ML20150C291

Summary of ACRS Subcommittee on Waste Mgt 880428 Meeting in Washington,Dc

ML20150C291
Person / Time
Issue date:	05/26/1988
From:	Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
References
ACRS-2574, NUDOCS 8807120418
Download: ML20150C291 (36)

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SUMMARY

MINUTES OF THE MEETING 0F THE ACRS SUBCOMillTTEE ON WASTE MANAGEMENT WASHINGTON, D.C.

APRIL 28, 1988 The ACRS Subconnittee on Waste Management met in Room H-1046,1717 H St.

NW., Washington, D.C. on Thursday, April 28, 1988. The announcement regarding this meeting appeared in the Federal Register on Friday, April 22, 1988 (Enclosure A).

Purpose:

The purpose of the meeting was to review the NRC Draft Comments on the Consultation Draft Site Characterization Plan (CDSCP) for the Yucca Mountain, hevada high-level waste repository site.

Implemerita tion :

The abote-named topic was reviewed and discussed in accordance with the Presentation Schedule (Enclosur' B). A list of the documents distributed during this meeting is also provided (Enclosure C). These documents are available in the ACRS files.

Subcommittee Action Taken:

In response to an oral request made by Mr. V. Stello, Jr., of Drs.

Moeller and Steindler during their ineeting with him on April 14, 1988, M' N Subbnhtee prepared draf t connents on this topic for ACRS

, f DESIGNATED ORIGINAL

, 3. 8907120418 880526 Eb L bL -'J [.-25 PDR - Cortified By jh )

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Minutes / Waste Management .2 ,

, April 28, 1988 Meeting l consideration during its 337th meeting, May 5-7, 1988. Mr. Stello desired to have the ACRS comments for his and the NRC Staff's consideration prior to their scheduled briefing of the Commissioners on this subject on May 4, 1988, and the proposed transmittal of the-NRC Draft Comments on the Yucca Mountain CDSCP to the Department of Energy (00E) on May 5, 1908.

Attendees: (Total - 38, Enclosure D)

ACRS Members - 3 D. Moeller M. Steindler P. Shewmon ACRS Consultants - 2 C. Mark J. Maxwell ACP.S Staff - 3 NRC/NMSS Staff - 18

0. Merrili B. Youngblood R. Savio M. Nataraja S. Duraiswamy S. Coplan C. Abrams DOE and Weston - 8 P. Justus R. Stein (DOE) J. Trapp E. Regnier (DOE) D. Gupta H. Bermanis (W) J. Kennedy A. Watkins (W) B. Belke

. V. Montenyohl (W) R. Weller C. Dell (W) D. Brooks D. Fenster (W) K. Chang E. Benz (W) D. Galson K. Stablein Others - 4 K. McConnell W. Ford J. Bradbury G. Lear Highlights:

1. Introduction and Opening Comments -- D. Moeller

Minutes / Waste Management 3

. April 28, 1988 Meeting Dr. Moeller opened the meeting at 8:30 a.m. and made the following observations prior to the NRC Staff's presentations.

1. There are issues other than the 5 major "objections" that he believes are of such importance as to be classified as objections.

2. Since there are no applicable regulations or standards for the emanations (from radium or radon) from the material excavated from a non-uranium mine, what standards (or regulations) will DOE use to assure that none of the workers or the general public will be exposed to any significant hazard due to natural radiation sources, as they state in the CDSCP?

3. Regarding the staf f's comment that some portions of the CDSCP have not been reviewed in detail, he said he would hope today that we can find cut what those portions are. And how did the staff decide what portions to review first and what portions perhaps to review later?

4. He stated his appreciation for the presence of R. Stein of DOE, and for Mr. Stein's offer to help clarify areas where NRC and DOE are at odds on some major point. And further, with the help of NRC as well, to find out if the point can be brought to closure at some future time, in which case its significance decreases.

I II. Introduction to the NRC Staff's Review of the CDSCP -- R. Browning

Mir.utes/ Wast.e Management 4 April 28, 1988 Meeting Mr. Browning provided a brief perspective of where the NRC Staff is on the overall process that will ultimately lead to a license application by the DOE for a high-level waste repository. He pointed out that the Consultation Draft of the SCP is neither required by law nor by NRC regulations, but that its submission in draft form to the NRC and the State of Nevada for the purpose of early involvement and feedback will expedite the review of the SCP by NRC, which is required by law, when it is submitted early in 1989.

Regarding the "Objections" referred to previously, he said that several of them are very fundamental, e.g. DOE's QA Program. NRC's objective in this regard is to have DOE ano their contractors put a QA program into effect that is not only good, but has supporting documentation that shows that it is good.

Also, he stated that the sinking of the experimental shaft (ES) and the accompanying experimental shaft facility (ESF) are major steps in the program, which 00E plans to begin by June, 1989. A big question is, i

where to locate the ES. Since excavated areas will be within the future i repository, exploratory excavations must not violate the repository's integrity.

l 111. Overview of CDSCP Review -- K. Stablein (Handout No. 1)

Mr. Stablein presented the "time line" for the NPC review of the CDSCP which started with the receipt of the CDSCP on January 8,1988 and runs I

to May 1988, at wh'.ch tir.t their plan is to issue the final "point

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Mii.;tes/ Waste Management 5

. April 28, 1988 Meeting papers" to DOE. He stated that the purpose of the NRC CDSCP review was to identify concerns with the SCP for consideration by DOE in preparing the statutory SCP.

He said that the scope of the review was limited, that they focused on the logic and structure of the program, but did not (due to the short review period) review the document in detail. He said that their concerns should be considered as potentially applicable to those portions of the CDSCP that they did not review.

Their concerns were categorized relative to their. importance, viz.,

1. Objections -- concerns of immediate seriousness, such that work should not start until they are resolved.

2. Comments -- concerns that would result in a significant adverse effect on licensing if not resolved, but would not cause irreparable damage if site characterization started before their resolution.

3. Questio3 -- concerns that preclude understanding the part being discussed well enough to be able to evaluate that part, viz.,

missing information, inconsistencies and ambiguities.

He identified 5 objections, the principal one being that the CDSCP does not recognize the range of alternative conceptual models of the Yucca Mountoin Site that can be supported by the existing limited data base,

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Minutes / Waste Management 6 April 28, 1988 Meeting A second objection pertains to QA plans and procedures for DOE and its' prime contractors. The other 3 objections relate to problems incident to the exploratory shafts (ES) and the ES Facility.

He explained that an NRC letter of March 7, 1988 transmitting the draft point papers to DOE identified a total of 161 NRC Staff concerns includ-ing the 5 objections. A draft point papers workshop was held in Rockville, Md., March 21-24, 1988, followed by an alternative conceptual models workshop in las Vegas, NV on April 11-14, 1988. The date for submission of'the final draf t of the NRC comments to DOE is May 5,1988, although he believed this date wculd slip in order to allow time to take ACRS coments into consideration.

The final CDSCP workshop on DOE response to the NRC final point papers is tentatively planned for the June / July time period. NRC has proposed interactions with DOE on key areas of concern, e.g., QA and alternative conceptual models. All of the preceding should better prepare the DOE for the submittal of the statutory SCP in early 1989, as well as to better prepare the NRC for its statutory review of the SCP.

Dr. Moeller asked questions on two principal concerns, expressed earlier in his opening comments, which were answered as follows:

1. Regulatory non-compliance was considered for possible listing as an "objection." However, according to Dr. Stablein, it did not meet the criteria sc was downgraded to a "comment," whose criteria it did meet.

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. April 28, 1988 Meeting

2. Radon is outside NRC jurisdiction until DOE becomes a licensee; in i 1

the meantime, 10 CFR Part 20 is believed to cover this issue.

Dr. Moeller called upon R. Stein of DOE to comment on the. question he had raised about radon. Mr. Stein's principal comments were:

1. The NRC has done an excellent job in their review of the CDSCP and has identified what it is DOE needs to focus on in its preparation of the statutory SCP. Also, DOE will have a continuous, on-going dialogue with both NRC and the State of Nevada that will assist it in the preparation of the final SCP.

2. The initial'NRC acceptance of the CDSCP was an acceptance of that Draft, indicating that it met their requirements to go ahead and review it on a preliminary basis, which they did. As a result, DOE understands what needs to be in the SCP for it to be formally reviewed by the NRC.

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3. Regarding the radon question, DOE has looked extensively at that question for more than a year and, during the preparation of the  ;

i CDSCP, arrived at certain conclusions as to how DOE plans to deal  ;

with this issue during the pre-licensing and the post-licensing periods.

Mr. Ed Regnier then discussed the radon issue; the highlights of his remarks follow, i

Minutes / Waste Management 8

. April 28, 1988 Meeting

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1. If there is a potential for radon build-up underground, he celieves.

that DOE's plans would include radon within the limits of Part 20 after DOE is a lidensee. 00E is currently excluding radon as part of the natural background. Prior to licensing, the Part 20 limits would not be legally binding on DOE, but after licensing they would be.

2. In both the pre-licensing and post-licensing cases, DOE will be voluntarily complying with the Mine Safety and Health Adminis-tration (MSHA) regulttions that govern the control of radon levels in mines, even though they have a Memorandum of Understanding with MSHA that, according to law, they are not bound to follow the MSHA regulations.

Dr. Mark cuestioned Mr. Regnier about radon in mines; Mr. Regnier said that, although there is a source of radon in tuff, with proper ventila-tion, which would be required for any occupied area, the radon levels would be minimal. Mr. Browning of NRC concurred.

IV. Quality Assurance Concerns on CDSCP -- J. Kennedy (Handout No. 2)

'After providing the bac.kground on the QA concerns, Mr. Kennedy said that the "Objection" regarding QA (No. 5) reads as follows: "The CDSCP references a number of QA plans and procedures for DOE and its prime contractors, many of which are undergoing potentially significant revisions, or which have outstanding staff review coments, or which have not undergone staff review. Based on staff reviews to date, they

Minutes /Wsste Management 9 April 28, 1988 Meeting do not fully comply with NRC's QA criteria. Data collected under these existing programs may not be usable in licensing." He emphasized that portion of the Objection which states: "they do not-fully comply with NRC's QA criteria. Data collected under these existing programs may not be usable in licensing." Following this, he stated the following recommendations (from the NRC draft comments):

1. DOE is to furnish the latest revisions of plans of participating organizations (principal contractors and subcontractors).

2. DOE is to respond to outstanding draft comments.

3. DOE should facilitate NRC Staff verification reviews such as audits.

4. The NRC Staff recommends DOE not start work (corrected to read "new" work by R. Stein of C0E) until additional confidence in the QA program is obtained by (NRC) Staff.

Dr. Steindler observed that, although the QA concern is a major ob-jection, none of the 161 comments reflect why it is so. A rather extensive discussion followed among Mr. Kennedy, Dr. Stablein, Mr.

Browning, Mr. Youngblood, Dr. Steindler and Dr. Moeller. It resulted in the following observations:

1. Mr. Browning said, by way of explanation, that in the pre-licensing mode, the emphasis is on making sure DOE's own QA program is 1

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Minutes / Waste Management- 10

. April 28, 1988 Meeting working effectively, and then NRC will be a lot more comfortable in a monitoring, sampling, auditing mode, which is the only thing NRC can do within its' limited budget. The only way this program is going tc work is if 00E does a good job.

2. DOE has a program for auditing the QA program of its contractors.

NRC accompanies DOE on their reviews and audits.

3. NRC has revieweo the 00E procedural manual for conducting QA audits of contractors.

4. Dr. Steindler questioned why QA is ranked so high and R. Browning commented that the QA issue is an "Objection" because it is fundamental; 00E is improving but not rapidly enough. He asked if DOE can have an acceptable OA program in place by June 1989 when DOE plans to sink a shaft, and added that now is the time to resolve this issue. R. Browning said that it is not unoer control, and that DOE's program to qualify existing data mt,. 00^ be rigorous-enough.

5. The probability cutoff of 10-5 ,er year for pre-closure events is not justified. NRC wants 10-6 to 10-7; EPA is pushing for 10-8 ,

6. DOE concluded for pre-closure that nothing on this matter would be )

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V. Performance Assessment Concerns

Minutes / Waste Management 11

- April 28, 1988 Meeting A. Performance Allocation and Assessment -- D. Galson (Handout No. 3)

Mr. Galson reported that another of the "Objection." became apparent through their review, i.e., the concern with how alternative conceptual models were dealt with in the perfor-mance allocation process in the CDSCP, which was the focus of the aforementioned NRC/00E workshop on April 11-14, 1988 at Los Vegas, NV. He gave an overview of the problem,.followed by a chronology of events from August 1983 through mid-April 1988. He gave a working definition of a conceptual model, viz.,

A conceptual model is a pictorial and/or narrative description of the repository system or subsystem that is intended to represent one or more of the following:

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- Relevant components of a system and/or subsystem.

- Interactions between the various components and/or subsystems and/or systems. ]

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Regarding conceptual models, he said that:

1. Conceptual Models form the basis for the predictive perfor-mance assessments of repository systems and subsystems that are required by 10 CFR Part 60.

Minutes / Waste Management 12

. April 28, 1988 Meeting

2. Conceptual models must be developed and confirmed, with reasonable assurance, to calculate releases for all scenarios needed to sh6w compliance with the EPA Standard (for HLW Repositories)

3. The SCP and performance allocation must consider a full range of alternative conceptual models (alternative working hypothe-ses) where uncertainty exists.

He quoted the~"0bjection" on this matter, which states that:

"The perforrance allocation process in the CDSCP does not directly address the investigations that would be needed to characterize the site with respect to the full range of alternative conceptual models and associated boundary conditions that are consistent with existing data."

Dr. Steindler asked what was meant by "full range," to which Mr.

Galson answered, those'"that are consistent with the existing data."

Mr. Galson said the most important of three considerations regarding the 1 above "objection" is as follows:

l "An important consequence is that it cannot possibly be determined l whether conducting one investigation would interfere with, possibly I

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Minutes / Waste Management 13 April 28,.1980 Meeting to the point of precluding, conducting another investigation needed to obtain information for licensing."

Mr. Galson identified 6 recommendations NRC is making to DOE on this matter, two of the most important of which are numbers 1 and 6 (see handout for complete list):

No. 1 Identify a full range of alternative conceptual models and associated bounda.ry conditions.

ho. 6 Accord high priority to investigations having the greatest potential for resolving issues that could lead to:

the site being considered unlicensable substantial changes in the characterization program.

B. Conceptual Models and Scenarios -- J. Trapp (Handout No. 4)

Dr. Irapp reiterated the definition of Conceptual Model given by Mr.

Galson, then defined Scenario as:

"An account or sequence of a projected course of actions or eve;ts," and that it "should be synonymous with multiple working hypotheses."

-- . . . , . . _ . _ - - -_. __ _ - . _ _ - ~ .. ,_ . . .

Minutes / Waste Management 14 April 28, 1988 Meeting He said that there is only one conceptual model, all others being only changes in boundary conditions, then asked-rhetorically ~,

"Is there (or can there be) a conceptual model for a scenar-io?"

He said that NRC's concern underlying the "Objection" is that "the progran of investigations as presented in the CDSCP may not detect features present, relevant processes and events which may have acted, are acting, or could act on the repository system." He cited 10 CFR Part 60,122(A), stating that DOE must demonstrate that:

1. Potentially adverse conditions have been adequately inves-tigated including the extent to which the condition may be present and still be undetected, and The condition must be adequately evaluated using assumptions l 2.

which will not underestimate the effect, and y

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3. The condition will not significantly affect waste isolation, or

4. The effect is adequately compensated, or 1

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5. The condition can be remedied.

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Minutes / Waste Management. 15 April 28, 1988 Meeting He then cited ten examples to illustrate the nature of the. application of the above conditions to certain items, resulting in ten significant comments.

He scid that DOE must establish the following (key words only; see handout for details):

1. What is known

2. Uncertainties

3. Significance of alternative hypotheses and uncertainty or existing data

4. Needs and investigations to discriminate between alternatives

5. Prioritization of investigations based on (1) avoidance of interference between tests, and (2)-the need to resolve key issues early.

VI. Engineering Concers -- D. Gupta (Handout No. 5).

Mr. Gupta said that 3 "Objections" (Nos. 2, 3 and 4) came out of this review, all 3 relating to the two exploratory shafts, ES-1 and ES-2, and the exploratory shaft facility (ESF). They are:

Minutes / Waste Management 16 April 28, 1988 Meeting Objection 2: Extending the exploratory shaft ES-1 400m below the repository horizon into the Calico Hills unit, and drifting laterally in that unit, may have adferse impacts on the waste isolation capc5ility of the site.

Objection 3: The CDSCP contains inadequate information on the ESF conceptual design to allow evaluation of: (1) potential interference of proposed investigations with each other, and (2) interference of construction operations in the two shafts and long drifts with these investigations.

Objection 4: The CDSCP does not adequately consider the potentially adverse impacts on waste isolation capability of the site and the ability to characterize the site resulting from proper locations of ES-1, ES-2, and othcr openings in areas that may be susceptible to surface water infiltration and to erosion.

Mr. Gupta said regarding ES-1 and ES-2 that, since they will eventually become part of the repository (for ventilation and for access of equipment to the repository), they should be designed to the same standards as other repository shafts. And, regarding regulatory criteria for the ESF design review, they will be acte.ptable if the design:

1. limits adverse impacts on long-term performance, and

2. dc.es not preclude adequate site characterization.

Minutes / Waste Management 17 April 28, 1988' Meeting The ES and ESF related key concerns are:

1. l.ocations of'ES-1 and ES-2.

2. Penetration into the Calico Hills formation.

3. Extent of lateral exploration.

4. Relative location of ESF tests.

More detail on the particular concerns in each of these key areas were discussed.

Dr. Moeller noted that:

1. DOE should recognize that any NRC criticism they reject will be.

subject to scrutiny during the public comment period.

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2. Cost ar.o cost-effectiveness should not be over-emphasized.

3. DOE's conservatism regarding the difference in elevations of the original locations of ES-1 and ES-2 relative to their present design location (to prevent water intrusion) is not adequate. At the new location, erosion may affect them even more.  !

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4. Will the waste packages have a pressure of 1 atmosphere on them?

If tuff creeps, the pressures might be greater, was the reply. The  ;

Minutes / Waste Management 18 April 28, 1986 Meeting vaste canister will have an air gap of a few inches around it to allow for tuff creep and faulting over long periods of time.

Vll. Geolccy Concerns -- C. Abrams (Handout No. 6)

The Geology / Geophysics Section reviewed the sections of the CDSCP covering these areas.

1. Pre- and post-closure tectonics, including faulting and seismology.

2. Surface characteristics

3. Seal characteristics 4 Total system perfornance

5. Erosion i

6. Rock characteristics

7. Clirate i

8. Human interference (intrusion)

9. Volcanism i i

10. Natural resources

11. Methods of exploration, including geophysics and surface-based and 1 in situ testing

12. Geologic aspects of performance assessment -l l

There was one "Objection" raised in this area, which was subsequently reduced to a "Comnent." It was the interaction between faulting and the waste package perfornance objective$ b cause, as important as it is, in th: e.taff's opinion, it did not meet the necessary criteria to be classified as an "Objection."

-Minutes / Waste Management 19-April 28,l1988 Meeting Ms. Abrams said that the central theme of recommendations to DOE is the integraticnoftheirinvestigations,i.e.,(1)integrateamongvarious geologicfnvestigationk,and(2)integrategeologicinvestigationswith other technical investigations.

Dr. J. Naxwell recomended that, since lateral fault slipping is very difficult to measure (7 to 8 times the slippina of vertical faults, which is more easily measured), DOE should take a direct approach to the problem by instrum2nting for lateral movement.

Regard'ng natural resources, Ms. Abrcos said that:

1. DOE had used out-of-date references,

2. there was no rrining in this area now or had there been any in the past -- the area was closed off 35 years ago,

3. no new exploration had been done in spite of new innov6cive techniques, and 4 there are epithermal gold deposits west of the site.

Regarding erosion, Ms. Abrams said the NRC's coment on this matter was ,

one of the most significant ones. P. Justus added their concern vas also about surface se&ls and other near-surface features due to ero 'n.

. Thus, there is a need for DOE to perform studies specifically dir .dt- 3rd the 'n Ttions of surface facilities. This relates s '. rot * " '~ >

,f ES-1, ES-2, and the ESF, in addition to the loce .s - " to the horizuntal drifts and the muck piles, ie., et , . clay excavated in mining. '

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Minutes /Wa%e Management 20 April 28, 1988 Meeting And, regarding the geological performance-assessment post-closure goals, he said they were not set high enough to assure compliance with the EPA Standard (with respect'to a possible breach of a canister by volcanism or vertical fault movement).

Dr. Maxwell said that DOE's concept of a 10,000-year cumalativ! slip earthquake was nonconservative and nat technically supportat'le.

Dr. Moeller commented on the fact that the 00E CDSCP (regarding occupational radiation protection) implies that only men will be working in the repository. For example, there are no precautions relative to radiation exposures of pregnant worten, etc.

Vill. Hydrolooy Concerns -- W. Ford (Handout No. 7)

Mr. Ford said that their review addressed the topics of

1. surface water, j

2. groundwater,

3. water resources, and f

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4. climatology t.nd metec-ology.

l Their basic hydrologic concern was a comprehensive investigation program for adequate site characterization for I'v N ogy and meteorology i

evaluations. There were no "Objection's" resulting from their review,  !

4 and only 18 comments and 4 questions.  !

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Minutes / Waste Management 21 April 28, 1988 Meeting Regarding surface water, Mr. Ford said th'ey were concerned about: (a) how surface water transfer batween basins would be achieved, and (b) the inadequacy of DOE's debris-flow studies.

Regarding groundwater, their primary concerns were:

1. DOE should do isotope sampling to date the groundwater in the upper part of the water table,

2. There is a need for prototype testing to characterize the unsaturated zone,

3. Past drilling activities may compromise the hydrologic and geochemical tests planned for the exploratory shafts, 4 The CDSCP description of investigations to evaluate the effects of faults on saturated groundwater flow is incomplete, and

5. The performance parameters for groundwater travel time listed in some of the tab'es (8.3.5.12-2 and 8.3.5.12-3) cannot be ,

correlated with tests described in other sections (8.3.1 to 8.3.1.16).

Mr. Ford said, regarding water resources, that the CDSCP does not 1

include the pres .nce or absence of significtnt sources of groundwater as l an information need to resolve issue 1.2 (regulatory requirement for i

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Minutes / Waste Management 22 April 28, 1908 Feeting limiting individual doses). Dr. Moeller noted the need for consideration of the effects of faults on groundwater flow in the saturated zone.. *',

And, regarding climatology and meteorology, their concerns were:

1. The averaging period for collecting meteorological parameters should be determined by the anticipated use of the data, and

2. Not all of the theories on late Pliestocene and Holocene climates derived fron various paleovegetation data have been addressed.

IX. Geochemistry Concerns -- J. Bradbury (Handout No. 8)

Mr. Bradbury delineated the geochemical information needs for site characterization, which are:

1. Present geochemical conditions and processes.

2. Changes in geochemical conditions and processes due to waste emplacement.

3. Future geochenical conditions and prccesses that will affect release and transpor t to the accessible environment

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Minutes / Waste Management 23-

-April 28, 1988 Meeting He said that there were no initial objections that were downgraded to comments; that there were 14 comments and 8 questions in this area. The keygeochemicaitechnidalconcernsofNRCare:

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1. Radionuclide transport and retardation, including:

a. Radionuclide precipitation

b. Radionuclide sorption

c. Matrix diffusion

2. The environment of the waste package, particularly the hydrolgic conceptual model with:

a, no fracture flow, and

b. groundwater first contacting the waste package in a dilute solution.

There was an extensive discussion of the effect of gamma radiation on radionuclide precipitation (item 1 a above) resulting in the following observations:

1. DOE coes not plan to do tests on radionucli:e solubility in a gamma radiation field, t

Minutes / Waste Management 24 April 28, 1988 Meeting

2. Gamnia radiation' produces reaction products (peroxides), which can react with the canister or with radionuclides that are released from it. There afe questions as to how important this is.

R. Browning said that NRC must ask the questions now, and it is up to DOE to answer then; versus the NRC asking them later an:t the DOE naving to answer them then. He also said that DOE does not plan to use natural 1

analogs, begarding the composition of the water in the hot springs in the area, Dr. Maxwell convented that NRC should be concerned about the volcanic l

stimulation of water under or near the site. Dr. Steindler said that he understood that NRC does not now know the composition of water in the repository formation. Mr. Brooks replied that DOE uses "J-13" water as a reference water, and that DOE has data on this water, but that they nave not shared it with NRC. Dr. Steindler added that gama radiation produces reaction procucts (peroxides), which can react with the canis'

• or with radionuclides that are released from it. There are questions as to how important this is.

i A copy of Dr. K. Krauskopf's memorandum containing his coments on geochemical concerns is attached to these minutes (Enclosure E). He was l unable to attend the meeting because of other commitments.

X. Waste Package Concerns -- K. Chang (Handout No. 9)

Ninutes/ Waste Management 25 April 28, 1988 Meeting Mr. Chang said that the NRC's primary issue of concern with the DOE waste package program is DOE's interpretation of "substantially complete containment" (i.e., th6 containment requirement of 10 CFR Part 60,113),

and the three related numerical design objectives for performance of the waste package and engineered barrier system. This issue was originally recommended as an "Objection" but was later downgraded to a "Comment."

He also identified three design objectives that 00E set as program goals, viz.,

1. 80 percent or more of the waste package will retain all their l raoicactive material content for a containment period of 1,000 years after permanent closure of the repository.

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2. At any time during the containment period, at least 99 percent of  !

l the radionuclides present from the original waste will be retained.

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3. Releases from the engineered barrier system in any one year during the containment period (1,000 years) should not exceed one part in 100,000 of the total inventory in the geologic repository.

The chief NRC concern regarding these design objectives is that they are:

1. Non-conservative,

Minutes / Waste Management 26 April 28, 1988 Meeting

2. Inconsistent with NRC's rulemcking and (the Comission's) intent of' requiring substantially complete containment during the containment period, and

3. Inappropriate to guide the waste package testing and design program.

The NRC says that, if attained, the design objectives would permit releases of radionuclides from the waste packages and from the-engineered barrier system during the containment period which are substantially in exct.ss of the radionuclide releases permitted during the post-containment period. ,

R. Weller of the NRC Staff said that their primary concern is that if DOE nieets these design objectives, it will fall short of Part 60.

Dr. E riler cbserved that if 10-5/yr is the release rate after 1,000 years, this is not a consistent step-wise interpretation; he agreed with K. Chang on their review of DOE's waste package design objectives. K.

Chang said that DOE said these are just goals.

The NRC position is that they do not expect absolute proof.that 100 percent of the waste package will have 100 percent containment for 1,000 years; however, they believe that it should be possible for DOE to establish conservative design objectives to guide a testing and design program which will lead to a waste package that meets the performance objective for substantially complete containment in Part 60,113. NRC

Minutes / Waste Management 27 April-28, 1988 Meeting-also believes that design of a waste package that will maintain its integrity in the range of 300 to 1,000 years is reasonably achievable.

Dr. Moeller asked why this issue was not an "Objection." R. Browning rep'ied that it falls into the category of a Regulatory Guide, and that he believes 00E is willing to change to meet the Regulatory Guide and that the issue can be brought to closure.

XI. NRC Sumary - R. Browning in a summary statement, Mr. Browning highlighted the following points:

1. Because of cost implications of NRC coments, it is better to raise 2nd and 3rd issue concerns now rather than later, i.e., during the hearing period.

2. The NRC review stauld be as thorough as possible.

3. In terms of trade-offs in various subject areas, why not place more emphasis on a more robust waste package? Then you wouldn't need to know so much detail on radionuclide travel time. We know better how to evaluate a man-made canister than the transport of a radionuclide through the natural environment.

l l

4. The micro vs. the macro picture is an iterative process; it is ,

\

important to keep the broad picture and goals in mind.

)

Min'tes/

u Waste Management 28 April 28, 1988 Meeting

5. The NRC Staff values expert opinion, but would prefer hard data.

Executive Session -

Following the formal meeting, the Subcommittee went into Executive Session during which they extensively discussed the-various presentations that had been made and summarized the key areas where questions remained and problems appeared to exist. On the basis of these discussions, they then prepared in written form their primary comments, suggestions and recommendations. Plans are to submit this meterial to the full ACRS for considerrtion during its 337th meeting, May 5-7, 1988. If the full Conmittee approves, the recommendation will be made that thes comments of the Subcommittee be forwarded to Executive Director for Operations for his information and use.

• • • • • • • • w.******

NOTE: A transcript of the meeting is available at the NRC Public Document Rcom, 1717 H Street, NW, Washington, DC or can be purchased from Heritage Reporting Corporation, 1220 L Street, NW, Washington, DC 20005, Telephone (202) 628-4888. All documents listed in Enclosure C are available in the ACRS files.

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-4 ___ _ _ . _ . _ _ _ _______ . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

, QQ g

. FedIrd Register / Vol. 63 No.'78 / Friday, April 22, 1968 1 Nitices 1 '," MES$63 administrative or atstutory exemption is reported;(3) who will be required or %e agenda'for the esbtect meeting

• not dispositive of whether the asked to report;(4) what the form will shall be as fetlows: N e A ji transaction is in fact a prohibited be used fon (5) an estimate of the -

Weeday. May A 288- 230 *ohnul tra ns action. number of responses; (6) an estimate of

(3)The availability of these the total number of hours needed to g, gg ,4,f FD' exemptions is subject to the express prepare the form. This entry is not .Wedneday. May 4 2988-A#,4.aytd.

conditio ; that the material facts and subject to 44 U.S.C. 3504(h). the conclusion ofbusiness . , %

representations contained in each

Title:

Music Profe:sional Training / ' He Subcommittee will conValse'$s application accurately describes all Music Recording / Centers for New review of material terms of the transaction which Music Resources Application ~ eeview B&W reactors.of the long term H safety .

/. ; 88 is the subject of the exemption Guidelines FY 1989. .  : Oral statements may be present'ed by Signed at Washington. DC. this 19 h day of Frecuency of Collection: One. time members of the public with the Apnl.1988 Respondents: State or local 1 concurrence of the Subcommittee Robert 1. Doyle governmen's; Non profit institutions Chairman; wr(tten statements will be Acting Assxiate Directorfor Regulations and Use: Guideline instructions and 4.ccepted and u '~ available to the Interpretations Pension and We/ fore Benefits applications elicit relevant Committee. Recordings will be permitted Admimstration. US Department of 4cbor. information from non profit only during those portions of the 1 (FR Doc 88493: Filed 4-21-88. 8 45 am) organizations and state or local arts meeting when a transcript is being kept, I aw.,o coce mm agencies that apply for funding under and questions may be asked only by i specific Program categories.This members of the Subcommittee,its information is necessary for the consultants, and Staff. Persons des! ring NATION AL FOUNDATION ON THE accurate, fal* and thorough . to make oral statements shou d notify ARTS AND THE HUMANITIES consideration of competing proposals the ACRS staff member named below as in the peer review process, far in advance as is practicable so that Agency hformation Collection EstimetedNumber of Respondents 250 appropriate arrangements can be made.

Activities Under OMB Review Estimated #ours for Respondents to During the initial portion of the deInformouon 11,800 m, ting. the Subcommittee, along with AGENCY: National Endowment for the Arts. Murray R. Welsh. ~ any ofits consultants who may be Dwctor. Adeinistratire Servkee Drriwa, present. may exchange preliminary Am Notice' NationalEndowmentfoe the Arse- views regarding matters to be SUM M ARY:De National Endowment in [FR Doc 8 Moos Pued 4-21-est He am] considered during the balance of the the Arts (NEA) has sent to the Offia of suseo coot rew e*e meeting. I management and Budget (OMB' the The Subcommittee will then hear i following proposal for the collection of presentations by and hold discussions l Information under the provisions of the NATIONAL SCSDeCE POUNDATION with representatives of the NRC Staff, I Paperw ork Reduction Act (44 U.S.C. Its consultants, and other interested l Chapter 35). Committee Maregement; Renewal; persons regarding this review.

DATE: Comments on this information Alan T. Waterman Award Committee Further information regarding topics collection must be submitted by May 23' The Director of the National Science to be discussed, whether the meeting 1988. has been cancelled or reacheduled, the Foundation has determined that the Aoomassts: Send convnents to Mr. lim renewal of the Alan T Waterman ChaLrman's ruling on requests for the Houser. Office of Mar.agement and Award Committee for an additional 2 opportunity to present oral statements Budget. New Executis e Office Building. years is necessary and in the public and the time allotted therefor can be 726 Ja cksen Place. NW.. Room 3002. interest. Thi: determination follows obtained by a prepaid telephone call to Wa shington. DC 20503. (202-395-7316). consultation with the Committee the cognirant ACRS staff member, Mr.

In additi6n copies of such comments Management Secretariat, General RJchard Major (telephone 202/634-1414)

, may be sent to Mr. Murray Welsh. Services Administation, between 7:30 a.m. and 4:15 p.m. Persons National Endowment for the Arts. M. Rebecca winkler, planning to attend this meeting are Administrative Sersices Division. Room urged to contact the above named

"##'"#"# II'#"*

203.1100 Pennsylvania Avenue, NW., individual one or two daya befort the Apnl 19.1968 scheduled meeting to be advised of any Wa shington. DC 20506; (202 682-5401). .

PoR FURTHER INFORM ATioN CONTACT: (FR Coc 6 Hee 2 Fbd 4-21-e8. 8 45 am) changes in schedule, etc., which may Mr. Murray Welsh, National sa m acoce w w have occurred.

Endowment for the Arts, Administrative e- Date. Aprilla.1968.

Services Division. Room 203,1100 nomas c. Mccr,tes ,

Pennsylvania As enue, NW., NUCLEAR REGULATORY g g. g Wa shington. DC 20506; (202 682-5401) COMMISSION

• 3,,j,j,j,,,

from whom copies of the documents are Advisory Committee on Reactor [nt Doc eHa85 Filed 4-21-88 t 45 am) available. Safeguards Babcock and Wilcox Sum.EutNT Any swoRu anon: The Reactor Plants: Meeting pcootree+ows .

Endomnent requests a review of the s/ ~

reinstaternent of a previously approved The ACRS Subcommittee on Babcock V Adyfoory Committee on Reector .

collection.This entry is issued by the and Wilcox Reactor Plants will hold a safeguards, Subcommittee on Weste Endowment and conta'as the following meeting on May 3-4,1988, Room 1046, Management; Meeung information: 1717 H Street NW., Washington, DC. . .s .

(1) The title of the form:(2) how often ' The entire meeting will be open to The ACRS Subc.ommittee on Waste the required information must be public attendance. Management will hold a meeting on ENCLOSURE A.

---

y

~

i 13364 Federal Register / Vsl. 53. No. 7s / Friday, Aprft 2.2, 1988 / Notices Apnl 28,288, Room 10441717 H Street AtWory Committee ori Reactor (Docaet No. SH411 NW., We shington. DC. Safeguards, Subcommittee on Weste (

l Dettof t Edison Co. and Wolverine The entire meeu,ng will be open to Management; WeeWng Power Supply Cooperative,Inc.

public attendance. The ACRS Submenraittee on Wasta (Forml 2); Exemption .

The agenda for the subject meeting ManaEement wiu bold a meeting on I shall be as follows May 4,19% Room 1167,1717 H Street NW., Washington, DC. Daroit Edloon Co.npeay (DECO) ed Thursday. Apri/23. 2986-3.30 c.m. until ne entire meeting will be open in the Wolverine Powar Supply the conclusion of busines, Cooperative,incorpormtad (the ..

public attendance.

The Subcommittee will receive a The agenda for the subject meeting licensees) are the holders of Facility briefing from the NRC Staff on their shau be as faHows: Operating License No. NPF-43 which comments on DOE : Consuhive Draft of authorizes the operation of the Ferml4 Wednesday, May 4.1986-d.]D a.as, facility at steady. state power levels not the Site Characteritation P{an (SCP) for the Yucca Mountain site.The DOE stMT until the conclusion o/ baness in excess of 3292 megawatts thermal.

wiu address these comments and The Subcommittee will receive a The license provides, amontother provida information as to how the points briefing from the NRC Staff on the thir s, that it la subject to su rules, raised wiD be disposed of before questions of BHow Regulatory Concem te ations and Orders of the Nuclear submission of the SCP. (BRC) and de minimis materials. Other Regulatory Commlision (the Oral statements may be presented by agencies, such as EPA, are expec ed to Commission) now or hereafter in ef#ect.

attend and provide background The facility is a boiling water reactor members of the public with the infonnada. (BWR) located at the licensees' site in concurrence of the Subcommittee Oral statements may be pressn wi by Chairman; wnt'en statements will be Monroe County, Michigan.

members of the public with the accepted and made available to tne concurrence of the Subcommittee U ~

Committee. Recordings will be permitted Chairman; written statements will be 10 CMt Part 50, Appenda J. Section ID A3.

only during those portions of the areepted and made available to the states: Type C tests. Type C tests shall be meeting when a transcript is being kept, Committee. Recordings will be permitted performed dunna each reactor shutdown for g refuelms but 1. no case at intervals greatar only during those portions of the mem ers of the S bco i ee. its rneeting when a transenpt is being kept, than 2 years.

consultants. and Staff. Persons desiririg and questions may be asked only by to make oral statements should notif, ne tests would become due at Fermi.

m' C ' 8' 2 for the lsclation valves which are the the ACRS staff member named beloE as *" '

far in advance as is practicable so th t o ma e a'l te t ould not 'Mf * *emp,, on on Ap apptopriate arrangements can be mat e. the ACRS staff member named below as section of Appendix ] to to Cm part 50 During the initial portion of the far in advance as is pracdcable so that are re ulted by Technical Specification meeting. the Subcommittee may appropriate arrangements can be made. 4.6.1.2 of the Fermi.2 Technical exchange preliminary views regarding During the initial portion of the Specifications.

matters to be considered during the rneeting, the Subcommittee may balance of the meeting.De exchange preliminary views regarding IH Subcommittee will then hear matters to be conridered during tne By letter dated February 22,1988, the presentations by and hold discussions balance of the meeting.ne Subcomittee licensees requested an exemption frorw with representatives of the NRC Staff wiu then bear presentations by and hold section IllD.3 of Appendix I to to CFR and other interested persons regardiAg discussiens with representattves of the Part '20 for certain Residual Heat this review. NRC Staff and otherinterested persons Removal (RHR) shutdown cooling Further information regarding topicz regarding this review. isolation valves. ne licensees to be discussed, whether the meeting Further information regarding toples requested that the initial 24 month has been cancelled or rescheduled, the to be discussed, whether the meeting testing interval for three RHR shutdown has been cancelled er rescheduled, the cooling inboard isolation valves (E11-Chairman's ruling on requests for b Chairman's ruling on regoests for the Foo9 E11-F408 E11-F808) be exteeded opportunity to preseM oral statements opportunity to present oral statements on a one-time basis until the Ftret and the time aHotted therefor can be refueling outage which should be no and the tirre allotted therefor can be cbtained by a prepaid telephone cau to the crymrarrt ACRS staff raember. Mr. obtained, by a prepaid telephone call to later than the end of 1989.

the cogntrant ACRS staff mesnber, Mr. The licensees have indicated that Owen S. Merrill(telephone 202/634- Owen S. Mernu (telephone 202/834- performing the leak testing on these 1413) between 7.15 a.m. and 4.15 p.ta. m3) bWun m s m. and 4:15 p.m. three vehes will require one or both of Persons plarning to attend this meeting Persons pianning to attend this meetic.g the following plant conditions:

are urged to contact the above named are urged to cuntact the above named (a) Reactor vessel head removal:

individual one or two da): before the I (b) Both RHR shutdown cooling loops scheduled meeting io be advised of any "[,' "{'d ,

rendered inoperable.

changes In schedule. etc., which may chap in scheme, Hrshid may The licenseu have currently hase occurred. have occ"tred.

- . .. scheduled the next reactor head removal Da* Aptd 18,19a8. D6se:Apn] 18,198a* cperation to occur during the first Th= G. Mconsus- . Themaa G. McCronese. .tfueling outage. To teridee both loops of Arrhennt hewthe DemsprArTweef A m awe n ec.o ,,a m s rA rT.cAread ,1HR shutdown cooling inoperable, b Activitim. - Acom s. Licensees would either be required to remove the drywell and reactor haads

[nt Dec. as-aaan n! d 4-twa *4s and [nt Dec. es-aaar nled +-22-et **4 am! and flood the venssi, or wait antil deca)

= = caoss ws . ,

saAme cocavs c a l

l

PRESENTATION SCHEDULE ACRS SUBCOMMITTEE ON WASTE MANAGEMENT APRIL 28, 1988

-Room 1046, 1717 H St., NW Washington -D.C.

TOPIC: CONSULTATION' DRAFT SITE CHARACTERIZATION PLAN (COSCP) 8:30 - 8:45 a.m. 1. Introduction - D. Moeller 8:45 - 9:15 a.m. 11. Introduction - J. Linehan, J. Youngblood 9:15 - 9:45 a.m. III. Overview of CDSCP Review - K. Stablein 9:45 - 10:00 a.m. BREAK 10:00 - 10:45 c m. IV. Quality Assurance Concerns - J. Kennedy 10:45 - 11:30 a.m. V. Performance Assessment Concerns - D. Galson, J. Trapp 11:30 - 12:00 Neon VI. Engineering Concerns - D. Gupta 12:00 - 1:00 p.m. *** LUNCH 1:00 - 1:45 p.m. VII. Geology Concerns - C. Abrams 1:45 - 2:30 p.m. Vill. Hydrology Concerns - B. Ford, D. Chery ,

2:30 - 2:45 p.m. BREAK E:45 - 3:30 p.m. IX. Geochemistry Concerns - J. Bradbury. D. Brooks

?:30 - 4: 15 p.m. X. Waste Package Concerns - K. Chang 4:15 - 5:00 p.m. XI. Executive Session - D. Moeller Subcommittee Chairman: D. V. Moeller Staff Engineer: 0. S. Merrill j Telephone: (202)634-1413 '

i i

ENCLOSURE B

LIST OF DOCUMENTS DISTRIBUTED DURING THE MEETING OF THE ACRS SUBCOMMITTEE ON WASTE MANAGEMENT

. APRIL 28, 1988

1. Briefing on the NRC Staff Review of the DOE CDSCP for the Yucca Mountain, Nevada, Site, B. J. Youngblood and K. Stablein, April 28, 1988.

2. Quality Assurance Concerns on CDSCP.

3. Compliance Demonstration Section: Scope of CDSCP Review.

4. Conceptual Model (and) Scenario.

5. CDSCP Review, Geotechnical Engineering / Design Section, D. Gupta, et. al.

6. Geology / Geophysics Section, Presentation of CDSCP Point Papers, C.

Abrams.

7. CDSCP Review, Hydrology Section.

8. CDSCP Review, Geochemistry Concerns, J. Bradbury.

9. Presentation to the ACRS Subcommittee on Waste Management on the Primary Issee of Concern With the DOE Waste Package Program, K.

Chang, April 28, 1988.

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ENCLOSURE C l 1

a h *

• 0. MERRILL ACPS SUBCOMMITTEE MEETING ON WASTE MANAGEMENT LOCATION Annm 1046.1717 H St. NW. Washington, D.C.

DATE April 28,1988 .

ATTENDANCE LIST NAME AFFILI ATION D. w'. At o c u.erz A CR 5 M em ver '

U h'l. J . $ Y W N b l W " -

p.s.Smnuou n J MA>cwe a C e w. w i r> w r '

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ENCLOSURE D

' O. MERRILL l l

. ACPS SUSCOV.MITTEE MEETING ON WASTE MANAGEMENT LOCATION Pnnm 104 6. 1717 H S t . NW . Washington, D.C.

l DATE April 28,1988 .

ATTENMNCE LIST NAME AFFILI ATION

$ YWorY $8 et" /) lev D0E Ra.Wn %tn Doe J w~s v~. ,e~ans k a  :

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G. MERRILL ACRS SUBCOMMITTEE MEETING ON WASTE MANAGEMENT LOCATION Rnnm 1046.1717 H St. NW. Washingt;n, D.C.

DATE April 28,1988 .

ATTENDANCE LIST PLEASE PRINT:NAME AFFILI ATION 6eorse Le w IvMSL #4C (+91sn?

WJ.' hlA s /-Ic rf 27- vt24h Mc\w, Nann] 9h Ossadre, b h)u h kwa4 ks aa e T>O h

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0. MERRILL

<5'SUBCOMMITTLE MEETING ON WASTE MANAGEMENT __ __

.0L AT,10ll f Room 1046,1717 H St. NW., Washinoton, D.C.

'DATE:

April 28, 1988 ATTENDANCE LIST PLEASE PRINT:

NAME BADGE NO. AFFILIATION l,

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STANFORD t f UNIVERSITY TEINtt0NE: (415)723-2537 bMtT%ENT'OF GEOLOGY inum woun rreenomfu School of Eav Scierets Sunford,Cahforma W30 Mil 5 20 April 1988 ,

RICEWED ..

Mr. O.S. Kerrill, Senior Staff Engineer . h* g, ACRS, Nuclear Regulatory Cocaission ~ #

Washincton, DC 20555 s 2 5 19861 I. : PU

Dear Owen:

7:U;i .'.M!j.%2 I1_tSid15is Yesterday I rashly offered to look over the NRC staff geview of DOE's CDSCP .

and make sone co::ents on it, in lieu of attending the subcensittee meeting next week. I find it difficult to make pertinent comments, and particularly to pick out gaps that have been overlooked, when I have only the review and not the original do:ument. In general it seems to me that the review is very thorough, I'veand finding restricted any gaps is like looking for the traditional needle in a haystack.

oy exaniration to hydrology, geochemistry, and geology, the only parts for which I can claim any expertise. ,

For hydrology I have nothing to offer -- seems to me the "Comments" and In "Questions" cre reasonable and well-based, and the recommendations should be helpful.

geochecietry it seems to ee that so=e of the review is almost too thorough, inFor that it asks DDE to undertake research that will be expensive and time-consuming.

example, in Comment 17 a determination of free energies of zeolites and albite by calorimetry is reco=cended. Is it really necessary to get these free energies so occurately? I don't kno.: what use DOE plans In to make of them, but I doubt that great Comment 20, study of competition among refine =ent is needed for their purpses.

radionuclides fo2 sorption sites is recommendedt here I might add that competition with othg nonrodioactive ions might be added to the recommendation (e.g Sr and Ca).

between to nctural analogs, but there ought to be aome restriction on such study -- research on natural analogs can go on indefinitely. As a general comment on geochenistry (and perhaps aleo hydrelegy). I wonder if DOE should be reminded that G-tunnel provides a natural envirer.aent very euch like that of the expected tunnels in the Topopah Springs, for possible in-situ experiments on sorption, solubility, and ground-water mover:nt?

Under geology again I found no gaps, but wonder if some of the recommendations don' t savor a bit of overkill. For example, the recommendation for Comment }8 seems to propose an exhaustive program of deep drilling and minutely detailed mapping to explore for possible ores; this would be tre endously expensive, and the chance of locating an ore deposit under the thick alluvi m seems so slim as to make it hardly worthwhile. I wonder also if the recommended detailed studies of earthquake risk are necessary? Would an earthquake, even a large one, really have =uch chance of libera-ting much radioactive material from a repository' above.the water table in this sort .

of climate?

Sorry I can't do better. You mentioned a possible meeting on 7-8 June; if my /

presence is wanted. I should tell you that I am scheduled to return from China on (If Barbara Jo 31 May, so arrangements for travel will have to be made in a hurry.

makes my reservations for a place to stay, please tell her it should be the lesbardy this time, not the Cosmos Club.) /

u n_fa, With best regards,l// (1WL

' GGf fI q GCP ~ Konrad B. Krnuskopf ENCLOSURE E

_ _ _ _ _ __