ML20246A091
| ML20246A091 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1989 |
| From: | NRC ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) |
| To: | |
| References | |
| NACNUCLE-T-0010, NACNUCLE-T-10, NUDOCS 8905080164 | |
| Download: ML20246A091 (199) | |
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O UNITED STATES NUCLEAR REGULATORY COMMISSION
,==========================================================s ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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9th ACNW Meeting )
Day One )
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-4 1407 27af7 Pages: 1 through 138 Place: Bethesda, Maryland Date: April 26, 1989
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O 076 26 056 307 fM HERITAGE REPORTING CORPORATION onscialReporters 1220 L Street, N.W., S'uhe 600 8905080164 890426 PDR ADVCM NACNUCLE Washington, D.C. 20005 T-OO10 FDC
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.O- UNITED STATES NUCLEAR REGULATORY COMMISSION
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ADVISORY COMMITTEE ON NUCLEAR WASTE In the Matter of: )
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9th ACNW Meeting ,)
Day One )
Wednesday, l April 26, 1989
. Room P-110 7920 Norfolk Avenue Bethesda, Maryland The meeting convened, pursuant to notice, at 8:30 a.m.
BEFORE: DADE W. MOELLER Chairman, ACNW Professor of Engineering
/]- in Environmental Health
"\ / Associate Dean for Continuing Education School of Public Health Harvard University Boston, Massachusetts ACNW MEMBERS PRESENT:
DR. MARTIN J. STEINDLER Director, Chemical Technology Division Argonne National Laboratory Argonne, Illinois l
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DESIGNATED FEDEPAL EMPLOYEES:
DR. SIDNEY PARRY OWEN MERRILL NRC STAFF PRESENTERS:
T.C. JOHNSON
- DR. MALCOLM R. KNAP5 J JOHN GREEVES ,
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1 PROCEEDINGS 2 MR. MOELLER: The meeting will now come to order.
3 This is the first day of the ninth meeting of the Advisory 4' Committee on Nuclear Waste. I am Dave Moeller, Chairman of 5 the ACNW. Dr. Martin Sheind19r, one of the other members of 6 the ACNW, is also present. Dr. Clifford Smith will not be 3
, 7 with us for this meeting. We have a team of consultants 8 here for the meeting consisting if Eugene Voiland, William 9 Hinze, Judith Moody, and bonald Orth.
10 This is the first day of a three day meeting. And 11 during today's portion of the meeting, we will hear a 12 presentation on the technical position on post-closure seals 13 in an unsaturated. medium. That will occupy the morning.
/ 14 And then this afternoon we will hear on the preliminary b
15 fundings of the waste confidence review group. And that 16 will be followed by an'open executive session in which we 17 will try to formulate committee positions on these two items 18 and consider writing letters on each of these subjects.
19 This meeting is being conducted in accordance with 20 the government's Sunshine Act and the Federal Advisory 21 Committee Act. Owen Merrill seated on my right is the 22 designated federal official for the initial portions of this 23 meeting.
24 The rules for participation in today's meeting 25 have been announced as part of the notice of this meeting Heritage Reporting Corporation (202) 628-4888
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( ,) 1 that was published in the Federal Register. We have '
2 received no written statements or requests to make oral 3 statements from members of the public regarding today's 4 session. l l
5 A transcript *of portions of the meeting will be I 6 kept. And it is requested that each speaker go to a 7 microphone and please identify himself or herself so that j 8 the Reporter can take down that information. And also speak 9 with sufficient clarity and volume so that everyone here as 10 well as the Reporter can hear what is being said.
11 Before I call on the first group to make their 12 presentation, I have several announcements that Mr. Fraley 13 has discussed with me, and we jointly believe that they 14 would be of interest to the committee and to those who are
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15 present today.
16 First of all', the NRC has established an Office of 17 Inspector General effective April 17, 1989. Martin G.
18 Mulsch, former Deputy General Counsel for Licensing and 19 Regulation, is the Acting Inspector General. The functions 20 of the former Office of Inspector and Audit have been 21 transferred, and the Office of Inspector and Audit has been 22 abolished. Those duties have been transferred to the 23 Inspector General.
24 Secondly, the NRC has approved one stop licensing 25 for standardized nuclear power plants. This will lead
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() 1 hopefully to early approval of sites and a combined 2 constriction permit and operating license will be granted q
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3 before construction begins. J 4 The third item is that Victor Stello, the 5 Executive Director for Dperations, has been proposed by 6 James Watkins who you know ip Secretary of Energy.
7 Mr. Watkins has proposed that Mr. Stello be appointed as 8 DOE's Assistant Sec4Vtary for Defense Programs. Before this 9 will take effect, Mr. Steilo would have to be nominated by 10 President Bush and approved by th3 Congress. But it could 11 be of significance to our operations.
12 Dr. Herbert Couts, whom many of you know and who 13 is a former member of the ACRS for example, had a heart 14 attack roughly a week ago last Th'2rsday, and he was taken to 15 George Washington University Houpital. He apparently is 16 recovering nicely and he is supposed to be released today.
17 And I know that all of us vould be pleased to hear that 16 news.
19 Lastly, the second building for the White Flint 20 site has been approved with several conditions by the 21 Montgomery County Planning Board. And the building permit l
22 is expected to be issued within the next ninety days. And 23 when that building is completed, of Laurse we would be moved 24 out there to hold our meetings anc he in closer physical 25 location with the rest of the NRC which would be a nice step
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() 1 forward.
2 MR. STEINDLER: I hope that somebody is looking at 1 3 the QA problem on the drinking water fountain.
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4 MR. MOELLER: All right. For those who do not 5 know, the drinking founhains in the current building had a 6 problem of lead. And then a,s Marty and I noted, in order to 7 correct the lead problem if you believe the NRC weekly I
8 information report, they added radium sulphate to the water, 9 and it was probably something like barium sulphate, but it 10 said radium sulphate. And no wonder the NRC shines.
11 This morning then we are going to be covering j 12 first of all to repeat the post-closure seals. We are 13 talking about the technical position for such seals in an
{} 14 unsaturated medium. I informally asked the staff if as th*-
15 beginning of this discussion and particularly for me if they 16 would really give me a'better physical feeling of where 17 these seals go, and what they look like, and how many of 18 them there are and so forth. So they have said tlat they 19 are going to do that, and I note tnat they have brought with 20 them a model which may be very helpful to us.
21 So there will be then first of all a description 22 and a discussion of the draft technical position, and that 23 will be handled by Dr. Dinesh Gupta. And then that will be 24 followed by a discussion by John Buckley, who will tell us 25 how the staff resolved the public comments that were
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/~T 1 received upon issuance of the draft technical position for V
2 open review. So Dr. Gupta, we will begin with you.
'3- MR. GUPTA: Good morning. My name is Dinesh 4 Gupta, and I am with the Division of High Level Waste 5 Management at NMMS. Th1s morning I am going to present to 6 you the draft technical position on post-closure seals in an 7 unsaturated medium.
8 (Slides shown.)
9 May I have the next slide, please. Just to give 10 yu. some background, I will briefly go over with you DOE's 11 proposed conceptual design of the repository, and then tell 12 you something about DOE's current seal decign concepts.
13 After that, I will go over the regulatory requirements, 14 the 1D CFR 60 requirements, that pertain to the seal design, j 15 the se<i testing, and the performance requirements for seals 1_
16 and the performance confirmation testing requirements for 17 the seals.
18 I will briefly describe to you why we thought that 19 a seal technical provision is needed, and then go over the 20 NRC's staff technical position on sealing issues. i 21 MS. MOODY: Are your first two comments 22 specifically to Yucca Mountain or are you speaking of them i
23 generally? !
l 24 MR. GUPTA: The conceptual design of the 25 repository specifically pertains to the Yucca Mountain site l
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.(J- 1 and so would the seal design concepts for the Yucca Mountain 2 site. f
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3 In September of last year, we sent the technical 4 provision for public comment, and we have received a number 5 of comments on the technical provision. John Buckley is 6 going to go over the proposed resolution of those comments 7 with you later on.
8 I would like to walk through that repository model 9 that I have over there just to give you some idea as what 10 the final repository will look like and how the seals would 11 be in place in that. I do not know if you can vil see it.
12 The final repository would have the surface 13 facilities and the underground facilities. The surface
{} 14 facilities is where the waste would arrive, and this would 15 be handled for taking it down. The waste would be taken 16 down from the surface.'
17 MR. MOELLER: What is the scale?
18 MR. GUPTA: The scale on this, if you see the 19 underground facility here, it would be about a mile and a 20 half wide by two miles long. That might give you some idea.
21 The distance width ? rom the surface facilities to the start 22 of the actual underground facility is about a mile. That 23 might give you some idea about the scale of this thing.
24 After the waste is ready for taking down, it will 25 be taken down through a ramp which would be at an incline Heritage Reporting Corporation (202) 628-4888 I
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[J'T 1 going from the surface to the underground facility about a 2 thousand feet below the ground surface at this location.
3 In the final repository, there will be altogether 4 six openings from the surface to the underground. One of 5 them, as I just mention'd,e woyld be this waste handling 6 ramp. There would be another ramp that would be used. The 7 ramp is here. That would be used for carrying the excavated 8 rock out of the underground facility. When the rock would ,
9 be excavated, it would be carried to the end of the ramp.
10 This would be another half a mile or mile long ramp.
11 In addition to these two ramps, there will be four 12 shafts. The two shafts, as you have heard about, during the 13 exploratory shaft facility discussion known as exploration 14 shaft one and two. In the final repository, they will be 15 used as ventilation shafts. In addition, there are two 16 other shafts. One is a men and materials shaft that will be 17 used for carrying men and materials for operations purposes.
18 And the fourth shaft is the emplacement exhaust shaft.
19 So in the final repository, there will be four l 20 shafts and two ramps. And those would be openings 21 connecting the surface to the underground.
22 MR. MOELLER: Excuse me, the last one, the 23 emplacement exhaust shaft, what is that?
24 MR. GUPTA: That would be the ventilation exhaust 25 shaft. They would be there to make sure that no
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r-( j\ 1 radionuclides migrate that would be trapped in this filter 2 building up here at the top of the shaft. So essentially, 3 this is a ventilation chaft for the exhaust from the 4 underground. l 5 Now in the un'derground facility, there will be ,
I 6 miles and miles of tunnels op drifts as we know them. There ]
7 would be three long drifts, three main ones known as the l l
8 waste main, another known as tuff main, and the third one l l
9 will be known as the service main, having different purposes 10 there.
11 The entire area will be divided into seventeen or 12 eighteen panels where the waste would be emplaced. And each 13 one of them, each panel would have several miles of drifting
(~) 14 for waste emplacement. Altogether in the underground v
15 facility, there will be a hundred miles or more of drifting.
16 For the sealing point of view, all of these 17 openings may need to be sealed at the final closure time.
18 The ramps, the shafts, and the underground tunnels.
19 MR. STEINDLER: How about the bore holes, are not 20 the bore holes sealed off?
21 MR. GUPTA: A good point. In addition to all of 22 these openings, DOE is proposing a number of bore holes for 23 exploration purposes, and those bore holes will need to be 24 sealed.
25 MS. MOODY: How about the hydrologic testing, I
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() 1 imagine that there must be several hydrologic holes that go 2 right through the repository horizon to the underlying rock, 3 how many of those are there going to be?
4 MR. GUPTA: There are going to be a large number i 5 of holes within the exploration facility for testing 6 purposes. And depending upop what is found in that area, 7 there may be a need to seal those holes as well.
8 As I just mentioned, the term sealing as used by ,
9 OOE, it refers to all activities that would be associated 10 with closure of the underground facility, the shafts, ramps, 11 and bore holes.
12 Now seals may be required to limit water flow from 13 the surface into the underground facilities, the water being
(} 14 caused by the flooding and other rainfall events. Also the 15 seals may be needed to avoid the flow of air outside of the 16 underground facility.
17 MR. STEINDLER: Excuse me, are you going to touch 18 on that again some time, that is the rationale behind the 19 restriction of gaseous flow?
20 MR. GUPTA: Yes, I will.
21 MR. STEINDLER: Okay.
22 MR. GUPTA: The two sources of water, as I 23 mentioned, could be from surface flooding or there could be 24 direct infiltration through faults. And for air, the 25 concern is that air might come out through the natural i
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12 1 1 faults, and there may be a need to analyze to see how those h( )
2 air flow concerns can be mitigated.- )
i 3 Next I will describe to you the various sealing l 4 components as proposed by DOE for Yucca Mountain just from k l
5 the sealing technical pbsitiory perspective.
6 Are there any ques,tions?
7 MR. MOELLER: Yes. How many seals are there, I 8 mean is there a minimum number of seals on any given shaft?
9 Like I see four on the vertical shaft here. Is that a 10 minimum number?
11 MR. GUPTA: DOE's current position is that seals 12 are not needed to meet the requirements of 13 10 CFR 60 to meet the performance objectives. Then to go 14 down and see if there is a potential for water infiltration 15 or there are some other concerns as they will note when they 16 construct the facility'. And at that time, they may evaluate 17 the need for seals. The number and where they will be 18 locating these and the actual design still have to be 19 decided later on by DOE based on what they find underground.
20 MR. MOELLER: There is no set number then?
21 MR. GUPTA: There is no set number.
22 NR. MOELLER: Okay.
23 MR. GUPTA: I will just go over the concepts as 24 they are right now to put the technical position in the 25 proper pers;ective. The first one here relates to the
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- 1 sealing of the four shafts. The various components of the 2 seals are at the surface of the shaft where it meets the 3 ground surface, there will be a surface cover core, and then 4 there will be a collar core, and these would be concrete
< 5 structures. There will*be an, anchor to bedrock plus. And 6 then the shaft itself will be backfilled by crushed tuff.
7 In order to avoid the settlement of this tuff, 8 there will be a number of settlement plugs that would be l
9 placed. And the number of them remains uncertain at this 10 time as to how many might be needed to control this 11 settlement. In addition where the drift meets the shaft, 12 there would'be a station plug to support the shaft backfill 13 and to control water infiltration into the drift.
14 If I could have the next slide. This is to show O- 15 the detail of the surface cover at the shaft. .The shaft 16' would be covered by a rip-rap along the surface cover. This 17 is the alluvium that would be the collar core here made of 19 concrete. And this is the plug, anchor to bedrock plug, 19 that would be grouted and then the shaft backfilled. This 20 shows the details of the seals at the surface of the shaft.
21 MR. MOELLER: And that rip-rap on the top is 22 10,000 year rip-rap or what?
23 MR. GUPTA: DOE's curreat assessment is that the 24 seals will not be needed to meet the performance objectives 25 for 10,000 years. And the current thinking is that if at Heritage Reporting Corporation O (202) 628-4888 t
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() 1- all needed the caps need to last only 1000 years.
2 MR. MOELLER: When DOE, and we had read that 3 -position, when they present that, are they saying that even 4 if they did not put anything at cil in this open shaft, just 5 let rainwater or whatev'er might run down it, that there 6 would be no problems? .
7 MR. GUPTA: That is correct. That is indeed their 8 position.
9 This shows the details of the settlement plug.
10 Now you will notice that DOE is proposing that through the 11 settlement plug that there will be tubes filled with 12 aggregate. So if water gets into the shaft, it is able to 13 get out through these settlement plugs and go to the bottom
(} 14 of the shafts. Their strategy is that if water gets into the shafts that it should be able to drain out through the 15 l 16 bottom of these shafts'. So the idea is not to completely 17 seal it but to be able to drain the water out, so that it 18 does not find its way to the waste packages.
19 MR. STEINDLER: Is that a position that has been !
20 accepted by the staff?
21 MR. GUPTA: No, we have not accepted it yet.
22 MR. STEINDLER: Have you addressed the issue as to 23 whether or not that is a reasonable approach?
24 MR. GUPTA: At this time, we are reviewing the 25 site characterization phase of the work, and the testing 1
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(% 1 that might be needed to show the effectiveness of these 2 seals. And we have made a number of comments in our papers 3 on the seals.
4 MS. MOODY: One of my questions to you is has 5 there not been some con *cern with respect to even sealing all 6 of the holes just for safety, reasons, not necessarily for 7 other reasons except for that?
8 MR. GUPTA: That is correct. One of the purposes 9 of the seals is to keep the intruders away.
10 MS. MOODY: That is correct. And that would be an 11 argument that you should seal anyway.
12 MR. GUPTA: Yes.
13 MR. MOELLER: But to be sure, and I do not mean to
{} 14 beat it to death, in other words the seal is primarily to 15 prevent easy intrusion or inadvertent intrusion, and the l
16 seal will be designed if DOE's proposal is accepted that it I 17 will be designed not to impede the flow of the water, but 18 what water gets in there that it can flow through and move l
19 on to the bottom of the repository, and then where is it l 20 taken?
21 MR. GUPTA: It will take it'down below the !
22 repository level to the groundwater table.
23 MR. MOELLER: Okay. So there will have to be an 24 opening all the way through to the groundwater?
25 MR. GUPTA: That is indeed their strategy. If you
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- 16 1 remember, in their previous design concepts for these 2 shafts, they were penetrating the shafts all the way down to 3 the bottom of the hill.
4 MR. MOELLER: Yes.
5 MR. GUPTA: Ahd the, idea was that when water gets 6 in there that the water would be able to accumulate there, 7 and that it will not finds its way ,o the waste packages.
8 And gradually the water would seep int the rock and 9 eventually find its way to the groundwater able.
10 MR. MOELLER: I guess that I find or I need to 11 think about it a lot more to understand it better, but you 12 had the Calico Hills which has been described time and time i 13 again to us as an impervious barrier between the unsaturated f- 14 and the saturated zones. And now we are hearing we really
\J 15 want to penetrate that so that water flow can go on down to 16 it.
17 MR. GUPTA: Well, it is hydraulically not 18 impervious.
19 MR. MOELLER: Okay.
! 20 MR. GUPTA: That the water would be able to go 21 through it.
22 MR. MOELLER: Would there be anything put into 23 these passageways to take out any contamination that might 24 be in the water?
25 MR. GUPTA: That is the strategy that DOE is Heritage Reporting Corporation O (202) 628-4888
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2 pathways should be uncontaminated. The pathways are not for l
3 contaminated water. And the design philosophies to keep the l 4 water away from waste packages and for all of the water that 5 is uncontaminated find h quick pathway down to the water 6 table. ,
l 7 Do you have a question, Ms. Moody?
l 8 MS. MOODY: I will pass this time.
9 MR. GUPTA: Okay. This picture shows the details 10 of the station plug where the shaft would meet the .!
11 underground drifting at the main repository level. As you 12 will notice here, the plan for the liner to be terminated 13 just above the repository horizon level. Below that the 14 liner would be removed. So that if there is any water that 15 comes through the shaft, it can dissipate into the 16 surrounding ground.
17 The concrete barrier here is placed at the 18 interface between the shaft and the main drift at the 19 repository level, and that would be put into the surrounding 20 rock.
21 MR. MOELLER: Excuse c.e, what did you say again on 22 that one about water, that even though there is a plug in 23 the drift that it again will permit water to flow?
24 MR. GUPTA: Let me show it to you. This is the 25 concrete liner surrounding the face of the shaft.
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1, MR. MOELLER: The shaft, right.
2 MR. GUPTA: DOE's plan is that at closure that all 3 of the liners at the level of the repository would be 4 removed, so that the rock is bare and there is no concrete 5 liner around the shaft.' If water comes down through the 6 shaft, it can dissipate into.the surrounding rock.
7 MR. MOELLER: Thank you.
8 MR. GUPTA: I just went through the sealing 9 concept for the whole shaft. There are similar concepts for 10 the ramps. There will be two ramps in the final design.
11 And DOE plans to seal the ramps in just about the same 12 fashton. There will be a surface plug, and the ramps will l
13 be backfilled with crushed tuff, and there will be a plug 14 placed in the intersection of the ramp and the main
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'15 repository level.
16 This picture'shows the details of the ramp plug at 17 the surface. There will again be rip-rap placed at the face 18 of the ramp, and there will be a concrete plug to see if any 19 water does not seep in and also to keep the intruders away.
20 MR. MOELLER: And again that will be lined, it 21 will be lined only up to the repository itself or that last 22 seal, do you have a liner to the left of the last plug?
23 MR. GUPTA: It does not show. I have not seen any 24 discussion on the ramp for this situation.
25 Now just to talk about the shafts and the ramps.
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19 l' This picture shows the sealing concepts for bore holes.
2 Bore holes, again there would be a bore hole cover, a 3 concrete cover at the top. There will be rip-rap placed at 4 the top. The bore hole will-be backfilled with granular l 5 material depending on what the need is.
6 Now coming to the underground facility. This-is 7 an area that our rule does not cover, the sealing of the 8 underground facility. But there will be about a hundred 9 miles of drifting underground, there will be a number of 10 faults and fractures that will be intersected by these 11 drifts and they may need to be sealed.
12 There are a number of concepts that DOE has for 10 sealing those at this time. Depending on what they find, 14 they might chose one or the other of these. One option is 15 that-if the fracture is like this, that they might put a l
16 sump at the bottom of the drift where the water can
- 17. accumulate for some_ time. There will be additional drainage 18 holes through which the water can seep below the drift 19 level. So the idea is not to plug the water that comes 20 through the - fract tre, but to let it drain down below the 21 bottom of the drift.
22 And just to emphasize again, the idea is to deal 23 with water only. The movement of gaseous radionuclides 24 through these faults is not addressed in the sealing 25 concepts of DOE.
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( )' 1 Another. option for sealing of the underground area 2 would be supported like this, and there could be a compacted 3 low backfill placed on one side of it, so that the water can 4 be stored.behind it for some time before it gets a chance to 5 seep below the drift levels. .
6 There are two other options shown here. One is to 7 put a concrete barrier here on one side with grouting on one 8 side of the fault. The other concept is to put bulkheads on 9 both sides and then fill it with free draining crushed tuff ;
10 and let the water just go through here. And in all of these 11 concepts, the idea is to let the water drain rather than to I 12 plug it up.
13 This is again for the drifts. One option is to
{} 14 15 backfill the entire drift with crushed tuff.
a number of ways that the backfilling can be done.
And there are The 16 emplacement could be by mechanical compaction or by pneumatic means.
17 18 Are there any other questions on this sealing 19 concept or where the seals would be?
20 MS. MOODY: Just one short one on the bore holes.
21 Are the bore holes going to be lined and then the 22 lining kept in place?
23 Mr. GUPTA: That is an option. I think that they 24 would be very reluctant to remove the lining, but it may 25 have to be done in some cases.
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_j 1 MS. MOODY: The way that that diagram is made, it )
l 2 looks like the lining is going to stay in place. ]
1 3 MR. GUPTA: Right.
4 MS. MOODY: At this time, do you have any idea how 5 many bore holes there a're going to be?
6 MR. GUPTA: In the,CDSP, there were some 350 7 shallow bore holes and about 40 to 50 deep bore holes.
8 MS. MOODY: Yes, I have a lot of concern about 40 9 to 50 deep bore holes.
10 MR. HINTZE: Excuse me, if I may. Your diagrams l 11 have indicated the concern with these f2 t:re zones that 12 are rather limited in their horizontal d' ions. We at 13 this point have no evidence that we will nt see fracture
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v 14 zones and fracture flow through a rather widespread 15 distribution.
16 How is this potential variation from the 17 preconceived concepts on Yucca Mountain being taken into 18 consideration, how is the fracture flow concept in contrast 19 to the coarse medium being taken into consideration as we 20 look at these seals?
21 MR. GUPTA: Well, in the latest discussions that 22 we have seen from DOE, DOE is considering that there might 23 be some fracture flows. The water may not necessarily 24 remain within the matrix, but it could come through the I 25 fractures. And as far as sealing is concerned, these are
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,, 1 the concepts. They want all of the-water to drain out of 2 those faults. They want to control the water. DOE's 3- concepts are that water should not' reach the waste area as 4 much as possible. Isolate them and let them drain as'much 5 as possible. ,
6 MR. .HTMTZE: Is that a subject of continuing 7 research by DOE 7 8 MR. GUPTA: .Yes, definitely.
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9 MR. HINTZE. Do you have any idea of what the 10 level and the intensity of that research is? .)
11 MR. GUPTA: I am afraid that there is no 12- hydrologist here who would be familiar with that program in 13 detail, but we can certainly address that. question in a 14 later session.
O 15 MR. STEINDLER: I have a question concerning the 16 approach that DOE is taking to the restriction of gas flow.
17 Has DOE in the readings that you have done 18 identified the source of their attention to the permeability l 19 to gas of these plugs, in other words is that an issue that 20 they have raised on their own or is this an issue that they 21 believe is inherent in the regulations, what is the source 22 of their concern?
23 MR. GUPTA: They have raised this concern. The 24 way that they are analyzing it is very different than how we 25 perceive the problem at this time. Their analysis entails Heritage Reporting Corporation O (202) 628-4888 i i
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() 1 using the medium as a continuum, assuming that the flow of 2 air would like go through a matrix if you will. And it does 3 not specifically address the possibility of air outflow to 4 fractures and faults. And using that analysis that DOE has l
5 presented to us in some*of the publications, they have !
6 indicated that they do not see any problem with air outflow.
7 But their analysis does not specifically address the 8 potential for air flow directly through fractures. l 9 MR. STEINDLER: 'Well, eventually I hope that you 10 will cover the rationale that you have built into the 11 zechnical position from your side of this on that same 12 issue.
13 MR. GUPTA: Yes.
I'T 14 MR. VOILAND: Mr. Chairman.
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15 MR. MOELLER: Yes, Gene.
l l 16 MR. VOILAND:' What are the quantities of water 17 that you are concerned with in this whole system; obviously 18 this is designed to pass water or to contain water, but are 19 your projections for that? j 20 MR. GUPTA* That remains very speculative at this 21 time. It is very uncertain. DOE has not addressed the 22 potential for fresh water zones within the ground, and there 23 is no information on that at this time. Their estimates are
! 24 very small quantities of water. They are talking about some 25 15 gallons per day through each fracture or something like l
l l
\ im i) Heritage Reporting Corporation (202) 628-4888
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() 1 th at . This is a very small quantity. Indeed the volume of j 2- the water through these fractures, there would be no concern
)'
3 as I see it.
4 MR. VOILAND: The permanent precipitation is what, 5 five inches per year or*something like that?
6 MR. GUPTA: Six inches or something like that.
7 The only concern could be some fresh water zones that could 8 find its way through the fractures.
9 MR. MOELLER: Dr. Hintze.
10 MR. HINTZE: Has any consideration been given to 11 the fracture of the liners as a result of movement along 12 faults, and how is that taken into consideration?
13 MR. GUPTA: DOE is designing the liners for
- G 14 seismic loading in nuclear plants. And their design
%.)
15 criteria is for a movement of about five centimeters.
16 MR. HINTZE: 'This is really with the passage of 17 seismic waves and not with the physical movement associated 18 with the development of earthquake activity, it is quite a 19 different thing. It must be of concern if the liners are j 20 pett of the whole syrtem that their Antagrity be maintained 21 through any earthquake movement, any earth movement.
22 MR. GUPTA: We fully agree with that. We have a 23 point paper. ;
24 MR. HINTZE: Excellent. If I may, one more 25 question.
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(~) 1 Is the position of DOE regarding let the water
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2 come and we will get rid of it someway or other down and 3 out, is this simply an admission that there is no way that 4 we are going to keep water out of the system?
5 MR. GUPTA: The thinking is that the water 6 quantities are going to be extremely small. That is the 7 perception that we get. And assuming that if the water 8 quantities are really small, then there would be no concern.
9 Some of these questions will indeed be answered when we go 10 down and see the rock.
11 MR. HINTZE: Thank you.
12 MR. MOELLER: Bill, you know that I am not a 13 mining engineering, but it seems to me that from what we are 14 hearing this morning that DOE is acknowledging that water
(.) 15 may gain access and that they are going to take care of it 16 if it does. And the idea too of putting the collection 17 basin beneath a fracture so that if water does come down i 18 that they again can take care of it makes sense to me. You 19 know, I want to hear more, but it makes sense. j 20 MR. HINTZE: It is certainly one of the viable 21 alternatives.
22 MR. GUPTA: It indeed makes sense. The only 23 concern that the staff would have is whether those drainage 24 passages could remain effective for the number of years that 25 DOE is relying on that drainage. And some testing, or some r~g Heritage Reporting Corporation
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(~) 1 data, or some evidence to that effect would have to be l A._J l 2 provided by DOE to address that question, i 3 MS. MOODY: Well, also tied to all of this 4 designing is the fact that the assessment as to predictions, !
5 whether predictions for*the n9xt 1000 to 10,000 years may 6 have some long-term predictability. Because like you say, 7 if you are going to design a repository for six inches of 8 rain per year, you are predicting that that six inches will 9 go on for the next 10,000 to 100,000 years. l 10 MR. GUPTA: That is absolutely right.
11 I will now quickly go over the regulatory 12 requirements that must be met for the seal design, for seal 13 testing, and for the performance of the seal.
f w, 14 The first and most important one is 60.112. It (J
j 15 deals with the overall system performance. The regulations 16 do not directly require the seal to meet any performance 17 objectives. Rather for the overall system, the requirement 18 is that the geologic setting shall be selected and the 19 engineered barrier system, and the shafts, and bore holes 20 and their seals shall be designed collectively to assure 21 that the EPA standards are met.
22 So if DOE decides not to assign any performance or 23 allocate any performance to seals, then the engineered 24 barrier system and geologic setting will have to take care ;
25 of the rest of the burden, and the seals may not be assigned l
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() 1 or allocated any performance at all.
But we are not saying
!' 2 that:that is what we are looking for. We are known on being <
l 3 on'the conservative side,-and it would be prudent that DOE
- 4. does design seals in a way that can' contribute some 5 performance to the over'all. ,
16 With respect to the design of seals, the
.7 requirements are that seals for shafts and bore holes shall 8 be designed so that following permanent closure they do not 9 become pathways that compromise the geological repository's 10 ability to meet the performance-objectives. This is a broad 11 based requirement for the design.
12 If I could have the next slide, please. For the 13 sealing materials and how these seals will be placed, the 14 requirements of 60.134 talks about the materials and
)
15 placement methods. And again the requirement is that the 16 materials and placement method shall be selected to reduce 17 the potential for creating a preferential pathway.and for 18 radinuclide migration.
19 With respect to the testing and the performance 20 confirmation program. Since seals have to be placed at the 21 closure time which is some time from now, the DOE has some 22 time to collect a lot of data on the performance of seals.
1 23 The requirements though call for the program of performance 24 confirmation to begin doing site characterization. And the 25 program shall include in situ monitoring, lab and field ;
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u 2 As far as the testing of the design of seals, the l
3 requirement of 60.142 states that during the early or 4 developmental stages of construction, a program for in situ 5 testing of such feature's as bore hole and shaft seals and 6 other components of seals sh,all be conducted. And the 7 testing shall be initiated as oarly as practicable.
8 MR. MOELLER: Now none of this has begun as of 9 today?
10 MR. GUPTA: No. There has been some lab work that 11 has been done on sealing materials. But at this time, that 12 is at a standstill to my knowledge.
13 MR. STEINDLER: I know that you folks have already 14 written those regulations essentially into concrete, and I f-)
Am/
15 am sorry for that pun, but I do not understand how you 16 expect a licensee to test bore holes that are sealed on a 17 post-closure basis.
18 Once the issue is closed and the shafts are 19 filled, what sort of testing do you expect somebody to do?
20 MR. GUPTA: The testing will have to start way 21 early. It is not that we are asking for tests to be done 22 after the closure. The testing is to be done before closure 23 and before the license is given for closing the facilities.
i 24 MR. STEINDLER: So the staff is prepared to accept 1 i
25 the fact that once a seal is in place that it is an 1
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('^j) 1 untestable feature, is that right? i 2 MR. GUPTA: No, that is not what we are saying.
i 3 MR. STEINDLER: Then you do expect the applicant d I
4 to test a seal once it is in place?
5 MR. GUPTA: Obr requirements call for testing of 6 seal design as it would be. ,
7 MR. STEINDLER: I think that there is a big 8 distinction between testing a seal design an2 testing a j 9 seal. l 10 MR. GUPTA: I do not know if after closure that we 11 have any requirements. I think that we close the facility 12 and go home.
13 MR. MOELLER: As I recall too, and I hope that my
/~ 14 memory has not slipped me completely, but like in terms of b}
15 environmental monitoring, once it is sealed up you quit.
16 MR. STEINDLER: Fine. I understand that. But I 17 am trying to reconcile that fairly obvious point with what I 18 think I see up there.
19 MR. GUPTA: Jim, do you want to add something?
20 MR. WOLF: Yes. I am Jim Wolf, the General' 21 Counsel's Office. The idea is that at the time of permanent .
22 closure that of course '.he Commission should have the 23 confidence that the seals and everything else are going to 24 operate when they are closed. But there is still a further 25 regulatory regimen that exists afterwards, from that stage Heritage Reporting Corporation
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( )- 1 -to the' stage of closure.until the termination of the
'2 license.
3 Now how the regulators will implement that remains 4 to be seen. But there has been.a good deal of discussion 5 about the desirability 'or feasibility of post-closure 6~ monitoring which could be considered if it was deemed 7: necessary and appropriate.
8 So the point is that if there is felt.to be a need 9 even after permanent closure for any further activities to 10 be undertaken that the Commission retains jurisdiction over 11 the Department of Energy so that could be done. But that is
'12 really getting decades into the future. And so the 13 regulations provide the flexibility necessary to deal with 14 the situation in a reasonable way at the time.- But I do not
)
15 think that it is any more specific than that.
16 MR. GUPTA: The next requirement that I am going 17 to address here is 60.24. It states that the license 18 application and the' environmental report shall be as 19 complete as possible in light of the information that is 20 reasonably available at the time of docketing.
21 And what we are referring to in this rule is that 22 when the license application is submitted that there should 23 be sufficient information on seal material, the replacement 24 method, and the performance of the seal, so that they can 25 evaluate the adequacy of those at license application time.
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I ) 1 Now I will go to the next topic of my discussion 2 this' morning. Why is there.a need for-a technical position 3 on the seals. And there are a number of issues here that I 4 would like to point out. The first one is that DOE has 5 concluded that there is'no need for seals to meet the 6 requirements of 10 CFR 60.112 However, DOE has stated that 7 it plans to install seals. And the thinking is that they 8 may later decide that need to allocate some performance to 9 seals.
10 And I think that it would be important for us to 11 provide some' guidance, that if that is the case then.what 12 performance criteria should be used to design the seals and 13 allocate performance.
() 14 MS. MOODY: Before you leave that, just quickly i 15 state that if DOE has concluded that there is no need for 16 seals, what is their criteria for concluding that or what 17 did they use, just low total rainfall or what?
18 MR. GUPTA: They have submitted an analysis both 19 with respect to the water infiltration and with respect to 20 gaseous outflow. Based on their calculation that they have 21 presented as-to how much water they can allow with time from 22 day zero to 10,000 years within the facility, they are 23 saying that their estimate of water that will come down in 24 the underground facility is significantly less than the 25 amount of water that they can allow come underground and )
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m 1 contact the waste.
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2 The same conclusions have beer made with respect 3 to the air outflow. The performance requirements that they 4 have used state that you can allow some 25 percent of the 5 air from the undergroun'd facility to escape outside. And 6 their estimates are that much less will go out based on 7 their modeling of the facility. And therefore even if the 8 seals are not there, the facility will meet the performance 9 objectives. Now of course, you have to realize that there 10 is hardly any data at this time.
11 MS. MOODY: That was the issue of raising the 12 whole point. That if you are going to do some calculations, 13 there has to be some cross-check to see whether or not those
{} 14 calculations are meaningful given the site itself. So what 15 you are saying is that some preliminary calculations 16 indicate that seals may not be needed. But if they are 17 going to continue to operate in that mode, they still have 18 to collect some data which may or may not back that up.
19 MR. GUPTA: Absolutely. I think that that is 20 exactly what we are saying.
21 The other point that I would like to stress here-22 is that the seal design concept for unsaturated medium are 23 so different than the concepts that are originally thought 24 out in writing the regulations. As I pointed out earlier, 25 doe is stressing more on the need for keeping the drainage Heritage Reporting Corporation
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() 1 option open. The water comes in and gets up, rather than 2 plugging the water in and not letting it in. The concepts 3 are so different that it seems that some guidance is needed 4 to DOE as to what requirements have to be met for those 5 concepts. ,
6 By the same token that DOE is not allocating any 7 performance to seals at this time, they have not put them on 8 the Q-list. And the staff feels that we naed to clarify our 9 Q-list requirements for seal position in this technical 10 position document.
11 MR. STEINDLER: Is the discussion concerning the 12 Q-list before the Q-list technical position document or to 13 so clarify?
() 14 MR. GUPTA: It is just a clarification of a 15 restatement of the same position specifically dealing with 16 seals. The position that we have taken in this document is 17 exactly what we are talking in NUREG-1318. They have to use 18 that document to come up with the Q-list requirement.
19 For performance confirmation, DOE's position is 20 that they do not need to start any in situ test program 21 until after the license is issued to them for construction.
22 And the staff feels that enough data should be collected 23 before license application on seals, so that when the 24 license application is docketed that we can review it to 25 ascertain whether seal technology is reasonabay available so O rie 9- eerei e (202) 628-4888 cerror eie- 1
e 34 1 that at closure that the facility can be effectively sealed.
'{ }
2 And we need to clarify these requirements, and the technical 3 position would be a good way to do that.
4 The next position on the need for a seal technical 5 position is that the sthff feels that for long-term 6 performance that seals have to last for a long time. It 7 would be difficult for DOE to demonstrate that seals can 8 last for a long period of time. And therefore if DOE needs 9 to locate performance to seals, DOE should try to minimize 10 the need for seals by using appropriate design measures, 11 with the openings at higher levels and things like that, but 12 DOE does not have to depend on seals.
13 Another reason why we thought that.a technical 14 position was needed on seals was that we need to clarify 15 predicting the longevity of seals for long-term 16 uncertainties that have to be considered in meeting the 17 requirements of 60.112.
18 Now we start with writing the technical position.
19 Whenever the staff develops a technical position, we are hit 20 from two sides. Some people come back and say you are 21' reiterating the regulation, what is written in the rule, and 22 why do you need a technical position.
23 If you go beyond that and try to explain the 24 regulation, people come and say you are using the technical 25 position as a vehicle to generate or create new rules and Heritage Reporting Corporation
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l 35 gw 1 new regulations, and you cannot do that in a technical N
2 position. So you are hit from both sides. You cannot just 3 reiterate the rule and you cannot make new regulations.
4 It is the same thing on the concept of whether it 5 .is too prescriptive or too general. If you try to specify 6 things that seem like provid,ing some guidance to DOE in 7' terms of some specific numbers and specific quantities, 8 people say that you are being too prescriptive. If it is 9 too broad, then people wiil come back to you and say it is 10 too general and it is of no use to us. So you nave to 11 really walk a fine line when you develop a technical i
12 position, and I hope that the committee appreciates that.
~
13 What we are saying up front in this technical 7
14 position is that technical positions are not substitutes for U 15 regulations. This is one way that DOE can demonstrate how 16 they can meet the requirements of the regulation. And the 17 staff will accept alternative positions if DOE can justify 18 that they will meet the applicable requirements using 19 alternative means.
20 Some of the issues that we could not cover in this 21 technical position, I am outlining them up there. Gaseous 22 outflow through existing faults and fractures. As I 23 mentioned, DOE's position is that they are not going to seal 24 the faults and fractures for gaseous outflow. And we have 25 not covered that particular asp""; in this technical Heritage Reporting Corporation O (202) 628-4888
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(_) 1 position. l 2 Our basis for not including that was that DOE will 1
3 have to assign that element of performance to the other l 1
4 components of the system like waste packages or whatever l
(
5 that is covered around kaste packages.
6 MR. MOELLER: The gaseous outflow is totally 7 releases from the waste?
8 MR. GUPTA: That is correct.
9 MR. MOELLER: It is not any other kind of gases?
10 MR. GUPTA: That is correct.
11 We have also not addressed specifically a scenario 12 where the water table would rise and inundate the facility 13 and how this seal would perform or not perform.
I') 14 The other features not covered in this technical V
15 position are the effects of credible future tectonic, 16 geologic, geomorphological changes, processes and events, 17 and also the thermal effects of emplaced waste.
18 MR. STEINDLER: I am sorry, I do not understand 19 that last one.
20 MR. GUPTA: The thermal effects?
21 MR. STEINDLER: Yes. You mean that you are not 22 going to take into account the temperature rise in the 23 repository?
24 MR. GUPTA: We have not specifically addressed it.
25 The seals could be significantly affected by the rising
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'(') 1 temperature. Their performance and their degradation with 2 time would definitely depend on the thermal effects.
3 MR. STEIN 0LER: The temperature regimen over at 4 least the first 300 to 1000 years is reasonably well 5 predictable apparently
- accord $ng to DOE's models.
6 Is there some reaspn why you excluded at least e 7 addressing the issue in-the technical position? It seems 8 like an obvious issue to address.
9 MR. GUPTA: We have addressed it in a general way, 10 but we have not been very explicit as to how the thermal 11 effects of emplacement should be accounted for.
12 MR. STEINDLER: I understand that, but have you at 13 least asked in some fashion or other, and I do not see it
{} 14 quito frankly, the applicant to identify what the impact of 15 changes in temperature might be on the various materials?
16 MR. GUPTA: Ne have stated in there and it is not 17 very specific and not very explicit.
18 MR. STEINDLER: N, it is not.
19 MR. GUPTA: It is in a general way.
20 MR. STEINDLER: So I am puzzled as to why you did 21 not I guess.
22 MS. MOODY: Well, each one of those points 23 geologically speaking are very important. And it is not 24 only part of the effects on emplaced waste, but gaseous 25 outflow and potential changes in water level, and the future
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' of geologic and geochemical processes. Those are all 1
2 important. And in terms of post-closure, they are very 3 important. So to add to what Marty said, my question is why 4 did you not address each one of those points.
5 MR. STEINDLERI: We pre saying that DOE does not 6 have to account for these. They have to account for all of 7 the items explicitly in analyzing the performance of seals 8 over a long period of time. At this time, we did not have 9 sufficient guidance for DbE to give on these issues, and we 10 chose not to include that in the technical position.
11 MR. MOELLER: On the gaseous outflow with respect 12 to the source term, I presume that DOE in testing the waste 13 canister or the spent fuel itself and so forth will have 14 data on that or that they are gathering data on that?
({ }
15 MR. GUPTA: Would you repeat your question, 16 please.
17 MR. MOELLER: In terms of gaseous outflow, are 18 there not data being gathered to determine the source term, 19 what you would anticipate in the way of gaseous outflow over 20 X number of years of spent fuel storage?
21 MR. GUPTA: I am not familiar with that part of 22 the program. There is nobody here to answer that question.
j 22 MR. MOELLER: Now back on the comments by Doctors 24 Moody and Steindler, you have explicitly stated in the 25 technical position that these items are not -- well, you say
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39 (j 1 that they are not explicitly addressed, but have you 2 explicitly stated that they are not explicitly addressed?
3 MR. GUPTA: It is stated up front in the 4 introduction that we have not explicitly addressed these 5 items in the technical positign.
6 MR. MOELLER: Okay,.
7 MR. VOILAND: Would you expect that these various 8 environmental changes that might occur would have any 9 different effect on the seals than it would have on the host 10 rock itself? It seems to me that this would be a secondary j 11 or tertiary order effect.
12 MR. GUPTA: Well, some questions were raised 13 earlier. The long-term effect could change the environment
(} 14 in the quantities of water that could come in. The teutonic 15 movements for example could affect the seal performance.
16 MR. VOILAND: It could upset the characteristics 17 of the host rock as well. ,
18 MR. GUPTA: That is true.
19 Just briefly summarizing some of the salient 20 technical positions that we have stated in this document.
21 The first one is we expressed the need for appropriate l
22 design features for DOE to reduce the need for seals. Just 23 to be on the conservative side, to use design features that j 24 the need for seals are reduced. For example by using l
l 25 appropriate construction controls by minimizing damage to l e (m) Heritage Reporting (202) 628-4888 Corporation
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[~y 1 rock mass. By locating the surface openings and locations
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2 where the infiltration of. water is reduced. l 3 On 0-listing, the position that we have taken is 4 that DOE should use NUREG-1318 to determine the Q-list. And 5- if seals are determined *not important to waste isolation, 6 then they can be removed from the Q-list. But if they are 7 included en the Q-list, then sealing activities should be 8 covered by an adequate QA plan.
9 MS. MOODY: I think getting back to your previous 10 slide that when you say that if seals are determined not 11 important to waste isolation, I think just that statement is 12 something that certainly not only in the public arena but 13 also in the technical arena can be argued. In other words, l 14 what DOE could be trying to state that it is not needed can O 15 be turned around and argued both technically and politically 16 that they are needed.
17 Has DOE put forward a paper at this point in time 18 that articulates why they think that sealing is not needed?
19 MR. GUPTA: DOE's current position on the Q-list 20 is that there is no item, zero items, even including this 21 package as any item on the Q-list. Because there is nothing 22 that they think is important to safety or important to waste 23 isolation. And that is where they are coming from.
24 The NUREG-1318 takes a position which is quite 25 different. It says that unless DOE shows otherwise that Heritage Re. porting Corporation p)
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(} 1 things are not on the Q-list that every item of importance 2 competence should be included on the Q-list. And it could 3 be removed if and when sufficient data is collected and you 4 can show in a reasonable manner that you do not need to put 5 it on the Q-list. ,
6 MS. MOODY: Then y,ou are stating that as far as 7 NRC's view is at this point then that there is not the data 8 available to prove that the seals or the waste package are j 1
9 not needed. So then by definition they are needed, or they l 10 should remain on the Q-list. I do not see where the data is 11 to prove that they can be removed.
12 MR. GUPTA: That is indeed our position at this 13 time, that the data is not sufficient to exclude the seals 14 from the Q-list.
15 Now with respect to the testing information 16 required at the license application time, we have taken a 17 position in the technical position that the preliminary data 18 from seal testing should become available before the license 19 application is submitted.
20 The next technical position deals with the 21 uncertainties in predicting the long-term behavior of seal 22 performance. And what we are stating in the technical 23 position is that in evaluating the overall system 24 performance that DOE should consider uncertainties in all 25 areas before they say that no allocation to seals is needed
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(} 1 in meeting the overall system performance objectives.
2 Just to recap the entire talk here. The sealing 3 concepts for unsaturated medium are very different than for 4 saturated medium. We are not talking about plugging the 5 water, but we are talking about pluggage and drainage for a 6 ?7ng time. And therefore we. thought that a technical 7 position and guidance on those design concepts is needed at !
8 this time.
9 The technical position provides one way of 10 complying with the regulations. And what we have emphasized 11 in the technical position is that DOE should use design 12 features to reduce the needs for seals, and collect enough 13 information before license application so that the staff can 14 evaluate whether technology is reasonably available to seal v
15 a closure. And then use redundancy and consideration of 16 uncertainties in analyzing the long-term performance of the 17 overall system.
18 MR. STEINDLER: A couple of questions. My reading 19 of the technical position paper that I have leads me to ask i 20 a number of questions. !
21 First off, am I correct in interpreting this !
22 document as being based on the assumption that the 23 Department of Energy's analysis are wrongly, namely that 24 they in fact will have to assign performance or allocate l
25 some measure of performance to these seals and therefore you l
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43 1 have written this document to guide them in that analysis?
2 MR. GUPTA: That may not be the way that I would 3 characterize it.
4 MR. STEINDLER: I am sure that it would not be.
5 But I am trying to see what the basic assumption was that 6 you used to even go to the trouble of writing this document.
7 MR. GUPTA: Our thinking at this time is that 8 there is no sufficient data avai2.able at this time to make 9 any conclusions one way or the other with respect to 10 allocating performance to seals. And DOE should collect 11 enough information and enough data so that reasonable 12 conclusions can be drawn based on the information from 13 in situ testing and lab tests.
14 MR. STEINDLER: That is not what this technic 21 15 position however states. The technical position gives an 16 outline of the approaches to be used based on the assumption 17 that there is a need for performance of a certain kind or at 18 a certain level of that seal.
19 MR. GUPTA: That assumption is on the basis that 20 if DOE decides to allocate performance after they have 21 collected information and data that then they should go 22 through all of this process.
23 MR. STEINDLER: Fine. The second question deals 24 with my topic on the release of gases. The introduction to 25 the technical position states as one of the goals of a seal, Heritage Reporting Corporation O (202) 628-4888
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(~ 1 I have forgotten precisely the words and let me look them
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2 up, but in effect to prevent, I guess is the word that you 3 used, prevent significant amounts of gases from escaping 3 4 through the shafts. There is an implied I think assumption 5 here, namely that that prevention is important.
6 Have you or the Department indicated that that is 7 a worthwhile endeavor and therefore should be part of the 8 technical position that the staff should take? ,
9 MR. GUPTA: Well, on the gaseous outflow from the 10 underground facilities, that is an area that Rvd is 11 undertaking at this time. The sense and opinion at this t 12 time in my judgment is whether DOE has conclusively shown at 13 this time that they do not need to rely on those, whether )
,_ 14 there is enough data available at this time to conclude .
k 15 that.
16 MR. STEINDLEk: I guess that I am confused. I do 17 not think that we are in the process of adjudicating the 18 32eue. I thought that we were in the process of defining le the position of the staff concerning bore holes seals. So I 20 an trying to find out why it is that repardless of what the 21 Department has written so far, why is that the staff 22 believes it necessary to insert in one of the major 23 objectives for these bore hole seals the significant 24 reduction of gaseous emissions.
25 I guess that what I am looking at is do you not
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1 have basically a sieve to air and other gases that you are l l
2 now trying to plug in four, five, or six different places, )
I 3 but the sieve remains. Why bother putting that kind of 4 requirement on seals.
5 MR. GUPTA: W' ell, first of all, let me address in 6 two different ways. Number pne, the escape of gases is 7 important from our perspective. In 1985 just to give you 8 some background, DOE submitted to us a preliminary f 9 performance assessment. ind the results that came out of 10 that analysis that DOE had made was that there was not much 11 of a problem with water 1.cflow but that for gaseous outflow 12 that there was a marginal factor of safety. And gaseous 13 outflow has been a concern of DOE as well as for the NRC
(} 14 staff.
15 Now how you can control it is another point here.
16 All of the manmade features, whether it is a shaft, or a 17 bore hole, or ramps add to the already openness of the 18 geologic setting. And I think that it would be prudent to 19 seal them in a way that you do not create more openings than 20 already exist. If you cannot show by analysis that it will 21 meet the performance, then DOE is in trouble with respect to 22 showing the suitability of this site. But whatever manmade 23 openings are there, I think that you can do something about 24 those, and that is what DOE intends to do.
l 25 The other point, as Dr. Moody pointed out earlier,
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1 1 if not anything at all you have to seal them up to avoid i 2 human int rusion.
t 2 3 MR. STEINDLER: Well, that gets me to my last i 4 question, namely how does the technical position document
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5 and the suggestions thab are pontained therein match the 6 need to have retrievability paintained for a certain period i 7 of time, has the staff examined that role and that issue?
8 MR. GUPTA: After closure?
9 MR. STEINDLER: Yes, post-closure.
10 MR. GUPTA: Jim, do you have any thoughts on that?
11 MR. WOLF: There is no retrievability requirement 12 after permanent closure, so I do not see that there is a 13 problem there.
14 MR. STEINDLER: Well, you do not see then that O 15 these shafts would be sealed between the completion of the 16 loading of the repository and the final closure, is that 17 what you are saying?
18 MR. WOLF: DOE certainly has the option to do that i
19 as long as retrievability -- in other words, you can ;
20 backfill during that time, but you must maintain the 21 retrievability option until permanent closure.
22 MR. STEINDLER: Then I take that to mean that this 23 technical position does not address the issues at all, so it 24 is based on the assumption that these seals would be put in 25 after the requirements for retrievability has expired?
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() 1 MR. GUPTA: We are talking about post-closure 2 seals, yes.
3 MR. STEINDLER: Well, there seems to be closure 4 and post-closure and really post-closure. We have heard a 5 number of criteria. Thhnk you.
6 MS. MOODY: One la,st comment. On the slide that 7 you have of this technical position when you say the very 8 first one, use of design features to reduce need for seals,
^
9 I mean I would completely reword that and say use of design 10 features to facilitate drainage in the repository 11 construction, all of the key she.fts and everything, waste 12 emplacement rooms. Because that is an important item that 13 you emphasized over and over again, that they want drainage.
f'N 14 Well, that is a key thing in the design features O '
15 that you could then say would facilitate perhaps not meeting I 16 the classic seal. What I am trying to say is to tell you 17 that the reduced need for seals is somewhat a supposition 18 that DOE is correct 4.n saying that they do not need them, 19 and I am not convinced that they are.
20 MR. GUPTA: A couple of things with respect to 21 drainage. Number one, whether they would remain effective 22 for a long period of time is a question mark. You can 23 definitely do something about reducing the infiltration by 24 locating the openings in a way and using the construction 25 techniques that do not create additional damage and pathways
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'l to facilitate water infiltration.
2 With respect to drainage, the thinking here is 3 that you are facilitating the drainage on uncontaminated 4 water. Now what happens if some water gets to the waste 5 packages and then the s'ame pathways become-rapid pathways 6 for radionuclides to the water table. So those are the 7 questions that one has to address in thinking about drainage 8 concepts.
9 MR. HINTZE: Mr. Chairman.
10 MR. MOELLER: Yes.
11 MR. HINTZE: Related to your first comment up 12 there. The main lever, as I understand it', for the change 13 in the technical position is the movement from a saturated e 14 to an unsaturated medium. I would suggest that perhaps not k
15 as important but certainly another major lever here is the 16 possibility that we do'have fracture flow rather than porous 17 medium flow. And in my reading of the document, this is not 18 brought out and is not emphasized.
19 And it would seem to me, and I have not thought 20 through the whole process myself, but simply the integrated 21 flux might be the same, the integrated flux of water might 22 be the same in fracture versus porous medium flow, but the 23 rate of that flux may be highly variable under those two 24 conditions. And I would think that would be a very 25 prominent factor in the effectiveness of the barriers or the
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' j 49 i 1 seals.
2 I think that one of my problems in reading this 3 document also is the fact that seals mean to me that you are-4 .really doing the job, that you have got 100 percent 5 efficiency in terms of hhe exglusion. It seems to me that' 6 there is a perception here when I started to look into this 7 that you are really talking about seals. But when I have 8 listened to you this morning that it is apparent that what i
9 we are really talking about are barriers and not necessarily 10 seals, and I think that there is a perception problem here.
11' MR. GUPTA: I agree with you. The term really has !
12 got a lot of room for confusion, confusing people. When l
- 13. they talk about seals, they imagine some plugs or really
- 14 controlling the water. But you are talking about isolating 15 the water and facilitating the drainage.
16' MR. STEINDLER: So it is quite different.
17 MS. MOODY: That is a totally different concept.
18 then.
19 MR. GUPTA: Right.
20 MR. MOELLER: A couple of other questions 21 continuing on this subject. It seems to me that in.your 22 technical position of course you say that, " Provisions for 23 rapid drainage of uncontaminated water through the 24 repository horizon can reduce the risk of water contacting 25 the waste packages." So you are encouraging or it sounds i
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(_/ 1 like you are encouraging DOE to quickly get rid of any water 2 that gets in or near the repository.
3 Then you say, "However such a drainage system can 4 also provide pathways for rapid flow of contaminated water 5 to the accessible environment," So as I read it, you aro 6 giving them a carrot and then you are taking it back.
7 While both statements are undoubtedly true, I do not know if 8 they are totally compatible. That is just on reading in it.
9 Some questions.' When was the decision made that 10 you would handle this as a technical position versus 11 rulemaking or how do you make that decision, I suppose that 12 is a legal statement?
13 MR. GUPTA: Brian, do you want to handle that.
() 14 MR. THOMAS: Brian Thomas, waste management, the 15 directorate staff. The decision was made to proceed with 16 this as a technical position in early January 1988 upon 17 review of the DOE CDSP. And the decision on rulemakings per a
18 the division's policy is to try to clarify uncertainties,
[
19 regulatory uncertainties, in the regulations. The technical 20 position is more for the purpose of conveying to DOE 21 criteria that if used by DOE, of course they have a choice 22 to use other criteria, but if used it would be acceptable to 23 the NRC as a method of demonstrating compliance with the l 24 regulations.
l 25 MR. MOELLER: Having said that though, then if you i( ) Heritage Reporting Corporation (202) 628-4888
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. i 51 I) 1 look in here, one of the major statements deals with 2 uncertainties. "The staff has recognized that large 3 uncertainties are likely to persist in evaluating the 4 longevity and long-term effects of seals." And you tell 5 them to control these uncertainties and so forth. So it 6 would sound like it was an ipeal subject for rulemaking.
7 MR. THOMAS: .The rulemakings focus more on 8 ambiguities and clarifications needed in the regulations.
9 Technical positions focus on the technical uncertainties 10 which are indeed derived from some regulatory uncertainties, 11 but the technical uncertainties deal more with the DOE's 12 methodology for demonstrating compliance. Their tests and 13 analyses and that type of detailed technical information.
14 MR. MOELLER: Okay. Thank you.
( ')
15 MR. GUPTA: Dr. Moeller, if I could amplify on 16 that. There are four areas in this technical position that 17 could be reasons for considering rulemaking versus the 18 technical position, and we have been talking about that for 19 some time. Number one, in the technical position, we have i 20 taken up the subject of sealing the ramps and the 21 underground facility. And the rule does not talk about the 22 sealing of the underground facility or ramps. It basically 23 talks about bore holes, shafts, and bore hold and shaft 24 seals. So that could be one reason for considering whether 25 you can extend bore holes and shafts seals and underground n
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() 1 ' facility seals.
2 The second point would be the concept of the 3 drainage itself. The way that the regulations are written, 4 they do not really explicitly deal with tha issue of 5 . drainage as a concept fbr seals. And that could be another 6 reason for considering or cl,arifying the regulation itself 7 rather than addressing it in the technical position.
8 One of the more important points is on the 9 treatment of the fractures and faults for gaseous pathways.
10 There is no provision in the rule which explicitly talks 11 about those issues and what could be the requirements for 12 those.
13 And lartly, we do not touch on that in great detail here, but there has been some discussion as to how
'( ) 14 l 15 much data that we can really require DOE to provide us at 16 license' application time. The rule is clear but not very I 17 explicit. And if one were to taking rulemaking aside, one 18 could clarify these issues as to when DOE should start, how 19 much testing, and provide how much data at license 20 application time.
21 MR. MOELLER: Okay. That is helpful.
22 Once again when will DOE probably begin their 23 testing of their seal designs?
24 MR. GUPTA: DOE's position that they are mainly 25 going to focus on laboratory testing for quite some time.
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- Will focus on what?
2 MR. GUPTA: ' Lab and bench scale tests.
3 MR. MOELLER: Okay.
4 MR. GUPTA: And would not start in situ testing in 5 the underground main teht area when they go about testing 6 for the exploratory shaft facility. The interpretation that 7 doe has of the regulation is that our rule does'not require 8 them to initiate any in situ testing before the license is 9 issued to them for construction purposes.
10 MR. MOELLER: Another comment. On page eight of 11 your technical position, you point out once again that the 12 shafts, bore-holes, and the seals shall be designed to 13 assure the releases of radioactive materials, this is item 14 number nine,'to the accessible environment following 15 permanent closure conform to EPA standards. That, you know, 16' is a major statement, because this committee has looked into 17 the problems of confirming conformance with EPA standards, 18 and those we think are quite complicated. Well, I think 19- that takes care of my comments.
20 Don, did you have anything?
21 MR. ORTH: Well, I have been jotting down notes.
22 I have not had any real questions.
23 MR. MOELLER: Full your mike over, Don. Thank.
24 you.
25 MR. ORTH: It was more or less advice to other Heritage Reporting Corporation O~' (202) 628-4888
54 I 1 people rather than questions. If even there is a small 2 probability that seals might be decided on, DOE really 3 should proceed as if they are needed. Even if.they are not 4 allocated performance, the public perception may make it 5 very prudent. And the hechnical position, you asked the 6 question why would they proceed with it, it would be very 7 useful for DOE in guiding the work that they need during 8 characterization regardless of how they are going to decide.
9 MR. MOELLER: Yes. I think that Dr. Moody had 10 . brought up that point. And the whole thing is that you can 11 save yourself a lot of time if you simply acknowledge at 12 this stage in terms of public perception that the public 13 will see a seal as needed. Bill.
14 MR. HINTZE: There are comments in the paper that 15 we have looked at here regarding minimizing the number of 16 drill holes. I think that somehow or other if that could be 17 emphasized some bit that it would be worthwhile. As we 18 noted in an analogous type of approach to EPA standards 19 regarding landfill sites and filling into landfill sites and j 20 the possible contamination of the water table, it is very 21 important that one perform as many tests as possible of an 22 indirect nature that are non-intrusive into the volume that 23 is of concern.
I 24 And I think that it would not be a worthless 25 exercise to emphasize that as the site characterization g Heritage Reporting Corporation I s_) (202) 628-4888 I
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\s,) 1 proceeds that a lot of thought be given to this early one
'2 .before holes start to be punched into this, that we maximize 3 the amount of information that is obtained from the drill 4 holes and we do that with non-destructive geophysical types 1 5~ of tests. ,
6 MR. MOELLER: Thank you.
7 MS. MOODY: The number of drill holes that 8 especially will penetrate through the saturated into the 9 unsaturated whether they-are hydrological, geological, or 10 geoseismic should be a minimum number just in terms of the 1 11 total long-term usage of that rock unit itself as a 12 particular potential repository.
13 MR. MOELLER: Martin.
, 14 -MR. STEINDLER: I do not want to sound like I am 15 arguing.against motherhood and apple pie, but it seems to me 16 that that' statement, that the' concerns about-the number of-17' bore holes which are perhaps somewhat secondary to the 18 = technical position on barriers, and I think that~ Bill's 19 poi.'t is exactly correct that this really should be renamed, 20 that that point might make a whole lot more sense if someone 21 were to do the quick arithmetic and ask how many bore holes 22 fully opened with no barrier in them at all are necessary to 23 match the permeation for example of a ten inch pressure 24 difference in the repository, permeation of gas.
25 Where are the flows that we are really concerned l
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,/ ,) 1 about, how much material.in the case of gas for example do 1
2 you get out through five bore holes in relation just to the 3 plurosity of the strata that have direct connection to the 4 outsid~ If that turns out to be an obvious result,.namely 5 you better not have mor'e than,five before you match porous 6 flow with bore hole pipe floy, then I think that one could 7 at least semi-quantitatively say to the Department hey, 8 fellows, you may have a problem.
9 But until that is done, and I do not have the 10 foggiest feel for.what kinds of numbers that one is likely 11 to come up with, until that is done, other than saying gee, 12 you really ought to limit the number of bore holes, I am not 13 sure that we could give the Department any great advice that
() 14 they do not already have reasonably on hand.
15 I would as a matter of policy in this document, my 16 feeling is that if you'are going to talk about barriers to 17 bore holes,'I think that is one thing in this document. But 18 you ought not to mix advice concerning the number, and what 19 you do with them, and so forth and so on in this document 20 with the commentary that relates to the quality of the seals 21 for example. I think that this ought to be a clean document 22 that should have a single topic in it. That is just a 23 comment.
24 MR. HINTZE: If I may, Marty, I think that that is 25 an excellent point. And a furtherance of it would be that O ritae- gerti e (202) 628-4888 cereeratien
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l' there may well be a couple of faults that provide a 2 sufficient amount of vertical movement that would just 3 overwhelm, that would just swamp out the effect of any drill l
4 holes. And this is part of yourt suggestion of really doing l
5 some calculations on some performance that is early on, 6 geologically as well as manmpde.
l 7 MR. MOELLER: Okay. I think that with that that 8- we will wrap this up and take a break. Before we do, let me 9 thank Dr. Gupta for a very well done presentation. It is 10 good to talk to an engineer.
11 MR. GUPTA: Thank you.
12 MR. MOELLER: Thank you.
13 (Whereupon, a recess was taken.)
14 MR. MOELLER: The meeting will resume. The next 15 item on our agenda is a summary of the public comments on 16 the draft technical position on post-closure seals in an 17 unsaturated medium, and our speaker is John Buckley. I 18 might mention that he is also an engineer.
19 MR. BUCKLEY: Good morning. My name is 20 John Buckley. I am also with the Engineering Branch, 21 Division of High Level Waste. It is my pleasure to be able 22 to speak with you this morning to give you a brief summary 23 of the public comments that we received. And my focus this 24 morning will generally be to try to tune into those comments 25 which were not in 100 percent agreement with the NRC staff.
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(~) 1 Before I start a summary of the comments, what I l %J l 2 thought that I would do is run through the major steps in j 3 the development process of the technical position.
l 4 (Slides shown.)
5 As you can se'e from,this slide, the development of 6 this technical position started in January of 1988. An 7 internal draft was presented and completed in June of 1988.
8 That draft was then passed around through the NRC staff for 9 review and comment, and a'public comment draft was completed 10 in September. Based on the comments received from the 11 public, that draft was then revised, and what we know have 12 is the final draft technical position which was what was 13 presented to the ACNW for review.
,, 14 Now I would like to focus on a discussion on the
15 public comments that were received. As can be seen from 16 this side, the NRC received four sets of public comments.
17 The U.S. Bureau of Reclamation provid.ed three comments. The 18 U.S. Geological Survey provided one comment. The State of j 19 Nevada provided 32 comments. And the Department of Energy 20 provided 30 comments. That was for a total of 66 public 21 comments.
22 As you may recall from your review of the 23 technical position, the technical positions themselves are 24 organized in four main topic areas. What this slide 25 presents are the number of comments that were received in f Heritage Reporting Corporation I
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L l 59 (m_) 1 each of those technical position areas. I have also added a 2 fifth group which I call here introduction to take up any 3 slack which includes the comments which were general 4 comments on the content of the technical position as well as 5 comments on the introduction and Section 2 of the technical 6 position. ,
7 As can be seen here, the majority of the comments 8 which were received focus on the introduction section or 9 general comments as well as on the Section 3.1 of the 10 technical position which is design considerations.
11 What I would like to do now is to give you a brief 12 summary of the major public comments that were received.
13 The Department of Energy and the State of Nevada expressed
(} 14 sharply contrasting views of the overall worth of this 15 technical position. In the transmittal letter from the DOE 16 transmitting their public comments to the NRC staff their 17 letter says, "In general, we believe that the staff has 18 prepared a good technical position, a draft which will lead 19 to useful regulatory guidance."
20 On the other hand, the State of Nevada points out 21 that this technical position provides a little guidance or 22 insight into how the NRC will review the performance 23 assessment and design. And it further goes on to say that 24 the entire technical position could have been summarized by 25 saying that the design of the seals should be such that they t
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1 meet the performance objectives of 10 CFR 60.
i 2 Actually we received three comments on the 1 3 introduction or general comments on the content of the 4 technical position. The first one here was from the State 5 of Nevada. And it says*that,,"The technical position 6 appears to be deficient in regulations regarding drainage."
7 The NRC's point of view on this topic is that 8 although the regulations, 10 CFR 60, do not specifically 9 mention drainage, since DbE has listed drainage as an 10 integral part of their sealing system that we right now at 11 this time feel that the sealing requirements are adequate.
12 The following two comments listed on this slide 13 come from the Department of Energy. The second comment that
(~)
v 14 is listed on this slide from the DOE says that, "The 15 technical position contains guidance on topics which are 16 inappropriate for this'particular technical position. "
17 They state examples such as overall system performance that 18 is mentioned, and quality assurance is mentioned. Location j
, 19 of shafts, ramps, and bore hole seals are mentioned. And 20 they feel that those are inappropriate.
21 The reason that the staff put these topics into 22 this technical position is that we feel that any topic which 23 may have an effect on the performance, the design, or the 24 testing of seals should be included in this technical 25 position, and that is why they are in here. I
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. 1 The last comment on this particular section from 2 the DOE says that the technical position imposes new F
3 requirements which have no basis in 10 CFR 60. Again as
! 4 Dinesh pointed out earlier, technical positions are not 5 meant to be regulations *. They provide an approach for 6 meeting the objectives of 10.CFR 60. Inerefore DOE really 7' has no obligation to take any of the guidance that we have 8 as a regulation.
9 MR. STEINDLER: What sort of new requirements did 10 DOE allude to when they made their comment?
11 MR. BUCKLEY: One example that they pointed out 12 was in the technical position it states that all bore holes 13 should be sealed to provide "a factor of safety". And they 14 are correct, that is not in the rule. There is nothing that O 15 says that they have to have a factor of safety. However 16 like we say, it is just guidance.
17 MR. STEINDLER: Why did you put it in?
18 MR. BUCKLEY: It was put in, because technical 19 positions are not meant to be regulations. They are 20 guidance and they provide an approach that DOE can use, an j 21 acceptable approach to the staff for meeting the regulations 22 of 10 CFR 60. As Dinesh pointed out earlier, there is a 23 fine line that you must run betwean 5#oviding guidance and ;
24 expanding on the regulations.
25 MR. ORTH: Did anybody have any idea what the term l
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('l 1 factor of safety meant in that context?
w/
2 MR. BUCKLEY: It was not expressed in the 3 comments, so I would not want to address that.
4 MR. MOELLER: Dr. Gupta.
t 5 MR. GUPTA: What we,are talking about here is the 6 design. Even if a performance is not allocated to a seal 7 component, the staff feels that it is prudent on the part of 8 DOE to provide redundancy in the design of all of the 9 system. So that in case that they have been able to 10 evaluate and collect enough data to show demonstrably some 11 performance of certain components but providing redundancy 12 or making sure that you have some margins available in the 13 design. You can never define a factor of safety in any p 14 given case.
L/
15 MR. BUCKLEY: The State of Nevada provided to 16 significant comments rbgarding Section 3.1 of the technical 17 position which deals with design considerations. The first 18 of Nevada's comments says, "The technical position should 19 assume that seals are important to waste isolation and thus i 20 should be included on the Q-list."
21 In the second comment, which is slightly 22 inconsistent from the first, tho State of Nevada says that, 23 " DOE should not rely on seals for any contribution to waste 24 isolation."
25 In response to both of these comments on this
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( ,) 1 particular topic, the NRC staff would agree more closely 2 with the first comment by the State of Nevada. Our position 3 is, as Dinesh pointed out earlier, that seals should be 4 assumed to be important to waste isolation and should 5 therefore be put on a Q'-list yntil such time that DOE can 6 show that they are not important to waste isolation.
7 Three significant comments were presented which 8 address site characterization considerations. And that is 9 Section 3.2 of the technical position. The first comment is 10 by the State of Nevada. The State of Nevada contends that 11 shaft and ramp locations should be such and can be such that 12 thej eliminate any potential for run-off of surface water 13 into the underground facility.
f (~3 14 The NRC comment to this particular statement is LJ 15 that the NRC cannot dictate to DOE the locations of shafts, 16 and ramps, and bore holes. The location of shafts and ramps 17 must be such that they are consistent with meeting f 18 performance objections of 10 CFR 60. If they are, the NRC l
19 cannot dictate their locations.
20 The following comments, comments two and three i
l 21 listed on this particular chart, are from the Departiumnt of 22 Energy. Again these comments go back to similar questions 23 which I addressed in the general comments. DOE states that, 24 " Shaft and ramp locations as well as bore hole locations and 25 the numbers of bore holes should not be included in this
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- 1. technical' position and are inappropriate topics."
2 -Again as I stated earlier, and as I think that
'3 Dinesh has pointed out,' topics which are or can be a factor 4 in determining the performance, design or testing of the 5 seals-should be include *d in this technical position, l
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8 9
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,(') 1 . MR . BUCKLEY: DOE presented the only major comment
. %.J 2 or significant comment regarding Section 3.3.
3 MR. STEINDLER: Excuse me. Let me take you back 4 to that last thing that you commented on.
- 5. MR. BUCKLEY: 'Okay.,
6- MR. STEINDLER: Is,there another technical 7 position either out or in preparation that deals with shaft, 8 ramp and borehole location?
9 MR. BUCKLEY: Currently there is not.
10 MR. STEINDLER: So this is the only place where 11 that issue is addressed?
12 MR. BUCKLEY:- Currently that is true.
13 MR. STEINDLER: And you claim that this is really 14 as an adjunct to the central focus of sealed barriers rather
' O. 15 than having to do with something that in fact gives guidance 16 on location of these mining operations.
17 So you don't really expect them to take that 18 seriously, is that what you are saying?
19 MR. BUCKLEY: I guess I'm not following your 20 question.
21 MR. STEINDLER: Well, if you were simply 22 restating, I guess my point is if you were simply restating 23 a technical position that relates to shaft and ramp l
l 24 locations, and you were doing it here in order to be 25 complete in the discussion of the quality and performance of ;
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s l k_) 1 seals and barriers, that I think is one issue.
2 But if this is the only place as you have j
3 indicated that the whole question of location of shafts and ]
4 ramps is mentioned in a technical position, then I am 5 confused as to what you* expect the department to do.
6 Do you expect them,to pay attention to the 7 prescriptions that you have provided on the location of 8 shafts and ramps, even though the subject of the technical 9 position does not really deal with location; it deals with 10 what you do with them after you have drilled a hole and you 11 want to now plug them up.
12 MR. GUPTA: Could I address that?
13 As you stated in the earlier portion of your
() 14 question, the description or the discussion on the location 15 and the number of boreholes has been included in this 16 technical position for' completeness sake.
17 As far as the basis is concerned, it is basically 18 a reiteration of 10 CFR 60.15.
19 We have not taken up any new ideas that the j 20 regulations require where and how many boreholes DOE should 21 be using for site characterization.
22 So it is not really a requirement that has been 23 added in any way to the technical position. It is basically 24 for completeness sake, a reiteration of what exists in the 25 regulations already.
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) 1 MR. STEINDLER: Would you not describe the
)
i 2 discussion in the technical position as being at least more 3 expanded than what you would find in the specific regulation 4 60.15?
5 MR. GUPTA: W'e might have some additional 6 discussion, but just for clarification, we have not added 7 any new requirements on where and how many boreholes should 8 be located.
9 MR. STEINDLER: Let me just make the comment that i
10 you think I think would not be too unhappy if the department 11 were to totally ignore as a method of proscription the shaft 12 and ramp discussion, because it is simply ancillary to the 13 seals issue.
14 Is that right?
[')S 15 MR. GUPTA: I am not very clear on --
16 MR. STEINDLER: Well, I guess I am trying to find 17 out whether it is obvious how you want the department to 18 react to the comments in a technical position dealing with 19 barriers and seals to commentary on shafts and ramp 20 locations.
21 MR. BUNTING: I am Joe Bunting.
l l 22 The motion that I understand the Staff has was, 1
23 back in an earlier slide that Dinesh gave, our purpose in i
24 addressing the location was to minimize the damage that 25 would have to be compensated for with the seals.
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~T 1 That was the only consideration that we had in (d
2 addressing that was it is kind of like what the discussion i
3 the technical review board had about the construction 4 techniques.
5 Rather than u' sing one technique which would cause 6 expanded damage zone, then trying to compensate for that 7 through some sealing technique, use some technique that 8 avoids that damage so that you do not have to rely on seals 9 to provide any performance.
10 That was the only indication, connection we had 11 with the shafts and seals.
12 MR. STEINDLER: Fine. I appreciate that 13 discussion.
,- 14 I have made the comment that I thought that this 15 technical position does stray on occasion from the specific 16 and somewhat narrow topic of barriers and seals and there 17 may be some advantage of paying attention to that particular 18 criticism.
19 MS. MOODY: What you are saying here in your 20 response is simply that NRC is only concernen with 21 performance objectives. That is what you are saying.
22 MR. BUCKLEY: What I am saying is that as long as 23 the DOE meets the performance objectives, NRC Staff cannot 24 dictate to the DOE the locations of shafts and ramps.
25 Does that answer your question, or is there (N Heritage Reporting Corporation t (202) 628-4888
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(,, 1 something else you would lip.e to ask me? l l
2 MR. MOELLER: I thought, though, and I am not sure i 3 I followed everything, but I thought the location of the i l
4 shaft and the ramps could very much influence the 5 probability or possibility of, water intruding into the 6 facility. .
7 So from that point you have argued in the past 8 that in fact you had asked that the shafts be relocated, the 9 positions be relocated.
10 Now, I guess though, continuing on with what Dr.
11 Steindler said, if the seals are being designed to 12 accommodate any flow that gets down the shaft, then what 13 pertinence does it have? Or why did you then discuss the
() 14 location of the shafts in the ramp?
15 MR. BUCKLEY: The locations as discussed in the TP 16 were only put there for the purpose that they may affect 17 either one, the performance of the seals, two, the testing 18 that is required, or to come up with a final seal design, or 19 three, the design of the seal.
20 So if it does not, if the location of the shafts 21 and ramps do not affect one of those three items, then it is 22 not intended to be covered here.
23 As I understood Dr. Steindler's question earlier, 24 I think he was wondering whether or not the NRC Staff was 25 planning on addressing location of shafts and ramps in some D
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(} 1 other technical position for some other purpose.
2 Is that -- ?
3 MR. STEINDLER: No. Almost. But in effect you've 4 got a Section 3.2 entitled site characterization 5 considerations. ,
6 You give five poinks that strictly interpreted 7 have very little to do with the barrier performance itself.
8 So I am trying to be a little more narrow in my 9 interpretation of what this technical position should 10 address.
11 And then I look at that comment from, those two I
12 comments from DOE and I sense that they have the same 13 concern I do.
,f g 14 Namely, it is not very obvious whether your
\-)
15 technical position paper as currently written would suffer 16 severely if you knocked out that whole section called site ;
17 character 12ation considerations.
18 MR. GUPTA: Could I address that, eir?
19 MR. STEINDLER: My conclusion is that if you took 20 those out, there are five items the rest of the technical 21 position could stand on its own without any serious damage.
22 But that is a viewpoint rather than an obvious l 23 conclusion.
24 MR. GUPTA: One of the major positions that we 25 have taken in this technical position document is that it Heritage Reporting Corporation
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) I would be difficult for DOE to demonstrate that seals were 2 lost for the time period for which they are required to l 3 perfora if they take credit for it. !
4 MR. STEINDLER: Right.
5 MR. GUPTA: Ahd therefore, it is prudent for DOE 6 to minimize the need for sea,ls. j i
7 Now, how do they go about doing that? l l
8 To minimize the need for seals you have to 9 minimize the possibility of infiltration of water into the 10 underground repository, and with respect to gaseous outflow, 11 what can be done with respect to any design features that 12 can be handled.
13 Now, for infiltration there are a certain few 14 things that can be done.
(( )
15 Like you can locate your openings in a way at 16 -elevations at the ground surface where the possibility of 17 infiltration is less than at some other locations that may 18 be considered for those openings.
19 So obviously that is a pertinent point, a 20 pertinent position in our view and very germane to the 21 overall technical position on seals.
22 MR. STEINDLER: Fine. I don't think it is worth 23 pursuing our discussion.
24 I think I have made my point and so have you.
25 MR. BUCKLEY: Moving on I guess then, DOE l l
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1 - presented the only major comment regarding Section 3.3 of
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'2< the technical position which deals with performance 3- confirmation considerations.
4 DOE' contends that the technical position presumes 5 that license application data,will be collected under the 6 performance confirmation program.
7 The'NRC Staff position on this particular topic.is-8 that although 10 CFR 60 requires performance confirmation 9 program to begin during site characterization, the' data may 10 not be available to support license application.
11 Therefore, the Staff believes that any data which 12- is required for seal design must be collected during the.
13 site characterization program rather than the performance 14 confirmation program.
15 MR. MOELLER: I don't understand the difference.
26 The performance confirmation program must begin 17 during site characterization, but data collected during that 18 program may not be available to support the license 19 application.
20 Data to support the a license application must or 21 should be collected during site characterization.
22 You have said the performance confirmation program 23 is going to be done during site characterization. So 24 therefore then why wouldn't the data be available?
25 MR. BUCKLEY: Let me give you a very brief 1
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.73 L( [ 1 discussion on this.- If it is not clear I would like to turn 2 it over to Jim Wolf who is a member of OGC.
3- The performance' confirmation program is required 4 to be initiated by 10 CFR 60 during site characterization.
5 The intention *of the performance confirmation data 6 is that it will be used to verify the analyses used in.
7 making the licensiag findings.
8 Therefore, performance confirmation data is 9 actually a, it is a_ post-closure usage or. post-licensing 10' usage.
11 Site characterization data is that data which is 12 used to make licensing findings.
13 MR. MOELLER:. Are the data collected under the 14 performance confirmation program subject to QA?
(}.
15 MR. BUCKLEY:- I believe so. ;
i 16 . Why don't I turn this over to Jim Wolf if he is 17 available? i i
l' 18 MR. MOELLER: I am totally confused.
19 MR. BUCKLEY: Yes.- It is not a topic which 20 confuses many.
21 MR. BUNTING: If Jim is not there, I'll take it.
22 MR. BUCKLEY: Joe, go ahead.
23 MR. BUNTING: I am Joe Bunting again.
24 It goes back to the icgal basis for what we can 25 require.
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() 1 My understanding in that this was the subject of 2 an intense discussion among the staff and I think with the 3 advice of General Counsel it was the, we would be better 4 . served to rely on 60.24 which had to od with data to support 5 the license application *, rather than to rely on division of 6 60.140 which is performance confirmation.
7 The reason being is that the intent of performance 8 confirmation in 60,140 was to make data available to the 9 Commission and the Staff at the time of closure.
10 So it is all oriented to providing information at.
L 11 the time of closure to verify all these assumptions, 12 analyses and things that you have based your construction 13_ authorization decision and tian the decision to emplace
/~T 14 waste.
V 15 So the notion there was we were leaning on the 16 wrong provision of the' regulation to require information 17 available, to be available to the staff during a license 18 application, l 19 We would be better served to find our support l
20 under Section 60.24. 1 21 We still want the same data. It is just which 22 section of the regulation do you invoke your authority for.
23 MR. MOELLER: That helps.
24 MR. BUCKLEY: The State of Nevada provided one 25 major comment or one significant comment regarding Section
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- (,) , 1 3.4 which deals with performance analysis considerations. j 1
2 The state contends that seal design and testing 1 3 program should be developed prior to any shaft sinking or 4 borehole emplacement.
5 The NRC Staff
- posit $on on this is that a test plan 6 for collection of data to support seal design should be in 7 place prior to construction of the ESF.
8 However, test program implementation of that test ;
9 plan should be started as early as practicable and may not 10 be started prior to construction of the ESF.
11 MR. MOELLER: Well, now, the ESF is. supposed to 12 begin this Fall or Winter or something as I recall?
13 MR. BUCKLEY: I think the data is slipping
(} 14 continually.
15 The last I heard for construction of the ESF 16 exploratory shaft was November?
17 MR. MOELLER: Yes, well, Fall or Winter 18 MR. BUCKLEY: Right.
19 MR. MOELLER: What -- so the test plan for the 20 collection of the data must be in place before next November 21 and the testing program, you are encouraging them to begin 22 it just as soon as they can?
23 MR. BUCKLEY: Implementation of that test plan or 24 the test program should be initiated as early as 25 practicable.
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MR. MOELLER: And again that would be laboratory and benchtop work?
3 MR. BUCKLEY: The test plan I believe would 4 include -- it would be laboratory test, bench scale and 5 underground testing. .
6 MR. MOELLER: Oh, pkay.
7 MR. BUCKLEY: And finally, I would like to quickly 8 summarize --
9 MS. MOODY: Do you know is DOE working on this 10- test plan?
11 MR. BUCKLEY: DOE, in their -- Dinesh, do you want 12 to answer?
13 MR. GUPTA: Yes. In the site characterization 14 plan they have identified their test program, yes.
15 MS. MOODY: Thank you.
16 MR. STEINDLEk: How can there be underground 17 testing if you haven't sunk the exploratory shaft yet?
18 MR. GUPTA: This is a plan for testing, not the i
19 actual testing, sir.
20 We are talking about the test plan.
21 MR. STEINDLER: Oh, just the plan.
l 22 MR. GUPTA: Right.
23 MR. BUCKLEY: Right. -
24 And to quickly summarize the public comment 25 package.
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(_) 1 Again, there were 66 comments received. The NRC 2 is in agreement with the majority of the comments. The j 1
3 comments were well thought out, well presented and in fact 4 the TP was revised and 32 changes were made as requested.
5 So 32 of the ' comments were taken verbatim and the 6 TP was revised. , j i
7 And finally, the NRC has not identified any major 8 areas of significant technical differences with the public 9 commenters.
I 10 And I would be happy to take questions.
11 MR. MOELLER: Okay. Bill?
12 MR. HINZE: Could you tell me who was, within the 13 United States Geologic Survey, was requested to make !
(~N 14 comments? Was this the group that was actively involved in l
%,)
15 the characterization of the site up to this time or was this 16 just a general review group?
17 What was the knowledge base as far as Yucca 18 Mountain goes?
19 MR. BUCKLEY: The comments were solicited through 20 the Federal Recister notice and provided on that bas 3a.
21 MR. HINZE: I see. They were not explicitly 22 requested from the United States Geologic Survey?
l 23 MR. BUCKLEY: No.
24 MR. MOELLER: Other? Gene?
25 MR. VOILAND: In Section 3.4, Item 3, it says the
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/(_)~ 1 analysis of overall system performance should consider the 2 possible consequences of partial or complete failure --
3 MR. BUCKLEY:. Excuse me. I am having a hard time I 4 hearing you.
5 MR. VOILAND: 'I'm sorry.
6 It says in Section,3.4 Item 3, it says the
'7 analysis of overall system performance should consider the 8 possible consequences of partial or complete failure of 9 seals and/or drainage oveb 10,000 years.
10 I would just like to ask why was that number 11 chosen rather than some other number?
12 MR. BUCKLEY: Dinesh?
13 ILt. GUPTA: Yes. This is with regard to the
(}l 14 performance objectives.
15 The EPA standards are required to be met for a 16 lifetime of 10,000 years. And that is where the number 17 comes from.
18 MR. VOILAND: I think this afternoon I am going to 19 have some comments about that. ;
20 MR. MOELLER: Okay.
21 Any other questions or comments for Mr. Buckley?
22 (No response) 23 MR. MOELLER: Well, we thank you.
24 And I think then if I understand our agenda, Dr.
25 Gupta, did you have any other items?
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MR. .GUPTA: .No, sir.
21 MR..MOELLER: Okay. Well,.I think with that.we 3 will bring to a close the formal portion of this' morning's 4 agenda and the Committee will go into Executive-Session,.
5 .still open to the publi'c, to have;a general discussion of.
6 this. topic, and decide, I think we are all in agreement that 7 we will' develop some sort of a report to send'to the 8 Commission on this. And the main thing we will'do between 9 now and Noon is decide what are the key comments or items 10 that we include in our report.
11 So with that, I will declare this portion of the 12 meeting recessed and.we will not.have a recording of the 13 Executive Session. .
14 (Whereupon, at 10:55 p.m., the formal portion of.
- 15. the mees.ing recessed, to be followed by an unrecorded 16 Executive Session and a luncn break, to reconvene on the 17 . record at 1:00 p.m. on the same day, Wednesday, April 26,
'18 1989.)
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i l 3 MR. MOELLER: The meeting will not come to order. I 4 The principal item for discussion this afternoon 5 is the following subjech: the preliminary findings of the 6 Waste Confidence Review Group. I 7 And what we planned to do on this was to have as 8 we agreed at the working group meeting last week to have a 9 summary which I will present of what we heard; and I guess l 10 everyone was here except Dr. Steindler and herd the detailed 11 half-day review.
12 So I will summarize, and there may even be errors 13 in my summary. But we will then ask Dr. Parry to add to it f;- 14 and then each of you.
(>)
15 And then we want to avail ourselves of the Staff 16 in terms of answering questions that may have developed in 17 the interim and questions that Dr. Steindler in particular 18 has and then we will, once we have done all of that we will ,
19 go into Executive Session and see if we can prepare some ]
20 written comments for the Commission on it.
21 Now, I did prepare a two or three or four page 22 summary and that should have been run off?
23 MR. PARRY: Yes.
24 MR. MOELLER: Okay.
25 MR. PARRY: We have it in a combined form,
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2 this afternoon or' tomorrow morning in preparation for the 3 meeting with the Commission, i
4 MR. MOELLER: The waste confidence portion is for )
l 5 this afternoon. ,
6 Could we pass that.out to them then?
7 MR. PARRY: Yes.
8 MR. MOELLER: It is the first three pages in this l 9 item.
10 While Jack is passing it out I will tell you 11 roughly what I wrote down from last week. And the other 12 important thing to put on the record and for Dr. Steindler 13 to know was that at the meeting we, for the first time 14 -received a copy of the preliminary draft of the Waste 15 Confidence Review Group's report.
16 We had not seen it prior to the meeting. It was l 17 given to us at the meeting. Of course they went over it and 18 we in the meantime now have had an opportunity to read it.
19 okay. In terms of my summary, I would offer the ;
20 following comments:
21 First of all, we met for half a day with Robert 22 Banero on April 19 and he reviewed the status with us.
23 I thought it was a very clearcut presentation.
24 I asked him how the review group was appointed, i'
l 25 how the membership was selected and he said that they were l ,
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82 1 selected for their expertise and to assure that all the 2 potentially impacted offices within the Commission were 3 represented.
4 And he pointed out that each team member had an 5 alternate'and that everybody was heavily involved. And I ..
6' think that came out rather clearly in the discussion that it 7 'was really a team effort and everybody had had a chance for 8 input.
9 He also brought to our attention and reviewed the i 10 existing waste confidence statement and that is the original l 11 review'was the result of the petition from the NRDC which 12 requested a decision on whether radioactive waste from j 13 nuclear power plants could be safely disposed of.
~
14 And they suggested that the NRC not. grant any 15 additional operating licenses until a satisfactory finding
~
l 16 had been made.
- 17. He also pointed out that that original confidence 18 proceeding was done on a specific plant basis, that is, that 19 'it was done for Prairie Island and Vermont Yankee.
20 As you will see in a few minutes, that is one of .l 21 the changes that we want to make that the Staff is proposing 22 be made in the revised statement. l 23 Now, the 1984 findings of the waste confidence !
24 review are listed, the five findings.
25 They concluded that disposal in a repository was Heritage Reporting Corporation
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,m 1 feasible, that at least one repository would be available by 2 the year 2007 to 2009, somewhere in ' hat time period.
3 Again, that is where we have a major change in the new l
4 findings. And that sufficient capacity would be available 5 within 30 years to disp *ose of,all spent fuel and high-level !
6 waste that had been generate,d.
7 They thirdly concluded that spent fuel can be 8 safely stored for at least 30 years. They felt that and 9 also concluded that sufficient onsite or offsite capacity 10 for interim storage would be available as needed. And 11 since, however, this decision involved predictions of what 12 is going to take place in the future, or to occur in the 13 future, they said that every five years they would revisit
(~3 14 their decision and reconfirm it or modify it as necessary.
\/
i 15 And the schedule, why we have to do our work at 16 this meeting, is that the staff is to submit a proposal to l
17 the Commission by May 12, next month, and the Commission 18 then will decide by May 31 whether it will be published and 19 if they agree to its publication the public will have until l
l 20 September 1 to comment.
l l 21 And then by December 15, the staff will have 22 revised it as appropriate and will be ready to issue the 23 final document.
24 Now, the key changes as my notes indicated are as 25 follows -- the key changes, that is, how will the new Heritage Reporting Corporation
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4 84 I 1 decision compare with the old one, what will be the changes:
2 Well, the first one, which I think essentially 3 everybody would agree with, is that the time frame, the year 4- 2007 to 2009, as' Bob Banero said, you know, 2008.plus or 5 minus 1 is totally non-healistic.
6 And so.they propos,e that they say that at least 7 one, that it is their prediction that at least one mined 8 geologic repository will be available within the first 9 quarter of the upcoming 21st Century.
10 And so that certainly is a much wider time span 11 and a more realistic prediction.
12 Then secondly the Staff believes that it will be j 13 possible that-spent fuel can be stored for up to 100 years.
() 14 Now, we need to call on people like Don Orth for 15 comment on that. Certainly they are not talking 100 years L
l 16 under water. They are' talking dry cask storage the last 17 part of that.
18 But they are saying 40 years would cover the 19 Initial operating license of a typical power plant. Then if l
20 ycu extend that license for 10, 20, 30 years more, you are f 21 up to 70 years and then you store it 30 more waiting to get l 22 it into the repository.
23 So they tried to pick a time frame that gives them 24 the flexibility that they need.
l 25 And then lastly, I should have probably said it in
() Heritage Reporting Corporation (202) 628-4888
i 85 1 1 the first one, is that the new confidence statement is 2 written on a generic basis. They are divorcing it from any 3 specific plants.
4 I am sure no one has any problem with that.
5 Now, to offer *a few more comments that came out of 6 the discussion, Mr. Banero s, aid that it was his opinion that 7 the need for an MRS is now to use his word, moot, quote 8 unquote. And with the development of highly acceptable dry 9 cask, onsite storage systems, simply the need for an MRS 10 almost disappears.
11 Of course we could say unless you consider the MRS 12 as the facility that fixes the waste in a form to put it in 13 a repository, then you might or you do need something but 14 you may not call it an MRS and it certainly is not there to 15 provide interim storage on any longterm basis.
16 Mr. Banero showed us four or five or six slides 17 which I found exceedingly useful.
18 He showed us the Surrey, I guess it is PWR 19 concrete cylinder storage casks that were located out on a 20 concrete platform.
21 And then he showed us the GE dry system which I 22 would call a mausoleum or something like that, in that you 23 move the cask over to this big concrete vault and it is like 24 slipping a casket into the --
25 MR. VOILAND: The new home system.
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,r 3 1 MR. MOELLER: Yes, the new home system. Thank you I (22 )
2 Gene. Slipping a casket into the vault. Instead of dead j 1
3 people you put in dead waste, and shut the door. But it !
4 looked pretty good to me.
5 Then next the NRC Staff provided the ACNW with a 6 preliminary draft and we all.need to review it. But I am I
7 sure that Bob was very straightforward with us, Bob Banero.
8 There are no hidden zonkers in the written report. He told 9 us everything that is in it.
10 Now, I wrote down just some questions that the 11 Committee might want to debate or consider. And let me go 12 over those and then we will call on Jack for comment and 13 call on any of you for comment.
14 But some questions that I wrote down:
15 One: What is our confidence that a high-level 16 waste repository can be constructed within the time frame 17 indicated by the NRC Staff?
18 Now of course Bob said that, I think he said and I 19 am sure he said, that his timeline accounts for Yucca 20 Mountain being declared unacceptable and then moving on to 21 somewhere else.
22 The second question: Will the NRC Staff be able 23 to demonstrate that the facility proposed by DOE will meet 24 the probabilistic standards promulgated by EPA?
25 And that came up this morning and it is going to e, Heritage Reporting Corporation
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i 2 Third: Need we consider the delays in the l
3 acquisition and analyses of the data needed for site 4 characterization?
5' As Lincoln sald, I guess I will "long remember" 6 Dr. Lehman's elegant presentation to us a month or two ago 7 on-that. It was one of the best I have heard and it sticks 8 with you.
9 So we need to think about that.
10 Four: Decommissioning wastes are to be considered 11 separate from this. That was just a key point. That is not 12 a question.
13 Banero stressed that when you are decommissioning 14 a plant of course the fuel has all been removed and you 15 don't mix up decommissioning wastes into this discussion.
16 That, to repeat, is a comment, not a question.
17 The next one: If orderly onsite dry cask storage 18 is available, the pressures for the repository are l 19 considerably released.
20 Now, having said that, it is still important to 21' note that Congress will not accept this approach and that is
..,, 2 2 why they have been hesitant on the MRS. They want the w
23 repository built and they want it put into operation.
24 I don't know how though you factor into it the 25 onsite dry cask storage, if it is working beautifully, and Heritage Reporting Corporation O (202) 628-4888 l l
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88 1 you know, it certainly takes the pressure off from the 2 repository. So I guess it is Congress' problem.
3 Marty, you have problems?
4 MR. STEINDLER: I am a little confused, as usual.
5 The topic is waste confidence rulemaking --
6 MR. MOELLER: But it includes --
7 MR. STEINDLER: -- which is originally driven by a 8 Court injunction or Court order. ;
9 MR. MOELLER: Yes.
10 MR. STEINDLER: If I read the Court order right, 11 you are required to address this in relation to both the 12 time schedule and the license termination.
13 NRC has apparently elected to set aside the time
() 14 schedule and set aside the license termination issue.
15 Was there any discussion at all during the course 16 of the meeting that the NRC believes they can get away with j 17 that?
I l 18 MR. MacDOUGALL: I would like to suggest that Bob 19 MacDougall, who is the senior person on the Staff, or John, 20 respond to those questions after this introductory talk.
21 MR. STEINDLER: Okay. Because some of the 22 discussions that I have heard, some of these questions are 23 interesting and probably in the larger sen'se pertinent, but 24 I think seem to be outside of my interpretation of what the 25 driving force for that rulemaking is.
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1 And if that is an issue inat we need to at least O 2 highlight to somebody --
3 MR. MOELLER: Well, could we go ahead with it now?
4 This is as good as any. Please, go ahead.
5 MR. MacDOUGALL: I'm Rob MacDougall with the 6 Office of Nuclear Materials pafety and Safeguards, I am 7 working on the waste confidence review. ,
8 Does the overhead projector work?
9 MR. MOELLER: Sure. Go right on up, string on a 10 mike and we will-hear you. j 11 MR. MacDOUGALL: Well, Dr. Steindler, I think I i i
12 would open my response by saying that the Commission 13 considered this question at the outset of what became of the
{
14 1984 waste confidence decision.
15 In its original Federal Recister notice in October 16 of 1979, it consciously went beyond the scope of what the 17 Court had ordered, to assess generically the degree of 18 acsurance now available tha* radioactive waste can we safely 19 disposed of -- and you can see it up there on the slide --
20 and determine when such disposal or offsite storage will be 21 available and to determine whether the waste can be safely 22 stored past the expiration of operating licenses until 23 offsite disposal of storage is available.
24 The Commission considered --
25 MR. STEINDLER: Would you say that is still within I
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() I the framework of what you believe the Court's message to you 2 guys is?
3 MR. MacDOUGALL: Well, it was intended to be 4 responsive both to the Court's remand which was focused on a 5 narrower issue of wheth'er there would be disposal by the end 6 of the available -- by the epd of the operating licenses for 7 the two reactors in question.
8 And then whether the spent fuel, if not, whether 9 the spent fuel could be safely stored onsite.
10 The context of the reactor licensing proceeding I 11 think, and we have an attorney here who can correct me if I 12 am wrong, limited the scope of the question that the Court 13 remand could deal with.
() 14 And the Commission decided that the itch the 15 interested public really wanted scratched was the question 16 of when disposal would'be available and in effect the issues 17 laid out in the waste confidence Federal Reaister notice.
18 MR. STEINDLER: Your comment then is that that l 19 statement that is currently up on the board not only include 20 what the Court remanded to you folks but also the larger 21 question that the then Commission believed to be of interest 22 to the public?
23 MR. MacDOUGALL: Yes.
24 MR. STEINDLER: But it included both?
25 MR. MacDOUGALL: That's right. ;
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'l 91 1 MR. STEINDLER: Thank you.
2 MR. MacDOUGALL: And it, and that scope still 3 controls for the purposes of this review.
4 'MR. STEINDLER: Okay. That is really my. question.
5 MR. MacDOUGALL: Yes.
6 MR. STEINDLER: I ,see. All right.
7 MR. MOELLER: Thank you.
8 Let me see. Finishing up my comment, and I am not 9 sure all of these are questions:
10 They pointed out to us that Yucca Mountain 11 protably will not be able to hold as much waste as Congress 12 has set as the limit for the first repository.
13 So another question is: Can spent fuel be held 14 safely for 100 years? Again, as I say, we have to look to 15 Gene Voiland and Don Orth for that.
16 Then last - ' and I thought this was probably one 17 of our key comments, even though I didn't get to it until 18 last, and that was: Has the NRC Staff, in our opinion, 19 considered a sufficient number of scenarios in looking 20 toward this decision, you know the various pathways that 21 activities may actually follow, have they looked at enough 22 of them?
23 And this may need decision on our part.
24 And so with that, Jack, could you offer any 25 comments you may have?
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1 MR. PARRY: I will not address technical 'l 2 questions. I will merely try and give you some
.3 administrative refreshment or refresh what you have been 4 given.
5 Last night yob received a package that was the 6 summary of the working group, meeting, contains the handouts 7 that you had originally.
8 Those are also included under Tab 3 in the
~
9 notebook.
10 I prepared a summary of the meeting itself, trying 11 to point out the specific points that were made by 12 individual members, by Dr. Moeller and individual 13 consultants.
() 14 In addition, I have just circulated'to you 15 comments by Mr. Voiland, and perhaps, Mr. Chairman, you j 16 would like to have him' elaborate on them.
17 MR. MOELLER: Yes. Gene, would you go over in 18 detail your comments? Pull a microphone over.
19 And I think we ought to ask the Staff wither 20 before or after Gene to comment on this scenario thing.
21 MR. PARRY: They are prepared I believe to respond 22 to all questions.
23 MR. MOELLER: What does the Committee prefer? To 24 talk about that now or later?
25 MR. HINZE: Why don't we let Gene do his?
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93 rg 1 MR. MOELLER: Okay. Lets let Gene do his, b 2 MR. HINZE: But when we do the scenario thing it 3 might be worthwhile for us to listen to the Staff talk about 4 these six diagrams which lay out scenarios, so we can get a 5 base of where they are bhinking.
6 MR. MOELLER: Good. point, Bill. ;
7- Okay. Gene, you go ahead and then we will do the 8 scenarios.
9 MR. VOILAND: I wa very pleased to receive a copy 10 of the preliminary draft, and really could hardly wait to 11 get at it and read it.
12 It turned out it reflected very well, as Bob 13 Banero presented to us, excellent. And I will just read a 14 -few of these comments.
?\
\2 15 I said that the document is well and clearly 16 written. It reviews the findings of the 1984 waste 17 confidence deliberations in a systematic manner and in the 18 light of technical advances and legislative changes, 19 particularly the effects of the 1987 amendments to the 20 Nuclear Wasts Policy Act.
21 In general, the review group found no reason to 22 abandon the conclusions previously reached that successful 23 disposal of spent nuclear fuel and high-level waste derived 24 therefrom could be accomplished and that extended interim 25 storage until the availability of the disposal repository Heritage Reporting Corporation O (202) 628-4888
9 94 1 posed no significant additional risk to public health and 2 safety.
3 Perhaps the most significant changes in the 4 rationale for the relatively few changes in wording of the 5 findings were one, the recognition that the earlier 6 congressionally-established timetable was no longer, if it 7 ever was, attainable, and that it was prudent to project 8 availability of the repository to some time in the first 9 quarter of the 21st Century; and two, that the actual 10 demonstrated accomplishment of dry storage of aged 11 commercial reactor fuel at reactor sites gave added ,
1 12 confidence in the successful, longterm storage of spent fuel 13 in the event of a long delay in commissioning the disposal 14 facility.
15 Such a delay could conceivably occur if the 16 congressional decree to quality sites successively rather 17 than in parallel turned out to have been a bad decision.
18 . Failure of the Yucca Mountain site to qualify 19 could perhaps result in a 25 year delay in availability.
i 20 The principal conclusion was that the various 21 changes could have profound effect on the timing of 22 beneficial use of the repository, but no real effect on the 23 confidence that the facility could and would ultimately be 24 operative.
25 The Review Group emphasized it was far better to l
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(,) .1 do the job right than strive to meet timing goals which were 2 not of great significance.
3 Then I had a number of specific comments. And 4 they are just that.
5 And they were*put dpwn here really for our Staff 6 to use if they felt they werp of significance. And I am not .
7 going to address many of those.
8 MR. MOELLER: Well, hit the highlichts. And let I 9 me just say for the purpose of the record that we do have 10 the memo from Gene Voiland and it will certainly be made 11 available to the Staff.
l 12 MR. STEINDLER: That is correct. j 13 MR. MTELLER: Yes. I would suggest that it be
~T 14 made available to the Staff because it points out typos and (G
15 so forth and'that way we get the benefit of your review.
16 So hit the highlights.
17 MR. VOILAND: I think the one comment that I felt 18 may be worthwhile is considering the capacity of the 19 repository, because that came up time and time again.
20 And the capacity of the repository is stated in 21 terms of metric tons of heavy metal or initial heavy metal, 22 specifically with a limit of 70,000df for the initial 23 repository.
24 This may make sense from a political perspective, 25 but it certainly does not from a technical point of view.
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96 1 Technical capacity will be dictated by the. volume O 2- of the waste packages, which could be affected by rod t 3 ' consolidation, thermal output of the waste and the heat 4 dissipation characteristics of the site.
5 But the delay *in availability of the disposal 6 facility, theoretically the beat output of the fuel will be 7' reduced and a more dense storage rate could be accommodated.
8 Also, the technology of rod consolidation could 9 improve.
L 10 A corollary of this is the undesirability of 11 transferring green fuel to the repository as the higher heat i
12 output would reduce the capacity because of thermal 13 dissipation considerations.
14 Another consideration is the specific effect of 15 higher fuel burnup in the reactor.
16 One effect is the reduction in the number of fuel 17 assemblies requiring disposition. However each assembly 18 does contain a greater amount of radioactive material.1 19 This effect only appears after a number of years 20 when the short-lived radionuclides? are decayed away.
21 A long term effect is the change in the nature and 22 quantity of actinide elements for the same amount of power 23 generated by the extended life fuel.
24 If it has not been done it would seem reasonable 25 to evaluate the technical capacity as a function of fuel I
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2 MR. MOELLER: I think again on this, Gene, I am 3 almost positive the limit is congressionally mandated and we j i'
4 just can't. But you have acknowledged that by saying it is 5 political. ,
l 6 MR. VOILAND: I think it would be worthwhile to '
7 know what you might call the stretch capacity of the i
8 facility could be -- i 9 MR. MOELLER: A good point.
10 MR. VOILAND: -- in the event that Congress 11 decides maybe that the 70,000 was not accurate.
i 12 MR. MOELLER: That would be interesting.
13 Jack, you had a comment?
() 14 MR. PARRY: Yes. I wanted to mention, and I think 15 it came out during the discussion about at least for example 16 Calvert Cliffs where they are going into dry cask storage.
17 The intent there is that they will dry cask 18 storage their oldest fuel and that it will be retained in 19 dry cask storage and fuel will go out of the pools into the 20 repository. So really newer or not the oldest fuel.
21 So I think your point about heat loading is one to 22 which the Staff may wish to address itself.
23 MR. VOILAND: I had a comment about that.
24 Bob mentioned that the DOE policy was to move 25 -coalesced fuel. And I guess my reaction is that what will
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2 that relieved before you go start going back as Jack has 3 suggested here into stored fuels.
4 But I think they may have to revisit that policy 5 decision. ,
6 There just a couple of items having to do with the 7 curves that were presented showing the amount of fuel that 8 would be put in dry storage, assuming their considerations 9 are correct.
10 It turns out to be quite a bit. It turns out to 11 be 500 tons of dry storage for each reactor.
12 All I did there was take a look at the quantities 13 of fuel which their curves indicated were in dry storage, 14 and did the division by year, et cetera.
Os 15 So that might be something to look at.
16 'There is quite a bit of money associated with that t
17 and I thought that the consequences of extended delay in the 18 availability of the repository could benefit from a 19 reasonably detailed impact analysis.
20 MR. MOELLER: Now, who should do that? Is that l
21 something DOE, you are suggesting DOE do it? Is this 22 something the NRC Staff would want to do?
23 MR. ROBERTS: I had two questions going. What was 24 tho question, Gene, on the cost of the extended storage at 25 the reactors?
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2 large extension in terms of time --
3 MR.-ROBERTS: Right.
4 MR. VOILAND: -- that means there will be more dry 5 storage and more cost ih that,and other consequences. )
6 And it would just seem to me that if DOE for 7 example changes its scheduling as a result of this -- as a 8 matter of fact it seemed to me that the presentation was a 9 good basis for some kind of a schedule -- then it would be 10 just reasonable to evaluate what that impact would be. ;
11 MR. ROBERTS: Well, I think we did touch on this 12 question.
13 MR. VOILAND: Yes.
14 MR. ROBERTS: Not from the point of view of the 0 15 impact, but pointing out that in terms of the Commission or 16 the Staff's conclusions on the Commission of certain 17 reasonable assurance, that given the regulatory situation 18 where the facilities are licensed, that of course the 19 utilities would remain in possession of the fuel and under j 20 the regulations could not abrogate that.
l l- 21 However, we also noted that DOE had made certain, 22 you know --
23 MR. VOILAND: That's the 1998 decision point?
l 24 MR. ROBERTS: Right. Yes. And that we suggested 25 that it would be prudent that things be resolved amicably r'g Heritage Reporting Corporation
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1 and early to avoid basically the type of uncertainty you are 2 talking about.
3 MR. VOILAND: That was clearly brought out and I l
4 really believe that is an important thing to do. There 5 shouldn't be any surpri'ses really to --
6 MR. STEINDLER: I am not sure I understand what 7 you are going to do with the data if you find out that a 8 ten-year delay cost you $60 billion.
9 I mean, you know, what are you going to do about 10 that?
11 MR. RODERTS: That's the point.
12 MR. STEINDLER: What are you going to do with the !
13 information --
/"T 14 MR. ROBERTS: Exactly.
V 15 MR. VOILAND: -- if it becomes 1-1/2 mils per 16 kilowatt? I don't think that's the case. But it does have 17 an economic impact.
18 MR. STEINDLER: Well, I am sure it does. But the
- 19 impact, you know, whether or not that impact is a taxable 20 issue isn't subject to just an economic analysis of what I
21 happens if DOE screwed up their schedule.
22 MR. MOELLER: Excuse me. This must have been 23 calculated to some degree because in the licensing support 24 system, which we are going to review tomorrow, whenever it 25 is, it is $200 million a year. Someone has already I
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2 So I don't know what the basis is, i
3 MR. VOILAND: Jack?
4 MR. PARRY: I would expect that the MRS Committee 5 will be taking this as 'an alt 9rnative into account. I don't I 6 know that thy are but I would expect that they might be. )
7 I might mention that you will be shortly receiving 8 an article by Luther Carter that was provided by Dr. Moody.
9 In that article he goes through an extended review 10 of the history of high-level waste management in general and 11 then makes what I thought was a rather cogent suggestion 12 about co-location of an MRS facility that could be sited ;
l 13 where you think you might have the repository so that you 14 could have the storage capacity there. i
}
15 Of course that would mean change in at least two 16 aspects of the Federal' law which one prevents co-location 17 and the other limits the capacity of the reposi&ory to 18 15,000 metric tons, besides other problems with timing and i 19 so forth.
20 MR. STEINDLER: Limits the capacity of the MRS.
21 MR. PARRY: 15,000 tons.
22 MR. STEINDLER: Yes. You said the repository.
23 MR. PARRY: Excuse me.
24 MR. STEINDLER: Or I thought you did.
25 MR. MOELLER: Well, Yucca Mountain is very close
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1 to California. You could put the MRS just across the l (G)i 2 border.
3 Gene, go ahead.
4 MR. VOILAND: That would make it fall off into the 5 Pacific. ,
6 (Laughter) .
7 , MR. PARRY: We could get Bill some work and put it 8 near the San Andreas fault.
9 MS. MOODY: But remember, we have a whole 'nother 10 issue that I have never heard anybody mention with respect 11 to the MRS or one of the things that does become very 12 important, once you saw it, and talk about moving the spent 13 fuel, dry of wet from Point A to Point B is a whole, all of 7s 14 the issues tied with transportation.
O 15 And I do know from my bit of involvement .ayself 16 with respect to the SALT program that that is also, that is 17 a major difficult issue.
18 So-there is another side totally to this question.
19 That is, keeping the waste at the place where the power 20 plant is has with it a sort of a cushion with respect to all 21 of the issues related to transportation.
22 MR. MOELLER: Gene, go ahead.
23 MR. VOILAND: A small comment on the LSS. Mostly 24 I guess because of ignorance, and I'm looking forward to 25 discussions on that.
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'h 1 I really have a question as to whether that is 2 going to speed up the licensing process.
3 The reason I say that is that if you read 10 CFR.2 l 4 as it stands today it really is a pretty good process. If 5 it is followed, I think'it is, efficient and it won't get you 6 in trouble, ,
7 On the other hand, what has happened is that it 8 has been abused and the NRC has allowed it to be abused, in 9 my judgment, and I can give you chapter and verse on that.
10 And I think, if LSS appears to be good, it is 11 going to have to be administered carefully. Otherwise, it l 12 will be abused.
13 These regulations are intended for people to
.14 . fulfill. If you find somebody that wants simply to cause 15- delay and obfuscate Congress and all the rest, they will 16 find a way to do it.
17 So this probably should be in abeyance.
18 And I have kind of the same feelings about
~19 negotiated rulemaking, since I don't understand how that 20 works well enough.
21 Again, AEC and the NRC have said that the purpose 22 of the regulation is to protect the health and safety of 23 people. There might be a risk that some of that could be 24 abrogated by negotiated rulemaking. I just feel 25 uncomfortable with that. It might be the best thing since O erie se aegerti=9 cerrer tie-(202) 628-4888 j l
104 rs 1 Crackerjacks, but I --
N-] l 2 MR. MOELLER: Any other comment before we go back 3 to the Staff and ask for a discussion of the scenarios?
4 MR. STEINDLER: Well, I have a series of questions 5 . I guess, let me toss 'out and see whether or not you 6 covered them. ,
7 MR. MOELLER: Fine. l l
8 MR, STEINDLER: I didn't find them in your i 9 writeup, Jack. But they may have already been covered.
10 A trivial one. One is in the documents that we 11 wore sent, the deadline was August of this year, for 12 completion and I thought I heard December as the new 13 schedule.
14 Again, what is the issue? When are we supposed to O 15 react to this? And what is the NRC deadline?
16 MR. PARRY: I believe that the Staff would like to 17 have a letter from the Subcommittee -- from the Committee, 18 pardon me.
19 MR. MOELLER: This week, 20 MR. STEINDLER: We've grown.
21 MR. PARRY: In the near term. By that, at this 22 meeting.
23 (Laughter)
- 24. MR. STEINDLER: Very clever. Okay.
25 ME. PARRY: Okay?
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() 1 MR. STEINDLER: But their schedule is August'then.
2 MR. PARRY: But this is the draft findings --
3 MR. STEINDLER: Yes.
4~ MR. PARRY: . -- that will go out for public 5 ' comment. ,
6 MR. STEINDLER: I ,see.
7 MR. PARRY: And then we will get another shot at 8 it. And the December.date is when the Staff projects 9 publication of the final findings.
10 MR. STEINDLER: All right.
11 MR. MOELLER: And the Commissioners will be 12- reviewing it in the next week or two and they want our 13 comments to help them.
. (^)
14 MR. PARRY: That's the principal reason for the
'q)
'15 request.
16 MR. MOELLER:' Fine. Fine.
.17 Go ahead. Marty.
18 MR. MacDOUGALL: Marty, just let me mention, there I 19 was not a lot of discussion because Dr. Moeller and the l
20 members, the consultants had not had an opportunity to 21 review the draft paper.
22 MR. STEINDLER: I understand.
23 MR. MacDOUGALL: And this is why the history may 24 be somewhat thin.
25 MR. STEINDLER: My questions at the moment are
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(~y 1 going to deal with frame of reference more than anything V
2 else.
3 Let me go back to my problem about time schedule.
4 In finding I guess number one, in finding number 5 one, is there a distinction made by the Staff on whether or 6 not a repository could be accomplished versus whether a 7 repository could be accomplished in the particular time 8 frame?
9 MR. MacDOUGALL: Yes.
10 MR. STEINDLER: There is.
11 MR. MacDOUGALL: Yes.
12 IR. STEINDLER: Okay. You make that distinction 13 consciously. That is why you bring in the first quarter of p_ 14 the next century?
+.1 15 MR. MacDOUGALL: Yes. The first question has to 16 do with whether it is technically feasible to safety dispose 17 in a mined geologic repository with --
18 MR. STEINDLER: Someplace.
19 MR. MacDOUGALL: -- scrupulous neutrality as to 20 the location or the timing.
21 MR. STEINDLER: Is it the contention of this group 22 that the number of options reviewed by the Staff to make 23 this generic determination that somewhere in this world you l
24 can build a repository to get rid of it, has been 25 sufficiently exhaustive to withstand antagonistic scrutiny? l
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2 MS. MOODY: Well,' generally -- generally you can 3 defend it.
4 But specifically, you are always going to place 5 yourself in the positio'n of being antagonistically 6 prosecuted just simply because of the geologic and 7 hydrologic complexity of certainly all the sites that DOE 8 has at this point in time considered in some manner or 9 another.
10 MR. STEINDLER: Okay. I mean, I'm excluding 11 frivolity. It's reasonably serious, but nonetheless 12 antagonistic.
13 MR. MOELLER: Don and then Gene.
I y- 14 MR. ORTH: I have a small problem. Are we b) 15 starting to go through this section page by page in essence 16 since you are starting'with finding one and start commenting 17 on it?
18 MR. STEINDLER: Oh.
19 MR. ORTH: Is that what we are to do now? What 1
20 are we supposed to do?
21 MR. STEINDLER: I was simply trying to get a frame 22 of reference within which you guys --
23 MR. ORTH: But he did not address things like 24 that.
25 MR. STEINDLER: Okay.
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2 sort of wanted to get his things on the table. !
l 3 MR. ORTH: We could start responding to his j i
4 questions, but that would also take up a fair amount of 5 time. ,
6 MR. STEINDLER: If.it's a new topic and if you j 7 didn't discuss it that's fine.
8 MR. MOELLER: Let's go ahead.
9 MR. STEINDLER: I just want to know whether it was 10 covered.
11 If it wasn't covered, let me go on to my next 12 question.
13 Can you tell me whether or not the rationale for i 14 that first quarter century was covered? I mean, it is 2035-i 15 and it isn't 2015, it's roughly the first quarter century. (
16 MR. MOELLER: Well, he didn't even say 25 years.
17 MR. STEINDLER: he said quarter century.
18 MR. MOELLER: He said a quarter century.
19 MR. STEINDLER: That is about 25 years.
20 MR. MOELLER: And I think he gave us, orally 21 Banero gave us some sort of a rationale for that.
22 He had the first Yucca Mountain being unacceptable 23 and another one being chosen and he came out that he still, 24 that enveloped, if that's a verb, or enveloped, the time 25 span.
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(')N 2 MR. MOELLER: That was his argument. )
3 MR. STEINDLER: So there was a discussion.
f 4 MR. VOILAND: He said you probably should find
]
5 Yucca Mountain wasn'tu s'ltabl9 if you are going to by the 1
6 year 2000. . j 7 MR. STEINDLER: I see. Okay. Okay. That does 8 it, basically, for frame of reference questions.
9 MR. MOELLER: Okay. Let's go with the scenario 10 discussion and then we will come back to individual .l 11 consultant comments and so forth.
12 MR. MacDOUGALL: I guess we confess.to some i
13 confusion as to whether the question about the scenarios is gs 14 directed more towards storage or towards repository
} (_) 15 availability or both.
l
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16 Can you help us on that?
17 MR, STEINDLER: I guess it was originally designed 18 to address repository availability. My personal view is I 19 have dismissed the problems that someone might raise in the 20 area of storage as being so reasonably handled even with a 21 modest amount of additional expenditure that I don't l
22 consider that to be an issue.
23 I do find less comfort in extrapolation by the NRC l 24 on the performance of a totally different agency.
I 25 If you guys were doing it, then you would have 1
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() 1 'some measure of experience on how you go about doing your 2 business. i 3 But you aren't. You are an interested spectator 4 to the process. That's why I'm looking at the confidence 5 that you are supposedly *having on somebody else getting the 6 job done. .
7 MR. MOELLER: But Marty, I think I am correct in 8 saying this. Let's not forget that in five years they are 9 going to revisit it.
10 MR. STEINDLER: Oh, no. I understand that. i 11 MR. MOELLER: So it is not irrevocable.
12 MR. STEINDLER: But the prediction is today for 13 the --
(} 14 MR. MOELLER: Correct.
15 MR. STEINDLER: -- next 40 years out or 30 years 16 out.
17 MR. MOELLER: Right. But even if they find they 18 are wrong in five years they will have to redo, they are !
19 going to redo it anyway.
20 MR. STEINDLER: But isn't this precisely part of 21 the problem? The Court in effect I thought had said we are 22 not going to continue this until you guys can tell us that 23 there is a way to handle the problem.
24 I doubt very much whether the Court meant you can 25 re-examine this thing every years and keep pushing the
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. I 111 1 deadline back until either the Judge is dead or something 2 else disappears.
3 (Laughter) 4 MR. STEINDLER: That is not, I think, what the 5 Court had in mind. ,
L 6 Now, I am neither ,a lawyer nor do I claim'having j 7 read the decision. But just on a pure rationality basis it 8 seems to me that somebody is looking for some reasonable 9 assurance.
10 MR. MOELLER: Maybe, is there a lawyer who can -j 11 comment on it?
12 MR. MacDOUGALL: I can quickly summarize, and 13 quickly be corrected ~if I am inaccurate.
14 MR. MOELLER: Okay.
O 15 MR. MacDOUGALL: I guess to begin with the Court 16 did not impose a Sword'of Damocles over the licensing of 17 these reactors. It let the NRC-approved license amendment 18 stand, and focused principally on the question of what 19 happens after the operating license expires. n 20 And so the 2007-2009 date came up pretty much as a 21 juridical artifact by virtue of the fact that that was when 22 these two operating licenses were due to expire.
23 And since the scope of the Court's ruling was 24 within the context of the license amendments at issue, it 25 really did not deal with the larger questions that the Heritage Reporting Corporation f^)
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112 gx 1 Commission felt they were probably trying to get at, having d 2 to do with the safety of disposal and when it would be 3 available, regardless of the expiration of the OLs of the 4 reactors in question.
5 I'm not sure that that's --
6 MR. STEINDLER: Well, no, that's fine, but let me 1.
L 7 play the devil's advocate and point out that what have you 8 done?
9 You have taken the expiration of the license and 10 said well, we don't think the repository is going to be 11 ready in the -year 2008 plus or minus one but we will push 12 the repository out to what we think is a more realistic 13 time, and then further we will declare that we can store the l s 14 fuel safely until that period of time.
15 Let me take you 15 years from now to the similar 16 hearing in front of a similar group going through the 17 similar process, having done it now three or four times. ,
18 I can envision the then Advisory Committee on 19 Nuclear Waste hearing from your counterpart or you saying 20 well, yes, the DOE repository is going to be late so we are 21 out in the year 2065, and oh by the way we think we can 22 store fuel safely for 200 years.
23 That is not an unnatural sequence, but I have a 24 hunch that you might get challenged on it if that is the 25 mode of proceeding.
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3 chastised. I am trying to figure out whether we are going 4 to get in trouble as we get further down the line with this
]
5 line of approach. ,
6 Okay. That is all,I am trying to do. I am not 7 sure it is resolvable. But that is what I am trying to do. )
8 MS. CYR: I am Karen Cyr. I am with the General
~
I 9 Counsel's office.
10 If the Court recognized that what they were 11 looking for from the Commission, I mean you are looking at 12 an environmental assessment in the nature of a prediction, 13 recognize that you are looking some years down the pike at 14 the time that'they remanded that decision to the Commission, 15 _meking some prediction whether they had reasonable i
- h. 16 confidence at the time' that the license expired that it 1
17 would either be disposed of or you could safely dispose of 18 it until at such time as that happened.
19 And the Commission made a determination that it 20 had such reasonable assurance, and it had a sufficiently 21 developed basis for reaching that conclusion, that in fact l
22 it had reasonable assurance, that you could store it while 23 you needed it, while it was onsite, and at that time we felt 24 that'there was reasonable assurance based on the information 25 we had available to us at that time that the repository Heritage Reporting Corporation i (202) 628-4888 o 1
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a 114 (m. I would be available then and that you could store it if need V
2 be. ;
3 So that we were looking at the environmental 4 consequences of letting the fuel continue to be generated 5 and the safety consequences of letting the fuel continue to 6 be generated and we reached ,a conclusion that we had 7 reasonable confidence that those were taken care of.
8 And I think this decision really follows on from 9 that. We are five years further down the pike. There have 10 been some good things and some bad thing happen in terms of 11 how DOE is approaching the program, but we've got more 12 information and we are reassessing that decision now and we 13 are still looking 20, 25 years down the pike. So I mean it
,, 14 is still very much in the nature of a prediction.
15 But that was, the Court recognized that at the 16 time that they remanded it to us. So that is what we are 17 doing, everything that we are doing because we are looking 18 so far along.
19 And so I don't think it is anything improper in 20 recognizing that that is what we are doing. We are making a 21 prediction based on the information we have available to us.
22 And we have a little better information today than 23 we had five years ago and so you ought to be more precise or 24 held perhaps a little more accountable than you were but you 25 are still looking a fairly long ways out into the future in
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'.( ) I trying to make that determination.
2 MR. STEINDLER: You have touched on a couple l
3 points.
4 But you know, one of the ones that strikes me is 5 that~we have had a little morp'information, therefore we are 6 trying.to be a little more precise, when in fact we have 7 loosened.up the thing.
8 We have said in'effect our backward look -- we 9 have gotten smarter I guess -- our backward look of 2007 to 10- 2009 was absurdly narrow.-We have moved this thing out now .
11 to a range.
12 You know, I am not suggesting that I have either a- l 13 better answer, which I do not, because I think you have done -
l 14 from what I can see all the possible homework that can be
}
15 reasonably done.
16 I am just trying to see whether or not there is 17 something that we should be looking at that is likely to get
-18 us into trouble someplace down the line. That is basically 39 it.
20 MR. MOELLER: We have a couple other comments.
21 But let me ask a question.
22 Who is it that decides whether your conclusions 23 are acceptable? Not you but the NRC's waste confidence 24 statement.
25 Who decides yes, it is fine.or no, I will not l O rie e- rerei 9 cerre (202) 628-4888 tie-
116 1 ' accept it?
2 MS. CYR: The Commission obviously in the first 3 instance makes the decision based-on the information that it 4 has.
5 MR. MOELLER: 'Okay.,
6 MS. CYR: And it is going to put out a proposed 7 decision which will be subject to public comment and we will 8 revise it as necessary to reflect those public comments, and 9 the Commission will again revisit it to determine, they are 10 really going to bc putting out a preliminary decision, 11 presuming they go along with what we send down to them on 12 May 12, that this is a basis for continuing to find 13 reasonable confidence. And then, presuming that 14 determination continues, then in December.
15 Now, at the time that we make that decision in 16 December, if someone thinks that we have not established an 17 adequate ba-is for our determination, someone could take us 18 to court and challenge that decision. .
19 MR. STEINDLER: So you are challengeable o this =j 20 rulemaking?
21 MS. CYR: It will be a final action of the agency l 22 when the Commission issues its decision in December. And if 23 so someone can establish that he has a basis to do so he may f
24 challenge'3%.
25 MR. MOELLER: Okay. That is helpful. Jack and Heritage Reporting Corporation O' (202) 628-4888 t
4 117 l b 1 then Gene. -
2 MR. PARRY: Karen, I noticed in the writeup, and 3 you used the term " reasonable assurance", does your 4 reasonable assurance that a repository can be made available 5 by the first quarter of* the npxt century, does that include 6 a licensed repository? .
7 In other words, are the regulations as presently 8 presumed demonstrable? Is that what 30ur finding concludes?
9 MS. CYR: I think our finding is that we are 10 determining that or making a prediction that there will be a 11 repository which will meet our requirements, not just that 12 there will be a hole in the ground but there will be 13 something which we have licensed or is licensable according 14 to our requirements, available when necessary.
({])
15 MR. PARRY: I would like to then remind the 16 Committee and the prevlous Subcommittee that.it had some 17 questions about the practicality of the EPA standard, Dr.
18 Okrent has mentioned those concerns. Mr. Voiland alluded to 19 them or touched on them this .aorning and may wish to 20 consider including or reminding the Commission of the 21 Committee's and Subcommit'.ee's prior views or concerns. (
22 MR. STEINDLER: I thought I just heard that the 23 issue was not licensability. I don't hear that word in here 24 at all.
25 MR. MOELLER: She said that --
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2 carefully.
3 MR. MOELLER: -- there would be a repository which I l
4 meets NRC licensing -- i 5 MS. CYR: Whi*ch meets our requirements.
6 MR. MOELLER: -- requirement. ]
7 MR. ROBERTS: Which meets our licensing 8 requirements.
9 MS. CYR: Right 10 MR. STEINDLER: I'm sorry.
11 MR. MOELLER: Gene? Pull your microphone back. I 12 MR. VOILAND: One other comment. Bob Banero did 13 address the question of whether the DOE management project 14 was adequate or not and he didn't say very much about that.
15 I noticed in the most recent news that I got that 16 there was a big hassle'about a contractor.
17 I presume that is for the construction and 18 operation of the site?
19 MR. PARRY: No, not necessarily. That is an 20 integrating contractor. I'm not sure it is total impact.
21 We do have a DOE representative here. You might want to 22 discuss it with him privately. But that contract has more 23 to do with the development of the license applications.
24 MR. VOILAND: Jack, is DOE essentially the manager 25 now for overall?
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2 MR. VOILAND: I guess I would ask the question, do 3 they have experience in that kind of management?
4 There are elements of the space program that 5 muddle along until they*put somebody in charge like Boeing ;
6 or whatever. ,
7 MR. MOELLER: We have of course, hitting upon 8 this, and I know that Bob Banero and his review grcup took 9 it into consideration.
10 If you read some of the Commission meetings and i 11 evaluations of DOE management they point out the high 12 turnover of their personnel, the fact that key positions 13 have gone untilled or with acting directors for long periods !
{} 14 15 of time and then Jack and I had recently been looking into the request I guess to the State of Nevada from DOE for 16 water rights which wers denied or was denied, whichever you 17 should say.
18 So there are a lot of complicating factors.
19 MR. PARRY: I think you will find a partial answer 20 to your question in th'- rticle by Mr. Carter that you will 21 be receiving, or at least an inferred answer.
22 MR. HINZE: Mr. Chairman, could I go back to some 23 concerns that I had that paralleled Marty's?
24 The two suggested changes in the findings are 25 major steps. They are quantum jumps as I see them ir. terms t
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2 I am wondering if anyone has really taken a look
! 3 at what might be the next five years. As one does this kind l 4 of thing, certainly you look ahead and that is part of it l
l 5 and I am wondering if the group that has brought this l
l 6 together has considered what,might be the requested changes 7 in the next five year review.
8 I look at the statements regarding the Staff 9 acknowledges that it is possible to spend fuel, maybe stored 10 up to 100 years, 11 If one takes the devil's advocate role, I wonder 12 if this isn't just preparing the public for the fact that 13 the next five years this is going to be extended even more
(~ 14 and is the Commission opening itself up to that kind of V) 15 concern and criticism by cushioning the public into the fact 16 that we can store this' for 100 or as someone said 200 years?
17 And I wonder if the staff that prepared this would 18 look ahead in their crystal ball on the basis of what is 19 onstream now as to what might happen in the next five years?
20 MR. MOELLER: On that point --
21 MR. HINZE: We would --
22 MS. MOODY: Excuse me a second.
23 On that key point of 100 years, Mr. Banero pointed 24 out that in the U.K. they had adopted the strategy of 25 storing it for 100 years before even thinking about a n
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2 And I think he used that as rationalization or )
I 3 justification. He did not present it that they are going to l l
4 make it 150 years later. l 5 MR. MacDOUGALL: To, answer your overall question, 6 Dr. Hinze, we would hope that our proposed revised finding 7 would cover the contingencies because our effort was to try 8 to come up with a sufficiently conservative estimate of what 9 is likely to happen over the reasonable foreseeable future 10 such that if for example the Yucca Mountain site did prove 11 to be unsuitable by DOE in DOE's judgment that the program 12 could still recover itself and progross from restarting or i
13 beginning from a new piece of paper on site screening to the
(} 14 actual operation of a repository within the first quarter of 15 the 21st Century.
16 The other point I think we might bear keeping in 17 mind concerning the 100 year storage is that it really 18 represents a 30 year increase in the existing Commission 19 expectation about the safety of storage, to cover the !
20 furthest known extent of license renewals.
21 MR. HINZE: That is excellent. I am just 22 wondering why your group felt that it was necessary to even 23 talk about this 100 years because I don't know whether I 24 want to trust the British or not, just like I don't want to 25 trust my own graduate students until I see the facts for
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2 MR. ROBERTS:' John Roberts. l i
3 I think I touched on this in, well, let's say the 4 Findings 3 and 4' touched on this.
One other fachor involved here is that we
~
5 )
d 6 realistically are looking at.not only what potentiallyson a '
7 shall we say pessimistic basis given as Gene Voiland noted 8 here that instead of three in parallel we have'one 9 repository and basically you are operating now in a 10, potentially. serious mode and basically a more or less 11 pessimistic assumption was made that potentially'you might 12 not, the first repository might not be it.
13 But beyond that we are also seeing that we seem
(} 14 likely at this point to get, we are already seeing an 15 extension of reactor licenses to full 40 years, it-seems j
~
16 like many of them are going that way. And beyond that, 17 renewal of licenses,.as Dr. Moeller noted, up to perhaps 20, 18 30 years.
19- So it -would be raore or less disingenuous of the 20 Staff to ignore these factors and come out with a view that 21- well, we are not going to see this one, when I think we
'22 realistically have to take into account these are the I
23 changes that are occurring in the industry and that we had !
24 best address them now and let the facts speak for 25 themselves, i
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- () 1 MR. MacDOUGALL: I think another thing that might 2 be helpful to bear in mind is that with the enactment of the 3 Nuclear Waste Policy Amendments Act in 1987 and the 4 direction to. characterize only one site for now, it really e 5 changed fundamentally the basis for our approach to this 6 question because we could no. longer assume that there would 7 be readily available alternatives to the site and that 8 preferred site is not -- I mean, that as a regulatory agency 9 we would not want ta) have our confidence rest on the 10 suitability of a site that had not yet been subjected to a 11 licensing proceeding.
'12 And so we felt that for our own sort of regulatory 13 integrity that we had to assume conservatively that Yucca
(} 14 Mountain would not prove out.
15 MS. MOODY: I think that is one point I was going 16 to make. When I read the whole thing in detail I was 17 impressed with the fact that I think you were more in terms 18 of projection of possibility that you did do a pretty good 19 coverage just simply because I agree with you 100 percent 20 that when we went down from three to one site that really is 21 a completely different game and completely different set of 22 possibilities than you had with you could go through the 23 detailed characterization of three sites.
24 It is a completely new game. Completely different 25 game than what we had been operating on for quite a long
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2 FR. MOELLER: Back on scenarios, what are the 3D principle scenarios you are considering?
4 We have heard a~ couple. One would be that Yucca i 5 ~ Mountain works out and *everybpdy is happy.
^
6 Two is that it' fails and. fails to meet the 7 requirements:and so.you start a second'one but you are 81 assuming there the second one works.
9 Now, if the second one doesn't work then your 10 schedule is all off.
11 What other -- maybe those are all the scenarios 12 you need? Is'that it? I mean what else is there,. from the 13 best to the worst?
14 MR. MacDOUGALL: One other possibility is that if
.O' 15 the White House gets around to appointing a negotiator there 16 is that avenue for.another site.
17 MR. MOELLER: Yes.
18 MR. MacDOUGALL:- So that the effort to find a-19 second repository could begin possibly before the 2007-2010 20 time frame.
21 MR. MOELLER: In fact that is a very good point to 22 make. That could be extremely helpful.
23 MR. VOILAND: That site has to be qualified just l 24 like any other site, i
25 MR. MacDOUGALL: Exactly. Yes. !
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2 comments. 1 3 Bill, do you have additional?
l' 4 MR. H1NZE: I just wanted to make certain that I 5 understood. ,
6 MR. MOELLER: Okay, 7 MR. HINZE: This figure 3 of the document, this is 8 the worst case scenario?
9 MR. ROBERTS: This figure 3 of the appendix on the 10 spent fuel projections? Is that what you are referring to?
11 MR. HINZE: Well, I thought it was just -- it's 12 the full document. It's on Page 125, sorry, 126. Or 127.
13 MR. ROBERTS: Is that total spent fuel versus
() 14 onsite inventory, figure 27 15 MR. HINZE: Well, and the following one, figure 3.
16 Figure 3 as i understand it is the one where no 17 repository is licensed by 2025.
18 MR. MacDOUGALL: Yes, I think it does represent --
19 MR. HINZE: And that is the worst case scenario.
20 MR. MacDOUGALL: It assumes renewal of licenses 21 for a substantial portion of the reactors which gives you a 22 different curve than DOE projections which do not make that 23 assumption.
24 MR. HINZE: And no geological repository.
25 MR. MacDOUGALL: Right.
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s 2 MR. MOELLER: Dr. Moody, do you have any 3 additional comments on the subjec't or questions for the 4 staff?
5 MS. MOODY: I*think,I'll hold for a while.
6 MR. MOELLER: Okay,.
7 And Don, what about you? I know you said you had 8 --
9 MR. ORTH: Is this general discussion we are 10 starting at this point?
11 MR. MOELLEF.: I think --
12 MS. MOODY: That is my point, too.
13 MR. MOELLER: Okay. Let's start general 14 discussion.
k' 15 MS. MOODY: Go ahead, Don.
16 MR. ORTH: If I am going to make general comments 17 --
18 MR. MOELLER: Can't hear you.
19 MR. ORTH: If I am going to make general comments, 20 I could start with what amounts to Page 8 on this draft 21 where it talks about the EPA standards which we have already 22 touched on a couple of times.
23 But there is a, the crux of the matter here was 24 that EPA has been, was remanded in July 1987 to start 25 promulgating some new rules.
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("'T 1 MR. MOELLER: What page again?
V 2' MS. ' MOODY: Page 8.
3 MR. MOELLER: Thank you.
4 MR. ORTH: Small print 8.
5 The second pabagraph there notes that it was July 6 1987 that the Court old EPA to get back and get some more 7 standards.
8 And they have been working along since then 9 presumably, and in cooperation with NRC.
10 Further down it notes that NRC believes it can 11 establish deterministic requirements not dependent upon i
12 probabilities to assure that DOE can do things.
13 And finally down on the next paragraph, maybe
- 14 grounds for concerned revised standards will be expressed in 15 a way that could make it difficult or even impossible to 16 evaluate compliance with probabilistic EPA requirements.
17 'To avoid this outcome the Staff will work closely 18 with EPA during its development of proposed revision to the 19 remanded standards.
20 The NRC Staff is confident that EPA will not 21 promulgate standards for which compliance cannot be 22 evaluated.
23 I think this is challengeable on the basis that 24 EPA frequently has continued on many fields, generated 25 standards on which it is almost impossible to evaluate
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1 compliance, with very little technical basis.
2 But that isn't my real problem. I think that 3 somebody will challenge that particular statement, probably 4 from industry.
5 But the point *being,that this is now middle of 6 1989, two years later after EPA was supposed to do 7 something.
8 Do we have any idea whatsoever when EPA is going 9 to get on with it, first of all.
10 Second, is NRC really actively working with EPA to 11 develop these standards?
12 MR. MacDOUGALL: The answer to your first 13 question, to the best of my knowledge I think the current
(} 14 projection is early 1990 for a proposed standard and the 15 answer to the second is yes, we are actively wor'cing with I 16 EPA.
17 I am not the best person to give you the 18 particulars on exactly what we are doing, though. If you i
19 like I can provide you some more information.
20 MR. MOELLER: We had a report on that which I read 21 prior to coming to this meeting and it said that EPA had 22 informed NRC at one of their recent meetings, and indeed 23 they are meeting, that the final standards are not, EPA does j 24 not anticipate that the final standards will be much 25 different from what exists now.
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g_ 1 MR. ORTH: Is NRC looking at how they are going to 2 comply with them?
3 MR. MACDOUGALL: Yes, I think that it is safe to 4 say that we.are. For example, we are embarking on a 5 rulemaking to better de' fine anticipated and unanticipated 6 processes and events for the. purpose of establishing some 7 kind of deterministic cast on what DOE may and may not or 8 must or must not consider in its performance assessment 9 calculations.
10 MR. ORTH: Then again if I am going to go through 11 and make what amounts to small quibbles, and I am sorry 12 about that.
13 MR. MOELLER: Well, that is what we want.
(')
LJ 14 MR. ORTH: On page 11 it refers to the Savannah 15 River National Laboratory in a couple of spots, and there is 16 no such entity.
17 MR. MACDOUGALL: You have got us there. I 18 MR. ORTH: There has never been a Savannah River.
19 MR. MOELLER: There is a Sandia. q 20 MS. MOODY: Yes, there is a Sandia. So it is just 21 the Savannah River Lab.
}
22 MR. ORTH: Well, tha site, the analysis of the
{
23 composition at the waste at SRNL, it is going to be Savannah 24 River waste.
25 MR. MACDOUGALL: That is right. I do not know how l
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(_j, 1 it escaped us, but it obviously did.
2 MR. MACDOUGALL: PNL is not the other issue,-is 3 it,'it is West Valley that is producing the second batch of 4 glass, and they have their own glass formulation which to be l 5 sure is not too far removed from that used at Savannah 6 River. But PNL is not at the moment anything other than.a 7 laboratory, and that is not really what you are going to 8 dispose of. You are going to dispose of the real world.
9 And I think that West Valley would be a better reference at 10 that point.
11 MR. PARRY: Actually PNL I do not think is 12 actually doing anything on that.. I think that the 13 assistance to West Valley came~from Savannah River.
(} 14 MR. MACDOUGALL: I am at a loss as to how this got 15 in here.
16 MS. MOODY: it needs to be checked. At one time, 17 PNL was involved with this waste form.
18 MR. MACDOUGALL: I understand that it came out of 19 the DOE site characterization plan, .but we will go back and 20 check. ;
21 MS. MOODY: It could be that they still are, 22 because they have a long history.
I 23 MR. MACDOUGALL: They may be referring to the 24 Idaho facility. I am not sure.
25 MR. ORTH: Another little spot down here. On t
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/"N 1 page 35 is the discussion of the licensing support system L]
2 again. And again the business of the negotiated rulemaking, 3 and there was a conclusion at the bottom. "The coalition of 4 industry groups dissented on the final text of the proposed 5 rule, so a consensus wa's not petually reached. But the 6 cooperation of the other parties showed that consensus was 7 still possible on important repository licensing issues."
8 Gene has already talked about that particular 9 issue. I think that the conclusion is a little broader.
10 Cooperation showed that consensus was ctill possible on 11 important repository licensing. I think that it is too l
12 broad a conclusion. And again it is that same issue that 13 the agreement was reached between people who were not
,s 14 subject to regulation and not with some of the people who j k) 15 had to worry about it. So that is hardly a consensus. It l
l 16 is just a com.nent. I do not know what you are going to do 17 with it.
18 MS. MOODY: That is very important.
19 MR. ORTH: Then I have a generic one which deals j 20 with the structure of the report as a whole. It is almost 21 impossible to follow it in terms of an outline. There are 22 main headings, and subheadings, and sub-subheadings. And at 23 no point can you follow what is a finding, and what is a 24 heading of a funding. There are a couple of spots in the 25 middle there are headlines labeled conclusion. But Heritage Reporting Corporation
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(_) 1 everything in there is either a summary at the beginning, a j 2 background with a main heading, and then two suh main 3 headings and a conclusion.
4 But the relationships of the findings to the 5 individual sections, ju'st hav9 somebody look through that 6 knows something about organiping documents. )
7 MR. MACDOUGALL: The basic structure of the thing 8 proceeds by finding. And within each finding, we looked 'at; 9 the issues that the Commission considered in its 1984 10 finding, and then we came up with what we thought were the 11 most difficult issues in light of developments in the past i 12 five years that we had to consider and then drew a 13 conclusion.
() 14 MR. ORTH: That is certainly right. But you have 15 got findings in small print underneath background in big 16 print, and conclusion in big print, but only two conclusions 17 before findings.
18 MR. MACDOUGALL: Yes. It is a hybrid animal, an 19 obvious product of a committee effort, but thank you. That 20 will be straightened out.
21 MR. ORTH: Again to me in trying to organize it 22 and relate the or,4ginal findings to the final findings, a 23 strong suggestion is if you are gojng to put a headline, 24 make it a big headline saying Finding 1, original and 25 revised.
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T ): 1 MS. MOODY: That would be excellent.
2 MR. ORTH: And then the rest of it explains how 3 you got from the original to the revised. In some cases, 4- the revised is all the way down at the tail end shown as a 5 revised. And in other ' cases,,it is just part of the 6 paragraph somewhere in the bpdy.
7 MS. MOODY: That is correct.
8 MR. MACDOUGALL: A fair point and well taken.
9 MR. ORTH: I will turn it over to somebody else at 10 this point.
11 ' MR . MOELLER: Well, on page two at the top, and I 12 know that I have asked this before, but I still do not 13 understand it. It of course begins at the bottom of page
() 14 one but it says on the top of page two, the third line, "No 15 discussion of any environmental impact of spent fuel storage 16 is required for the period following expiration of the 17 license or amendment applied for."
18 Now if you apply for spent fuel storage before 19 your plant's license is over, then you du have to file an 20 environmental impact statement?
l 21 MR. MACDOUGALL: Well, the purpose of the waste 22 confidence proceeding was to assess generically among other l
23 things whether the fuel could be safely stored past the ,
i 24 expiration of the operating license. And on the basis of l 25 this generic proceeding, the Commission concluded that it 1
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() 1 could safely be stored. And so as a result of this generic 2 finding, individual applicants for licensing amendments for 3 storage no. longer need to address the question of 4 post-operational safety of storage or environmental. impact 5 of storage, because the' generic proceeding takes care of it.
6 So it was really ap' amendment to the existing l 7 rules on preparation of environmental impact statements to 8 acknowledge that we have done a generic proceeding on the 9 storage question.
10 MR. MOELLER: All right. That helps. Now I am 11 sure that this is covered, and perhaps'again we have asked 12 it before. The nuclear power plant, the utility, is license 13 operated. So it is now shut down and they remove the fuel
(} 14 from the core, but for decades thereafter there is going to 15 be dry cask storage on site.
16 So what does'that do then to the utility, you 17 certainly cannot just mothball that and walk away or can 18 you?
19 MR. ROBERTS: What is happening and what has 20 happened is for example the fuel is continued to be stored 21 in the reactor pool and so forth. Whether or not you have 22 on site dry storage, you will have what is called a 23 possession, and I do not know if that is a legal term as 24 yet, but a possession only Part 50 license where your 25 Part 50 license is restricted basically to the storage of
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1 1 that fuel in the pool. And you would also have an existing 2 Part 72 license in conjunction with that for the storing of 3 fuel in dry storage on the site if there was excess fuel 4 outside of the reactor base.
5 MR. MOELLER: 'And the utility is still going to be 6 responsible until all of tha,t fuel is removed and the site 7 16 restored?
8 MR. ROBERTS: Yes, that was the point of some of 9 our findings.
10 MR. MOELLER: I think that we want to ask any more 11 questions that we have and then we will take a break, and 12 then we will go into executive session to figure out what we I 13 are going to say. But let's hear any more questions that we
(} 14 have and any more comments that anyone has.
15 MR. HINTZE: I have a brief question that shows my
- 16 ignorance, but what happens if a utility goes bankrupt and 17 we have all of this waste sittizg in dry storage, what 18 provisions are then available to us?
19 MR. ROBERTS: Actually I think that is addressed 20 in one of the findings where we reference the section in 21 there earlier. Under the Atomic Energy Act, the Commission 22 has the power basically to take over. I forget which l 23 finding.
24 MR. MACDOUGALL: I know that we covered the 25 question of bankruptcy in our discussion of Finding 2 if a I
'm
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1 reactor does go bankrupt. We found confidence that using 2'
'2 funds from the nuclear waste fund _ established by the Waste 3 Policy Act that DOE would be able to handle the management 4 of the fuel until a repository were available. We are 5 really talking about thb time,before DOE takes title to the 6 fuel under a contract with e,ach of the reactors. So while 7 we do have the authority to require that the fuel be managed-8 safely by some o.ner entity than the licensee if it comes to 9 that, I think that we are' fairly confident that it will not' 10 come to that. That DOE will take over and have the will and 11 wherewithal to do the job.
12' MR. HINTZE: Thank you.
13 MR. MOELLER: One other question. I have read
() 14 this and I do not remember. When the Commission considered 15 this in 1984, was the vote unanimous and w9re there added 16 remarks by any of the Commissioners and what were those?
17 MR. STEINDLER: There was I think an interesting 18 remark by Gilinsky.
19 MR. MOELLER: Yes, I thought so. I would like to 20 be refreshed on what Gilinsky's remarks were.
21 MR. MACDOUGALL: We could get you those. They are 22 in your handout. I do not think that there were any 23 separate dissenting or concurring opinions in the Federal 24 Register notice of 1984. But the deliberations of the i l
l 25 Commission leading up to the decision itself probably I i
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f(_) 1' reflects some differing views. I am sure that they had some I
2 differences.
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.3 FGl. MOELLER: Dr. Steindler is showing me here 3
- 4. that there were separate from Chairman Paladino, .
5 Commissioners Aselstein', Gilinsky, and Ahern. So there were l 6 quite a few. .
7 MR. MACDOUGALL: That was the 1983 proposed .
I 8 decision.
9 MR. MOELLER: Okay. That is not the final. So 10 supposedly, some of those were resolved.
11 MR. MACDOUGALL: We will get you a copy of the 12 1983 proposed decision.
13 MR. PARRY: Rob, you provided me a' copy with that 14 previously.
(
15 MR .~ STEINDLER: I did not get a chance to read the 16 full document.
17 Did you address the issue of the requirement for
~d
. PRAs, the possible requirement for PRA laid upon you folks 19 by EPA, and whether or not it is a doable issue?
20 MR. MACDOUGALL: Yes.
21 MR. STEINDLER: You did, okay.
22 MR. MACDOUGALL: That was one of the things that 23 we spoke about a few minutes ago on page eight concerning i 24 EPA's probabilistic standards.
2t MR. MOELLER: Okay. If there are then no other l
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2 Will-you people disappear or will you-still be 3 around, or we certainly could get you on the phone I guess 4- if we had a question?
5 MR. MACDOUGALh: If,you want us to stay, we will 6 stay, or some of us will. .
7 MR. MOELLER: If one or two could stay just in 8 case something comes ty) during our executive session. Okay.
9 With that, I think that I will declare the formal portion of 10 our meeting this afternoon'to be recessed. We will take a 11 break and then we will go into executive session first to-12 try to solidify and summarize what our opinions are and our 13 comments are on this waste confidence proceeding. Then when
(} 14 15 we finish that, we will have available a first real rough
~
draft of proposed comments on this morning's discussion.
16 And then that should wrap up today. And the executive-17 session will not be recorded, but it will be open to the 18 public.
19 (Whereupon, at 2:30 p.m., the hearing was 20 recessed, to reconvene immediately in executive session.) <
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$m,/ 1 CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory Commission in the matter i 5 of:
6 Name: 9th ACNW Meeting, Day One 7
8 Docket Number: ;
l 9 Place: Bethesda, Maryland 10 Date: April 26, 1989 ,
11 were held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory' Commission taken stenographically by me and, 14 thereafter reduced to typewriting by me or under the
('} '
15 . direction of the court reporting company, and that the 16 -transcript is a true and accurate record of the foregoing 17 proceedings.
18 /s/ 'G*S V (0/fN/
19 (Signature typed) : Irwin Coffenb 'y 20 Official Reporter 21 Heritage Reporting Corporation !
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6-184
. DECEMBER 1988 1
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6-187 i
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6-189
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5-4
4 O
E 60.112 OveraH system performance ob.
jective for the geologic repository after permanent closure.
The geologic setting shall be selected and the engineered barrier system and the shafts, boreholes and their seals shall be designed to assure that re- .
leases of radioactive materials to the '
accessible environment following per-manent closure conform to such gen- )
O erany applicable environmental stand- {
ards for radioactivity as may have been established by the Environmen-tal Protection Agency with respect to !
both anticipated processes and events j and unanticipated processes and l events.
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f E Draft: D. W. Moeller f LET223 -- 4/22/89 l
SUMMARY
OF DISCUSSION ON WASTE CONFIDENCE PROCEEDINGS
- 1. At a meeting of an ACNW Working Group, held on April 19, 1989, Mr. Robert Bernero, Director, Division of NHSS, reviewed the current status of this matter.
- 2. NRC team members, ch 5en to review this topic, were selected for their expertise and to assure that all affected Offices were represented. Each team member had an alternate and all were heavily involved.
- 3. The origin of the eriginal review was a petition from the NRDC which requested a decision on whether radioactive wastes from nuclear power plants can be safely disposed of, and that the NRC not !
grant any additional operating licenses until a satisfactory finding could be made.
Note: The original petition was based on challenges to two plants that had requested to expand their spent fuel storage capacity -- Prairie Island and Vermont Yankee.
The 1984 findings of the Waste Confidence review were:
- 94. a. Disposal in a repository is feasible;
- b. At least one repository will be available by 2007 - 2009; and that sufficient capacity will be available within 30 1 years to dispose of all spent fuel and HLW generated;
- c. Spent fuel can be safely stored for at least 30 years;
- d. Sufficient onsite or offsite capacity can be made available as needed;
- e. Because these decisions were made in the form of a prediction, the NRC promised to re-evaluate the situation every 5 years.
- 5. The schedule for the current review calls for:
- a. NRC Staff to submit a proposal to the Commission on May 12, 1989;
- b. Commission will decide on publication by May 31, 1989;
[' c. Public Commerits until September 1, 1989;
- d. Final Decision to be issued by December 15, 1989.
I
- 6. Changes likely to be made in the new decision, versus the old one:
- a. Instead of citing a specific time frame (2007 - 2009),
they plan to say that at least one mined geologic l repository will be available within the first quarter of the 21st century;
- b. The Staff acknowledges that it is possible that spent f uel may have to be stored f or up to 100 years --
40 years for the initial operating license for a nuclear power plant, plus 30 year renewal of license for extended operation, plus 30 years waiting for repository capacity; >
- c. The Staf f is writing the new decision on a graeric basis. It will no longer be tied into Prairie ;
Island and Vermont Yankee.
- 7. Another interesting observation of the NRC Staff, as a result of this assessment, is that the need for the MRS is moot. With the i f '~3 development of highly acceptable dry-cask on-site storage systems, l / the need for an MRS becomes less and less.
Q ,)
- 8. The NRC Staff provided the ACNW at the Working Group meeting a copy of a preliminary draft of the Waste Confidence Review Groups
" final" report. This needs to be reviewed and evaluated by the .
ACNW members and consultants and a report written on the matter at this meeting.
- 9. Items for the ACNW to consider include:
- a. What is our confidence that a HLW repository can be constructed within the time frame indicated by the NRC Staff?
- b. Will the NRC Staff be able to demonstrate that the facility proposed by DOE will meet the probabilistic standards promulgated by EPA?
- c. Need we also consider the delays in the acquisition and analyses of the data needed for site characterization?
- d. Decommissioning wastes are to be considered separate from this. The fuel will already have been removed from a plant being decommissioned.
W
- e. If orderly on-site dry cask storage is available, the pressures for the repository are considerably reduced.
However, it is important to note that Congress will not l
l s
f
_. ' accept this approach. That is why they have been hesitant on the MRS. They want the repository built and in operation,
- f. Yucca Mountain will probably not be'able to hold at much as the limit for the first repository (70,000 MTHl
- g. Can spent fuel be held safely for 100 years, as
[*
indicated (assumed) by the NRC Staff?
i
- h. Has the scenarios inNRC Staff considered evaluating various pathways a sufficient thatnumber o. j.
this mat f !
might follows? This may need some discussion.
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e D. W. Moeller LET224 - 4/22/89 ,
WEST VALLEY DEMONSTRATION PROJECT
- 1. During it b .1xth n.eeting, January 23 - 24, 1989, the ACNW met with representatives from the U. S. DOE, its contractors, and the State of New York Energy Research and Development Authority for a review vf the West Valley Demonstration Project.
- 2. I t-m:. discosued included the procedures that have been developed and are being applied in solidifying decontaminated supernatant low-level warteu and testing the melter for vitrification of the HLWs.
- 3. Th. prucedureu being applied at West Valley include passing the ,
sun inatant through ion exchange media to remove the bulk of the l dicuolved radionuclides, and then solidifying the decontaminated papernatant for disponal ac a LLW. Although this approach appears reasonable, it does raise what has been a basic question as to whether such an approach is acceptable. Some may say that it means p_q redocing what wac. a HLW to a LLW.
I t i J ,
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At Wect Valley, the resinc on which the radionuclides (primarily Cu-137) are being removed from the supernatant, and the sludge in the bottom of the waste storage tanks will be solidified !
and handled a; a HLW. In essence, this results in a fractionation of what were originay HLWs with a major portion of the radionuclides being concentrated in a solidified HLW fraction.
- 4. 1.1though the program appears to be appropriately focused and the i results are favorable, we noted several areas in need of attention:
- a. Acceptance criteria for the vitrified HLW, including the enumeration of testing procedures .
; to indicate conformance with these criteria, need to be identified by DOE for the waste producers, and need to be reviewed by the NRC to determine if they are acceptable;
- b. Public health and safety criteria for the facilities and land areas being decontaminated and decommissioned as part of this project need to be established.
# 5. Other questions that should be considered in the evaluation of this situation include:
1
't , _
e, \. ,
- u. Whether there are mixed wastes at West Valley now and, if not, could the above procedures lead to the development of such wastes?
- b. While the DOE and NRC appear to be demanding that careful criteria be developed for characterizing solidi-f led HLW:., similar criteria do not appear to be required for spent fuel -- which will also be placed in a HLW repository. Is there a justification for this uit uation?
i
- c. perhapu the ACNW and/or the Commission should request that the NPC Staff outline the approaches that were used in approving the waste disposal procedures currently underway at Savannah River and We ;. L Valley. Similar questions pertain to the watte. currently in storage at Hanford.
- d. Perhapu it is also time, once again, to consider developing a definition for HLWs. This might be ut.e f ul in 2eviewing similar tasks in the future.
C. The ACNW still plans to visit the West valley Site sometime thi
,q summer.
I ) C/ 4 e
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O D. W. Moeller LET220 -- 4/22/89 STATUS OF SCP/5CA REVIEW Jn pr eper i ng fcr the f ut urer.iaspects f the of its NPC ongoing Staff participation pertaining to'the in the rev2eu of the ec t i vi t i ec E:WA ft~ the DDE p opocc1 for the construction of a HLW
- e. pot: f or y et the Yucca Mountain Site, the ACNW has taken the
'o] lo i nt ac t 2 on: -
- 1. In .
- Uition tc a W:'rking Group session held on this subject on
<tp r i ] 19, 1999, we have scheduled three additional full ACNW mec t i nt; between now and the time we anticipate issuing our " final"
, : ,or m t . or, th : r u t: .j e c t . These meetings will be held on:
"ny : . J ': Bo ; Jane 13, and June 28-30, 1989.
t Although w t. c' o n c.t want to duplicate the work of the NRC Staff, we do want to explore cer tain t npi cs in sufficient depth to assure In this regard, we i I. that we he m gasen them an independent r e vi ew. ta.e te en stept t i. request indepth rev2ews of certain aspects of r These reviews wi11 theco ac t i vi t l e'. by sclec t ed ACNW consult ants. cupplement t hoto bei ng conduct ed by t he ACNW member s and Staf f and l (g) ,f will cucure that t ht:se t opi c s, e v j eu :. . Exemp: ec of the topics in particular, ar e given detailed being assigned to consultants
- (_/'
include:
~ne Dc;1gn Acceptability Analysic for the Exploratory 5% f t Fa:ility; and
' The Ee"en Separate Sect ions c f the SCA being developed Each of these under the various NPC Teart..el,aders. to a separate professional Sec t i on s. pm t ai ns , in gr or eclentific at egor y -- hydology, seismicity, volcanism, et c . c
- 3. Al t h ough the degree to which we explore other categories willthe depend pr;marily on the time available, we did explore indepth Study P1an pertsining to the determinaticin of groundwater travel timc. Dr. Steindler has also outlined the following additional ar en. ac portsble subjects for exp1 oration:
l Peaction of breeched fuel with groundwater; Cor rocion r ate predictions of canister closures; Sensitivity of one or another migration model to uncertainties in the redox potential of fractured rock surfaces; Prediction of f r ac t ur e formation because of mining engineering acti vities in tuff; The quality of data likely to be derived f rom process variability in glass manufacture; and 1
b H '
'!io pr edi ct ability of the ef fect of irradiation of
~
fuel / glass on reaction kinetics and products f r oin wct er / wast e interaction, etc.
. Although thic ie on1y in the discussion stages, we have been evploring the potcibility of requesting that the NRC Staff ask DOE t o devel op c Scoping Study PRA for the Yucca Mountain facility. We note that t h t, ha.m M ready had an Environmental Pathway Analysis Scoping 5t uay pc r f ormet t for the Yucca Mountain Site (issued as SAIC-D7-8010, Mar:h. 1909).
O, pricary ib .jec t i ve in calling for such a Study (i f, indeed,
.h do) w d d be to c on f i r ni t he ident i fic at ion of the key parameters af imp -tm.co in the per f ormance of the repository and to help ic niify e r ., " fats) ' 4 s .m " t i .at may exist at Yucca Mountain.
t In te u e3 m mct recent ac t i vi t i es, several "new i .40, unt.;" Rvt been revealed on which we plan to have additional i!M er < s t 1 u n . Thest include
- a. In terc: of pathway analyses, one that has recently b e ar, discurted with the ACNW is the potential for release of carLion- N into the atmosphere above the repository. We plan to e-.plore this further.
o b. Quections have been taised by the NRC Staff as to [ ( ,/
) whether the current location of the ESF will be adequate to pr avide " representative data" for the site. The acquisition of too many samples could damage the integrity of t h c: cite; the acqui sition of too f ew samples could 1.:.s d to improper c har ac t er i: at i on. This, again, is cometh;ng that we plan to explore.
Ar iot he r question that has been raised by the ACNW cvouultents it whether DOE is using the most up-to-date methodu in acquiring information on the site. A factor in t hi c quect i or. Is t he requirement by the NRC Staff that only " proven" methods be used. This latter requirement may be hampering the range of technologies being applied by DOE. We plan to explore it further. One possible avenue, suggested by one of our consultants, would be to inquire about some of the techniques being used by commercial groupc, such as those i nvol ved in the exploration for oil.
- d. We have been informed that the Nuclear Waste Technical Review Boer d (established by DOE to provide them ,
independent analyses of their Yucca Mountain program) has ! questioned the proposed methods for excavating the ESF and particul arly whether the extent and direction of the proposed dri f ts are adequate. We p1&n to maintain close n ties with the NWTRB and to keep abreast of their f' J recommendations, George Lear attended th( first meeting ( /' of the Technical Review Board and Dr. Melvin W. Carter, l 2 l
rv - - - - - ---
- - - - 3 I + .
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.' one of the ACNW consultants, serves as a member of the NWTRB.
- 6. As part of i t s c onsi der at i ons, the ACNW has looked into the QA activities being irr.plemented by DOE in support of the HLW repository program. Nc r evi ew indicates that GA activities may account for 15% to 20% o f the cost of many data gathering operations. While
'her e mi ght Le e a tendency on the part of some to call for a reduction in these activities (and especially the associated costs),
t% ACNU conc.luded that the program is necessary and that, for the present, the cortt may be just i fi ed. The ACNW is monitoring the ; _ ; t u z t 1 ;.in (: ncluding possible participation in one or more of the OA ' vc_t.
' er.d wa11 effur suggettlons as appropriate.
A: though the ACNW r ecogni: es the desire of the NRC Staff to , c' , , . r a: i n c:np en d en t capability for evaluating DOE's conceptual (
. i, . _ s t. ) ; for the HLW repoutory, we believe this capability should be b a ed on the application of existing models, modi fied as necessary, en c on t r i.rc t ed to the development of new models. The development of s ., : et t '.y new mucel is corrplex, lengthy and expensive. The same ,
t r ue for the development of codes for joining submodels to permit l
! < - w, a l v a t i c - ef c omp l et e systems. For the NPC Staf f to attempt to l
' ' w.l v i t m i t tus h activitiet on a totally independent basis would l appo n to u; ta be beyond their renources.
A: t hough at eppear: that DDE has expanded its hori: ons to W nclua.s alternete conceptual models (in response to NRC's expressed
- t. m ; o r n, aoJi'ivoci det v.11 c vi11 be needed before judgments can be ordt so thc adequscy of theue changes. l 0, In the way of relcted "admi ni st r at i ve" aspects of the DOE
_ffort, we share with the Commissioners and the NRC 9taf f the following :oncernc: l
- a. The challenge of the State of Nevada to the request by DOE for wat er rights for the si te char ascter i::ation activities; a
- b. The long time required for the acquisition and analysec of data pertaining to the site; 1
- c. The high turnover rates within the DOE Statf; the lack of con fi rmed appointment s 'of peopl e to fill key positions; the legal challenge to the designation of a contractor to handle site activities, etc.
As a final comment, we offer the f oll owi ng obser vati on. And 9. this is not meant toBut bewecritical of the NRC Staff -- it is an note that, in its review of the final observation, only.
" statutory" SCP, the NRC Staff has observed new " concerns" relative to some of the expanded and revised sections. We would urge that care be taken to assure that this does not lead to an ever expanding I z
number of new concerns, much as was the case some years ago when another component of the NRC Staff developed and attempted to I
, re Cs,.>r,_ ; 1 J v .:.t L M n! rLduce t he DLimber Of "UDY eSol ved Sa fet y i SSueE"
. . a t t;;l tv nuclear power plants.
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lo: File rrem: .E. F. Voiland Tubject: Comraantary on Preliminary Draft - Pr oposed 19 8 9 - Waste Confidence Decision. Prepared by We , t e Confidence C ec. i c w Group,-April 17, 1989. I General Comment Thic document ic well and clearly n itten. It review the findings of the 1984 Waste Confidence deliberations in a systematic rnanner and in the light of technical advances and legislative changes; particularly the offects of the 1987 Arnendment c to the Nuclear Waste Policy Act (NWPAA). I ri gen eral. the Review Group found no reason to abandon the con ~ clusions previously reached that successful disposal of spent nuclear fuel and high level wastes derived therefrom could be accomplished and that extended interim storage until the < avcilebility of the disposal repository poced no significant
' additional rinhato public health and safety.
Perhaps the most significant changes in the rationale for the (relatively f ew) ' changes in wording of the findings . were (1) the recognition that the earlier congressionally I established time table was no longer - if it ever was - at- ! () teinable and that it was prudent to project availability of the repository to some time in the first quarter of the 21st Century,_and (2) that the actual demonstrated accomplishment of dry storage of aged commercial reactor fuel at reactor sites gave'added confidence in the successful long-term cto-rage of spent fuel in the event of long delay in commission-ing-the disposal facility. Such a delay could conceivably occur'if the congressional decree to qualify sites successively rather than in parallel turned out to have been
- a. bad-decision. .(Failure of the Yucca Mountain site to i
qualify could perhaps result in a 25 year delay in availabil-ity.) The principal conclusion was t,ha t the various changes ; could have profound effect on the timing of beneficial use of the repository but no real effect on the confidence that the facility could and would ultimately be operative. The Review Group emphasized that it was far better to do the job right than strive to meet timing goals which were not of great ; significance. . J Specific Comments for Possible Consideration Page 15, para. 3. Is the term " decommissioned" equivalent to " permanently closed"?
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V r ace 29, para. 6. There ic an inconc intency bttween the
- tattwent of "...five reac t.or s cited above. ." and the 1ist-ing'of'only four in the-previous paragraph. Should Morris Operation be included for completenous cake? It's Part 72 license expires in 2001, I believe.
Page 35, para. 2. I doubt the effectiveness:of the LSS in I speeding up the licensing process. 10CFR2 fundamentally
' defines a good process for resolving 4csues and contentions.
However it is predicated on the belief that. it will be used by people of good will. The sad truth is that the procedure l has been abused by interveners who are simply opponed to nuclear energy end abuse - or are allowed to abuse - the j licensing process to achieve *donial through delvy". i Page 35, para. 3. I believe there is a real risk tnat negotiated " ru l enia k i ng " could relieve the NRC of its respon-sibility for rulemaking. I am not surprised that the indus-trial coalition dissented from the consensus position in the wor d i r.g of the text. Industry is the only one of the groups
-with possible exception of. DOE - which is subject to the regulatory pr oc ess . NRC is t he regulator. The State of Neveda, Nevada local govern'ments, and the national environ-mental groups are all apt to be interveners in the process and historically a n t i-n u c l e'a r .
Page 37.-para. 2. I wonder about DOE's capability for manag-ing a program as large and complex as the repository program. What other programs of this magnitude has DOE managed and what was the result? Page 39, para. 1. If there is a substantial delay in the availability of the repository will the additional cost to utilities arising from the need for additional storage at reactor sites be borne by the utility or funded by DOE 7 Page 47, bottom line. One of very few typos! MTHM shcald be ; MTHM/yr. '
. General. The capacity of the repository is stated in terms of MTHM or MTIHM, specifically with a limit of 70,000 MTHM for the initial repository. This may make sense from a political perspective, but certainly doesn't from a technical point of view. The technical capacity will be dictated by the volume of the waste packages (which could be affected by rod conso-lidation), the thermal output of the waste, and the heat dis-sipation characteristics of the site. With a delay in avail-ability of the disposal facility, theoretically the heat out-put of the fuel will be reduced and a more dense storage l array could be accommodated. Also, the technology of rod con-solidation could improve. A corollary of this, is the undesi-
/ r 1bility of *
, a .ft er i r, q 'or <n' G ol to t i, i<;ovitorv .
tha higher i .a t out pat would e- ::u c e t)e c 4-city becauue of ;
'hermal d h.wi .r.a t i on c onu i d e r a t i ont. . Another conufderatson is !
- t. he specific effect of higher fu l burnuo in the tenctor.
One'effect is tho reduction in the nunber of fuel anstwblies requiring dicrocition, however, each ascombly does contain a greater amount of radioactive material. This effect only appears after a number of yrvrc,-when the short-lived radionuclides have decayed away. The long term effect is a charge in the nature and quantity of actinide elements for the same amount of power generat ed by the extended-life fuel. If it has not been done, it would sicem reasonable to evaluate the technical capacity as a function of fuel decay period, rod consolidation and other parameters that could affect the t<chnical cepacity of the repository. Page 69. pare. 2 DOE policy decision to dispose of the oldest spent f u' i will heve to be reviewed. The intent will undoubtedl keep reactors operating with minimum provicion for.o dry storage. Since the fuel transfer rate to the repos sry is hardly greater than the production rate, it is p r o ba bi r. that fuel ctored at shut down reactors will not be moved until all operating reactors with storage problems are taken care of it is pocsible that a detailed logistics study at come time in the future would bet useful. Appendix 2, page 2, item 1. The average discharge of 30 Te
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MTIHM is probably realistic; however the refueling interval
-i s not stated. There is a trend for more extended operating intervals between refuelings. For example, Dresden 2 and 3 reactors are discharging on an annual basis about 22 Te of
-fue.l. (These are 8004 MW units.)
Appendix 2, page 2, item 2. The_ curve of Figure 1 suggests a build up rate of1 from 20 to 24 Te per year assuming 110 reactors on line. Is this consistent with the 30 Te per discharge cited above? Appendix 2, Figure 3. The dry storpge requirements suggest that on the average each of the 110 assumed reactors will need about 500 Te of dry storage capacity at the end of year L 2047. This is not an insignificant cost. The total amount of fuel used in the same period assuming 110 reactors, and 25 Te j per year discharge would be 40 yr x 25 Te/yr or 1000 Te. I think the consequences of extended delay in the availability of the repository could benefit f rom a reasonably detailed impact analysis. April 23, 1989 i { Q _}}