ML20246M909
| ML20246M909 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0011, NACNUCLE-T-11, NUDOCS 8905190297 | |
| Download: ML20246M909 (323) | |
Text
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u 4!GlNAL 6 UNITED STATES NUCLEAR REGULATORY COMMISSION 1
ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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10th ACNW Meeting )
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- May 11, 1989
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Q HERITAGE REPORTING CORPORATION Oficial Reporters 1220 L Street, N.W., Suke 600 Washington, D.C. 20005
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. 1 UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON NUCLEAR WASTE In the. Matter of: )
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10th ACNW Meeting )
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AMENDED COPY Thursday May 11, 1989 Room P-110, Phillips Dldg.
7920 Norfolk Avenue Bethesda, Maryland i The meeting conven6d, pursuant to notice, at 10:00 a.m.
BEFORE: DR. DADE W. MOELLER
. Chairman, ACHW Professor of Engineering in Environmental llealth Associate Dean for Continuing Education School of Public Ilealth liarvard University Boston, Massachusetts ACNW MEMBERS PRESENT:
DR. MARTIN J. STEINDLER Director, Chemical Technology Division Argonne National Laboratory Argonne, Illinois DR. CLIFFORD V. SMITH Chancellor, University of Wisconsin Milwaukee, Wisconsi:-
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'ACRS-MEMBER PAUL SHEWMON NRC STAFF R. BROWNING B'. YOUNGBLOOD J. LINEHAN R. BALLARD J. BUNTING p
[: PRESENTERS I
CilARLOTTE ADRAMS r
KEITH MCCONNELL BUCK. IBRAllIM JOHN.TRAPP ,
- i. MIKE BLACKFORD HAROLD LEFEVRE -
TOM CARDONE
. CONSULTANTS:-
WILLIAM J. HINZE DICK FOSTER
' DONALD ORTH EUGENE E. VOILAND PAUL POMEROY MEL CARTER DESIGNATED FEDERAL OFFICIAL:
S.J.S. PERRY O iierate9e Reverttee (202) 620_4000 Cerveretiee
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0 1 PROC 88D1"as i 2 DR. MOELLER: The meeting will now come to order.
1 3 This is the tenth meeting of the Advisory Committee on 4 Nuclear Waste. I might mention that we consider the tenth 5 meeting quite a major event. We won't celebrate again until 6 the twenty-fifth. So it does make it important, and we hope 7 to have a little festivity this afternoon to honor the 8 occasion.
9 I am Dade Moeller, chairman of the ACNW. The 10 other ACNW members present afe Clifford Smith on my right, 11 and Martin Steindler on my left. We have a team of 12 consultants with us today, including Bill Hinze, Dick 13 Poster, Paul Pomeroy, Gene Voiland and Mel Carter, and Don (n,) 14 Orth, and we have kindly loaned to us from the ACRS one of 15 the members there, Paul Shewmon. !
i 16 During today's meeting the committee will review 17 the latest information on and status of the site 18 characterization analysis and the technical position on i 19 environmental monitoring of low-level waste disposal 20 facilities, the position which is being developed by the 21 low-level waste management staff.
22 This meeting is being conducted in accordance with 23 the provisions of the Federal Advisory Committee Act, and l 24 the government in the Sunshine Act, Dr. S. J. Parry, seated 25 on my left at the end, is the designated federal official
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2 The rules for participation in today's meeting 3 have been announced.as part of the notice that was published 4 in'the Federal Register. We have received no written 5 statements or requests from members of the public or others 6 to make. oral statements at today's session.
7 A transcript of portions, in fact, I guess a 8 transcript of essentially all of the meeting will be kept,.
9 and it is requested that each speaker go to one of the 10 microphones, identify yoursel'f and speak with sufficient 11 volume and clarity, and do we have microphones?
12 On the table, but none other than those. Okay.
13 Well, just speak up so that you can be heard. And if the L() 14 reporter has any problems, wave your hand or hit the-window 15 or something so we will know and we will correct the 16 problem.
17 In the way of other brief items, the committee is i 18 in receipt of a' memorandum of appreciation from Chairman 19 Zech. We will make certain that everyone here receives, 20 certainly the consultants and committee members receive a 21 copy of this memorandum, because I consider it a compliment 22 and a thank you to each of you for the strong support that 23 you have provided us over the past year.
24 For the members of the committee, we will be, or 25 each of you has been given a calendar for 1990, and we hope
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() J you will put down your availability on it so that we can 2 begin to sit down dates for our meetings in 1990, or sa that 3 the staff can do that.
4 One other item. We had talked within the 5 committee about the PRA doing a' scoping study. PRA'for the 6 Yucca Mountain site, and I have received information that 7 RES, the Office of Nuclear Regulatory Research, has a PR7 8 study under development for the Yucca Mountain site. So I 9 hope that in time the committee can hear a report on that.
10 Today, in terms of'the presentations.on the SCP, 11 the staff's review of the SCP, we will take them in the 12 following order: Quality assurance will be first. Geology-13 geophysics will be second. Hydrology and geochemistry will O 14 be entra e"a tuet 111 texe ue en to 1ueca. ^"a orter 15 lunch we will do materials engineering, performance 16 assessment and then it says engineering in general is the 17 last item. Then when all of that is completed, we will look 18 at the technical position on environmental monitoring.
19 One other item or reminder, an item of caution to 20 all of the consultants and the members of thc committee is 21 that the material provided to us as background for this 22 report is predecisional. In fact, the staff moved heaven 23 and earth to simply get some words to us so that we could 24 join with them in their thinking and see where they are.
25 And so that is not to be released outside this
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.( ) 1 room or in fact not to be released from your own care.
2 Are there any comments or questions from Clifford 3 or Martin?
4 (No response.)
5 DR. MOELLER: And do any of the consultants have 6 comments or questions at this point?
7 (No response.)
i 8 DR. MOELLER: All right, there being one then, we i l
9 will move ahead and I will call on John Linehan. I don't 10 want to catch you off guard,' John. Everybody said just call 11 od John. lle'll handle everything.
12 (Laughter) 13 MR. LINEHAN: lie will turn it over to King 14 Stablein.
15 DR. MOELLER: Fine.
16 MR. LINEHAN: King is going to handle the meeting.
17 DR. MOELLER: Okay, King.
18 MR. STABLEIN: Good morning. Is this where you 19 would like me to be, Dade?
20 DR. MOELLER: I think it's excellent. I believe 21 it's a good position.
22 MR. STABLEIN: Okay. And can everybody hear me?
23 My name is King Stablein, and I am the project i
24 manager in charge of running the NRC staff review of DOE 25 site characterization plan for the Yucca Mountain site.
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() 1 In past meeting, we have indicated how the SCP 2 review is proceeding. We are still in the midst of the SCP 3 review, but we have now reached that stage where we are able 4 to provide the ACNW with our preliminary point papers on the 5 concerns that the staff members have come up with regarding 6 the SCP.
7 What you received is called the branch draft point 8 papers. This means that the point papers have gone through 9 review by the section leaders and by the branch chiefs in 10 the Division of High Level WE'ste Management. They are still 11 draft. They are still undergoing a revision. And even in 12 cases where you might see something designated in a term 13 that might indicate order of importance or priority like r
( 14 objection, that really is potential objection, or should not 15 be taken to mean we have decided that will be an objection 16 as opposed to the. comments or questions that you see 17 contained in the package.
18 At this point what you have are our concerns with 19 the SCP. And, of course, based on our own internal 20 discussions, any commentary we might experience today or 21 interchange, these are still developing and you will be 22 receiving another draft called the division draft around May 23 22nd, according to plan before you receive the draft for 24 formal review on June 2nd. That will be HMSS office draft 25 of the SCA, the site characterization analysis. And that is 1
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'() 1 what we, of course, have been aiming to have you formally 2 review.
3 And all the steps that we have taken up until now 4 and to that time are designed to get you aboard our thinking 5 in advance os that when you do receive that package on June 6 2nd, you feel like you are somewhat acquainted with its 7 contents and it doesn't come as a total surprise.
8 And, of courn: :oday's meeting is another step in 9 the process, and I hope hat this will be a very profitable 10 step.
11 Now, what you will hear today from the staff 12 itself will not be a page-by-page run through of the massive 13 amount of material that you receive. The staff will be
() 14 emphasizing for you selected major concerns. There will-be 15 certain themes highlighted to indicate the direction of our 16 thinking during the review, and we will not attempt to go 17 through the specifics of all those papers. We would not get 18 through those probably ir a week.
19 But what you do have the opportunity for today is 20 to hear from the personnel that developed these and talk to 21 them directly. And, of course, they are the experts in 22 these areas and therefore this should be a valuable 23 opportunity for some exchange and understanding of the point 24 of view that they have brought to the review and to 25 understand the results that they have come up with so far, O iierite9e nevertie9 cerveretioe (202) 628-4888
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( ,) 1 even if.they are still in the preliminary stage 2 DR. SHEWMON: Sir, let me stop there and ask you,.
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3 you are in the preliminary stage. Is that what you mean?
4 MR. STABLEIN: We are still in the process of the 5 SCP review.
6 DR. SHEWMON: How final is the document which has 7 been submitted for review?
8 MR. STABLEIN: Oh, the document. The SCP is 9 final. I'm sorry. DOE's site characterization plan is 10 final. '
11 DR. SHEWMON: Okay, that answers my question.
12 MR. STABLEIN: Great. l 13 DR. MOELLER: But it is to be updated every six h 14 months.
15 MR. STABLEIN: That's correct.
16 DR. SHEWMON: The las thing I heard it wasn't 17 clear what they are going to put around the fuel, around the 18 waste. So I look forward with interest at finding the final 19 decision on what they are going to make their canisters out 20 of which was not final a few months ago.
21 Fine, okay.
22 MR. STABLEIN: That's my territory.
23 DR. PARRY: Gene?
24 MR. STABLEIN: Yes.
25 DR. PERRY: I know that you have met for the last I Heritage Reporting Corporation (202) 628-4888
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-( ) I two days with the department. Will any.of the comments that L 2 are made by the staff during their presentations take into l 3 account any of that interaction?
l 4 MR. STABLEIN: Certainly that will be folded in as 5 the staff member speaks to the committee. It may not be 1
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6 explicitly recognized or called out, but all that discussion 7 that took place will be factored in as well.
8 DR. PARRY: Also, last week, I understand, was a 9 rather extensive tour field trip by the geologists out to 10 and the surrounding areas ar6'und Yucca Mountain.
11 Will their impressions be either implicitly or 12 explicitly included in their discussions?
13 MR. STABLEIN: I think that the geologists'
() 14 comments and ober 7ations will benefit it and have been 15 deepened by the experience. Again, I don't know if that 16 will be called out explicitly. But all of that is being 17 folded in in this ongoing process, right.
18 You are certainly up to date on the latest 19 happenings in the programs. It's true that we had a week 20 long field trip to various sites in Nevada last week with 21 the State of Nevada and the Department of Energy, looking at 22 the study sites for both programs, the state's and the 23 DOE's, and that is what Dr. Parry is referring to with the 24 field trip. !
25 DR. MOELLER: Bill Hinze.
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() 1 DR. HINZE I just want to make certain that I am 2 with you.
3 Are you going to be touching here the concerns l
4 that are of principal interest and concern to the staff? Or 5 are you going to be discussing with us those things that you 6 have a problem with that you are trying to develop the 7 concerns? Which way are you headed?
8 MR. STABLEIN: These are principal staff concerns.
9 DR. IIINZE : The principal concerns regarding the 10 SCP.
11 MR. STABLEIN: That's correct.
12 DR. IIINZ E : Okay, thank you.
13 MR. STABLEIN: Yes. Those should coincide in
() 14 large measure with our areas of most interest because that's 15 what we are t ying to identify early on are potential 16 problem areas.
17 Are there any other questions at this point?
18 All right, I only have one piece of paper in the 19 handout and that is the organization chart for the Division 20 of 111gh Level Waste Management. And this is given to you 21 just so you can relate the people that you hear from today 22 to the organization that we have, and also because it offers 23 an opportunity to see the management involved in the review.
24 Of course, Mr. Browning, the Division Director, is 25 over here with us today. Mr. Youngblood, I don't believe is O iieritese Revert 1 2 cerneretio-(202) 628-4888
12 I )' 1 in the room. And Mr. Linehan, the director of the 2 directorate, you have already heard from briefly this i
3 morning. The other chiefs are Ron Ballard and Bill Bunting, 4 and you will probably see them later today.
5 The section leaders are indicated on here and, of 6 course, they play a very important role in this process in 7 terms of assuring the quality and consistency of the 8 products that emerge from their sections.
9 Now today you will hear the presenters will 10 representthesedifferentseftions. We have lead reviewers 11 from each section involved. But the section leader will 12 also be present and will be available to help provide backup 13 support for the various questions that you all might have.
() 14 Are there any questions on the organization chart 15 or the purpose for having it here today?
16 DR. MOELLER: Let me --
17 MR. STABLEIN: You go ahead.
18 DR. MOELLER: -- I should have, when you offered 19 the opportunity a moment ago, to make a comment. I should 20 have made some at that time. And it ties back into the 21 question how complete is the SCP.
22 I was reading, just to refresh myself for this l 23 meeting, the site characterization plan overview. And if 24 you go through the entire thing, you finally end up at the 25 back a couple of what I would call appendices. One is a
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g 1 glossary.
2 Now, in the glossary it seems to me that the 1
3 definitions -- it's really definitions of terms. And it 4 seemed to me that some of those are crucial, I mean is the 5 definition in there one that the NRC staff agrees with.
6 Now, unfortunately, some words like "substantially 7 complet.e containment" is not defined, you know, and I know
,8 you are working on it. But they give a definition, for 9 example, of high level waste which some of us have all
-10 wondered what it is. That's'in there. There are a number 11 of definitions which I would question. For example, they 12 will talk in terms of -- they will talk in terms of the EPA 13 standard. Now I forget what term they are defining, but 14 they will say the EPA standards are sometimes expressed in 15 quantitles of radionuclides that can be released or the 16 concentration of radionuclides that can be released. And 17 then it will put a period. And then it will say, these are 18 given in units of dose.
19 Well, I'm baffled, you know, how you give a 20 quantity of a radionuclides and a concentration in units of 21 dose.
22 So I would urge that you -- you know, I'm fearful 23 maybe because I have never seen any NRC staff on that.
24 comments on that glossary, and I am fearful that it may have 25 fallen through the cracks.
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1(_) 1- Another thing at the back of it, and I'm glad I 2 had. time to look at it, there is a whole section called 3 " Issues and Information Needs for the Yucca Mountain Site".
4 That's an appendix. And in here, if you go through it, 5 there are some very interesting words. Well, there are 6 typographical errors in the issues and information needs so 7 it hasn't had too much QA.
8 There is a footnote at the end that I couldn't 9 find what the footnote applied to. But there are statements 10 in there -- oh, like Issue l'7, which is, "Will the 11 perf ormance confirmation program meet the :: requirements of 10 12 CFR 60,137,"
13 Then the comment is, "The information needs to be
() 14 determined." Well, I would think that would be a rather 15 important item.
16 And then Issue 1.8 and 1.9. "No additional 1
17 information needs have been identified."
18 Well, do you agree that they know all they need to 19 know to settle Issue 1.8 and 1.9? I have never seen any j 20 staff comment on this. So let me drop it at that just to 21 encourage someone on the staff to look at these two parts.
22 For example, they could come back at you, or not l
23 that it's a confrontation, but let's say down the line we 24 suddenly find that we are thinking totally two different 25 ways about some subject because DOE had defined the term in
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() I here and you didn't realize it, and you don't even agree 2- with the definition. And that could be really a problem.
3 Mel.
4 DR. CARTER: I had one other to that. When I 5 looked at the DOE overview, then mentioned, for example, 6 .that the category of seals, one of the things they included 7 is backfilling of the underground repository even though !
8 backfilling is not included in the regulatory definition of 9 seals. I think, again, that could be a rather crucial 10 differenceofopinionbetweefNRCandDOE.
11 DR. MOELLER: Well, and just not to leave them
- 12. hanging. The place where there is a line typed twice on key 13 Issue 4 at the top of page 162 just for the DOE staff to
() 14 realize what I was talking about.
15 Okay. Well, that would help me.
16 One other thing in here, on page 11 of the 17 overview the National Academy of Sciences was going to --
18 the government solicited the views of the National Academy 19 of Sciences on investigating tuff as a host rock and 20 received a favorable response.
21 So I guess that academy report was issued, and it 22 must have been favorable.
23 MR. STABLEIN: Well, the only report I am aware of 24 is the 1979 report that the academy did on tuff, and with 25 certain cautions they found tuff to be a potentially j
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1 favorable medium.
2 DR. MOELLER: Okay, thank you.
3 MR. STABLEIN: We could provide that should you be 4 interested. It was a letter report.
5 DR. MOELLER: Oh, okay. Well, let's go on.
n 6 Were there any other comments?
7 Let's go on.
, 8 MR. STABLEIN: We will look into the items that 9 you have mentioned though. I think that the different 10 disciplinesmayhavetakencfreofthoseintheirreview.
11 Dut to make certain, we will go back and check on those, 12 especially the glossary in the overview.
13 DR. MOELLER: But not to beat it to death, but O 14 they define reasonably available technology . mean they 15 have a clear -- what they consider a clear definition of it, 16 and I know that is a controversial subject.
17 MR. STABLEIN: You should hear about that during 18 the waste package discussion this afternoon.
19 DR. MOELLER: Okay.
20 MR. STABLEIN: That's definitely part of one of 21 our important comments.
22 DR. STEINDLER: Let me just add a comment on this 23 point that you brought up, Dade, where no additional 24 information needs have been identified. That's a statement 25 of the Department of Energy after the SCP has been put
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is_f 1 together. It doesn't come as a great surprise to me that 2 the department, viewing its SCP as a completed document, 3 comes to the conclusion that they have satisfied all the 4 information needs that are associated with this here called 5 Issue 1.0. So I don't have any problem recognizing where I
6 that comes from.
7 But am I correct in assuming that you are not 8 going to walk down specifically these issues and challenge 9 them one way or the other? But rather, that whatever 10 challengetheremaybeisbufiedinthereviewofamuch !
11 larger text?
12 MR. STABLEIN: The entire issue resolution 13 strategy, which is Chapter 8, is being reviewed from.the top
() 14 down by the staff, especially the systems performance group 15 fol. lowing the issue resolution strategy from the statement 16 of the issue on down to the information needs.
17 You should hear something about that in the 18 performance assessment section this afternoon. But this is 19 obviously a crucial area of interest to us.
20 Are there any other questions or observations?
21 (No response.)
22 MR. STABLEIN: Dr. Moeller, should I proceed?
23 DR. MOELLER: Fine. PLease.
24 MR. STABLEIN: Well, I think it's time to get to 25 the more interesting part of the meeting, and that's where
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e 1 -we bring the technical experts up here to talk to you ab)ut 2 the different areas. And the first area that we are goir,g 3 to cover will be quality assurance.
4 Jim Kennedy is the section leader for QA. I don't 5 know if Jim is with us this morning. Jim Kennedy, back 6 here. And Jim Conway will be giving the presentation.
7 Jim.
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.(,-) ' 1 MR. CONWAY: Good morning.- Thank you, King.
2 I am a project manager in.the QA section. And 3 'again my boss is Jim Kennedy.
4 As noted in the handouts, the concerns in quality 5 assurance with the SCP are concentrated primarily in three 6 different areas.
7 One is the QA program description, or the overall 8 DOE QA program for site characterization, 9 The second item is the qualification of existing 10 data. And the third item is'the Q list. ,
And I will briefly 11 go through and touch on all three.
12 With regard to the DOE's QA program, in a July 13 1988 meeting, DOE and NRC agreed on an approach for the NRC O) q_ 14 acceptance of the Yucca Mountain, of DOE's QA program for
'15 the Yucca Mountain project.
16 The approach and schedules for implementing this 17 were revised in a January 1989 meeting.
18 Our concern here is related to the fulfillment of 19 the implementation of activities to meet the established 20 milestones such that the staff can gain confidence and be 21 assured that DOE's QA program satisfactorily meets the 22 requirements of Part 60, Subpart G, and also that we can 23 accept DOE's QA program as being fully qualified for the ,
l 24 Yucca Mountain project. l 25 In the same area, since the QA program is at a 1
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~T 1 critical point in its development, we are also concerned 2 that DOE does not have permanent QA managers who have the 3 authority and responsibility for the QA program at both the 4 Ileadquarters and project levels.
S We feel that both these positions should be filled 6 as quickly as possible, 7 With regards to Item Number 2, qualification of 8 existing data, since 1977 data has been gathered during site I 9 exploration which may be used for site characterization and 10 insupportofalicensingapflication.
11 Our concern in this area is related to the fact 12 that DOE one, has not submitted the procedures that they 13 will utilize to qualify this existing data, and two, that
() 14 they may have eliminated tests and experiments during site 15 characterization, because it has been determined that the 16 existing data would satisfy the licensing requirements even 17 though the data has yet to be qualified.
18 DR. MOELLER: Has DOE qualified any data from past 19 work?
20 MR. CONWAY: To the best of my knowledge, I have 21 no idea. I don't think they have, but we are not aware of 22 it, Mr. Moeller.
23 DR. SMITH: Excuse me. llave you discussed 24 procedures for qualifying pre-existing data?
25 MR. CONWAY: We have not discussed procedures, A
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() 1 although I believe DOE has the procedures. It's just that 2 they haven't formally submitted them to us.
3 DR. SMITil: But you are aware of what those 4 procedures are in an informal way?
- 5. MR. CONWAY: In an informal way I would say yes.
6 DR. SMITH: Do you have a problem with them?
7 MR. CONWAY: I would say no.
8 MR. LINEHAN: Dr. Smith, we had, I believe a year, 9 year and a half ago, issued a technical position which laid 10 outanacceptablemethodologftoqualifyingexistingdata.
11 When DOE developed their QA program plan for the 12 Yucca Mountain project, they committed to use that general 13 methodology.
() 14 What we have not seen is the procedures that they 15 will use to implement that methodology. And to the best of 16 our knowledge, we don't know whether they have been 17 developed yet or not. But there will be an interaction with 18 the Department once they do have that.
19 DR. SMITH: I guess I am a little baffled as to 20 why if you don't know what the status is and the DOE is 21 located in the same town, it seems to me a phone call would 22 answer the question, where are you.
23 MR. CONWAY: In their submittal at the SCP, in the 24 appendix to the section on QA, they have listed the 25 procedures that they apparently either have generated or are r
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.O 1 planning to generate, that indeed will meet the requirements 2 of NUREG 1298 which John has mentioned. This was the NUREG 3 document that identified or was given as guidance to DOE as 1
4 tar as what we would like to see in a package to qualify 5 existing data.
6 MR. KENNEDY: Can I add to that? Jim Kennedy from 7 the staff.
l 8 They are in the process of developing these l
l 9 procedures for qualifying existing data. We expect them to i 10 be in conformance with the t6chnical position that they l
11 published last year. We don't expect any problems. They 12 just haven't-been formally submitted to us yet. We have 13 talked about them, we know they are being developed, and it I 14 is one of the open items that we are tracking that has to be 15 resolved before we can consider t.he program being qualified.
l 16 DR. SMITH: So as to whether or not you will have l
l- 17 a problem with what they deliver, you don't really know?
l 18 MR. KENNEDY: We don't really know. Our iee1ing 19 is that it doesn't look like we are going to have a problem 20 because they have made the right commitment, they were 21 involved in the development of the TP and they've agreed 22 with the positions in the TP. So there could be some o 23 questions on it, but I expect them to be resolved and 1 1
24 don't expect any major problems.
25 DR. STEINDLER: May I make a comment about that l
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1 topic?
2 I've had'a look at this NUREG document in light of 3 a paper tha'. was published in the very recent past on cold 4 fusion, which by all odds is a paper that produced very poor 5 if in fact consequential data.
6 Unfortunately, mj simplistic reading of your 7 technical position would qualify the data in that paper as 8 being perfectly acceptable.
9 I have a fundamental problem with that. And I 10 don't know quite whether or $'iot the, what I really don't 11 know is whether or not the adherence of the department's 12 procedures to your NUREG document is good or bad.
13 I realize it is good from the standpoint of
() 14 meeting whatever paper trail is required. I think it may be 15 bad science.
16 Have you qualified your NUREG guide -- it's not a 17 guide, but whatever -- by looking at some papers that are 18 either generally conceded to be good papers or bad papers?
19 Heaven knows that literature is full of fairly 20 commonly agreed on documents of that kind.
21 MR. CONWAY: I will let Mr. Kennedy handle that 22 one.
23 MR. KENNEDY: Since I was involved in the 24 development of that, no, we haven't. We are doing this step 25 by step. And the first step vas to develop a technical
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( 1 position laying out generally what was acceptable for 2 qualifying existing data.
3 The second step is DOE writes a procedure which 4 implements that TP.
5 And the third and probably most important step is 6 for DOE to go off and qualify some data in accordence with 7 those procedures and to have us review and to see if we 0 agree with that qualification process.
9 We have not done that yet.
10 DR. STEINDLER: Whit I guess I am saying to you is 11 that if DOE comes through with a set of procedures that do 12 not match your NUREG guide, don't immediately toss them out.
13 They may in fact be better than what we've got (O
_j 14 here.
15 MR. KENNEDY: That's true. They don't have to 16 meet the letter of that. They can submit other approaches 17 and different approaches and perhaps even better.
18 MR. CONWAY: Continuing on here, the third item in 19 the qualification of existing data that DOB has not 20 identified existing data by activity that needs to be 21 qualified for use in the licensing process.
22 I would point out three sections in the SCP that 23 strongly infer that existing data will be utilized in the 24 licensing process and the sections are, 8314.215, which 25 addressed magnetic properties and stratigraphic IIeritage Reporting Corporation (202) 628-4888
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! 1 correlations.
2 Surface and surface stratigraphic studies are 3 identified in Section 8314.211.
4 And Section 8314.311 identifies systematic 5 drilling program.
6 Any other questions on qualification of data?
7 (No response) 8 I will move on to our third bullet which is the Q 9 list.
10 As you are all awafe, certain items and activities 11 are subject to the QA requirements of a 10 CFR Part 60 12 Subpart G QA program, for both the preclosure and 13 postclosure phases of a repository.
() 14 Our concern in this area is related to the 15 incompleteness of the existing lists for these items and 16 activities and also to the rationale that DOE has used in 17 identifying items and activities to be covered by a 10 CFR 10 Part 60 Subpart G QA program.
19 A couple of examples.
20 In Section 6.1.5 of the SCP, it stated that only 21 the waste container and not the waste form will be on the 22 proposed Q list of items important to waste isolation.
23 A second example: We feel that the Q list should 24 be expanded to include items such as the dealgn to preclude 25 criticality, or another list should be created to identify
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4 Any questions?
5 DR. MOELLER: Yes. Bill and then Judith.
6 DR. HINZE: I would like to go back if I could to
- 7 qualification of exist.ing data.
8 is there some type of priority listing for the 9 qualification of the data?
10 1 am looking at the problem for example of the 11 exploratory shaft, and some of the data that was used in 12 siting the exploratory shaft.
13 That whole situation is very imminent. What O 14 er1 res are being made t pri ritize the qualification of 15 the existing data so that there can be a continual and 16 logical flow in the whole process? i 1
17 MR. CONWAY: I think this is one of the areas that
- j. 18 we are looking for a response from DOE as to going through 19 all these sequences, whether it is on the ESF or any other 20 aspects of the repository, that indeed they should know
[ 21 which data has to be qualified or should have a good feel l
22 for it.
23 And this is one thing that a far as I know how ve
- i. 24 haven't gotten a listing on.
25 DR. HINZEr Have you asked that they identify i
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(_j 1 these critical areas?
2 MR. CONWAY: Let me pass to Jim Kennedy here.
3 MR. KENNEDY: That is a good question on the 4 exploratory shaft, because they are using data in the design 5 of the exploratory shaft.
6 And the appropriateness of that data in the design 7 is one of the areas that we asked them to look at in 8 connection with the design acceptability analysis that we o 9 are doing for the exploratory shaft.
10 DR. MOODY: Does that data meet QA standards?
11 MR. KENNEDY: Some of it does, some of it does 12 not.
13 And what we said for the exploratory shaft data is
() 14 if you cannot meet the QA standards, then you need to be 15 able to make a case that the data is being used 4
16 appropriately. 1 J
17 That is, for example, that you have large margins 18 to take into account the uncertainty associated with the 19 data.
20 I don't know the exact status of our review of 21 that. I do know they are using some of that data, they have 22 put margins on it, they have tried to take into account 23 uncertainties. l 1
24 I don't know whether we have any comments at this 25 point on that.
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.!.f). ^ 1 Do you, John?
2 MR. LINEHAN: I think our design folks this 3 afternoon will be going into that and will be addressing 4 where they stand on the review of the DEA. And one of the 5 issues they are going to talk about is the existing data.
6 DR. HINZE: I would just like to observe that I 7 believe that it is very important that someone identify the 8 priority at which this qualifying of existing data takes 9 place.
10 Because one could l'ose all their time on data that 11 isn't needed for some time or it is pretty obvious that 12 there needs to be prioritization.
13 MR. CONWAY: I agree.
() 14 MR. LINEHAN: If I could just add, DOE is looking 15 at core data that was collected in the vicinity of the 16 exploratory shaft in trying to determine whether they can or 17 cannot qualify that data.
18 And that is ongoing right now. And if you wanted 19 any further elaboration, someone from DOE may be able .o 20 give it to you.
21 DR. PARRY: John, is that DOE or is that the USGS?
22 MR. LINEHAN: Well, it's DOE that is heading it 23 up, the project office. I'm sure there would be GS people 24 involved.
25 DR. MOELLER: Does anyone from DOE want to
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2 MR. BROCOUM: Steve Brocoum of DOE.
L l l
! 3 This is the core collector of the weld G core 1 1
4 which was collected by the USGS but now is in the possession
- 5. of the sample management facilities' cooperative effort to 6 see if they can qualify the collection of that core and how-7 it is handled, how it is collected, where it is right now.
O DR. MOELLER: Thank you.
9 DR. MOODY: When do you think that that is going 10 to be done, you know, the tisfie and effort for evaluating 11 which is usable and which is not?
12 Has there been a time frame? Is it going to be 13 done in two months' time, the end of the fiscal year?
() 14 MR. BROCOUM: I don't have the exact schedule. I 15 don't really know what that is.
16 DR. MOODY: Okay.
17 DR. MOELLER: Go ahead.
18 MR. CONWAY: Any other questions?
19- (No response) 20 MR. CONWAY: That concludes my presentation.
21 DR. MOELLER: For the people who are standing, are 22 there seats down there? If there are, let's go ahead and 23 use them.
24 MR. STABLEIN: Dr. Moeller, are you ready for our 25 second presentation?
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30-() 1 DR. MOELLER: I believe so. Let's go ahead.
2 MR. STABLEIN: All right.
3 I might mention that our transcriber here is 4 having trouble hearing some of the people, especially in the 5 audience. And so be sure to try and project your voice so 6 she has a fighting chance.
7 Our second presentation today is on geology and 8 geophysics.
9 The Section Leader of the Geology-Geophysics 10 Section is Philip Justice. 1 don't know if Phil is in the 11 audience.
12 Giving the presentation today will be Charlotte 13 Abrams. She was the lead reviewer for the Geology-() 14 Geophysics Section.
15 We also have with us today Keith McConnell, 16 sitting behnd Dr. Steindler; Buck Ibrahim, over here, who 17 worked on geophysics; John Trapp; Mike Blackford, who worked 18 on seismology; liarold LeFevre; Tom Cardone, all participated 19 in various aspects of the Geology-Geophysics review.
20 And as I say, some of these people are available 21 to help provide backup in their areas of expertise. J 22 I will turn it over to Charlotte for the 23 presentation.
24 DR. MOELLER: King, before you step down, this is 25 the first section where we have, you know, a rather complete i
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- 1 , text of', draft of what'.youlare thinking about.
2 In some of the-background material that was l
3 'provided to.us,'it was clearly stated that, or NRC clearly )
4 stated to the staff 'that they were not; serving as peer ,
5 reviewers for DOE's SCP, not should they be considered to be 6 performing that function.
7 I gather that is roughly a correct statement.
-8 MR..STABLEIN: Right.
9 DR. MOELLER: then when you look though at a
-;10 section such as Geology-Geopf[ysics, and I am not arguing 11 'with it', I think-what you have done is very well done. But 12 'you go through, if you take each concern, you go through it
'13 and you. clearly state the subject matter, you state some I
h 14 comments, you give the basis and all. And then you end up 15 with recommendations.
16 And if I were DOE I would very much appreciate the 17 recommendations, because in the recommendations you'tell 18 them exactly what approach you would consider acceptable for l
19 resolving this particular concern.
20 I just wondered how you, what is it, blend that or 21 make that compatible with your statement that you are not 22 performing a peer review.
-23 MR. STABLEIN: I am not sure whether we are 24 walking a very fine line or not.
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(,T/ 1 before is to examine the structure and logic of DOE's '
2 program in an attempt to identify potential problem areas.
l 3 As part of our contribution to the program, an 4 atteapt has been made to be specific in terms of what can 5 they do about it rather than to just leave DOE hanging with 6 some critical observations.
7 DR. MOELLER: And I fully concur with what you are 8 doing.
'9 You could stop without giving them the 10 recommendations. ButyouhafegonethatextrastepandI 11 find it very helpful.
12 I suppose you debated long and hard as to the 13 degree to which you offered guidance to them.
.( ) 14 MR. STABLEIN: This is all the scenario where we 15 have to be careful to stay on the right side of that.
16 DR. MOELLER: As I say, I don't object. I find it 17 very helpful. I assume though there will be people who will 18 question it.
19 MR. STABLEIN: Possibly.
20 Thank you, Dr. Moeller. Are there any other 21 questions before Charlotte comes up?
22 (No response) 23 MR. =STABLEIN: Charlotte? ,
24 MS. ABRAMS: Good morning.
l 25 I am going to talk about the Geology-Geophysics ,
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- 1 Section's point papers and concerns. And these are selected 2' preliminary concerns that I am going to discuss.
I' 3 Basically within the --
4 DR. PARRY: Charlotte,; excuse.me.- When you say 5 selected, does that mean'there are others?
1'
'_ 6' 'MS. ABRAMS:- .There are.others. This.is just some L
7- we selected to mention.
8 DR PARRY: This is:what rose to the top?
MS. ABRAMS:
9- Yes.
10 DR. HINZE1 .Again,'that goes back to my. question.
11 Are these the.most important ones or are these the ones you 12 are having trouble with, trouble defining, trouble trying to 13' establish just what the problem is?
(f 14 MS. ABRAMS: I think these are the ones we would 15 say are our biggest concerns.
16 DR. HINZE: Thank you.
l '7 MS. ABRAMS: I've delineated here in our 18 discussions, we have found that there are central themes in 19 our point papers. And those are a problem with integration 20 among investigations that appears to occur and also apparent 21 nonconservative numerical criteria that are defined within 22 the SCP.
23 Now, these central themes are umbrella topics
- 24. under which many aspects of our point papers will fall.
25 These themes I will elaborate upon when I get into
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( l the subdiscipline technical areas, l
2 Now, with respect to our exploratory shaft I i
I 3 -facility concern,.the Geology-Geophysics section exploratory 4 shaft facility concern relates to the DAA, and the apparent 5 failure to integrate all available technical data into the 6- ' shaft location decision making process.
7 And to elaborate upon that, the Bertram report is 8 cited as the basis for the decisions regarding the shaft 9 setback distance from faults. And this was stated as the 10 exclusionofalllocationsbfing100 feet from the nearest 11 fault.
12 However, other reports such as Smith & Ross note 13 the presence.of possible adverse structures whose presence
() 14 may violate the parameters that were cited in Bertram.
15 Therefore, the design process may have overlooked key 16 information about the suitability of the shaft locations and 17 shaft locations should be re-examined or re-evaluated based 18 on available data.
19 I will go on into our concerns with respect to 20 tectonics. And we have divided that up into several areas, 21 the first of which is faulting.
22 DR. HINZE: Excuse me. .
I' 23 MS. ABRAMS: Yes.
24 DR. HINZE: Charlotte, before you move on, a 25 question about the exploratory shaft. !
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is ,) 1 Is it correct that the whole total appraisal of 2 the ESF or the exploratory shaft has been redone after ti.e 3 relocation of the shafts to be concerned about the position 4 in the wash and the erosion problem?
5 There was some confusion as I read the documents.
6' MS. ABRAMS: They did re-examine this. Do you I
7 want to go into more detail, Keith? i 8 MR. McCONNELL: Well, they went through quite an I
9 effort. Keith McConnell, NRC. They went through quite an '
10 effortcalledthedesignaccfptabilityanalysis, that went 11 back and looked at the design and the locations of the ]
12 shafts where they are now.
13 DR. MOODY: is this the Title I design?
~
14 MR. McCONNELL: Yes.
15 DR. MOODY: Okay.
16 DR. PARRY: Charlotte, did you also address the 17 question about location of the shaft within the block that 18 is representative of the whole structure that the repository 19 is going to be in?
I 20 MS. ABRAMS: That is one of our programs and'that j 21 is one point I will discuss in here, yes.
)
22 Under the heading of " Faulting" the first general 23 concern was that alternative conceptual models are not fully 24 integrated into the site characterization plan for l l
25 tectonics.
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/5' y 1 And some examples by way of models that we think
'2 could possibly be considered would be a model in which
. . 1 3 faulto in and outside of the emplacement areas are related I i
4 to each other. 1 l
5- Therefore the slip rates on faults outside of the j 6 emplacement areas would bear on the prediction of expected j i
7 movement of faults which are inside.
l 8 Another example of a type of model would be a 9 model in which all favorably oriented faults within the 10 contextofthestressfield[ntheYuccaMountainareawould 11 be susceptible to failure.
12 Now, with respect to faulting there was also 13 identification of an apparent integration problem and that
() 14 was with respect to the detachment studies which are in the 15 preclosure part of the SCP.
16 And we did not see where there was a direct link 17 to the post-closure and feel that these studies should be 18 input to post-closure performance issues.
19 The next heading under " Faulting," the next 20 concern, is the post-closure performance program appears not 21 to be integrated with the waste package and performance 22 issues.
23 There is no clear integration in the SCP of post-24 closure tectonics data into the issue resolution strategy 25 for performance issues 1.4 and 1.5 which are essentially
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(_ I will the waste package and the repository barrier system 2 meet the performance objectives.
3 Now, in our discussions yesterday with the DOE, 4 they feel that we may have missed something and we intend to 5 _ revisit this topic.
6- We still don't see a direct link, but there may be 7 an indirect link.
8 So this is one topic area that we would have to go 9 back into.
10 With respect to s11'p rates, it appears to us that l
11 the uses of slip rates alone are not a conservative approach 12 and may result in optimistic predictions about the effects 13 of faulting on the system performance.
(G s,j 14 To elaborate on that, slip rate averages offset 15 along a fault over a series of events and it appears to 16 obscure the episodicity of faulting an offset that could 17 possibly occur within a single event.
18 And another problem in that area is there is an 19 uncertainty with respect to the total offset on faults due 20 to the uncertainty in determining the degree of offset on 21 strlke slip faults or the degree of lateral motion.
22 DR. HINZE: Excuse me. In your review are you 23 satisfied that the strike slip rates have been well enough 24 ascertained? l 25 MS. ABRAMS: No. They say that they have problems
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) l in ascertaining strike slip rates. The DOE admits that is a 2 problem.
3 DR. HIhZE: Your concerns here about this, are 4 these i>ased upon the general knowledge of the staf f of the 5 Geology-Geophysics of the basin and range area and the Yucca 6 Mountain in particuler?
7 Or are you going back and looking at original 8 data, data that were collected by the U.S. Geological Survey 9 and DOE 7 10 What depth are you' going into to come up with ,
11 these concerns?
12 MS. ABRAMS: This is based on literature from the 13 basin and range and also U.S. Geological Survey reports that r
14 have also been produced with respect to this program.
15- DR. IIINZE : Are you looking at any of their data 16 and looking also at the quality of their data, that really 17 goes back to the qualification of existing data?
18 MS. ABRAMS: With respect to data we see some data 19 in reports.
20 But we have not conducted a data review as such 21 since 1984, on geology.
22 DR. SIIEWMON : Is there a criteria that was set by 23 DOE saying that slips beyond this rate in that particular 24 area would cause a concern of this sort?
25 Or is this more a matter of we want to have this O
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(_) 1 general knowledge of the field because then we will feel 2 more comfortable about it?
3 MS. ABRAMS: Well, there are values given. And 4 actually I will get into that in a minute, 5 But if you want to address that now, Keith, or do 6 you want to wait?
7 MR. McCONNELL: Keith McConnell again.
8 In their performance allocation tables they have 9 goals and estimates that relate slip rates to faults in and 10 near the repository. ,'.
11 And our concern is that the rates that are given 12 as goals do not adequately encompass the amount of 13 uncertainty that is imparted to the slip rates by this
() 14 inability to determine lateral motion on faults.
15 DR. SHEWMON: Let me come back to my original 16 question.
17 Let's say that it was really off by a factor of.2.
18 Do they talk about how that would make any 19 difference? Or do you have something that puts it in your 20 mind that makes it different? Or is it just a matter of 21 professional price that you like to do it better than that?
22 MR. McCONNELL: No, it is more than that.
23 It is, in our view the uncertainty would have much 24 greater effects on possible performance in the repository l 25 than the DOE bas alluded to in the performance cllocation l
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() 1- tables.
2 We feel that as they have addressed it they will 3 not encompass that uncertainty, and therefore there is an 4 impact-on performance, possible impact on performance, if it 5 is off a magnitude, order of magnitude.
6 So we don't think that they have bounded it.
7 DR. MOODY: Do you think that it also is an impact 8 'that influences the exploratory shaft design, repository 9 design?
10- MR. McCONNELL: I ' th' sorry . Could you repeat that?
11 DR. MOODY: What I said is, we are talking about 12 the rate of, strike slip rates of movement or possible 13 movement along the strike slip and along also existing
() 14 faults.
15 Don't you think that that also will influence the 16 necessary input to the design of the shaft and the 17 repository? Or do you think it is trivial?
18 MR. McCONNELL: Certainly the repository is going 19 to be impacted by the presence of faults within it and also 20 the waste emplacement design would be affected by that, I 21 would assume.
22 Now, the exploratory shafts themselves and their 23 locations I am not sure that it necessarily would be 24 affected.
25 DR. PARRY: Charlotte, have you found that the ]
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() 1 Department has been perhaps selective in the choice of their 2 data or references? In other words, perhaps have you found 3 references that they have not made use of or taken into 4 account or that they have not balanced all the data within 1
1 5 the references that they have before them?
l l' 6 MS. ABRAMS: I would not say that has occurred 7 with respect to faulting.
8 There may be some problems in other areas with 9 respect to some of the choices of references such as natural 10 resources. But I would not say that is a problem in 11 faulting.
12 Another area of concern with respect to faulting, 13 and we have touched on this already, is that the
() 14 characterization, design and performance parameters appear 15 to be non-conservative of quality, and performance 16 parameters, characterization parameters and goals proposed 17 for fault displacement, particularly for facilities 18 important to safety, appear not to be justified.
19 Some examples of this are that faults appear to be 20 considered as single strands of narrow width rather than the 21 wide ridge zones that are so commonly associated with faults 22 in the Yucca Mountain area.
23 Another example is that postclosure 24 characterization, the postclosure characterization parameter 25 for the investigation of faults in the repcsitory is
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.V 1- characteristics of faults with greater than ten meters of 2- offset. And this may not consider the cumulative offset of 3 faults in a fault zone.
4 Another example is that the preclosure 5 characterization parameters for identification and 6 characterization of significant faults in the repository
.7 block is limited to those faults that have greater than one 8 meter of offset of quaternary material and greater than 100 9 meters of offset of tertiary rocks.
10 We feel'this is liSited and may miss some 11 important faults.
12 Another example is that there are assumptions that 13 future faulting will follow old fault patterns. We believe
-( ) 14 that is conservative.
15 We are also uncertain as to how the standoff 16 distance will be used in designing the program 17 investigations in performing design and analysis for the 18 surface facilities. 3 19 And the waste emplacement area relies on a seven 20 centimeter air gap and we believe episodes of faulting have 21 exceeded this.
22 Any questions on that part?
23 (No response) 24 MS. ADRAMS: Okcy. I am golng to go to the topic 25 of vulcanism under tectonice.
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V 1 DR. SilEWMON: Let me come back to this once more.
2 If I find the right person, will I find a model which would 3 talk about how any of these concerns would influence the 4 performance of the container or the way that he fuel is 5 emplaced, the waste?
6 MS. ABRAMS: Would you find a model that would 7 talk about that?
8 DR. SilEWMON : That way say, given this kind of 9 differential, different distribution of faulting or 10 different faulting rate, that'would come down to how this 11 would impact on risk, and that would then have to go through 12 a model of how it releases waste.
13 MS. ABRAMS: You are saying would you find a model
? 14 like this in the literature?
l 15 DR. SHEWMON: No. Would I find it anyplace in 16 DOE's proposal or anything behind -- I mean, you have 17 concerns. I want to know what the basis for these are. You 18 are asking a bunch of questions. Nobody can ever predict 19 where that fault is going to occur and so you have to come 20 back at it and say well, so what? If it comes at a 21 different place, what has to happen before I get in trouble 1
22 or before the public health and safety is endangered?
- j. 23 MS. ABRAMS: l We dcn't believe we see a model that i i
24 encompasses all of these concerns in the SCP.
I 25 Mlt . McCONNELL: ThEy do haVO Scenarios which they
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L 2 Our concern is that there are episodes of faulting 3 out there that have exceeded the design that they have in 1
L 4 the repository around waste packages which they are relying j l l 5 on to meet the performance objective in CFR 60. ]
6 Now, these are outside the repository, these 7 faults that have exceeded, at - 'st the ones we know of.
! 8 What we are asking t; to do is look at these 9 faults outside the repository and come up with a model of 10 faulting within the repositofy that it possibly encompasses 11 that, and input that into your design in the waste 12 emplacement areas.
13 In other words, if you are in an area of faulting,
() 14 you would want to consider not putting canisters Jn that 15 zone.
16 And that is basically what we are asking.
17 DR. SHEWMON: But if you won't admit that you have 18 any way of predicting where the faulting can occur, then you 19 have to know something about how that faulting will impact 20 the emplacement or else you say the whole game is off.
21 MR. McCONNELL: There are ways of predicting it 22 and that is what your models are for.
23 DR. SHEWMON: That is what I am asking about.
24 Where do I find the models that would predict how this 25 faulting would impact the waste canisters?
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( 1 MR. McCONNELL: You have tables of models that 2 define or attempt to predict faulting in the repository.
3 DR. SHEWMON: Tables of models. That boggles 4 some. l 5 MR. McCONNELL: Well, they are alternative 6 conceptual models.
7 DR. SHEWMON: Okay.
8 MR. McCONNELL: And they list the relevant 9 hypotheses or what are believed to be the relevant 10 hypotheses. Andthereisafreferredhypothesisthat the 11 DOE is using.
12 And these will be inputted into the scenarios to 13 determine how waste isolation might be affected.
() 14 DR. SHEWMON: And that is in this 6,000-page 15 proposal or in supplementary documents?
16 MR. McCONNELL: That is within the 6,000-page 17 document.
18 DR. SHEWMON: Okay. Thank you.
19 DR. PARRY: Charlotte, perhaps Keith could provide 20 a reference for that for Dr. Shewmon and just pass it on to 21 me and I will pass it on to Dr. Shewmon.
22 MR. LINEHAN: Dr. Shewmon, I think -- oh, John 23 Linehan. The questions you arc asking I think could be 24 addressed direct by our waste package statf this afternoon.
25 The geologists are providing input to the waste
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4 DR. SilEWMON : Okay. Thank you. l 5 DR. MOELLER: Dr. Moody.
6 DR. MOODY: Can 1 ask one question?
7 When you'say that there has been observed strike 8 slip, have measurements been made for the region? You are l 9 talking about the region outside the proposed repository. l t
10 IIave actual measurements been' made on observed strike slip?
11 MR. McCONNELL: Keith McConnell again.
12 For the region, there have been, particularly on 13 some of the more active faults over in the Death Valley e
14 area.
15 There have also been estimates made for some of 16 the Northwest training faults which in some models aro not 17 considered active any more.
18 But there is also a reference, Swadli and others, 19 USGS, which indicates that there is a great deal of 20 difficulty in measuring strike slip offset in the order of I 21 think 3 meters or less.
22 In other words, if it around 3 meters, they may 23 not be able to assess it with current technology.
24 DR. IIIl1Z E : Isn't it true that a great deal of 23 focal mechanisms in the basin range shove strike slip f% Corporation
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(_) 1 movement?
2 DR. MOODY: Yes.
3 DR. HINZE: That's a primary movement.
4 Let me ask another question.
5 In your review of the documents and the 6 literature, do you feel that the DOE hat mapped and 7 presented in the SCP evidence that they have mapped all the 8 faults in the Yucca Mountain area?
9 MS. ABRAMS: I don't think they would even say 10 that. There'is some uncertal'nty.
11 DR. IIINZE : How do you see this uncertainty being 12 resolved?
13 MS. ABRAMS: Well, they have conducted surfacial O 14 mapping. But there is always the likelihood that in the 15 rock body that you are looking at you may not see evidence 16 of faulting if it is concealed at the surface.
17 They may find more when they get below the 18 surface.
19 Also, good geophysics could possibly help that 20 interpretation.
21 DR. IIINZE: I gather that you feel that some of 22 the resistivity studies, for example, have not been taken 23 into account properly in defining some of the faulting?
24 MS. ABRAMS: I don't know that that is 25 particularly true. I think I would refer that question to lieritage Repcrting Corporation (202) 628-4888 {
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.1 Buck --' I bra him , though. He is our geophysicist.
2 MR. IBRAllIM: Buck Ibrahim from NRC.
3 There was one other report by Ross and Christenson 4 which you'are talking about, and'which is some resistivity' l
- j. 5 study,.and they found an~ anomaly very close_to the 6' exploratory shaft and were' raising the question what is, how 7 much confidence-you have in this report. And I think DOS is 8 trying to look at this paper again and examine it and see 9 what is. exactly the outcome of that report.
10 So there is some r6'sistivity that has been done in; 11 the viciinity. of theshaf t, but looked over in a large area 12 of the exploratory shaft.
13 DR. iiINZE: Buck, has there been any GPR, any h 14 ground penetrating radar done in the area?
15 MR. IBRAHIM: No, I am not aware of GPR in the 16 area. That is one of the things we are asking DOE to look 17 at and investigate if possible.
18 DR. HINZE: That would be a fairly high priority 19 item?
20 MR. IBRAHIM: And also we are talking about high 21- resolution seismic complexion in the area. And all this we-22 will put on the table for the DOE to take into 23 consideration.
L24' DR. HINZE: Thank'you.
p ,
25 DR. MOELLER: Any other questions on that? _;
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! 49 1 (No response) 2 DR. MOELLER: Go ahead.
l 3 MS. ABRAMS: Now on the bottom, on volcanism 4 under tectonics, again it appears that alternative 5 conceptual models had not been fully considered with respect 6 to volcanism.
7 It appears that boundaries for models are aerially l 8 restrictive and the physical domain is limited to the 9 Southern Great Basin which appears to be too limiting and 10 perhapsDOEshouldconsiderfreasoutsideoftheSouthern 11 Great Basin. For instance, the Death Valley Pancake Range 12 Volcanic Belt, which does go through the site.
13 With respect to natural analogs, again the Death
() 14 valley Pancake Range volcanic zone stems through the site 15 and processes that resulted in the formation of the lunar 16 crater volcanic field, which is in the Northern part of that 17 Death Valley Pancake Range volcanic zone, may be applicable 18 as a natural analog.
19 Under volcanism, another concern is the tentative 20 performance goals and parameter values.
21 A 70-kilometer parameter limit on some of the 22 volcanic studies excludes lunar crater basaltic field and 23 the seam of basaltic field analogs. That is a concern.
24 Also, there appears to be a reliance on volcanic ,
25 rate calculations which are cone counts and magma volume. j l
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() 1 And this is developed largely independent of 2 consideration of underlying processes, and volcano tectonic 3 processes. And it could underestimate the potential impacts 4 on the performance of the repository.
5 DR. MOELLER: In that line, you commented in the 6 written material that the term parameter goal appears to 7 have been inconsistently defined in various parts of Chapter 8 8. In tieing back into one of my earlier comments, I 9 quickly then looked at the glossary to see if parameter goal 10 was defined there. And it is not.
11 Had it been or if it is this important, then why 12 isn't it defined?
13 You know, it is not your problem, it is DOE's
() 14 problem, but I would think if it is a key term or phrase, it 15 should be in their glossary.
16 MS. ABRAMS: You will probably hear some more on 17 this topic from the performance assessment people this 18 afternoon. But Keith, do you want to elaborate?
19 MR. McCONNELL: No.
20 MS. ABRAMS: Okay.
21 An additional concern is that the tentative goal 22 with respect to the probability of basaltic volcanism is l i
23 such that it appears that the site will not meet the EPA '
24 standard.
1 25 With respect to integration -- I 1
i
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51 rs l,_) 1 .(Laughter) i 2 DR. SMITH: That was a mouthful. Could you 3 elaborate on that one a little bit?
4' MS. ABRAMS: Well, I think we will have our 5 expert, John Trapp, elaborate on that one.
6 MR. TRAPP: This one came up during -- John Trapp l
7 from the NRC.
8 This one came up first off during the CDSCP 1
l 9 review. It came up yesterday as raising a few concerns and 10 questions, also.
11 It is a-combination of a geologic problem, a 12 performance assessment problem, and a performance allocation 13 problem.
() 11 What it amounts to is there are goals set within 15 the SCP on voli:anism which greatly exceed any value which 16 would allow the site to meet the EPA standard.
17 Now, ty the same token, the DOE --
18 DR. PIRRY: I'm sorry. I have trouble following 19 that.
20 Could yct clarify that last part?
1 Okay.
21 MR. TRAPP: In specific terms, the DOE has 22 set a goal for volcanic parameters of probability, of an 23 annual probability of 10 to the minus 6.
24 Now, if you assume a straight random event, this 25 would be basically 10 to the minus 2 or 10,000 years.
r'
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't) . 1 This is much greater than 10 to the minus 3, 10 to 2 the minus 4, over 10,000 years, which is the requirements to 3 stay within the EPA standard.
4 The consequence that is stated within this thing 5 ba-ically comes out to an EPA ratio of 170 using the 6 reference inventory that DOE uses.
7 So you have a value, and I would have to draw it 8 up on the board, but if you took the curve and took this 9 value and plugged it in you would be sitting way pnst the 10 excedence. ,
11 Now, carry it a step further.
12 DOE states that their expected value is much less 13 than this. The expected value that they have is such that O 14 it - #1a re11 ituie tne re ee, there1 ore "ot vio1ete tue 15 standard.
16 Now, the real questlun we have here like I said is 17 dealing with the whole performance assessment, performance 18 allocation, because in going through there they are setting 19 a goal which if the investigator is going to follow, and if 20 he meets this goal, the site falls, there is something L 21 missing in the whole performance allocation if you are not 22 driving the program by goals that would help you meet the 1 23 standards.
l 24 DR. PARRY: What do you mean by goal? Isn't the l
L 25 probability of an earthquake or an event not a goal but a L
l
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-( ) 1 physical parameter of the site?
2 MR. TRAPP: Not the way the whole performance 3 allocation process is bound together.
4 There are goals for instance on faulting which say l
l 5 we will have a probability of 1 times 10 to the something, i' 6 that this fault will not more than such and such. This is a 7 goal. This is something they want to prove by their
! 8 investigation, 9 DR. MOODY: Is the EPA standard the frequency or 10 the potential frequency for s'olcanic activity? What is the l 11 EPA standard?
l 12 MR. TRAPP It is more than that. It is a sum of 13 all the processes which could occur during the post-closure,
.() 14 and the consequence of all these processes.
15 The thing is, when you put the whole thing 16 together and add volcanism in there, this is one of the 17 scenarios that on this site unfortunately is going to have 18 to be considered.
19 And like I said, the goal that we had set would 20 cause the site to fail.
21 The expected value by itself would not cause the 22 site to fail. It is because performance allocation is i
23 supposed to help you decide which studies you do, how much I 24 money you put in the study, how much time you put in the 25 study. There is something that is backwards in the way I
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-5 1 this whole performance allocation went together, at least in 2 this example.
3 DR. MOELLER: And you are saying that DOE set, the 4 term you are using, the goals. And supposedly if you set 5 goals, which I would have defined a the limits, the 6 acceptable limits on certain key parameters, then those 7 goals should, you would have thought would have been set so 8 that as long as you are within that limit, you are okay.
9 But you are pointing out you are not okay. You 10 are outside.
11 MR. TRAPP: Basically you took the punchline out 12 of our comment because that is what the punchline was that 13 we would expect them to be set within the limit.
() 14 DR. MOELLER: Okay.
15 MS. ABRAMS: Finally, another concern under 16 volcanism is that there appears to be a lack of integration 17 between volcanic studies and other tectonic studies. For 18 jnstance, the regional faulting studies, or other mapping 19 studies.
20 Now, we were out, last week several of us, out in 21 the field with DOE inve9tigators. And we did see again this 22 problem existed.
23 We had an excellent meeting with them. They have
': 4 excellent people working on the project. And we -- many of 25 our comments with respect to the SCP still stand and we do
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(,) I have to comment on the SCP record.
2 But they do have good people working on this, and 3 we did have an excellent interchange with them.
l 4 DR. SMITH: Do you feel that there are concerns or 5 questions that you raised that they share snd that they are i
6 moving towards being able to address these issues? 1 l
7 MS. ADRAMS: Some of them.
8 DR. MOELLER: Back on the previous item, the 9 question has been raised as to how much of this might be 10 semantics? '
11 In other words, you are using words differently 12 than DOE is using words. Maybe their idea of a goal is 13 different than your idea.
() 14 You are sure you are defining the goal the way 15 they mean it to be?
16- MS. ABRAMS: I think we can only interpret it as 17 it is presented to us in the SCP.
18 And if they do mean something else by it, I don't
]
19 think they have gotten that across to us in the SCP.
20 DR. HINZE: I take it from your comments that you 21 feel that the group with DOE that is working on this problem 22 is coming to grips with it in a more substantial way than is 23 expressed in the SCP.
24 1s that correct?
25 MS. ABRAMS: Well, we did see some things that
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(_) 1^ they are doing that we were not aware of from the SCP. That 2 is not to say that all of our concerns are resolved. And we l 3 are commenting on the SCP, not on the visit with them.
l l
4 DR. HINZE: Is that because you don't have in your l 5 hands the plans? l l
6 DR. MOODY: Are those in the site study plans?
7 DR. IIINZ E : Are we worried here because we have a 8 document that, despite the 6,000 plus pages, is not 9 complete, we are looking for the plans, and is therefore 10 somewhat just smokewithverflittlefire?
11 MS. ABRAMS: It almost seems like you talked to me 12 before this meeting.
13 We would love to have some of the plans. The
() 14 volcanic studies are ongoing studies, and have been ongoing 15 for a long period of time. And that is one of the study 16 plans that we are very anxious to get.
17 DR. MOODY: You haven't seen it yet, though?
i 18 MS. ABRAMS: No. No, we have not.
19 DR. HINZE: have you encouraged the DOE to, in 20 their revision, in their semi-annual revision of the SCP, to 21 elaborate on some of these activities that are underway and 22 some of their results? Will we see those?
23 MS. ABRAMS: We will see the elaborations in the 24 study plans.
25 DR. IIINZE: In the revisions.
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() _ 1- MS. ABRAMS: Well, actually in the study plans 2 themselves.
3 DR. HINZE In the plans themselves.
4 MS. ABRAMS: Yes.
5 DR. IIINZE: Okay. But not in the SCP, which is 6 brought up to date on a semi-annual basis.
7 MS. ABRAMS: I don't think that is actually the 8 intended level of detail for the SCP.
9 DR. MOELLER: I know that DOE has told you or 10 given the NRC a tentative scftedule for the issuance of the 11 study plans, because you know, we have seen the first five 12 or ten or so.
13 Do you have an opportunity to tell them that here
() 14 are some key study plans that we would like to have 15 expedited?
16 MS. ABRAMS: I think that should be a question 17 that King Stablein should answer really.
18 DR. MOELLER: Okay. In other words, do you have 19 input into the sequence in which the study plans are 20 provided to you?
21 MR. STABLEIN: We had a meeting on December 15 22 with the DOE at which time we discussed the content of the 23 study plans, some differing views as to what would be in 24 those and we also discussed a schedule of the study plans.
25 At the time we indicated that we would recommend DOE give
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'V 1 priority to certain study plans as opposed to others and 2 amongst the group that we emphasized were the ongoing 3 studies such as the volcanic studies.
4 We followed that up in a letter to DOE which 5 accompanied the meeting notes from that study plan meeting 6 re-emphasizing the point and we continued to engage in an 7 exchange of letters with DOE on the topic of schedules for 8 study plans.
9 DR. MOODY: When are you going to get the one in 10 volcanology?
11 MR. STABLEIN: At this point, there is no way of 12 telling, according to my information.
13 DR. PARRY: Charlotte, wasn't there a study plan O 14 or a work outline dated about 1983 in this area? I thought 15 I saw one.x 16 MS. ABRAMS: I am not familiar with it. I wasn't l
17 here in 1983.
18 MR. McCONNELL: Keith McConnell again, NRC.
19 That was a work plan, I think that we requested 20 from the DOE and they sent us.
21 DR. PARRY: What is the difference between a work l 22 plan and a study plan?
23 MR. McCONNELL: Quite a bit. About 100 pages.
24 (Laughter) 25 DR. MOODY: Is the site study plan more detailed?
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()\ 1 MR. STABLEIN: Yes, it is.
2 DR. MOELLER: Is this problem included, King, in 3 any of your concerns, the sequence of the study plans, or 1
I 4' the lack of a study plan on volcanism?
j 5 MR. STABLEIN: I don't believe that the timing of 6 the study plans is part of our comment on the SCP itself i 7 which is at the level of detail above the study plans. I 8 believe that this would primarily have to be handled apart 9 from the SCP.
10 DR. MOELLER: Dick' Foster.
11 DR. FOSTER: Maybe you can help me understand 12 little bit more on the significance of these goals, 13 Is this a situation where if they clearly can meet O 14 ene 9ee1 thet eeee tie 11v v e ere n e tree e tuet 15 particular item; if you don't meet the goal then you have to 16 study the situation further in order to qualify it, quantify 17 it and fit it into a larger picture to see whether the site 18 is still okay?
19 MS. ABRAMS: Some of our concerns are with the 20 goals themselves. So whether they meet the goal or not is 21 really not the concern, in a lot of cases. It is the goal 22 itself.
23 MR. TRAPP: John Trapp again.
24 Part of what you are asking really goes beyond the 25 level that you will find in the specific discipline of
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l 60 (O_/ 1 geology, et cetera.
2 What you are asking is getting into the whole l
l 3 series of performance assessment.
l 4 Now, there are concerns with the overall goals, 5 the way these goals are carried into performance' assessment l
l 6 and how these will be factored into the overall plan.
7 You have to take a look at, well, for instance 8 going back to something like the 7 meter air gap and tfie 9 rest of this type of thing.
10 Therearegoalsthftarebasedonthis. But then 11 you take a look at the analysis, the performance say for a 12 61.13 where they are talking about the engineering barrier 13 system, and there are assumptions made that under
'A 14 anticipated process and events, for instance, that there
()
15 will not be anything more than lipostatic stress on the 16 waste package.
l 17 Therefore, if you start going back and work into 18 faulting, if faulting occurs, and if you put this lipostatic 19 stress on the waste package, therefore it is not the same 20 assumption that is being used in the performance assessment.
21 If you go into the overall performance assessment, 22 one of the assumptions is that you will have this air gap, 23 therefore water will not have a direct contact with the 24 waste package, and you carry this thing all through.
25 If faulting occurs, you have the stuff up against 1
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I the waste package, you start bringing it in, then your 2 performance assessment for overall systems is different than 3 the baseline case.
4 So you cannot take a look at any one of these and 5 look at it in isolation. You have to carry it through from
'6 the discipline all the through the performance assessment to 7 the. ultimate product before you really have an answer. And 8 it is one of the things that makes this whole systems
, 9 approach rather complicated.
10 DR. FOSTER: This is why you are saying that there 11 is some evidence that they may have approached the problem 12 from the wrong direction?
13 MR. TRAPP: It is our opinion, yes, in some cases.
14 DR. FOSTER: Instead of looking at the performance 15 assessment and working backwards.
16 MR. TRAPP: Well, you have the disciplines which, 17 let's face it, I am basically a geologist, I want to look at 18 all the geologic stuff. You have people coming in from this 19 place. You have the people coming from the performance 20 assessment. And what we are trying to do is meld these 21 together.
22 Now, in some cases we do not think the mesh has 23 quite made it. It is an extremely difficult problem. It is 24 one that both sldes recommend, recognize it is an area -- we 25 have talked about a lot more this afternoon but it is an floritage Reporting Corporation (202) 628-4888
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r~g 1 km) 1 area -- where DOE and NRC need to.get together so that we 2 can really work out some of the differences we have in how 3 you do the overall performance assessment.
4 DR. FOSTER: Thank you.
f 5 DR. MOELLER: Cliff?
6 DR. SMITH: I was going to say you have touched on 7 an issue that was bothering me as I listened to all this.
8 And that is that it makes you wonder when you 9 listen to all of the details that we are getting into, are 10 we ever going to get to a pol'nt where someone'is willing to 11 make a decision or judgment that perhaps this site makes 12 some sense?
13 It seems to me you have your performance lh 14 . assessment procedures. And I would think that the most a
15 important thing is that you and DOE kind of agree on what 16 those are and then maybe in a scoping way begin to look at I
17 broad issues, is it okay, and then begin to focus those 10 down.
19 I guess my feeling is that there is no end to the 20 research that one can do on this whole matter. We can keep 21 geology going forever. But at some point we have to come to 22 some rational conclusion as to whether or not we think we 23 can engineer a repository in Yucca Mountain.
24 And so the question is, how much in detail do you 25 want to get into proving it and proving it and proving it,
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'(). 1 in every little detail, so when you go in a licensing 2 hearing you can answer any question,that ever comes up?
, 3 MR. TRAPP: You basically are getting into an area t
f.. ,
4 which has been raised a. couple of. times by the Commission 5 and a couple times I think by DOE -- are we pondering the !
'6 imponderable?
7' MR. BROWNING: There is a mechanism that is 0 available. It is just neither DOE nor we have got it moving 9 yet in the right direction, is my impression.
10 And I think you wil'1 hear that more when you talk 11 about the performance assessment late this afternoon. That 12 is the thing that theoretically should tie all these boxes 13 together and make sure they fit, or if they do not fit you h 14 make them fit, or if one is that you are studying it to 15 death and you do not need to, because it is not really 16 Important, that is the mechanism that should allow you to 17 rationally decide that. And it is not in place yet to the 18 degree we need it to be.
19 MR. TRAPP: I think there is another point that 20 needs to be made.
21 It is much easier to sit and criticize the program 22 of DOE I think than in some cases to do it.
23 We are making a lot of criticism about the 24 program. But the point that also has to be recognized is 25 the amount of progress that is being made. There has been a O neritese Regeruno cergereuee (202) 628-4888 i
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7 M '64
-q D 1 lot of progress since the CDSCP, and we are kind of locked
- r. 2 in place in commending on the SCP when in many ways we.know 3 .there are study plans, we have seen.maybe bits and pieces of 4 the study plan, we have seen a lot of reports which aren't 5 . referenced in the'SCP.because that'wasn't. logged in time.
s 6 There is progress being made on all these areas.
l 7 Maybe not enough, but we are getting there.
8 DR. MOELLER: Well, and in that line,.in the 9 material that was provided to us, there are dozens of,-and I 10 forget just-what is a common' phrase to use to cover whether 11' it is an objection, a question or whatnot. But there are 12- dozens of concerns which your bottom-line.is, this is-13 resolved.
h 14 So;there is progress being made.
15 DR. ORTil: I guess I have one question that goes 16 with that.
17 It seems with every concern that is resolved, we i
18 generate a couple more. So we may be making progress in 19 resolving concerns. But what about the total number of 20 concerns that are at steady state right now? Are they going 21 .up or going down?
22 DR. MOELLER: IIere though, I am sure you realize 23 for example, the DAA had not been seen before this stage and 24 in fact it wasn't even with the SCP, the statutory SCP. It 25 came a few weeks later.
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N_) 1 And all of those concerns are new because that has !
2 never been reviewed before.
3 DR. STEINDLER: Can I go back to this volcanism 4 thing?
5 I finally dug out the right sheet of paper and'I 6 think I know at least what my problem is. And let me see 7 whether it is of any use to identify it.
8 You make a comment -- I guess I can read this 9 thing, since it seems to be tentative.
10 In the specific case of volcanism intersecting the 11 repository, the consequences are sufficiently high that the 12 probability goal should be set to assure that if met the 13 scenario would not by itself cause the site to fall.
.t 14 That is a fairly clear statement with one major 15 problem.
16 And that is, it sounds as though somebody from the 17 outside world is going to start setting the probabilities of 18 earthquakes. And that is not I think what you meant.
19 We don't set the probability of earthquakes. We 20 guess at them. They are going to be what they are. And I 21 think therein lies the problem. What does somebody mean 22 when they say they are setting the probability goal?
23 And it gets so intimately tied up to the 24 performance allocation process, that the statement, if 25 isolated, and read by itself, which is what you are doing,
() IIeritage Reporting Corporation (202) 628-4888 i
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2 That is where I got hung up and it to me a while 3- to listen to that conversation over there.
4 5
6 7
8 9
10 '
11 12 13 f '14 15 16 17 10 19 20 21 22 23 24 25 l
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(,) 1 MS. ABRAMS: I don't have a response.
2 DR. STEINDLER: It requires no response.
3 MS. ABRAMS: Bear in mind, these are preliminary.
4 DR. STEINDLER: Yes, I understand thal.
5 MS. ABRAMS: All right, we will move on to 6 seismicity and our concern in seismicity. And thia also was 7 CDSCP concern, and it deals with the 10,000 year cumulm ive 8 slip earthquake concept. Appears to be a nonconservative 9 approach. And essentially if you need elaboration on that, 10 1 can give you some, and Mike Blackford is here, our 11 seismologist, and he can elaborate much more fully on that.
12 DR. STEINDLER: You made the comment several times 13 on the nonconservativeness of the DOE document and that was (r ]) 14 a major issue raised earlier. Would you say that there has 15 been any significant progress toward a more acceptable 16 conservatism overall that you have seen in this section?
17 MS. ABRAMS: I can't really think of any numerical 18 values that have changed drastically. Now they have 19 resolved some of our concerns with respect to seismicity.
20 Mike, would you like to say anymore on that? Do 21 you see anywhere where nonconservative values have been 22 resolved from the CDSCP to the SCP?
23 DR. MOELLER: Give us your name for the record.
24 MR. BLACKFORD: I'm Mike Blackford.
25 I'm thinking back to some of the comments 1 have rn (j IIeritage Reporting Corporation (202) 628-4888 1
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68 1 4
-1 stated that weren't resolved. In most cases they were on a
2 ' seismicity and this had to do with offsets associated 3 .with -- well, if you --
4 DR. MOELLER . Can you make it louder, please?
- 5 'MR. BLACKFORD: Okay, these offsets had to do more
.I 6 with the problem affecting the groundwater and the responses 7 of the DOE were-adequate to demonstrate the effectiveness.
8 MS. ABRAMS: Keith.
.9 MR. FCCONNELL: Keith McConnell, NRC.
- i. h . ,
10 I think they have 6ecome more conservative in.the 11 area of alternative conceptual models. They have provided
.12 these tables outlining the alternatives, and they do put 13 their preferred hypothesis in there, but it does address 14- that.
- 15. DR. SilEWMON : Maybe my question has been answered 16 and maybe it hasn't. But I wanted to ask the same question 17 .I'had before of, okay, so the earthquake is bigger or more 18 likely. The stuff gets shaken more often. So what?
19 Now faulting or shifts, I can see that that would 20 make a difference. But these canisters sure aren't going to x 21 be bothered by any type of an earthquake we design nuclear 22 plants to. If it's right in the middle of a fault like
- 23. Ilumble Bay was, why then maybe you have got a concern. But 24 if it's not, I have trouble knowing. So what?
I
- p. . 25 MS. ABRAMS: We do have faults in the area.
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.2- , DR. MOELLER: Well, they also have.a G value. I 3' mean.your design.
4 MR. TRAPP: -- go through on this is basically the
.5- fatigue factor. And if you take a look through some of the 6 preliminary analysis that have been done with canister 7 lifetime, especially as the canister ages after X number of
- 8. hundreds of years, thousands of year..
- 9. The' number of repetitions that come through with
' 10 ' earthquake tend.to have an ef'fect on stability of the. ,
11 canister and how.it performs during this period. So there ,
1 12 is a seismic effect. It may not be that great or:as
.13 spectacular.as you do'from a nuclear power-plant or'this
] )[ '14 type of thing. But there is an effect that has to be taken 15 .into account. !
16 DR. SHEWMON: I have profound difficulty and very.
17 dubious, let's say, that one could make that. technical 18 argument with any validity or_any particular certainty. I i 19 agree it's shaken, but it's not like a set of pipe where you 20 wiggle one end and the other end goes differently. You have ;
l 21 got this solid mass which moves with'the earth, and that 22 doesn't set any stresses in it.
l-23 DR. MOELLER: You have a G value, do you not, for 24 the design? I mean you. DOE has a G value for the design 25 of the repository?
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(,) 'l MR. BLACKFORD: Yes, the DOE has in the SCP and 2 elsewhere stated a value of .4 at the surface, and about 3 half of that at repository depth.
4 DR. MOELLER: And what again are your concerns in 5 terms of the impact of an earthquake on the high level waste 6 that's been placed in the repository?
7 MR. BLACKFORD: For the preclosure, the concerns 8 are is the G value sufficient to meet the performance of the 9 retrievability and the health and safety at the surface 10 facilities. Forthepost-clfsure, it's the isolation of the 11 waste, and that will be the effect of a larger quake, a 12 post-closure earthquake on the groundwater.
13 DR. STEINDLER: On'the groundwater?
A(_j 14 MR. BLACKFORD: On the ground water. On a change 15 in the groundwater level to such that it is being passed of 16 the radionuclides to the groundwater.
17 DR. ORTH: Question: If we are going to be 18 concerned with the health and safety of the surface site, 19 does that mean the surface site is going to have to be built j 20 to earthquake criteria? ;
21 MR. BLACKFORD: Of course.
22 DR. MOELLER: Gene.
23 MR. VOILAND: It seems to me that those 24 definitions, when we are talking about essential i
25 containments, that they are looking at the containment, the lieritage Reporting Corporation (202) 628-4888 l
L 71 r-)s s . 1 containment period as being around 500 years. And after l 2 that was the isolation period.
3 And wasn't that containment period the period 4 during which you expected the waste container to be 5 functional?
i 6 Now you are talklug about predicting things. I 7 don't know if one predicts earthquakes or predicts anything
- 8. 500 years from now, but that's a lot different than from 9 10,000 years, and I don't think we are looking at that 10 issue.
.11 MS. ABRAMS: It's 300 to a thousand years.
12 DR. MOELLER: Could the staf f conunent on that?
13 Over what period of time are you concerned about the O 14 seismic, the effects of the seismic event in terms of the 15 canister?
16 MR. TRAPP: It's the full 10,000. Because in 17 addition to the requirement to meet the 61.13 requirements, 18 the waste package requirement, in going through the overall 19 system performance, the requirements to meet the EPA 20 standard, there are assumptions made on how the canister 21 will perform past the period of containment, during the 22 period of isolation.
23 Therefore, you have got to go through the whole 24 period after this 500, 1,000 years, et cetera, and see how 25 the shaking might possibly disrupt the cladding, disrupt the p)
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'..- 1- ..fuelfpellets, change the groundwater flow system, .possibly
.2: bring up different material into'the repository, different 3- -3 types of moisture. There are -- again, it is not a simple 4 Lone because you have got to go through the multiple 5 scenarios of different futures that could occur to the site
- 6. during the 10,000 years.
7 Each one of them has got to be evaluated. I 8 forget the exact number. DOE had done one calculation which' 9 was:several thousand which we are required to go through, 10: but'each.one of them has tofeevaluated,eachpossibility.
11 And unle'ss you go through the total analysis, you really 12 . don't know the real effect of earthquakes, et cetera.
'13 'The idea right now is to bound what could happen 14 .in the'different types of natural areas. Bound what could 15 happen with the. repository -- not the' repository, but the 16 engineering of various systems while this is' going, put 17 together into scenarios, and try to figure out will, through 18 these different types of processes, different types of 19 futures, will the site meet the overall goal. And it is a 20 systems approach that is not the kind of thing that you can 21 directly yes/no. You have got to go through all of them.
22 DR. ORTH: Haven't you just defined a PRA?
23 MR. TRAPP In many ways it is quite similar to a 24 PRA.
25 DR. ORTH: Identical?
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em k_) 1 MR. TRAPP No. l I
2 DR. ORTH: Identical? ]
3 MR. TRAPP: No. Very similar but not identical.
~
4 One of the main difference is in the PRA you basically are 5 taking risk time consequences. You are basically running 6 this thing through.
7 What you have got here is risk versus, or plotted 8 against consequence and ends up to be a slightly dif'._ ant 9 calculation. The overall effect is extremely close to a PRA 10 though, yes.
11 DR. STEINDLER: Let's see if I understand you 12 correctly. Seismic issues are related to some assumptions, 13 I thought I heard you right, that you have to make about the
() 14 integrity of'the container beyond the containment period.
15 MR. TRAPP: Yes.
16 DR. STEINDLER: Does that imply that that's a 17 necessity, or do you think that that's simply what the DOE 18 has done?
19 MR. TRAPP It's basically the series of 20 assumptions that are made right now and the series of 21 allocation that DOE has given to different components.
22 It may turn out that after they go through all the 23 analysis, after they have got all the information, that they {
24 can run a fault through here, move the thing 50 meters, and 25 they will find out in their analysis that nothing happens.
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1 Now I kind of doubt that, but 1et's make that l-2.- . assumption.. They don't have the-information right now.
3' What they.'are doing is saying,-okay, there are different:
-4 assessments that have to be done. We have to get the 5 different information'to. fit in there,'and they all have to-6 be fit together into one overall series of -- if.you want to
-7 call it mega-PRA.
'O MR. VOILAND: Is that being done?
o' 9 MR.~TRAPP: It has started to be done. And like I 10 said, it's coming from two s1[ des. It's the performance 11 assessment side and it's the input of the individual-12 disciplines. -
.13 MR. VOILAND: I guess I tend to-think of that.as
- h '14 starting with some-kind of' baseline condition, and then 15 looking at all of these factors as perturbing factor. You 16 know something about the seismic character at the present.
17 time and you have to make-some assumption that it's going to 18 go. Then you can perturb that any way you want. And by all 19 the, I guess the worst case perturbations, you end up with 20 an impossible situation. So some place in there some
-21 probabilities have got to be thrown into the --
22 MR. TRAPP: Yes, there are probabilities thrown in 23 here and that's where you come to this basic 10 to the minus-24 one over 10,000 years and 10 to the minus three over 10,000 25 years, and the EPA standard criteria by which that has got I
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_en 1 to meet.
2 MR. VOILAND: But in the meantime the material is 3 decaying away and it isn't the same at 10,000 years as it 4 was --
5 MR. TRAPP: That has got to be factored in also.
6 MR. VOILAND: Where do you buy those 10,000 year 7 crystal balls?
8 MR. TRAPP: We are looking for them.
9 DR. MOELLER: Further comment on this?
10 Dick Foster.
11 DR. FOSTER: My impression on this site 12 characterization is that you are developing data toward I i
13 demonstrating that the performance will be good enough and
() 14 you talked about these DOE goals a minute ago which 15 ' presumably are tied .tnto something which would be good 16 enough.
17 There is a flip side of that coin which says that 18 you want to discontinue characterization of the site if you 19 in fact find a fatal flaw.
20 My question then is, is anybody looking at setting l 21 the lower limits? It says if some situation is not good 22 enough, we quit. Is anybody looking at that end of the 23 spectrum?
24 MR. TRAPP Let me try that, and I think DOE would 25 probably be better to answer this one. But basically if you
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(_,) 1 take a look at the DOE guidelines, there are a series of 2 disqualification standards. And it's my understanding that 3 i[ DOE discovers any time during the site charact.erization 4 that disqualifying statements are met, that they will 5 automatically discontinue site characterization.
l 6 Now like I said, I would like to refer to somebody 7 like Ed or the rest to discuss that.
8 DR. MOELLER: Well, that's what the SCP overview 9 clearly states.
. \
Well, let's go ahe5d then.
10 11 Dick, since you, of course, haven't been to very 12 many of our meetings, the committee has very frequently said 13 what we should be looking for, or what we should be
() 14 developing as a plan to discover as early as possible any 15 fatal flaws. You know, if the site has to be discontinued, i
16 then it should be.
17 And you are correct. If we could, in studying the 18 values on these parameters, the limits on them, if we could 19 set some limits which represent fatal flaws, then that would 20 be a good way to go.
21 Cliff.
22 DR. SMITII: Those questions the other side of what 23 I was asking earlier, and I guess the presumption we all are 24 making is that we haven't found a fatal flaws. So then the 25 question is really in a broad sense how much is enough to lieritage Reporting Corporation (202) 628-4888
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(,j 1 ' qualify the site. )
2 DR. MOELLER: Go ahead, Charlotte.
3 MS. ABRAMS: I'll move on into our next area of 4 concern which is with respect to natural resources. Again, 5 it does not appear that alternative conceptual models have !
6 been tully considered, and it appears that studies are 7 primarily directed towards tuff models, and not structures, 8 veins or subsurface rocks that could be possible host to j i
9 ores. And geochemical elements that are proposed to be 10 analyzed for appear to be mal'nly tuff oriented. l 11 Also under natural resources, there appears to be l 12 a problem with integration, and there appearc to be a lack 13 of integration with other investigations.
{} 14 For instance, no apparent geophysical studies that 15 we could tell are directed towards natural resources, and 16 this would also occur with respect to drilling studies. i 17 Now, both of these problems were addressed also in 18 the CD3CP. I 19 DR. CARTER: Let me ask you a question. What kind 20 of boundaries exist on this as far as economic value?
21 In other words, what would you have to project or 22 predict in the way of natural resources to exist there? Do 23 you need a billion dollars worth or 200,000, or what would 24 you worry about?
25 MS. ABRAMS: It is essentially stated as deposits lieritage Reporti.ng Corporation (202) 620-4888
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l 78 1~ of economic value. And as you know, there is a difficulty 2 in projecting what would be of economic value over the next 1
3 10,000 years. They can't predict for 15 years.
l 4 DR. CARTER: Yes, but presumably somebody has got 5 to do something. It looks like to be an extremely fuzzy l' 6 area.
7 MS. ABRAMS: There is -- they do need to -- in 8 10 CPR 60, it requires that they compare these areas with 9 areas in the geologic setting. And they are supposed to 10 delineate areas known or ide6tify ore deposits in the area 11 of the repository. So there is a problem.
12 DR. STEINDLER: Part of your question. You are 13 faulting them because they only address tuff, is that what Q 14 you are saying?
15 MS. ABRAMS: Yes.
16 DR. STEINDLER: Where else would you have them 17 look, I guess, since the whole area is fairly replete with 18 that material?
19 MS. ABRAMS: There is a problem with ore deposits, 20 in particular, gold deposits in the area of Yucca Mountain l
21 are hosted within fault zones. And we don't see natural 22 resources investigations directed towards fault zones. And, 23 for instance, with their drilling studies, most of the 24 proposed drill holes are vertical drill holes. The faults 25 in that area are near vertical. So it would be very O iieritaue Reverti 9 Cerveretien (202) 628-4888 ,
79 I) 1 difficult to hit a fault with vertical drill holes.
2 There is also examples of ores located in veins 3 and then we have the subsurface paleozoic rocks that should 4 be considered.
5 MR. MCCUP.JLL: Keith McConnell, NRC again.
6 If those of you who were out at the site remember 7 when we were on top of the mountain if you looked off to the 8 west, there was another ridge, which was Bear Mountain. And 9 there is a gold mine in the paleozoic rock on the east side 10 of Bear Mountain. And paleof'ic o rocks do extend beneath the 11 sub.
12 DR. CARTER: Is that mine worth $100,000 or 2 13 billion or what? You know, there is some value. You know,
() 14 we have already spent a billion or so on this repository 15 planning, and I presume this has to be balanced.
16 As far as I know, most of the gold mines in Nevada 17 or the other mines are relatively small. There are some 18 exceptions to that. You know, a lot or them are mom and dad j 19 operations. You know, they've got a wheel barrel anu two l
20 shovels.
j 21 DR. SilEWMON : One car went home at the end of the 22 day when we were out there.
23 MS. ABRAMS: In the area of Yucca Mountain, there 24 is another gold find in Northern Crater Flat which is also 25 in the saae area of the mine you observed. And it's a large i
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80 1 deposit that will presumably be put into production this 2 year. There-is also a very large gold deposit in host rocks 3 over near Beatty, Nevada, which is located in host rocks 4 that also extend beneath Yucca Mountain. So we have to 5 consider this.
6 DR. HIN"Er I think it also has to be made clear 7 that we are not really talking about preventing the private 8 industry from getting into this area to exploit some mineral 9 resources. We are concerned about the intrusion in 10 subsequent years. Andourefplorationstrategiesthathave 11 been developed over literally centuries have defined certain 12 flags, certain signatures which directly the exploration as 13 to an area.
() 14 And I think the concern here is that there are 15 sufficient geophysical data collected, sufficient geological 16 data and drilling data to see that there aren't those 17 critical f?ags or anticipated flags in the next decades to 18 come or next centuries to come. I think that's the critical 19 issue. That we are really looking for those signatures 20 which would drive the exploration community into this area 21 in subsequent centuries.
22 MS. ABRAMS: Thank you.
23 DR. SHEWMON: And tha't area would be the area of 24 the repository. We're not worried about somebody drilling 25 for gold over on the next mountain. It's some idiot coming
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() 1 in who can't tell radioactive waste from gold, or whatever 2 it is, and digging it up and hurting himself.
3 Isn't that the scenario?
4 MS. ABRAMS: Predominantly. If drilling 5 activities or excavation activities could change the i 6 groundwater regime, then it could also have an affect upon 7 the site.
8 DR. CARTER: Well, it's still a two-phase thing, 9 though. One is the economic value of a loss of that and the 10 other is the intrusion.
11 I'm like Paul, you know. Looking somewhere else 12 is a different problem. As Gene Voiland said, I think this 13 one is a tough problem.
14 DR. PARRY: I would remind the committee that the-({}
15' State of Nevada had experts who made a considerable point of 16 potential mining.
17 DR. MOELLER: I would remind the committee that 18 when we finish this we're going to take a break.
19 (Laughter.)
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2 MS. ABRAMS: Another concern was the area of-3 methods of exploration. And we had concerns in this area on L4 the CDSCP,'a review also.
5 In'the area of geophysics, we still see a lack of 6 apparent integration between geophysic studies to identify 7' and characterize deep crustal and shallow geologic features
- d. and their' interrelationship.
9 We also see no apparent geophysical program 10' directedtowards'theidentiffcationofvolcanicigneous: ,
11 teatures and their extent under or close to the. site. And, 12 a?so, there appears to be still a lack of integration 13 between various geophysical activities. Now, the DOE did
(} 14 add significant revision to this area. But we still do have 15 some problems.
16 With respect to surface based and insitu 17' testing --
18 DR. STEINDLER: Excuse me. I realize that ycu're 19 not in the business of assigning cause and effect, but would 20 you guess that the reason you're missing the kind of 21 integrated discipline that you're looking for is that it's 22 not sufficient time has passed, in contrast to the DOE not 23 being aware of what's needed?
24 MS. ABRAMS: We don't see the proposed activities 25 to integrate.
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- 1 .DR. SMITH: That's.been the' theme through your 2 whole presentation, one of the major themes.
3 MS. ABRAMS: That is one of the problems.- And it
~
4? may just.be a problem with the structure of the SCP.
5 DR. HINZE: There's not.only a problem of 6 -integration, but, as you point out in your background 7 material, also the problems'of, what you call, sequencing or
.8 staging of the studies. And.I think that we have to make 9 certain that our term " integration" is not just integration
-10 of data,- but datia' that are a6 quired at the proper sequence,
'11 in the proper stage. And that will eliminate, it will have
-12 the effcct, of cutting down on costs, making the whole 13 precess much more efficient. The integration term-here is
. -14 good, but it's not complete enough.
15 MS. ABRAMS: Yes. That is another aspect that we 16 just didn't cover in this today. But, yes, you're right.
17 It's very important.
18 DR. MOELLER: Other places in the same realm, they 19 pointed out that the interference where one test interferes 20 with another, well,.that's all part of integration. It's 21- quite possible that the staff, if they have not already
'22 considered it, that they should look at the integration 23 problem as generic to the entire site. characterization
~ 24' program.
25 MS. ABRAMS: With respe't to surface based and Heritage Reporting Corporation (202) 628-4880 l
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- ( ) 'l insitu testing, again, there' appears to be an' integration.
'2 problem in-the surface mapping-problems. _
There are surface.
3: mapping programs that deal with vulcanism studies, 4 ' tectonics, geomorphology, surfacial deposits. We don't see S; a clear integration of these mapping projects.
6 And, finally, for Dr. Parry here, 7 representativeness. The program of drifting that's proposed
, 8 with the ESF in the north'of the repository block, combinedE
-9 with systematic drilling and feature sampling drilling, appears.unlikely to provide Ihe lithologic and structural
~
10 11 information necessary.to adequately characterize and 12 investigate potentially adverse conditions at the site or 13 insure that observations made and data collected will be
' 14 representative of conditions and processes throughout the 15 entire' repository block.
16 DR. HOELLER: Any additional comments or 17 questions?
10 DR. PARRY: Is there any discussion about 19 exploring the entire block? We understand that the 20 Technical Review Board has, I think, raised this point with 21 the DOE staff. llave you all considered requirements or 22 expanding the investigation by drifting or lateral l.
23 boreholes?
24- MS. ABRAMS: I think what we're trying to say here 25 really, we just questioned whether they could gather enough
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85 1 data.in thic area to characterize the whole site. And we're-2 not saying that they have to drift extensively. But what we 3 are saying is, can you show us that you're drifting, that is 3 J
4 proposed, along with your surface based testing program, l
5 provide adequate data. j 6 Keith, would you like to elaborate any more on
-7 this?
8 DR. MOODY: Charlotte, are you saying that there's 9' a great deal.of heterogeneity in the rock. It's not a 10 homogenous rock; it'sveryhfterogeneous. Drill hole number 11 one may not tell you what's going to be drill hole number 12 three. Right?
13 MS. ABRAMS: That is correct.
() 14 DR. MOODY: And that is a site problem.
15 MS. ABRAMS: Geologic structures are very 16 different. Do you want to elaborate on that?
17 MR. MC COLLUM: I don't think we want to be placed 18 in a position of telling the DOE how to do it. What we're 19 saying bae' colly with this concern is that what they've 20 shown us to date, does not appear to be adequate to satisfy 21 the requirements.
22 DR. PARRY: When they come in for license, they're 23 going to want to have the license cover a certain number of 24 metric tons of fuel. As I remember from previous 25 existences, if you will, the capacity of that block for
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- O .1 spent fuel, nowhere approached'70,000 metric tons. And, in
,2' fact,.they were as dependent on the second repository which' c, 3 has not gone by the board.
p
-4 Also, as I' remember, there was some discussion-
- 5. that they would start exploration, I thought, to the north.
6' But that was through a fault system that they were going to 7 have to go into to get into:another-block that would-be;
- 8 sufficient for the rest of the spent fuel.
9 The basic question is, though, how is'the site
- 10- characterizationworkgoingfojustifytheobtainingof.a 11 license'for all the spent fuel that's expected to go into 12 the facility? If it's not, then maybe that in itself.would 13 constitute a very serious blocking point. Is the staff
-14 going to look at that question?
15 MS. ABRAMS: I think that's being looked at by 16- other disciplines other than geology. And our basic comment
'17 would be just that we are aware of the adverse structures 18 and the differences in the structures in,the other areas of 19 the repository. You're right, they do have possible 20 expansion areas, and one is to the north.
21 DR. PARRY: Through a fault zone.
22 MS. ABRAMS: It appears to be a fault zone based 23 on some surface mapping to the north, and geophysics. So it 24 is interpreted as a fault zone now; yes.
25 DR. PARRY: When you say " surface mapping" that IIeritage Reporting Corporation (202) 628-4888 l
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1 .means. surface observation, not geophysical remote testing.
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It '2 Is that correct.
3 MS. ABRAMS: They have done some geophysical f
.4 testing in~that area', too.
5 DR '. MOELLER: Gene.
- 6. MR. VOILAND: My-question was, is the staff.
7- -satisfied that enough information has been gathered by 8 measurements made from the surface versus what is expected 9L to be accomplished through'the boreholes, and maybe has 10' been, and also.the experimen{'al check. Are we using up-t.o-11 date methods? I happened to see on TV the other day, 1
l 12 Cornell. University seems to have some linkage of a 13 supercomputer with seismic, to produce seismic studies and O 14 t "-
15 DR. MOELLER: Could you comment on that?
16 MS. ABRAMS: There's certainly more surface-based 17 work they can do. But a lot of these features, I don't 18 think we're going to know enough about until we do get down -
19 there. a 20 MR. VOILAND: But do we know what we can know from 21 surface measurements?
22 MS. ABRAMS: Probably not entirely; no.
- 23 MR. MC COLLUM: I think we have an idea of what we I 24 can determine from the surface. And I think that's what's 25 driving the concern, that you have to come up with different 11eritage Reporting Corporation f (202) 628-4888 i e
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() l' approaches than what's listed in the SCP.
2 DR. MOELLER: Any other. comments or questions on 3 this topic? I presume you'll be around if we want to come 4 back. Okay, thank you very much. We'll now take a 15 5 minute break.
6 (Whereupon, a short recess was taken.)
7 DR. MOELLER: The meeting will resume. We brought 8 in extra chairs. We apologize for the inconvenience
.9 earlier. But we're hoping now to be able to seat everyone 10 who's here.
11 We'll move on then into what is hydrology and 12 geochemistry, the next item.
13 MR. STABLEIN: That is correct. The next area 14 that we're going to talk about is handled by the hydrologic
)
15 transport section. Don Sherry, sitting over here, is the 16 section leader for hydrologic transport. The lead reviewer 17 in that area is Jeff Pohle who will be doing a presentation.
18 And we aise had working on this particular area, in the area 19 of hydrology, we had Fred Ross, Neil Colman, Bill Ford. I 20 don't know that any of them are in the room today. In 21 geochemistry, we had John Bradbury, who is sitting over i
22 here; Tim Moe and Dave Brooks. So we have John here for 23 backup as well as Don Sherry. I 24 I'm going to turn it over this time to Jeff Pohle.
25 MR. POHLE: Good morning. The concerns we've ]
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l 1 outlined in the handout can be fully categorized in three 2 ways. There's a series of cautionary concerns dealing with L ) 3 the issue resolution strategy for ground water travel time, 4 which my section, our section, has the lead responsibility 5 for. There's concerns related to generally the area of 6 relating the testing program to the strategy to resolve 7 ground water travel time. And there's some items dealing 8 with some inadequacies of the testing program that we've 9 observed during the review of the SCP. So that's the 10 general areas we've put forth'here for this short list.
11 The first item, dealing with the disturbed zone, l 12 is that the disturbed zone boundaries is not delineated by 13 considering the effects of waste heat on physical or
() 14 chemical properties that contribute significantly to 15 repository performance.
16 Essentially, in the SCP, they put forth primarily i 17 plan on looking at intrinsic permeability and effective 18 porosity changes to delineate the disturbed zone. Now, 19 that's similar to what the NRC staff had been thinking, but 20 we do not have any significant technical support for such a 21 narrow focus on what to consider and delineate in the' 22 disturbed zone. So we put forth this concern essentially 23 to, as a cautionary measure, suggesting that, perhaps, what 24 is considered not to be too narrowly focused, and ultimately 25 on all properties that are considered essentially to come up
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(_) 1 with the conclusion as to what is significant to the 2 repository. And then those would serve as.the basis for 3 anything in the disturbed zone.
4 Any questions? Or I'll go on to the next item.
5 DR. MOELLER: Go ahead.
c.
6 MR. POHLE: Okay. The strategy for resolving the 7 regulatory requirement for prewaste and placement ground B water travel time does not include consideration of 9 anticipated processes and events.
10 DR. SHEWMON: Anti 6ipated what?
11 MR. POHLE: Processes and events. It's just not 12 even discussed as a concept in that section 83512 with the 13 SCP.
(') 14 DR. PARRY: Excuse me, isn't the groundwater 15 travel time requirement based on undisturbed conditions?
16 MR. POHLE: The disturbance caused by in placed l 17 waste or the construction of the repository, that aspect of ,
18 the prewaste and placement, in reviewing the record, is 19 dealt with through the disturbed zone. Now, that does not 20 deal with essentially the geologic study from the disturbed 21 zone to the accessible environment.
22 tiow, reviewing the statements of consideration for 23 the rule making, says clearly that the performance 1 24 objectives, are the standards for the individual barriers, )
25 were essentially deemed adequate assuming anticipated r )s
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[() '1' processes and events. And that type of language is: carried.
i' 2 through in a number of' places', which to the staff means that 3 for.the purposeslof groundwater travel time,-anticipated 4: processes and events would be a consideration of those 5 natural processes-that could change the system during the 6 performance _ period,: which we interpret as being the
'7 . performance period'of<the repository.
8 .DR. PARRY: 1. thought'that the groundwater travel 9 time requirement in -- I'm sorry I forget the section -- was 10 explicitlydefinedasundistfrbedperiod.
11 .MR. POHLE: No. We can't find that anywhere 'n i
12 the regulatory record, something that explicit, completely 13 undisturbed. I can only repeat myself. I can, perhaps, 14 give a couple quotes.
(}
15 DR. PARRY: No, please don't.
16 MR. POHLE: No quotes, so okay.
17 DR. PARRY: Don't take the Committee's time.
18 DR. MOELLER: I tend to agree with Jack. I recall 19 that the groundwater travel time was to be based upon the 20 natural setting undisturbed.
21 MR. POHLE: Put it this way: If its purpose is to-22 represent a goodness of the geologic setting, and really the 23 greatest need for a good geologic setting would come during 24 a period of time after the engineering aspects are no longer 25 relied upon, .or the waste package; then along with some
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92 d 1 assurance that that geologic setting would maintain the 2- characteristics that would deemed favorable today during the 3 period the repository is expected to perform. Which is why 4 the anticipated processes and events were deemed relevant to 5 this particular performance objective.
6 DR. MOELLER: I realize that the definition of 7 unanticipated and anticipated processes and events is under 8 discussion, where does that stand? Can you refresh us?
1 9 MR. POHLE: I will refer to John Trapp on that.
10 That really wasn't relevant 60 the comment we were trying to 11 make here.
12 DR. SMITH: Well,' basically are you saying that 13 assuming that engineer who buried the canister and so forth
() 14 is gone, then what are the potential geologica1' events'that 15 could happen that would cause the travel time to change?
16 DR. STEINDLER: The sentence that I see here, and 17 what I think I heard -- I'm sorry I came in late -- I think 18 it's exactly what I would interpret the regulations to be.
19 If, in fact, it's missing, then I think that's a legitimate 20 complairrt .
21 MR. POHLE: Shall I proceed then?
22 DR. MOELLER: Yes.
l 23 MR. POHLE: The next item was the proposed method 24 for constructing cumulative distribution curves for 25 groundwater travel time by weighting alternative conceptual
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(%) 1 models as theoretically inappropriate.
2 The concern of the staff in this area is that the 3 expression of the uncertainty in groundwater travel time in 4 the demonstration of compliance, needs to be thorough and 5 complete, and all information be provided to the staff. We 6 would be concerned that if a methodology was used, from what 7 we interpret was presented in the SCP, that methodology 8 could result in essentially compressing the predicted 9 variable toward the mean. The bottom line is, we like to 10 see the full expression of tfie uncertainty and not just an 11 estimate of the mean behavior of the system. We did get 12 some help on this from NRR. There are some NUREG's dealing 13 with this issue.
14 DR. SIIERRY : From research.
k'~Jh 15 MR. POllLE : From research? Excuse me, that was 16 from research.
17 DR. STEINDLER: I don't understand why you say 18 it's theoretically inappropriate just because you do get 19 compression toward the mean, which is what you would expect.
20 Why is that inappropriate?
21 MR. POIILE : If your objective is to express the 22 full uncertainty and the predicted variable, essentially you 23 lose the details.
24 DR. STEINDLER: It may be varied in the theory and 25 methodology, but it's not obvious why you would have to do l
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() 1 that. In fact, it isn't very clear to me what alternative I
2 you're' proposing, if you're proposing any. In other words, 3 is it doable in relation to --
4 MR. POHLE: Why take a family of curves and lump 5 them into ore and present that to us. Essentially, you're 6 going to average out what is essentially perhaps a broader f 7 expression of the uncertainty in the estimate. That's one 8 way to look at it. ,
9 DR. SHEWMON: And you want to have them give you 10 the curves and then let then'still take the mean and get 11 down to the bottom line.
12 MR. POHLE: And do if you will, yes, when you're 13 saying, " Don't do that but present us all what went into r's 14 that."
()
15 DR. STEINDLER: That doesn't solve my j 1
16 theoretically inappropriate question, but I'll wait. l 17 MR. POHLE: The next item, again, refers to the 18 strategy for groundwater travel time. All assumptions about 19 features, events and processes related to the hydrologic 20 system for the initial modeling strategy to predict 21 groundwater travel time are not completely identified. That 22 particular chapter stresses a number of items. For example, i
23 for the unsaturated zone, it's noted that out at Yucca 24 Mountain, the current understanding of the system is that it 25 essentially is a fracture flow system.
() Heritage Reporting Corporation (202) 628-4888 J l
1 l
95 il Now, I.think one of the initial assumptions in-2- - there, they say when they actually do the modeling to-make.
i 3 the prediction, we will probably treat that.as,an equivalent 4 force medium. Well, that's fine; that's one assumption a 5- that's-clearly identified in the text. But there are a lot
~
6 .of'other aspects of the groundwater. system that are 7 described under the geohydrology program or chapter 3, and 8 it's'not exactly clear to what degree certain features, 9 processes or events will be simplified and/or omitted from y- 10 the mathematical model. I'm'just trying to get-the whole c .
'll structure' laid'out so we can assess the progress.
12 DR. SHEWMON: Sir, you.know how much comes out of-13 the sky and lands on the earth pretty well out there, I 14' presume. Last time I was near this, there was uncertainly 15 as to how much of that ever reached'the water table. Is 16- that in better shape now, or are there tests.being done'to 17 establish what will actually come through the level of the 18 repository?
19 MR. POHLE: I see nothing.new, let's say in 20 chapter 3,.that we haven't been aware about for quite a 21- while in terms of data or information.
22 DR. SHEWMON: One percent of the rainfall or 10 23 percent of the rainfall?
24 MR. POHLE: Oh, I convert.
25 DR. SHEWMON: Or one-tenth percent or what?
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is 1 MR. POHLE: I think the best estimate provided in 2 the SCP is, what, .05 millimeters per year. At the .l l
3 repository horizon, the rainfall out there may be six ]
4 inches.
5 DR. MOODY: Per year? f i
3 6 MR. POHLE: Per year, whatever that is in
]
7 millimeters, an extremely small percentage using those --
8 DR. SHEWMON: That's tenths of a percent or less. j 9 MR. POHLE: There are a lot of studies and 10 activities laid out in this s'1most 500 pages of the 11 geohydrology program, ranging from continued meteorological
~
12 collection to both artificial and natural infi1tration 13 studies, to tests at the repository horizon tests in single 14 holes in the unsaturated zone, all trying to get at what the
(( )
15 best flux value is. It's from a number of directions, not 16 to mention the hydrochemistry looking at isotopes and that.
17 So there's a number of approaches being proposed in there, 18 all trying essentially to get at that same number. !
19 Okay, I'll move forward. This next concern 20 relates to the chapter 83.12, which is the geohydrology 21 program. The technical basis for initial assessment of the 22 significance of individual features, events and processes of 23 the hydrogeologic system to performance measures or design !
24 or performance parameters is not discussed. In fact, in '
25 that chapter, essentially the current understanding of the
(")
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1 regional and site groundwater systems are in effect 2 summarized through a couple tables. And for each feature or o 3 element of the systems, a hypothesis is presented on how 4 that feature or process interacts with the groundwater 5 systems.
6 Also in there is a column outlining the relevant 7 performance measure parameter, design parameter, 8 characterization parameter. And then after that is 9 essentially an assessment of the significance of a 10 particular aspect of a systeS to that measure or parameter; 11 now, essentially is given as high, medium or low. And that 12 assessment essentially does provide a foundation for, let's 13 say, the priority or the need for how much to do at the r~T 14 process.
V 15 Now, I think this is not dissimilar from the 16 previous comment dealing with assumptions in the 17 mathematical model as to what features are most important to 18 the variable of interest. But in this case it's essentially 19 making a similar comment through the geohydrology program, !
20 rather than in the section for the particular performance 21 objective. We're trying to take a theme and carry it 22 tnrough the entire document in a number of directions to see 23 how it all ties in together.
24 Now, there certainly are activities in there 25 planned to answer this type of question. It's generally
] IIeritage Reporting Corporation (202) 628-4888
98 cm 1- under the model, conceptual model, integration and synthesis
()
2 type of activities which they have for each level of 3 investigation whether it's regional or site, unsaturated, or 4 site saturated, where the objective is to look at various 5 features, processes or events and make a determination to 6 the degree they are important or significant to each 7 performance assessment. And if they can be found to be 1 8 negligible, for example, they could either be one greatly 9 simplified in a modeling strategy or even omitted. So this 10 is, againsomethingtofolloftheprogressondownstream.
11 The next item. The SCP does not contain a plan to 12 adequately characterize the hydrologic properties of the 13 Calico Ilills unit, which is the designated primary barrier r's 14 to groundwater flow and radionuclides transport.
D 15 At the moment, DOE is looking at a number of 16 options in seeking alternatives to try to characterize the j l
17 Calico Ilills unit because of the problems outlined, I guess, i 18 by the engineers, with extending the shaft down to that 19 horizon. Since that's just still being developed and is 20 under consideration, it's an item we're carrying through i
21 until we see the specifics. I 1
l 22 DR. MOELLER: llow -- and this is not my area, but 1 23 you complained, the staff has complained very much about the !
l 24 early, earlier implication that DOE might drill down into 25 the Calico Ilills, or even through it. And here you're I
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. l' saying, well, you have no plans to characterize some-of.the 2 details.about that. formation. Well, you can't have it both 3 ways. Ilow are they going to do ' this?
l 4' MR. POllLE : Well, right now some of the options
- 5- would be,'I think, considering, what, inclined drilling l
L- '6 perhaps, and are essentially to' seek some unspecified 7 alternatives. -I don't know exactly what those alternatives 8 would be, perhaps even going to something outside the 9 repository block to do some' experimentation. Perhaps that's-
.10 a feasible alternative. Evid'ently, they're still being 11 under consideration.
12 DR. MOELLER: Ilow f ar does the Calico Ilills 13 extend? I mean, it's --
14 MR. POllLE : There are actually outcrops in the' ..
15 Calico Hills themselves.
16 DR. MOELLER: Okay. So you feel they could go 17 -over there and get -- j 18 MR. POHLE: I'm not sure.
19 DR. MOELLER: But they might consider it.
20 MR. POHLE: To me it's a theoretical alternative 21 whether or not --
22 DR. MOELLER: Okay, that is all.
23 MR. POHLE: I'll move ahead then. Activities
'24 presented for the study of the saturated zone flow system 25 are not adequate to characterize saturated zone hydrologic Heritage Reporting Corporation
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-(_ f~)\ 1 boundaries, flow directions and magnitudes and flow paths.
2 Part of this is really a carry-over from the CDSCP comment 3 where one of the activities to study the saturated zone was 4 to evaluate the relationship of faults to the saturated zone 5 flow system. l 6 During the reviewed SCP, we put forth the ccmment 7 that we thought that perhaps the plan activities were too 8 limited to really accomplish the fairly broadly stated I
9 objective, and recommended considering doing some work to 10 evaluate other faults, generfilysoutheastorsouthofthe 11 repository block, rather than focusing only on the solitary 12 or canyon fault.
13 Now, in response to that, it states in the SCP
() 14 that these faults are assumed to act as conduits to water l l
15 flow, essentially because of the flat grading out there.
16 The staff was concerned whether that observation 17 and that observation alone is enough to really support that 18 assumption. So we carried through this or.e. And in 19 addition, we've added some points dealing with the multiple 20 well testing program at the sea well complex.
21 The proposed plans are -- there are two options i i
22 that are proposed that could be followed upon review of the 23 results of the testing at the sea well complex. One option ;
24 is to do another multiple well testing at some location; or i
25 two, to finish out the testing program through a series of fleritage Reporting Corporation (202) 628-4888
101 cm
'(_) 1 Individual or single hole tests.
2 Now, even in the SCP there are some limitations to 3 the single hole tests in accomplishing the stuc objectives.
4 And we certainly agree with those, and we've discussed those 5 in some detail in our paper.
6 IIistorically, I think, the staff has always tried 7 to stress the importance of doing testing at an appropriate 8 scale for the problem involved, especially when trying to i
9 determine flow pads or internal boundaries to the system, to 10 use that term. It's more of'an understanding of the process 11 rather than an approach to these statistical database type 12 sampling approach, what we're dealing with through this 13 particular comment.
() 14 DR. SliEWMON: Have you come to the end of your 15 presentation?
16 MR. FOllLE : No, I have a couple of more items 17 here. At this point we're --
18 Dh. MOODY: I have a question with respect to your 19 adequacies of studies of saturated zone flow systems. In 20 terms of what DOE has written the SCP in review of that, is 21 there an adequacy yet defined in terms of regional flow 22 system versus the repository flow system?
23 MR. POffLE: We have not expressed any concerns on 24 the testing program for the regional system.
25 DR. MOODY: Do you think it's adequately defined,
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1 then?'
2 MR. POHLE: I.think my' interest in that is to what
-3 degree is the regional system significant or' relevant to 4 predicting performance at the scale of the accessible
[ .5 : environment. You're dealing with an awfully large system.
'I 4
6 You're talking, 130.to 150 kilometer base, and that's been: '
- , 7- defined all around the site. And that'is huge. In terms of.
8' -- we' find it very difficult to start expecting the
- 9. Information at the, or the amount, as you would expect for 10 the site level in the regionf 1 1 -- DR. MOODY: Do you have access to the Nevada test 12 site information.
- 13 MR. POHLE: Well, we have access to anything 14 that's published or available. And we are pursuing other
)
15 means in trying to access the databases, I guess, through t
- 16 the computer systems, and that's in progress right now.- I 17 think there's been some correspondence --
- 1l8 MR. STABLEIN: .I think Dr. Moody may be asking.
19 about the data specifically gathered for the weapons program-20 sort of thing. We haven't really gotten all that data yet.
21 DR. MOODY: You have a formal request for it 22 though, or do you? When you talk about the region, I mean !
23 the region includes the Nevada test site, and I'm not 24 totally familiar on how many holes they've drilled, although
' 25 I think it's a sizeable number. And so having access to
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(_) that data would also, in terms of you declining the 2 regionality and everything else, you may have the database 3 there that might be very useful.
4 MR. POHLE: We have presented a concern on the SCP 5 which is not on this vertical short list. It 's very short-6 as part of the testing program to gather hydrochemical 7 information, the groundwater, and establishing baseline 8 chemistry to include things like technetium and iodine-129 9 on the list of things to be analyzed for. So we're kind of 10 covering the basis.
11 MR. STABLEIN: -As I understand the strategy, we 12 have a formal request in for the hydraulic databases from 13 DOE and our hope is that test site data will be part of that
() 14 database. If it's not, we will have to go further in 15 pursuing it.
16 DR. MOELLER: Do you know if DOE is using those 17 data, the waste group in DOE 7 18 MR. STABLEIN: I do not. I don't know if the.
19 hydrologists know whether they're using those are not. The 20 most relevant would be chemistry. And I wish I had Neil 21 here because Hell has been following that.
22 DR. SIIERRY : But the site is basically down graded 23 from the repository anyway, so it's out there --
24 DR. MOELLEP: .Can you speak up, please.
25 DR. SHERRY: Okay. I'm Don Sherry. The site
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y-104 k l li wells are going to'be beyond the accessible environment 2- 'boun'ary.
d a~
L3 DR. MOODY: 1.know that. That's why-I camenback 4' to the questions about regional systems, because I. think-5 that-that's, l'n terms of meeting EPA'_s' standards, the 6 regional. systems has to be addressed because_of potential 7 access.
8- DR. SHERRY: The focus is going to be on the 9 performance evaluation to the accessible boundary. Now, s
(10 where those will be-very interesting is looking at' maybe:
11 some transport.
12 [Mt. MOODY: That's right.
13 IM1. SHERRY: We expect to pursue that,if allowed,-
- 14 but the way this review is going is to focus on_the
[
15 performance assessment of the accessible boundary.
16- MR. POHLE: In terms of the regional and 17 groundwater system, the most relevant aspect is if, you have 10 to put some type of a boundary on your mathematical model.
19 And it's not certainly clear that at that fortuitous scale 20 of five kilometers or_something like that, you're going to 21 actually have a physical feature you can hang your het on as 22 the boundary to that system. And to'get the types of detail 23 out of it, you neither generate a calculated flux boundary 24 based on the much larger scale regional model. And that is 25 an option which, I think, is noted in the SCP as one way
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) 1 perhaps, or one assumption, that would have to be in the )
2 actual compliance demonstration models.
3 Now, then if that is really the one piece of 4 information you need, then in turn, what information that M*'S goes into the regional model are most important to that 6 calculated flux at that particular location. And you get 7 into another tier, essentially of sensitivity analysis which 8 I do not have. We haven't done any dealing with that. But 9 that would be in the SCP plans to deal with the synthesis 10 and integration-type activities. That's all the soft and 11 numerical activities. That would be an issue that could be 12 addressed through that.
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() 1 DR. MOELLER: Paul?
2 DR. SHEWMON: My interest is in primarily what 3 happens around the waste package. And one of the questions 4 there'has to do with the relevant environment that people 5 should test in. Is it ever under water? Is it just moist 6 air? Is it dry air? The rainfall up top is episodic but 7 after you damp this out over a thousand feet, do you then 8 expect the water flow down there to range over a wide level 9 or completely damp out so that you can specify what the 10 humidity is but never wet or'what?
11 MR. POllLE : I think the current thinking is is 12 there, again, there is a consistency within there. I think 13 the .05 millimeters essentially is the flux value that they 14 based on how much water would be at the bottom of an open 15 emplacement hole, you know, with the canister in it. And 16 that's five liters or something like that over some time, 17 whatever that time period or how many years that would be to 18 collect that.
19 But one concern we did note, at least in the 20 geohydrology program doesn't seem to be really responsible 21 for that aspect of it in the context, if you look in 8312 22 and their sumn.ary system, they're dealing with, you know, 23 potential climate changes and the effect on the groundwater l
24 system, tectonics, volcanics, and the geothermal gradient 25 but the natural gradient. What is not really discussed in
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( 1 that chapter is what are the effects on the groundwater 2 ..ctem due to the heat and the waste emplacement.
. And we 3 did present a little concern on point paper dealing with 4 that.
5 Looking over to the repository and waste package 6 programs at some of the correlation tables between the 7 parameters they need to know and what studies or activities 8 will provide that information, I saw there was one cross 9 reference essentially dealing with what's the changing 10 moisture content wi th time 1([ the repository, and that 11 correlated at the broad level to 8312, the geohydrology 12 program.
13 Well, if that meant the change in moisture content 14 with time due to hea from the waste package, the 15 geohydrology program is not going to provide them with that 16 information. So there's a disconnect there, perhaps, if 17 that was the intended meaning of that btt of information.
18 DR. SHEWMON: I guess, you know, what happens with 19 regard to moisture vaporizing or heat vaporizing water. I 20 suspect somebody can handle who's not a hydrologist. But 21 what the flux of water and how this varies over a ten-year 22 period and comes into this heated envelope, is something 23 that one might expect a hydrologist to know the se'. about.
24 MR. P0HLE: There's activity in 8312, '
> or three 25 activities that are essentially the numerical model th IIeritage Reporting Corporation (202) 628-4888
.u
( .
21 . development, but essentially some modeling exercises. An :
2 under one, there's essentially six issues they've. laid out.- ,
)
3 -I.think I have a concern that there areia lot of other 4 issues they shoul'd beLlooking at'and that six is not i 1
5 necessarily all-of them. But one of them deals with looking 1 6 at the upper boundary, otay. And'what is,.let's say, 7 sensitivity of groundwater travel time --
'8 DR. SHEWMON: Is this the upper boundary;1n some-
~
9 distribution:or. physical space?
A boundary which is essentially.the 10 MR.' POHLE:
11 land-surface, okay Looking at the sensitivity to 12 performance measure like groundwater travel' time to episodic
'13 rainfall events. And it's not exactly ~ clear, I mean, if 14 that's the. general' issue, whether it's going to be in the 15- study plan short time plus long time variability with the 16 variability'in space and in time of the infiltration to pass.
17 that~ boundary and then looking at the impact, you know, at 18 the deeper repository levels. .Trying to assess the 19 sensitivity of the various performance measures to that.
20 DR. SHEWMON: Let me come back.
21 My question was, what is the feeling about the 22 periodicity of the flux of water at the repository level,
, 23 and your answer is, somebody_is studying it or trying to 24 estimate it with a model, or not?
25 MR. POllLE : I said the current hypothesis would be 1() lleritage Reporting Corporation (202) 628-4888 r
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() 1 its steady state today.
l 2 DR. SHEWMON: Okay, so there's no variation with j 3 time?
4 MR. POllLE : That's the current hypothesis. But 5 there's planned activities to support that hypothesis.
6 DR. SHEWMON: Now, you talked about accumulation 7 some place. And this is then on the outside of the canister-8 in this hole where they put the canister, is that where 9 you're talking about the accumulation of a millimeter or 10 whatever it was?
11 MR. POIILE : Well, when I read in the waste package 12 program, I get the impression that it's just five liters of 13 water at the bottom of the hole.
14 DR. SHEWMON: That has to be after several
(
15 thousand years when there's not enough heat being generated 16 to evaporate it?
17 MR. POllLE: Perhaps.
18 DR. SHEWMON: Okay, thank you.
19 MR. POHLE: The next three items deal with the 20 geochemistry program.
21 DR. IIINZE : Before you get into that, I want to 22 ask a question.
23 Where do we stand on the fracture flow.versus 24 porous media flow? You seem to have accepted rather readily 25 the fact that the assumption is made that even though it is
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). 1 fracture flow that apparently in the tuff that it is modeled 2 as porous media flow. I've read something in there?
3 MR. POHLE: No, I haven't necessarily accepted 4 that. You're saying, "we," meaning the NRC staff?
5 DR. HINZE: Yes, right.
6 MR. POHLE: I think I may, I pointed out one 7 comment dealing with that's one assumption of many. There's 0 a lot of other assumptions you haven't done it. But in 9 relation to so:ae of these other activities in there, that is
-10 going to be covered. Therefreplanstoaddressthat, 11 support it two ways, not only through the field testing 12 program but again some of these calculational exercises. In 13 fact, that's --
14 DR. MOODY: You mean they are going to try to deal
. (])
15 with fracture flow rather than porous flow? Is that what 16 you're saying?
17 MR. POHLE: Essentially, they'll probably put a 10 case together to support that assumption. That's what their 19 objective is, all right.
20 DR. MOODY: Which one is it? To support what?
21 MR. POHLE: For example, in the saturated zone if 22 their initial strategy would be to attempt to model that as 23 an equivalent porous media, knowing full well that it's a 24 fracture flow system from the evidence in the field testing, 25 that says probably be modeled as that system. However, a
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111 1 number'of activities under the saturated zone investigation 2 program, their objectives are primarily to do work to try-3 and support that assumption, or its calculational exercises 4 and essentially the sensitivity analyses. Now, whether that 5 will bear fruit, I don't know.
6 DR. HINZE: Does it concern the staff that what is 7 being attempted is to prove an assumption that's already 8- been made and not keeping the mind open to other 9 possibilities?
10 MR. POllLE: I can',b accept the stratege where you 11 cannot simplify things in the mathematical model. I'm 12 saying they know full well from the field testing program 13 that it's a fracture flow system. They don't need to -- the 14 work will -- it's like, although there's work planned in the
{}
15 field, they can almost be assured that that's the way the 16 system is, all right.
17 Now, the question that needs to be defended is the 10 simplification of that in a given performance analysis. And 19 the only way one can do it is through a series of 20 sensitivity analyses, perhaps. And if you get a yea or a 21 na) on that, that remains to be seen. That work has not .
1 22 been done.
23 DR. HINZE: What about in the unsaturated zone?
24 Is the Staff comfortable with the approach that is being 25 used to establish the significance of fracture flow? And I
() lieritage Reporting Corporation (202) 628-4888
112 1 assume in fracture flow, you're also including fault flow.
2 MR. POHLE: Well, let me explain then in terms of 1
l 3 what the least -- from what I read of the other chapter, 4 what the initial strategy would be for the unsaturated zone.
5 If it cannot be demonstrated that fracture flow is 6 continuous, the preferred strategy would be to model it as 7 an equivalent porous media for the saturated zone.
8 If it is shown that flow and fracture is 9- continuous in the unsaturated zone, the approach would be to 10 try and deal with that, eith0r directly or getting into this l-11 uncertainty in that through tuis alternative conceptual 12 model and so that whole strategy starts to come into play,
- 13. which gives us other problems.
. 14 DR. PARRY: By " continuous," do you mean spatially 15 or temporally, here?
16 MR. POHLE: I .hink you'd have to -- it wasn't 17 clear but -- from what I understand from the reading of it 18 that, if fracture flow is discontinuous, let's say in space, 19 and probably time, their preferred strategy would be to say 20 that that is not particularly significant to the performance '
21 measure of interest and it could then be justified in doing 22 u porous media equivalent. That, again, would be another 23 assumption I think that would have to be defended.
24 DR. S!!EWMON : Yes, indeed.
25 MR. POHLE: You bet.
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() 1 DR. PARRY: Wouldn't this lead to birched water?
2 MR. POHLE: What you're saying is, the system's 3 header geneity(ph.) is that's all you're saying.
4 DR. MOELLER: Cliff?
5 DR. SMITH: I'd just like to look at this a little 6 bit from just a broader standpoint. Maybe you can refresh 7 my memory.
8 DOE has issued the site characterization You are 9 now raising a lot of issues with it, that you're sharing, I
^
10 presume, with DOE on some priority basis or maybe you 11 aren't. I'm trying to get in my mind how do we resolve 12 these issues? What happens next? Once you get all of this 13 put together, then you will issue your analysis, right?
14 Then that will allow DOE time to, then they will have some 15 time, I suppose, to revise their SCP?
16 And if that's the case, my concern is, is someone 17 who's thinking about that, now? It's just little confusing 18 as to Srv we're going to bring this thing to closure.
19 DR. MOELLER: John Linehan wants to comment on 20 that point.
21 MR. LINEHAN: The past two days we met with DOE to 22 lay out for them what our preliminary concerns are with the 23 SCP. :
24 DR. SMITH: You have done that.
25 MR. LINEHAN: We have done that. It was very l'h
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114 1- brief in each technical area, just like the presentations 2 today.
3 DR. SMITil: Did you give your concerns on a 4 priority basis? For instance, in the hydrology area, say 5 this is --
6 MR. LINEllAN : No, no. We have not prioritized 7 'that, and that's why. Once we issue the SCA, which will be 8 some time in the end of July, the Site Characterization 9 Analysis, we have already agreed with DOE that on these high 10 priority concerns --
11 DR. SMITil: Which haven't been identified yet.
12 MR. LINEllAN : Which haven't been identified from a 13 review of the SCP but this, the groundwater flow of fracture
. 14 versus matrix, etcetera, has been an oa-going concern, and 15 everyone is aware that it's a high priority concern, not 16 just from the SCP review. But we will start technical --
17 with the Department of Energy once we have the SCA issued.
18 So we won't be waiting for them to respond in the next up-19 date of the -- in the SCP progress report in six months. We 20 will be requesting specific meetings with them to discuss 21 these high priority issues.
22 DR. CARTER: John, do you intend to put those in 23 priority in the analytsis, in the formal?
24 DR. MOELLER: Can you increase your volume, John?
25 MR. LINEllAN : I'm sorry.
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(_/ 1 In the SCA, we will define things as objections, 2 comments and questions; objections being the highest 3 priority. In addition, there will be write-ups in each 4 technical area that will put in perspective these various 5 things and give some sense of the significance.
6 DR. CARTER: And so you've got a format 7 essentially.
8 MR. LINEllAN : Yes.
9 DR. CARTER: Thank you.
10 MR. P0llLE : Well, ,l 'Il proceed on, then.
11 The next three items deal with geochemistry. The 12 first item, the geochemistry program has not studied the 13 potential process of concentrating radionuclides on fracture
() 14 surfaces and subsequent episodic transport.
15 And if there are any questions or need for 16 elaborations, I think I'm going to defer this to John 17 Bradbury who's the geochemist here.
18 DR. STEINDLER: Are you saying there is nothing in 19 the SCP that indicates that DOE is going to do this work, or 20 what they have stated is inadequate?
21 MR. POllLE : John?
22 MR. BRADBURY: I don't see any indication of them 23 considering this potential scenario. They talk about. In 24 their table on alternative conceptual models, they talk 25 about faults and fractures being features that can either be O nerueue Reverues Cergereuom (202) 628-4888
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/~T 1 the barriers or liquid flow, or conduits for liquid flow t,_/
2 . depending upon the ambient water saturation conditions.
3 They also talk about these fractures as being 4 conduits for air flow and water vapor flow. But they do not 5 consider when you couple those two conditions occurring at 6 fractures when you couple those in such a way that because 7 the system is open with respect to water vapor, you could 8 .get evaporation at the surfaces, slight or weak. Actually, 9 we don't know how much is needed, but that fractures could 10 act as concentrators of radi6nuclides.
11 They look at the effects of dispersion, but they 12 don't consider any processes in the unsaturated zone that 13 might concentrate radionuclides at some distance from the
() 14 waste package.
15 DR. STEINDLER: Does your statement hold true for 16 both the far zone and near zone, as well, the -- zone?
17 MR. BRADBURY: Yes.
18 DR. STEINDLER: I'd better go back and read it 19 again. I thought they were addressing the issue of what 20 kind of geochemistry do you get on clean fractures due to 21 the mining operation or whatever disturbances there are.
22 But I may be mistaken on that.
23 MR. BRADBURY: I don't see anything, not with 24 regard to concentrating radionuclides. They do recognize 25 that fractures can contain unique minerals different from
() -
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!h 1 the minerals found in the matrix. They recognize that.
2 They also recognize that there's a significant flux, vapor 3 flux at the repository horizon.
4 DR. STEINDLER: In focusing your attention on this 5 evaporation process, do you have any information that 6 indicates it's important? How likely in a moderately 7 constant humidity environment would you expect this to be, 8 and can you define for somebody where in the priority order 9 this is likely to occur?
10 MR. BRADBURY: All'I can take and go from is the
- 11 information given in the SCP in the references. And, as I
- 12 stated, there's an indication that there can be a 13 significant flux of vapor upward at the repository horizon.
(} 14 They base that upon geothermal information. They talk about 15 the Yucca Mountain as being able as essentially breathing, 16 and whether that's a near surface or a deeper phenomenon, is 17 still to be determined. But I don't think that they have 10 found one way or the other how much water is being moving as 19 vapor and how much is moving as 11guld at that Yucca 20 Mountain.
21 DR. MOODY: The way that you have this written, 22 concentrated radionuclides at fracture surfaces and 23 subsequent episodic transfer. When you talk about 24 concentrating radionuclides, are you saying that they're 25 going to precipitate in a zeolite mineral or some solid
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118 O1 meteria1, or whet 2 2- MR. BRADBURY: My simple view of what could go on 3 is that the. water containing rodsonuclides flows in the 4 matrix toward the fractures. During a dry period, the 5 fractures would be the first features to dry out. So water 6 potential grading would drive the water to the fractures.
7 When the water reached the f a:acture surf ace, some 8 evaporation might occur which would concentrate the 9 radionuclides in solution, depending upon how close you are 10 tothesaturationofsomerafionuclidebearingmineralwould 11 determine whether precipitation would occur or an increase 12 of a material sort on the fracture surface.
13 But one way or the other, if evaporation occurs,
() 14 it essentially concentrates the radionuclides at that 15 structure.
16 MR. 'IOILAND : Is it thought that -- is at 17 equilibrium, steady state? When you talk about things 18 drying out and so on, that's all got to be a very relative i
19 sort of a term, isn't it?
20 MR. BRADBURY: My reasoning for the possibility, 21 if everything is at equilibrium, then only gravity will i 22 affect the flow of water through the unsaturated zone. But 23 the fact that the DOE is using thermocouple sitometers would 24 Indicate to me that there are differences in the relative 25 humidities at different times in the unsaturated zone and
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()' 1- that the matrix potential is a significant driving force 2 moving water frcm one place to another..
3 MR. VOILAND: I guess I have a very simple view of 4 that. I see a certain amount of water coming down onto the 5 ground and most of that being transpired through plants or 6 evaporating or what-have-you, and a little bit'of it 7 eventually goes down and gets down in ground water and I 8 think down some place there's a water table, and an 9 equivalent amount of water all the time is going into that.
10 Anditwouldseemtomeifyfuwentthroughthissortof !
11 quantitative calculations about the flow, just on an overall' 12 kind of mass transport, that that's extraordinarily slow I 13 mean, it's got a long ways to go and it doesn't move very
(~ 14 fast. And if one quantifies all of this, I wonder if M) 15 there's a problem there.
16 MR. BRADBURY: It doesn't move very fast.
17 MR. VOILAND: And it doesn't contain much because 10 not much gets into it.
19 MR. BRADBURY: Well, the current conceptual model 20 says that it doesn't move very fast in the matrix, but given 21 the possibility for transient conditions in which you have 22 major recharge events, water could flow down those fractures 23 and reach those radionuclides and quickly carry them to the 12 4 groundwater table. ,
I 25 MR. VOILAND: And that major recharge? i O
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) 1 MR. BRADBURY: This is out of my field.
2 DR. SHEWMON: That is the same question I asked 3 earlier about the flux due the site, and I was told that the 4 best estimate then was that the flux was constant, which 5 says.there aren't these recharge events that you're talking 6 about now.
'l Are you saying that these recharge events will 8 attenuate before they get 1,000 feet down through the 9 ground, or that they only occur through channels which 10 weren't at the same place he'was talking about, or what?
11 MR. BRADBURY: I don't how far they go. I imagine 12 it depends upon how much water, how long the recharge event 13 is occurring, and how much and where.
() 14 DR. SHEWMON: But it seems to me, you have to pay 15 some attention to it because if it all damps out at 1,000 16 feet before it gets to the repository level, it's a no-17 never-mind.
18 MR. BRADBURY: That's right.
19 DR. SHEWMON: If it goes through all the way to 20 the water table, then it makes a different.
21 MR. BRADBURY: That's right. And that's what the 22 DOE should be doing.
23 UR. ORTH: DOE may very well have to determine 24 that just to get all of these things washed out. However, 25 the same thing occurs if the average flux down through the
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, , 121 l ' 1: repository horizon is always the same, the. average. flux'over 2 time, so recharge event versus the time -- were all' dead"- --
3 DR. SHEWMON: I'm not concerned about that.
4 DR.-ORTH: No, no Let.me-even postulate-that~
5 it's episodic. That the average is the same. Then'all that 6- time that the hypothetical material was sitting there 7 concentrated on that,.it' was also decaying. .So it will 8 reach the ground table on the average, the same amount of L
9 material whether it's concentrated or not, because it was
~10 . sitting and decaying while if.'was sitting in the fracture.
~
11 DR. SHEWMON: My interest is in-what you use for 12 environment.-for the canister, not how fast the stuff 13 transports once it's out. So it's not. clear to me that the 14 . average over all these episodes gives.you the.'same answer 15 for.the corrosion process, independent of whether it's wet
- 16' and dry or whether it's always a little bit humid.
17 DR. ORTH: I understood that part, which was'a 18 slightly separate question. But that raised another one for 19 me.
20 Weren't the canisters not to be stored in 21 fractured zones?
.22 'DR. MOODY: It's not possible in this heterogenous 23 rock.
'24 DR. ORTH: No, the actual individual drill holes.
25 I' thought there was some kind of a restriction.
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'iq) 1 MR. BRADBURY: Well, I am not distinguishing 2 between fractures and faults. I see them as the same 3 structural- feature for concentrating radionuclides. That is 4 there are plenty of surfaces in which there's some opening.
5 DR. MOELLER: Gene?
6 MR. VOILAND: It's my understanding that this 7 unsaturated zone has got water to the extent of 65 or so 8 percent of saturation. Is anything known about the solute 9 concentration of water that's taken from different samples 10 in that zone? And does the shlute concentration vary with 11 depth, or what's known about it?
12 MR. BRADBURY: It's preliminary information.
13 There are some people in USGS who are squeezing rocks and 14 they're finding that the concentrations -- my memory's not 15 going to serve me well here -- but the compositions are 16 different from J-13 water and that they do vary with depth.
17 And I can't say how much.
18 MR. VOILAND: The implication of that might be 19 fairly uniform flow. I don't know.
20 MR. BRADBURY: It obviously depends upon where 21 they sample the rocks, and a lot of other things.
22 DR. MOELLER: Jeff, go ahead.
23 MR. POHLE: Okay.
24 The next item is investigations radionuclides .
25 retardation focus on determination of a KD or use in matrix Ileritage Reporting Corporation (202) 628-4888 i
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(, 1 and fracture retardation equations. It's two different 2 equations provided in their strategy for test -- releases.
3 This transport modeling approach has not been substantiated 4 .for all expected states of the Yucca Mountain flow system.
5 That is, the range and saturations up to complete 6 saturation.
7 This, I'll refer to John, also.
8 DR. STEINDLER: I'm sure I don't understand that.
9 MR. BRADBURY: Our concern is with these 10 equations, which you don't have in front of you. They are 11 the retardation factor is equal to one plus RO Kd over 12 theta. Now, those equations, or that equation is valid 13 under certain restrictions. For example, that's for
() 14 sorption or a situation where sorption is occurring and the 15 sorption process has to be fast under equilibrium conditions 16 that is reversible and also that on a linear range of 17 sorption isotherm. And there are indications in the SCP 18 that these restrictions aren't being adhered to in the use 19 of these equations.
20 DR. MOODY: That's a classic problem that goes 21 back at least ten years.
22 DR. ORTH: Except that KD does not have to be fast 23 only in relation to the relative flow. If you have a slow 24 flow, you can have a very slow approach to equilibrium. I 25 think we're postulating slow flow.
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() 1 DR. STEINDLER: llave you concluded that under the j i
2 conditions that KDs are being used in the unsaturated zone, 3 that the results of those measurements are non-conservative, 4 even though they may violate the strict assumptions of 5 steady state, not equilibrium, etcetera. But do you get a 6 non-conservative answer?
7 MR. BRADBURY: I haven't been able to evaluate f 8 that, yet. But, yes, yes.
9 DR. STEINDLER: Yes, what?
10 MR. BRADBURY: Yes' I have been able to evaluate 11 it. There are certain situations where non-zero KDs would 12 not result in retardation. For example, a KD that for 13 example, at the Kat ion exchange capacity, where you have a
() 14 KD as measured by the amount of radionuclides on the solid 15 versus that in the liquid, that KD would be non-zero.
16 Ilowever, you know that if that situation occurred, the rock 17 is already saturated with respect to the radionuclides; 18 therefore, no retardation would occur. So a non-zero KD 19 does not necessarily mean that you get retardation.
20 DR. STEINDLER: That's not a violation of the 21 original assumptions used to determine KD, however. That's l 22 a question of what kind of model you want to put in. What 23 I'm driving at is, you know, where in your priority list of l
24 important items is the difficulty in using KDs, determining 25 KDs in what I would call the normal legitimate way, is that j I
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(_) . 'l a very important issue? Is it a non-important issue? And i 2 the way I was trying to get at it.is to find out whether or ,
j 3- not the deviations are conservative or non-conservative. In 4 the determination of KDs, not in their application.
5 MR. BRADBURY: If KDs are determined as a function ,
4 6 of all of the parameters that are stated in the SCP, and 7 there's a tremendous list of them, and if those values were 8 used in the modeling effort in a reasonable way, then I 9 wouldn't have trouble with the determinations of those KDs.
10 It's in the application of tfie KDs in the transport modeling 11 that I presently have concerns with.
12 DR. STEINDLER: If that's what you meant, then-1 13 didn't understand it right.
() 14 DR. MOELLER: Any other discussion on this one?
15 MR. BRADBURY: Can I?
16 DR. MOELLER: Sure.
17 MR. BRADBURY: I see a shaking head. When I talk 18 about KDs, I just want to make sure that people understand 19 the KD I'm talking about is determined as a function of 20 composition of the water, reactions that go on on the 21 surface, spatiation, etcetera. All the things that are 22 included in the SCP. So it is definitely a very rigorous 23 number.
24 DR. MOELLER: Yes, Gene?
25 MR. VOILAND: I would just make one comment about IIeritage Reporting Corporation (202) 628-4888
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()
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I the distribution coefficient. It really applies only to 2 conditions and situations where you're dealing with lons,
-3 not complexes or anything else. And where there is indeed 4 that equilibrium that occurs. Ions go on to the ion 5 exchange or whatever it is. They come off at a given rate, 6 and that establishes the relative concentrations in each.
7 If you're dealing with something that's not ionic, something 8 that's colloidal or something that doesn't fit into that 9 scheme of things, then the KD is really kind of an 10 inappropriate thing to think'about.
11 DR. MOELLER: I noted that you didn't mention in 12 the preliminary pre-decisional material we were provided, 13 you did not mention the item that immediately preceded the one you're on now.
f} 14 And let me just quote it because I think 15 it's a classic statement:-
16 "The geochemistry program is incomplete because a 17 potentially important transport mechanism has not been 18 considered."
19 Unless you define it or elaborate on it, it's not 20 much help. Now what was, just for our edification, do you 21 know what that transport mechanism was?
22 MR. SilERRY : That's the -- he just read to you.
23 That is the comment.
t 24 DR. MOELLER: Oh, the next thing is -- oh, all 25 right.
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127 (m_) 1 MR. SHERRY: Concentrating on the fractures.
2 DR. MOELLER: Okay. Well, go ahead.
3 MR. POHLE: The last item on the handout which is 4 to say, existing sorption characterization data for alkall 5 and alkaline earth elements are insufficient for performance 6 assessment analyses and consequently sorption data 7 collection plans are incomplete. In the SCP, it outlines a 8 r>eries of information that is necessary to deal with.
9 sorption coefficients. There's a list of groundwater 10 composition, mineralogy and surface structure, absorbing 11 species, waste element concentration, atmosphere, 12 temperature, colloidal material, organic complexion, 13 sorption kinetics, biological sorption and transport.
r')
%./
14 And the conclusions reached'in there that all this 15 information then would be known for the alkall and alkaline 16 earth elements and from Chapter 4, the references, I gather 17 the geochemists cannot find all the information in all these 18 categorical areas outlined in the SCP.
19 DR. MOELLER: Any questions or comments on that 20 item?
21 Paul?
22 DR. SHEWMON: When you were answering my question, 23 you referred repeatedly to A.312. Could you tell me what 24 the more complete reference on that is, or what document. It 25 is?
O iierite9e nenort1#9 corvoretio" (202) 628-4888
128 j/'N ,) ' 1 MR. POIILE : I've been referring to Chapter 2 0.3.5.12 in the SCP, that's on groundwater travel time.
3 Then another reference would be 8.3.1.2 which is the 4 geohydrology.
5 DR. SHEWMON: I heard "A" as in "able." I should 6 have been hearing 8 as in number 8, is that right?
7 MR. POHLE: That's possible, yes.
8 DR. SHEWMON: And 8.3.12 is 8.3.12?
9 MR. POHLE: 8.3.1.2 is the geohydrology' program in 10 theSiteCharacterizationPlfn.
11 DR. Si!EWMON : You referred me to what I heard as 12 A.312. I'm trying to get a translation of that.
13 MR. POllLE : Well, it can only be one of two
(} 14 things: 8.3.5.12 which is the issue resolution strategy for 15 issue 1.6, groundwater travel time. Or section 8.3.1.2 16 which is the geohydrology program. And those were the only 17 two numbers I would have referred to there.
18 DR. SHEWMON: Thank you.
19 DR. MOELLER: Other questions?
20 King?
21 DR. STABLEIN: Dr. Moeller, I don't know if you'd 22 be interested in doing this before lunch, or after. But we 23 would like another try at the third item where Dr. Steindler 24 still had a problem. We'd like to offer a little more 25 explanation.
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( 1 DR. MOELLER: Well, let's go ahead and do it now.
2 DR. STABLEIN: Don Sherry is going to offer some 3 clarification on that.
4 MR. SHERRY: You said you didn't understand what 5 our question -- comment was there. They made a comment that 6 they were going to combine alternative conceptual models 7 generating a CCDF. We start our basis by saying what we 8 interpret their meaning of an alternative conceptual model.
9 To me, that interpretation is that it would be some 10 simplified model of the flow' transport system that they 11 would use in their performance assessment.
12 That could be if the complex modeling of the 13 natural system would probably start out would be, as I
(} 14 indicated, is going to be a couple of flow transport 15 continuity equations -- finite -- type model three 16 dimensions. Get fancy with it. They're not going to be 17 able to use those type of models for performance assessment.
18 So you may use your linear -- simplification of that or your 19 input output responses or a convolution. That's what we 20 state is our interpretation of their alternative conceptual' i
21 model would be one of those models of that flow transport 22 system.
23 Now, you can only come down to using one to 24 represent that system. If you combine several 25 representations of that, you know, one linear regression for
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() 1 one configuration of the system, then go develop another 2 configuration of the system and make another simplified 3 model, and.come back and combine those with some kind of 4 weighting factor, which I think -- judgment, maybe, -- when 5 you generate the CCDFs for each of the individual models you 6 would get a CCDF. You come back and combine the two, you'd 7 get some mixed CCDP which is doesn't have the information in 8 details that you would have with the individual. generating 9 with the individual model.
10 And we give a coupl'e of citations to a couple of 11 NRC NUREGs that discuss this process.
12 DR. STEINDLER: And your assumption or your 13 concern is that those tails, that the information buried in 14 those tails is sufficiently important to warrant some
(]
(-
15 significant amount of extra effort?
16 MR. SHERRY: Well, there's no extra effort in it.
17 Actually, we say it's just theoretically inappropriate to do 18 that. You've lost the information. I don't know what's
-19 gained by going and getting another model, you know, 20 representation of the system, combining several of those 21 together.
22 DR. STEINDLER: Theoretical inappropriateness is 23 because you lose information. Is that your point?
24 MR. SHERRY: You lose the information, that's 25 true. But why do that, too. Why go --
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(_w) 1 DR. STEINDLER: I'm trying to distinguish between 2 the theory and the practice. I understand the practical 3 problem that you have, namely, why did they bother doing 4 that, etcetera. But your comment was, I think, 5 theoretically inappropriate. And I'm trying to figure out 6 what the theory is. The theory is is total information 7 package? The loss of information is the theoretical base 8 for why you don't want to do that?
9 MR. SilERRY: I would say it's inappropriate to 10 The net effect is that takeanothermodelandcombif[eit.
11 you lose information. Firstly, the model of the complex 12 system, or whatever your reduced model is, we will say that 13 has to be substantiated or supported. In other words, 14 you've got to go through this process, and that's the only 15 one. I don't know how you can go and get another 16 representation of that and start adding them together.
17 MR. POllLE : If you want to look at it the other 18 way, is the mean behavior of the system is that what we 19 consider to be conservative. I mean, clearly you read in 20 there that related to that one assumption that was made in 21 the SCP that even though a saturated zone may actually be a 22 fracture media, we are going to nodel it for 23 conservativeness as an equivalent porous medium. I can 24 debate whether that's going in a conservative direction, or 25 not. You have to do some sensitivity studies. But if
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() I conservativeness is the objective, then perhaps that is not 2 the appropriate way to get a conservative answer by just 3 providing someone with a mean response to the system.
4 DR. STEINDLER: Fine.
5 MR. SHERRY: Also, I might, on the comment that 6 Dr. Moody brought up about the legitimacy maybe of 7 representing the fracture system out there with an 8 equivalent porous medium. If you're going to look at 9 modeling this with 100 meters by 100 meter blocks, or maybe 10 greater, is that inappropriate. I can't reason the Staff 11 can't say that that's going to be an inappropriate process 12 until all this is evaluated.
13 You take the scale of the fractures against 100
(} 14 meter dimension of a dispensation or a finite element 15 representing elementary volume, what is the net effect of 16 thousands of those within that system, within that element?
17 And that's the way modeling's done.
18 DR. MOODY: I know.
19 MR. SHERRY: Okey. We have to be aware of how 20 things are done.
21 22 23 I 24 25
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'l DR. MOELLER: Any other questions or comments?
'2 (No response.)
3 DR. MOELLER: Hearing none, I declare a one-hour 4 recess for lunch.
5 (Whereupon, at 12:10 p.m., the hearing was
[ 6 recessed for lunch, to reconvene the same day, Thursday, f 7 May 11, 1989, at 1:10 p.m., in the same place.)
8 9
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134 I 1 AFTERNQQN g E E E I_ Q N 2 DR. MOELLER: The meeting will resume. We will 3 take up the next topic which is materials engineering, if my 4 schedule is correct.
5 King?
l' 6' DR. STABLEIN: That's right, Dr. Moeller. The 7 next. topic we're going to take up will be the materials l 8 engineering.
I 9 DR. MOELLER: Well, what is the different in 10 materialsengineeringandenfineering?
11 DR. STABLEIN: Our package, the materials folks 12 were very unhappy with me because originally 1 labeled them 13 materials science which is -- so I finally got them right, r
14' and t.he engineering in your package is now correct.ly labeled 15 "geotechnical engineering."
16 DR. MOELLER: Oh, okay.
17 DR. STABLEIN: I asked the engineers about what 18 that term means, and I'll let them explain that to you when 19 they get a chance. But the geotechnical engineers will deal 20 with the shaft and repository design and the materials 21 engineers will be focusing today on the waste package.
22 We have with us today, Rick Weller, the section
- 23 leader for the materials engineering section. Rick's over l
24 here.
25 Kien Chang will be presenting the material on the O iierite9e Revertino cereeretien (202) 628-4888 l 1 L__ _----- - - - - - - - - - - - - -- - - - -- - - - - - - --- A
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( 1 waste package program. So I'll turn it over to Kien, now.
2 MR. CIIANG: The materials engineering, we address 3 the waste package, whereas in engineering, I think they 4 address the repository design as a whole.
5 DR. MCELLER: Thank you.
6 MR. CHANG: That's about the major difference.
7 The sections that address waste packages are in
.H Chapter 7 of the SCP and also most of the test programs are 9 addressed in Section 8.3.5.9 and 8.3.5.10. So that might 10 helpyoualittlebitwhenyfuarelookingforthewaste 11 packages portions.
12 In the CDSCP which is the predecessor of the SCP, 13 the CDSCP defines substantially complete containment in such 14- a way that they said that they would allow a maximum of 20
-(])
15 percent failure for the waste packages during the 16 containment period. And that was one of our major 17 complaints when we reviewed the CDSCP.
18 So in the SCP, the Yucca Mountain project came up 19 with a new interpretation for a substantially complete 20 containment. And you may find that new interpretation in 21 Section 8.3.5.9. I'm going to read that interpretation 22 because the whole waste package program is pretty much 23 geared towards that interpretation.
24 And that statement says: "the DOE under.tands 25 substantially complete containment to mean that the set of 1
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(,) I waste packages will fully contain the total radio nuclear 2 inventory for a period of 300 to 1,000 years following 3 permanent repository closure, allowing for recognized 4 technological limitations and uncertainties."
5 Ther; are two things -- from the old 6 interpretation. They added the set of waste packages, 7 rather than the waste packages. And then t. hey added 8 allowing for recognized technological limitations and 9 uncertainties. You do not find these in the old CDSCP.
10 And after defining'also you will also find in the 11 same section which is 8.3.5.9, which discusses about 12 implementation or this understanding. It says, 13 " implementation of this understanding will be based solely
() 14 on reliance on the waste package as the major component of 15 the engineer barrier system." So basically these are two 16 philosophies that DOE planned their waste package program.
17 You will find that ! . Chapter 7, as well as in 18 Chapter 8, the Yucca Mountain project basically set up 19 goals, goals and objectives to outline the test program to 20 satisfy these requirements. When we reviewed the Chapters 7 21 and 8, we had difficulty in different areas. And these 22 areas are outlined in the viewgraphs that I presume everyone 23 has a copy of it.
24 We find quite a bit of inconsistencies between the 25 goals that are set. They set goals for different components
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137 L O 1 1 the -eete eec*e9ee eea tuer e1 o eet 9oe1e tor the 2 repository conditions, situations like that they expect, you 3 know, no more than five' liters of water in a bore hole for 4 each waste package. They defined that as one of the goals.
5 1 don't know what it means, you know, if you find more water 6 because to me, it-seems to me a goal is something that you 7 can reach, hopefully, and maybe you can change it. But if 8 they say that the goal is no more than five liters of water 9 in each waste package, we have difficulty to interpret that.
10 Becauseyoucannotreallychfngeit.
11 DR. SHEWMON: Why is it that the water comes down 12 through the rock for a thousand feet but can't get out the 13 bottom of the bore hole?
_f 14 MR. CHANG: I think in the present design for the 15 waste packages, the bore holes are supposed to be sealed.
16 They did not tell us exactly what material they will use to 17 seal them. All they say --
18 DR ,SHEWMON: So you're interpreting this that it 19 only seals the bottom, it doesn't seal the top?
20 MR. CHANG: No, they --
21 DR. SHEWMON: Where does this five liters 22 accumulation come from?
23 MR. CHANG: We have no idea. It's just what they 24 say.
25 DR. SHEWMON: That's their assumption, --
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2 DR. SHEWMON: -- that somehow it gets in there and 3 can't get out.
4 MR. CHANG: Right, right.
5 MR. WELLER: Dr. Shewmon, let me amplify on that a 6 little bit. Because the whole repository concept is based 7 on drainage. And if water can get in, you know, the whole, 8 hopefully, design philosophy is that what can percolate in 9 can percolate out. But there's at least one SCP reference 10 which states for example that'the total effect might be such 11 that it will seal up the rock around the bore hold. There 12 is a concrete shelf like there. If that cracks for whatever 13 reason or if there is a gap or something between the liner 14 and the rock such that water can leak in, it may not be able 15 to leak out. And there are scenarios that you could 16 postulate whereby you could fill the bore hole with water.
17 DR. SHEWMON: Now, this is after a thousand years 18 when steam doesn't get generated. Presumably if the water 19 could get in, steam could escape through that same hole.
20 MR. CHANG: Excuse me. That's even during the 21 containment period, too, that five liters of water.
22 DR. SHEWMON: So whatever this is, there is a 23 pressure vessel which is semi-permeable; it'll let steam in
.24 but won't let steam out. I find that hard to visualize.
25 Dut that's what DOE assumes?
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( 1 MR.; CHANG: :Right, that's what DOE assumes.
2' MR. WELLER: Dr. Shewmon, let me also state, I
' 3: . think there's an open. question about what the thermal 4 profile is actua11'y going to look like. I wouldn't 5 ' necessarily presume that you're going to have steam around
'6 every waste package for a-thousand years. Because let's.not-
~7 forget.that the heat load, for example, on the gas canisters-8 is a lot lower than the heat load on the spent fuel. Not.
~
9 . only that, unless DOE takes very strong administrative
'10- controlstobalanceor.ensurfsome'kindofaverageor' 11- nominal ~ heat output per canister, you may well have some in
,12 which temperatures could.go below bo111ng.at.600 years.or 13 450. years or something like that, especia11yLthose perhaps L14 around the perimeter where the --
- 15 DR. SiiEWMON: Yes, I grant you could have a cold.
16 one, but if you had a cold one, then that would probably 17 also say something about if the water then came in because
'18 it was cold, it's cold for corrosion, then, too, presumably.
19 MR. WELLER: Well, I don't think the. DOE's 20 designing for any kind of water to contact the waste 21 package. That's why they have all these goals of limiting 22 the content per bore hole to five liters and the water 23 content for 90 percent of the bore holes to be no water at-24 all during the containment period.
25 DR. SilEWMON: They design for no water but they
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,,J
(_ 1 assume five liters.
2 MR. WELLER: These are performance goals. These 3 are things that I'm not sure you can really design that well )
4 for because -- and you're going to be stuck with the natural 5 environment in the Yucca Mountain. And these are goals that 6 they can perhaps test for. But if indeed the test results '
7 that they find indicate that there's a lot more water that 8 collects in a bore. hole, they may have to reassess their 9 performance allocation-and beef up the --
10 DR. SHEWMON: Would these bore holes be sealed?
11 You talked about these a minute ago was a sealed bore hole 12 that the water got in somehow we don't know when they do the 13 tests, are they going to be sealed in the same way, or is 14 that just an empty bore hole?
(}
15 MR. WELLER: I don't think they'll be cealed in 16 the sense that they're going to be grouted. There will be a 17 shield plug but I'm not sure there's going to be any 18 conscious effort to grout the bore hole or anything like 19 that.
20 DR. SHEWMON: I misunderstood what you said 21 earlier, then.
22 MR. WELLER: No, what I'm saying is what I said --
23 it's a radiation shield plug just like --
24 DR. SHEWMON: So people can work up above.
25 DR. MOODY: Okay, gotcha. So it's just over one
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' () 1 part. Okay.
2 DR. CARTER: Could I ask a question related at 3 least to the position, there's a statement in the overview 4 that there's going to be a bottom plate for vertical l 5 emplacement of the waste container. There will also be a 6 partial lining that goes down the hole to below the top of L 7 the canister to protect it. Now, what's it going to protect 8 it from, those two things, 'amely the bottom plate and the 9 partial lining?
10 MR. WELLER: The purpose of the bottom plate, as I 11 understand it, is to keep the canister off the bottom hole 12 such that if you have any water that accumulates, the 13 canister itself would still remain dry. And the liner can 14 protect against spoiling, at least to some extent, or
(}
15 dribbling or whatever you want to call it, that comes out 16 from vibration or whatever, and there will also be a 17 structure, as I understand it, also attached to the liner 18 which will help to guides, for example, will help to hold 19 the container in place in an upright vertical condition such 20 that it doesn't fall over and lean against the bore hole 21 itself.
22 DR. SHEWMON: That's the soft crushable spacer?
23 MR. WELLER: I'm not sure what the material is. I 24 would presume they do have --
25 MR. CHANG: I think they all -- material
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-1 compatible with the material that they use. That's all they-2 say.
-3 DR. SHEWMON: I don't~know if you were here this-i-
4- morning. -But the question arose as to what the geologists 5 were' concerned about with their faulting. And one came away.
6 withothe impression that.there could be rather diffuse-u ,
7 faults which would sheer the general area by a-certain 8 number of centimeters or. angles of sheer. .Whether orenot
'9 that would'do any damage to the package was something they,
~ 10 .hadn't' considered about, whi6) seemed to me relevant.
11 MR. CHANG: I have no doubt it will, if there is 12 ' movement.
13 DR. SHEWMOt4: I'd like to know how.
14 MR. CHANG:
} Because the waste package is only one 15 centimeter thick, one centimeter thick, which is very thin.-
.16 And'I don't think it's designed to bear any load at all.
17 DR. SHEWMON: Shaking but not shearing.
18 MR. CHANG: Right.
19 DR. SHEWMON: Fine. Let's get on with the 20 package. Pardon me for - .
21 DR. STEINDLER: Before we leave that, there's a 22 section in this write-up that we have that states, " design 23 goal number one," which I assume comes out of the SCP.
24 MR. CHANG: Yes.
25 DR. STEINDLER: Counts for a design goal for
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('-) 1 drainage of bore holes that will be met with a high level of 2 confidence. How does that match with your conmuent that they 3 plan to accommodate the five liters of water?
4 MR. CHANG: Design goal number one. Okay.
p 5 DR. STEINDLER: That's what I'm looking at on an t
l 6 unnumbered page out of a stack that's an inch high, so I 7 can't tell you where I am.
8 MR. CHANG: Okay. I don't know whether you're 9 talking about design goal number one for thermal loading?
10 DR. STEINDLER: Wel'1, it's called emplacement hole 11 drainage, design goal for drainage of emplacement holes, 12 page 8342-27, paragraph 3. I hope that means something to 13 you.
(~) 14 MR. CHANG: Yes. I think it means -- we have one
%)
15 of our comments on that, too, comment number 9.
16 DR. STEINDLER: I don't know what number it is, 17 but I'm looking at comment 7, I think.
18 MR. CHANG: Comment 7.
19 DR. STEINDLER: All I'm saying is, it looks as 20 though if this is correct that DOE is in fact counting on 21 designing that bore hole so that it will in fact drain, 22 rather than accumulate, which seems like a reasonable thing 23 to do. But I don't understand the original comment about 24 the five liters.
25 DR. MOELLER: At the meeting, our most recent
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'1 meeting on shaft seals and so forth, it was clearly pol'nted.
-2 'out that they were not to be impervious to water, they were 3: to let,the water through.
4 MR. CHANG: We had the same difficulty. We try to
.5' address that in Comment 9. .And we say one of the two design R 6 goals-. number one, for thermal. loading states that 7 ' repository layout will be. designed so that the thermal' 8 loading characteristics will assist in keeping liquid water
- . 9 from contacting the waste package for the first 300 years o..-
.10 sfter closure. . llowever , iffoulookatdesigngoalnumber.
11 two, . design goal. number two says if you allow five percent,
-12 of the waste packages to be contacted by less than five
'13 ' liter of water per year. So in one goal, it says, you know, 14 no water. In the other goal, it says you allow five liters
(])
15 of water.
16L The only reason I can think of is maybe they tried 17 to have some redundancy in design, you know, trying to.
18 assume that there's no water. But in case that there is 19 water, they can still handle it. But they did not explain 20 that in the SCP. So we quoted it as one of the 21 inconsistencies.
1
( 22 DR. STEINDLER: It strikes me that DOE's put up 23 two criteria for keeping the water out. One is, it's going 24 to be drainable. Two, they're going to space the stuff with 25 the knowledge of the heat flux such that the temperature (f- Ileritage Reporting (202) 628-4888 Corporation
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) 1 stays up so that even if there is blockage of drainage, or i'
2 whatever have you, the amount of condensate that you form 3 essentially then at atmospheric pressure is zero because 4 your temperature is up.
5 And then on top of that, my interpretation is that 6 if all of that fails, you still design them to allow five 7 percent of the canisters standing in five liters of water.
8 The original design goal, though, at least as I see it., is 9 drain it and heat it.
10 Is that right? Is'that the way you see it?
11 MR. CHANG: Yes, that's the way we see it, too.
12 However, it wasn't quite -- if you go through the SCP, these 13 goals weren't quite related. At least they did not explain
{} 14 it. And also when they put out, they quoted five liter, 15 they did not explain on what basis they used that number.
16 So that was also one of our comments, basically the basis 17 for the numerical values that they picked.
18 DR. SHEWMON: A minute ago, five minutes ago, you 19 said that this bottom plug or plate or whatever was in the 20 bottom of the hole was so that the water would not get up 21 around the canister. Is that plug designed so that five 22 liters won't reach the canister? Is that your --?
23 MR. CHANG: No, that's not my interpretation. All 24 they say is they designed it in such a way that they do not 25 expect more than five liters of water.
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.1: DR. SHEWMON: I know. 'I! understood that-each time 21 you've said.it. But my question was,,1f'there is this.-- I-3 . don't . know exactly what the word was -- this plate ---
4 DR. CARTER: .It's a bottom, plate.
L, 5 DR.'SHEWMON: -- bottom plate. And you said the
.6 purpose'of'that-bottom plate was'to. keep'it'-up above the' 7 water.
8 DR. CARTER: Mr. Weller said that.
7 9 DR. .SHEWMON: Okay. And is that,.will11t keep.it
- 10 up for.one liter or five 11tirs or do.we haveLany idea?
11 MR. CHANG: We don't have any' idea.
- 12 MR..WELLER:- Dr. Shewmon, we haven't done that 13- calculation but our contractor that we talked to from the
' 14 center indicates that it really doesn't take too much water L
(}
15 in view of the rather small gap, air gap around the waste
' 16 _
package to-create a' water line on the. canister itself. I 17 don't know what the number is, but it doesn't take a whole 18 lot of water.
19 DR. SHEWMON: Thank you.
20- MR. CHANG: Do you recall what the gap is?
21 MR. WELLER: No more than an inch. It's not very 22 much.
23 DR. STABLEIN: Seven centimeters.
- 24 MR. CHANG: Seven centimeters.
' 25 Anymore questions on that?
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.l 1 DR. MOELLER: Anymore questions?
2 (No response.)
3' MR. CHANG: Okay. The next area we have 4 difficulty is on the testing. One of our CDSCP comments was ,
f 5 that there was very little discussion on standardized tests.
6 And we still find that to be the case in the SCP. The only 7 standardized test is the MCC, one test. And it is a static 8 test, 28 days, and so we -- I think-the DOE also agreed, you 9 know, that it is not a realistic test, either, even though ,
i
- 10 it is a standardized test, fut it did not shed any light or 11 did not have any additional discussion on how they would 12 develop standardized tests in the future.
13 DR. SHEWMON: This is a test to test what?
[} 14 15 MR. CHANG:
form leeching.
To test both the waste forms, waste 16 DR. SHEWMON: Okay, so it's a waste form leeching 17 test.
18 MR. CHANG: Waste form leeching test. And also 19 there hasn't been any what you'd call standardized test for 20 corrosion, either. When we talk about corrosion, for 21 instance, we must address, in most cases they talk about 22 corrosion tests in deionized water or J-13 water. But even 23- if that were the case, we do not expect the underground 24 water to be identical to J-13 water. And even if they were 25 identical to J-13 water, you still have to consider
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l 148 1 evaporation and other ingredients that the water might pick 2 up when it flows through the failed waste packages. But 3 r.one of these are described in the tests.
4 DR. SilEWMON : Is your concern when and how the 5 waste package canister would fail? Or, you've talked about 6 leeching and corrosion. Let's leave leeching for a minute 7 and talk about corrosion.
8 MR. CIIANG: Okay.
9 DR. S11EWM0ll: Do you know what the material is, 10 yet, orwhatdoyouassumeifwillbeinthecanister 11 outside?
12 MR. CHANG: They have a candidate material.
13 DR. SilEWMON: What is it?
(} 14 MR. CilANG: 304-L.
15 DR. SIIEWMON: Okay. And what sort of testing are 16 they trying to do, or what criteria?
17 MR. CIIANG : They have outlined testing which says 18 that they will do it for deionized water, corrosion using 19 deionized water as well as J-13 water.
20 DR. SHEWMON: But is this a general corrosion 21 wastage test? Or is it a stress corrosion cracking test?
22 Or what?
23 MR. CllANG: Stress corrosion cracking.
24 DR. SilEWMON: I would think wastage would pass
'25 with flying colors.
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p _hr- 1 MR. CIIANG : Well, they claim that there is no 2 general corrosion.
1 3 DR. SIIEWMON : Fine. That's not what you said a 4 minute ago, but that's what I would agree with.
5 Now, so they're doing a stress corrosion test of 6 some kind?
7 MR. CIIANG: Right.
8 DR. SilEWMON : In these various waters.
9 MR. CIIANG: Right.
10 DR. SilEWMON: Now,'what fraction of the time do 11 you think it will be underwater, or just to have something 12 so you can run a test, you assume it's under water all the 13 time, or do they assume it is?
(} 14 MR. CHANG: It wasn't too clear. It wasn't too
- 15. clear what they would run for it. I have some idea, I 16 think, you know, what they should test it because basically 17 you could have dry conditions, okay. You could have steam 18 and you could have steam and water. So those are the three 19 combinations you can have.
20 MR. WELLER: Dr. Shewmon, let me amplify on that a-21 little bit, because I'm sure that DOE is doing parametric 22 studies just like our own contractors are doing, some on the 23 steam environment, some with pure J-13 well water, some with 24 concentrated components of J-13 well water, varying Ph, 25 wat' temperatures of 90, 95 degrees centigrade, the full
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. i 150' 1 gamut of. parametric studies.
1 2 DR.'SHEWMON: Do they have criteria based on those
~
3 . tests which will have to be met in order to establish that-4 it will meet the criteria needed or that it'll be -- what's
,5 a. satisfactory test.
6 MR. WELLER: Well, they're going to study.first of 7 all'for'all different kinds of failure modes whether that's 8 hydrogen embrittlement or stress corrosion cracking, 9 whatever, depending on what kind of metal you're looking at, 10' crevice' corrosion. And then' inasmuch as the waste package 11 design is designed to be corrosion resistant and not to ..
112 provide for corrosion allowance, you know, they will -- I'm
'~ 13 sure they're going to look at corrosion rates, as well, to 14 ensure that indeed in the time frame of interest, whether 15 that's a containment curve or the full ten thousand years 16 that this materially will last for.that period of interest.
17- DR. SilEWMON: We agreed that general wastage at 90 18 degrees C. was probably not a problem. So then there's some 19 search for some other kind of an accelerated failure 20 mechanism. And when we find one, we'll recognize it. And 21 if we don't find one, we'll know that, too. Is that the
~
22 ' philosophy?
23' MR. WELLER: Well, presumably they'll to the best' 24 of their ability look for every conceivable failure 25 mechanism.
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l 151 1 MR. VOILAND: Is there a study plan on that test?
2 MR. WELLER: You won't find that kind of detail in 3 the SCP.
4 MR. VOILAND: Not in the SCP but in the study 5 plan.
6 DR. MOODY: Site study plan.
7 MR. CIIANG : In the SCP, you will find they have 8 descriptions on hydrogen embri tlement tests, stress 9 corrosion cracking tests, and so on. But you'll not find 10 the details. But detail, I Sean, you know, at what 11 temperature or how long.
12 DR. MOELLER: Gene's question, though, is quite 13 appropriate. Is there a study plan underway or being 14 developed? And when will it be available if yes?
15 MR. CHANG: Okay. I know that they are doing a 16 study plan underway, but they have not been officially 17 released.
18 DR. MOELLER: Okay. So it's underway.
19 DR. SilEWMON : How will you judge whether or not 20 the corrosion results are satisfactory? What criteria will l 21 you use?
22 MR. CHANG: From NRC standpoint? Okay, I would 23 try to relate it to a scenario. First of all, you must 24 identify under what scenario the waste package will undergo.
25 And then I would try to relate that to the test conditions, t IIeritage Reporting Corporation (202) 628-4888
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) 1- see if they really tested the material under those 2 scenarios. And then relate the --
3 DR. SHEWMON: When will the scenarios be defined?
4 MR. CHANG: Yes, there's --
5 DR. SHEWMON: No. When will they be defined?
qi- 6 MR. CHANG: When.
7 DR. SHEWMON: You say you'll work with these 8 scenarios.
9 MR. CHANG: Well, right now it is not very well 10 defined in the SCP. ,'
11 DR. MOELLER: So you're saying the DOE has to give 12 you the scenarios and then you'il work with them?
13 MR. CIIANG: Right.
I~T 14 DR. MOELLER: Now, in the last meeting, we heard V
15 the presentation on the potential for carbon-14 being 16 released.
17 MR. CHANG: Yes.
18 DR. MOELLER: Now, how does that change, if at 19 all, your studies or criteria or requirements for the waste 20 canister?
21 MR. CHANG: The carbon-14, you said, is very 22 different carbon. Now, we have one of the comments, one of 23 the comment are the DOE has a strategy to handle the Carbon-24 14. Let's see what comment that is.
25 DR. MOELLER: While you're looking that up, I
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2 straightforward 1y said, the 11guld pathway is the primary
- 3. pathway of concern. So if Carbon-14 proved to be important 4 or more important than the 11guld, they'd have to go back 5 and rewrite that?
6 MR. CHANG: Yes.
i 7 DR. MOELLER: Okay. But they're looking at'it.
8 DR. SIIEWMON: Carbon-14 would be gaseous? Or why 9 wouldn't it be liquid, too?
10 DR. MOELLER: Thefhoughtwasitwouldbegaseous
) 11 and would emerge at the surface.
12 DR. SilEWMON : This is some COCO 2 or something.
13 MR. WELLER: It's Carbon-14 in monoxide form.
14 DR. ORTH: And is it assumed not to exchange with 15 all of the carbonate that's in the water system and the rest 16 of that thing, too.
17 MR. WELLER: That's something I'll have to look at 18 and assess. They recognize that there may be some exchange 19 in the natural environment. But Carbon-14 can also come out 20 in the liquid pathway. There is certainly a large enough 21 inventory to get them into trouble either in the gaseous 22 pathway or the liquid pathway.
23 MR. CIIANG : The SCP addressed that on page 83520.
24 They talk about alternative designs on how to handle that.
25 As a matter of fact, one of the alternatives that they IIoritage Reporting Corporation (202) 628-4880
154 I) 1 mention is basically change of rule. Change, request an 2 exception of NRC.
3 DR. MOELLER: Or EPA, I presume.
4 DR. STEINDLER: I. guess I'm still a little 5 un'certain about your objection concerning the testing ~and 6 your focus on standardized tests.
7 MR. CHANG: Yes?
8 DR. STEINDLER: What is it that you believe should 9 be written into the SCP that is not there now.
10 MR. CHANG: Conceri[ing standardized tests?
11 DR. STEINDLER: Yes.
12 MR. CHANG: We would like to see written in the 13 SCP that DOE would address areas where standardized tests 14 are required. And if they're not in existence, how they 15 would go about developing these standardized tests, like 16 going through peer review and so on. So that the tests that-17 they collect in different labs can be compared with one 18 another. As of now, tests including corrosion tests, they 19 are all collected in different environmental conditions, 20 it's very difficult to compare the results that they've 21 collected from different labs.
22 DR. SIIEWMON : In addition to that, you're going to 23 have tests which somebody can run over a weekend or at most 24 a. month and try to take some of that and extrapolate the 300 25 years.
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() 1 MR. CIIANG: Yes. Right, that's on the prediction 2 portion. And in the SCP, they mention that they'll probably 3 use short-term tests when they mention short-term, they 4 mentioned up to five years. However, they did not outline 5 any strategy with regard to how they'll use that. They did 6 mention about model development and so on but there wasn't 7 really enough detail on how they would use those tests.
8 DR. STEINDLER: Well, I guess I don't really know 9 what you mean by standardized tests but are you saying that 10 you really would like to see'a, say, an ASTM related test 11 that lasts five years? I have some difficulty in 12 understanding how you expect the Department to do that and 13 still meet some kind of a time schedule. Because it takes a 14 fair length of time to qualify standardized tests if you're
-(])
15 talking standardized ala for example ASTM. If you mean 16 systematized where everybody in the complex *is doing the 17 same thing, that's a little bit different.
18 Now, can you tell me, allowing me that 19 distinction, can you tell me what you mean by 20 " standardized"? ,
1 21 MR. CilANG: Well, when I say, standardized, 1 22 really mean systemized, which means everybody using the same 23 one. It doesn't have to be ASTM. Actually, if you go to 24 ASTM, there are none that you can apply directly for the 25 waste package program.
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156 If 1 DR. STEINDLER: Depending on what your after, I 2 guess that's right.
3 DR. SHEWMON: What people usually do is to do 4 something like a slow strain rate test which takes days and 5 if they get some indication in this that some stress 6 corrosion cracking occurred. And for the rest of you non-7 corrosion people, this is a test where you literally pull a 8 tension test very slowly in the particular corrosive or 9 media which you want to check to see if it's corrosive. If 10 you see any evidence of thatl'then you say, well, yes, over 11 a long period of time, it may be prone to that. And that's-12 usually the best that people have.
13 And that is not five years. It's going to be five
(} 14 days and that's it. And you're going to have to then go get 15 your crystal ball, or they are, and decide what's going to 16 happen in 500 years.
17 MR. CHANG: We don't find enough detal] concerning 18 how they would use those tests for long-term prediction, 19 aven though they did mention about a maximum of five years L 20 test data. And for that reason, we think that in situ test
- 21 is very important. However, if you go to the SCP, you do 22 not find any discussion on in situ tests for the waste 23 packages. That was one of our comments. Because we feel 24 like that, you know, with all the uncertainties in the 25 environment and in the waste package analyses, in situ tests
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-1 'seems to be at'least one'way to minimize or to reduce some 2 uncertainty ~1n that respect.
3 DR. MOELLER: In that regard, I've.always been --
l 4 I shouldn't say, troubled; that's too strong a word - .but 5 by-the fact that I would have' thought that, you know, after 6 the. repository was finished and the waste was emplaced and 7 it was sealed and you l' eft'it, that you would have still run 8 a few' wires down there to be taking some readings and 9 following what's happening. But I gather, once it's sealed .
10 up, there will be-nothing; n$ more data.
11 MR.' CHANG: There is no requirement after closure.
12 DR. MOELLER: Right, I understand.
13 MR. Cll/d1G: On the other hand, it seems to me, 14 even.ifLthat's the case, you can still set up some-15 experiment now so that you can collect them until you --
16- DR., MOELLER: And again for 50 years or more,.you 17 could be getting data, yes. Okay.
18 MR. CHANG: But we don't find that, in situ tests.
19 DR. MOELLER: So you're encouraging them to do 20 that.
21 MR. CilANG: Right.
22 DR. MOELLER: Fine. We better move along. Let's.
23 take up performance conformation programs.
24 MR. CHANG. I think we've pretty much covered that 25 already, you know, because in the case of testing, we
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158 r i mention'about, they mentioned about five-year testing.
2 However, we don't see how they would use those data for
- 3. long-term prediction. And also we don't see, you know, in 4 situ tests in their program.
5 DR. MOELLER: All right.
6 DR. STEINDLER: Are you saying that the SCP has no 7 Information that tells you how the Department is going to i i
8 extrapolate, for example, the performance of glass in ground 1 9 water? Is that what you're saying?
10- MR. CHANG: Not muc'h, not enough information.
11 DR. STEINDLER: I must say, I'm puzzled. I 12 confess not having read the entire 6,000 pages, a revelation 13 that I'm sure comes as a great surprise to you. But the 14 program that I'm aware of that.the Department is running in
(~ }
15 this area is an extensive program. I'd be startled not to 16 find some significant mention of it.
17 MR. WELLER: His whole point about performance 18 confirmation is that in the Section of the SCP on 19 performance confirmation, they have a table of long-term 20 tests that they will continue after the site 21 characterization program is over with. And the simple 22 essence of our point paper here is that there are no waste 23 package tests. And we're wondering why, as Dr. Moeller 24 questioned, it wouldn't be a good idea to start some of 25 these long-term tests during site characterization and let
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() 1 .them run for 40, 50, 60 or 70 years prior to closure, such 2 that it can aid in any-decisionmaking about closure itself.
3 Or if you're going to have to invoke some retrievability 4 decisions.
1 5 MR. CHANG: We are aware that they're doing a lot 6 of lab tests on leeching and so on. But we can't really 7 relate that to long-term predictions because the conditions 8 are all different.
9 DR. STEINDLER: But you're willing to accept the 10 mechanistic model if the mec6anism is reasonably well 11 understood?
12 MR. CIIANG: Yes. Yes. Nevertheless, there is a 13 lot of synergism that you're not able to address in lab 14 tests. So it seems to us that something must be done, 15 something like in situ tests to reduce that uncertainty or 16 confirm what the data is collected in the lab.
17 DR. MOELLER: Does that rest your part, now?
18 MR. CIIANG: Yes, pretty much.
19 DR. MOELLER: Well, thank -
, Mr. Chang.
20 And we'll move on then to the next item.
21 King?
22 DR. STABLEIN: The next topic that we would like 23 to bring up for your attention is performance assessment.
24 And the section leader for the repository performance 25 section is Seff Copeland who can't be with us today. Norm
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,m.
(_) 1 Eisenberg is going to present our concerns. Ile's the chief 2 reviewer. Also with us today is Pauline Brooks over here in 3 the second row, who's worked on this review. And Dan 4 Parringer, who.I don't believe is in the toom today.
\ '
5 So I'll turn it over to Norm.
6 MR, EISENBERG4, In summary, our concerns are the 7 following: The SCP commits to a systematic integrated !
t 8 approach to site characterization. That is the issue 9 resolution strategy. However, the SCP does not appear to !
10 demonstrate that such an appfoach has been implemented.
11 And we have some specific areas of concern, six of 12 them. They are: performance allocation, alternative 13 conceptual models, the use of performance assessment to
() 14 guide and evaluate site characterization, the validation I
15 program, scenario analysis, and the formal use of expert 16 judgment.
17 Before addressing each of these in turn, I'd like 18 to say that an overall concern is that DOE may get 19 information to resolve issues in each di3cipline, but the 20 aggregation of these datas to resolve overall issues such as 21 the four quantitative regulatory criteria, may not be 22 successful because not all the needed data were obtained 23 during site characterizati,on.
24 A few more general remarks: this issue resolution 25 strategy has been articulated by the DOE. The NRC staff has
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ra O ' 161 1' agreed that this is an appropriate approach. Many 2 agreements have been concluded between the two staffs over a 3 period of years and-have led to this approach.
4 In addition; I should point out that the NRC staff'
~
- 5. had some comments related to performance assessment on the 6 consultative draft. In particular, we had an objection on 7 alternative-conceptual models, and for some other issues, 8 including scenario analysis. Clearly, the DOE.has expended 9 a lot of effort in responding to these. concerns as in the 10 developmentJof the extensive' hypothesis testing tables.
11 Nevertheless, we still have concerns,.and are 12 attempting to determine the significance of these concerns.
13 I think our problems are largely with the execution of the
- 14. approaches and the potential impact these problems may have
(]~
15 on the ability of DOE to get sufficient information to make 16 licensing: decisions at the end of site characterization, 17 rather than the approaches themselves.
18 Yes, sir?
19 DR. STEINDLER: Let me ask a question.
20 I assume these words are fairly carefully chosen, 21 namely, the thing that you're concerned about is that such 22 an approach, as you said, issue resolution strategy, 23 etcetera, has not been fully implemented. The implication 24 of that is that you expect the site characterization plan to 25 reflect an activity that's already well completed and in O iieriteve nevertie2 (202) 628-4888 Corgeretion l
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(_) 1 place. Is that a realistic expectation, or am I 2 misinterpreting what you're saying.
3 MR. EISENBERG: I'm not sure I understand the 4 question.
5 DR. STEINDLER: Well, what it seems to me is you 6 have objected to the fact that something is not already in 7 place, fully implemented is what I think you said.
8 MR. EISENBERG: What we're trying to say is that 9 the agreements with regard to issue resolution strategy have 10 not been executed in the SCP'as a planning tool in the way 11 that we anticipated, or in a way that we feel is going to be 12 sufficient to assure that the plans, if executed as laid out 13 now, will obtain the required information.
(} 14 DR. STEINDLER: If that's what you mean, that's 15 not what you said.
16 MR. EISENBERG: Okay. Sorry.
17 I'm sorry, but the comment regarding issue 18 resolution strategy and its execution is as displayed in the 19 SCP.
20 DR. STEINDLER: Okay, that's not what I got out of 21 that sentence. I thought you already wanted this thing all 22 in place ready to roll, in fact, rolling and you're 23 objecting that it isn't done.
24 MR. EISENBERG: Taking these issues one by one.
25 We feel that performance allocation has some logical gaps.
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( 1 One is that the activity, parameters, which are the 2 objectives of the investigations, do not have goals and 3 confidences set for them in all cases. Therefore, the 4 linkage between the objectives of the field and laboratory 5 studies and the regulatory requirements that drive them is 6 not altogether claar. And we're not sure that, if executed, 7 that the data obtained will be sufficient to resolve the 8 issues.
9 The performance allocation of the total system 10 performance does not appear C'o be completely satisfactory 11 because the goals as stated, if met, will not assure that 12 the standard will be met. And one of the principles behind 13 performance allocation is that the goals in the performance
(} 14 allocation tables, if the site characterization eucceeds in i 15 demonstrating that those goals are achieved,'then that will 16 resolve the issue.
17 In this case, the goals chosen, which are the 18 expected partial performance measures, were ten or more 19 times tite upper limit of .01 which was articulated in the 20 text as the limit for the sum of all of these EPPMs, 21 Expected Partial Performance Measures. So there seems to be 22 a logical disconnect.
23 The performance allocation for individual 24 protection, which is Issue 1.2, and the waste package 25 license time, issue 1.4, seem to have some problems. For
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h' 164 l( ) 1 issue 1.2, both liquid and gas pathways are considered.
2 llowever, the strategy presumes that if there is no 3 significant scurce of groundwater, tha liquid pathway will 4 not give you any violation. In fact, it's possible to have 5 exposure by drinking water from other than significant 6 sources of groundwater. And there may be a possibility for 7 exposure via routes other than drinking. So the strategy, 8 as stated in the SCP, does not seem adequate. -
[
9 DR. STEINDLER: Do those other avenues constitute 10 what the Staff would believe'to be reasonable scenarios? In 11 other words, integrated into a scenario and have come out to R 12 be significant?
13 DR. MOELLER: Is this irrigation of crops? Okay, h 14 MR. EISENBERG: I'm not sure.. But one would think f^/
15 that up front, one would at least in the planning phase set 16 that up as a possibility and then require that the 17 information necessary to eliminate it be obtained.
18 For the waste package life time requirement, the 19 performance allocation table specifies performance measure 20 which is the maximum fraction of containers that failed in 21 any given year. And the goals are set for three time 22 periods within a thousand years. And the text warns the 23 reader that one cannot multiply these annual failure rates 24 by the time periods involved to determine what the upper 25 limit on total packages failed would be.
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( 1 However, to demonstrate compliance with the 2 regulatory requirement, you need to know what the total 3 number is. You need to know if it's small enough to be 4 considered substantially complete containment.
5 DR. MOELLER: So the failure rate per year is a 6 maximum and they're simply saying, it won't occur every 7 year.
8 MR. EISENBERG: They're saying, this is to guard 9 against peak type releases and to prevent that issue or that 10 occurrence, but not -- itdofsn'tseemtosatisfythat if 11 you meet that requirement that you would then be able to say 12 you complied with the regulation. Which is at least the way 13 I read it is a requirement on the average rate or the 14 cumulative failure. So, again, there seems to be some
(])
15 problems in the upper level logic.
16 We believe that the treatment of alternative 17 conceptual models in the hypothesis testing tables have some 18 inconsistencies and gaps. The logic used to create the 19 tables seems uncertain because in some cases the same 20 antecedents in the tables yield a different need to reduce 21 uncertainty in selection of the hypothesis, which is column 22 0, which seems to be the bottom line of those tables.
23 We're currently reevaluating this comment based on 24 feedback from the recent sessions with DOE. But to try to 25 explain where our concern is, the hypothesis testing tables
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O1 have some hey entries. Column 3 is the uncertainty between
- 2. the current representation and the alternate. Column 6 is 3 the needed confidence in the parameter or performance measure. d 4 Column 7 is the sensitivity of that parameter to J 5 the different conceptual models. And then Column 8 seems to 6 sum it up as the need to reduce-that uncertainty between the 7 conceptual models.
8 I would presume that Column 8 would have some kind 9 of logical relationship to Columns 3, 6 and 7. And there 10 does not appear to be a cons 1' stent relationship. This 11 either means that the logic used to construct the tables was 12 not consistent, or that there is information important in 13 determining the need to reduce that uncertainty which has 14 not been entered in the tables.
15 That's not very desirable because'it's an 16 important issue that needs to be very well planned for and 17 we would like to see the rationale for the need to reduce 18 the uncertainty.
19 The DOE staff -- whether or not reducing the 20 uncertainty between conceptual models would bring the 21 performance measure from out of compliance to within 22 compliance, or vice versa, presuming that the sensitivity is 23 just sort of a gross measure, and it doesn't tell you where 24 on some plot of the performance measure versus some 25 compliance criteria where you are relative to that. Anyway, IIeritage Reporting Corporation (202) 628-4888 I
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() 1 we're going to continue to look into that one.
2 Going on with the hypothesis testing tables, there 3 appear to be instances where the studies cited in the tables 4 will not provide the data needed to differentiate among the 5 alternative conceptual models in the table. An example is 6 that sorption column test are cited as tests to distinguish 7 whether KDs can be used or whether a more complex chemical 8 model is necessary to model migration.
9 However, if you look into the description of.the 10 tests themselves, they appeaf to assume that the KD concept 11 is valid, and they are going to use the KD concept to L-12 interpret the data.
13 Some additional problems with the hypothesis
(} 14 testing tables is that they don't appear to be integrated 15 -across disciplines. The hypothesis testing tables are laid 16 out according to the 17 subject areas contained in 10 CFR 17 960, rather than according to the various parts of the waste 10 disposal system or the four quantitative NRC performance 19 standards. And that doesn't seem to be a good way to 20 integrate that particular issue.
21 Some important alternative concepts appear not to 22 be included the tables. There does not seem to be a study 23 aimed specifically at the unique features, if any, of 24 geochemical interactions in the unsaturated zone versus the 25 saturated zone. In that context, I might refer you to
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Comment 1211n the hydrology package, which discusses the l H 2 same issue.
3 Another example might be that the alternatives
'4 regarding.the influence of heat on flow seem to focus'on 5l : magmatic intrusions rather than on the heat from the 6 emplaced waste.
7 The'next large' topic area is performance 8 assessment. And it does not appear to have been employed in 9 a way that.would integrate the data gathering during site, 10 characterization. One item l's that the issue resolution 11 strategy places primary reliance for decisions for 12 terminating.a particular type of test on meeting the 13; performance allocation goals. Now, these are the goals that 14 are stated now in the SCP.
15 We question whether or not the criterion for 16 terminating testing shouldn't be to do a performance 17 assessment to see whether the standard is met. The 18 performance assessments do not appear to be phased in as
.19 site characterization proceeds. Contrary to the statements 20 indicating that performance assessments will be performed 21 iteratively, the first total system performance is not 22 scheduled until near the end of site characterization in 1993.
23 24 The fourth major item.is the validation program.
25 And it does not appear to be adequate. In that regard, I 11eritage Reporting Corporation (202) 628-4888 m.- m._i_ _ _..___._._____.-.m - _ _ _ _ _. ___-_____..m_ - _ _ - - _ _ _ m-__ m
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() 11 think Seff Copeland would like me to say that the validation 2 . issue-is very difficult and unusual, yet it's.a very
!3 import' ant issue in this'particular context. Performance 4 must be projected for 10,000 years and.significant parts of-5- the decision on licensing will. depend on these projections.
-6 of performance.
7 These projections require an interdisciplinary 8 analysis so that what might be satisfactory model' validation P 9 in any one discipline, hydrology or geochemistry, may not be 10 sufficient forthesemultidifciplinarymodels.
Il DR. PARRY: Are you saying that the SCP does not'.
12 lay.out a program where by they will prove the value of the 13 models being used? Is that what you --?
(}'14 MR. EISENBERG: Well, validation is addressed in 15 Section 8.3.5.20 but'it is addressed in a very general way.
16 There are citations to the hypothesis testing tables which 17 of course have an integral role in assessing the validity of 18 the models. But there does not seem to be a very strong 19 empharis on validation activities or on beginning validation 20 activities now.
21 DR. PARRY: How would the staff propose that 22 - validation be performed? Or what would be satisfactory to 23 the staff?
24 MR. EISENBERG: I'm not sure I have a ready 25 answer. I have a lot of views on it. I'm not sure that
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(_ 1 it's universally accepted by the staff. I've written a 2 couple papers on the subject.
3 Certainly at a minimum, I would think the primary 4 models for calculating performance, far afield radionuclides 5 transport, mass transfer from the engineered barrier system, 6 those models must in some way be evaluated and they have to 7 be evaluated, I think there must be a tie between the 8 laboratory tests and the in situ tests you can do in the 9 field, and natural analogs which give you the advantage of 10 havinglongertimescalesanfmuchlongerspatialscales, 11 but which have the disadvantage of they are not controlled 12 experiments. You're not sure what the conditions are.
13 To my knowledge, no one has been able to devise a 14 way to assimilate these various lines of evidence into a
(}
15 program that makes sense.
16 DR. SMITil: Does this, getting back to your 17 original point you just made a few minutes ago, that while 18 you may be able to develop models for the hydrologic effects 19 or the geologic effects and validate them, that when you 20 begin to put all of these things together, you don't have a 21 multidisciplinary model?
22 MR. EISENBERG: That's part of it, yes.
23 DR. STEINDLER: Is that based on the assumption 24 that there's some strange synergism among the various pieces 25 of the model that causes the whole to be something other
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h -1 than the sum of.its parts?
2 MR. EISENBERG: 'Well, I would answer that question 3 by.-saying that I don't know that there's a strange 4 synergism. I think that --
5 DR. STEINDLER: Strike the word, strange'.
6 MR. EISENDERG: -- given the way science is of t.en 7 done and compartmentalized, you may find, in fact I think
'l 8 -there are examples in the NRC program in the DOE program and 9- the internationaltprograms over the past 10, 15 years where 10 people have focused on a par (icular issue, focused on a 11 certain conclusion which someone coming in from another 12 field will say just does'not apply. It's not correct.
13' DR. SMITH: Well, something's bothering me. I 14 mean, we've been studying this issue of waste for, what,- 20
.15 ' years, 30 years? And we've always known that when you put 16 the canisters-in the ground that there are various different.
17-' things that might happen. And are you saying that you don't 18 have a model that currently feeds in all of those differer.t.
19 scenarios and gives you the possible different boundary 20 conditions or?
21 MR. EISENBERG: I don't think you have a validated 22 model. 1 don't think anybody does. -
23 DR. SMITil: Is it possible to come up with a 24 validated model?
25 MR. EISENBERG: You can come up with some partial fleritage Reporting Corporation (202) 628-4888
172 l 1 validation. I don't think you can do validation in the 2 usual scientific or engineering sense of having a model i
3 based on well-established scientific theory, making 4 predictions and going into the laboratory or the field and 5 determining if the predictions agree with the experiment.
6 DR. SMITil: I can't agree with you more because 7 generally speaking we come up with a model and then we can 8 go out and test it and you can plug it back in and you can 9 see how much the model deviates from what happens in the 10 real world. IIere , you're gol'ng to be trying to tell us what 11 happens 6,000 years from now.
12 MR. EISENBERG: But that, I believe, is the very 13 central issue in licensing and one that must be addressed.
14 DR. SMITH: Well, I don't disagree with you on
(}
15 that. It's very troublesome.
16 DR. PARRY: But effectively then going back to the 17 validation question, the staff does not at this time have a 18 concise position on how validation could be performed to 19 their satisfaction?
20 MR. EISENBERG: It's my understanding that there 21 is a plan to develop a technical position to address that 22 issue. I couldn't tell you off the top of my head what the 23 due date for that is. Maybe somebody else in the room can.
24 Dut I believe that is on the books as something to try to 25 get some consensus point of view of the staff.
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173 p) (_ 1 DR. PARRY: Will the Staff's comment on the lack-2 of validation information in the SCP acknowledge the fact 3' that the Staff's technical position will be forthcoming to 4 assist DOE.
5 MR. EISENBERG: But I think our point still holds, 6 regardless of what technical position the Staff ultimately 7 is able to arrive at. It seems to me, anyway, that there 8 are validating activities that should be begun now at the 9 beginning of site characterization and hopefully be allowed I 10 to continue for decades.
11 DR. SMITH: Because otherwise what you're doing is 12 you're proceeding down the road, spending an awful lot of 13 money, "we", the U.S., and really don't have a model or an 14 agreement on a model that will tell us whether or not the 15 performance assessment is what we want it to be, that it 16 will meet the standard. I mean, we've got the cart before 17 the horse.
18 MR. EISENBERG: Well, I don't agree with that. I l
19 think we have to do the two parallel.
20 DR. SMITH: At least parallel. Because then if 21 you don't know that, then how do you know what you're doing i
22 right now is what you really ought to be doing?
23 MR. EISENBERG: Let me just add one other thinc..
l 24 rath the NRC staff and the DOE are participating in an 25 international study which is attempting to validate models
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( 1 of radionuclides migration in groundwater. And this is the 2 Intraval study run by the Swedish Nuclear Power Inspector.
3 And they are getting some interesting results and making I 4 progress. Ilowever, it's a very difficult issue.1 5 DR. PARRY: Turning to Dr. Steindler's synergistic-6 effects, where everything is supposed to add up versus 7 having an interrelationship that gives you a different 8 number than you would expect from direct addition, isn't 9 performance allocation a direct addition? That's certainly 10 thewaythatSeffhasdescrifedit.
11 MR. EISENBERG: I don't believe so, not when it's 12 done for total system. For total system, you have to 13 consider the synergistic effects and you have to consider 14 alternative conceptual models. Performance allocation is,
.( }
15 as I understand it, an interim measure to be used in the 16 absence of a thoroughly robust performance assessment pool 17 that could tell you the sensitivities of the various 10 parameters that go into your models, and the need for 19 various kinds of data.
20 DR. STEINDLER: 1 would just make a comment. I 21 think this is in fact a central issue and I would hope that 22 the next time we v.isit the validation question as you've 23 raised it, that it becomes a little more clear. It isn't 24 altogether clear to me but I hope it will be to your 25 customer and yourselves what it is that you expect DOE to do
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(,) 1- in validating a model whose predictive time frame is a great 2 deal longer than you could possibly expect any reasonable 3 experimentation to do, validation in the sense that you l
4 normally use the term.
5 MR. EISENBERG I don't think that you can do 6 validation in the normal sense; going to have to do 7 something else.
8 DR. STEINDLER: What I'm saying is, I hope we can 9 define from your objections what that something else is and 10 whether or not in fact it is'inore useful to the overall 11 process than what DOE is currently proposing, even if you're 12 assuming that DOE may not be proposing anything.
13 MR. EISENBERG: They're proposing something but it 14 doesn't appear to go far enough.
(}
15 DR. SMITil: Doesn't the NRC have some 16 responsibility to give them some technical guidance or some 17 indication as to how is NRC going to make that assessment in 18 a licensing mode?
19 MR. EISENBERG: I'm not sure I'm qualified to 20 answer that question. Could anybody help me out?
21 DR. S!!EWMON : Well, it seems to me if NRC doesn't 22 know the answer to that question, the program is badly 23 lacking. Because that's a fundamental problem that you've 24 had facing you for several years. That was identified a 25 long time ago.
,m
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.1" MR. BALLARD: Well, I'm Ron Ballard, Chief of 2' Geosciences Performance Assessment Branch. And the Staff 3 has recognized that. problem in a Commission paper, what-is
/ ?4 it,88-285, something like that, we have laid out all of the 5 . problem' areas that we think we're trying to tackle. And one 6- of them,.as.was mentioned, is the amount of validation.
, .7' We're.trying to take a position.
8 DR. MOELLER Is that a SECY?
9 MR. BALLARD: Yes. -SECY-88.285, issued about~1ast 10 November.- '
11 DR. MOELLER: November, '88.
12 MR. BALLARD: Yes. And in there,-we list a number 13 of rulemakings which are. intended to try and unscramble and 14 clarify staff positions.where they're needed, not on1'y 11 5 rulemaking but technical positions. They're a rather long-16 list. One of them is model validation. And there are a 17 number of others which you've touched upon during the day 18~ that are on that list. Extrapolation of, data is one. They 19 are very tough problems and at this stage, we just haven't
~20 been able to factor those into a reasonable schedule.
21 DR. SMITH: You know, I understand that. I guess 22- what bothers me in a broader context is moving along some 23 path, trying to meet milestones, millions, billions are 24 being spent, and yet we're in a position where we really 25 aren't sure how we will answer the question.
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- iq 1 MR. BALLARD: We're not sure how it is to be 2 answered. I think that in reviewing the plan, our primary 3 responsibility here is to try and identify areas where we, 4 based on whatever experience we've had in licensing, can 5 identify potential deficiencies, and want to get a prompt an 6 attempt to get those resolved.
7 In other words, the plan is e , mpy in this area.
8 And we would think the plan ought to t fleshed out in that 9 area to make sure that come the end of performance 10 assessment, we don't end up 61th some very large gap of 11 information that could throw a licensing schedule into a 12 two- or-three-year delay. That's what we're trying to avoid 13 by this process.
() 14 It isn't easy for DOE or us. They've done a 15 remarkable job since the issuance of the CDSCP and early 16 expanding in this area. It may look like we have more 17 quertions but we have a lot more to look at now, so to some 18 extent that was not an illogical result.
19 DR. MOELLER: Well, let's move ahead. You have 20 two more bullets.
21 MR. EISENBERG: Right. Two more major issues.
22 One is scenario analysis for the total system 23 performance appears to have some problems. Number one, the 24 scenario classes used in the performance allocation do not 25 meet the formal definition stated in the SCP for scenario
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-( ) I classes and therefore their use with the performance 2 measures, the EPPMs, is not consistent.
3 By way of explanation, scenario classes are 4 broadly based on release mechanisms while the performance 5 measures used are derived from this very precise 6 mathematical definition of scenarios as a sequence of 7 events. And so it's questionable what those tables mean 8 since the scenario classes that they're designed on are not 9 the same as what the performance measure in them was 10 designed for. ,
11 Some other problems are that the alternative 12 conceptual models are confused with scenarios.
23 I'm sorry?
14 DR. SMITI1: Can you give me an example of that?
15 MR. EISENBERG: The one just before?
16 DR. SMITH: No, this one just now.
17 MR. EISENBERG: Oh, yes. For example, in this 18 rather long discussion of scenarios, a l'ot of time is spent 19 discussing scenarios taken from a report by Ben Ross. And 20 some of those scenarios are only possible if you have 21 horizontal flow. And yet the preferred model for the site 22 is vertical flow. So it would seem that it's really a 23 different conceptual model.
24 Another example are different corrosion 25 mechanisms. Different corrosion mechanisms are in the Ross
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) 1. -methodology give rise to different scenarios. Well, in
- L fact, if you look.at the problem as a. system subject to 3 external events, and the external events are your scenarios, 4 then all of those different kinds of corrosion should be 5 considered subject to the different battery conditions 6 ' supplied by the external events.
7 Those are two examples.
8 Also, it appears that initial conditions are 9 confused with scenarios. For example, in the Ross report, 10 defects in placing the waste' packages give rise to a set of ,
11 scenarios. Well, actually, if such a thing were to occur, 12 it would apply to all theLscenarios. Remember in the EPA l13 standard, the role of scenarios is to try to_ bound the 14 uncertainties with regard to future states of nature, and
-()
15 not necessarily what might. exist right now.
16 DR. PARRY: Norm, excuse me. Who is Ross and what 17 is this?
18 MR. EISENBERG: Ben Ross? lie has a small ' company 19 in town here, and for the life of me, I can't remember the 20 name of it. And he did a repor* for Sandia which is sited 21 in the SCP in Section 8.3.5.13.
i.
22 DR. PARRY: Could you kindly make a copy of that
} 23 available to us?
I' 24 MR. EISENBERG: Sure.
25 DR. PARRY: Thank you.
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() 1 DR. POMEROY: And, Jack, would you kindly make a I
2 copy of that available to us? j l
3 DR. PARRY: It's going to go around, around the 4 table. I k
5 MR. EISENBERG: Okay, one final on scenarios. )
6 There seem to be inconsistent approaches to the scenario 7 analysis. There's a mixture of the scenarios from the 8 decision-aiding methodology, the Ross report scenarios, the 9 additional scenarios added to supplement the Ross scenarios.
10 Then there are 49 scenarios (' hat appear to have no other 11 citation other than in the SCP. Then there's.this 12 mathematically precise definition of scenarios. And then 13 finally we end up with these five so-called scenario classes 14 which were used to do the performance allocation.
(])
15 And although there was an attempt made to link all 16 of these together, I'm afraid it wasn't all that clear to 17 me.
18 DR. POMEROY: May I ask you a question about that?
19 MR. EISENDERG: Yes, sir.
20 DR. POMEROY: I've been reading your comment 21 number 4, I believe. And I think I agree with it quite 22 strongly that you can't very well use a mixture of these two 23 approaches.
24 1 wonder who chose? Is that a DOE choice that was 25 made to, that this mixture should occur, and what is the
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, 181 ii- 11 s Staff's -- I'm.sure the Staff has' discussed this with the 2' l Department o'f Energy, and so'.I'm curious as to'know 3 something what'you said to them and what their response has
'4- been to'that?
J 5- -MR. EISENBERG: As I believe, I'm not sure all the 6 ' discussions that have gone on but at the. discussion we hadL
~
7 two days ago, this was raised. And'I believe -- and I don't 8- want-to misrepresent the Department of Energy'-- but I 9 believe.the. response was, well, we went through this 10 analysis;isthereanythingfeleftout? Is there any part 11 'of-the site characterization program that would be changed
~
12 because we might consider some other scenario or consider 13 them in different ways.
14' That was their response and I guess my view is two.
15 things: one is, again, this document is supposed to lay out
- 16. the rationale for the site characterization program. And if 17 the logic is faulty, you cannot be sure just be examining
-18 what the program is. I mean, the program may look complete 19 but without these logical threads leading you back to the 20 resolution of the issues and satisfying the regulations, you 21 can't be assured that that's going to happen. That's one 22 thing.
23 And the second thing is that I feel that if they 24 are going to generate CCDFs to demonstrate compliance with 25 the EPA standard, they must have a much more logically tieritage Reporting Corporation l (202) 628-4888
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j i
2 DR. POMEROY: I gather, and perhaps this has been 1 3 discussed before, but I gather that.these Ross scenarios are 4 an accepted way to approach the problem, or is this the 5 alternative approach that you discussed in your comment?
6 MR. EISENBERG: Yes. Because this is the approach 7 that was taken by, I believe, the IAEA while sitting down 8 and writing down all the things you can think of that might 9 effect a repository rather than say a more structured PRA 10 approach. '
l 11 The last bullet is formal use of expert judgment.
12 We had some problems with that. One is is that the text 13 seems to indicate in a number of places, but especially in 14 Section 0.3.1 that at some point, if the needed data to
(])
15 resolve an issue are not obtained, or at some point in time 16 if not all the data are in, then the DOE intends to use a 17 formal application of expert judgment to resolve the issue.
18 And I guess we feel that the DOE should articulate 19 criteria for the fonnal use of expert judgment, to make sure 20 that priority is given to more objective methods and to 21 obtaining the required data.
22 One other point in the application of expert 23 judgment, the method proposed for developing a CCDP in 24 Section 8.3.5.13 indicates that the DOE intends to !
25 incorporate alternative conceptual models as one of the
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(_) 1 uncertainties rolled up into the CCDF. In other words, they 2 intend to have experts apply a probability to different 3 conceptual models and then to develop the consequences for 4 the alternative conceptual models, weight them with the 5 probabilities and roll them up into the CCDF.
6 The Staff believes that that's not a good idea to 7 aggregate the uncertainties in that way because it makes the 8 licensing decisions more difficult.
9 That's it.
10 DR. MOELLER: Any $ther questions or comments for 11 Dr. Eisenberg?
12 DR. POMEROY: I have one more question.
13 I'd like to know, you said you'd like to see DOE
(] 14 15 toll you how they would use expert judgment.
involved in expert judgment for many many years, I would.
Having been 16 like to ask you the question: how do you see expert 17 judgment? How does the Staff see the use of expert 18 judgment? And is expert judgment, has that been accepted?
19 I know it has been in the particular instance, but I was 20 curious about the position of the Staff with regard to 21 expert judgment.
22 MR. EISENBERG: Let me answer in two ways. The 23 Staff is developing guidance, a technical position on the 24 formal use of expert judgment. And the Staff's view will be 25 articulated there. I am a rather unrepentant renegade and I
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( ,/ 1- don't like expert judgment. I would much rather have data.
i 2 But that's just speaking for myself.
3 DR. STEINDLER: But is that really the issue? I l
4 thought the issue was, when you cannot get data --
5 MR. EISENBERG: No, no. It's not a question'of 6 not gettin'g it. It's in the absence of the data. In other 7 words, part of the articulated issue resolution strategy of 8 DOE is that at any point that they must prepare the license 9 application, rather than tieing that to the acquisition of 10 the required data, they will'go ahead and prepare a license, 11 application and in the absence of required data, they will 12 substitute expert judgment.
13 DR. STEINDLER: Are we quibbling over words?
14 MR. EISENBERG: I don't think so.
.( )
15 DR. STEINDLER: The absence of required data, 16 whether you can't get it or it's too late to get it, or you ;
17 can't meet the schedule mandated by Congress. I mean, 18 what's the differenco? There isn't any data.
19 MR. EISENBERG: Well, I think the difference is, 20 is that if you plan up front for using expert judgment 21 rather than planning up front to make sure you acquire the 22 essential data, that's a mistake.
23 DR. STEINDLER: Fine. You can plan up front on a 24 success driven schedule and find that you just weren't quite 25 as smart as you thought you were, and you arrive basically
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2 110w , my queotion to you is, do you accept expert 3 judgment?
4 MR. EISENDERG: I think, I believe the Staff will 5 come out with a technical position that will allow the use 6 of expert judgment.
.7 DR. MOODY: The problem is that, you may realize 8 this, it's not even if you have the data that quote unquote 9 is needed, the scientific and engineering judgment is the 10 interpretation of that data. So there are many -- or do we 11 just want to talk about geologic and geophysical information 12 -- but it's also interpretation of data that is there. So
- 13. no matter how you look at any of the particular problems
] 14 that we're talking about here in terms of expert judgment, 15 data interpretation is included in judgment. So you never, 16 what I'm trying to tell you is you never get away from it.
17 MR. EISENBERG: I agree, especially in the 18 geosciences.
19 DR. MOODY: Well, in a lot of the disciplines, 20 they have data, and what does that data meet? Does it 21 actually meet your basic hypothesis? So, it's a scientific 22 problem in all the disciplines, some higher than others.
23 DR. POMEROY: Is there a time frame for the 24 release of the Staff's position?
25 MR. EISENBERG: Yes, there is. It's I believe in
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ij 1 the same SECY paper. I don't know what the date is.
2 DR. MOODY: Jack, do you know what the date is?
'3 DR. PARRY: When I get a hold of the SECY paper, 4 we will all know.
5 DR. MOELLER: Any other questions or comments?
6 Well, let's bring this presentation to a close.
7 All right, go ahead. Jack has an announcement.
8 DR. PARRY: Owen Merrill has obtained a copy of a
/ 9 list of the site study plans that will be available and the 10 schedule of them. Ile will b6'providing that to everybody in 11 the near term. There are about 19 expected through October 12 of '89.
~ 13 DR. MOELLER: Okay. We'll take a break at this 14 time, and we'll resume about 3:00 o' clock.
.( )
L 15 (Whereupon, at 2:40 p.m., a brief recess was 16 taken.)
17 18 19 20 21 22 23 24 25 1
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._/ 1 DR. MOELLER: The meeting will resume. And while 2 the remaining people are taking their seats, let me offer a 3 <
couple of comments. We have one more item, geotechnical 4 engineering, to cover on the SCP review and commentary.
5 Then I gather John Linehan that you wanted to go over a 6 little bit about this schedule for the rest of the review.
7 Then we have an environmental monitoring report to review, 8 and all of that we need to do certainly no later than 9 5:00 and hopefully by 4:45 or so. And for matters of the 10 record, I will have to leave'for about fifteen minutes at j 11 4:00 but I will come back. Okay. Let us go on then. King.
12 MR. STABLEIN: We will get right into it then, 13 Dr. Moeller. Our last presentation is on geotechnical
() 14 engineering, the shaft and repository design. Mysore 15 Nataraja is the section leader of the geotechnical 16 engineering section. Raj is over there. Dinesh Gupta is 17 the chief reviewer and he is up here and will be giving the 18 presentation. We also have at personnel who worked on this 19 John Buckley over here and John Peshel next to Raj. So I j 20 will turn it right over to Dinesh.
21 MR. GUPTA: Thank you. Good afternoon. As King 22 just mentioned, I will go over the NRC's top concerns on the 23 SCP in the area of geotechnical engineering, and also cover 24 the adequacy of the exploratory shaft facility design and 25 the testing in the area of geotechnical engineering.
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\_j 1 In this area we have reviewed the DOE's responses 2 to SCP concerns that we had raised last year. We also 3 review the acceptability analysis and I will cover that in a 4 minute and the SCP itself. And I will go over our concerns i
5 on each of these areas.
6 To start with on the draft site characterization 7 plan, we had three objections in the area of geotechnical 0 engineering, one being related to the location of the two 9 exploratory shafts. In the draft site characterization 10 plan, DOEhadproposedtolofatethetwoshafts, the 11 exploration facilities, in the area of Coyote Wash on the 12 side of the area where the water can flow in that wash.
13 Our concern was related to potential flooding and 14 infiltration of water going to the two shafts and could
()
15 affect the performance of the repository, of the waste 16 isolation capability of the site itself.
17 In response to our objection, DOE has presented an 18 analysis of potential flooding in that area. Our staff in 19 the hydrology section has reviewed that analysis and has 20 come to the conclusion that that is an adequate and 21 acceptable analysis. And base on that, we have come to the 22 conclusion that that issue is satisfactorily resolved at 23 this time.
24 Now on the location of the two shafts, there are 25 some other concerns that were discussed this morning with l
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(_ 1 respect to the. geology of the area, and you have heard about 2 those this morning. Those concerns would be tracked by SCP 3 concerns.
4 Our second objection was related.to DOE's plans to 5 penetrate the exploratory shaft number one below the 6 repository horizon another 400 feet or so into the barrier 7 of Calico Ilills. That is an important barrier between the 8 repository horizon and the underground water table, and we 9 had raised concerns that DOE should analyze the consequences 10 of penetrating that barrier ind see if it could affect the 11 waste isolation capability of this site.
12 In response to that, DOE has stated now in the SCP 13 that their current plans have been changed to limit the 14 penetration of exploratory shaft one just below the
{}
15 repository horizon, and that it cannot be penetrating the 16 Calico 11111s . Ilowever, they retain the option of coming 17 back to this decision later on and review it. And if there 18 is a need determined at a later date to penetrate that 19 barrier, they would inform the staff and would perform an l
20 analysis of the consequences of that penetration. And based 21 on that response, we find that they have adequately 22 responded to our objection at this time, and we consider 23 that objection to be resolved.
24 DR. SMITil: You said just below the repository 25 horizon, how many feet?
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'( ) MR. GUPTA: Fifty feet.
2 DR. SMITH: Fifty feet?
3 MR. GUPTA: Yes.
4 DR. MOODY: If we'can go back to the first one.
5 Did DOE, I think that I know the answer but verify it, did 6 DOE change the location of the exploratory shaft?
7 MR. GUPTA: No, they have not changed the 8 location. The location was changed in 1987 before the draft 9 was published. At that time the shafts were in the middle 10 of the Coyote Wash. In 1987' they decided to move them on i 11 the side of that wash. And our comments and objections on 12 SCP were based on the location of the two shafts on the side 13 of the wash and not in the middle of the wash.
14 DR. MOODY: In other words then, that issue has
(])
15 not been resolved?
16 MR. GUPTA: The analysis that they have presented 17 is for the new location.
18 DR. MOODY: What do you think of their analysis?
19 MR. GUPTA: I am not a hydrologist. Our hydrology 20 staff has reviewed that, and they have concluded that that 21 is an adequate analysis and that there is not a potential 22 for flooding of those shafts.
23 Our third objectisn was related to potential 24 Interference of tests. In the SCP, DOE had not provided 25 enough details for us to evaluate whether the tests that
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() I they are planning underground at the repository horizon 2 would interfere with each other. And we had raised a 3 concern that if there is not a strategy to avoid test to l 4 test inference that the results may not be adequate for use 1 5 in the license application.
6 Based on that, DOE had come up with an excellent 7 strategy to calculate these zones of influence of each test 8 where they would be located. Our review of the 9 implementation of that approach suggests that there are 10 concerns remaining in that afea, and we would be tracking 11 those concerns as part of the SCP concerns.
12 With respect to our other concerns which were not 13 objections but were comments and questions, we considered 14 that DOE has satisfactorily resolved about two-thirds of
{}
15 those concerns, and the remaining ones will be tracked as 16 SCP concerns.,
17- DR. PARRY: Have you developed any new concerns?
18 MR. GUPTA: Yes, we have. The reason for new 19 concerns, Section 8.4 of the SCP was substantially revised 20 by the DOE in response to our comments and questions. They 21 have presented a lot of new material, and they have really 22 expended a great deal in that area. They have really put in f
23 a lot of effort in giving us a lot more details. But because 24 there is new information there are some additional concerns 25 in that area.
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) 1 Our first concern in our handout here is on the 2 acceptability of the ESF design. Based on the review of the 3 SCP, we have concluded that the SCP and its references do 4 not demolistrate the adequacy of the ESF design and the 5 design control process, and therefore the adequacy of the 6 design itse1.f.
7 DR. SHEWMON: The design of what?
8 MR. GUPTA: The design of the exploratory shaft 9 facility. That includes the two shafts, the underground 10 areaoftesting,plusthedrfftsthatDOEisproposingto 11 explore.
12 DR. MOODY: Is this Title 17 13 MR. GUPTA: Title I, yes. Our concern is that G 14 since SCP is based on Title I design that Title II may not (V
15 be a logical extension of that design, but rather a redesign 16 to correct deficiencies. And the basis for our conclusion, 17 and I will go over a number of points to explain the basis 18 for our conclusion.
19 Before the SCP was released last year, we had 20 raised issues regarding DOE's exclusion of critical 21 regulatory requirements in the design resulting in 22 deficiencies in design and uncert inties regarding the 23 effectiveness of the design control process.
24 In response to those concerns, in December DOE 25 decided to undertake a design acceptability analysis, in
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() 1 other words to go over the Title I design all over again to 2 review the acceptability of that in response to our 3 -concerns.
4 That analysis was submitted to us in February of 5 this year. We find that that analysis fails to consider 6 certain key provisions critical to acceptance of the 7 conclusions. And I will go over some examples of why we 8 find that analysis seems to be inadequate.
9 Number one is the independence of the reviewers.
10 The reviewers who looked at (he Title I design, at least 11 five of them were certified not to have contributed 12 previously to the ESF Title I design. But in the design 13 acceptability analys.s document itself, they are identified 14 as authors, reviewers, contributors of specific documents
(])
15 with input to the ESF design. So there is a question about 16 the independence of the reviewers who looked at the ESF i 17 Title I design.
18 DR. MOELLER: How could this happen, I have read 19 what you said and I hear you now, how could DOE say these 20 reviewers were independent when indeed you found that they 21 had apparently at least, unless there is something that we 22 are totally overlooking, that they had apparentJy been.
23 involved?
24 MR. GUPTA: We nave not discussed this issue with 25 the DOE, and I believe that there might be some technicality lleritage Reporting Corporation (202) 628-4888
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connote what they mean by a person not being a principal-3 contributor. And we might be misreading or misinterpreting 4 those' terms.
5 DR. MOELLER: But at the moment?-
6= MR. GUPTA: That is correct.
7 DR. MOODY: Principal contributor, what is-the-8 difference between a principal contributor.and somebody who, 9 has contributed 40. percent say, it still meansethat they-
'10- have not been independent'of'that project?
11 'MR. GUPTA: We have'to clarify these issues at 12 DOE. I am sure that there would be extensive discussion on 13- these things at DOE. Our finding at this. time is that the
- 14- . independence has not been established.
)
.15 DR. STEINDLER: llave you identified for the 16 Department what'you mean by independence?
17 'MR..GUPTA: Yes, we have.
18 DR. STEINDLER: The names of those folks are 19 nowhere to be found?
20 MR. GUPTA: We have given the names and we have 21 also been given by the DOE itself. The DOELthemselves have 22 dentified what the individuals did in the ESF design. They 23 identified what they contributed to the ESF design. And we 24 would like to understand from DOE why those individuals are-25 certified as not principal contributors.
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() 'l- Our second basis point.for stating that DOE failed-2' to consider certain key provisions critical to our 3 acceptance-of the DAA deals with neither the design nor the 4 -what DAA concerns as qualitatively or quantitatively. eleven .
4 5 of the'10 CPR 60 requirements.
6 When DOE went.back to check the adequacy of-the 7 design, .in the initial design they did not consider all 8 Part 60 requirements, but the idea was that if they had 9- considered all'of.the applicable' requirements would-the 10 design have chan'ged.- And in'doing that, they have still 11 missed eleven of the applicable requirements. They did not 12 look at those. And we have in our point papers identified 13 those requirements.
14 .The next point is that in their analysis DOE
()
.15 stated that 52.10 CFR 60 requirements would be applicable to 16- the exploratory shaft facility design. However, only'22 of 17 those were considered quantitatively, and the remaining 30 18 were said to have been considered qualitatively. And I will 19 go over the differences as they have stated in the DAA.
20 For the issues that were considered
-21 quantitatively, the design criteria corresponding to the 22 Part 60 requirements. The regulations that were looked at 23 'i n a qualitative way they did not do that analysis in a 24 vigorous way. Included in those 30 requirements would be 25 the performance confirmation program, retrievability, safety
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(_) 1- and such issues.
2 The next basis point that I have is that out of 3 the 22 requirements that they looked at vigorously in a 4 quantitative way that we have identified inadequacies in 5 those. For example, concerning the requirement for the 6 alternatives to major design features, the requirement 7 6021C.12(d). That requires DOE to consider alternatives to ,
l 8 major design features important to waste isolation. We find 9 that the analysis presented was limited and incomplete, and 10 I will explain what Imeanbfthat.
11 DOE limited its analysis of the~ alternatives to 12 five locations of the exploratory shaftrs that they had 13 considered. In fact they had some analyses available to 14 them in the past that they had done on other alternatives 15 like shaft versus ramp for example. As a matter of fact in 16 one of the previous reports, it considers several 17 alternatives as to what would be the best way to explore 18 this height.
19 Let us go over the conclusions of one of their 20 reports, considering several alternatives for exploration.
21 The clear recommendation is to design and construct the 16 22 foot diameter exploratory shaft and the 19 foot diameter.
23 They go on to say that other considerations require a less 24 expensive means of providing a second access. The 12 foot 25 diameter exploratory shaft and 6 foot diameter second shaft
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(,) 1 satisfies the requirement to improve safety. Because a ramp-2 can be constructed by a tunnel machine more quickly than a 3 shaft can be constructed, it may actually be possible to 4 reach the dense area ahead of the current schedule.
5 in the analysis that they presented to use on 6 alternatives, they have not discussed their previous work 7 that they had done in this area.
8 In the alternatives, they also did not consider 9 various methods of construction, for example drill and blast 10 versus mechanical exploratioli for shafts, and they did not 11 consider several alternatives for example for the test 12 layout that you could think of. We considered that the 13 analysis for consideration of major alternatives to major
{) 14 15 design features appears to be limited and incomplete.
Our next basis point for stating that they failed 16 to consider certain key reasons relates to the adequacy of 17 data. One step in the design acceptability analysis was to 18 check the adequacy of the data that went into the design.
19 Based on our review of what they have done, we have 20 concluded that the design acceptability analysis did not 21 thoroughly check the adequacy of the data used in the 22 exploratory shaft facility design.
23 Now obviously one step would be to find out what l'
24 data, how much data or what information went into the ESF 25 design. What DOE has done is basically relied on the I
r 1
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. t,g\ . 1 information provided in Section 8.4 of the SCP as a basis 2 for what data went into the ESF.
3 We find that that is not all of the data that went 4 .into the ESF design. We have identified in our point papers /
5 what additional information that we have identified that 6 went into the design and was not checked.
7 Another basis point for this issue is --
8 DR. STEINDLER: Excuse me.
9 MR. GUPTA: Yes.
10 DR. STEINDLER: Yofsaidwent into the design but 11 was not checked?
12 MR. GUPTA: That is correct.
13 DR. STEINDLER: So you know what data are checked 14 and what data are not checked?
15 MR. GUPTA: They have identified in the design 16 acceptability analysis what was checked.
17 DR. HINZE: What do you mean by checked?
18 MR. GUPTA: Well, you look at the adequacy of the
- j. 19 data, whether the data is reasonable or not.
20 DR. HINZE: Is this a verification of the quality 21 assurance of the existing data?
22 MR. GUPTA: Before they started the design l 23 acceptability analysis, we agreed that they would not go as 24 far as checking the verification of the qualification or the 25 quality of the data, because that would be asking for too
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.- ( 1 much at this time. They were verifying the adequacy of an 2 existing design. And we agreed that if the reasonableness 3 of the data is established that that would be satisfactory 4 at this time.
5 DR. HINZE: How do you establish the 6' reasonableness of data?
7 MR. GUPTA: Well, you look at the data. If there 8 is a range of information, then you see if'you have used it 9 in a conservative way or not. You see the source of where 10 the data came from, and were'there any problems identified 11 there. Wban we reviewed the fifty percent design, we were 12 out there in Las Vegas when the DOE consultants were 13 reviewing the fifty percent design, the Title I design.
14 Their own consultants had questioned the validity of some of 15 the information that was going into the design. And that 16 was one reason that we asked DOE to look into this and 17 verify the data that is going into the design is reasonable.
18 DR. POMERY: I must confess that I have problems 19 with that reasonableness question also. I also have 20 problems with the use of the term conservatively. I have 21 always been at sea in determining what a conservative use of 22 data is, and perhaps you could clarify that for me. One 23 conservative position would be that nothing is acceptable.
I 24 Of course, that is a very conservative position, and so we 25 all should go home. In the spectrum of conservative l
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t I positions, I presume that DOE itself would say that they 2 have a conservative position.
3 So from that standpoint when you say 4 conservatively, what does it mean to you?
5 MR. GUPTA: I cannot give a universal answer. Of 6 course, when you look at where the data is going and what 7 calculations, you can generally figure out if you use one 8 range of the barometer on one side versus the other that you 9 car, do a sensitivity analysis on most of the data to see 10 what kind of results you are'getting, and you can establish 11 in general whether you are using data in a conservative way 12 or not. In engineering design, that should not be a very l 13 difficult thing to do.
14 DR. SMITH: Do you have defined procedures as to
()
15 how you make that determination, or is it based on 16 experience? I mean some of us who have been in engineering 17 design know from looking at things over a period of time 18 that you can look at something and say that is not 19 reasonable, that that does not make any sense.
20 MR. GUPTA: Many times you can do that. l 1
21 DR. SMITil: I mean is that the way that you are 22 approaching this or do you have a little more sophisticated 23 way to say whether or not the data is conservative or it is 24 not conservative?
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() 1 DOE that they do more than what you have just stated. But 2 eventually there would have to be some studies to illustrate 3 and to show that data has been used in a conservative way, 4 especially when complex calculations are involved in 5 modeling when it is not apparent which side of the range of 6 parameter is conservative to use. You will have to do some 7 sensitivity analysis and calculations to show that indeed i
8 that would be the conservative way to go. !
9 DR. HINZE Let me go back if I might for a 10 moment.
11 Are you saying that there was a peer review 12 exterior to DOE that came up with reasonableness?
-13 MR. GUPTA: Yes.
14 DR. Il1NZE: Who were the people who did this 15 review?
16 MR. GUPTA: Somebody can correct me if I am wrong,
- 17. but they had a team of some fifty people that went into the 18 design acceptability analysis. And documents were 19 distributed to various experts in different areas, and they 20 looked at the adequacy of the information that was contained 21 in those documentu. So they have done extensive work on 22 this.
23 DR. IIINZE: This is independent review?
24 MR. GUPTA? That is what we hope for. That is 25 what we hope for.
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"2- of the people who made that review?
3 MR. GUPTA: That is in question at this time as I
~
4 mentioned.
'5 'DR.'HINZE: Do you have any sense that the-sc 6 deadline is the driver here?
7 MR.'GUPTA: I would not speculate on that.
.8 'DR. IIINZE Thank you.
9 DR. MOELLER ' Gene.
10 MR. VOILAND: I ren'd through that' review, and I 11 was reasonably impressed with the depth. At least from my 12 lack of knowledge about.it, it looked pretty good to me.
13 But the point is that you do not necessarily have to I think 14 havo every bit of information to.be able-to come to the 15 conclusion that the results of the Title I investigation are 16 correct. I mean all you.are looking for is it adequate, 17 does it support what was done. .And that is fundamentally 18 what I think they did. And there is a list of.five pages of 19 documents' reviewed and the names of the reviewers here.
20 There are a number of pages of a tabulation which indicate 21 what the report was and whether it was appropriate or not 22 and so on.
23 It seemed to me, again from my position with not 24 much knowledge on this, that they did a reasonably good job.
25 If they are completely independent, you will never get them O >>erite2e negertino (202) 628-4088 cergeretion
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7 2 DR.'MOELLER: Right. 'That is a constant problem.
3 MR. VOILAND: In addition to that, they are 3 1
-4 reviewing outside of their own field-of expertise. So in l 5 that respect I think that there is a certain independence'.
f -
6 DR. MOELLER: I would say that the staff.certainly.
(
7 'has called for an independent review, but I would'want to 8 question whether it is always beneficial for the people.
9; reviewing some report not to know anything about'the 10 subject.
11 MR. GUPTA: There are a few thingc in~ addition
-12 that bothered us besides the data adequacy in this area.- We
.13 knew that DOS had not gone into the details of verifying the 14 calculations, like they did not check the calculations. And 15 what we did in the process of review is we had a small' 16 appendix of some five pages that we thought;that we could 17 quickly check whether they have gone through an adequate 10 process of reviewing the design work.
19 And it so happened that in that particular review 20 that we found a number of errors, and that then gave us the 21 feeling. The other piece of information like the presence 22 of a fault identified in Chapter 1 of the SCP and in the 23' -review of the design that piece of information was never 241 accounted'for. So it did not give very good feelings in 25 certain areas.
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204 l_ _( 1 DR. MOELLER: We noted the errors that you 2 observed and those are disappointing.
3 MR. GUPTA: Let me just hasten to add there that
.4 those errors may not be significant by themselves and may 5 not change the design results at all. But it is just 6 whether a review has been done or not. That was the issue.
7 DH. MOELLER: They are indicators of performance.
6 MR. GUPTA: Yes.
9 10 11 12 13 14
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p 205 I ): 1 MR. GUPTA: (Continued) So much for acceptability l' 2 analysis. No, we have reviewed the SCP, and based on that, 1
3 there are some-additional questions about the acceptability 4 of the ESF design. And one relates to our continuing 5 concern on the test interference.
6 Based on the response to our previous objection on 7 test interference,.we have concluded that DOE has still not 8- demonstrated that the main test area layout and test 9 durations will permit all tests to be conducted for the time.
10 periodsrequiredwithoutintfrference.
11 Now, I think again I will say that DOE has given 12 us the details of.an excellent approach in this area, how to 13 calculate the zones of influence. It's just a matter of how 14 they have. implemented it and come up with the test' layout.
)( )
15 The concerns-that we have in this area are the locations of 16 several tests, including one of the very important tests, 17 the heater test, that may occupy significant space down 18 there is not identified. Some of the tests are located too 19 close to the shaft areas and those tests could be affected
~20 by operational interferences.
21 Some of the durations for tests, for example, for 22 canister scale heater and heated block and heated room test, 23 the durations are given as 30 months, 100 days and 36
-24 months. And based on that, the calculations have been made 25 for zones of influence. There's every possibility and we l () Ileritage Reporting (202) 628-4888 Corporation l
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(~ ,) . 1 hoped certainly that these tests would be run for a longer 1
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2 period of time than indicated in the SCP. If that is the l l 3 case, then the zones of influence could be larger than what i 4 DOE has provided us in the SCP.
5 In some cases, it has been indicated that the same 6 opace can be used for some of the tests; after one test is 7 over, the second test can be started, and you could run the 8 tests in the same space. And, again, if there are delays of ,
9 the initiation of the first test, that could affect the 10 second test. Theremaynotfeenoughdataatthelicense 11 application time based on that planning assumption.
12 At this time again, we considered the large 13 uncertainties in modeling and in data, and those 14 uncertainties have not been accounted for in calculations of 15 the zones of influences.
16 Another issue is whether all the space that DOE 17 has identified as suitable for tests will be suitable. When 18 you go down there, there might be areas where you have 19 ratios or unsuitable locations where you may not want to run 20 your tests. llave there been any contingencies allowed for 21 in these space requirements down there? Based on that, we 22 have concluded that there are some concerns that should be 23 pursued as SCP concerns.
24 Another area in which we have concerns on the 25 exploration facility design is whether there has been an
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() 1 option left for a full scale waste package testing. Now, we 1
2 lieard earlier from our colleagues in the waste package. area 1
3 that it would be a good idea to at least have the option i i
4 available for a waste package testing in the main test area.
5 Based on the current design of the exploration facility, you 6 cannot lower down a waste package.along with the cask that 7 would be required to be taken down. Again, the underground 8 test area is not designed from the point of view that there 9 could be any radiation in that. You will have to design it 10 differentlyforventilationfndallofthat. So any 11 provisions in the current exploration facility design and 12 layout have not been made for any possible waste package 13 testing.
('l 14 There are some other concerns with respect to ESF
%)
15 design criteria. For example, if it stated that DOE needs a 16 holding area of about 150 cubic meters in the exploration 17 facility at the bottom of the shaft, in case some water 18 comes in, they would be able to hold that much water in 19 there. That volume will require some 155 feet depth of the 20 12-foot diameter shaft with some porosity of the rock that 2 .1 would be in there. And they have only provided for 50 feet 22 of the depth below the exploration facility.
23 So there are a number of reasons why we consider 24 at this time there are concerns about the -- that DOE has 25 not demonstrated the acceptability of the exploration
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'f^%
l' V 1 facility design.
2 Now, individually, all these may not be big issues 3 and big concerns, but when you look at them in a collective
'4 way, you come to this conclusion that there is something 5 that needs to be fixed here.
6 I'll go over to the second bullet on the 7 demonstration of the proposed site characterization testing, 8 whether that would yield the necessary information for 9 iicense application. Based on the review of the SCP, we 10 have reached the conclusion Ihat SCP has not demonstrated 11 that the proposed site characterization testing program will 12 yield necessary information for licensing applications.
13 And I'll go over the reasons for that conclusion.
(] 14 There are analyses presented in the SCP as to how many bore 15 holes need to be on the side and how far they have to be 16 spaced and what should be the inclinations of those bore 17 holes. The analyses supporting the number of bore holes and 18 the location is based on geostatistical analyses. The 19 systematic drilling program that calls for 30 borehole pairs 20 in 10,000 feet spacing range. Now, based on our 21 geostatistical experts here, it is considered that 30 pairs 22 of boreholes may not be enough. Thirty is considered to be 23 the lowest possible number for acceptability.
24 Now, on one hand, the 30 is the lower range at 25 which you would consider borehole pairs to be acceptable for n
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209 1 ~ such a large area. . .There's a' tight clustering in the o 2 southern portion of the block where the boreholes are. spaced 3 very close to each other. And that may not give independent 4; borehole pairs.that could be counted in that number of 30.
.5 DR. SHEWMON: Why do you keep talking about 6 borehole pairs?
-7 MR. GUPTA: Well, that's how these 8 geostatisticians work on the availability and the 9 ^ representativeness of the entire area based on.how the
-10 boreholes are spaced one wit 6 relation to the other.
11 DR. SHEWMON: And do they then do a combination of' 12 one with all'the others to see how it correlates?
13 MR. .GUPTA: Yes, they do.
() 14 DRi SHEWMON: Okay. Thank you.
15 DR. SMITH: What kind of drilling are they going 16- to'do for these'boreholes??
17 MR. GUPTA: I'm coming to that.
18 The second 1ssue is with respect to the 19 inclination of these boreholes. In the CDSCP, DOE had 20 identified that since the fractures are predominantly
'21 vertical in many areas of che block, they would want to have 22 -some angled boreholes so you could get some information on 23 predominantly where it would fault.
24 In the SCP, basically all the boreholes are 25 vertical. And we find that the analyses supporting that
() Heritage Reporting (202) 628-4888 Corporation
~210 h1 decislon is' insufficient.
2 Now, ' coming to how the.boreholes will be drilled, 3 DOE has proposed:that all-the boreholes will be drilled dry-
'4 -without the use of-water with provisions for. continuous
- . 5 . coring. They will want to.take continuous cores out of 6 these' holes. This is an unproven technology, and DOE.is 7 planning _to check the feasibility of this technology in the 8 near future. I understand, based on some concerns, that 9' feasibility' study might be done at the test site in the near 10 future. '
11 DR. SMITH: -Is there some reason why they picked 12 . dry drilling then with continuous core removal, which were 13 unproven, technologically unproven?
14 MR. GUPTA: .There have.been concerns raised with 15 the use of' water. If you want to avoid water penetration
- 16. into the site.
17 DR. SMITH: You mean, no one has done dry drilling 18 before?
19 MR. GUPTA: For that depth with continuous coring.
20 Boring is no problem; the problem is with continuous coring.
21 DR. SMITH ' Okay.
l 22 DR. HINZE: What's the technology that they intend 23 to use or to test?
24 MR. PERSHEL: I understand it's a dual wall
-25 drilling where I understand basically they will be using a
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'211 l' tricone -- with an -- left in the center that's where the 2 ' core would remain and the air -- I don't'know exactly.
'3 MR. GUPTA:- It's easy to get chips out of these 4 holes with dry drilling. The problem is, if you want to get' 5- mechanical properties of the rock, you need cores. And to
-6 get cores out of a dry drilled hole in this' medium 7 especially'is unproven at this time for continuous coring.
8 And DOE's program for shaft' construction-isLbased on the 9' demonstration of -- well, they plan to drill some bore holes 10 in the vicinity of the shaft &Ibefore they start sinking the-11 shafts. And so the first step in doing that is to 12 demonstrate the feasibility of drilling these holes, go back 13 and drill those multipurpose boreholes using'that technology 14 and then start the. shaft demonstration.
15 Now, the question here is, what would be the 16 criterion used in determining the successes or failure of 17 this technology? Whether you get half the cores or one part 18 of the cores? Would that be considered an adequate basis'to 19 proceed with this technology, or what?
- 20. The next issue I have here is, as you have heard
-21 this morning from our geology folks, is regarding the extent
~ 22 of the proposed underground drifting. The SCP has not 23 demonstrated that the proposed underground drifting includes 24 . a sufficient amount of drifting to collect data for 25 supporting license applications. Since DOE plans to explore O u-1tese nee-une c-e-euee (202) 628-4888 l-
__m_____-m _ - _ _ . - _ _ _ _ _ _ . _ _ . . . _ _ _ _ _ _ _ _ . _ _ _ _ - - - . _ _ _ _ _ _ . _ _ _ _ . _ _ _ , _ _ - _ _ _ - _ ._._________-___.2- . . . . _ _
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l t;)% 1 basically the northern portion of the repository block, and i
2 the concern is how will that give you information for the I 1
1 3 remaining portion of the block. And there is an opinion l 4 that there are significant differences in' characteristics of 5 the rock in the north and the south.
6 I'll go over the third bullet point in the handout 7 with respect to the integration of the repository design.
8 The regulations require that DOE's exploration program i
9 should be designed taking into consideration how the 10 eventualrepositorywillbefullt. And the exploration 11 program should be integrated with the future repository 12 design.
13 We consider that the proposed site
- ] 14 characterization program in the area of design, DOE has not 15 demonstrated that integration has been adequately done at 16 this time. And I'll go over the basis points for that 17 conclusion.
18 The area that DOE is proposing to characterize, it 19 has not been demonstrated that that area will provide enough 20 suitable space for repository development. In.the SCP, DOE 21 h'as given a range of how much area they need for say, 70,000 22 metric tons emplacement down there. The range is from 1400 23 acres to 1800 or 1900 acres. Now, we calculated the area 24 within the perimeter boundary of the repository block that 25 is shown in the SCP, and that comes to about 1600 acres.
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( )- 1~ And based on:that, we have' concluded that DOE's' nots 2 exploring sufficiently the area that might be needed;for the !
-3' repository develo'pment.
4 There's also a concern that'if some1portionsLare 1 1
s 5 -not found suitable, and if DOE plans to go in the -- area
'6 for example, in'the; northeast or so,:whether those should be j 7 included in the characterization-program at this time, or-f, -81 later.
9 DR. CARTER: Let me ask you a question.
10' I thought in the D6'E overview that they had a-11 calculated that the area available was something over 2,000 12 -acres. underground?
- 13' MR. GUPTA: I'm just giving you the figures.
L14 DR. . CARTER: And that they would need 1300 or
- 15. 1400.
-16 MR. GUPTA: I'm giving you the numbers that we
.17 have made. They'are the numbers -- we actually measured the 18 area that was given in'the drawings in the SCP. Now, if 19 those are different, we would have no concern.
20 DR. CARTER: Well, it sounds'to me like they're-21 quite different. It seems to me their number's about 2100.
22 MR. GUPTA: The need for 1400 would be based on a 23- very high heat density. The range comes from like when you
- 24. will need 1400 versus 1800, if you go with say 40 kilowatt 25 per acre, you might need 1000 or 1900 acres. If you go with
( )- Heritage Reporting Corporation (202) 628-4880
214 L1 say 90' kilowatt per acre, then you might need 1400 acres.
2- 'So-'some decisions have'to be made as to how much area you'll
,3j actually really need.
4 Coming back to the how much area is.available, my.
S numbers, as...I just quoted,.come from our measuring of that 6 area. If they.are different than how much area is-available 7 we would have no concern.
O DR. CARTER: Sounds like to me that's something.
9 that needs'tefbe looked in to. It: sounds like-a reasonable 10 thing-to calculate the area Ivailable, and.it sounds'to me 11 like we've come up..with numbers that are appreciably 1
12' different. And I presume they're based on the same 13 assumptions.
14 MR. GUPTA: You have to also allow for some --'as 15 to, are you assuming that the entire area within the 16 perimeter boundary will be suitable for repository 17 development?
10 DR. SHEWMON: You're quoting the number that DOE 19 put out.
20 DR. CARTER: In the DOE overview, yes.
21 DR. SHEWMON: So you don't reproduce their number, 22 it seems.to me you might check how they got their number 23 when it's 50 percent difference.
24 MR. GUPTA: We are not arguing with DOE at this 25 time because our information is basically based on some of
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215 I] 1 the drawings and this would be a basis point for our 2 concern. If DOE can provide us with -- our concern would go 3 away. l l
4 DR. MOELLER: Excuse me. We have a comment from '
5 DOE?
6 Oh, I'm sorry, NRC wanted to comment. Okay.
7 MR. MCCONNELL: And maybe DOE's better, but 8 possibly what may be involved here is the 2,000 figure may 9 come from possible expansion areas.
10 MR. VOEGELE: MichfelVoegelefromDOE in Las 11 Vegas, Support - . The discrepancy is simply that
- is 12 quoting a number where heat's measured inside what we call 13 the conceptual perimeter drift boundary. Within a primary
(} 14 area, primary exploration area, there are several hundred 15 more acres of land which are not -- they are within the 16 areas which we have called expansion areas in some of the 17 figures in the SCP, but they are not inside of the 18 conceptual perimeter boundary so there is about 500 more 19 acres, between 400 and 500 more acres inside of that area 20 that we consider to be equally acceptable for repository 21 development.
22 DR. CARTER: But those are available and could be i 23 used?
24 MR. VOEGELE: Yes. The reason the repository, 25 there is a conceptual repository drift layout in the SCP,
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() 1 and it is laid out in a way to make the most efficient use 2 of drifting and minimize long lengths of drifts. There 3 would have to be a conceptually different repository layout 4 to efficiently use the 400 or 500 acres that Mr. Gupta has 5 excluded in his calculation.. But that's just simply a 6 question of laying out the repository a little bit 7 differently.
8 DR. MOELLER: Dr. Shewmon?
9 DR. SIIEWMON : No, I'm taken care of.
10 DR. MOELLER: Go al[ead, Cliff.
11 DR. SMITH: I want you to help me here a little 12 bit with something that's bothering me.
13 We're in an area where the rainfall is very --
14 going back to these boreholes -- very very small amount of
}
15 rainfall.
16 MR. GUPTA: Six inches.
17 DR. SMITH: And by the time you get town do the 18 depth of the repository, I don't know how much would be 19 there, but it would be very small. You could almost assume 20 that even if that amount of rainfall just went down, and you 21 provided the appropriate amount of drainage, you're not 22 going to have a problem. So why fracture this thing with 30 23 different boreholes around? I'm trying to understand 24 exactly what you hope to gain with that many holes stuck 25 into this thing?
1
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'l MR. GUPTA: Well, DOE needs to develop a three-2 dimensional model of the repository block.
3 DR. SMITH: To what extent do you bother the
'4 .
integrity of the overlying strata there?
5 MR. GUPTA: Well, there are some conflicting
! 6 requirements here. One is obviously you should be able~to 7 extrapolate the behavior of the repository for the post- j o .
8 closure' period. You need to model'the repository block and j 9 for that,.you need all the characteristics and properties of 10' 'all the' overlying strata abofe the repository.
I 11 DR. SMITH: Well, you're'not sure you can get them.
12 right anyhow, because you're not-going to get the core out 13 of there the exact'way it's laid in.
14 MR. GUPTA: I didn't say that. DOE's making an 15- -attempt to get those cores and test those.
16 -DR. SMITH: Okay. I'm just worried about 30 holes 17 that you're going to. drill -- not you -- and then you're not 18 going to be sure what it is you're pulling out of there.
19 And you're only talking about a small amount of rainfall 20~ anyhow. And even if it went straight down, it's not a major 21 problem.
22 DR. SMITH: Maybe there's something I'm missing 23- here.
24 DR. MOODY: Cliff, that's a very valid point. And 25 it certainly, in terms of the other sites at one time, it's l
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- ' l - just been a continuous argument. .And that is, in terms of 2 if we look specifically at Yucca Mountain, they don't have 3- the problems with excess water. But the other problem they.
4 LdoLhave is'that with all these potential drill holes and all 5 the fracturing and faulting. So what you're doing is you're 6- facilitating that potentially by the density of the'dril1~
7 holes ~. And the validation of why they want that one group 8 is'something that many people question.
9 DR..MOELLER: Dr. Gupta, we're going to have to 10 . move along, if you can wrap l't up.
'1 1 lRR. GUPTA: Okay.
12- All right. Just every quickly, two additional 13 basis points for having some questions on the validity of
.14 - the integration of the design with the site characterization 15 program, is that the current design calls for separation 16 between the ESF and the waste panels by a distance of 30 17 meters. And a separation distance between the two shafts 18 and the waste panels of 500 feet. And we considered that 19 the bases for these separations has not been sufficiently 20 justified.
21 Also, DOE has stated that they want to make a 22 selection on the waste emplacement mode, whether the waste 23 should be emplaced horizontally or vertically within'the 24 repository by September, 1989. And we consider that the 25 site information and the results of field demonstration at I-Heritage Reporting Corporation (202) 628-4888 l
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() I the repository horizon for the selection will not be 2 available until much after tnis date. So there is not 3 enough integration between the design decisions and the 4 exploration.
5 Another point in developing the strategy for 6 retrieval, DOE has not considered the requirements of 10 CFR 7 60.132(a) which is a retrieval issue requires that the 8 surface facilities be designed to allow safe handling of the 9 retrieved waste. And they have listed a bunch of other 10 regulations but have not con 64.dered this particular 11 regulation, as an example.
12 Coming to the fourth observation in the handout, 13 we consider that the details of the performance confirmation 14 testing program are insufficient for NRC Stafi evaluation.
'}
15 And our basis points for these would be, number one, SCP has 16 not addressed potential gaseous releases through natural 17 faults and fractures. And that's an issue that has been 10 previously discussed here.
19 Also, DOE has stated in references to the site 20 characterization plan that seals are not needed to meet the 21 performance objectives. However, we ;onsider that DOE has 22 not adequately demonstrated that seals will not be needed.
23 Also, we find that the SCP does not provide an 24 adequate site characterization or performance confirmation 25 program for seals and waste packages. There are no in situ
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1 testing planned and described in the SCP.
2 That concludes my presentation if there are any 3 questions.
4 DR. STEINDLER: Are there any questions on this 5 topic?
6 (No response.)
7 DR. STEINDLER: If not, thank you very much. Very 0 good.
9 10 11 12 13
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221 l'^l y.j 1 DR. STEINDLER:(Continued) We will take a three 2 minute break and then pick up the next and final topic on i
3 the agenda. l 4 (Whereupon, a recess was taken.)
5 DR. STEINDLER: In the absence of the Chairman, l 6 let us just proceed with a review of the technical point and 1
7 environmental monitoring of low level disposal sites. John.
8 MR. STAPMER: Yes, thank you very much. I am 9 John Starmer, the Chief of the Technical Branch within the 10 Division of Low Level Waste flanagement and Decommissioning.
11 I am pleased to be here this afternoon to discuss our final 12 position paper on environmental monitoring. As you know, we 13 briefed you last year on the draft position paper, and we 14 found that your comments and your constructive criticism was 15 very useful for my staff to revise the paper.
16 One of the main items that you asked us to 17 reevaluate was what the purpose of the environmental L 10 monitoring position was, whether it was a general policy 19 guidance document or detailed technical guidance on 20 environmental monitoring.
L 21 After careful review, we have decided that it 22 should be provided as general policy guidance.
23- Dr. Ed Shum who is up at the podium has significantly
[.
24 revised the position paper, and he will discuss this issue 25- as well as others this afternoon. As an introduction, I
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h,. 1 Dr. Shum is a senior environmental chemist in the siting 2 section within my branch. Professionally his training is as 3 a nuclear chemist and health physicist.
4 lie is a-task force member of the NCRP Scientific 5 Committee 64 on radionuclides in the environment. Before 6 joining my staff, he job function at the AEC/NRC was serving 7 as an environmental project manager for a number of the 8 major fuel cycle. facilities. And I am very pleased that 9 Dr. Shum has joined my staff. And he will give the 10 presentation, and I will add'whatever needs to be. Thank 11 you. !
12 DR. SilUM: Good afternoon, Mr. Chairman, and 13 members of the ACNW, and the audience. The briefing this afternoon is on the final DPT. First I would like to
()_14 15 refresh your memory on the background information that is on' 16 your viewgraph, page two. On November 5, 1907, we issued a 17 draft BPT and announced it in the Federal Register with a 18 request for public comments. As a result, there are about 19 fourteen organizations and agencies that provided us 20 comments on the BPT. l 21 And subsequently on July 22, 1988, we briefed the 22 ACNW on this subject and reviewed the comments from the !
23 transcript. And your next viewgraph number three is a list i 24 of the government agencies, national labs, and licensees, 25 and also ACNW provided us comments. And your next viewgraph I
fleritage Reporting Corporation (202) 628-4888
w l' j L 223 b) Il summarizes 1the major comments on-the draft BPT and.the 2 staff's analysis. You have a copy of the staff's analysis.
3 And on the-final BPT, we looked at all of these comments and 4 tried to resolve all of them.
- 5. Now. item one the comment is that the intent of the 6- .BPT should be stated clearly. In that draft BPT, we say 7 this is'non-prescriptive. But as pointed out by the 1'
L 8 commenter, seme part of.it is rather prescriptive. And
.9 there is a-comment on item two that the BPT should provide 10 .more specific guidance.
Somfcommenterwouldliketohave 11 it more prescriptive. And on the third' item, the objective-l 12 of the monitoring is' unclear. Now this is mostly from 13 health physics, and the health physicists come in.
14 Since some of the measurements at the BPT in our
')
15 monitoring program as required in our regulations are not E 16 related to the measurement of radioactivity in the 17 environment, they cover the site characterization which is 18 not radiological measurement at all, but it is required in 19 our regulation. So they feel that the BPT does not have the 20 flavor that the health physicist perceived that it ought to 21 be ..
22 So the-fourth is the one year pre-operational
-23 monitoring should be extended. That is our regulation. In 24 our revised BPT, we did encourage the applicant to extend 25 some of those measurements beyond the one year period. And
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() 1 the fifth item le that the critical pathway should be 2 considered. Those are really a solid health physics 3 principle incorporated particularly in the operational and 4 environmental monitoring program.
5 DR. CARTER: Excuse me.
6 DR. SIIUM: Yes, sir.
7 DR. CARTER: You are opening a few more. I am 8 just being a little facetious. By the way, I would like to 9 say that I am pleased to be in the room with Dr. Shum. I 10 happen to be the Chairman of' Scientific Committee 64, so 11 welcome to the group.
12 I think that there are two or three things that I 13 noticod in going through. I think that one was the rm 14 definitions of the monitoring periods, the pre-monitoring, (s) 15 the monitoring during operation, and the post-menitoring. I 16 think that there is an inconsistency in the definition, and 17 I will be glad to point that out.
18 DR. SHUM: You mean that it is in the regulation, 19 sir?
20 DR. CARTER: No. The way that you have got them 21 defined here, if you look at page five in your document, it 22 describes the beginning and ending of each of those periods, 23 at the top of the page there in Item 2.2.
24 DR. SHUM: Okay.
25 DR. CARTER: And the question that I had when I
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(_ 1 looked at that part is of course why not start the 2 operational period when waste is first received. And 3; actually you have it starting when construction starts which 4 i presume would be a considerable period of time'before the 5 waste is received.
6 And then if you look at page seven, you see at the 7- bottom of the page in Item 3.1 under program objectives it 8 says, "The primary purpose of the pre-operational program is 9 to characterize the environment before any waste handling 10 operations are begun." Andfctuallyyouhavestarted 11 something else when construction started. So I would say 12 that they are a little bit internally inconsistent.
13 DR. SHUM: Okay. The construction base in our t' 14 regulation under the operational program, if you look at I
}
15 believe it is page four, you see that that is defined during-16 the land disposal facility site construction and operation.
17 So they tie in all of this as to the operational monitoring 18 program. That is in the regulation.
19 DR. CARTER: Well, I do not have any problem with 20 that. I just have a problem in reading them. They look 21 like they are inconsistent. I think that there a few words 22 in there that would explain that perhaps.
23 MR. STARMER: I think that you have a good point.
24 I am telling you that we have really struggled on this.
25 Because from a health physics point of view, and I think
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-n Q 1 that even if you were wearing your hat of EPA and talking 2 strictly about monitoring without radionuclides, that you 3 would think of it in one way. And we have a regulation 4 which has constructs in it which essentially says that you 5 have to do it a different way because we are talking about 6 site characterization at the same time.
7 And as a result of this, we thought that the 8 reason to go for a guidance document rather than specificity 9 was to provide the clarification. And you are essentially 10 saying that we need to provide some more clarification.
11 DR. SHUM: We are stuck with this site 12 characterization. That is why a lot of the measurement that 13 is not really in the sense of a health physicist as I am in 14 looking at it, those are not in the health physics term the 15 definition of a monitoring program. It is a measurement of l 16 radioactivity in the environment. If it is not covering 17 site characterization, we have a hard time of separating 18 these two.
19 At the nuclear power plant, this is four pages of 20 a reg guide that is on environmental monitoring. It is all 21 general guidance. In this reg guide, they separate the site 22 characterization. That is the difficult part of it. We 23 share the feeling of Dr. Steindler on the last transcript.
I 24 It seems that we are measuring the whole wide world. I do !
25 not like that. But in our Part 61.2, we got stuck on the
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'227-11- definition. They define monitoring-in.our regulation in
.2 61.2 as the observing and measurement of parameters for the 3 ' site performance and characteristics. So we got stuck with 4' it, and we have to include it.
S' We have' considered to separate it. .And then on
- 6' the pre-operational phase, if it is just limited to the-7' background radiological characterization. It~1s as; simple' 8 as the nuclear power plant. But we feel that we'have no 9 choice in this.
10 DR. SHEWMON: Are y'ou saying that your regulations 11 .say that you have to characterize this in the same way that 12 you would on a nuclear power plant site?
13- DR. SHUM - We did not say that. But in the regulation it says at the time that a license application is
( { 14
'15 submitted that the' applicant shall have conducted a 16 pre-operational monitoring program to provide basic.
17 environmental data on the disposal site characteristics.
118 ~ That is.not health physics measurements. That is the site 19 selection process. We are stuck.
20 DR. SilEWMON : You said that three times. Do not 21 say it again, please. It seems to me that if you think that 22 what you are doing is nonsense and unnecessary that you
- 23. might try to see if you could get the modifications. If 24 they are relevant to your kind of site, you feel that you 25- are still bound by them?
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(_/ 1 MR. STARMER: It is not nonsense. The problem is 2 that we are talking about a geologic setting for a. disposal 3 site. And when we put together the regulation a few years l 1
4 ago before I joined the program but that does not make any
.5 difference, we put in areas talking about monitoring of G collecting both radiological as well as site 7 characterization type of monitoring data that would be 8 useful for characterizing the site. Like groundwater flow, 9 we are interested in for both reasons, and others would be 10 for looking at the site characterization. s 11 Now where we are is when a person who has been 12 raised in the atomic energy /NRC/ DOE arena gets involved with 13 coming up with a license application, we are afraid that he 14 will wear a mind set of worrying about only the
()
15 radionuclides even though the regulation is broader than 16 that. We thought that we needed a guidance document.
17 DR. CARTER: The point that I was making is write 18 it within the document. And it would appear to me on pages 19 seven and nine that the wording is internally inconsistent 20 and needs a little polishing.
21 DR. SilUM: Okay.
i 22 DR. CARTER: The other thing, I would agree on the I. 23 prescriptiveness, and again that is on page nine primarily.
l 24 But then it is compounded if you will by throwing in 25 Appendix A which is extremely prescriptive. I mean this is
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f( h 1 prescriptive all the way.
! 12 DR. SHUM:- It needs an explanation. I believe
- 3. this is Dr. Carter that~I am talking with. J1
'4 DR. CARTER: Yes.
I' 5 DR'.'SHUM: Yes, I~ remember you. We are looking 16 into the comment, like I.say Dr. Smith asked how many people 7.- thinhLthat they need more prescriptive _ guidance. Almost all 1
8 of the commenters would like more specific guidance. But 9 really we are limited. The ICRP-43 for the design of an-10 environmentalmonitoringprofram,onlygeneralguidance:is 11 given because it is really site specific.
412- 'Now with all of these requests for.some kind of a
'13 minimum tech spec or a minimum requirement. We do not see 14 that if at the nuclear power plant that if they put all of 15 this.down in four pages of things. We try.to.have an 16' example.
17- MR. STARMER: ~We would be more than willing to say
- 18 let's take out the appendix.
L.
19 DR. SHUM: If you want us to delete it, fine, you
- 20. know. But the applicant, the licensee, would like to have 21 this, so.that we will provide the best we could. We are 22 just between what is prescriptive and what is not.
23 DR. CARTER: I would suggest that you take it out, 24' and you certainly could modify a few of the words. You can 25 cover it in a reference. You can say if you want more i
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.m V 1 detail, you can say the reference section. That comes out 2 of a DOE report as I recall.
3 DR. SHUM: Okay, fine.
4 DR. CARTER: Another one that I had, and I guess 5 that it supports this fifth one that you had on the critical 6 pathways. It would appear to me that you have not 7 explicitly gone into the fact that you are going to need-to 8 environmental modeling and so forth. Certainly there is an 9 implication in here, but I do not think that it is really 10 discussed in the manner that'it deserves.
Because most of 11 the performance assessment of this is going to be done with 12 modeling.
13 DR. SHUM: Right, absolutely.
14 DR. CARTER: I think that it is a little light on
(}
15 that aspect.
16 DR. SHUM: Yes. We tried not to touch on that.
17 We call it a can of worms. On the environmental modeling on 18 the low level waste burial site, we have got a problem on 19 the source term, and we do not want to get into all of the 20 complexities of the pathway analysis. And we do have 21 problems with coming up with a source term. And it is 22 affecting the pathway. It is affected by the ongoing 23 standard. We have discussed this at great length with 24 Dr. Moeller. We have several standards floating around.
25 As you know, currently you are aware of the EPA's lieritage Reporting Corporation (202) 628-4888
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- :1 Clean; Air Act standard which is from .03 to 10 millirem.
2 .Let me tell you that the pathway analysis is supposed to be 3 applicable to the low level' waste burial site.
And the 4 pathway analysis, normally we would take a conservative l I
5- ' approach on.the low level waste-burial site, because we'do j 7 6 Lnot know the' source term and all of this. j
^ 7 Now what is the critical pathway. We.try not to:
.8 get into that. 'That depends on the standard. We use a 9 conservative approach. I cannot-imagine in the low: level 10' waste burial site, thereisfotmuchradioactivitythatis 11 going to be released if it'is in'a container. It is not 12- like a-fuel cycle facility where we are handling tons of 13 uraniumL in a' chemical form and have. chemical processes. We p '14 canl survive that. The critical pathway.really to me is not-15 very significant.. It will come to'the' background I-16 measurement on the overall environmental monitoring program.
17 MR. STARMER: We are doing some work that 18- thc. Shum is also project manager.on at Sandia National 19 Laboratories on performance assessment-in which we are 20 worrying about codes and working in the performance
- 21 assessment area.
22 But again, Dr. Carter, you have certainly 23 identified an area that we have certainly tried to address.
24 maybe not as well as you would have liked, but we have 4
25 struggled with it because trying to provide specificity in
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) I this area I think would cause problems and could drive it in 2 the wrong direction.
3 DR. SHUM: My concern is that on the pathway, l
4 imagine the pathway, the critical pathway, it is changing as J l
5 a function of time depending on what type of waste is input 6 to it, and the alpha release air pathway may be critical.
7 There is cesium cobalt in the burial trench. It could be 8 direct gamma radiation, the ingestion pathway. So we try 9 not to get too much into that to provide specificity. We 10 only mention that inthehumfnsitethatthepathwaymaynot 11 be the same. But a low level waste burial site, an 12 incinerator, the air pathway is the most iniportant I feel.
13 Other than that, I cannot imagine low level waste 14 as tough as a fuel cycle facility, but it depends on the
(')1 t
15 standard. And we cannot why this standard. We run the NRC 16 test, and we pop in the NCRP compliance code. The uranium 17 mill is about that, it is about that. That will complicate 18 the pathway analysis. How critical depends on the standard 19 that is coming out.
20 DR. CARTER: The other thing about this of course 21 is that an awful lot of what you are going to be measuring 22 around a low level site in my opinion are going to be very, 23 very low numbers.
1 24 DR. SHUM: I agree with you.
25 DR. CARTER: So you are going to have be in the I
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() 1 modeling.
2 DR. SHUM: The environmental monitoring program.
3 But it was set at .03. I do not think that the .03 will 4 come out anyway. Even at 3, we are in trouble anyway. And 5 at 10, we are in trouble. We did calculate .03 for an 6 uncontaminated site for NRC. We popped in the code, and it 7 exceeds three times the .03. For an forty acre site, it is 8 uncontaminated land. I do not imagine the .03, but you have 9 other standards there too. Dr. Carter, there is the EPA 10 Clean Water Act. Youwillrfmemberthefourmilliremorgan 11 dose. Ilowever small, it is a critical pathway.
12 DR. CARTER: Well, we ought to mention though for 13 the record that what Dr. Shum is talking about on the EPA
' 14 now,are things that they have proposed under the Clean Air 15 Act. And they basically would be quite low, the numbers 16 that they are proposing. And it is indeed a proposal, and 17 it is out for comment publicly at the moment.
18 DR. STEINDLER: Let me ask a peripheral question, 19 and then Gene ought to get a chance. If you take the five 20 references in Section 3 and you never issue this document, 21 is the potential applicant in any worse shape because you 22 have not issued your document?
23 DR. SHUM: I am trying to make the.t statement that I
24 the staff feels that the EPT although it provides guidance 25 that it does not going into the insight of what the NRC
() lieritage Reporting Corporation (202) 628-4888
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-1 1 ' staff wants in the acceptance of that. We feel that the BPT
, 2; with the current literature references, for example the site 3' characterization is a two inches thick-document, and they 4 call it non-prescriptive still, because of the site 5 select' ion process. And we feel that the applicant or state 6 should have ample guidance in the design of an environmental L
7 monitoring program.
8 DR.-STEINDLER: That is not my question, my 1 question is what happens if you never issued this document?
10 MR. STARMER: Youfalsedagoingpoint, and we 11 have talked about it, Dr. Steindler. And I can understand 12 on one hand, and we talked about it even after your 13 recommendation to go forward with doing something, of saying 14 let's scrub it and not go forward with it at all. But the 15 problem that I am looking at is the manager of the site, an 16 authority, a state, the Texas state authority or something,.
17 and they' basically said the only thing that I need to get at 18 the beginning is some monitor people who really truthfully 19 know radionuclides, and I am going to bring them in because !
20 that is what I want to have them do.
21 And in a way as you certainly said the last time 22 that we discussed this that people who are experts in 23 environmental monitoring certainly know how to do .
24 environmental monitoring. But who do you bring in to do 25 this, do you bring in people to worry about seismic, do you O nerite2e Reverue2 cergereuoe (202) 628-4888 l
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, '235-L -b l' -endlup worrying about seismic problems at a low level' waste 4
2 site.in environmental' monitoring. I L3 .It was mentioned in the regulation giving a little L 4' bit ofLguidance, a little bit, and that is what I come back,
'5 : to. AndEI appreciate'the comments.and maybe what you.are.
6 going to' recommend after we get through with this is maybe 7; we just go and terminate and call it: success or failure'and
'8 move on.-
9 But I can see that a person who is not a 10 ~ specialistintheareamaynfedthistype'ofanoverall
.11 guidance' to get an idea of saying these are the documents, 12 these.are the typesoof things that we must take into-13 consideration,rthat this is the type of staff or consulting.
'14 firm that I am going'to have to bring in, rather than narrowing it.down'and saying hey, I.know how it has been'in
.15 . .
16 the past and we do it this'way. llave I helped you with it 17 at all?
10 DR. STEINDLER: That is fine. So what you are L
19 saying, let me rephrase it,.you are saying that if this 20 document were not in place that whoever this chap is that we 21- are talking about is going to have to dig out these five 22 -plus six other documents a picture as to what he ought to do 23 as he begins to worry about the Texas Panhandle or the low 24' level waste disposal area.
l 25 MR. STARMER: Yes. And some could certainly do it f
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(,) 1 without any question, and others I think may have some 2 difficulty with this.
3 DR. SMITH: One of the criticisms too has always 4 been of NRC in many aspects is that you had to go to ten to 5 fifteen different documents to get what you needed in order 6 to know how to design it. It would be nice to have it in 7 one place whether it is prescriptive or what in what it is 8 that you are looking for.
9 DR. .SHUM: So we are trying to consolidate. If 10 you want more specific guidan'ce on the design, those still 11 are not prescriptive. We are stuck that we can only give 12 general guidance on the principles, on the objectives, and 13 on what areas need to be covered. If you want it more 14 specific, if you refer to those DOE documents, they are not
- ]
15 going to put out another document two inches thick on the 16 site characterization. That is from DOE. That is a lot of 17 information there. And not only are we trying not to be 18 specific on the site characterization, because most of the i
19 site that is selected is probably contested by the public.
20 We do not want to defend =,omething that we have not seen 21 before.
22 ,
23 24 ,
1 25 IIeritage Reporting Corporation (202) 628-4888
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1- DR. MOELLER: Since I'm following up 2 Dr. Steindler's citing of the five references, I looked at 3 the five references and, you know, they're good. But then I 4 said to myself: What have I used? You know. And, of 5 course, I'm behind the times a little bit, but I brought 6 along the three references that to me are sort of the 7 classics in the field.
8 One is EPA's Environmental Radioactivity ,
1 i- 9 Surveillance Guide. I'm sure you are familiar with it. It i 10 is very thin. And, you know' it's old. It's dated probably 11 20 years ago, 1972. But it is still not all that bad. l l
12 Well, then the second thing -- and this is the one '
13 I really use is DOE's Guide for Environmental Radiological
(} 14 Surveillance at U.S. DOE Installations. Now, it's 1981.
15 So, it is only eight years old. And it, to my way of 16 thinking, is one of the very best reports around. It's not 17 excluelvely for a low level waste site, but it is a terrific 18 report.
19 And then one I have always loved for years because 20 I view the author, the senior author, as the "Mr.
21 Environmental Surveillance," is the Use of Reconnaissance 22 Level Information for En'ironmental Assessment by Richard 23 Foster. And it's NUREG CR-0990. Richard did thi s in -- ,
24 it's only 10 years old.
l 25 MR. SilUM: Those are terrific reports. If you ;
() lieritage deporting Corporation (202) 628-4888 l !
- . 1 238 1- Slook at.the. current DOE report at 1989, they are just' coming' 2 'out.
- I give respect to all the old -- they are~ talking
'3 Lthen,_ start'thenion 1982, a_ lot of this. That's.why-I-1 4 referencerit there. And those'are'related to environmental l I
p 5 monitoring on low level waste barrier site. We look at your!
~6 transcript before. .There are some ANSI standard, whatever.
7 Of course, we have all this floating around. But this is 8 the most current publication. . And the author like 9 Dr. Danman have~been working on that since 1982 and we have 10 a whole group of people therf. And then now, I know, has 11 consolidated all this into two big. documents. A lot of the 12 EPA literature references including on guidance, analysis,
- 13 they are all in that current 1989 DOE document. I didn't
-14'
} bring a copy of it, but I review all this that what you 15- said. But'I feel that those are the most current documents.
.16 : .They are consolidated, a lot of the past work. You want us 17 - to reference a particular one, we will be happy to put it 18 in.
19 DR. MOELLER: One othrr one is the John Till and 20 others, the radiological assessment NUREG.
21 Dick, go ahead.
22 DR. FOSTER: When I read through the document, my 23 general reaction was: Gee, this is laying out the right !
24 kind of guidance and about the right level of sophistication 25 and it's providing the rationale. And it is telling us that Heritage Reporting Corporation (202) 628-4888 i.
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1 for specific sites.~you need to develop the specific program 2- .according to the local characteristics.
3 And with some few, I'll say relatively modest -
1 4 comments, things were going pretty good.until I.got to the o 1
- 5. appendix' , Then came all the prescriptive stuff. J 6 MR. SHUM: Since this-is a. consensus, when I
'7 . review all~-- yes, .I agree with the' consensus.
8 (Simultaneous conversation.)
- 9 MR. STARMER: It will be deleted.
10- MR. SHUM: That wil'1 be fine.
L At first we:tried 11 to make it non-prescriptive. I remember it was asked in the 12 last transcript: Did any licensee that asked-that you ought-13 not to be that prescriptive? None. So, I' thought.that is
'14 in between. We give an example.- We look at your
'15 consideration and you want it to be something like a tech 16 spec on minimum requirement in your last. comment. That is 17 why we compromise on that and said, put an example there.
18 Now, I have a feeling if I put an example there, if I'said 19 NRC endorsed it,'okay? You guys don't want it. Take it 20 off.
21 MR. STARMER: For the record, we were wrong. j 22' DR. MOELLER: Richard, do you have others?
23 DR. FOSTER: If they are going to remove it --
24 MR. SIIUM: Yes.
25 DR. POSTER: I was going to say, you people in 'the j Heritage Reporting Corporation i (202) 628-4888
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() 1 -regulation business know better than I that if you put that 2 . appendix in as it is, an applicant is going to feed that 3 directly back to you without ever going to his health 4 physics to say: This is what we are going to put in our !
S tech specs.
6 MR, SIIUM: Really, I was inferenced by that a 7 minimum requirement, how it looked like, you see, that 8 Dr. Moeller' comment, I' remember clearly is that we look at 9 nuclear power plant. You have tech spec now. All this.
10 Tables and all this. Ilowcofeyouguysdon'tput in there?
11 Okay?
12 DR. POSTER: I've got some editorial kind of 13 things.
14 DR. MOELLER: Maybe we can share those'just by b)
15 giving him the copy. Gene is really next. Go ahead, Gene.
16 MR. VOILAND: Thank you. 1 guess that a couple of 17 things have happened here. One is that they tightened up on 18 the kinds of wastes that you can put into low level :
19 facilities. Anything that is reasonably high level, if I 20 could use that term, is concreted or converted to a solid.
21 A lot of the trash is simply slightly contaminated. But 22 fundamentally, there is the source term that you expect out 23 of the plant, out of that facility is pretty small.
24 The other thing is that we have operated Beatty, 25 Barnwell and the Richland site for a number of years. What
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(_j 1 Js their experience? What does their monitoring program 2 show? And I will bet it shows a bunch of zeros.
3 MR. SHUM: I agree with you. And as I say, that 4 critical path might depend on how you -- we have a ccuple of 5 DOE prototypes.- How do they develop a source term? Very 6 conservative. Assume all the drum surface contamination up' I 7 to NRC limit and released in a certain time frame and still 8 insignificant amount. Insignificant, I mean is well below 9 25 millirem. Not three. Okay? If three, we have got to 10 mesh with those. That's why'we've got soir.e part in there i
11 that is absolutely important. We concur with your last 12 comment on October. All these things that are floating 13 around. It does affect the environmental monitoring Qv 14 program, the scope, the level. And if it is not brought to 15 whatever the highest attention, that we could have some 16 problem. That there's a lot of cost that add to the 17 implementation of it.
18 MR. VOILAND: Well, I'm only saying that that's 19 one point in reality that exists out there the performance 20 of existing facilities.
21 The second thing, it seems to me, that there is
- 22. again the usual tightening up and becoming more 23 conservative. We talk about a zone of 10 kilometers, I
-24 think, here, which is six miles that you have to be 25 concerned in monitoring which seems just incredible for this O iieritese nevertino cerneretien (202) 628-4888 .
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()L .1 kind 1of an operation. We.are also talking about'500 years 2 in here when the regulation, itself, is lo'oking at 100 or _
3 300.
4 MR. STARMER: Well,'let me back off. On tne 5 regulation, the regulation doesn't when it talks ~about 6 accessible environment does not specify a time frame for the 7 25, 75,.25 millirem. I am again, you know,.that is 8 something that we didn't do and I wish we had.
9 Secondly'is that we have A, B, and C waste and the 10 C waste, we'reessentiallyafaintalkingabout it or at.
11 least human intrusion for 500 years so.that the sea waste as.
- 12. far as the emplacement is for a period up to 500 years when
~
13 it would be back to background level.
'14 MR. VOILAND: But I don't know that you're 15 worrying about sea waste for air. I think you would be 16 dealing with water in that. instance.
17 MR. STARMER: Yes.
38 MR. VOILAND: And that's what you're monitoring 19 out at 10 kilometers for, not the water, but the air.
20 MR. SHUM: The DOE document you are talking about, 21 I did not spell out the 10 kilometer. I did not see the 10 22 kilometer. What document?
23 MR. VOILAND: I read about it in here someplace, I 24 think.
25 MR. S!!UM: Now, it may be in the appendix. The f( ) Heritage Reporting Corporation (202) 628-4888
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(_) 1 DOE called for if there iv :ome background or monitoring, 2 the people that have wells there, if they allow them, you 3 know, to do some monitoring, that's up to a distance. Since 4 we are deleting all this, okay, so that the issue is gone.
5 DR. MOELLER: Jack Parry, you had a comment.
6' DR. PARRY: I just want to remind the committee 7 and sub that I don't believe this will be used by any 8 licensee. My expectation, and I think this is right, John, 9 all people who make use of this will do so voluntarily under 10 the agreement state program.And, so, it is not quite -- I 11 don't disagree with anything that's been said, really, but I 12 just wanted to mention that point.
13 DR. MOELLER: But on that point, the states have
,C) 14 clearly asked for help.
V 15 Okay. Mel Carter?
16 DR. CARTER: Thank you. The other major comment I 17 had about it: I would suggest you take a little bit closer 18 look at sort of two things in there. One is the requirement 19 for all the wet chemistry. And by wet chemistry, I am 20 talking about doing things like uranium, probably Carbon 14 21 in a liquid form, Iodine 129 and things of that sort. The 22 question is why do you need those. You may want to do 23 screening with things like tritium and gamma scans and that 24 sort of thing and then look for specifics if you find 25 something. But it would appear to me that there is a fairly 1
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244 1 heavy responsibility on the people that would use this to do 2 considerable amount of wet chemistry. The question is 3 whether it is-necessary or not.
4 For example, related to that is the fact that this 5 thing calls for gross alpha, gross beta and gross gamma. I 6 don't really think you need all of that. Gross alpha, in my 7 opinion, has never been very successful. And gross alpha 8 may be a little more useful. And, certainly, a gamma scan 9 is very good.
10 MR. SHUM: Well, that has a whole spectrum of 11 radio nuclide'in the low level waste burial site and the 12 gross alpha, we use it as, normally, as a screening 13 technique, some measurement that is specific. It may be in 14 the appendix, Dr. Carter, that you are looking at, the DOE 15 document. They would like to do some lodine and all of 16 this.
17 DR. CARTER: Some of them are in that appendix, 18 but also some of them are in text. There are fewer of them 19 in the text, but I think if you read it, I think Dr. Foster 20 got the same impression, there is a fair amount of wet 21 chemistry implied.
22 MR. SHUM: But we say that in the document is that 23 unless it exceed the action level for the screening 24 technique then we will require isotopic analysis. We never 25 want a licensee to do isotopic analysis if they can 11eritage Reporting Corporation (202) 628-4888
l 245 l 1
() 'l demonstrate compliance. We don't want them to spend a dime, )
2 you know, to do all this if they with reasonable assurance j i
3 if they can demonstrate compliance.
4 So, in that document, we only say that this is a 5 screening technique. To me, I would imagine that the 6 environmental monitoring program is measuring' background, 7 probably if they don't operate in a terrible manner.
8 DR. CARTER: Well, all I'm suggesting I guess,is 9 as you look at it, because it would appear to me if you were 10 goingtohavethemdogrossflpha, beta, gamma and that is 11 going to trigger all the rest, now the question is how much 12 is triggered? Should it trigger specific things like 13 looking for tritium, looking for Cobalt 60? Looking for 14 this, that and the other. And does it imply that you have 15 got to do the whole gamut of them?
16 My impression is that it implies that you should I
17 do all of this.
18 MR. SIIUM: We will straighten that out on the 19 action level. The action level, I only learned briefly that 20 exceeding certain screening level, whatever it is, you are 21 going to do maybe isotopic analysis. That was in the 22 statement at the back there and we would rather require the 23 use of a screening technique before we use isotopic analysis 24 unless that is also affected by what the standard that is 25 coming out would be. Okay? We cannot assume conservatism.
() lieritage Reporting Corporation (202) 628-4888
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.246 nl ~ If. I say all gross beta you measure, assuming that it is all 2 strontium 90,'that will probably give the highest impact.
3 If:they-can say why'with the standard, we are not
, 4- going to.ask for isotopic' analysis.
5 DR. MOELLER: Well, I think we have to wrap this
'6 .part up. As I have heard the discussion and trying to-
- 7. summarize it, you will delete the appendix.
8 I believe personally that the text, itself, if you 9 set-it aside for a couple of weeks and then come back to it 10 that you will find.it can be' shortened and sharpened up.
11 There is repetition, but if you.just have a document of the 12 . text only and sharpen it up and come back to us in a couple 13' of months, we will-be glad to go over it in detail.
h
-14 ,And I think, Richard Foster, if you will give them
{]g' 15 your. copy and I may give you mine with just some notes in 16 it, I would urge that you go bend over backwards to be as 17 precise and highly professional as possible to say, we'll 18 count gross alpha -- I've forgot how-you said'It. But I 19 wrote down slang. You know, there is a proper scientific 20 way of saying it. So, say it that way.
21 1 think with that then -- yes? Don Orth.
22 I'm sorry. Don wanted to comment.
23 DR. ORTH: I didn't really want to take an 24 opposition position to-all of this talk about not being too 25 prescriptive, but.I think that maybe somewhere in there in Heritage Reporting Corporation (202) 628-4888
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I the objectives section up front, it could be worthwhile to 2 emphasize for the states, the state official, as well as for 3 the applicant exactly why some of the pre-operational 4 testing is to be done.
5 And let me give a couple of examples. Downstream 6 from the place that I work, we found fair amounts of mercury 7 in the water and we found it in water-leaving our site.
8 very simple: We must be contaminating it.
9 tio . We draw water out of the river and then we 10 run it through some equipment'and run it back to the river.
11 The mercury came from the plant upstream. But on the 12 initial go-around that you find mercury in water leaving us, L3 we got blamed. !
[} 14 15 Cesium. Cesium has the property of being virtually irreversibly retained on certain clay compounds.
16 So, somebody dredging the river downstream finds cesium.
17 Well, fine. Of course, we all got blamed for this, too,
~ 18 until you go upstream and dredge equivalent sites and we 19 find out it's fall-out cesium, 20 I could cite lead, mercury, various other things, 21 plutonium at low levels from fall-out plutonium. So, it is 22 well up front somewhere to point out to both the state, 23 because they are the ones that will get blamed if later on 24 they license the site and they get blamed for things. There 25 is a very reason for at least -- not necessarily being
() lieritage' Reporting (202) 628-4888 Corporation
F 248 rs l (,) 1 preceriptive and how you do it, but.at least identifying 2 almost everything that people ought to be looking for to 3 cover, if you will cover the vernacular, parts of their I
4 anatomy later on.
5 DR. MOELLER: Thank you, Dc n .
6 DR. ORTH: I have lots of comments on that vein, 7 too, but you don't need those. I think I have given it'now.
8 DR. MOELLER: Well, if you want to share your 9 draft, whatever you want to do.
10 Well, I think with'that I am going to bring to a 11 close the 10th meeting of the Advisory Committee and this 12 will complete the reporter's summary of the meeting.
13 (Whereupon, at 4:47 p.m., the meeting was 14 adjourned.)
15 16-17 18 19 i
20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4000 u - - _ _ . - - - - - - _ _ - - - _ _ - - _ - - - _ - - - - - - _
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( 1 CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4 l
4 United States Nuclear Regulatory Commission in the matter 5 of: ADVISORY COMMITTEE ON NUCLEAR WASTD !
6 , Name: 10th ACNW Meeting 7
8 Docket Number:
9 Place: Bethesda, Maryland 10 Date: May ll, 1989 11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and, Q 14 thereafter reduced to typewriting by me or under ths 15 direction of the court reporting company, and that the 16 transcript is a true and accurate record of the foregoing ,
17 proceedings.
18 /s/ Oh M JOAN ROSE 19 (Signature typed) :
20 official Reporter 21 Heritage Reporting Corporation 22 23 24 25 O Heritage Reporting Corporation (202) 628-4888
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MEETING Handout Agenda Item Iki 1Oth 3.1 0.S$$h 1l1910l ihik g I
REVIEW AND RESOLUTION OF C0f!MENTS ON THE DRAFT TECHNICAL BRANCH i : h:l!i POSITION PAPER ON ENVIRONMENTAL MONITORING 0F LOW-LEVEL RADI0 ACTIVE k '
j{g WASTE DISPOSAL ACILITIES 3
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'i MEMORANDUM FOR: R. John Starmer, Section Leader Technical Branch Division of Low-Level Waste Management ;
and Decommissioning, NMSS '
TROM: Edward Y. Shum Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS SCEJECT: REVIEW AND RESOLUTION OF COMMENTS ON THE DRAFT .
TECHNICAL BRANCH POSITION PAPER ON ENVIRON- l MENTAL MONITORING OF LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITIES E_3 c r.grou nd on November 5, 1987, the Nuclear Reguletory Commission (NRC) announced in the Federal Register (FR42486) the availability of a draft Branch Technical Position (BTP) paper on Environmental Monitoring of Low-Level Radioactive Waste Disposal Facilities and requested for public comments. Thirteen organizations / agencies and several individuals commented on the draft BTP. Subsequently, the
The staff has reviewed all these comments and the transcript of the ACNW meeting. The final BTP is revised substantially taking into consideration of the comments. The following is a summary of the comments from various organizations / agencies and the staff's response and resolution to these comments.
General Comme 3ts of the Draft BTP
- 1. The intent of the BTP should be stated clearly.
CommeD13IE1 Department of Nuclear Safety (State of Illinois); j ACNW Slaff Response: The staff has revised section 1.2 and has defined the purpose and scope of the BTP, The staff has made l
it clear that the BTP is non-prescriptive and only general guidance is given. ;
1
- 2. The BTP should provide more specific guidance.
C_o_mpanters : EPA; ACNW; Chem-Nuclear Systems, Inc. (South i Carolina); U.S. Department of Interior (Fish and Wildlife Service); Department of Nuclear Safety (State of Illinois);
Department of Ecology (State of Washington).
I 890".030427 890427 l
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\
- & R. John Starmer '
Ralf Response: The staff has defined the objectives of three phases of the monitoring program and provides general guidance and examples on how to meet these objectives. In addition, literature references are provided for more detailed design and implementation of the monitoring program. The staff recognizes that an environmental monitoring program for a low-level waste disposal f acility (LLWDF) is site specific (see section 1.2) and has suggested that the general guidance should be applied with flexibility.
- 3. The objectives of monitoring is unclear.
Commenters: Department of Ecology (State of Washington);
ACNW; Department of Nuclear Safety (State of Illinois).
S_taff ResAonse: The objectives of three phases of the .
monitoring program are defined, (see section 2.3). These objectives constitute an acceptable basis for use in establishing an environmental monitoring program.
- 4. The document should clarify NRC's role and authority for requiring nonradiological monitoring.
I Staff Response: The role is clearly stated in sections 1.2* i 4.1. The requirements for nonradiological monitoring are under the authority of the state and EPA. The nonradiological parameters included in the BTP are limited to the extent that they serve as indicators for waste migration or site characterization purposes.
- 5. One year of preoperational monitoring should be extended to define baseline information.
Commenters: EPA; U.S. Department of the Interior; Department of Ecology (State of Washington); Department of Health Services (State of California).
Half _Resppolise : The staff has revised the BTP to clearly encourage the applicant to carry on the preoperational monitoring on certain parameters to beyond the requirement in the regulation.
In addition, some of the measurements, such as wind speed-direction-stability, groundwater parameters and radiological background characteristics should be carried on through the license review period and the operational phase.
- 6. General lack of specificity on overall monitoring program.
I
R. John Starmer .:. Commenters: EPA; Chem-Nuclear Systems, Inc. (South Carolina) ;
Department of Ecology (State of Washington).
S_taff Response: The BTP is extensively revised to separate each phase of monitoring to provide more specific guidance.
In addition, examples of suggested programs are given and literature references are provided.
- 7. BTP should consider all critical pathways of radiation to the public.
Commenters: ACNW Staff Resp _onse: Critical pathways are considered and discussed in section 4.2.1 along with other considerations, such as critical groups and nuclides.
S. BTP should provide other literature references for more detail design of an environmental monitoring program.
Com enter: ACNW Staff Resp.nses: o Literature references are provided in the revised BTP.
Other Specific Comments:
- 1. Meteorological data should include measurernent of atmospheric stability.
Commenter: Georgia Power Company Ea fi Response: The measurernent of atmospheric stability is included in section 3.2.1.
- 2. The BTP should link the monitoring program with the modeling of site behavior prior to licensing.
. Commenter: EPA; ACNW E_af_f 3 pnonsel The subject is considered in the pathway analysis discussion in section 4.2.1.
The staf f agrees that an ef fective environmental monitoring program should be linked and related to the modeling of radionuclides transport at the site (pathway analysis).
- 3. It would be helpful to site operators to include a bibliography on specific techniques and equipment for the various monitoring requirernents.
i l.
i I
- i R. Jchn Starmer !
Commenter: EPA Sia.f f . Repppn se : This guide is intended for applicants or their consultants to design an acceptable monitoring program to meet NRC's requirements and objectives. Operating l procedures and specific techniques for measurement are not l provided but can be found in the staf f's suggested literature
) references. The NRC's Regulatory Guide 4.15 on quality j assurance / quality control should ensure that the applicant's monitoring program is implemented in an acceptable manner.
- 4. There is no regulatory requirement that a statistical data base be developed or that statistical analysis be performed.
If the NRC wished to encourage this kind of analysis, much luore detail should be included or referenced.
~
C_ppr ent e r : EPA Slaff Response: The referenced statement was deleted as part of the major revision of the BTP. Data collection; compilation and analysis, however are integral of the overall monitoring program. The staff has referenced the NRC Regulatory Guide 4.15 on quality assurance / quality control in Section 4.2.3 which provides acceptable approaches covering the above areas.
- 5. The monitoring program components listed on this page are the subject of this Technical Position Paper. As our cover letter points out, most of those components are discussed in a cursory fashion, providing little guidance or detail on the baseline characterization / monitoring systems that the NRC would consider adequate. We also note that three of the listed components (geology, geochemistry, and seismology) are not addressed at all.
Staff Response: Section 3.2 supplements the omission on geology, geochemistry, and seismology. Staff has provided more detail throughout the document.
- 6. Action levels for investigative or mitigative action should be referenced to the site boundary dose limit, not to the background levels.
Commenter: Chem-Nuclear Systems, Inc.
Sigif Response: The staff redefines action level such that a percentage of applicable dose limit or multiples of background levels can be used for references in setting an action level. ,
k.
R. John Starmer r Other minor comments are also evaluated and major revision of the BTP is done by the staff to take into consideration of these comments.
Sincerely,
$ 4' (K Edward Y. d um Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS Distribution:
Central Files: LLTB r/f NMSS r/f JSurmeier, LLTB EShum, LLTB PDR Yes:/ / /
PDR No:/ / Reason: Proprietary / / or CF Only /[ / ,
ACNW Yes:/ ,/ / No:/ /
SUBJECT ABSTRACT:
OFC :LLTB :LLTB :LLTB :LLWM
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DATE: w/t//89 : / /89 : / /89 : / /89 OFFICIAL RECORD COPY
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v UNITED STATES NUCLEAR REGULATORY COMMISSION DIVISION OF LOW LEVEL WASTE MANAGEMENT AND DECOMMISSIONING TECHNICAL BRANCH TECHNICAL POSITION PAPER r3 ENVIRONMENTAL MONITORING OF LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITIES I
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TABLE OF CONTENTS Page 1 INTRODUCTION........ ............................................ 1 1.1 Background.......................................... ..... . 1
1.2 Purpose and Scope
................... ................. ..... 2 2 ENVIRONMENTAL MONITORING PROGRAM 0BJECTIVES...................... 4 2.1 Regul a to ry Requi reme nts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- 2. 2 Environmental. Monitoring Program Phases..................... 5 2.3 Objectives of Environmental Monitoring Program.............. 5 3 GENERAL GUIDANCE ON PRE 0PERATIONAL ENVIRONMENTAL MONITORING.... . . 7 3.1 Program 0bjectives.......................................... 7 3.2 Environmental Factors and Parameters........................ 8 4 GENERAL GUIDANCE ON OPERATIONAL ENVIRONMENTAL MU!ITORING. . . . . . . . . 15 7-s
(~/ 4.1 Program 0bjectives.......................................... 15 4.2 Considerations in the Design af an Operational Environmental Monitoring Program................... ... 15 l 4.3 Measurements of Parameters in the Environment............... 18 5 GENERAL GUIDANCE ON POSTOPERATIONAL ENVIRONMENTAL HONITORING..... 22 5.1 Program 0bjectives............................................. 22 5.2 Physical Survei11ance....................................... 22 5.3 Environmental Sampling Media.................... ........... 22 l 6 REFERENCES....................................................... 24 .
APPENDIX A - Suggested Preoperational Environmental Sampling Program Covering an Arid and a Humid Site........... A-1 j l
APPENDIX B - Suggested Operational Environmental Sampling Program Covering an Arid and a Humid Site........ . B-1 A
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- 1. INTRODUCTION .,
I 1.1 Background I j
The Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974 give the U.S. Nuclear Regulatory Commission (NRC) the responsibility for licensing and regulating commercial nuclear facilities. The licensing requirements for p near-surface disposal of low-level radioactive wastes (LLW) are in Part 61 of Title 10 of the Code-of Federal Regulations (10 CFR 61). -NRC is also respon-sible for ensuring compliance with the provisions of the National Environmental Policy Act (NEPA) of 1969. The licensing requirements related to environmental protection are in 10 CFR Part 51.
With passage of the Low-Level Radioactive Waste Policy Amendments Act of-1985, C
, O ;ongress ect to Congressioneiimproved procedures epprovai, for theofimplementation for tne purpose of interstate Co esteblisnieg end opereting Regional low-level radioactive waste sites. Initial steps have been taken~by States.that will lead to the development of new sites for LLW disposal. To pro-vide timely assistance in this process, NRC is issuing this Technical Position on environmental monitoring programs.for near-surface LLW disposal facilities.
The environmental monitoring program required in 10 CFR Section 61.53 has to be submitted as part of a license application, along with the Environmental Report (ER), required in 10 CFR Part 51.
On November 5, 1987, NRC announced in the Federal Register (52 FR 42486) the availability of a draft Branch Technical Position (BTP) on " Environmental Moni-
, toring of Low-Level Radioactive Waste Disposal Facilities" and requested public comments. Thirteen organizations / agencies and several individuals commented on the draft BTP. Subsequently, NRC's Advisory Committee on Nuclear Waste (ACNW) also commented on-the draft BTP. This final BTP has been revised, taking into consideration the comments.
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O~ 1. 2 Purpose and Scope I
The basic NRC requirement for near surface LLW disposal site monitor g is in 10 CFR Section 61.53. The regulation calls for environmental mr ;toring during the preoperational, operational, and postoperational stage' of the facility. The primary objective of environmental monitoring is to' provide assurance that the performance objectives in 10 CFR Part 61 are met. The staff's interpretation of this basic objective, as well as of related objectives, is discussed in this paper.
The purpose of this paper is to provide general guidance, developed in accord-ance with 10 CFR Part 61, to applicants, their consultants and. regulatory authorities (NRC Agreement States) on monitoring low-level waste disposal facilities. This paper is not intended to be a handbook of detailed or manda-tcry procedures. It must be stressed that an environmental monitoring program for a low-level waste disposal facility must be tailored to the detailed moni-toring needs dictated by the site-specific operating and environmental con-ditions. Because each site is unique as regards topography, meteorology, Q demography, geohydrology, etc., only general guidance can be given. In the design of an environmental monitoring program, there is no substitute for good professional judgement combined with a thorough knowledge of the local environ-ment (ICRP 43,1984). Thus the guidance presented herein is not mandatory, and flexibility in applying this guidance is suggested, on a site-by-site basis.
Although only general guidance can be given in this paper, it provides insight into the opinions and expectations of NRC staff for the acceptance review of the applicant's environmental monitoring program.
In this paper, the staff will define the objectives in the three phases of an environmental monitoring program. These objectives constitute an acceptabir {
basis for use in establishing an environmental monitoring program. Genera?
guidance is then provided for the applicant in the design of the monitoring program to meet these objectives. The staff also provides literature references I for more details on the planning, design and implementation of an environmental monitoring program relevant to the operation of an LLW disposal facility.
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. Early 'in the development of an LLW disposal facility, the' applicant is encouraged to meet with NRC ttaff and discuss in specific detail the design of en appropriate environmental moni;.oring program suitable for a particular site. This is especially important during the preoperational phase, which covers a rather broad scope of monitoring requirements, as defined in 10 CFR Subsection 61.53(a). This may help in avoiding any major deficiencies, during its review, and that licensing action would not be delayed.
For the purpose of this paper, an environmental monitoring program consists of the collection of samples, and the measurement of radioactive concentrations or 3
direct rsdiation, chemical concentrations, and other physical properties of specific 'nedia in the environs of a low-level radioactive waste disposal site, during all phases of facility operation. The scope of the monitoring program here is broader than those for other existing nuclear facilities that essen-tially consider only the measurement of radiological components in the environ-ment. The regulations in 10 CFR Section 61.53 require a broad range of moni-toring, covering the three phases of operation for a new low-level radioactive waste dispcsal site. Nonradiological and physical parameters are included in the monitoring,-because they serve as indicators for waste migration and site characterization; however,. their compliance with environmental standards are subject to the regulations of the State or the U.S. Environmental Protection Agency (EPA).
Monitoring'of worker exposure during site operations, in accordance with 10 CFR f q
Part 20--such as dosimetry for personnel and radiation surveys of containers, l; equipment, materials, and support facilities--is not included as environmental {
monitoring in this paper. Effluent monitoring of plant operations (e.g.,
j releases from stacks through waste-handling or incineration, liquid effluent point of discharge from treatment of leachate) is not covered in this paper, 1 I
either. Generally, worker exposure and effluent monitoring will be required in the applicant's safety analysis report (SAR), to demonstrate compliance with ,
I the requirements of 10 CFR Subsection 61.12(k). Also, the monitoring of acci-dental releases is not included here, since, in emergency situations involving sudden major radioactive releases, as a result of such events as criticality Q and fire, a special' surveillance effort beyond the routine monitoring program may be required.
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' 2. ENVIR0NMENTAL MONITORING PROGRAM.0BJECTIVES 2.1 Regulatory Requirements The-requirements pertaining to an environmental monitoring program are l: described in 10 CFR Section 61.53, " Environmental Monitoring":
"(a) At the time a license application is submitted, the applicant shall h have conducted a preoperational monitoring program to provide basic envi-ronmental data on the disposal site characteristics. The applicant shall l obtain information about.the ecology, meteorology, climate, hydrology, geo-logy, geochemistry, and_ seismology of the disposal site. For those charac-teristics that are subject to seasonal variation, data must cover at least a twelve month period.
'(b) The licensee must.have plans for taking corrective measures if migration of radionuclides would indicate that the performance objectives of Subpart C.may not be met.
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(c) During the land disposal facility site construction and operation, the licensee shall maintain a monitoring program. Measurements and observations must be made and recorded to provide data to evaluate the potential health and environmental impacts during both the construction and the operation of the facility and to enable the evaluation of long-term effects and the need for mitigative measures. The monitoring system must be capable of providing early warning of releases of radionuclides from the disposal site, before they leave the site boundary.
(d) -After the disposal site is closed, the licensee responsible for postoperational surveillance of the disposal site shall maintain a moni-toring nystem based on the operating history and the closure and stabili-zation of the disposal site. The monitoring system must be capable of providing early warning of releases of radionuclides from the disposal site before they leave the site boundary."
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O 2. 2 Environmental Monitoring Program Phases Environmental monitoring consists of three major phases: preoperational, operational and postoperational. Preoperational monitoring occurs during the p id before license application and could continue during the license reviews.g period. Operational monitoring occurs from the beginning of facility l construction through the period when waste is no longer accepted and the .
facility is closed. Postoperational monitoring occurs from this point through {
the long-term care period. Although monitoring during each phase is related to the performance objectives in 10 CFR Part 61, the emphasis, scope and intensity of monitoring will vary from phase to phase. The monitoring program should be planned so that the data collected during each phase will be compatible with and supplemental to data collected during previous and subsequent phases.
2.3 Objectives of Environmental Monitoring Program The principal objectives of the three phases of an environmental monitoring l O proore= ror e io -ieve' reoioactive weete dienoee' reci ity are ee ro11 owe:
Objectives for Preoperational Monitoring
- 1. Provide site characterization information. ,
- 2. Demonstrate site suitability and acceptability.
- 3. Obtain background or baseline data.
Objectives for Operational Monitoring
- 1. Demonstrate compliance with applicable environmental radiation standards.
- 2. Obtain data on critical pathway parameters to allow more accurate evaluation of radiation dose to the general public.
- 3. Provide records for public information.
Objectives for Postoperational Mor.itoring O
- 1. Demonstrate comniience with site-cloeure req #iremeats.
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- 2. Provide data to support long-term impact evaluation, such as long-term l impact on groundwater.
- 3. Provide records for site closure and for public information.
The following chapters provide general guidance on establishing and implementing an environmental monitoring program and meeting the objectives of the three phases of monitoring, as just described. The guidance is intended for use by applicant managers or their consultants in developing erevironmental monitoring program. Before the development of the environmental monitoring program, the applicant is encouraged to meet and discuss with the NRC staff for further details.
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- 3. GENERAL GUIDANCE ON PRE 0PERATIONAL ENVIRONMENTAL MONITORING The preoperational environmental monitoring program, including site characterize-l tion of a LLW disposal facility, covers a broad scope of observations and l measurements. The program is comprehensive and site-specific, because each site will vary, depending on the physical characteristics of the site, proposed 4 facility design, and the site environs. The following sections provide general guidance on the design of a preoperational environmental monitoring program.
The guidance provides the specific areas that need to be covered but is non-prescriptive. Details on methods and frequency of sampling and location of sampling will vary among specific sites, because of the variation of environ-mental factors such as geology, hydrology, climate (arid and humid sites), land i use, water use, and local population. The applicant should refer to the follow-ing documents for discussions of more detailed design and implementation of a preoperational program- '
1 A. NUREG-0902 - Branch Technical Position, LLW Licensing Branch - Site Suitability Selection and Characterization (NRC-1982).
'] B. Site Characterization Handbook (00E, 1988), ,
C. Low-Level Radioactive Waste Management Handbook Series, " Environmental Monitoring for Low-Level Waste-Disposal Sites" (D0E,1989). j D. " Recommendations to the NRC for Review Criteria'for Alternative Methods of Low-Level Radioactive Waste Disposal Environmental Monitoring and Surveillance Programs" (NRC, 1988).
E. " Technology, Safety and Costs of Decommissioning a Refrence Low-Level Waste Burial Ground-Environmental Surveillance Program" (NRC, 1981).
3.1 Program Objectives The primary purpose of the preoperational program is to characterize the environment before any waste-handling operations are begun. This program consists principally of collecting monitoring data to evaluate the geological, hydrogeological, climatological, ecological, radiological, and O
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O: nonradioactive pollutant environments of the site and the surrounding area. The i site characterization is to demonstrate it: acceptability and suitability as an LLW disposal site, compared with other alternative sites in the applicant's site-selection process. In the preoperational phase, environmental media are sampled and analyzed to provide background or baseline data to characterize the site environment. Some of the environmental . sampling media can be used as indicators for long-term impact assessment. The choice of types of media and level of sampling depend on the critical pathways, which are generally site-specific.
For those characteristics for which continuous measurements are required (e.g.,
windspeed, wind direction, and atmospheric stability; subsurface water levels and contaminants; and radionuclides concentrations in air that may be subject to seasonal changes), the program should be conducted for a minimum of one year (i.e., 12 consecutive months) and preferably should continue during NRC's license reviewing period (approximately 12 to 15 months). During the initial review of the license application, the NRC staff will work closely with the applicant to identify any additional preoperational monitoring needed, so that the applicant can still take action during the review process. However, as discussed above, O the applicant is enco raged to discuss the preoperational program with the NRC staff before the initiation of the program, in order to avoid major deficiencies which otherwise might be identified later. The following section describes the environmental factors or parameters that need to be covered in a preoperational monitoring program.
3.2 Environmental Factors and Parameters 3.2.1 Meteorology and Climate l l
Meteorological data are needed, during the preoperational stage: to provide baseline information on meteorologic conditions; to determine the site's water budget; to evaluate the impact from airborne release; to obtain information on the frequency probability of severe meteorological events; and to provide base-line air quality. The significant parameters specific to meteorology are:
onsite windspeed, wind direction and atmospheric stability joint frequencies; atmospheric pressure; precipitation; temperature; evaporation; solar radiation; O severe weether; end conceatretion of centeminents in eir.
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O\_/ Most of the aforementioned data and other meterological information, such as humidity, snow depth, and inversion height can be obtained from the nearby weather station, which has similar climatological patterns for the site. If l
there is no nearby weather station, the key parameters measured onsite are the !
joint windspeed, wind direction and atmospheric stability data and precipita-tion and evaporation-rate data. Initial onsite measurements of these parameters, for a period of at least 12 consecutive months, or preferably, 24 consecutive months, are necessary. The program should be continued during the operational phase.
l The background radiologic and nonradiologic air quality data should be measured for a period of at least 12 consecutive months, or, preferably, 24 consecutive ;
months, to account for seasonal variation. The locations of air sampling sta- l tions, depending on the availability of power supply, should be at some of the !
strategic areas, such as upwind, downwind, area of maximum impact, nearest resi- l dential area, and fenceline. These stations can also be used during the opera-tional phase. For more detailed planning, (for background air quality measure- 1 O ment), on sampling frequency, sample size, nonradiological and radiological para-V meters, and sample number in areas covering arid and humid sites, the licensee !
should review references in Section 3 to aid in developing an appropriate pro-gram tailored to the needs of site specific operating activities and environ-mental conditions. An example of a suggested preoperational environmental sampling program on background radiological measurements covering an arid and a humid site is shown in Appendix A (DOE 1989 ).
3.2.2 Hydrology 3.2.2.1 Ground Water Hydrology Groundwater data are needed to provide evidence for site suitability evaluation and to demonstrate that the site is hydrologically simple, that the site can provide sufficient depth to the water table so that ground-water intrusion into the waste is unlikely or, if disposal is below the water table is proposed, molecular diffusion must be the predominant means of radionuclides movement and the ground water pathway impact can be modeled and will meet performance objectives (NRC 1982).
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At: disposal sites in humid climates, the primary mechanism for radionuclides migration will most likely be ground-water flow. Hum!d sites generally have more direct. ground-water recharge than do arid sites, usually resulting in larger seasonal . fluctuations of water level and water quality, with the likeli-hood that flow rates will be higher and more transient. Arid sites may have very deep, relatively stagnant flow systeas with little seasonal change in water
' level or quality. Ground-water flow may not be the principal release pathway at arid sites, because or the long travel time for contaminants to reach the water table-(or a confined aquifer) and for the contaminated groundwater to reach the facility buundary. Although both the saturated and unsaturated zones are important in both cases, the monitoring emphasis will depend largely on the behavior of the flow system. For example, at arid sites, the unsaturated zone should be emphasized. At humid sites, both the saturated and unsaturated zones should be considered.
1 Preoperational ground-water monitoring involves the characterization of the recharge and discharge zones, and the determination of the rate and direction of ground-water movement, and the potentiometric and water-table elevations for all potentially affected aquifer systems in the vicinity of the LLW disposal facility. The applicant should install an adequate number of monitoring wells, so that variability of flow rate and direction, during any given time period, can be assessed. The movement of infiltrate in the unsaturated zone, the potential for deep percolation, and interactions of the unsaturated zone with saturated strata should be evaluated and used in design of the monitoring network.
Water levels and capillary potentials for the saturated and unsaturated zone, respe::tively, should be determined often enough so that seasonal fluctuations are taken into consideration.
Water samples from the saturated and unsaturated zones should be collected, when possible, and analyzed for radiological, and selected nonradiological, consti-tuents, so that the water chemistry can be assessed. Sampling frequency must be established on a site-by-site basis, taking into account expected changes in water quality and/or hydrologic conditions during the year. The applicant should define vertical and horizontal gradients throughout the affected saturated and ;
Q unsaturated zones and use the information to design ground-water monitoring sys-tem for the operational and post operational phases. Furthermore, these data will enhance the understanding of the hydrogeologic system at the site.
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j i The' applicant should sample, when possible, nearby residential, municipal, and industrial wells. The duration of preoperational sampling shall be at least forLa period of 12 consecutive months, preferably extended to 24 consecutive months.
3.2.2.2 Surface Water Hydrology Surface water data are needed during the preoperational phase to verify that:
the site will be generally well-drained and free of areas of flooding or fre-quent ponding;. upstream drainage areas will be minimized to decrease the amount of runoff that could erode or inundate the site; the surface water pathway analysis meets' performance objectives; and baseline data on water quality are provided (NRC, 1982). This compilation will include data on water users,
. histo'ric floods, and droughts, rainfall,- and snowfall records.
Field measurements will include runoff, infiltration rates, erosion rates, surface-water flow rates,.and water. quality on radiological and nonradiological
! components. In addition, sediment samples from a representative cross section of: nearby surface water courses should be taken and analyzed.
'3.2.3 Geology and Seismology Information on geology is needed to characterize the site to demonstrate that the. natural processes affecting the site occur at consistent and definable rates, and that the site will be geomorphically and tectonically stable for a period of 500 years (NRC, 1982). The information includes geomorphology, stratigraphy, lithology, tectonics, structure, seismology and geologic hazards.
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Most of this information can be obtained from organizations such as the U.S. ;
Geological Survey.
Preoperational measurements consist of surface and trench geologic mapping and sampling, borehole logging, and sampling and analysis.
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g 3.2.4 Geochemistry and Hydrochemistry l.
1 Geochemistry and hydrochemistry information are.needed to provide background chemistry data, to permit monitoring of Ley indicators of water quality and leachate migration, and to identify parameters that may affect transport of the waste leachates to the-environment. Preoperational monitoring includes '
measurements of water quality, ion-exchange capacity, organic content, Eh pH, distribution coefficient, isotope content, performance of laboratory simulations of field conditions, and field tracer tests, if necessary.
3.2.5 Ecology Information on ecology is needed to define the baseline terrestrial and aquatic characteristics of the site, to support environmental impact assessments and
- mitigation planning. Important concerns include abundance of characteristics of species, importance of the species, and seasonal and migration patterns.
Ecological information includes terrestrial fauna species, terrestrial flora O species, aquatic species, livestock, food chain, migratory species, game animals, habitat, and threatened and endangered species. Most of this information can be'obtained from organizations such as the U.S. Fish and Wildlife Service.
A preoperational program includes surveying the site vicinity for major vegetation types and commercially or recreationally important vertebrate species.
Sampling should be conducted for a minimum period of 12 consecutive months, to determine seasonal variation of species. Site reconnaissance surveys (including aerial photography) can be used to confirm information obtained from existing sources, to determine species and habitat conditions, and to select sites and techniques for more intensive investigation, as necessary 3.2.6 Demography Demographic data on geographic distributions and sizes of both existing and projected human populations, with designated distances of up to a 50-mile radius of the site, are needed. This information will be used to analyze the potential O heeith imnect from feci,ity oneretion. The informetioe 4acledes non#ietioo 12
centers, population density, local residence distribution, transient population, and projected population. Most of the information can be obtained from the U.S.
Bureau of Census or the State or local government records.
A preoperational survey includes measuring or estimating distances and directions, regarding local residents' distribution, around the site, to evaluate the area of maximum impact from facility operasion. This should include nearby schools and hospitals.
3.2.7 Background Radiation Characteristics Background radiological data are needed to establish baseline data on radiological characterization of the site. These data will be used as indicators to evaluate facility operation impact, decommissioning, and site closure, and they may be used as references in setting action levels.
Preoperational. monitoring includes measurements of direct gamma radiation, Q airborne radionuclides, soil, sediment, surface water, ground water, flora, fauna, and food. At least one year (12 consecutive months) of preoperational data should be submitted in the applicant's license application. Most of these measurements may have to be continued during the operational phase.
(See suggested program in Appendix A.)
3.2.8 Land Use Land-use data in the vicinity of the site are needed to evaluate the impacts of
-the plant operation on existing and potential surrounding land uses. Informa-tion includes residential, industrial, agricultural, and recreational land use, spe-ial areas, zoning restriction:,, local land-use plans, farmland-use classi-fication, and utility land uses. This information generally can be obtained from the State and local government and the U.S. Geclogical Survey. The land-use infor- I mation should include location of cultural resources at the vicinity of the site.
The identification of. buildings, structures, or objects of historical, archeo-logical, architectural, scenic, cultural, or landmark significance in the vicinity h of the site.is required before disposal facility construction.
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,R k 'Preoperational monitoring may include field reconnaissance, and limited surface testing on archeological finds, if necessary. The applicant should consult the State Historic Preservation Officer in all data-collection activities, to ensure compliance with standards and procedures.
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- 4. GENERAL GUIDANCE ON OPERATIONAL ENVIRONMENTAL MONITORING 4.1 Program Objectives The principal purposes of the operational environmental program are to h.. .iitor site performance and to demonstrate compliance with applicable standards.
During the construction phase of an LLW disposal facility, the environmental j monitoring measures non-radiological impacts of facility construction on the environment, because no radioactive materials are disposed of at the site yet.
Most of the environmental concerns are from release of airborne dust as a result of earth work; enhanced soil erosion caused by disturbance of the site and traffic; and noise impact. The monitoring of these effects is subject to the regulation and compliance requirements of the State or EPA. During routine operation, minute quantities of radioactivity and chemical effluent may be released from the site.
The radiological releases are subject to the regulations and compliance requirements of NRC. Non-radiological chemicals in air and ground water are normally regulated by the State or EPA. Surface water discharges of chemicals are regulated by the State or EPA. The following monitoring discussion will emphasize radiological aspects. Non-radiological constituents are discussed only to the extent that they affect transport of radionuclides and can be used as early warning indicators of waste migration, into ground-water.
It is expected that the site operational environmental-monitoring program will be conducted during the entire time that waste is being buried, estimated at about 30 years. Appropriate records and data must be submitted to NRC during periodic license-renewal action, and as public information, to demonstrate com- '
pliance, for continued operation. The data and records will provide information for the post-operational prugram.
4.2 Considerations in the Design of an Operational Environmental-Monitoring Program 4.2.1 Pathway Analysis
{ The pathways for the migration of waste from the burial site to member of the public are important in the design of an operational environmental-monitoring 15 L ___ _ _ .
4 1
^
I program. The purpose of pathway analysis is to predict the amount of waste that )
reaches persons under a measured or assumed set of conditions and to estimate L the potential hazard to humans resulting from this exposure. By performing a radiological assessment, the critical pathways of radiation dose to humans can be identified. The objective of an operational program is to monitor critical pathways, by selecting appropriate environmental sampling media and sample locations, to ensure that human exposure can be measured or calculated as accu-rately as possible. The critical pathways where monitoring efforts should be concentrated are site-specific and will usually be known after the preoperational program and after the completion of the radiological assessment, which is required as part of the license submittal of an Environmental Report (ER), in support of the license application.
4.2.2 Critical Nuclides and Groups The " critical" nuclides and groups refer to the radionuclides and population groups that receive the greatest exposure in the radiological assessment. To O identify critical radion clides, the characteristics of the waste that is to
.be buried at the facility must be known. The following documents or references provide some guidance on the waste characterization of existing low-level waste-disposal facilities.
A. NRC, " Update of Part 61 Impact Analysis Methodology," NUREG/CR-4370, 1985.
B. NRC, F'ral Environmental Impact Statement on 10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive Waste," NUREG-0945, 1982.
C. 00E/RW-006, Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics - Updated Annually,.
During the preoperational phase, demographic data should be obtained and incorporated into the pathway analysis, to identify any population group whose location (with respect to the site) and dietary, domestic, and occupational habits make it the critical group.
16
- j
.O 4.2.3 Quality Assurance / Quality Control l
l The applicant's environmental monitoring program should include a quality l
assurance / quality control program. These programs are needed for the following reasons: (1) to identify deficiencies in the sampling and !
measurement processes to those responsible for these operations so that cor-rection action can be taken, and (2) to obtain some measure of confidence in the results of the monitoring programs in order to assure the regulatory agencies and the public that the results are valid.
In general the design of a quality assurance program should take the following factors into account (ICRP, 1984):
(a) quality of equipment and instruments; (b) training and experience of personnel; (c) verification of procedures by the routine analysis of control samples and the use of standard methods for analysis;
] (d) frequency of calibration and maintenance of equipment and instruments.
Variability in the measuring system will be an important aspect of influencing this matter; (e) the need for traceability of the results of monitoring programs to a national standard; and (f) the degree of documentation needed to demonstrate that the requried quality has been achieved and is maintained.
Quality control applies to all steps of a measurement prograu which include sampling procedures, precautions to be taken in transport of samples, initial physical or chemical preparation, radiochemical separation, measurement of activity, data interpretation, reporting and record keeping (ICRP,1984).
The applicant should refer to the following NRC documents for the design of a QA/QC program. The program should apply to all phases of the environmental monitoring program.
O 17
A. NRC Regulatory Guide 4.15 - Quality Assurance for Radiological Monitoring Program (Normal Operations) - Effluent Stream and the Environment (NRC, 1979).
B. NRC NUREG-1293 - Quality Assurance Guidance for Low-Level Radioactive Waste Disposal Facility (NRC 1980).
4.3 Measurement of Parameters,in the Environment 4.3.1 Physical Parameters In the operational phase, most physical parameters to be measured during the precperational stage are not measured, since the site has been characterized and found to be acceptable by the NRC or the State (Agreement States).
The physical parameters, such as data on the onsite windspeed, wind direction and atmospheric stability joint frequencies should be measured throughout the operational phase to determine movement of air releases from routine or accident situations. Precipitation, temperature and evaporation data should be measured onsite to determine water budget. Ground-water direction and velocity should be reevaluated during periodic license renewal action usually every five years, since changes may occur as a result of variation in precipitation rates, water use, pumping and other factors. These changes may indirectly affect the ground-water monitoring program.
4.3.2 Radiological Contaminants The sampling and measuring of radiological contaminants in the environment constitute the major components of an operational environmental monitoring pro-gram. The sample locations, frequency, and radionuclides measurement are site-specific and are determined on a case-by-case basis. In general, samples should be collected to represent background levels, points of maximum impact, where people can be exposed, and where measurements can be useful in interpreting the results of the overall monitoring program. The frequency of sampling depends Q on the critical pathway determination and the compliance requirements, which are site-specific. Radionuclides to be measured in the sampling media depend on 18
- 1. .
the waste characterization and pathway consideration. An example of a suggested operational monitoring program on radiological measurements covering both an arid and a humid site is shown in Appendix B (DOE 1989). The applicant should refer to the numerous literature references on the methodology of sampling and analysis of variouc environmental media in this document (DOE 1989).
4.3.2.1 Environmental Sampling Media 4.3.2.1.1 Air Air monitoring is one of the major components in an operational monitoring program. Waste can become airborne from spills, waste-handling and by incinera-tor operation. Gases containing tritium (H-3), carbon-14 (C-14), and radon-222 (Rn-222), for example, can be generated by chemical or biological activity reac-tions in the waste, and by evaporation of volatile compounds. Evaporation may be the critical pathway in an arid site, because there is less vegetative ground cover and lower soil-moisture in an arid site than at a humid site, thus enhancing airborne and evaporation processes. Air monitoring should include fenceline and offsite sampling. The locations of the sampling stations should be based on meteorological data (wind directions) and critical group locations.
Radionuclides to be measured include gross alpha, beta and gamma, in particu-lates which essentially serve as a screening measurement and some of the aforementioned isotopes (H-3, C-14, Rn-222), as appropriate.
Based on operating experience (D0E, 1989), the probability of an airborne release from a low-level waste site is small, and the level of monitor-ing should be tailored to its need. For example, if the radiological assessment from routine operation demonstrates that the offsite dose resulting from airborne releases is well below the applicable standards, such as the existing NRC stan-dards (10 CFR Section 61.41) or the currently promulgating EPA Clean Air Act standards (54 FR 9612), then the level of air monitoring, particularly the offsite monitoring can be reduced to a minimum, such as periodic sampling at prevailing down wind locations simply to provide a periodic record for public information. In addition the level of monitoring should be adjusted by com-Q paring the data to a preset action level, as discussed below.
19
k
. 1 4.3.2.1.2 Direct Radiation Direct gamma radiation should be measured onsite and offsite. Thermoluminescence detectors (TLD), which are easily installed at a fixed location are commonly used.
The onsite TLDs provide information on direct gamma radiation for workers or transient workers, such as truck drivers inside the facility. Offsite TLDs should reflect background variation since it is not expected that direct gamma radiation from a LLWDF would change off-site background radiation significantly. The slight change of direct gamma radiation offsite from background can only be estimated by pathway modeling. The TLDs measurement off site will serve as a record that the change is insignificant.
4.3.2.1.3 Ground Water Because early warning can provide an opportunity for timely mitigating action during operational phase, ground water sampling stations should be located up gradient and down gradient of operating trenches or sumps at disposal units to detect potential leachate from the trenches. Non-radiological parameters, such as pH, specific conductance, nitrate or fluoride can be used as indicators in ground water to provide an early warning for potential problems. Gross alphas, betas and gamma should be analyzed in ground water and serve as screening levels.
Analysis of key radionuclides based on trench waste inventory may be needed if action levels are exceeded. The applicant should establish action levels for the key sampling parameters and reporting requirements (see following discussion).
4.3.2.1.4 Surface Water During the operational phase, surface water sampling should be conducted in areas ,
of runoff from active operation. If there is a direct discharge into the surface stream, the outfall and the water course, upstream and downstream, should be monitored. Sample analyses should be the same as the ground water sample analyses during the operational phase.
O 20
O 4.3.2.1.5 Soil and Sediment Soil and sediment samples should be taken at strategic locations such as:
upwind, prevailing wind direction, and area of maximum impact; area of potential contamination frnm waste handling, runoff, and outfalls. Analyses should include gross alpha, beta and gamma measurement and isotopic analysis if action levels j are exceeded. Only periodic sampling is needed since they serve as indicators J for long-term impact from operation.
4.3.2.1.6 Vegetation and Farm Crops and Others Vegetation and farm crops representing dominant species of the area should be sampled periodically at locations representing background, off site impacted areas. Analyses are the same as for soil and sediment. They serve as indicators for the ingestion pathway impact analysis. Other indicators, such as small mammals, game birds, fish, and milk (if obtainable) should be sampled and anal-yzed periodically. Grab samples are acceptable since the data provide a record Q to demonstrate that the off-site impact from pathway analysis is insignificant.
4.3.3 Action Level An action level is defined as the concentration of radionuclides or chemical indicator above which an investigation is required. The investigation includes checking on laboratory procedures for analysis, contamination, resampling, iso-topic analysis, increased frequency and expansion of monitoring. The findings could lead to mitigative action. The applicant should set the action level on the key environmental media to ensure that mitigating measures are taken in a timely manner and in compliance with 10 CFR Subsection 61.53(b). Action levels should be related to background concentration or percentage of the applicable dose limits that are intended as triggering levels for initial investigation.
The applicant should also set concentration levels on key environmental media (i.e., air and water), such as levels that exceed the applicable dose limit for the reporting requirement to NRC.
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i l
O- 5. GENERAL GUIDANCE ON POSTOPERATIONAL ENVIRONMENTAL MONITORING 5.1 Program Objectives After closure of a LLW disposal site, it is expected that the facility has been properly decommissioned and that residual contamination at the site has I been decontaminated to acceptable levels. Disposal units are capped to protect intruders and to provide biobarrier intrusion. The site is placed under institutional control. The postoperational monitoring is to ensure that the site continues to meet closure requirements. At this time, most of the environmental sampling can be terminated except for ground water monitoring, which will need to be carried on to provide data to support long-term impact evaluation of ground water.
5.2 Physical Surveillance A physical surveillance program should be conducted periodically after site O closure. The surveillance program should provide for physical insreu son of the site and the performance of any required repairs to maintain the site integrity. This includes the repair, and maintenance of the perimeter fence, backfill of any area due to subsidence of the trenches, and repair of damage caused by erosion.
- 5.3 Environmental Sampling Media l
l 5.3.1 Ground Water l
After site closure, the primary path for radionuclides release to the environment is through the ground water pathway. The ground water monitoring program for the operational phase should be continued during the initial period after site
! closure, and can be gradually reduced, at proper timing if no problem exists.
I The analysis of chemical indicators should be continued and for radionuclides, emphasis should be placed on long-lived isotopes, such as tritum, Sr-90, Tc-99, I-129, C-14, uranium and thorium isotopes and Ra-226 or Ra-228. ,
O If subsurface water could to reach ground surface and eventually enter any streams, rivers, or lakes, these water bodies should be monitored.
22
- 5. 3. 2 Other Sampling Media Vegetation (particularly deep-root plants) grown on the surface of the site to control soil erosion should be sampled periodically (i.e. annually) tn determine any uptake of radionuclides. Burrowing animals that may inhabit the site should also be sampled and analyzed. This serves as an indicator to demonstrate the effectiveness of the biobarrier design.
O O
23
t O 6 REFERENCES
- 1. Department of Energy - (updated annually) - Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics.
- 2. Department of Energy (1988) - Site Characterization Handbook - National Low-Level Waste Management Program. DOE /LLW-67T.
- 3. Department of Energy (1989) - Low-Level Radioactive Waste Management Handbook Series - Environmental Monitoring for Low-Level Waste-Disposal Site, 00E/LLW-13Tg (Draft).
- 4. Federal Register - Availability and Request for Public Comment on a Branch Technical Position Paper Concerning Environmental Monitoring, Vol. 52,
- p. 42486, November 5, 1987.
- 5. Federal Register - National Emission Standards for Hazardous Air Follutions; O Reauietion of Radionuclides; eroPosed Rule end Notice of eoelic seerino.
Vol. 54, p 9612, March 7, 1989.
- 6. ICRP-43 (1984) - Principles of Monitoring for the Radiation Protection of the Population.
- 7. NUREG-1293 (1989) - Quality Assurance Guidance for Low-Level Radioactive Waste Disposal Facility. ,
- 8. NUREG-0902 (1982), Branch Technical Position--Low-Level Waste Licensing Branch - Site Suitability, Selection and Characterization.
- 9. U.S. Nuclear Reguletory Commission (1979) - Reg. Guide 4.15 - Quality Assurance for Radiological Monitoring Programs (Normal Operations) -
Effluent Streams and the Environment.
10 . U.S. Nuclear Regulatory Comoission (1981) - Technology, Safety and Costs O of Decommission 4ng e Reference tow-tevel Weste ser4ei Ground - Environmeetel Surveillance Program, NUREG/CR-0570 Addendum.
24
O
'N 1 11. U.S. Nuclear Regulatory Commission (1982) - Final Environmental Impact Statement on 10 CFR Part 61 " Licensing Requirements for Land Disposal of {
i Radioactive Waste." NUREG-0945.
- 12. U.S. Nuclear Regulatory Commission (1985) - Update of Part 61 - Impact Analysis Methodology. NUREG/CR-4370.
- 13. U.S. Nuclear Regulatory Commission (1988) - Recommendations to the NRC for Review Criteria for Alternative Methods of Low-level Radioactive Waste Disposal Environmental Monitoring and Surveillance Program.
NUREG/CR-5054, PNL-6553.
O O
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f- 4
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l APPENDIX _A SUGGESTED PREOPERATIONAL ENVIRONMENT AT SAMPLING PROGRAM C0VERING AN ARID AND HUMID SITE -- TABLE TAKEN FROM REFERENCE 3 0F THIS PAPER (DOE 1989) l I
O
I i
Suggested preoperational environmental sampling program l k
l Sample Arid a Humid a
Sample type Sampling frequency size sampling number sample number
~
Air- particulate Continuous, with weekly --
2 perimeter 2 perimeter filter changes Air--tritiated water vapor Continuous, changed --
2 perimeter 2 perimeter weekly Air- gases and radiciodine Continuous, changed --
2 perimeter 2 perimeter weekly Precipitation Monthly --
1 perimeter 1 perimeter location location Direct radiation-TLD Bimonthly --
6 perimeter 6 perimeter Water--surface Semiannually 4L Lakes, streams, ponds, rivers etc., within 10 km Water--offsite--subsurface Semiannually 4L Wells, municipal and private within 10 km Wa r--onsite--subsurface Quarterly 4L 8 perimeter monitoring wells in the satu'ated zone and any wells into equifers Soil--subsurface -- --
Collect soil at time boreholes are dug Surface soil--onsite Annually 4-5 kg Divide site in grid system of 100 x 100-meter squares and take one soil sample from each grid Surface soil--offsite Semiannually 4-5 kg Collect multiple samples using the sampling distribution outlined in Ref. 3 (DOE 1989)
Vegetation- grass Annually with soil 1m2 --
Collect grass samples at 30% of the soil sampling locations n
U A-1 l
1 e
' O.
Suggested preoperational environmental sampling program (Continued)
Sample Arid a Hunid a
Sample type Sampling frequency size sampling number sample number Vegetation--other-onsite Once 1 kg Representative samples of the common vegetation of the area Bottom sediment Annually Up to Nearby rivers Nearby rivers several that drain area that drain kg if within 10 km the site (upstream and downstream)
Small mammals Once Total Representative samples of the of 1 kg common species of the area Game birds Once Total In-season species at conveni-of 1 kg ent locations within 10 km of the site Fish Once Total Nearest river Upstream from of 1 kg that drains site and down-p area stream where V seepage or runoff from the site may occur Farm crops Once 1 kg Representative samples of per the major constituents species within 10 km of site Milk Semiannually when cows 4L If available Upwind of the are in pasture, and from site and a local dairy downwind of the site
- a. Sites where the unsaturated zone extends for greater than about 50 ft below the trench bottom are defined as arid; those sites where the unsaturated zone is less than about 50 ft are classified as humid. It should be noted, however, that arid and humid are extremes of a continuum of conditions.
l l
O 1
A-2
f%,
V Suggested preoperational analysis schedule Sample type Analysis Conditions Air- particulate Total alpha and Composite weekly Total bets samples by location Gamma ray spec each month Air--tritiated water vapor Hydrogen-3 All samples Air--other vapors, gases Carbon-14, Iodine-129, Krypton-85 Radon-222 50%
Precipitation Gamma-ray spec Analysis on evaporated residue Direct radiation Water--surface Gamma-ray spec 50%
Hydrogen-3 All samples Strontium-90 25%
Uranium, Carbon-14 O Tecnnetium-99 Radium-226 10%
Water--of f site--subsurf ace Gamma ray spec 50%
Hydrogen-3 All samples Strontium-90 25%
Uranium, Carbon-14 Technetium-99 10%
Radium-226 Water--onsite--subsurface Gamma ray spec 50%
Hydrogen-3 All samples Strontium-90 25%
Uranium, Carbon-14 Technetium-99 10%
Radium-226 Soil--onsite Gamma-ray spec Total of 30 Hydrogen-3 (soil moisture)
Strontium-90 Uranium Q Soil--offsite Same All Soil- subsurface Same 10% of total collected A-3
______ - - _ - - - - _ - - - - - - . - _ i
\
J l
Suggested preoperational analysis schedule (Continued)
Sample type Analysis Conditions Vegetation- grass Gamma-ray spec Analyze 30% of those Hydrogen-3 collected Vegetation--other Gamma-ray spec Each species Hydrogen-3 Bottom sediment Gamma-ray spec All Small mammals Game birds Gamma-ray spec Each species Fish Farm crops Gamma-ray spec Each variety Milk Gamma-ray spec All Hydrogen-3, Iodine-129, Strontium-90 O
l l l l
l 1
l O
l A-4 l l w----__--- - - - - -
1
e 4
O APPENDIX B SUGGESTED OPERATIONAL ENVIRONMENTAL SAMPLING PROGRAM COVERING AN ARID AND HUMID SITE - TABLE TAKEN FROM REFERENCE 3 0F THIS PAPER (DOE 1989)
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DOE /EP-0023 4
A Guide For:
Environmental Radiological Surveillance At U.S. Department of Energy Installations l 1
Revised July 1981 0
9 Prepared for:
U.S. Department of Energy Assistant Secretary for Environmental Protection Safety and Emergency Preparedness Office of Operational Safety
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Prepared for the U.S. Nuclear Regulatory Commission Pacific Northwest Laboratory Operated for the U.S. Department of Energy. ~
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by Battelle Memorial Institute Z r.- OBattelle i m I,v) . - _ _ _ _}}