ML20248F375
| ML20248F375 | |
| Person / Time | |
|---|---|
| Issue date: | 03/23/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0008, NACNUCLE-T-8, NUDOCS 8904130046 | |
| Download: ML20248F375 (251) | |
Text
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O UNITED STATES NUCLEAR REGUMTORY COMMISSION ( ADVISORY COMMi" TEE ON NUCLEAR WASTE 4
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In the Matter of: )
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8th ACNW Meeting )
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afWWfmalln$9llaJW O ' Do Not Remove from ACRS Ofice I 1 l Pages: 1 through 182 ] l Place: Bethesda, Maryland ] Date: March 23, 1989
........................................................ 7 HERITAGE REPORTING CORPORATION l O osuaen-1220 L Street, N.W., Suite 600 Washington, D.C. 20005 8904130046 890323 (202) 628-4888 PDR ADVCM NACNUCLE T-OOO8 PDC
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'1 PUBLIC NOTICE'BY'THE I
2- UNITED STATES NUCLEAR REGULATORY COMMISSION'S
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3 ADVISORY COMMITTEE'ON NUCLEAR WASTE-4' MARCH 23, 1989 5 6 7 The contents of this stenographic transcript of. 8 the proceedings of the United States Nuclear Regulatory 9 . Commission's Advisory Committee on Nuclear Waste . (ACNW) , 10 as reported herein, is an uncorrected record ~of the 11 discussions recorded at the meeting held on the above date. 12 No member of the ACNW staff and no participant at~ 13 this meeting accepts any responsibility for errors or 14- inaccuracies of statement or data contained in this 15 ' transcript. O 16 17 18 19 20-21 22 23 I i 24-25 Heritage Reporting Corporation
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1 jj. UNITED STATES NUCLEAR' REGULATORY COMMISSION V
. ADVISORY COMMITTEE ON NUCLEAR WASTE In the-Matter of: )
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8th.ACNW Meeting )
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. Thursday, March 23, 1989
{_ Room P-110, Phillips Bldg. 7920 Norfolk Avenue Bethesda, Maryland The meeting convened, pursuant to notice, at 10:00 a.m. BEFORE: DR. DADE W. MOELLER Chairman,.ACNW Professor of Engineering in Environmental Health
-()- Associate Dean for Continuing Education School of Public Health Harvard Un3versity Boston, Massachusetts ACNW MEMBERS PRESENT:
DR. MARTIN J. STEINDLER Director, Chemical Technology Division Argonne National. Laboratory Argonne, Illinois DR. CLIFFORD V. SMITH TECHNICAL SECRETARY H. STANLEY SCHOEFER EX_ECUTIVE DIRECTOR ACRS RAYMOND FRALEY Heritage Reporting Corporation O' (202) 628-4888
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.i A'Q PRESENTFAS. ]
l EDWARD RINGE STEVE BROCOUM
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l DAVE < DOBSON I JUDITH MOODY 1 CONSULTANTS-i WILLIAM J. HINZE K. KRAUSKOPF - DONALD ORTH EUGENE E. VOILAND TED NORRIS BOB EROWNING DESIGNATED FEDERAL OFFICIAL: OWEN S.-MERRILL S.J.S. PERRY. r I i Heritage Reporting Corporation O (202) 628-4888
1 3 r~ 1 EBQREERIHGE (_ 2 DR. MOELLER: The. meeting will now come to order. 3 This is the 8th meeting of the Advisory Committee on nuclear 4 Waste. I am Dave Moeller, Chairman, of the committee. The 5 other committee members are present, Doctor Martin Steindler 6 and Doctor Clifford Smith. 1 7 We have a team of consults with us consisting of 8 Doctor Judith Moody,. Donald Orth, Connie Krauskopf, Gene 9 Voiland, and Bill Hinze. 10 'We also want to mention at this point, something 11 that is always a pleasure, certainly for me as Chairman of 12 the Committee, and that is to call to the attention of all 13 of those present that the Association for Women in Science 14 of Central Ohio is having its annual award dinner and
/"T \l 15 ceremony for the outstanding Scientists of the Year Award 16 for 1988 to 1989, and there will be two recipients, one of 17 which is Doctor Judith Moody. We are certainly pleased to 18 see that, and I am sure it is well deserved.
19 DR. MOODY: Thank you, Dave. 20 DR. MOELLER: During today's meeting, the 21 committee will hear a discussion on the side i 22 characterization plans by DOE, and conduct a discussion of 23 the exploratory shaft facility study plan on water movement 24 tests, and this discussion will be led by several of our 25 ACNW consultants. i r~g Heritage Reporting Corporation (/ (202) 628-4888 , 1
4 jr.s 1 The afternoon will consist of an administrative d 2 session. Topic discussed at that time will be our. future 3 schedule, a planning session for the ACNW review of the SCP 4 and the SCA. The discussion of issues related to the 5- repository development, possible discussion of a ACNW 6 response to letters that have been received by the NRC 7 concerning the section 20.205, for the proposed revision of 8 10 CFR Part 20. 9 I might also mention that this afternoon, Robert 10 Browning will be with us, who is the director of the 11 division of high level waste for the NRC, and he had told me 12 on the phone that he will be available to discuss a wide 13 range of subjects with the committee, including report on 14 where they stand on the review of the SCP, and so forth. O 15 Let us plan to devote some time this afternoon to a 4 16 discussion with him. 17 The meeting today is being conducted in accordance 18 with the provisions of the Federal Advisory Committee Act, 19 and the Government in the Sunshine Act. Owen Merrill, who 20 is seated to my right is a designated federal official for 21 the initial portion of the meeting. 22 Also at the table will be Jack Perry, who is also 23 a ACNW Engineer, and he will be serving also as a designated ) 24 federal official for the meeting -- for certain portions of 25 the meeting. Let me ask at this time if there are any Heritage Reporting Corporation O (202) 628-4888 l l l _m__ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _
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1 5. fjsp 'l - questions or comments by members of the committee or the kl 2 consultants? 3 (Negative response.)- 4 DR. MOELLER: Okay, seeing none then,,we.will move 5 ahead with.the meeting, and as you will note, the first hour 6 and one half'is devoted to. presentations by DOE on a 7 discussion of the side characterization study plans,'and 8 then we will have a break. 9 In following that, we will have the consultants 10 discussions related to the particular study plan on-water 11 movement tests. We have with us Ed Ringe, who will be 12 leading the DOE discussion on the study plans. Ed, it is'a 13 pleasure to have you back. 14 MR. RINGE: . Thank you Doctor Hoeller. I am Edward 15 Ringe with the Licensing Branch in the Department of 16 - Energy's Office of Civilian Radiative Waste Management. We 17 are pleased to be here today to continue our discussion of 18 the Department of Energy's high level radiative waste 19 management program with the Advisory Committee on Nuclear 20 Waste. 1 I 21' As you know, on February 22nd, we had a discussion 22 with you concerning the Department's side characterization 23 plan, often called the SCP. We had planned as part of that 24 presentation to have a discussion of our study plans. Do to f L 25 time constraints, we were unable to give that portion of the j 1 Heritage Reporting Corporation O (202) 628-4888 l
6- i s ! 1 presentation. (') 2 Today we are pleased to have an opportunity to 1 3 finish up that presentation and give a discucsion on our 4 study plans. Basically our study plans our a program 5 planning document thei provides more detail than the SCP, 6 more less link the general plans in the SCP with the more 7 detailed fiel<1, or laboratory procedures. 8 In today's presentation we will describe these 9 study planr, in more detail that I just did, and describe how 10 they do f t in with the rest of the program. We will give 11 brief descriptions of some of the typical study plans, and i 12 we.will describe the status of their development. 13 In the second presentation, we will describe the 14 quality assurance process that we are using in generating O- 15 the study plans. The first presentation will be given by .j i 16 Doctor Steve Brocoum, who is the Chief of the Site and ] l 17 Geosciences Branch in the Department of the Office and 18 Civilian Radioactive Waste Management. Steve? 19 DR. MOELLER: While he is coming up, Ed, and I am l 1 20 sure we have asked this before, whose decision -- or who l 21 selected the five study plans that had to be part of the 22 submission of the SCP? l 23 MR. RINGE: Well those five study plans were more i 24 or less reaching a mutual discussion with the NRC staff. l 25 Again, we don't really consider them so much as being part l m rg Heritage Reporting Corporation l (/ (202) 628-4888 -
f o , l J 7 11 of' the SCP, - but they are . study plans for some of the first.
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'2. tests whicht would be run, so it is appropriate that they be 1 3- submitted early to enable NRC to look at them before we 4 start that-testing. So as a eatter of. timing on those, it 5 was a matter of discussion with the NRC on what they wouldl l 6 need to see early. j
-1 7 DR. MOELLER: Have the plans that were -- the (
8 following up additional plans that were listed as coming l 9 along'in March, have.those been submitted?- 10 MR. RINGE: Part of Doctor Brocoum's presentation 11 will go into detail and the status of-all of the plans. 12 'DR. BROCOUM: Good morning, I am Steve Brocoum. 13 Just to follow up a little on your question. .Those five are 14 tests that will be.done during construction of the shaft. U 15 So those are some of the first tests that will be done in 16 the shaft, and that is why those five study plans were 17 selected. 18 The first viewgraph covers the topics that.I will 19 be talking about.. The first topic is how the study plans 20- relate to the SCP. I will briefly describe the May of ' 86 i 21 DOE /NRC level -- what is called level of detail agreement,
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22 how we plan issue, and how we understand the NRC. ) 23 We will review study plans, and then I will go to ; 24 give some examples. This was the original presentation that j 25 I was going to give last time. Since we have a little more p Heritage Reporting Corporation l (202) 628-4888 - - _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ =1
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< 1 time today, we decided to add to the presentation.
' ) 2 I will talk a little bit of what our area of 3 uncertainty are in mostly the geosciences and give examples 4 of study plans that-will be helping us to understand those 5 areas of uncertainty. 6 We have some viewgraphs that give a status of all 7 of the high priority study plans. I will not actually talk 8 through that. That just gives you a more or less current 9 status. Finally, I will talk about the status of 10 commitments from the meeting that the DOE /NRC had on 11- December 15th of last year. 12 The first viewgraph describes how the study plans 13 in the SCP relates. So the first one really describes the 14 SCP. The SCP presents the overall rationale for site 15 characterization program. Through the process of 16 performance allocation which Don Alexander went through, I 17 think, at the last meeting, we identified the information 18 needed from site characterization. I 19 The SCI covers the overall testing strategy and 20 describes the hierarrhy of all of the programs, 21 investigations, si ud4.as and activities which are going to be 22 conducted to provide this needed'information. Tha SCP in a 23 sense is the controlling document as to what activities and 24 studies are done at the site. In other words, one cannot do 25 an activity or study that is not described in the SCP unless
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I 9 j f-; 1 we change that and report it in the progress report. U 2 DR. STEINDLER: Is the converse correct, that'is, 3 are all study plans limited to those items that are in.the 4 site characterization plan? 5 DR. BROCOUM: Yes. 6 DR. STEINDLER: There will be no'other study plans 7 than thne? required by site characterization? 8 DR. BROCOUM: Currently. ! 9 DR. STEINDLER: . Currently. ! 10 DR. BROCOUM: If we decide that we need s new 11 study plan for one reason or another, then that will be 12 described in the semiannual progress report, and a new study 13 plan or a'new activity, or a revised study plan will be 14 s ssued. O 15 DR. STEINDLER: Okay. 16 DR. BROCOUM: But, currently, that is correct. 17 DR. BROCOUM:' Let's see -- 18 DR. MOODY: Hang on a second. What if you' find 19 .something in terms of your characterization that you did not 20 anticipate finding? How are you going to integrate new 21 information into the site study plans and into site 22 characterization? 23 DR. BROCOUM: The site characterization plan will 24 not be revised. The way it will -- the way the site 25 characterization will be updated will be through reports in (S Heritage Reporting Corporation l (,) (202) 628-4888 f L - - - - - - _ - - - - - -
10 gy A 1- the semiannual -- through semiannual progress reports. So
?Q' 2' if there is a new study or a new activity, or a major 3 revision, it-will be reported there.
4~ However, study plans will be revised as necessary. 5 So if you need to add a new activity, you will revise'the 6 study plan to include.that activity, and in. fact, in. 7 completion of the SCP, we added to one of the study plans, f 8 the NPBA's activity, for example. We took out, since at the x 9 current time, we were not going to Calico Hills. We took' l
'10 out those activities that describe the Calico Hills.
11 Overall schedules are presented in the site 12 characterization plan, and those will be updated in the 13 semiannual progress. reports. Potential for overall 14 interference among tasks are described in the SCP in Section O 15 84. H 16 So I think in summary I might say, that the-SCP is-17 integrated planning document, in a sense it' stands alone, 18 and you don't need the study plans to readland understand
'19 the SCP. The study plans give you details of a testing 20 program, or more details.
21 Now, the study plans, the content, was agreed at 22 the May '86 meeting, and they provide more detail 23 information on the activities, the tests, the methods and 1 24 procedures, duration and sequencing, constraints of various 25 tests, and QA requirements. QA requirements was not a Heritage Reporting Corporation O (202) 628-4888 1
11 1 result of this meeting, but was added later.as the QA 2 program evolved. 3 The study plans provide the link between the j I 14 overall program described in the SCP and'the detailed 5 procedures that describe exactly how something will be 6 sampled or analyzed, (nr trunch mapped, or bore hole logged. 7 The study plans.are kind of a connecting document.between a 8 very detailed procedure that the investigators work to and 9 the SCP which describes'the whole program. 10 So the final point is that they define a technical 11 work to be performed by the investigators. Although the SCP 12 .is a stand alone document, the study plans are not. You 13 need to understand the SCP to understand the study plans. 14 They are not meant or never have been meant to be stand O 15 alone documents. 16 The next slide. DOE has currently identified 106 17 studies in the SCP, and those study plans for these 106 18 studies are under development. Approximately 50 are in
- 19. draft form or in review -- are in.the system one way or the 20 other. The rest are yet to be developed.
21 Since studies consist of one of more activities, 22 there are 320 separate activities. Again, that is an 23 approximate number. I need to point out here that it was 24 never intended that all of the study plans would be issued
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25 with the SCP. ' l Heritage Report. tag Corporation O (202) 628-4888 l l u- _ - _ _ - _ _ _ _ _ =
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I 1 In fact, if-you!1ook at the attachment'of the-i i(/
-2 . level of_ detail agreement, it states there that study plans 3- would be developed throughout the site characterization
~ 4 program. The second bullet.just states that activities or 5_ studies may change as we progress with site 6 characterization, and as new information is.obtained. ,
'l 7 I described how that would be reported on the ;
8 progress reports. That is what the third bullet says, that j 9 this will be reported in a semiannual progress reports. iThe
'10 next slide, please.
11 This viewgraph just gives you a little information 12 on the format on the level of detail agreement. The level 13 of detai1Lagreement specified what should be included in the 14 study plans, and is specified each section of the study 15 plan,'and the exact details of course depends on the 16 particular activity being described. 17 The section headings are these headings, and if l 18 you look at the level of detail agrooment, for example the 19 first one, purpose and objectives of the study, it describes 20 the information, describes performance goals your trying to 21 address or the design goals. 22 In terms of the rationale of the selected study, 23 it gives you the numbers, locations, durations of various 24 activities, it gives you the kinds of. constraints that might 25 be on them, the scale, the phenomena you are trying to look I l t Heritage Reporting Corporation
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13 l' at, impact on the' site, that is a very important issue with 2 the staff, the accuracy of the. types of measurements that'
- 3. you'may take, and the amount of time you have available.
4 The third one, the description of tests analysis 5 describes testa methods, the range of expected results, 6 ' methods 1of analysis you would use, and so on. There is.a-7 lot more of these actually described in much greater detail. 8 I am just summarizing the level of. detail agreement. 9 Finally the fourth one says where this information 10- will go that you are collecting in this study. 11 The fifth one gives you schedule and milestone of 12 a particular study. . 13 DR. MOELLER: Each study plan, I gather, will be 14 assigned to a contractor to prepare? 15: DR. BROCOUM: The study plans are in' general being i 16 prepared by either.the.USGS, Los Alamos, Sandia, some by 17 Lawrence Livermore, and some by the Technical Support 18 ' Contract that deprives those SIAC, and a few of them are 19 being prepared by more than one. Is that correct Dave?. - 20 A few of them are being prepared by more than one. They are 21 integrated across. 22 DR. MOELLER: Are all 106 being worked on at the 23 moment? I 24 DR. BROCOUM: No. 25 DR. MOELLER: Okay. Heritage Reporting Corporation s_/ (202) 628-4888
- = _ . _ _ - _ . _ _ _ - - _ _ _ _ _ _ _ _ _ _ - - _ _ - - _ _ _ _ - _ _ _ - - _ - _ _ _ - - - _ - _ _ - - - - - - _ _ .__ _ _. _-. --_ _ 14 I ggg 1- DR..BROCOUM: Roughly 50 are being' worked on at y V ~ 2 ~ the moment. 3 DR. STEINDLER: Is it the intent of DOE to have 4 each study plan contain sufficient information so that a 5 reasonably knowledgeable reader can evaluate.the' evidence 6 -supporting each'of those things that you have up there? .
.7 Specifically, let me give you an example.
8 The question of the rationale for a selected-9 study, and the applicability of the data to the site, for 10 example, is always an issue in any protocol. Do you view
'll the study plans from the DOE standpoint to be self contained 12 in providing sufficient rationale and information to allow 13 somebody to evaluate that?
14 DR. BROCOUM: I think you need to -- in terms of 15 the rationale, it has to be in conjunction with the SCP, is 16 what I would say. In writing and review of the study plans, 17 we have a lot of internal debates and discussions on exactly 18 how much detail that one can interpret, for example, level' 19 of detail agreement, so we had a lot of debates back and-20 forth. 21 Yes, generally I would say that my answer to your 22 question is yes, but not with the qualifications, you need 23 to have the SCP also, because that really gives you the 24 reason why you need to do something. The study plan should 25 give you why you are doing it a certain way. CD (202) 628-4888
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,1 DR. STEINDLER: Okay.
2 DOCTOR SMITH: Let me ask you a~ question. Don't-3 you run the risk a little bit? You have your site l' 4 characterization plan, and then of course you are involved l 5 in your study plans. 1 6 You have chosen that you are going to perform site 7 characterization along some way, but you really won't know 8 what you chosen to do, make sense, until you really have 9 gotten the study plan done and reviewed by peers, as to 10 whether or not this makes sense. That you can indeed 11 characterize the site this way. I guess I get a little l l 12 worried when you say that it sounds to me like you are 13 starting from the top and then you are filling in all of the 14 details rather than the other way around. O' k- 15 DR. BROCOUM: No, I would say that the overall 16 development study plans and the overall development of the 17 SCP has been done more or less in parallel in reality. That 18 is how it was done. These 106 study plans -- 19 DR SMITH: I guess that is the question that I am 20 getting at. 21 DR. BROCOUM: Yes. 1 22 DR. SMITH: I mean you really have -- I don't see 23 how you can come up with a site characterization plan, and 24 then later on say, "Well now we will come up with a study 25 plans", and indeed, you're not even working on 50 of them, Heritage Reporting Corporation O (202) 628-4888
16 g g: 1 and you may get involved in one of those somewhere down the
'O 2 road, and you find that it doesn't give you the answers that 3 you want. It isn't right.
4 DR. BROCOUM: You bet. 5 DR. SMITH: You got to change something. 6 DR. BROCOUM: I think then you will have to go 7- back, revise what you are planning to do -- the study, 8 report on the six month progress report, and develop an new 9 study plan, or revise that one so that it gets the 10 information that you need. The whole program is designed to 11 be iterative. 12 DR. SMITH: Yes. 13 DR. BROCOUM: In other words, when we start 14 actually collecting information, we go back and see if it is
\ 15 providing what information we need, and see if it is helping 16 resolve that particular issue.
17 The issue is an iterative process. So it is not 18 just when you write the SCP, or when you write the study 19 plans, but it is actually as you collect data. So I think 20 we have the flexibility to do that. Just to back off one 21 second, the SCP in an sense, and the whole program has 1 22 developed from the top down. 23 In other words, the logic, the rationale, and the i 24 issue from the top, but the actual studies were kind of 25 developed from the bottom up, then they all had to be made Heritage Reporting Corporation
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17 1 to mesh. That is what we did in the SCP. O 2 DR. SMITH: Yes. 3 DR. BROCOUM: That is why I said it was done in 4 parallel. 5 DR. SMITH: I see. 6 DR. BROCOUM: Okay. 7 MR. HINZE: If I may, please. What-type of 8 scientific license is permitted within the plans? What is 9 it going to take to get a modification in the approach that 10 one uses to analyze the data -- to' interpret the data? How-11 long is this going to take? Who is going to make those 12 types of decisions on a week to week basis? You say that 13 they are going to be in the semiannual reports, but what 14 about on a more limited basis? 15 DR. BROCOUM: If you are going to make -- and we 16 have had some discussion on this in house. If you are going 17 to make a minor change in the way you collect your data, but 18 not change your overall scope of your study, but change -- 19 the principal investigator will have a lot of latitude in 20 doing that, but it has to be well documented, because QA 21 requires that. 22 If you are going to change the scope of your 23 study, or are going to change the kind of information that { 24 you are collecting, then you will have to go through some 25 change -- control process which is now being developed to do j Heritage Reporting Corporation q(_/ (202) 628-4888
I' f 18 1 that.
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2 I don't know if the e=act boundaries where:the 3 investigator has latitude and a change _ control process comes 4 in and-it has been. decided yet, but basically ~anything that 5 changes the overall goal of a study,1or would require that 6 something be reported in a semiannual progress report, will 7 need to go through a formal-change control process. 8 MR. HINZE: Well would that mean that a change in 9 methodology would have to be reported? That is not a change 10 in goal. 11 DR. BROCOUM: I can't give you a straight - I 12 think.it is going to be on an individual case. 13 MR. HINZE: I knew -- 14 DR. BROCOUM: It is kind of a difficult answer -- 15 MR. HINZE: But somebody has to think these things 16 out before hand? 17 DR. BROCOUM: I would say that if it didn't change 18 the scope of a study, probably not. If it does change the 19 scope, probably yes. 20 MR. HINZE: Will there be sufficient elasticity in 21 the budget and the time scheduling to accept these types of 22 internal changes within -- 23 DR. BROCOUM: No. 24 MR. HINZE: -- without changing the scope? 25 DR. BROCOUM: That is why I use the word " scope", Heritage Reporting Corporation O (202) 628-4888
pi 19
- l' by change of scope, not only-do you include changes in.
-O . 2 schedule, but also changas.in budget. That, I don't think 3 the principal' investigator can do on his own. That will 4 have to go, I believe, through formal change control 5 process. DOE is in the process of baselining --
6' DR. MOODY: That's correct.
'7 DR. BROCOUM:' -- the whole programs. So you-do 8 control the changes'in.a formalized way.
9 MR. HINZE: Those changes will be reported up to 10 what kinds of levels, at what types of levels will they be 11 discussed?
.2 DR. BROCOUM: To the-appropriate boards that will 13 be both at the project office and at headquarters, depending 14 on the scope of the change. There will be formalized change 15 control procedures.
16 DR. BROCOUM: Study plans are designed to be 17 reviewed by technical experts. I would rather use the word 18 " experts" than " peers", because a peer review has a very 19 special connotation in a quality assurance program that we 20 have. I don't think we really meant peers on this 21 viewgraph. 22 A peer is someone who could actually do the work 23 that you are reviewing as opposed to somebody that is 24 knowledgeable enough to review it. The reviewer -- so I 25 think that is the wrong word. I would say technical expert. Heritage Reporting Corporation O (202) 628-4888
20 1 It is assumed that the reviewer is familiar with 'O 2 .the:SCP, and therefore the' study plans,'again, as I.said
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3 earlier, not stand alone documents.- Study plans reference 4 detail technical procedures, but do not.in themselves i 5' describe -- and.you would have to read all of the procedures 1 6 if you wanted to understand them all. 7 They must implement the particular testing 8 strategies developed in the SCP. So my guess would.be if 9 you want to change your testing strategy, that is'a change 10 in a sense.that the SCP -- so that.would go through a change, i 11 control process. 12 Study plans address interference and-testing 13 impacts on' waste isolation relative to the particular tests 14 or methods that'are going to be used. In terms of among 15 studies, or between studies, that is done in the SCP. 16 DR. MOODY: How important in your' view is who is 17 going to do the work that you define in the site study plan? 18 DR. BROCOUM: I am not sure I understand your-19 question. Study plans are written-by the. principal 20 investigators who will be doing and or overeeeing the work 21 directly. The authors are the principal investigators 22 themselves. So, you know, it is either GS or Los Alamos. 23 DR. MOODY: Well, what if they say that part of 24 the work is going to be done by a subcontractor,r and the 25 subcontractor is not identified?
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'1 DR. .BROCOUM:- Well.any subcontractor that does the-2 work will have to have a qualified QA program to do the 3 work. They will have to be within the whole QA program-l'
~4 either at the project'or at headquarters. They will have to 5 have qualifications, and they will have procedures and 6 record keeping, so that is the way -- one of the ways that 7 you can control a' subcontractor.
8 -There is also, of course, a requirement for. 9 competitive fitting for subcontractors, so you need to go 10 through that -- I believe that that is true. I am looking i 11 at the opposite. It think you basically bid most of'your 12 subcontractors. Sole sourcing is a very difficult thing to 13 do. 14' DR. MOODY: I know, but that may or may not have
'O 15 some relationship to the quality.of the work that will'be 16 done by a given group.
17 DR. BROCOUM: If you are doing a study that has a 18 unique. requirement and is only say one individual or one 19 Then you can ' company in the whole world I can do it. 20 justify a sole source contractor. But you need to be able 21 to justify that that is -- that person -- it is not a thing 22 that you can easily go out and bid for. 23 The next viewgraph. Now, I am going to turn a 24 little bit, just to give some examples of study plans. 25 DOE is planning to issue study plans six months prior to the Heritage Reporting Corporation (202) 628-4888
9 22 1 -start of work where that is possible. That may not be
- O. 2 pa 91ble in all instances. If we want to stay on with the 3 schedule that we are on at the given time.
4 It is our understanding that the NRC will review 5 each study plan for a three month period. What we call a 6 start -- they call it a start work review, and then any 7 major concerns that they have with that study fund, they 8 will identify those to DOE. 9 If there are no major-concerns identified in that 10 three month period, DOE can move ahead with preparing to 11 conduct that study. They will also at that time identify 12 study plans that they believe need to go through what they 13 call a detailed technical review, and they will inform us. 14 Those study plan -- then you will have another three months O 15 to go through a detailed technical review. So it is a six 16 month -- a maximum of a six month period of time that the 17 NRC needs to look at study plans and interact with DOE. 18 19 20 21 22 23 24 25 Heritage Reporting Corporation O (202) 628-4888
23 1 MR. SMITH: Okay. You eay where possible up
.O 2 there in your first bullet.
3 DR. BROCOUM: Yes. 4 MR. SMITH: And NRC is saying, well, in some cases 5 they are going to need six months. So, what do you.do if --
-6 DR. BROCOUM: Well, we intend to have most of the 7 study plans say, 75 or 80 percent or a large percentage of 8 them out six months before, but there may be some -- say, we 9 can only get out five months before. And the NRC Staff has.
10 . indicated, you know, if you have a problem meeting the six 11 months, come and see us and we'll see what we can work out. 12 I mean they're out to help us. 13 So, for most study plans -- by "most" I mean the
'14 great majority,.we will try to meet that six months.
15 MR. SMITH: But you are not going to get started 16 on a study plan. I mean you are not going to actually 17 implement it until you at least have that first review, are 18 you, by NRC? 19 DR. BROCOUM: That's correct. 20 DR. STEINDLER: But there is at least one other 21 activity between starting work and the study plan and that 22 is to get the procedures in place and approved. How do you 23 intend to squeeze those in? They tend to be somewhat 24 critical in some areas. 25 DR. BROCOUM: No. Procedures need to be in place l l Heritage Reporting Corporation O- (202) 628-4888
24 f.s . 1 and based on -- I think it's in that agreement -- 60 days
'U 2 prior to the start of an activity. That's also formalized.
3 And the Staff will ask us for any procedure that they want 4 to see. And based on the last meeting -- the agreement says 5 we will send them all, quote, non-standard procedures. At 6 the last meeting they say they would just rather pick out 7 the ones they want to see and let us know and we will send 8 it to them. 9 DR. MOELLER: Gene? 10 MR. VOILAND: It seems that some of these 11 activities are very complicated and will require quite a lot 12 of advanced planning and effort. 13 DR. BROCOUM: That's correct. l 14 MR. VOILAND: Will you do some kind of screening. El 15 to be sure that the six months is enough? You may have to 16 get started earlier on subcontractors or whatever. 17 DR. BROCOUM: Well, the whole preparation takes 18 much longer than -- 19 MR. VOILAND: I understand. 20 DR. BROCOUM: We intend to issue it to the Staff 21 six months prior and to the state. But the whole 22 preparation may take much longer. Some of these studies, 23 these five that we have issued were written several years 24 ago. 1 ! 25 MR. VOILAND: But you might have to go out and rw Heritage Reporting Corporation (202) 628-4888
25. 1 consummate contracts and get people lined up. Would you do 2 that before.the study plans are~ approved? 3 DR.' BROCOUM: That's correct. Well,-I think 4 before we start work on the contracts'rather than before 5 their released. But the other thing you can't always
-6 predict is theLreview-process itself. Some. reviews have 7 gone relatively smoothly, others have had a lot of 8 differences of opinion and it took.a lot of revision and 9 additional reviews to get a study plan through.
10 So, I think we realize that. But for our-11 planning, for our planning, we're planning on six months-in 12 all out year planning, now, we're working on issuing a study 13 ' plant six months before we intend to start work. 14 By starting work, basically what we mean is either-15 collecting Level 1 data or doing anything that can-
- 16. compromise the ability of a' site to isolate waste. There 17 may be preparatory things that we can do prior to those six 18 months. For example, putting in a drill pad or something 19 like that. -
20 DR. MOELLER: Now, NRC has said that they are not 21 going to review all of the study plans and I don't want to-22 misquote them. Maybe they are saying not in depth. I am 23 sure they will look at all of them. Do you have any idea 24 and we can ask this afternoon to'get a answer from them, but 25 do you have any idea what percent of the study plans NRC has Heritage Reporting Corporation O- (202) 628-4888 , 1 i
26 1 . indicated they will review in depth? O 2- DR. BROCOUM: At the December 15th meeting, they 3 indicated about 20 percent. 4 DR. MOELLER: Okay. Well, just for a comment on 5 that, I know Dr.-Moody at the last meeting suggested that, 6 you know,. ideally you would review all of them.. And in 7 preparation for this meeting, I went through the list of 106 8 in my own perhaps layman sort of an approach. And I.said to 9 myself, "Well, let me find 10 percent 'cn 20 percent that I 10 really would want to review." Well, I ended up with well 11 over half that I had checked that I thought.were very 12 important. 13 DR. BROCOUM: And there is nothing that precludes 14 the Staff from doing that. And that's why they want -- the O 15 NRC Staff wants all plans six months before. And we are 16 trying to accommodate them as best as we can. If they 17 decide they want to review all of them, they can do that. 18 The point I am just trying to make here, they do 19 have a three-month window for whatever this start work 20 review consists of, okay? 21 DR. MOELLER: There is a note for the Committee. 22 We ought to ask Mr. Browning this afternoon how many 23 full-time equivalents are available to pursue this. And, of 24 course, it would take a multitude of talents. 25 DR. MOODY: That's just the question I was writing Heritage Reporting Corporation O (202) 628-4888 i
27 1 down. -Does NRC have the staff to do this. 7-)-
%)
2 DR. BROCOUM: Now, I was just going to go through 3 some of the' areas of uncertainty we have about Yucca 4 Mountain and this first viewgraph kind of summarizes that we 5 have areas of uncertainty in geohydrology, generally, the 6 low processes in the unsaturated zone, in tectonics 7 preclosure, we are worried about surface faulting for the-8 surface facilities particularly and ground motion. For the 9 post closure we are worried about the impact of tectonics on 10 the hydrologic conditions and also potential impact.of 11 vulcanism. 12 In terms of climate, we are worried about the 13 impact, the change of climate in the future and what impact 14 that will have on the hydrologic-system and in terms of 15 resources, we are worried about the potential for the 16 presence of significant resources and what that means in 17 terms of human intrusion. 18 I have additional slides on each of these bullets. 19 We shall expand on them a little bit and then we will show 20 you some of the study plans that are coming out more or less 21 in the near term that will address them. 22 DR. MOELLER: This is just a side comment that is 23 probably not for you to respond to. But, now, under 24 tectonics, you look at preclosure conditions and postclosure 1 25 conditions, but then when I read the proposed outline for (s ( Heritage Reporting Corporation (202) 628-4888 i _ _ _ - _ _ _ _ - - - _ _ - _ _ _ _ _ _ - . _ _ _ b
28 1 the safety-analysis report which DOE submitted to NRC simply 2 as.a matter of information, they look in terms of accident 3 analysis only preclosure. There is no accident analysis 4 postclosure. At least I couldn't find it.
.5 DR. BROCOUM: I guess they're talking about the 6 operating phase of the repository where a accident could 7 happen.
8 MR. GAMBLE: It's a matter of terminology in the 9 sense that accident analysis is something done for the 10 operating system. And then the postolosure, it gets into-11 the area of scenario analysis -- so, it is r change in 12 terminology between the two periods of time. 13 DR. MOELLER: So, you are saying in essence that 14 DOE will look at accidents postclosure. l b) Ns 15 MR. GAMBLE: Loosely speaking, yes. They will 16 look at events processes that could disrupt -- 17 DR. BROCOUM: A natural accident I guess you would ; 18 describe than -- 19 MR. GANELE: The regulations don't use the term-20 accident in the postclosure period. 21 DR. BROCOUM: This is Bob Gamble of Weston. Okay? 22 DR. MOELLER: Thank you. 23 DR. BROCOUM: Okay, the next viewgraph just lists 4 24 some of the major questions we have within flow crossing and ; 25 saturated zone, what is the rate and distribution of net I Heritage Reporting Corporation p) gi (202) 628-4888
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.1 infiltration 1near the surface. What is the rate and 2 direction of ground water movement'in the unsaturated zone-from the surface, the repository horizon. Is there 4 significant lateral flow in the unsaturated zone? Is there 5 perch water. That is a major issue. Is there significant 6 ground water flow in the fractures? This is a very.
7 significant issue, also, in terms of ground water travel 8 time. This will have a major impact on ground water travel 9 time. And what is.the rate and direction of ground water
-10 moving from the repository itself to the accessible 11 environment.
12 Some of the. study plans we have is the use 13 unsaturated zone percolation which includes-the 14 multi-purpose borehole near the exploratory shaft. -That 15 study plan is designed to detect and sample perch water if 16 it is present, through the multi purpose borehole, and the 17 effects of shaft construction and how that might affect the 18 hydrology in the area of the shaft. That is one of the five 19 study plans that the NRC has. 20 The second one I have listed here is -- and these 21 are just examples. They are not meant to be comprehensive, 22 just to show the Committee how things were doing. 23 Characterization of the unsaturated zone, infiltration, 24 using artificial and looking at natural rainfall 25 infiltration. And that is due -- I'm not sure if that is in 1 Heritage Reporting Corporation O (202) 628-4888
l 30 1 orinot,-but that was due to headquarters this month. 2 The third example is unsaturated zone percolation. 3 This is a major program to do throughout the site and within 4 the controlled area, a series of unsaturated boreholes to 5 study the hydrology unsaturated zone to get the spacial and 6 temporal variability of all hydrologic properties. That is 7 in headquarters and it is under revision based on comments 8 generated during the headquarters review. 9 The fourth example is regional studies in the 10 ground water of the flow system.- And among other things, it 11 will-evaluate recharge in 40 mile wash. And that is due at 12 headquarters this month. These are all relatively speaking 13 near term. Okay? 14 The next viewgraph gives you some of the major 15 expansion and the major questions on tectonics and we will 16 show soima of the study plans to address that. Surface 17 faulting ground motion, what's the earthquake magnitude and 18 the recurrencables for the local quaternary faults. As I 19 showed I think the last time-I was here in one of the maps, 20 there are lots faults. Most of them trending north-south 21 that have a quaternary and in some cases -- what is the 22 vibratory ground motion, what vibratory ground motion should 23 be used to design the structures and systems and components 24 important to safety. And what is the likelihood and 25 characteristics of potential surface faulting. This is a Heritage Reporting Corporation O (202) 628-4888
31 fS 1 major issue for the surface facilities. V 2 I think there are more questions here. In terms 3 of postclosure what are the impacts of tectonics on 4 hydrologic conditions and to what extent can the future 5 tectonic events cause change in the ground water conditions, 6 fracture. flow, matrix flow, or a rise in the water table. 7 What are the origins and agents calcite-silica deposits 8 which may suggest a higher water table in the past. Are 9 they hydrothermal or pedogenic. 10 What is the potential for vulcanism and what is 11 the probability that the repository could be penetrated or 12 impacted by basaltic magma? 13 Some of the study plans that will address these 14 questions include study plan'on historic and current /~,\ \" 15 seismicity. It's a USGS. study plan. These activities are 16 actually ongoing. These are monitoring activities. We have 17 a Southern Great Basin in the Yucca Mountain site neck which 18 is a part of the Southern Great Basin seismic and we also 19 are recording strong motion. We have strong motion 20 instruments in place and being installed. The study plan, 21 itself, is due in October of '89. And I believo we are 22 trying to accelerate that study plan. 23 DR. MOODY: Just a question of information. In 24 terms of your present seismic work, do you detect the 25 underground explosions of the Nevada Test Site nuclear Heritage Reporting Corporation O- (202) 628-4888
32' 1 explosions? O 2 DR. BROCOUM: Yes, we do. Second is, in fact, the 3 strong motion instrument is the one for the NTS. We are' 4 installing our own strong motion instrument now. , 5 The second study. plan is faulting potential at the j 6 surface facility. Locations,.that's in Midway Valley. This 7 study. plan has been reviewed at headquarters. 'It has been .I 8 revised. It's come back to headquarters for the final, we 9 call audit review, verification review. And there's a few 10- more revisions. That will be. released in the next several 11 weeks. And that is important because we're trying to start 12 the investigation of Midway Valley because the advance 13 conceptual design is scheduled to start this fall. So, we 14 need to start this study. L 15 The next one is quaternary faulting in the site 16 area, a USGS. study plan, also. That includes mapping 17 entrenched with the characterized possible quaternary faults 18 and the value in the age and recurrence of movements on all 19 these faults. This is now in headquarters and it is 20 undergoing review. And they are due to meet on that in mid E ' 21 April. So, that will probably be out in the next several 22 months. 23 Parts of these activities are ongoing, but there 24 is no surface disturbance. But some of these activities 25 that don't disturb the surface are ongoing. Heritage Reporting Corporation , (202) 628-4888 _-_-_- 1
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33 , 11 Finally, we,have the volcanic features'and .O 2 potential and potential for future volcanic activity. 'This 3 is the Los Alamos study plan which will include drilling and 4 coring. Geophysical anomalies have been identified. That
'5 might be due to volcanic features that'we will study the 6 geochronology of the volcanic events and other field studies-7 of volcanic features.
i 8 Some of these are also ongoing, but not the 9 drilling and the' coring. 10 Now, the next group is climatological questions 11 which require investigation. And basically, the question is 12- the impact of two things: how the future climate conditions 13 can.be bounded and, secondly, is what will be the impact of 14 future climate on groundwater hydrology. 15 And the near term thing we have is -- the near 16 term study plan is a characterization of the quaternary 17 regional hydrology, a USGS study plan. That is undergoing, 18 that has been reviewed, revised, it's back to headquarters, 19 making sure that the revisions have been incorporated. And 20 that will be issued over the next month or so. And it 21 includes regional pp.leoflood studies. It-includes 22 hydrochemical analysis of the unsaturated zone, evaluation 23 of past discharge areas, analog studies for recharge and 24- studies of calcite-silica hydrogenic deposits. Some of-25 these are also ongoing. Heritage Reporting Corporation O (202) 628-4888 i
34
. ,-s 1 I've been mentioning ongoing several times. I j
\
'-) 2 should just clarify: things that-were ongoing when the
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3 level of detail agreement was written were allowed to 4 continue pending release of the study plans. But we are not 5 doing anything that could impact the ability of a site to 6 isolate waste. So, we are not drilling or trenching or any j l 7 other major disturbing -- until the study plan is issued. f 8 This is a near term one. There are six or seven 9 other climatological studies in preparation ranging from the i 10 present climate in the Southern Great Basin to studies that 11 look at potential future climates and their impact on 12 hydrology. 13 The next major question is natural resources. 14 What is the potential for significant resources. What is i O '/ 15 the potential for mineral and energy resources of economic 16 value. What is the future supply and demand for groundwater 17 resources near the site. And to what extent can these lead 18 to -- the first two bullets -- lead to potential for human 19 intrusion or exploration for resources. 20 That study plan which will pull all this together 21 is the natural resource assessment studies. This is being 22 prepared by SAIC. That study plan is being written. We 23 don't have a schedule for submission to headquarters. But 24 this study plan is an assessment. It takes results of other 25 studies and activities and uses them to assess a natural Heritage Reporting Corporation
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1 l l 35 ! l g 1 resource. So, all of these types of things that are listed
-) 2 here, you know, geochemical analyses from surface sampling ;
I 3 in core, geophysical data and geological data, evaluation of { l 4 heat flow, evaluation from other geological, geochemical and , 5 stratigraphic studies are all from other studies and 6 activities, okay? So, those will all be analyzed in this 7 study. 8 Now, the status of study plan development and 9 these numbers were current as of a few weeks ago. We have 10 gotten a few study plans in since then. So, these numbers 11 may need to be updated a little bit. But, basically, we 12 have about 19 study plans at headquarters for review. There 13 are more study plans at the project office review. Five f 1 14 have been transmitted to the NRC. Two are being revised
?
15 based on the verification review that the comments that were 16 agreed to were incorporated. Two of them are actually being i 17 verified. Two are being revised. The authors in response 18 to the overall headquarters review, six are currently in I 19 technical review and then one is in acceptance review. 20 That's when we first receive it. We want to make sure the 21 study plan looks complete before we review it. And one of 22 them at the moment is on hold because it is not one of the 23 high priority study plans. . I 24 So, as of the date of this slide, we had 19 in the 25 System, 14 of those were of the 17 high priority studies , l
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_ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ = _ - _ _ _ _ ___ ____ _ __ . _ _ _ _ _ l 36 fg 1 that were listed in a letter of May 10 of last year. V 2 So, the point I am trying to make is though we may 3 not meet the exact dates in that letter, we basically are on 4 schedule with those, almost all of those study plans. 5 MR. ORTH: Just exaotly who is doing these 6 verification reviews? 7 DR. BROCOUM: Headquarters. 8 MR. ORTH: That doesn't tell me a thing. 9 DR. BROCOUM: Our technical support contractor I l 10 think does the actual verification and the lead reviewer. 11 MR. GAMBLE: Headquarters and lead reviewer is 12 responsible for verifying that it in fact the comments have 13 been read and incorporated -- 14 MR. ORTH: I am wondering about -- I don't mean to 15 imply anything bad about this. I am wondering about the. i 16 technical competence of the, quote, lead reviewer. When I 17 say who, I mean what technical background, organization, l 18 whatever. 19 DR. BROCOUM: Each study plan was reviewed from' ! 20 six to twelve and I think Dave has one to show the number of 21 reviewers in the water tracer tests which we're discussing 22 today, if you want to see the list of reviewers, we have it. 23 There might have been 20 on that one. But generally 6 to 12 24 reviewers from headquarters, Weston, Argon, Oak Ridge, 25 Lawrence Berkley, okay? Plus the project office has its r^ (_)g Heritage Reporting Corporation (202) 628-4888
37 1 reviewers from their various organizations. if~1 v 2 MR. ORTH: I can't resist it, but when you just 3 say " headquarters" I can't avoid that old remark: "I'm from 4 the government and I'm here to help you." 5 DR. BROCOUM: "The check's in the mail," too, 6 right? No, we have a large group of reviewers from the 7 various national -- mostly from the national labs. 8 DR. MOELLER: Now, you said there were 17 high 9 priority plans. Those are'17 selected out of the 1067 10 DR. BROCOUM: That is correct. They include 11 activities that we want to begin early during site 12 characterization. 13 DR. MOELLER: Okay. They are high priority in 14 terms of time? 15 DR. BROCOUM: Yes. 16 DR. MOELLER: Not in terms necessarily of data. 17 DR. BROCOUM: I would say the highest priority was 18 in terms of timing. 19 DR. STEINDLER: We seem to be missing three 20 high priority plans. If there are 17 identified in the 21 letter and you are working on 14 right there, where are the 22 other 37 l 23 DR. BROCOUM: In the last couple of weeks, several 24 more came to headquarters. I'm not sure. I haven't ] 25 personally checked the list to know if they are all in. e Heritage Reporting Corporation 5 x (202) 628-4888 , l l
38 1 But we:are going to update all of this to the NRC 2 in April. Okay, but I can't you an answer right now where 3 they -- 4 DR. STEINDLER: I guess the point I am asking 5 really is: Are those three buried in those 19 that you have 6 up there? 7 DR. BROCOUM: No. That 19 included 14 of the 8 original 17. 9 DR. STEINDLER: Are there any high priority study 10 plans that are not very far along at this point? 11 DR. BROCOUM: I think they are all -- I think you 12 have to ask Dave Dobson back there because he is the project 13 officer. I think they are all within three months of the 14 original schedule. O r
\/ 15 DR. STEINDLER: That's fine, thank you.
16 MR. VOILAND: Gene, I'd like to follow Don Orth's 17 question. The people that you mention in terms of reviewing 18 largely came from national laboratories and research 19 organizations. I hope there is a good representation from 20 the practical people that have to deal with projects 21 involved in those reviews. 22 DR. MOODY: Well, see, that ties into the comment 23 I was going to make and that is that there is another 24 thinking out there and that thinking is the national labs 25 are just another government agency. And whether or not Heritage Reporting Corporation O (202) 628-4888 i i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ )
L 39 1 those really can be considered independent is very much open 2 to question. 3 DR. BROCOUM: The question of independence has a 4 lot of ramifications because it depends on whether you are 5 talking about QA but in terms of the way it is defined in 6 QA, those people are independent. Also, the people, many of 7 the people in national labs that we use are not directly 8 tied into our program. In other words, they do not do site 9 characterization. Okay? 10 So, they are independent in that sense, also. 11 They don't report -- they have contracts from DOE, but they 12 don't report to us in the management chain. So, I would 13 argue that they are fairly independent. 14 MR. VOILAND: Well, in any respect, NRC is going D- 15 to be reviewing it and they are going to be using 16 independent contractors, ones that are separate. So, I 17 guess I don't have a problem with it. You are using the -- 18 it is DOE's responsibility and you're using the best people. 19 DR. BROCOUM: The reason we got all national labs 20 is because when these study -- about a year ago, when all 21 these study plans started coming, all these study plans 22 coming into headquarters, we needed a resource of people, a 23 pool of people we could use to help us review. And, so, we 24 signed on -- contractually, it's very easy to sign on a 25 national lab, and so we got help from national labs so we Heritage Reporting Corporation O- (202) 628-4888
i l 40 f-1 would have a resource of people. I J 2 You had question and I don't think I answered it, i 3 though. 4 MR. VOILAND: Yes My question was: Are there 5 people that are, you know, hands-on kind of people that. deal 6 with the kinds of activities that we are talking about here. 1 7 DR. BROCOUM: Hands-on people we have from l 8 headquarters are familiar with the overall program and 9 people from our technical support contractor, Weston, and i 10 equivalent people from the project office. So, they are 11 involved in review, also. l 12 We don't just give it away to a national lab to 13 review. We are involved in that review, you know what I 14 mean, we have representatives at all the meetings, we [ 15 participate, we make comments. I mean I'm talking about I 16 headquarters and its technical support contractor. 17 MR. RINGE: Steve, may I also add that the quality 18 assurance process that we apply to the review does require 19 that there be a certification of the requisite expertise in 20 the reviewers. So, I suppose one could wonder how effective 21 that is, but there is a formal effort to assure the 22 expertise of the reviewers. 23 Maybe a possible example, now, we do have when 24 Dr. Dobson gives his presentation, I think he brought some 25- backup viewgraphs that do show the typical list of reviewers 1 1 fs Heritage Reporting Corporation (202) 628-4880
41
,, 1 .or a sample list of reviewers on one of the study plans 2 which, in view of the interest in this, I think it might be 3 worth showing. We can present that a little later.
4 DR. MOELLER: Bill? 5 MR. HINZE: We're in the site characterization 6 phase of this study and, yet, you mentioned the surface 7 facilities in Midway Valley and moving some high priority 8 study plans for that facility. Is that facility required 9 for the site characterization or are we talking about an 10 operational phase? And if so, why is that such a high 11 priority. ! 12 DR. BROCOUM: That facility is important for the 13 preclosure accident scenarios that we were talking about 14 carlier because that is the waste handling, that will 15 include the waste handling building, and if they do a 16 repackaging or putting into containers, that will be where 17 it's done. So, it is important. 18 It is not important from the postclosure 10,000 19 year I believe isolate wastes. It is important from the 50 20 to 100 year time frame that the facility will be operating. 21 MR. HINZE: Well, I am concerned about getting at 22 some of the fundamental problems that we have concerning the 23 site characterization and letting the surface facilities be 24 a driver on the available resources and talents. 25 DR. BROCOUM: Well, the problem we have is we need f^ Heritage Reporting Corporation t (202) 628-4888 } L_ _ -_ -_- _ __ - -
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42 fs 1 to have a seismic design basis for those surface facilities. b 2 And there is one, but we need to verify that that is the l 3 correct seismic design basis. And one of the things we need 4 to do about that is to make sure there are no faults 5 certainly under the facility because it is very hard to 6 design for surface offset. That's a much more important 7 question to us and to the designers than, say, for example, 8 vibratory ground motion which is easier to design for. 9 Considering the area that we're in that has lots 10 of known quaternary faults. 11 DR. SMITH: Can you refresh my memory as to the 12 total cost of the site characterization process and the 13 length of time? Do you remember? 14 DR. BROCOUM: You mean from now to ' 957 15 DR. SMITH: Yes. In other words, we are going to 16 spend what? Some billions of dollars and I don't know how 17 many years to try to say whether or not it is okay to bury 18 waste in Yucca Mountain. And perhaps it is inherent in the
,1 19 site characterization plan, but I just wondered if when you 20 did put that together in all your studies, you looked at it ,
21 from the standpoint of, you know, first making gross 22 studies, gross exams, if you will, at minimum cost, surfaced , 23 based, whatever you can do to make sure that you don't find 24 a situation where it is not the place to be. And if that 25 passes, then you go on to more detail and if no problems i l g Heritage Reporting Corporation
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43' 1 arise-and that passes andrat some point, you may make the O~- 2 decision: Let's get out of here.
-3 "What I get the feel of -- and I may be absolutely 4 wrong, is I see an incredible massive study on all fronts i
5 moving faster than the dickens, going to cost billions of 6 dollars before we ever make the decision that maybe this 7 isn't the place to.be. ! 8 DR. BROCOUM:' It's a very complex question. There 9 are different aspects to this. First of all, we have -- the 10' things I tried to indicate on these slides are the areas 11 where we think we have the greatest uncertainty, where wo 12 think we have to look at those areas relatively early, which 13 we are trying to do. 14 DR. SMITH: So, you are sort of picking out -- 5 15- okay.
~16 DR. BROCOUM: Yes, as examples. The single most 17 important area is the unsaturated zone.
18 DR. SMITH: Right. 19 DR. BROCOUM: We did do in the fall of '77 an 20 analysis for the three sites at the time, what things could 21 we look at to see if we studied those sites for one or two 22 . years in terms of disqualifies, what can we use to 23 disqualify a site early on, if you like. One of the things 24 that Congress was debating at that time was requiring us to j 25 do that. 1 i Heritage Reporting Corporation () (202) 628-4888 ] l b I
l 44 i f- 1 In terms of this site, the unsaturated zone, the J 2 seismic tectonics were two of the big areas. And those are 3 two of the areas.I have shown up here. Okay? 4 But in discussing and in completing the SCP, we j 5 had a lot of discussion on these things and there was no 1 6 consensus, for example, by all the investigators involved l l 7 that say we should just go do surface based testing and not 8 do the exploratory shaft for a period of time. 9 There is a lot of -- you would get all different 10 sides if you talked to the various people. So, it is very 11 hard to say, " Gee, let's just do these ten tests now and you ; i 12 can find out if the site is likely to be suitable." 13 As far as we know now and the site has been 14 studied for 10 or 15 years already, there are no, quote, O 15 disqualifies as they define in 10 CFR 960 at the site. 16 Some of the qualifying conditions in the 17 regulation require performance analysis. To do a 18 performance analysis, you need to have data to do that. 19 They are not very simple. If you get a certain number, you 20 disqualify the site. 21 DR. SMITH: So, you would say that after 10 years 22 of studying this site, based on everything you know now it 23 looks like the right site. But because of the regulations 24 and other things that you have to really meet and have 25 evidence we are still looking at maybe a multi-billion Heritage Reporting Corporation {}/ s- (202) 628-4888
45 1 dollar bill in five or six years. 2 DR. BROCOUM: Yes, depending on how you define 3 site characterization, it would range 400 million to 1.6 4 billion dollars. And I don't want to be putting those 5 numbers on the record, but -- 6 DR. SMITH: I understand. 7 DR. BROCOUM: If you include drilling, you don't 8 include drilling. If you include actually constructing the 9 shaft as opposed to just the cost of the test and so on. 10 DR. STEINDLER: Steve, let me add that I believe 11 those numbers reflect the cost of the entire program during 12 the site characterization phane which includes -- a 13 significant portion of that includu things other than the 14 actual site characterization wor!c, design work and other 15 activities. 16 MR. RINGE: Well, we never did get to a figure, 17 though, Ed. 18 DR. SMITH: That's true. 19 DR. MOELLER: Excuse me. For purposes of the 20 record, you said that when you were looking at several sites ' 21 I believe in 1977, was that the correct -- did I hear that 22 date correct? 23 DR. BROCOUM: Yes. 24 DR. MOELLER: And that is the correct date? 25 DR. BROCOUM: Yes. The fall before the Nuclear i q Heritage Reporting Corporation () (202) 628-4888 '
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'l- Waste :' Olicy Act amendment was passed. Oh, what did'I say?
O 3 '777 l 3- DR.-MOELLER: That's the way'I heard it. l 4 DR. BROCOUM: I apologize.- I meant to say '87.- 5 DR. MOELLER: Just so the record is correct. 6 DR. BROCOUM: The fall of 1987.. 7 DR. MOELLER: Thank you. 8 DR. BROCOUM: Now, the next three-viewgraphs I 9 wasn't going to go through. That's just a listing of the 10 study plans and about'when we think they will be estimated 11 at the NRC. Some of these dates currently may be one to
-12 three months longer than actually shown in this viewgraph.
13 We are going to update these dates and send them to the 14 staff in Apr'.1. Okay? So, I just want to skip over - *
' 15 . these are for your information, but'I wasn't going to talk 16 to them.
17 DR. MOELLER: One thir% though, that hits you in 18 looking at this list is the high percentage that are being 19 done by the USGS. Now, we also heard at our February 20 meeting, at least I got tho impression that frequently it is. 21 rather difficult to get a final report out of USGS or to get 22 any data, to obtain data from them. Are you taking that 23 into consideration in your assignment? 24 DR. BROCOUM: Yes, in terms of y.:oparation of i 25 study plans, I would say that the GS has been responsive in Heritage Reporting Corporation . O. (202) 628-4888 !
L 47 1 preparing the study plans. 2 DR. MOELLER: But you earlier said to us that the 3~ people preparing the study plan will probably do the work. 4 So, if USGS does the work, are.we ever going to see the 5 data? 6 DR. BROCOUM: The configuration management system 7 that.is being put in place to control the flow of data will 8 have certain requirements on the data to be put into the 9 reference information base, certain requirements as.to what 10 preliminary work can be done on that data and there is a 11 whole-configuration management system being put in place 12 that we hope will address the flow of data. , 13 It is not a USG3 problem. It is a project-wide 14 problem because you have so many participants and
- 15 subcontractors. And about a year ago, I heard it was a 16 total of 27 that controlling the flow in data and making 17 sure it feeds to where it is needed is something that is 18 being addressed through the configuration management system.
19 DR. MOODY: Well, the critical thing there is the 20 USGS agreeing to input their data in a timely fashion into 21 that. 22 DR. BROCOUM: Well, it is, there is a USGS 23 representative here today. It is a part of the agreement i 24 between DOE -- I mean they are participants in the program i 25 and I think they understand they need to feed their j i p Heritage Reporting Corporation l 1 (202) 628-4888 l l i ___r___________._______.__
48 l :information so-that it'can be used'in' performance analysee JO 2- or by other participants. In that water tracer test,. forL 3' example, it indicates that data will'be exchanged .between 4 the.USGS and the.Los Alamos. 5 We will have to improve our availability of data. 6 The way we-have done business in the' business in the past. 7 will not get-us a licensed application in. January 1995. We 8 need to improve the transferability and availability of 9 data. And I think we all realizeithat, including the USGS. 10 DR. STEINDLER: Let me go back just a second.. I 11' thought I heard you say that tectonics and one other major 12 subject were issues that addressed, I guess hydrology, 13 addressed the site suitability. 14 DR. BROCOUM: Are very important issues. I want 15' to point out those aren't the only issues. 16 DR. STEINDLER: And thus far, I gather, you have-17 not seen any information coming out of that site which 18 indicates that either tectonics or I guess hydrology would 19 make the site unsuitability. If that is correct, then let 20 me go on and ask: If those two topics in site 21 characterization represent the highest chance of finding 22 some unfavorable attributes of the site and, therefore, 23 disqualifying the site, why aren't study plans dealing with 24 those two topics much more prominent in your early schedule? 25 DR. BROCOUM: As I have indicated because a lot of , i Heritage Reporting Corporation i 1O. ' (202) 628-4888 i
49 f 1- ~ activities that are non-disturbing are. going on, they are (_/ ' 2 ongoing activities. And we.have of the 320 activities, 3 roughly 80 of them are classified as ongoing. And there is 4 a letter which will be coming to the NRC shortly, which 5 according to my viewgraph has been sent, but hasn't yet, 6 which will identify each of those activities. And I think 7 you will see when you look at that list. There have been 8 for a period of time lots of work going on and continuing 9 today. But at the same time, we are trying to get those 10 study plans out. 11 DR. STEINDLER: So, there will be study plans for 12 ongoing activities? 13 DR. BROCOUM: Yes, absolutely. In fact, the Staff 14 made that a major issue at the December 15th meeting. They 15 want those study plans as quickly as possible. And we are 16 reassessing our schedules based on what they said. 17 DR. STEINDLER: I gather then the Department 18 doesn't feel that the risk that seems to be involved in 19 having study plans of ongoing activities that relate to the 20 -- directly relate to important issues on the qualifying the 21 site might in fact be either rejected or modified in a major 22 degree. 23 DR. BROCOUM: My guess, on most there will be a 24 lot of comments because we have had a lot of internal 25 comments on these things. Each of our study plans we l Heritage Reporting Corporation _/ (202) 628-4888 L. _ _ . _ . _ . _ _ _ _ . _ _ _ _ _ . _ . _ _ . . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _
50 q~ 1 reviewed, we have had up to 400 comments. . And generally 50 2 to 100 would be a typical number. That doesn't mean the l 3' study plan is bad. It-is.just when you get a consensus of g 4 people, they have1various opinions that you need to work 5 through. So, I will not be surprised if the NRC Staff has a 6 lot ~of comments. I am hoping we don't have too many_ 7 objections to our proceeding. Okay? I am hoping they will 8 pass as we hope the SCP will. 1 9 But I think having comments is a healthy thing 10 because it will help us improve our program. But I need to-11 back off and point out that, again, it is very difficult to 12 think of a single measurement or a single suite of
'13 measurements that will tell you that that site is 14 unqualified since qualification ties in so closely to 15 performance assessment.
16 The closest thing I can think of is if you found 17 out that all your groundwater movement in the unsaturated l 18 zone or substantial portion was in fractures rather than 19 matrix. That would really cause us to pause and to reassess 20 our understanding of that site. But everything we have to 21 date tells us that that isn't true. But remember, we have a ! 22 minimal amount of data compared to what we will have as we 23 proceed through site characterization. 24 So, I was going to now go -- I think I only have 25 one more viewgraph left, which tells you the status of the p Heritage Reporting Corporation 1 (202) 628-4888
51 ) l 1 commitments that came out of the December meeting with the l l 2 NRC. First was the study plan analysis for the five study l 3 plans. And Dave Dobson will cover that in the second talk. 4 Secondly, the Staff asked for a list of study 5 plans that covered all ongoing activities and the 6 responsible participating organizations,.that list has been 7 prepared. A letter has been written. It is still in.our- i 8 concurrence process, okay? When we wrote these slides a 9 week ago, we thought the letter would be out. 10 The NRC asked us to reevaluate our position on 11 prototype testing. They suggested a prototype testing ought 12 to be QA Level 1. We are in the process of evaluating our 13 position. 14 Some study plan references were missing. All the. 15 references have been provided to the NRC Staff except for 16 two which require a copyright release. And at least as of a 17 few weeks ago, those were not yet released. 18 DR. STEINDLER: Let me ask what you mean by 19 prototype testing? 20 DR. BROCOUM: This is testing done in G-tunnel or 21 outside the control zone to develop a testing procedure or l 22 to verify a testing procedure or to develop procedures for 23 doing a test. ! 24 DR. STEINDLER: And NRC's position is that should 25 be QA Level 1? Heritage Reporting Corporation
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R 52 c 1 DR. BROCOUM: I don't think they have a position. j f 'I 2 They just made a suggestion or they asked a question because i 3 they said: How do you know that your procedures are really 4 right if you don't do a QA Level 17 ) 5 That is the question they asked. I don't think , i 6 they took a position. And I think you need to look at the 7 minutes from that meeting which has what their position on 8 that was. Okay. That is my presentation. 9 DR. MOELLER: At this point, let me just ack a 10 question. Probably you're not the one, maybe Ed is the one, i 11 but we saw in a report of NRC's Center for Nuclear Waste 12 Regulatory Analyses, they issued a report on February the 13 10th, 1989, in which they simply were quoting from others 14 that the National Park Service Water Resources Division has (3 k-) 15 filed a formal protest opposing the DOE application to 16 Nevada for a water permit to support the work at the Yucca 17 Mountain project site. Could you comment on that? I mean 18 if you don't get water, could you go ahead with the project? 19 Can you haul in water? 20 MR. RINGE: I really can't comment on that. I am 21 not aware of the status of that. Certainly, we would have 22 to get water from somewhere. There is no question about 23 that. 24 DR. MOELLER: Okay. We will ask it at a later 25 time and I'm sure we'll get information later on it. g~ Heritage Reporting Corporation (,) (202) 628-4888
53
,g -l ;
Are there other. questions for. Steve before he U 2. leaves?
- 3. (No response.)
4 DR.EBROCOUM: 'The.next' speaker is Dave Dobson from 5 the project office. He's'the Chief of the Regulatory 6 . Interaction Branch of the project office. And I also~want-7 to point;out we also have in'the audience today'and will be 8 available to answer any questions the principal investigator 9' of the: water tracer test studies, Dr. Ted Norris, from H10 Los Alamos. 11 DR. MOELLER: Fine. And I might repeat and
'2
. I'm sure Dr. Norris knows this that we will be discussing or 13 hearing reports from our consultants on their impressions of 14 this. study plan at the end of this presentation and 15 following our break.
16 DR. DOBSON: I just have a short briefing that was 17 originally designed for 15 minutes at the last presentation, 18 obviously, in which we discuss a little bit about the 19 controls that we have applied ts the development and the 20 review of the study plan. It is just to give you a feeling 21 for who we have to review them and how they're reviewed and 22 what sort of controls we feel are required. 23 Basically, it probably won't surprise you to hear 24 that we have attempted to control study plans throughout. 25 According to a process that we have designed to insure that Heritage Reporting Corporation O (202) 628-4888
'J 1
54
,- :1 'all the requirements, and those requirementsLare taken-ly )- !
2 :largely from quality assurance requirements from NQA-1 and -j 3 our quality assurance plan have been met. 4 The procass, obviously, has been consistent with 5 the QA plans .we have had in place throughout .the program and : 6 at least since we started reviewing study plans which was in 7 mid-1987. 8 Obviously, also, the quality assurance plan has-9 evolved throughout time so that the process we had in place 10 in 1987 is not quite the same process as we have now. So, 11 there's been an evolution both in terms of the program and 12 our procedures. 13 The study plan content and control, one constant 14 perhaps.in this thing is that the study plan content has 15 been controlled and reviewed against agreements that the DOE 16 reached with the NRC at the May 7, 1986 meeting on the level 17 of detail in the.SCP and the study plan. At that meeting, 18 essentially, study plans were created and the content of 19 study plans was defined. 20 I-mentioned that the process had been evolutionary 21 and along the top part of the chart here, you can see sort 22 of the evolution of procedures and things like that. We 23 have the May agreement here. The site characterization plan 24 management plan which was the tool that we used to develop 25 the SCP originally was also used to cover the study plans 1 Heritage Reporting Corporation t (202) 628-4888
j 55' 1
; gq 1 'which were considered-and still are considered to be
%) a 2 fundamentally apart of the SCP.
3 DOE headquarters' developed 2a review and approval' {
~4 procedure that wasLissued around December of 1986, I think. ]
5 And other procedures have" evolved over time, including 6 another version of the SCP management' plan, an' interim j 7 headquarter procedure, another project' procedure called 8 Administrative Procedure-110Q. This line out here is where 9 Revision 2 of-our quality assurance plan 88-9 which is the 10- plan that has been accepted by the NRC as an adequate QA 11 plan was -- that's the period in which it became effective. 12 So, you can see much of the review and approval of the study 13 plan obviously occurred prior to our having had a completely 14 accepted'QA-plan by the NRC. Q 15 DR. STEINDLER: 88-9 is not a headquarter plan, is-16 it? 17 DR. DOBSON: No, that's the project plan. 18 DR. STEINDLER: Are there any approved 19 headquarters plans for review of these studies? ~ 20 DR. DOBSON: There are headquarters procedures 21 which have been approved by headquarters since -- the first 22 approve.1 procedure took place here. But it is also a true 23- statement that the overall headquarters QA plan was not 24 accepted by the NRC. 25 DR. BROCOUM: The status of headquarters plan is Heritage Reporting Corporation O (202) 628-4888
56 1 study plans that we reviewed to date have been reviewed 2- under what we call our interim procedure which is a fairly. 3 ' detailed procedure. And starting Monday, the 27th, we are 4 under a formalized headquarters QA plan. There is a 5 procedure. A quality assurance administrative procedure 3.1 6 that describes technical reviews. We are in the process of 7 revising our interim _ procedure to make it what we call a 8 implemented line procedure which will formalize the process 9 of reviewing study plans. 10 We don't think there will be many substantive 11- -differences from what we have done in the-past. But there 12 are paperkeeping and a few other in terms of making sure we 13 document people's qualifications and we train people to do 14 reviews. O 15 DR. DOBSON: We will discuss this a little more 16 later, but that fact that you pointed out is the one that 17 led the NRC at the December meeting to. request that we do an 18 analysis of the five study plans that we had submitted.to 19 insure that the process that we used to control them was 20 adequate. In other words, they recognized just as you did 21 that, okay, fine. You did them according to procedures, but 22 you have also told us that your old procedures were not 23 consistent with the program that we just accepted. So, 24 therefore, we would like to have some demonstration that the 25 quality of the study plans is adequate. Heritage Reporting Corporation O (202) 628-4888
57 1 And just so you get a feeling for the number or O 2- quantity of reviews: The water movement test which is the 3 one that several of the consultants here have reviewed was 4 ' originally written by Dr. Norris back in the summer of 1986 5 soon after the May 7-8 agreement was. signed. 6 l[t was reviewed in an informal sense back in here 7 and it has been in sort of revision and participant review 8 at Los Alamos and through various other sources. 9- During this period of time, it was reviewed by 10 quite a number of people in connection with other testing 11 programs, for example, the exploratory shaft testing program 12 was reviewed by an independent group in 1987 or was it '86. 13 I think it was early '87. 14 It then started in the formal study plan review 15 process that I will describe. So, all of these blocks 16 represent various review periods throughout the sort of 17 evolution of that study plan. So, the plan has seen a lot 18 of reviewers. q l 19 Basically, to quickly summarize the current 20 controls that we have study plan development, at the project 21 office, we have an administrative procedure called 1100 22 . which describes all the requirements for preparation, review 23 and approval. And it is intended basically to implement 24 sub part (g), 10 CFR 60 (g) controls for the control of the 25 review and the qualifications of the individuals involved. Heritage Reporting Corporation O (202) 628-4888 l 3
t (~ 58
;1-Basically, the requirements fall'into four major categories.
2; As I mentioned, study plans should be prepared and 3 reviewed by qualified staff.- Study plans need to conform to 4 the'1evel of detail agreement, the DOE-NRC agreement, on 5 . level of detail. And they must, of course, also be 6 consistent with the SCP from our. view since the SCP is the 7 regulatory document that controls the technical planning. 8 The process of development revision approval, et 9 cetera, is controlled now according to specified procedures. 10 - In our case, the project is the AP.and headquarters has 11 procedures for their review as well. 12 And, . finally, records documenting that we have 13 done all of these things need to be maintained. 14 And, so, those are the requirements that have been. 15 in place and we have attempted to implement.since at least 11 6 I've been on the project which is May of ' 87. And they_have 17 been formalized now according to the NRC accepted program in 18 88-9, Rev. 2. 19 This again was discussed in some more detail by 20 Steve and I just-thought I would put it up here for 21 reference, but the format of a study plan, for your benefit, 22 I'm not sure if everyone had available the level of detail 23 agreement, but the level of detail agreement does lay out
)
24 the format and therefore constrains the sort of structure of 25 the study plan. And it has five major sections, the purpose l l
=e ite.e gorein, cor, ora,1,m O (202) 628-4888
"59 l' and objectives, including scientific or technical objectives
.O 2 as well as the regulatory rationale and justification.
-3 It has a rationale for the selected study. The 4 idea of part.2 is given that you need to get a certain-piece 5 of information that the SCP says that you need, what test 6 will you do to get that-information and how did you select
- 7. this particular test from a suite of tests that might give 8 you similar information.
9 Again, there are two parts to that: the rationale 10 for the selection of the type of test and, second,.what sort 11 of constraints exist on the study. What sort of things can 12 you do or can you not do as a result of the characteristics 13 of the methods that you have selected. 14 Third, of course, is the description of the tests. 15 And there is actually quite a long list of things to 16 consider when you write the description of the test and the i 17 level of detail agreement. 18 Fourth, again, the application results: Where 19 will we use the data that you are producing here? And that 20 is specific both to the performance and design aspects of 21 the program as well as to site characterization. In other 22 words, there are a number of studies in the site 23 characterization program that don't really feed directly 24 into a design. But they feed into another site program 25 which then produces a piece of information for design. And, Heritage Reporting Corporation p/ s_ g (202) 628-4888 l
60 ) i 7s 1 finally, the schedules and milestones, of course. o 2 Again, just to sort of briefly summarize the 3 process, we have a couple of viewgraphs in here which just- _ 1 4 show the flow of what happens to a study plan and how it l 5 evolves. i 6 It starts with the participant and the PI who { 7 considers the SCP and the level of detail agreement as well 8 as his own technical knowledge of the subject when he start 9 writing the study plan. 10 He prepares it. It is reviewed in house. So, a 11 Los Alamos study plan before the DOE ever sees it gets 12 reviewed by Los Alamos according to their own internal 13 procedures for review, i 14 It also is required now to have a quality 15 assurance review in house before it comes to us, although 16 that requirement did not exist until the recent program was 17 implemented. 18 The participant following their review cycle, they 19 submit it to the project office where we do a quick 20 screening review of a few days and determine whether it is 21 ready for a full technical review. 22 At which point, we start a big review. And 23 basically there are four aspects to our major review. There 24 is a technical review, a management review, that should say 25 regulatory. We don't do review reviews -- well, actually, Heritage Reporting Corporation O. (202) 628-4888 l l
1 61 7S 1 we probably do. And QA reviews. V 2' There was a question earlier about'whether or not 3 we are getting the right sorts of people to review these 4 things. And I think the question was: Are hands-on sorts 5 of people looking at them. And I guess the answer is that 6 when we set up a review, we do try and have all the. 7 *ppropriate people get a look at a review. In other words, 8 if a fellow is doing an unsaturated zone hydrology test, and 9 it is going to be done out of drill hole, we will.have 10 people who ere familiar with drilling technology and the 11 ability to take things in and out of a hole and whether to 12 case or not case. We'll have those sort of people review 13 the study plan as well as the scientists who know how to l 14 deal with the transducers and the instrumentation that was s-l ' 15 used down there. But that is obviously something that we 16 establish on a case-by-case basis. When we get a study plan, 17 we say who is the appropriate group to review it. 18 But we do try and keep that in mind. We do need 19 to obviously make sure that we are able to do the tests as
, 20 written. And that is one criteria of the review, 21 Currently most of the reviews are conducted in 22 parallel by the project office and headquarters. And at the 23 conclusion of these rather detailed reviews, as Steve 24 mentioned, we have had numbers of comments ranging from 60 25 or 80 on some of the smaller plans to over 400 on some of Heritage Reporting Corporation s) (202) 628-4888 l
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c 62
, 1 the bigger plans. And these~are plans that are thick study 2 plans, several hundreds of pages.
4 3 We then have a comment' resolution meeting where l 4 the reviewers get together with the author and we talk 5 though all the comments, basically, and we arrive at a 6 ' resolution. What we come to at that meeting is what we call 7 a proposed resolution. We take the study plan home. The d 8 principal investigator takes it home and revises it. O Resubmits it and then the study plan is checked. This 10 auditor verification review is done. It is not a new 11 review, it's just a check that the revisions we have agreed l 12 to previously were implemented. ; i 13 Once that is all done, hopefully, the study plan
]
14 is approved and then transmitted to the NRC. And it is i 15 obviously a long process. We think that the reviews are 16 very important. And we have them reviewed both in house 17 within the project participants to make sure, for example, 18 that they produce, if it's a site program, that it produces 19 the information, the performance or design needs. 20 We have them reviewed by the other national labs, 21 as Steve mentioned, who are not involved in the program both L 22 for technical credibility and for a sort of technical 23 analysis of whether what we're proposing is reasonable. 24 DR. STEINDLER: The study plans are not, as I see j l 25 them, at least protocols: explicit, detailed procedures, l i Heritage Reporting Corporation O. (202) 628-4888 j
.63 7 1 DR. DOBSON: That's true.
2 DR. STEINDLER: In the course of your technical 3 analysis of what these plans are, do you require the 4' principal investigators to have at hand detailed procedures 5 of how he is actually going to do all this? 6 DR. DOBSON: Yes and no. The nnswer is the 7 technical procedures are required to implement any of these 8 things. As you are aware, probably, the SCP and the study 9 plans both reference technical procedures. And I know we 10 put together a package of what's currently available for one 11 of the-unsaturated zone studies that the NRC has last week 12 and there are several thousand pages of technical 1 13 procedures. So, what we have attempted to do basically is 14 write the study plans at a level that is sufficiently O k/ 15 detailed for a technical expert or peers -- not in terms of 16- a peer review, but somebody who is familiar with that sort 17 of work can review them and approve in general that the 18 plans are adequate, that they have sufficient detail for up 19 here in the field to review and approve them. 20 On the other hand, if we attempted to include 21 procedural level detail we would literally have study plans ; k 22 that are regularly thousands of pages long. 23 And, so, we recognized that we didn't want to do I l 24 that. 25 DR. STEINDLER: I guess the question I have is l Heritage Reporting Corporation l I (,) fs (202) 628-4888 1
I 64
. f. 1 that-I am trying to see what.the magnitude of that technical
'(,
2 review is, that box that is sitting up on the very upper end 3 of the screen out of sight. It is hard for me at the moment 4 to see how a technical review of a plan can be done without 5- having some idea of how the guy'who is going to do all this 6 is going to implement the various portions of this fairly 7 broad scope activity. And it is in that context that I am 8 wondering whether or not the details of the protocol, of the 9 . protocols that are likely to be followed are available at 10 the time when six people sit in the room and look at this
'11 plan.
12 DR. DOBSON: Well, I guess my response is that we 13 attempt to write them to a level of detail so that if you're 14 sitting around a table with a group of people who do the e
\- 15 same sort of work, technically, there won't be a lot of 16 questions about what's intended when the PI writes -- in 17 other words, if Dr. Norris says he is going to do mass 18 spectrometry, he is not going to write down: The first 19 thing I am going to do is plug in the spectrometer.and then 20 I am going to go through it one by one. But we would have 21 it reviewed by people who are familiar with the technique so 22 that he wouldn't have to do that.
23 He can say, "I'm going to use mass spectrometry to 24 do the chlorine 36 analysis and I will develop such-and-such 25 a procedure to control that." (as Heritage Reporting Corporation (202) 628-4888 i
65
- ll And we-try and put in there the level of detail 2 that we hope a person who is familiar with that sort of work' 3- would want~to see. Obviously, it is always a balance, 4 whether'you put in more details or less. But our goal is.to 5 put in a' sufficient. level of detail that technical people 6 can read it and say, "Yes, I understand what he is doing and 7 I endorse it." Or "I don't endorse it. 'I have questions 8 about a certain thing."
9 This might be an appropriate place to show just in 10 terms of numbers of reviewers. For example,.you were asking 11 about technical reviewers. This is just a short summary of 12 some of the technical -- some of the reviewers that we had 13 on the water movement test which is the one that you 14 reviewed. If we had it reviewed by several people at O, 15 Lawrence.Berkley Lab, we had it reviewed by the USGS fellow 16 that works with the DOE as well as several independent 17 consultants, for example, Pat Domenico, who is on contract 18 to some of the national labs and this is -- those are people j 19 who reviewed.it at headquarters for water movement test. 20 There is another list of people who reviewed it-at i 21' the project office. So, you see that if you get 18 or so 22 people like this number together you are going to generate a 23 lot of commente in general on a plan. 24 I might add that for this particular test, it had , 25 been reviewed as I mentioned earlier by probably 10 or 12 Heritage Reporting Corporation Os (202) 628-4888 f l
66 es 1 people prior to our ever having received it as a study plan U 2 in our office. So, they are. technically reviewed. And, so, 3 when we try to find that balance of what is the right level 4 of detail, basically, that is what this process does. 5 We go through it and we give it to a lot of people 6 who'we think are competent in the field in general. For 7 example, my name is on this list for water movement. I am 8 not an expert in chlorine 36 analysis and my review of this 9 study plan, I haven't listed the field review. Mine was 10 obviously a management, a sort of DOE review in terms of 11 policy and aspects of it in that regard. 12 We have, of course, on file the qualifications of 13 all the individuals and what aspects that they are supposed 14 to be reviewing. But if we give it to a group of 15 hydrologists and we let them sort of thrash around and find 16 that right level of detail. 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation O (202) 628-4888 l L___________________ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - - - - - _ _ _ _ _ _ _ _
67.
-s 1 DR. MOELLER: Do'each of them do a written report, 1 id. 2 or do they do it in groups?
3 DR. DOBSON: They do it individually on comment 4 sheets that we provide. So that is how we track all 5 comments. We have formal comment response,.or -- it's 6 called a. comment review sheet. 7 DR. MOELLER: Yes. 8 DR. DOBSON: And then at the comment resolution 9 meeting, the group assembles the reviewers and the author, 10 and discuss the proposed resolutions to those comments. So 11 we have a lot of large meetings in various cities where we 12 convene our reviews and discuss -- 23 DR. MOELLER: And they will spend a day, then -- 14 DR. DOBSON: At least two, and sometimes a week. (~') v i 15 DR. MOELLER: And these are the individuals who 16 independently review, and then all of them get together, 17 they see each others comments and share and discuss? 1 18' DR. DOBSON: That is basically the way it works, 19 yes. 20 DR. BROCOUM: This is all formalized in the QA I 21 procedures, and it is required by our procedure and the 1 22 project procedures. They want to make a correction -- they 23 don't all necessarily have to be there. j 24 DR. DOBSON: Well it -- 25 DR. BROCOUM: It has to be representatives. Say gg Heritage Reporting Corporation i s_/ (202) 628-4888 l l I L
l 68 f 1 that the U.S. has six people look at it. They don't
'~#
2 necessarily have to have all six people at the meeting. It 3 can'be one or two people who are going to present the other 4 people. 5 DR. DOBSON: In some cases we may have a lead 6 reviewer from an organization. Oakridge may send -- l 7 DR. MOELLER: Sure. 8 DR. DOBSON: One person instead of three people -- 9 DR. MOELLER: Okay. 10 DR. DOBSON: -- that reviewed it. But the intent 11 is to gather the reviewers and discuss the resolutions. 12 DR. MOELLER: Okay. 13 DR. DOBSON: Excuse me, I mentioned that at the i 14 December meeting, the NRC having looked at our process for i 15 controlling study plans over time, pointed out to us that we I 16 had -- well at the December meeting we agreed to control j 17 study plan preparation review as a QA level one activity. 18 It had formally been designated a level two. l 19 The NRC expressed some concern that the' study ; 20 plans hadn't been prepared according to an NRC acceptance 21 program, and a level one program, and therefore requested 22 that we look at the quality of the five studies that we had 23 submitted them, or that we were about to submit them at that 24 time with the SCP, and document the result of our analysis 25 of the quality of the study plans.
-% Heritage Reporting Corporation
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69 1- So we agreed, obviously, to do that, .and we have ,
' ) 2 written something called the study plan ~ analysis in, order to ;
3 attempt to do that. It is currently -- well it says here 4 that the-a'nalysis does go through everything from the 5 reviewer qualifications to the process used to control each 6 study plan, to a-discussion of the reviews of each study . l 7 plan, and the adequacy of that review. 8 All of the reviews that have been done are I 9 included -- including both the project office reviews and 10 the headquarters reviews, and the various types of technical , 11 management. regulatory quality assurance reviews,'and our
~
12 study plan analysis is currently in the final review at DOE.. 13 Prior to transmitting it to the NRC. 14 DR. STEINDLER: Did you agree readily to convert O~ 15 this to a QA level one activity, or did you struggle a f i 16 little? ; 17 DR. DOBSON: Pardon me, I am not sure I heard 18 that. 19 DR. STEINDLER: I gather you were urged to move
- 20 from level two to level one?
21 DR. DOBSON: Yes, it was -- 22 DR. STEINDLER: Did you agree readily, of did you 23 struggle a little? 24 DR. DOBSON: Well we struggled -- I suppose you 25 can say there is a long answer to that question. I don't Heritage Reporting Corporation O (202) 628-4888
70 g3 1 know if you want to hear. V 2 DR. BROCOUM: We had a lot of internal debate, and j 3 I would say the technical people did not have the consensus 4 that that issue be level one -- that it should be level one. 5 There was a lot of debate. 6 DR. DOBSON: I would add that we have always 7 viewed all of those aspects of subpart G, and 10 (c) Part 50, ! 8 that applied to development of plans as applicable. We'have 9 always viewed the activities that are described in here as 10 level one activities, so the site characterization 11 activities which provide the data that we intend to use in 12 licensing are clearly level one, and we have always tried to 13 control the activities and the plans associated with them 14 according to what is required in 10 (c) Part 50, and Subpart 15 G. 16 DR. STEINDLER: It isn't very obvious what you 17 gained by moving the planning to level one. 18 DR. DOBSON: Well -- 19 DR. STEINDLER: It is pretty obvious what you 20 gained when you do the activity at level one. 21 DR. DOBSON: Right. 22 DR. BROCOUM: The basic thing we are gaining is 23 the impact. In other words, when you drill a hole, that 24 will be a level one activity. When you dig a trench, that 25 will be able to impact to the ability to characterize -- rs Heritage Reporting Corporation i (202) 628-4888 i
71' L1 impact to the natural barriers, and things like
~~-2 interference, and impact,.and the ability to characterize a 3 site. In' terms of data collection as Dave'said, we were 4 always.at level one.
5 DR. DOBSON: Okay. The preliminary conclusions of 6 the study plan-analysis based on the draft that we have in 7 review now are essentially -- we did have controls that are 8 more or less equivalent to those for a QA level'one 9 activity,~and that is based on an analysis of -- if you look 10 at.our current program and'say, "Okay, if you were to set.
'11 this process up, the QA level one process, what would you 12 do?", and by matching those requirements against what we 13 did, it appears to us that the controls were substantially 14 equivalent.
15 We did have in term of our current program, 16 essentially requires prequalification of people like 17 reviewers and things like that. In other words, you 18- shouldn't give a person something to do without having 19 previously qualified him, and in some cases, in the study 20 plan review.in the past, we did not do a quote, unquote, 21 prequalification. 22 We have gone back to verify the qualifications of 23 all of the individuals involved and found that they are -- 24 we' haven't found anybody that is unqualif3od yet, who has ; 25 reviewed them anyway. Finally, we have not -- so far 1 Heritage Reporting Corporation i
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72 cs 1 anyway, identified any deficiencies in the content that we
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2 know of. 3 This.is just -- I am not going to talk.through 4 this, but this is an outline of the content of the study 5 plan analysis, and it just shows what sort of things we 6 looked at. Section two talks about, at the beginning, what 7 controls are required, based on our QA plan that has been 8 accepted by the NRC, how are we implementing those controls 9 in section 2.2, and in section 3.3, what was the evolution 10 of the procedures and processes that got us to where we are 11 now. 12 Section three is the evaluation of the exploratory 13 shaft study plans that the NRC asked us to look at. That 14 includes a description of the review process for each of the i 15 five study plans, and an evaluation of its adequacy for each 16 of those five in terms of the review. 17 Finally just a summary with the conclusion and 18 some recommendations. We have, not surprisingly, I think, 19 identified a number of minor things that we think we can 20 improve in the process. l 21 We don't feel any of them are really quality ) i 22 affecting. We think that they study plans are in pretty i 23 good shape. We are always striving to improve the program, 24 so we got some recommendations there. I think that is about 25 all I have. l p Heritage Reporting Corporation (202) 628-4888 ! l l l
.73 1 -DR. MOELLER:f-Any other questions for Doctor 2 Dobson?
l' 3 (Negative-response.) 4 DR. MOELLER: Okay, well let.me'then close out the 5 ' initial portion of our meeting for today. I particularly-I
.6 ~ want to thank the DOE people, ED and Steve,_ Dave, the group, 7 for coming, and I apologize.again that we couldn't schedule-8- you.-- or, you know, get you -into the schedule last tiime 9 when we had promised. The wait was well worth it. Thank 10 you very much.
11 MR. RINGE: I would like to thank you for this 12 opportunity. I am glad we didn't try to work it into the 13 last meeting.in the half an hour we had scheduled then. 14 Your remarks, I think,.and discussions have been helpful to 15 us. I certainly hope that our presentations will be useful 16 to you in your role assisting NRC in. reviewing the SCP and 17 the SCA. Again, we certainly look forward to further 18- opportunities to have discussions with you. Thank you. 19 DR. MOELLER: Will your people remain for the: rest' 20 of the morning or not? 21 MR. RINGE: Yes, some of us will. 22 DR. MOELLER: Okay, that's fine. All right, with 23 those remarks let us take a 15 minut- break. 24 (Whereupon a brief recess was taken.) 25 DR. MOELLER: The meeting will resume. The next l Heritage Reporting Corporation ! (202) 628-4888 l
74 i gg 1 item on our agenda is the discussion of the reports of three V 2 consultants to the'comr.ittee that had been asked to review 3 the study plan on water movement tests. 4 These were Doctors, Melvin Carter, Connie 5 Krauskopt, and Judith Moody, and two-of these consults are 6 with us today. We are going to begin with Doctor Moody, and 7 ask that she give us orally a report of her findings, 8 conclusions, recommendations, and so forth. Judith? 9 DR. MOODY: All right. 10 DR. MOELLER: Do you need someone to change your 11 viewgraphs? 12 DR. MOODY: No, I can do that. 13 DR. MOELLER: You can do that, thank you. 14 DR. MOODY: I can do it, I don't mind. Is this 15 thing on? 16 DR. MOELLER: Yes. 17 'DR. MOODY: All right, what I have done 18 is -- I put up here, please note this, this is consultant 19 review of this site study plan, 83122 water movement test. 20 After everything that has already been said about this site 21 study plan, this one in particular, water movement test, I 22 have to tell you that what I am presenting is an independent 23 consultant, and I have derived certain things after a great 24 deal of thinking and looking at the available literature. 25 In fact, I have in addition, three key references Heritage Reporting Corporation O (202) 628-4888
75 1 that really directly relate to.this particular site study O 2 plan and water movement test. All right, now what is the 3 purpose of this test? What it is, is to do a analytical 4 measurement through using the isotope chlorine 36 to 5 actually detect the movement from the surface to the vadose 6 zone, 'and specifically just to the repository depth. 7 'The other thing that they did admit in the site 8 study. plan, and I put up here, is that the water 9 variability, or the past water movement through those 10 unsaturated rocks should vary with respect to depth. 11 The other thing that I have to -- will keep 12 repeating several times over, that depth is important, 13 especially when you are talking not only about the
'14 particular rock itself, but also the variability that that O
\~/ 15 particular' rock may bring to the water that has originated 16 at the surface. 17 DR. MOELLER: In the variability, this is probably 18 obviously, the variability that you are referring to is the 19 rate of movement of water, that varies -- you should expect 20 that to vary with depth? 21 DR. MOODY: That is correct. 22 DR. MOELLER: Okay. 23 DR. MOODY: Also you would expect -- my 24 geochemical background, you should also expect chemical l 25 variability. Heritage Reporting Corporation O (202) 628-4888 j i _-__________a
76 1 DR. MOELLER: 'Yes. i:) 2 ir
-DR. MOODY: The reason I am emphasizing that here, 3 not only the movement that this test deals with, but also
- 4. because they are measuring an isotope, chlorine 36. That is 5 tied also to chemical composition of the water. So what we 1 6 really are talking about, Dade, is both the movement and .f 7 change in chemical composition as it moves.
8 DR. MOELLER: I am probably jumping ahead, but is 9 it a known fact that chlorides move at the same rate as 10 water moves?. 11 -DR. MOODY: Yes. That is usually an assumption 12 that is most often valid. 13 DR. MOELLER: Okay. 14 DR. MOODY: Because chlorine tends to remain as a I O-b 15 dissolved ion in the water. f I 16 DR. MOELLER: Yes, okay. 17 DR. MOODY: So it moves with the water. We will 18 talk about that a little bit later in terms of their 19 interaction with cat ions, but generally speaking, that is 20 an assumption, and it is a valid one. 21 DR. MOELLER: So if there was ferric iron, it
- 22. could precipitate out, I would presume.
23 DR. MOODY: Well ferric iron usually precipitates 24 out of water as an oxide, a hydroxide. 25 DR. MOELLER: Oh, okay. Heritage Reporting Corporation O (202) 628-4888
i 77 1 DR. MOODY: Ferric hydroxide. O 2 DR. MOELLER: Rather than chloride? 3 DR. MOODY: That's correct. 4 DR. MOELLER: Okay. 5 DR. MOODY: Although you may trap a little bit of 6 chlorine in the hydroxide. 7 MR. VOILAND: Just a question of information -- 8 DR. MOELLER: Use your mic. 9 MR. VOILAND:- Is it a correct assumption to view 10 this whole system as a steady state system? Has it been in 11 operation so long that the water distribution -- 12 DR. MOODY: My assumption as a Geologist is that 13 that is incorrect. I do not think -- now remember, I am 14 talking about geologic time, which does not mean ten years, 15 it mean more like a 1000 to 100,000, to a 1,000,000 years. 16 I do not think that you can say for that 1,000,000 years, 17 that it has been necessarily stable. 18 That is one of the things that they are going to 19 evaluate in terms of vadose zone itself, whether or not they 20 can prove or disapprove this variability. I am just saying 21 it is not a good assumption to say that it has been 22 constant. 23 MR. VOILAND: How about over an interval of 10,000 24 years or 1000 years? 25 DR. MOODY: That is a possibility, yes. I Heritage Reporting Corporation O (202) 628-4888
78 1 MR. VOILAND: Thank you. 2 DR. MOODY: In that time frame it is possible. 3 MR. VOILAND: All right. 4 DR. MOODY:' All right, this is a slide out of the 5 condensed site SCP. What I wanted to do with this is just 6 remind you in terms of what we are talking about here in 7 water movement. So what we have shown here is the fact that 8 the water does originate at the surface, and this is the 9 location of the repository site. 10 The repository itself comes across something like I 11 this. I'll show you later the slide in which is duplicated 12 or used in the hydrologic modeling in which we actually show 13 you the repository location about right there. 14 Now the thing that is important when we talk about O
\l 15 water movement, is the fact that certainly in terms of these 16 top two units, there is the potential possibility for 17 laterel movement. So water can in the upper two -- remember 18 these Tivia Canyon welded unit, and especially the Paint 19 Brush non-welded unit, because this one is more porous than 20 this one, so this is what you see here when you see lateral 21 movement.
22 That is common for a surface expression of 23 collection of water. Something that you have already heard 24 that is very important, of course, is that normally, water 25 does movo vertically downward, but in this particular area, Heritage Reporting Corpo' ration O (202) 628-4888
79 7s. 1 there are major faults. d 2 You can see three of them here. This one in 3 particular, the Ghost Dance Fault does at this particular 4 time, the way they had planned the repository does go right 5 through the repository depth -- I mean repository itself, 6 and does connect, as far as they know right now, to the 7 saturated zone. 8 So once you define -- remember for a water table 9 we are taking about the unsaturated verses the saturated 10 zone. Now the other thing that we know that is perfectly 11 normal is that as you get closer and closer to the water 12 table itself, you also increase the percentage of pore 13 space, if you will, with water. 14 Up here.it is about 50 or 60 percent water filled (D's' 15 as you move closer and closer to the water table. Down here 16 it is about 90 percent, and of course the water table itself 17 means that you are now into a 100 percent of the saturated 18 zone. 19 DR. MOELLER: Doctor Perry has a question. 20 DR. MOODY: Yes? 21 DR. PERRY: All of the drawings that I have seen, 22 I can remember seeing about -- that show the saturated zone. 23 Does not show the blockage of the various structures. 24 DR. MOODY: Yes. 25 DR. PERRY: Is the same non-uniformity of Heritage Reporting Corporation O (202) 628-4888 i l
80 l gw 1 structures expected in that saturated zone? V' 2 DR. MOODY: Yes. 3 DR. PERRY: Now I also heard that the lateral 4 movement in those areas -- 5 DR. MOODY: The lateral movement is -- 6 DR. PERRY: No , excu: e me, I meant in the 7 saturated zone. 8 DR. MOODY: Yes, right. l 9 DR. PERRY: In the saturated -- 10 DR. MOODY: Right here. 11 DR. PERRY: Yes. That that is very rapid, and 12 <ould, 8n fact, not support compliance with the regulation 13 in 10 CFR 60, if. water or the isotopes from the repository 14 reach-that point. Given that that lateral movement is very O '15 rapid there, wouldn't we expect that lateral movement might 16 .be very rapid in the upper blockage if the blocks, if they 17 are the same -- have the same basic structure? 18 DR. MOODY: That is a possible interpretation. 19 DR. PERRY: So then the feasibility of very rapid 20 vertical movement, and or lateral movement exist. 21 DR. MOODY: That is tra). You see, the vertical 22 movement track is highly tied to the faults. 23 DR. PERRY: Yes. 24 DR. MOODY: Because water will move very rapidly 25 down the Ghost Dance Fa ult. Now one of the key things that Heritage Reporting Corporation O (202) 628-4888
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81 1- in this site study plan that is not addressed, perhaps it is ( () 2 addressed in another site study plan, is that it is very 3 important if you are going to use this special methodology 4 to try and actually track water movementy to measure the l 5 total water movement all the way down the water-table. 6 Remember that the site study plan ne it is now 7 written is only to measure to the repository depth, and if 8 you really want to get an answer on-the hydrology of the 9 site, you have got to make the measurement down to the water 10 table itself, and then even measure the water in the 11 saturated zone, and can you really trace the traceability of 12 horizontal movement in the saturated zone itself. 13 DR. STEINDLER: Is this test designed to tell you 14 anything about the saturated zone? 15 DR. MOODY: No, it is not. 16 DR. STEINDLER: So the discussion about -- 17 DR. MOODY: That I will bring up all right? 18 Now, the discussior, of this site study plan has used 19 chlorine 36 traceability down to the repository horizon. 20 One of my comments, of course, that this is not adequate. 21 Maybe in the hydrology -- well can DOE comment now in the 22 hydrologic test itself, is the there a test that is planned 23 to use chlorine 36 as a traceability to the saturated zone? 24- DR. DOBSON: I don't know if I can_ fully answer 25 your question. This is Dave Dobson. You are quite right, Heritage Reporting Corporation O- (202) 628-4888 l
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'82 1 the current study plan is designed.for testing in the I
L. 2 exploratory shaft facility, and therefore is limited to the 3 depth of the facility. 4 Ted is also working on the development of the 5 technique for use with drill holes. If we decide that it is 6 feasible, then we would expand the study to include drilling 7 elsewhere on the site, basically. 8 DR. STEINDLER: If I may please -- 9 DR. DOBSON: That is right, we could also expand 10 it to include sampling below the water table -- sampling of 11 the water. 12- DR. MOELLER: Yes. 13 DR. MOELLER: Bill? 14 DR. STEINDLER: If I may please, what are the 15 concerns about using chlorine-367 16 DR. MOODY: It will come up. 17 DR. STEINDLER: Well -- 18 DR. MOODY: It will come up. 19 DR. MOELLER: Let's-for the remainder of our 20 presentation -- 21 DR. MOODY: Yes, why don't you let me -- 22 DR. MOELLER: Let Doctor Moody give her 23 presentation. 24 DR. MOODY: We can come back. I think I will 25 address it. 1 Heritage Reporting Corporation O (202) 628-4888 ] i
83 1: DR. MOELLER: Thank you.
-2 DR. MOODY: All right. Now, in these tests, I am j 3 going to address each one'of these issues, that is, sampling i
4 procedure, the analytical techniques used that'is important )
'5 to this site study plan. I think that three is just as 6 important as one and two.
l' 7 That is,-data collection, data analysis, and 8 interpretation. We haven't emphasized that enough yet, 9 though I am sure it is in many -- it is not only.what-you 10 are going to do in a site study plan,.but also:when you do-11 get-the data,.-how are you going to use the data, and'in 12 terms offreferee comment, you can get just as many 13 differences of opinion when you. talk about'the 14 interpretation of the data that you spent time in the field 15 and in the laboratory collecting. 16 Now, this is point number one, sampling 17 procedures. It is hard for me -- remember, I am an 18 independent consultant. What I have generated here is 19 something that I will stand on my own two feet and defend /. 20 but what I have done is classify procedures as -- and I have 21 come up with what I call the ideal, one called the 22 reasonable, and C, the marginal. 23 Now I am going to start with the marginal, because 24 the marginal'is the one that is now defined in the site 25 study plan, and then move to the reasonable, and then to the Heritage Reporting Corporation O (202) 628-4888
L < l 84 7-1 idea. Now conceptually remember that this came from Judith 2 Moody. 3 All right, this is marginal sampling. This is now 4 what is in the site study plan. All right, you are going to l 5 generate the samples from explosive blasting of the rock, at 6 a particular depth, and the depth cannot even be -- 7 according to site study plan, can not even be defined 8 exactly, it creates rubble. l 9 The rubble is going to be placed in a barreled ! 10 container. The rubble is then moved through the barrel > 11 container to the surface. At the surface, the rubble 12 samples are going to be collected. There is possible 13 contamination of these rubble samples from two specific 14 places. 15 One is the water itself, though the supposed tests 16 for that potential contamination is they are adding bromine 17 to the water -- the J13 water that is going to be used in 18 the further testing at depth, and they are going to measure 19 the samples then to see whether or not there was any 20 contamination from the water itself. 21 Then there is chloride in the explosives, so the 22 chloride content of the explosive is going to be determined, 23 or at least measured in a couple of the explosives to see 24 whether or not there could be any contamination in the 25 rubble samples from the explosive removal of the rock. Heritage Reporting Corporation O (202) 628-4888 3
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=1 So these two additional analyses that have to be done, have C:). !
2 to be done in order for you to make an assessment of l 3 . chlorine 36. 4 DR. STEINDLER: I'm sorry, I don't understand that 5 last point you have there. The chloride content of the 6 explosives is going to measured by adding bromide? 7' DR. MOODY: No - pardon? Go ahead. 8 DR. STEINDLER: How do you see in the study plan 9 the intent to measure the chloride content of the 10 explosives? l 11 DR. MOODY: The intent is to know what the 12 chlorine content is of the explosive, and if.you get a total 13 chlorine content in the rubble-sample that you analyzed, and 14 it is higher than the natural chloride content of the rock, O 15 it will tell you then that the sample that you analyzed for 16 Chlorine'36 has a higher than total chloride content that it 17 should have. How you are going to exactly correct your 18 sample analysis is the key point that you have raised, 19 Marty. ' 20 DR. STEINDLER: Yes. Were you able to discern any 21 reasonable way in which it will be done or can't be done. 22 DR. MOODY: Let me go through my other sampling 23 procedures, okay? 24 DR. STEINDLER: All right. 25 DR. MOODY: This is what is proposed in the site j Heritage Reporting Corporation O (202) 628-4888
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86 1 study plan. One_of my major contentions,is, the
.O 2 contamination that you are going to do'by using this 3' particular site. study plan may - you may never be able to 4 deal with the contamination.
5 This one is out of the site study plan, and one of 6 my criticisms _I have refusing rubble also, is_geologica11y' 7; speaking, you always like to when you are doing an 8 analysis -- Judith Moody has done analyses on deep sea core 9 from the Pacific, and you want to know the depth at which 10 the sample was collected. 11 The problem with the explosion is, you can see 12 here that we got more or less relatively exactly depth for-13 these different formations here. When you have a rubble 14 sample --these are over here, all of the different points 15 which they have defined that they would like to get at least-16 one rubble sample from. 17 The way that I. view this proposal at this point 18 and time, not only can you have potential contamination from 19 the water and the explosive material, but you also may have 20 contamination from the upper unit that has already been 21 explosively removed from the shaft. 22 You may have rubble falling down here in the next 23 point where you want to measure from above. So there is a 24 potential also of contamination in the explosive activities 25 from the upper units into the lower units. r ' Heritage Reporting Corporation 1 (202) 628-4888
87 Maybe there are protection procedures you can use, a1 2 but I am just saying it is'also a potential problem from the 3 explosive activity that goes on all the way down to the' 4 ~ depth, and the depth here is the repository depth. 5 DR. MOELLER: Judith, I don't know this much about 6 it, but could you -- or maybe they are planning to drill so 7 many feet than have an explosion, or put.in an explosive 8 device to break off some samples, and then could you clean 9 it up prior to drilling on deeper, so that you would avoid 10 this problem?
-11 DR. MOODY: Well see, if you could clean up dry, 12 but a lot of the procedures that they have specified so far, 13 all use water.
14 DR. STEINDLER: Oh, okay,.sure. l /'T
\/ 15 DR. MOODY: And water is a potential source of 16 contamination.
17 DR. STEINDLER: Sure. Okay, thank you. 18 DR. MOODY: All right. I have como up -- here is 19 my next suggestion, and this is what I call reasonable 20 sampling. The difference between what we talked about 21 before and what I stated here, is that if you are going to 22 do ESF shaft blasting, is it possible -- and I know it is 23 possible, it is just whether or not the time could be taken 24 to it, is to dry air drill a horizontal core into the ESF 25 wall. ] l Heritage Reporting Corporation (202) 628-4888 __-_____-_a
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- 1 In other words, rather than taking the material 2 that is collapsed over, say, ten or twenty feet, measure the 3 depth as best as you can, and then at a particular depth, 4 say do a penetration piece of core, and you don't need to 5 make that much.
6 You don't need more than -- I would say for a 7 particular unit, you don't need -- let's say, more than a 8 foot of core inward, and the reason that I am suggesting 9 that this may be a possibility is because potentially, 10 getting a foot of horizontal core in the shaft wall, you may 11 be able to protect yourself from explosive contamination and 12 the water contamination. 13 What you could do in terms of sample collection, 14 that is better than anything that has been described in the
'- 15 SSP. So let me move to what I would consider to be the 16 ideal, and I am not necessarily suggesting that this -- I am 17 suggesting that it could be done, but again, we're maybe 18 also getting a little bit into cost.
19 This is my definition of ideal sampling. The 20 reason I am saying it is idea, is because could we do a dry 21 air drill separate from the ASF? The reason why I am saying 22 separate from the ASF is I think you already know, and that 23 is because to lessen the probability of contamination from 24 either the explosive or the water. 25 So my other point here is that the exact depth can r"g Heritage Reporting Corporation (_) (202) 628-4888 l
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7s 1 be measured by an independent core. Now you don't need a t_) 2 large diaraeter core. I am not saying you have to i
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3 generate -- you don't need anything more than a quarter or 4 half-inch core. What I am suggesting is doing this 5 independent -- remember I am saying separate from the ASF. 6 Maybe you want to make it a close proximity, that 7 is an engineering consideration in terms of the rock itself, 8 but the only reason that I am suggesting it is because the 9 contamination that may come both from the water and 10 explosive. 11 This fourth point in terms of sample collection, I 12 don't care whether you used the idea or at the marginal, or 13 my other one in terms of reasonable. You cannot 14 geochemically speaking, if you are going to measure an O 15 isotope, chlorine 36 that is present to the 10 to the minus 16 15th grams, in other words, such a small amount. It is not 17 even small when you think about a 10 to the minus 15 grams. 18 I have talked to people -- a key person who is the 19 expert on chlorine 36 analysis in this country, and he is 20 the one that really hit rubble. Even if you have a rubble 21 sample, that sample at the depth at which you collected, 22 should be placed in a plastic bag, sealed, and then placed 23 in a sealed container with the depth labeled as best you 24 can. 25 Certainly the closer you can get to the real depth q Heritage Reporting Corporation (_/ (202) 628-4888
l I 90 1 that the sample came from, the better off you will be in 2 terms of interpretation of the data that you collect. This 3 is my conclusion from my reading of the site study plan as 4 it is presently written, and that is that its procedure is l 5 the one that I ranked marginal. 6 As you know, I gave you two other possibilities, 7 and maybe somebody else can even think of a third. You know 8 this from what I already said, that the reason I find it l 9 difficult in terms of the interpretation of the chlorine 10 36 -- and remember sooething that you -- well, I'll cover 11 that in a minute. Two sources for contamination and even a 12 third one thct is rubble from overhead, 13 In other words, the Topopah Springs contaminating 14 one of the lower volcanic units. The most probable is O 15 something that maybe I and the other reviewers would not 16 agree on, but I would say that the way the procedure -- the 17 present sampling procedure is, most probable is very valid 18 interpretation. 19 Even though -- see part of the reason I can see 20 through the review procedure has gone through, that the 21 decision to use the bromide into the ground water itself, 22 the J13 well water, and also the discussion of measurement 23 of the chlorine content of the explosive dynamite, that that 24 was a possibility of dealing with this contamination. 25 Whether or not you can actually do that is what I Heritage Reporting Corporation (202) 628-4888
e ! l 91 j_s 1 say in terms of interpretation. All right, that 11 b 2 sampling. So as you can see, I found some considerable 3 problems of sampling. So the next thing that we need to do 4 is to look at the analytical procedures. 5 In other words, once you have samples that have 6 been collected, and hopefully stored properly, and then you 7 have to take them to a laboratory to be analyzed. I will 8 show you table three. It states that the analytical l 9 decision, the only one that has been actually defined as of 10 February 1989, is the decision for total chloride. 11 The reason P.his is important is because the mass 12 accelerator, this new special instrument now, which there i 13 are only two or three in the' United States, you are going to 14 measure chlorine 36 -- the ratio of chlorine 36 to chlorine l' i k j 15 35. 16 Total chloride then is what you measure with this I 17 analytical technique. You need that measurement because all 18 you get out of the accelerator is the ratio of 36 to 35, 19 which is the major chlorine content. So you need the total 20 chloride to even be able to calculate back as to what 21 chlorine 36 is by itself. 22 Now this is something that was also put in the 23 site study plan in order to get the chlorine that was in the 24 water, and now is only on the surface. They say that you 25 need a very short -- you must use a very short leach time 1 r's Heritage Reporting Corporation (-) (202) 628-4888 l l
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i ( 1 92 I 1 from what might have been a surface water on the rock _7 s d 2 itself, in order not to actually get to the rock chlorine, 3 and what I just basically stated here is that you are going 4 to have to prove that that's true. It is stated as another 5 problem. 6 Of course, something that needs to be done in 7 terms of any snalytical technique, is I think for a certain 8 number of your rock samples from the different horizons, you 9 are going to need to do a total chemical analysis to that 10 particular rock, and of course because of this problem up 11- here, that you are getting the chlorine off the rock,.you 12 need to do chlorine 36 in the rock itself as well. 13 Just to, again, to assess whether or not you had-I' 14 done partial leaching of the rock, and just remove the 15 surface chloride. This you could do -- one of the ways that 16 you could actually look at this, is just do an SCM of some 17 of the powder that you had to make in order to do the 18 analysis, and see if there is any etching of the powder 19 themselves -- scanning electron microscope. l 20 There is a way that you can determine this, but it 21 is going to need some careful laboratory experiments. Now l 22 what was in the actual SCP, I'll just show you these and 23 point out some of the problems. This is table three out of 24 the SCP. l 25 When I told you before that there has only been l Heritage Reporting Corporation p)g (, (202) 628-4888
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- one, you;know, analytical. technique that has been defined,
- O '2 you.can see all of these others you got over here to be 3 determined, or maybe there might be -- if they are in the 4 process'of being prepared, but at this point and time from 5- .the site study plan, there is not an adequate definition, I 6 do not think, of the analytical techniques.
7 All we have is that'during the process of 8 preparation -- that is all we can say. Now this is'another 9 one that tells you -- that defines for you the equipment 10 materials and services needed for this particular test. 11 This is the one that identifies for you the water tracer,
'12 sodium bromine.
13 It is put into the J13 water, which is going to be 14 used in'some of the deeper extraction of the rock, of the 15- explosion for the exploratory shaft itself. Again,.you can 16 see that a lot-of'this -- the procurement itself has not 17 been defined in the course.-- I do not agree with this, of 18: course, because I think.the rock should be identified or at 19 least collected at the depth at which it is being taken out. 20 This is a rather interesting selection as well. 21 There is a tremendous amount in the analytical techniques 22 that at this point and time are not defined. Of course 23 another one -- a strong geochemist would say whether or not 24 the analysis -- analytical techniqyes. 25 It is not only assessing that there defined valid, Heritage Reporting Corporation
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2 is going to do the analysis, that is also, in reality, very 3 important to the kind of numbers that you are going to i 4 generate.- The numbers are important in terms of the 5 chlorine 36, if you are going to use this as it has been. 6 defined to be used. 7 Now in the site study plan, itself, all of these 8 isaues that I have -- the data interference problems, have 9 been addressed some in greater detail than in others. In 10 terms of looking at the data interpretation, in other words, 11 the samples that have been collected, the analytical results 12 have been done, what is your interpretation of the data that ; 13 you do have. We have already been through sample 14 contamination. 1 .' L 15 This is one of the interesting things that l 16 chloride can do faster than some of the cat ions, but that 17 was just a statement that was made -- you might have some 18 interesting things to say here in terms of interpretation. 19 We have talked about this one already, that the 20 past water movement in the unsaturated zone can be both 21 vertical and horizontal. That is going to be something that 22 in terms of data interpretation is going to be very 23 critical, and of course given even what we have known about 24 the Yucca Mountain site for last 10,000 years, this is a 25 very critical one. 3 Heritage Reporting Corporation
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95 1 In other words, we already know this, but it has O 2 to be studied in more detail, that there has in the last 3 10,000 years in the Yucca Mountain area been specific times 4 of high rainfall. This is in terms of interpretation of 5 chlorine 36 as a function of depth in the particular 6 different volcanic rock units. 7' This is also a very important point. . What we are 8 talking about here is, once you have the data 9 interpretation, what'can it mean, and there are some key 10 critical points geologically speaking in terms of the data 11 itself. , 12 Now tied in with the data interpretation as we all 13 know, is the actual hydrologic modeling itself, and this is j i 14 something that the USGS will be heavily involved in. These 15 are some of the major points with respect to interpretation 16 and need to be tied into any hydrologic modeling of the 17 site. 18 Now the reason that these measurements are being 19 made, is to generate data that can then be-tested in 20 terms of a Yucca Mountain hydrologic system. I put down 21 here things that I consider-to be important. The site study 22 plan mentions them all, but that is about.it. 23 In other words, non-uniformed hydrologic flow most 2? probable. We already talked about vertical and lateral flow 1 25 possible faults and fractures-will influence the flow of Heritage Reporting Corporation O (202) 628-4888 1
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96 1 water downward and laterally. This is another problem that j O~ 2 is specific to the Yucca Mountain site. i 3 That is there has been chlorine 36 generated.from ) 4 the nuclear explosions. The influence of this particular 5 human activity needs to be addressed. Now what I have done I 6 just quickly to show-you, as you remember our nice USGS l 7 geologists last June did present information that is S important with respect to hydrologic modeling. t l 9 You can see in this one that we do have the 10 repository in placed in the key unit that is going to be in-11 placed in. Topopah Springs Unit, and what Hoxie did. You 12 can see our key. I just used this, so you can see my -- I 13 put this on the original thing that I had scribbled on here. 14 You can see I put here the major faults, and also the major 15 rock units. 16 What our USGS geologists did is show you all of 17 the potential movements of the water. He didn't -- I had 18 shown in that other previous slide, the fact that - yes, we 19 have done it here, lateral movement through the Paint Brush 20 top here. 21 And then of course, vertical movement down the 22 fault, and then actual movement -- all water to the water 23 table itself, and of course we had in the other side, the 24 water was moving in this direction. So this is just to 25 remind you in terms of the modeling, these are -- it is a n Heritage Reporting Corporation (_) (202) 628-4888
i I 97 1 f_s
.1 complex set of geologic activities. j
') \
2 Again, remembering what we were talking about 1 i 3 previously, is the fact that irt terms of the water in the q 4' unsaturated porous media, we have pieces of the rock, and we j 5 also have water in between these pieces, or.they could be an { 6 individual mineral, but it is probably a rock which is an . 7 aggregate of minerals.-
- 8. So we have water in the pore space. :There is 9 potential storage, and a key point here, of course, is the 10 fact that the reason that the water moves vertically is 11 because-of gravity. What you see here is just a possible 12 trajectory for water in low saturation.
13' So the other key thing is the area -- the pore 14 space in the rock itself, besides water, also has air. So 15 when we talk about the increasing saturation as we go down f 16 to the completely saturated, what we are talking about there 17 -- remember we are going from 60 to 90 to 100 percent. Well l 18 what you are talking about is that as you increasingly 19 saturate the rock in its pore space, you decrease the amount 20 of air. l 21 This is a general storage of water, and talking 22 about storage capillary forces which involve the air as l 23 well. This is just one to remind you of potential movement 24 of water down fractures. Just remember that both can occur. 25 Now, what he has done in diagraming here, is that p Heritage Reporting Corporation j (202) 628-4888 ( l
98 s 1 air can maybe moved across the fracture, but there is in
'#~
'2' terms of water flow, possible. flow upwards and downward on 3 the fracture plane.itself. Also the question is that in.
4 these fracture planes, if they are old fracture planes, 5' there is a possibility that they can be' welded. 6 That mean that over a period of time, once the 7 rock has fractured, that you can have recrystallization 8 sometimes into secondary mineral products. Zeolites for-9 example. They are going to do important work on zeolite 10 minerals in the unsaturated zone. 11 That is a recrystallized mineral in the presence 12 of water to produce a water bearing mineral. So the 13 fracture planes themselves can be. welded or unwelded. 14 ~ Welded means that simply there has been precipitation of.the 15 new mineral in that particular fracture. So modeling of 16 water movement in the site itself is all tied to a large 17 number of different measuring parameters of which chlorine 18 36 is one of the ones that will be done in order to 19 potentially trace water movement from the unsaturated to the 20 saturated rock. 21 I have put this on -- it brings up a question that 22 was discussed early that this work is heavily tied into the 23 USGS hydrogeochemical work, and needs integration. Whoever 24 is going to do the work itself on chlorine 36 traceability. ' 25 it has to be tied into all of the other hydrologic work that g Heritage Reporting Corporation (202) 628-4888
99 1- is being'done on the site'itself. O 2 My interpretation of the site study plan as of 3 February 1989, is that it is an incomplete document in all 4 of the things that have been defined for a site study plan. 5 I have presented, I think, reasons -- the only thing I 6 haven't addressed is QA, but we are in the process -- we 7 have had a little discussion previously as to where we are 8 with respect to QA and site study plans. 9 As you can see from comments I made, you know, I 10 do think that more thinking has to be done on sampling. I-11 also had -- surprising, but in the time and effort that I 12 put into reviewing this document, there are three major 13 publications that were not referenced, which means my 14 interpretation is as if they weren't read and used. k 15 These two, Elmer and Phillips, this is one that. 16 was published in Science in 1987. This one which is 17 published in November of 1988, but you can see that chlorine 18 36 and Tritium from nuclear weapons fallout is tracerous for 19 long term liquid and vapor movement in the desert. 20 This paper very closely ties in to what they are 21 interpreting in the site study plan, in terms of I 22 interpretation of data once that you got the chlorine 36. 23 Now the very top document, I spent a tremendous amount of 24 tracing time on this. l 25 It is a document -- it was Paul Drez who is the l l 1
- Heritage Reporting Corporation (202) 628-4888
3 y 100 g
' key author of this document.
1 It says " Summary Report of
'o . 2 Potential Methods for Salt Repository' Project Geochemical-3' ' Sampling,' Sample Preservation, and'Onsite Analysis. This l
l 4 document, you.can see it'is a summary. report. l l 5 Even though it was written.for the salt project, 6 most of the information in this summary. report is.up to j 7 date, and it applies to all rock types. The thing that 8 surprised me -- I only got a copy of this report on Monday 9 from Albuquerque, New Mexico, and I was flabbergasted, but 10 everything that I had issued, that I have raised in terms of, 11 sampling procedure, is very well documented in this report. 12 I do not want the rubble sample collected. .Even 13 if you collect.the rubble sample, it should be collected at' 14' depth'and put in to container systems that I have 15 identified. In other words, there are many many important' 16 points that the site study plan may mention in one sentence, 17 but needs to be addressed in a bit more detail in order to 18 be collecting a adequate geochemical sample, 19 To make a long story short, this final' report was 20 an intera report. You can obtain a copy of this report 21 either by calling Paul Drez. You can get it from his 22 specifically, or it is part of the Battelle files, our 23 archival files, so that you can get a copy of this document 24 from Battelle and Warel institute as well. 25 So in other words, this is not a private document. seritage Reporting Corporation
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I l l 101 1 It' is a public document that can be made available to 'l O 2 anybody who would'like a copy of it. I think it is a very 3 important document, not only for these samples that we are 1 4 collecting for chlorine 36 analysis, but samples for other 5 particular rock samples that you want to do a chemical 6 analysis on or water samples as well. Okay, that is all 7 Judith Moody has to say. 8 DR. MOELLER: Thank you. Let me ask one quick 9 question on the,three references. How did you search those 10 out? Was that a computer surge? 11 DR. MOODY: No it was not. I searched these out. 12 This one I knew something about because I use to work at 13 Battelle. 14 DR. MOELLER: Yes. 15 DR. MOODY: So this one I got from my own work 16 that I had been responsible for. Now these two I called one 17 of the isotopic geochemist in the country, Gaunter Fower. 18 DR. MOELLER: Yes. 19 DR. MOODY: He is not Editor of Geochemical 20 Counsel Chemica Acta, and Gunter is the one that told me. 21 He is on the faculty of Ohio State University, that I should 22 call Phillips. Phillips sent me copies of his reprints. 23 Phillips is the one according to the isotopic community, he 24 is faculty person at the University. He is one of the 25 expert chlorine 36. He led me to a couple more references, Heritage Reporting Corporation ()
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102 1 but these'are certainly.very key to the DOE program site
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study plan.: 3 DR. MOELLER: Thank you. Well let us have 4 questions and comments. Doctor Steindler? 5 DR. STEINDLER: Let me make a comment about the 6 Elmer documcpt. I th3nk the Science article is one of a 7 number of accelerated mass spectrometry -- 8 DR. MOODY: Yes it is. 9 DR. STEINDLER: Documents, anc; I am sure since Los 10 Alamos, I assume prepared this thing. They have a machine - 11 - they are' fairly well aware of that one,'and the article by 12 Phillips. 'Let me ask a couple of questions. I gather that - 13 - 14 DR. MOODY: Can you provide those to DOE? 15 DR. STEINDLER: Okay. 16 DR. MOODY: If there are others -- 17 DR. STEINDLER: I assume they have them -- I mean 18 the article in Sciences is buried in almost everybody's file 19 I would think. 20 DR. MOODY: Why wasn't it referenced? 21 DR. STEINDLER: I am not sure since I didn't write 22 this thing, but I would guess that this is not an exhausted 23 bibliography. ( 24 DR. MOODY: Well let me turn -- 25 DR. STEINDLER: I mean it is obviously isn't -- Heritage Reporting Corporation O (202) 628-4888
l 103 1 DR. MOODY: Let me turn it around another way. If 7. g 2 you don't reference something, my interpretation is that 3 it's not that.important to your document that you are , 4 writing. 1 5 DR.'STEINDLER: Okay. My purpose here is not to j 6 try and defend whoever wrote this thing. My purpose is to 7 find out something about it. You indicated that the 8 sampling, apparently, is inadequate, and you gave two 9 specifics. One is contamination from the chloride -- from 10 explosives, and the other one, I gather, is the 11 contamination from chloride in what ever water is used in 12 drilling -- 13 DR. MOODY: Yes, that is correct. 14 DR. STEINDLER: Both of those are mentioned in the 15 stitdy plan. 16 -DR. MOODY: That is correct. 17 DR. STEINDLER: Is it your conclusion that the 18 treatment that the folks who wrote this study plan give to 19 these two issues is not satisfactory, or won't work? Is 20 that why you have sampling as an inadequacy? 21 What I think is -- and remember, this comes from the hard 22 experience of Oudith Moody, from or my own analytical work 23 that I have done geochemically. What I do think, is that 24 they have tried to address the contamination, but do I think 25 it will adequately help them when it comes to trying to Heritage Reporting Corporation i _/ (202) 628-4888 ! i
L 104 1 calculate chlorine 36? My answer is that I do not think 2 that they are going.to be able to really be able to address 3 the. numbers that they do get. 4 They'are going to find that their numbers have a 5 higher probability of being anomalous. I mean -- 6 DR. STEINDLER: Are you saying that the method, 7 therefore, won't work? 8 DR. MOODY: I am not saying that the method won't 9 work, what I am saying is you are going to be able to get a 10 series of numbers that then you can try to recalculate the 11 chlorine 36, but you are going to run into problems that 12 will make that interpretation very difficult. 13 DR. STEINDLER: Okay. You also indicated that the 14 accelerator mass spectrometry technique gives you a ratio of 15 chlorine 36 to chlorine 35. 16 DR. MOODY: Yes. 17 DR. STEINDLER: These folks -- 18 DR. MOODY: I may be wrong on that. I think it is 19 the total chlorine. 20 DR. STEINDLER: Yes, they indicate very clearly 21 that it is total chloride -- 22 DR. MOODY: That's right, it is. 23 DR. STEINDLER: I don't whether you -- 24 DR. MOODY: No, it is a -- J 1 25 DR. STEINDLER: No something aDout it. l Eeritage Reporting Corporation
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-1 DR. MOODY: It is misnoted.
i [) 2- DR. STEINDLER: Okay, so that is not an issue. 3 DR. MOODY: It is total chloride. 4 DR. STEINDLER: Okay. You put up there a table of 5 the specific procedures, and were concerned -- 6 DR. MOODY: Those are - yes, go ahead. 7 DR. STEINDLER: That some of them indicated that 8 the non-standard procedures availability date is to be 9 determined. Did you see in any of those an attempt to do a 10 procedure that is probably isn't going to work, or -- 11 DR. MOODY: There is no procedure -- 12 DR. STEINDLER: That can't be done? 13 DR. MOODY: See this is it. The problem is that 14 there -- all this table does is tell you where they are 15 right now. 16 DR. STEINDLER: Right. 17 DR. MOODY: There is nothing written on - you 18 know, there is nothing written here. 19 DR. STEINDLER: In this mornings discussion we -- 20 DR. MOODY: In the site study plan there is 21 nothing written. 22 DR. STEINDLER: Yes, In this mornings discussion 23 we specifically -- at least one of us specifically asked 24 whether or not a site study plan is a protocol, and the 25 answer was no, it is not a protocol. It is an outline of Heritage Reporting Corporation O (202) 628-4888
i 106. i
,a4 l 'the scope of the' study and some indication of the basis, and L) 2 that. specific technical ~ procedures are the third phase of u 3 this exercise that starts out with a site _ characterization 4 plan, and goes to a study plan,. and then finally tofa o i
~5 procedure.
-1 6' The review that we are.looking at here is an q 7 attempt to look at the study plan to see whether -- if not
- 8. fatal flaws, then certainly some questionable issues. There.
9 'is nothing, I gather, in'this list of technical procedures 10 which leads you to conclude that they are going to have 11 major problems in doing any of the things that they 12~ indicate, whether they'are standard or-non-standard. Is 13 that-correct,.or not correct?- 14 DR. MOODY: I think again we come to how you 15 choose to interpret. If you want Judith Moody to say that-16 this site study plan-is acceptable to me with this kind of 17- specification, I simply would say that it is incomplete. 18 I do not accept that. I think the site study plan 19 -- I am not talking about a lot of' detail, but I do think 20 you can see that I have been highly critical of this first 21 one, sampling, and field sampling. These two should be 22 combined. I have identified major problems with this whole 23 thing right here. Now these down here are -- they are 24 saying that they are all non-standard or specialized 25 standards, but that is a non-statement. j l Heritage Reporting Corporation l O (202) 628-4888 1
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107. i
,_ 1 .What you are saying_.is -- let us put it another ;
2; way'. If.this testing -- you can say that this testing is 3 .. not going to begin until-the exploratory shaft possibly a 4 begins to_-- drilling for the exploratory shaft begins, so 5 if-we are gett'ing back to this statement that DOE did make
-6 this. morning, that there is going _to be a certain level of 7- information available in that site study plan before they 8- actually begin drilling for the exploratory shaft, these may 9 be better identified at that point in time. . They are not 10- identified now.
11 DR. STEINDLER: Okay. 12 DR. MOELLER: Excuse me, we might ask Bob Browning 13 this afternoon, you know, the NRC staff. I can see that you D - 00 That a right', you'can.- 16- DR. MOELLER: Go ahead Marty.
-17 DR. STEINDLER: My final question. You indicated 18 that you were concerned about the interpretation of the data 19 in relation to other hydrologic models. Did you get --
20 DR. MOODY: Interpretation hydrologic model. Go 21 ahead. You know there isn't just one hydrologic model yet. 22 I mean -- 23 DR. STEINDLER: Yes. 24 DR. MOODY: Okay, go ahead. 25 DR. STEINDLER: Did you get the impression from ; I Heritage Reporting Corporation O' (202) 628-4888
108 s ja- ' -1 reading-the. study plan that the department is aiming to have 2- this as the.only source of information.to. feed into the 3 models? 4 DR. MOODY:- No, that is absolutely not true. 5 DR. STEINDLER: Okay, so there is no' racketing 6 information.- In-here it says that they are not going to use 7 this together with whatever else they need to feed into 8 models. 9 DR. MOODY: That is correct. 10 DR.'STEINDLER: Yes. 11 DR. MOODY: I mean it is one piece of information 12 that they can put into the total hydrology model for the 13 site. 14 DR. STEINDLER: Okay. I am trying to go back to 15 your list of deficiencies, one of'which includes hydrologic 16 .modeling. I' guess I don't really have a good picture of 17 what it is that you think about hydrologic modeling that you 18 think is deficient in this plan. l 19 DR. MOODY: The' problem is that you have general' 20 modeling techniques, and I am not an expert in hydrologic 21 modeling, but I do know that there is several different 22 models available that can be used in terms of modeling the 23 Yucca Mountain site, and so from a hydrologist point of 24 view, the question is what hydrologic -- or are you going to 25 take an existing model and then redefine it so that it Heritage Reporting Corporation O (202) 628-4888
, 109 o -1' 1 applies to the Yucca Mountain Site,itself.
2 'DR. STEINDLER: I am having some problem trying to 3 figure out why this focuses in on the water movement test. 4 DR. MOODY: .Because that is'part -- the reason 5 that they are doing this-at all, Marty, is because how the 6 .w ater moves, or the potential of previous movement down 7 to -- from the unsaturated saturated zone, that is part or 8 the total hydrology of the site. ! 9 Certainly that is one of the reason why I did on 10 one of my slides say that the chlorine 36 should be done 11 from not only the surface to the repository horizon,.but 12 should also be done right down to the saturated. zone, and 13 then also possibly used as a tracer in the saturated zone 14 itself. O 15 So this site etudy plan, let's put it another way, 16 only deals with in terms of modeling Yucca Mountain. It' 17 only deals with one part, and that is, is the part above the, l l 18 repository horizon to the horizon itself. In terms of total 19 hydrologic modeling, you need information for the total 20 site. 21 DR. STEINDLER: Is there anything in the study 22 plan that indicates that they are not going to do that? 23 DR. MOODY: There is nothing mentioned about depth L 24 below the -- because remember, this is tied into the l 25 exploratory shaft, and the -- Heritage Reporting Corporation O- (202) 628-4888
110 1
- .1 DR. STEINDLER:. Right. l 1([I 1 2 DR.' MOODY:- Issue right --
3 DR. STEINDLER: In the unsaturated zone.
'4 DR. MOODY: Is in the unsaturat'ed zone.
5 .DR. STEINDLER: So the focus at'the moment is just [ -6 water testing.-- that is, water movement testing in the 1 7 unsaturated zone. 8 DR. MOODY: That is correct. That is all this 9' site study plan' addresses.
- 10 DR. MOELLER: Okay, other questions or comments?
11 Gene, did you have something? 12 DR. VOILAND: I think that has been a very good 13 definition of the potential pitfalls. 'In the' study plan
-14 there is. comment that several recent studies suggest that
.O 15 chlorine 36 may be'-a suitable indicator, et cetera, and 16 Andrews and'others have used the 36 -- chlorine ratio for 17 ground water flow pass studies.
18 I would presume that an analysis of those 19 particular papers, and so on, would indicate how those 20 people have dealt with these very issues. It is always to 21 go back to somebody who has actually done it and see what 22 has been done. Can you make any comment about how they -- 23 for example, I can see how you might be able to get some 24 pretty good samples. 25 In the plan it says that they are going to put a Heritage Reporting Corporation (202) 628-4888 ! l i
J l,' , 111 IL l geologist, I guess hanging on a very long rope, down into
'a. 2' the hole to select 1the pieces, so it would seem to me that 3 he could put those in bags, and I can see perhaps taking 4 those particular samples when_you get them out, physically.
5 machining them on a lathe or something of that sort, ,so that 6 you'wouldn't have water' contamination, how you prepare that ; 7 leaching water to'be free of' chloride, it sounds like'it is 8 challenging, but I suppose you just precipitate the heck out 9 of it with silver nitrate or something like that. I am not 10 sure how they'do that. 11 DR. MOODY: Yes.
-12 DR. VOILAND: .I think some of those -- you know 13 the potential pitfalls can be met, and I would like to know 14 other people did that.
15 DR. MOODY: Well see, when I went from near 16 marginal to reasonable, to ideal, what I was doing in that i 17 procedure was just more clearly stating the possibility of 18 obtaining an uncontaminated sample. Certainly if'you read 19 those two papers by Phillips, especially the second one in 20 water resources, they spend several paragraphs explaining 21' what they did and why they did it. In terms of the 22 referenced literature, I mean to do a dry drilling rather f 23 than a wet drilling, and many other critical things. 24 Sample collection bagging, that has always been a 25 geochemical problem. It is not necessarily what you are Heritage Reporting Corporation (202) 628-4888
112 i i c 1 . analyzing, why_you are analyzing. The first thing is V 2 whether or not you have collected the sample under a 3 reasonable procedure before you even do the analysis. 4 It.has been a consistent long term problem. 1 5 DR. VOILAND: I agree with that. In my checkered 6 career, I managed an analytical lab for a while, and the ; 7 sampling, you can do the best analysis in the world on a 8 rotten sample. I mean, you don't get anything out of it, so 9 I think the definition of these pitfalls is extremely 10 important. Then the question is can you work around them. 11 I mean, how do you defeat them, is what it amounts to. 12 DR. MOODY: That is correct. 13 DR. MOELLER: Bill -- 14 MR. HINZE: I think Judith has done an excellent 15 job. It is apparent that one of her problems in doing this, l 16 is the same problem that I and perhaps the rest of you have- ! 17 had, and that is, there is some information that is not 18' available to us, and one of the questions is as Marty stated 19 is, what else is going on that is really interactive with 20 this. 21 As we heard Steve this morning, talked about the l 22 interactive nature of the entire process. I think that if 23 we are going to evaluate these plans, or if anyone is going 24 to evaluate them, that they have to see it in the proper 25 context of the other plans, and the whole scope of the r^g Heritage Reporting Corporation (_/ (202) 628-4888
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'113 1 project. .o 2 I do have some specific items that I would<like to 3 bring up. In terms of the sampling, there are two aspects 4' of-the. sampling. -The first is the integrity of' the ~ sample, 5 and the second is a representative nature of the sample. 'I 6 believe that Judith has --
7 DR.' MOODY: Extremely valid. 8 DR. MOELLER: I think Judith has addressed the 9 problem very well of the integrity of the samples. . From a
- 10. lack of knowledge, I wonder if one should even be concerned:
11 about the chlorine 36 that might be associated with the 12 plastic bags, but that is presumably something -- there 13 should be an expert that can answer the question on -- real' 14 rapidly, and I happen to know this from my.own background in
.O 15 collecting carbon samples and wrapping them up in newspaper 16' to do carbon 14 analysis, that is really not an accepted-17 procedure.
18 The other problem.is whether we -- what is going 19 to be the interpretation,: and what is going to be the impact l 20 of the interpretations from these measurements, and that 21 gets at the point of the representative nature. I think 22 that Judith has well addressed the point of the really , 23 critical area, that is the area from the repository to the [ 24 water table, which is not going to be addressed here. 25 The other question that I have is really one of my Heritage Reporting Corporation i O (202) 628-4888 i l
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- . 1 concerns in the last couple meetings of the exploration V 2 shaft. I think one really needs to know what were the 3 geological criteria that were used to select the site of.the 4 exploratory shaft, and what that means in terms of the 5 measurements that we are going to -- what the 6 interpretations are going to be made.
7 There are two factors here, and that is one of the 8 fracture flow and the matrix flow in this interpretation. 9 There is also the problem of the lateral flow, which is 10 going to be an extremely critical item. It isn't 11 immediately apparent to me that we are geing to know how to i 12 interpret, for example, where we have perch water tables. i 13 Perched or heavy concentrations of water in the i 14 vados zone can arise by two mechanisms -- at least two ; 15 mechanisms that come to mind. One of those is by perching, 16 and another is simply by slugs of water -- by recharge, that 17 really move through vados zone as what I would call a slug, i 18 is a heavy concentration. 19 In order to really place much significance upon 20 these measurements, I think that one has to really learn the ! l 21 geology of the exploration site. It may be to much detail, 22 but I don't think so, and that is that one not only has to 23 know the hydrochemical properties associated with that area, 24 but also the hydrologic properties. 25 For example, just the porosity permeability i Heritage Reporting Corporation O4 (202) 628-4888
115 a - 1 factors. associated with that facility, and whether those are O 2' fracture-or whether those are matrix. I am reminded of a 1 3 conversation that I had not-to long ago'about petroleum { l
'4 exploration in Nevada, and the production that is now being
'5 obtained in hydrodynamic reservoirs within welded tuffs in.
i 6 Railroad Valley. l 7 I think'there may be just to the northeast of 8 Vinteas, I think there are some things that we can learn 9 from the kind of reservoir engineering that petroleum
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10 companies get into that might help us in interpreting the 11 results of this. 12 In terms of so much of the sampling,-but I guess I. 13 would like to get to the question that I wanted to ask of 14 Doctor Dobson who suggested that we are really in an O' ' 15 experimental stage, if I understand correctly, an 16 experimental stage in terms of using dry core drill samples. 17 Drill drilling core samples for a chlorine 36. Is that in 18 an experimental stage, and if so, what is the problem? 19 DR. DOBSON: Well-I am not quite sure I 20 understand. We are doing what is described as prototype 21 work on dry drilling at that site, and basically what it 22 amounts to is an effort to combine conventional coring 23 techniques with conventional dry drilling pneumatic 24 techniques, and we don't really anticipate at this time any 25 major problems with it, but it is a kind of technology that p/ Heritage Reporting Corporation (202) 628-4888 i
, 116 1 -is not' standard, so we are1 working on it.
-2 MR HINZE:
. Are you talking about the drilling, 3 Dave, or are you talking about:the'use of-studies of 4 chlorine 36?
<5' DR. DOBSON: I was just' referring to the drilling.
6 We are also --
-7 FE. HINZE: 'All right.
8 DR. DOBSON: Doing work --
- 9. MR. HINZE: Because that concerned me.
10 DR. DOBSON: I might add though, that we are doing 11 work in response to what Doctor Moody said. We agree that 12 there may be considerable potential for this1 technique in 13 the drilling, and therefore we are doing considerable 14 developmental work on the applicability of chlorine 36 15 sampling, to samples that we can get'out of drill holes. 16 .Again, as Doctor Moody pointed out, this study 17 plan was primarily written at this time to focus on the 18 testing we plan to do in the shaft. As a matter of fact, I 19 could go one step further. The samples that we analyze -- 20 that Ted analyzes for this study are rock samples, not water 21 samples. 22 You actually analyze the rock. 23 MR. HINZE: Yes, I understand. 24 DR. DOBSON: We are also looking at the 25 feasibility of doing chlorine 36 samples on the water. For j l Heritage Reporting Corporation O (202) 628-4888
117 IL example, below the water table, or on the extracted water-2 from'the unsaturated zone that is' covered in other parts of 3 .the SCP, the hydrochemistry studies that are actually being 4 'done.by the USGS. 5 MR. HINZE: Dave, while you are there, if I might 6 ask you a question that goes back to.some of.the discussion 7 that we had. Is there any specific information that would 8 tell us that the faults in the Yucca Mountain site have high 9 permeability or are they aquatars. 10 DR. DOBSON:- Well right now -- 11 MR..HINZE: They can be both. 12 DR. DOBSON: They could be either or both. As you 13 are well aware, we do have a number of studies-in the 14 hydrology program that characterize the hydrologic 15 properties of-the faults. We at this time, you know, the 16 faults may be aquafers or aquatars. 17 MR. HINZE: You are going to have a tough time 18 interpreting this data until you have that kind of 19 information. 20 DR. DOBSON: That is absolutely right. We agree 21 with respect to the use of this data and all data in 22 modeling, it needs to be considered. Of course within the 23 structure of the SCP. That is one of the reasons that Steve 24 emphasized this morning. 25 We need to read the study plans in the context of i Heritage Reporting Corporation O (202) 628-4888
t 118 1 the SCP,Lbecause there are numerous of' studies of modeling l 2 of both the unsaturated zone and the saturated zone, and the 3 total system. This data is a piece of those models. Ted is 4 not the guy in charge of the hydrologic modeling or the 5 unsaturated zone. 6 MR. HINZE: I understand. Again, if I may. 7 DR. DOBSON: Sure go ahead. 8 MR. HINZE: I just have a couple more points or 9 questions. Again, this is because of a lack of information, 10 in this kind of never never land that we are operating in 11 here where we can have fail flaws, if you will, to our 12 measurements. It is a very good idea to try and calibrate 13 with other techniques, get points of verification. Again, 14 we are not privy to that in terms of this report. What
-15 plans are underway to try to calibrate these studies, or to 16 check them. Are there other isotopes that can be used?
17 There must be at least in the near surface zone, and how are 18 they going to be fed into this? I think that kind of thing 19 in the study plan would be very helpful'in terms of the l 20 review and alleviate a lot of concerns that people do have. 21 DR. DOBSON: Yes, I agree. What we have tried to 22 do basically, is that those study plans that provide data to 23 another study that basically acts as an integrator reference 24 over to that study. So for example, Ted talks about the use 25 of his data in the hydrologic modeling.
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119 1 To answer more directly your question, yes,.we are O" 2 -doing other sorts of. isotopic studies, and in fact, the 3 .hydrochemistry section of the study plan that was also 4 submitted to the NRC on Unsaturated Zone Percolation 5 . Exploratory Shaft Facility Studies -- that is a long title. 6 One of the activities in that study is called 7 hydrochemistry. That study which will be done in parallel, 8 obviously at the same time as Ted's study, will collect 9 samples. We will work on Carbon 14, we will work on -- I am 10 not sure what all other techniques. 17 There are several other techniques for using both 12 for residence times, and of course, as Doctor Moody 13 mentioned, it is important to understand the complete 14 composition -- chemical composition of the samples. 15 MR. HINZE: Why aren't some of those studies 16 incorporated into this study plan so that it can really be 17 an integrated study plan? 18 DR. DOBSON: I believe they are referenced. Now, 19 they are not incorporated -- that is always the question. 20 How much of the detail from another part of the program you 21 include in this one. 22 MR. HINZE: Looking at the titles of these plans, 23 they are not really methodology oriented. I mean, we don't 1 24 have a geophysics or a geochemistry plan. We have a study j I 25 of the seisemotectonics or the vulcanism. We don't have Heritage Reporting Corporation O (202) 628-4888 l
1 1 120 J
- l' : petrology. LIf the are not methodology or discipline 2 oriented,.they are goal oriented. ]
I' 3 It seems to me what we are looking at here is a 4 methodology: oriented plan that isLjust focused around 5- chlorine 36. Shouldn't we be looking at a plan that is'.
, 6 really trying to characterize the entire vados zone ~in terms 7 of its flux and flow ring?
8 DR. DOBSON: I agree absolutely. I think I would 9 repeat what Steve said this morning. That plan is the SCP. 10 At the. level that we can integrate things - you know, the 11 description of the hydrochemistry,-or the unsaturated zone-12 hydrology in the SCP is probably 300-or 400 pages long. 13 That includes Ted's and all of the other 14 unsaturated zone studies. So I.think it is very important
/*~'s k- 15 to try and integrate it. It is the question again of the 16 level of detail in each piece.
i 17 MR. HINZE: A final question. Do you know, or 18 does anyone know what the range of age dating of chlorine 36 19 in rocks -- what is the range that has been measured in 20 ~ rocks? 21 DR. DOBSON: I think I will refer to Ted who has 22 done -- 23 DR. MOODY: It is 500,000 to 2,000,000 is the 24 average. I mean in terms of range, that is the range. 25 MR. HINZE: There was some surface measurements Heritage Reporting Corporation O (202) 628-4888
l 1l 121 l 1 referenced in the study here that are very young ages do to (
)
2 the hydrogen bomb -- slugs. 3 DR. DOBSON: This is doctor Norris who has done 4 many of those measurements. 5 MR. HINZE: Okay. 6 DR. NORRIS: The surface studies with chlorine 36 7 are due to a different phenomena that the radioactive decay 8 of the 300,000 year isotope. They are do to the bomb pulse 9 that occurred from testing in the pacific ocean in the 10 period of 1952 to 1962, where the chlorine in the sea water 11 was activated, and the chlorine 35 through neutron 12 absorbtion became chlorine 36. 13 That is a particularly well characterized time 14 zone and its time period, and the pulse was roughly up to a 15 thousand times what the cosmogenic fallout was. So when one l' 16 sees this very large signal, one can say this is from the 17 bomb pulse. 18 The other studies I believe you are asking about, 19 Fred Phillips has done studies on the question of 20 calibration of chlorine 36 with other dates. Searles Lake 21 in California, where there is magnetotectonic information, 22 and Carbon 14 information, and he has put chlorine 36 in 23 between to tie them to the Carbon 14 at the low end, which 24 can only go up to about roughly 75,000 years at the very 25 best, and that is kind of where chlorine 36 can start. /- Heritage Reporting Corporation ()) (202) 628-4888
122 a l 7, . 1 The magnetic reversals are on a much longer time 2 scale of the order of a million years is' kind of where they 3 start. There is some overlap there,.so this was the basic 4 study,.and it is in reference that I gave in this paper, is q 5 a review paper that mentions these sorts of things., 6 One needs that information. More recently than 7 that, there are studies of chlorine 36 build up in recent 8 magma deposits on.the surface, and this is a phenomenon when 9 you'get chlorine 36 deposits. It falls out, and you can 10 track the build up on it, so that you are looking at the 11 other end of the curve. j l 12 When the chlorine 36 goes up to an equilibrium 13 steady state condition. During that period before it 14 reaches there, you can use that for timing very recent
'15 events -- very recent geologic events in a period of a few 16 thousand years. That has been recently published, and I 17 don't know if that helps answer your question.
18 MR. HINZE: It does, thank you very much. : 19 DR. MOELLER: Could you stay there Doctor Norris,
^20 for just a moment.
21 DR. NORRIS: Yes. 22 DR. MOELLER: Let me comment. I don't think we 23 want to cut off this discussion. I think maybe what -- 24 unless I hear loud objections we will go ahead with this, 25 and Connie -- go ahead and have lunch, and ask you to speak Heritage Reporting Corporation i (202) 628-4888 1
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. 1- immediately after lunch, if that is all right. Would Doctor 2 Norris -- I joined with' Doctor Hinze when I read this study 3 plan of having'a problem with solely depending on chlorine 4 36, because I read it as being -- or having the potential' ;
5 for measuring travel times as low as 100,000 years, and you 6 might be able to crowd it down to 50,000 or so. 7 What we are looking for is if we meed 10 (c) part 8 60, as a travel time greater than 1000 years, so I kept 9 saying to myself, what if it is 30,000 years, it's fine, but 10 your tests will miss it. So now you are telling me -- you 11 are clarifying, and it is good to hear it, that you have 12 other backups using Carbon 14 and so forth to test these 13 shorter time periods if indeed it proves not to be as long 14 as 50,000 or 100,000 years. Am I correct? ( 15 DR. NORRIS: That is correct, and I believe there 16 is a reference to that in section two of the study. 17 DR. MOELLER: Okay. I totally missed it in 18 reading it. It could well be there. What other question or 19 comment -- Doctor Moody put up to three references, and we 20 realize to, again, in the earlier presentations this morning 21 where you said this -- you wrote this three or four, or five 22 years ago. 23 DR. NORRIS: Yes. 24 DR. MOELLER: And it has been massaged ever since. 25 So I can understand, unless you had gone back and updated l Heritage Reporting Corporation (q) (202) 628-4888 i
b 124 , 1 .your references, you would have missed.those. Were you O 2 personally 1 familiar withithe three references that she 3 cited?- 4 DR. NORRIS: I am personally familiar with two of 5- them which Fred Phillips was the author. I was-not-6 acquainted with-the entire-report. l
-7 DR. MOELLER: Okay.
8 DR. NORRIS: In fact, on the third one, if I may i 9 have a little explanation, the third reference came from my-10 work at. Yucca Mountain. I have a report that is referenced ~ 11 in there on infrotration at Yucca Mountain Nevada, traced by-
-12 chlorine 36. !
- 13 On the third page of this, I report that there was 14 only one other measurement at the time this work was done to- R 15 a study of that type by Kenneth Trotman, a graduate student.
16 from the University of Arizona who was working with Fred 17 Phillips at Socorro, and they measured the integral of the 18 bomb pulse at Socorro at their one site, and I referenced 19 that it was a factor of one order of magnitude lower than'I 20 ;got at the Yucca Mountain-site where I did a 'imilar s type 21 measurement. 22 My measurement correlated with the chlorine 36 23 bomb pulse integral from ice samples that were measured in i 24 Greenland when they were corrected for latitude or
)
25 variation. The question arose as to why this off by an i Heritage Reporting Corporation O- (202) 628-4888
p 125
, 1 order of magnitude at Socorro.
2 . Doctor Phillips heard my talk. -I gave a talk at 3 the American Chemical Society meeting in September.of 1985, 4~ and presented'my preliminary results. He.was the speaker 5 there to. He went-back and did a second sampling at Socorro 6- and another one farther south at Las Cruces, which is'the 7 basis or the three measurements - or the basis of this 8 paper. 9 He did that as a result of my work, and he found 10 at Socorro that there is an anomaly at two different sites,. 11 they are off by an' order of magnitude compared'to everybody 12 else, but'not at Las Cruces. So I am well aware of -- we 13 are in communication. 1 14 As far as the review paper.in Science, I feel that l 15 the review papers that are cited in the publication, as you 16 mentioned, I wrote this in 1986, and did not update the
- 17. list. In fact, that one didn't come out until December. I 18- am acquainted with the work, and I am publishing in the 19 field. My work is sufficiently good that Fred Phillips is 20 doing work to find out why his isn't -- didn't get the 21 correct answers.
22 (Laughter.) 23 DR. MOELLER: On a couple of statements in the 24 study plan, one was that you are assuming that the chlorine 25 36 fallout has been relatively constant. Does it go down i Heritage Reporting Corporation O (202) 628-4888 1 i
126 f-1 with the sun cycles on an 11. year cycle, or is it-not , V - 2 . influenced by -- 3 DR. NORRIS: It has not been. observed to do so. 4 The ice, age -- the' ice rings have been studied, and they 5 'have been looking more for the minimum of 200 years ago than 6 they are for.the 11 year sun cycle. 7 DR. MOELLER: Oh,-okay. 8 DR. NORRIS: It is just not a sensitive technique 9 for such'small scale developments, and it can't even track 10 the minimum very well. There is not evidence that it is not 11 constant,.but on the other hand, the data that has been 12 presented so far that I have seen are not readily 13 interpretable of a strong correlation with things like the 14 mondrum minimum. 15 DR. MOELLER: Okay, are there questions 16 particularly for Doctor Norris? Orth and then Mr. Voiland.
'17 DOCTOR ORTH: The protocol that the study plan
.18 calls for, obviously is based upon a great amount of work.
19~ Are there any plans to test out all of the components 20 sometime between now and the time you actually' start the 21 study? Let me expand just slightly what I am talking about. ! 22 For example, it is going to take a long time to 23 get the study plan approved, the reviews in, start the 24 exploratory shaft, and get there. Meanwhile, some little i 25 component like surface leaching of the water or of the rock I i I p' (j Heritage Reporting Corporation (202) 628-4888 i
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,_ 1 to make sure there is not contamination, and various other 2 things, obviously could be tried between now and then on 3 miscellaneous samples from other cores dug all over the 4 place.
- 5 So in effect, although you.got this long study 6 plan that is going to to take years and years to implement, 7 it would be fairly easy, it would seem to check out if any 8 of the specific analytical things are all right. So what. 9 kind of program do we have to make sure that when we finally 10 get around to doing is what we really need to do.? 11 DR. NORRIS: That is a very good question. I 12 agree completely with you. This is an ongoing program, and
~
13 as such, I have been able to get samples from some dry cored 14 holes at Nevada. In fact, I went through and analyzed nine
' 15 of those samples -- I believe it was nine, in a suite of 14 16 at the University of Rochester accelerator in January.
17 I have the preliminary results from them, but I 18 need more data interpretation time. There is a prototype 19 hole that is planned for, for which I have requested samples 20 to work out the techniques, and get all of the techniques in 21 order. You are entirely correct, the program is going on. 22 DR. MOELLER: Gene -- 23 DR. ORTH: Obviously if I -- oh, I'm sorry. 24 DR. MOELLER: No, go ahead. 25 DR. ORTH: Since you probably didn't have a QA Heritage Reporting Corporation O, (202) 628-4888
128 1- plan in order, or agreed upon,Enone of the dataLthat you are-
- 2 getting would be any good even though it may show that~the 3 -technique is alright.
-4 DR. NORRIS:- That is entirely.the case.- In fact, 5 one of the things that-I know I must do is get the QA' 6 program -- get the detail-technical. programs approved and [
7 acceptable to the NRC so that the data can be used for 8 lleensing.- 9 I feel that the prototype work -- well-I call it 10 prototype work, it -is. not official that within the program,- 11 is very important for finding out just what sort of 12 protocols that we need so that we can write down that,-but-13 we are not at that stage yet. 14 We know, for example, in the table that Doctor O 15 Moody showed, it shows that the procedures have not-been 16 approved yet. The procedures exist for chlorine 36 analysis 17 at the accelerator. There'is a difference between having a 18 . procedure and an approved procedure. L 19 DR '. MOELLER: Okay, Gene? 20 DR. VOILAND: Yes, you mentioned cosmogenic 21 formation of chlorine 36, by this, I presume this is the-22 interaction of chlorine with cosmic rays secondary and so 23 on, and then their fallout, is that what that is? 24 DR. NORRIS: Yes. The high energy neutrons from 25 the cosmic ray secondaries interact with the argon 40 n Heritage Reporting Corporation U (202) 628-4888 L__-_ __- _ _ _
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l ll primarily.and cause a fallout. It is in the stratosphere,
.(
l 2 and.there is'a small amount of -- what is the other stable 3 argon isotope, _ argon 38, I guess. 4- Anyway,!there is'are small components,~ dominantly 5 argon 40, and it does fall out the' integral of fallout -- 6 all of global fallout is roughly eight-atoms of chlorine 36 1 7 per square meter per second. 8 May I mention, on the other component from the 9 bomb pulse, that there are.very specific requirements for i 10 -that. That is there be a' source of chlorine to activate. 11 Chlorine 36 is not a fission product. You may remember it i 12 is in between the chlorine 35 and the chlorine 37. It is 13 not formed as a fission product, and it-is formed only in-14 neutron -- the pulse of fallout occurred from neutron 15 activation of sea water only where you had a large quantity 16- of neutrons from thermonuclear weapons where.the fireball 17 touched the surface of the water. 18 When the fireball did not touch-it, such as in the 19 higher altitude nuclear weapons bursts, that was not a 20 component of the fallout. Now, the Nevada test site program 21 has not tested thermonuclear weapons, and there is not a 22 chlorine source there, so the chlorine 36 fallout from the 23 Nevada test site operations is not a factor in this sort of 24 work. 25 DR. VOILAND: Has the possibility of looking at i Heritage Reporting Corporation O (202) 628-4888
130 1 chlorine 36 that might be activated in the surface rock as a 0 2 result of cosmic rays been look at? For example, one can 3 measure radiosodium in the urine of pilots that have flown 4 the polar route. 5 It is not very much, but it is measurable. We are 6 dealing with very small quantities here. This site is at 7 5000 feet, and it is higher than the Swedish site, for 8 example -- I don't know much about the radiometric there, 9 what you would call them, but has that been considered? 10 DR. NORRIS: No , it would be -- in essence, part 11 of the background that would be there, and the background is 12 a concern as to how low we can go, and how much -- what the 13 eventual age, you know, whether you can go to one million 14 years or two million years, if that is important. O 15 DR. VOILAND: Yes. 16 DR. NORRIS: We are concerned about the 17 background, and are trying to determine it both through 18 calculations, but. there are two things there, the measured 19 chlorine content of the Topopah Spring tuff is approximately 20 three parts per million. 21 The measured uranium content is of the order of 22 ten to twelve parts per million if I remember correct. The 23 thorium content is of the order of 14 parts per million. It 24 is somewhat similar to granite, but with the low chlorine 25 there -- Heritage Reporting Corporation 9 (202) 628-4888
1 l I 131 ! 1 DR. VOILAND: It seems unlikely. O- 2 DR. NORRIS: That this is not a limiting effect. 3 DR. VOILAND: Sure. 4 DR. NORRIS: On the measurements as we see them. 5 DR. VOILAND: It seems unlikely that it would be, 6 but on the other hand if it were formed, then you might have 7 some kind of a background which would be higher near the 8 surface where the cosmics interact and produce the neutrons
'9 than down Irw.
10 DR. NORRIS: Still, it would be a measure of water 11 movement because the only way that that chlorine 36 could be 12 taken down would be from their -- by water transport if it 13 were found lower, and that is the object. 14 DR. VOILAND: But unless -- 15 DR. NORRIS: The source is .really fairly 16 unimportant. It is the water movement itself that the test 17 is concentrating on. 18 DR. VOILAND: Yes, but the concentration in the 19 rock might be of some interest. Thank you. 20 DR. MOODY: Yes, it is. 21 DR. MOELLER: Other questions or comments? Doctor 22 Steindler? 23 DR. STEINDLE'": I have one general question. 24 There are a whole raft of steps that are involved, some of 25 which has been listed here, each of which involve some sort i Heritage Rep *.rting Corporation O (202) 628-4888
132
,_ 1 of assumption on the applicability of a method to the data 2 that one thinks that they are getting out of'it.
3 For example, the business of leaching chloride out 4 of the rock that yru pointed out. The non-selectivity of 5 the isotope detection method, et cetera, and a whole bunch 6 of those, is it likely that the department is going to be 7 able to validate this method as a legitimate method for the 8 determination of water movement by some process as yet not 9 identified? 10 DR. NORRIS: Would the department like to answer? 11 (Laughter.) 12 DR. STEINDLER: I mean, isn't the department going 13 to have to answer the question somewhere along the line. 14 How do you know that this gives you answers of the kind you 15 think you're getting? I.E., water movement. What you get, 16 the primary data, is a still variation with sample, which 17 may be isotope variation with depth -- 18 DR. BROCOUM: Ted said that he would try to answer 19 the question. 20 DR. NORRIS: I feel that the primary validation 21 isn't doing really high quality scientific work that is 22 published, and is examined by peers in the literature. That 23 is really my goal in this work, is to do that sort of work, 24 and to publish the results. That is why I have been 25 publishing papers, and I feel that that will be the Heritage Reporting Corporation O (202) 628-4888
133 1 validation. O 2 As far as cross checking with the other things, it 3 turns out that chlorine 36 has a half life that seems 4 applicable to the situation at hand, and we will try to make ; l 5 measurements. We are discussing other isotopic measurements 6 now using krypton 81, which would be a good tracer, and we 7 are trying to do that. 8 We want a good scientific study, and we will use 9 every isotope that is applicable for the cross check, but 10 they are not at all of the place where we have study plans 11 yet. 12 Does that help? 13 DR. STEINDLER: A little. Thank you. 14 DR. MOELLER: Other questions or comments? 15 DR. VOILAND: I just have one comment. I think 16 there is some risk in this. On the other hand if it would 17 work, it really is a dandy method, so my reaction would be 18 that it looks like the risk is well worth it. When you are 19 on the kind of the forefront of the scientific adventure, 20 things are not all that certain. 21 DR. MOELLER: They have said to us, this isn't 22 something that corrects. What Doctor Moody mentioned in 23 terms of sampling, but they do have other tecP,iques, other 24 tracers that they are going to use, and so forth, so that 25 helps. 1 l l f- Heritage Reporting Corporation l (_) (202) 628-4888 l l L - - - - - - - - - - - - - - - - - - - _ - - - - -
134 ] 1' Well I think with that then we will'take a one O 2 hour recess for lunch, and we will immediately.begin with 3 Doctor Krauskopf. 4 (Whereupon at 12:00 p.m. the meeting was adjourned 5 to be reconvened at 1:00 p.m. the same day.) 1
- 6. -{
7 8 9 10 11 12 13 14 15 16 17 18-19 20 21 22 23 24 1 25 i Heritage Reporting Corporation O v (202) 628-4888
1 l 135 1 AEIEBHQQH EEaaIQH (' ) 2 DR. MOELLER: The meeting will resume. 3 As I mentioned at the lunch break, we are going to 4 begin eith Bob Browning who is on a tight schedule. And 5 we've ask Bob and he kindly consented to come down this 6 afternoon, and he'll begin with a status report on where the 7 NRC staff stands in the preparation of the Site 8 Characterization Analysis. And then we'll have a free-9 wheeling open discussion on any items that the Committee is 10 interested in. 11 Bob, we welcome you. 12 MR. BROWNING: Thank you very much. ; i 13 First of all I want to thank the Committee for _4 accommodating my production work on the SCP review and in 15 the process discombobulating all your staff's plans for this 16 particular session. I appreciate it very much. 17 In order to give you a view of where we stand in 18 our process, I've got several handouts. And the one I'll be 19 talking from is this one which is the Bar Line Schedule of 20 Events. It's a one-sheet piece of paper with some bar 21 schedules on it. 22 This is the schedule that was laid out and 23 included NR Review Plan for the SCP and it lays out the 24 seven-month process for getting through the review 25 generating a Site Characterization Analysis and getting both Heritage Reporting Corporation O (202) 628-4888 I
1 136 l' your-review an'd the Commission's review prior to.issuingfit s
.O2 to the Department of Energy.
3 I've also handed out a letter from Mr. Bernero to 4 Mr. Rousso dated March.lst which is of interest because this 5 letter says we have, as of this point in time in our
-6 process, now got all.the documents that we had indicated we 7 needed to do an adequate review of the Site Characterization 8 Plan and our process is, in fact, starting. Even though it 9 really started when-we received the first SCP.
10 As you are aware from looking at the study plans, 11 'the Site Characterization Plan is a broad document that 12 ' integrates.all the testing that they plan to do, that they 13 perceive they need to do right now? And that will be 14 updated every six months. 15 There are more detailed documents that are 16 necessary in order to understand that, including reference 17 documents in the SCP itself and some of the key documents 18 related to the sinking of exploratory shaft, which in the 19 Department's scheme of things is the most important l 20 production of that to getting the Site Characterization
- 21. Program underway.
22 So even though we did not get all the documents 23 that we had identified we needed in order to do an adequate , 24 review until-several' months or so after the date started, we 25 have accepted the documents for review and are still on our Heritage Reporting Corporation
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137 l 1 . - 1 schedule for getting the analysis to the Department by July
\_) 2 of this year. l 3 The reason I could not have the staff come down
]
4 and talk to you is that we're a. the stage of all the 5 individual disciplines submitting their particular' comments 6 on the thing as they view it. And we're going in to what I 7 refer to as our technical integration step. We are trying 8 to make sure that what one person thought was important ' 9 matches up with what other disciplines think are important 10 to come up with a thoroughly integrated technical set of 11 comments. 12 What we don't want to do is just take a whole 13 bunch of isolated disciplines, comments, staple them 14 together and send them off to the Department. That's not 15 going to help them and it really isn't the kind of job that 16 the NRC ought to be doing. 17 One of the things I think you'll find as you get 18 into things like the study plans, if you look at a 19 particular piece of this study plan and look at that in l 20 isolation, you may very well be missing what really is 21 important in this overall process. 22 So one of the lessons we've learned from doing our 23 comments on the draft SCP was a technical integration step 24 was extremely important. And that's the process we're going 25 through now. IIeritage Reporting Corporation O (202) 628-4888
138 g- 1 '- From the standpoint of timing.and scheduling as to
'V 2
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when'I would be comfortable giving you a produ'ct that I~ 3 think would be worth spending your time reviewing in terms 4 of my product, it would be at the time'we finish the 5- internal QA and Management Review which is in the. time frame 6 between April 7th and 6/2. 7 And so what I'd like to do is 'try to work very
'8 closely with your staff to try to make sure that meetings 9- that-you've schedule.during that period of time, that we can 10 'get-to you with some of the key issues that we see rising 11- from our comments so that you can independently do whatever 12 you need to do to get confidence and to comment to the 13 Commission as to whether you think we've done an adequate 14 job or not.
O 15 So that's in general terms where we stand. 16 I'd be glad to entertain any questions you have'in 17 that regard. 18 DR. MOELLER: At this stage even in a preliminary 19 way, do you have any specific problems with the SCP that you 20 could share with us or is it too preliminary? 21 MR. BROWNING: Oh, I think it's really too 22 preliminary. Let me share with you two things that I've 23 asked the staff to be looking at very, very closely. And
- 24 if, in fact, we have--you know, their comments provide facts 25 to support these kinds of broad concerns, they'll end up Heritage Reporting Corporation O- (202) 628-4888
. _ _ _ _ _ _ - _ - _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ - _ 139 1 being a broad concern. If the facts don't support it, we O- 2 won't be making the comment. 3 One of the things I just mentioned is technical
-l 4 integration is extremely important. So that's one of the !
5 things we're going to be looking for. And looking at it 6 from all the isolated discipline standpoints and an 3 7 integration step is how good a job does it look like the DOE 8 process for doing this work and laying out a plan, how well j i 9 does it come out that they are doing a good job of ; 10 integrating all the technical disciplines. Because I think 11 that's going to be very important. , 12 We cannot in the NRC just as you cannot, even with 13 regard to my limited piece of work, do a 100 percent check 14 of everything. I can't do a 100 percent check of DOE is
\l 15 doing. You can't do a 100 percent check of what I'm doing.
16 There is just not enough resources in the world to go around 17 to do everything 200 or 300 percent. So you have to have 18 some rational way of sizing up. Does the whole thing make 19 sense? And then picking and choosing key pieces and making 20 sure they are going well and then drawing a broad 21 conclusion. 22 So one of the things we'll be looking for is how 1 23 well the technical integration of this work is going. 24 Another which is more a programmatic scheduling 25 problem so I can schedule and plan my work is how well is i Heritage Reporting Corporation l O (202) 628-4888
L-a 140 1 the work going to be'done and reported'and analyzed and O 2- subject to their scrutiny, my scrutiny or the public's 3 scrutiny or a scrutiny-in the scientific community? .Is that 4- . going to come out in a reasonable time frame? And are the 5 schedules that are laid out'for these things making sense? 6 And if not, we'll be raising questions about how 7- could we be doing that in such a_way that it'will give us 8 greater assurance that we know that key test results are 9 going to come out in time to support key decisions for 10 continuing doing the work. 11 It's that kind of thing that I'm looking for. I'm 12 not looking for just a whole bunch of detailed technical 13 comments on this.particular test method or that particular 14 test method. Just how well does the whole thing fit in 15 together and does it seem to make sense. 16 And in that regard, you know, I've encouraged the 17 Committee to focus as much attention as you can on the 18 performance assessment aspect of this work. Because that's 19 one of the technical integrating tools that I think is going 20 to be very, very important for us to all keep our eye on. 21 So that we don't fall into the trap of getting enamored with 22 trying to understand everything there is to know about a 23 particular subject when in fact when you try to use that 24 information o n snake e prediction about how the site is going 25 to perform over the long term, it really doesn't matter. 4 Heritagn Reporting Corporation O (202) 628-4888 L___ __. _ _ _ _ _ __
i i l l 141 1 And that's a difficult thing to come to grips with 7S
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2 but I'm going to keep focusing my staff's attention on that 3 particular aspect and that's one reason why we keep 4 emphasizing the importance of this whole aspect of how do 5 you predict performance of the site and the engineer 6 barriers over these long periods of time that are required 7 by the EPA standard and the very nature of this particular 8 project. Something that's never been done before. 9 And the earlier in the process that starts the 10 better we can calibrate--DOE can calibrate, we can calibrate 11 --as to whether we're really focusing in on the most 12 meaningful aspects of that particular site and how it's 13 going to perform over the long run. 14 DR. MOELLER: A question. You mentioned the dates fm k- 15 that you would be ready--the window for the SCA, April the 16 27th or something, until June the something? 17 MR. BROWNING: Yes. During that period of time, , 18 I'll know better after April 7th, which is when I'm going to 19 start getting some visibility of how well this thing fits 20 together and how well our comments are making major 21 programmatic kinds of comments. 22 DR. MOELLER: So it's April the 7th to June the 23 2nd? 24 MR. BROWNING: Right. If you look on this 25 schedule, it's the bar line that's labeled " Internal QA and Heritage Reporting Corporation I O (202) 62C-4888 { _ _ _ - _ _ _ - _
142 1- Management Review of the SCA."
'O 2 DR. MOELLER:- Okay.
3 MR. BROWNING: See, ideally we would like to wait 4 until that's all done and then dump it on you on 6/2. 5 DR. MOELLER: But in other words, what'you are l 6 saying-- 7 MR. BROWNING: But I don't think that's fair to 8 you. 9 DR. MOELLER: Okay. Well, this is important 10 because what you're saying and we're thinking of rather than 11 have every presentation be before the full Committee, we're 12 tninking of having working groups or sub-committees and have 13 the people come down and spend a calmer day going over a 14 certain segment or a certain series of questions and all and 15 then writing up a report on the basis of that day's meeting 16 and forward that to'the full Committee. 17 So beginning from April the 7th on we can start 18 scheduling those meetings? i 19 MR. BROWNING: That's my best estimate. Now, 20 April 7th I may be back to and saying "I'm not really ready 21 yet." I don't want to subject you to something that I'm not 22 happy with yet. 23 DR. MOELLER: Okay. 24 DR. PERRY: Excuse me, Bob. We do have a plan for 25 about a two-hour summary presentation in the April meeting. Heritage Reporting Corporation O (202) 628-4888
143 1 Are you committing to that? 2 MR. BROWNING: Yes. That's in late April, right? 3 DR. PERRY: Right. 4 MR. BROWNING: Yes. By that time I think we'll 5 have a pretty good handle on whether we're on the right 6 track or not. -And our approach will be if.we see anything' 7 major we're not going to wait to tell DOE about it at the 8 end of the July. If anything major starts coming out of 9 this, we probably.will plan to send them letters alerting i 10 them to things we think we see so they can start thinking 11 about it in parallel. I mean there's no point in just 12 dumping on them in July either. If in fact we start seeing 13 .some questions or concerns starting to evolve from this 14 whole process. 15 Just as we've committed in the management letter 16 Bernero sent to Rousso that if any issues come up with 17 regard to sinking of the exploratory shaft, because that's a 18 very important production item and their particular plan of 19 events. We plan to get that to them as quickly as we 20 practically can. Not wait until July. 21 And I think the same thing would apply to any 22 other things we see that might indicate a concern on our 23 part, because it may very well be when we bring it to their 24 attention that they can satisfy that it isn't a problem and j 25 therefore it wouldn't show up in the July Site Heritage Reporting Corporation O (202) 628-4888
144 i 1 Characterization Analysis.
- D 2 So I think it's very important that everybody in l
3 this process keep a good ongoing. technical dialogue going so 4 we don't end up dumping surprises on each other. I 5 Now, part of the problem of that is'we'll come 6 down and talk to you about this stuff and if it starts
- 7. showing up in the newspapers, then we'll be diverted off DOE 8 and we will be off reacting to newspaper articles.
9 So I'm beginning to see why DOE is reluctant to 10 have me involved while they're trying to digest'it. I have 11 exactly the same problem when I'm trying to do my job and 12 produce something to get back to them.- It has a high 13 potential of you are losing ~ control over the content and 14 sequenceLof your own work ~by putting in the public domain 15 something that may not end up being exactly the way it is at 16 the early point in time you put it in the public domain. 17 So I ask you- you know, it's something we are 18 going to have to evolve. I do not think it's fair to dump. 19 this report on you and then have you have to submit a report 20 a month later to'the Commission as to what you think about 21 it. It's just not fair. 22 DR. MOELLER: Well, I think if we can count on it 23 to begin our meetings early April, you are giving us roughly 24 two' months. And it will mean a lot of work, but I think we 25 can do it. Heritage Reporting Corporation
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145 1= And again, for'information to our consultants, we
.O O~ 2 are planning smaller,-not' full committee meetings, smaller r 3 meetings on particular segments and we'll be in touch on 4 possible dates and so forth.
5 MR. ORTH: Small correction. Early April is two 6 weeks.
- 7. DR. MOELLER: Pardon? I'm not with you. April
.8 the 7th until June the 2nd.
9' MR. BROWNING: Early April is.in two weeks. 10 MR. ORTH: Oh, right. Sorry. I thought.it was-11 way off. Thank you. Oh, boy. l 1:2 DR. MOELLER: Do you have other comments or 13 questions on the SCA for Bob. Browning? 14 MR. HINZE: I would like to ask a question if I O' . 15 may. 16 Mr. Browning, the technical integration you are 17 talking about sounds excellent. I'm wondering if you and 18 your staff have enough information across the board in terms 19 of performing.this integration? Do you have the necessary , 20 input to it? 21 And the reason I ask that question is because we 22 have looked at one of the study plans and it is apparent 23 that we're missing a lot of other things that we need to 24 integrate with that in order to properly evaluate that. And 25 I'm just wondering in terms of the work you are doing-- Heritage Reporting Corporation O (202) 628-4888
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- 1 MR. BROWNING: Well, I think part of your problem >
'~'
2 may be--I don't know whether you had a chance to look at the 3 whole study plan. I'm sorry. The whole Site 4 Characterization Plan and then look at the study plan. You 5 may have looked at the study plan first in the absence of 6 having looked at the Site Characterization Plan. 7 My staff hasn't even begun to look at the study 8 plans, so in a way in the particular study plan you focused 9 in on, you are ahead of my particular. sequence.. My sequence 10 is to take a look at the whole Site Characterization Plan 11 because that's how all these pieces fit together. 12 For example, it tells what nondestructive tests 13 are going to do on the ground. That's my way of referring 14 to geophysical tests or whatever the earth scientists talk 15 about, trying to understand what's going on under the earth 16 without actually digging holes in the earth. You know 17 that's laid out. 18 Then they are going to be boring holes. We're 19 trying to say, well, does all that make sense? Are they 20 doing the nondestructive test first to give them an idea of 21 where they sink the holes? Does that all fit together in a 22 logical sequence? 23 Then you may want to look at a detailed study 24 plan. The reason we have the five study plans in hand right 25 now is they were all the key study plans that DOE felt they l l p Heritage Reporting Corporation (202) 628-4888
147 1 needed to be running in conjunction with sinking the
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2 exploratory shaft. 3 And one of our comments on the draft SCP was that 4 we were concerned that unless they looked at it very 5 carefully they may find that when they sank the sham they 6 perturbed the very thing they are testing for. 7 And so ultimately we want to look at the study 8 plans in that context. But we're still waiting for some 9 confirmation that they have some kind of baseline systematic 10 way of developing those plans so that we can'have confidence 11 that if we check one or two, we've got some confidence that 12 all the rest- you know, whatever conclusions we draw from 13 one or two are valid across the rest. 14 And we refer to that as worrying about their QA 15 plan for developing those things. 16 So in a way, you are a step ahead of me. We're 17 trying to make sure that all the broad testing sequences and 18 approaches they're using seem to make sense. And then we'll 19 get down to worrying about specific-details of the study 20 plans. 21 Some we will go into excruciating detail on, if we 22 think they are really fundamental to a key license and a 23 regulatory kind of issue at the particular site. 24 You know, what's the groundwater doing under there 25 is one of the key questions. So things related to Heritage Reporting Corporation O (202) 628-4888
148 f- 1 groundwater, like you guys focused in on, but that's only (g) r- 2 one test. .There are many, many tests that are going on'to i 3 try to get a handle on that. 4 Now, internally, I have staff that are i 5- knowledgeable on all the technical disciplines. We also i 6 depend on some outside technical contractor help. And we've l 7 been bringing that to bear. 8 One advantage I have over DOE is I can get an I 9 integrated team in one room. I think that's an advantage.- 10 You don't hear quite so many voices either. I mean I get 11 two or three opinions. They probably get a hundred. So 12 they've got to sort all those out. 13 My job of technical integration is a great deal 14 easier than theirs is. O 15 I think there was some interest in what we planned 16 to do with the study plans when we get around to reviewing 17 them. 18 DR. MOELLER: Okay. 19 MR. BROWNING: This was covered to some extent but 20 probably got lost in the details of our plan for rev3m;ing i 21 the Site Characterization Plan when the staff briefed you 22 back in February. 23 Right now DOE is estimating that there will be a 24 total of about 107 study plans. We plan to review all of 25 those study plans. At least to the level of making sure Heritage Reporting Corporation O (202) 628-4888
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i 149 j- 1 they are consistent with agreements we've reached with them 2 on the level of detail and the kinds of contents and do we 3 have the referonces. 4 Then we'll go into a decision process as to which' 5 ones we want to look at in great detail. And right now I'm 6 budgeting'and planning on the basis of about 20 percent'of. 7 all the study plans I will go into in' great detail. We may i 8 have to adjust that depending on how confident we are that-9 DOE is doing a great job and whatever overall program they 10 have for developing study plans. 11 But our whole philosophy for how we're dealing 12 with this is the burden is on DOE to do a good job, 13 demonstrate to us that they are generally doing a good job 14 and then auditing and getting into great technical depth on 15 specific key issues so that we've got some' independent 16 confirmation of what they are doing. We'll pass a , 17 regulatory licensing kind of review. 18 'I know the Commission has expressed concern about 19 whether the 20 percent is enough or not. All we can say is 20' that what we' re budgeting and planning on, we'll see as we 21 go. ! l 22 And I notice with interest you picked 20 percent. 23 DR. STEINDLER: A question on your reviews. ' 24 Do you believe you have a procedure in place 25 whereby study plans can be changed when and if new ) Heritage Reporting Corporation O (202) 628-4888
r y o, 150 7 1- information has arisen?-
}
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.MR. BROWNING:- Oh, absolutely,. absolutely. .
3 DR. STEINDLER: You don't anticipate--
-4 MR. BROWNING: The.whole process of the six-month 5 update is to make sure that--I.mean there's no way I~see 6 that this initial SCP is going to.be carried through to 7 completion without any changes.
8 DR. STEINDLER: No, no. That isn't-quite.what I 9 meant. Suppose for a moment that DOE-proceeds-to implement 10 a particular program based on'the study plan that you have 11 initially. okayed. Reviewed, okayed, et cetera. And-12 subsequently finds that either'because of some of the 13 particular details that had to be worked out specifically 14 for this study or for'some other reason,.that plan really 15 needs-to be significantly changed, and there is a process 16 for changing it. 17 What do you intend to do with the information 18 gathered up to that time some of which may still be 19 - perfectly good? Do you have any difficulty with, in a 20 sense, selecting those areas that-were valid and allowing 21 that to be incorporated into the new program? , 22 MR. BROWNING: The whole concept is they'd have a 23 baseline QA program in place for all the work. They'd have 24 procedures developed. They'd have change procedures in
'25 order. Which in some cases involve changes made on the Heritage Reporting Corporation
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. - 1- site.- You?know, as.they collect data.. They.may need the q
'N_f 2 flexibility to change the procedures right there. .' But the 2 '
3 procedures will be.in place for doing that, so you have a 4 record of what went on. So I would have no problem 1
-5 accepting what was done before the change or after the -i 6 change.
7 DR. STEINDLER: So the issue then is that the QA 8 plan supporting that kind of activity up and down the line 9 will have to be:in. place in order for you to be reasonably 10- safe? 11 MR.-BROWNING: Absolutely. The baseline QA 12 program. 13 DR. STEINDLER: Yes. 14 MR. BROWNING: QA plans change with't'ime too. 15 They'll find that they weren't quite right there'and they'll 16 have to change them. But at least you've got a baseline 17 fundamental plan. Everybody can say, "This is where we 18 started from." So you start from a known way of doing 19 business which over the years will get better. What j 20 happened before you got better was inadequate. 21 DR. MOELLER: Now, your turnaround time on the 22 review of the study pian is six months and I think we heard 23 this morning maybe sometimes you could do it in three. l E And one of the questions that came up this morning 24 25 was how many full-time equivalents are you setting aside to Heritage Reporting u,rporation O (202) 628-4888
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l 152 7-1 do'these reviews? We realize it won't be the same people ) 2 because they'll rotate around. But what percent of your-- 3 what number of people do you anticipate will be required to 4 handle the reviews? 5 MR. BROWNING: Well, a number of people is 6 difficult to deal with, but on the order of--let's.see-- 7 DR. MOELLER: Well, you are going to review all of 8 them in a-- 9 MR. BROWNING: We're planning to review all of 10 them-- 11 DR. MOELLER: At least somewhat. 12 MR. BROWNING: Somewhat. But some we'll do in ! l 13 more detail than other. l l 14- DR. MOELLER: Right. 20 percent in depth. 15 MR. BROWNING: 20 percent. So it's not a j 16 situation where they'll be some study plans we haven't even 17 looked at. We will look at all of them. 18 DR. MOELLER: Yes. 19 MR. BROWNING: The process for selecting the ones 20 that we think we want to look at in detail will be based on j 21 whether it's related to a key technical topic that's of 22 great concern and will be very, very important in the 23 licensing heaning. 24 If it's related to any of the SCP objections, you 25 know, resolving objections, concerns va have on the SCP. Heritage Reporting Corporation q/ (, (202) 628-4888 j
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,f s l' Unique, non-standard or controversial kinds of tests, b 2 We want to reserve the right to do some random 3 sampling. We don't want DOE to know which ones we're 4 looking at and which ones we're not in advance. For obvious 5 reasons.
6 And then just selected procedure. We think 20 7 percent will give us a good overall feel for--and if the 20 8 percent sample is a problem, we don't fix the problem by 9 going to 100 percent. We go back and tell them, hey, you've 10 got something fundamentally wrong with your way of doing 11 study plans. Go back and fix it. 12 DR. PERRY: Dr. Moeller? 13 DR. MOELLER: Yes. 14 DR. PERRY: You may remember that the staff in a 15 previous presentation indicated that there are actually 16 three levels of review for each study plan. Acceptance 17 review, which is relatively short term. There is a review 18 of ninety-day start work review. And then at the end of 19 that up to a 180-day detailed review. 20 DR. MOELLER: Well, I assume you could--again, you 21 wouldn't necessarily want DOE to know this, but you could 22 adopt a policy something like NRR does with nuclear power 23 plants. You know, if they find one that's doing well, they 24 back off and spend more time-- 25 MR. BROWNING: It may be less than 20 percent. Heritage Reporting Corporation O (202) 628-4888
154 'l 1 DR. MOELLER: Right.
~2- MR. BROWNING: I doubt it.
3 .DR. MOELLER: Sure. -So you could do the same 4 thing. -All right. 5 MR. BROWNING: No , absolutely. If we sense
] l 6- something is going well,1we plan to back off and go !
i 7 concentrate on things that aren't going so well. 8 DR. MOELLER: Sure. Okay. 9 MR. BROWNING: The secret is, you know, based on 10 the sample, can we make these broad overall judgments about. 11 the rest of the study plan. So we'll have to be very 12 careful on how we select them and how we document about the ; 13 fact. How we select it, if we ever get challenged in the l 14 licensing arena. We'll have a good logical. argument as to
'15- why we did look at some in detail and why we didn't look at 16 others in detail.
17 DR. MOELLER: Now, what other subject--changing 18 the subject for the moment, that the Committee had talked i 19 about was to ask you to tell us specifically what were the 20 more important things we should be looking at, not in terms 21 of study plans, but in the gross sense and I believe your 22
- response would be that you discussed those things and that's 23 what George Lear is here for to give us a list--
24 MR. BROWNING: George has a list of things that we 25 think are timely that are coming up-- Heritage Reporting Corporation A(_/ (202) 628-4888
155 1 DR. MOELLER: Right. I
,T MR. BROWNING:
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2 But I think in the broadest sense 3 things like performance assessment--you've had a detailed 4, briefing by DOE about where they stand and what they are 5 doing. 6' I'm in the process of trying to reassess how I and 7 my staff on the NRC could best interface with that and make 8 some. conclusions. And I think that's going to be 9 fundamental to being able to say, we've met the EPA 10 standards, to be able to say we've got models that 11 represent, as close as we can, to, you know, reasonable way 12 to the real world. We've collected data that's meaningful < 13 to put in those models. We've exercised the models. And 14 there's a reasonable technical consensus that the models are , 15 telling us something that makes sense. And we're all--not 16 all, but a reasonable group of people, whatever that is, 17 would agree is good enough to go ahead with this project. 18 DR. MOELLER: This is beyond and above--beyond, at 19 least, in time above the Site Characterization activities? 20 MR. BROWNING: Oh, yes. Now, this is focusing in 21 on DOE being able to say, "We've met the EPA standard." And 22 us saying, "We agree, you've met the EPA standard." Now, I 23 think we'va all got to keep our eyes focused on that. 24 Because if we get--like I said, if we get too embedded in i 25 trying to worry about all the esoteric technical details of l { Heritage Reporting Corporation O (202) 628-4888
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,_ 1 the site, we may be missing the. forest for looking at the
(_J- 2 trees. 3 And ultimately, the test of this is going to be 4 whether DOE can lay some models on the table that everybody 5 thinks reasonably model what's going on at that site and
'6 pushing the button and projecting out 10,000 years.and 7 everybody's saying, that sounds good enough.
8 There are some short-term things about, you know, 9 investigating the site and some of the short-term hurdles 10 that the R rule puts in place, like groundwater travel time 11 and those questions. But I think the main thing to do is 12 keep your eye on the performance assessment piece. 13 I don't know that much about WIPP but from what I 14 read in the papers, it seems like that may have been one of 15 the problems there. They collected data and thought they l 16 had enough, and now they're trying to figure out how to use j l 17 that data and make a case that they've met the EPA standard l 18 and it isn't necessarily matching up. 19 So if we could learn--whether my perception is 20 right or not, I think we ought to avoid that kind of problem 21 in the civilian repository by exercising the performance 22 assessment capabilities, as limited as they are, early in 23 the game. And I'm getting a lot of pressure from my boss, 24 Bob Bernero, to start practicing what I preach. Start i 25 exercising whatever I've got. And obviously I have a lot Heritage Reporting Corporation O (202) 628-4888
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157 1- less than what DOE does. O L2 So any insight'you.can give me in our. program as i 3 to whether we're interfacing with that aspect ~ correctly. l 4 Because'I can't do 100 percent duplication of what they are 1 1 5 doing. I forget what their. budget is'for that effort. But 6 .it's like $100 million a year and I don't have that' kind of i 7 money to spend. And I do'n't think it's really necessary. If l 8 in fact they are doing a good job, they shouldn't need to l 9 duplicate the whole thing. 10 But there may be some bits a.nd pieces.that make 11 sense for a regulatory agency to duplicate and the earlier 12 we get consensus.on that, you know, at least within our 13 community and then ventilate that outside, make sure the-14 Commission understands what I'm doing and agfees with. And
- - 15 that.you guys agree with what I'm doing and understand and 16 agree with it, it'll help get it past the Commission.
.17 But I think there are people that think I'm going 18 to duplicate 100 percent of what DOE is doing in a 19 performance assessment. And there's no way I can do that.
20 Or should I? I don't think I should. 21 DR. MOELLER: In terms of performance assessment 22- and how much priority you put on the various barriers and so 23 forth, at our last meeting the suggestion was made that it 24 would be very beneficial if a limited or if a scoping study. 25 probableistic risk assessment were performed for the Heritage Reporting Corporation
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158 1 repository anticipated or proposed for location at Yucca O 2 Mountain. 3 What is your reaction? Had you thought ever of 4 requesting DOE to do a PRA in terms of insights and all that 5 it would provide? 6 MR. BROWNING: No, we hadn't. We're beginning to 7 ask that question of ourselves, so maybe it is appropriate 8 for both of us to be dealing with it, because the nature of 9 the EFA standard does require a probableistic assessment. 10 DR. MOELLER: Right. 11 MR. BROWNING: And at least on the appearance a 12 very precise one. And there tre people that say, " Hey, 13 that's never been done before. You can't get any two 14 experts to agree on that refined a number." So it may very 15 well be useful to take an example--for example, vulcanism, I 16 think, is the one that at least comes to my mind. Is it 17 going to be practical to come up with the probableistic kind 18 of assessment for just the phenomena of vulcanism at that 19 site, and start working that early. 20 I don't think anybody would be able to come up 21 with a number right now but they nigPt be able to start in 22 process, say, an exercise, if yoc will, to keep bumping 23 against the site investigation that's going on. I know l 24 people are digging trenches and looking at layers and dating 25 layers and trying to know what that tells them. But I'm not gp Heritage Reporting Corporation
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;' - l' 'sure'they~then have taken that and tried to say whether-
~2 they'll be able to do some kind of probableistic analysis 'of 3 it '.
4 DR. MOELLER: .But it would seem to me--
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5 MR. BP. OWNING : It might be useful. l 6 DR. MOELLER:- Yes. To me it would seem to be 7 -useful. 'For example, on vulcanism you would put in the r 8 probabilities:and the consequences, and you' d come up with 9 an assessment of the' risk of that relative to-the risk of. 10 other things, scenarios. 11 MR. BROWNING: I think it would be meaningful only
< 12 if it's in the-context of trying to make sure that
- 13. implementing the EPA standard is going to be a practicable 14 way of making a case of.whether the site.is' going to be 15 adequate or not. If there was some way of: picking a site 16- mechanism,-a site-related issue that the scientists feel 17 they understand pretty well and start subjecting that to 18 that-probableistic approach.
19 DFu MOELLER: Uh-huh. 20- MR. BROWNING: That reight be very useful. I don't 21 know whether--you might try to find out whether they've done 22 a similar thing at the WIPP site or not. Because the WIPP 23 site has to meet the same probablistically based EPA 24 standard also. So maybe they are a step ahead of this. I 25 don't know.
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Heritage Reporting Corporation (202) 628-4888 1
160 1 DR. MOELLER: Okay. That's a good point. O~' 2 Now, in terms of the Yucca Mountain site, we've 3 read recently--and in fact we mentioned it this morning to 4 the DOE staff and they did not have the right people here to 5 address it. But this whole thing about the National Park 6 Service Water Resource Division has filed a formal protest 7 . opposing DOE's application to the State of Nev".da for a 8 water permit to support the work there. 9 That's one thing. And then the second thing is 10 you mentioned WIPP. And it rang the bell in my mind of how 11 the procedures are underway there to ask for, quote, "a land , 1 32 withdrawal" or plural--to ask for, quote, " land withdrawal ] 1 13 procedures for WIPP i l 14 Now, are we going--is DOE going to have to file l 15 for land withdrawal procedures for Yucca Mountain in 16 addition to these water rights? 17 MR. BROWNING: Yes. 18 DR. MOELLER: They are? Now, what do you see as 19 the potential for smooth sailing on those issues or are 20 they-- 21 MR. BROWNING: Nothing ever goes smooth in this-- 22 DR. MOELLER: Well, how do you view them? You are 23 on the sidelines watching? l l 24 MR. BROWNING: Yes. On those particular things, 25 our agency is really on the sidelines. That's an issue Heritage Reporting Corporation O (202) 628-4888
161 1 betw(en DOE and the State of Nevada, which we have no role Q whatever. 3- DR. MOELLER: Okay. 4 MR. BROWNING: Now, we're interested in things 5 like the water withdrawal, not from the standpoint of 6 getting permits that have to be obtained from whoever the 7 right authorities are, but what does that tell us about the 8 amount of water they are going to use in sinking the shaft-9 and does that-have some question on the impact of that water 10 use on the validity of the tests, such as these boring tests 11 you are talking about. 12 That's the kind of technical integration I was
)
13 talking about earlier. You can't just look at that test and 14 have the scientists running that test--if you said, "Well, O. 15 the hole is ready. Come run your test." They need to know, 16 somebody needs to know, how was that hole made and is the 17 way that hole was made going to give them invalid results? 18 And that's the kind of technical integration that's very 19 difficult to come by. And we want to make sure it's 20 actively being worked at the DOE end. 21 DR. MOELLER: Uh-huh. 22 MR. BROWNING: So from that standpoint, we'd be 23 interested. But in terms of getting the permit, we're not I 24 involved in that at all. 25 DR. MOELLER: Dr. Perry. ) I Heritage Reporting Corporation O (202) 628-4888
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'l- -DR. PERRY: I want to mention to the Committee the !
L 2- . consultants.at the WIPP site,. DOE does the performance 3 assessment themselves. And they make a' judgment whether or' 4 not they've met a standard. That's not done by an 5 independent organization or reviewed by--I don't believe 6 it's reviewed by-anybody other than their own internal 7 reviewers. 8 MR. BROWNING: I think the National Academy of 9 Science has a group that watches that. 10 DR. PERRY:= Yes. 11- MR.. BROWNING: And I also think there's some--I-12 know that there's some pending legislation that says EPA 13 will have to decide whether they've met it or not. That 14 hasn't gone through yet. I know that EPA folks that are our 15 counterparts over at EPA are going to come over and try to 16 . find out how I'm doing it with the civilian repositories so
;17 if they get charged with it they'll have some feel for what 18 they are getting into. I was hoping they'd come over and 19 tell me how to do it.
20 DR. PERRY: I'think that would be a very just 21 thing to have EPA judge their own standard. I think it 22 would serve them right. 23 DR. MOELLER: Okay. Additional questions or 24 comments for Bob Browning? 25 Gene. Pull your mike over, Gene. Heritage Reporting Corporation LO. (202) 628-4888 I
163 1' MR. VOILAND:- I was very happy to hear about-the integration because recently I went through Section 8.3,'all SL
'3' 474 pages of it, which related to geology and hydrology.
4 And it read to me like an encyclopedia of topics in geologic 5 and hydrological research. And there was an indication 6 there of how these various program. elements went together. 7 But it seems to me the coordination has to'be an 8 ongoing thing, very strong. For example, we heard this 9 morning about a possible direct measurement of groundwater 10 movement. And that's the best kind of measurement you can-11 make. If you measure it directly. Generally if you can't 12 do that, then you do a lot of other things and try to infer. 13 So it seemed to me that if that proves to be 14 successful, there are many elements of that program that-15 could probably be deleted because you have answered one of 16 the key questions. 17 On the other hand, there are lots of others, the I 18 homogeneity of the site and all the rest that you can't. I l 19 So does that integration and coordination look at 20 the program elements in terms of some hierarchy value where ML you do one? 22 MR. BROWNING: Yes. 23 MR. VOILAND: And you can then think about others. 24 I observed also that in the testing of--testing 25 methods and requirements, each test had its own list and yet l Heritage Reporting Corporation O (202) 628-4888 i [.
4 o 164 1 many of those repeated all the way through.
. O- '
2 Is-there some sort of coordinated effort on 3' approval in review of testing methods so that each study 4 plan doesn't, you know, get its own independence and you 5 have a lot of repetition? .Would there be some kind of-- 6 MR. BROWNIN3: Well, I don't think we're going to-7 be actually approving each individual. method per se. That 8 is probably something we'd be looking at and maybe making a ! 9 comment to DOE if that would be helpful, to try to make sure 10 there's some consistency across the whole program. 11 MR. VOILAND: That would be DOE's responsibility, 12 of course, to do that. 13 MR. BROWNING: Yes, sir. To make sure it's 14 consistent. l 15 MR. VOILAND: Right. Good. 16 I wonder if I could just mention a couple of other 17 things. I presume you folks know that the Technical Review 18 Board that the Nuclear Waste Act called into being is now in 19 effect and has had their first meeting with DOE. Is that-- 20 DR. MOELLER: Yes, we saw that. 21 MR. BROWNING: Okay. 22 DR. MOELLER: Because one of our consultants, Mel 23 Carter, is on that group. 24 MR. BROWNING: Okay. I think it would be very 25 important from my standpoint, and I assume also DOE's rw Heritage Reporting Corporation (202) 628-4888
1' 165 3 1 standpoint, if there could be some really good interchange ! d 2 and working relationship with those groups so that the 3 duplication of effort is eliminated as much as possible. 4 It's going to be difficult. I don't know how to 5 do it, but-- 6 DR. STEINDLER: We have.potentially a problem in 7 that area though, Bob, if we are to give independent advice 8 to the Commissioners. We need to be reasonably sure that 9 that is indeed independent advice. 10 MR. BROWNING: No , the kind of thing that I had.in 11 mind was if they are going to be making a trip to the site 12 to look at a particular area and it matches up with an area 13 that you guys are interested in-- 14 DR. STEINDLER: Sure. (" \ ! \ 15 MR. BROWNING: --you know, you could both go at 16 the same--I presume this would be an advantage to DOE. 17 Maybe they'd have different ideas. But I shouldn't be 18 worrying about them. So far, we haven't been called in 19 front of them to talk to them, but I think eventually 20 they'll find out we exist, if they don't already. And 21 Carter obviously knotis we exist, so I can't hide too long. 22 But they'll want to know why we're asking for the 23 things we are, I presume. I was very glad to see the group 24 come into being because if in fact they are able to look at 25 some of the technical aspects of the work, it will relieve Heritaae Reporting Corporation O *
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e 166 L j, ~1- what'I think my staff has perceived to be a burden. 2 They have an addition to worrying about the
~
3 regulatory aspect of the job. .A: lot of.them-are'very i 4 knowledgeable, technical peoplefao they always want to.say,. 5 "Well, gee, isn't there a better way to do it?" Andlthat 6 really isn't our job per se. 7 If the job l DOE is doing will give us the kind of' 8 answers we need, it's none of our business to tell them how 9 to get there. And yet they seem to want to--my staff are 10 always-trying to say, "Well, gee, maybe an automatic boring i 11 machine is better than this." 12 I sense this group is doing that kind of function. 13 So I think that would help a lot to allow me to focus my 14 staff on.what we are supposed to be focusing in on which'is 15 the. regulatory' adequacy of the work. 16 DR. MOELLER: Well,.while you are talking about 17 other review groups, of course, there is the MRS Review 18 Group. 19 Now, have you appeared before them? 20 MR. BROWNING: No, I haven't. But people that 21 worry about the MRS within the NRC have. 22 DR. MOELLER: They have. 23 MR. BROWNING: Yes, sir. Yes, sir. 24 DR. MOELLER: Okay. And I'm not sure I understand 25 too much about that, because when I read about the MRS the Heritage Reporting Corporation O. (202) 628-4808
167 L 1 law statms that you cannot move forward with planning ~on the. Ld 2 MRS until I believe the construction permit.for the 3- repository has been' issued? 4 MR. BROWNING: Yes. There are all kind of 5 restrains on it in the law, but one of the things that-this 6 group would be'doing is if they--I presume that if they 7 conclude that an MRS is in fact desirable, which is their 8 main charter to go back to Congress and tell them what they. 9 think about the need for an MRS.. If there is a need for an
.10 MRS, probably-some of the constraints in'the current law 11 would.have to be changed.
12 HDR'. MOELLER: Okay. 13 MR. BROWNING: The way the law is written right 14 now, it's not at all clear that an MRS does you very much 15 good. 16' DR. .MOELLER: Okay. Other questions or comments?- 17 MR. BROWNING: One other document.I think got 18 distributed to you is a letter we received from DOE on a 19 ' separate subject. Namely, the rule making on what to do 20 about Above Class C Low-Level Waste. 21 They've asked for a meeting to make sure that the 22 office management knows what their concerns are on that 23 proposed rule make. I think this letter flowed out of a DOE 24 hearing, a presentation my staff made to you folks. 25 Actually Research and my staff made to you folks about that A su Heritage Reporting Corporation (202) 628-4888
1]
, '168 g-~ ' 1 proposed rule.- So we are. planning-on'having a meeting.with 2 them at their' convenience. I~think currently it's scheduled
'3 -for April'14th.
1 4 I think the problem flows.from'aibasic ' 5 misunderstanding of what the rule is which hopefully your. 6- comment back to us and what we're doing_to resolve your 7- comment will fix. Namely, we are not requiring that above - 8 cle:ss C low-level waste go 'to the repository.- All we're 9 saying is that would be an acceptable _way. -If there's 10 another way, feel free to propose it. I mean either way we 11 have to license it. 12 From my narrow standpoint, if I' wanted to license-13 one facility, I think I'm better off in having a License 2, l- 14 but--
- O '15 MR. ORTH: I thought I remembered reading in that 16 letter, commenting on their comments though, something to 17 the effect--and this is almost a quote, semi-quote- "that 18 you do interpret us correctly. We do prefer that you do go 19 into the' thing." Which is hardly the same thing as being L 20 ' neutral.
l 21 MR. BROWNING: The rule is neutral. 22 MR. ORTH: The rule. Not the comment just from 23 the letter. 24 MR. BROWNING: In which letter? 25 MR. ORTH: It was a letter from NRC answering Heritage Reporting Corporation O (202) 628-4888 l 1
169 fj S 1 DOE's comments. U 2 MR. BROWNING: No. I think I know the letter you 3 are referring to. This was a letter when DOE sent their q 4 report to Congress saying they couldn't do anything until we 5 gave them regulatory cuidance. We sent a letter saying, 6 " Hey, one of the options you should think about and which 7 fully is acceptable, is putting in the repository." 8 I think that's the letter. Because we never have 9 sent them a letter in direct response to their comments on 10 the rule. Maybe it's in the rule-making package. It may be 11 in the rule-making package. I'll have to take a look at 12 that, because we're trying to avoid either the appearance or 13 the reality of a bias. We're putting it in the repository 14 because it really isn't there. And if they can come up with O
\' 15 something that they think is better, more efficient, a 16 better way of dealing with it, the option is there.
17 DR. MOELLER: Okay. Any more questions or 18 comments for Bob Browning? 19 MS. MOODY: Just a quick question. What's the 20 name of the new DOE Review Group? 21 MR. BROWNING: The Technical Review Board, I 22 believe. 23 MS. MOODY: Okay. 24 VOICE: Nuclear Waste Technical Review Board. i 25 MR. BROWNING: Yes. It was a creation of the last (~s Heritage Reporting Corporation (202) 628-4888 i
170 1 Nuclear Waste Policy Amendments Act. It has.eight members
.O! 2 right now.
- 3. DR. MOELLER: Okay.
4 MR. BROWNING: Once last item. I'm sorry. I am 5 cutting into Dr. Krauskopf's time and I apologize. 6 One of the things we would like to try to arrange 7 with you and schedule is a visit for you down at the Center 8 for Nuclear Waste Regulatory Analysis. I think that would 9 be a much better way of interfacing with them, getting an 10 : idea of what they are doing rather than having a meeting 11 here. I think it would be much.better if we could 12 orchestrate so you actually physically go down there and see 13 some of the things they are doing and get to meet the 14 people. 15 DR. MOELLER: Okay. 16 MR. BROWNING: So 'I'd highly recommend that if you 17 could possibly do it. 18 DR. MOELLER: All right. We'll put it on our 19 future agenda. 20 Any other questions or comments? 21 Well, thank you, Bob. That was very helpful. 22 DR. KRAUSKOFF: Is it all right if I stay on this 23 side? 24 DR. MOELLER: Absolutely, absolutely. 25 DR. KRAUSKOPF: I believe you all have the first Heritage Reporthg g " (202) 628-4888 l
I 171 7 1 momorandum that I wrote and I believe you have received a. 2 second version this morning, so just discard the first one, 3 and the-second version is just.a slight exaggeration of the 4 first. 5 Judith covered the ground pretty thoroughly'this 6 morning and I don't have a great deal to add. I am sure 7 that if she and I would get together, we would find lots of 8 minor points of disagreement, places where our opinions 9 don't quite agree. But I don't think there are major points' 10 of controversy. 11 I tend to take a more charitaLc. attitude toward 12 the proposal or the plan that we have been looking at. I'm 13 afraid.I considered that this was a plan that was to be 14 carried out because-of the opportunity that it would be 15 offered by the construction of the shaft in November, which 16 is planned for November. 17 And so the idea was to put together a plan that 18 could be coordinated with the drilling of the shaft and it 19 might give some useful information. 20 So I am inclined to think that the plan as 21 proposed is a good one. I think the people who put it 22 together have covered the technical parts of it well. I 23 think the plan, as it is proposed, will be difficult to 24 carry out but I think it is feasible and I think the chances 25 of getting useful results are good enough so that it would Heritage Reporting Corporation Os. (202) 628-4888
= _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - _
172 1 be worthwhile ~to try to do it in pretty much the same way O 2 that the plan proposes. 3 'Now,-Judith has proposed a lot of refinements,. 4 which, of course, would make the results scientifically. 5 better. I guess my feeling would be that the plan ought to
- r. 6- las carried out as it is proposed and shouldn't take a great '
7 deal of extra time. , 8 -Then if later it is decided that this kind of an 9- investigation can give really precise information about i 10 water movement, then I think it would be time to go into 11 some of the refinements that Judith suggested. The shaft 12 will still be there. It would still be possible to do some' 13 dry drilling from the surface so that the various 14 refinements about getting more accurately located samples 15 and carrying the investigation on down below the top of the 16 Calico Hills bed could be done later, if it should prove 17 desirable. 18 When I say that the plan is a good one, I think 19 that perhaps the authors ought to have made a little more 20 explicit recognition of just how chancy it is. As far as I 21 know, the Chlorine 36 method has never been used in a 22 situation at all comparable to that at Yucca Mountain. The 23 investigators here are exploring new ground. This is 24 something that has not been done before. 25 There are lots of details that will have to be Heritage Reporting Corporation O (202) 628-4888 1
u ^ 173 1 ' looked at-very carefully. And I think they.ought to be
- 2. aware that. chances are good that the method will really not 3 work as they expect it to. And I think they ought to be 4 ready to abandon it if,~as.they go along,'it looks as if i i 5 they are not getting reasonable results.
6 As I think in a method like this, where.you are-7 looking.at a really new application of science, you have to 8 expect all sorts of difficulties and all sorts of changes in l 9 your plans as you go along. 10 It is particularly important that this method not 11 be looked at as the only method of determining water flow as j 12 was talked about at some length this morning. It will be 13 important to coordinate it with instruments of water 14 movement'from ordinary hydrological reasoning, from Darcy l O 15 flow, from Carbon 14 measurements, from cretium measur ements 16 near the top, which can all give you some idea about water
~17 flow. This is simply one possible method. l 18 The sampling procedure that Judith talked about at 19 great length has some obvious difficulties but it seems to 20 me that it is worth trying as it is suggested.
21 The samples are to be obtained by picking up large 22 chunks from the results of blasting, immediately after 23 blasting. Then treating those samples by using only the 24 interiors which presumably have not been appreciably 3 L l 25 contaminated. Heritage Reporting Corporation A) (_ (202) 628-4888
L 174
. 1- And it seems to me that it is at least possible I
2 that thi's method will work out satisfactorily. l -3 The authors,.I think, have gone-over pretty 4 carefully the various things that may go wrong with this 5 method of getting rock agents and groundwater movement. I 6 wonder if they have given enough thought to the-7 interpretation of the possible results that may come out of: 8 this, as I think it would be a good idea just to sit down 1 l- 9 and think what your reaction is going to be if you should o. 10 find that there is no change in the Chlorine 36 chlorine 11 ratio al1~the way down, or if you find that the change is 12 completely erratic. 13 And what conclusions are you going to draw? I 14 think that would be worth thinking about ahead of time.. A
\/ 15 To come back a moment to.the possible sources of 16 error, one that bothers me is the possibility of confusion 17 of the chlorine that is obtained by leaching with a rock ;
18 with the chlorine that's already in the rock. 19 This was mentioned to some extent this morning. I 20 noticed that it is one of the items on Mel Carter's 21 memoranda about this plan. It disturbs me a good deal 22 because rocks like these tufts at Yucca Mountain I would 23 expect might have a good deal of chlorine that would be 24 pretty easily leached out on contact with water. I believe 25 that Dr. Norris mentioned this mouna 'g that the chlorine in Heritage Reporting Corporation O (202) 628-4888 l __x____________--_-_______ .__- __- _ . _ _ . ___ - . _________-_____-___-______ _ _ Q
1 l'75
,h 1 these rocks is only about 3 parts _per.million. .
.I imagine it' 2 lwould be different in some parts of the tuft.than.others.
3 'That is a pretty small amount. It may be small enough so < L 4 that<you can disregard.it. 51 But I would worry about_-it because'a volcanic , 6 eruption like the ones that-produce this tuft generally are
- j .
'7 accompanied by a lot of hydrogen chloride and gases. .The 8 small inclusions-in many kinds of igneous rock and probably-9 in some of.the shards in the tuft often have quite l 10 concentrated sodium chloride solutions. >>
.11 -Now, the proposal is to grind up this rock pretty
~
12 fine and then to leach it in water to get out the chlorine. 13 I think a good deal of the rock chlorine would be soluble'in. 14 the water'and would be obtained at the same time. . O 15 I should think it would be worthwhile trying some i 16 preliminary experiments on samples of tuft taken from near j 17 the~ surface, say, at a depth of a few meters below.the 18 surface. And just try out this method to see if-it'will ( 19 work. And try different degrees of grinding. Try letting
.20 the water get in contact with chunks of the waste and'then 21 the very finely ground waste, to see what different sorts of 22 chlorine analyses you get from the same rock at different j 23 stages of comminution.
24 Because I think in that way you would get an idea :j 25 whether the rock itself is contributing any chlorine that Heritage Reporting Corporation O- (202) 628-4888
b' 1[ .!. <
.4 176 1.
e might be' disturbing.
.Iq- _) ~
L i. 2 + .The particular difficulty that appeals to me about b '7 p 3 this'possible chlorine in the rock is that if enough is ! o I 4 there to cause trouble, it would make the' rock appear older 5 than it was. And so that would~give.you a false sense of
'6 ' assurance that the~ water movement may have been slower than I' 7 'it actually was. So I think that ought to be looked into
.8 pretty' carefully.
9 The Chlorine 36 that is generated by neutron 10 captured byLChlorine 35 is very commonly cited as one of the 11 difficulties as Chlorine 36 will build up in rock simply l; 12 because neutrons that come from spontaneous fission of 13 uranium or thorium can react with Chlorine 35 to make 14 Chlorine 36. Of course, this is mentioned in the plan. .The A~ I/ 15 authors of the plan are quite aware of this. And they f 16 simply say that the amount of Chlorine 36 so generated can 17 be calculated without explaining how the ca.'culation.can be 18 done. 19 But I believe this morning Dr. Norris told us that' 20 he has good figures on the amounts of uranium, the amount of 21 thorium and the amounts of chlorine in the rocks so that 22 that calculation should be pretty standard. It should be 23 possible. So that that possible interference I think can be 24 handled. 25 The chlorine from explosives. The plan is a I Heritage Reporting Corporation O (202) 628-4888 ] i l 1
i 177 l' little indefinite-on that. I got the impression from 2 reading it that the amount of chlorine in the explosives to 3 be'used is very small, but it can be analyzed for in the
~4~ explosives to start with so that you can get an idea of how 5 much of an interference it might cause. So perhaps this is 6 taken care of.
J 7 The chlorine from the wash water, of course, is
.8 more troublesome. By using the interiors of large rock 9 specimens and by using embronium' tracer added to the wash 10 water, it seems to me there is a good chance that this will 11 be a satisfactory method in determining how much chlorine 12 might be there from the use of the wash water.
13 I believe that the authors of the plan are quite 1 14 aware of the difficulties that may come from the various A kJ 15 routes through which water may descend through the tuft, i 16 Going down, some of the water being evaporated. Some of the 17 water moving up on the parts left behind. The possibility i i 18 of horizontal movement. I think these routes are all pretty 19 clear in the minds of the people who will be working on the 20 plan. 21 And, of course, they have the possibility of l 22 making the water movement very erratic, very difficult to 23 work out even if you do have information from experiments l 24 like these. 25 Now, what sort of results can you expect if you j l I l Heritage Reporting Corporation s (202) 628-4888
l 178 -l 1 -just sit back and think what the water ages are-going to be 2? at different depths in this sequence of tufts? In the very 3 best possible circumstance, the ages will simply get older 4- .as you.go down in the shaft.. Juni at~ the bottom, maybe there j 5 will be ages ~on the order of 100,000, 200,000 years or-l 6 something like that. I
- 7. And maybe there will be a regular succession of !
l 8 ages going down,.and, of course, that would be what you'd i 9 hope for. That would really give you an idea that the water 10 is mcving fairly regularly down and has been for a long 1 11 time, so'it will no doubtless continue to move below the i 12 repository site because in the Calico Hills formation, the i 13 groundwater almost certainly will not move faster than it-14 will in the repository horizon because the Calico Hills l (:) 15 formation.has a good deal of clays and zeolites. 16 So that scenario would make this all worthwhile. 1 17 We would really have one solid bit of information that would : 18 really go far toward qualifying the site. And I think the 19' chance of this result is good enough so that the experiment 20 is worth undertaking. 21 You can think of other possibilities. Maybe at 22 the very bottom of the shaft you will get a sudden upsurge 23 of Chlorine 36 much higher than the meteoric valley value. 24 of course, this would mean that a lot of Chlorine 25 36 has moved down through the tuft very rapidly and would s Heritage Reporting Corporation (202) 628-4888
L 179 1 certainly mean that the chlorine from the bomb tests back in ( ' 2 the fifties was getting down much' faster than it should and 3' .this would probably,.to'most people, really queer the site. 4 That is, if it's going to move.that fast, the sace is just 5 not suitable at all. 6 It would be more difficult to interpret if there 7 is no change in the 36 chlorine ratio all the way down. I 8 That could mean, of course, that the water is moving pretty-9 fast and that at the bottom you are simply getting a kind of 10 chlorine that is indistinguishable on the basis of present -q 11 experimental capabilities from the chlorine at the top. I 12 That is, chlorine might have been moving pretty fast. I 13 But the sensitivity of the method is not great j i 14 enough to detect water that is older than--well, at the 15 ' extreme, 30,000 years. So a uniform age all the way down 16 might mean that the water at the bottom actually has been 17 moving for 30,000 years and that would be slow enough so 18 that the site would still be a good one. 19 So that a uniform composition all the way down 20 would just leave you pretty much up in the air. What could , 21 you conclude? 22 And, of course, I think the most probable result 23 of the measurements is going to be that there will be--I 24 mean if the downward progression of ages is recognizable at 25 all, it will probably be irregular on the way down because Heritage Reporting Corporation O (202) 628-4888 i
180 i
,1 of the different ways that water can move, but in that case
(_/ 2 the results may be pretty difficult to interprot. But 3 still, if there is a general progression down te an age of 4- several hundred thousand years at the bottom,.it would still 5 be a pretty good indication that the general movement is 6 slow. 7 As the authors of the plan recognize, if the water 8 movement has been in pulses at different times, which it 9 almost certainly has been, pulses will tend to smooth out 10 downward so that you may get record of the pulses in the 11 upper part of the shaft, but down toward the bottom they 12 will probably be smoother. This is emphasized in the paper 13 by the U.S.G.S. by Montazor and Wilson which is referred to 14 in the plan which is the best conceptual picture of water 15 movement than I've been able to find. They make this point 16 pretty strongly, that probably the pulsing will be H' 17 detectable in the upper part of the tuft, but will gradually 18 smooth out toward the bottom. 19 Well, these are the various scenarios that I think 20 would be worth some thought. Just how are you going to 21 interpret the results that you may get from this experiment? ! 22 Then just a few very minor points. In the plan 23 there is a suggestion that measurements of the ratio of 1 24 Chlorine 37 to Chlorine 35 might be a possible way to 25 distinguish present day chlorine from the surface from r- Heritage Reporting Corporation (202) 628-4888 , p
i81 1 rainwater from chlorine in the rock. And I believe as part O- 2 of the measurements, the isotope measurements,.that all 3 three of the chlorine isotopes will be measured.
'4 It seems to me that this is a pretty-vain hope.
5 As far as I know, separation of Chlorine 37.from Chlorine 35 6 in nature has been noted in only one paper, which is 7 referred to in the plan, which is a paper on groundwater in 8 Ontario in Canada where there is a large volume of 9 practically static groundwater. Chlorine has b ea moving l 10 through this groundwater largely simply by diffusion. Very
- 11. slow diffusion. And that sort of settle might-give you a 12 separation of isotopes as close together as this.
13 I think that the record of separation of these two 1 isotopes there in Canada was especially favored because it O . 1514 was produced by very slow diffusion through a large volume l' 16 of groundwater which is very different from the situation at 17 Yucca Mountain. 18 Bromine is going to be analyzed by standard 1 1 19 methods, but bromine is going to be present in the parts of 20 the rock that will be leached or samples from which silver j 21 chloride will be precipitated for analysis. Now, of course, 22 any bromide that is still there will come down with the 23 chloride. Silver bromide is just as insoluble as silver j i 24 chloride. 25 If the water has any sulphate, the solid Laritage Reporting Corporation (202) 628-4888 i 1 E- - - -- - - - - - - _--_--_--____--__J
p 182 I 1 precipitate-might even be. contaminated with. silver sulphate. O '2- Which is-fairly insoluble.
-3 I don't think that either sulphate or bromide 4 would interfere with the ultimate analysis for Chlorine 36 5 but it might be worthwhile just'to keep that flagged and 6 make sure that they will not interfere because the chloride 7 'will not be there by itself.
8 Well, I think that's probably enough. I 9 DR. MOELLER: I think that's very good. I 10 Do we have questions or comments on Connie's 11 presentation? 12 Well, it was obviously very clearly presented, and 13 you had given us the write-up earlier,-so that's very l 14 helpful. ! 15 Well, if there are no comments then, I think with 16 that we probably can bring our formal portion of our 17 Committee meeting today to a close. 18 We will immediately follow this with a break and 19 then we'll resume in Executive Session. Any members of the 20 public who are here are welcome to stay. 21 (Whereupon, the proceedings were adjourned.) 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
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l l 1 CERTIFICATE j dr 2 i
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3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the_ matter 5 of: ADVISORY COMMITTEE ON NUCLEAR WASTE 6 , Name: 8th ACNW MEETING 7 8 Docket Number: , 9 Place: Bethesda, Maryland 10 Date: Thursday, March 23, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the O 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/ \ )u /d4ful 19 (Signature typed) : l 20 Official Reporter 21 Heritage Reporting Corporation 22 23 I 24 l 25 1 1 O rie. ,orei , cor or eiem (202) 628-4888
N A L P E Y T S D A U W T T N T N E R S E M M A F E E E G G A L O A N N A C S A O U YM H M G E RT T N U CE NT E S N N T AS RA N E A F W OO A M U BW OE I E T O SE EV TI V NT TE S C CT NC Y I O EC AT E A R G MA T O T NI T D O R I CO S DN I E N I RD A P A EM B O E AE E R DN SM E A J G RF NO O D AT A R S. IL UI V PC W N A NILN AI E I C Y E H GIV M NCT 7 F R I 4 V P I O TF R 2 O E I S OA P 9 E R 6 IC S T ,EE 8 FCD E 5 I F F V S EI I F .
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o BRAFT G Q TABLE OF CONTENTS 1 Introduction
1.1 Background
1.2 Purpose and Scope
j i 2 Summary of Quality Assurance Controls Applied to Study Plans l 2.1 Derivation of Required Controls from the Yucca j Mountain Project Quality Assurance Plan 2.2 Implementation of Controls in the Current Program l 2.2.1 Yucca Mountain Project Office Procedures 2.2.2 DOE Headquarters (OCRNM) Procedures 2.2.3 Participant Procedures 2.2.4 Sumary of the Adequacy of current controls 2.3 History / Evolution of Quality Controls for Study Plans 2.3.1 Yucca Mountain Project Quality Controls 2.3.2 DOE Headquarters (OCRNM) Quality 2.3.3 Participant Quality Controls
, 3 Evaluation of the Five Exploratory Shaft Facility Study Plans 3.1 Description of the Reviews 3.1.1 Excavation Investigations 3.1.2 Water Movement Test 3.1.3 Characterization of Percolation in the Unsaturated Zone - Exploratory Shaf t Facility Studies 3.1.4 Characterization of Structural Features in the Site Area 3.1.5 Characterization of Site Ambient Stress Conditions 3.2 Evaluation of the Adequacy of the Quality Controls in Place During the Review and Approval of the Study Plans 3.2.1 Evaluation of the Requirements for Control of the Study Plan Process 3.2.2 Deficiencies Identified in the Study Plan Process 3.2.2.1 Yucca Mountain Project Controls 3.2.2.1 DOE /HQ (OCRWM) Controls 3.2.2.3 Participant Controls 4 General Sumary O)
( 4.1 Conclusions
, 4.2 Recommendations '
E T S A N W A L S P T 1 E S H R 1 Y E E T E A D T U T T I T S U O C L S NE E S T U T , E M T E A E I N I Y C U 2 W- S V O D O N S 1 EN M M O S E V 2 3 I VO Y
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SCHEDULE AND OUTLINE FOR DISCUSSION 8TH ACNW MEETING MARCH 23, 1989 BETHESDA, MARYLAND 1 (Revision 1) Thursday: March 23,1989, Room P-110, 7920 Norfolk Avenue, Bethesda, Maryland 8:30 - 8:40 a.m.. I I. Chairman Comment's (,0 pen) L 1.1) Opening Remarks 1.2) Items of current interest 8:40 - 10:00 a.m. 2. DOE Discussions of Site Characterization Study Plans' (OSM)
-10:00-10:15 a.m. ***** BREAK *******
10:15-12:00 Noon 3. Discussion led by ACNW Consultants M. Carter, K. Krauskopf and J. Moody on ESF Study Plan for study 8.3.1.2.2.2 re: Water Movement Tests (OSM) O 12:00-1:00 p.m. ***** LUNCH ****** 1:00-5:00 p.m. 5. Administrative Session to include: FutureSchedule(0 pen)
- Membership (Closed)
ACNW discussion of a possible report related to the repository development schedule, implementation of Study Plans and resolution of critical issues, etc. (0 pen) ACNW planning its review schedule for the SCP/SCA including additional meeting dates,consultantsandtopics(0 pen)
- Possible discussion of ACNW response to letters to the Comission concerning the ACNW position on the elimination of Section 20.205 from the proposed revision -
to 10 CFR Part 20 (0 pen) O 5:00 p.m. ADJOURN I
r i Depadment cf Energy. WaaNngton, DC 20555 i. MAR 7198S q k> Er. Robert M. Bernero, Director Cffice of Nuclear Materials Safety 's and safeguards U.S. Nuclear Regulatory Commission Washington, D.C.' 20555 , near Nr. Berneros on Augusten 30,the 1988, the Department of10 (DCE) Energy,Part submitted:its 61, published comments preposed anendment to CFR on May 18, 1988, concerning the definition of high-level waste (HLW) and disposal of greater-than-Clas s-C waste (GTCC) . Based l en the recent Nuclear Regulatory Corzis.sion (NRC) staff presentation before the Advisory Cerrittee on Nuclear Waste, the i off1ce of civilian Radioactive Waste Management (OCRUM) is concerned that fav, if 'any, of the DDE reco==endations and , corrents were adoptsd by the NRC staff in preparation of the l final rule. We need tc understand the reasoning behind the final
' rule as it could impact many arsas of the CCRWM geologic repository progran, as yell as affect other DOE programs.
In our corrents transmitted en August 20, 1968, an opportunity Qvas'requestedtodiscuss'theapplicabilityoftheexistingrepository technical the disposal of GTCc wastes in a repository. such a discussion
- would allow DOE to gain an understanding of the considerations which guided devoleprent of the final rule and assure us that the NRC fully understands the potential cost, schedule and technical implications of its proposed action. .
Th9 tepics identified below are of particular concern to CCRWM with regard to the impact on repository development. ' 1. If the NRC intends to suggest in the final rule that GTCC wastes be disposed of in the repository, DOE needs to understand why NRC believes it is ne:essary to include this in the final rule. The alternative is to specify irrespective of requirements for disposal destination, to allow later determ of GTCC,inations as to the most effective nethod for meeting those requirements.
- 2. FRC appears to have aba.ndoned its efforts to define HLW based on its radiological characteristics. DOE has stated a preference for this risk-based approach and needs to understand the NRC's position.
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0 The introduction of GTCC waste in the waste nahagorent e systou 3. portends potential changes.to technical criteria, performanc objectives and environmental standards for the geologic - repository (e.g., wasta package bas.is forcriteria, testing, repository and risk surface and subsurf ace design criteria,isposal costa. assessnent basis), as well as d 4. The NRC staff has based estimates of GTCC volumek on it aThis report February 1987 LOE report (ECE/NE-0077) .
". . . the Depart cnt identified several f actors that ra e impossibis to reconmend spccific fnderal or nenfederal disposal options at this time"r DOE still believesincluding, that tha "Inade GTCC icw-layel vastes. . . ."
uncertainty in the estimates of GTCC waste voluna preclude selection of c disposal option. i ith I would appreciate the opportunity to discuss these iled top cs wThe . you at your earliest convenience. t on the deta straightforward as they may appear and deserve licy more Act,
~ discussion and consideration with respect to their inpac geologie repository program under the Nucinar Waste Po, as amended. f at Pleasecontactneat5B[-6842,orRalphSteinofmystaf
(])586-6046, agreeable time for us to raet on this topio. -
' sin ~erely,
- acue ounse, Acting Director .
ffice of civilian Radioactive Wasta Management
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- 3. J. Youngblood, WRC J. Linehan, NRC R. Leux, State of Nevada D. Bechtel, Clark County, Nevada M. Baughman, Lincoln County, Nevada S. Bradhurst, Nye County, Nevada .
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Ca? UNITED STATES f, . o,, g NUCLEAR REGULATORY COMMISSION VWASHINoToN. D. C. 2o655 p MAR 011989
/
Mr. Sam Rousso, Acting Director
~ Office of Civilian Radioactive Waste Management U.S. Department of Energy Washington, D.C. 20545
Dear Mr. Rousso:
On December 28, 1988 the U.S. Department of Energy (DOE) transmitted to the U.S. Nuclear Regulatory Commission (NRC) the Site Characte for the Yucca Mountain site. SCP (i.e., the Exploratory Shaft Facility (ESF) Design Acceptability Analysis (DAA) and the five study plans on ESF construction-phase testing) were not provided at that time, we began our acceptance reviewBased of the upon SCP on Jan 1989. On February 9, 1989 we received the outstanding documents. our previously completed examination of the SCP and its references, and uperl ' our more recent examination of the contents of the DAA, We are we are now able to therefore
~ conclude that the SCP is acceptable for further review.
proceeding with that review. ! 31, 1989, we In our letters to you dated January IS,1989, and January f indicated that the delay in submittal of the.SCP key supporting documents af
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the corresponding delay in completion of our acceptance review Despite that delay,could we impact oul
' - overall schedule of seven months to complete our SCA. i intend to make every effort to complete the SCA on our original schedule, w j had the review beginning on January 2,1989, and the SCA being transmitted We recognize that beginning ESF construction is on the DOE on July 28, 1989. ; critical path of your current site characterization schedule and will bring any +
3 ESF-related concerns to your attention as soon as they are identified. 5
- There schedule.
are, however, two matters that have the potential lt l If major concerns with the DAA are identified as a j to conduct in mid-April. N 3 result of that audit and of our coincident detailed rev affected until those concerns are resolved. The second item that could impact our SCA At the schedule ESF-related December 15, 1988 study plans that were sent to us on February 9, 19 not start our' review of those five study plans until DOE provided an evalua ;
- supporting that they are of the same technical quality as if they haI ;
prepared under a QA level I program. We cannot begin our review of the ~ but we have not yet received that document. study plans until we receiveBecause DOE's the evaluation content of confirming the study plans that is the study are ready to be reviewed by NRC. 6 directly related to the ESF design in the SCP, comments on at least the pol
; of the SCP involving the ESF design might be delayed until the study plans c
~~ l be reviewed.
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- Mr. Sam Rousso-Should either of these two matters or any unforeseen factors force us to reexamine our SCA schedule, we will immediately not.ify you.
If you have any questions concerning this letter, please call me (492-3352) or J. Linehan (492-3387). Sincereiy,
- Robert M. Bernero, Director Office of Nuclear. Material Safety and Safeguards 1
f* i, ! J j O , i l
l 1 i C i; i m i._ r,.,im iu ,,,a,, bd 24 Ni .1 p.1% (lwo
% k,w Iwhn..l.p Pubimhmg Editorial Searching for new levels of confidence The recent revision of the radiation induced carcinogenic risk estimates based on the Japanese aton+ic bomb survivors are about a factor of ten or more greater than those used by ICRP in recommending dose limits for workers and members of the public. Except possibly for leukaemia, the increase in the risk estimate is not so much due to revised dosimetry but due to different methods of extrapolating the risks over a lifetime and the increased number of excess cancers observed in the survivor population since the major UNSCE AR review in 1977.
The dose effect relationships for the excess cancer mortality in the survivors are more linear than previously consiered and carrespond to a similar linearity in the dose-effect relationship for treast cancer arising from irradiati o~;! r medical diagnosis. Hence, the extrapolation from the high dose, high dose rate exposures of the survivors to the low dose, low dose rate exposures characteristic of normal worker exposures can no longer invoke a redtaticin based on considerations of a non linear dose-effect relationship. sonetimes used previously in justification, but must invoke dose rate considerations"'. It has generally been accepted abet it;ducing the dose rate of low LET radiation reduces the carcinogenic potential by factors of between 2 and 10';l However, this has only been extensively demonstrated in ene species, the mouse, although evidence from other species suggests that similar dose-rate reduction factors apply and this is supported by investigations of the responses of cultured cells in ritro. In anticipation of the probable ICRP reaction to the increases in risk estimates, authorities in both Europe'W and North America'" have suggested either that dose limits should be reduced or that worker b] exposures should be managed in such a way as to reduce the average annual exposures below those of the present annual dose limits. The reduction factors proposed are in the range 3 to 5. Some sections of the public and of the scientific community have expressed criticism that these factors are too small and argue that no allowance should be made for a dose rate reduction factor. If it is considered important to increase confidence in this factor then further animal experiments are required. These experiments would need to ! study the effects of dose rate on radiation induced carcinogenesis oser the lifetimes of the animals. Such l experiments could also help to verify the important hypothesis advanced by Storer, Mitchell and Fry *. This ' hypothesis is that multiplicatis e (relatise) risk factors can be extrapolated across mouse strains and to other species including man. If this hypothesis is correct. it represents a major advance towards understanding radiation carcinogenesis and its verification would be a major step towards establishing confidence in radiation risk estimates. J A Dennis Editorial Board Member
- 1. Stather, J. W., Muirhead. C.. Edwards. A. A., Hamson. J. D., Lloyd. D. C. and Wood. N. Heahh Effects Models Des elopedfrom the IVM UNSCEA R Report. National Radiological Protecnon floard Report R226 09M).
- 2. NCRP. Inpueme of Dme and as Disinhution in Time on Dose-response Relationships for Low-LET Radianons.
National Council on Radiaiton Protection and Meawrements Report No M Washington (198n). 3 NRPB. Interim guidance on the Imphcatums of Recent Res isions of Rhk Esnmates and the (CRP 1987 Como Statement. National Radiological Proicetmn Board Report GS9 (1987). LBGA. Argumente far eme Neufestlegemg des Gren:wertes fur berupsch strahlenexp<mierte Pers: men Bundesgesundheitsamtes November 1987. l
- 5. Anun. Sweduk Natwnal Instaure of Raduatwn Protecnon suggests amended dose hmits. Statens Stralskyddmstitut March 192.
6 NCRP. itecommendatums on Limus for Expmure to lonising Radsation. Nationat Council on Radsunon Protection and Measurements Report No. 91. Bethesda (1987). 1 Starcr, J. B.. Mitchell. T. 3.. Fry. R.1. M. Extrapolation of the Relative Rusks of Radrogenic Neoplasms across Mouse brains and to Man Radiat. Res. Ilt 331-353 09M) (% (,/ l
I l 1 l (~)
\J l
j i ADDITIONAL KEY REFRENCES l l Drez, P., D. Meyer, C. Cravatto, J. Tyburski, and J. Pearson,
SUMMARY
REPORT OF POTENTIAL METIIODS FOR SP.LT REPOSITORY PROJECT GEOCllEMICAL SAMPLING, SAMPLE PRESERVATION, AND ON-SITE ANALYSIS. Final Report, Intera Technologies, Inc., Austin, TX, August, 1987. Elnore, D. and F. M. Phillips, ACCELERATOR MASS SPECTROMETRY-FOR MEASUREMENT OF LONG-LIVED RADIOISOTOPES, Science, 216, 543-550, 1987. ()
\. Phillips, F. M., J. L. Mattick, T. A. Duval, D. Elmore, and P. W. Kubik, CHLORINE 36 AND TRITIUM FROM NUCLEAR WEAPONS FALLOUT AS TRACERS FOR LONG-TERM LIQUID AND VAPOR MOVE}ENT IN DESERT SOILS, Eater Resources Research, 2.1, 1877-1891, 1988.
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