ML20203E994
| ML20203E994 | |
| Person / Time | |
|---|---|
| Issue date: | 07/22/1986 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| ACRS-T-1534, NUDOCS 8607300064 | |
| Download: ML20203E994 (416) | |
Text
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ORIPINAL O UNITED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO:
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON WASTE MANAGEMENT O
LOCATION: WASHINGTON, D. C. PAGES: 1- 291 DATE: TUESDAY, JULY 22, 1986
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() PUBLIC NOTICE BY THE UNITED STATES NUCLEAR REGULATORY COMMISSIONERS' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
TUESDAY, JULY 22, 1986 The contents of this stenographic transcript of the proceedings of the United States Nuclear Regulatory Commission's Advisory Committee on Reactor Safeguards (ACRS), as reported herein, is an uncorrected record of the discussions recorded at the meeting held on the above date.
No member of the ACRS Staff and no participant at
), this meeting accepts any responsibility for errors or inaccuracies of statement or data contained in this transcript.
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59700101 1 marysimons UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3
4 5
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 WASTE MANAGEMENT SUBCOMMITTEE 7
8 Nuclear Regulatory Commission 9
Room 1046 1717 H Street, N.W.
Washington, D. C.
10 Tuesday, July 22, 1986 11 12 The subcommittee convened, pursuant to notice,
() 13 at 8:30 a.m., Dade W. Moeller, Chairman of the Subcommittee, 14 presiding.
15 16 ACRS MEMBERS PRESENT:
17 D. MOELLER W. KERR 18 J. C. MARK F. REMICK 19 20 ACRS CONSULTANTS PRESENT:
l 21 a srs1xonsa D. ORTH 22 M. CARTER l ACRS COGNIZANT STAFF ENGINEER:
O. MERRILL
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~59700101 2 marysimons 1
NRC AND INDUSTRY PRESENTERS:
2 J. LINEHAN 3
J. BRADBURY P. JUSTUS 4
D. BROOKS P. WADE 5
J. PARRY 6
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59700101 3 marysimons O 1 PR0CEEDINGS 2 MR. MOELLER: The meeting will now come to order.
3 This is the second day of a three-day meeting of 4 the ACRS Subcommittee on Waste Management.
5 Today we are going to be covering the following 6 topics: (1) sorption and solubility, generic technical
, 7 positions and draft letter report on the sorption workshop; I
8 (2) the Division of Waste Management's five-year plan; (3) 9 the NRC proposed federally funded R&D center; and, lastly, 10 the status of the NRC review of DOE's final environmental 11 assessments for the candidate repository sites nominated for 12 site characterization.
j ( 13 I am Dade Moeller, the Subcommittee Chairman, and 14 we have joining us today Forrest Remick and William Kerr, 15 '
l members of the ACRS, and we anticipate that Carson Mark will 16 join us shortly.
I 17 Our team of consultants consists of Melvin Carter, 18 Donald Orth and Martin Steindler. We also have with us Jack 19 Parry, Senior ACRS Fellow, and seated on my right is Owen l
l 20 Merrill, the assigned ACRS Staff member for the meeting.
21 I believe we will move right into the meeting l
22 then, and we have the NRC Staff here with us to begin the l
23 discussion of, according to my agenda, the discussion of the 24 first item which once again will sorption and solubility, 25 generic technical positions, and the draft letter report on O
i l
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i 59700101 4 marysimons 1 the sorption workshop.
2 I understand that John Linehan will be the MC for 3 this portion of the program.
4 John.
5 MR. LINEHAN: Thank you, Dade.
6 We are going to start today with a discussion on 7 two generic technical positions in the geochemistry area, as 8 Dade as indicated, one on solubility and the other~on 9 sorption.
10 I am on this handout right here, this very thin 11 one.
12 The briefing on the GTP's is going to be given by
() 13 John Bradbury of our Geochemistry Section.
14 Prior to him giving that briefing though, we are 15 going to have a very brief overview of the geochemistry 16 program. Phil Justus, who is sitting directly to my left, 17 is the Acting Branch Chief of the Geotechnical Branch, and
! 18 he will be giving that overview.
I j 19 Before he does that, I would just like to say a 20 few words from an organizational and programmatic standpoint l
21 how the geochemistry program fits into the overall high-22 level waste program.
l l 23 If you could turn to the first slide there.
1
! 24 (Slide.)
l 25 I am not going to spend any time on this 73
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O 1 organizational chart. You have seen it many times, but just 2 to point out that within the Division in our matrix 3 organization the Geochemistry Section is located in the 4 Geotechnical Engineering Branch.
5 The Geochemistry Section, like all of the other 6 technical sections, supports the three main program areas, 7 the high-level waste area, the low-level waste area and the 8 uranium recovery area.
9 In the Geochemistry Section we have seven 10 professional staff members, and the way we handle the work 11 in the high-level waste area is that we have three teams.
12 Each team is dedicated to one of the sites being pursued by
-( ) 13 DOE for the first repository.
14 On each one of these teams we have a lead .
15 geochemist who is based up by the other geochemists in the 16 section. That is for the site specific work.
17 For the generic work, the different activities are 18 divided up among the geochemists in the section, and most of 19 these generic activities are contributed to by more one of 20 these individuals. 9 14' 21 Just to give you a little perspective ---
22 MR. STEINDLER: Before you leave that, how many 23 ge,ochemists do you have among that seven staff in the l g 24 GefochemistrySection?
a
,g 25 MR. JUSTUS: Six of the staff are geochemists, and k_/
7 9
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59700101 6 marysimons 1 the Section Leader is a chemist.
2 MR. MOELLER: Another question that is sort of a i
3 sidelight, but one of interest to the subcommittee, what 4 percent of your effort at the present time is on low-level 5 wastes versus high-level wastes, or are you totally high 1
6 level?
i
- 7 MR. LINEHAN
- Well, I am totally high level.
8 Looking at the total staff for the Divicion of 148 staff, l
j 9 approximately two-thirds of those are high level and one-10 third is low level.
11 Now at the present time though one of the beauties ,. (
12 of the matrix organization is that as priorities shift, we
() 13 can shift from one to the other. Right now I think it is 14 more of a 50-50 split if we were looking today due to the
{ 15 number of activities in the low-level area resulting from 16 the passage of the Act last year, and this is going to ,
i l 17 change over time. When the SCP's come in, we are going to 18 see a peak in the high-level.
19 MR. MOELLER: Thank you. That is helpful.
l 20 (Slide.)
1 21 MR. LINEHAN: If you would turn to the next slide, 22 just to give you a little perspective on our technical 23 assistance budget and the amount devoted to our 24 geochemistry.
6 25 We have got an overall budget of approximately O
I ACE-FEDERAL REPORTERS, INC.
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.V 59700101 7 marysimons O 1 Now a certain amount of this, if you look at
$7.5 million.
2 that note, is going to be dedicated towards the start-up of i
3 the FFRDC, which is the federally funded Research and 4 Development Center that we will briefing you this afternoon.
5 But looking at the $6.8 million, you can see from 6 this pie chart that approximately 18 percent of our 7 technical assistance budget is dedicated to geochemistry.
8 I am presenting this really just for your 9 information. If you have any questions, we would be glad to 10 go into them and respond to them.
11 MR. MOELLER: Excuse me. Now you mentioned the 12 total budget and you mentioned that some of that will go to
() 13 the startup of the FFRDC. Where does the money for the 14 FFRDC come from?
l 15 2 '
MR. LINEHAN: It is out of our total technical 16 assistance budget. The total is $7.5 million, and typically 17 that would be divided amongst the various contracts that we l
18 have. We have set aside some for startup for a phase-in of 19 the FFRDC.
20 MR. REMICK: So this $7.5 million is just for -
b:i' 21 technical assistance, and it is not research or not internal 22 costs.
23 MR. LINEHAN: Just technical assistance, that is 24 correct, just contractors that support the Division of Waste 1 25 Management staff.
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m) 1 MR. PARRY: John, excuse me. As you get the FFRDC 2 ongoing, what fraction of the technical assistance work 3 woult you expect that FFRDC will pick up?
4 MR. LINEHAN: Ultimately the majority of the work 5 will be with the FFRDC. The folks that are going to give 6 the presentation this afternoon could give you specifics on 7 that if you are interested.
8 MR. MOELLER: So if the budget continued, the 9 technical assistance at $7.5 million, you are saying a large 10 portion of that would be assigned to the FFRDC7 11 MR. LINEHAN: Yes, and there is going to be a ..,
12 gradual phase in.
O 13 MR. JUSTUS: All of the geochemistry work that we k._/
14 i have in place now devoted to the high-level waste program, 15 which is divided between Oak Ridge Laboratories and Sandia 16 Laboratories, will become folded into the FFRDC.
17 (Slide.)
18 MR. LINEHAN: If you could turn to the next sheet, 19 this is just information for you to give you an indication 20 of the different contracts we have within that technical 21 assistance budget in the geochemistry area.
22 And, again, if you would like an explanation of 23 any of them, we would be happy to go into them.
24 MR. MOELLER: Well, roughly, how much money then 25 are you talking about that would be pulled out of ORNL and O
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1 be pulled out of Sandia ultimately, presuming that neither 2 of them is the FFRDC7 .i 3 MR. LINEHAN: We really can't answer that at this 4 time. We don't have a good answer. You know, the FFRDC was 5 set up to give us long-term continuity and avoid the 6 conflict of interest. There may be contracts that remain 7 that can meet that criteria. It is something that hasn't 8 been determined at this point in time really.
9 MR. JUSTUS: Presently though we are talking about 10 a $500,000 annual budget for geochemistry technical 11 assistance.
12 MR. PARRY: Won't that really depend, John, on who
()
13 the FFRDC contractor is?
14 / MR. LINEHAN: Yes, right.
l (
15 MR. PARRY: And that could be a wide mix.
- 16 MR. LINEHAN: Yes, where their areas of specialty 17 are. You know, they are going to have to have broad j 18 l coverage, but it is going to depend on the contractor, and 19 also some of the long-term technical assistance we have had, t
l 20 if people can meet that criteria for conflict and guarantee 21 some type of continuity.
22 If there a"e no other questions, I would like to 23 turn the presentation ever to Phil Justus, l
! 24 MR. CARTER: Let me just ask one thing. It is l
l 25 indicated that the contractor for the new center might be i
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1 Sandia or ORNL. I would assume it wouldn't be a national 2 laboratory.
3 MR. JUSTUS: I think you are correct.
4 You didn't say that they would be, did you?
5 MR. MOELLER: The implication was there that it 6 might be one of these. So that is good to have that answer.
7 Go ahead, Phil.
8 MR. JUSTUS: It has been more than three years 9 since the geochemists in the Commission staff have presented 10 a position and asked for your feedback on that position.
11 As you may recall, the last opportunity that we ..,
12 look was with regard to the site characterization analysis (1 13 that BWIP developed in 1983.
14 We have a lot of geochemists in support of this 15 presentation, aside from John Bradbury, to my left. His 16 section leader, Ken Jackson, is present and the various 17 geochemists who are leads for the high-level waste sites, in 18 addition to some new geochemists who are experiencing an 19 ACRS subcommittee meeting for the first time.
20 This morning we do want to concentrate and 21 emphasize our positions on what we expect DOE to undertake l 22 should they elect to determine the solubility and sorption 23 of radionuclides.
24 The DOE has determined, and we agree with them, 25 that solubility and sorption are the principal mechanisms or l O l ACE-FEDERAL REPORTERS, INC.
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59700101 11 marysimons (3
V 1 processes by which radienuclides are transported from the 2 source in the waste package through the engineered barrier .i 3 system and into the rocks.
4 (Slide.)
5 The first slide in this group here called 6 "Importance to Geochemistry" summarizes the principal 7 groupings of issues or technical concerns that the 8 geochemists in DOE and NRC are dealing with.
9 We would like to focus on two aspects of the 10 geochemistry program, that is, what is the chemical 11 environment of the waste package and how will radionuclides 12 be transported beyond the waste package towards the
() 13 accessible environment and, conversely, how might they be 14 retarded during that transport phase.
15 Close in to the source in and around the waste 16 package, the concentrations of radionuclides are at their 17 highest. As time goes on, the concentrations will diminish 18 perhaps by dispersal, too, during transport.
19 The solubility of the radionuclides appears to be 20 most important close in to their source where the -
c.
21 concentrations are highest.
22 The sorption of radionuclides is important further 23 out where the radionuclides are encountering minerals in 24 pores and fractures in rocks.
7-25 The performance of a repository is measured i
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a 59700101 12
.marysimons 1 ultimately as to whether the' releases of radionuclides from 2 the repository would meet the EPA standards or the NRC l
3 standard for release at the engineered barrier.
4 Knowledge of solubility and sorption of those 5 radionuclides that must be measured against the EPA 6 standard, as DOE has already told us, are a large part of 7 the geochemistry investigation prograu.
I 8 There are potentially favorable and adverse 9 chemical conditions at the sites that also must be j
10 investigated and factored into the design of the waste
! 11 package, and an evaluation of measures that might mitigate, ,
12 for example, unfavorable characteristics.
13 (Slide.)
[ 14 The geochemistry issues on the next viewgraph 15 serve simply to categorize the kinds of matters we interact 16 .with DOE on.
17 Principally we want to identify early on what 18 information DOE will need to collect about the environment 19 of the waste package, and in order to describe the behavior i
20 of escaping radionuclides over a 10,000 year period.
l 21 The present site chemical conditions is being 22 discussed in the context of site characterization. DOE does 23 have plans that they are in various stages of developing and i 24 revealing to us and discussing with us regarding site 25 characterization to investigate geochemical parameters.
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g 59700101 13 marysimons O 1 The changes in site chemical conditions due to 2 emplacement of wastes also needs to be developed by DOE and .I 3 that is the information that DOE would need to use to make 4 projects over a long time frame as to what, if not where, 5 various radionuclides will be at the end of the first 10,000 6 years.
7 (Slide.)
8 We interact with DOE through a series of 9 meetings. On this next viewgraph we have enumerated just a 10 list of the kinds and dates of activities or interactions we 11 have had with DOE since our geochemistry program was 12 established.
() 13 We have been striving to streamline, or help DOE 14 streamline its geochemistry data gathering process by 15 meeting with them and giving what we hope is constructive 16 feedback on their programs and publishing our feedback. We 17 call that guidance.
18 We have established a record of input to DOE on 19 what aspects of their geochemical program is perhaps 20 deficient in one area or another.
c 21 With regard to the important matters of 22 determining solubility and sorption, we have focused our 23 guidance in two documents that will be described or 24 summarized shortly. I 25 MR. CARTER: I have a question about your O l ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coserage 800-336-6M6 i
59700101 14 marysimons O 1 meetings. Are all of them in the local area or are some of 2 these at potential sites?
3 MR. JUSTUS: All of those that are site related, 4 labeled as NNWSI, BWIP or Salt, have been conducted at the 5 out-of-town DOE project sites, principally at Richland, Las 6 Vegas or Los Alamos and Columbus.
7 Those that deal with generic matters where 8 headquarters staff, DOE headquarters staff is involved have 9 been in town. These are all noticed on the 800 line for DOE 10 and NRC states and tribes are given on advance notice in 11 writing. ,
12 MR. LINEHAN: For the overall program I think we O(_/ 13 are running about 75 percent of the meetings are out at the 14 sites and we are trying to up that to get better state and 15 local tribal involvement in the meetings.
16 MR. MOELLER: On a typical meeting, are long are 17 they and how many people are there for each of the parties?
18 MR. JUSTUS: They will run two days, and we will 19 have, including our contractors and staff on the site teams 20 that are not geochemists but have a strong interest in the l
1 21 discussions, such as hydrologists, waste package materials 22 scientists and project managers roughly I would say 8 to 10 23 staff and contractors.
24 MR. MOELLER: Thank you.
25 MR. STEINDLER: That is from your side?
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59700101 15 marysimons 1 MR. JUSTUS: That is from the NRC's side, yes.
2 MR. STEINDLER: And there is another twice that .i 3 from the other side?
4 MR. JUSTUS: There is another 10 or -more from the 5 DOE side and approximately the same from states, tribes and 6 various interested parties.
7 MR. MOELLER: Carson, did you have a comment.
8 MR. MARK: I was wondering if you are in full touch 9 with the experience of the Los Alamos people and perhaps 10 Livermore as well on the actual transmigration of products 11 from the site of an explosion to another site nearby?.
12 MR. JUSTUS: Well, we are aware of work that has o
\_) 13 been done, specifically the ruthenium that has been 14 documented in the literature. More particularly, I might 15 defer to the geochemists who ---
16 MR. MOELLER: What this relates to the 17 subcommittee and the full committee, I am pretty sure~, in 18 several commentaries over the past couple of years has 19 suggested from time to time that there might be data and 20 information from the Nevada test site'that if nothing else e
21 would help in the evaluation of the proposed Tuff 22 repository.
23 MR. MARK: That's the kind of question I was 24 trying to raise.
25 MR. MOELLER: Could we have a comment from some of r
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I the geochemists?
4 2 MR. JUSTUS: Well, Ramspot's work, for example, is 3 known to us. We don't directly contact the DOE, or the NTS 4 side of DOE. We have asked DOE staff at Nevada to do that 5 also through their Los Alamos contractors.
6 MR. LINEHAN: Do we have a Nevada geochemist here?
7 MR. BROOKS: David Brooks. That's John, but he 8 has just taken over that position. The one article that we 9 are most familiar with is that by Aramafy Gold, or Gold 10 Aramafy. Other than that we are aware of, but we haven't 11 been really active in trying to pry that information out at ,
12 this point.
() 13 MR. MARK: But are they not the only direct 14 evidence that there is around on this sort of subject?
15 MR. BROOKS: I would agree with you, and we will 16 be looking at it.
17 MR. MARK: I believe you should.
18 MR. MOELLER: Owen Merrill reminds me, Carson, 19 that you did provide us several reports on this several 20 months ago and he passed them along to the RES staff, 21 particularly Mr. Costanzi.
22 MR. KERR: The language used by the commentor 23 would suggest that he expects difficulty in getting the data 24 from DOE. Is that the case?
25 MR. MOELLER: I hope not. Could we clarify that?
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9F 59700101 17 marysimons O 1 MR. BROOKS: It is my understanding that that is 2 Defense Department Information. Our experience at this M 3 point has been that it is more difficult to get that 4 information than other information.
5 MR. JUSTUS: We have had difficulty ---
6 MR. MARK: It doesn't sound as if DOE has it 7f either.
8 MR. BROOKS: I don't know. We really have to look 9 into it. One of the things that this relates to is our 10 interest in looking at field analogues, national analogues 11 versus something more like this which would be maybe 12 considered a mandate analogue of radionuclide release.
() 13 So this is an area again that we will be looking 14 into, i
k 15 MR. CARTER: A lot of this data, by the way, Dade, 16 has been published. Although DOE is obviously involved, a 17 k lot of it has been put out by the Geological Survey and so 18 forth.
19 MR. LINEHAN: I think we agree with your point.
]
20 We are at aisadvantage where the team member that has been 21 working on Nevada is not here today. We may indeed have an 22 activity going on in that area. We can get back to you and 23 let you know of anything specific, but we agree with the 24 poin t you are making.
25 MR. MOELLER: Make a note of that, Owen, because ACE-FEDERAL REPORTERS, INC.
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v 1 the question keeps coming up and it would be nice to pin it 2 down.
3 So, John, yes, if you could provide a follow-up on 4 that it would help us.
5 MR. LINEHAN: In fact, Linda Kovach, and she 6 recently transferred to our research group, she was the lead 7 geochemist on Nevada, and she will be giving a presentation 8 tomorrow on the research program. I will get with her 9 before that and ask her to specifically address that point 10 to let you know what we have been doing.
11 MR. MOELLER: Fine. ,
12 (Slide.)
() 13 MR. JUSTUS: We have over the years developed a 14 list of guidance documents that have various forms. Some of 15 them are contractor reports on various topics. Some of them 16 are our positions and comments on important DOE documents 17 that bear on geochemical matters.
18 They are enumerated here just for your 19 information. These are available to you on request or 20 anyone else who wishes to have a copy.
21 (Slide.)
22 On the last, or viewgraph No. 4 here, we wish to 23 concentrate our technical guidance that is presently 24 scattered through the various meeting summaries and reports 25 into these consolidated technical positions on a particular i
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59700101 19 marysimons O 1 important point.
2 So far we have developed two complete general or -
3 generic technical positions. The one on solubility was 4 published in the Federal Register in final form in 1984.
'S The sorption position is in the Federal Register now for 6 comment in draft form as you have it before you. You also 7 have the final version of the solubility GTP before you.
8 MR. MOELLER: What sort of comments to you receive 9 and from whom?
10 MR. JUSTUS: I will let John answer that.
11 MR. BRADBURY: For the sorption GTP we have 12 received comments from two of the states as of this time, f) 13 Those comments are essentially technical in nature 14 discussing where they believe emphasis should be placed.
15 Major changes do not appear to be necessary, but that the 16 emphasis, depending upon which state the comment comes ---
17 MR. MOELLER: Are these from states that are r
i 18 candidates for a repository?
19 MR. BRADBURY: One of them was. That was Nevada, 20 and the other one was from Minnesota.
l 21 MR. LINEHAN: Minnesota was potential for the t
22 second repository.
23 MR. MOELLER: Now I understand that a number of l 24 the Indian tribes have built up substantial technical i
25 competence. Do they comment?
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59700101 20 marysimons 1 MR. BRADBURY: That is right. For the solubility 2 generic technical position we had comments from the Yakimas.
3 MR. PARRY: Has the state provided comments?
4 MR. BRADBURY: We have not received any official 5 comments as of yet.
6 MR. PARRY: From either project or headquarters?
7 MR. LINEHAN: No, not at this point in time.
8 What we do in the different technical interactions 9 we have with DOE where the states and tribes participate, we 10 do get comments through those meetings we have.
11 What we are going to do though throughout the 12 whole program is set up a mechanism where we are going to
() 13 identify target groups in the technical community, different 14 committees and different professional societies, and 15 specifically send them letters requesting they comment. The 16 same will go to the states and tribes.
17 If we do not receive comments from the, we are 18 going to follow up and ask them again. What we want to do 19 is try to flush out everyone's concerns with the different 20 positions we are taking and try to build a better consensus.
21 Unfortunately, when a GTP goes out, it is 22 sporadic. We may get one or two comments, or we may get up 23 to 30 different comments, and we want to try to improve 24 that.
25 MR. MOELLER: Well, I think that sounds good to ACE FEDERAL REPORTERS, INC.
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59700101 21 marysimons 1 me. Certainly it is to your benefit to have at least a j 2 multitude of comments, as you say, to try to build a 1 3 consensus.
4 MR. LINEHAN: One of the things, or help we could 5 ask from you is if there are particular groups in'the j
6 technical community that you think we should be targeting l
f 7 and sending these to, we would appreciate that.
I i 8 MR. MOELLER: Well, just off the top of my head I 9 know there are waste management subcommittees in various 3
10 organizations. For example, looking at Mel Carter, do you i
- 11 send it to the NCRP for comment?
12 MR. LINEHAN: Up to this point we haven't. We
() 13 need to start sending it to organizations.
14 MR. MOELLER: And then obviously there would be J
15 the professional societies. Do you go to people like EPRI?
16 MR. LINEHAN: All along we have been dealing with 17 the environmental groups because they have come to us. We 18 have just gone to our EEI/AIF and given the briefings on the 19 program, and indeed we are going to start mailing the things i^
20 to them and soliciting their comments.
21 MR. STEINDLER: That is different than EPRI.
j 22 MR. LINEHAN: You are right.
! 23 MR. MOELLER: Right, i
]
24 MR. LINEHAN: We have had interactions with EPRI 25 also, but I don't think we specifically sent the GTP's, i
i i
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59700101 22 marysimons 1 MR. MOELLER: EPRI and NCRP to me would be sound 2 technical in-depth comments, whereas the other might be more 3 policy or management or something like that.
4 MR. LINEHAN: Yes, that's very true.
5 MR. MOELLER: I don't know what the Health Physics 6 Society has. Do you know, Mel?
7 MR. CARTER: No, I sure don't. I don't believe 8 they have a committee or anything set up in this area at the 9 moment.
10 MR. MOELLER: Of course, the ANS does. That is 11 another group. What is the professional society for 12 geochemists?
/~%
(_) 13 MR. JUSTUS: Well, the American Chemical Society 14 does have an active Subcommittee on Radioactive Waste.
4 15 MR. MOELLER: That would be excellent.
16 MR. JUSTUS: And we have presented papers at their 17 symposium on the subject, and we will do so on these l
l 18 subjects coming up as well.
1 i 19 MR. MOELLER: Do you, and I know you do go the 20 National Research Council or the National Academy?
l 21 MR. LINEHAN: Yes, we have.
I
- 22 MR. MOELLER
- I know you have done that, and this t
23 might be another place.
24 MR. STEINDLER: I am not aware that the National 25 Research Council's Subcommittee on Radiochemistry and l
[
I I
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1 Nuclear Chemistry has received any communications from the 2 NRC. I am on that panel and I don't recall ---
t 3 MR. LINEHAN: We probably haven't on the 4 geochemistry. The way we have handled it has been sporadic, 5 and we have got to come up with a systematic way so we hit 6 all of these people. We have gone to them on various things 7 though.
8 MR. JUSTUS: We intend that these positions should 9 greatly help DOE in planning their geochemistry programs.
10 They are written to encourage DOE to take a broad and open-11 minded approach to their chemical program and not to focus 12 in on single-method experiments or to follow any one
() 13 prescriptive method for determining solubility or sorption.
14 In these positions DOE is encouraged by using a 15 multiplicity of experimental routines to develop defensible 16 solubility and sorption data. To the extent that DOE wants 17 to rely on solubility and sorption to demonstrate compliance 18 with NRC release rate standards or EPA concentration 19 standards, they would have to certainly justify well that 20 data, and we think these positions present that framework 21 for them to operate in.
22 MR. KERR: What fraction of the data which is 23 likely to be needed already exists in the literature and 24 what fraction has to be developed? Do you have any feel for 25 that?
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1 MR. JUSTUS: Are you speaking towards any 2 particular kind of data when you ask that?
3 MR. KERR: I am speaking toward the whole process 4 and whatever one has to do to develop the new data to get a 5 facility licensed, and I assume that not every bit of data 6 has to be developed, or is this the case, and are there no 7 data that apply to this problem? .
8 MR. LINEHAN: From the overall extent of the 9 program, I think a good bit of it is going to be site 10 specific data. Depending on the conceptual models you can 11 build at the site in any technical area, a geological 12 conceptual model, then you can build on other analogues that (h
q,/ 13 are out there, but you really need a basic understanding of 14 the site somewhat before you can tap a lot of the data in 15 the literature to see how the site compares.
16 In geochemistry I don't know if we have any 17 specifics that we could go into.
18 MR. BRADBURY: The question is a somewhat 19 difficult to answer because right now we don't know how much 20 credit they will will be taking for solubility or sorption.
21 If they are going to be taking a lot of credit and 22 essentially relying on these retardation mechanisms so that 23 their sites are licensable ---
24 MR. KERR: It would seem to me to some extent one 25 would take credit depending upon how much is known about the O
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1 process and whether it is something for which could take 2 credit, and that is really sort of the question I am 3 raising. I am neither a chemist or a geochemist, but I 4 would assume that we aren't starting from absolute zero on 5 this, and I was just trying to get some idea if it is just a 6 matter of cleaning up a few unknowns or it is an almost 7 completely unplowed field?
8 MR. JUSTUS: Let me answer it broadly. The matter 9 of understanding the behavior of man-made radionuclides in 10 the geologic setting io a new ball game, and with the 11 exception of releases from underground explosions, to my 12 knowledge, outside of leaks from surface storage facilities,
() 13 there isn't any analogue or system that has been in effect 14 that can be studied in situ to deal with this relationship.
15 MR. KERR: Is the laplication of your statement 16 that these chemical species behave quite differently, 17 depending on whether they are radioactive or not, or that 18 one simply doesn't know how normal chemicals behave in such 19 an environment?
20 MR. JUSTUS: I am speaking to the various redox 21 states of radionuclides of importance. There are a variety 22 of non-radiogenic components of rocks and minerals and trace
! 23 metals whose behavior in the natural system are much better i
24 known than that of neptunium, plutonium, americium and l
25 others. Part of the problem that DOE faces in determining l
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ss 1 how much credit they can take is, unfortunately, constrained 2 l by the dearth of data on the interaction of radionuclides in 3 the natural setting.
4 We are trying to propose ways or suggest a 5 framework for DOE to operate in whereupon they don't think 6 they have to develop a universe of data, that there are ways 7 of focusing in on defensibility solubility and sorption 8 methods.
9 Specifically I don't know what percentage of the 10 universe DOE would find they need to develop of the possible 11 developments in radionuclides.
12 MR. PARRY: Well, haven't actually two of the (G_) 13 projects taken your advice too hard and they in fact are not 14 depending upon solubility, but the limited amount of fluid 15 that they project is not going to be present, that is the 16 salt and the tuff programs. So actually they are taking the 17 other viewpoint that they don't care what the solubility is 18 and they are not going to have enough working fluid to be of 19 concern. Of course, the third project is an entirely 20 different viewpoint and perhaps copious quantities are 21 available.
22 MR. STEINDLER: A quick comment. The field of 23 trace element migration, which is really what we are looking 24 at in a geological setting, I would guess to be of any 25 significant size is perhaps 40 years old at the most. It Dgs ACE FEDERAL REPORTERS, INC.
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59700101 27 marysimons I has grown up as the analytical techniques have improved to a % -
2 moderately sophisticated combination of chemistry and '
't 3 surface analysis.
4 The impetus for doing R&D in that area came from a
.s 5, 5 couple of applied areas, and geothermal is one, 6r a mineral 6 format $on is a second. .,
7 The third component of what I guess Iewod1d call
- \
8 the world research community is just basic research trying
. s 9 to study the interaction between new minerals and trace 10 elements. That is a very slow way to get-information into a 11 reasonably decent data base and it tends to be no't enough 4 12 site specific to be of any great use to the DOE folks.
() 13 I think as a consequence most of'the projects that 14 I am aware of view their geochemical activity largely as 15 something they are starting from scratch, including, 16 unfortunately in many areas, haverto' develop techniques toI, 17 get the research done.
18 If you look back at the rather slow progress in 19 the first four or five years of the waste managemen,t 20 business, and I started to say 10 years ago, the first 21 series of false starts were largely made because the 22 techniques for the processes were at least poorly understood i 23 by the dearth of real geochemists that were then involved in 24 the program.
25 So what you had is a very slow start that 1
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l 1 gradually picked up as people realized that they had to get i
2 reasonably expert people in the business.
1 3 I think the geochemistry portion of the DOE 4 program as I am familiar with it is picking up steam at a 5 pretty good rate. Even in the areas that Jack mentioned, 6 these folks do have some geochemistry to do even though they 7 don't have the liquid transport medium of consequence that 8 they are interested in.
9 I would say they are starting totally from 10 scratch, but they are pretty close to it at this stage of 11 the game.
12 MR. ORTH: Let me make two comments, and one of (m 13
(_) them is just to be an answer on the record for Bill's 14 question. The fact that anything is radioactive has nothing 15 to do with this issue here. Americium, curium and 16 plutonium, that is immaterial. The point is is that they 17 are not naturally occurring. So therefore we don't have any 18 analogues down there. The radioactivity does not enter into 19 that.
20 The other one is that what is known, because it is 21 part of the starting point of all of this, is that a lot of 22 the characteristics of the groundwater, and all of this test 23 work that was described in all positions says you have got 24 to know what you are doing there.
25 There is a lot of analysis and people have taken a ACE-FEDERAL REPORTERS, INC.
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'59700101 29 marysimons O 1 lot of water out of deep spots in various media and checked 2 the pH and eH and the age of it, the mineral constituents 3 and things of that nature. So that enters into part of the 4 beginning part of it.
5 MR. BRADBURY: I would also like to point 6 something out. The statement was made that two of the three 7 types of sites will not be taking credit for solubility and 8 sorption because of the lack of water.
9 Well, it is true for salt that there isn't really 10 that much water. So it is hard to conceive of solubility 11 and sorption being mechanisms which will be that effective 12 in retarding the release of radionuclides from the
() 13 environment.
14 But the tuff site, that group that is involved 15 with that, although they do say that there is a limited 16 amount of water and they are taking credit for that, they
, 17 are also taking credit for the sorption of the l 18 radionuclides, which means the radionuclides must be 19 migrating out of the system via liquid flow. So they are i 20 taking credit for solubility and sorption.
l l 21 MR. PARRY: I only want to clarify my comment to 22 say also that they are striving to take credit for little 23 water.
24 MR. BRADBURY: Correct.
l 25 MR. PARRY: It has not been proven that there is
()
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59700101 30 marysimons 1 not going to be a lot of water.
2 MR. JUSTUS: Tuff is not totally dry. It has 3 actually up to 80 percent saturation.
4 MR. BRADBURY: By the way, we do have some, and 5 they are not really natural analogues, but they are long-6 term man-made in. situ tests. There has been a document 7 recently published concerning a pond that contained 8 plutonium at Los Alamos that has been leaking, and the 9 experiment I think has been going on for 20 or 30 years now, 10 and they have found that some of plutonium and some of the
< 11 americium has migrated long distances, much longer distances 12 that they ever expected. So there are experiments that have
() 13 been going on that give us an indication of the problems 14 that can occur in these systems.
y 15 MR. PARRY: These are not planned experiments.
16 MR. BRADBURY: No, they didn't plan that.
17 MR. JUSTUS: Okay, John.
18 MR. BRADBURY: I appreciate the opportunity to 19 describe some of the work that we are doing in the 20 geochemistry section.
21 This morning what I would like to do is, first of 22 all, discuss the purpose of these generic technical 23 positions in a very general sense, the status of these 24 positions. I think some of this has already been covered,
- 25 but I will go into a little more detail than what Bill has ACE FEDERAL REPORTERS, INC.
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v 1 done.. Then I will go into essentially the gist of these 2 generic technical positions, the content of these GTP's and 3 why we think the position that we have taken is important.
4 MR. MOELLER: In your review it would help us, and 5 .I think you have already said you are going to cover it, to 6 know the present status of these GTP's because we have read 7 them and we are prepared I am sure to give you some comments 8 on them.
9 MR. BRADBURY: We do appreciate any comments you j 10 have. Following describing what is in the GTP's and why we 11 think the position we have taken is important, then I will 12 briefly discuss some of the comments that we have received
() 13 from the public.
14 Again, please feel free to interrupt me.
15 I assume you all have the packet of slides. So I 16 will start to go through that.
17 The purpose of our generic technical position is 18 to provide guidance to the DOE without being prescriptive.
! 19 These documents must be flexible enough to give DOE the 20 ability to plan their own experimental program to 21 characterize solubility and sorption.
22 But we also want to indicate to the DOE what 23 information we will need in order to make licensing 24 decision.
25 Now the DOE has been putting an effort into t
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1 characterizing these retardation mechanisms and the generic 2 technical positions are responses to that effort. We aren't 3 trying to tell the DOE what to do. We are responding to 4 what is being done and trying to make sure that they 5 understand what we think we need.
6 (Slide.)
7 The first slide just shows the status of the 8 different generic technical positions.
9 As mentioned earlier, the solubility GTP is in a 10 final form, and this was noticed in the Federal Register in 11 November of 1984. We had several comments concerns the 12 solubility GTP, including comments from the ACRS. Some of
() 13 those comments were taken and used to make minor 14 modifications on the final GTP.
15 So the copy you have now is somewhai. modified from 16 this what call the final noticed in 1984, November 1984.
17 The sorption GTP came out as a draft in January of 18 this year, again noticed in the Federal Register, and public 19 comments were solicited from January to March of this year.
20 As I have said, we received a few comments. We 21 have received all that many as of yet.
22 In May of this year we had a meeting or a workshop
! 23 with NRC contractors in dealing with problems involved in 24 determining sorption parameters, and from that meeting what l
25 was produced was a draft letter report, which is also in i
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1 your packet of information. This letter report, we have 2 just recently received it and haven't really had enough time 3 to go over it. That is why we got it to you late and we 4 apologize for that inconvenience.
5 Barring any major problems concerning the position 6 we have taken on sorption determinations, we anticipate that 7 a final for this position will be put out in September of 8 this year.
9 MR. LINEHAN: Joe, if I can just interrupt.
10 Dade, in response to your question as to the 11 appropriateness of commenting, even with a final GTP, we see 12 a lot of them as evolving documents. We get smarter as DOE
() 13 gets more information. In addition, their generic 14 positions, very often they are going to be followed up by 15 site specific technical positions.
16 From your folks or anyone in the technical 17 community, comments at any point in time will help us as we 18 go down the road of the problem.
19 MR. MOELLER: Okay. Thank you.
20 MR. BRADBURY: We feel that the experimental 21 process protocol is still in an evolutionary type mode, 22 especially for sorption. So because we feel that is the 23 situation, the generic technical position has to be quite l
l 24 general and flexible. Then as new techniques are developed
- 25 and new theories are developed, these will be incorporated uJ r
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V 1 into new documents concerning sorption and solubility.
2 Instead of talking about the GTP's separately, I 3 would like to talk about them together, the reason being 4 that solubility and sorption have a lot in comment, and 5 because of that, both of them are retardation mechanisms, 6 because of that the two documents have a lot in common.
7 I am sure you will note that a number of our 8 position statements are common to both documents. So 9 instead of being redundant, I will try and combine those, 10 the discussion of both into one discussion.
11 (Slide.)
12 l The next slide it just a definition of
( ) 13 solubility. Solubility is just the concentration of a x_,
14 ! radionuclide in liquid when that liquid is in contact and in 15 equilibrium with a solid containing the same radionuclide 16 and that solid has a fixed composition.
17 (Slide.)
18 I The next slide then is a definition of sorption.
19 Sorption also involves the interaction between material in 20 liquid and solid, the liquid and solid phases. However, in 21 sorption the amount of radionuclide in the solid is variable 22 and can change in relationship to the amount of radionuclide 23 in the solution.
24 MR. MOELLER: Why does it exclude precipitation?
25 MR. BRADBURY: This is excluding precipitation of
-)
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v 1 the fixed composition phases, the stoichiometric phases.
2 That precipitation of stoichiometric phases is the 3 solubility of that phase. So what I am saying is that 4 sorption and solubility are essentially processes that lie 5 on a continuum and solubility is the extreme. So the pure 6 end member of, for example, a solid solution is 7 precipitated, and that fixes then the composition both in 8 the solid, the concentration of radionuclide in the solid 9 and in the liquid.
10 MR. CARTER: Let me ask you one thing. What about 11 adsorption then. Is that what you consider chemisorption, 12 and this is something other than a surface phenomenon,
(~)
(,, 13 adsorption?
14 MR. BRADBURY: These terms, ion exchange, t
15 i adsorption and chemisorption are terms that people have 16 tried to apply to sorption when they really don't know 17 exactly what is going on. So they say chemisorption is one 18 in which the material in the liquid is attracted to the 19 solid and the bonds that it forms with the solid are much 20 strohser than these other types of processes.
21 So the different names are really guesses of what 22 is going on and they are trying to explain macroscopic 23 effects. Adsorption might be close to chemisorption because 24 adsorption would tend to mean migrating into the solid 25 phase, and one would think that it would be difficult to get g ,)
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V 1 that material back out again. So at least from a 2 qualitative point of view they could be the same type of 3 process.
4 (Slide.)
5 The next diagram is a well known diagram showing 6 a conceptual model of what happens in the vicinity of the 7 waste packages. Groundwater moves into the system, corrodes 8 the packages, leaches the waste form, dissolves the waste 9 form, and in the vicinity of these waste packages, as 10 mentioned earlier, solubility reactions, which are really 11 precipitation dissolution reactions, the two processes 12 combined, they will occur close to the canister and probably
() 13 more so because the concentrations are higher, the 14 radionuclides are higher in that region.
15 As the groundwater migrates from the waste 16 packages, then sorption will occur and this is where 17 radionuclides are attracted to the solid material that is 18 already present.
19 MR. CARTER: What is the only mobility agent of 4
20 transport mechanism?
21 MR. BRADBURY: Right now we are talking about only 1
22 water. There is a concern that some of the radionuclides 23 may come out in the vapor state and sorption can occur also, 24 you know, solids adsorb gases, but I am pretty such that no 25 much work has gone into characterizing that type of O
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2 One would think that probably a more conceivable 3 scenario would be if material came out in a gas form that it 4 would reach an equilibrium with the liquid that is also i 5 present. That is, it would dissolve in the liquid and maybe 6 come out of the liquid,-and that type of mechanism would be 7 a retardation mechanism which slowed the migration of the 8 radionuclides out of the system.
j 9 By, anyway, for right now I am talking just about 10 the liquid state, the liquid stage as being the migrating 11 medium.
12 MR. PARRY: Is concern also being given about the t
() 13 dissolution of the canister, and in the case of the spent 14 fuel the zirconium?
9 15 MR. BRADBURY: Yes. I am sure people are 16 concerned about that.
17 MR. PARRY: Is that factor contained in your i 18 technical position, too?
19 MR. BRADBURY: The technical position talks often 20 in generalities. What we suggest is that in experimentation 1
21 that site specific materials are used or you are at least 22 are concerned with what those materials will do in terms of 23 affecting solubility and sorption parameters.
24 MR. STEINDLER: Did you say you expected 25 precipitation to be more prevalent in the near field than ACE FEDERAL REPORTERS, INC.
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59700101 38 marysimons 1 sorption in the far field? Is that what you said?
2 MR. BRADBURY: Yes, because that is where the 3 radionuclide concentrations are the highest. Now that is 4 not universally a common occurrence. If a radionuclide is 5 migrating out from the system and the composition of the 6 fluid containing the radionuclide is undersaturated with 7 respect to some radionuclide bearing phase, it will 8 continually pass out of the system.
9 However, that fluid may encounter some system 10 which will change the geochemical conditions, at which point 11 a radionuclide may participate out. So solubility controls 12 can occur also away from the packages, but I envision that
() 13 solubility constraints would be dominantly occur near the 14 waste package.
15 MR. STEINDLER: No. 1, I don't know what you do i
16 with that bit of information because you can't ignore i 17 solubility issues in the far field and, No. 2, you have a i
18 thermal gradient to boot which is in the wrong direction for i
l 19 most solubilities unless they are retrograde.
20 Why did you bring up the issue in the first 21 place? you surely aren't going to ignore solubility in the 22 far field.
23 MR. BRADBURY: No, I won't ignore solubility ---
24 MR. STEINDLER: And you can't ignore sorption in 25 the near field.
1 i
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59700101 39 marysimons 1 MR. BRADBURY: That is correct.
2 MR. STEINDLER: So you have got both phenomena f
- 3 that you at least need to consider throughout the migration 4
4 path.
5 MR. BRADBURY: But the emphasis of the 4
6 experimental programs might show that most of our solubility 7 experiments are done at higher temperatures and most our 8 sorption experiments are done at lower temperatures.
9 MR. STEINDLER: Is that what you are recommending 10 that DOE do?
i 11 MR. BRADBURY: I am saying that that is a 12 reasonable approach. I am talking about emphasis now. I am
() 13 not saying that they should exclude studying processes 14 around the waste package.
15 MR. STEINDLER: If your documents or your position 16 is supposed to be guidance for DOE, what is it that you are 17 telling DOE?
18 MR. BRADBURY: That they should try and simulate
- 19 the conditions in the repository in their experiments. That 1
20 is one of the things we are trying do so.
21 MR. MOELLER: What I hear Dr. Steindler saying is
( 22 that to imply that emphasis should be on solubility near the l
j 23 canister and sorption in the far field may be wrong.
I 24 MR. STEINDLER: That is what I said.
25 MR. MOELLER: I think it is clear that you have l
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'J 1 recommended that certain things be emphasized at certain 2 places. So we want to be sure you are right.
3 MR. BRADBURY: Can you tell me why you think it is 4 wrong? You think solubility can occur away from the 5 package?
6 MR. STEINDLER: Sure. Solubility can occur 7 anywhere along the path, and you can expect at least for a 8 long time a temperature gradient. Precipitation can be 9 expected at a lower temperature if you saturate it at a 10 higher temperature.
11 MR. MOELLER: And I could have said that sorption 12 should be studied right now to the container because that is (n) 13 , where it is most important because that it is where it would 14 hold up the migration, and you are telling me no.
15 MR. BRADBURY: No, I am not telling you no. I am 16 not going that far. I am just saying that I envision that i
17 solubility and sorption will occur. It will occur anywhere 18 that rock solid material is in contact with liquid, and 19 seeing as there is more volume, that there is a larger 20 volume of material at ambient conditions, that is material 21 away from the canister, that there is a lot of availability 22 for sorption processes to occur.
23 MR. ORTH: Dade, let me make whack at this 24 slightly. Both of the phenomena are important close in of 3 25 course. The only distinction is that when you get a lot way
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59700101 41 marysimons 1 away and have had a chance for the material to get polluted 2 by diffusion and interaction with it, once you get far 3 enough away there is going to be a much lower concentration 4 of the material that you are concerned with in that phase.
5 Therefore, solubility will tend to be less important.
6 MR. MOELLER: Okay, that makes sense.
7 MR. ORTH: It doesn't mean that it is not 8 important everywhere. It just means that if you look at the 9 relative probabilities of the two phenomena, once you are in 10 a very dilute solution you are going to have to worry a 11 little bit less about solubility.
12 MR. MOELLER: And sorption could be more important
() 13 in the far field if you are viewing that as your last 14 barrier to the release of the material.
15 MR. BRADBURY: I think we agree.
16 MR. MOELLER: Right, I think we agree. Go ahead.
17 (Slide.)
18 l MR. BRADBURY: Now the next diagram shows what 19 happens when a packet of fluid migrates away from the waste 20 package. It has already dissolved the radionuclide from the
! 21 waste and now contains the radionuclide.
22 The processes and mechanisms listed below show how 23 material is removed and ends up in the solid phase and 24 therefore is slowed down because the fluid is moving and 25 there is time when the material is attached to the solid O
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59700101 42 marysimons O 1 phase and then under equilibrium or steady state conditions 2 the material would dissolve and go back into the liquid 3 phase.
4 Anyway, this retards the radionuclide's migration 5 out of the repository system. Now the processes are 6 precipitation dissolution, which is solubility, the 7 solubility of a radionuclide bearing phase, and to the right 8 we show that we put out a generic technical position in 1984 9 on that, and sorption with its detailed processes is also 10 going on, and that position we are currently working on and 11 should go out later.
12 Another process is called matrix diffusion, and
() 13 that is the process in which water flowing down a fracture 14 that contains radionuclides, and this fracture is in a rock 15 that contains pores, the radionuclides can diffuse out of 16 the fluid that is going through the fracture into the pores
- 17 and the pores essentially can act as dead-end streets or 18 whatever, and thus the radionuclides would tend to be 19 retarded.
20 There are two sites that are using this process or 21 might take credit for this process, that the tuff and 22 possibly the basalt sites.
23 The Geochemistry Section plans to write something 24 about this retardation process in the future. ,
25 MR. CARTER: This essentially increases the l
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1 surface area available to the radionuclides in the solution 7 2 MR. ORTH: It is not a chemical process they are 3 talking about. It is strictly a physical process.
4 MR. BRADBURy: A chemical process could be couple 5 with it. That is, a material could sorb onto surfaces in 6 the pores, but that is not necessary. That would tend to 7 retard any radionuclides more, but it is not necessary. It 8 is just a diffusional process.
9 (Slide.)
10 The next diagram is a flow chart showing 11 l essentially what I have just described about the water 12 '
interacting with the engineered barriers and dissolving the
() 13 waste from the solution.
14 Then we have the two major retardation mechanisms 15 that would go to both control the concentration, that is the 16 solubility, the solubility of precipitation processes, and 17 the retardation processes which is sorption.
18 , Listed underneath those two boxes are the l
19 information needs. These are the data that we think we need 20 in order to make sound licensing decisions.
21 First of all, I would like you to know, as I 22 mentioned earlier, that there are a number of common 23 position statements to both documents. Some are not common 24 and these reflect the fact that, one, the solubility and l
, 25 sorption, the experimentation is somewhat different and,
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\-] 1 two, that we are responding to the efforts being put forward 2 by the Department of Energy.
3 MR. MOELLER: Excuse me. The dates, sorption FY-4 86, does that mean it is the date you formed these positions 5 or when you will need the data?
6 MR. BRADBURY: These are the dates that the GTP's 7 have been published or we anticipate them being published.
8 Now starting off with each position.
t 9 (Slide.)
10 The first statement position is common to both 11 documents. We suggest that the DOE develop a matrix of 12 experiments. The matrix of experiments essentially means
() 13 what parameters should be studied so that we can get a good f 14 idea of how solubility and sorption can vary in relationship 15 to those parameters.
, 16 Also, the matrix of experiments, when this matrix 17 is developed at an early stage we will be able to tell how 18 much time it is going to take to do all this information.
19 The purpose of this procedure is to, one, 20 demonstrate what experiments will be crucial, what are the 21 most important experiments to run, and it may also help in 22 eliminating non-essential effort. We don't want to be 23 carrying out experiments in which this solubility or 24 sorption isn't sensitive to the parameters that we are 25 varying.
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s_J 1 MR. STEINDLER: Excuse me. Are you describing
. 2 your program or are you describing what you expect DOE to be 3 doing?
4 MR. BRADBURY: We are describing what we would 5 like DOE to do.
6 MR. STEINDLER: Why do you care about whether they 7 waste their time? What does that have to do with the 8 technical position of the NRC7 9 MR. BRADBURY: Well, if they waste their time, 10 then the information that we will need we won't get when we 11 have to make our decision. So I would like them to give me
- 12 as much good information as they possibly can prior to the
() 13 time that we have to make our decision.
14 MR. STEINDLER: Isn't the role that you are trying i
15 to play is one of saying here is the kind of information I 16 need period? We don't care how you get it. You can buy it, 17 you can steal it out of the literature or you can get it any 18 place you want, but you have got a time schedule and you are 19 going to have to give me that information. You don't care 20 whether they waste their time or not or blow resources.
21 That is not your job to worry about that. That is DOE's 22 job? Am I not correct?
s 23 MR. LINEHAN: It is mainly DOE's job, but the way 24 this whole program is laid out in the Wasto Policy Act, 25 prior to the license application, this preconsultation i
l i
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1 period it is consulting with the Department. It is not the I
2 typical role of the NRC. We have to be careful that we 3 ' don't step over that line where we tell them how to do 4 things, but it is lay out what has to ---
l 5 MR. STEINDLER: That is exactly my point.
6 MR. LINEHAN: It is to lay out what has to be done 7 in the most effective and most efficient manner.
t 8 MR. KERR: It seems to me if you tell an 9 organization not to waste time, what does it accomplish?
10 MR. LINEHAN: The thing we are concerned about is l
11 the time constraints that we face.
2 12 MR. KERR: I understand that, but I am not quite
() 13 sure what you expect the results of such an injunction would j 14 be.
j 15 MR. BRADBURy: What we are trying to do, and let 16 me give you an example. We see at this time that a lot of
! 17 emphasis is being placed on batch sorption tests, and these l
18 tests have been going on for many years now. They are 19 coming up with a lot of numbers, empirical numbers that are 1
20 extremely difficult, if not impossible, to extrapolate to 21 repository conditions.
j 22 We are saying you had better change direction and i 23 you had better do something more. At this point this l 24 appears to be non-essential effort, and change what you are 25 doing or otherwise you are going to come up to licensing I
t O
I
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1 time and it won't be good enough.
2 MR. KERR: For some reason they are collecting 3 this non-essential information. Is that just stubbornness 4 on their part?
5 MR. BRADBURY: Momentum essentially is one part 6 that governs these programs I think. Right now we are 7 hearing whether this information that they are collection is 8 of licensable quality. They are asking us that, and we have 9 to come back to them and ---
10 MR. KERR: I would consider, you know, you have 11 the alternative of telling them what you don't want or the 12 alternative of telling them what you do want. It seems to
() 13 that the latter might be more effective.
14 MR. MOELLER: Well, in a sense I hear what both 15 you and Marty are saying In a sense they are telling them 16 what they want when they say we want a matrix of 17 experiments.
18 MR. MOELLER: Dade, that is now what they want.
19 They don't want a matrix of experiments. They want the 20 results of a matrix analysis, and whether it is DOE or 21 anybody else, it is immaterial whether it is DOE. Whether 22 DOE or anybody else goes through a matrix methodology of 23 focusing down as to what they should be doing or uses some 24 other methodology, it strikes me it should be totally 25 immaterial to the NRC since they are interested in the q
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2 One of the difficulties I have with looking at the 3 two position papers is there is an awful lot of here is how 4 you guys are going to do it, and not enough this is the kind 5 of information we need and we don't care how you get it.
6 MR. LINEHAN: The intent here though is to lay out 7 what we see as an acceptable strategy to go about getting 8 that data. It is an acceptable way of doing it and they 9 don't have to do it that way, but it is just a means of 10 trying to give them guidance.
11 I think it is similar in some of the reg. guides 12 the Commission has issued in the bioassay area, for example, O 13
(_) where wo lay out the basic strategies for bioassay 14 programs. The applicant is free to come up with any 15 program, but it is just basic guidance as opposed to saying 16 that we want the data giving, giving additional guidance as 17 to acceptable ways of going about obtaining it.
18 MR. KERR: But you see, when you do that, the 19 danger, and I have sure seen this in reg. guides, is that 20 you have described a method and if they follow the method, 21 independently of the quality of the result, you will accept 22 the result. What you really want is a good result.
23 MR. LINEHAN: I think you are right. That is a 24 pitfall we have to watch for. What we are trying to do in gs 25 the GTP is to lay out broad strategies where, you know, they b
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59700101 49 marysimons O 1 can't just say, hey, we are going to follow the strategy. 1 2 They have got to do a lot of independent work to develop the ;
3 strategy and prove to us that under the specific situations 4 at any one of the sites it is an acceptable strategy. They 5 are going to have to prove that it can be implemented at 6 that site.
7 Now if we are going too far in laying things out 8 for them, we would like that feedback.
9 MR. CARTER: Let me ask a question on the example 10 you mentioned, the batch test, and I presume these are 11 either batch tests or column tests and, as you say, that
- 12 might not be applicable, f
() 13 The question is what would be applicable to make i 14 that information applicable directly site specific? There t
i, 15 is still going to be some translation involved in this in f 16 one way or the other.
l
- 17 MR. BRADBURY
- That is right, there always will l
18 be, and that is why in the GTP we don't specify what tests l
I f 19 we thing should be done because we know it will be a i
20 pitfall. So we suggest that multiple approaches be the way
- 21 to go. The batch test is the simplest test to carry out.
i l 22 The column test is a harder test to carry out, but it does '
. i 23 have advantages over the batch test. It can show, for 24 example, if colloids are present and whether the l
i
{ 25 radionuclides are migrating from the system as colloids, but l
l -
1 l
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("T l NJ l 1 it also can have disadvantages, too. l 2 Then you can go on from there and you can say, 3 okay, instead of using crushed materials, use intact 4 materials and find out how that affects your sorption 5 process. When you grind up a rock, you are really 6 energizing the surfaces and you are exposing different 7 surfaces, different minerals and you are exposing a lot more 8 surface area. The numbers that they derive from these batch 9 sorption tests may be totally useless, 10 MR. CARTER: Well, I guess, to pursue it a little 11 bit further, I have been involved in batch tests, and I 12 would agree with you. I don't think they serve very much of
() 13 a useful purpose except in gross screening. I think column 14 tests are much better. I think you will find that the bulk 15 density of the material is going to make an awful lot of 16 difference.
17 MR. BRADBURY: And when fluid is flowing through a 18 fracture, the column test in which the material is ground 19 may also not be representative of what is going to go into 20 the repository.
21 MR. ORTH: I think what we are getting back to is 22 the same thing that we should not really be telling them how 23 to do the tests, which is what we are talking about right 24 now, how to do the tests.
, 25 What is really needed is a clear statement of what ACE-FEDERAt. REPORTERS, INC.
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v 1 are the products you need, you need information on this and j 2 that, and a listing, if somebody wants to put it, of what t
3 are the things you have to worry about. If you are going to 4 do tests in certain ways, be aware of all of those things in 5 case they don't know, but I think you will find most of 6 those people doing those kinds of tests already know those 7 things.
8 So you can list a set of products you will want i 9 and you can put a bunch of caveats and bewares and all of 10 those things because you are going to ask them +.hosr.
11 questions and you are going to have to prove that a bat 6h
, 12 test was this and was really done right or that this kind of
()
[ 13 test is applicable. But there is an awful lot of 4
l 14 prescription going on in here.
- 15 I can just pick out one example from this as an 16 example on this chart we are looking at right now. A couple 17 of dots down under the solubility position it says 18 characterization of experimental products. Well, so 1
19 somebody makes a test and they show that under some i
20 condition which does simulate the repository, and everybody l
l 21 agrees to that, I have the right kind of rock and everything l
l 22 else, I have the right solutions there and the material 23 disappears from solution. Somebody comes and says, you l 24 haven't proved how it disappeared from solution and
- 25 therefore we won't give you credit for it.
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, marysimons 1 Well, I don't care whether I can really 2 characterize the product in that case. If I have a physical l 3 phenomenon and I have measured it, I would like to take 4 credit for it. I would rather not see it quite so 5 prescriptive myself.
6 MR. BRADBURY: The reason that we put that 7 statement in there is because the DOE or their contractors j 8 were calling certain experiments solubility experiments, and 9 when you talk about solubility you are talking about 10 solubility of some solid phase.
- 11 They were talking about solubility experiments of l
12 glass in waste forms or whatever. They were not
! () 13 characterizing what the products of the reaction were.
< 14 Therefore, they can't say that we have the solubility of the 15 glass. The experiments they were running were really leach i 16 experiments and not solubility experiments in a classical
) 17 sense. I i
q 18 MR. ORTH: I happen to agree with you. So the i
19 words are wrong. The point is a certain phenomenon is l
20 occurring. The material either is coming out isn't coming i
i 21 out and it is coming out at this rate or it is 22 disappearing. To quibble about whether you have used the
] l 23 right word is, you know, not quite as important to me.
l 24 MR. BRADBURy: Okay. Well, you put a number of 25 assumptions in there and you say that we know that i
i l
j
(
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59700101 53 marysimons O 1 everything is just the way it is in a repository and we see 2 this phenomenon occurring but we can't quite describe it and 3 we don't know exactly how it occurs.
4 Therefore, what the NRC is contending is that you 5 haven't characterized fully the experiment by not 6 determining what the solid produce is that you form. So you 7 don't know that you have simulated what is going on in the 8 repository. You don't know that your experiment simulates 9 the repository.
10 MR. ORTH: Well, I'll get over to one more point 11 then, and the other bit, which is reasonably well done I 12 might point out. I am not quibbling at all about the
() 13 relations between morption and solubility on the little 14 curves and how they go. You can pick a point in there and 15 you don't know whether it is sorption or solubility or 16 whatever, and I don't really care. I just know that it is 17 reacting like that, and trying to quibble as to what is l 18 really happening there isn't that important still to me.
19 MR. STEINDLER: Let me ask a more fundamental 20 question. I think it is apparent from your answer that you
{ 21 are not ready to accept empirical data; is that correct?
22 MR. KERR: What other kind is there?
23 MR. STEINDLER: In contrast to mechanistic.
- 24 MR. KERR
- Well, mechanistic is pretty empirical.
(Laughter.)
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j 1 MR. STEINDLER: Well, no. Let me draw an 2 artificial distinction for the moment between I define as 3 empiricai data where you don't necessarily understand the 4 total aspects of the system or you have not analyzed it I
5 certainly and mechanistic data in which you have a good 5
6 enough handled to be predicted based on fundamental l
7 considerations.
8 Am I correct in assuming that you do not from your
- 9 comment, that you will not accept empirical data? Because
, 10 if so, I think there is not a prayer in hell that the Al repository is going to be licensed either this century or 12 the next century.
() 13 MR. BRADBURy: What we are striving for is an
'( 14 emphasis or a redirection towards more mechanistic 15 approaches in determining sorption. That is not to say that 16 we won'*. accept empirical data alone.
I am not exactly sure 17 what we are going to accept when the licensing time comes 18 around, but right now we have a lot of empirical data and we 19 cadnot run a series of experiments and they can't predict 20 '
what is going to happen in the next experiment.
1 21 I will have real trouble in trying to base a 22 licensing decision on that kind of precision.
23 MR. STEINDLER: I am not saying that you should 24 accept lousy empirical data. All I am asking for is whether I
- 25 or not -- what I thought I heard was that you would not ACE. FEDERAL REPORTERS, INC.
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3 MR. BRADBURY: No. If we have" precise empirical 4 data, that certainly would influence and probably affect our 5 decision in saying that we could grant a license.
6 MR. KERR: What if I put it another way and say if 7 they have acceptable empirical data he will accept it.
8 MR. JUSTUS: And how it is used is'just as 9 important, and the extrapolation for 10,000 years is why we i
10 are so fussy abou\ getting or asking DOE to get defensible 11 data, empirical or otherwise. We are not saying that we 12 won't accept empirical data.
() 13 MR. STEINDLER: One other question in general 14 terms. Nowhere in either of these position papers is what 15 you have said so far, and perhaps you are going to get to 16 it. Have you addressed the question of how good these data 17 have to be in order to satisfy you? Is that because you 18 don't know or because you expect somebody else to tell you 19 or what?
20 MR. BRADBURY: First of all, we don't know how 21 much credit we will be taking for either of these 22 mechanisms, and the amount of credit taken will determine 23 how much we will have to rely on those numbers and how 24 certnin those numbers will have to be. At this point I 25 don't know how much.
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1 MR. KERR: Are you thinking about the possibility 2 of deciding that by comparing it with the uncertainty in 3 predicting what the repository will look like in 10,000 4 years from now, for example, that it may be covered with a 5 thick lawyer of ice or there may be a volcano there?
6 MR. BRADBURY: Geochemistry is one sub-aspect of 7 everything and ---
8 MR. KERR: I know, but it seems to me that there 9 is not too much point in asking for an extremely high 10 precision in one parameter if other parameters that may have 11 equal influence are of necessity going to be known to one 12 with very large uncertainties. I am not sure I would take
'\
(~/
(, 13 this into account, but it seems to me at least qualitatively 14 it should be considered.
15 MR. PARRY: What sort of precision do you normally 16 expect solubility to be, 25 or 30 percent, plus or minus?
17 MR. BRADBURY: Well, with the actinides and in 18 very complex systems in a geologic medium, that would be 19 extremely nice to get that results like that.
20 MR. PARRY: So you expect 50 percent or better 21 perhaps?
22 MR. BRADBURY: If we got numbers like that, we 23 would be very pleased.
24 MR. PARRY: Has anybody considered what that does 3
25 to the performance assessment answers and the variability in
%-)
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2 MR. JUSTUS: That is why it is so difficult to 3 answer the question. DOE will have to decide what precision 4 they will need to demonstrate the compliance.
5 MR. PARRY: That is not the way though. It isn't 6 what precision they need. The point is what precision can
- 7 they attain? They may need five percent precision, but that 8 is impractical or technically infeasible.
9 MR. JUSTUS: Then they will not be able to rely on 10 that particular let's say retardation scheme to demonstrate 11 compliance.
12 MR. PARRY: But that exists all the way down the (D
(j 13 line.
'14 MR. JUSTUS: If you are pointing out the 15 interrelationship of developing a performance assessment 16 methodology and the scenarios that lead up to demonstrating 17 the performance, retardation can be an important factor in 18 demonstrating compliance, and if it is particularly 19 important at a site, and that is to say that a license 20 decision may depending on that component, that Is how 21 important it might be ---
22 MR. PARRY: BWIP is what, 70 to 80 percent 23 retardation.
24 MR. JUSTUS: The kind of accuracy and precision g, 25 that led up the reliance on that particular factor becomes V
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59700101 58 marysimons O 1 more important that in some other context. We think of it I 2 guess as a sliding scale. That is why we are trying not to 3 be prescriptive. If we would be prescriptive, we may be 4 overly prescriptive as well as underprescriptive.
5 MR. MOELLER: Well, I think you have gotten the 6 gist of the subcommittee's comments on that topic.
7 We have been going well over an hour and a half.
8 Why don't we take a 15-minute break.
9 (Recess taken.)
10 MR. MOELLER: The meeting will resume, 11 What I have suggested to John in the meantime 12 during the break is that we go ahead with his presentation
() 13 and finish up the rest of his handout covering each of the 14 items, and then I would like to go through both of the 15 generic technical positions page by page and have the 16 subcommittee offer comments because to me that is one of the 17 key reasons we are here is to offer our comments on these 18 positions. It will mainly be an update, but I think we 19 should do it.
20 Why don't you go ahead then, John, and continue.
21 MR. BRADBURY: I will try and go as fast as 22 possible here. We have covered a number of these points 23 already. So in those situations I will just flip over those 24 slides quickly.
l 25
() (Slide.)
1 I
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59700101 59 marysimons O 1 The next position statement is to characterize 2 starting materials and products. This statement position is 3 common to both documents. In so doing we can determine the 4 effects of experimental protocol. I have already explained 5 when you determine the products you essentially have an idea 1
6 of whether you are bounding the geochemical and physical I 7 conditions.
l 8 Possibly you can look at retardation mechanisms.
I 9 The mechanistic approach was mentioned earlier. And as most 10 of these procedures do, it might demonstrate that the data l 11 are realistic and conservative.
12 (Slide.)
(j 13 The next position is ---
14 MR. KERR: Excuse me. How can data be both j 15 realistic and conservative?
j 16 MR. BRADBURY: Well, my definition of conservative 1 *l is say, for example, from the actual concentration that will 18 occur in the repository to something greater than that. So 19 that the two overlap, and we want to make sure that the 20 concentrations or the sorption parameters are at least ---
21 MR. KERR: Why don't you want the data to be the
- 22 best data you can get? I hate to see a conservatism 23 introduced at every step of the way giving you finally a 24 total conservatism.
4 25 MR. BRADBURY: Yes, which would be. totally ACE FEDERAL REPORTERS, INC.
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4 59700101 60 marysimons I unrealistic.
~
2 MR. KERR: It may turn out even to be a non-3 conservatism, because what is conservative for one piece of 4 an overall puzzle may not introduce conservatism in the 5 total. I would urge that one look for the best data that 6 one can get.
7 MR. BRADBURY: For sure. The next position 8 statement is that we suggest that sorption isotherms be 9 documented as opposed to batch KD experiments in which a 10 single KD is determined.
i
! 11 I am going to zip through these pages.
12 (Slide.)
() 13 All I am saying in the next one entitled 14 solubility or sorption is that chemical reactions for 15 solubility and sorption can be expressed in a similar 16 fashion.
17 (Slide.)
18 The next diagram shows a typical sorption 19 isotherm. This is an idealistic case. Sorption occurs in 20 the sloped region of this graph at low concentrations of 21 radionuclide in the liquid and low concentrations on the 1
22 solid.
23 As you increase the concentration in the liquid 24 and on the solid, you eventually reach an apparent 25 concentration limit which would be a solubility of some
()
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59700101 61 marysimons O 1 radionuclide in the solid phase.
2 (Slide.)
3 The next diagram, schematic isotherm, shows what 4 happens -- each one of these arrows would indicate a single 5 batch KD experiment. What I would like to point out here is 6 that the lines at the low concentration end essentially I
7 would determine a sorption type experiment. The lines on 8 the upper end determine a solubility experiment. So that 9 shows why they are essentially a continuum of each other, 10 solubility and sorption.
i
~
11 (Slide.)
12 This final isotherm, I wanted to show that, and I
() 13 am not going with all schematic diagrams and maybe the 14 things don't really exist. This is one in which uranium is 15 sorbed onto the basalt. You can see one factor that often i
16 has to be considered in sorption experimentation is the 17 effect of time on the numbers that one derives from these 18 experiments. You have to carry these out for a long enough 19 time to reach some steady state or equilibrium situation. i l 20 MR. KERR: Are these figures for the education of 1
21 the subcommittee, and they are certainly well taken as far i
22 as I am concerned, or is this something you also pass on to j 23 DOE 7 f
24 MR. BRADBURY: No, these aren't going on to DOE.
25 (Slide.)
l l
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59700101 62 marysimons O 1 MC. BRADBURY: Now we have a position in the 2 solubility GTP which states that solubility determinations 3 should be carried out from both the direction of 4 undersaturation and oversaturation.
5 (Slide.)
6 Now this diagram explains what we mean by 7 conservative and realistic.
8 MR. KERR: Is this a conventional approach of both 9 under and over, or is it something unusual?
10 MR. BRADBURY: I'm sorry, what was the first part 11 of that question?
12 MR. KERR: You say the NRC position is to
() 13 determine solubilities from both undersaturation and 14 oversaturation. Is this the way one would normally do it or 15 is that unusual?
16 MR. BRADBURY: One should normally do it that way, 17 and it is the preferred way of carrying out solubility 18 experiments, the reason being that if you carry out, for I 19 example, a solubility experiment from undersaturation, that 20 is you put a crystal containing radionuclide in a liquid and 21 let that crystal dissolve, the concentration in the liquid 22 will increase and approach some equilibrium situation, 23 depending upon how long you carry out the experiment.
24 You can do another experiment in which you have a l
25 liquid containing more radionuclide and other components f
i l
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1 than normally would occur under equilibrium conditions.
2 Material will precipitate out and that is this curve on the 3 top of this diagram.
4 This shows two things. It shows, one, that 5 experiments carried out from oversaturation are important 6 because those experiments are conservative and thus better 7 describe what could possibly go on in the repository, 8 This dual type experiment is also important 9 because it shows from the gap, from the distance between the 10 two experiments you can determine how much uncertainty you 11 tie into the number that you are quoting. The solubility of 12 some greater nuclide bearing phase is this concentration
() 13 plus or minus that amount.
14 MR. MARK: Where in nature do you find an 15 oversaturated situation?
16 MR. BRADBURY: You find oversaturated situations 17 often in nature. Things can be out of equilibrium for 18 millions of years. If there is nothing to essentially drive 19 the reaction over the kinetic barrier to some more stable 20 situation, oversaturation can occur.
21 MR. MARK: You are drilling a hole in some 22 unperturbed rock or you are down there in the rock and some 23 water is floating around and you say it can be 24 oversaturated.
25 MR. BRADBURY: With respect to some minerals, yes, C
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I 59700101 64 marysimons O 1 because the temperatures may be low and the kinetics of the i 2 reaction are too slow for the reaction to occur. Generally 3 speaking, the lower temperature the environment, the more 4 kinetics comes into play. So a number of these chemical 5 mechanisms are affected by kinetics of the reactions and not 6 so much the thermodynamics 7 MR. PARRY: If the kinetics are delayed, how do
+
8 you know what is truly equilibrium?
t 9 MR. BRADBURY: This is a real problem that i 10 experimentslists are always running into, and one of the ~
11 limitations of experimentally determined solubility and 12 sorption parameters. The problem is to carry out the
-() 13 experiments for a long enough period of time so that you
! 14 have an indication of where his equilibrium will occur.
15 The prior diagram would essentially say, okay, I
{ 16 assume equilibrium will occur at this concentration although 17 I haven't reached equilibrium in either experiment. That
- 18 fact that the two lines are converging indicates to me where 19 an equilibrium situation will occur.
l 20 MR. PARRY: Is DOE doing any test like this?
l 21 MR. BRADBURY: I am sure they are on a limited 22 scale.
I 23 MR. PARRY: You are sure they are?
24 MR. BRADBURY: On a limited scale. We don't see 25 enough emphasis in discussions, you know, information O
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1 discussions, they tell us that, yes, we are doing that type 2 of ___
3 MR. PARRY: Have you seen data presented formally 4 at your review meetings?
5 MR. BRADBURY: No, I haven't personally.
6 MR. STEINDLER: The requirement that you approach 7 solubility from both sides in the context of a repository 8 related material requires that either the system be fairly 9 simple and you can obtain the solid phase and synthesize it, 10 or that you have an awfully good handle on a complex 11 assemblage of minerals.
12 I go back to my question on empiricism as I define
() 13 it. What is the position, in light of your comment that 14 solubility should be determined from both under and 15 oversaturation, when DOE runs into a fairly complex 16 assemblage of minerals where synthesis alone might in fact 17 be, if not very difficult, it is certainly a very time 18 consuming process and where kinetics are uncertain?
19 MR. BRADBURY: These are very difficult problems, 20 and as far as we are concerned, the quality of the 21 information depends upon how well they have characterized 22 products and done these experiments. If they take site 23 specific materials and put what they consider a site 24 specific solution in there and they figure they l
25 precipitation or sorption, we suggest that they identify the ACE. FEDERAL REPORTERS, INC.
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2 This bring up I think a real good example of what 3 we are looking for. In one of the EA's there was a 4 reference to an article. It is the most recent article 5 about sorption, and in that article it said that in our 6 batch tests we have not disproved precipitation when we are 7 doing the experiments with actinides.
8 Well, the actinides are what most people consider 9 the key radionuclides, the ones that we are most concerned 10 with. Now if in a batch test if thty don't prove that 11 precipitation has not occurred, then they cannot take credit 12 for retardation via the sorption process.
() 13 Let me explain this, and I will give you an 14 example.
15 If you take, for example, a beaker and put into it 16 silica beads, something non-sorptive, and then you pour into 17 it a solution containing radionuclides and precipitation 18 occurs, the experimentalist will take that solution, and he 19 doesn't see the precipitator, the experimentalist will take 20 that solution and say, ah, sorption has occurred and 21 therefore I can use that in my performance assessment 22 calculations, and using the KD, plug it into the equation 23 saying the retardation factor is one plus, and there is an 24 equation essentially that talks about how KD's and 25 retardation factors are related, l ACE FEDERAL REPORTERS, INC.
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()3 1 So the performance assessment person says the 2 radionuclides are retarded this much and they won't pass out 3 of the system given this retardation factor.
4 Now if you take that solution and you decant it 5 into a column that contains the same nonsorptive beads, the 6 radionuclides are going to pass through the system just as 7 fast as the water. So no retardation has occurred although 8 the test over here indicated they thought that sorption was.
9 occurring.
10 So the NRC's position is that batch sorption _ tests 11 are not enough. You can't rely on that because you are not 12 proving retardation.
() 13 MR. MOELLER: Well, I guess though the question I 14 immediately have is would not DOE's contractors or the 15 people doing their research similarly recognize this 16 problem?
, 17 MR. BRADBURY: This was a report by their 18 contractor.
I 19 MR. MOELLER: Where they made this error.
20 MR. BRADBURY: They made the statement, and again l-l 21 this is the latest document ---
22 MR. STEINDLER: But you are not suggesting that l
23 that is a non-remediable situation caused by the generic j 24 batch sorption experiment --- ;
I i
25 MR. BRADBURY: No.
l
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59700101 68 marysimons 1 MR. STEINDLER: --- but you are just saying that >
2 the experiment was poorly done. Are you saying batch 3 sorption experiments cannot .lar their very nature distinguish 4 between sorption and precipitation?
5 MR. BRADBURY: I am saying that in a batch 6 sorption test if you don't determine either what is sorbed 7 or what was transferred from the liquid to the solid phase, 8 then you haven't proved that retardation will occur.
9 MR. ORTH: That is not true. That is just a 10 question of the mechanism if doing the batch sorption test, 11 and anybody that I know who does batch sorption tests 12 usually knows what you have to do. Again, that comes down (O
,/ 13 to characterizing the product issue. You make that same 14 ( test that you just talked about and you decant the solution, 15 and if it is really a true sorption, when you repeat that 16 same test with that same solution on a fresh batch of beads 17 you will get the same result. If you don't, then you have
- 18 something else.
19 In either case, I don't have to characterize 20 products in order to demonstrate that it was a batch 21 sorption.
22 MR. BRADBURY: That is correct. What you can do 23 is you can run an sorption isotherm, and if you run a 24 sorption isotherm, then what you will find out is that the
, 25 two liquids, the final liquids will have different chemical l
l
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2 Essentially by varying the chemical composition of 3 the liquid, you can fall on different points on a curve. If 4 you fall ---
5 MR. ORTH: you don't have to vary the chemical 6 composition of the liquid either. I just take that stuff 7 from the first precipitation in the first test and you 8 repeat it on a new batch of beads, you know, the same test, 9 and if I end up with the same value, I've got a genuine 10 sorption phenomena. If I don't, I don't.
11 MR. BRADBURy: Possibly. We are talking in the 12 idea situation where everything goes to some steady state
() 13 concentration, but when they get these curves and they are 14 saying okay, well this is close enough, there are a number 15 of gray areas.
16 MR. ORTH: Well, I happen to agree. If people 17 don't do the tests right, they don't come out with the right 18 results, and that is true no matter what we do.
19 MR. MOELLER: Well, what is the conclusion that we 20 as a subcommittee should reach? It seems to me that either 21 DOE is hiring the wrong people to do the work, meaning they 22 are not fully qualified, or combined with that when DOE 23 reviews the results that are reported to them, they are not 24 doing a careful enough review of it, if indeed, as the r 25 implication is here, that NRC discovered this and no one (3)
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2 MR. STEINDLER: It seems to me that it is almost a 3 given that there is data that is in the literature that 4 isn't worth reading, and some of it is actually being put in 5 by DOE contractors, and some of them I know personally.
6 I think the issue that I tried to raisc here not a 7 question of whether or not there is lousy data in the 8 literature. Heaven, yes, there is all kinds of poor data in 9 the literature, and the job of the NRC is to try and make 10 sure that they can distinguish between good data and bad, 11 but not in a technical position.
12 The technical position addresses, to go back to my
(~N 13 i
(_) point, the technical position says it is going to be our 14 position, NRC's position to have DOE determine solubilities
! 15 from both undersaturation and oversaturation. And while 16 ideally that sounds grand, and is indeed the way you would 17 determine pure phase solubilities for say thermodynamic 18 purposes, you don't have very simple phases in this system, 19 especially in the mineralogy in some of the areas that I can 20 think of. It is a horrendous job that you can even figure 21 out what the phases are, to say nothing of trying to 22 synthesize them so that you can do the kind of experiments 23 we are looking at.
24 It isn't very clear to me that that is a 25 requirement. It gets back to my question of whether or not i O ACE FEDERAL REPORTERS, INC.
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( 1 they will take, so to speak, empirical data versus 2 mechanistic data.
3 What they are looking at here, it seems to me, is 4 they are looking for mechanistic data regardless of the 5 complexity of the system. I think that is nice and it 6 certainly would be preferred if we had infinite resources 7 and time. I don't think that DOE or anybody else has 8 infinite resources or time.
9 MR. MARK: Are you speaking of data at least at 10 some points connected with tests, that is to say explosives 11 set off in the Nevada test site?
12 MR. BRADBURY: No. The tests that I have been
() 13 talking about are in the lab.
14 MR. MARK: They are experiments directed at this 15 purpose?
16 MR. BRADBURY: Yes, In our position we say that 17 because of the limitations of laboratory tests in simulating 18 conditions that go on in the repository we would suggest 19 that in situ tests or studies of in situ tests and natural 20 analogues also be included in your overall program for 21 characterizing these parameters. So explosions and things 22 that look at underground nuclear tests we consider would be 23 important things to look at.
24 MR. MARK: Okay. But nothing you have described 25 came by that route yet?
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U 1 MR. BRADBURY: Right.
2 MR. MARK: And in order to get anything from such 3 a route which would itself be likely to be rather vague in 4 its quantitative relevance, it would take at least a year or 5 two to prepare to collect the kind of numbers that you would 6 find interesting because that is totally outside the range 7 of the things they normally do.
8 MR. BRADBURY: Yes.
9 MR. MARK: That means that we have to keep on 10 testing.
11 (Laughter.)
12 I have been searching for a good reason.
() 13 (Laughter.)
14 (Slide.)
15 MR. BRADBURY: The next position statement is that 16 we determined sorption parameters using multiple approaches, 17 and I have already discussed many reasons why this is so.
18 We don't know that much about the mechanisms of sorption.
19 We know very little about the mechanisms of sorption.
-20 So to fill that void, we suggest that more than 21 one approach be used to determine the sorption parameters, i
22 I am going to go right through these.
4 23 (Slide.)
24 This is an example of what one might want to 25 encounter in a repository. This might affect how you set up i
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2 (Slide.)
3 The next diagram shows the effects of experimental 4 protocol on certain sorption parameters, and you can see 5 that just stirring or shaking or whatever can change the 6 number by up to a couple of orders of magnitude.
7 MR. MOELLER: Again, though, is this where you 8 found people making errors, or you have observed errors, or 9 are you telling this to DOE 7 10 MR. BRADBURY: DOE knows this. What it appears to 11 us is that a lot of the emphasis is being placed on simple 12 cat ions, the sorption of simple cat ions in crushed
() 13 material, and the reason for that emphasis is because they 14 get very good reproducibility in their experiments. But it
- 15 is not all that applicable to the repository situation. So 16 we are saying let's go on.
17 (Slide.)
L 18 I have a couple of diagrams showing different 19 types of sorption processes. I'll skip through that.
20 (slide.)
21 As I mentioned earlier, in addition to the 22 laboratory tests, non-laboratory studies should be d
23 determined, and the reason for that is -- well, for example, 24 in situ testing -- you can use site specific materials that 25 are less disturbed than those that you have to take back to I ACE-FEDERAL REPORTERS, INC.
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l 59700101 74 marysimons O 1 the laboratory. The spacial scale might be closer to that-2 of a repository, at least it could be a little bit larger 3 than that in a lab.
4 MR. KERR: What do you have in mind when you talk 5 about in situ testing?
6 MR. BRADBURY: Well, examples might be like 7 putting a tracer down a well and determining how long it 8 takes to get to another well, or cutting a block out of rock 9 in a mine and determining how fast material passes through 10 that block. That is the type of thing, but it can go on 11 from there.
12 MR. KERR: I was just curious. I mean you had
() 13 something in mind when you wrote it.
14 MR. BRADBURY: That is what I had in mind. I am 15 sure there are otber things.
16 In terms of natural analogues now ---
17 MR. MOELLER: Well, I presume they doing it and we 18 will hear about that tomorrow. They are doing a lot of in 19 situ testing, and we saw it several years ago in the basalt 20 at Hanford.
21 MR. BRADBURY: Natural analogues is another 22 approach to take. Inasmuch as all of the experiments that 23 are carried out that I have described so far are limited in 24 terms of the time, and we are always concerned that we have
( 25 carried our experiments out for a long enough period of
(
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1 time, one procedure is to l'ock at natural analogues, 2 analogues of different aspects of the repository.
3 This would provide a closer approximation to the 4 time scale of the repository and likewise of the spacial 5 scale of the repository.
6 (Slide.)
7 This position statement concerning geochemical 8 modeling, this essentially says that we should limit the use 9 of geochemical models, that is limit the use of geochemical 10 models for interpreting the experimental results of our 11 solubility and sorption tests and for planning experiments.
12 These geochemical models that I am talking about
() 13 are models that predict solubilities of radionuclides, and 14 they aren't the models that might be used in performance 15 assessment calculations.
16 MR. STEINDLER: Did you say you should limit them?
f 17 MR. BRADBURY: Limit the use of the models that i
18 predict solubility and sorption to just explaining what the 19 experiments are showing us, and don't use the models to tell 20 us what the solubility of a radionuclide is. Use the model 21 to compare it with, you know, the experiments to say, yes, l 22 our experiments show that the data that we have, the input 23 data for this model is correct or it isn't correct and 24 modify the model, depending upon the outcome of the
-s 25 experimental work.
(_)
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1 What we are saying is use experimentally derived 2 data and don't come up with theoretically derived data 3 concerning solubility and sorption.
4 MR. MARK: Dade.
5 MR. MOELLER: Yes, Carson.
6 MR. MARK: I'm sure I don't really understand 7 everything you are telling us. I am supposing that we are 8 talking of a situation where we have a pocket of nasty 9 stuff, a mixture of isotopes and chemicals, and we are 10 worried about how quickly this will get from where it is 11 emplaced to some distance away.
12 Now with the experiments you have described, we
() 13 know that it can't get there quite as fast as the speed of 14 light. In fact, we are pretty, or at least I am perfectly 15 willing to assure that it can't get there any faster than 16 the speed of water, which is a measurable I suppose kind of 17 thing, or is in fact maybe one of your assumptions. How 18 long does it take for water from here to get to there.
19 Nothing can go faster than that.
20 Now you say it needn't go that fast because of 21 absorption and supercrystalization or such phenomena which 22 will slow it down. It is not necessary, I would guess, 23 under all circumstances to know by how much it slows it down 24 if some earlier simpler estimate has said that is long l 25 enough and I don't really care.
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1 MR. BRADBURY: Yes, that is correct. If it can be R 2 proved by the hydrologists that the water doesn't get here 3 from there fast enough, then sorption and solubility are a 4 no-never-mind.
5 MR. MARK: That was my vague feeling. How much 6 are we improving the picture by the work that you are 7 describing? You will never be willing to come out and say 8 it can't travel as fast as the water, but the water only 9 goes so fast, and you will never persuade all the 10 intervenors that it can't.
11 MR. BRADBURY: I don't believe that the 12 hydrologists haven't yet proved that the water, you know,
() 13 that water won't get there within a particular time.
14 MR. MARK: Oh, they will always invent little pipe 15 which run at infinite speeds.
16 (Laughter.)
17 But you might feel in your own conscience that I
- 18 know damn well, that it doesn't go any faster than this.
19 I wonder why it is necessary to push that terribly 20 much further?
21 MR. JUSTUS: There are some reasons for doing so.
, 22 MR. MARK: That is the kind of question I am 23 asking.
t 24 MR. JUSTUS: The waste package and materials 25 engineers need to understand the environment that their ACE-FEDERAL REPORTERS, INC.
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1 waste package will see and be subjected to, and the 2 environment that they need to understand is the chemical 3 environment, the chemical conditions of that waste package, 4 the understanding of that environment.
5 MR. MARK: The thermal and chemical.
6 MR. JUSTUS: Yes, and pressure, and also the redox 7 condition and the chemical composition of the backfill and 8 the water at various stages of evolution of the water as 9 time goes on.
10 Also, some components of the engineered 11 repository, whatever they may be, need to be sensitive to 12 the chemical changes that occur with time due to radiogenic
() 13 heat loss, rise and loss, and water chemical changes 14 commensurate with that, resaturation and outflow.
15 I guess what we are saying is there are reasons 16 for geochemical investigations to go on regardless of 17 whether DOE wishes to say that radionuclides travel to the 18 l accessible environment at a particular rate less than water 19 travels.
20 MR. MARK: I am just a little concerned, 21 fascinating and complicated as this is, whether one need 22 push it as far as it sounds as if they have tried to push it 23 because you will wind up with a scene in which you say we 24 have proved that instead of a thousand years, it is going to 25 be 2300 and who will care.
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59700101 79 marysimons O 1 MR. JUSTUS: Well, we appreciate your question and-2 we asked DOE that question, how far do you want to push it.
3 MR. MOELLER: Okay. Let's move on then.
4 (Slide.)
5 MR. BRADBURY: The last position statement is 6 common to both and it really covers all of our major 7 position statements. We suggest that all the sources of the 8 uncertainty be characterized and documented. We want to see 9 what the DOE thinks the sources of the uncertainty are, and 10 these can be both conceptual, that is do we have the right 11 concept for the repository and experimental, the precision 12 and the uncertainties that comes from just the experiments
() 13 themselves.
14 As with our other position statements, by doing 15 this, chis would help determine whether the data are again 16 realistic or conservative, how good they are really.
17 MR. MOELLER: I have noted in neither of the 18 reports, neither of the GTP's did you offer any comments 19 about validation of the experimental approach or models 20 used. Is the reason for that because all validation is 21 covered in another technical position? Why was it not J
l 22 mentioned in neither of these?
23 MR. BRADBURY: The definition of validation 24 being? Can you explain ---
25 MR. MOELLER: Well, there are even procedures to 4
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2 MR. LINEHAN: It is something we are dealing with 3 generally in association with the QA program, what types of
, 4 technical procedures are necessary, whether it is 5 experiments, whether it is running models codes, how you go 6 about validating them and verifying them, this all falls 7 under the general QA umbrella.
l 8 MR. MOELLER: Okay. That is what I wondered. I 9 at least I think would have put a sentence in both of these 10 saying that is covered elsewhere.
11 Does that wrap up then this?
12 MR. BRADBURY: Yes.
() 13 MR. MOELLER: With the subcommittee's concurrence, 14 I would like to just call now for general comments on each 15 of the two generic technical positions.
I 16 I picked up the one on solubility first. Why 17 don't we go through it and offer the staff any specific 18 comments that we have. We could talk generally or talk in 19 terms of specifics.
20 I can lead off. I found right on page 1 that I 21 didn't understand really in the first paragraph on the 22 purpose. The first line says "The purpose of this document
[
23 is to present a general approach," and then the second 24 sentence says "It is not intend to prescribe methods."
, 25 Well, that is largely I guess what we have been l
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i marysimons O I discussing this morning. I don't think that you followed i
2 your purpose, and it seems to us, and you have heard us, 3 that you are prescribing methods.
4 MR. BRADBURY: Our definition of prescriptive is t
5 like a recipe for baking a cake. We don't want to give them
. 6 the recipe, but we want to tell them what cakes to bake.
7 That is the analogy we used. Now whether that is correct or
)
s l 8 not, we have been very concerned about what is a document 9 that provides guidance and what is one that provides too 4
10 much guidance and becomes prescriptive. '
l
- 11 We have considered this for a long time and have 12 tried to figure out some reasonable approach to this.
i
() _13 MR. KERR: Do you have an intention to provide the i 14 DOE either formally or informally the accuracy that they 15 need to demonstrate in their data, the accuracy that will be 16 acceptable to NRC in specific situations?
17 MR. BRADBURY: We haven't put any numbers ---
, 18 MR. PARRY: Do you mean accuracy or precision?
i 19 MR. KERR: I don't know whether I mean accuracy or
! 20 precision. I am willing to accept an answer in either one.
l 21 It seems to me that the way in which one goes about an l
22 experiment depends considerably on what one is trying to l 23 achieve, and some guidance in this, if it not given earlier, l
24 may have to be given later on when you have determined that 25 'he data are not accurate enough.
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1 MR. BRADBURY: Well, as you said, it depends upon 2 the particular experiment that you are running.
3 MR. KERR: Well, let's suppose it does. Have you E picked out those where you want very accurate results and
, ,- 5 very precise results, or others in which it is not 6 important?
7 MR. LINEHAN: I think the first step is DOE has to 8 talk about performance allocation. They have to lay out 9 what they want to do with that data. One of the things they 10 are going in the SCP is when you look at all the different 11 technical areas and all the different components of the
- 12 system, the waste package, the release from the waste
() 13 package, retardation by the engineering barrier, retardation 14 by the natural system, they are going to have to determine 15 how they want to allocate the performance and they are going 16 to have to design experiments and determine what data they 17 j are going to need to be able to prove the case.
18 We will give them guidance once they take the 19 initial step.
20 MR. KERR: I am simply asking are you giving them 21 guidance, and what you are going to mean by proving their 22 case and what will you accept as proving their case, or you 23 are not going to decide that until you see the case?
24 MR. LINEHAN: What I am trying to get at is I 25 don't think we can give them that guidance until they tell O. -
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1 us what they want to do with the data, for example, if they ,
2 want to use the solubility data and the sorption date for a 3 opecific purpose to show that something is h'appening.
4 MR. KERR: Let me oversimplify'and say that they
~
5 are going to demonstrate that the water t, hat travels from 6 point "A" to point "B" will take a thousand years, plus or 7 minus 300 years. Is that an acceptable accuracy if your 8 goal is 1000 years? I mean they might decide that that" 9 would be appropriate. Would you accept that?
10 MR. LINEHAN: That is regarding just the 11 groundwater travel time. That is one of the things that we
'12 have laid out in the GTP on groundwater trave 1' time. We ,
() 13 have laid out proposals and we have questioned -- that is 14 out for public comment, or it is going out for public 15 comment. ,
16 MR. JUSTUS: It is out already.
17 MR. LINEHAN: It is out. That is one of the 18 questions we have posed that we are asking people to comment 19 on. We are going to give DOE guid&nce in that area, yes.
20 But when you take that step further and you are 21 talking strictly about groundwater travel time, that is 22 simple. If you are talking about compliance with the EPA 23 standards, you know, the uncertainty you can live with is 24 going to depend on how that builds in with the other l 25 uncertainties.
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1 MR. KERR: I do not propose to be able to give a 2 recipe for the way in which you describe that, but it seems 3 to me it is a fairly important item and it will have a 4 tremendous influence on how much research and the point of 5 the research.
6 If, as Carson suggests, if it could turn out that 7 that would be the only question, for example, that one,would 8 ask, that groundwater travel, then probably not. There must 9 be parts of this that are more crucial than others, and 10 which ones need better or worse data?
11 I don't pretend that it is an easy thing to do, 12 but at some point you have to either explicitly or es
( 13 implicitly decide on this.
14 MR. LINEHAN: You are absolutely right. The 15 problem we are facing on this right now is we don't know 16 enough about a lot of these sites. you know, when you talk 17 about relying on the groundwater travel time, and taking 18 BWIP as an example, there is the question there that DOE 19 doesn't know how well they are going to be able to 20 characterize that site due to the fracturing, for instance, 21 and how good a handle they are going to get on just the
! 22 flows there.
23 Because of that, you know, until they get down i
l 24 there and they do their experiments and they do their large-25 ccale hydrologic testing and thingc of that nature, there is 7-l l
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59700101 85 marysimons O 1 just so much uncertainty and we are not at a point right now 2 where we can define things better for them.
3 We do have to do that as they develop the data.
4 MR. KERR: Let me ask another question. Let's 5 suppose that one sets a number for groundwater travel, if it 6 turns out to be an important parameter, of 1000 years. One 7 could satisfy that by determining using a best estimate 8 calculation or data or whatever that you achieve a thousand 9 years but the uncertainty is plus or minus 200 years.
10 You could require that they demonstrate that the 9
11 best estimate is 1200 years in order to satisfy the 1000 12 year criteria, or you could decide that the 1000 year best
() 13 estimate with an error of plus or minus 200 is acceptable.
14 Which of those two kinds of approaches are you likely-to 15 take? And I am not suggesting that you give me an answer 16 now, but it seems to be that kind of thing in some sense 17 that is almost independent of the site. That is a policy 18 question.
19 MR. LINEHAN: That is right there when you get a 4
20 fixed number, you know, of a thousand years. In that case j 21 we have started to do.that in the GTP on groundwater travel 22 time, and we are going to make a call like that. We are 23 going to come up with something. ,,
24 MR. MOELLER: Let me just mention a couple more i
25 items that I had in this one.
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1 I have got some editing that I will suggest to 2 you.
3 On page 4, just below Item 5 in the last sentence 4 of that paragraph it sort of stands out alone. It says 5 "When combined with a judicious choice of key radionuclides, 6 this approach will maximize the usefulness of the 7 information obtained from a minimum number of experiments."
8 We have discussed it, but it seemed to me, and I 9 am nit-picking, but it will maximize hopefully the 10 usefulness of the information obtained from the 11 experiments. Whether it is a minimum number, I don't know, 12 but in my opinion, it would simply read better to say in the
() 13 last line "obtained from the experiments."
14 MR. KERR: It seems to me it is unfortunate in 15 that sentence it maximizes the minimum.
16 (Laughter.)
17 MR. MOELLER: That dates you you know in terms of ,
18 music.
19 (Laughter.)
20 On page 5 ---
21 MR. STEINDLER: Before you leave 4 may I inject 22 something here.
1 23 We got into a lot of discussion during the course 24 of the presentation about the business of identifying the
- 25 solid phase, and then I read on Item 2, it says, " Determine
()
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v 1 experimental run product compositions for liquids and, where 2 feasible, solids using analytical methods. . . ."
3 Well, supposing by declaration I say it isn't-4 feasible. Then what do I do, present you with a bunch of 5 data that you can't use or you refuse to accept?
6 The other point that I would have is why do you 7 insist on the state of the art technique? I mean those are 8 great sounding terms, but ---
9 MR. BRADBURY: In fact, I don't really like the 10 term.
11 MR. STEINDLER: That is prescription in the most 12 useless since I think.
() 13 MR. BRADBURY: Yes.
14 MR. STEINDLER: But I have a fundamental question, l
15 Dade. The technical position purpose outlined here, it 16 says the purpose of this document is to present a general 17 approach for determining solubility.
18 Now how, is that is true, how does that differ l 19 from a good textbook on physical chemistry, which this is 20 not?
21 MR. MOELLER: Yes. you are hitting at what has 22 trouble me from the very beginning and why I and you have l
23 asked about some of these drawings, were they provided to 24 DOE or did you keep them for yourself.
j gs 25 There is nothing wrong with this, but I do receive l 0 l
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f 59700101 88 marysimons O 1 the impression, and I have done the same thing, that this is 2 a good exercise for the staff to go through the preparation 3 of a document such as this, and they should do it in that it 4 helps them think through how the experiment should be done 5 and so forth. And I think having done the exercise then, I 6 really don't know what you do with the report.
7 MR. STEINDLER: I think you throw it away because 8 you have gone through your learning process and have taken 9 physical chemistry 362 and you now know what it is likely to 10 be coming at your from the Department of Energy.
11 It strikes me that DOE, however, is still looking 12 for something that is not here, and that is a statement of
() 13 what is the technical position about important issues, not 14 how to do it, but important issues of what they are going to 15 need in the area of, in this case, solubility, the next 16 case, water travel time and what-not.
17 It seems to me that the problem that DOE would 18 have or any applicant has is not being able to guess as to 19 what the staff will thing is important.
20 MR. CARTER: Yes. I have the same exact problem.
21 MR. ORTH: And I think I have already expressed 22 myself.
23 MR. MOELLER: Okay. Well, that will be obviously 24 a comment.
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1 minor, under 4.1 I had a little trouble as a reader. I 2 could understand the variables which should be included 3 include temperature and pressure, and I guess I wanted to 4 say ionizing radiation exposure rates or something. I mean 5 you didn't say thing things that should be included are 6 solids and liquids. You said the solid composition and the 7 liquid composition.
8 I guess for me I would have said ionizing 9 radiation exposure rates because I think that is probably 10 what you meant.
11 MR. STEINDLER: Isn't it a little strange to say 12 that prior to experimentation, the total range in r~g (j 13 compositions and proportions of phases that occur anywhere 14 at any time in the repository should be considered?
15 MR. MOELLER: Right.
16 MR. BRADBURY: I think that is saying keep an open 17 mind here.
(
18 MR. STEINDLER: Prior to experimentation ---
19 MR. MOELLER: That is the purpose.
20 MR. STEINDLER: I mean don't you allow these folks 21 to say, look, there is a frame of reference we have called 22 the repository about which we know something. This is not a 23 totally black box which we are going into. You are not 24 allowing them to constrict the range of things that they 25 look at?
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1 MR. BRADBURY: No.
2 MR. STEINDLER: You're not?
3 MR. BRADBURY: I am not restricting them.
4 MR. STEINDLER: But are you allowing them?
5 MR. BRADBURY: Yes, I am allowing them.
6 MR. STEINDLER: You are? That is not what this 7 sentence says.
8 MR. JUSTUS: Well, I believe the sentence suggests 9 that we consider it prudent for DOE to consider the range of 10 variables in the repository that are to be simulated by 11 their experiments. We don't tell them they must do it.
12 MR. STEINDLER: If that what you mean, that is not
() 13 what I read. It is possible that people will take you 14 literally.
15 I got hung up on the experimental proscription 16 about taking Eh and pH measurement at temperature, aside 17 from the fact that Eh measurements are likely to be more 18 random than anything else because to get them in a 19 reasonable fashion is very difficult. High temperature pH 20 measurements continue to be illusive even under the best 21 conditions, and Eh measures, as far as I know, have not been 22 done and reported sensibly in the literature.
23 What are you asking from these poor guys?
24 MR. BRADBURY: There have been a number of 25 comments about that portion.
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L 59700101 91 marysimons O 1 MR. STEINDLER: I hope so. ,
' 2- MR. BRADBURY: And it wouldn't hurt the NRC in the 3 least to remove it.
4 MR. STEINDLER: Okay.
I 5 MR.'MOELLER: What page was that?
6 MR. STEINDLER: The bottom of 6 and the top of 7.
7 MR. KERR: Well, what's wrong with you chemists 8 that you can't measure pH7 9 MR. JUSTUS: Generally we are stupid.
10 (Laughter.)
11 MR. KERR: That-has been around for year and 12 years.
j
() 13 MR. STEINDLER: The best numbers that we get we 14 get out of a computer.
15 MR. MOELLER: Page 12 ---
16 MR. BRADBURY: I was just going.to say one thing 2
17 though, that EH and pH are two very, very important 18 parameters ---
19 MR. MOELLER: Absolutely.
20 MR. BRADBURY: --- that very strongly affect the i
j 21 solubility ---
l 22 MR. KERR: If nobody can measure them how do you 23 know they effect solubility?
24 MR. STEINDLER: you folks insist on measurements,
! 25 separate measurements of Eh and pH and you will not allow l (
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1 the only sensible way to do that, namely, you let the 2 behavior of a multi-valent actinide give you what the 3 effective Eh and pH of the system is. But you won't allow 4 that at this stage of the game because you insist on having 5 in a sense mechanistic data and you won't the empirical 6 data.
7 MR. BRADBURY: I don't think the multi-valent ion 8 that you are talking about, the radionuclide, which is but a 9 trace element in the geological system is going to control 10 the Eh and pH of the ---
11 MR. STEINDLER: You are not asking for control.
12 You are asking for measurement, unless I misread it, which
() 13 is possible. What you are talking about here is the 14 measurement of Eh and pH, and what I am saying is that 15 instead of requiring direct measurement of Eh and pH why 16 don't you let the behavior of an actinide serve as the 17 marker for what the Eh and pH in that system is, controlled 18 by whatever experimental buffering technique you want. But 19 judging from all the comments we have heard so far, you i 20 won't allow that because that would be in effect an 21 empirical, as least as I define it, an empirical approach.
22 MR. BRADBURY: So you are saying to determine the 23 amount ---
24 MR. STEINDLER: Measure the migration of neptunium
. 25 in the cystem you have got.
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59700101 93 marysimons 1 MR. BRADBURY: As a particular species in the i
2 system.
3 MR. STEINDLER: Yes, and infer from that what the 4 valent state has to be knowing something about the chemistry 5 of neptunium. You can do it at any concentration you want.
6 MR. BRADBURY: We agree that the Eh and pH of a 7 system may not effectively set the radionuclide valence of 8 that species in the system. For example, one of the 9 statements made by the DOE is that the system is chemically 10 oxidizing or chemically reducing, and therefore all of the 11 radionuclides that are in there. If it is chemically 12 reducing, then all of the radionuclides are in their reduced
() 13 state, and we have not bought off on that particular 14 argument.
15 Although the environment may be a reducing 16 environment, oxidized radionuclides may exist under that 17 kind of a situation.
18 MR .- STEINDLER: My comment was related 19 specifically to the requirement that you have here which I 20 think is unrealistic.
21 Now I agree that this is not a requirement with a 22 capital "R" and you insist that this is guidance, but 23 sometimes I think folks look at your guidance and say well 24 that is next to the law. So I think you have to be a little 25 careful what you write.
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1 MR. MOELLER: Don.
2 MR. ORTH: I still have a question. Did you 3 really want to go over page by page?
4 MR. MOELLER: I think major things.
5 MR. ORTH: Well, then let's pick on page 7, which 6 is where we are. In the top paragraph there underneath the 7 Eh and pH that we have just been talking about includes that 8 business of analytical techniques for characterization of 9 the products and determining which reactions and that sort 10 of thing. I think we have discussed already to some extent 11 that characterizing what you have produced is nice, but it 12 may be impossible in some conditions and even state-of-the 13 art techniques may not get you there, and that sort of 14 thing.
15 MR. BRADBURY: We agree.
16 MR. MOELLER: Okay. Any other general comments on 17 this anywhere in it?
18 MR. STEINDLER: Is there some reason why you don't 19 discuss or at least touch on colloids and colloid formation, 20 or have I missed it?
21 MR. CARTER: Yes, I noted that, too, like on 4.4.5 22 that colloids is not mentioned.
23 MR. BRADBURY: Da page 13.
( 24 MR. MOELLER: I remember seeing it.
i l 25 MR. CARTER: Yes, 4.4.5. Do any of those things l
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I form colloids, these key radionuclides?
2 MR. BRADBURY: Yes, they do.
t 3 MR. CARTER: It would be a helpful mechanism, and 4 I would think it would help the retardation considerably.
5 MR. BRADBURY: But there are scenarios in which 6 you could say that it would hinder the retardation.
7 MR. CARTER: I can move liquids through these 8 materials a lot quicker than I can solids through them.
9 MR. BRADBURY: One of the mechanisms that the Yuca 10 Mountain site is calling on is matrix diffusion in which 11 again the water is flowing through a fracture. If the 12 colloids are too big to flow into those pores, matrix
() 13 diffusion would not occur. Thus, retardation by that 14 mechanism would not occur.
15 So there are cases where, yes, colloids are good 16 and cases where, no, they are not good.
17 MR. MOELLER: Other comments?
18 MR. PARRY: Are you planning to look into the 19 question of which isotopes are of concern? That is, you 20 have the limitation in 10 CFR 60 that only those isotopes 21 having a release rate consisting of 1/10th of 1 percent of
. 22 the thousand inventory need be considered. Has that been 23 defined? Has there been a technical position written on 24 that?
25 MR. DRADBURY: There hasn't been a technical i
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, 59700101 96 marysimons 1 position written on it, but we have been concerned about 2 what are the " key" radionuclides. We had reviewed a number 3 of documents that had also addressed the same concern and as 4 of yet Je haven't produced our own GTP on that.
5 But in terms of the key radionuclides, most of the 6 documents so far say that the actinides, americium, 7 p1'utonium and neptunium and uranium, and thoce are the I 8 radionuclides that we think should be studied for solubility 9 and sorption.
10 MR. PARRY: Beside the EPA Table 1 isotopes, too.
11 They must be considered.
12 MR. STEINDLER: I have one other questions.
() 13 MR. MOELLER: Okay.
14 MR. STEINDLER: On 4.4.2 on page 11 and 12 you 15 give a short synopsis of the problems determining the redox 16 conditions, and it is one of these two-handed scientists 17 kind of operations.
t 18 At the end of that I couldn't tell what the NRC 19 position concerning the measurement of the redox potential 20 is. Can enlighten me on what is it you guys are looking 21 for? You have given a pretty good indication of the 22 problems.
23 MR. BRADBURY: There are problems. It isn't 24 stated there, as you correctly have observed what our 25 position would be. If it were up to me, I would say that we at least need an attempt at determining the redox, the Eh ACE-FEDERAL REPORTERS, INC.
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3 This is another part of characterizing your 4 experiments, the products of your experiments. You are 5 looking at the composition of the solution that results from 6 your experiment.
7 MR. STEINDLER: Well, I can extract out of this 8 paragraph a statement that says it is not worth the trouble, 9 because supposing I identify several redox couples, and you 10 indicate frequantly th! systems are irreversible and 11 frequently clearly incrmpatible. So why do I bother?
4 12 MR. BRADBURY: I defer to Dave Brooks.
() 13 MR. BROOKS: I would like to make a 14 clarification. I think there is a misunderstanding that is 15 prevalent. Our position is covered in Section 3.0. The 16 discussion sections were attempts to show why each position 17 point was important to the NRC and that this particular ;
18 section on redox, and none of these sections in the 19 discussion section are supposed to be taken as additional 20 positions by the NRC.
21 We are saying merely under that particular one 22 that it is a source of uncertainty and we are trying to j 23 describe why we think redox is a source of uncertainty and 24 needs to be discussed under that position point. So maybe i
.5 that is not coming out.
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!C:) 1 MR. STEINDLER: Your statement then is that the l
, 2 NRC's position is that the redox systems need to be 4
i j 3 established?
4 MR. BROOKS: We feel a-position needs to be 5 written on redox. It is not contained in this document. We j 6 feel that a source of uncertainty in conducting solubility 7 experiments involves an understanding of redox, and that is
}
8 the only purpose of that discussion in there.
9 MR. KERR: The purpose here is to establish that 10 the subject is confusing.
11 MR. MOELLER: Any other comments on this one?
l 12 (No response.)
i
() 13 Let's move on to the other one, which is the one 14 on sorption.
l 3 15 I guess this is for my own education, but in the I
16 first sentence again of the purpose on page 1 it says that l
17 this is a general approach for estimating radionuclide t
j 18 sorption on solids.
19 Is that the only way that they would be held up, i
20 and are solids the only thing you sorb on?
l
} 21 MR. BRADBURY: Yes.
I i 22 MR. MOELLER: That is a straightforward answer.
j 23 Now on page 3, in the first full paragraph, you '
j i 24 say in the first line that DOE determines how much credit i
{ 25 can be taken for sorption. Is that correct? I guess they I
i I
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i determine how much credit they want to take for it? Is that 2 what.you are saying?
3 MR. JUSTUS: That is what we mean.
4 MR. MOELLER: I am moving along rather rapidly, 5 but on page 5 in Section 3.0, the statement of position.
6 You have two sentences. The first one says "It is the 7 position of the NRC Staff that sorption parameters chall be 8 based on experimental data," and then "The staff considers 9 that if the following points are included in the DOE 10 experimental program, equilibrium constants can be 11 derived." Then you say "Such a strategy is vital," et 12 cetera.
() 13 I guess I didn't see that as a strategy, but maybe 14 it is. What is the strategy?
15 MR. BRADBURY: This is the strategy by using this 16 technique to determine parameters that might be useful in
' 17 extrapolating to repository conditions, that is these so-l 18 called equilibrium constants.
l j 19 MR. MOELLER: Well, you have given me two 20 statements, that sorption parameters shall bo based on l 21 experimental data, and then if you include the following
- 22 points in your experimental program the equilibrium 23 constants can be derived.
- 24 I would have said then at the beginning our l
l 25 strategy is that, sorption processes or equilibrium i
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1 constants will do thus and so or can be used for thus and so 2 or will be adequate to do something.
3 I never, as I said, understood what your strategy 4 was.
5 MR. STEINDLER: Before you go on, may I go back a 6 page.
7 MR. MOELLER: Yes.
8 MR. STEINDLER: On page 4, the first full 9 paragraph under the approaches for sorption determination, 10 2.2.
11 The last sentence says "This technical position 12 should not be construed as endorsing either approach,".and
() 13 it discusses the two things above it.
14 Where does that leave you? It leaves you with no 15 approach whatever.
16 MR. BRADBURY: We have had other comments 17 concerning this section here, and the suggestion is that we 18 delete it, and we plan to delete it because it appears that i
i
- 19 we are trying to endorse something, or at least we should if j
20 we mention it. So we plan to delete it.
! 21 Can I pick up the same place you had. You keep 22 talking about the equilibrium constants, and some of these 23 systems come to equilibrium very slowly.
24 MR. BRADBURY: Yes, that is a poorly ---
25 MR. STEINDLEH: At no place in here do you even i
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ll 59700101 101 j marysimons 1 strategy here and I ignore kinetics, I will not get to 2 equilibrium. I will get to steady state or maybe what we 3 think is steady state with an experimental error, but I will 4 not get to equilibrium.
5 MR. BRADBURY: A different term would be better 6 there.
7 MR. CARTER: I have got one on page 6 in Item 4, 8 for example, where you talk about the applicability of 9 sorption parameters to repository performance, and you 10 mention that before the multiple approach, but that to me 11 seems extremely open ended, and should you do three of these 12 or 17 or 81 or just what? I think that could be worded
() 13 perhaps somewhat differently.
14 MR. BRADBURY: Where was that? I'm sorry?
15 MR. CARTER: That is ---
16 MR. ORTH: Top of page 6.
! 17 MR. CARTER: Yes, in the statement of position, 18 item 4.
, 19 MR. MOELLER: And say again your comment, Mel.
j 20 MR. CARTER: Well, to use multiple approaches, you l 21 know. It says by using various experimental approaches, and
- 22 then it gives very specific kinds of those. Well, to me 1 23 that is a very open ended kind of a wording. That is like f 24 bring me a rock, and how many rocks do you need.
l 25 MR. MOELLER: On the same page in Section 4.0, the r
i l
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1 59700101 102 l marysimons i 1 last line of that opening paragraph, and I am really nit-2 picking, but you say "There is reasonable assurance that the
- 3 radionuclide migration is not underestimated." You mean the
- 4 rate of radionuclide migration.
5 On page 7, the middle paragraph, I had a lot of 6 problems, and I don't remember what they were, but go to the 7 fourth line, and you say "Some radionuclides may occur in 8 low enough quantities that, if they need NRC release rate 9 requirements, they will not contribute significantly to 10 exceeding these limits."
11 Well, if they meet the release rate requirements, 12 how would they exceed the limits?
I () 13 MR. BRADBURY: Yes, I think there is a problem in 14 terms of the reference of the pronoun. I think we may be 1
15 talking about NRC requirements and then also something about 16 the EPA limits at the accessible environment.
l 17 MR. JUSTUS: These limits in that sentence I a
18 believe are referring to the EPA concentration rates. The 4
19 earlier part of the sentence is referring to the 10 to the l 20 minus 5 release rate of Part 60.
21 MR. MOELLER: Oh, okay.
22 MR. STEINDLER: In the paragraph above that you 23 talk about the establishment of a relationship between 24 sorption mechanisms and experimental values. You keep
- 26 looking for sorption mechanisms as a product of an ACE-FEDERAL REPORTERS, INC.
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V 1 experimental program, and presumably DOE's.
2 The same point I made the last time, only here it 3 is even more difficult to get the sorption mechanism in the 4 true mechanistic sense is a job which I am not sure is even t
5 rationally possible in the time scale that DOE has or is 6 supposed to have considering the complexity of the solid 7 phases that these folks are going to have to put up with.
8 Somewhere it seems to me this document ought to at 9 least allow recognition, explicit recognition that there may 10 be a problem in getting at mechanisms and that mechanistic 11 information is not the only thing you will tolerate.
12 MR. BRADBURY: We are very aware of that and this (q
_) 13 was more of a goal and it should have been stated as such.
14 MR. STEINDLER: This will be read as your 15 technical position presumably.
16 MR. ORTH: And in the middle of that same 17 paragraph where you are talking about the matrix 18 development, the combination of the parameters and the size 19 of the matrix would be greatly reduced by considering the 20 dependence of interrelation of phases and deleting those 21 things, that again amounts to a lot of advice on how to save 22 a little time or money or something like that and being not 23 very specific.
24 MR. BRADBURY: That is the way of these generic 25 technical positions, you know, they are not very specific.
O.
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1 MR. MOELLER: Okay, other comments in the report 2 anywhere?
3 MR. ORTH: Well, getting to 4.2. Again, there is 4 a long discussion having to do uith characterizing 4
5 experimental material and products. I think the same sort 6 of generic thing we raised with the solubility one comes in 7 there. Defining the products can be overemphasized. If
! 8 somebody says I am going to let you use that data because i 9 you can't tell me what the product really was. Granted,
! 10 there are things that enter into that, but at least we don't 11 want to be so prescriptive that people decide that if you 12 can't decide what really happened, then you can't use the 13 data.
i 14 MR. MOELLER: Okay.
j 15 MR. STEINDLER: Can I move you to page 9.
16 MR. MOELLER: Fine.
4 j 17 MR. STEINDLER: you talk about this apparent i
[ 18 concentration limit approach, but what you don't say in here ,
1 i
19 is that somebody needs to pay attention to not only say the 20 actinide under consideration or whatever it is that you are j 21 looking at, but the ancillary lonic or even non-lonic 22 constituents of the groundwater system that have a strong i
i 23 influence on the sorption isotherm, but you are silent on 24 that issue.
i 1 25 The impression I have is that you didn't recognize l
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1 it or you didn't think it was very important. Since I 2 submit to you that they are likely to be determining i 3 factors, you wouldn't want to run an apparent concentration 4 isotherm varying just say neptunium and leaving at some R
5 strange concentration everything else that complexes 6 neptunium and strongly influences the sorption isotherm.
! 7 MR. BRADBURY: The isotherms are drawn showing I B just the variation of the radionuclide. All small fractions 9 of the other components are held constant.
10 MR. STEINDLER: Well, that is precisely my point.
11 The data from those kind of experiments aren't worth much.
! 12 MR. BRADBURY: What we are saying is to generate a
() 13 family of sorption isotherms showing the effects when you l
14 vary these other components.
15 MR. STEINDLER: Well, if that is what you say
]
l 16 here, fine, but that is not what I read. That is explicitly i 17 not what I read.
. 18 MR. ORTH: Let me go back up then near the top of l 19 page 9 because there was an issue mentioned here at the 20 bottom of that top paragraph which is underemphasized I 21 think in the rest of the report and could be emphasized 22 because it deals with a lot of these other things, 23 specifically the last sentence. "Because sorption is 24 predominantly a surface phenomenon, the surface area of the
{ 25 solid may strongly affect the experimentally determined
() '
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1 sorption parameters, et cetera.
2 The fact is not just may strongly affect. It does 3 strongly affect, and basically most of these sorption 4 phenomena, as opposed to diffusion into an ion exchange 5 beam, but in the rocks in most cases it is really the 6 surface area that is the determining fact. Now remembering 7 the quibbling we had with why some of the crushed rock data 8 aren't good because too much surface area and that sort of 9 thing, what really is happening and what we should emphasize 10 is that the surface is really the thing, and if you are 11 going to compare two batches of solid, what comes out of the 12 repositcry and somewhere else, it is that surface that area
() 13 that determines whether it is a decent comparison.
14 So in emphasizing the surface area, maybe 15 elsewhere it is sort of a thread that hangs together why a 16 bunch of the other stuff is not to good. So this one I 17 think could be emphasized and put back in all of the 18 sorption point.
19 MR. STEINDLER: But the caveat is that it depends 20 on the kind of surface area. It is not necessarily the BT i 21 surface area that is important. It is the surface area 22 accessible to the liquid containing the ions that you are i 23 Interested in, and then the statement is compelling. Don i'
24 has a perfectly good point.
25 MR. MOELLER: Okay. Any comments on the next i ACE-FEDERAL REPORTERS, INC.
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1 couple of pages?
2 I know it is a nit, but it is another one that I 3 consider worth mentioning. On page 11, in the middle of the 4 page you begin a new paragraph, and you say "To verify the 5 applicability" of thus and so, "the site should use multiple 6 experimental approaches.
7 I would at least say the investigator or the 8 applicant or somebody.
9 MR. MOELLER: Okay. Let's go ahead with others 10 and wrap this one up.
11 MR. CARTER: Dade, on page 13 there are a number 12 of comments in here. It is talking about some natural A
(_) 13 analogues, and of course there are others here.
14 If you look just above Section 4.5, I think that 15 last sentence there really doesn't add very much. It says 16 you have got to have a good analogy or you shouldn't use 17 it. I can't disagree with that.
18 MR. MOELLER: Okay. Well, as a bottom line it 19 seems to me that we have offered some comments, and they are 20 not necessarily the ones that I am sure you want to hear nor 21 the one that we most like to give. But as I hear us 22 talking, No. 1, we say that the documents appear to us, and 23 this is just our comments, to be overly prescriptive.
24 And, secondly, having gone through this exercise, 25 and we have one member of the ACRS that is always telling us ace-FEDERAL REPORTERS, INC.
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1 to look at the cosmic issues and not, you know, the nuts and 2 bolts, I would say your having gone through this exercise, 3 if possible I would use it as a springboard to leap up to 4 some new higher plane or plateau where in some sort of a 5 supplementary report you would really state what we have 6 been saying you need to tell DOE, some of the things Bill 7 Kerr and others have said, and that is, what is it that is 8 going to be acceptable to you, what are you going to 9 require, how precise and what is the product that you want, 10 not how to get it, but what is the product you want.
11 That seems to be the message we are giving.
12 MR. LINEHAN: We definitely agree with you as far O)
(_ 13 as the product, the points on what is acceptable and the 14 precision.
15 I think the real difference is laying out a 16 strategy or a methodology for getting there. I will be 17 going into that little more in the next presentation of why 18 we feel we need to do that, and again I would like comments 19 back on that.
20 What we are trying to do right now is we are at 21 the point in the program where DOE is focusing on three 22 sites and we are really re-evaluating the program to this 23 point of what we have been doing in ways of giving guidance 24 and in ways of interacting with DOE.
25 And, believe me, we have got an open mind right l
ACE-FEDERAL REPORTERS, INC.
l 202 347-3700 Nationaide Cos erage funk 336-6M6
59700101 109 marysimons G
V 1 now because we are trying to reassess where we stand and 2 where we should go over the next five year, and all these 3 comments are very helpful.
4 ,
But when I go into the five-year plan and give you 5 some of the reasons why we think we need to lay out these 6 strategies, and why we need to go to the line of not being --
7 we don't think we are being prescriptive, but very close, 8 which you may indeed interpret as being too prescriptive. I 9 will give you some of the reasons there, and if you could 10 give us additional feedback, I think we really need to 11 consider that.
12 MR. MOELLER: Well, the thing, too, that we have O
(_j 13 to consider, because we want to consider it, is that you are 14 dealing with DOE on a daily basis and we are not, and you 15 have the benefit of that interaction, and I am sure that 16 influences what you produce and what you provide. So we are 17 l merely offering our comments.
18 Let me then ask at this point, it is noon, are you 19 constrained on time or do you plan to be here this afternoon 20 for awhile?
21 MR. LINEHAN: We will be here all day.
22 MR. MOELLER: Owen, unless there is some 23 objection, I would prefer to break for lunch and resume at 1 24 and we will just pick up where we left off.
25 Thank you.
ACE-FEDERAL REPORTERS, INC.
202 347-37(x) Nationwide Coserage 8(K)-33MM6
i i - ,
, - 59700101 110 _119 j marysimons lO
' 1 We will recess for-lunch.
4 2 (Whereupon, at 12 Noon, the subcommittee recessed, t
I 3 to reconvene at 1:00 p.m., the same day.)
a
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20 21 22 23 24 25 ACE FEDERAL REPORTERS, INC.
202 347 3700 Nationwkie Coverage sm.336-6M6 s
ACRS SUBCOMMITTEE ON WASTE MANAGEMENT BRIEFING JULY 22, 1986 GE0 CHEMISTRY GENERIC TECHNCIAL POSITIONS:
- 1. Solubility
- 2. Sorption e
Introduction:
(5 minutes)
John Linehan WM Repository Proiects Branch 8 Overview of Geochemistry Program (10 minutes) -
Philip S. Justus WM Geotechnical Branch 8 Briefing on Sorption and Solubility (55 minutes)
John W. Bradbury Geochemistry Section, Geotechnical Branch O O O
~4 DIVISI0fl 0F WASTE MANAGDENT DIRECTOR (2)
~
DEPUTY DIRECTOR (2)
W-SITE LIENSING EPRESENTATIVES (3)
EPOSITORY ,
POLICY #0 PROJECTS ENGIEERIfXi RulEGINICAL Pim<AM C0fiTROL L N-LEVEL a URANitM BRA.Til BRAN 01 BRANCH BRANCH PROJECTS BRAhCH PROJECTS MATERIALS HYDROLOGY POLICY LW-LEVEL PROJECTS EllGIf 8 til4G OUALITY ASSURANCE MINING, EOLOGY/ PROGRAM PLAihlNG URANilFi ECOVERY PROJEGS GE0ENGlhEERING GEORlYSICS PROJECTS FACILITY DESIGN TEOiNICAL NOCK E0lANICS E001EMISTRY INTECP/.TIW -
INTEGRATION #0 '
PEFF. ASSESSFENT EGULATION 8 PROCM1 Cdulu.
EhVIR0ffENTAL AND ANALYSIS
[004T CONTRDL ENTER 28 28 31 33 '
21 O O * .
DWM HLW Projects ror FY 87 Geo 10.4%
d Geochem
// Hydro '
d FL.
4 15.4% :
17.8% I'k Lic/Sup 6.8% dYkk$f Envir 1.5%
1 , }, , \ , .. , . .. . - ~ - .,..
.. . , .e ~
3; .
c{f" ,..a. .
Q' tq4.7"} WPf ' Form ;;y ' .
PA 8.9% 'f"? ~
23 2'.
l 14.5% hygyp.2% ,y57 xE QA 1.5% 'f,) 7 Des / Rock .
Percentages are based on a total l TA Budget of 6804K. Thic does not include 1
771K for st9,rt-up of the FFRDC.
q
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=
s:
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$"g _g'. '- E g g _ g"s$h_shlge
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O IMPORTANCE OF GE0CHEMISTY l
l 1
+ Multi-barrier Concept Requirement:
Assess the Environment of Waste Packages Assess Radionuclide Transport and Release to the Accessible Environment
+ 10CFR60 Requirement:
Assess Radionuclide Release (EPA Standard)
Assess Favorable Conditions Assess Potential Adverse Conditions e O O
8 GE0 CHEMISTRY ISSUES
+
WilAT ARE THE PRESENT SITE GEOCHEMCAL CONDITIONS / PROCESSES
+
WHAT ARE T}lE CHANGES DUE TO WASTE EMPLACEMENT IN SITE GE0 CHEMICAL CONDITIONS / PROCESSES
+
WHAT ARE THE SITE GE0 CHEMICAL CONDITIONS / PROCESSES THAT WILL AFFECT RELEASE AND TRANPORT OF RADIONUCLIDES m
0 t
GE0 CHEMISTRY INTERACTIONS WITH DOE NNWSI Geochemistry / Hydrology Meeting March 1979 BWIP Geochemistry / Waste Package Workshop _ _ _ __ _ _ _ _ _ _ _ August 1982 NNWSI Geochemistry Workshop
__________________ January 1983 BWIP Geochemistry Workshop
__________________ January 1984 NNWSI Geochemistry Workshop July 1984 Salt Geochemistry Meeting _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ August 1984 NRC's Comments on DOE's Draft Mission Plan (Meeting) December 1984 Meeting on DOE Siting Guidelines _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ April 1984 Discussion of NRC Comments on DOE's Draft EA's _ _ _ _ _ _ _ _ _ April 1985 Salt Geochemistry / Waste Package Meeting January 1986 NNWSI Sorption Meeting _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ May 1936 e O O ..
2 GE0 CHEMISTRY PRODUCTS Selected Hydrologic and Geochemical _ _ _ _ _ _ _ _ _ _ January 1983 Issues in Site Characterization for Nuclear Waste Dispsoal; Flood Basalts at the Hanford Reservation (NUREG/CR-2983)
Status of Geochemical Problems Relatino March 1983 to the Burial of High-Level Radioactive - ~ ~ ~ - ~ - -
Waste, 1982 (NUREG/CR-3062)
BWIP Site Characterization ~~~ April 1983 Analysis (NUREG- 0960) ~----------
Evaluation of Radionuclide Geochemical March 1984 Information Developed by DOE High-Level- - - - ~ ~ ~ ~
Nuclear Waste Repository Site Projects Salt Issue Oriented Technical - - -- - - ~ ~ ~ ~ ~ - ~ ~ September 1984 Position (Draft)
NNWSI Issue Oriented Technical Position (Draft) ____
September 1984 BWIP Issue Oriented Technical Position (Draft) _ _ _ _ _ September 1984 Review and Assessment of Radionuclide September 1984 Sorption Information for the Basalt --------~
Waste Isolation Project Site (1979 through May 1983) (NUREG/CR-3763)
& ~
GE0 CHEMISTRY PRODUCTS (CONT)
Review and Assessment of Radionuclide ~~~~~~~'-
September 1984 Sorption Infonnation for the Basalt Waste Isoletion Project Site (1979 through May 1983) (NUREG/CR-3763)
Determination of Radionuclide -~~~~~~~~~~~~ November 1984 Solubility in Groundwater for Assessment of High-Level Radionuclide Waste Isolation Progress in Evaluation of Radionuclide Volume 1 September 1984 Geochemical Information Developed by DOE - Volume 2 October 1984 High-Level Nuclear Waste Repository Site Volume 3 February 1985 Projects (NUREG/CR-3851 and NUREG/CR-4236) Volume 4 October 1985 Volume 1 October 1985 Volume 2 December 19P5 Volume 3 April 1985 Standard Fonnat and Content February 1985 of Site Characterization Plaiis - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
for High-level Waste Geologic Repositories (Revision 1) '
NRC Coments on DDE DEA's for Hanford _ _ _ _ _ _ _ _ _ March 1985 NRC Consnents on DOE DEA's for Seven Salt Sites _ _ _ _ Ma'ch r 1985 NRC Comments on DOE' DEA for NNilSI _ _ _ _ _ ,, ,, , ,. _ March 1985 Proceedirgs of the Conference on the Application of Geochemical Models to -~ ~~~~~~~ June 1985 High-level Nuricar Waste Repository Assessment (NUREG/CP-0062)
Determination of Radicroclide January 1986 Sorption for HLW Repostories (Draft)~ ~ ~ ~ ~ ~ ~ ~ ~ ~
Interpretation and Identification - - - - ~ ~ ~ ~ ~ ~ ~ Jul y 1986 of the Disturbed Zone (Draft)
O O O i
4 GE0 CHEMISTRY TECHNICAL POSITIONS 0
Solubility _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ FY 1984/1985 0
Sorption _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ FY 1985/1986 FUTURE:
Mineral Stability Geochemical Conditions Analogs Matrix Diffusion e e # ..
- n y . . . . . ._
BRIEFING ON THE i I
SORPT!ON AND S O LU B l L.!TY GENERlC TECHN! CAL POSIT!ONS .
to the
^GRS ' ^/ASTE M AN AG EM E!'!T S U B C O b.! M .~ITEE i
z.
ous une Geoc h e mistry S ectio n , Geotechnice' B ra n c h ,
Division of Waste Management, F #. S S , !!RC J u ly 22, 1986, Washington, DC l
I L. .
. . .J
1 S~A-~ JS So'uai'ity G~?
Tina': No-iced in IR .\ovemaer, ~ 98L i Sor nion G:-)
Draft: .\ oti cec i n 2R '- u ah ua r-y , ' 986 3di ic Comments ~~o Varca , ' 986 r
.ina': Antici aatec -
Seatemaer, 986 I
l l
l e O
- ehe -heaw I
l DEFINITION i
Solubility - the concentration of a given radionuclide in liquid in equilibrium with a stoichiometric (fixed composition) solid containing that radionuclide.
l 1
O O O
1 JEr N ON '
Sorption one or more physicochemical l processes, including ion exchange, adsorption, and chemisorption, but i excluding precipitation of stoichiometric
! phases, in which the radionuclide
- is removed from a liquid phase by
! interaction with a solid phase.
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Conceptual Mocel of Processes Involved in Retardation (after Muller and Ouda, 1982).
l l
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SURFACE WAIER n
1 P SUBSURFACE WAIER L N NN 0
SORPTION (POSITION)FY86 ? SOLUTION ; i SOLUBILITY (POSITION) FY84
+
I 8 INFORMATION NEEDS -
INFORMATION NEEDS j I
I o MATRIX OF EXPERIMENTS o MATRIX OF EXPERIMENTS o CilARACTERIZATION OF o CilARACTERIZATION OF STARTING EXPERIMENTAL PRODUCTS MATERIALS AND PRODUCTS .
l o DETERMINE SOLUBILITY FROM o SORPTION ISOTiiERMS ,,'a!#wlswidshwillii ks k (, N k N k um illLENGill TilR0llGi G- OVERSATURATION AND 1(REG 10N OF SOLUTION-CEOMEDIA INTERACil0N5) UNDERSATURATION o MULTIPLE EXPERIMENTAL APPROACliES }
e o USE MODELS TO AID INTERPRETATIONS 3 0F EXPERIMENTS o CilARACTERIZATION OF UNCERTAINTIES l o CllARACTERIZE UNCERTAINTIES g
e ,
s 8 .
i BIOSPilERE Radionuclide Interaction in Geologic Media G G e
NRC POSI"IO.\:
a Ma'.;r1x of Develop
- -x3erimen,:s Jur]ose l
i
! o Demonstrate crucial exaeriments I o Eliminate nonessential effort
- o Instill, confidence in cuality of data 5
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Clarac :erize S :ar :inc Va :eria's anc1 3rocuc s Juraose
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URANIUM IN LIQUID (mol/L)
N Sorption isotherms for uranium on Cohassett basalt. Batch contact tests under anoxic conditions with synthetic groundwater GR-4 at 60*C.
Meyer, R.E., 1986, NUREG/CR-4236.
O O 9
1 NRC POSITION: l Determine solubilities from both undersaturation and oversaturation.
O O O
SOLUBILITY EXPERIMENT Q
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FRACTURE I ( ALERAM MINERALS t :
Conciueiane: -
- Groundwater velocity probably much greater than rate of diffusion of radsonuclides into '
j buk rock, thus Ko nonconservative.
- Freehty crushed bulk rock surfaces used in test probably not representative of fracture !
rnenerale, thus test may not be representative of in situ behavior.
Kelmers, A.D., 1985, unpublished work l
O l
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O FEED FLASE Eh M ELECTROCES m m il 'II am6mmu SEOsaseNT FLOW 04ASCT10N COLua880 l
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~
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to -
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pone v0Lusses stuTuo Uranium Concentration in effluents from Colues experiments.
\ !
I i
I i
l O'
9 T. .
l
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_l
Non Laboratory Studies In Situ Testing Advantages: A closer approximation of (1) Site-specific materials (undisturbed) i (2) Spatial scale (compared to lab)
Natural Analogues Advantages: A closer approximation of l (1) Ti'me scale
! (2) Spatial scale l
1 O O ,
'O
,1 l
NRC POSITION:
Use cjeoclemical modeling for interpreting experimental results and for planning e,xperiments
- s O O O
L NRC POSITION:
9 o Characterize All Sources of Uncertainty o Types; Conceptual Experimental l 0
Purpose:
Demonstrate data are realistic l and conservative l -
i l
G S ,
'G
As
. o Determination of i
Radionuclide Sorption
- for High-Level Nuclear Waste Repositories i
l Technical Position j January, 1986 4
1 i
i Geochemistry Section - Geotechnical Branch 1
i O Division of Waste Management U.S. Nuclear Regulatory Commission 4
i i
1 i -
l l . .
O
TABLE OF CONTENTS l
t"')
kJ j
l l
fase ;
1.0 INTRODUCTION
.......................................... I 1.1 Purpose ......... ..................... .......... I 1.2 Regulatory Framework............................ ... 1 ,
1 1.3 Definitions of Radionuclide Sorption and Related Experimental Parameters ........................... 2
2.0 BACKGROUND
.......................................... 2 2.1 Use of Sorption in Performance Assessment Analysis... 3 2.2 Approaches for Sorption Determination................ 4 3.0 STATEMENT OF P0SITION.................................... 5 4.0 OISCUSSION .......... ............................... 6 4.1 Matrix Development.................................. 6 4.2 Characterization.of Experimental Starting .
Mat'erials and Products........................... 7 4.3 Isotherm Development for Closed-System Experimentaiton 9
4.4 Determinati
of Sorption Parameters by Multiple Experimental Approaches.. ............... ...... ... 10
(]) 4.5 Documentation of Uncertainties... ...... ............ 13
5.0 REFERENCES
.............................. .......... 14 e
o O
OETERMINATION OF RADIONUCLIDE SORPTION FOR HIGH-LEVEL NUCLEAR WASTE REPOSITORY O, NRC TECHNICAL POSITION
1.0 INTRODUCTION
1.1 Purpose This document presents a general approach for estimating radionuclide sorption on solids anticipated in a high-level nuclear waste repository in support of licensing findings. It is not intended to prescribe specific methods for radionuclide sorption determinations. Instead, the information is provided to the Department of Energy (00E) to be used as guidance for preparing detailed plans for radionuclide sorption determinations and submitting appropriate documentation early in the site characterization process.
1.2 Regulatory*Framework .
The Nuclear Waste Policy Act of 1982 (P. L.97-425) defines the role of three Federal agencies in the national program for disposal of high-level radioactive wastes. The Environmental Protection Agency (EPA) has been responsible for developing " generally applicable standards for protection of the general environment from offsite releases from radioactive materials in repositories."
These standards have now been issued as final regulations (85 FR 38066). The NRC develops and issues "... technical requirements and criteria that will apply in approving or disapproving (1) applications for authorization to construct repositories; (ii) applications for licenses to receive and possess spent nuclear fuel and high-level radioactive waste in such repositories; and (iii) applications for authorization for cicsure and decommissioning such repo'si to ri e s." In th'is way, it will implement the EPA standards. The
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I Department of Energy (DOE) is responsible for collecting the data needed for site characterization and for constructing and operating a waste disposal facility in accordance with NRC regulations.
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1.3 Definitior.s of Radionuclide Sorption and Related Experimental Parameters Sorption - one or more physicochemical processes, including f an exchange, adsorption, and chemisorption, but excluding precipitation of stoichiometric (fixed composition) solid phases, i'n which the radionuclide is removed from a liquid phase by interaction with a solid phase or phases.
Sorption or Desorption Ratio, R, - the ratio of the concentration of radionuclide on or within the solid to that in the liquid (units
+
are L/Kg).
Retardation Factor, R - the ratio of the velocity of the liquid to that of f
the radionuclide in an open (flowing) system.
. Sorption Capacity - the maximu'm amount of radionuclide that can be sorbed on a unit mass of solid for a given set of conditions.
Starting Material - the substances added to a reaction vessel at the outset of an experiment, e.g., reactants.
2.0 BACKGROUND
A geologic repository controls the rate of radionuclide release to the accessible environm!nt by means of'two major subsystems: (1) the geologic
- setting; and (2) tne engineered system. The geologic setting (site) is selected for'its geologic, hydrologic, and geochemical attributes that enhance radionuclide isolation.
In order to. compensate for the uncertainty in predicting the behavi,or of geologic systems over long periods of time, the NRC has adopted a multi-barrier a.pproach in its licensing criteria. In this approach the staff v.iews the I repository to te composed of three major barriers: (1) the waste package, (2) the eng~ineered structure, and (3) the site and its environs. In general, this approach puts emphasis on: (1) engineered containment of radionuclides during the period of peak fission product decay, and (2) assurance of a controlled 2
i
release thereafter. This simplifies analysis and reduces uncertainties introduced into the analysis of the total system. During the period of engineered containment of the waste, the site geology should provide sufficient backup to account for those scenarios which may result in loss of engineered containment. Thereafter, the site geology should also have the capacity to retard the movement of the long-lived radionuclides to the accessible environment so that 10 CFR 60.112, the overall system release performance objective (EPA standard), is not exceeded. The DOE endorses the multiple barrier approach and places primary importance on the capabilities of the natural system for waste isolation (00E,1984).
Within the limits defined by 10 CFR 60.112 criteria, the DOE determines how much credit can be taken for sorption as a means of limiting radionuclide release. Radionuclide sorption parameters can be used in performance assessment models for characterizing the performance of a high-level nuclear
. waste site. These parameters are difficult to determine precisely because future geochemical conditions cannot be known with complete certainty and laboratory tests may not accurately model site behavior. However, by experimentally investigating sorption parameters using site-specific phases and conditions, it should be possible to take account of sources of uncertainty and make reasonable estimates of sorption along radionuclide release pathways in the subsurface repository.
2.1 Use of Sorption in Performance Assessment Analysis When a liquid is flowing through permeaole solid media, sorption processes can act to retard the migration of the solute relative to the liquid flow.
Radionuclide sorption experimentation can be used to estimate this. retardation and, thus, quantif - vo aspects of repository performance. First, sorption experiments can be used to help identify which " key" radionuclides can be sorbed on repository solids. Key radionuclides are defined here as those radionuclides that might require some retardation in the host rock to meet regulatory criteria'. Second, sorp' tion studies can also be used to determine the ability of the subsurface repository (the engineered system and the geologic setting out to the accessible environment) to isolate radionuclides from the accessible environment. For example, parameters such as sorption or 3
y desorption ratios, sorption capacities, and retardation factors derived from these studies can be used to help quantify the ability of the subsurface (
repository to retard radionuclide migration.
1 2.2 Approaches for Sorption Determination i
The NRC recognizes that there is more than one approach to determining sorption for use in performance assessment analysis. Initial experimentation used to characterize radionuclide sorption can be based either on thermodynamic or empirical approaches. The thermodynamic approach involves the use of simple systems (few components) and measuring fundamental thermodynamic parameters of the components participating in the dominant sorption reaction (s). These parameters could then be used in the performance assessment analysis to extrapolate to the complex systems of the repository. The empirical approach consists of determining the effect of various physical and chemical parameters
'on sorption ,under some site-specific conditions (complex systems). By combining the results of the initial experiments using'the empirical approach l
I that show the effect of varying the individual parameters on sorption, it should be possible to derive an equilibrium constant for the dominant sorption reaction if enough restrictions are placed on the systems studied. Both the thermodynamic and empirical approach yield uncertainties associated witn the extrapolation to site-specific conditions not simulated in the experiments.
This technical position should not be construed as endorsing either approach.
In general, sorption experiments can be subdivided into two types: 1) closed systems; and 2) open systems (NEA, 1983; McKinley and Hacermann, 1984). Both approaches have been used to approximate one aspect of repository performance.
For charactetizing sorption phenomena, closed-system expeHments, such as batch sorption tests, involve contacting radionuclide-free (or deficient) solids with a radionuclide-bearing.. solution for the duration of the experiment followed by analytical deterinination of the sorption ratio, R3 . (Batch desorption experiments, on the other hand, involve contacting radionuclide-free (or deficient) liquid with radionuclide-bearing sol. ids, followed by measurement of' the quantity of radionuclide leached.) Open-system experiments, such as flow-through column tests, involve the introduction cf liquid solution at one O- end of a reaction vessel containing solid and the removal of the fluid at the 1 4 i
other end. The solid material sorbs the radionuclide(s) and, as a result, O retares the misratioa or t8e contaminant (s) reiative to 18et or the ifau4d.
This is expressed as a retardation factor, Rf .
There are advantages to both experimental approaches. For example, the advantages of the closed-system experiments are that they are relatively (1) simple, (2) inexpensive, and (3) better suited for mass production than the open-system experiment. On the other hand, the advantages of the open-system experiments are that they may better model radionuclide migration in flowing systems by revealing the presence of multiple speciation, mass action competition, colloids or particulates that might not be apparent in the closed-system experiment (batch test) (Kelmers, 1984).
3.0 STATEMENT OF POSITION It is the position of the NRC staff that sorption parameters'ased in performance assessment' calculations shall be based on experimental data. The O NRC staff considers that if the following points are included in the DOE V
experimental program, equilibrium constants for sorption processes can be derived. Such a strategy is vital to limiting the uncertainty involved in extrapolating experimental conditions and results to those of the repository, thus, allowing licensing decisions to be made. The DOE site programs should:
- 1) Develop a matrix of experiments that involves starting materials based on the anticipated range of proportions and compositions of phases under the various physicochemical conditi.ons expected in the subsurface repository;
- 2) Characterize solid and liquid experimental starting materials and products;
- 3) For closed-system experiments, determine sorption isotherms- by varying radionuclide concentrations u'p to an apparent concentration limit if appropriate; i b v
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- 4) Determine the applicability of sorption parameters to repository O perrorm #ce ex osi"9 v ricos experime t i aaro c8es i#voiv4=9 eoth open and closed laboratory systems, and in situ field tests, and studies of natural analogues; and
- 5) Occument the magnitudes of experimental and conceptual uncertainties from all anticipated sources.
Details on the individual points from the Statement of Position, along with a discussion on why the NRC staff thinks these points are important, are given below.
4.0 DISCUSSION It is the responsibility of tne 00E to demonstrate that when
. experimenta,lly4de, rived sorption parameters"(plus some. uncertainty factor, If necessary) are used in performance assessment calculations, there is reasonable assurance that the radionuclide migration is not underestimated.
V 4.1 Matrix Development A matrix of experiments should be developed as a planning tool for characterizing the sorption properties of a subsurface repository. With a matrix, the DOE should be able to demonstrate that crucial experiments that characterize sorption have not been overlooked. As a result, the 00E should be able to demonstrate with reasonable assurance that the derived sorption parameters are appropriate.
Variables such as solid composition, mineralogy, and texture, liquid composition, proportion.of phases, temperature, pressure, particle size,' flow rate and re~gime (porous and fractured media), time, and ionizing. radiation should be considered i'n the matrix. The 00E can then effectively demonstrate its :ltionale for choosing some combinations of parameters. for study and eliminating other combinations as inappropriate.
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The matrix s1ould include scoping experiments, performed early in the O exper4mentai pro ram, whic8 invs ve reiet4ve v m pie systems e eeterm4ne the effects of various physicochemical conditions on sorption. Following the scoping experiments, the matrix development should reflect combinations of the above parameters that simulate physicochemical conditions and pnase assemblages likely to occur in the repository system. Consequently, the size of the matrix would be greatly reduced by first considering the dependence or interrelation of phases and conditions upon each other and deleting incompatible combinations. As experimentation progresses to a point where enough insight has been gained to establish the relationship between sorption mechanisms and experimental values, a theoretical basis may be established for reducing the number of experiments in the matrix.
Also, the priority of testing needs to be established. For example, radionuclide studies can be prioritized by comparing radionuclide inventories
, in the repository to release l'imits specified in 10 CFR,60.112 of the NRC regulations. Some radionuclides ma"y occur in low enough quantities that, if they meet NRC release rate requirements, they will not contribute significantly to exceeding these limits. These may be assigned a lower priority than those radionuclides whose cumulative releases over 10,000 years are likely to exceed j the release limits in the absence of sorption effects.
4.2 Characterization of Experimental Starting Materials and Products In choosing appropriate solid starting materials for sorption studies, emphasis should be placed on the identification and characterization of waste form, canister, backfill, seals, packing, and host rock primary and secondary phases occurring along paths the radionuclide-bearing groundwater will take as it flows away from the waste, s,1nce these are the solids most likely to react with j groundwater.and thereby affect radionuclide concentrations and release rates.
Characterization of the solids should include chemical, mineralogical, textural, and particle size determinations. Thus, it is important to.show with reasonable assurance that laboratory experiments involving sorption on crushed solids (for example) is relevant to sorption at the repository site. The
, surfaces of crushed material may be significantly different from the surfaces i of intact material, both porous and fractured. Grinding may expose the 7
n surfaces of solid phases different from those which groundwater would contact in a repository and/or may change the reactivity of the same mineral surfaces with dissolved radionuclides.
Similarly, the range of groundwater compositions expected in a repository system should be considered in selecting liquid starting materials, Generally, in the rock-dominated environments of a high-level waste repository, groundwater compositions can be affected by reactions with solids at various temperatures and pressures. Consideration of the range in water compositions used in experimentation should be based on the range of compositions of analyzed groundwaters at ambient conditions, the range of compositions calculated from solid assemblages assumed to have equilibrated with the groundwater, and the range of groundwater compositions experimentally determined at elevated temperatures and pressures.
.The applicab'ility of synthetic starting materials to the conceptual model
- employed in developing the matrix should be addressed. Failure to do so might result in experiments that do not adequately simulate repository conditions.
For example, the preparation of radionuclide-bearing groundwater commonly involves the addition of a small amount of acidified tracer to a synthetic solution simulating the natural groundwater. The resulting solution may neither be representative of repository conditions nor be stable.
In addition to characterizing the starting materials, it is also important to characterize the experimental products. Following the experiment, analysis of the liquid products should include the determination of major, minor, and trace element concentrations, along with pH and redox conditions.
The extent of sorp - n of some dissolved radionuclides on engineered barrier materials and host rock.can be strongly dependent on the redox potential (Eh) and, acid.ity (pH) of the groundwater. For example, Benjamin and Leckie'(1981) show that the sorption of Cd', Cu, Zn, and .Pb ort amorphous iron oxyhydroxide is strongly dependent on pH. The percentage of cation sorbed varies from approximately zero to one hundred with a change in pH of two units. Likewise, Kelmers et al. (1984) have shown that sorption ratios for neptunium and technetium are dependent on the redox condition of the system.
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b The characterization of solid products from sorption experiments is important because, for example, under the same physicochemical conditions, different solid phases can have drastically different sorptive capacities for the same radionuclide. Characterization of the solids is important in determining which reactions took place and how these reactions depend on experimental technique.
In addition to determination of the composition of individual solid phases, i characterization should include surface area and/or particle size measurements.
Because sorption is predominantly a surface phenomenon, the surface area of the solid may strongly affect the experimentally determined sorption parameters.
For example, neptunium sorption ratios increased two orders of magnitude as particle diameter decreased from 200 to 2 um (Kelmers et al.,1984).
4.3 Isotherm Development for Closed-System Experimentation Probable release scenarios call for radionuclide concentration gradients in the
' repository system. The conckntrations of radionuclides in the repository ca,n
^
range from zero to an apparent concentration limit. The apparent concentration limit is the greatest radionuclide concentration that the liquid can maintain when the temperature, pressure, and moles of all other components in the liquid, n , are held constant.
j The apparent concentration limit is controlled by the solubility of some stoichiometric radionuclide-bearing solid phase.
Figure 1, a schematic sorption isotherm, illustrates the relationship between concentration on the solid versus concentration in the liquid when all other parameters are held constant. Analysis of the liquid product can be used to monitor the constancy of the other parameters. Although this figure shows a l linear sorption region, many sorbed species, including radionuclides, show
- nonlinear relationships between the quantity sorbed and the solution
{
concentration: Thus, sorption ratios can be dependent on radionuclide concentration (Serne and Rel, yea,1982).
Because radionuct'ide concentrations are expected to vary in the repository and sorption parameters can be concentration dependent, it is reasonable to design i experiments to determine the effect of concentration on sorption ratios.
Sorption isotherms should be determined up to an apparent concentration limit if possible, so that it can be shown that precipitation is not contributing to the sorption ratio. Experimentally, it should be possible to determine an 9
e apparent concentration limit of a radionuclide in liquid in contact with solid.
V For example, at the same temperature, pressure, and n j in the liquid, two sorption experiments with different concentrations of the same radionuclide in the liquid starting material should yield the same radionuclide concentration in the liquid products at the apparent concentration limit (see Figure 1).
4.4 Determination of Sorption Parameters oy Maltiple Experimental Approaches If a sorption experiment could be designed that simulated all anticipated repository conditions, it would not be necessary to use multiple experimental approaches to determine sorption parameters. However, simulation of all, anticipated repository conditions in sorption experimentation would be difficult and/or impractical. The fact that some parameters or conditions cannot be bounded requires the extrapolation of these conditions to those expected in the repository. This extrapolation introduces uncertainty into the modeling of sorption parameters. Therefore, multi'ple approaches are importanti because they can lend support to, and reduce the uncertainties of, experimental results from studies $ which some parameters are not site specific. Some experimental parameters can be varied over a large enough range as to bound the conditions anticipated in the repository. These parameters include surface area / volume ratio (SA/V), temperature, pressure, composition, and flow rate.
Other parameters that often are not caplicated in the laboratory are scale, residence time, water / rock ratio, and flow characteristics, which can include saturated versus unsaturated flow and porous media versus fractured flow.
Experiments are designed so that measurable effects of physicochemical reactions c.an be monitored in a reasonable time. Section 60.101(a)(2) of 10 CFR Part 60 allows for the use of accelerated tests to demonstrate compliance
'with performance objectives 'and design criteria. At the relatively low temperatures anticipated ~1n the repository, chemical reactions involving geologic materia'Is can be extremely slow. In order to accelerate these reactions so that changes are measureable in experimental time,' conditions other than those anticipated in the nuclear waste repository are sometimes boosed on the experimental system. For example, experiments have employed crushed solid material, high concentrations of solutes, agitation,' catalysts,
'O rapid flow rates, and elevated temperatures, 10
s In addition to accelerating reaction rates, laboratory experiments are designed
/l so that the amount of material required can be handled reasonably. By scaling V .
down systems of interest (repository size) to laboratory size, certain physical conditions must be altered. For example, the water / rock ratio in most repository systems is significantly less than one. However, in order to obtain enough water for analysis in laboratory experiments, the W/R ratio is ordinarily increased significantly. This technique makes the bulk chemistry of the experimental system different from that in the repository. The proportions of phases in experiments has been shown to affect radionuclide sorption parameters (Palmer et al . ,1981; Rafferty et al . ,1981; Meier et al . ,1982).
Thus, the effect of this technique on sorption parameters should be considered.
One can argue that in a fractured medium, with little porosity, most of the rock will not be in contact with the groundwater. Consequently, water / rock ratios used in experimentation should be higher than those that take into account all the rock in a repository system. If this argument is used,
,however, it follows that the solid reactants should be predominantly fracture material and not bulk rock. Sorption experiments involving crushed bulk. rock might have little applicability to sorption phenomena in fractured media.
O To verify the applicability of experimentally determined sorption parameters to a repository system, the site should use multiple experimental approaches.
[This approach was a recommendation of the Waste / Rock Interactions Technology (WRIT) Program (Serne and Relyea, 1982).] Using this approach, sorption 4 parameters can be analyzed and compared. . For example, the sorption ratio, R ,
3 obtained from batch experiments has often been used to calculate a retardation factor, R .
f The relationship between R, and Rf is taken to be 8f = 1 + pR,(1 - 9,)/e,
- where p is the bulk dehsity of the rock, and 4, is the effective porosity.
This elationship is based on ion exchange theory as applied to porous media flow. However, due to the variety of processes that contribute to sorption, the calculated R fvalue may not equal the measured Rf value determined from a O flow-through column experiment.
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s s
Comparison of the sorption and desorption parameters obtained from O ciosed-sustem ad oaea-sxstem exper4me#ts is recommeaeed. cenerativ. the sorption parameters (e.g., R,) derived from closed-system experiments are equal to or greater than those derived from open-system tests using the same solid material (NEA Workshop, 1983). As a result, closed-system tests'may overestimate the effectiveness of a repository system to isolate radionuclides (Relyea et al., 1980). The difference in sorption ratios may be due to particle abrasion in stirred closed-system experiments or the relatively short residence times in open-system experiments (NEA Sorption Workshop, 1983).
Other factors that can cause a discrepancy between the sorption parameters from open and closed systems are the presence in the liquid of multiple radionuclide species, colloids, and particulates. Changes in physicochemical parameters such as temperature, fluid velocity, radionuclide concentration, time of reaction, and fluid composition may shed some light on the causes of the discrepancy between the two types of systems. Thus, a rationale for the
. difference in sorption paramet'ers observed using different methods. contributes to the overall certainty that can be assigned to the sorption parameters.
O Extrepoietioe of sorpt4oe parameters from iaeoretory exper4 meets to a large-scale, long-term repository system can be highly uncertain. The flow characteristics of the groundwater can have a drastic effect on the applicability of laboratory-derived sorption parameters to repository performance. Most experiments use crushed material as a solid medium because it is easy to handle and characterize, and accelerates solute-solid reactions.
The application of crushed material' to intact porous media may be adequate but not so when the natural system is fractured rock. Sinnock et al. (1984) and Nuttall and Ray (1981) have calculated that rates of radionuclide migration via fracture flow can be two orders of magnitude greater than that via porous media flow. Thus, for performance < assessment calculations, consideration of flow regime can be of the utmost importance.
If groundwater flux in a repository is predominantly via fracture-flow, sorption tests in the laboratory may not adequately simulate repository conditi~ons. One method of further reducing the uncertainty caused by the inadequate simulation of various flow characteristics could be to perform in situ tests on site-specific solid material (Serne and Relyea, 1982; Abelin et 12
s al., 1984; Neretnieks et al., 1982). The scale of these tests can be larger )
than that of the experimental tests but smaller than that of the repository.
Furthermore, the in situ solid materials would certainly not have suffered the 1 effects of handling (grinding, sieving, washing) required in laboratory tests.
Time constraints, however, would still apply in these experiments. Comparison between the laboratory and field results can illustrate the usefulness of the different approaches, but the physicochemical conditions must be carefully controlled in the in situ tests to ensure a parallelism in the approaches.
I Therefore, in situ tests in conjunction with laboratory tests can be performed to reduce the uncertainties of extrapolation to the repository systems.
Although field tests can expand spatial scale over that which is normally handled in a laboratory, the time scale is still several orders of magnitude less than that of a repository. The study of natural analogues is a means of shedding some light on the migration of radionuclides in natural systems that
.have existed' for long periods of t.ime. Thus, their use is a way of dealing with the uncertainty associated with extrapolating short-term laboratory-and field experiments to long-term performance of a repository. Common examples of systems used as natural analogues are ore bodies such as Oklo (Brookins, 1978) and the uranium deposits in the Northern Territories of Australia (Airey, 1983). Igneous intrusives have also been studied because they simulate anticipated thermal histories and alteration patterns. To be useful, however, the natural analogue should include a process that is demonstrably equivalent to the same process present in the repository and have well-defined boundary conditions.
4.5 Documentation of Uncertainties There are many sot !s of ut.icertainty in sorption studies. For example, l
sources of uncertainty stem from failure to duplicate anticipated repository conditio.ns, improper extrapolation of experimental results to reposito'ry conditions, incorrect experimental results, and analytical error. The fa.ilure 1
to duplicate repository conditions can be caused by an incorrect understanding of the conditions, an inability to duplicate the conditions or an inadvertent improper experimental design. Likewise, improper extrapolation can also l originate from improper experimental design. Incorrect experimental results 13
__ _ __ ~ _ - . . _ _ _ _ _ _ - _ _ _ . _ _ - - - . _ _ _ _ - - _ _ _ _ _ _ _ _ . - - - . ,
i t
l can be caused by imprecision or misinterpretations of the data. Ways that O encertainties can be m4nimized ere (1) t8e use ef muitiPie tec8niaues to determine repository conditions, (2) analyses to bound adverse impacts, (3) multiple experimental methods, and (4) the independent duplication of results.
The characterization of uncertainties is important for determining how much credit can be placed on sorption. By characterizing uncertainties, the DOE should be able to demonstrate with reasonable assurance that the sorption parameters are appropriate.
5.0 REFERENCES
Abelin, H., J. Gidlund, L. Moreno, and I. Neretnieks, " Migration in a Single Fracture in Granitic Rock" in Scientific Basis for Nuclear Waste Management, VII, Elsevier Science Publishing Co. , p. 239-246, 1984.
Airey, P. L., Radionuclide Migration Around Uranium Ore Bodies - Analogue of Radioactive Waste Repositories, NUREG/CR 3941 AAEC/C40, vol.1,1984.
Benjamin, M. 'M. and J. O. Leckie, Multiple-Site Adsorption of Cd, Cu,'Zn, an'd Pb on Amorphous Iron Oxyhydroxide, Journal of Colloid and Interface ~
Science, vol. 79, no. 1, p. 209-221, 1981a.
Brookins, O. G. Retention of Transuranic, Other Actinide Elements and Bismuth at the Oklo Natural Reactor, Gabon, Chem. Geol., p. 307-323, 1978.
00E/RW-0005 CRAFT, " Mission Plan for Civilian Radioactive Waste Management Program", U. S. Department of Energy, April, 1984.
Kelmers, A. D., Draft Analysis of Conservatism of Radionuclide Information Measured by Batch Contact Sorption / Apparent Concentration Limit Isotherms, Letter Report, L-290-3, 1984.
Kelmers, A. D., J. H. Kessler, W. D. Arnold, R. E. Meyer,.N. H. Cutshall, G.
K. Jacobs, S. Y. Lee, Evaluation of Radionuclide Geochemical Information Developed by 00E High-Level Nuclear Waste Repository Site Projects, NUREG/CR 3730, 1984. -
McKinley, I. G. and J. Hadertifann, Radionuclide Sorption Oatabase for Swiss Safety Assessment, EIR ,Bericht, Nr 550, October,1984.
Meier, H., E. Zimmerhackl, G. Zeitler, and P. Menge, "The Static or Batch Method for Testing the Sorptive and Oesorptive Characteristics of Geologic Media" in Standardization of Methods for Measuring Migration of Radionuclides in Geomedia, Proceedings of the US/FRG Bilateral Workshop, Berlin, Municn, October, 1982.
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NEA (Nuclear Energy Agency), " Sorption, Modelling and Measurement for Nuclear Waste Disposal Studies", Summary of NEA Workshop held 6-7 June 1983 in
\ Paris, 1983.
Neretnieks, I., T. Ericksen, and P. Tahtinen, Tracer Movement in a Single Fissure in Granitic Rock: Some Experimental Results and Their Interpretation, Water Resources Res., vol. 18, no. 4, p. 849-858, 1982.
NRC, " Nuclear Regulatory Commission,10 CFR Part 60, Oisposal of High-Level Radioactive Waste in Geologic Repositories", 1984.
Nuttall, H. E. and A. K. Ray, A Combined Fracture / Porous Media Model for Contaminant Transport of Radioactive Ions" in Scientific Basis for Nuclear Waste Management, vol. 3, New York, p. 577-590, 1981.
Palmer, D. A., S. Y. Shiao, R. E. Meyer, and J. A. Wethington, Adsorption of Nuclides on Mixtures of Minerals, J. Inorganic Nucl. Chem., vol.43, p.3317-3322, 1981.
Rafferty, P., S. Y. Shiao, C. M. Binz, and R. E. Meyer, Adsorption of Sr(II) on Clay Minerals: Effects of Salt Concentration, Loading, and pH, J. Inorganic Chem., vol. 43, p. 797-805, 1981.
Relyea, J. F.', R. J. Serne, and D. Silva, Methods' for Determining Radionuclide' Retardation Factors: Status Report, PNL-3349, Pacific Ndethwest Laboratory, Rich';-d, Washington, 1980.
() Serne, R. J. and J. F. Relyea, "The Status of Radionuclide Sorption-Desorption Studies Performed by the WRIT Program" in Technology of High-Level Nuclear Waste Disposal, 1982.
Sinnock, S. , Y. T. Lin, and J. P. Brannen, Preliminary Bounds on the Expected Postclosure Performance of the Yucca Mountain Repository Site, Southern Nevada, Sandia Report SAND 84-1492, 1984.
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DIVISION OF WASTE MANAGEMENT HIGH-LEVEL WASTE PROGRAM FIVE-YEAR PLAN FY86-FY90 l
MISSION:
NRC's mission in the National High-level Waste Program is derived from the Nuclear Waste Policy Act of 1982 (NWPA). A key element of the NWPA is I to have the first licensed geologic repository available to begin permanent disposal of spent fuel and high-level waste by 1998. As directed by the NWPA, l DOE has lead responsibility for siting, designing, constructing, and operating the repository, with full participation by affected States and Indian Tribes l
NRC is responsible for licensing the repository (its construction and .
operation) in accordance with its itcensing criteria contained in 10 CFR Part 60.
1 According to the NWPA, NRC must reach a licensing decision within 3-4 years of receipt of 00E's license application, during which time NRC will be on the I
critical path of the national program. Acc:rding to DOE's latest published
)
(q estimates, a license application for the first repository (out of two currently
) planned) will be submitted to NRC in 1991 and the repository will begin accepting high-level waste in 1998, the date specified by the NWPA.
parties toIndian affected the NRCTribes. licensing hearing will be the NRC, 00E, the host State andThe major As part of its mission to license the repository, NRC's activities in the next five years will be based on develtming . licensing guidance fnr 00E:
developing the staff's independent licensing assessment cacabilityt an identifying and implementing ways to make the licensinq process more errictent, All of NRC's activities will be carried out in an open manner, assuring the other agencies. necessary interaction with affected States, Indian Tribes and MAJOR FIVE-YEAR GOALS:
In five years from now, NRC's high-level waste program should be in a position whereby all necessary licensing guidance has been provided to 00E; major licensing issues have been adequately ventilated among all parties involved and resolved, to the extent practicable; and the NRC staff has the technical competence and ability to conduct a thorough review of DOE's licensing O
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t r -
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application and complete its licensing hearings within the mandated 3-4 year time frame. In order to achieve this strategic position within five years, NRC has the following major goals:
- 1. Develop and maintain an aggressive program focused on activities necessary to provide sufficient licensing guidance to 00E and sufficient interaction with 00E, States, Indian Tribes, and other agencies in order to identify licensing issues and begin the process of resolving them.
- 2. Develop and maintain an aggressive program that strives to assure the formal resolution of licensing issues prior to the licensing hearing, to the extent practicable.
- 3. Develop the staff's technical capability to review 00E's licensing application within a 3-4 year time frame and to adequately defend NRC's position on all licensing issues.
O*. Identify and eliminate, to the extent possible, imoediments to meeting NRC's statutory time frame for completing its licensing proceeding and identify and implement efficiencies in the licensing crocess.
OVERALL FIVE-YEAR STRATEGY o Focus the program on the key Itcensing decisions that must be made with respect to 10 CFR 60 performance objectives and siting and design criteria.
o At least 70% of the staff's effort will be devoted to the formal resolution of licensing issues and in developing an independent capability to conduct the licensing review and hearing within the NWPA-mandated 3-4 year time frame.
I o In the event of year-to year sche'dule delays in the DOE program (e.g., in the issuance of Site Characterization Plans), NRC resources devoted to activities dependent on 00E's schedule (no more than 30% of the staff's effort) will be freed up and diverted to formal issue resolution. ,
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ACTION PLANS:
GOAL 1: Provide sufficient licensirg guidance to 00E so that its license
, application will be complete, comprenensive, and of high quality and assure sufficient interaction with 00E, States, Indian Tribes, and other involved agencies in order to identify licensing issues and initiate their resolution.
Action Plans:
A. Provide guidance to 00E and identify licensing issues through reviews of site characterization plans, environmental assessments, and other 00E plans and reports (generic and site-specific).
B. Provide guidance to 00E on an acceptable quality assurance program and conduct audits of 00E's implementation of it ,
quality assurance program, r"' C. Provide guidance to 00E on format and content of license
(_ 3/
application documents.
B. Review DOE's site characterization activities at the three candidate sites.
C. Initiate resolution of licensing issues, both generic and site-specific, through documented technical meetings, workshops and data reviews.
D. Maintain continuing liaison with State and Tribal representatives to keep them informed of NRC activities.
E. Develop and implement specific processes and procedures to permit affected States and Indian Tribes to participate, as appropria,te, in the NRC pre-licensing and licensing processes, without adversely affecting schedules and responsibilities.
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GCAL 2: Develop and maintain an aggressive program that strives to assure the formal resolution of licensing issues prior to the licensing hearing, to the extent practicable.
Action Plans:
A. Continue the development of staff technical positions (generic and site-specific) on acceptable methods, tests, and design characteristics for meeting Part 60 performance objectives and siting and design criteria.
A. Establish and implement a procedure and process for formally resolving site characterization and licensing issues through rulemaking or other feasible alternatives.
B. Establish and implement a procedure and process for systematically managing and tracking the identification and resolution of licensing issues.
C. Establish and maintain a priority list and schedule of Y issues to be resolved through rulemaking or other formalized
(/
k- process.
D. Implement rulemaking or other formalized process for l selected, prioritized issues.
GCAL 3: Develop the staff's technical capability to review 00E's licensing !
application within a 3-4 year time frame and to adequately defend
, NRC's position on all licensing issues.
Action Plans:
A. Ensure that the technical staff remains abreast of developments in the disciplines involved in high-level waste disposal.
B. Review and verify existing models and codes for assessing long-term performance of a geologic recository system and its subsystems, in relation to Part 60 ,
performance objectives and EPA standards.
l C. Develop selected models and codes for assessing long-term performance.
- 0. Develop a standard review plan (s) for NRC's licensing review.
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GOAL 4: Identify and eliminate, to the extent possible, impediments te meeting NRC's statutory time frame for completing its licensing review and hearing and identify and implement efficiencies in the licensing process.
Action plans:
A. Systematically examine NRC's licensing process to identify impediments.
- 9. Work with 00E to develop an integrated network of a Licensing Information Management System to support NRC, 00E, States and Tribes during discovery; and establish a system for interim use.
C. Establish a Federally Funded R&D Center to alleviate contractor conflict of interest with the DOE program and to assure continuity in technical expertise D. Review NRC's current system for handling allegations and adapt it to NRC's NWPA program, for both pre-licensing O~ and post-licensing appiscation.
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ASSUMPTICNS:
o Resources will be available to carry out NRC's responsibilities under the NWPA.
o A license application to construct a high-level waste repository will be submitted in 1991.
o In the event of year-to year schedule delays by DOE, NRC will still be required by the NWPA to complete its licensing review and hearing within 3-4 years.
o The high-level waste program will continue to be highly contentious.
MAJOR LICENSING ISSUES:
o Performance Issues Before Permanent Closure:
({ safe emplacement of HLW retrievability of HLW After Permanent Closure:
' containment of HLW within waste packages release rate of radionuclides from engineered barrier system pre waste emplacement groundwater travel time o Site Issues I
geology waste package , hydrology geochemistry design / rock mechanics environment performance assessment quality assurance o Institutional / Policy Issues (} - State / Tribal oublic
' ^ ~
O O O EARLY IDENTIFICATION AND CLOSilRE OF LICOSih6 OFEh ITEFS j l l l ACRS BRIEFING JULY 22, 1986 JceN LINEHAN
' ' ~
O O O l FI'E YEAR Pt AN - HIGH LEVEL WASTE Ef0SITORY PROGRAM O WALS AMJ ObJECTMS. AG61ESSIVE PRCGR/h FOCllSED ON ACTIVITIES NECESSARY 'io PILVILE SlfFICllMI LIEl61l6 GUIDANCE TO DCE AND SlfFICIENT liflERACTION WITh iff, STATES, INDIAN TRIPES, AND OTl[R AGENCIES IN ORDER TO IDGff1FY LICENSING OHih litfS AI.D LEGlh TIE PRCCESS OF RESOLVING Til01. ILGfESSIVE PAUGRAM THAT STRIVES TO ASSUPE A FORMAL RESOLiffl0N OF LICEHSiflG OPEN ITEfB FRIUk TO T!E LICENSING EARING, TO TIE EXTEffT PimCTICAPLE. DEVELOP AN litVJENDBfT TE0tilCAL CAPABILITY TO REVIEW DOE'S LICENSE APPLICAllW WITHIN A 3-4 YEAR TlK FI#E.
- IDENTIFY AND ELIMINATE, TO TIE EXTENT POSSIBLE, lifEDIENTS TO EETING NRC'S STATUTORY TiK Fit,1E FOR LICENSE PRDCEEDING AND IDENTIFY AIO IFPLBENT EFFICIENCIES Ill TIE LICENSING PROCESS.
- 1
O O O KEY ELBENTS OF THE FlVE YEAR PLAff4116 APPL 0A0i I o P10 ACTIVE AS OPPOSED TO REACTI\E.
- o FOCUS ThE Pf0 GRAM ON THE KLY LICENSIflG DECISICNS T11AT t0ST BE MADE WITli RESKCT TO 10 LFR 60 PEPFORMANCE OBJECTIVES AND SITING AIO DESIGN CRITERIA.
o OPEN AND DOClFENTED PiOCESS FOR TE. vel.CfVENT OF GUIDANCE AND EAklY IDENTIFICATION, PRIORITIZATION AND RE50LbTION LF OPEN ITEMS, SCP/SCA PROCESS IS PRINCIPAL F0ffi. i o PROVISION FOR EAPLY AND FULL INVOLVBM Willi 1)CE, STATES, INDIAN TRIBES. o DEVELORtNT OF A FulFAL RCHANISM FOR IPPLEWhTATICfi. 2
O O O l i e 'I I % IDELOP SYSTEMATIC APPROACH FOR DLNELGRNT W 61;1 DANCE l AND FOCUSil6 FILGRN1 ON EARLY IDENTIFICATION AND CLCSUE W Gell ITEPS 0 OPEN ITEli ID0lTIFICATION AND PRIORITIZATI0fl. l t o IDELOP K01ANISM TO FOCUS DEVELOPKNT OF GJIDNCE AND IRC/ DOE INTERACTIU4S U1 FUfML CLUSURE W (AH iTDS. i I i l 1 3
O O O OftN llBi ILENTIFICATION AND PRIORITIZATIM
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o (fdERIC ClifLIAfCE FRONSTRATION ISSUES i o SITE SPECIFIC OPEN ITEMS o CONSULT WITli DUE, STATES, AfD TRIPES o PRIORITIZATION DElElfilNE WlERE GUIDAICE AliD lA>RK W OPEN ITEN RESOLLITION IS M)ST NEEDED i'UST ColffElffl0US OftN llEMS i CRITICAL TO EARLY PHASES OF PROGRAM LONG-LEAD TltE ITB1S TIMllE 111111 RESPECT TO OVERALL PROGRAM SCHEDULES 1 4
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, l'EElli6S VENllLATE F0 SIT 10f6 TO ESTABLISH TECHNICAL CONSENSUS
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PUBLIC CtW81T TARCET CHUPS DOCLENT CONSENSUS /AGIGEffS IN FINAL TECHNICAL 10 SIT 10f6 11)E, STATES, AND TRIPES T/ PES OF TEGNICAL KSIT10NS SlRATEGIES - DEVELOP CRISP BASELINE / GROUND RULES, E.G., HYDROLOGIC TESTllE IfHiODOLOGIES - IPPLEE NTATION OF EPA STAl0ARD. 6 .
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f V) LR-287-47 nn/nn/86 LETTER REPORT TITLE: PROCEEDINGS OF THE NRC/ORNL WORASHOP: RADIONUCLIDE SORPTION MODELING RELATED TO HIGH-LEVEL NUCLEAR WASTE REPOSITORY PERFORMANCE ASSESSMENT Date: May 13-15, 1986 l Location: Willste Building, Silver Spring, Maryland Organizing Cometttee: ORNL - G. K. Jacobs, A. D. Kelaers; . and R. E. Meyer NRC - D. J. Brooks O Workshop Moderator: G. K. Jacobs AUTHOR: A. D. Keleers Chemical Technology Divtsion OAK RIGGE NATIONAL LABORATORY Gak Ridge TN 3783I PROJECT TITLE: Technical Assistance in Geochemistry, 4
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. PRO' JECT MANAGER: G. k. Jacobs ACTIVITY NUMBER: ORNL No. 41 88 54 92 4 (FIN B0287)/NRC No. 50 19 03 01
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A U
--------------------------------NOTICE---------------------------------
This letter report is a prettetnary draft of a report to summartze the conclusions of a workshop on sorption held during May 13-16 in Silver Spring, Maryland. All of the workshop particpants have not had the opportunity to review this letter report for: (1) consistency with their perception of the c.onclusions from the . workshop. (2) clarity, (3) technical accuracy, and .=) completeness. -ne participants are now revtewing this letter report and a final version should be available within the next
)
month.
--------------------------------NOTICE---------------------------------
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SUMMARY
A workshop was held to: (t) explore issues pertinent to the measurement and modeling of sorption processes in rock / groundwater systems that must be resolved to satisfy the regulatory process for high-level nuclear waste reposttery analysts, and (iil help support the revtston of the draft NRC Technical Position on sorption, The conclusions of the workshop were:
- Understanding of sorption processes at candidate repository sites wtll be necessary for release scenarios of radionuclides which are important to predicting compliance with' regulatory standards.
Understanding will be necessary to conduct either accurate (~s, performance assessments under expected condittons, or
\" conservattve bounding release calculations for lietting condittons.
- Understanding of sorption processes must be developed through laboratory programs wntch produce the information needed to support the modeltng of radtonuclide sorption and releases to the access 151e envtronment.
- The experimental paraeeters that must be explored and quanttfled t
to achieve understanding of sorption were tdenttfted and priortti:ed at the. workshop. The experim' ental programs should initially emphastze sit'e-specific testing. out sho'uld also be supplemented'by detailed experimentation designed to estabitsh an understanding of the sorption processes. O Page 3
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- 1. PURPOSE AND GOALS -
The workshop was planned to help support the NRC regulatory process for the candidate high-level nuclear waste repository sites through an evaluation of the technical and regulatory issues associateo with modeling sorption of radionuclides in repository systems. Such an evaluation is tirely, because the DOE site projects are currently: (t) predicting radionuclide releases to the accessible environment that are consistent with regulatory requirements, and (ii) crediting sorption processes as an important barrter in achieving these releases (DOE 1986a, DOE 1986bl. A discussion of the DOE sorption modeling methodology is included in the Appendix. Concern ov,er the curr.ent DOE methodology for modeling sorptic'n provided much of the impetus for the workshop. Performance assessment calculations are being conducted by () DOE with so-called conservattve estimates of sorption values. these sorption values have often been estimated fece empirical tests However, which provide insufficient understanding of the sorption processes. Without understanding the processes, the degree of conservattsa cannot be quantified. Some of the problems or uncertaintres associated with an emotrical'acproach to sorption data measurement and prediction of re.tardation performance, as well as the need for a better understandtrg of the sorption reactions or processes involved, have oeen previously expressed'tPelvea et al. 1980; Barney 1991; McKinley and West 1981; Serne and Relrea 1981;.NRC 1983; Katch et al. 1984: Siegel and Erteksen 1084; Tripathi et al. 1986). The' purpose of the workshop was twofold. First, to identtfy the modeling methocology and supporting experimental data that wouId be required to' accurately and defensibly model. sorption processes at the repository sites for various radioactivity release scenarios, and, second, to contribute to the develop' ment of the NRC Technical Posttton Page 4
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on sorption to be tssued in final form this fall (a draft Techntcal Position was issued in January 1986 for public comment).
- 2. CONCLUSIONS The following sections summart:e the consensus of the workshop participants. Selected pertinent references to previously published consents on specific items, supporting discussions, or examples of the effects of the parameters, are included. The discussion during the workshop fell into two general categories: (i) an evaluation and analysis of the role that geocheatcal sorption processes may play in the multiple barrier concept for high-level waste isolation, and (ii) a descriptton'and prioritization of the sorption parameters that must be -
quantified to accurately and defensibly model radionucitde retardation in rock / groundwater systems. There was general agreement at the (} workshop concerning the need to understand sorption processes. However, unantaity did not exist with respect to the level of detail required or the prtoritt:atton of all sorption parameters. It seems probable that each radtonuclice/ site / release scenario analysis would have to be resolved on a case-by-case basts. 2.1 Scrptten and the Performance of Reposttertes Gaining an understanding of sorption processes will be essential to modeling the future behavior of radionuclides in the rock / groundwater system of any s , so.that,extrapolatio.1 of sorption behavtor over time and space will ce possible. Obtatntng an understanding of sorption processes to a degree adequate to support, accurate or conservative' predictions of radtonucitde retarcation wtll require appropriate theoretical concepts, valid mathematical models, and the supporting data required by the models. It is the responsibtlity of the DOE site projects to shot, an understanding of the sorption processes which is , Page 5 1
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O sufficient to satisfy the reasonable assurance aspect of regulatory standards, and additional experimentation and use of improved models by the DOE may be necessary to achieve that goal. Improvements are likely to be incremental over tree. To maximize the benefit from the addittonal work, it will be important to recurrently evaluate and prioritize the work needed to reduce the predictive uncertainties. 2.2 Soration Parameters, A major accomplishment of the workshop was the comptlation and prioritization of the parameters which should be included in the DOE experimental program to develop an understanding of sorption processes. It seemed appare.nt to thg workshop participants that a substantial body of new information would be required to achieve understanding of sorption processes, and that most of the new data would have to developed as a result of laboratory experimentatten. The following paragraphs briefly describe the geochemical parameters relevant to sorption which were identified during the workshoo. The parameters are divided into two broad categories: those which were constdered to be essenttal for modeling the sorption properties of one or acre important radionuclides and at one or more candidate repository sites; and those which may have to be evaluated because they might be essenttal. l 2.2.1 Essenttal Parameters Guantification of these pa,rameters is constdered essential for either
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stte-specific tests or experiments designed to reach understandtng of the processes.- For site-spectftc tests, the measurements must be made i 1 under test conditions that are relevant to th'e repository.and the l release scenario under evaluatton. The geochemical conditions associated with,some sites or release scenarios or reposttory asoects may be difficult to establish. This uncertainty can best be dealt with O Page 6
<<< DRAFT 06/30/86 >>> ,r 's) by conducting tests over ranges of parameter values. This approach will contribute to an understanding of the sorption process and will serve to identify the more important parameters. While the experimental program should initially emphasize site-specific testing, this work must be extended to include detailed experteentation designed to establish an understanding of the sorption processes.
Solids - The solids used in the expertmental program must be representative of the sorptive phase (s) in the waste package and along the release pathway (Relyea et al. 1980 Barney 1981; NRC 1983). The major and minor site minerals must be characterized physically and chemically (Serne and Relyea 1981). This charactertzation may require Identification of release pathways 'at the site.. 1.e. fracture flow, . matrix diffusion, etc. (Neretnieks 1980), and physicochem*. cal charactertzation of ':rtil core and exploratory shaf t samples (Relyea et (} al. 1980). Actual site materials or representative generic materials should be used in the sorption tests. Single mineral experiments can be used to identify specific reactive phases and help gain understanding of reactions (Palmer and Meyer 1981), while whole rock tests may serve to better model site behavtor. Dtfierent results may be obtained with tests using crushed vs tntact rock, and tuese differences should be evaluated (Barney 1981). The surface area of the test matertal should be representative of the 2n situ system, or else the effects of the surface area / volume ratto of the. tests should be quanttfied (Htqqo and Rees 1986). If rocks have been pulverized for use in the experteents, understanding the effects,of grinding, surface area change, and
. potential alteration of surface coatings on the sorption reactions will be important. Methods such as x-ray diffraction, scanning electron . etcroscopy, as well as surface charact.ertzation analyttcal methods (e.g., ESCA. Auger, etc.) will'De useful in understandtng the surface
- phenomena (Relyea et al. 1980; Serne and Relyea 1981).
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O (_/ Solutions - The solutions used in the site-specific tests must be representative of the radionuclide-bearing altered groundwater released from the waste package to the reposttory site (Relyea et al. 1980; NRC 1983). The alteration of groundwater composition due to radiolytte and thermal effects as well as the presence of waste package components in the engineered factitty should be included in the test matrix (NRC 1983). Also, tests should be designed to investigate the effects of changes in groundwater composition due to geochemical reactions along release pathways. The possible effects of organtcs that could be present (McKinley and West 1981). or particulates which could form due to groundwater instabtlity, waste package components, or radtonuclide hydrolysts reactions.should be considered (Relyea et al. 1980). Because sorption reactions may be sensttive to the radionuclide speciation (Siegel and Ertckson'1984), the solution species released from the waste package should b'e tdenttfied and used in the tests, or actual solutions (} from waste fore dissolution tests should be used. Some experiments to develop a better understanding of the sorption reactions may need to be performed using soluttons containing only a few constituents of the groundwater. Systematic variattans of the composttian of these simplified solutions may yield significant insight into the sorption mecharises occurring in the more complex systems. Test Methodolooy - Both static ano dynamic (closed and open) expertmental methodologies must be employed (Relyea et al. 1980). Baten contact tests allow rapid screening of a number of parameters, while column chromatographtc tes,ts more accurately simulate flowing
~
groundwater and allow eva1uation of a greater variety of parameters (Relyea 1982). Other experimental methods such as staged expertmentation, at'xed-flow reactors (Walton et al. 1982; Theis and V #.21 1985), etc. may be contribute to the Interpretation of the'stte-
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specific batch contact and column tests. A limited number of larger scale tests should also be conducted in the field to validate the u.) Page 8
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predictions based on laboratory results (McKinley and Hadermann 1984). Experience has shown that sorption behavior in the field is mot always similar to that measured in laboratory tests (Nyhan et al. 1995). Conditions - For site-specific tests, the geochemical conditions during the test must be representative of the release pathway conditions and the release scenario under evaluation (Relyea et al. 1980). Thus, the test pH, redox conditton, pressure of CO2, etc. should be known and established to mimic the release pathway. Since repository time cannot be duplicated in the laboratory tests, means of conducting accelerated tests should be explored. Both statte and dynaatc tests should be conducted to simulate reposttory conditions (Barney 1981; McKinley and
, Hadermann 1984). In general, ranges rather than single values.of all conditions should be investigate'd to establish the sensitivity of the parameter to the expertmental condittons. For experiments designed to
() increase the level of understanding of the sorption reactions, the conditions may need to be evaluated separately and thus may not reflect actual site conoittons. Important Selease Scenarios and Radionuc!! des - It is obvious that all the above parameters cannot be quantifted for all sites, potential release scenartos, and radionuclides in a time frame consistent with the repository development schedule. It will be necessary to judiciously identify those scenarios and radienuclides that are particularly critical to showing compliance with regulatory standards at the
, respective sites. The ex,perimental programs would .thus focus, at least initially, on the qua,ntification of these scenartos and radionyclides.
2.2.2 Parameters for Evaluation The parameters included in this section are those which may, or may not, be important for some radtonuclides'and/or release scenarios at one or Page 9
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more sites and, therefore, should be initially investigated only to see if quantification is necessary for defensible sorption predictions. Comoetttten - Competttton among radionucitdes and major groundwater constituents for sorption sites may be important (Serne and Relyea 1981; Katch et al. 1984). The sorptive phases may have a limited number of active sorptton sites and competition for these sites may decrease the sorption of some radionuclides. Conversely, some sorptive phases may be selective for specific radtonucitdes and, thus, may be unaffected by competttron effects (McKinley and Hadermann 1984). Competition among radionuclides and major cation constituents of groundwater for complexing agents can also occur, as well as the formation of mixed metal complexes among . radionuclides (Grenthe et al. 1986). Sorption . tests frequently are run with only one radionuclide at a time, which does not allow evaluatton of competition effects. To evaluate these () phenomena, sorption tests should be run with several relevant radtonuclides present in apprcprtate combinations and proportions (McKinley and West 1981). vin 9 tics - Estaclishing kinette relationships for sorption processes is important not olly to addressing site behavior, but also to help understand tha sorption processes. For e< ample, detailed investigations into apparent sorptton/ desorption dasequilibrium for some radicnuclides has suggested that the presence of multiple species in batch contact tests may be the cause of the apparent disequilibrium (Higgo and Rees 1986). If actu , sorption / desorption disequiltbrium occurs, the results from batch contact tests may be conservative, relative to the anticipated behavior in the reposttory sv. stem (Barney 1985). However, this conservattsm cannot'be unegut'.acally demonstrated without an understanding of the processes' involved. In some groundwater systems (especially fracture flow systems), the rate of sorption for some radionuclides may be slow relative to the groundwater residence tree or 3. (U Page 10
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p) (- to the rate of mass transfer of the radionuclide to the sorptive gnase (Neretnteks 1980). In these cases, Quantifytng the kinetic relations will be essential for reliable estimation of radionuclide migration (McKinley and Hadermann 1984). Colloids /Particulates - Some radionuclides could be transported as colloids or particulates rather than solution species, and these vartous forms may migrate differently in the repository (Relyea et al. 1980 McKinley and Hadermann 1994; Higgo and Rees 1986). Consequently, it may be necessary to consider non-equilibrium forms of radionuclides (Travis and Nuttall 1985). Both americium and plutonium, which likely will be important radionuclides for performance assessments due to the very low cumulative relea,se ltatts in t,he EPA regulation, can be present in colloidal' forms in many groundwaters (Olofsson et al. 1982; Nyhan'et al. 1985; Mailen and Bell 1986). Other radionuclides may also have colloidal forms in some site groundwaters.
}
SorDtion Isotherms - The sorption value measured in tests may be dependent upon radionucitde con:entration (Relyea et al. 1980). Typically. the distribution cowfficient decreases at htgner radionuc!tde concentration due to saturatten of the sorption sites (McKinley and West 1981). To explore and quantify this effect, it may be necessary to develop sorption data in the form of sorption isotherms (Serne and
, Relyea 1981: McKinley and Hadermann 1794).
Mineral Surface Coatinos , Mineral surface coatings may. play an
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tmportant role in sorptton (Jenne 1977). Characteri:ation of the in situ coatings along release pathways should be constdered. Tests to explore the effects of surface coattngs on sorption reactions may be important for quanttftcation of the. sorption to be expected at a given site (Erickson.1985). Page' 11
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O Thereadynasic Data - Additional thermocheatcal data will be needed to support modeling calculations and extrapolation of laboratory data to different conditions and times (Relyea et al. 1980; Serne and Relyea 1981). As site-specific tests are conducted, the needed data will become apparent. For example, the stability constant for a particialar complex or a solubility product for a solid phase r.ay be needed to elucidate the nature of a sorption reaction. As these needs become apparent, the data should be obtained. l 4 O i i s () Page 12 l 1
- . - - .,------,n , , -- , . _ . - - - , - . - . - - - - . - ,, .. _ . - . . . . , , - - --.n - . . . _ . . . , - - . - , - . - - - - . - - . . - .
. l
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i l
- 3. LIST OF PARTICIPANTS Lawrence Berkeley Laboratory -
A. F. White Nuclear Regulatory Commission - D. J. Beata P. S. Justus G. F. Birchard W. R. Kelly J. W. Bradbury L. A. Kovach
. ,0. J. prooks
- T, Mo ,
K. C. Chang J. Tescriero K. C. Jackson M. F. Weber O Oak Ridge hattonal Laboratory - W. D. Arnold S. D. 0"Kelley J. G. Blencoe R. E. Meyer G. K. Jacobs V. S. Trtpath
- 4. D. keiser's i
Pacific Northwest Laboratory - i K. M. Krupka ' R. J. Serne Sandia National Laboratory - t ! E. J. Bonano M. D. Stegel R. Rechard 1 i Page 13
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0
- 4. APPENDIX - BACKGROUND INFORMATION ON SORPTION AND DOE ANALYSIS OF CANDIDATE DEPOSITORY SITES Much of the tapetus for the workshop, and the reason for many of the conclustons dtscussed earlier, was concern over the current DOE methodology for predicting sorption processes in performance assessments. The artncipal concerns are DOE's use of the "Ko" approach; the underlying theoretical concept, the data measurement methodology, and the mathematical modeltng are all atens of concern (Tripathi et al. 1986). This appendix summarizes these concerns.
A high-level waste repository site will consist of several ka8 of rock - surrounding the emplaced waste.' In additton to physical isolation from the environment, this large volume and mass of rock will, for some sites, also provide an extenstve sorptive medium 4 3r retardattan of solubilt:ed radionucitdes. Sorption is specifically cited in NRC regulations only in 10 CFR Part 60.122 as a favorable condition for siting criteria. However, most scientists have assumed that sorption by the host rock would play an important eole in predteting site performance which is in compliance with the cumulative radianuclide release lieits to the accessibt'e environment spectfled in the EPA regulation 40 CFR Part 191. Far many radionuclides, even poor to moderate' sorption could result in retention of the radionuclides for times longer than those required for radioactive decay to reduce the concentration and release,of radianuclides to acceptable levels. The Environmental Assessment reports (EA's) issueo by the DOE for the Yucca Mountain (DOE 1986b) and the Hanford Site (DOE 1986a) candtdate repasttortes include an analysis of the retardation of solubtit:ed ! radi'an.uclides in groundwater by sorption onto the tuff at Yucca Mountain and the basalt at .the Hanf ord Site.- Less emphasis was given to sorption O Page 14
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O processes in the EA descrtbing the candidate salt site (DOE 1986c). In both cases, the mobility of many radionuclides was calculated to be retarded oy orders-of-magnitude, relattve to the groundwater, as a result of sorption reactions involving the host rock. These predictions were based on application of the idealized chromatographic relattonship (so-called Ko modt!) developed for saturated, porous ton exchange media R, = 1 + Ko(d/p) , where R, is the retardation factor, d is the rock bulk density, p is the porosity of the rock, and Ko is an experimentally measured equilibrium distributton coefftetent. This modeling approach may prove acceptable
,, for some'radtonuc11 des at one or more sites. However, predtetions of -
the mobility of some radionucitdes in some geologic systems say prove to be inaccurate and non-conservattve because sorption tn some () rock / groundwater systems may be poorly represented by this chromatograchte model. The following are :mportant uncertainties or non-conservative aspe:ts of the application of Ko model to geologic systems (references are included to some similar statements of concern puolished by others). (1) The radionuclide-transporting medtum (groundwater) may not contact all of the reactive volume of the stationary sorbent phase (rock) due to: (i) the prevalence of fracture-flow hydrolo , :endttions, and/or (11) slow diffusion rates of radionucitdes into host rocks (Neretnieks 1980: McKinley and Hadermann 1984: Hadermann and Roesel 1985). (21 The sorption-reactions controlling the measured Ko value may not reach chemtcal equilibrium (Barney 1981). Page 15 1 l
t
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~
O (3) The measured K. value may not be independent of the radionuclide concentration and thus cannot be accurately modeled by a single value (Barney 1981: Serne and Relyea 1981; McKin!?y and Hadermann 1984). (4) Radionuclides may undergo chemical reactions during atgration, be present as multiple species, or competition between radionuclides or groundwater constituents may occur for the sorptton sites (Serne and Relyea 1981; Stegel and Erickson 1984; Katch et al. 1984; Higgo and Rees 1986). (5) Unsaturated hydrologic systems, such as the Yucca Mountain
, repositor.y f ormation, are dif ficult to properly model.
(6) Migratton of collotdal radionuclides, either real or pseudo-() co!!oids, are difficult to model (Travis and Nuttall 1985; Hagga and Rees 1986). Many of the crablems or uncertainties associated with the retardation predictions in the EA's stem free the experimental design chosen by t.1e DOE laboratories for the sorption tests; for example, pulveri:ation of stta rocks for use in tests. The emptrical test methodology used may te characteri:ed as " process blind," and at provides little insight into ; I the sorption reactions. Although significant amounts of empirtcal sorption data exist, the data do not contribute to understanding and may not afford reasonable assurance that conservative values have been , selected for modeling. calculations. . Care will have to be exercised by the DOE to demonstrate that.the uncertaint'tes and'liattations in the data and the Ko modeling methodology will preclude non-conservattve predictions. In some cases, it seems likely that the Ko modeling approach may not even be adequate Page 16
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O for estimation of bounding radionuclide retardation values under limiting conditions. As dtscussed eartter, the con.ansus of the a workshop was that understanding of sorption processes will be necessary 4- to support performance assessment modeling for some important radionuclides. This understanding will be important whether DOE attempts to calculate bounding values (the values must be demonstrably conservative and bounding) or accurate values using more comprehensive hydrogeocheatcal models.
- 5. REFERENCES Barney 1981 -
G. S. Barney, Evaluation of Methods for Measurement of
, Radionucli.de Distribution in Groundwater /Fock. systems, RHO-BWI-LD-47, -
, Rockwell Hanford Operations. Richland MA, August 1981. Barney 1985 - G. S. Barney. D. L. Lane, C. C. Allen, and T. E. Jones. [) Soration and Desorotton Reactions of Radionuclides with a Crushed Basalt-Bentonite Packino Material, RH0-BW-SA-416 F. Rockwell Hanford Operations Richland WA, April 1985. DOE 1986a - U.S. Department of Energy. Environmental Assessment. Reference Recository Location. Hanford Stte. Washinoten, 00E/PW-0070, Washington DC. May 1986. DOE 1986b - Department of Energy. Environmental Assessment. Vucca Mountain Site. Nevada Research and DeveloDeent Area. Nevada, 00E/RW-0073, Washington dC, May 1986. DOE 1986c - U.S. Department of Energy, Environmental Asses-seent. Deaf intth County Site. Texas, DOE /AW-0069, Washington DC, May 1986. Erickson 1985 - T. E. Ericksen, A Laboratory Study on Radio'nuclide Page 17
- r w- r ---, -m- - .,n --,.---.-,.r,-,-n,--,---<~-m -m g- e +-.-,,-.v-,,n-,...n ------,,,,-m-, - - .-g- ,- - ,-- --
4
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Migration in Single Natural Granitic Fissures," Nge,1. Techno!. 70. 261-267 (1985). Granthe et al. 1986 - I. Grenthe, C. Raglet, and P. Vitorge, " Studies of Metal-Carbonate Complenes. 14. Composition and Equiltbria of Trilinear Neptuntum(VI)- and Plutonium (VI)-Carbonate Complexes," Incro. Chem. 25, 1679-1684 (1986). Hadermann and Roesel 1985 - J. Hadermann and F. Roesel, Radionuclidt Chain Transcort in Inhomooeneous Crystalline Rocks. Limited Matrix Diffusion and Effective Surface Sorotion, EIR-Bertcht Nr. 551, Satss i Federal Institute for Reactor Research, Wurenlingen, Switzerland,
, February.1985. .
Higgo and Rees 1986 - J. J. W. Higgo and L. V. C. Rees, " Adsorption of Actinides by Martne Sediments: Effect of the Sediment / Seawater Ratio on O< ss the Measured Distribution Ratto," Environ. Sci. Technol. 20, 483-490 (1986). Jenne 1977 - E. A. Jenne, " Trace Element Sorption by Sediments and Sotls--Sites and Processes," in SymDostem on Molybdenum in the Environment, W. Chappel and K. Peterson, eds., Vol. 2, pp. 425-553, M. Decker Inc., 1977. V,atch et al. 1984 - N. Kat.oh, H. Tasaka, and T. Asano, "A New Safety Assessment Model for Shallow Land Burtal of LLW Based on Multicomponent Sorption Theory," In Waste Manaoement '94, pp. 551-555, American Nuclear
- Society, La Grange Park IL, 1984.
M+tlen and Bell 1986 - 'J. C. Mailen and J. T. bell, Plutonium ' l Cheatstry and Micration Behavior in Hioh-level Waste ReDosit'ory Environments, Letter Report LR-287-29, Oak Ridge National Laboratory to Page 10
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O U.S. Nuclear Regulatory Commission, February 12, 1986.
.1cKinley and West 1981 -
I. G. McKinley and J. M. West, Radionuclide Sorotton/Desorotton Processes Occurrina Durino Groundwater Transcort, ENPU 81-6, Harwell Laboratory, Oxfordshire, England, May 1981. McKinley and Hadermann 1984 - I. G. McKinley and J. Hadermann, Radionuclide Sorotion Databsso for Swiss Safety Assesseent, EIR-Bericht Nr. 550, Swiss Federal Institute for Reactor Research, Wurenlingen, Switzerland, October 1984. Neretnieks 1980 - I. Neretnieks, " Diffusion in the Rock Matrix: An Important Factor in Radionucitde Retardation?,".J. Geoohysical *
~
Research 85, 4379-4397 (1980). () NRC 1983 - U.S. Nuclear Pegulatory Commisston, " Appendix T, Determination and Interpretation of Sorption Data Applied to Radionuclide Mtgratton in Underground Repositories." in Draft Site Charactert:ation Analysis of the Site Charactert:ation Report for the Basalt Waste Isolation Project, NUREG-0960 Washington DC, March 1983. Nynan et al. 1985 - J. W. Nyhan, B. D. Drennon, W. V. Abeele, M. L. Wheeler, W. D. Furtymun, G. Trujillo, W. J. Herrea, and J. W. Booth, "Distributton of Plutantum and Amertctus Beneath a 33-year-old Ltquid Waste Disposal Site," J. Environ. Qual. 14, 501-500 (1985). Olofssen.et al. 1982 -- U. Olofsson, B. Allard, K. Andersson,,and B. Torstenfelt, " Formation and Properttes of Americium Colloids in Aqueous Soluttons," in The Scientific Basts f or Nuclear Waste Manacemen(, Matertals Research Society Symposia Proceedings Vol. 11, ed. W. Lutze, North-Holland, 1982. O Page 19
L
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^
3 (G Palmer and Meyer 1981 - D. A. Palmer and R. E. Meyer, " Adsorption of Technetium on Selected Inorganic Icn-Exchange Matertals and on a Range of Naturally Occurring Minerals Under Oxic Conditions," J. Incro. Nucl. Chem, 43, 2979-2984 (1981). Relyea et al. 1980 - J. F. Relyea, R. J. Serne, and D. Rai, Methods for Deteretnino Radtonuclide Retardation Factorst Status Reoort, PNL-3349, Pacific Northwest Laboratory, Richland WA, April 1980. Relyea 1982 - J. F. Relyea, " Theoretical and Experimental Considerations for the Use of the Column Method for Determining Retardation Factors," Radioactive Waste Manacement and the Nuclear Fuel Cvele 3. 151-166 (1982). . Serne and Relvea 1981 - R. J. Serne and J. F. Relyea, "The Status of I'T Radionuclide Sorption-Desorptton Studies Performed by the WRIT Program", G in Technoloav of Htch-level Nuclear Waste Manacement, DOE / TIC-4621, Vol. 1, pp. 203-254, Department of Energy, Oak Rtdge TN, 1981. Stegel and Erickson 1984 - M. D. Siegel and V. L. Ertekson, "Radionucitde Releases from a Hypothetical Nuclear Waste Repository: Potential Violations of the Proposed EPA Standard by Radionuclides with Multiple Aqueous Species," in Waste Manacement '8a, American Nuclear Society, La Grange Park IL, 1994. Theis and Vaul 15 - T ., L . Theis and L. W. Kaul. " Rates of Sorption at the Goethite-dater. Interface", American Chemical Society Meeting September 1985, pp. 281-283. Travis.and Nuttall 1285 - 8. J. Travts and H. E. Nut t all , A Tr anspor t, Code for Radionucitde Micratteat With an Assessment of an Actual Low-Level Waste Site, LA-UR-84-3954, Los Alamos National Laboratory, Los O V Page 20
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Alamos NM, 1985. Tripathi et al. 1986 - V. S. Trtpathi, G. T. Yeh, G. K. Jacobs, and A. D. Kelmers, " Performance Assessment of High-level Nuclear Waste Repositories: Can Kd's Represent Geochemical Reality?," to be presented i at Sympostum on Geocheatcal Aspects of Radtoactive Waste Disposal, i American Chemical Society Meeting, Anahetn CA, September 10, 1986; manuscript in preparatton. Walton et al. 1982 - F. B. Walton, T. W. Melnyk, R. G. Abry, and K. Fleury, "The Determination of Nucitde-Geologic Kinettes Ustng Mixing-Cell Contactors," Chem. Geol. 36, 155-178 (1982). o O e e b O Page 21
h) t s i , O i i Determination of Radionuclide Solubility i in Groundwater for Assessment of a High-Level Waste Isolation 1
-l t
I \ Technical Position - November 1984 t l .
- Geochemistry Section - Geotechnical Branch O oivisio" or weste " " 9 eat U.S. Nuclear Regulatory Commission J
f i i i i l 4 l r l O O I I L,,,,,,.--.n--.--.... . . . _ ,
TABLE OF CONTENTS Page
- 1. 0 INTRODUCTION .......................................... 1 1.1 Purpose .......................................... 1
- 1. 2 Definition of Solubility......... .................. 1
- 1. 3 Use of Solubility................................... I 1.4 Regulatory Framework................................ 2
2.0 BACKGROUND
.......................................... 3 3.0 STATEMENT OF P0SITION................................. .. 4 4.0 DISCUSSION .......................................... 5 4.1 Matrix Development.................................. 6 4.2 Determination of Run Product Compositions........... 7 4.3 Determination of Radionuclide Solubilities.......... 8 4.4 Source of Uncertainties.............. .............. 11 4.5 Geochemical Modeling and Solubility /Speciation _
' Calculations........................................ 14 - *
5.0 REFERENCES
...... ..................... ............. 16 O
1 9 i .
~
l l l l
DETERMINATION OF RADIONUCLIDE SOLUBILITY IN GROUNDWATER A FOR ASSESSMENT OF HIGH-LEVEL WASTE ISOLATION
\ - NRC TECHNICAL POSITION
1.0 INTRODUCTION
1.1 Purpose The purpose of this document is to present a general approach for determining radionuclide solubilities in support of high-level waste site characterization, repository construction authorization and licensing decisions. It is not intended to prescribe methods for radionuclide solubility determinations. Instead, the Department of Energy (00E) should use this guidance to prepare detailed plans for radionuclide solubility determinations and should submit appropriate documentation early in the site characterization review process.
- 1. 2 Definition of Solubility . .
Solubility is defined i this technical position as the precipitation-limited O co"ce"tretio" or e 9've" redio""ciide '" oro""e eter- ^ arecipitetioa-ii ited concentration occurs when the groundwater is in stable or metastable equilibrium with one or more precipitated stoichiometric (fixed composition) solid phases containing that radionuclide. 1.3 Use of Solubility Solubility estimates can be used in four general aspects of site characterization and performance assessment. First, solubility studies can be used to help screen for " key" radiont.clides which are defined here as those radionuclides that are highly toxic and mobile r d cccur in cignificant quantities in the nuclear-repository. The mobility of radionuclides depends in part on radi~onuclide solubility and groundwater flux. Radionuclides with very low solubilities could be eliminated from extensive testing if i.t can be shown that they will never exceed the. release rates or significantly contribute to the integrated radionuclide flux in accordance with the Nuclear Regulatory Commission (NRC) regulations. Second, solubility estimat'es can be used as a performance measure for waste package. Simulated waste package can be tested 1
to determine the effectiveness of their design to contain radionuclides, limit
'a their concentrations, and retard their escape when a breach occurs. Third,
)
solubility determinations involving the waste package can be used as input for determining the capacity of the near field to inhibit radionuclide mobility. Fourth, solubility estimates can be used to specify the source term for far-field performance assessment. 1.4 Regulatory Framework The Nuclear Waste Policy Act of 1982 (P.L. 97-425) defines the role of Federal agencies in the national program for disposal of civilian (commercial) nuclear waste. For high-level radioactive wastes, the Environmental Protection Agency (EPA) is responsible for developing "... generally applicable standards for protection of the general environment from offsite releases from radioactive materials in repositories." The NRC implements the EPA standard and develops
.and. issues ". . technical requirements and criteria that it will apply in -
approving or disapproving (i) applications for authorization to construct repositories; (ii) applications for licenses to receive and possess spent nuclear fuel and high-level radioactive waste in such repositories; and (iii) applications for authorization for closure and decommissioning such repositories." The 00E is responsible for collecting the data needed for site characterization and for constructing and operating a waste disposal facility in accordance with NRC regulations. Prior to approving construction authorization, the NRC must have "... reasonable assurance that the types and amount of radioactive materials described in the application can be received, possessed, and disposed of in a geologic repository operations area of the design proposed without unreasonable risk to i the health,and safety of the public. ." (NRC, 1984). NRC criteria require information on the near. field behavior of the repository resulting from waste package / water / rock interactions. EPA criteria are evaluated on the basis of far-field performance assessment. Each assessment requires information on the relea3e of radionuclides to the accessible environment which depends on radionuclide concentrations in groundwater, radionuclide-bearing colloids and l particulates and the groundwater flux.
\
2
2.0 BACKGROUND
g
'O A geologic repcsitory achieves isolation and controls the rate of radionuclide release to the accessible environment by means of two major subsystems:
(1) the geologic setting and (2) the engineered system. The sfte is selected for geologic, hydrologic and geocheraical attributes of the geologic setting which can enhance isolation. Because licensing of a high-level waste repository ultimately will involve performance assessment modeling of radionuclide release to the accessible environment, input of radionuclide concentrations to performance assessment models is necessary. Radionuclide concentrations in the groundwater of the nuclear repository system may be very difficult to determine precisely when future geochemical conditions will not be known with complete certainty. However, an upper limit to these concentrations can be defined through experimental determination of solubilities of radionuclides for anticipated repository conditions. Both theoretical and empirical approaches have been used to estimate radio-nuclide concentration limits The theoretical approach involves measuring the d thermodynamic solubility product constants for radionuclide solid phases and equilibrium constants for solution species. Solubilities are then calculated for site-specific conditions. The empirical approach consists of measuring radionuclide solution concentrations under site-specific conditions. Limitations of these approaches are that the theoretical approach would require an extended effort to acquire the necessary data for all of the potentially significant radionuclide compounds and aqueous species anticipated in the repository, while the empirical approach is most relevant only to the precise conditions under which the solubility data are measured.
. 3.0 STATEMENT OF POSITION It is the position of the NRC that any site program that elects to take credit for solubility-limited release rates, should design a set of experiments to determine radionuclide solubilities applicable to the site-specific conditions.
~
l l In designing this set of experiments, the site program should: l0 3 { t
g 1) Develop a matrix of experiments in which the selection of starting k) materials is based on the anticipated range of proportions and compositions of phases under the various physicochemical conditions expected for a nuclear waste repository;
- 2) Determine experimental run product compositions for liquids and, where feasible, solids using analytical methods that include state-of-the-art techniques;
- 3) For the experimental matrix, determine radionuclide solubilities from undersaturation and oversaturation (experimental reversal) or, if this is impractical or impossible, from oversaturation where the concentration of radionuclide in the liquid decreases as the system approaches equilbrium;
- 4) Document the magnitudes of experimental and conceptual uncertainties from
. 'all anticipated sources; and.
q 5) Use geochemical modeling only for interpreting experimental results and U for planning experiments. The NRC staff considers that this approach of experimental determination of solubilities will provide reasonable but conservative estimates of solubility under repository conditions. When combined with a judicious choice of " key" radionuclides, this approach will maximize the usefulness of the information obtained from a minimum number of experiments. 4.0 DISCUSSION The amount of geot
- tical work necessary for determination of radionuclide solubility in grounawater to support waste isolation can be limited if it is carefully defined and conducted withi.n expected site-specific ranges of chemical / environmental conditions. Determinin'g release rates of radionuclides requires information on both radionuclide concentrations and groundwater fluxes. 'In determining release rates, consideration should be given to the physicochemical characteristics of the waste and other solids, groundwater chemistry, repository temperature and pressure, and kinetics of 4
i l l dissolution and precipitation reactions. One approach to estimating release A V rates may be based on radionuclide solubilities. The possibility that radionuclide-bearing colloids and particulates will form and/or that radionuclide concentrations in groundwater will exceed radionuclide solubilities (oversaturation) are important exceptions to this approach which should be considered. Furthermore, radionuclide concentrations in groundwater in equilibrium with radionuclide-bearing solids may be affected by the groundwater flow rate. Acquiring and confirming this information will be an ongoing, long-term goal to be achieved prior to repository closure. However, the NRC staff considers that it is possible to reduce the level of effort needed to obtain a release rate by making a bounding estimate of radionuclide concentration and coupling this with groundwater flux. 4.1 Matrix Development A matrix of experiments can be used to determine which tests are required to._ characterize solubilities of radionuclides in the various physicochemical' environments of a nuclear waste repository. Variables which should be included O V in the matrix are solid compositions, liquid compositions, proportions of phases, temperature, pressure, and ionizing radiation. Prior to experimentation, the total range in compositions and proportions of phases that occur anywhere and at any time in the repository should be considered. For solid materials, emphasis should be placed on the identification and characterization of solids which can include waste form, canister, backfill, seals, packing, and host rock minerals occurring along likely groundwater flow paths . These are the solids most likely to react with groundwater and affect radionuclide concentrations and release rates. Characterization of the solids should include chemical, mineralogical, and textural analyses. In designing solubility experiments, selection of solid reactants should be based on this characterization. Similarly, the. range of groundwater compositions expected in a repository syst~em should be considered in selecting liquid reactants. Generally, in 'the rock-dominated environments o.f a HLW repository, groundwater compositions will ce controlled by reactions with solids at various temperatures and pressures. Considerations of the range in water compositions 5
used in experimentation should be based on the range of compositions of V analyzed groundwaters at ambient conditions and the range of groundwater compositions experimentally determined at elevated temperatures and pressures. Following consideration of the complete range of compositions and proportions of phases in a repository, the size of the matrix may be reduced by first considering the dependence or interrelation of phases and conditions upon each other and then deleting incompatible combinations. The matrix developed prior to experimentation can be modified continuously as information from experiments is obtained. Knowledge of liquid and solid compositions gained from the results of preliminary experiments can be used as input into subsequent tests. From the standpoint of concentrations, key radionuclides can be identified experimentally as those having high solubilities while radionuclides with low solubilities may be eliminated from the testing plan.
" 4.2 Determination of Run Product Compositions 1 A number of analytical lethods are available for determining the concentration V of major, minor, and trace elements in water samples. Since the utility, detection limits, and reliability of the various methods differ for different elements, no single method can be recommended for a complete chemical analysis of a water sample. The choice of methods usually depends on the instruments that are available, the concentrations of the components to be measured, and the level of precision needed. In addition to analyzing for major, minor, and trace elements, characterization of aqueous liquid should include measurements I
of the pH and, if possible, redox conditions. The redox potential (Eh) and acidity (pH) of groundwater can strongly influence t'he mechanisms of dissolution'of the waste forms and solubility of primary and l secondary solid phases wh'ich, in turn, affect radionuclide release rates. In the past, the Eh and pH of experimental hydrothermal solutions have been calculated from quench measurements that are extrapolated to the' experimental conditions of high temperature'and pressure. The main disadvantage of this metnod lies in the unknown effects of quenching on the che'mistry of the (3 solutions. In order to eliminate the uncertainties associated with quenching, LJ 6
4 fm Eh and pH could be measured at experimental conditions if the sensors are shown
' to yield accurate and reliable results.
The NRC recognizes that characterization of some solids from experiments may be extremely difficult to perform due to the small quantities of these phases as run products. However, the characterization of solid run products from solubility experiments using analytical techniques including state-of-the-art methods is important. For example, at the same physicochemical conditions, different solid phases containing the same radionuclide can result in different radionuclide solubilities. Characterization of the solids is important in determining which reactions took place and how these reactions depend on experimental technique. 4.3 Determination of Radionuclide Solubilities 4.3.1 Theoretical.. Considerations In this technical position, reactions or processes in heterogeneous systems pd involving solid and liquid phases are divided into two major categories: sorption / desorption and precipitation / dissolution processes. The sorption process can be subdivided into physical adsorption, electrostatic adsorption (ion exchange), specific adsorption, and chemical substitution (coprecipitation or solid solution), (NEA Workshop on Sorption, 1983). The distinction between the two major categories of reactions, as' defined in this technical position, is that in the precipitation / dissolution reaction, the concentration of radionuclide-bearing component, i, is fixed at constant temperature, pressure, and mole fractions of all other components, X), in the solid phase, (s). Under the same conditions, in sorption / desorption processes, the concentration of i in the solid can vary as a re'sult of changes in the. concentration of i in the. liquid,(1).. In addition, the chemi. cal potential (p) and activity (a) of i in the solid is fixed in precipitation / dissolution reactions and can vary in sorption / desorption processes at constant temperature, pressure, and X) in the s o l i c'. O
- See Denbigh'(1971) for definition.
7
[D x_/ In a heterogeneous system involving a solid and liquid phase, component i will be transferred from the solid to the liquid in a dissolution / desorption reaction as the system approaches equilibrium if p; >p jg. tomponent i will pass from the liquid to the solid in a precipitation / sorption reaction if pgj>pg . When equilibrium exists between the solid and liquid phases, pg =pj) and the liquid is s' aid to be saturated with respect to the solid. For the chemical equation, ij s *I l
- d , lwhere i is the radionuclide-bearing component and j are all other components common to both phases, the equilibrium constant is a a j,j j,)
K= . (1)
.a -
- ij,s ,
n If the solid is pure ij, then a jj equals one and the equation becomes V K sp
=a a 9,j j,j (2) where K sp is the solubility product co'nstant. For nonequilibrium conditions, if the right side of (2) is less than the left side, the liquid is undersaturated with respect to the radionuclide-bearing solid. If, on the other hand, the right side is greater than the left side, then the liquid is oversaturated with respect to the solid.
4.3.2 Experimental Consideratioris The theoretical considerations concerning solid-liquid reactions can be used as l
- a. basis for determining experimental protocol in radionuclide solubility studies. These experimental procedures should yield radionuclide solubilities that are demonstrably conservative.
Q From the definition of solubility used'in this technical position, the ' b radionuclide-bearing solid phase controlling the solid-liquid reaction should I l 8 l
be a pure stoichiometric phase or the radionuclide-rich end member of a solid f)w solution. The chemical potential of i in this type of solid is greater than that in an impure phase or radionuclide poor solid solution phase under the same physicochemical conditions. As a result, at equilibrium the radionuclide concentration in the liquid is greatest when the composition of the solid controlling the reaction is fixed. Experimentally, it may be possible to determine when the composition of the solid controlling the solid-liquid reaction is fixed. For example, at the same temperature, pressure, and X) in the liquid, two precipitation experiments (p; j > p; ) with different radionuclide concentrations in the liquid starting material should yield the same radionuclide concentration in the liquid run products if the coexisting solid compositions are fixed. This is the maximum radionuclide concentration at equilibrium under these physicochemical conditions. In solubility experiments, equilibrium conditions may not be obtained iri a
,q reasonable length of time. However, equilibrium radionuclide concentrations can be estimated by determining concentrations under steady-state conditions.
Steady state is defined as the condition where measurable changes in concentrations are not occurring over practical experimental times. It should be noted, however, that this technique can lead to uncertainties in the estimated equilibrium concentration if metastable phases are involved in the precipitation / dissolution reactions (see Section 4.4.4). Radionuclide solubilities should be approached from both undersaturation and oversaturation (experimental reversal). If the steady state concentrations for both experiments are equivalent, then equilibrium is implied for the specific physicochemical cc - tions. 'If, on the other hand, a unique steady-state concentration is not det$rmined, then the steady-state concentrations from oversaturation (p g g > pg ] are equal to or greater than equilibrium concentration when temperature, pressure, and X) j are held constant. When reaction kinetics are unfavorable (slow), it is more important to determine radionuclide concentiations from precipitation reactions (oversaturatien) than from the corresponding dissolution reactions (undersaturation) since those from precipitation reactions yield higher radionuclide concentrations. 9
q Solids that are anticipated in the nuclear repository which may tend to buffer the composition of the liquid phase can be added to experimental charges. The presence of these solids in experiments may conveniently hold certain geochemical parameters constant while other parameters are varied. This eliminates the need to continuously readjust solution concentrations that can change drastically in unbuffered systems. Two assumptions underlie the use of buffers in solubility experiments. First, equilibrium or steady state conditions exist between the phases of the buffer assemblage fixing the chemical potential of some component common to the assemblage. This assumption can be verified analytically. Second, the assemblage chosen to buffer the system should be applicable to repository conditions. Unlike the first assumption, this assumption cannot be verified experimentally. However, reasonable bounds can be identified so that solubility experiments could yield radionuclide concentration applicable to repository conditioris.
, Two general approaches in designing solubility experiments can be utilized in the test matrix. One approach uses radionuclide-bearing solid starting material as the sole source of radionuclides in the system. This approach is probably most applicable to solubility experiments involving waste forms. The other approach uses radionuclide-bearing liquid starting material, which may be most appropriate to solubility studies representing repository conditions at some distance from the waste form. Each approach has advantages and disadvantages.
The advantages of performing solubility experiments with radionuclide-bearing solids as starting materials are that solids can be well characterized and I
, waste form solubilities can be determined. Disadvantages to using radionuclide-bearing solids as starting materials are that approach to steady-state concentration from oversaturation may be difficult and synthesis of site-relevant radionuclide-bearing solids including waste forms is i .
necessary. O the eeveeteses or soi#6'14tv experimeets ree ita reeio##ciide-ee r4#9 iiavid starting materials are that approach to steady-state from oversaturation may be , , 10
r_ relatively easy and synthesis of site-relevant radionuclide-bearing solids is Furthermore, these experiments should yield conservative results (n) unnecessary. because the initial radionuclide concentrations may be greater than the equilibrium concentrations. The disadvantages of doped-liquid experiments are that the experimental liquid may not represent anticipated radionuclide-bearing groundwaters and the solid (s) controlling radionuclide concentration may be difficult to characterize. 4.4 Sources of Uncertainties Uncertainties associated with solubility experiments stem from the inaccurate experimental representation of portions of a nuclear waste repository and imprecise analytical techniques. The choice of experimental conditions that simulate those in a nuclear repository requires consideration of certain paremeters which might affect radionuclide release. These parameters could e include groundwater composition and pH', redox conditions, rock / water ratios, a kinetics and metastability, and radionuclide-bearing colloics and particulates. One approach for handl' g uncertainties associated with choosing appropriate O V chemical conditions would be to determine, through sensitivity analysis, the range of repository conditions that could affect radionuclide solubility. These conditions would then be used in the experimental studies. 4.4.1 Groundwater Composition and pH Variation in groundwater composition and pH can have a strong effect on radionuclides solubilities (Apps et al, 1983; Moody, 1982). Increasing the concentration of certain groundwater components can either increase or decrease radionuclide solubility. For example, some groundwater components can act as ligands and react with the free ions of the radionuclide to form complexes. This results in enhanced radionuclide solubilities. However, when the i concentrations of other components, common to both_ groundwater and a precipitated radionuclide-bearing solid phase, are increased in'the groundwater, radionuclide solubility is decreased (see equation (2)). In order-l to. determine the effect of groundwater composition on solubility, experiments q should encompass the range of compositions expected in the nuclear repository. l V l 11 l
,. 4.4.2 Redox Conditions O
The solubilities of many radionuclides can be markedly different in their different oxidation states (e.g., technetium and the actinides (Apps et al., 1983)). The oxidation state of multivalent radionuclides may be governed largely by redox reactions that occur as a result of rock / groundwater 1 interactions. The redox potential (Eh) can be rigorously defined on a thermodynamic basis as the electrochemical potential of a system where all the reversible redox couples present are at equilibrium. Discussions of redox potential are presented by Hostettler (1984) and Garrels and Christ (1965). Natural systems usually contain more than one redox couple which should yield the same potential at equilibrium. However, redox reactions in natural systems are frequently irreversible (nonequilibrium), and the measured redox potential is often a mixed potential resulting from several redox reactions that may be coupled with each other. An unequivocal redox potential cannot be defined for
~
asuch nonequilibrium systems (e.g., Lindberg and Runnells, 1984; Morris and - Stumm, 1967; Whitfield, 1972). 4.4.3 Rock / Water Ratio The proportions of phases in experiments may affect radionuclide concentrations. Most experiments must be run under water-dominated conditions (mass of water > mass of rock), whereas a repository will typically be a rock-dominated (mass of rock > mass of w ter) system. Therefore, the effects of varying the water / rock ratio should be considered in solubility determinations. At high water / rock ratios, certain solid phases may be totally consumed by dissolution. As a result, liquid run products may not simulate groundwater anticipated in rock-dominated repositories. ( 4.4.4 Kinetics and Metastability Uncertainties arise from experiments in which the phase assemblage.does not reacri equilibrium. Experiments that do not produce a unique steady-state concentration for a given set of physical and chemical conditions result in uncertainties in the solubility of the radionuclide. In this case, the size of the error is experimentally defined by the range in the concentrations when 12 l r
steady-state conditions are approached from both undersaturation and
\
(V oversaturation. The inability to duplicate steady-state concentrations from undersaturation and oversaturation would require explanation. For example, irreversibility may indicate that an " unexpected" chemical reaction or experimental error had occurred. Consequently, the results coGld not be used. The inability to duplicate steady state concentrations also may result from slow reaction rates which impede complete reversal. The values established from oversaturation, where the radionuclide concentration decreases as the system approaches equilibrium, should be used because they are equal to or greater than equilibrium concentrations. A second type of uncertainty arises from experiments in which steady-state conditions involve equilibrium of a metastable phase assemblage. Steady-state concentration of the radionuclide involving a metastable phase assemblage can be greater than or less than steady-state concentrations involving a stable
. assemblage.. In order to dete'rmine if the radionuclide. concentrations in -
equilibrium with a metastable phase assemblage are greater than those in equilibrium with a stable assemblage, it is necessary to characterize the (J solids and use appropriate thermochemical data, if it exists, to calculate the stable phase assemblage and the radionuclide solubility. 4.4.5 Other Sources of Uncertainty Most studies of radionuclide migration in anticipated repository environments have focused on the transport of d'issolved forms of the radionuclides by flowing groundwaters. Colloid formation, however, is not uncommon in geologic systems, and colloidal and particulate forms of clays, ferric and aluminum hydroxide, and silicic acid polymers are frequently found suspended in groundwaters. It is possit>l'e that significant quantities of some radionuclides could be adsorbed on the surfaces of these particles in groundwaters (pseudo-colloids) or, under the proper circumstances,.the radionuclides themselves could form colloids (true colloids). Radionuclides in a colloidal form could conceivably migrate farther and faster than they would in a dissolved form involved -in sorption / precipitation reactions (Apps et al. ,1983). O 13 l
Attempts to separate colloids from the liquid phase in solubility experiments r3 (V can result in sorption on filters of dissolved radionuclide species resulting in lower concentrations in the filtrate or incomplete filtration which results in higher concentrations than those under equilibrium or steady state conditions in the filtrate. If sorption on the filter is suspected, preconditioned (saturated) filters can be used. If incomplete filtration is suspected, finer filters or more rigorous centrifugation should be used. Most solubility experiments study the chemistry of only one radionuclide, in contrast to the repository system which will have numerous radionuclides. Solubilities obtained in studies of one radionuclide may be much greater than those in systems containing numerous radionuclides. For example, when there is a limiting amount of complexing ligand, the concentration of a single radionuclide would be greater than that if two or more radionuclides were present which competed for the ligand. Solubility studies using multiple
.radionuclide's can be used to address this uncertainty. '-
q 4.5 Geochemical Modeling and Solubility /Speciation Calculations G Solubility and speciation of radionuclides in various synthetic and natural groundwaters can be calculated using computer codes. However, the results of those calculations may have limited validity for the following reasons: A. Equilibrium assumed. Calculations of radionuclide solubility / speciation are based on the assumptions that both homogeneous (one phase, groundwater) equilibrium and heterogeneous (multiphase, groundwater and solids) equilibrium are achieved. However, it is unrealistic to expect that reaction rates will be so rapid that both homogeneous and heterogeneous equilibria will continuously prevc - under conditions of varying temperature, mineralogy, pH, and redox potential. Furthermore, the radionuclide solubilities are calculated in equil.ibrium with most stable solid phasets) which can result in nonconservative concentrations. B. Incomplete mass transfer. Generally, solubility /speciation computer codes that are presently available (e.g., PHREEQE, EQ3/6) do not permit a 14
proper accounting for all of the potential chemical effects in mass transfer
- D V processes, such as ion-exchange and chemisorption.
C. Data base limitations. It is well known that the data bases for radionuclides in solubility /speciation computer codes are incomplete and also contain data of questionable validity. Numerous radionuclide complexes can form in groundwaters, but independent evidence that proves the existence of particular species is almost nonexistent. It is, therefore, likely that some complexes inferred to exist in significant concentrations under certain conditions may, in fact, not exist at all. Furthermore, it is likely that there are some important radionuclide complexes which have yet to be identified. Corresponding omissions also probably exist in the list of radionuclide-bearing solids that can form as a result of reactions between groundwaters and coexisting solid materials. Finally, the uncertainty (limits of error) of thermodynamic data, such as log K and AH f values for speciation
' reactions.can be large. -
D. Experimental validation required. As a result of the above consider-b ations and the complexity of the repository system, any solubility /speciation calculations will require experimental validation before their results can be employed in repository performance assessments. Thus, by themselves, the results of computer calculations are insufficient to establish the nature and significance of radionuclide solubility /speciation under repository conditions. However, geochemical models are useful for characterizing geochemical conditions (e.g. , groundwater ' chemistry, redox, pH controls and thermal stability), and for interpreting experimental data. These calculations could be used to guide experimental determin'ations and should only
, assume a supplementary and/of supporting role in the determination of solubility /speciation values unless they can be shown to be fully consistent with a substantial body of independent (experimental data) information.
O 15
i l
5.0 REFERENCES
(v Apps, J. A., Carnahan, C.L., Lichtner, P.C., Michael, M.C., Perry, D., Silva, R.J., Weres, 0., and White, A.F., " Status of Geochemical Problems Relating to the Burial of High Level Radioactive Waste, 1982", NUREG/CR-3062, Lawrence Berkeley Laboratory,1983. Denbigh, K. , The Principles of Chemical Equilibrium, Cambridge University Press, London, 1971. Garrels, R.M. and C.L. Christ, Solutions, Minerals, and Equilibria, Harper and Row, New York, 1965. Hostettler, J.D., " Electrode Electrons, Aqueous Electrons, and Redox Potentials in Natural Water", Amer. Jour. Sci., (284), 734-759, 1984. Lindberg, R.D. and 0.D. Runnells, " Groundwater Redox Reactions: An Analysis of Equilibrium State Applied to Eh Measurements and Geochemical Modeling", Science, (225), p. 925-927, 1984. Moody, J.B., "Radionuclide Migration / Retardation: Reasearch and Development c Technology Status Report", ONWI-321, Office .of Nuclear Waste Isolation, _:. Battelle Memorial Institute, Columbus, Ohio, 1982. . Morri s , J. C. and W. Stt. e , " Redox Equilibrium and Measurements of Potentials in pv the Aquatic Environment", in Equilibrium, Concepts in Naturd Water Systems, Advanced Chemistry Series, (67), p. 270-285, 1967 NEA (Nuclear Energy Agency), " Sorption, Modelling and Measurement for Nuclear Waste Disposal Studies", Summary of NEA Workshop held 6-7 June 1983 in Paris, 1983. NRC, " Nuclear Regulatory Commission, 10 CFR Part 60, Disposal of High-Level Radioactive Waste in Geologic Repositories", 1984. Whitfield, M., "Eh as an Operational Parameter in Estuarine Studies", in Limnol. Oceanogr., (14), 547-558, 1969. O 16 1 1
CERTIFICATE OF OFFICIAL REPORTER O This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS
.l SUBCOMMITTEE ON WASTE MANAGEMENT i
DOCKET NO.: PLACE: WASHINGTON, D. C. DATE: TUESDAY, JULY 22, 1986 were held as herein appears, and that this is the original
- transcript thereof for the file of the United States Nuclear Regulatory Commission.
(sigt k / ! (TYPED) [ ! MARY C. SIMONS / Official Reporter ACE-FEDERAL REPORTERS, INC. Reporter's Affiliation . O
. - . - _ _ . ~ , - . _ . _ _ _ _ _ _ _ _ _ - _ - _ . . _ _ _ . . . _ _ _ _ _ . _ . _ _ _ _ . _ . _ , . - _ . _ . _ _ _ - . _ _ _ _ _ _ _ . _ _ _ _ -
ss i O O O BRIEFING ON NRC'S REVIEW 0F DOE'S FINAL ENVIRONMENTAL ASSESSMENTS TO ACRS WASTE MANAGEMENT SUBCOM11TTEE July 22, 1986 Robert L. Jchnson 109/RJ/86/07/22 86/07/22
_______.._____._.i_- O O O ' i i l li INTRODUCTION r o OVERVIEW 0F DRAFT EA REVIEW i o REVIEW PLAN FOR FINAL EAS l o REVIEW PREPARATIONS FOR FINAL EA REVIEW l 0 CURRENT STATUS OF NRC FINAL EA REVIEW l i t i I i I i ! I I 1 3 86/07/22 109/RJ/86/07/22 t
O O O OVERVIEW OF DRAFT EA REVIEW i o ENVIRONMENTAL ASSESSMENTS (EAS) SUPPORT THE' SITE SELECTION PROCESSES AS REQUIRED BY I NUCLEAR WASTE POLICY ACT o DOE ISSUED NINE DRAFT EAS IN DECEMBER 1984 4 o DRAFT EA CONTENT l - SITE SELECTION PROCESS i - SITE INFORMATION AND DATA i - SITE CHARACTERIZATION ACTIVITIES AND EXPECTED EFFECTS
- REPOSITORY DESCRIPTION AND REGIONAL AND LOCAL EFFECTS
- SUITABILITY OF SITE IN TERMS OF GUIDELINES
- SITE COMPARISONS i
o SITES PREFERRED FOR CHAP.ACTERIZATION ]
- DEAF SMITH (TEXAS)
- HANFORD (WASHINGTON)
- YUCCA M00NTAlh (NEVADA)
] o OTHER SITES PROPOSED FOR NOMINATION I
- DAVIS CAYON (UTAH)
- RICHT0N DOME (MISSISSIPPI) i l
! 109/RJ/86/07/22 86/07/22 I
O O O
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Figure 1. Potentially acceptable sites for the first repository.
- e .. 1
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\ O. - O . i i 4 c. 1 i a i i i I L OVERVIEW OF DRAFT EA REVIEW (CONT.) i i o NRC REVIEWED AND ISSUED COMMENTS ON ALL NINE DRAFT EAS ON MARLH 1985 O NRC COMENTS FOR EACH DRAFT EA CONSISTED OF: 14 MAJOR COMENTS
- 100-200 DETAILED COMEhTS 4
I i t 1 j 109/RJ/86/07/22
- 66/07/22 l
j . . i O O O , i i i i i l OVERVIEW 0F DRAFT EA REVIEW (CONT.[ 4 1 I i o GENERAL CONCLUSIONS WERE:
- NO DISQUALIFYING CONDITI0h CLEARLY PRESENT AhD NO QUAI.IFYING CONDITION CLEARLY ABSENT l
- TYPES OF CONCERNS REPEATEDLY GBSERVED WERE:
- UNCERTAINTIES AND ALTERNATIVE INTERPRETATIONS NOT CONSIDERED i
I
- AVAILABLE INFORMATION NOT CONSIDERED
- - MAJOR COMMENTS (SEE TABLE) i i _
j 109/RJ/86/07/22 86/07/22 - i 1
O O O
SUMMARY
OF HAJOR COMMENTS BWIP NTS SALT HYDROLOGY e GROUNDWATER TRAVEL TlHE e GROUNDWATER 1 RAVEL TIME g GROUNDWATER TRAVEL-T e CilANGES IN HYDROLOGIC CONDITIONS e " FREE DRAINAGE" 0F Tile e FLOODINGOfSURfAGE; , o FLOODING Of SURFACE FACILITIES Il0ST ROCK FACILITIES . ,; e EFFECTS Of CLlHATIC CilANGE e HYDRAULIC GRADifMT.:r' o FLOODING Of SURFACE FACILITIES (UTAH) .;l v W ,.
! GE0 CHEMISTRY e GE0CllEMICAL ENVIRONMENT e GROUNDWATER CllEMISTRY e MINERAL STABIEITY : f :s e RETAR0All0N OF RADIONUCLIDES , RAD 10NUC8.IDE NOBIEITY'#I e HINERAL STABILITY yy/,
GE0 LOGY e, TEC10NIC STABILITY - e FAUL1 AClIVITY p FPACTURES AN0HALOUS './ e NATURAL RESOURCES e lECTONIC S1 ABILITY-VOICANISH/ ZONES AND STRUCTUS$L 3d flVDROTilERHAL ACTIVITY DISCONTINUITIES .;' ~ g DISSOLUTION ..,
, TECTONICS 4, DESIGN / ROCK e TillCKNESS OF Il0ST ROCK , HOST ROCK HETER 0 GENET HECHANICS e SilAFT CONSTRUCTION , RETRIEVABILITY e SHAFT SEALING .
WASTE PACKAGE o WASTE PACKAGE LIFEllHE o WASTE PACKAGC POSICLOSURE 9 WASTE PACKAGE PERFORMANCE PERFORMANCE .' OTHER e CONTROLLED AREA SIZE o flELD TESTING IN CANYONLANDSPARK(UTAN) GENERIC
, COMPARATIVE EVALUATION Of SITES-WEIGilTING OF FACTORS
l 4 O O O i l l DOE ISSUANCE OF FINAL EAS } o DOE REVISED DRAFT'EAS BASED ON OVER 20,000 COMMENTS f I o ONMhY28,1986 DOE: 1
- NOMINATED FIVE SITES: DAVIS CANYON, DEAF SMITH, HAHFORD, RICHTON DOME AND YUCCA MOUNTAIN 1
l
- RECOPMENDED THREE SITES FOR CHARACTERIZATION:
1 DEAF SMITH, HANFORD, YUCCA MOUNTAIN i
- ISSUED: ;
] j - FIVE FIrlAL EA5 ! - DECISION-AIDING METHODOLOGY DOCUMENT ;
- RECOMMENDATION DOCUMENT j
4 i i i 109/RJ/86/07/22 86/07/22 I
O O O i l REVIEW PLAN FOR FINAL EAS ) o PURPOSE i - PART OF ONGOING PRELICENSItiG CONSULTATION PROCESS j :- FINAL EAS GIVE NEW EVALUATIONS AND CURRENT OFFICIAL DOE CONCLUSIONS
- OPPORTUNITY FOR EARLY IDENTIFICATION OF POTEhTIAL LICENSING ISSUES
- INFORM COMMISSION OF ANY MAJOR CONCERNS WITH DOE RESPONSES TO COMMENTS OR NEW INFORMATION IN FINAL EAS.
- o OBJECTIVE
, 1 l - IDENTIFY MAJOR CONCERNS WITH DOE RESPONSES TO NRC MAJOR COMMEiTS
- IDENTIFY MAJOR CONCERNS WITH NEW DATA /INFORMATION l
; - IDENTIFY INCONSISTENCIES WITH THE SITING GUIDELINES l - IDENTIFY MAJOR CONCERNS WITH TECHNICAL INFORMATION SUPPORTING THE SITE COMPARISONS
- NO REVIEW OF SITE COMPARIS0N METHODCLOGY 109/RJ/86/07/22 86/07/22
^^
O O O I l l i i i REVIEW PLAN FOR FINAL EAS (CONT.) l j o RESULTS OF REVIEW l ! - MAJOR COMMENTS WILL BE SENT TO THE COMMISSION WITH RECOPEENDATION FOR ANY APPROPRIATE ! FOLLOWUP ACTION IF NEEDED
- MAJOR COMMENTS ALSO WILL BE TREATED AS OPEN ITEMS TO BE FOLLOWED UP WITH DOE ThROUGH OUR
] ; NORMAL PRELICENSING INTERACTIONS (TECHNICAL MEETINGS, LETTERS TO DOE, SCP REVIEW) i l l l-
- i i
109/RJ/86/07/22 86/07/22
'~~
! O O O l I ; REVIEW PLAN FOR FINAL EAS (CONT.) I o REVIEW ACTIVITIES AND SCHEDULE (SALT SITES) ! STEP I TECHNICAL REVIEW JUNE 23-JULY 28 l SCAN / READ FINAL EA REVIEW AND PREPARE COMMENTS, CH 1-6 REVIEW AND PREPARE COMMENTS, CH 7 and DECISION AIDING METHODOLOGY DOCUMENT STEP 2 QUALITY REVIEWS OF COMMENTS JULY 29-AUGUST 20 SECTION/ TECHNICAL QUALITY REVIEW PROJECT REVIEW MERGE C0MMENTS STEP 3 MANAGEMENT ASSURANCE REVIEWS AUGUST 14-SEPTEMBER 5 ! BRANCH CHIEF REVIEW DECISION. SUPPORT SYSTEM REVIEW DIVISION /0FFICE DIRECTOR REVIEW CONCURRENCE / REPRODUCTION 109/RJ/86/07/22 86/07/22
l O O O PREPARATION FOR FINAL EA REVIEW o REVIEWED SELECTED NEW OR REVISED FINAL EA REFERENCES WHICH CONTAINED SIGNI[ICANT DIFFERENT INFORMATION o REVIEWED' DRAFT EA COMMENTS FROM STATES, INDIAN TRIBES, AND OTHER FEDERAL ) AGENCIES TO IDENTIFY ANY MAJOR CONCERNS NRC HAD NOT IDENTIFIED o CONDUCTED TECHNICAL MEETINGS WITH DOE, STATES, AhD INDIAN TRIBES ON TECH-NICAL CONCERNS
- STRUCTURAL DISCONTINUITIES, DEAF SMITH SITE I
- WASTE PACKAGE /NEAR FIELD GEOCHEMISTRY, DEAF SMITH SITE I
i - EXPLORATORY SHAFT CONSTRUCTION, HANFORD SITE i i t F 109/RJ/86/07/22 86/07/22
i - , i O O O i ' j i i i l
, PREPARATIONS FOR FINAL EA REVIEW (CONT.)
o CONDUCTED DATA REVIEWS AND SITE VISITS i
- EXAMINATION OF C0P.E, DEAF SMITH SITE, PALO DURO BASIN j
- EXAMINATION OF FAULTS IN OUTCROP AND TRENCHES, YUCCA MOUNTAIN SITE
)l 1 1 l 109/RJ/86/07/22 86/07/22
, e v , -
= .
O O O CURRENT STATU5 OF NRC FINAL EA REVIEW o NRC STARTED ITS REVIEW ON JUNE 23, 1986 o COMPLETED THE TECHNICAL REVIEW AND FIRST DRAFT OF COMMENTS (STEP 1) o CURRENTLY BEGINNING QUALITY P.EVIEW 0F FIRST DRAFTS OF COMMENTS (STEP 2) o NOT IN POSITION NOW TO DISCUSS COMMENTS o PROPOSE A BRIEFING ON THE RESULTS OF OUR REVIEW AT THE NEXT SfSSION OF THE ACRS WASTE MANAGEMENT SUBCOMMITTEE 109/RJ/86/07/22 lE 86/07/22
~
i O i i I ! I BRIEFING ON THE YUCCA MOUNTAIN SITE i FOR THE . ACRS WASTE MANAGEMENT SUBCOMMITTEE I I i ! k'"e S14 stein . ! O JULY 22, 1986 i i i O
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O O O . SELECTED ISSUES RELATED TO THE YUCCA MOUNTAIN SITE O FAULT ACTIvlTY AND ITS SIGNIFICANCE 0 ORIGIN AND SIGNIFICANCE OF CALCITE-SILICA VEIN DEPOSITS n 0 ACCEPTABILITY OF CORE IN LICENSING 0 GROUNDWATER FLOW PATHS AND TRAVEL IIME O RETARDATION OF RADIONUCLIDES O ITEMS NEEDING RESOLUTION PRIOR TO EXPLORATORY SHAFT CONSTRUCTION O SUSCEPTIBILITY OF WASTE PACKAGE MATERI ALS TO CORROSION
O MAJOR MILESTONES IN THE NNWSI PROJECT PROGRAM 0 RELEASE OF FINAL EA--JUNE, 1986 0 RELEASE OF SITE CHARACTERIZATION PLAN--DECEMBER, 1986 0 START CONSTRUCTION OF EXPLORATORY SHAFT--MAY, 1987 O i l t
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1 120 1 AFTERNOON SESSION 2 (1:00 p.m.) 3 DR. MOELLER: The meeting will come to order. 4 We are ready to begin our af ternoon session, continuing on 5 the subject of High Level Radioactive Waste. 6 We are going to take the following sequence in 7 treating the various items, which is diff erent than shown on 8 the printed agenda. 9 The first item we are going to cover is the 10 federally f unded R & D Center. The second item will be the 11 briefing on the Nevada Test Site and, thirdly, the Division 12 of Waste Management's Five-Year Plan. K/ 13 Then we will conclude the afternoon with a 14 status report on the NRC review of doe's final environmental 15 assessments. 16 John Linehan will be our coordinator for the 17 NRC presentations, and I call upon you, John. 18 MR. LINEHAN: The presentation on the FFRDC is 19 going to be given by Paula Wade, who is in the Policy and 20 Control Branch of the Division of Waste Management. 21 Paula.
- 22 MS. WADE
- What I would like to discuss today l
23 is the purpose of the FFRDC and where we currently stand, 1 f 24 As most of you might know, we have a paper 1 25 currently bef ore the Commission requesting approval to ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
V 121 7_ 1 contract for an FFRDC, and the FFRDC would provide technical 2 assistance and research to NRC throughout the duration of 3 the NWPA program. It would cover all waste management areas 4 of the NWPA. 5 The NWPA program _ manager, who is Mr. Davis, has 6 determined that contractor conflict of interest with the 7 NWPA program is unacceptable and that steps must be taken 8 early on to assure that NRC's licensing decisions are fully 9 independent and free from conflict of interest. 10 Our current situation is that most of our 11 technical assistance and research is obtained through the 12 DOE laboratories and private contractors, most of whom also 's 13 work for DOE. 14 The agency has taken some interim measures to 15 avoid conflict of interest by requiring separate management 16 schemes within the contractor organizations. For example, 17 the group working for NRC can't be talking with the group 18 working for DOE. But that is seen only as an interim 19 measure. 20 There is nothing that we can do to preclude 1 21 contractors from leaving NRC altogether and going to work 22 for DOE, whose budget is significantly larger than ours, and 23 the same situations applies to the states and tribes who are 24 also parties to NRC licensing hearings. 25 So because of this problem the long-term ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
122 _ 1 continuity of our technical program is threatened. So in O 2 order to both preclude the conflict of interest from arising 3 and to maintain long-term continuity throughout the duration 4 of our program, the staff is recommending that an FFRDC be 5 established and solely sponsored by the NRC. 6 The nature of an FFRDC is governed by OMB 7 guidelines which are future output out through the Office of 8 Federal Procurement Policy. 9 According to OMB, before an FFRDC is put in 10 place the agency head must make a determination that the 11 existing resources cannot suffice because of the need for 12 long-term continuity or conflict of interest problems. 13 Once an FFRDC is selected and put in place, it 14 does not have to be recompeted at the end of every five-year 15 interval, which is the case with current contractors. 16 Another special requirement'for our FFRDC is 17 that it be a not-for-profit entity, free from any control by 18 a profit-seeking concern. 19 We have ref usal right for the FFRDC to perform 20 work f or any other entity. 21 DR. KERR: Excuse me. You say it didn' t have . 22 to be re-something or other in the five years. 23 MS. WADE: Yes. It does not have to be
/ 24 recompeted, but the agency does have to perf orm a --
25 DR. KERR: What does recompete mean? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
123
- 1 MS. WADE: It does not have to go out in the
(/ 2 Commerce Business Daily requesting proposals. 3 DR. KERR: Thank you. 4 DR. MOELLER: Well, what leverage do you have, 5 then, to keep them on their toes if they are no longer 6 competing? 7 , MS. WADE: What we are planning to do when we 8 issue an RFP, we are ask the offerors to come to us and tell 9 us what kind of incentives ' arrangements you will have, what 10 kind of controls you will have to maintain responsiveness in 11 a noncompetitive environment. 12 We have been talkirg to other agencies who have 7 (/ 13 FFRDC and also some of the FFRDC, themselves, and we have 14 found they have some controls to put in place to maintain 15 responsiv eness . 16 DR. KERR: Is the principal purpose of this to 17 avoid conflict of interest, the only purpose? 18 MS. WADE: Right. With an FFRDC you 19 essentially have a captive contractor and you can put 20 constraints on the contractor to not perform work with any 21 other party in the hearing process which you can't do with 22 others. 23 DR. MOELL ER: Your goals go far beyond the 24 conflict of interest. 25 MS. WADE: Right, long-term continuity goes ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
124 zm 1 hand in hand. ( ) v 2 DR. MO ELL ER: Right, long-term resource and so 3 forth. 4 MS. WADE: Right. One of the primary roles 5 will be to serve as our primary contractor witness during 6 the licensing hearings. 7 We are essentially building up expertise in all 8 the key areas of waste management. They will carry us 9 through to the licensing process and be our expert 10 contractor witness. 11 DR. MOELLER: Did these people who responded to 12 the announcement realize that the group that does this has ('/ (- 13 to be not-for-profit? 14 MS. WADE: They are all aware of ti. sut 15 there are some profit seeking concerns that have still 16 expressed an interest. 17 DR. MOELLER: Right. 18 MS. WADE: The burden is on them to prove to us 19 they can still establish a not-f or-profit entity that is 20 autonomous. 21 DR. PARRY: The point you made about not being 22 required to recompete does not mean, though, that you can't 23 kick them out if they fail. 24 MS. WADE: One of the things we had in mind, 25 keeping with that concern, is when we set up the contract we ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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125 1 would have, what we are proposing to do is to have a U 2 two-year contract with price options for the remaining three 3 years. 4 If the contractor is not perf orming well, you 5 know, it's up to us to keep them or not keep them. 6 DR. PARRY: Right. 7 MS. WADE: At the end of five years we have to 8 do a comprehensive review on the continuing need for the 9 FFRDC and its role and mission, et cetera. 10 So we still have that leverage over him if he 11 is not being responsive. 12 DR. REMICK: To what extent would these people (' , ks' 13 get involved in policy issues? 14 MS. WADE: The way we have the statement of 15 work written, we have six major areas we want them to be 16 involved in. We have the geologic setting area, engineered 17 barrier system and most of the technical areas. 18 But we also have an area called systems 19 engineering. That will be one of their key roles, to do 20 overall systems engineering of the waste management program. 21 We also have a special projects and analytical 22 evaluations program in which case they will get involved in 23 some of the policy analyses, legal, institutional types 24 analyses. 25 DR. REMICK: In your work statement you don't l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
126 1 say much about the social, political, economic. I ( 2 MS. WADE: That's right, we have since revised 3 it. 4 DR. REMICK: Have you? 5 MS. WADE: Yes. What you all had was the draft 6 solicitation package that was made available to the public 7 for comment. We have since received comments. That was one j 8 of the comments that were throughout. We are in the process 9 of revising it right now. 10 DR. REMICK: Yes. 11 MS. WADE: When we do issue the package, what 12 you saw was an overall statement of work which we. refer to 3 13 as the umbrella statement of work. 14 One of the additional things that will go along 15 with the RFP is individual statements of work for each'of. 16 the six areas which will go into more detail as the types of 17 work we envision, specifically we will be detailing ' the 18 five-year obj ectives of our program, and then what the. 19 center will be accomplishing within the first year. And 20 each year those would be updated. l 21 DR. PARRY: Would you expect, f or instance, f or 22 this group to provide, perhaps, the draf t for the SCA's? 23 MS. WADE: To perf orm a review of it? f 24 DR. PARRY: Well, no, or to prepare drafts for l 25 the staff to finalize. ! ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
127 s 1 MS. WADE: Well, what we envision is that they / 1 \~J 2 would most likely be involved in the review. But they 3 provide their recommendations to the staff. The staff is 4 who actually writes the review. They make the decisions. 5 The center in most cases will be providing 6 recommendations to NRC. 7 DR. PARRY: Weston, for instance, for DOE does 8 the alternative. They actually prepare draf ts. 9 MS. WADE: Yes. 3 10 DR. PARRY: I am just clarifying, that is all. 11 MS. WADE: No, the way we envision is the staff 12 will maintain its responsibility in developing reports, k/ 13 whatever. 14 DR. MOELLER: We probably should let you 15 continue, you know, and tell the story. 16 You have already mentioned, though, one thing 17 that I didn't understand. What is the purpose of the 18 center? You know, you have -- 19 I thought we were going to talk and when I read 20 the material I thought I was going to talk about a federally 21 funded R & D center. 22 MS. WADE: Yes. 23 DR. MOELLER: Maybe I am using the wrong word. 24 Then when I looked at it it's not even called that, you 25 know. ACE PEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
128
- 1 There is something else that I guess is the t
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2 umbrella group above the center? 3 MS. WADE: The center is called the Center for 4 Nuclear Waste Regulatory Analysis. 5 DR. MOELLER: Then the Fed thing is called a 6 center, also. 7 MS. WADE: Okay, let me just backtrack. An 8 FFRDC is a group that is established by a government agency, 9 it's a contractor, who is put in place for a long term 10 period. And it's put in place to meet requirements that 11 your standard contractors cannot meet. Again, our 12 requirements are long-term continuity and conflict of (_/ 13 interest. 14 But the FFRDC, itself, that is the group, and 15 the group's title is the Center for Nuclear Waste Regulatory 16 Analysis, something like that. 17 Let me just mention its role. There are sort 18 of three phases to its role. One, they will provide 19 technical assistance and research to NRC and all of the key, 20 in all of the key areas that we need to be involved in to 21 reach our licensing decisions. 22 The second role is they will provide systems 23 engineering support to NRC, which means that they will have L 24 a look at the entire program and will make recommendations 25 to us regarding any integration of interfacing, anything ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
129 1 involving systems engineering. 7-U 2 Right now our approach is piecemeal. We have 3 contractors doing a lot of individual pieces but there is
\
4 really nobody to pull the whole thing together. So they 5 will be providing systems engineering role to us, or support 6 to us. 7 Then probably one of the more important roles 8 is-they will be the expert, the contractor expert witness i . 9 during the NRC licensing hearings. So they have to develop 10 and sustain the expertise in each of the key disciplines 11 over the long-term. 4 12 DR. MOELLER: Okay. 13 MS. WADE: Does that does that answer your 14 question? 15 DR. MOELLER: Yes, that is fine. 16 MS. WADE: I will just move on to the current 17 status of it. 18 DR. REMICK: Before you leave that, I have what 19 I consider a major suggestion. 20 MS. WADE: Okay. 21 DR. REMICK: The CNRWA, an acronym you can't 22 say, if you put the Center at the end, it's NRWAC, which 23 makes it very easy to ref er to. 24 MS. WADE: One of the things, we came across 25 that. A lot of people have told us that. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
4 130 1 One of the other ways of solving the problem is 2 we were just referring to it as the center. 3 DR. REMICK: Yes. 4 MS. WADE: The staff initially -- 5 DR. STEINDLER: There are a thousand centers in 6 this country. Every time you turn around there is a center. 7 MS. WADE: Okay,- the staff initially sought 8 permission approval to establish the FFRDC last December, 9 and the Commission gave its approval in February to publish 10 a notice of intent in the Federal Register and Commerce 11 Business Daily. 12 The notice would'give a summary of no we are 13 doing and why, and it would also request public comments. 14 Luring March through June, three notices were 15 published and we also made available to the public our draf t 16 solicitation package. 17 So we not only asked for comments on the 18 general concept of the FFRDC, but we also requested comments 19 on some of the specific provisions of the contract. 20 We received comments f rom about 21 different 21 organizations. It was a broad range. We got comments from 22 not-for-profit organizations, profit seeking organizations, 23 consultants. We got a DOE J ab and several universities. 24 Nineteen of the 21 commenters indicated an 25 interest in competing for the FFRDC and overwhelming support ACE FEDERAL REPOR.TERS, INC. Washington, D.C. (202) 347-3700
131 1 for the concept of it. O 2 The other two commenters were the DOE lab and 3 one of the -- a small NRC contractor, and they sort of 4 questioned the concept because of the cost effectiveness and 5 reasons like that. 4 6 DR. REMICK: If I recall one of those national 7 laboratories is somewhere in the Midwest there, Marty, made 8 a comment that universities should not be considered because 9 professors come and go. 10 I thought that was an interesting comment. 11 DR. STEINDLER: If there was a response from 12 Argonne, that violates the ground rules that we were given 13 in no uncertain terms. 14 DR. REMICK: Is that right? 15 DR. STEINDLER: Yes, DOE explicitly told us we 16 couldn't respond. 17 DR. REMICK: There was a response from Argonne 18 wasn't there? 19 MS. WADE: We did not get. 20 We did get one from Argonne. 21 DR. STEINDLER: It was not within the approval ! 22 chain. 23 MS. WADE: At the present time we are awaiting 24 a Commission decision. We have asked for one by the end of 25 July and at the same time are finalizing cur solicitation l l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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132 1 package. O 2 We hope we can release it soon af ter the 3 Commission makes their decision, if they approve it. 4 DR. MOELLER: Ready for questions and comments? 5 MS. WADE: I am ready. I have been prepped 6 already. 7 DR. MOELLER: It seemed to me, just to offer 8 some comments, that the package you are putting out or 9 proposing would, for example, be totally unacceptable to the t 10 university where I am employed. They would reject this 11 outright. 12 And the reason they would would be that you 13 state that you will review the reports and have input. 14 DR. REMICK: Approve. 4 15 DR. MOELLER: Yes, approve the reports. Our 16 university says we will write whatever we want to and you 17 shall not, you know, constrain us or hold us back. 18 And then you stated that all speeches must be i 19 approved, and that you will not even pay to support journal l l 20 publications of the results of the work, which that, I don't l 21 know that that would be unacceptable to my university, but 22 that seems negative. ! 23 And then I also didn't understand what happens, 24 like on page 9 of one of the documents I read it said that 25 the NRC staff of course will comment on the reports in l i ACE FEDERAL REPORTERS, INC.
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- 133 1 draft.
2 What if you comment and the FFRDC refuses to 3 accept your comment? 4 MS. WADE: What we do in a case like that, when 5 they get ready to publish the report the staff has so many 6 days to review and comment. 7 If that kind of situation happens, I would 8 think, and somebody correct me if I am wrong, but that they 9 would still publish the report but NRC's comments would be i 10 appended to it. 11 DR. MOELLER: I see. 12 MS. WADE: Now, on some of these others, I
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(/ 13 would have to say we did take a lot of the comments into 14 account. 15 In fact, we tried to accommodate as many i 16 comments as we could. There were somewhere we had to really 17 lighten up on. One of them is the prior approval.= 18 , DR. MOELL ER: Yes. 19 MS. WADE: I think we changed it. I can't 20 think offhand exactly the way the wording reads but 21 something to the effect that what we are interested in is 22 release of -- prior release o ' predecisional material : so 23 we changed it to something like 30-day review and if you f 24 don't hear from us, that is fine. 25 But we will inform you if there is ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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1 134 f_s 1 predecisional content that should not be released. U 2 The same way -- there were some other comments. 3 Prior review and approval of the parent organizations' new 4 contracts. 5 DR. REMICK: That was very unrealistic. 6 MS. WADE: Yes. 7 DR. MOELLER: You have there that they can't 8 change the project manager and if any employee leaves they 9 must be replaced with one of equivalent quality and so 10 forth, 11 MS. WADE: Yes. 12 DR. MOELLER: Is this standard? 13 MS. WADE: Those are in quite a bit of our 14 contracts. 15 DR. STEINDLER: Those contracts are generally, 16 well, they certainly last f or one year, period. They are 17 subj ect to renewal, but they last for one year. 18 There is a great deal of difference between i 19 being willing to accept a research contract for a fairly 20 modest period of time. l 21 DR. MO ELLER: Yes. 22 DR. STEINDLER: And the kind of thing they are 23 talking about which is essentially -- l MS. WADE: What we are trying to preclude is f 24 l 25 somebody coming in with a fantastic proposal that has the ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
- 1 135 i l
1 1 most high quality people in the country and then six months O 2 later they all sort of go by the wayside and you get 3 mediocre -- 4 DR. KERR: Well, the proposal assumes that the 5 organization can specify all the people who will be , 6 involved? 7 MS. WADE: At least the key people, at least 8 the key managers and the key people. 9 DR. MOELLER: Then you require monthly reports. 10 I would think they would keep a couple people busy just 5 11 writing those. 12 MS. WADE: We have lightened up on that, too. x/ 13 In fact, any reporting requirements will be specified in any 14 of the individual task statements that go out. 15 DR. MOELLER: When you say you have lightened 16 up, where can we see the lightened up version, or is it , 17 available yet? 18 MS. WADE: We have got a solicitation package 19 that we are still working on. I don't even think we have it 20 in typing, yet. 1 21 DR. REMICK: Going back, you indicate you have 22 changed some of the, I believe the corporate requirements. 23 Some of those were that corporate officers, fully backed 24 position of the center and so f orth. 25 Is that some of the things you have changed, ACE FEDERAL REPORTERS,
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,- 1 which is unrealistic in a large organization, that board of
(_3) 2 trustees would know the day to day positions. 3 MS._ WADE: Right, we got a lot of comments on 4 that. What what we are considering doing is to change it to 5 the center management. 6 DR. STEINDLER: Let me make a couple comments 7 if you don't mind. 8 It struck me listening to you and reading this 9 pile of paper that all one needs is to change the label on 10 this group of experts and you can replace the entire Waste 11 Management staff of the NRC, because except for certain 12 policy related issues, which surely you can get these folks 13 to make, the need for the NRC staff structure now has 14 disappeared. 15 Is that, aside from being unfair, is that an 16 overstatement of the case, too drastic? 17 MS. WADE: I hope so. The way FFRDC generally 18 work with the other agencies, it's a partnership 19 arrangement. 20 DR. STEINDLER: How many are there besides the 21 one on electronics? 22 MS. WADE: About 35 in existence. Midre is 23 one, Aerospace, Jet Propulsion labs, those kinds. f 24 DR. STEINDLER: I see. 25 MS. WADE: What we envision for the FFRDC is, 1 i f_ _ ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
137 s 1 they have got to develop the expertise. They have got to be d 2 in it as much as we are but they provide recommendations to 3 us. But the staff still retains the responsibility f or the 4 program. 5 But instead of having, you know, 30 different 6 contractors doing 30 different pieces, you have got one 7 group responsible for the entire program. 8 DR. STEINDLER: How does the staff intend to 9 identify the quality of the output of this captive group of 10 experts? 11 How would you recognize nonsense if you saw it? 12 MS. WADE: Nell, I guess it's just like any 13 other contract, but we are wcrking on performance evaluation 14 procedures which would evaluate them on the quality and 15 evaluating anybody on quality is a judgmental type -- 16 DR. STEINDLER: Yes, but how does the staff 17 intend to do that, what kind of mechanism do you see putting 18 in place to make sure that when you get up in f ront of the 19 hearing board, the staff's position is_at least defensible 20 on a technical basis? l l 21 MS. WADE: I think it's just the same that we 22 could do with any other contractor. We are just going to 23 have to have close controls, evaluate them at periodic
/ 24 times.
O
- 25 DR. KERR
- What you do with other contractors i
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138 1 frequently is to get another contractor to review the work 2 of the first. 3 MS. WADE: I am sorry? 4 DR. KERR: What is done currently by NRC with a 5 contractor is to get another contractor to review the work 6 of the first one. Is that what you have in mind? 7 MS. WADE: If I am interpreting your question 8 in the right way, the FFRDC will be involved in reviewing 9 other contractor's work if there are other contractors. 10 DR. KERR: No, but -- 11 MS. WADE: There might also be peer review 12 process, quality assurance --
, 13 DR. KERR: My-question was, will you get some 14 other agency, entity, laboratory, contractor, to review the 15 work of the FFRDC as a method of quality control. That was 16 the question.
17 MR. BUNTING: I am Joe Bunting, Branch Chief. 18 The answer of your question, sir, is that is 19 the role of the staff. Staff must maintain sufficient 20 expertise on staff to be able to make that will have a 21 judgment by how well the contractor is doing. 22 If we can't then we have in f act turned over 23 our responsibility to the contractor. We can' t wind up f 24 being a rubber stamp. 25 That is our responsibility now when we contract ACE INC. FEDERAL REPORTERS,,_._.._.- Washington, D.C. (202) 347-3700
139 1 out with individual contractors, is to be able to review gg
%)
2 what they tell us, and make the judgmental decision, does it 3 make sense, is it nonsense, to be able to develop the 6 4 rationale that supports their recommendation. 5 If we don't maintain that on staff then we have 6 turned over the entire program to the contractor. 7 DR. STEINDLER: I understand. I guess what I 8 am looking for is if in fact you are going to focus all your 9 technical expertise in a single contractor, the impression I 10 have from the discussion and f rom what I have read is that 11 the staff, itself, will be less than technically competent 12 in those areas. A (/ 13 MR. BUNTING: You should not read anything in 14 that contract that relieves the responsibility of the staff. 15 DR. STEINDLER: Then what you then see is a 16 duplication of the technical competence of the staff? 17 MR. BUNTING: Just like today, we have 18 duplication. We are 50/50. What we have told the 19 Commission is we can't have staff to handle everything. 20 At the same time, the Commission has told us 21 don't parcel everything out to the contractors. 22 So our technical program is based on 50 percent 23 each, roughly. 24 DR. KERR: So your staff will do about 50 25 percent of the research? ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
140-1 MR. BUNTIBG: Our staff is supposed to be O 2 responsible for 50 percent of our technical program. 3 DR. KERR: That was not the question I asked. 4 I was asking whether they would do 50 percent of the 5 research? 6 MR. BUNTING: I don't see the staff anywhcre 7 here doing research, period. 8 DR. KERR: I don't, either. And generally, if 9 one is to evaluate research being done in a new area, as 10 this one is, one needs to be involved in it on almost a day 11 to day basis in order to evaluate it. 12 MR. BUNTING: Well, I believe that this 13 approach will allow our staff more time to become involved 14 in it. Right now-- 15 DR. KERR:' I don't know what you mean by become 16 involved in research if they are not doing research. How 17 does one become involved in it? 18 MR. BUNTING : Right now a lot of the staff is 19 put being a lot of their time into the administrative 20 process of constantly renewing contracts. 21 DR. KERR: Yes. 22 MR. BUNTING: Their time is taken up with 23 administrative burden. DR. KERR: f 24 Yes. 25 MR. BUNTING: These contracts turn over in two, ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
141 g_s 1 three years. In many cases, new procurement. I don't know 2 how many of you have gone through a competitive procurement, 3 it's horrendous. 4 DR. KERR: I understand the difficulty. What I 5 am looking -- 6 MR. BUNTING: What we propose is to be able to 7 do it once, give them time to look at what the contractor is 8 doing. We envision down the road having on-site exchange of 9 staff between this center and the agency. 10 Now, that approach has been used by Aerospace 11 in the Air Force and has worked very well. I haven't gotten 12 the Commission to buy off on that, but at least that is my 13 concept in following things that have proven effective in 14 other arrangements between the sponsor and the FFRDC. 15 So to that extent 6 hey could become involved in 16 research which they are not now doing. 17 DR. STEINDLER: If you have, pr esumably, you 18 are looking at funding for this agency or this group, 19 center, f or prolonged periods, if you have the kind of funds 20 that apparently are necessary to function in this center, 21 why is it that you simply do not increase the magnitude of 22 your staff and have the NRC employees, NRC staff carry out 23 that same f unction? 24 MR. BUNTING: I will leave that to the , 25 policymakers that decide how many staff you can afford to go ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
142 g_s 1 down to the Congress and suppert each year. You can expect (-) 2 s V- a little bit of variation of that. 3 As you understand, when the government hires 4 people, you have got them for lif e. Now, that doesn't say 5 we expect to have an up and down in the contractor, either. 6 That is going to be one of our, I believe, 7 toughest problems. That is how to maintain stability at the 8 contractor. So at the moment we are proposing to contract 9 f or less than what we really think we need and to force a 10 scramble for those scarce resources and try not to have this 11 up and down. 12 Now, I can't answer your question about why not 13 put it all into the staff. Personally, my own evaluation is I 14 it isn' t very ef f ective, it isn't very practical. You must 15 realize of course that we have a high turnover rate right 16 now. 17 DR. STEINDLER: I thought you had them for 18 life? 19 MR. BUNTING: Beg pardon? 20 DR. STEINDLER: I thought you said you had them 21 for life. 22 MR. BUNTING: No, staff. 23 DR. STEINDLER: Yes. fj> 24 MR. BUNTING: We have a high turnover rate in 25 staff. It's as to when they want to leave as to when they l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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,- 1 le av e. About you if you look at past performance of the %.)
2 division we are running somewhere around 18 to 20 percent. 3 We have difficulties competing with the salaries of the 4 outside world. 5 Now you can look at all the literature 6 supporting an FFRDC, and, look at Mr. Packard's report that 7 was given to the president. He sites that as a prime 3 example. 9 It doesn' t j ustify why we can' t do it, but it 10 does reflect the facts of life as they exist today and 11 limitation on federal pay. 12 DR. MOELLER: Don? O (/ 13 MR. ORTH: I sort of wonder where you expect to 14 be operating. That may be a premature question, but 15 operating in the spectrum of management and independence is 16 that establishments can have, the two extremes as an example 17 being, one, hey, I need advice on the thing. Go off and get 18 all the information I need. 19 The other being complete micro management where 20 people in your staff are basically assigned to sections in 21 the other one and they are on a day by day, telling them 22 what to do. 23 So these are zero to 1, if you will. f 24 MR. BUNTING : Yes. 25 MR. ORTH: How do you expect to operate? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
144 1 MR. BUNTING : We tried again to take a page O 2 f rom the air force experience, particularly Aerospace. We 3 were very intrigued by the requirements in the Aerospace 4 contract in which the center's. management is called upon at 5 each launch, or every phase of the mission, particularly the 6 lawn chest, to stand up and take a corporate position that 7 they have managed the risks. 8 They even have a provision in there that if 9 you, the FFRDC were to come to me as a project manager and 10 give me advice that I chose not to follow, then if you 11 thought that that was going to be so significant it would 12 get in the way of your corporate position of being able to 13 support the launch, you have the requirement to move that up 14 to your boss and he comes to my boss. That gets escalateed 15 up to a position point. 16 We intend to use that kind of a same approach. 17 We haven't specified it but we have asked the FFRDC to 18 propose to us exactly the procedure to address that 19 question. l 20 MR. ORTH: All right. 21 DR. MOELLER: You mentioned earlier that 22 perhaps, or from your point of view you would like to see 23 the opportunity for NRC staff to go out and work at the 24 FFRDC for a period of a year, maybe. 25 MR. BUNTING : Right. \ l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
l L 145 7, 1 DR. MOELLER: And come back. N' 2 Will members of the FFRDC come up and work at 3 headquarters? 4 MR. BUNTING: Yes. 5 DR. MOELLER: I think that is -- 6 MR. BUNTING: We want to have an exchange. 7 DR. MOELLER:, Swell. 8 MR. BUNTING: That is,the way the Air Force 9 does it. Tnere are some contractual requirements. The 10 amount of space you give them has to be equal to the space 11 they give you. Those kinds of things have to be arranged. 12 But it's been done before. 13 DR. MOELLER: Sure. Well, that is good. 14 MR. BUNTING: It's worked well, and I believe 15 it will work well here. 16 DR. STEINDLER: Given that Davis has determined 17 there is a conflict of interest among, well, I guess among 18 some the contractors, has that issue ever been spelled out? 19 I read the SECY -- 20 MR. BUMTING: Yes, it was spelled out in the 21 Commission paper last December. 22 DR. STEINDLER: Last December. 85-388? 23 MS. WADE: Right. 24 DR. STEINDLER: I looked at that and thought it 25 was one of the weakest arguments I had ever heard, and that ACE FEDERAL REPORTERS, INC. . Washington, D.C. (202) 347-3700
146 g- 1 has been an argument that has come up in front of this LI 2 subcommittee almost from day one. 3 Is there someplace a f airly clear statement as 4 to what constitutes a conflict of interest and what 5 constitutes an unacceptable conflict? 6 MR. BUNTING: All you can do is go back. There 7 are two statements on the Commission -- two policy 8 statements on conflict of interest. 9 They have to do more with the contractual 10 arrangement of conflict of interest, which is unfair 11 competitive advantage. 12 DR. STEINDLER: Which is not an issue here. 13 MR. BUNTING : Which is not what we are talking 14 about here I think motivation for bias. One of the 15 arguments we had in the paper, you may have thought it was 16 weak, you have to understand. Conflict of interest is much 17 like a beauty contest, in that it resides in the eye of the 18 beholder. 19 Mr. Davis has decided he does not want that to 20 be a potential issue at the time of licensing. 21 We went to school on a case included in the 8 22 paper on the Long Island Lighting hearing in which a 23 consultant who was put on the stand to testify for NRC was
. 24 also shown to have done work for other utilities, not even 25 Long Island Lighting. And that was viewed by the hearing ACE FEDERAL REPORTERS, INC.
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147 1 board as being a conflict of interest. O 2 Whether you agree with that or not or think it 3 is wrong or week weak, we have to deal with that. So we do 4 not wish it to become an issue. We are trying to take the 5 steps now to make sure that is not an issue that prolongs 6 this hearing. 7 DR. STEINDLER: As I recall the hearing board 8 didn't say it was a conflict of question. 9 MR. BUNTING: They called a question on it. 10 DR. STEINDLER: And on that basis, my view is 11 that this is an unworkable scheme. I don't think you can 12 provide for a 20-year contract for a series of experts that 13 you refuse to let publish. 14 An expert who is basically out of the research 15 business and out of contact with the field for any length of 16 time becomes a non-expert pretty quickly. 17 That is certainly what I see here. I haven't 18 read the revised version. 19 MS. WADE: You are saying we refuse to let them 20 publish. 21 DR. STEINDLER: That is not the case. 22 MS. WADE: Not at all. 23 DR. STEINDLER: You do not support their f 24 publication? 25 MS. WADE: No. I l l l ACE TEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
148 1 MR. BUNTING : I don't believe we addressed O 2 that. We said-- 3 DR. STEINDLER: You sure did.
, 4 DR. MOELLER: Yes, you did, at least in what we 5 were given. What we are thinking of particularly are page 6 charges. A journal today will charge an author, oh, a 7 typical number, $80 a page. If you had an 8 or 10-page 8 article you are talking 500 to $1,000.
9 The authors, again, I am speaking for myself, J 10 unless a contractor will pay for it, I am really hampered in 11 publishing. 12 MR. BUNTING: That is a boilerplate clause I 13 didn't want to have in here. I don't think it's there at 14 the moment. 15 Our only interest in controlling publication 16 was to respond to the commission's concerns that matters 17 that were before them for decision were not published in i ! 18 advance of their decision. 19 So the only reason we would have to withhold l 20 publication would be something on predecision. I i 21 DR. REMICK: Are you defining predecisional in l 22 the follow on, because that is a pretty loose term that we 23 around the table might understand but in general people 24 don't understand it. 25 MR. BUNTING: No, I am using the term where if _ __ ACE PEDERAL REPORTERS, INC. Washington, _ __ _ D.C. (202) 347 _._____. ________ _-3700 . _ _ _ _ _
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,- 1 I tell you it is predecisional I should be able to tell you 2 the event that will release that document.
3 DR. REMICK: When you send out the RFP, you 4 want an explanation of what you mean. 5 MR. BUNTING : W'e do. We have. 6 DR. REMICK: All right. 7 MR. BUNTING : We have told them our only reason 8 for withholding would be predecision. 9 We have also tried to put in a statement where 10 we encourage publication of volumes. I 11 DR. MOELLER: See, in what we were given, what 12 Marty and I are siteing is a statement of work. I don't see
/O
(_/ 13 a date on it. 14 But in section 12.0 on Technical Presentations 15 and Publications it says, "The Center shall prior to release 16 outside the center's organization obtain the NMSS project 17 manager's approval of final drafts of any proposed speeches, 18 journal articles, press releases, et cetera. 19 " Costs for actions associated with these 20 communications," meaning to me, page charges for a journal 21 publication, "are beyond the scope of this contract unless 22 specifically approved by the NMSS proj ect manager. " 23 So we interpreted it as making it very 24 difficult for the person involved. , 25 MR. BUNTING : No. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
-150 1 MS. . WADE: But what we are doing in the RFP I
L 2 that is about to go out is that we have worded it such that 3 our only concern here is predecisional content. If they 1 4 wanted to publish something, we would at least tell them l 5 what sections are predecisional and at what time that can be 6 published. 7 MR. BUNTING: You have the choice of publishing 8 everything except that part that is predecisional. 9 DR. STEINDLER: Are you going to support that I 10 kind of activity?
; 11 MR. BUNTING : Yes, we will be glad to give you, i
,' 12 we have a matrix in which we listed all the commenters I k/ 13 believe across the page end all the individual commentc down 14 the page. 15 on the right-hand side we gave you a little
- 9 16 score sheet like where we are going to accept this comment 17 or where we are going to change it.
18 For the most part we have incorporated most of . 19 the comments and recommendations we got, which I thought was 20 the first time this agency had done this kind of thing and I 21 thought it was -- 22 DR. MO ELLER: Well, and some other things that, i l 23 you know, stood out like red flags when I read it. f 24 In section 10.0 it says, "If the center ! 25 proposes to verify less than 100 percent of all computations l t ACE FEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
151 s 1 and mathematical equations and derivations, the center must 2 first obtain written approval from NMSS." 3 Then up here, if you -- in all reports, "In all 4 reports, including numerical -- which do not contain 5 numerical analyses must be reviewed by the center's 6 management and approved with two signatures." 7 Is that still in there? 8 MR. BUNTING: No. 9 DR. MOELLER: Is that the way you operate? 10 MR. BUNTING: What you are reading there is in 11 many of the existing contracts. Those are standard boiler 12 plates we have thrown in there. I s/ 13 DR. MOELLER: I see. 14 MR. BUNTING: Those have been revised based on 15 comments we have received. 16 DR. MOELLER: I am very pleased, I am sure we 17 all are, to hear you are responding. 18 I was fearf ul that you might not be permitted 19 to respond to the criticisms. 20 MR. BUNTING: No. 21 MR. CARTER: That would essentially close the 22 door just about to all universities f rom participating. 23 MR. BUNTING : We have tried to go to heart on . 24 he is these comments and tried to get the widest and the 25 most response we can out of this. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
152 1 We want this to really be a true competition (,,) 2 because we would like to pick the best f rom the field of the 3 best. 4 DR. REMICK: Have you given consideration to 5 some of the detailed conflict of interest questions, like 6 there might be somebody now or in the past working on DOE 7 high level work who is willing to commit to the NRC. Is 8 that permissible? 9 MR. BUNTING : Yes. 10 DR. REMICK: A transition period. Or is that 11 going to preclude those? 12 MR. BUNTING : Yes, in talking to the lawyers 13 these things have to be done on a case by case basis. 14 By the way, we have also restricted the 15 information we are asking on that, also. But the key is you 16 can't put either an organization or individual in the j 17 position where he is reviewing for us work he has 18 participated on or helped on for the applicant. That 19 becomes the test. 20 DR. REMICK: That is a reasonable position. 21 MR. BUNTING : That doesn't say that he could 22 not work at the center if he worked for DOE, let's say, on 23 something in high level waste. It just says the center 24 can't use him in reviewing that work for us. 25 DR. MOELLER: Well, I personally und I speak ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
153 4-j 1 only f or myself, obviously I am not in f ull agreement with LO 2 the rest of'the subcommittee, but it seems to me.to be l 3 potentially an exciting opportunity. 4 In terms of the conflict of interest the 1 ' 5 subcommittee has questions, we have talked to Browning any 6 number of times, because we really didn't understand .the i
, 7- depth of his concern.
8 DR. STEINDLER: It's more important than that, j 9 Dade. I have yet to see a f airly clear-cut spelling out of 10 just what it is that NRC considers to be conflict of l 11 interest. , f 12 MR. BUNTING: I will give you a fairly good i-i 13 example. When Golder who had been under contract for us for l 14 two or three years under the terms of its contract has to i j 15 come and notify us it is now going to take a contract with i l 16 the Department of Energy and the crystaline program, 1 17 proposed ways to meet NRC criteria on the chrystaline i 18 program, then comes to us and says we are willing to set up 19 a separate entity that will only work for you, l i 20 But because both are profit seeking and come l 21 together in a holding company somewhere in Canada, we view i 22 that as a conflict of interest. ! 23 At this time our only recourse is to stop 24 dealing with Golder. But in doing that we lose the l 25 continuity of the contractor. r r l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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p . 154 1 DR. STEINDLER: I am not saying that you don't
.O 2 have a conflict of interest set of ground rules for a case 3 by case basis. I have just never seen the thing put 4 together in a coherent single statement.- :
5 I have heard a lot of comments of the example 6 -kind you give me and they seem on the surface pretty 7 reasonabic, but how far away do you want to go for a holding 8 company before the thing gets to be kind of silly? 10 9 Also I see a significant amount of paranoia in 10 the whole thing. I agree hearing boards are ill-tempered an 11 unpredictable, or sometimes ill-tempered and predictable, 12 depending on whether you are on or off them. But I see the 13 statement you make in SECY 85 , and I think it's pretty 14 weak. 15 Secondly, I think we are going to run out of 16 experts, even if you scour the areas outside the continental , 17 United States you are going to run out of reasonably decent i 18 experts pretty fast. 19 So the whole question of conflict, it seems to
- 20 me, ought to be looked at by the Commission once and for all i
21 so that we don't have to make a guess as to whether or not l 22 we can employ an expert who two years prior to that 23 published a paper under DOE and now is going to be working f 24 for, FERC. I j 25 MR. BUNTING: We can certainly higher him but , ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
155 ', C .
, 1 we can't have him evaluate the paper he wrote for ust C) 2 DR. STEINDLER: There is nothing wrong with 3 that.
4 DR. KERR: Marty, I would share what I'think is 5 your concern. That appears to be and is apparently -- an 6 organization whose life is limited. I don't know what the 7 limit is at this point. And is going to look f or people 8 with expertise that I think is comparatively limited. 9 DR. STEINDLER: I think it's very limited. '
, 'i 10 DR. KERR: Then it is going to try to isolate ,
11 them professionally from the other people who do the same-t 12 sort of work. 13 DR. STEINDLER: Yes. 14 DR. KERR: And to do it in a short time, 15 because you want this start up time on this to be something 4 16 less than a year. 17 DR. MOELLER: Yes. l 18 DR. KERR: It's probably not impossible but l , 19 it's a f ormidable task. l 20 MR. BUNTING: It is a formidable task, and we 21 are trying to be somewhat sensitive to that by developing a 22 phase in plan. We are not asking them to leap to the moon - 23 on day one. We are not dropping everything that we have f 24 going on day one, either. < 25 It is not absolutely necessary and mandatory
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'7- 1 that every dollar we get in f uture resources has to go to 2 the center, but I do think we have to evaluate what it is we
\
3 want to have done. 4 And if we are concerned about having that i expertise available for the hearing, then the way Mr. Davis
-6 feels is that it's insufficient, just unsatisfactory to rely 7 on an individual.
8 This is a long-term program and we have to 9 assume that people are going to come and go. We have to 10 build institutional support behind them. You are right. It T 11 does have a limited lifetime. That is the. nature of all 12 FFRDC. 13 However, this program, as long as we are 14 looking at it, 20-plus years, I think it has sufficient N 15 expectancy to attract and retain.
~ 16 If you look at the other 35 FFRDC, the kinds of 17 problems that you are concerned with, back in day one in the 18 space program, I think people could have made the same case 19 about setting up an FFRDC with limited expertise to put in 20 it.
'l 21 But they have shown it can be done. It is not 22 easy.
\
23 DR. STEINDLER: How many of those are involved ! 24 in this question of conflict of interest? 25 MR. BUNTING: Almost all of them. That is ACE FEDERAL REPORTERS, INC. Washington, D.C.
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157 1 exactly why the Ae';ospace Company was set up. It grew out 2 of conflict of interest because STL at the time was advising 3 the Air Force on how to do it and then bidding on doing it. 4 As a result Congress chartered the Aerospace Corporation and 5 people had to choose. Either you are going to be on the 6 commercial side and build it or on the other side and 7 advise. i j 8 DR. KERR: You mentioned earlier you expected a i 9 stable of NRC staff members to be able to evaluate the work 1 10 done by the FFRDC, which I assume means they have to become f 11 f airly expert on this. 12 MR. BUNTING: Yes. 13 DR. KERR: Why is it not feasible to have those 14 people do the testifying before boards? ) ! 15 MR. BUNTJNG: They can. i ) 16 DR. KERR: So you don't need these people just l 17 to testify bef ore boards? 18 MR. BUNTING: We are not relying wholeheartedly 19 on this group of people to testify bef ore boards. Our 20 primary responsibility lies on the staff. 21 DR. KERR: I misunderstood. I thought that was 22 the principal aim. 23 MR. BUNTING : No. To put this in the same [) U 24 context that we are putting, right now, for instance, tr.ese 25 folks will go out and ask the contractor to give us a point i I ACS FEDERAL REPORTEFS, INC. Washington, D.C. (202) 347-3700
158 1 paper on the Rockfers potential. If we want early 0 1 V 2 resolution on Rockfers potential we would probably troop 3 that person in to defend the paper. 4 To the extent we would do that with existing 5 contractors if that contractor, if that contractor ! 6 subsequently goes to work for DOE you really can't troop him 7 in and expect much confidence or much reliability on the ! 8 board to put in that paper. 9 What we are now trying to do to the same i , 10 extent, we want to rely on the contractors we presently have i 11 to come to a hearing, we are trying to arrange an j 12 arrangement whereby we can guarantee institutional support 13 for the life of the program. 14 We didn't mean to imply our entire support for 15 the hearing rests on this contractor. 16 DR. REMICK: I would just like to say a few l 17 words in favor of the concept, not saying that the words you 18 have heard about whether there is a conflict of interest 19 aren't things that are worth considering. 20 But I have had a personal involvement with a 21 unit, an organization that was a FFRDC f or many years. I 22 think the sponsor of the organization, and certainly the j 23 people running it, think it was a huge ruccess. It was a
/ 24 technical base laboratory for the Navy.
25 And I think those things can work in the manner 1 j ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
159 1 in which you are describing, and one of the keys is that you O 2 don't let the contract people run it. 3 MR. BUNTING: That's right. 4 DR. REMICK: If the contract people run it, 5 then you will lose what you are trying to gain. You have to 6 make sure the technical people write the contract in a 7 manner that you can accomplish the thing. If you fail to do 8 that, then I think you will fail. 9 - MR. BUNTING : I would like you to say that loud 1 l 10 every place you go. 11 DR. REMICK: I agree, this bit of approving I 12 publications is completely unacceptable to universities, but 13 you can do that if technical people want to make it work and 14 make sure something doesn't get out in the literature that 15 is classified. l 16 With that type of system you can have graduate 17 students doing thesis research in which all these cease are 18 unclassified and so forth. 19 If the sponsor and institution want it to work, l 20 a -- that is important. If the contract people get in and l 21 write all the clauses and lawyers and so forth, pretty soon l 22 it goes downhill. l 23 MR. BUNTING: You hit on a very key point. It l i 24 is a different between the government and contractor, and 25 the OMB policy letter points that out. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
160 l l 1 DR. REMICK: Yes. O 2 MR. BUNTING: It's kind of hard to get that ! 3 notion across to everybody. 4 DR. REMICK: Incidentally I believe at one time 5 at least FFRDC's accounting procedures were different than 6 typical accounting required between government contracts and 4 7 universities. i 8 I don't know if that is still the case, but if 9 it is, somebody ought to be thinking about are there special l 10 contract-type of provisions that might apply for an FFRDC. 11 At one time there ware. . + 12 MR. BUNTING: We will check. , 13 MS. WADE: Yes. 14 DR. MOELL ER: One other question I have which 15 is a detail, but, none theless, it intrigues me. i 16 When the FFRDC initially tools up it could be a 17 group that has maybe a small cadre cadre of qualified 18 people, 19 But they are obviously going to have to build 20 up. In building up I gather they may hire some people f rom i 21 DOE labs and so forth. . 22 How do you control that? Do you have a cooling 23 off period? 24 MR. BUNTING: We have our own way in which we f 25 think -- p_ l l 4 ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
t 161 i g- 1 DR. MOELLER: You can do that. (_/ 2 MR. BUNTING: We can do that. But rather than 3 specify them we have called it out in the RFP. ! 4 LR. MO ELLER: Fine.
- 5 MR. BUNTING
- The contractor will call us and t 6 that will be the basis for management control.
7 DR. MOELLER: That is very reasonable. 8 What do you want from us? < 9 MR. BUNTING : Well, I think what this gentleman 10 said about the importance of how to make this thing work is i 11 very important. If that message can get across to everybody 12 here at the Commission I think that would be most helpful. 13 And I think maybe a look see from time to time to see that 14 that is happening is very important. 15 DR. MOELLER: As of the moment, though, it is 16 before the commission for a decision? 17 MR. BUNTING: Yes, sir. 18 DR. MOELLER: This then I would view as mainly 19 informational. 20 MR. BUNTING: Right. i 21 DR. MOELLER: We appreciate it. We have P 3 22 followed it, a number of us and are intrigued by the 23 concept. 24 Not to beat it to death, but on the conflict of 25 interest, of course, the NRC looks not only at conflicts but i ACE FEDERAL REPORTERS, INC. Washington, D.C.
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,- 1 perceived notion of a conflict.
() 2 MR. BUNTING: Yes, correct. 3 DR. MOELLER: I can understand it. It may look 12 4 bad now, but if you do save yourself some time in the future
,5 a major flap --
6 MR. BUNTING: Well, with Mr. Davis' concern, 7 recognizing that it was a judgmental thing, is there a way 8 we can just avoid the issue, something we can do now to 9 avoid that. 10 DR. MOELLER: Well, thank you, very much. 11 MR. BUNTING: Thank you. If you do have any 12 comments that we haven't addressed here relative to looking (-) 13 at what was handed out, I will hand you back the matrix we 14 did on the analysis of the comments. 15 DR. MOELLER: Yes. 16 MR. BUNTING: I would appreciate any comments 17 you have bef ore the RFP goes out. 18 DR. MOELLER: We appreciate that. 19 DR. STEINDLER: Did you say you have revised 20 the -- 21 DR. MOELLER: Statement of work is being 22 revised. l i 23 DR. STEINDLER: If and when that gets done, 24 maybe that is what we ought to be looking at. 25 DR. MOELL ER: Okay. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700 _
163 i i -s 1 DR. REMICK: What is yout estimate now of RFP? 2 MR. BUNTING: We just had to bite the bullet on 3 that. 4 Again, I give the caveat that, assuming 5 everything went smoothly, and that's never happened yet, but , 6 assuming that everything went smoothly, I think it would 7 probably be the middle of September before the RFP went out. 8 We are then looking at a two-month, 60-day 9 proposal period. You will notice that when we sent the 10 package out for comment, we made the notice of 11 availability -- available, people called in and, or wrote 12 and asked for the package. 13 We not only gave them the statement but also 14 gave them draf t criteria by which we would be looking at 15 their proposal. That criteria was heavily weighted on 16 knowledge of the issues as opposed to, what does your stable 17 look like? 18 Inasmuch as they have had this for some time, 19 we think those who are interested and serious about this 20 should be able to put together a proposal within 60 days. 21 We think from the day the RFP goes out until 22 the day we are able to make an award, somewhere about six 23 months. 24 DR. MO ELLER: ( All right. Thank you. 25 We will move to the next item. And, John, that ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
164 1 is the briefing on the Nevada test site or Yucca Mountain O 2 site. 3 MR. LINEHAN: Right. This briefing was 4 originally put on the agenda due to the proposed site visit 5 which has been delayed by the ACRS staff out to Yucca 6 Mountain. That has since been delayed. 7 Since Yucca Mountain is one of the three sites 8 chosen by DOE for site characterization, we plan to go ahead ; 9 with the briefing. 10 What we will do in subsequent meetings with you 11 is to give you briefings on the other two sites, the Hanford l 12 site and the Deaf Smith site in Texas.
/~
4 l 13 The briefing today is going to be given by King i i 14 Stablein, who is the Proj ect Manager of the Division of 15 Waste Management Team Action, dedicated to this site. l 16 He is going to be assisted by Charlotte Abrams, , I 17 who is the lead geologist on the Yucca Mountain team for us. l 18 MR. STABLEIN: How is the visibility on this? j 19 DR. MOELLER: As high as you can is always 20 good. 21 MR. STABLEIN: Thank you. 22 Good afternoon, I am King Stablein, as John i 23 introduced me. 24 Charlotte Abrams is a member of the NNW site 25 team working on the Yucca Mountain site. We have members ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
I 165 s 1 from all the disciplines on the team. (G 8 2 I also have Dave Tiktinsky with me today 3 sitting over here representing rock mechanics and design, 4 should we have the need to bring Dave in for a question or 5 two. 6 I have two purposes in addressing you today. 7 The first is to just acquaint you with the site almost as if 8 you were going out there since we couldn't, or you couldn't 9 go out there at this time. 10 (Slide.) 11 MR. STABLEIN: Then secondly, to at least 12 introduce some of the key issues that are dominating our 13 thinking and the dough does thinking at the Yucca Mountain 14 site right now. 15 So let me start by setting up the site for you. 16 (Slide.) 17 MR. STABLEIN: Here is the State of Nevada. 18 Down here, here is Las Vegas. If you go about a hundred 19 miles to the Northwest you come to Yucca Mountain, right at
- 20 the border of the Nevada test site.
21 The next vugraph will show you that in fact 22 it's on the border of three jurisdictions. But it is i
-23 important in terms of some of the issues that the State of 24 Nevada will be concerned with to realize the relation of the 25 site to the major population center in the State of Nevada.
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166 j l l 1 (Slide.) i O 2 MR. STABLEIN: I.made reference to the site 3 being on three j urisdictions. You can see the NTS here 4 blown up, or the site blown up. In this way we will have a ! 5 better views of the repository block, itself. You don't i 6 have to be too concerned with that. This is the repository 7 block, the outline of it. 8 A small part of it is on the Tiva test site, a 9 large part of it is en the Nellis Air Force range. The 10 remainder is on Bureau of Land Management land. , 11 (Slide.) i 12 MR. STABLEIN: All right. v 13 DR. MOELLER: Is the Bureau of Land Management 14 in the Department of Interior? i 15 MR. STABLEIN: Yes, I believe so. 16 MR. CARTER: Yes. 17 DR. MOELLER: What does it mean, Bureau of Land 18 Management? 19 MR. CARTER: What it means out there is quite 20 often they own the land and they can then delegate, if you 21 will, or assign grazing rights for animals. 22 DR. MOELLER: Okay. 23 MR. CARTER: That basically is what is involved , 24 in that area. 25 MR. STABLEIN: Now, moving in closer to some of ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
167 i es 1 the features at Yucca Mountain and surrounding, some of the h 2 names you will be hearing as I talk about the Yucca Mountain 3 site and as you read about Yucca Mountain over the coming 4 period of time, here is Yucca Mountain site, itself. The 5 outline is a little bit faint. I 6 Jackass Flats is on the east side and Crater 7 Flat is on the west side. 40-mile wash is here. The Calico 8 Hills. You were going to visit the EMAD facility. That was 9 right about in here. 10 Climax Granite experiments were up in here. G 11 tunnel, which is where the DOE has done many of its i 12 preliminary experiments on a welded tuff that is similar to 13 the tuff that is going to be the proposed horizon for the 14 repository at Yucca Mountain, G tunnel is in Rainier Mesa. 15 Bear Mountain is over here. The Bear Mountain 16 fault has been remarked upon by the DOE and is included in l 17 their discussions of faults that they have to be conscious 18 of.
- 19 When we get to the geologic map I will show you l
20 more of the faults than you can see here. 21 I think that those are the key names that you f 22 want to keep in mind for the present. We can come back to 23 this if we need it in the future. 24 (Slide.) 25 MR. STABLEIN: I promise to try and make this ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700 .- -.
168 1 feel a little bit like you were going out there to the site. 3 2 This is nothing like being out there at the end of July, but 3 I might, if you let your imagination go just a little bit, 4 might give you a feeling for the type of environment we are 5 dealing with. And this is Yucca Mountain. 6 I will try it this way. I apologize for that. 7 That is an interesting thing, when you are out 8 there a lot of these places can look look the same. You 9 will see as we look at more of these diagrams it is 10 difficult to tell where you are sometimes. 11 But Yucca Mountain should be pretty much etched 12 in our mind. A k/ 13 This is the repository site, area of interest. 14 Not all of Yucca Mountain will be part of the repository 15 block as I will show you or as you can see on the last sheet 16 in your package, which is the geologic map. 17 This is looking at Yucca Mountain from the 18 east, coming across Jackass Plats, which is the way we 19 generally drive up to it when we go on one of these trips. l 20 ( Sli de . ) 21 MR. CARTER: What are the surface dimensions of 22 it, roughly? 23 Is it a square mile in size or a couple of ( 24 square miles, or 700 acres, or what? 25 MR. STABLEIN: That is a good question. We ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
169 i
._ 1 have something with scale on it.
2 Do you recall dimensions? 3 MR. MERRILL: The second map is the scale, has 1 4 the scale here. 5 MR. STABLEIN: Let's go back to that for a 6 second. I don't have really tight numbers on that. 7 (Slide.) 8 MR. STABLEIN: But this will give us an idea. 9 Here is the scale. And the area that is indicated there l 10 would be something like maybe 7 by 15 miles,105 square 11 miles in this whole block. But the repository block, 12 itself, is much smaller. 13 In fact, one of the concerns at Yucca Mountain 14 is that in the repository block there could be concern about 14 15 having enough volume in which to put the repository. 16 MR. CARTER: Let me ask you a stupid question. 17 Why wasn't it made bigger if that is a concern? 18 If there is one thing they have got out there, it's lots of 1 19 space. 1 j 20 MR. STABLEIN: Well, that's true, they do have i l 21 lots of space. And in fact, the NNWSI project f olks have 22 five proposed expansion areas in which, out f rom the main 23 block that they could take the repository. 24 But you are constrained in not only the block 25 itself to some extent, but when you start getting into the l l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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- 1 other blocks by such things as an extreme amount of 2 f aulting, or you don't have enough over burden. You are <
required by the guidelines, DOE siting guidelines to have a l 3 4 minimum of 200 meters of over burden. And the favorable 5 unit in which they want to put the repository comes close to 6 the surface. 7 The quality of the rock in some areas that they 8 would like to expand into is questionable. 9 Charlotte? 10 MS. ABRAMS: There is also from the main 11 repository area to the expansion blocks, most of those areas 12 are separated by faults. ! 13 And the DOE has said that there can be up to a 14 hundred meters or more of offset along those faults, which 15 would put you offsetting your repository horizon and could 16 put you into another stratographic unit entirely. 17 MR. CARTER: Do all of these faults in the area i 18 have a surface manifestation? I I ) 19 MS. ABRAMS: No.
^
20 DR. MOELLER: Maybe it was asked. Do you know 21 when they moved? 22 MS. ABRAMS: The DOE is doing work on that now. l 23 They don't have a handle on that for all the faults. 24 Some of them, based on thermoluminescent ages, 25 they see movement of possibly 6,000 years ago. But none of _ _ - ~ . . _ _ _ _ _^CEf_EppR{_REgR{ERS, _ INC. Washington, D.C. (202) 347--3700
{ 171 I
~ 1 this stuff is -- i ! ') .
DR. MOELLER: 2 Firm. 3 MR. CARTER: By the way, those get moved quite i 4 often due to the testing activities out there, I imagine, so i t 5 they get shocks occasionally. 6 MR. STABLEIN: These are good questions about I 7 the nature of the faulting and the surface expressions. 8 Now, besides what I am going to put on the 9 screen for you, I have a number of large photographs, some 10 of which illustrate points about the site that I think would 11 be of interest to one or more of you. 12 (Slide.) k-) 13 MR. STABLEIN: For example the abandoned Wash 14 Fault is highlighted in this photograph. I am going to pass 15 these around in case people are interested. 16 And there isn't really any surface expression ! 17 through the abandoned Wash Fault or at least any unequivocal I f 18 surface expression. l 19 Charlotte and I, I believe, have both walked 20 this fault. I know I was on it during one field trip, and l l 21 Bob Scott of the USGS was pointing it out. But it was not 22 something where we could put our hand on the fault plane and 23 say, oh, yes, I can see displacement. I can see layers 24 which have been shifted. f 25 MR. CARTER: I am intrigued by the name, is the ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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,,-. 1 abandoned part of the name or is it descriptive?
2 MR. STABLEIN: It's now part of the name. It 3 may have been descriptive, also. 4 Anyway, I am not going to run through all of 5 these in the f orm of slides or transparencies. I do have a 6 couple of more to show you, just to give you other views of-7 Yucca Mountain. 8 DR. MOELLER: Excuse me. Now, where is the 9 site on this? 10 MR. STABLEIN: Okay, I haven't described this 11 one yet. I just put this one up. 12 DR. MOELLER: Oh, okay. O V 13 MR. STABLEIN: But I was about to say that we 14 are looking at Yucca Mountain in this instance from the 15 north. Yucca Mountain being here. And this is the west 16 side. The So'ltario Canyon fault is one of the most j 17 important faults to keep in mind. It defines the western 18 edge of the repository block, which shows up on that map 19 that is your last sheet in the package. That is along here. 20 And Yucca Mountain is over here. 21 This is Crate; Flat. You can faintly see one 22 of the cones, volcanic cones which are present out in crater 23 flat. 24 Is this Black Cone or Red Cone, Charlotte? Do ! 25 you recall which one is the northern most? ! ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
173 1 MS. ABRAMS : It would be --
) 2 MR. STABLEIN: It's on our geologic map, there.
3 I have trouble keeping them straight. 4 That one is Black Cone, and there is another Then even f urther South
~
5 cone further south called Red Cone. 15 6 you have Lathrop cone. 7 And then going across Crater Flat is Bear 8 Mountain, which doesn't show up well at all here, but which 9 in the photos that are being passed around, with fairly 10 decent. captions on the back, you should be able to see Bear 11 Mountain. 12 Let me give you one more view. 13 (Slide.) 14 MR. STABLEIN: We have seen this f rom the north 15 and from the east now. And here is, I am going to take this 16 up a little higher at first. If you want to see the upper 17 part we can come back to that. 18 But this is the Solitario Canyon fault. We are 19 right on the fault plane. This is the fault plane. 20 This is a drill rig for one of the holes that 21 the GS drilled and Yucca Mountain is back in here. 22 Then looking across Jackass Flats, you can see 23 Skull Mountain in the background. Get an indication that ( 24 this is a vehicle traveling along that has created that 25 dust, and, as I say, one of several drill Riggs that have l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
i 174 i x 1 been photographed out there. I
~
2 This is for an older hole. Right now the one t 3 that is featured in the photos that are being passed around l 4 is the unsaturated zone called U Z 6 that was drilled f rom l 5 Yucca Crest. 4 l 6 There is nothing like going out to the site and 7 actually experiencing it, but this is an attempt to give you f 8 some feeling for what it actually looks like when you go out 9 and step upon it. l 10 If there are no questions or observations on 11 that part right now, it's time to make that cut into the 12 third dimension and go into the subsurface for the site. I () ) U 13 (Slide.) i j 14 MR. STABLEIN: First of all, very schematic, an j 15 idea. This was actually created to indicate the highlight , 16 benefit of the Yucca Mountain site. I know you are all i 17 aware of that, it being that it's an unsaturated site. i 18 That is, that in the repository horizon which i ' 19 is the Topopah Spring, we are well above the water table and 20 these rocks are not saturated or filled with water. I 21 That doesn't mean that there isn't any water i 22 there, but it means that the void space is not one hundred i 23 percent filled with water. l 24 DR. KERR: Like maybe one percent? ( '
} 25 MR. STABLEIN: Pardon me?
l __ ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700 [
175 1 DR. KERR: One percent, maybe? (,s) '^ 2 MR. STABLEIN: If I recall the numbers 3 correctly, Charlotte or Dave can help me out, I believe the 4 rocks have been measured at 40 to 95 percent saturated. 5 So it's not like there is just a small amount 6 of moisture relative to the void space. They can be almost 7 saturated. 8 So the term " dry" in ref erence to these rocks 9 is not really a good way to characterize them because in I 10 fact there is water present. 11 (Slide.) i 12 MR. STABLEIN: Now, this schematic is okay to 13 introduce us to the benefits the site. But we have a little 14 better look at the subsurface. This is a fairly typical 15 cross section showing the different layers and the 16 repository envelope. 17 Now, the rocks at Yucca Mountain, especially 18 near the surface, and in the zone of interest, are primarily 19 volcanic tuffs. They range from welded to unwelded. Thri 20 Tiva Canyon up at the top is primarily welded and the rocks 21 beneath that canyon and Yucca Mountain are largely unwelded 22 then the Topopah Strings, which is approximately 350 meters 23 thick, is largely welded. Especially in the part of the l ( 24 Topopah Springs that is intended to be the repository, the t 25 rocks are highly welded and accompanying that they are very l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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- 1 fractured. Those are key characteristics.
( ) 1
,g 2 Another character particular is that they have l 3 n lot of lythophyzene, these gas-created cavities sometimes 4 filled with minerals, secondary minerals, and sometimes not.
5 So if you get too many of those in a zone of , l 6 the Topopah Springs or other rock, it could become not
- i 7 useable f or siting a repository or if the rock were too l'
i 8 fractured, ! 9 But the NNW site has identified a portion of i 10 the unit they feel they can put the repository in. i I 11 Did you have an observation? i i 12 MS. ABRAMS: Show them the -- on the Solitario l 13 Canyon Fault. l 14 MR. STABLEIN: The Solitario Canyon fault is 16 15 here. What Charlotte points out is the Topopah Springs i 16 located here and here. 17 MS. ABRAMS: That is what I was talking about I 18 as far as lateral flexibility. I 19 DR. MOELLER: What height? I guess it is in 20 meters. You are talking about, it looks like several 21 hundred meters of height in that particular -- 22 MS. ABRAMS: Offset? 23 DR. MOELLER: Yes. 24 MR. STABLEIN: Displacement? 25 DR. MOELLER: Yes. C ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
1 177 1 MS. ABRAMS: Yes, this is somewhat schematic, O 2 but it gives you an idea. I don't know that this is exact. 3 MR. STABLEIN: Well, it's not drawn to be -- it 4 says approximate scale and that is what it is. This is not 5 meant to be a not to scale sort of thing. 6 For example, I think it indicates with some 7 reasonable accuracy that the repository horizon is on the 8 order of 250 to 350 meters down, something like 650 to 700 9 feet to 1200 feet below the surface. And then you have 10 considerable distance again between the horizon and the 11 water table. 12 So this is where the rocks are saturated, down b s/ 13 here. They are not saturated here. And here is the 14 repository horizon. 15 MR. MARK: Let's see. The surface of the 16 general area is around what, 3,000 feet above see level? 17 MR. STABLEIN: The topo maps should be able to 18 tell us. I was under the impression it was a little higher 19 than that. , 20 MR. MARK: Fine, it could be. 21 MR. STABLEIN: I know it stands a thousand feet l I 22 higher than the surrounding, the flats to the east, for 23 example. About, well, maybe even more to the west. 24 Do we have that. 25 MS. ABRAMS : There is a benchmark, about 4500. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
17 8 g- 1 MR. MARK: 4,000, 4500 with things going up to
'Q) 2 five?
3 MR. STABLEIN: I was going to say 5,000, that 4 sounded a little high, especially af ter you suggested 3,000, 5 I wanted to.take another look. But it stands up there four 6 to five thousand feet high. 7 DR. KERR: I see something marked 4951. 8 MR. STABLEIN: Okay. 9 DR. MOELLER: How does the depth of the 10 proposed location of the repository here compare to Deaf 11 Smith and to the Hanford site. 12 MR. STABLEIN: John? 13 MR. LINEHAN: the Hanford site is close to 14 3,000 feet below the surface, did he have submit is 2400 15 below. 16 DR. MO ELLER: What is the depth here in Nevada? 17 MR. STABLEIN: It ranges from about 700 where 18 it gets really close to the surface, relatively speaking, 19 down to 1200 feet or more. l 20 MR. CARTER: What is the variability with time 21 of the water table in this area? I presume they measure 22 that. 23 MR. STABLEIN: That's an excellent question. I 24 guess I don't have a real good answer. I am not sure even 25 what sometime scale we should try to deal with that on. ACE FEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
17 9 1 It's something they are still measuring with all their O. 2 hydrologic holes. 3 Go ahead, Charlotte. 4 MS. ABRAMS: They have seen small scale l 5 fluctuations measuring to the west in a spring area they ) 6 call Devils Hole, but no large fluctuation. l 7 MR. CARTER: When you say small, do you mean ! 8 feet or meters? I 9 MS. ABRAMS: Yes, no raore than - several feet. i 10 This is short-term measurements, too. 11 MR. CARTER: Yes. l 12 MR. LINEHAN: Is the long-term variation a 13 significant issue, over 10,000 years? 14 - MS. ABRAMS: I hesitate to answer for the i 15 hydrologists, but it is something that has been questioned. 16 MR. STABLEIN: What we have indicated in our 17 comments in the past on the long-term variation is that we 18 feel it's enough of a concern for them to continue to
- 19 investigate during site characterization, to try to see what i j
j 20 sort of fluctuations they can gauge from , l 21 paleo-climatology-type studies. 22 We are not saying that it is definitely going i j 23 to be a problem, but it's something of extreme interest 1 O ( 24 because you could take away the benefits of the site if the l 25 water table rose. i ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
180 1 MR. CARTER: You are either talking about
.h- 2 saturated or unsaturated.
3 MR. STABLEIN: That's right. 4 MR. CARTER: That is the potential. 5 DR. KERR: If you discovered something about 6 the last 5000 years would you use that to predict the next 7 5,0007 8 MR. STABLEIN: Well, that would be one of these 9 questions where, obviously, I hate to sound like I am 10 weaseling cet of it, but this is where expert judgment and 11 scientific community has to make an assessment on that. 12 DR. KERR: If you are asking somebody to 13 investigate the last X thousand, surely you have in mind 14 something that is to be done with the information. 15 MS. ABRAMS : They are doing studies. They 17 16 looked at pack rat mines and done datirg on those and tried 17 tc determine water levels. So they do have ongoing i 18 research. i' 19 DR. KERR: My question is what are you going to i 20 do with it? i 21 MS. ABRAMS: Well, it depends on, I guess, the j
! 22 climatologists, their determinations.
23 MR. LINEHAN: I think it would be not only that ( 24 there was a significant difference 5,000 years ago, but what 25 caused that difference and whether it might occur again over ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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~~ l the next 10,000 years. It would be the cause we would be 2 looking at.
3 DR. EERR: I can see with some difficulty how 4 you might determine what has happened over the past 5,000 5 years. 6 I have more of a problem in knowing how you are 7 going to predict what will happen in the next 5,000 8 MR. LINEHAN: So do we right now. The most 9 difficult thing in this whole program is going to be dealing 10 with those uncertanties over the 10,000 year period. 11 MR. CARTER: I want to offer a complaint. This 12 one is in here twice. ( 13 (Laughter.' 14 MR. STABLEIN: Noted. 15 I wanted to -- 16 DR. STEINDLER: Befote before you leave this 17 area, there is a portion of the ground rules that you folks 18 operate under which in effect say that the geology must not 19 be too complicated, or words to that effect. 20 On the basis of what you see here and the 21 comments you have made does this geology begin to approach 22 complications at the level where you can begin to rej ect the i 23 site? [) 24 MR. STABLEIN: Do you want to address it or do i \_/ 25 you want me to? l ACE FEDERAL REPORTERS, INC. W'ashington, D.C. _ _ _ _ _ (202) 347-3700
182 7- 1 DR. STEINDLER: You are entitled to the Fifth D 2 Amendment. 3 MS. ABRAMS : It's a loaded yes. 4 DR. STEINDLER: Yes, it is. 5 MS. AB RAMS : I think it just bears upon further 6 gath- .g of evidence. 7 Right now the DOE says according to the 8 evidence, only one major f ault intersects the repository. 9 That's going to have a big bearing, how many faults 10 intersect the repository. 11 DR. STEINDLER: The repository, or the horizon? 12 MS. ABRAMS: The repository block, itself.
. . 13 DR. STEINDLER: The repository block, itself.
14 MS. ABRAMS : Whether these faults are active or 15 not, or recently active, is another problem. 16 There's just going to have to be a lot more 17 evidence gathered. 18 DR. STEINDLER: Okay. 19 MR. CARTER: I made the comment earlier out 20 there, that whole area is extremely well faulted, or there 21 are many faults in it. 22 But, you know, certainly they, with the testing 23 program, and they have measured that seismically now for ( 24 many, many years, certainly those f aults have had an awful 25 lot of jolts. They get them every month or so due to ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
183 1 underground testings. O_s 2 I suspect if they were going to move, they - 1 3 certainly have had the impetus to do it on numerous , 4 occasions, and I assume DOE has well documented that sort of 5 thing.
; 6 DR. STEINDLER: I don't remember in the 7 regulations a statement that says you have to shoot off a 8 weapon now every month for 10,000 years in order to keep the 4
9 faults lubricated. 10 MR. CARTER: No, but as far as movement of the 11 thing, I think there should be ample data at least over the 12 last decade or so to give you some indication of what has O A/ 13 occurred. 14 Do you all have access to that sort of thing? 15 MS. ABRAMS : We don't have complete access to 16 the test site data. We are identifying what is available. 17 And the way we have seen handle it is to just identify what 18 is available and make that known to the DOE. 19 It's simply -- it's not just what would move 20 due to a test shot, but what would move normally. What I 1 21 mean by normal movement is not movement in reaction to a ! 22 test. i ~ 23 MR. CARTER: I understand that. But what they 24 are doing, I presume, should trigger them or jolt them or
, L 25 whatever.
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l . 184 l 1 MS. ABRAMS: DOE is also conducting stress ' (s") 2 tests in the area to assess the stress on these faults at l l 3 the repository. So, as you said, there is ongoing work. 4 MR. STABLEIN: It seems to me we recently 5 received a report on ground motion related to those, some of 6 the tests. 7 Dave, do you recall that? Have we had a chance 8 to look at Workman's stuff yet? 9 MR. TIKTINSKY: Yes, we have looked at it a 10 little bit. Basically, where most of the tests are, the 11 closest thing is Yucca Flat, which you see on the one map, 12 that is on the order of about 14 kilometers away from the (/) ( 13 site. 14 The ground motion caused by an explosion within 15 the limits of the test ban treaty, which I think is 150 18 16 kilotons is relatively insignificant. 17 We had some concerns if that treaty some time 18 in the future is broken and we decide to shoot off something 19 on the order of what they did in the '60s, you know, many 20 megatons, it may produce some ground motion, at least may 21 have some effect on the ground openings in Yucca Mountain, 22 whatever was done in the late '60s. 23 MR. CARTER: Part of the problem of what you 24 say, Payute Mesa was used for larger tests and it was used 25 for tests a lot larger than 150 kilotons. Only the more ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
185 1 recent ones under the restraints of the treaty -- 2 MR. MARK: I am not sure there has been 3 anything out there appreciably larger than 150 kilotons. 4 They are worried about the buildings in Las Vegas. 1 5 MR. CARTER: This is why they went to the 6 Payute Mesa area, to get the test about halfway between 7 Vegas and Reno. 8 Anyway, in my opinion there were tests larger 9 and closer than Yucca Flats. 10 MR. TIKTINSKY: If that thing was broken and 11 they did start setting off large weapons again, that may 12 have some eff ect on the underground openings. O) ( 13 As of where it stands right now, it would 14 probably be very minimal. 15 DR. MOELLER: All right. 16 MR. STABLEIN: Before I take this off, I bave 1i one more thing I wanted to mention about it. In fact, two 18 more things, because Charlotte mentioned the one significant 19 fault that has already been identified that goes through the 20 repository block. That is the Ghost Dance fault, shown 21 hcre. 22 The other key unit is below the Topopah 23 Springs, Calico Hills, right here. Some of it is above the [)/ Q 24 water table, some below, mostly above the water table where 25 it's beneath the repository. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
186 1 The important thing about the Calico Hills is O 2 that in terms of retardation, you all discussed retardation 3 quite a bit this morning, Calico Hills is that zeolitic unit 4 which the DOE is counting upon for considerable absorption. 5 That is right here. Here is the repository. 6 (Slide.) 7 MR. STABLEIN: All right, that kind of sets the 8 stage for consideration of some of the major technical 9 concerns at the site currently. It's in your package if I 10 don' t come up with that transparency. 11 DR. MOELLER: We have a list of selected 12 issues. ( 13 MR. STABLEIN: Those are the ones. 14 DR. MOELLER: Well, that is all right. 15 MR. STABLEIN: That transparency has wandered 16 away, so I will have to just speak f rom the sheet. 17 What I have done is not all the issues, there 18 are lots of issues, some of which will become much larger as 19 site characterization proceeds, some of which may diminish. 20 But these selected issues are ones that are 21 , clearly of importance now. NRC is actively involved in 22 working toward resolution of these and as I go through this 23 list, I am going to make reference at least briefly to what
) 24 has been going on relative to each of these issues.
25 The first one listed is fault activity and its ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
187 1 significance. As you have already seen, the faults are one 7s
\~) 2 of the most important features of the site, and I have gone 3 ahead and tried to make a little bit of a transparency to go 4 along with the last sheet in your package.
5 I couldn't get everything on it, but you can 6 see that the block, itself, the repository block is bounded 7 by faults. That is the way the block is actually defined. 8 This is the Solitario Canyon fault which we saw 9 in photographs and earlier transparencies. The drill hole 10 Wash Fault. And coming up along here is the abandoned Wash 11 Fault. 12 Besides the fault right next to the repository O> (- 13 block you have many other maj or f aults and f ault systems, 14 including Bow Ridge fault, Paint Brush fault, Midway Valley 15 fault, which is drawn dotted in up to here, and picks up 16 again to the north. 17 And now some maps are projecting it as going 18 right across the valley there Now, the DOE is trying to site 19 a repository, surface and underground facilities. 20 Of course, with the experience with nuclear 21 power plants siting near faults along which there may be 22 movement is, you know, very inadvisable and of course has
- 23 prevented some plants from being built.
) 24 Here we have a situation with a different kind l
25 of animal. We have a repository. And at the present time, l I ( - .- ACE FEDERAL REPORTERS, INC. Washington, D.C. _ , (202) 347-3700 l
188 1 discussions are taking place and documents are being written
' 'O 2 by both the NRC and DOE to deal with this problem of, well, 3 how close to faults that may be active or capable can you 4 put a repository, the surface facilities, we are concerned 5 about for preclosure, and the underground facilities in 6 terms of underground motion that could cause a loss of 7 containment or threaten waste isolation.
8 My case in point today, because just this one 9 topic could fill up entire sessions, is the topic that the , 10 DOE is struggling with right now. And that is the surface 11 facilities. 12 They have got a problem in that it is time to 13 start thinking about where they are going to put those. And 14 they have a site that they feel they would like to put the 15 facility at. 16 Unfortunately, you can see the Bow Ridge fault 17 is right here. This is Exile Hill. They have some latitude 18 on where they put it. Another major fault, Paint Brush 19 Canyon fault, and the Midway Valley fault. 20 The DOE feels that if they have to live 21 strictly by Part 100 Appendix A criteria, and the history l 22 that goes along with that, that they would have a difficult 23 time putting the surface facilities here and getting NRC 24 approval. 25 So at the present time the NNW site project is ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
189 1 writing a position paper in which they are proposing how O 2 they wculd go'about evaluating and utilizing data involving 3 fault activity and sides seismic data to establish whether 4 in f act for this type of f acility they could locate nearer 5 to such faults than in the case of your nuclear power plant. 6 DR. KERR: Is the issue that these are expected' 7 or suspected of being active faults, because there certainly 8 are plants located on faults. 9 MR. STABLEIN: Right. 10 DR. KERR: It's just.that they are very ancient 11 faults. 12 MR. STABLEIN: We are talking about recency of 13 movement here, absolutely. 14 DR. MOELLER: I guess for the nuclear power 15 plant you are talking 40 years, and here you are talking 16 what, 10,000 years? 17 MR. STABLEIN: That's correct. 18 DR. MOELLER: Refresh me. What is the surf ace 19 facility? What is its purpose? 20 MR. STABLEIN: This is where they are going to l 21 handle the waste. 22 DR. MOELLER: Prepare it prior to putting it in 23 the ground. , l)
\.J 24 MR. STABLEIN: Right.
25 DR. MOELLER: Why don't they put it on top of 4 ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
190 1 the repository? 2 MR. STABLEIN: Well -- 3 MR. TIKTINSKY: Can I help you on that? 4- MR. STABLEIN: Yes. 5 MR. TIKTINSKY: They are planning on going down 6 with a ramp instead of vertical shaft. So that is 7 approximately a mile away, but will be on a decline and go 8 right into the repository horizon. 9 DR. MOELLER: I suspected that. Okay, thank 10 you. 11 MR. LINEHAN: Due to the terrain there would be 12 quite a job bringing f uel up to the top of the repository, 13 also. 14 MR. CARTER: How about indicating on the map 15 there where the repository is, which direction or what the i 16 alignment is. 17 MR. STABLEIN: This is the repository block 18 right here, and most of that could be used in there for the 19 repository. The surface facilities are over here. 20 As Dave described, maybe a mile away from the 21 repository. 22 DR. MOELLER: So they would have -- the surface 23 facilities are at a much lower elevation, so they would just () 24 have a sloping incline into the repository, is that correct? Yucca Mountain is also a hill, 25 MR. TIKTINSKY: ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
,_. ~ , . - . _ - -
1 91 1 so it's.up at a higher elevation. So you go down slightly O 2 and intersect it at Topopah Spring. I think it's about an , 3 eight percent grade, something like that. 4 DR. . MOELLER: Are the NRC regulations written 5 to apply -only ' to a vertical shaf t, or do they equally apply 6 to what could be a roughly horizontal -- 7 MR. LINEHAN: They apply equally to either. 8 DR. MOELLER: All right. 9 MR. STABLEIN: Let me move to the second one on 10 your sheet, origin and significance of calcite vein 11 deposits. 12 I think I will leave this up to indicate some () 13 of the places we will be referring to. 14 Some of the photographs that were - already 15 passed around dealt with the vein deposits. We have another 16 set here specifically oriented on vein deposits. 17 In September of 1984, NRC went out with USGS 20 18 and DOE to survey several features at the Yucca Mountain 19 site. 20 During that trip we went into trench 14 which 21 was dug to try and intersect the Bow Ridge fault. In fact, 22 they did intercept the fault. 23 What we saw in the trenches were the features () 24 you are seeing in these photos, which looks like white paint 25 spilled all over the rocks. ACE FEDERAL REPORTERS,.INC. Washington, D.C. (202) 347-3700
192 1 What that material is is a secondary filling (# 2 made up of calcite, calcium carbonate and silica, which have 3 filled in along the Bow Ridge fault, in this case. 4 Subsequently, this material has been found in 5 many other places in and around Yucca Mountain. 6 Now, the reason why this is significant is 7 because this material, depending on its origin, has much to 8 do with how the site, how well the site can maintain waste 9 isolation, for example. 10 These vein deposits could have at least two 11 different kinds of origin. They could be could be 12 pedigenic, which would below temperature, water flowing down O V 13 the cracks and fractures in times when there is arraign 14 storm, and depositing these minerals from the surface on 15 downward. 16 The alternate interpretation, or let me say an 17 alternate interpretation, because Charlotte knows of at , 18 least a couple of other alternatives to this, but these are l 19 the major two N member type interpretations, would be { 20 hydrothermal. 21 That is, the material came up from below at 22 high temperature, deposited by waters with temperatures 23 greater than 100 degrees C, probably. I guess in some of
/ / 24 the interpretations it could be lower, but it could be much V
25 higher, also. l _ ACE FEDERAL REPORTERS, INC. Washington, D.C. , (202) 347-3700
193 ! 1 The point is, though, that hydrothermal O 2 activity, possibly related to vulcanism in the area, but 4 3 certainly related to higher temperatures below would be i 4 shooting the hot waters upward, perhaps creating new 5 pathways, and changing, therefore, the hydrologic system and 6 depositing these minerals where we see them today. 7 DR. MOELLER: And again, is there any date on 8 when these were-deposited? 9 MR. STABLEIN: They have been attempting to age 10 date them. 11 I don' t know if they have good dates yet, do 12 you,-Charlotte? f3 (_) 13 MS. ABRAMS: They have done a little bit of i 14 work on them, but it's suspect. They have set up a group to 15 establish work plans. l ! 16 And because there are so many interpretations, 17 there is a third interpretation. It can be a spring deposit 18 that doesn't have to be hot waters, extremely hot waters. i [ 19 So they have a working group set up. They are l 20 putting together a work plan. They have established l 21 attentive list of impartial, we hope, people who will look 22 at the work plan, identify if they think it's complete 23 enough. () 24 And then they will go in to do I can doing the 25 actual work. The bottom line is the resolution won't come ACE FEDERAL REPORTERS, INC. Washington, D.C. - . . . (202) 347-3700
194 s 1 until August of '88. 2 DR. MOELLER: Okay. 3 MS. ABRAMS: Due to the length of the study. 4 DR. PARRY: 888? 5 MS. ABRAMS: '88. 6 DR. MOELLER: Will it be definitive at that 7 time? 8 MS. AB RAMS : It -- I mean, there is a 9 possibility even then it could not be resolved. 10 DR. MOELLER: Sure. 11 MR. CARTER: Let me ask you a question. 12 Certainly one of the notable features out there 13 are those cones, like the Red Cone, for example. 14 What produced those? They are relatively close 15 by. 16 MS. AB RAMS : They are volcanic cones, vosaltic 17 cones. Vosaltic, you don't normally see the hydrothermal 18 activity so the hydrothermal activity, if it in fact exists, 19 would be the result of solicit activity. 20 MR. STABLEIN: This is an issue we identified 21 in September of '84 and called to their attention. DOE was 22 concerned, they reacted by getting USGS out there to look at 23 this. 24 As Charlotte has layed out, they are devising a ( 25 particular effort to determine the origin and significance t ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
195 1 of these deposits. V 2 We have made it clear as recently as June this 3 year that we need to be involved before they finalize the 4 test plan for determining the origin. We expect to have a 5 meeting on this with the DOE some time in December or 6 January, whenever they have the plan in a state ready for us 7 to interact with them on it. 8 MS. ABRAMS: Part of their problem and part of 9 the problem with the timeframe is the work stop order with 1 10 the USGS out at Nevada. A lot of the principals that would 11 be involved in the study are also, their work has been 12 stopped. 13 DR. MOELLER: Refresh me on that. 14 MR. STABLEIN: They are not familiar with the 15 stop work-order. 16 MS. ABRAMS: I am sorry. 17 MR. LINEHAN: What has happened, at several of 18 the contractor f acilities, not just f or the Nevada project, 19 also for, I think in the case of salt, also, there are 20 situations where DOE or a DOE contractor has audited like 21 USGS, looked at their QA and technical procedures, 22 determined they were not adequate for one reason or another 23 and issued a stop work order. 24 DR. MOELLER: Okay, thank you. 25 DR. STEINDLER: In light of the potential ACE FEDERAL REPORTERS, INC. Washington, D.C. _ (202) 347-3700
196 , 1 importance of finding out the source of that mineralization, 2 are you carrying out or thinking about carrying out an 3 independent program in which you take samples and determine 4 for yourselves the origin of that material? 5 MS. ABRAMS: No. 6 DR. STEINDLER: LIf not, why not? 7 MS. ABRAMS: We made recommendations to the 8 DOE, and if they follow the plans and suggestions that have 9 been set up it should be a very thorough study. 10 DR. STEINDLER: Wouldn't you think you would 11 like to have the answers a little more than six months 12 before the license application comes flying in here?
) 13 MR. LINEHAN: What we are doing right now, we 14 are in the process of meeting with DOE so that we can reach 15 agreement on the type of testing that needs to be done to 16 hopefully resolve the problem. It's going to take a long 17 period of time due to the studies that need to be done out 18 there.
19 You know, the answers aren't something that are 20 going to be readily available within a number of months. 21 There is going to have to be some extensive testing out 22 there. 23 We are going to rely on their QA procedures, () 24 their technical procedures to verify that things are done 25 properly. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
1 97 fs 1 In addition we will have staff out at the site d 2 while they are doing a number of these tests, observing what 3 they do, critiquing what tt y do as they do it. 4 There may be the possibility that, depending on 5 what they run into, we may want to do some independent 6 analysis on some of the samples they pull out. We haven' t 7 determined that at this point in time. 8 But in general, the emphasis is on making t i 9 sure -- is having them do the work, but making sure that it 10 is properly controlled through their QA' program and their 11 technical procedures. 12 And again, we have a technical rep on the site ( 13 who will be there almost f ull-time while they are doing 14 critical testing and supplementing him with staff like 15 Charlotte, who are experts in the areas they are looking 16 into. 17 DR. STEINDLER: Who is going to be doing the 18 work? 19 MR. LINEHAN: It will be the Department of 20 Energy and their contractors. 21 MS. AB RAMS : Los Alamos Lab is doing a lot of 22 it. 23 DR. PARRY: Will site characterization studies 24 ( be carried on, continued? 25 MR. LINEHAN: Yes. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
198 g, 1 DR. PARRY: There will be no delay or deferral? V 2 MR. LINEHAN: No, they are planning ongoing 3 right ahead with the site characterization program. This 4 would be one of the studies. 5 I just want to point out so that we put things 6 in the proper perspective. We are focusing today on the 7 Nevada site. 8 When we do give you a briefing on the Hanford - 9 site and the Deaf Smith site, we have got maybe not the same 10 types of concerns, but we have got a number of potential i 11 concerns. 12 DR. MOELLER: Sure. 13 MR. LINEHAN: And I don't want people to walk 14 away with the impression that, you know, we have got-15 problems at Nevada. There are technical issues that have 16 been identified. 17 It may turn out that once they do the studies 18 they are not even the major issues with respect to 19 licensing. 20 But right now they are the things we are 21 focusing on that need to be resolved. 22 MR. STABLEIN: Let's try the third one. 23 DR. MOELLER: Well, if we are ready for a third () 24 one, maybe we should take a break. We have been going quite 25 awhile. Let's take a break then. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
199 7_ 1 (Recess.) V 2 DR. MOELLER: Let's get ready to resume, 3 please. 4 Okay, the meeting will resume. We are going to 5 finish up now with the review of the remaining selected 6 issues related to the Yucca Mountain site. 7 Then we have the two remaining topics, the 8 5-year plan and status of the review, the NRC review of the 2 9 final environmental assessment. 10 So let's move on, King, with the remaining 11 issues. 12 MR. STABLEIN: I am going to move through these 13 five f airly quickly, but of course, I welcome questions at 14 any point. 15 The next item is the acceptability of core in 16 licensing. The DOE has thousands and thousands of feet of 17 geologic core in their core library. And much of the 18 research that they have been doing and will be doing at Los 19 Alamos, Lawrence Livermoota and Sandia, as well es U.S. 20 Geological Survey, depends upon knowing that that core is 21 what it's supposed to be. 22 In other words, it's from the horizon it's 23 supposed to be. () 24 And back in September, 1984, as part of this 25 trip that we took where we identify the vein deposits, the l ACE FEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
200
-s 1 NRC also visited the core library. And at the time noted 2 that there appeared to be some difficulties with core 3 handling procedures and documentation of custody of the core 4 from the time that it was drilled to the time where you can 5 see it now in these boxes. And there is much that has been 6 discovered since that time about this.
7 We have had quality assurance personnel and 8 geology personnel interacting with the DOE on this crucial 9 problem, because they need to know as they go into site 10 characterization whether that core is any good or whether 11 they are going to have to drill more holes to have useable 12 material for their experiments. 13 At the current time, after an exchange of 14 letters and these visits that we have taken out there, the 15 U.S. Geological Survey is currently revising their 16 procedures and attempting to tighten up things so that any 17 future core at least will be useable. 18 They are also attempting to establish the 19 pedestrian agree of the core that they already have, but l 20 this is a difficult job. 1 21 Obviously, this core has been collected over 22 the last eight or nine years, and so they are going back 23 through the records and attempting to establish the t's
/ 24 usability of all or part of that core f or licensing purposes
(/ 25 for these experiments that will produce licensing-worthy ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
201 1 data. 2 All right. 3 MR. CARTER: Do you have to have legal 4 accountability in this sort of thing, traceability, or 5 whatever the correct terminology is, say for cores? 6 MR. STABLEIN: I am not an expert on whether 7 you have to have legal traceability. It's been established 8 that they have got to have a well documented record of 9 traceability. 10 And I don't know if that comes up to legal 11 accountability or not. 12 MR. LINEHAN: It's, ideally you need from a ( 13 legal standpoint the traceability. If you don't have it, 14 then less weight will be given to the information from that 15 core in the licensing proceeding. 16 You know, also you can correlate it with 17 something else. If you can back fit, establish the pedigree 18 through backfitting. 19 MR. CARTER: So it's flexible in terms -- 20 MR. LINEHAN: Yes. 21 MR. MARK: This is really very strange and very 22 stupid. That place has been drilled since 1950 over and 23 over, here and there and everywhere, more drilled than () 24 probably anyplace else in the country. ( 25 And everybody knows where the water table is l
- l ACE FEDERAL REPORTERS, INC.
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202 j f 1 here, there, everywhere else. 2 And you, because of QA, need more 3 documentation. 4 MR. LINEHAN: I think if you look at the test 5 site as a whole, you know, that is true. But when you look 6 at the area they are talking about and the particular 7 formation -- 8 MR. MARK: Yucca Mountain, specifically. 9 MR. LINEHAN: Yes. 10 MR. MARK: I am of course thinking of Yucca 11 Plats. 12 MR. LINEHAN: Right. But, you know, there is 13 very little data on Yucca Mountain except what we are 14 talking about right now that has been specifically obtained. 15 Again, if they can correlate it with other 16 data, then they can provide a pedigree for that core. 17 MR. MARK: Fine. 18 MR. ORTH: Do you know if anybody is actively 19 trying to match horizons now with all of this stuff that has 20 been drilled over these years? 21 MR. STABLEIN: W'e believe, but I can't 22 guarantee that that sort of exercise is going on currently 23 with the USGS and the Department of Energy as part of what () 24 they are doing to try to recoup the situation. 25 MS. ABRAMS : Some of these same units that they ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
203 ,- 1 are looking at at Yucca Mountain aren't present over in the s 2 Yucca Plat area. So it's very difficult to correlate. 3 DR. PARRY: Was this part of the reason for the 4 stop work order to USGS? 5 MR. STABLEIN: This was a contributing factor. 3 6 The stop work-order actually originated as a result of an 7 NNW site audit at USGS, of their whole program. 8 This was initiated prior to that, but I think 9 it provided quite a bit of impetus for that. 10 Would you say that is fair? 11 MR. LINEHAN: Yes, I think so. And it's not 12 that we are just hung up on, you know, a procedural thing. p 's > 13 The situation our people observed when they went out there 14 was people were removing pieces of the core, as I understand 15 it and there wasn't control over what was going out. You 16 know, there are some real questions as to what you have got 17 there. 18 It's not just a procedural hang up where they 19 have a nice, neat core but they don't have the specific 20 documentation we want. 21 MR. STABLEIN: That's correct. Sometimes you 22 will find boxes with half of the pieces of core gone and all 23 that is lef t is a crumpled piece of paper with a handwritten (/~ ) 24 ncte, "Los Alamos, 8 -7 7 . " \__/ 25 MR. CARTER: This is the reason for the ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
P' 204 73 1 question about the legal traceability, because obviously ( i 2 with the labs doing this the technical or scientific people 3 had their particular needs I suspect and my guess is they 4 aren't aware of these problems, or weren't. 5 MR. STABLEIN: They weren't. 6 MR. LINEHAN: They weren't. 7 MR. STABLEIN: Over the several years, right. 8 DR. STEINDLER: They are now. 9 MR. CARTER: Yes. 10 MR. STABLEIN: The next selected issue is the 11 ground water flow path and travel time. The key thing that 12 I think I'd like to just mention for you here is that there p kJ 13 is some controversy about how the water proceeds through the 14 unsaturated zone to the saturated zone and then to the 15 accessible environment. It makes a big difference in terms 16 of the travel time, you know. The estimated travel time is 17 many thousands of years. 18 If you go with the conceptual model that the 19 DOE is currently invoking, which is almost entirely matrix 20 flow, the water, I think John Bradbury was talking to you a 21 little bit about this this morning, the water can percolate 22 through the matrix through the pores of the rock. 23 And at Yucca Mountain going through those t8 24 tuffs, particularly the welded tuffs, water that works its t (a) 25 way through that way is going to take a long time to get I l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
205 1 down to the water table. 7-V 2 However, I mentioned today that those rocks are 3 highly f ractured. And if the water is running down the 4 fractures, it is conceivable that the travel time would be 5 greatly reduced. 6 So this is a matter which we have raised with 7 the DOE in several data reviews and meetings, and is being 8 pursued. We are attempting to set up a geology / hydrology 9 meeting at some point with the DOE to consider their plans 10 by which they will ascertain exactly what is going on with 11 the type of flow at Yucca Mountain. 1 12 MR. MARK: When you say " greatly reduced," you ! l s/ 13 referred earlier to thousands of years? 14 MR. STABLEIN: Yes. l - 15 MR. MARK: Do you mean reduced to a few years, 16 a few thousand? 17 MR. STABLEIN: If all the water during a rain 18 storm were to charge down fractures, it could be reduced, if 19 I am correct in the way I recall it, it would be reduced to 20 like tens to hundreds of years in the extreme case. 21 Now I don't want to even suggest that we have 22 in any way determined that to be the case. We are calling 23 attention to the possibility of considerable fracture flow () 24 and reduced ground water travel time at the site. It's 25 something that the DOE needs to consider in site ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
. . - . . . . _ = . . . . -- - - . .
206 1 characterization. -7 2 MR. MARK: All right. 3 MR. STABLEIN: But it could cause a substantial 4 reduction. 5 MR. MARK: I was just asking, and your 6 substantial in this case means a factor of ten. 7 MR. STABLEIN: Could be. 8 MR. MARK: Or perhaps even more? 9 MR. STABLEIN: Yes. 10 Does that seem like an exaggeration from your 11 reading of the materials? 12 MS. ABRAMS : Well, somewhat. But we have to 13 consider everything. i j 14 I think another concern is that what would 15 fault activity do to ground water travel time if you had 16 movement on the fault? It might only temporarily alter f 17 travel time, but you would still have that factor to l 18 consider. 19 MR. MARK: I know it isn't in the area that you-l 20 are examining, but you are familiar, I am sure, with the, I 21 think it's called Camrick work? I l 22 MS. ABRAMS : Yes, I know what you are talking 23 about. 24 MR. MARK: Where they pump water f rom one place
- 25 to another, must know something, or something to be deduced i
ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
2 07 l' about -- p, k-) 2 MS . AB RAMS : Yes they did geochemical studies 4 3 with the water. 4 MR. MARK: Yes. 5 MS. ABRAMS: I am not familiar with -- but I am 6 f amiliar with the fact it was done. 7 MR. STABLEIN: Maybe that is something we 8 should look into. One of our other staff members is looking
! 9 into that work, who is not here today.
10 MR. MARK: It had specifically to do with radio 11 nuclides through tuff, below the water table. 12 MR. STABLEIN: Linda Povotch is apparently one ( 13 of the people working on that. i 14 The next issue is one that you probably have - 15 talked about enough. It's the retardation of radioactive ! 16 nuclides. I have mentioned the Calico Hills as being a i 17 zealatized unit that the DOE hopes will retard the 18 radioactive nuclides. 19 But we have raised questions and in fact intend 20 to have a meeting with the DOE to raise some of the concerns 21 that you were talking about this morning, that their 22 experiments may not mirror what is actually going on in the 23 actual situation. 24 f They have been primarily doing those batch 25 experiments, and you have discussed the difficulties with i ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
, 208 < 1 those, John discussed'those with you.
- o' 2 They also are relying as he mentioned on matrix i 3 diffusion and he indicated some doubts we have as to the 4
4 efficacy of that. 5 The sixth one is items needing resolution prior 3 6 to exploratory shaft construction. On this one, Dave, if i i 7 you want to, you know, you can chime in on this. i 8 The history on this one is that in 1983 we sent 9 the DOE all the sites a letter in which we outlined our . 10 concerns about what needed to be done prior to starting i 11 sinking of the exploratory shaft. l i i= 12 And the concerns centered around possibly i 13 compromising the site when you put a shaf t.in there that in l 14 this case is going to be a 12-foot diameter shaft for the l 15 one shaf t and six or 12 for the second shaf t. i l 16 And, secondly, to ensure that the shaft will i 17 allow for adequate testing of the site. And we then went on 18 to detail several concerns under those points. 19 The DOE responded to us with a letter and with 20 a performance analysis which purported to demonstrate tr.at i j 21 the sinking of the shaf t would not produce any difficulties
- 22 relative to public health and safety.
f 23 In other words, that any damage zone that they f 24 would create by sinking the shaft would not lead to release i 25 of radioactive nuclides later on or create new pathways or l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
r 209
. 1 the like.
2 We held a meeting last August and we did come 3 to agreement with the DOE as far as the method of sinking 4 the shaft, drill and blasting. We did agree on that point, 5 which represes."Ae significant progress. 6 However, there remained several open items 7 before we and the DOE are agreed that they can begin sinking 8 the shaft. 9 The DOE is re-doing their performance analysis. 10 That is supposed to come to us in October. They have 11 proposed and we are inclined to agree to at least two 12 meetings so that when they stand ready to begin sinking that 13 shaft, they can do so without the fear that we are going to 14 have to come along and say, sorry, it was a mistake, and you 15 have got to put a stop to it or start over. 16 I just want to see if Dave has anything he 1 17 wants to add to that because this is his area. 18 MR. TIKTINSKY: No, I think as a general 19 overview you have pretty much got it unless there are any 20 specific questions. 21 MR. ORTH: I have a specific question. 22 What if anything was DOE planning to do that 23 would have or could have made you say, forget drilling that 24 shaft? 25 MR. TIKTINSKY: One of the things they could ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
m 210 1 have done, if they -- 2 MR. ORTH: Were planning to do. You talked 3 about a meeting with them. 4 MR. TIKTINSKY: Well, the meeting that we had 5 back last year was to discuss their response to our original 6 letter. So their performance analyses that they had put in 7 there basically, they did a study that said if we did 8 absolutely nothing and just lef t the shaf ts open and let any 9 water that would come in there just flow into the shaf t, 10 then it would have, it would still have no effect on 11 radionuclide release. This was their argument they were 12 trying to make. 13 MR. ORTH: We are talking about sinking the
- 14 shaft, not whether they sealed it up. What was it they were 15 proposing to do while sinking the shaf t that would have made 5
16 you say, don't' sink the shaft that way? 17 MR. STABLEIN: What about the method of j 18 excavation? 19 MR. TIKTINSKY: Two methoda, one would be blind 20 boring which uses a lot of drilling mud and hydrologists 21 have said -- they have lost a lot of different water and 22 fluid on the small holes. Had they gone by blind boring, l l 23 they probably would have introduced a large amount of fluid ( 24 into the different horizons and possibly messed up any 25 possibility of doing the hydrological testing if they had l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
211
- 1 chosen blind boring.
2 Instead they went for conventional drill 3 blasting, which does does not introduce much water and 4 should not affect the hydrological testing.
5 MR. ORTH: But that was only testing and had 6 nothing to do with the ch:f t itself and wh$ther the shaf t, 7 something they did during construction would have imperiled 8 the repository? 9 MR. TIKTINSKY: Just construction construction 10 of the shaf t, that water would have imperiled the ability to 11 test the repository. 12 MR. STABLEIN: You mean the properties for 13 isolation? 14 MR. ORTH: I understand what you are saying. 15 MR. STABLEIN: I am not sure we are getting our 16 concerns across. We still have these concerns relative to 17 the shaf t, itself, in that they believe that sinking that 18 shaf t doesn' t have to be quality level, quality assurance 19 level 1. 20 They believe that since it's not going to 21 create present or future problems for public health and 22 safety, they don't need to have the NRC, is what they are 23 basically saying, oversee construction of the shaf t. () 24 At the present time we don't agree. We think l 25 that they could create enough damage and problems in sinking l l r ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
212 1 the shaft that it needs to be watched over. 2 DR. STEINDLER: Do you have an estimate as to 3 the diff erence in both time and money ' caused by a shif t f rom 4 quality level 1 to quality level 2 for that shaf t? 5 MR. STABLEIN: I really don' t. G DR. STEINDLER: I think somebody needs to take 7 a very hard look at that before you lay on DOE quality level 8 1 exercise where there is some reasonable doubt, at least in 9 one party's mind, I assume, that that whole thing is going 10 to pay off. 11 There is enormous difference, as you well know. 12 And I would guess you can get various kind of estimates on 13 the factors used in increasing cost and the time it takes to 14 run that system on quality level 1. 15 MR. STABLEIN: I think that is a valid point, 16 and we are attempting to take a balanced view of it. And 17 they may be able to come back with a performance analysis
- 18 that puts our doubts to rest.
I l 19 But their first one, we layed out certain 20 concerns that they hadn't dealt with yet. 21 MR. TIKTINSKY: Also quality assurance level 1 22 for this case, if it's not something that caused a lot of 23 damage, may not be very strict. It may be nothing more than 24 just making sure when they put lining it it just meets the 25 minimum requirements. , ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
213
- 1 It doesn't have to mean they have to put 3-foot U 2 concrete or something like that. Just good, standard 3 practice.
4 What they originally plan to do, they say we 5 will follow conventional shaft, good construction methods 6 which could mean some areas will have very large amounts of l 7 blast damage and they may not even know it were there, where 8 if they followed controlled blasting or something about the 9 quality level 1, at least even if the damage doesn't make 10 any difference, at least they will know what is there. 11 DR. STEINDLER: I understand the difference 12 between QA level 1 and QA level 2. Maybe not in the area of 13 drilling shafts, but that is not my game. 14 All I am saying is that I think you need to 15 look at the differences as they impinge on schedule and 16 cost. I think they will end up to be very large. I realize 17 you don't need Concorde. That is not the issue. The issue 18 is the QA aspect, not -- 19 MR. MARK: I believe you spoke of a 12-foot 20 shaft? 21 DR. MOELLER: Yes. 22 MR. MARK: Why not 12-inch? 23 MR. TIKTINSKY: The materials can't get down 24 that shaft. 25 MR. MARK: You can find out everything you need ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
214 1 to know about geological lay years in 12 inches. 2 MR. ORTH: This is the'one for the -- 3 MR. CARTER: This is the work shaf t. 4 MR. MARK: But why is the NRC involved with 5 working the rock? They want to know where the rock is, 6 where things go and -- for finding out what it takes to make 6 7 a structure where people can live and work you need 8 something bigger than 12 inches, yes. Why is NRC involved 9 in that? 10 Why not turn it over to OSHA? 11 MR. TIKTINSKY: It not just safety. You have i 12 to go down and get representative values. If they go down l') (- 13 and just take a core sample and base everything on that, 14 that may be true for that very small sample. 15 But if you try and model large block behavior, 16 take into account discontinue new which tease, thermal j 17 mechanical behavior, hydrological behavior, all kinds of l l 18 tests need to be run. 19 To try to examine an area 12 miles by one mile l 20 wide approximately, you need to get a reasonable amount of 21 representative values for the key parameters throughout the 22 repository.
- 23 MR. MARK
- You still don't do that from 12 24 feet. All you learn f rom 12 feet is whether the f all caves 25 in or not.
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215 1 DR. STEINDLER: Carson, the 12 foot is just to I) 2 be able to get a piece of gear down into the repository 3 horizon to begin to drill the drifts. 4 MR. MARK: So it's not a 12-foot shaf t, it's a 5 shaft from which you can run side -- 6 DR. STEINDLER: Yes. 7 MR. MARK: For that you need -- 8 DR. STEINDLER: You need to be able to get 9 equipment down there, and I guess 12 feet as round a 10 number -- 11 MR. MARK: It's to explore how you work when 12 you are down there? 13 MR. TIKTINSKY: It's to gain access to the 14 horizon from the test facility. 15 Also as you are going down you can learn a lot 16 of things about the different rock layers that are above -- 17 MR. MARK: That is what I was saying. You can 18 learn that from a 12-inch hole, everything you need to know 19 about the rock layers. 20 MR. TIKTINSKY: But you can't learn anything 21 about the horizon. 22 MR. MARK: You can't work in the horizon, that 23 is true. 24 So it's a 12-foot shaft in order to do some 25 borings down at the, what, 2,000 foot level? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
216 1 MR. STABLEIN: I think their target is 1200 O'
'~
2 foot level. 3 MR. TIKTINSKY: Yes. 4 MR. MARK: I have had the feeling, not only 5 from today, but earlier, that the NRC is expressing an 6 interest in whether it is safe to work there, whether the 7 roof falls in or not, those things don't belong in NRC at 8 all. 9 DR. MOELLER: Right. But they are mainly 10 interested in avoiding any compromise of the facility due to 11 sloppiness, that is perhaps the wrong word, but improper 12 drilling of this 12-foot hole. (O/ 13 Like he was saying, they propose using, or 14 should they propose using the mud drilling technique, they 15 would introduce a lot of water, I presume, into the various 16 levels. And this would compromise later tests. 17 MR. MARK: I halfway understand that. It would 18 introduce so much water, it would reach out two or three 19 feet. 20 MR. TIKTINSKY: There may be a lot more than 21 two or three feet. One of the small bore holes they have 22 done they found, I think it showed up in one of their other 23 bore holes they drilled. This is from, one is annex 2, two O
/ 24 and an eighth inch core?
/
25 MS. ABRAMS: I am not sure. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
217 1 MR. TIKTINSKY: Very large amounts of fluid 2 loss in even a small hole. 3 DR. MOELLER: How much is large amounts, . 4 thousands of gallons? 5 MR. TIKTINSKY: I think they had it in barrels. 6 I think it was of the order of a million barrels. 7 DR. MOELLER: That would be a lot. 8 MR. MARK: That is millions of dollars, too. 9 DR. MOELLER: Okay, go ahead. 10 MR. STABLEIN: The final issue I would like to 11 bring to your attention today is susceptibility of waste 12 package materials te corrosion. O) (. 13 In this connection I neglected to mention when 14 we talked about those vein deposits and the problems 1 15 associated with the hydrothermal origin, and it ties into 16 the corrosion problem, DOE needs to consider the waste 17 package environment. 18 If the environment includes these very high 19 temperature fluids, which can be very corrosive to a 20 package, or the cannister, this could enhance a prob 1cm 21 which we have already called to the DOE's attention in the 22 waste package meeting last July and two years before that in , 23 which we have called into question the advisability of 24 leaning so heavily in their testing on austenitic stainless f 25 steel, which has a history as I understand it in the ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
218 1 literature developing nonuniform corrosion. O 2 We have been encouraging them to at least look 7 3 at the other material they are testing at an alloy called , 4 incolay.
; 5 DR. STEINDLER: Where are they going to get-6 high temperature liquid?
7 MR. STABLEIN: The second issue I brought to 8 your attention were the vein deposits in the trenches. If 9 they are created by hydrothermal fluids coming up f rom i 10 below, they could be at temperatures greater than a hundred 1 11 degrees C. j 12 DR. STEINDLER: How? You have no hydrostatic 13 head, you are basically at one atmosphere pressure, i 14 furthermore, you are at 4,000 feet. 15 So the boiling point of water at that 16 temperature, altitude, is 90 C, whatever? That is the 17 maximum temperature. 18 MR. STABLEIN: It's the same sort of mechanisms 19 you have that allows for volcanic activity and movement of 20 lava upward. In fact, this water could be heated by a magma 21 chamber below. 22 DR. STEINDLER: Okay. 23 MR. STABLEIN: Then rise toward the surface or f 24 be impelled toward the surface. 25 DR. STEINDLER: I am sorry, I don't follow that i ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
219 1 at all. 4 2 I mean, I may agree with you that they have to 3 look at something other than austenitic stainless, but I 4 don't understand a mechanism that says the system open to 4 5 the atmosphere at about 4,000 feet above sea level, that you , 6 are going to get water at high temperature, especially in an a l 7 unsaturated system. i 8 MR. STABLEIN: I haven't made it clear. I am 9 sorry, I just haven't made it clear what the postulated 4 10 model would be in the subsurface. 11 There is indication there'could be magam
- 12 chamber below the area, there have been recent indications
( 13 of volcanic activity, higher ~ temperatures in some of the 14 bore holes, that things are already much hotter than you 15 would expect in the subsurface. The hot waters would come 16 f rom down below, not from out the surface. 17 DR. STEINDLER: I am not suggesting'you can't j 18 get hot water. Surely, you can get hot water under 19 pressure. 20 But as soon as you hit the repository horizon, 21 however you got there, you are going to be at atmospheric. 1 22 It is an unsaturated area, direct line to the surface. You i j 23 are 300 meters, 200 down below, I will grant you the 200 f 24 difference in head. j 25 But that simply raises the boiling point a i I,
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I 220 l l
- 1. couple degrees C. I don't think you are there.
O O 2 MR. STABLEIN: You don't think it can happen. 3 I am not a great one -- 4 DR. STEINDLER: I am not saying I don't think 5 it can happen. I just don't understand the rationale. 6 Nevada has said from day one. 7 If you challenge the fact they are at 8 ' atmospheric pressure, we have a different argument. But 9 Nevada has said from day one. 10 They are at atmospheric and X hundred meters 11 above the liquid ground-water system. 12 MR. STABLEIN: Right. 13 DR. STEINDLER: If you challenge one of those, 14 we have a different discussion. 15 But I don't see how you can insist we get 16 liquid water at high temperatures attacking their stainless 17 steel or whatever it is they are using. 18 MS. AB RAMS : If I understand you right, there
-19 is a potential for these hydrothermal zones, if these veins 20 do in fact turn out to be hydrothermal.
21 So you are pumping these hot waters up, and 22 they would be at boiling point when they reached the 23 surface. () 24 DR. STEINDLER: Okay. 25 MS. ABRAMS: And our concern is just that with ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
221 1 waters at this temperature, how would they affect the waste O 2 canister if they contacted -- 3 DR. STEINDLER: The question it seems to me you 4 should be asking is what is the corrosion rate of austenitic 5 stainless steel and steam of condensation to be determined 6 by flashing off whatever the junk is that comes up out of 7 there, which clearly isn't distilled water. It's going to 8 have HF in it, fluorides in it, because there are fluorides 9 in the ground-water. 10 But I don't think you can get liquid water in 11 that system, as I understand it. 12 MS. AB RAMS : There -- ( 13 DR. STEINDLER: This is not an issue we can 14 settle here. I am just raising the point. You are asking 15 to do the right thing, but maybe for the wrong reason. 16 I think the problem with austenitic stainless 17 steals are they indeed have significant forms of corrosion 18 other than uniform corrosion, and this that is particularly 19 sensitive at the closures, where they either weld or screw 20 it shut or whatever. They are subject to corrosion 8 21 mechanisms that are difficult to extrapolate for at least a 22 thousand years. 23 MR. STABLEIN: Right. When they raised, when () 24 we raised this the focus was strictly austenitic stainless 25 steels. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
222 1 I wanted to harken back to the silica -- their 2 significance with the stainless canisters. It's going to be 3 difficult if not physically impossible to move the water to 4 the repository horizon and bring it in contact with the 5 canisters. 6 MR. STEINDLER: Those turn out by however you 7 do it, temperature measurements, turn out to be deposited at 8 high temperatures. You and USGS will have to try and 9 explain their relationship to a system that is open to the 10 atmosphere. 11 At least I would assume that that is where you 12 are going to get challenged by the applicant, who will read 13 you the standard laws of chemistry. 14 MR. STABLEIN: Right. 15 DR. STEINDLER: And say, " Hey, fellows." USGS has done a number of studies 16 MS. ABRAMS: 17 on vein deposits and active systems in that area, so they 1 i 18 have been looking at it. In some of these, as you said, the i 19 boiling point is below the surface where the waters actually l 20 reach. 21 DR. STEINDLER: Yes. 22 MR. STABLEIN: Any other comments on these 23 issues? 24 The last slide that I had to put up simply is 25 very brief. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
223 1 ( Slide . ) 2 MR. STABLEIN: A very brief statement in terms 3 of where the project is in terms of the release of the final 4 EA which we are now reviewing. You are going to hear about 5 the status of that review this af ternoon f or all of the 6 sites. 7 Release of the site characterization plan is
- 8 still scheduled for December of this year, and the plan to 9 start construction of the exploratory shaf t, May, next year, t
10 giving us a five-month comment period for the site 11 characterization analysis to be written.
, 12 DR. STEINDLER: Do these people have to get I 13 your concurrence on the site characterization plan before 14 they can otart their exploratory abaft?
15 MR. LINEHAN: They have to consider our 16 comments on the site characterization plan. 17 We will be preparing what we are calling a site i ) 18 characterization analysis based on the plan, and the i ! 19 regulations require they consider those comments, yes. I I 20 DR. STEINDLER: Do you have a formalized 21 process whereby the exploratory shaf t is approved, okayed, 22 or the start of it is authorized?
- 23 I mean, what is the role of the NRC?
24 MR. LINEHAN: There is no formal approval . 4 25 DR. STEINDLER: No formal approval ? 1 ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700 .
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224 i 1 MR. LINEHAN: No. ! 2 MR. STABLEIN: I think cur intent on that is
- 3 that these meetings we have to resolve those open items that i 4 I have referred to before is the process that we are
- 5 planning on to ensure that everything is all right before i
6 they go ahead with it. 7 DR. MOELLER: Why at Hanford were they holding 8 up f or so many years the drilling of the .shaf t, if no i
; 9 approval is required?
10 MR. LINEHAN: I don't know the history going l 11 back several years, but when the act was passed, what the ) 12 act layed'out was that they had to prepare the site 13 characterization plan before they could go ahead with the 14 shaf t. i l 15 DR. PARRY: Actually, just before the_act was i i 16 passed, they were, I would hate to say rushing, but they i 17 were working very hard. They had a drilling rig in place. i
- 18 The rig base is in place, it's set, I guess they are down a_
19 couple of hundred feet. 3
; 20 And the rig has been there, or had been there 21 for two or three years under rent, or purchased, I forget, f
1 22 now. And I think they, DOE, was warned not to start just i before the act was passed. 23 24 DR. MOELLER: I see. l 25 DR. PARRY: They felt there would be an i
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225 i 1 appearance of an unfortunate nature. O 2 MR. ORTH: They were told not to. 3 DR. MOELLER: Well, have they drilled now? 4 Will Nevada drill before Hanford? 5 MR. LINEH AN : It depends on when the site 6 characterization plans come in. I think the current 7 schedule calls for them both to submit their SEP's in 8 December of this year, and then start the exploratory 9 shafts, I believe it's six months after the SEP. 10 DR. MOELLER: Any other questions or comments? 11 Thank you, Charlotte and King. 12 MR. STABLEIN: Thank you. 13 MS. ABRAMS: Thank you. 14 DR. MOELLER: We will move then immediately on 15 to the next topic, which I gather now is the status report 16 on the review of the final environmental assessment. 17 MR. LINEHAN: That's correct. This 18 presentation is going to be given by Robert Johnson, Acting 19 Section Leader of the Reposits Section within the Repository 20 Branch. 21 MR. JOHNSON: Good afternoon. As John 9 22 indicated, I would like to give a brief description to you 23 this afternoon of our plans to review the final environmental assessments. ( 24 25 ( Slide . ) ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
226 1 MR. JOHNSON: What I have done is divide my 2 talk up into four basic parts. 3 DR. MOELLER: Could you ref resh my memory on 4 the environmental assessment versus the site 5 characterization? 6 MR. JOHNSON: Versus the site characterization 7 plan? 8 DR. MO ELLER: Well, we have a site 9 characterization plan, a site characterization analysis, and 10 an environmental assessment. 11 Is there an inter-relation between the 12 assessment and the plan? A (/ 13 MR. JOHNSON: They are different. The 14 environmental assessments, as I will mention later on, 15 support the decisions that DOE has made recently on-site 16 nomination and site recommendation. 17 DR. MOELLER: Okay. 18 MR. JOHNSON: Those decisions precede site 19 characterization. They trigger site characterization. 20 DR. MOELLER: That refreshes my memory. 21 MR. JOHNSON: Okay. 22 MR. MARK: The environmental assessment will 23 include such things as the Indian tribes and the air quality 24 ( and stuff like that, or is it, does it only look at the 25 rocks? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
2 27 1 MR. JOHNSON: Environmental assessments cover a 2 full range of technical stop picks all the way from the 3 geo-technical concerns that are closer to concerns in 10 CFR 4 60. 5 But they also include the environment and 6 socio-economic concerns, cultural, archeological concerns 7 that relate to eventually the environmental impact 8 statements. 9 MR. MARK: Also, all the site characterization 10 features. 11 MR. JOHNSON: It includes site characterization 12 features. It includes technical questions that would be 13 addressed by site characterization. , 14 DR. MOELLER: But the environmental assessment 15 is part of the decision process which leads to a full site 16 characterization? 17 MR. JOHNSON: That's right. It precedes site 18 characterization and triggers site characterization. 19 DR. MOELLER: Right. 20 MR. JOHNSON: DOE's decision to recommend 21 three sites is a decision to begin characterization at those 22 three sites and identifies those sites that they will 23 proceed the site characterization on. () 24 MR. MARK: That could only be done after the j 25 environmental assessment? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
228 g 1 MR. JOHNSON: That's ri ght, yes. 2 MR. MARK: Thank you. 3 MR. JOHNSON: I will go over this a little bit 4 more in the moment. 5 But the four parts of my presentation this 6 af ternoon are to give you a brief overview of the draf t EA 7 review and also to orient you a little bit to some of the 8 points we have already mentioned in the decision-making 9 process. 10 Secondly, I will summarize our review plan for
, 11 the final EA's, and I will describe some of the review 12 preparations for our review.
13 And then I will conclude with the current 14 status of our review at this point in time. 15 (Slide.) 16 MR. JOHNSON: Before I discuss our current 17 review, I'd like to give this brief background on the EA's 18 and the site selection process. 19 As you may be aware, the Nuclear Waste Policy Act 20 established a process for selecting sites for the disposal , 21 of spent fuel and high level waste in geologic repositories.
- 22 As I mentioned before, some of the key steps in l
23 this decision process included the DOE's development and 24 NRC's concurrence on siting guidelines. 25 Another key step was the nomination of at least ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
229 7\ 1 five sites suitable for characterization. Then another step U 2 would be the recommendation of these three sites for 3 characterization. 4 Environmental assessments support this site 5 selection process as required by the Nuclear Waste Policy 6 Act. 7 Actually, th'e nomination of the five sites, 8 that decision has to be accompanied by the final 9 environmental assessments, and these environmental 10 assessments therefore are the basis for this nomination 11 decision. 12 Furthermore, much of the information in the 13 environmental assessments also are the basis for the 14 recommendation decision. 15 Back in December of 1984, DOE issued nine draft 16 environmental assessments. The EA's, as I will refer to 17 them now, consisted of descriptive information on the site 18 selection process, contained a great deal of site 19 information and data and also referenced much of this 20 information.
- 21 It described site characterization activities 22 and the expected effects of these activities.
- 23 It described the repository and also the
() 24 regional and local effects of the repository. This includes 25 environmental effects, but also effects that will get into 1 ACE FEDERAL REPORTERS, INC. . - .-._- . Washington, D.C. (202) 347-3700
230 I waste isolation. 2 It also described the suitability of a site in 3 terms of the siting guidelines that NRC concurred on. 4 And lastly, it compared the sites. 10 5 The draf t EA's concluded, or they identified 6 the preferred sites for characterization as the Deaf Smith 7 site in Texas, Hanford site in Washington and the Yucca 8 Mountain site in Nevada. The other sites that were proposed 9 for nomination included Davis Canyon in Utah and Richton 10 Dome in Mississippi. 11 I have included in your package in the next 12 page a map just for your quick reference to locate these 13 sites. I won't go into any more descriptive information 14 about their locations at this point. 15 (Slide.) 16 MR. JOHNSON: NRC reviewed and issued comments I 17 on all draft EA's in March, '85. NRC's comments consisted 18 of for each site about ten to 14 major comments. Also, we 19 had about a hundred to 200 detailed comments for each of the 20 sites. 21 (Slide.) 22 DR. MOELLER: Did the ten to 14 major comments 23 just come out that way, or did you seek to have it that () 24 range, ten to 147 25 MR. JOHNSON: No, I think they just kind of ACE PEDERAL 1EPORTERS, INC. Washington, D.C. (202) 347-3700
231 1 shook out that way. We had a feeling for what was a major O 2 comment related to, maybe how a concern might affect a 3 finding, particular finding. 4 As you will see on another slide there are 5 topics that are different for each. So it's not that we had 6 the same comment for all the sites and, therefore, leading 7 to the same number. 8 There were different comments that were made 9 for the sites, and it just came out sort of this way. 10 DR. MOELLER: Fine. 11 MR. JOHNSON: Our general conclusions -- 12 MR. MARK: As an example -- 13 DR. MOELLER: We have a question. 14 MR. JOHNSON: Excuse me. 15 MR. MARK: As an example, in your major 16 comments, presumably, you compared Davis Canyon with 17 Lavender Canyon or Richton Dome with Cyprus Dome. 18 What were the kind of comments that 19 distinguished those? They are very close together, they are 20 in the same geology. At least two of them were in one 21 geology and two are in another. 22 What kind of comment did you make when you 23 looked at Richton Dome vis-a-vis Cyprus Dome? 24 MR. JOi!NSON: The major comments, and I think 25 probably most of the detailed comments were the same for ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
232 1 these domes, as well as the other example you mentioned, O~ 2 Davis Canyon, Lavender Canyon. Those two sites are about 3 four or five miles apart. 4 As you said, they are in the same area. Given 5 the sparse amount of data that exists for those sites, there 6 isn't that much that you can say that would distinguish the 7 two. 8 I think with respect to the domes, Richton and 9 Vacherie Dome are much different in size and some of the 10 otructural characteristics surrounding the dome. So there 11 was more difference in those two domes from the evidence 12 that we had, but it didn't really change our comments that 13 much. 14 Our comments with respect to the salt domes 15 were quite similar or identical. What I was referring to 16 before is that there were differences in our major comments 17 amongst the difference medium, like Hanford versus Yucca 18 Mountain versus Deaf Smith. 19 MR. MARK: I could easily picture differences 20 there. 21 MR. JOIINSON: Right. 22 MR. MARK: More easily than between Lavender 23 Canyon and Davis Canyon. () 24 MR. JO!!NSON: Absolutely. 25 DR. MOELLER: I gather now the siten you ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
233 1 rejected, not you, but DOE rejected, were those for which 7s h 2 you had the least data, or for which DOE had the least data, 3 is that true? 4 MR. JOHNSON: Well, DOE -- 5 DR. MOELLER: I gather there was sufficient 6 data to show that those sites were not as good as the first 7 three. 8 MR. JOHNSON: That was not the basis for their 9 decision. They used the available evidence at all the sites 10 to make findings against the guideli.nes and come up with 11 their decisions as to which sites were preferred, based on 12 the available evidence that they had. 13 And any assumptions, conservative assumptions 4 14 that they might have to make in the absence of data. So 15 there was not a part in the decision-making process that 16 drew upon a lack of data as a factor in the ranking or 17 selection of sites. 18 DR. MOELLER: I see. 1 19 MR. JOHNSON: That has been something that 20 people brought up, of course. The Deaf Smith site, you 21 know, also, doesn't have as much data as let's say Hanford 22 or Yucca Mountain, but they had enough evidence that they 23 could make the findings they did. 24 DR. MOELLER: I see. I 25 MR. JOHNSON: The general conclusions we drew
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234 t 1
. 1 f rom our review of the draf t EA's was that no disqualifying 1 Q,f 3 2 condition was clearly present and no qualifying conditions 3 clearly absent for any of the sites that we reviewed in the 4 draft EA's.
- 5 Just for a little background here, the 6 guidelines that DOE developed and NRC concurred on in 10 CFR 7 960 identifies a number of disqualifying, qualifying, 8 f avorable and potentially adverse conditions f or the 9 guidelines.
10 In the EA's DOE came up with findings with 11 respect to these various conditions. So since the j 12 disqualifying and qualifying are so for -- we did find that
! 13 we had no disagreement with DOE on their conclusion here, 14 and we felt that was a significant conclusion to make, 15 because if either of those are present, then the site would 16 have dropped out.
17 Some other types concerns that we repeatedly i 18 observed in the EA's were that uncertanties and alternative 19 interpretations were of ten not considered to our i 20 satinfaction.
- 21 And also in some cases available information 22 was not considered. And we brought, that we brought to 23 DOE's attention.
24 We also have a number of major comments. I 25 have attached those, or I have put those into your package, 1 ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
' 235 1 a tchle just summarizing the topics of these major comments. , ) 2 I don't plan on going into any of these in detail, but I 3 just thought I would include it for your reference in this 4 package to give you a feel again for the types of topics 5 that we identified as major concerns and major comments in 6 our review of the draf t EA.
7 MR. CARTER: What about this available 8 information not considered? 1 9 I would think that would be a f airly 10 substantial issue, if there was much of it. 11 MR. JOHNSON: I am sorry? 12 MR. CARTER: The question is how significant, I (_ 13 guess, is the fact that they did not use the available 14 information, or did not consider the available information? 15 MR. JOHNSON: I think in some of the examplet 16 we used it was a matter of bringing it to their attention, 17 because the support for a particular finding was weak 18 because of them not considering certain pieces of 19 information. 20 So with this brought to their attention, you 21 know, it should improve their support for a particular 22 finding. Or possibly might have led to a change in a 23 particular finding. f 24 So that is what we asked them to do. We asked 25 them to consider our comments, whether they were related to, 4 ACE FEDERAL REPORTERS, INC. - - _ . Washington, D. C. (202) 347 _3700.-__,_
236 1 you know, new data or data we knew of that they didn't 2 consider, we asked them to consider that and revise their 3 findings'as appropriate or work it into their evaluation if 4 it supports their original finding. 5 So that is part of what we are reviewing now, 6 to see how well they responded to our major comments and can 7 we tell whether they considered this information or 8 uncertanties that we brought up to them. IIow well did they 9 consider those and to what extent were the findings changed 10 to reflect those changes. 11 MR. CARTER: All right. 12 DR. STEINDLER: Available information. You are 1 (/ 13 talking about the literature or stuff they had done 14 themselves? 15 MR. JOHNSON: This could be any source. It 16 could be oil field data, it could be literature, published 17 literature or information. It could be possibly even their 18 own data we couldn't tell them, reviewing the EA's, you 19 know, how they considered it in a particular evaluation on a 20 finding. 21 Well, following the comment period for the 22 draft EA's DOE revised the drafts based on over 20,000 23 comments received by a wide variety of interest groups, 24 state people, Indian tribes, NRC and ott.~. federal agencies. 25 On May 28,1986, DOE nominated five sites for ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
237 1 characterization. These are Davis Canyon, Deaf Smith, 7. 2 Hanford, Richton Dome and Yucca Mountain, in alphabetical 3 order. 4 And they also recommended three sites for 5 characterization. Those are Deaf Smith, Hanford, Yucca 6 Mountain. And they recommended these sites to the president 7 f or his approval and he did approve those three sites for 8 characterization. 9 (Slide.) 10 MR. JOHNSON: At the same time in May, they, 11 along with these decisions, issued the five final EA's. 12 They also issued a Decision 80 methodology document and a (_/ 13 recommendation document. 14 As I said before, the final EA's support the 15 nomination decision, and the Decision 80 methodology 12 16 document and recommendation document support their 17 recommendation of the three sites. Of course, they also 18 draw upon the FEA's as their data base for the 19 recommendations. 20 DR. MOELLER: And in the selection of the three 21 sites for characterization, this is where they went to the 22 National Academy of Sciences and asked for a review of their 23 procedures or methodology? 24 MR. JOHNSON: That's right. f 25 DR. MOELLER: And got or received concurrence, ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
238
,-- 1 as I recall.
f _.) 2 MR. JOHNSON: Yes, the Decision 80 methodology 3 document. 4 DR. MOELLER: Right. 5 MR. JOHNSON: This one here is what was 6 reviewed by the National Academy, both the methodology and 7 the application. 8 DR. MOELLER: Okay. 9 MR. MARK: Three sites have been under written 10 by the president without any particular preference? 11 MR. JOHNSON: That's right. They are 12 alphabetical, those three mark arc Deaf Smith, Hanford and (/ 13 Yucca. 14 MR. JOHNSON: That's right. 15 MR. MARK: Went through a full characterization 16 of each of those three? 17 MR. JOHNSON: That's correct. 18 MR. MARK: Before the next step? 19 MR. JOHNSON: That's right. 20 MR. MARK: A few hundred million at each place 21 and then decided we didn't need to because we were going to 22 use this one, anyway. 23 MR. JOHNSON: It's hard to predict now. 24 MR. MARK: Does the government own land in Deaf 25 Smith county, I thought it was all full of peanuts. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
239 ,s - 1 MR. JOHNSON: Excuse me.
~~'
2 MR. MARK: Does the government own a block of 3 land in Deaf Smith county? 4 MR. JOHNSON: No, it's all privately owned. 5 MR. MARK: As I said, I thought it was all 6 growing peanuts down there. 7 MR. JOHNSON: Among other things, sorghum, 8 corn, cattle. 9 MR. MARK: It does own the land in the other 10 two. 11 MR. JOHNSON: Federal government does, yes. 12 MR. MARK: Yucca and Hanford. Why can't they .f- w k_ 13 settle down and leave Deaf Smith alone? 14 MR. JOHNSON: Well, one of the items in the 15 final recommendation of sites was diversity of rock type. 16 That is required by the guidelines. l 17 MR. MARK: They are quite diverse, that is l 18 true. I know each site somewhat. 19 MR. LINEHAN: Not that this gives you 20 consolation, but it is basica21y what the act requires them 21 to do, to fully characterize at least three sites. 22 MR. MARK: Gee, I wish I owned a bit of land 23 down at Deaf Smith. 24 (Slide.) 25 MR. JOHNSON: With this amount of background in ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
240
~ 1 mind I would like to now summarize our review plans for the k_)s 2 final EA's.
3 We consider that our review is part of our 4 ongoing prelicensing consultation process with DOE. We 5 viewed the final EA's as we did the draft EA's, as 6 containing a number of evaluations, new evaluations and in 7 particular the final EA would contain current official DOE 8 positions, technical positions and conclusions, based of 9 course upon this extensive body of comment that they 10 received, including consideration of our own comments. 11 So we felt that this was an excellent benchmark ! 12 for us to look at what technical positions they were taking (O/ 13 in this document, and, therefore, giving us an opportunity 14 for us to identify early licensing issues again to identify 15 concerns we had with DOE's technical conclusions that might 16 eventually possibly become licensing issues. 17 So this is the spirit of our ongoing 18 prelicensing process, and as we see documents, particularly 19 important ones like this that represent DOE positions, then 20 it does give us this opportunity to identify potential 21 issues. 22 The second purpose of our review was to, or is 23 to inform the Commission of any major concerns that we have 24 with dough dose response to our major comments, or any major f 25 concerns we have of new information that might have been put ACE FEDERAL REPORTERS, INC. Washington, D.C. __ (202) 347-3700
241
- 1 into the final EA's.
("' ) 2 Now, let's look at some of the objectives of 3 our review. First would be to identify major concerns with 4 DOE responses to our major comments. 5 Again we are looking primarily at our major 6 comments and how DOE has responded and revised the EA's in 7 reaction to our major comments. 8 Secondly, we are looking for any major concerns 9 Sith new data and information, and thirdly, we will be 10 identifying any inconsistencies in the EA's and the other 11 documents with the siting guidelines. 12 To summarize, what our obj ectives really are is o lx/ ! 13 to identify major concerns with the technical information 13 14 that supports the site comparisons and the decisions that 15 DOE made. 16 In other words, we are interested in the 17 quality of the data supporting the decisions. 18 We will not review the Carson methodology. We 19 are only concerned with the technical data that is 20 supporting the comparisons and methodology. 21 ( Slide . ) 22 MR. JOHNSON: Now, the requirements of our 23 review will be treated in the following ways. Our major 24 comments will be sent to the Commission with a 25 recommendation f or any appropriate follow-up actions, if any ACE FEDERAL REPORTERS, INC. Washington, D.C. (20e 347-3700
242 7- 1 is needed. V 2 So they will be informed of the results of our 3 review, and we will recommend any actions, if any are 4 needed. 5 The second way of following up would be to 6 treat our major comments as open items. We would follow 7 these up with DOE through our normal prelicensing 8 interactions. 9 These types of interactions, of course, include 10 our technical meetings, include our technical meetings that 11 we are having all along and continue to have with them. 12 Other mechanisms include letters that we would write to them (_/ 13 highlighting specific technical concerns. 14 Also, we would f ollow up some of these items in 15 our SEP review and our development of our site 16 characterization analysis. 17 (Slide.) 18 DR. MOELLER: So in essence this is just an 19 interim step in many ways, particularly if you follow it up 20 during the normal prelicensing interactions? 21 MR. JOHNSON: That's right. That is why in the 22 beginning I said we view this as j ust another step along our 23 whole prelicensing interactions with DOE. 24 DR. MOELLER: Particularly, since you are not 25 entering into the selection of the sites, themselves, you ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
243 ,\ l are concentrating primarily on the quality and usef ullness V or accuracy of the data. 2 3 MR. JOHNSON: Right. 4 DR. MOELLER: Therefore, you are not really 5 involved at this stage. 6 MR. JOHNSON: That's right. 7 MR. MARK: How long does this dreary phase 8 continue when you have to keep looking at Amarillo and Las 9 Vegas and Hanford, equally? 10 MR. LINEHAN: They are due to make, based on 11 the site characterization data they obtain, they are 12 scheduled to make a decision, I believe it'c approximately
- )
s 13 around 1990. 14 MR. MARK: So between now and 1990 you have got 15 to keep looking at all three equally? 16 MR. LINEHAN: That's correct. 17 MR. MARK: Do you have a f avorite candidate? 18 MR. LINEHAN: Not that I am going to say. No. 19 As I pointed out before, people have opinions. But there is 20 just so much unknown about the sites until you actually do 21 some of this key testing. 22 ,r MR. MARK: I would have thought that you would
*l 23 .' surely exclude Deaf Smith because it's such a bore to be
^
24 around there. ; v
- 25 ,' (Laughter.)
ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
244 7x 1 MR. JOHNSON: I guess I will have to get used 3 MR. LINEHAN: I don't dare say a thing, because 4 every time I do, it gets quoted someplace. 5 MR. JOHNSON: I would like to just quickly 6 summarize some of our review activities and our current 7 schedule important for these activities. 8 The first step of our review was a technical 9 review. This was done by our staff, with some contract 10 support. And they reviewed the document in their respective 11 technical areas, and where they have comments they have 12 prepared draft comments. /~') (_/ 13 This part of the review was f rom July 23 rd 14 through July 28th. 15 The second step is a quality review of the 16 comments that were developed by the technical reviewers. 17 And this step will last from July 29 through August 20th. 18 The third and last step is the management 19 assurance review, and this consists of reviews of the 20 comments by the branch chief s, a review by the decision 21 support system team. I will describe that in a minute. 22 And then the division and office director 23 review. 24 The decision support system review is an f 25 independent review done by senior NRC staff members who ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
245 c~s 1 aren't involved with the actual review and development of () 2 the comments. 3 And this independent review is being done to 4 just stand back and take a look at the comments from a broad 5 perspective and f rom an independent perspective, and then to 6 report on the findings to our division and office director. 7 This last step in our review will, as currently 8 scheduled, go f rom August 14th to September 5th. 9 (Slide.) 10 MR. JOHNSON: Well, in addition to developing 11 the FEA review plan, the staff repaired prepared for their 12 review of the final EA's in other ways, as well. i A
)
k.s' 13 We reviewed selected new or revised final EA 14 14 references which contained significant different 15 information. 16 Just, for example, the three salt sites that we 17 are reviewing right now had about 800 new and revised 18 references for them. So our staff needed to be aware of 19 these ref erences and select f rom these ref erences key ones 20 that looked like they had a significant new information or 21 revised inf ormation that needed to have special attention, l 22 special review by staff and the contractors. 23 We also reviewed the draft EA comments from l 24 states, Indian tribes and other federal agencies to identify f 25 any major concerns that they raised that possibly we had ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
246 7- 1 not. We did not find any. t : 2 We conducted a number cf technical meetings 3 with DOE, the states and the Indian tribes between the time 4 period of our draf t EA review and our final EA review. Many 5 of these technical meetings touched upon concerns that we 6 had brought up in our draf t EA reviews. 7 For example, our major comment on structural 8 discontinuities at the Deaf Smith site was discussed in a 9 meeting on structure and tectonics of the basin. As a 10 matter of fact, the whole meeting basically addressed our 11 major comment and various details that related to the major 12 comment. I } k) 13 Similarly, the waste package meeting that we 14 had for salt dealt with some of our concerns that were 15 raised on the area of waste package and near field 16 geochemistry. 17 Likewise at the Hanford site, our major comment i 18 on shaft construction was discussed in the meeting on l 19 exploratory shaf t construction. l l 20 (Slide.) 21 MR. JOHNSON: We also conducted a number of 22 data reviews and site visits to review data referenced in 23 the EA's. 24 For example, we examined a lot of the salt 25 cores in the basin area relative to the Deaf Smith site. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
2 47 l l l l 73 1 This particular core examination trip was about a week in O 2 length and was multi-disciplinary, we had hydrologists, 3 geologists and a rock mechanic along on this particular 4 trip, where we had the opportunity to examine in detail a 5 number of the cores for the hole in the Palo Duro Basin and 6 discussed interpretations of this core with investigators 7 from DOE, as well as with the Texas Bureau of Economic 8 Geology. 9 All of the information you can glean from cores 10 of course is relevant to studies in ground-water flow, 11 studies in geochemistry and also our rock mechanic's 12 concerns related to the development and design of the n lx/ I 13 repository, considering the heterogeneities or impruities 14 that exist in the salt unit. 15 So it gave our staff an excellent opportunity 16 to get a good feel for the extent and nature of some of the 17 heterogeneities that are seen in these vaprite cores. 18 Another example rerates relates to the Yucca 19 Mountain site, where a number of our staff members and 20 consultants examined some of the faults King was earlier 21 describing, examining them both in the out crop and trenches i 1 22 near the Yucca Mountain site. 23 (Slide.) 24 MR. JOHNSON: Lastly, the current status of our 25 review is as follows. We started our review in June, June ACE FEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
248 1 23rd, 1986. This is a couple weeks af ter DOE released the f~ V 2 final EA's as you will probably notice. 3 This type of delay was needed because we didn't 4 receive adequate copies initially to support the staff and 5 our contractor review. So we had to delay the beginning of 6 our review until we had sufficient copies for everyone to 7 work with. 8 We have completed or virtually completed the 9 step one, technical review by the staff and their 10 development of initial drafts of comments. 11 We are currently begining, actually, today, the 12 quality review of these first draf ts and comments. Quality 13 review by the project people and also by the section leaders 14 and technical people. 15 So at this point in time we are not in a 16 position to discuss our comments. However, what I propose 17 is a briefing on the results of the review in the next 18 session of this subcommittee. 19 So I have given you an overview of the draf t 20 EA's and summarized our review plan f or the final EA's, 21 given you a feeling for where we are at in the review with 15 22 our scheduled dates and also proposed a follow-up briefing 23 with the results that we will have from our review. 24 DR. MO ELLER: All right, thank you. I think 25 that is a good summary. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
249 - 1 MR. MARK: I have a question, Dade.
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2 DR. MOELLER: Yes. 3 MR. MARK: You have looked at several sites. 4 Now, maybe to some extent nine, more intensively, three. 5 Except for lack of information, can you think 6 of a place in the U.S. which wouldn't be okay for a site, 7 like how about Bedf ord, Massachusetts, or Manhattan? 8 Wouldn't they all be okay if you just had enough 9 information? 10 MR. JOHNSON: That is a tough question to 11 answer. 12 MR. LINEHAN: Manhattan wouldn't meet the /- (/ 13 criteria in the siting guidelines for population. There are 14 a number of factors, like closeness to population and 15 different things. 16 MR. MARK: Okay, I will assume Manhattan -- 17 MR. LINEHAN: The point you are making, I think 18 there are a number of sites around the country, you know, 19 that could meet the criteria. 20 MR. MARK: I am wondering if almost anyplace 21 that isn't too heavily populated and too expensive wouldn't 22 be perf ectly okay. 23 You shouldn't go into the Oglala Aquifer, 24 probably, is that the right expression? The one in -- 25 MR. LINEHAN: Yes. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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-- 1 MR. JOHNSON: It overlies Deaf Smith site, yes.
2 MR. MARK: But I am sure you can go down 3,000 3 feet under Los Alamos and find a perfect site, right? 4 Well, don't worry about it. 5 DR. MOELLER: Don? 6 MR. ORTH: Just one question. Do you see any 7 impediments right now since you are about a third of the way 8 through your schedule to meeting that September 5 deadline 9 you have down here? 10 MR. JOHNSON: No, we don't see any right now. 11 It's the schedule we are working to right now. 12 DR. MOELLER: You would propose to brief us (- (_) 13 after you have finished that work to tell us your 14 conclusions and so forth? 15 MR. JOHNSON: Some time after the completion of 16 the review and after we have sent our comments down to the 17 Commission. i 18 DR. MOELLER: Fine, okay. l l 19 Any other questions or comments? ! 20 Well, thank you, Bob. 21 MR. JOHNSON: You are welcome. l l 22 DR. MOELLER: We will move on then to the last i l 23 item of the day, which is the review of the five-year plan. f 24 And all of us, John, of course, have the plan, 25 and f ortunately it was relatively short. So we have gone ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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,, 1 over it.
Okay.
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2 MR. LINEH AN : 3 DR. MOELLER: Go ahead and tell us. Well, let 4 us know what it is you would like from us, and brief us on 5 the plan of course. 6 MR. LINEHAN: Okay. The reason for the 7 briefing is to highlight some of the major points in the 8 plan, specifically those that deal with early identification 9 and work towards resolution of licensing issues. 10 I don't plan to go through the plan, you know, 11 page by page. You have had the opportunity to read it, 12 hopefully. I might highlight some of the things in it. n 4 k_/ 13 What we are af ter feedback on is we have to 14 implement this plan now. The plan is something that has 15 been developed by the staff, signed off by our management 16 earlier this year. We are on a course now to develop a 17 program to implement the specific goals and objectives of 18 the plan. 19 DR. MOELLER: Excuse me. This has already been 20 approved then? 21 MR. LINEHAN: Yes it has. 22 DR. MOELLER: Okay. 23 MR. LINEHAN: The first slide lays out the
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24 major goals and objectives of the plan. To go through these 25 quickly, it's to focus our activities, the first obj ective ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
252
,y 1 is to focus our activities on those activities that are e ~'
2 necessary to provide DOE sufficient licensing guidance, to 3 provide DOE whatever guidance they need so that they know 4 what is going to be required in the license application. 5 And also to interact over this five-year period 6 with DOE, the states, the Indian tribes, any of the major 7 parties involved in the program. To flush out early on what 8 are the concerns of these parties, what are the potential 9 licensing issues. 10 And in working with threes various parties, to 11 focus on a process for resolving these different issues. 12 What we are trying to avoid is the situation kl 13 that we have run into repeatedly in reactors, where new 14 issues pop up once a license application is filed during the 15 actual hearing on the license application. 16 What we are striving for here is while the ball 17 is still in DOE's lap, while they are pulling together the 16 18 license application or characterizing the sites, identifying 19 to them what we see as the key questions, the key issues 20 that are going to have to be addressed by that license 21 application. So the burden is not on the Commission. 22 In the waste policy act the Commission has a 23 statutory timef rame, three to four years in which testify to 24 complete our review of the license application and conduct a 25 hearing. cs ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
253 1 That doesn't mean we are not going to do 7~ V . 2 whatever is necessary. We will take as long as is necessary 3 to do our independent review and to conduct a full hearing. 4 But what we want to do is try to identify ways 5 of -- identify efficiencies that will help us meet that 6 three to four-year time period. One of them is to flush out 7 all of these issues early on in the program. 8 The second goal there ties in with this 9 identification of licensing issues. What we hope to do is 10 to bring some of these issues to closure, formal resolution 11 prior to the licensing hearing. 12 We realize there is only a number of issues we 7 (_) 13 will be able to do this on, but in instituting this process 14 where we try to identify what needs to be done to identify 15 the maj or issues, even if we haven't resolved them prior to 16 the time of the licensing hearing, hopef ully they will be 17 better focused for the hearing. 18 Now, what we are looking at in terms of formal 19 closure, it runs the gamut from reaching agreement with DOE 20 on how they are going to deal with a specific issue, to 21 going to a f ormal rule-making, possibly setting up very 22 early in the process, before the license application, a 23 hearing board to hear select issues. 24 This is a process that would just, that we are f 25 just starting to implement now, and these are the things we ACE FEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
254 1 are considering to try to build efficiencies into this V 2 overall process. 3 DR. STEINDLER: You don't have a thing in this 4 document that we have, which is your memo to Knapp and 5 Grieves, that mentions the word " rule-making." Why not? At 6 least I couldn't find it. 7 MR. LINEHAN: Okay, do you hav e the -- you do 8 have the five-year plan, okay? 9 DR. MOELLER: Yes, right. 10 MR. LINEHAN: Okay. It's, one of the things we 11 have come up with signs we developed the five-year plan. 12 The five-year plan lays out the basic goals. k/ 13 What I am discussing now is ways we are 14 considering of implementing those goals to achieve them. 15 DR. STEINDLER: I am looking at the strategy 16 statement. 17 MR. LINEHAN: Right.
- 18 DR. STEINDLER
- We talked about rule-making at l
19 least in this subcommittee for three years. I was a little 20 bit startled not to find mention of it in here. 21 DR. MO ELLER: In fact, that was going to be the 22 mechanism through which these items were to be nailed down. 23 DR. STEINDLER: Closure. 24 DR. MOELLER: Closure, yes. 25 DR. STEINDLER: I am a little startled. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
255 1 MR. L IN EH AN : If you can turn to goal number i
'~'?
2 two in the five-year plan. The goal talks about formal 3 resolution of licensing issues. 4 DR. STEINDLER: Yes. 5 MR. LIN EH AN : Item D under that, the action 6 plans, talks about implement rule-making or other formalized 7 process for selected prioritized issues. 8 DR. MOELLER: So it's there. 9 DR. STEINDLER: It's there, it's just not in 10 your strategy. 11 MR. LINEHAN: It's not in the goal, itself, 12 yes. (/' 13 DR. STEINDLER: Yes. 14 MR. LINEHAN: It's one of the actions we have 15 recognized. Whether we talk when we talk about formal 16 resolution, what we mean by that is, you know, going through 17 the rule-making, going through these middle hearings. That 18 was our intent. 19 DR. MOELLER: Also in this memo that Dr. 20 Steindler has cited, you mention the task group and open 21 item tracking system. 22 Again, if that was in the plan or referred to 23 again, I missed it. 24 MR. LINEHAN: Okay. If you could just bear 25 with me for a minute or two. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
2 56
,, 1 DR. MO ELLER: Okay.
i ) 2 MR. LINEHAN: I will get to that and show you
\
3 where it is. 4 DR. MOELLER: Good, I will wait. 5 MR. LINEHAN: The third goal we have there is 6 to develop an independent technical capability so that we 7 are prepared to review DOE's license application when it 8 comes in within the three to four-year timeframe. 9 What what we are going to be doing here is 10 developing whatever tools are going to be necessary for us 11 to do our independent review. 12 We went into that during our last session with
-,3
)
K/ 13 you when we described the modelling strategy document and 14 some of the activities in that particular area. 17 15 And then finally the fourth goal, identify and 16 eliminate to the extent possible impediments, identify 17 efficiencies in the licensing process. 18 If you turn to goal number four in the 19 five-year plan, and you look at the action plans there, item 20 B is to develop this integrated network of licensing 21 information management system to aid in the discovery 22 process. 23 What we are looking at there is revising 24 through a negotiated rule-making, revising the discovery 1 25 procedures in our regulations that would require the DOE ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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,-~ 1 license application and all supporting records to be put in .s 2 a standard electronic format where they would be readily 3 available to all parties so we wouldn't have to go through 4 that prolonged discovery process.
5 Paula talked this af ternoon about the FFRDC 6 which we see as another efficiency we can build into the 7 process. 8 What I would like to do is, since we have 9 talked about the FFRDC, we have talked about the modelling 10 strategy document and our independent review capability, 11 development of it, I would like to focus on the first two 12 goals here which have to do with identification of issues 13 and working on early closure of these issues. 14 If you can turn to the next slide. 15 DR. STEINDLER: Which? 16 MR. LINEH AN : The next figure. There is a 17 hand-out. 18 DR. M0ELLER: It has this on the front. 19 MR. MERRILL: You have got it. There were two. l 20 DR. MOELLER: It's with your copy of the i 21 five-year plan, et cetera. 22 DR. STEINDLER: Go ahead. 23 MR. CARTER: We don't have that. 24 DR. STEINDLER: I don't think so. Never mind. 25 I have got it. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
258 1 1 DR. MOELLER: They have got it.
) 2 DR. STEINDLER: No, one of us has it.
3 MR. MERRILL: It's called Early Identification 4 and Closure of Licensing Open Items. 5 MR. ORTH : It didn't have the same title, you 6 see, was the problem. 7 MR. LINEHAN: Okay. 8 DR. MOELLER: Go ahead. 9 MR..LINEHAN: On page 2, few of the key 10 elements of this approach we are going to be taking, it is 11 pro-active as opposed to reactive. 12 Generally, the program to date, we have been k- 13 reacting to what DOE does. 14 DR. MOELLER: This is true. 15 MR. LINEHAN: When they publish a document, 16 comment on it. 17 What we are going to do is set up our own 18 program so we can focus on what we meed to do over the next 19 five years to be a.ble to focus on that application, also to 20 lay out for DOE what will be required in the license 21 application. Give them guidance on what they have to do to 22 satisfy the performance objectives in Part 60. 23 DR. STEINDLER: There is a radical 180 degree 24 change of policy for staff, at least, from the way you 25 started out, where the answer to DOE's question "What is it ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 247-3700
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- 1 that you want?" was " Bring me a rock." '~
2 While I think that may be a good direction, my 3 question is, what prompted you to take this policy and what 4 makes you think you can do it better now than you could have 5 four years ago when the explicit or when the implicit 6 comment I think would have been made, well, we are not smart 7 enough to be able to tell them what they ought to do, 8 although I must say nobody ever said that exactly. 9 MR. LINEHAN: There are several factors, going 10 back a few years, we were forced with looking at nine 11 different sites. 12 Now we can focus on three sites and focus on 7 ,, (~) 13 real issues at those sites, look at those issues in terms of 14 Part 60. 15 What we have observed over the past couple of 16 years is there has been continual slippages in the program 17 and we were sitting, waiting for a document to come in, 18 gearing the staff up to do a review at a particular point, 19 the document didn't come in and it wasn't an efficient use 20 of our resources. 21 In addition, there is quite a bit of concern 22 about the timeliness of this whole process. We have the 23 timef rame layed out in the act to complete the review and 24 the hearing within three to four years. We want to make 25 sure that we are not left holding the ball. ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
260 l
, x 1 We want to make sure that DOE is aware of
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2 everything they have to do up front. The only way to do 3 that, to get that message across to them is to take this 4 aggressive approach. 5 Hopefully from the overall program standpoint 18 6 as we take this approach and lay out what is needed to, what 7 needs to be done so that DOE can provide the how they are 8 going to go about doing it, it will build efficiencies into 9 the overall program. 10 Now the concern we have.here is not to step 11 over that line and be proscriptive and start telling DOE how 12 to do things. 13 What we are trying to do is identify problems 14 with their current program. 15 If you remember the last briefing we had with 16 you in the QA area, we identify, based on our observation of 17 DOE audits they were done conducting, where we saw problems. 18 We identify some of the root causes and we threw it back to 19 them to determine exactly how to correct these problems. 20 But, you know, in taking an aggressive 21 approach, we have got to be very careful that we don't tell 22 them how to run the program. 23 DR. STEINDLER: Is there any other area in the 24 NRC activities in which the same kind of an approach has 25 been taken? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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- 1 MR. LINEHAN: No.
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2 DR. STEINDLER: Or is being taken? 3 MR. LINEHAN: No. 4 DR. STEINDLER: You have no model? 5 MR. LINEHAN: This is unique. 6 DR. MOELLER: I might mention in response to 7 the comment about the deficiencies in the QA program which 8 you observed, the subcommittee recommended of course that we 9 take that to the f ull ACRS and propose that they write a 10 letter on that matter. 11 We went to the full committee with that 12 proposal and they declined. They felt that at this stage (_/ 13 the NRC staff had made known its concerns to DOE and they 14 thought that the better approach would be, and I hope I 15 remember it correctly, would be simply if you later came 16 back and said well, we have told them and they are not 17 responding, then we might have written such a letter. 18 But we felt you simply had informed us and you 19 did not say no one was responding. 20 MR. MARK: I was going to ask on the same 21 point, have you noticed any difference in DOE's handling of 22 that career? 23 DR. MOELLER: Right. 24 MR. MARK: Since the last, what was it, three 25 months ago? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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1 DR. MOELLER: Right. r Since that peri 5d of time we have
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2 MR. LINEHAN: 3 had management meetings with DOE where they have brought 4 these things to their attention. We haven't seen a 5 difference in the way they run the program. They have 6 responded to us positively that they agree there are 7 problems there, and they are going to be doing something 8 about them. 9 MR. MARK: Do you have the impression that they 10 are in fact doing that? 11 MR. LINEHAN: We know that they are starting to 12 do it. We are going to have to see how well they carry it g U 13 out. 14 MR. MARK: Yes, okay. 15 MR. LINEHAN: Going on, again we want to focus 16 the program on what are the key licensing decisions that 17 must be made. There are going to be thousands if not 18 hundreds of thousands of different issues that are raised by 19 various parties. 20 What we want to do is not get sidetracked by 21 these tangential issues, to focus on those that relate 22 directly to Part 60 and to determinations we have to make. 23 Throughout this whole process we are going to 24 be dealing in a very open way with all of the parties and we 25 are going to be creating a documentation trail that shows ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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,~s 1 exactly how we have gone about identifying the issues, who
(' ') 2 we have met with, what input we have solicited to try to lay 3 out what needs to be done to resolve these different issues. 4 If this is going to work, we are going to have 5 to have the involvement of not only DOE working with us, but 6 the states and the Indian tribes, any of the parties to the 7 process. 8 DR. MARK: We keep referring to Indian tribes. 9 Are there any Indian tribes in the neighborhood of Yucca 10 Mountain? There is the Yakima Indians who are concerned. 11 DR. MOELLER: For Hanford. 12 MR. LINEHAN: There is the Umatillas, the Nez (-) 13 Perce, there are a number of tribes, I think they are all 14 associated with the BWIP site. 15 DR. PARRY: No, there is not. 16 MR. LINEHAN: There are not? 17 MR. MARK: I didn't think of any, and there 18 aren't any in Texas. They ran then out of there. 19 MR. LINEHAN: Just looking at BWIP, their 20 expertise in the area of hydrology is probably going to be 21 greater than ours. I 22 The tribes are hiring a number of consultants. 23 They are focusing all their resources on one technical area, 24 and it's going to be a very different situation for the 25 Commission as we deal with these f olks. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
264 19 , 1 I can go to a hydrology meeting on the BWIP l \ 2 site and they can have seven or eight f airly high-powered 3 hydrology consultants for the tribe sitting there, and I may 4 have two or three staff people. 5 MR. CARTER: They may end up running your 6 research center for you. 7 (Laughter.) 8 MR. LINEHAN: Okay, in order to implement this 9 approach, what we have got to do is come up with some formal 10 systematic mechanism. Now the SCP/SCA process which I think 11 you are familiar with calls for the DOE to lay out in the 12 site characterization plan what are the issues associated g V 13 with each site, what are the data needs that they are going 14 to have to develop to answer those issues, answer those 15 questions. What testing is going to be necessary to provide 16 that data. , 17 The NRC is required under ,the act, under our
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18 regulatJons,to review the SEP and we will be coming up with 19 a site characterization analysis which is the principal form 20 of guidance we have for DOE. It's the statutory document. 21 But as I mentioned before, there has been a 22 number of slips in these programmatic documents, and what we 23 are trying to do -is come up with other mechanisms where we 24 can keep this whole process active, from Tueeting with DOE, 25 for trying to reach agreement on what needs to be done at ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
265 1 each one of the sites with respect to specific issues. 2 If you can turn to the next page, the two key 3 activities I have mentioned, what needs to be done to 4 identify and prioritize the various issues at each site, as 5 well as the generic issues that have to be dealt with by the 6 Department of Energy and how can we go about focusing our 7 guidance, focusing the interactions we have with the 8 Department on formal closure on these issues or open items. 9 The whole purpose is to maximize the 10 effectiveness of any of the interactions we have with the.. 11 department, rather than sit down and talk about their-12 overall waste package program, to try to make sure that any 13 meetings we have with them focus on the key issues wi,th 14 respect to the waste package program. 15 If you can turn to the next slide, where we go 16 into the open item identification and prioritization -- 17 MR. MARK: Go back a second. 18 To what extent is the waste package problem 19 different from one site to the next? I l 20 MR. LINEHAN: A lot of the geochemical l 21 environment, very significantly. 22 When you are talking about salt, we.have 23 concerns about brine, you know, comparing it to a site like 24 Yucca Mountain if it's unsaturated. 25 MR. MARK: The acidic content of the waters are J ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
266 1 'different, temperature range may be. 2 MR. LINEHAN: Many of the mechanism such as how 3 you extrapolate so many years of data in the lab show that 4 you have a package good for 300 to a thousand years, many 5 are the same. 6 MR. MARK: I was thinking there was a fair 7 amount of similarity, but not in the surface chemistry. 8 DR. STEINDLER: At least for example in the 9 corrosion area, different waters bring different he 10' corrosion mechanisms and of course they have different 11 alloys there. 12 So you have the problem of trying to decide , (_/ 13 which of those you can use to do the kind of extrapolation. 14 MR. MARK: I was just curious about that, as to 15 whether you are thinking of different packages, sites 1, 2, 16 3. 17 MR. LINEHAN: They have chosen site specific 18 packages, not to go with a generic package. 19 , DR. STEINDLER: There are a whole raft of 20 differences. For example, the thickness of the, some people 21 i call the over pack, is quite different among the different f 22 cites. 23 MR. LINEHAN: Yes. 24 DR. STEINDLER: The spacings between the 25 packages is purposefully different in one case than the ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
267 1 other because they are interested in maintaining a fairly C-s 2 high temperature to make sure they don't get liquid water in 3 there under any conditions and so on. 4 The consequence of all that nonsense, coupled 5 with differences in ground-water and atmosphere and 6 pressure, gives you an environment that the waste package 7 sees where mechanisms are different, materials are different 8 and, hence, the work you have to do to extrapolate out to 9 whatever period of time you need to is likely to be quite 10 different. 11 MR. MARK: All right. So do you have, you have 12 a nice technical array of problems there. (- (> 13 MR. LINEHAN: Yes. 14 MR. MARK: Which I can vaguely understand. Go 15 on. 16 MR. LINEHAN: Okay. I am on page 4 right now. 20 17 What we are doing to identify these issues is 18 the staff right now is going through the performance 19 obj ectives in Part 60. 20 For each one of the performance objectives, 21 they are trying to identify all of the important subissues 22 related to each of those performance objectives. 23 They are going through a procccc of determining 24 what is going to be needed to resolve these issues, what 25 activities are going to have to be conducted, what the NRC l ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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1 staff has to do to provide guidance to the Department of 73 V 2 Energy in terms of some of the questions asked this morning 3 in terms of what is enough in certain areas. 4 What activities are going to have to be 5 conducted by DOE themselves to gather the data that is going 6 to be needed to resolve these issues. 7 We are breaking this up into different phases. 8 What are the things that will have to be considered prior to 9 the start of site characterization so that DOE has the 10 appropriate guidance necessary to fully develop the site 11 characterization plans and the test plans that will 12 ultimately implement those site characterization activities. O (_/ 13 Then what is going to be necessary when DOE 14 comes in wit h a license application. What is finally going 15 to be necessary for them to prove compliance with the 16 different parts of our regulations. 17 We are currently in the process of this 18 planning activity where we are laying out these generic 19 issues and the subissues. 20 In addition we are going through a similar 21 process for each one of the sites that DOE has recommended 22 for characterization. 23 What we are focusing on at the sites is l 24 specifically what guidance, what issues need to be discussed 25 with DOE prior to the time that they start site 1 ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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2 We have had meetings in July with the salt 3 project and with the Nevada project to reach some tentative 4 agreement on what the key issues are that need to be 5 considered prior to site characterization, and we have a 6 meeting set up at the Hanford site with DOE the beginning 7 August. 8 All of these meetings are open to the states 9 and tribes and the public, and in fact we are encouraging 10 participation by the states and tribes. 11 It is this consultation process with all the 12 parties where, af ter we lay out what we, what we come up (\ (_J 13 with going through these generic and site-specific planning 14 exercises where we can get input from all the parties to 15 make sure we haven't missed any key issues. ' 16 MR. MARK: On that general point, you mentioned 17 the hydrological experts the Yakima Indians have rounded up, 18 so there's obj ections to sort of over here on the lef t hand, 19 the Hanford site from them. l f 20 Are there obj ections to the idea of having a 21 site in Deaf Smith or Yucca Mountain from some background 22 public? 23 MR. LINEHAN: As far as the Deaf Smith site, 24 most of the interactions we have had to date have been with 25 the state, and the state has a number of concerns. ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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- 1 I don't believe there are any other parties 2 that have approached us, on there, Robert, with respect to 3 the Deaf Smith site?
4 MR. JOHNSON: Not that have approached us. 5 MR. MARK: Could you say that again. 6 MR. JOHNSON: The only people that have been 7 involved with our technical meetings are the people f rom the 8 State of Texas as, and there have been no other interest 9 groups. 10 MR. MARK: But that is the state officialdom. 11 MR. LINEHAN: Yes. 12 MR. MARK: Who are raising questions, which ',_/ 13 might even be reasonable. 14 Now, at Yucca Mountain there is probably 15 nobody. 16 MR. LINEH AN : Yucca Mountain, there are no 17 other parties I know that are involved r!.ght now. 18 MR. MARK: Okay. 19 MR. LINEHAN: It's the state, again. What we 20 do have is, we have got a number of the national 21 environmental groups that are following all the projects. 22 MR. bmRK: Ch, yes, they are going to obj ect no 23 matter where you settle down. 24 DR. MO ELLER: Is there a similarity in the 25 questions being raised by Nevada versus Texas? ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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- 1 MR. LINEHAN: There is some similarity, but a v
2 lot of them are very site specific. 3 DR. MOELLER: Okay. 4 MR. LINEHAN: You know, the concerns of the 5 State of Nevada on tourism, what the effect is going to be 6 on Las Vegas. 7 In Texas you have very unique concerns with the 8 f armers that we have mentioned and the concern about 9 potential contamination of the Oglala Aquifer. 10 When you deal with any of the states or tribes 11 you start to get into very site specific types concerns. 12 DR. MOELLER: Okay. 13 MR. LINEHAN: Once we have layed out all of 14 these issues and recognizing that this is going to be an 15 iterative process, as we become smarter about the sites, as 16 DOE does, the issues are going to change, there will be new i 17 issues, issues drop out, what we will try to do is l 18 prioritize the issues since we don't have the resources to 1 19 focus on each and every issue in the same same depth, come 20 up with criteria, I have a few listed there, to determine 21 where we need to focus our resources. l 22 Where we are focusing right now prior to the 23 SEP are those things that are critical that will be resolved 24 prior to DOE starting site characterization. 25 For instance, at the Hanford site there is a l l [_ ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
27 2 s: 1 question as to the type of hydrologic testing that has to be 1 2' ~done prior to' sinking the shaft at that site. 3 The concern is that unless you get resolved 4 what has to be done and get it done prior to sinking the 5 shaf t, you are going to . perturb the hydrologic base line 6 there with the shaf t, with any associated dewatering that 7 may take place. It may be a number of years before you.can 8 go back in and conduct the hydrologic testing that is 9 necessary. , i 10 So get that determined up front so that it is 11 done prior to sinking the shaf t. 12 DR. STEINDLER: Who is aiding the staff at this ! 13 process at each of the sites, is that strictly-an internal i' 14 in-house operation? 15 MR. LINEHAN: It is right now on the generic i l 16 issues-on the site specific. It was in-house at the sites 17 for Nevada and salt. .- 3
- 18 We have had these open public meetings where we j 19 have discussed them, where we have got feedback f rom DOE and 20 from the states.
21 We are just starting to do and we are trying to 22 decide exactly how we have to go about it to get all of the 23 parties involved that should be and to get the appropriate 24 feedback from the technical community. I will get into that l 25 in just a minute. i ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
273 l 4 1 We are considering, f or instance, laying out O 2 this whole approach in the Federal Register. That is one 3 option. So that a number of parties are familiar with what 4 we are doing. 5 Again, identifying as I mentioned before for 6 the GTP's target groups, letting different technical 7 professional societies know what we are doing and soliciting 8 their input. 9 MR. MARK: This Deaf Smith county site, how far 10 is that from New Mexico? 11 MR. JOHNS'ON : I think it would be close to a 12 hundred miles. ( 13 MR. CH ANNELL : It's less than that, 30 or 40. 14 MR. MARK: I was curious as to whether the New 15 Mexico government might becoming down. Thirty or 40 miles, 16 is that far enough to keep them out of the hair? i 17 MR. LINEHAN: We haven't gotten any feedback 18 from the State of New Mexico, that I am aware of. 19 MR. MARK: Good. I am just worried about our 20 administration, if it got into the act. 21 DR. MOELLER: The commenter is Jim Channell. 22 He will be speaking tomorrow. 23 If you can offer us comments tomorrow on the 24 Deaf Smith site, we would appreciate it. 25 MR. MARK: Thirty, 40 miles is surely far ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
274 1 enough to keep them away. O 2 MR. LINEHAN: If we could go on to the next 3 page, once we have gone through the process of identifying 4 these issues, the next step is to focus as I mentioned 5 earlier our interactions with the Department of Energy on 6 how to resolve these issues. 7 What we are going to be doing with the various
, 8 parties is agreeing on various consultation points, when we 9 should interact upon the various issues.
10 The idea here is that if we identify the need 11 to give DOE guidance in a particular area, we want to make 12 sure that it is early on in their process of developing l Q
\- 13 technical plans in that area so that they don't go through 14 the whole process of laying out a test program, hiring 15 consultants, and then have us lay out what we think needs to 16 be done.
17 We want to make sure f rom a timing standpoint 18 that we give them feedback early on in the process. 19 In the past, the number of meetings we have l 20 had, the number of interactions with the Department of I 21 Energy, some of them have been data reviews, some of them 22 have been reviews of their overall program. In general they l 23 weren't that well focused. 24 What we are going to be doing is publishing I 25 agendas for all these meetings, laying out what will be ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347 3700
27 5 1 discussed at the meetings to make sure that when we get in O 2 the meeting we can control what happens there. 3 This is critical if you are going to have a 4 number of involved parties take part in the meeting, so that 5 we can control the meeting. 6 Ultimately, what we want to come out of these 7 meetings with is documented minutes that reflect where we 8 stand on the issues that were discussed, what agreements we 9 have reached with the various parties, where there are 10 disagreements and what we are going to do to try to resolve 11 these disagreements. 12 DR. MOELLER: So, and I think this is very 13 important for us to hear and to understand, if you are 14 meeting, say, in Hanford, and the Indian tribes are there 15 and the state is there, and they raise an issue that you 16 consider to be a very valid question, then you will follow 17 up on that and they can have comfort in knowing that you are 18 following up and hearing periodically from you. 19 MR. LINEHAN: Yes. 20 DR. MOELLER: On how things are going. Okay. 21 MR. LINEHAN: This ties in with the issue 22 tracking system. 23 DR. MOELLER: Okay. 24 MR. LINEHAN: Where we are going to be able to 25 let these parties know how we are dealing with the issues, ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
276 g~ 1 how we are considering them.
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2 DR. MOELLER: So hopefully, well, as of the 3 moment, are your relations pretty good with, say, the states 4 and the Indian tribes? 5 MR. LINEHAN: Yes, I, pe r sonally , think they 6 are very good. 7 DR. MOELLER: Okay. 8 MR. LINEHAN: We haven't -- the overall 9 relations are very good. We haven't had the amount of 10 participation in some of the meetings we would like to date. 11 Part of that I think is that the NRC and DOE 12 haven't always provided the tribes with information they n '( /) 13 needed prior to the meetings, so they would be in a position 14 to really participate. But I think over all the 15 relationship is very good. 16 DR. MO ELLER: You mention minutes are kept and 17 that the meetings are open. 18 Do you formally send a copy of the minutes to 19 each of the states? 20 MR. LINEHAN: Yes, we do. 21 DR. MOELLER: Aggressively, you are being 22 pro-active rather than reactive. 23 DR. STEINDLER: That has always been done, 24 hasn't it? That is not new. 25 DR. MOELLER: Okay. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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277 i 1 MR. LINEHAN: There have always been minutes. O 2 We are trying to structure the minutes so that someone who 3 wasn't at the meeting can f ollow exactly what happened. 4 DR. MOELLER: Fine. 5 MR. LINEHAN: In addition, we are working with 6 the Department of Energy on a mechanism to make sure that 7 upper management in both the NRC and DOE concur in what 8 happens at these meetings. 9 It may involve having people at Browning's 10 level attend the close-out of the meetings or having them 11 briefed over the phone prior to us closing the meeting and 12 formalizing agreements with the Department at the staff 13 level. 14 DR. STEINDLER: That will make it more 15 cumbersome.
- 16 MR. LINEHAN
- It will, but one of the problems l 17 we have run into in the past is having agreements reached at i
i 18 the staff level and then having management look at them and l 19 management not necessarily agreeing. We want to try to put i 20 the burden on management to get involved, you know, prior to i j 21 the end of the meeting. l 22 DR. MOELLER: Okay. i 23 MR. MARK: That is what we keep telling reactor 24 people, that the management should be -- 25 DR. MOELLER: Involved. i ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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,_ 1 MR. MARK: Inv olved.
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2 MR. LINEH AN : You know, learning from the 3 reactors and what we have gone through so far in this 4 program, unless you get to the key management, a lot of the 5 things, problems we identify, John Davis elevates to Rusche, 6 directly. Until you get to those top decisionmakers, you 7 really don't know where you stand. 8 If we could go on to the next page, one of the 9 mechanisms we are considering using when we come out of 10 these meetings with DOE in order to document consensus on 11 the agreements reached is to do this in technical positions. 12 These technical positions may vary n (_J 13 significantly in format and in scope f rom what you have seen 14 in the past. But it would be a method of documenting where 15 we stand on resolution of an issue or what needs to be done 16 by the department to address an issue. 17 The reason for documenting it is to make it 18 available to a number of parties to ventilate their 19 positions, to peer review groups, get them out to the public 20 through the Federal Register and also to target groups that 21 I have talked about earlier today. 3 22 Again, it's to not only build a technical 23 consensus on what we are doing but to flush out concerns 24 that any responsible parties may have, any knowledgeable 25 parties may have with the approach we are taking. ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
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27 9 _ 1 What we are considering is once we go through 2 this process, that would typically be with a draf t technical 3 position, is to develop a final position that we would get 4 NRC, DOE, the states and the tribes to sign off on, that it 5 was a particular approach that was going to be followed in 6 the program, to document that agreement, recognizing that in 7 many areas, that as we collect additional data, you know, a 8 need may change to modify the approach. 9 But at least have some base line that we can 10 work from. 11 What we have found in the program to date is 12 when we deal on a particular technical area, when a new 13 issue comes up, you know, very of ten there is so much 14 turmoil you will go back to square one, how do we deal with 15 this. e 16 And what we are trying to do is lay these 17 things out in steps to get around that problem. 18 Now, there's different types of technical 19 positions that we will be developing. We went over the 20 ground-water travel time and disturbed zone with you at the 21 last meeting. We are considering developing technical 22 positions that deal with implementation of the EPA 23 standards. What is going to be necessary to show compliance 24 with that standard. h 25 We are going through a process right now where ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
2 80 I i
'I we are breaking apart the standard, trying to identify what O 2 the' key subissues are. And through our contractors, we are-3 going to be trying to identify what -really needs to be done 4 ~to deal with uncertanties, things such as uncertanties, how 5 do you deal.with long-term geologic probabilities, things.of 6 this nature. Try to lay out acceptable approaches or lay 7 out what needs to be done by the Department in these 8 technical positions.
9 Where we can get some consensus on an 10 acceptable approach for-dealing with any of these subissues, 11 we will be making determinations as to whether it is 12 appropriate on some of these to go to rule-making to get-13 them closed out. 14 What we are after is, we don't want to be in a
-15 position where DOE finishes site characterization and we 16 have to go back and tell them, hey, that data just isn't 17 adequate in order to address compliance with the EPA 18 standard.
19 And in order not to leave it as an open issue, 20 the only way we have of closing it is through the 21 rule-making process. 22 DR. STEINDLER: Does that mean you are going to 23 go to rule-making on essentially everything? 24 MR. LINEHAN: It's going to be on select 25 issues. Rule-makings are resource intensive and it's going ACE FEDERAL REPORTERS, INC. Washington, D. C. (202) 347-3700
2 81 1 to have to be something very important to the program. 7s d 2 We are also considering the option of setting 3 up a hearing board in the near future. That is another way 4 to formally close these things out. 5 Now we have talked to -- 6 DR. STEINDLER: Well, that is the same thing. 7 MR. LINEHAN: Excuse me? 8 DR. STEINDLER: You are talking about a hearing 9 board for rule-making. 10 MR. LINEH AN : No, just set up the actual 11 hearing board fortunately sense application, set it up 12 before we get the license application filed. Actually have su 13 a hearing board sitting so they can hear issues as we feel 14 they are ripe for resolution. 15 DR. STEINDLER: Unless the hearing board in 16 fact issues a finding in the form of a rule-making that the 17 Commission accepts, you haven't closed the issue. 18 MR. LINEHAN: You are probably right. I am not 19 familiar with the finding the hearing board makes. These 20 are things that our legal staff are looking at right now. 21 DR. STEINDLER: Yes. ( 22 MR. LINEHAN; Now, when we have talked this 23 over with the states and tribes in public meetings, they are 24 in favor of having something go before some type of board. 25 They feel that they will have more of an opportunity to have t j ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
282 1 a say, to have their contentions heard, rather than going O 2 through the standard rule-making process where they can 3 submit comments. They would rather have some type of 4 hearing. 5 DR. STEINDLER: It sounds like they have 6 misunderstood what the possibilities are in rule-making. 7 The Commission, if the commission so elects you can have 8 rule-making with cross-examination, which is an adjudicatory 9 process. It can get as nasty or as non-nasty as the subject 10 matter warrants. Everybody gets a chance to be heard. 4 11 MR. LINEHAN: When I talk about rule-making we 12 are talking about the standard rule-making where we publish 13 a regulation where there is no hearing. Granted, there can 14 be no hearing; there can be a hearing. 15 DR. STEINDLER: If you publish a notice of some 16 sort on rule-making and the label is waste management, you 17 will get a petition for formal hearing, which is going to be 18 tough to deny. 19 MR. LINEHAN: I am laying out our preliminary 20 thoughts of how to go about doing this. We are in the early 21 stages and any of this feedback is really helpful. 22 Turning to page 7, this just goes on to discuss 23 the fact that we need to develop criteria for what topico we 24 would take to rule-making or to a hearing board. 25 DR. STEINDLER: I don't know whether you -- ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
283 1 DR. MOELLER: No, go ahead. 2 DR. STEINEuER: Let me just comment. I think , 3 you need to select very carefully the topics that you want 4 to pull into rule-making, recognizing that, as you say, it's 5 intensive f or. resources, but it is the f astest way to 6 railroad a perfectly respectable licensing process into 7 oblivion in the courts if you don't get those kind of things 8 taken care of early. 9 So, you know, I see you have got two topics 10 down here. But I think what you need to do is try to 11 find -- I think you need to try and find those issues of 12 fundamental basic characteristics that are likely to be 13 contentious, which if challenged have a domino effect, those 14 are the ones where the principles need to be laid down and 15 become nonchallengeable by a rule-making. 16 Once you have identified the process you have i j 17 layed out so far, I think you will be able to focus more l j 18 sharply on the possible topics that go into that rule-making 19 process. There are some other things to think of. 20 MR. LINEHAN: Those are the type of topics we 1 l 21 are considering when we look at implementation of the EPA i 22 standard, some of these key areas. ! 23 And again, when we talk about this formal 24 closure of open items, again, it spans everything f rom l 25 reaching agreement with DOE, with states and tribes in I i l [ ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
284 1 public meetings, to formalizing that agreement in technical 2 positions, to going to something like a formal-rule-making. 3 What we are after here is going through an open 4 process, documenting it, so that any of the parties that are 5 concerned'are going to have the opportunity to raise issues 6 early.- That when we get into the hearing process, we are 7 going to have laid out how we went about doing this. 8 And if people want to raise new issues, there 9 is going to be a burden on them to show that indeed they are 10 new, significant issues. 11 DR. STEINDLER: One other comment on this 12 rule-making thing. I think both the states and Indian 13 tribes surely must recognize that if they go to rule-making, 14 they must, assuming appropriate standing, must open the 15 process up to more than just the states and Indian tribes. 16 And so that you will get a whole host of intervenors who 17 will bring to the table issues which heretofore have only 18 been covered by the states and the Indian tribes. 19 They may come in at you out of left field, and 20 have, clearly. 21 So the rule-making process is not simply the 22 result of a nice, quiet meeting between you and DOE, the 23 states and Indian tribes. 24 MR. LINEHAN: Definitely. 25 DR. STEINDLER: All of a sudden you have opened ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
285 7, 1 this ball game up to anybody who can swing a bat. You are ( ) 2 going to get an interesting time of it there. You have to 3 be prepared for that. 4 MR. LINEHAN: I think what we are trying to do 5 to prepare, as I mention any time we go to a rule'-making 6 generally there is going to be some type of tech cam 7 technical position preceding it. 8 That is why we are going to go, try to go to 9 all these groups, whether they are technical credentials, 10 whether they're they are an environmental group that's shown 11 an interest in the program, mail it out to them, follow up 12 with letters if they don't respond to try to solicit their n k_) 13 input, try to find out where they stand on the issues so if 14 we go to rule-making hopefully there will be -- there will 5 15 be new issues raised and new parties, you are right. But 16 hopefully, we can minimize that type of thing. 17 DR. PARRY: But, Marty, wouldn't you think that 18 a rule-making on selected issue, on an issue would be much 19 better than waiting until you get to the license 20 application -- 21 DR. STEINDLER: Oh, absolutely. Absolutely. 22 In fact, if you wait until you get to the license 23 application, neither you nor I nor our kids are going to be 24 around before that is done. 25 DR. PARRY: Right. ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
286 l' 1 DR. STEINDLER: Sure. All I am saying let's 2 not get so come portable with a topic we all agree on, we 3 being the four parties, NRC, DOE, states, Indian tribes. 4 It's going to be a broader issue than that. I can easily 5 envision that the kind of ground rules that have been agreed 6 to in the discussions between the NRC and DOE may not be 7 followed by the folks who come to a rule-making. So it's 8 essentially an open game at that stage. 9 DR. PARRY: It can be defined though by the 10 hearing board or the commission. 11 DR. STEINDLER: That's right. 12 DR. PARRY: As to be one topic. 13 DR. STEINDLER: Lef t open to the discretion of 14 the hearing boards. Hearing boards, depending on how 15 persuasive the arguments are, can very well broaden it out. 16 Let me be a little more blunt. If I were i 17 sitting as an antagonistic intervenor the first time a topic 18 came up for rule-making, I surely would recognize what it is 19 that the strategy that the NRC is pursuing, especially if
- 20 you publish it in the Federal Register for the whole world i
21 to see, which is fine. 22 And I am sure people understand that if you, if 23 their object is to obstruct, they have got to be able to 24 take the rule-making hearings on and extend those to the
- 25 extent possible and challenge them every step of the way.
l ACE FEDERAL REPORTERS, INC. Washington, D.C. . _ - - - . (202) 347-3700
287 1 I would not be surprised if that happens, even 2 if you have narrowed the topic down to a technical issue 3 that is f airly clearly define able. 4 The Atomic Safety and Licensing Board hearing 5 record is replete with various pleadings that have said you 6 guys haven't considered such and such. 7 Well, such and such is out in left field, but 8 you have got to go through the appeals process, it gets up 9 to the Commission sometimes. That is a long process. 10 DR. PARRY: Yes. 11 DR. STEINDLER: But I agree entirely. 12 Rule-making is the only way to avoid that kind of mischief. 13 MR. ORTH: There was one item you mentioned 14 sort of in passing awhile ago. You meationed putting things 15 out in the Federal Register and maybe getting technical 16 societies involved too. 17 Now you mention you might be sending out 18 letters to various groups. By all means do not forget the 19 technical societies. There have been nuclear chemistry and 20 technology division in ACS which has in the past sent in 21 things if somebody tells them about it. 22 You have the Waste Management Fuel Cycle 23 Division in ANS who again will get active if somebody let's 24 them know something is going on. 25 You have a division in, Nuclear Division in ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
1 288 7- 1 AICHE, I am not sure how many others, those three I am 2 f amiliar with, interacted with several of them in the -- I 3 know back, for example, in 1979, something came around 4 soliciting and they commented on having to do with the waste 5 things. But they have got to know. 6 MR. LINEHAN: Yes. 7 MR. ORTH: You can get to these organizations 8 specifically, to the chairman of those various 9 organizations, you get a lot of technical input. It won't 10 all be, won't all be opponent. Some may be supportive. 11 MR. LINEHAN: That is what we are going to be 12 doing. s_- 13 In fact, as we go through this process of 14 identifying these various groups, I will be flying that by 15 you folks to see if there is any one we have missed. If you 16 have any recommendations, if you will just pass them on to 17 us. 18 Okay, the final slide here I really didn't plan 19 to go through. It deals with that third, in any detail, it 20 deals with the third goal of developing our independent 21 review capability which I think we covered with you in the 22 last briefing. 23 DR. MOELLER: Right. 24 MR. MARK: You mentioned some national groups 25 in addition to tribes and states, governments, possibly ACE PEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
289 1 local citizens. O 2 MR. LINEHAN: Yes. 3 MR. MARK: Who is prominent in that category of 6 4 the national groups, the NRDC, Sierra Club or who? 5 MR. LINEHAN: Sierra Club, Environmental Policy 6 Institute, Southwest Research, I forget what their name is. 7 MR. MARK: So there's three or four at least? 8 MR. LINEHAN: Yes. 9 DR. PARRY: UCS, Union of Concerned Scientists. 10 MR. LINEHAN: Okay, yes. 11 DR. MOELLER: Do we have additional questions 12 for John? 13 DR. STEINDLER: Let me make a comment. 14 DR. MOELLER: Yes. 15 DR. STEINDLER: And I started out by saying 16 that this is a 100 degree change f rom the policy they 17 started before. And this nsw a proach in my judgment is 18 first rate to my thinking. ;W view is that they are doing
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19 exactly what they should be doing. 20 I chide the NRC staff for waiting four years to 21 get into this mode, but I certainly would not chide them for 22 doing it. 23 It does place on them I would say suddenly a 24 burden of some major significance and requires that they f h 25 proceed on a technical, in technical areas with sufficient l l [ ACE FEDERAL REPORTERS, INC. Washington, D.C. (202) 347-3700
290 1 knowledge and care so that competence is evident. _/ ,_)
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2 They will of course be challenged by DOE, but 3 not necessarily on what I would call purely technical 4 grounds. They have to be able to defend themselves. 5 My question to the staff would be, maybe it's a 6 question that you ought to ask, Dade, and that is, having 7 adopted this, starting into this what I think is new policy, 8 what does this do for their resource needs? What do they 9 need to be able to pull this off successfully? i 10 You are only going to get one shot at it, and I 1 11 think we ought to see whether or not we can provide comments 12 on support this they might need for resources.
\_ 13 DR. MOELLER: Okay. Any other comments or 14 questions for John before we wrap up this particular 15 session?
16 We ll, John, it's been a long day for you, and 17 we do appreciate your time and patience with us. And 18 particularly we appreciate the informational nature of 19 everything you have presented today. 20 MR. LINEHAN: We appreciate the opportunity. 21 We discussed over lunch a number of the comments you had on 22 the GTP's this morning, and there is a lot of points there i i 23 that we really have to consider. You know, especially going 24 into this approach. h 25 I think there were a lot of valuable comments _ . _ _ _ _ ACE PEDERAL REPORTERS, INC. Washington, D.C. __ (202) 347-3700
_ . _ - - - _ _ - . ~. 291 4 1 provided to us. ( 2 MR. MARK: I liked the reference John just 3 made. We see from this paper how cagily they are proposing
, 1 4 to make DOE malleable, and over lunch they were taking a 'l' l
5 look at us. 6 (Laughter.) 7 DR. MOELLER: Okay. Well, with that I think we 8 will wrap up today. 9 And I will simply point out that the 10 subcommittee will go into a very brief executive session. a . 1 11 Then we will reconvene at 8:30 in the morning. i ! 12 Thank you. l 33 (Whereupon, the meeting was adjourned at 5:20 f 14 p.m.) i 15 16 4 l 17 i j 18 ^ 19 ) 20 l 21 i ! 22 23 ! 25 i i _,-__.. _ __--_ ___._ ___--_--REPORTERS, ACE FEDERAL _-_ _._ - _ INC.
-- __ _ _'shington, Wa D.C. (202) 347 3700
4 CERTIFICATE OF OFFICIAL REPORT 3R
~
O This is to certify that the attached proceedings before the UNITED STATES NUCLEAR REGULATORY COMMISSION in the matter of: 3 NAME OF PROCEEDING: ADVISORY COMMITTEE ON REACTOR SAFEGUARDS SUBCOMMITTEE ON WASTE MANAGEMENT f DOCKET NO.:
. I PLACE: WASHINGTON,' D. C.
DATE: TUESDAY,.' JULY 22, 1986 were held as herein appears, and ' th t this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission, i l f.y o /
'( sigt ) Of //S ' *<e
[( (TYPED) CRAIG L. KNOWLES Official Reporter ACE-FEDERAL REPORTERS, INC. Reporter's Affiliation O}}