shaft is just off here.
21 MR . HINZE: Before you remove that, Jeff.
[ '3L MR. KIMBALL: Sure.
ll ' HR. HINZE: -What is the outcrop control on thia, i 5- what is the quality of the outcrop? l f
~6' MR. KIMBALL: In general once you get into the i
7 . walls;and up on the ridges, the outcrop is very good with
.8- the'following caveat. That the stratigraphic units tend to 9 be gradational, so you have to get very experienced with 10 seeing that gradational contact. And obviously that 11 gradational contact, your ability to map it ends up with a 12 certain resolution to saying that you are able to see faults 13 or not able to see faults and fractures.
~
.14 ' One thing that I wanted to point out, and if I
- O-15 did not do it here I was going to do it because we have a j 16L later map basically showing the same area, is that you can 17 see based on this mapping, and it is true of all.of the 18' geologic maps that exist of Yucca Mountain, that when you !
19 spend time looking at the outcrop that you find that the l 20 outcrop is jointed and fractured. That is a condition that 2 0
21 exists essentially throughout Yucca Mountain. It is a l 22 condition that is typically associated with this type of 23 volcanic material, particularly the welded tuffs. I think r
24 that the hydrologists on the staff pointed out the same !
I 25 condition.
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176 1 It is-an important point in bringing that out in 2 terms of when one worries, I guess that would be the.right 1
3 word, about.a fault is that one-has to put that into 4 perspective for this site with the fact that the rock is 5 fractured anyway,-in terms of any waste isolation concerns.-
6 And I will touch on that topic when we get to the 7 comparative evaluation.
8 MR. HINZE: If I may, please.
9 MR. KIMBALL: Sure.
~
10 MR. HINZE: The 1ine again, could you please 11 indicate what the significance of the line has north wall 12 fracture analysis on the.right-hand side?
13 MR. KIMBALL: This?
r- ' 14 MR. HINZE: Yes, the line curvilinear.
15 MR. KIMBALL: It is an area that the geologist 16 spent more time basically with the outcrop that he had 17 available doing a more detailed pattern of counting and 18 looking at orientation of fractures in terms of the fact 19 that the fractures will filled with certain material. In 20 the Dixon letter, I believe that it refers to it.
21' MR. HINZE: What directed him to that particular 22 route, were there more fractures there, is this abnormal or 23 is this representative?
24 MR. KIMBALL: I would have to ask him that 25 question. I really do not know the answer.
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()[ 1 MS. MOODY: The other point too, Dick, is the 2.
fact that'the line is dashed, is that indicating that may be
'3 a. fault?
4 MR. KIMBALL: Up here?
5 MS. MOODY: Yes, the dashed line.
6 MR. KIMBALL: Here?
7 MS. MOODY: No. Move over further to your right, 8 that line, yes.
9 MR. KIMBALL: I should have had that symbol 110 probably explained. If it is not explained, that is just an 11 Linner stratigraphic contact line. If I can tilt my head, it 12 is the transition between the unit called the rounded step 13 'into the unit called the upper level. That is just the 14 contact-line.
15 MR. HINZE: If I may while you have that on 16 there, unless you are going to show it on another 17 transparency, could you briefly show us the position of the 18 . geophysical surveys which were conducted in this area?
19 MR. KIMBALL: Sure. I do have it on another 20 transparency. But if I do not get to it, remind me.
21 MR. HINZE: It is particularly interesting in 22 view of the geology.
23 MR. KIMBALL: Yes. We have on one of the later 24 viewgraphs, I believe that I put all of the same features 25 that are on this map along with the geophysical surveys.
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/m 1 The only point to make is the reason that we put this point 2 on here is again that the same person, Mr. Scott, who 3 published the Yucca Mountain map using the same information l l'
4 that:he did in 1982, an6 that map extends throughout 5 Yucca Mountain and it includes the area where the current 6 shafts are located. And that map also has identified no 7 surface expression and no evidence of fault.
8 In 1985 both in the mission plan and in the draft 9 environment assessment back at that time, DCE announced that 10 two shafts would be constructed instead of one. The primary 11 reason was it was based on a consideration of requirements 12 in terms of emergency egress and ventilation requirements, i 13 Between that time and 1987, the DOE and NRC had gs 14 interacted a number of times. The NRC expressed a number of
(-
15 concerns about the shaft. And the two primary concerns 16 related to shaft location had to do with the issues of 17 erosion and flooding.
18 During that time DOE assessed these issues based 19 on the NRC concerns. And in April of 1987, there was a 20 meeting out in Las Vegas between the Department, the state, 21 and the NRC to discuss proposed changes to the shaft 22 location in an attempt to resolve the NRC concerns. At this 23 time the location changes were based again on best avai.'.atie 24 information available in April of 1987. So they consisw. d 25 information that had become available between 1982, 1984 and Heritage Reporting Corporation
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l 2 If you could just flip to the next viewgraph real ,
l 3 quick and I will come back to this. Maybe we should just )
4 flip it to the side so we have the same orientation that we 5 did before. This slide is up this time. This is Coyote 6 Wash through here. The old shaft for site one is here and 7 that is about where the dot with the X was on the map that I 8 showed you from the Dixon letter. The bore hole G-4 is 9 here. The second shaft, the old second shaft, was here.
10 And in that meeting DOE proposed to move the first shaft 11 440 feet to the northeast of this location and to keep the 12 second shaft approximately 300 feet away from that. It then 13 had to move the second shaft to that location.
14 MR. MOELLER: At that time of course you were 15 moving the shaft around based predominantly upon surface 16 factors, flooding, et cetera.
17 Were you also thinking about whether the shaft 18 would enter a representative section of the repository 19 block?
20 MR. KIMBALL: I think that one of the criterion 21 in Bertram was to address site characterization data. In 22 fact it was about the most heavily weighted screening 23 criterion at that time. When the move was made, they 24 essentially honored the Bertram preferred area. So if Mike 25 would put that back up. I would have to try to trace it Heritage Reporting Corporation s,) (202) 628-4888 J 1
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(_) 1 with my hand. But essentially the move from here to here 2 was honored inside the Bertram area. In other words, they 3 wanted to stay in that same area that had already gone 4 through a screening process. Part of the criteria of that 5 was the ability to get representative site characterization 6 data.
7 The one item to point out at this time as 8 documented in the meeting minutes is that there was a 9 general agreement, the NRC generally agreed at that time and 10 I call it generally, that the shaft location was adequate.
11 But they did have a number of concerns back then and even 12 earlier than then to ensure that DOE show that the location 13 of the shaft did not impact waste isolation. Those concerns 14 precipitated a number of analyses that had been made. Some j f-)
s/ '
15 of those were reported in the CDSCP and in references to the i 16 consultative draft.
17 However based on that review, that information 18 and discussions at that time resulted in another NRC comment 19 last year that DOE re-look at the shaft location issue and 20 this time explicitly look at it with respect to waste 21 isolation since this was not an explicit consideration in 22 the Bertram study.
23 In response to this as part of the technical l
24 assessment review that Mike had mentioned, different than 25 the DAA, the DOE also did a comparative evaluation of the l
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_1 . waste isolation, capabilities of.the' alternate' shaft j 2- ' locati~ons , the five preferred areas in the Bertram report.
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'3 So we went back and looked at those preferred areas. i
'4~ That essentially ~the historic perspective on it, i- 5 and what:I 'would likeito do now is just spend a 'ninute 6 summarizing what was done as part of that. comparative 7' . evaluation, recognizing that this does not really go into "8 the detail of:the work that was done, but just to give a L
L 9 flavor for what we did and basically the bottom line 10 conclusion of that review.
j, .11 MR. MOELLER:. Dr. Hinze.
12 .MR. HINZE: Jeff, before you start on that, I 13 want to make certain that I understood a statement that you 14 just made.
15 You reviewed the location in terms of the five 16 original sites and not the whole' site as a whole, is that l
'17 correct?
18 MR. KIMBALL: Both. Mike, if you could put that 19 up for me. What I will try to do is come back to the 20 purpose on the next viewgraph also. The purpose of the 21 comparative evaluation was to address three issues in terms 22 of waste isolation. The first one would be to look at the 23 preferred areas and compare and contrast them in terms of 24 waste isolation-and say would it have made a difference in 25 the selection of one of those five.
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p (f lLL The next part of'it. was saying how about if you I
~2 add a shaft to any of those, does that make a difference, l
- 3. ,does adding a shaft to this spot versus any of these other >
U I 4' spots affect any judgment that you would have made. And-the i 5 third part is the part where we then included the rest of 1
h 16- the repository and said if you had now basically put these 7 five areas in perspective ith the rest of the repository 8 .and would that have made a difference in terms of location 9 and selection. So the third piece did try to address the 10 ' waste isolation aspects of shaft location in terms of the-11 entire repository area.
12 -MR. HINZE: And did you have detailed geological 13 and geophysical data?
114 MR. KIMBALL: If you can go back to the next 15 viewgraph.
16 MS. MOODY: That is tied into a question that I 17 had, what were the criteria that you used?
18 MR. KIMBALL: I will skip over this since that is 19 just basically what I said. What we attempted to do was go 20 on to existing performance assessment calculations that were
- 21. available and existing hydrologic modeling and information 22 used to develop a site characterization plan. And the 23 criteria that we identified were a set of site 24 characteristics that we thought were useful to comparing 25 potential performance of the alternate locations.
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183 1 Without having.the full list in front of me, I l2 . can try to give you some examples that we. thought were 3- essential surrogates for performance. .One would be the 4 -thickness of the unsaturated zone beneath the repository 5 elevation and the water table. That does change from shaft 6 ' location to shaft location.
-7 The next one a little more detailed than that 8 would be to take that whole unsaturated zone and break it.up 9 into its subunits or its units, and each of those have 10 -different pros and cons in terms of hydrologic aspects. The 11 welded units and some of the non-welded units have slightly 12 different hydrologic characteristics which make.for example 13 the probability of fracture flow higher than one in relative 14 sense compared to the other.
l 15 The distance from adverse structures was another 16 consideration to attempt to address issues such as is there 17' an intervening structure that would provide some type of 18 pathway with horizontal flow. So while exact performance 19 assessments were not done for this comparison, we1 attempted 20 to pick a set of characteristics which we could compare-in 21 contrast between the five locations and the whole site to 22 try to make a judgment, to make the judgment of whether one 23 site is different than another and what would it mean.
24 I have one example that might be useful to show.
25 It is not in your package if you could pull it, the second l
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() I to last one just to show an exnmple of it. This example is 2 pulled right out of the comparative evaluation and there are 3 numerous plots like this to show what criteria or what data 4 were used to compare and contrast.
5 This one is the total thickness of the 6 unsaturated zone between the repository and the water table.
7 You can see for example that the current Area 4 where the t
8 site is has about 700 or 720 feet of unsaturated zone 9 compared to 10 Area 1 which in the middle would have about 950 feet and 11 compared to the part of the repository down at the southern 12 end which has considerably more.
13 The inference from this type of figure is that if 14 you had an equal performance line that they would g~)3
%- i 15 essentially be somewhat perpendicular or roughly 16 perpendicular to those contours and that performance would 17 be relatively better at this end of the repository where you 18 have a thicker unsaturated zone which you expect to give you 19 longer ground water travel times. These were the type of 20 comparisons that were made at the time.
21 One point to be made in coming up with those 22 plots and things like that is again the comparisons were 23 made with the best available information. We again used as ,
24 much information as we could to develop the data base or the i
25 criteria to compare and contrast. :
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'2 ~ documented in the comparative' evaluation was that 3- differences between'the shaft locations in the opinion of 4
4' the group that put'together the_ comparative evaluation would 5 'not have' changed the' selection of the current location if a
6 that had been an explicit consideration'in the Bertram 7 study.
.8' In fact possibly the opposite would have 9 happened. It might have added another criteria that would 10: have strengthened the scientific basis for choosing the
' l l' current site. I would like to. explain that and just take a 12- minute.to explain it. As the example that I showed you, on 13 average the characteristics of the site when trying to_look 14 at the site characteristics in terms of what they may mean Os .
15 for performance, the same trend appears to occur in that the 16 relative least favorable performance tends to be in the 17 northeast corner of the repository toward where the 18 exploratory shaft facility is located, that whole corner lL 9 basically _and not necessarily a point.
20 But the point to be made is that if one wants to 21 structure a conservative characterization program to address 22 uncertainties in parameters and processes that most 23 adversely affect performance that the quadrant of the 24 repository essentially that the shaft is in is a
-25 conservative quadrant to be in.
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'( 1 Compare that with the entire opposite corner of 2- the repository, which.would be the south block or none of i
3' the preferred sites, one could challenge that if one were to 4 .put a shaft down there in terms of the shaft.being a'means 5 to get' underground to do testing, particularly to'do 6 processor in situ related testing, that that might not be 1
7 conservative'in terms of addressing all of the factors that 8 .could be'important or could exist throughout the whole area, i
9 The last point that I would like to spend a few t- 10 minutes talking about is the geophysical anomaly that has 11 been inferred to be a fault near the current locations. I 12 would like to first point out before I get into the details 13- is that at various times it is not always explicit or 14 transparent what information is or is not used. And O 15 ' geophysics probably tends to be the lone wolf. Sometimes 16 people while they know about it they do not always know 17 about it.
18 I think that in reviewing all of the historic 19 documents that probably the existing geophysical information 20 has gotten the short shrift in terms of being explicitly 21 written up about when decisions were made. That is one of 22 the reasons that we thought from the information as best as 23 we could tell was available to the geologist. They knew 24 about it when they went out and did the mapping. However it 25 is not explicitly in any document. We thought that the best Heritage Reporting Corporation (202) 628-4888 l 1
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187 l ) l' way to' address the questions that are being raised was to
'2, perform a-new or current technical assessment review to 3 explicitly go back in the record and look at that
,l 4 geophysical data and the interpretation.
5' This just states as you are aware'that as part of 6 the NRC's review of the site characteristic plan that they
'7 have found 1979 work documented in a 1982 open file report 8 which has been interpreted to show a fault and I will show
'9 -you a map of it where it fits in terms of the current shaft 10 sites.
11' I will touch on these in the next figure where-12 the data lines are, where the anomaly is and where the 13 inferred fault is. This is just'to re point out in an 14 explicit sense where you can find documentation that we have 15 relied on a detailed geologic mapping completed by the USGS
- 16. over time. Not necessarily just the Dixon letter, but 17 throughout-the time. And the mapping has consistently shown 18 that there is no faulting within several hundred feet of the 19 shaft. And I will describe a little bit of what the 20 technical assessment review is.
21 (Continued on next page.)
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l 1- .MR.-KIMBALL: Again, on this! figure, north would 2 be straight up. We-will: call this a-rough schematic map r; .g
.3 because I drew.it myself based on a tracing of some real n' .~ .
4 geologic maps. But I wanted to -- I had to put.different
, 5 features on:it so that's why we did it.
6 Again, showing you the Nevada coordinate systems 7 so if you have this type of information available, you can 8 see'where things came from. Coyote Wash comes up this'way 9- and splits like this. Here is 44. The old shaft then, 10 Shaft 2 would be right here and Shaft 1 would be over in
'll here somewhere.
12 The current locations of the shaft,. Shaft 1 is 13 here and Shaft 2 is over here. Some other features I put on
'14 the map is - (1) is.the Ghost Stance fault from that other
- 15. map. The Dixon Letter geologic features are here. I didn't 16 'put on that'one little squiggly line that said I think 17 " North Wall Fracture" mapping, but that's where that would 18 be.
'19 That's where the southern most dense joining area 20 was shown on the Dixon map. So, it is very close to that 21 shaft site.
22 The two, there are actually three geophysical
- 23 lines run up Coyote Wash. Line A is here. Line B is here.
24 There is a Line B Prime which actually just overlays on that 25 Line B.
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( ll The topography is shown and we put it on this map (
i ~. 2 to' bring up:one of the issues that had been raised during.
3 the technical assessment review. . General' topography, ,
1 (
h 4 50-foot contours. : And the. resistivity anomaly or where'the l 5 inferred fault is.
6 And the other. thing I've' labeled on this map, 7 instead of theLcontacts themselves, is just the rock-8- alluvium contact.- So,.this area in here is all alluvium.
9 Land this area outside here is all bedrock, i 10 Dri Hinze, do you want to make-an additional ill- point with us before I go on?
12 MR. .HINZE: Well, I was interested in where the
- 13. geophysical surveys -- where are the rest of the surveys 14 that have been conducted in the area?
15 MR. KIMBALL; Right up Coyote Wash? j 16 MR. HINZE: What else has been done?
17 NR. KIMBALL: There is some electromagnetic -- in 18 terms of surface or borehole? I'll try to address both, i 19 actually.
20 MR. HINZE: Surface to borehole?
21 MR. KIMBALL: They both have been done I guess is.
22 what I am trying to say and I will try to address both.
23 A couple of points. One is all of Yucca Mountain 24' has been geophysically surveyed on a number of things like 25 gravity and aeromag and things like that. So, the whole gg Heritage Reporting Corporation
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J2 ' In particular at Coyote Wash, there are about p, 3 the same: time frame,,there were some other geophysics run.
- 4. .The: exact lines -- I'll-have to pull out another. figure and L .,. 5 -see, exactly where they are but they essentially come up 1
'6 Coyote Wash also and that's electromagnetic type work.
7 -Going back on those interpretations in terms of 8 this' particular resistivity anoinaly, .this .particular 9 inferre'd fault, for example, it is.not pointed out on those 10 lines. Whethe.r they explicitly knew about that 11- interpretation or not, I don't know. We would have to go
'12 back and talk to them.
13 There is down-hole geophysics in G4, a number of 14 ~ measurements. And there are other boreholes, I am sure they
?O.
15 do fit on this diagram somewhere out in this area and going 16 further to the east that also have down-hole geophysics.
.17 And off the map, there is another wash that comes up out to 18 .the northeast, drill-hole wash which has a nur.ber also of 19' geophysical measures in them.
20 MR. HINZE: Does that lead to any hole to surface 21 work on G47 22 MR. KIMBALL: In the past, no, I don't believe 23 so.
24 MS. MOODY: On your Ghost Stance fault, when 25 you've got that solid line versus the dashed line, is the Heritage Reporting Corporation O *
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191 d) 1 dash just.not on the surface? What are you showing there?
2 MR. KIMBALL: Yes. This is just taken right off 3 the map as the way it was mapped. But this little kink here 4 is essentially a small eroded out area. Bob Scott when he 5 did the mapping on it, there's a contact that.would run 6 about half-way up the hill here, he does find four meters of 7 displacement on it. But I think the reason he dashed it 8 there is while he sees evidence for a fault, it is concealed )
9 between --
10 MS. MOODY: The alluvium.
11 MR. KIMBALL: Yes. But there is evidence that 12 four meters en a certain stratigraphic unit where he 13 believes he can see it, that's where, f- 14 Lastly, I would like to talk about the technical
+
N-15 assessment review. It's an ongoing evaluation that the 16 Department, the Project Office, basically, is doing at this 17 point. It has the following purpose. One is to explicitly 18 review the geophysical data anu ia,erpretations that have 19 been made. And that is not just tha resistivity data which 20 has been most talked about, but actually the USGb 21 participant on this is searching through the system to make 22 sure we have an accurate picture of all the geophysics that 23 have been done at Coyote Wash. To also look at other data 24 that relates to the possibility of faulting in the vicinity 25 of the shaft location. In particular, the most readily I
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i h 1 'available' data is the geologic mapping that has gone on in 2 the past. .
3- Then based on these two major piecesto evaluate. :
4 whether faulting is present or absent, identifying i
5 uncertainties or restrictions on the ability.to say .l 6 conclusively whether a faulting is present or absent, then 7 to provide those recommendations to the DOE manager.
8- Within'this two groups ~have been formed to j 9 address the issues up here. There is actually a third group 10 recently have been formed to tried to pull it altogether.
11 But the two major groups have been formed to review both the 12- geologic evidence and the geophysical evidence.
'13 And then.the results of that will then be 14 integrated to make the final recommendations. That's the 15 main role at this point of the third group, I would just 16 point.out that I am kind of a pseudo-member of all the 17 groups. Being DOE I can do that, I guess. And there is 18 another DOE person from the Project Office, but I am 19 participating in essentially all aspects of the technical 20 assessment review. Probably participating more in the 21 geophysical end than the geologic end, but trying to follow 22 all of it as it goes on.
23 And, lastly, to point out being a technical 24 assessment review, it is being completed as a quality level 25 1 activity under subpart G controls. And if all goes well, Heritage Reporting Corporation O- (202) 628-4888
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1 we hope to be finished in July or August of this year.
t 2 At the okayed of the group -- I talked to them i
3 last week -- I am able to tell you a couple of things about-4 the ongoing review. One is that the geology field group has I k
5 completed a field check of locations. And the results of j 1'
6 that field check is that they have also found no evidence of 7 surface faulting.
8 I think the general conclusion that they're l
, 9 reaching is that the mapping completed by the USGS appears i 10 to be of excellent technical quality. They are able to 11 identify; features and about the right location that the USGS 12 has on their maps. So, they are getting a good feel for 13 what Bob Scott actually saw in the field when he put those 14 features on the map.
15 And I spent a fair amount of time walking along 16 the Ghost Stance fault at various locations to get an 17 understanding of what that kind of feature would look like 18 if it was to be seen in other locations.
19 The geophysical data, particularly at this point 20 the resistivity data, and we're still searching to see what 21 other information needs to be reviewed. The main point 22 there is based on the review we've done to date, I think the 23 team basically feels that the data could have been 24 interpreted in other ways than a fault.
25 It is worth pointing out that it was completed in g- Heritage Reporting Corporation
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. l' 1979.and a lot' of more data has become available since 1979 1
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- 2. ~ and prcbably gives.one more of a basis to stand back and 3 interpret: it differently than it was ' interpreted back .at.
-4 'that time. -There was much more limited data available. ,
,; 5; Some of the issues that have'been brought out, 6 ~ Mike, maybe-you can. throw me back the figures showing the H ,
' .7 : lines just ' to point out a couple 1 of things.
8 A couple of issues to point out, the authors that
- 9 did the original work knew that, for example, topography
-10 could be an- important uncertainty in how one interprets the
- 11. lines.
12- In. fact, they assumed that they would need a 13: -topographic-correction along the line and they recognized at
' 14 the' time that a three-dimensional-topographic effeet may.be
' ~
15 important. It is worth pointing out: It's a "may". We 16 don't know. ,
17 But also to point out that with the locations of 18 the lines are essentially near very fairly substantial hills 19 out here which is essentially all bedrock laterally from the
)
20 line in this' direction and all alluvium laterally almost 21 from the line in this direction. And almost the same 22 consideration can be said about this line.
23- Additionally, the authors at that time had a 24 concept of what importance the alluvium itself would have on
'25 their interpretation. I think now we probably look at it a Heritage Reporting Corporation O (202) 628-4888
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195 (v) 1 little differently than they did and say that making sure we 2 model correctly the alluvium, particularly where it crosses 3 the line is an important consideration.
4 So, if you go back, that leads us to some 5 relatively simple modeling that two separate groups are 6 doing as part of this technical assessment to try to look at 7 the sensitivity of topography and I apologize I left off and 8 the near surface alluvium.
9 The modelling that was originally done was fairly l 10 complicated and this modelling is being done to try to 11 address whether you do need a complex model to explain the 12 data or some simpler models particularly those that address 13 topography and the near surface alluvium could essentially
- f. s 14 explain that data.
(j 15 All technical assessment review results are 16 reported per the procedure in something entitled the review 17 record memorandum and these recommendations will be done 18 that way, also.
19 What I would like to close with before I restate 20 the conclusions is some actions that DOE is basically going 21 to state and I've probably stated it at various times in the 22 past. The first one is that the pad excavation when it goes 23 in will be mapped in detail. We believe that that will 24 provide the most definitive evidence for any substantial 25 faulting or fracturing at the site.
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)) -1 We point out here, though, that based on all the 2 mapping we_have, we. fully expect in putting the pad in or 3' essentially.throughout' Yucca Mountain that fracturing,
'4 particularly in the welded' units, jointing,and fracturing, 5: we'will' find in a number of locations.
1 l: '6: That basically is the' reason'we continue to 7 support the second action'and that is in particular'for the' 8 shaft, we are going to do continued modelling during Title 9 II design, performance type modelling to evaluate the 10 = sensitivity of the' shaft performance to fractures or faults 111 that may' intersect the shaft as possibla water ingress 12 pathways.
13 Some.of the preliminary work along these lines is 14 reported in Section 8.4 of the SCP and we are going to 15 . continue that type of work as we go through Title II design.
16 . Finally, as a commitment that we will evaluate 17 the recommendations that come out of the technical 18 assessment review and explicitly recognizing that some of 19 those recommendations may suggest additional field work. .At 20' this tirce, I don't know if it will or won't. But those will 21 be carefully evaluated and if need be additional field work 22 would be done.
23 That leads me to restate the conclusions.
24 Essentially, as I said, looking at the record we have from 25- '82 until now, we believe that the best available Heritage Reporting Corporation
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197 o f .1. information was used to make location. judgments essentially 2 Lfrom then until now. 'We have.gone back, looked at the 3 sequence of actions and decisions and we think they are 4' appropriate'. To:re point out that we most recently did an 5- evaluation of shaft location late last year and found that
-6 if waste'isolat' ion had been an explicit consideration that' 7 the current location would continue to be appropriate and to 8- . point'out that we are explicitly now going back and looking.
9 at the geologic and geophysical data and the interpretations
.10 made.to confirm that the shaft locat' ion, again, is
-11 acceptable.
12 Any questions?
13 MR..MOELLER: -Any other questions? Yes, Gene?
14 MR. VOILAND: Could you just satisfy my curiosity 15 about what the field check entails?
16 MR. KIMBALL: Dure. The field check was 17 completed in two days. Basically, the geology team went out 18 there and spent the first day with the map, the old maps, 19 familiarizing themselves with how the geologist made 20 decisions about what they called certain features on the 21 map.
22 And the USGS had two members participating in 23 that who were particularly familiar with the stratigraphy at 04 the site and things like that. Spent quite a bit of time 25- walking the Ghost Stance fault to familiarize ourselves with Heritage Reporting Corporation O- (202) 628-4888 L
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198 a() I what a fault would or would not look like in the field. And 2 spent most of the second day walking to contacts above the 3 shaft sites and staking and flagging those contacts and then 4 looking at what they staked and flagged based on a group 5 consensus, essentially, and making a judgment whether that, 6 whether what they saw based on that show of faulting or no
'7 faulting. So, that's essentially what --
8 MR. VOILAND: This is all interpretation from 9 observation of the surface. Is that correct?
10 MR. KIMBALL: Yes, from bedrock observations, 11 MR. VOILAND: There were no additional seismic 12 tests or anything like that.
13 MR. JIMBALL: No.
14 MR. VOILAND: Thank you.
O G 15 MR. HINZE: A couple of quick ones, if I may.
16 MR. MOELLER: Go ahead.
17 MR. HINZE: Could you give me an idea in terms of 18 helping to be able to consider the resistivity anomaly?
19 What is the contrast in the resistivity between the fault 20 gouge material and the surrounding Calico Hills.
21 MR. KIMBALL: I'm sorry. I didn't hear the last 22 part.
23 MR. HINZE: What is the difference between the 24 resistivities in the Calico Hills where it is unfaulted and 25 the fault gouge, approximately? Resistivity contrast.
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199 (m) 1 MR. KIMBALL: For the anomaly, itself, I guess I 2 am still not sure of your question.
3 MR. HINZE: The anomaly is being interpreted on 4 the basis of a resistivity contrast between the fault gouge 5 and the unfaulted Calico Hills.
6 MR. KIMBALL: Right.
7 MR. HINZE: What is the contrast as a result of 8 borehole geophysical work?
9 MR. KIMBALL: Well, let me answer the first 10 question. The. anomaly itself, the anomaly is measured from 11 the surface, itself, is about a factor of 3 to 5. So, it is 12 a substantial anomaly. In terms of the relative resistivity 13 from the low where the fault is interpreted, the fault was e 14 interpreted where there is a resistivity low and the b 15 surrounding measurements I think baseu vu the figures -- and 16 I'd have to go back and look at them, but it is factors of 17 3 to 5. So, it is, from an anomaly standpoint, it is a 18 substantial anomaly.
19 Now, from borehole resistivity measurement that 20 we have been able to gather and that's one of the things we 21 are using to do the new modelling, I would have to ask the 22 people doing it, but I believe their conclusion is that they 23 are getting a relative consistency from borehole to borehole 24 for the stratigraphic units.
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(( ) 1 .they have seen a resistivity value from a zone. And one of l 2 the boreholes that they would call a fault gouge, so they 1
t.
3 could say, "Here is what we see in a fault gouge versus the' l 4 same rock unit that is not fractured."
1'
- 5. We could ask them.
6 MR. HINZE: Thank you. A second very quick 7 question. Is any thought being given to putting a drill 8 hole on the site of the first exploratory shaft?
9 MR. KIMBALL: I would probably ask Mike to help 10 address it, but there is going to be a -- well, two things:
11 in terms of geophysics, the only thing I am aware of at this 12 point is that G4 during the site characterization program, 13 the existing borehole is going to be part of a vertical
- 14 seismic profile.
15 When that is -- we are checking on the current 16 schedule for when that would be in terms of the timing of 17 it.
18 Mike, you can address the drilling that will 19 precede the shaft as it is sunk.
20 MR. VOEGELE: Right. I wanted to point out that 21 virtually as soon as the pad construction begins, one of our 22 first activities will be to go in and put in the 23 multipurpose boreholes that are to be used to monitoring, 24 detection of water and monitoring shaft construction. There 25 is one by each of the shafts. And they will be virtually Heritage Reporting Corporation
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201 ft( ,1 .the first' activities we do in the field after'we level the.
'2 ' pad area.
3 MR. HINZE:1 But that is not being done as part of li ~this technical assessment?
5 MR. VOEGELE: No.
6 MR. HINZE: Thank you.
v 7 MR. KIMBALL: If that is all the questions. We 8 'have one more relatively short presentation and that'will be' 9 by Dr. Alexander pn performance assessment.
10 MR. MOELLER: As Dr-. Alexander comes forward, I 11 would like to give a moment to_ Ralph Stein. Just use that 12 microphone, if you want to, Ralph.
13 MR. STEIN: Thank you. There was some 14 interesting question related to quality assurance activities
.O 15 that are currently underway in support of the Title'II 16 design activities. And what we responded is that we have no 17 QA level 1 activities currently underway as part of design.
18 And that is correct. But I thought that because of the 19 interest that was expressed you might like to know the 20 schedule. So, we called back and it looks like, based on 21 our schedule, that we have some quality level 1 activities
- 22 that will probably be starting up in the next about two 23 weeks from now.
I '
24 So, that is current information and I know that 25 Dr. Moody was interested in that.
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( l' MR. MOELLER: Thank you.
2 Dr. Alexander, you are the summarizer or the 1
3 commencement speaker?-
4 MR. ALEXANDER: Yes. Good afternoon.
5 As you know, I am Dr. Alexander, Chief of the 6 Regulatory Compliance Branch. I work in the office of 7 Systems Integration and Regulations. Ralph Stein is the 8 Director of that office.
9 In the next 10 minutes or so I will address a 10; couple of concerns raised during your review of the SCP in
'll the. area of performance assessment.
12 First, I will focus on two major concerns raised.
13' by the.NRC Staff. The first regarding the incomplete
- 14. presentation of performance assessment in the SCP and the 15 second regarding the belief that only one total system 16 performance assessment would be conducted and that wouldn't 17 be until 1993.
18 Finally, I would like to clarify our approach to 19 the treatment of human intrusion in the CCDF and try to 20 answer any of your additional concerns.
21 May I have the next slide, Dave?
22 Now, with regard to the first concern, the SCP, 23 as you know, is specified in the NWPA was intended to be a 24 ' general plan for site characterization, performance 25 assessment is used in the SCP only insofar as it assures Heritage Reporting Corporation O (202) 628-4888
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' n'/ 1 that the test program at an investigation level of detail is ss 2 adequate.
3 The SCP was not intended to provide an in-depth 4 performance assessment program plan. It is intended to be a 5 general plan for site characterization. Nevertheless, a 6 considerable emphasis is placed on performance assessment in 7 the SCP. First, PA is fundamentally a part of the licensing 8 strategies throughout Section 8.3 of the SCP. Analyses will )
9 be required for the resolution of issues within each of 10 those strategies. And, so, you should look at those 11 strategies very carefully and I think you will note that 12 there is considerable work from the performance assessment 13 point of view that has been woven in there.
- 7. 14 Secondly, only summaries of PA strategies appear
)
15 in the SCP. There are, however, approximately 500 pages of 16 such summaries in Section 8.3.5 of the SCP.
17 Finally, however, DOE recognizes that there is a 18 need for a carefully planned PA program. Thus, a parallel 19 set of documents are currently being developed that Ralph 20 mentioned this morning -- earlier, which will provide the 21 detailed integration of PA and site characterization 22 activities and they include the performance assessment 23 management plan, a strategy plan, and an implementation 24 plan.
25 MR. OKRENT: Before you move on, the first bullet g3 Heritage Reporting Corporation
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-204 M] L1 says that.' licensing.. strategies in the'SCP show how PA fits.
- 2. .into issue resolutions, strategies and prioritizes. .'Have 3 there.been some performance assessments done,' written down, 4' that'we'can see which would show us where testing.was-5 prioritized, for example?.
6 MR. ALEXANDER: In that context, the answer would 7 be no. The objective of the licensing strategy development 8 was to lay'out a logic, a system-logic upon'which future 9 calculations of the system would be approached. From that 10 logic,.then, we would go back'and look at what-information-11- 'was needed to resolve the issues that are discussed in that 12 Section 8.3.
13 MR. OKRENT: I read those pages. It was some 14 months ago,.but I did read them. If you haven't done any g-
- 15. performance assessment, when do you expect.to-have completed 16 performance assessments, which performance assessments, for 17 example?
.18 MR. ALEXANDER: That's a topic of about two
.19- slides forward. And, so, I will cover that in some detail.
20 I think that is a very important question and I want to hit 21 on.that. I agree with you on that one.
t 22 MR. OKRENT: I can be patient that long, i
23 MR. ALEXANDER: I'm almost there, though. '
24 The next clide?
25 Okay. I wanted to tell you a little bit about
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1 each of these documents. As we mentioned in a previous 2 . meeting, two of these documents will be available in the 3 fall for information purposes.
4 The first is a management plan which describes 5 the organizational responsibilities for performance 6 assessment throughout the program. It will discuss the 7 technical objectives and major milestones and in a sense 8 will be used as our QA document.
9 The strategy plan, on the other hand, describes 10 the general technical strategies, specific strategies for 11 major milestones and objectives and importantly deals with a 12 question that was raised several times today about 13 integration of performance assessment with site and design, f _.
14 The implementation plan will be issued each
~'
15 fiscal year. Essentially, it is a rack-up of the work 16 statements that will ha conducted by the various 17 laboratories and other organizations. It will address near-l 18 term PA activities and the role of each of the activities 19 within the integrated effort.
20 Next slide, please.
l l 21 MR. POMEROY: Excuse me. But you said tuo of 22 them would be available in the fall, I believe. ;
l 23 MR. ALEXANDER: Right.
24 MR. POMEROY: When will the third cr= be 25 available? Because I assume the PA can't go forward until l
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() 1 all three of those are written.
2 MR. ALEXANDER: The PAIP will be available at the
-3 end of this fiscal year, bocause as you know, it will be 4 used to implement our program in FY 1990.
5 Finally, then PA is a part of the overall issue 6 resolution strategy. It contributes to performance 7 allocation and thus to prioritization of testing. It is 8 integrated into the development and review of the site 9 characterization study plans. There are approximately 30 10 study plans which directly address analysis.
11 And, finally, PA is now and will continue to be 12 used to evaluate the adequacy of parameter needs and test 13 dats es it was in 8.4 in the SCP.
~ 14 The second concern which gets back to
~
15 Dr. Okrent's question is that PA of the total system would 16 only be conducted once and this would not be until 1993. We 17 probably weren't as clear as we should have been in the SCP 18 and numerous -- because numerous total system and subsystem 19 cualyses will be conducted each year for the next several 20 years. In FY 1989, we'll conduct preliminary PA exercises 21 in all the major areas.
22 Right now, there are a number of analyses that 23 are already coming in.
24 Dr. Okrent?
25 DR. OKRENT: By the way, it is not I who raised
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(_f 1 the question would they be conducted once or before 1993, 2 but I am interested in knowing more about just what it is 3 you say you are doing now and what it is you expect to have 4 in FY 1990. If you are doing some now that means in fact 5 there have been some techniques, methodologies defined, 6 presumably written down, reviewed, and at least given some 7 kind of preliminary approval for whatever it is you are 8 doing. And.I assume, hence, there is some kind of written 9 documentation that could be made available to the NRC or 10 maybe has been and to this committee. Is that correct?
11 MR. ALEXANDER: There are a whole suite of codes 12 that are currently in use in the Department of Energy for 13- the purposes of looking at total system performance 14 assessment, engineered barrier assessments, waste package (g
f
/
15 release rate and lifetime hydrology, et cetera, et cetera.
16 There are a lot of codes that are currently in vogue.
17 DR. OKRENT: That is a general answer in a sense 18 because if I were asked by Dr. Moeller, "Look at whatever 19 you were doing on system assessment." I would presumably 20 have to prepare the set of scenarios that he wanted me to 21 include and to see in fact is your methodology adequate for 22 assessing these scenarios and so forth and so on.
23 From your answer, one has no idea, you know.
24 There are systems and there are systems. Do you understand 25 what I'm saying?
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f 1 MR. ALEXANDER: Right. I do.
\-)
2 To follow up on that for a moment, with respect 3 to the first bullet that we show here in 1989, there is 4 currently an going exercise which is laying out a whole set 5 of problems in the four major areas of the performance 6 objectives in the rule: namely for total system, for the 7 engineered barrier systems, and for groundwater travel time.
8 There is a meeting that is going on at this very 9 moment out in Las Vegas to try to bring all that to closure.
10 That material will then be used in part to define the FY 11 1990 work. The problem sets that I have seen so far are 12 very extensive and I think we are going to have a really 13 exciting year next year in evaluating these problem sets.
14 The purpose of the problem set exercise next year O' 15 is to determine where our capability strengths are, where 16 our weaknesses are so that we can build the kind of program 17 we will need several years down the road to conduct major 18 assessments that are listed here in the out years.
19 DR. OKRENT: Can I continue then just for one 20 more moment?
21 MR. ALEXANDER: Sure.
22 DR. OKRENT: It sounds like you are working 23 progressively now to develop some kind of methodology which 24 you will be able to exercise for the first time and find 25 the weak and the good points and so forth. It will be Heritage Reporting Corporation
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- /* l' 4 another year after 1990 before you have a;second round of 2 - methodology.- -It.seems, just listening and-thinking how 3 rapidly can.one really develop something for so_ complex'an 4 'overall' set of scenarios, it may be 1992,.really, before you.
o p
L 5' have any~ feeling you want-to say is good enough to set
, 6 ' priorit'ies.
- 7. The point-I am trying.to.make is you are saying 8 you are going'to use these'to set priorities, but I think 9 you are going to have many of your measurements well 10 underway determined, however you want to put it, before you.
11 think you have a system of analysis that is. good enough'that-
^
12 it can set the priorities. Am I missing something?
13' MR. ALEXANDER: No. Of course, the analyses that'
- 14. we're going to be doing over the next couple of years are 15 data constrained. They are very Jimited with respect to the '
1
~16 . amount of data that we have from the site.
17 But on the other hand, there is a lot of 18 . information that is available in the geologic literature and E 19 from the site which has been obthined over decades which we 20 can use to do some preliminary scoping calculations. 'But 21 the objective right now is to not come up with a definitive 22 analysis of the system next year.
23 The objective, as I stated earlier, is to try to 24 define our strengths and weaknesses.
25 (Continued on next page.)
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( l 1 MR. POMEROY: I would like to ask one question,
,2 Don, if I'may. .
3' MR.. ALEXANDER: Sure.
4 MR. POMEROY: Your second billet under FY 89 5 says,. ILthink, that you are going to-conduct a comprehensive 6 assessment of ESF titlod "To' Design". Is that presumably by 7 the end of'FY'89?
8 MR.: ALEXANDER: Actually that is being 9 initiated -- it hasn't been' initiated yet. It will probably 10 be. initiated later this' year, .and hopefully in FY 90 we will 11 get1some results for that, so it is not fully underway.
12 Sandia International Laboratory is in charge of producing 13 that analysis. I spoke to the lead person there just the
'14 other day about that.
O 15 MR. POMEROY: Thank you.
l .16 MR.~ ALEXANDER: Yes. In addition we will be 17 doing some assessments of the system to define requirements 18 for ACD, and in 1990 then, we will be conducting these 19 sensitivity studies.
l 20 We have been encouraged by the NWTRV to conduct 21 the sensitivity studies. We have been planning for them 22 well over a year, and it looks like we will be ready to 23 conduct those next year.
24 We will be begin to think about the assessments 25 required to support the EEI scoping hearings, and the nature Heritage Reporting Corporation
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i) 1 of those analysis is different from those which are in the 2 main stream for the safety analysis report.
3 In that, we are looking at dose rather than 1
4 cumulative release. And then -- Dave, if you could move the 5 slide a little bit please. In FY 91 we will complete the 6 assessment of the system, sub system to evaluate the ACD, 7 and we will initiate the EIS performance assessments based 8 on the current schedules.
9 In FY 92 we will start conducting the EIS 10 performance assessments based on the issuance of a draft DIS 11 in the 10-93 time frame. At that same time in FY 92, 12 current plans are to conduct the performance assessment to 13 finalize the approach for the SAR.
,r 14 I would like to mention one other significant
(~
15 analysis that we are conducting right now, and that has to i 16 do with the evaluation of the suitability of both spent fuel 17 and glass as waste forms.
18 Our target date for the completion of that 19 exercise would be 3-91. Basically the analysis that we do 20 to evaluate the suitability of that waste form involves the 21 evaluation of the total system, because we have to evaluate 22 the waste form in the context of the total system.
23 So that will be a very significant analysis. We 24 have done a complete analysis on the suitability of spent 25 fuel already. That was completed last year within the Heritage Reporting Corporation
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' 11 context of the total' system.
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So there hasLbeen numerous total' system analysis l
3 :done, J and we : fully intend to conduct more. That concludes
<4 ;my-remarks on the major twn. concerns that'were aired, and
.5 .what I would like-to do now is-focus on.the question of U
6 human intrusion,- and how it would be treated in the CCDF, 7 MR.-POMEROY: Lynn, excuse me.
8' MR. ALEXANDER: Sure.
9 MR. POMEROY: How do you' respond, quickly, to the
-10 statements made by the NRC staff this morning, which I also
.11 - share, regarding the difficulties involved in constructing a 12 CCDF. DAre'you saying that you have indeed constructed 13 CCDF's in these various performance assessments, and you 14 have no problem with doing that?
h' 15 MR. ALEXANDER: That is what I am going to 16 address in the next two slides.
17 MR. POMEROY: Oh, I thought you were just 18 treating human intrusion here, and there are other scenario 19 analysis --
20 MR. ALEXANDER: No, I am going to do both.
21 MR. POMEROY: Okay.
22 MR. ALEXANDER: In a previous presentation that 23 we made here, some of you will remember that Scott Scenik 24 presented a CCDF plot. He plotted it up based on available ,
I 25 information from the literature. !
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213 (j. 1 So the direct answer before I go into the two 2 slides here, is that yes, we can construct a CCDF, and that 3 is really not the critical problem, and I am going to tell 4 you what the critical problem is. There is a problem, and 5 I'll get to that in just a second.
6 MR. OKRENT: Isn't it a little bit glib like --
7 it is an unkind word, to say yes, one can construct a CCDF.
8 Of course you can make a set of assumptions that takes one 9 to construct it.
10 MR. ALEXANDER: Right.
11 MR. OKRENT: The issue is can you construct one-12 that has some plausibility as applying it --
13 MR. ALEXANDER: That's in my talk, you're giving 14 them my talk.
15 MR. MOELLER: He's not finished.
16 MR. ALEXANDER: Yes, you are giving my talk 17 actually, but that is exactly the point. The real question 18 is how do -- I am going to talk about it, but I might as 19 well just hit you right back with the answer.
20 The problem is in assigning probabilities to the 21 human intrusion scenarios, okay --
22 MR. OKRENT: Beating those out. You haven't 23 discussed the effect -- in fact, I don't think I saw the 24 word on any of the previous viewgraphs. I did see 25 sensitivity studies. I may have missed it.
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MR. ALEXANDER: Agaih, that is in my next two-
$. 2 pages here.
L 3 '(Laughter.)
4 MR. MOODY: Move forward, Don. )
5- MR. ALEXANDER: Can I move forward? Let me just ~
~6 ' move.. forward, and hopefully then I'll be able to'answerLyour 7' questions. Maybe I'll do it in my talk. Okay first, 8- ^ regardless of how we treat human intrusion'in'.the CCDF,'and I
9' this'-is a real.important point that I want to make.
i
. l 10 We'believe'that.we have defined the data 11- requirements to evaluate' human intrusion scenarios.
12 Therefore I believe that the SEP is adequate in'this area'at 13 the level..of detail to which it has been developed. '
~ 14 Namely that I think we have identified the kinds!
15' of information that we'll need to address human intrusion.
16 That doesn't say that we know how to. assign ~ probabilities to 17 human intrusion scenarios at this time.
18 MR. STEINDLER: Is that data written down some
.19 place, Don? You know, the criteria? Is there a document --
20 MR. ALEXANDER: For assigning the probabilities?
21 MR. STEINDLER: No , on that definition of the 22 kind of data you need.
23 MR. ALEXANDER: This information here comes right L 24 out of the SEP. There are investigations on natural 25 resources, impacts on markers at the site, and affects on Heritage Reporting Corporation fO.- _ (202) 628-4888 i
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L !,,h 1 ' human intrusion. That is all addressed in the SEP.
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2 MR. STEINDLER: Okay.
3 MR. ALEXANDER: Okay second, in developing the 4 test program in the SEP, we wanted to make sure that human 5 intrusion investigations wouldn't be exaggerated. This is a 6 point that led to a lot of confusion in presentations by 7 previous speakers.
8 We wanted to make sure that human intrusion 9 investigations wouldn't be exaggerated at the expense of 10 investigations of natural, disruptive scenarios. This 11 deserves further explanation.
12 Human intrusion scenarios such as the release of 13 radio nuclides due to drilling without suitable constraints 14 such as those in 60.2, and in the EPA standard by the way, 7,)
I 15 have a much greater impact on the cumulative releases to the 16 accessible environment, as the natural event such as 17 volcanism, or faulting.
18 The reason for that is that at this time it is 19 very difficult to assign and defend the probability of the 20 individual human intrusion scenarios. If we were to assign 21 a probability to the human intrusion scenario at this time, 22 the probability would likely be very high because of the 23 uncertainties in establishing the likelihood of what man 24 will do over the next 10,000 years.
25 If DOE had assigned the conservable high Heritage Reporting Corporation
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2 developmen+. of our testing program according to performance l 3 allocation principles, the testing program would be biased 4 or driven by human intrusion scenarios rather than natural 5 events.
6 The difficulty therefore in the definition of 7 human intrusion scenarios and the assignment of 8 probabilities 30 not unique to Yucca Mountain. It is a 9 problem that neecs to be dealt with soon by DOE and NRC, or 10 it will be difficult to construct a realistic CCDF for any 11 site.
12 Now the bottom line is that whatever the strategy 13 for combining human intrusion with other processes and
,_ 14 events in the CCDF are the same set of investigations would
(~)s 15 he conducted for human intrusion we believe.
16 Now my final slide was presented previously by 17 Doctor Felton Bingham. It shows an example of CCDF's for 18 scenario classes S-1 to S-N, and if you assume that one 19 class such as S-2 were to represent human intrusion, the i 20 difficulty, as I have pointed out, is not in combining the 21 CCDF's into a total CCDF, but the problem in assigning 22 probabilities to httman intrusion in the first place in a way 23 we can defend it at this time.
l 24 So the bottom line is that we need to make 1 l
25 certain that we have a common understanding of how to apply
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h (f 1 -parts'of the regulation such as 60.2 in constraining these
,; 2 . unanticipated events.
- 3. MR. OKRENT:. Put the last viewgraph on. That is.
L.
.4 .really a methodology" cartoon.
5- MR. ALEXANDER: Right. What I.am saying
- 6 basically.is that we are going to have at this point in-7 time,.we
- feel that we got a difficult time in establishing 8 the probabilities for this, and~being able to deviant them.
9 Basically it is;this term right here that we are talking 10 .about.
11' MR. OKRENT: But as I sit and listen, and if I 12 . read what the advisors from the State of Nevada worry about, 13' or raise. questions about, and so forth, there are really a
-large number of. areas where --
10 '14 15' MR. ALEXANDER: Human Intrusion?
- 16 MR. OKRENT: Human Intrusion -- where the
- 17 phenomenology is lacking here, it is not a question of date, 18 ~but phenomenology is lacking.
19 MR. ALEXANDER: An understanding of the process, I J
, 20 that's right.
21 MR. OKRENT: Right. What I am getting at is how 22 are you going to -- can you address these in a way that is i
23 not only satisfactory to me, and maybe even to NRC, but to '
24 third parties as well, and the fact on the time scale you 25 are referring to.
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- P 1 .CI have in; mind-the recent problems.that-the NRC
, 2 hadtin. developing;that to Reg 1150 which really is a topic 3 -that is all' tack. 1400'came out-15-. years earlier or' 41 something, and'where as to - yeu probably know,,there was
'S abundant criticism from ' within ~ t he family.
4.
You didn't have
- 6.. to go to the public and. interveners to find criticism about 7- - this,;and in.a sense, I-think, they'have had.an easier 8 ' problem than,you have..
9-l TSo-this is why I wonder, you know, in view of-10 .where you'are now, your ability.is getting ready -- in a way
- 11. that is acceptable for a purpose. This is where I am 12 getting at.
131 MR. ALEXANDER: Yes, that is the bottom line.
p '14 MR. OKRENT: .. Okay.
V 15 MR. ALEXANDER: That is why in a previous _ slide, n 16 -a couple slides.back, I pointed out.that the interpretation 17 of 60.2, for. example, and how it is applied, is critical, 18 and'we need to'come to a' common understanding.
19 ~ As I said earlier, we have shown plots of CCDF's f l
.20 in the past. It can be done, and that is not really the 4 21 question. The real question is whether or not we can 22 a'dequately address the uncertainties, i j
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23 We can adequately assure everyone that we have a 24 complete set of independent scenarios that are represented 25 in.that CCDF, etcetera. They are mutually exclusive, arm 1 >
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( ,) 1 that is something that has got to be worked out.
2 Regardless of how we approach that analysis in 3 licencing, which is years down the road, the real question 4 today is whether or not we have the right set of data 5 collection activities to provide that information.
6 If the methodology demands a different set of 7 information, then we got a problem right now. I believe 8 that we are okay. Are there any question?
9_ MR. SHEWMON: Two questions, not particularly 10 related. On the question of human intrusion, can you tell 11 me roughly - you must have some distribution of the 12 probability of this over time. When does it rise up 13 significantly above zero? In ten years, a hundred years, a 14 thousands years, or ten thousand?
k' 15 MR. ALEXANDER: Well the key assumption is that 16 the markers will be around for a significant period of time, 17 and so I guess my answer would be after a thousand years.
18 It will be well after a thousand f ears.
19 We fully expect markers to be around for at least 20 a thousand years, and I think that was the intent of the 21 regulation was to assure that at least there were markers at 22 the site for as long as possible.
23 MR. SHEWMON: That comforts me some, because I am 24 willing to bet that my grandchildren are technically much 25 better than I am.
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?MR.! ALEXANDER: Mike, me to,.I agree with you.
, 2 MR. SHEWMON: .Okay. The other question'then'is j
+
i 23' you said.that there was a PA on a waste form. i 1
'4 MR. ALEXANDER: . Right.
5 MR. SHEMMON: That had been done and was somewhat:
6 global,ythough that'wasn't your word maybe. H 7 .MR. ALEXANDER: It's true.
8- 'HR.JSHEWMON: Is this available in a DOE report, 9 or in some form where we could get it and look at it, back
'10 on what he had?
a 11 MR. ALEXANDER: I believe -- I guess I would have 1:2 to ask Ralph if'thac was -- I believe it was released as a 13 'PNL report, Ralph? It may still be in the final draft
< 14 stage...
15 MR. STEINDLER: I think the answer to the
'16 question is that.any report that we have that at least is at' 17 least at a draft stage is available if you would like to 18- have it. I am not quite sure what report Don . is talking 19 about.
20 We have done a number of. reports. For example, 21 we did a literature based study on risk which is still in a 22 draft stage, which is going toward final, which I think I 23 would have offered up at an earlier discussion except that I l 24 wasn't sure what the status was.
25 MR. SHEWMON: Well I picked the one on waste form Heritage Reporting Corporation (202) 628-4888 I l
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+' ds' 2' l about', and if it is relatively recent,.I,would appreciate it'
-e ;3' 'ifLit?is available if you would get the number to the staff 4' : member.
e 5l MR. STEINDLER: If it is available, y are will 6 certainly'will have it soon.
, i 4 7 :MR. SHEWMON: Yes.
'8 -MR. ALEXANDER: Nearly all of the information f( 9 'that'is in'the report was' presented to the NWTRB several 10 weeks ago,. and ;that presentation was made by Doctor McApted, 11- and' Doctor Tom Pickford. I think that it is a very 12 -interesting report and you got to look at it.
13- ,
MR. SHEWMON: .I would like to have the chance, t
14 MR. ALEXANDER: Yes.- You know the bottom line of:
O 1 50 that reportlis that the low solubility of fuel dominates the 16 assessment.- I'said that.before, and Marty Steindler, and I 17 ~htve talked-about.that a few times.
18 The solubility of the fuel is very low if you
^ t 19 Lasume -- if you make certain assumptions about how the fuel 20 behaves in the post closure period. It essentially 21 dissolves congruently, and by that we mean that gap and 22 gre us boundary phases when once released, if the system 23 operating on a matrix that remains operates congruently,
- 24 then we are in a very good situation.
25 MR. MOELLER: Doctor Pomeroy?
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b - 222 11 MR. POMEROY: ' Don, I wanted to come back to'-- I if think'you heard-the-comments of the NRC staff this morning,
~
p 3 and the concern was not simply about the human intrusion 4' -question.
, 5. MR. ALEXANDER: Right.
~
6' 'MR. POMEROY: But that there were a. number of' 7 other factors that entered into the. question of the 8- possibility.of calculating the CCDF'in-an acceptable manner
' 19 - to them.
10 MR.' ALEXANDER:. Right.
11- MR..POMEROY: Among other things. Could you just 12' tell me bEiefly'what kind of steps you can see that could be 13 ~taken towards closing this issue, towards resolving this
' 14 - concern that was expressed this morning.
~15 MR. ALEXANDER: Well yes, fundamentally.we need 16 to identify'the scenarios that we need to fold into the 17 CCDF. There are steps being taken te do that. I will be 18 participating this fall irt a PAAGA meeting, performance 19 assessment advisory group meeting at NEA, and this subject
- 20. ~ will come up and we will be addressing it.
21 It is not as unique as I pointed out. It is not 22 unique to the U.S. program. It is an important program s23 consideration for all nations operating under waste 24- management business.
25 So the first -- I think the first item of f Heritage Reporting Corporation (202) 628-4888
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2 considered,fand it.is clear.that even at this time, even if-3- we as an international community were to define those
<4 . scenario classes,'and the individual or' discreet scenarios 5 within'thoseLclasses, more.will-come for each of the vites
'f 'being looked at internationally, depending on site specific 7 characteristics, and that is clear.
8- MR. POMEROY:. And you believe that the scenarios 9 and scenario classes in the SEP are at this point sufficient 10 for you to move' forward as you define those scenarios more 11 -specifically.
12 MR. ALEXANDER: Right, I do.
13 MR. MOELLER: Gene?
14 MR. VOILAND: When you talk about a scenario, are 15-
'you simply _ talking, for example, about a pathway for 16 radiative materials to get from the fuel to outside where it 17 is going to affect people?
18 MR. ALEXANDER: Essentially. I have a 19 supplementally side,-because I figures that we would start
[ ,
20 getting into this subject. In the SEP, and we presented 21 this slide also here before.
I 22 There are a whole host of scenarios that are 23 considered, and there are not just five scenarios, or seven 24 scenarios. There are a whole host of them which you might 25 consider in matrix form, and this p&rticular slide that was i
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(,) 1 presented earlier, we put cause on one side, and affect on ?
l 2 the other side, so scenarios don't involve just direct i
! 3 release.
]
4 They involve change in flux raised in the wate:
5 table, change in UZ properties, discharge points, etcetera. l 6 On the other axis we list all of these naturally occurring 7 events, and a number of what we think are the predominant 8 human intrusion evente, 9 So for example, here is the exploratory drilling 10 scenario. Dave, maybe you can move it up again so that they 11 can see it. The exploratory drilling scenario, but there 12 are a whole host of other human intrusion scenarios that we 13 got to consider.
,- 14 In the regulations you know that irrigation is a 15 consideration that we have to undertake, impoundments, is 16 another, mining is another, and ground water withdrawal, for 17 example.
18 We don't know what the climate is going to be in 19 the future, but one assumption is that the climate there at 20 the site will change, and if it does, then some of these 21 become interesting scenarios that we will have to consider.
22 MR. VOILAND: But isn't the one common thing is 23 somehow the radioactivity gets out of the fuel?
24 MR. ALEXANDER: Accumulative release to I 25 accessible environment, that's right, from any of these Heritage Reporting Corporation O (202) 628-4888 l
225 1 . scenarios.
2- MR. VOILAND: All of the scenarios that don't 3 lead to that --
4 MR. ALEXANDER: Are eliminated.
Sf MR. VOILAND: You can just cross them all of the 6 list, can't you?
f 7 MR. ALEXANDER: That's correct. That is why some 8, -of these boxes are essentially left.out. In other words, 9 extreme climate, change doesn't result in a direct release.
10 It'is a process'that can lead to a release.
11 MR. VOILAND: Well if it gets hot enough I guess 12 people wouldn't be there anyway.
13 MR. ALEXANDER: Yes.
14 MR. MOELLER: Other questions or comments for-O 15- Doctor Alexander?
16' -[ Negative response.]
17 MR. MOELLER: All right. Mr. Steindler, do you-18 have.any final comments?
19 MR. STEINDLER: Only two comments. One is that I 20 would like to thank you again for the opportunity to present 21 our views, and to offer up any other occasion that would 22 warrant our appearing and discussing some of our program 23 with you, and we would like to do that.
24 The second comment is that I would like to l
25 reiterate what I had said earlier, and that is that we think l
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- 1 that'we have reached a point in our program-in the analysis 12 that we have
- made the' interpretations, the reevaluations and-f
~
3 so on=that we believe'we are at_a point where we are to be 4 productive.
5 To be able to go forward and try to find out 6 whether this site is suitable or not. We really need to get 7 on and do' site' characterization work. That is basically 8 what our theme is at this point. Thank you very much.
9 MR. MOELLER: Well thank you. On behalf of the 10 committee let me thank the entire DOE staff and its' 11 -contractors for coming in this afternoon and sharing this 12 time with'us and bring us up to date on their latest 13- thinking in terms of the site characterization for the Yucca 14 Mountain site. Yes, Doctor Okerent?
.15 MR. OKRENT: I thinking back to Doctor Shewmon's-16 question about available documents. Do you automatically 17 .see forms --
18 MR. MOELLER: We will follow up on those 19 performance assessment documents, and we have been promised 20 that we will be given the titles and indeed be given drafts, 21 draft copies of any that have reached that stage, so we will 22 certainly count on that, particularly for Paul -- both 23 Pauls.
24 MR. OKRENT: I would assume that they would l
l 25 supply them in all areas.
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l I l 227 (j 1 MR. MOELLER: Yes.
l 2 MR. OKRENT: Okay. l 1
3 MR. MOELLER: Absolutely. Okay, Jack Perry will 1
4 make a note of that and follow up. Well with that, this l I
5 bring to a conclusion the formal portion of today's meeting. ]
j 6 For members of the public and the DOE, and NRC staff who are 7 here, let me also thank the NRC staff for being with us the 8 entire day in responding particularly this morning to a host 9 of questions that we had.
10 Our game plan for the remainder of the day will 11 be to go into executive session and to attempt to put down 12 in writing the formal comments of this committee which we 13 will be submitting in the next day or so to the NRC g- 14 chairman, offering our suggestions, comments, criticism on
\~J 15 the SEP and the SCA.
16 During the executive session, we will not be 17 recording it, and it is perfectly acceptable though, for 18 members of the public to be here, including the NRC and DOE 19 staffs. We will be though, deliberating among ourselves.
20 It could be that if you are here and some 21 question of fact comes up where we solicit information, we 22 may want to call upon you for that, but we will not be 23 subject to additional presentations.
24 In other words, the presentations -- the formal 25 presentations are over. So with that, let me thank you once Heritage Reporting Corporation
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- t 1- again. For the committee, we will take a break. During the 2 break, Jack Perry will distribute the current draft of our '
q 3 comments, and I might point out to you that there are -- at 4 least I have a half a dozen items that have to be added to 5 the letter of modifications to be made, but nonetheless, we 6 will give it our best shot. I presume that we should finish I 7 by 6:00 p.m. That concludes the meeting.
8 (Whereupon at 4: 00 p.m., June 28, 1989, the ;
I hearing adjourned.)
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k 3 This is to certify that the attached proceedings before'the I
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United States Nuclear Regulatory Commission in the matter 5 'o f : 12th ACNW Meeting Day'One 6 Name:
7 S' Docket Number:
9 Place: - Bethesda, Maryland 10 Date: '
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 s,.
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/ N f// r- /2/// '
19- (Signature typed) : IrwinCoffenb/Iy /
20 Official Reporter 21 Heritage Reporting Corporation 22 23 1 24 1
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5 Heritage Reporting Corporation (202) 628-4888
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() REVIEW OF THE ESF TITLE 1_
DESIGN ACCEPTABILITY ANALYSIS (DAA)
For obvious reasons this review of the DOE Design Acceptabil-ity Analysis is a limited review. It is fundamentally a review of the process used in the conduct of the study. It also addresses NRC's concerns over the DAA and provides some general impressions of the comprehensiveness of the DAA effort. This review is essentially of the Review Record Memo-randum (RRM) and some antecedent documents only. It involved no examination of the appendices mentioned in the RRM which contain data, calculations, reference material, criteria, summaries, etc.
The DAA Study Process, Findings, and Comment.
The conduct of the Design Acceptability Analysis appears to have been a weII controlled activity:
- It was classified as a QA Level I activity
- A plan was developed for the conduct of the program
- Document Control procedures were established The Design Acceptability Analysis was properly author-
- O ined and an administrative committee formed to guide the
'*vdy effort
- QA records were maintained relating to QA classifica-tion; personnel selection and certification: QA surveil-2ance reports; team member participation in ESF Title I design., design review or involvement with related SCP authorship meeting minutes; correspondence, etc.
A group of 27 engineers and scientists augmented by other specialists as need dictated constituted the task force gath-ered to undertake the study. They were divided into three
'sub-committees' with the following respective tasks:
- Establish an independent list of criteria (responsive to the requiremen&s of 10CFR60 and NRC Comments 1,2, & 3) to test the applicability of the ESF Title I Design
- Assess the adequacy of the data used in the ESF Title I Design
- Review the adequacy of the location for Exploratory Shaft 1 in comparison with other possible sites The criteria were developed from consideration of the repo-O sitory conceptual design, the SCP Performance Allocations, the preliminary Subsystem Design Requirement Document (SDRD) for Title II Design, and the professional judgement of the 4
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.,Raview of Title I.DAA (cont.)
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..(', _r.vestigators. Of the 282 criteria developed, 93 were L thought to be fully addressed by the ESF Title I Design, 127 l partia11y, and'63 not-at-all. It was felt that the ESF Title I designers consciously responded to the performance objec-tives. The sub-committee'did not seem to be to unduly alarmed about the extent to which the criteria were met because the thrust of the' ESF Title I Design design effort was functional rather than addressing regulatory requirements. Also, it was noted that the ESF Title I Design was of a very preliminary nature. My ir.pression is that this sub-committee covered a lot of ground!
i The sub-committee looking at the appropriateness of the data and the uncertainties in the data used in the ESF Title I rer'gn was also energetic. They reviewed 53 documents, i
assessing them for:
l l - Reasonableness of the data 1
- Appropriateness of method i - Treatment of uncertainties 1
1 1
- Appropriateness of data for use in the ESF Title I Design Recommendations O '
effort Reference Information Base (RIB) 3.001 was the primary source of much data.
There were about 30 independent recommendations made as a result of the DAA three-quarters of which did not relate directly to the Title I Design, but were mainly recommend-ations or suggestions relating to tests, operations or Title II design. Those deemed directly related to the Title I effort addressed such items as (a) failure to specify the drilling techniques to be used, (b) possible effect of the water pond on the site isolation capability, (c) the absence of some sensitivity studies, (d) appropriateness of some drift separation distances, and (e) possible bacterial acti-vity.
The DAA did address the use of the EEF as part of the repo-sitory apparently concluding that only the shafts and long drifts would be incorporated (as part of the repository ven-tilation system.) Since other adits also serve as air ducts I they did not view the shafts as critical to safety. They j essumed that neither shaft would be used to transfer waste, I hence no radiological risk would result from failure of the I' shafts. (It is hard to believe that the construction of the shafts to serve the underground test facilities would be O much different than for shafts to serve the repository.)
However cognizance of the possible inclusion of the ESF as
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,Rovjcw of Title I DAA (cont.)
j ps:t cf the repository must be maintained in the Title II design stage, even though exactly how the ' repository' ele-ments of the ESF will fit in must await consideration in the preliminary design of the repository. It is obviously of prime importance that the ESF's use in Site Characterization should not compromise its potential use in the repository.
The study concluded that the ESF Title I Design was a suit-able point of departure for the Title 2 design effort. It also produced the previously-mentioned recommendations for consideration in the Title 2 design program which they beideved would improve the ESF.
My overall impressions of the Design Acceptability Analysis s-e as follcws:
- The Analysis appears to have been carried out in a well planned and disciplined manner
- The effort appears to have been quite comprehensive
- ! believe the Design Acceptability Analysis provides additional confidence in the validity of the ESF Title I Design
- Overall. I think it was a job well done
(._) -<ideration of NRC Concerns The Staff has reviewed the DAA in considerable detail and har identified a number of deficiencies:
- Five members of the DAA team appear to have been involved in Title I activities and thus their indepen-dence as reviewers may be compromised. Their partici-pations should be reviewed to determine whether their Title I area of involvement overlaps the DAA review area.
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- NRC believes that the DAA either fails to address or l inadequately addresses the conformance of the Title I J Design with a number of 10CFR60 requirements. In consid- !
ering the applicability of 10CFR60 requirements, it must be remembered (a) the 10CFR60 requirements do not apply very extensively to the ESF as part of the potential !
repository since the ESF's use in the repository is !
quite limited (b) the use of the ESF in the repository will be addressed in the repository design if the site proves acceptable, (c) there is some potential for the ESF to impact on the isolation characteristics of the repository which abuts the dedicated test area, but much of the area is probably sufficiently remote for such
(')N
( potential to be very great, (d) the validity of the acquired test results must meet licensing requirements:
Review of Title ! DAA (cont.)
f')
is:ility design since the latter is dependent on the former, (e) excluding radioactive waste from the ESF during its use in the Site Characterization Program ell-minates applicability of a number of 10CFR60 require-ments. In determining which 10CFR60 requirements apply, it is therefore necessary to carefully review the func-tions of the ESF.
- The DAA did not thoroughly address adequacy of the data used in the ESF Title I Design. These deficiencies should be addressed in the Title II Design effort.
NP.C has also listed other concerns about the ESF Title I design, but it is anticipated that they will be addressed in t- $
Title II Design.
Quality Assurance
- c. = a:4 indicator of the status of QA plans for both Title I and Title II designs, I developed a Design Control Checklist (attached) to test both current and past design control systems of this sort. I was informed that Fenix and Scisson, Inc. had no QA program comparable to that required by 10CFR50 Appendix B at the time of the Title .T Design effort. However, for reasons discussed in the "ESF Title I Design Review", I believe the issue of Title I design control should be revi-
.. t & s's current design control procedures, at least
()
,.were responsive to the check list and appear to be E.E. Voiland June 21, 1989
-4
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.O DESIGN CONTROL CHECKLIST
- . Does the designer have a formal Design Control program?
- How is it documented?
- What is the authority for its existence?
- 2. How is a Project initiated?
- Who authorizes the Project?
- What is the organizational structure for project manage-ment and implementation? Who appoints the Project Manager?
- What is the procedure or process for determining the QA classification of the project; whether a safety analysis is required: or the impact on licensing conditions.
- 3. What.is the procedure or process used for Design Preparation?
- What is the procedure or process used to determine whether c her projects proposed or in existence will interact with-O the currently proposed project?
- Is there a procedure or process for control of calcula-tions? Who determines the need for and depth of calculation overchecks?
- Is there an acceptable drawing and document control sys-tem? Is there a drawing QA Classification system? Is there an adequate system for control of " Safeguards" information?
- Is there an acceptable procedure or process for preparing and approving specifications?
Is there an adequate configuration control procedure or process?
- Is there a procedure or process for establishing the need for, scope and depth of design reviews? Who establishes the design review individual or committee? How are the results of the design review dispositioned?
- Who determines if a Safety Analysis is required? What is the procedure or process for initiating a Safety Analysis, assigning responsibility for it, and conducting it?
) 4 Design Approval
- Is there a procedure or process describing in detail the design approval process? Does it consider design elements such as the following:
a i
i, e
V)
. project initiation
. Safety Analysis requirements
. QA considerations including classification
. Licensing matters
. conformance to design criteria
. calculation over check
. safeguards
. environmental impact
- Is there a procedure or process for instituting a change in the project design? and for effecting the subsequent changes in drawings and documentation?
- 5. Is there an 'as-built' system in place?
o Is there a formal engineering record system in place? Does it include drawings, specifications, equipment identification, storage requirements and methods.
- 7. Is there a procedure or process for authorization, prepara-tion, issue and control of engineering specific.ations?
- What does the scope of specifications include? (materials, aquipment, system, testing, etc.)
O_ ' . = there a review and approval procedure or process for specifications?
- Is there a procedure or process for changing specifica-tions?
A
t (f -
. QUALITY ASSURANCE REVIEW Quality Assurance Objection (QA-1)
Issues. DOE and NRC agree on the need for an approved Quality Assurance program to be in place before the onset,of site characterization test programs. This agreement was formalized in July, 1988 and updated in January, 1989. Substantial progress has been made in achieving the objectives of the agreement; however, the NRC Staff is concerned about the fol-lowing' perceived deficiencies:
- none of the participating organizations has yet in place an approved quality assurance program.
- two important QA management positions remain unfilled.
- some QA concerns with the ESF Title I Design Acceptabil-ity analysis are unresolved
- NRC has recommended that DOE address these items and bring them to a conclusion in timely fashion as.the Staff feels that the DOE Program cannot proceed effectively until this is accomplished.
' cciderations. I believe the Staff position is defensible.
- ,$te the desire to see the whole QA program in place they have made provision for dispensing from the prohibition on start of work if DOE can demonstrate that acceptable QA pro-gram e3ements appropriate to the specific work program are in place.
I concur with the necessity of filling the vacant QA posi-tions. It is important both to ensure that appropriate manag-erial attention is being applied to the quality program and also that DOE takes its quality responsibilities seriously.
At present there is a lot of effort being expended in estab-lishing the QA plan (s). But it should not be forgotten that that is only the first step. It will take some effort on the part of all levels of management before the QA system oper-ates routinely. It will also take some practice to apply the plans in a reasonable manner such that neither excessive nor deficient quality requirements are stipulated.
Quglity Assurance Comments 1-3 COMMENT 1 (QA-2) SECTION 8.6.4.1
)
() This comment deals with the qualification of data which might he important to safety or waste isolation and which was not "cquired under an acceptable QA Program. NRC's recommend-ations that (1) such date be identified, and (2) that the procedures for qualification be submitted to NRC are reason-f.
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QA' Review.(cont.) '
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able, especially since DOE agreed to this course of action.
(However, there would seem to be nothing wrong with DOE qu'lifying a the data.under .NUREG-1298 without any prior sub-mittal of procedures. It could be argued that such procedures are simply implementing-procedures or instructions under the umbrella of the approved QA Plan and not subject to NRC approval.)
COMMENT-2.(QA-3) SECTIONS 8.6.4.2 and 8.3.5.5 This comment primarily' deals with quality classification and
'Q-list' items. Please refer to Quality Assurance Classifi-cation for some thoughts on this subject.
The staff
"... suggests that DOE should start by making a list of a12 engineered items and barriers associated with hand-ling and isolating high-level waste. Items could then be removed from this list as reliable data and suitable analyses show that a low-level of, or no, QA is required for such items. What remains on the list would, at any given time, be the "Q-list"."
...all engineered items and barriers..." suggests that a
"- y large ' universe' of system elements must be considered.
O : think, but am not certain, that, if a Probabilistic Risk oassment (FRA) were made, the elements important to safety and to waste isolation would be more efficiently defined and their quality classification would be straight forward.
COMMENT 3 (QA-8) DESIGN ACCEPTABILITY ANALYSIS This comment pertains to the extent to which credit was taken in the Design Acceptability Analysis for design control pro-cesses used in performing the ESF Title I Design. A briefing meeting between DOE and NRC was scheduled but so far has not occurred. NRC's recommendation that this issue be addressed is reasonable.
Quality Assurance Classification Issue. There appears to be a difference of opinion between NRC Staff and DOE on the assignment of Quality Level I to various program elements. To perhaps oversimplify, NRC feels that items which might ultimately be designated Level I should be so labeled and if later developments prove this decision wrong the classification be changed. DOE feels con-() versely that if there is doubt about the validity of classi-fication as Level I, assignment should be deferred until the uncertainty is cleared.
Background. SCP 8.6.1 specifies that Quality Level I is r' -
.___2--_-__-_______m _ _ _
QAjReview.(cont.)
O- . assigned to items and activities
"...that are important to either safety or waste isola- '
tion and that are associated with the ability of a geologic nuclear waste repository to function in a man-ner.that prevents or mitigates the consequences of a process or event that could cause undue. risk to the radiological health and safety of the public. Items important to safety are those engineered structures, systems. components, and related activities essential to the prevention or mitigation of an accident that could result in a radiation dose.to the whole body or to any organ of 0.5 rem or greater at or beyond the nearest boundary of the restricted area at any time until the completion of the permanent closure of the reposi-tory." (NOTE. The value 0.5 rem is a factor of ten lower than the 5 rem prescribed for a spent fuel storage facility. This seems unreasonably low for an accident condition.)
" Items and activities important to. waste isolation are those natural and engineered barriers and related acti-vities that are relied on for achieving the postclosure performance objectives in 20CFR60 Subpart E..."
f3 SCP 8.6.1 goes on to say that b "QA Level I must be applied to activities, including site characterization, scientific investigations, facility and equipment design, procurement, construction, facility operation, performance confirmation, permanent closure, and decontamination and decommissioning sur-face facilities when they are specifically concerned with the protection of the public's health and safety with-respect to radiological hazard."
The same document, in six paragraphs which I have either copied or paraphrased as follows, provides more detailed guidance as to the application of QA Level I.
- 1. Items relating to the public's radiological health and safety during the preclosure period.
- 2. Activities that provide data to assure a design that will meet performance objectives of the repository.
- 3. Activities that could adversely impact the isolation capabilities of engineered and natural barriers.
Items that are relied on to meet the postclosure per-O 4 formance objectives of the engineered barriers of the repository system, l
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- 5. Items or activities which, if they failed, could cause a QA Review (cent.-)- ,
failure of a QA Level I item or irretrievable loss of QA. Level I data.
- 6. Detailed design-.of engineered items.or systems important to safer'; or waste. isolation will be assigned a QA Level I classification. As'the design proceeds, system ele-
) ments within the detailed design will be classified appropriately.
There is additional-guidance in SCP 8.6.1 related to QA Level II come of wh3ch seems to conflict mildly with guidance for QA Level I.
DOE's response to SCPCRD Comment #106 confirmed their intent to evaluate engineered items
"...to determine if they are important to safety or important to waste isolation. If they are important, they will be placed on the Q-list."
which appears to be within the spirit of the QA Plan.
In SCA 3.1 IRS e--:t ion 3. 6. 2, NRC summarizes its position with respect to this issue by commenting that
.it is the NRC staff position that those items which
-O DnE is taking credit for in the prevention or mitigation of release of radionuclides should be subject to a 10CFR Appendix B (or equivalent) QA program. The primary purpose of developing a Q-list is to assure that those structures, systems and components which are essential to prevent.or mitigate the release of radionuclides to the environment are subject to appropriate quality con-trol. If it is assumed that the design is sufficient to prevent release of radionuclides, and hence that there is no need for design control, the whole purpose of the Q-list and quality control procedures is negated."
Discussion. The apparent difference of opinion between DOE and NRC is not difficult to understand. NRC with its respon-sibility for licensing the facility certainly wants to be sure that the basis for granting the license is beyond cri-ticism, particularly in the area of the validity of the data which the applicant is using to support his license applica-tien. On the other hand DOE with the horrendous task of managing this extremely complex program does not want to saddle itself with unnecessary quality requirements, knowing that it is much much more difficult to downgrade a quality requirement than to upgrade it. It is my belief that both parties are whole-heartedly committed to a licensable, utili-() terian product; a repository that will perform in a manner to dispose of high level nuclear waste and provide adequate protection of the public. I also believe that this issue of .
quality classification is readily resolvable.
1 QA Review (cont.)
b -
In examining the requirements for application of QA Level I tc the repository program, one perceives that there seem to be some apples and oranges in the quality ' fruit basket'.
One kind is the usual kind of quality, that which is applied te engineered systems (items 1, 4, and 6 above). Most good que13ty assurance plans - such as a plan that will meet the elements of 10CFR50 Appendix B - will, if properly imple-mented, assure an appropriate design and fabricated and installed equipment that will perform in accordance with the quality requirements imposed. This is the concept that I believe most people think about when they hear the words quality assurance. One ends up with a physical system that can be turned on and off; it produces a product or a service; and its performance can usually be readily measured.
In the application of QA classification in the repository program, DCE is asked to apply the same classification termi-nology to items quite different from the physical systems mentioned above. In one instance (item 2 above) the quality program is simply to assure that knowledge used in defining the capabilities of the repository site and its engineered systems is 'true' or close enough to 'true' to meet the needs. In items 3 and 5 above, the QA Level I term is to be applied to system elements or activities whose failure could result in impaired isolation capability, failure of a QA s *-"n' *
- tem. or Joss of QA Level I data.
%)
.Jderations.
- 1. SCP 8.6 provides only a broad description of the quality assurance program to be used in the repository project.
It, however, " ... directs each participating organization in the Project to prepare quality assurance administra-tive procedures (QAAPS) to control their activities affecting quality." Further, in Section 8.6.4.2.1 a number of general activities are called out as requiring QA Level I classification and "... DOE is reviewing the documentation to develop the Q-list...".
In this documentation review, DOE should be urged to address in considerable detail the quality requirements for each one of the QA Levels. With so many different participants jnvolved a uniform guide for use by all would seem to be necessary.
An approach which suggests itself with respect to engi-neered items is development of a requirements matrix which lists under each of three QA Level headings examples of appropriate items for consideration and sample quality attributes for each of the major elements
(' associated with engineered items - design, procurement,
\s) fabrication / construction, inspection, testing, and records. For example, under Level I for ' Inspection' requirements might be (a) inspection per an approved inspection plan, (b) in-process inspections at fabrica-
_ _ _ _ _ _ a
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QA Review:(cont.)
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tor's facility,'(c) documentation for materials, manu-facturing processes,. personnel qualification records,.
7 and (d) inspections for release of material. For Level III, the Inspection requirement might be checking a purchased item by a warehouseman for conformance with a Purchase Order.
A similar matrix could be developed for the testing program (although the notion of different quality levels
, when it comes to acquiring scientific or engineering data is somewhat strange!. It seems that all such data should be sought with the intent that it be valid and that appropriate measures be taken, therefore, to assure that the degree of validity is acceptable.) A virtue of a quality classification program; however, is to assure that sufficient consideration is given to items which are important not only to their use in the physical sys-tems but also because of their.importance in the licens-ing process; therefore, flagging particular test pro-grams with a QA Level I designation is not inappropri-ate. .
Such a'QA matrix for test activities might include design of the test, assessment of uncertainties, need for design review, type of measurement systems, calibra-
- or, statistical treatment, duration of tests, computer O rupport, modelling, approvals, documentation, etc.
- 2. A second consideration related to the quality classi-fication of program elements is the problem of knowing what exactly to apply it to. For example the QA plan requires that QA Level I be applied to activities that could adversely impact the waste isolation capabilities of the engineered and natural barriers. Although the SCP intensively addresses engineered and natural barriers, there is no conclusive evidence as to which are truly important or necessary to provide the required degree of safety. For example, if it were concluded that the fuel cladding would provide adequate containment for 1000 years, there would be less concern about the performance of the waste container and one would be less concerned as to its quality classification. Or if it could be shown that the transfer of radioactivity from the cer-amic fuel core to transient ground water were negligibly slow, there would be little need to be concerned with ground water travel rates.
This suggests - if it has already not been done - a serious safety analysis using existing information to assess the quantity of radioactive material which might be expected to be available to the ground water (the Source Term). Perhaps a preliminary Probabilistic Risk Assessment (PRA) as has been suggested by others would be useful. Such a study would also be useful in estab-lishing temporal priorities for characterization
_._ . _ _ _ _ _ _ _ }
- Q A R e v i e w !.( c o n t . )'
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Q.
- ctudies, the relative importance of various character-ization program elements, linkage to the licensing pro-cess, and the reasonableness of certain regulatory requirements.
I believe there is ample justification for such a study.
DOE has done'a very good job in outlining the many sce-narios which describe the universe of phenomena which could be important to containment.of emplaced high level wastes and spent fuel or which could result in threats to that containment. However, I am not aware that there is any effort planned to reduce the universe to a galaxy (or even a moderate size solar system). The SCP is very conservative and largely qualitative in its approach, which probably results in the size of the universe. It is only by quantifying system performance as much as and as objectively as possible can one get an idea of what is important and what is not. For example:
- Has the ability of the cladding of the fuel rods been given sufficient credit in containment of the fuel material? (Tens of millions of fuel rods have sur-vived very well for three or four years at 500 degrees Fahrenheit in 1000 or 2000 psi pressurized or boiling water.)
What is the significance of a defined breach allowing i a flow of IE-4 atm-cm3/s of air to the rate of flow !
of water?-(The industry concern for breached fuel is the concern of reactor operators for the release of fission gases during reactor operation which might result in exceeding Technical Specification limits i and require redaction in reactor power level and loss of energy output.)
- Has the experience in storing spent fuel in water j basins significance to the repository program? (There is substantial evidence that ' leaking' fuel continues to leak, and sound fuel continues to be sound.) l
- How fast do radionuclides really move in a repository environment? (What is the significance that fission product nuclides have been found in ore (fuel?) after the ore had been subjected to water flow at least sometime during the two billion or so years since the fission products were formed in the pre-historic nat- .
ural reactor in Gabon, Africa?) .
- 3. The practice of requiring a very high degree of quality with respect to safety related items stems, I believe,
() from the heritage of reactor safety. In the case of reactors, one is dealing with systems involving immense amounts of energy and a heat producing system which must {
be controlled in the event of certain events which could j be a threat to that control and, possibly, to the pub- j L_ '
.QATReviewJ(cont.)
(~$ ~ .
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- lic. The principal feature of such events is that they can happen very quickly and therefore ameliorative response.must also occur very quickly. High quality is imperative to prevent'such events in the first place and' to assure that response equipment is of the uttermost reliability. In the case of a repository - as in the case of a spent nuclear fuel storage facility 'one is dealing with a very passive system where immediate threat to the public is essentially non existent. This fact was formally acknowledged over a dozen years ago in a communication between the Advisory Committee on Reac-tor Safeguards and the Nuclear Regulatory Commission (excerpt attached).
(On the other hand, because of regulatory requirements there is the necessity of assuring that the repository system will perform as required).
A passive system which embodies a number of the features of the repository - cask handling, fuel transfer, lift-
.ing cranes, etc. - is the Independent Spent Fuel Storage Installation (ISFSI). The nature of the low risk asso-ciated with thir, type of operation is indicated by one of the Design Considerations of ANSI /ANS-57.7-1988, Design Criteria for an Independent Spent Fuel Storage Installation (Water Pool Type)-
"3.4 Overall Design Considerations"
"(b) The underwater storage of aged spent fuel is a low hazard potential activity. Very little of the radioactivity present is available in a dispersible form and there is no mechanism pre-sent to cause the release of radioactive materi-als in significant quantities from the installa-tion."
As a consequence of this consideration, very few items associated with an ISFSI are considered to be of impor-tance to safety. This does not mean, however, that quality assurance is ignored and Section 6.6.12 speci-fies that systems with important confinement features require a sound quality assurance program.
If DOE has not done so, it may be worthwhile for them to review ANSI /ANS-57 7-1988. It may have pertinence or provide insight useful to the repository program.
Because of this heritage of zealous concern for reactor safety, the specters of 3-Mile Island and Chernobyl, an
}]--
aggressive anti-nuclear faction in the public and a hair-trigger media, there is a tendency to be over conservative in the application of quality assurance to reactor and by kinship to other less susceptible nuclear systems. It is therefore especially important to recog-
I l QA.R; view (cont.) l 1
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- nize the real risks of high level nuclear waste dis-l posal, objectively. classify equipment and activities, 4 and apply the appropriate measures to assure the useful-ness and safety of the repository. q l
E.E. Voiland June 21, 1989
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.QA Review-(cont.).
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L ATTACHMENT l
"On the basis of-its' review, the Committee has concluded l
that there is a need to recognize in the development of Federal Policy for waste management, the differences in the magnitude of the immediate risks associated with the various components or portions of the nuclear fuel cycle. Most nuclear safety experts, for example, would agree that the potential for impact'on the health and safety of the public from accidents is greater for nuclear power plants than it is for a facility properly designed for the long term storage of solidified high level wastes. The potential health problems associated with a disposal facility would be primarily of a chronic low level nature and would decrease substan-tially during the first few hundred years of decay. The Committee has been unable to develop or postulate an event in such a facility that would be comparable to a Class 9 accident. Although this does not mean.that there are no associated hazards, it does mean that the period of time during which responses to problems must be implemented will generally be relatively long (months to
, years). The option of retrievability should greatly fecilitate the appideation of corrective measures."
"The Committee believes that there is a need for a bet-ter understanding of the long range risks associated with the disposal of high level wastes. After a thousand years decay, the relative hazard of the total quantity of long lived transuranic nuclides in such wastes would not be more than a few times that of the original ura-nium ore. Because the wastes would be in a solidified form and would be deeply burfed in a carefully selected geologic structure, the actual hazard should be less. As a result, even though inaccessibility for a period of hundreds of thousands of years cannot be guaranteed, it appears reasonable that one or more of the methods' pro-posed for the disposal of such wastes would be adequate to provide protection for the public and environment from any potential long range hazards."
Excerpted from a letter to the Honorable Marcus A. Rowden, Chairman, U.S. Nuclear Regulatory Commission from Dade W. Moeller, Chairman, Advi-sory Committee on Reactor Safeguards. " Report on the Management of High Level Radioactive Wastes." December 20, 1976.
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I i
-() EXPLORATORY GHAFT FACILITY TITLE I DESIGN REVIEW This review of the ESF Title I Design is limited primarily to the concerns expressed in the NRC Site Characterization Analysis (SCA), and in the Objection, Comments and Questions of the SCP
~
Point Papers. Those concerns principally address Adequacy of the design control process used in the ESF '
l Title I Design effort.
--Adequacy of the Title I Design per se.
- Deficiencies in the ESF Title I Design Acceptability Analysis (DAA). (Reviewed separately.)
- Specific design items such as consequences of a possible
-nearby fault, possible interferences among tests, need to accommodate additional tests, possible inadequacy in size of the test area, and the appropriateness of some site design criteria.
I hope that this review - from the viewpoint of someone who has not been immersed in the program for an eon - will be useful in consideration of these issues.
O E?ck;round - General Design Considerations P
In the construction of any structure cr. facility whether it is simple or complex there is a sequence of activities or events which is generally followed to assure that the finished product is adequate for its intended purpose. These activities'are:
- A description of the intended purpose of the facility with salient details as to the nature of products or services, capacity, location, general site requirements, transportation needs, etc.
- A conceptual design which defines the basic process or type of facility; produces a preliminary layout of pro-cess buildings and support facilities; and establishes design criteria which address such items as utility needs, transportation access, heating and ventilation, environmental control requirements, regulatory require-ments.
- A preliminary design (sometimes referred to as Title I) which specifies the required buildings, equipment and ,
services; and establishes the utility of the construc- 1 tion site in enough detail to meet design criteria and j p)
(_ serve as the basis for a fairly eccurate cost estimate. J
- A detailed design (Title II) which serves as the basis
_ _ _ _ _ _ _ _ _ _ bf6 .)
LESF Title I Des'ign Raview (cont..)
LG Ek/ for the preparation of fabrication or construction con-tractars' working drawings.
For additional clarification a definition of Title I < design was requested and two definitions, substantially the same, were pro-vided- by the Staf f. Quality Assurance group:
t
" Utilizing the design concepts or criteria that have been prepared in the conceptual design phase,, sufficient design needs to be performed in Title I to firmly fix the project scope and features." (DOE 4700. i. Chap..V.
Part C.2.e.1'which pertains specifically to underground repositories.)
, " Title I - Provide the necessary topographical and'other field surveys, test borings, and other subsurface investigations; prepare preliminary studies, sketches, layout plans, and outline specifications; and prepare reports including-estimates of cost of the proposed pro-ject and of all structures, utilities, and appurtenances thereto." (Atomic Energy Commission Procurement Regula-tions (AECPR Cire. No. 1. Sept., 1969))
Discussion One Exploratory Shaft Facility consists of support facilities on m- surface, two shafts connecting to drifts and underground test-
... rooms. (See included Figure 4.3 from the SCP Overview Sec-tion.) It is a multi-purpose facility intended to perform the fol-lowing functions:
- Provide an underground test area for a 1crge number of
, scientific and engineering tests aimed at characterizing the geographical site for its intended use as a high level nuclear waste repository.
- Provide an opportunity for investigation of.the geolo-gical and related properties of the-rock as a function of depth by observation, sample acquisition and analy-sis, and by limited testing.
- Serve as an integral part of the repository system, if and when it becomes operational, by incorporation of the shafts and some drifts into the repository support sys-tem.
Following are specific comments:
i
- 3. The Role of ESF as part of the repository. The SCP in Section 8.4 addresses in considerable detail the ESF as O a site.for performing tests and obtaining data. It does not specifically address in much detail how the ESF will
{
1 4
be incorporated into the repository proper.. The Staff questions whether (1) the design contro3 measures were
- - - - - - _ _ _ - - - _ - _ _ - - _ - - _ _ _ - _ - _ - _ - ]
p -, .;
g TG Explosives storage i
..# ,, Second exploratory /--
- shaft' Firct exploratory ,J
, 10 shaft -
Equipment Main ESF
' yy,- ,, s pad 1 *\ *'* 9
- I To water tank ,
D,r I ing %
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,{n i t g; '
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- ' D t hy To imbricate
'halt ,* .
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fault ,
To Ghost 8.F.,.2, Dance fault ( g
- Main test level s
Figure 4-3. Cutaway view of the exploratory-shaft facility.
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)
LESF Title I'Dasign Review (cont.)
cdequate to qualify the ESF for such purpose, and (2) whether the design, itself, is adequate.
It should be kept in mind that the ESF Title 1 Design is primarily the design of the ESF as a test facility.
Parts of that facility may be. included in the repository only because they will be constructed in advance of the repository (at1 great cost) and will be geographically proximate to and available for use in the repository.
How -or whether.- those parts of the ESF .possibly both shafts and some drifts - will be used as part of the repository will be determined in the design of the repo-sitory upon consideration of operational requirements during the preclosure period. Initially the ESF wil?
include the support system of the underground test facility; during the operational period of the reposi-tory it will cor. tribute to the support system of the repository. The support system for the ESF will not nec-essarily be the same as the support system for the repo-sitory.
Although the SCP does not appear to explicitly address the role of the ESF as a part of the repository, it does so 3mplicitly in Section 8.4.2.3.6.3 " Integration of the exploratory shaft facility with the repository design."
In this instance, the repository design is the concep-tual design described in Chapter 6 of the SCP.
There is tacit recognition that not all parts of the ESF will be part of the repository. Thus the establishment
.of a dedicated area to contain the experimental facili-ties which dedicated area would have a "... limited impact on the usable repository area..." It was also understood that other parts of the ESF such as the long drifts could possibly become part of the repository.
This is recognized by such design considerations as:
- limiting the number of interconnections of test area j and repository I - locating boreholes in pillars if possible
- conforming the long drifts to anticipated repository specifications with respect to grade and drainage ;
- recognizing that drifts which might be used for waste emplacement may require dimensional modification depending on emplacement mode
- These considerations suggest that the elements of the ESF which are likely to be incorporated into the O repository should be identified, applicability of 10CFR60 requirements determined and quality require-ments established. As a corollary those elements not
(
li i ESF171tle-I' Design Review (cont.)
to be incorporated should be reviewed to determine whether-any special treatment to isolate them from !
the~ repository would be required or whether - as 1
,a seems possible -they could simply be abandoned in l place.
l l
- 2. Pertinence of Comments.to ESF Title I design. A number i of Comments'concerning the ESF Title I Design seem to' apply to the' site characterization testsfrather than to j '
the facility itself. According to the SCP (p.B.4.2-153)
"The ESF test requirements are established by the ,
principal investigators (PIs) for each test. The PIs fdentify standoff distance, space, drilling require-ments, utilities, test instrumentation and data acquisition requirements, special construction and operational control criteria, and other special or general test-support requirements to limit test interference and potential. impacts on post closure performance. These requirements, once reviewed and J approved...become the fundamental bases for the design of the EFS... and are incorporated into the SDRD."
Thus, the ESF Title I Design as it currently stands can only reflect the input information available at the time of design.
It is not clear whether some of the Staff comments relate to'the inadequacy of the design, inadequacy of the SDRDs, inadequacy of the SCP, uncertainty about the test design, or other. Although architect-engineers are generally believed to be clairvoyant - and, alas, some AEs believe they are - they still find it difficult to deal'with undefined tests, partially defined tests, impact of unforeseen delays in test durations, tests that haven't been proved unnecessary, etc. A further complication is that the ESF is designed to obtain information which would be nice to have as a basis for its own design!
The SCP recognizes the limitations of the design (as well as a requirement of 10CFR60) by addressing the issue of flexibility (p.8.4.2-218) with respect to test location, test area expansion, response to ' surprises' in construction, and schedule changes.
From reading Section 8.4 of the SCP there is no question that very serious consideration has been given to the requirements of the testing program. Based on the input -
information described, it appears to be technically ade- l
,/) quate as a basis for the ensuing detailed (Title II) v design. On the other hand, the Staff Objection and Com-ments contain a number of very valid points which require consideration in the Title II Design phase.
)
_______- -_ _ _ _ - - .- 1
1 1
..ESF.TitJe .I Design Review.(cont.)
I L
Some items which seem to require attention are as fol-((]) - lows:
q I
- Details of individual tests which impinge on facility !
design should be identified as soon as possible.
This does not mean that the detailed study plans need ]
i to be completed; but, it does mean that those criti- I cal items that affect design should be identified if I they have not already been.
l - Uncertainty about the inclusion or deletion of tests from the testing program should be resolved.
- The Reference Information Base (RIB) should be updated and its use promoted. It seems reasonable that many of the inconsistencies noted in the Staff review might have been avoided if this data base were used consistently.
- Similarly the SDRD should also be reviewed and updated in the light of Staff and other reviews and the new things learned as the project has progressed.
- 3. Design Control Considerations. The design control, pro-cess for the Title I design is described generally in SCP Section 8.4 (p.8.4.2-151) and is depicted in Figure 8.4.2-21, a copy of which is included. Key authorizing
() documents obtained from the Executive Summary of " Yucca Mountain Project ESF Title I Design Control Process Review Report.(DOE-NV)" January 19,1989 are listed in Appendix A. This document was an attempt to assess the design control (and quality assurance) measures in place
.during the ESF Title I Design effort. It was based largely on written questionnaires sent to the contrac-tors and interviews with contractor representatives. A cursory examination of DOE-NV disclosed mostly perfunc-tory comments which were not very helpful in establish-ing the formality of the control processes. The contrac-tor for design of the underground facilities, however, did list a " Project Control Manual" which suggests the.
presence of a formal program for design control (as well as control of other project aspects). DOE-NV also stated that project participants' design control procedures with a few exceptions which did not seem significant had been issued prior to the start of Title I Design. DOE-NV contained the following ' disclaimer' which is apparently based on the fact that the adequacy of the procedures had not been assessed and the degree to which the proce-dures had been followed was unknown.
"Unless specifically nated otherwise, the report can-eq not be used as a basis for representing the quality
(.) assurance standards implemented during the prepara-tion of specific project documents. It is the respon-sibility of users to (sic) this report to verify that
D, ,
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\.
' DECDGER 1988 10 CFR 60 -(UNDERGROUND OPENINGS) 1 r >
GENERIC REQUIREMENTS - APPENDIX (UNDERGROUND OPENINGS) 1r FUNCTIONAL ANALYSIS 1 f 1 f REFERENCE SUBSYSTb ' DESlhN CONFIGURATION REQUIREMENTS C7CUMENT Q (UNDERGROUND OPENINGS) (UNDERGROUND OW tlNGS) U E 1 I
'f A S b DESIGN BASIS (ARCHITECT ENGINEER) if T
g DESIGN CONTROLLED SUPPORTING Y DATA BASE ANALYSIS LINER DESIGN PERFORMANCE A GUIDE S C CONFIGURATION p EVALUATION O DEVEOPMENT S REFERENCE e.g.10 CFR 60.133
"""^" U O y Deslo" STUDIES p.
- "ASe gm.
(-)(') ^"o (2) a R
DESIGN A g SEISMIC DESIGN CALCULATIONS N GUIDE g E
Y : REVIEW < Y 1 r DESIGN PRODUCTS FINAL DESIGN
- REPORT
- DRAWINGS ANALYSIS ASSURA CE
- CONSTRUCTION
- COST REPORTS REOORDS SPECIFICATIONS ESTIMATES 8 &MIP.8CP/111 Des
.o Figure 8.4.2 21. Incorporation of regulations into design process.
8.4.2-152
ESF: Title I Design Review (cont.)
() the quality assurance stated to be in existence at the specific dates indicated in this report was l implemented in the preparation of specific reports L and/or data."
l l There is an apparent inconsistency among the documenta-l tion describing Title I Design control measures, the inferred evidence of design control from the scope and detail of the Title I Design, the seemingly conflicting statements of DOE-NV and the reluctance of the Staff to recognize any control of ESF Title I Design as adequate.
This suggests that
- a review in considerable detail should be conducted to determine to what degree the measures actually used in the ESF Title I Design work will qualify or partially qualify the ESF Title I Design according to the guidelines of NUREG 1298. (This suggestion is essentially the same as the Staff recommendation of Comment 3 (QA-8) Design Acceptability Analysis.)
- 4. ESF Construction.This review has not given much thought to the actual construction of the facility. I am con-vinced that there have been enough coal mines, gold mines, tunnels, and underground etorage facilities built that mechanically this project doesn't pose a serious challenge. It can probably be constructed using standard
() mining techniques. What is most needed
- are better-definition of the test room requirements and updated project criteria both of which at start of the Title I design effort were undoubtedly more doubtful than at the present time. The Title II designers need to have the best base to work from that can be provided.
General Comments In general, I believe that the Title I Design as expressed in the Site Characterization Plan and the few other documents I have reviewed, is an acceptable point of departure for the detailed Title II Design phase. This Title I design may not be as crisp as one would like. On the other hand I suspect it is reasonably responsive to the design criteria which originally guided its pro-duction. Perhaps the most serious shortcoming was failure to explicitly address the role of the ESF as part of the repository.
(On the other hand, the integration of the ESF and the repository is clearly addressed.) The Staff has recognized this deficiency, but seems to have considered the whole ESF as part of the reposi-tory, rather than only part (which seems more reasonable). This should be sorted out by reviewing the ESF components and classify- i ing them for potential use in the repository system.
. us
{'} l Finally, I do not believe that the Staff's Objection and Comments l should be construed as criticism of the authors of the Title I g
_ _ _ _ _ _ __ _ _ _ _ _ __ _ _ _ _ _ .l
ESF. Title I Design Review (cont.)
() Desien. Rather, Staff's review has pointed out perceived shortcom-Angs which stem from a variety of' sources: knowledge available now, but not when the design criteria were established; recogni-tion of new characterization plan needs; improved understanding of the test requirements: a desire to make provision for speculative activities; and, of course, the inevitable errors that occur in highly detailed documents. The perceived deficiencies in the Title 1 Design as it stands today probably reflect a change in the rules of the game rather than how the game was played! Through the review process these shortcomings have been identified for consid-eration and correction where appropriate in the Title II process.
Consultant's Gratuitous Comment
- DOE should hire the best and most knowledgeable engi-neers they can to follow the design activities of the architect / engineers and other contractors.
- During the Title II design phase the designers should seek the counsel of the people who will operate the facility to assure the practicality of the design. Only too often, when the designers have turned off their CAD-programs and the construction people have applied the last bit of paint, ' Operations' inherits a bunch of problems!
Vdland
- m. , 1989 O
4
,x N,
Appendix A ESF Design Control Documentation Chronology 8/80 NVO-196-17 NNWSI Project Quality Assurance Plan (sub-sequently revised eight times and now known as NNWSI 88/89 Rev 2) 10/85 DOE /RW-0032 OCRWM QLality Assurance Management Policies and Requirements 7/8E ESF Subsystem Design Requirements Document (SDRD) issued.
S/80 Assignment of OA Level II to ESF Design activities.
3/07 : DOE /RW 090:OGR/8-2 Appendix E. Generic Requirements for a Mined Geologic Disposal System issued.
/O.
i s j SDRD Rev. 1 (NVO-309) issued.
12/87 Contractor design base documents - prepared by Fenix and Scisson and Holmes and Narver - approved by WMPO.
(Implies. the existence of a QA program.)
1/86 Start of Title 1 Design authorized.
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