106th ACNW Meeting U.S. Nuclear Regulatory Commission, February 24, 1999
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *** MEETING: 106TH ADVISORY COMMITTEE ON NUCLEAR WASTE (ACNW) *** U.S. Nuclear Regulatory Commission Two White Flint North Room T-2B3 11545 Rockville Pike Rockville, Maryland Wednesday, February 24, 1999 The committee met, pursuant to notice, at 8:32 a.m. MEMBERS PRESENT: JOHN GARRICK, Chairman, ACNW GEORGE HORNBERGER, Member, ACNW CHARLES FAIRHURST, Member, ACNW RAY WYMER, Member, ACNW MARY L. THOMAS, Member, ACNW. PARTICIPANTS: PRESENT FOR THE ACNW STAFF: DR. LARKINS ANDREW CAMPBELL LYNN DEERING RICHARD K. MAJOR ACNW CONSULTANT: MARTIN STEINDLER PRESENTERS: ERNEST L. HARDIN, Technical Lead, Near-Field Models, DOE Office of Civilian Radioactive Waste Management CAROL L. HANLON, Yucca Mtn. Site Characterization Office, DOE Office of Civilian Radioactive Waste Management DAVID STAHL, Waste Package Materials Dept., CRWMS/ M&O Natural Environmental Program Operations, DOE Office of Civilian Radioactive Waste Management DWIGHT T. HOXIE, Process Models and Performance Assessment Support, CRWMS/M&O Natural Environment Program Operations, DOE Office of Civilian Radioactive Waste Management PARTICIPANTS: [Continued] PRESENTERS: [Continued] STEPHAN BROCOUM, Office of Licensing and Regulatory Compliance, Yucca Mtn. Site Characterization Office, DOE Office of Civilian Radioactive Waste Management. P R O C E E D I N G S [8:32 a.m.] DR. GARRICK: Good morning. The meeting will now come to order. This is the second day of the 106th meeting of the Advisory Committee on Nuclear Waste. This entire meeting will be open to the public. Today the committee will hear presentations by NRC Staff and DOE on the viability assessment for repository at Yucca Mountain and we will meet with representatives from the Nuclear Energy Institute to hear their perspective on upcoming 1999 high level waste initiatives. Dr. Andrew Campbell is the Designated Federal Official for the initial portion of today's meeting. This meeting is being conducted in accordance with the provisions of the Federal Advisory Committee Act. We have received no written statements of requests to make oral statements from members of the public regarding today's session and should anyone wish to address the committee, please make your wishes known to one of the committee staff and as usual it is requested that each speaker use one of the microphones, identify himself or herself and speak with sufficient clarity and volume so that he or she can be readily heard. The committee member that has the lead on viability assessment is George Hornberger and George will moderate and orchestrate the discussion that we are going to have this morning. DR. HORNBERGER: Are you ready to start, John? DR. GARRICK: Yes. DR. HORNBERGER: Is Steve here? We are just going to start right in and we'll hear first from Steve. DR. BROCOUM: I assume I am on line -- sounds like I am. Lake was supposed to give this presentation but he is unable to attend, so they have asked me to speak for him. Lake had prepared his remarks in detail so I prepared remarks for myself and I guess for Lake -- Status of Yucca Mountain Project. I understand you wanted to focus on looking ahead as to looking behind, so I will quickly summarize. The Congress had directed us to prepare the viability assessment, that report, and we issued that report in December, on the 18th I believe, and it gave the status at that time of site characterization. It identified the key issues that will be addressed before we can proceed with the site recommendation. Some of the if you want to call them conclusions or statements in the viability assessment -- the viability assessment stated that Yucca Mountain remains a promising site for a geologic repository. This word "promising" created a lot of debate within the Department of Energy and a lot of internal discourse before we were able actually to state that. If you look in the overview, you can get the exact words. The mountain has been stable for at least a million years. Our performance assessment suggests that at least for the first 10,000 years after the repository is closed, people living near Yucca Mountain would receive little or no increase in radiation exposure, less than a millirem over the first 10,000 years, and the cost to develop the repository, on the order of $36 billion, taking all historical costs into account. Some of the characteristics of Yucca Mountain, and those who have heard our repository safety strategy will recognize this is reworded by similar -- on the whole water moves through the mountain, slowly percolates at six, seven millimeters a year on average. Little of this water would contact any waste packages, and that is of course part of our ongoing research. The waste packages would substantially contain waste for thousands of years. As you know we are looking at making the waste packages even more robust than they are today. If there was a breach of the waste packages there would be a low release of radionuclides and finally the concentration transport of radionuclides released from this package would be reduced by adsorption, dilution, other processes. These four things make up our repository, the key attributes of our repository safety strategy. The key uncertainties that need to be addressed before an evaluation of suitability and therefore site recommendation -- more information on amounts, the rates, and the mechanisms for water seepage into the repository. Seepage of water onto the waste package is our most sensitive parameter in our performance assessment. More information is needed on the waste package materials for long-term performance and also we had to recommend that we evaluate alternative design concepts, which we are doing. Cladding is an area of intense debate within the program. How we can demonstrate -- we know we have cladding but how we can actually demonstrate it at a licensing hearing has always been a big issue. We need to look at that some more. Finally, the interaction between the repository and the natural system, that coupled processes in and around the waste package, the engineered barriers and the rocks around there is one of the big drivers for alternative designs, particularly for the very hot alternatives. There should have been another bullet on here, and think there was in an earlier draft, the saturated and the unsaturated zone, movement of water through the saturated and unsaturated zone after it leaves the drifts, and you will have some discussion on that today certainly for the unsaturated zone from Ernie Hardin. The whole VA was built around our reference design, so that we had a consistent basis for early analyses of performance assessments and sensitivity studies, the uncertainty that we presented in the VA. We are now evaluating design alternatives. I think you heard quite a bit of that yesterday for the process from Ric Craun. Our goal is to choose a design to move forward with to site recommendation. One of the big issues is the temperature ranges. We are looking five alternatives from a very low thermal load to a very high thermal load and we are looking at design features that would minimize contact of the waste with water. The key thing is water here. If we can keep water off the waste packages, if we can keep water off of the waste itself, the performance is really enhanced. Finally, we are looking for design flexibility to allow us to close the repository as soon as 10 years after emplacement of the last waste or as long as 300 years after emplacement of the last waste. The idea here is a recognition that we are not going to be the decision-makers at the time it's time to start debating repository closure. There will be other people in my shoes. There will be other people sitting around this table and therefore that is an explicit recognition that some future generation will actually make this decision. This criteria in some cases may be difficult to implement. For example, closing as early as 10 years after emplacement of the last waste puts severe -- could put severe constraints on a thermal load repository because one of our other criteria is not to raise the cladding temperature over 350 degrees C., so if you just emplace the waste and you put backfill in and you close, you would probably not meet that 350 degree C. cladding criterion, so there's a lot of issues here and as we come up with alternatives we will have to revisit this requirement. The United States Geological Survey did a review of the viability assessment before it was released. That review was done by USGS in Reston. They generally agreed that a repository could be designed and built at the Yucca Mountain, however they raised several important issues from their point of view. They believe that most of our models for the flow of water through the mountain are overly conservative. In other words, they think we have more water flowing than they believe is the case. Since in their view we have overly conservative assumptions, they believe that those overly conservative assumptions have driven our design and in some cases we may not have an optimum design for Yucca Mountain, so this is an important thing we need to look at. They recommended an expert elicitation be completed for future climate to provide more representative filtration estimates. We have planned that into our program this year. They believe that a repository should be designed so performance confirmation monitoring can be undertaken that is efficient and comprehensive, and one of the major concerns they had here was that in our reference design we had the concrete-lined tunnels which they felt would impact the ability to look at those tunnels once you have emplaced waste. They recommended also that a cooler repository be considered, cooler than the 85 MTU per acre that was in our reference design, so these in a nutshell were the concerns from the United States Geological Survey. I need report on another report that just recently came out or will be out very shortly -- TSPA Peer Review Panel has issued a report. The report is dated February 11th. I didn't receive my copy until February 18th. That report also has a lot of comments about the robustness of our PA. It puts them into three general categories. In some areas things are very complex and they may be difficult or impossible to analyze with our current state-of-the-art. In other areas we may not have enough data and they are very concerned about that, and third -- let's see. There was a third -- oh, our assumptions in many cases may not be adequately justified. Those three areas. So that panel has a public meeting scheduled for the 17th of March in Las Vegas. So that's some of the other input that's coming on the VA so far. Basically what they recommended, so I just finish my thoughts here, in areas we don't have enough data to get more data, in areas where things are very complex and they're not necessarily easily analyzable to be conservative, in areas where the assumptions are not adequately justified, justify your assumptions or make conservative assumptions. So our next steps. We're planning to complete key tests and analyses to update our process models and to continue to enhance our design to address those uncertainties. And that will of course be the new design or the enhanced current design we choose to move forward with. We are trying to transition from a reseach-and-development-type culture to a regulatory culture where we are the owner-applicant, we're in full compliance with QA and all its procedures, and all our technical positions are fully documented. And this is taking a lot of our effort this year. So we have put a lot of attention on quality initiatives we're trying to resolve. We have five open concerning data, traceability, procurement, and so on, and we have reorganized the project to enhance our quality and excellence. In my mind VA is history. It was off my table whenever we got it done; we actually got it done the end of August. It took us a few months to get it out of the Department. And we focused from the VA, now we're thinking of EIS, the draft EIS is coming out this year and the evaluation of the suitability to Yucca Mountain. We recognize that we have some deficiencies regarding documentation and traceability of data. We've done several vertical slices, and that's what the data has told us. And in our process models, you know, fully documenting and tracing them has been a challenge. So we developed a plan to become fully compliant with all QA requirements that we develop appropriate documentation and that the data is qualified or identified as nonqualified. That means that we're putting a lot of emphasis on the data we have in house as opposed to getting new information. Not that we're not getting new information. But we're paying a lot of attention to making sure that the reports we put together that support suitability and the suitability of the LA are fully documented and are fully traceable. We have undertaken the process validation and reengineering activity, which we look at all of our technical and business practices to make sure we understand what we're doing, lay them out, and then if there's something wrong with them, we're fixing them. So basically for each key area, technical area, we are in a sense seeing what the present process is, seeing if it needs improvement, and if it needs improvement, improving it. We are hoping, and the goal in fact in doing this is to minimize the number of procedures we have. We have today overlapping -- numerous overlapping and very complex procedures. In fact, we have something like on the order of 580 procedures. The goal is to have less procedures. We have several review procedures. We have several procedures for each thing we do. What we're trying to do is have one procedure that all parties could use. And that's part of that goal. A little bit about organization. We have three key offices, the Yucca Mountain Site Characterization Office, the Office of Acceptance, Transportation, and Integration, Dwight Shelor, Acting, and the Office of Program Management, Dwight Shelor also Acting. This slide is out of date. Sam retired at the end of December. We have four key offices at Yucca Mountain, the Office of Project Control, the Office of Project Support, the Office of Project Execution, and the Office of Licensing and Regulatory Compliance. These are the two offices that do all the technical work. This next viewgraph is just here to show you in addition to the four offices at Yucca Mountain I talked about -- these are the four -- the other direct reports to the project manager. We have people at headquarters that report directly to the project manager. We have a chief counsel. And we have an Office of Institutional Affairs. I will talk about the Quality Assurance Assessment Team on my new viewgraph. The idea here was to set up a customer-supplier type relationship where the ultimate customer is the Secretary of Energy for site suitability or the Congress or the NRC for a license application. My office would define the requirements that are needed to meet that need. The Office of Project Execution goes and collects all the information. For example, they're responsible for doing the TSPA's. They're responsible for doing the site description. They're responsible for doing all the detailed technical reports. These two offices are supported by these offices, Project Control, which takes care of cost and scheduling and that kind of stuff. The Project Support, all the other contractual support you need to run the program. And finally the Office of Quality Assurance has an assessment team. If we need -- if we have some question about if we're following procedures correctly or implementing QA correctly or things are traceable, we can call in the Office of Program Assessment to help to do an assessment, whether it's a formal QA, order of surveillance, or an informal surveillance to tell us how we're doing. As an example, I'm asking this office to come and look at the process we have for reviewing the EIS to see if it meets our requirements in the project right now as the EIS is going to major reviews. Again, the technical work, these two offices have to work very closely to get the work done, and the next viewgraph tries to get at that. On the right are the key products that will be coming out in the next few years. For example, this summer we have our draft EIS. We have a site recommendation, which I'll talk about a little more in a few minutes. And if suitable, the LA. On the left we have all the detailed engineering and scientific reports. And the middle is the interface between the products we need to get out in a sense for our customers and all the detailed work going on in the project. So as manager of these key products, what I'm trying to -- these licensing and regulatory products, I'm trying to focus on major technical reference reports that we can draw on to write our products. And this is an example of the major technical reference products. And then -- so my span of responsibility goes from the key licensing and regulatory products through these major technical reference reports. Dick Spence, the head of Office of Project Execution, his responsibility is making sure all the detail work gets done that supports the production of these major technical reference products which we need to get out, our major regulatory products. That's how we're working together so that I, responsible for these things, don't have to worry about the myriads of reports that are produced by all national labs, the GS, and within the M&O. We do have a comprehensive multiyear plan that will lead to a final EIS in 2000, will provide we hope the basis for collecting sufficient information for a defensible evaluation suitability in 2001 and if suitable a recommendation to the President that we proceed with submitting an LA to the NRC. That comprehensive plan was iterally produced as reproduced volume 4 of the VA. Volume 4 covers a period from today to license application, and Carol Hanlon will talk about that in the next presentation. Our key major products for this year. Since the VA was this year, this fiscal year, that's on the slide. We have internal draft right now an annotated outline for the site recommendation. That's due in March of '99. We are working on the design alternatives which Ric Craun told you about yesterday. That's due in May of '99. We will issue our draft environmental impact statement in July. And we have a working draft license application. We're going to probably change the name of this to working draft license application outline in August of '99, because it will not be a full draft LA. I just put this up here so you could get some idea of the key milestones coming up. And our next big key milestone is if the site is suitable for site recommendation. These numerous things on the top here are all the steps we think we need to go through to issue our site recommendation. You know, everything from hearings to completing the hearings, having comment period, concurrence drafts, receiving State of Nevada comments, receiving NRC sufficiency comments, we now have it scheduled for 5/25/01, completing our review and issuing it on the 27th of July. So that's kind of we've laid out our schedule to do this. These are the key feeds from science and TSPA, and these are the key design feeds into the process. So you see we have a lot of detail here on site recommendation. We don't say too much about LA, because right now on our near-term horizon for the next two years is the suitability and site recommendation. This is kind of in a graphical form how we view our site recommendation package. The bottom of the pyramid is all the information we've collected in site characterization. Second layer are all the detailed reports. Those would have been the ones on the left side of the document I talked about earlier in general. The third, and I will talk about this in a little more detail in the next few viewgraphs, what the site arrangement itself will look like, we'll probably have an overview, a short recommendation, a letter from the President to Congress if we ever, you know, get that far. We're now envisioning four volumes, but as we work through our outline, we're having a lot of debate on these two volumes here, and it's conceivable they'll be combined or put in some other order. But as we see it today, a volume will contain the technical information required by section 114 of the Nuclear Waste Policy Act. That includes a description of the design of the proposed facility, a description of the waste form and of the waste package, and a discussion of the information collected during site characterization relating to the safety of the site. Volume 2 would be our analysis of the suitability of the site using our guidelines. Those two volumes would be completed by or around November of -00 so when we go into hearings, those two volumes would be issued in draft form for the hearing process and public comment. Volume 3, which would not be ready in draft form for obvious reasons, other information required by Section 114 of the Nuclear Waste Package, the views and the comments of the Governor and legislature of any state or affected Indian together with the Secretary's response -- obviously we won't get those until after the hearing process, any other information the Secretary considers appropriate and any impact report submitted by Nevada to the Department. Volume 4 would contain the Nuclear Regulatory Commission's preliminary comments on sufficiency of site characterization, and finally the final EIS will accompany the SRR. So the first two volumes are information we, the Department, can put together with our own internal information, and those we will release to the public for public comment. Volumes 3 and 4 are information that we get from outside -- NRC's comments and the State of Nevada's comments and so on, other states and Indian tribes, so Volumes 1 and 2 would be out for public comment and as the information comes in we would put together Volumes 3 and 4. Is that a fire alarm? MS. DEERING: No, it is an announcement. DR. BROCOUM: What are our key priorities this year? The number one key priority is implementing an effective, efficient program process, validation and hearing process. That is when we look at all our business and technical processes and make them more efficient -- develop defensible, traceable and reproducible technical baseline -- complete our draft EIS and select our design for our possible site recommendation. We are conducting detailed planning for how we would evaluate suitability and a possible site recommendation. That is the annotated outline I mentioned. We are conducting investigations on reducing key uncertainties. Those include the waste package, the saturated zone, the unsaturated zone, seepage into the drifts -- those kinds of things. We are going to revise the process models, try to make them more representative of site conditions for the next iteration TSPA which would be for the site recommendation. We are trying to complete the system description documents. Those are what define the whole design. We need them to do the TSPAs for the site recommendation. We are working on a working draft license application outline -- they've got it right on this viewgraph. That is kind of where we are at the moment. DR. HORNBERGER: Did you guys at least take a deep breath at the end of August after you finished the VA? DR. BROCOUM: No, because we had a lot of internal -- the Secretary did an internal review so it was a lot of -- we finished but then we had to respond internally to a lot of questions and that kind of thing so it was a small breath but I wouldn't say it was a big break. DR. HORNBERGER: Do we have questions for Steve? Marty? DR. STEINDLER: Two things. One, I noticed in this Table of Organization one of the things that is not clearly evident is somebody responsible for communicating with the outside world. There is no relations indication or anything like that. Does that mean you haven't got the message or that it just got buried in here someplace? DR. BROCOUM: If you look -- that is why I showed this chart, in part. The Office of Institutional Affairs -- these are the key offices doing the work and supporting the work done. There is an Office of Institutional Affairs under Alan Benson. It's his job to do. For example, now we are having a series of public meetings. We had one yesterday in Reno and we had one last week in Amargosa Farms -- public update meeting we call them. DR. STEINDLER: But my other question is more technical. In Volume 2 of the site recommendation documents, what level of detail do you anticipate putting into that in relation to -- as measured by, for example, the final documents that you would submit for the license application? Same kind of level or -- DR. BROCOUM: I don't see the same level because if it was the same exact level, the next day, assuming it was recommended, the next day we submit a license application. I view this more as a proposal. You know, it's looking pretty good. We think we can make it, but we are not the NRC. We can't say -- but from our perspective it looks like we ought to move forward, so in my view in these volumes we would have a fairly comprehensive analysis of the post-closure because that is the -- I don't want to call it beyond the state-of-the-art but that is the thing that has never been done before. We would have a less comprehensive analysis of the pre-closure design. It would be less developed. I think for an LA the NRC would of course want more detail on design, on the concept of operations and that kind of stuff, so certainly in the pre-closure area I would see less detail here and in the performance assessment area, I have a lot of detail. It might not be fully traceable to the standards that the NRC would require for a licensing hearing. DR. STEINDLER: But you are not going to have enough time to get any significant amount of additional data so it is a question of what you already have, the fraction of that you are going to put in the Volume 2. DR. BROCOUM: That is correct. One of the things we are thinking that we are going to do for the TSPA this time around is write a report for each key process model. That report would contain all the information -- we are calling them Process Model Reports, PMRs. We will try to make that report as stand-alone as we possibly can -- [Pause.] DR. BROCOUM: Anyway, so these PMRs, we would try to make them as self-contained as possible so this report and any references to it will be fully traceable, fully qualified, and fully support those process models and their abstractions. We may not have those fully completed for site recommendation. Right now we are planning eight or nine of those I believe, and that is all in the planning stage. That is why I can't be more definitive. DR. HORNBERGER: Other questions? Charles? DR. FAIRHURST: Steve, I don't know, maybe I should defer this to Ernie but yesterday Richard Craun and you mentioned it briefly here, the high temperature, low temperature, and then you had a third, which was the enhanced access was a significant consideration. What I want to know is you mentioned the problem of putting in backfill and high temperature with 350 C. problem. Is the enhanced access needed at all for a low temperature repository? It is primarily a high temperature concern, is it -- because you have to keep the things open longer and -- DR. BROCOUM: Sure. Well, I mean enhanced site, you have to be able to put in radiation -- say you had to go in and work on the waste package -- DR. FAIRHURST: Yes, I know -- DR. BROCOUM: -- you would have to put radiation protection, that kind of stuff. What we are thinking of now is enhanced access is a feature that we can add to any option, so it is not -- Ric should have mentioned that -- it is not being thought of as a third design anymore. DR. FAIRHURST: No, he didn't say that. He didn't say that. DR. BROCOUM: Right. DR. FAIRHURST: I am just saying that from what I heard you say it seems to me it would be less necessary if it was a low temperature design. DR. BROCOUM: I would say it would be easier to implement. I think we are saying very close to the same thing. DR. FAIRHURST: Because I am saying -- you have a low temperature option which I am beginning to think has got a lot of merit to it, and that two of the other three concerns, the high temperature and enhanced access, would probably obviously not be required. But the other thing -- what is the major disadvantage? Is it a question of real estate with the low thermal? DR. BROCOUM: It is real estate. It is about double the real estate, I believe. DR. FAIRHURST: I understand that. DR. BROCOUM: It might add some more cost because you are going to construct more drifts. It depends on your point of view whether that is a disadvantage or not. It's really a trade-off. DR. FAIRHURST: But is there a concern for the real estate available? In other words, you know, is there a limit -- DR. BROCOUM: There is some concern but I think we're pretty comfortable. I think even the low temperature will fit in the upper and the lower blocks. DR. FAIRHURST: And that is all with a single layer repository, right? DR. BROCOUM: Yes, but the blocks would be offset slightly if you have to go to the lower block but they are not overlapping. DR. FAIRHURST: Yes. Okay. DR. BROCOUM: I want to make a comment on that. The issue here is keeping the waste packages either, as we like to say, cold and wet or hot and dry -- not warm and moist, and you have to worry about a thermal profile through time relative to the materials you have selected and so you have to work all of that out to make sure you minimize your time in the corrosive regime which is warm and moist. DR. FAIRHURST: You don't feel it is possible to have cold and dry? It's hard to prove. All right. DR. BROCOUM: It is hard to prove and many people believe that once you have shut off -- if there is no ventilation and you shut it off, the relative humidity will go up to 100 percent. Now dripping -- who knows? DR. HORNBERGER: Ray? John? DR. GARRICK: In one of your slides you said as one of your next steps the project is transitioning from a research and development orientation to a regulatory culture -- which is kind of a mouthful -- just as the transition to an environmental cleanup agency has been a tremendous challenge to you. Are you taking advantage in that transition of the enormous experience base that already exists in working in a regulatory environment? One of the things that I think is very impressive and not talked about much is the maturity of the nuclear power industry with respect to the implementation of QA and the whole process that has evolved over the last 30 years in that regard. It seems to me there's a lot of expertise out there to help you in that area and there's not much excuse for not tapping it and not much excuse for being clumsy about that transition. What are you doing about that? DR. BROCOUM: Well, you know, the M&O has brought in several senior managers that have nuclear licensing experience. Dan Wilkins, who is Acting General Manager right now, running the whole M&O in other words -- he's had experience over I think 30 years at General Electric in the nuclear business. Jack Bailey, who is a regulatory lead over there, has had experience. Winston & Strawn, the lawyers that work for the M&O, have had experience in the nuclear business. They have set up a detailed training program. It is an all day program that every employee on the project is required to go to. That is being given right now, where they actually go through some examples. They even go through some example hearing type questions and how people had to answer questions and where they were not traceable, you know, how they lost their credibility, so there is an intense effort going on I would say for the last six months here to take that experience and bring it down to the 2000 troops. Also I believe NEI is going to come in and look at some of our programs from their perspective and give us some advice as to how we could better emulate industry. On terms like "commitment tracking" we are trying to use industry practices for commitment tracking with the NRC. We visited several nuclear power plants to see how they meet their commitments to the NRC, so there is a whole series of activities like that that we have been undertaking. I am not sure if we are missing anything, but that is the kind of stuff that we have been doing so far. DR. GARRICK: Yes. Well, I think that the fact that a lot of U.S. plants now are making it into the Top Ten World Performers, and if you look at those plants that are doing that, one of the contributing factors is in many instances the maturity of the QA process and the expanded interpretation of that process, so that was just a thought. The other thing I noticed, you talked about something that caught my attention of selecting a design in 1999. Given what we have been seeing and reading and hearing as to the options and alternatives and variations on the design, it appears that you are going to have a tremendous convergence here -- DR. BROCOUM: We hope so. DR. GARRICK: -- in the next few months -- [Laughter.] DR. GARRICK: -- and I guess I have a little difficulty seeing how that is going to happen that quickly given what we have been hearing about alterative designs and maybe it is just what you mean by a design. Yesterday, we had the meeting divided into two categories: design of a rather basic and elemental nature and design features that, while there may be an ongoing and continuing change in design features, the basic design decisions are likely to be forthcoming here. Not that we believe that you should necessarily freeze a design until you have what you consider to be a good design, the best design, but we are interested in knowing what you mean by what you say. DR. BROCOUM: I think we're more talking about the basic design, you know, the thermal loading probably, the sizes of the waste packages, the base materials, you know, whatever the factors the engineers need to go on, you know, you'll be able to hand it down in more detailed engineering to do the proper tradeoff, not to have all the -- I'll call them bells and whistles frozen in May. Some people say we should only decide whether it's high or low temperature. There's a big debate going on in the project as to exactly what the decisions we have to make are. We've set up an application design integration group that consists of myself as the chairman, Rick Craun, Dick Spence as the key feds, Wilkins, Mr. Snell from the M&O is the chief designer, and several other people, to sit down and decide what decisions we are going to make because we haven't laid those out exactly. We're working on those right now. There's a big workshop coming up in the second seek in March where the designers are going to get together, you know, and debate all the different permutations and everything they've been thinking about. But we're going to make the decisions we have to make to be able to go on with the process. So we have to make some decisions. We're not going to make every single decision, but we're going to try to at least get the path that these designers have to go down. I think that's what we're basically talking about. So that's more on the basic side of your discussion. DR. GARRICK: Thank you. DR. HORNBERGER: Steve, this isn't the first time, of course, that we've heard that DOE has some problem, shall we say, in the area of QA. Now, this time, of course, you're going to assure us that you're going to solve these problems. What I'm curious about is -- because again, the time gets so compressed for doing these things looking at your time line. We might divide them up into three kinds of problems. The first kind of problem might be that, okay, there's a problem with these data because somebody didn't fill out Form 7937 giving the model of the spectrometer or something, not too serious. I can believe that you could fix those. Another kind of data problem could be where the person didn't record a calibration curve for an instrument, and whether or not you can go back and do that could put the data in real jeopardy. Then the third would be that the data really are questionable. What's your mix of problems? DR. BROCOUM: The mix is mostly the first two. DR. HORNBERGER: Okay. DR. BROCOUM: For example, on a procurement, there are some cases where we haven't necessarily done the procurements correctly. So all the data that came out has been out -- labelled as indeterminate. That doesn't mean it's necessarily indeterminate, but until we sought that procurement thing out, they were all labelled as indeterminate. So a lot of our data looks like it's of indeterminate quality when, in fact, when you look at it in detail, it's not quite that bad. I'm hoping that's the way -- that's what the evidence show so far. But, you know, all this work has been done by national labs, by world-class organizations, so I think from a scientific or engineer perspective, they followed at least their normal standards. By the actual standards of QA where an independent auditor has to come through and be able to trace everything through, you know, and everything is checked off, we don't meet that test yet, and that's part of -- and it's a -- for these people, it's a major cultural shift. I just want to add one more thing to Dr. Garrick's comment here, and my question is, we also have to put in everybody's performance standards throughout the whole organization that we have to work these -- their quality assurance, and we're basically telling people if you can't work the procedures, we don't want you on the job. I mean, that's what we're telling people. A person, if he cannot follow the procedure, either he must follow it or he must stop work and then go to a supervisor and say, I can't follow this procedure for whatever reason and change the procedure. We're instituting that kind of rigor, which we haven't had in the past. DR. HORNBERGER: Other questions? DR. FAIRHURST: Could I follow up? With regard to this LADIC group that you're going to chair, -- DR. BROCOUM: Yes. The group is in existence already. We've had quite a few meetings. DR. FAIRHURST: It would seem to me that you can certainly come up with a design that's high temperature and low temperature, and wouldn't propose either of them if they weren't able to meet what appear to be the, you know, regulatory standards. But in the long run -- so technically, I think you can do either. But in the end, it's still going to be some political public persuasion type of decision. And doesn't the fact that every other country in the world is looking at low temperature options give you some pause if you propose something that's not that way? Admittedly, you've got a non-saturated zone. Everybody else is saturated. I know the arguments. But nevertheless, to the person outside, doesn't it say that we're doing something very different than everybody else and we're going to have a hell of a job just to -- DR. BROCOUM: Well, let me just talk about the LADIC. The LADIC is there to do policy decisions. In other words, we're not going to do tentacle decisions that the engineer should be -- DR. FAIRHURST: Okay. DR. BROCOUM: The engineers will do their various tradeoffs and come to us, and then any policy implications we will decide. So we're not trying to take the engineering away from the engineers. Secondly, yes, that issue is a very important one. I mean, you know that Nye County has recommended a ventilated repository, okay, so we have to -- DR. BROCOUM: The USGS has opted for -- the USGS has suggested cool. The TRB has suggested strongly that we look at a cool repository because of the analyzability problem. In other words, it's easier to analyze. As you know, Lawrence Livermore for many years has been a proponent of a very hot repository because they want to keep the water away from the waste. And so these are some of the -- you know, and that's probably been for the last ten years. So we have to weigh all of these things, and the question is, you know, is it easier to make the licensing case very hot and keep the water away with all the uncertainties we have about analyzing a system, or is it easier to have a cooler repository that's easy to analyze but maybe not as easy to argue that we're going to keep the packages dry all that time. I don't know what the tradeoff -- but those are the kind of things that we're going to be facing in making those decisions. DR. HORNBERGER: Steve, your view on that particular issue is keeping it dry, the advantage being the thermal period keeps everything dry. The NRC staff has some concerns that I've heard expressed that you people don't take into account the reflux during the thermal period, that there are data from your own tests that suggest that it won't remain dry during the thermal period. DR. BROCOUM: That is -- the original concept of our current -- one of the original premises of our current design is that we would keep it dry during the high thermal load period. The reflux would occur after that when it isn't so hot anymore, 3000 years or more after. But the premises on the two low thermal designs are in one design, we keep it under 96, and therefore the rock temperature never goes above boiling; and the other design, the second design, though, we keep between the pillars under 96 so that it can drain. That has become an important issue for us. It may be easier to make that kind of an argument than to make some kind of an argument we're going to get some kind of, you know, clogging of the pores above it and creating a cap, which is the argument that the people for that -- you know, some of the people are making for the high thermal designs. These -- again, we're going to have to decide these things. These are going to be decisions we have to make coming up in the next few months. DR. FAIRHURST: Does that push you to wider pillars? DR. BROCOUM: I believe that the lowest thermals I heard, yes, the drifts were 70 meters apart. DR. FAIRHURST: Yes. DR. BROCOUM: Versus I think 28 today in a current design. DR. FAIRHURST: Yes. DR. BROCOUM: So that makes a difference in the area, that's correct. But again, we don't want -- DR. FAIRHURST: Well, I'm not sure it's necessary. DR. BROCOUM: If we decide, for example, to go with option 1, which is a very low thermal design where we don't let the rock get over 96, we're not going to specify exactly; we'll then let the engineers go do their various tradeoffs and they'll come back and tell us what they think is the best. So we're not going to arbitrarily set these things up as limits arbitrarily, okay; we're going to have to try to have engineering studies and system studies to help us optimize the system. DR. HORNBERGER: Okay. Thanks very much, Steve. DR. BROCOUM: Okay. DR. HORNBERGER: We will continue our presentations. Let's see. Carol, you're next. MS. HANLON: Good morning. I'm Carol Hanlon and I'm here today to discuss with you Volume 4 of the Viability Assessment -- that is, the license application plan. I apologize that we're a little late in giving you this presentation. I think it would have been useful to you to have it earlier. I wish that it happened, but hopefully it will be of some value to you today. I would like to just call your attention to some changes in the order that you will see in your agenda today. Dr. Ernie Hardin is here also to follow me. Ernie spoke with you in December about the prioritization of the principal factors. Today, he will also review that prioritization, especially as it pertains to three highest priority principal factors, those of seepage, flow and transport through the unsaturated zone, and corrosion of the inner barrier materials. In addition, Dr. Dwight Hoxie from the USGS will be here to give you specific details on the plan for seepage, flow and transport through the unsaturated zone; and Dr. David Stahl will be here to discuss with you waste package corrosion inner barrier material corrosion. So I think it's helpful as we discuss the license application plan if we go back to the purpose for that plan that was envisioned in the civilian radioactive waste management program plan, and that was that this plan would identify the remaining scientific investigations and engineering information that would be needed to complete the license application, with our long-term goal being submittal of a docketable license application to the Nuclear Regulatory Commission. In addition, the program plan called for is to identify the cost associated with securing this information. With this purpose in mind, the intended use of the license application plan was to provide the public with the understanding of how the department had identified, prioritized, and described those major areas of work remaining to be conducted during the next four years, also with the goal, of course, of a docketable license application, and to present the schedule and the cost for those work activities identified. In addition, we discuss the statutory and regulatory activities and supporting work for completeness briefly. In reviewing the license application plan, I think it's helpful to keep in mind that it was not intended, I think as Steve mentioned earlier, to provide a lower level details on those work activities identified. Those details are in both our annual work plans and our multi-year planning system. In addition, work plans and procedures will be developed and they will be identified in individual work packages that are available in the record system. The license application plan also is not intended to provide detail on the statutory, regulatory or support activities, such as quality assurance programs, site recommendation and license application. Those details are provided in separate management documents which are specific to each area, such as the license application management plan and the quality assurance requirement description. So with that as a background, I would like to turn to the organization of Volume 4, license application plan. It draws, of course, heavily from the other volumes of the VA -- site description in volume 1, the reference design presented in volume 2, and TSPA-VA presented in volume 3. There are seven sections of the license application plan, an overview, rationale, section 3, technical work plans. Those are the most important things, I really believe, from our standpoint. In addition, we have a fourth section on statutory activities, including EIS, environmental compliance, site suitability, site recommendation, license application. We have a section covering the support activities that go in the field to support the activities that we're conducting. Six and seven are also very important -- the cost for the license application and the schedule. Again, I've highlighted those areas that I believe to be of most importance. Those are the overview because it's a good introduction and it puts things in perspective, the rationale for the work needed to complete the license application, especially with the postclosure safety case, the prioritization of the principal factors and the description, and the technical work to follow those up. So our areas of emphasis are those five -- the rationale for the technical work needed to complete the postclosure safety case, the postclosure safety case itself, expected postclosure performance, the principal factors of postclosure performance, and technical work plans. In section 2, the license application plan rationale -- we gave a great deal of emphasis to this rationale because of its importance in identifying the work needed to complete the postclosure safety case and the preclosure safety case and take us toward our goal of a docketable license application. The information that we have acquired during more than 17 years of characterization at Yucca Mountain has been incorporated into the site and design process models. That information was also used to develop both a TSPA-VA for the viability assessment, and the repository safety strategy. That safety strategy is actually considered the framework for integrating our information on site, design and PA. Now, both of those, the TSPA and the repository safety strategy, were used to build the postclosure safety case. Similarly, the information for the design and process models was used to develop our operational considerations and design basis events and those were used to build our preclosure safety case, which is roughly analogous and similar to the postclosure safety case but actually quite different. The postclosure safety case has five elements. The first is the assessment of expected performance. The second is design margin and defense-in-depth. The third is consideration of disruptive processes and events. And those actually work very closely together to give you your expected performance. The fourth element is the insight from natural and manmade analogs, which gives us the opportunity to look at other existing sites that have existed over long periods of time and have spacial variability to see how that confirms what we're finding. Finally, we have the performance confirmation plan, which will be our plan through the long term to continue to monitor what's happening and draw conclusions from that. Preclosure safety case is a bit similar to that. The systems evaluation of the design basis events is roughly analogous to postclosure performance. Classifications of structured systems and components may be really the design features, defense-in-depth, verification of system design and use of demonstrated technology. Now, for all of those elements of the postclosure and preclosure safety case, the viability assessment discusses the status of the current -- our current status of the information that we have. With the postclosure safety case, we'd go through each of the elements and present the information, a summary of the information as we have it. For the preclosure safety case, we'd talk more about the processes and how they will unfold. We also talk about information that will be needed and the technical workplans to acquire that information in summary fashion, leading on forward to the workplans themselves. In the case of the assessment of expected performance, we've taken another step with the 19 principal factors, and that is to assess those principal factors which are culled out both in TSPA and the repository safety strategy, to prioritize them in terms of the order of their importance. DR. GARRICK: Karen, in the preclosure safety case are you making a distinction between a 100-year open repository and a 300-year open repository? We haven't -- of course we're not involved in that, and we haven't seen anything specific. But -- MS. HANLON: No, I don't think we call that out clearly -- DR. GARRICK: Right. MS. HANLON: In the -- DR. GARRICK: And in the preclosure safety case, are you actually doing performance assessment in the sense of performance measures similar to the postclosure case, that is to say, are you doing dose calculations? MS. HANLON: No, it's a little bit different. It was hard to make it fit into the same paradigm as the postclosure. And so as I said it's roughly analogous, but it's not as rigorous as the postclosure. DR. GARRICK: One of the real interesting outcomes of this whole process would be the revelation that the preclosure risk is much greater than the postclosure risk, and I don't get the sense that this is really being addressed. But we can talk about that later. MS. HANLON: And that's also one of the things that we've been reflecting on that has been called to our attention recently, and we're taking steps to address that also, Dr. Garrick. So with the 19 principal factors, they were prioritized, and this was for the purposes of identifying the technical work with the best potential to reduce uncertainty in the postclosure safety case. And consideration was given to the factors to which the peak dose rate was most sensitive. This work has consequently received priority funding and resource allocation. To recall some of the prioritization considerations that we used in this prioritization and that Ernie discussed with you in December, I'll just go over briefly three factors. Our consideration -- is that straight? -- our considerations first of all were the significance of these uncertainties to the total system performance assessment, the effect of the uncertainty on the peak dose rate calculation, and that was classified as high, medium, and low. Secondly, we looked our current confidence in what we knew about that factor and rated it from 1, which was a low, to 7, which was high. Our question here was is this current representation realistic and does it capture the entire range of conditions which are important to performance. Thirdly, we looked at the confidence goal, again ranking it from 1, low, to 7, high. Not only did we look at the desirability and the significance to TSPA and the importance of these factors or the information to defensibility of technical basis, but we also looked at the feasibility of being able to accomplish the studies in time for input to the site recommendation and license application. So our priority then ends up being a simple subtraction of the confidence goal minus the current confidence. Just to show you a summary slide here that's out of the license application plan, we've taken the principal factors in this slide and correlated it with the repository safety strategy attributes they correlate with for each of the principal factors we have discussed the significance of uncertainty, high, medium, or low, then have presented the current confidence and the confidence goal. This summary slide shows then the priority of each of these ranked from zero to 3; 3 of course means they're of very high importance and have a high priority, and zero means we're closing in on where we would like to be. I think an important point for these is that for all of these 19 principal factors work will be done. So these are all considered to be very important. Work will be done for all of those, but on the 2's and the 3's, that's probably where our highest emphasis will be, because they pertain most to the performance of the site. And this came out, just for that purpose I have taken the liberty of bolding those highest-priority items, the 2's and 3's you can see on here, percolation to depth seepage and so forth, and our subsequent speakers will discuss seepage into the drift with you, flow and transport through the unsaturated zone, that will be Dr. Hoxie, and integrity of the corrosion-resistant waste package barrier. So that prioritization and rationale in section 2 then led us into section 3 where we present the technical work plan, and then Steve also discussed, we had an ongoing multiyear planning effort that was going on throughout the whole course of developing the license application plan. That was somewhat similar -- that was very similar to the efforts we have had ongoing through the years, and it identified the work that we have evaluated as being necessary to do. And with the prioritization effort, we took another look at that multiyear planning, and based on the prioritization and what we have said were our most important areas, we've really looked at that work. So we've crosscut that and attempted to show what was really essential, what must be done for the license application docketability, and also what was less important and actually could fall off. So our technical work then is organized by three functional areas which won't surprise you -- the site investigation, the design, and the performance assessment -- and what I'd like to tell you about this is there are a couple things here. You can see under site investigation that that's where we have put the fourth element in discussion of the fourth element of the postclosure safety case, and that is performance confirmation. We've also put our management areas there. You can see on the site investigation and design that there are eight tables, summary tables, that we have identified there, and those tables are for the purpose of making it clear and more easy for the reader to understand where the work is being done and what it correlates with. This is an example of that table, just to walk you through it. We take the work category from the text and we correlate it with either the postclosure or the preclosure safety case. In some cases it may correlate with both. We then discuss which principal factors it applies to under expected postclosure performance with a priority for the SR and the LA. And then we also discuss the design, what other elements of the postclosure safety case that particular work may apply to. We also correlate the work category with the PSS activities, the project summary schedule activities, which are presented in chapter 6, especially in Table 6-2. So throughout the document we've tried to make it easier for you to understand things by going forward, forward referencing even back to earlier volumes such as the design in the TSPA and referencing forward to where later we will discuss cost and schedule. Because our later speakers are going to be talking about the discussion of seepage and transport and flow, I have shown you this example in your package of unsaturated zone processes, because it does pertain heavily to both seepage and flow and transport. And I've also included waste package corrosion process from the design chapter. There are no tables -- actually there are no similar tables in the performance assessment section. That did not lend itself so well to actually correlating it, and it was rather redundant, so we made the decision that that wasn't particularly useful there, and we didn't use that. So that is basically our chapter 3. I'd like to call to your attention a couple of other things. We've had concerns over the DOE's consideration of key technical issues, and we have considered them, attempted to consider them throughout the viability assessment in all volumes they are mentioned, all four volumes. Site design, site description, the design and TSPA all reference the key technical issues where they are appropriate; a license application plan goes a bit further. Wherever we discuss technical work in a chapter or section 3, we correlate those work activities with the specific key technical issues that they will address. We also have a table, 4-2, that shows the location of the information related to key technical issues throughout the viability assessment volumes. And in section 4-3 we discuss the key technical issues, what the status we believe of our work to address those are, and we discuss the interactions we've had with the Nuclear Regulatory Commission staff on those key technical issues. So we've tried to include those. This is an example. This is the Table 4-2 that I mentioned that proves useful to you. So a question actually is how have our priorities evolved as we were addressing the license application plan and developing it. And basically we've evolved from an effort in learning about Yucca Mountain over the last 17 to 20 years to develop the knowledge base for Yucca Mountain, we've evolved from that to beginning to confirm the knowledge base and reducing the uncertainty in key areas. So we're also moving toward maturing the design and performance assessment to the levels appropriate for site recommendation and license application. In addition you'll see in the following slide I will show you that we have established higher confidence goals for the engineered system in the license application plan that we have in previous plans. The confidence goals we are showing for the engineered system are as high or higher than goals we show for the natural system, and that indicates a higher priority on several aspects of the engineered system than we may have had in the past. So as our understanding of the natural barriers is increasing, our efforts are also shifting to maturing the engineered system and the performance assessment. To reiterate this slide, I put a box around those factors that pertain to the engineered system, and you can see that in fact they do have among the highest priorities, and they are as high or higher than the system -- excuse me, the natural system priorities. So just to recap, we've looked at our goal of a docket of a license application, and we feel that it's very important to have the comprehensive safety cases to do that and a detailed rationale for additional work, which we feel that we've provided not only by including the repository safety strategy attributes but the prioritization of the principal factors. We've included the technical work remaining to be completed, and the postclosure safety case receives strong emphasis. Regulatory, statutory, and other activities are included for completeness but are developed with lesser detail, as I've said, because they are -- the details are contained in other documents. And we've given consideration to key technical issues throughout. So with that as an introduction, I'd like to answer your questions and then turn it over to our next speakers. DR. HORNBERGER: Thank you, Carol. Let me start. I have the impression from looking at the prioritization that your confidence goals, at least in some cases, were quite heavily influenced by what people thought could be accomplished in a timely fashion for the license application. Is that a fair assumption? MS. HANLON: Yeah, I think that is a fair statement, a fair assumption, and there was a quite a bit of discussion and debate about that. In a perfect world, you would like to say I have to have this, -- DR. HORNBERGER: Yes. MS. HANLON: -- and I have lots of time to get it. But because we are looking at our goal of the license application in four years, we also felt constrained to look at our ability to acquire that information during this period, knowing also that we were relying on natural analogs for confirming information and the fact that we would have a performance confirmation plan that would follow, actually, the results as we went out. Also, that we would have a long time in -- a longer time in the license application process to reflect on additional information as it evolves. So, yes, we took that into consideration. DR. HORNBERGER: Okay. And given your answer, is it then safe for me to infer from your answer that you don't think that there would have been major changes in that list if you had been looking at a 14 year rather than a four year timeframe for license application, simply because you have all of these other performance confirmation periods built in? MS. HANLON: I think we have roughly the same set that we would have had. Ernie may like to confirm or deny that, to show areas where we might have separated. DR. HORNBERGER: Okay. Other questions? Marty. DR. STEINDLER: The general notion of a performance confirmation time period during which, in fact, DOE is going to acquire additional data to support a previously submitted license application represents an interesting approach to the issues of licensing. It is not normally the way the process runs. What assurance do you have that that is, in fact, what the NRC is likely to consider to be sufficient as a methodology of getting a license? MS. HANLON: I didn't mean to say that we would submit a license and add additional information through performance confirmation to make that acceptable. What our intention has been throughout this process, as I have said, is to look at what the requirements are for a docketable LA and make sure we had those requirements. And that is why we went through what may be considered a rather tedious rationale process to identify the repository safety strategy and go through the performance, expect a performance of principal factors and say these are the most important and this is the work I am going to do. So that was all aimed at giving a docketable license application, a complete or an acceptable license application, if you will. Then ongoing, as the NRC has asked and requires of us, is the fact that there will be a performance confirmation. Some of those tests like the heater tests were started -- have already been started, started some years ago. They give us the body of information that allows us to evaluate what we have put together and see if we are still on course for that, or if we are seeing things that are unexpected in the behavior. DR. STEINDLER: All right. So your -- the term performance confirmation is not quite what I thought it was. Fine. You indicated four years in one of your slides, and unless my arithmetic is faulty, which it may well be, I have only got three years. MS. HANLON: In '98, I think we had four. [Laughter.] MS. HANLON: The seconds start ticking. DR. STEINDLER: That's not bad, but as soon as you write four years in 1999, I begin to wonder what kind of a licensing process you are envisioning, was the basis of the question. MS. HANLON: Oh, Dr. Steindler you are so good. DR. STEINDLER: That's it. DR. HORNBERGER: Other questions? DR. FAIRHURST: I just wanted to pick up on what Marty said, and I am not sure where we are at with this. But given the fact that we, or anybody will have, presumably, 50 to 100 years of pre-closure activities, doesn't it make imminent sense to build into that performance confirmation the gathering of information and feeding it into a process? Admittedly, you have got a license application now. But if you found out something terribly adverse, you should be open to the fact that it is -- one has got to do something about it. Maybe it wasn't a good idea, maybe, because you have the option of retrieving everything over that 50 to 100 year period. And, you know, in the EPA, dealing with WIPP, there is sort of a continuing recertification every five years. I am not saying it is something you should do here, but there is a notion of certain information keeps -- as you mentioned yourself, the heated drift experiments, well, they will star to cool down over a four year period, but it probably will continue going on beyond that, and it could be useful information. MS. HANLON: That's really what we are looking at, and the idea of improving information, additional information. As one of the gentlemen, I think in your last international conference, one of the gentlemen discussed the fact that with the design, we wouldn't be getting the perfect design, we wouldn't be getting the best design, we wouldn't be getting the most inexpensive design with the first design that we put out. We perhaps might not even -- his suggestion was we might not even strive for that because, with the information we found out about how the repository worked and how the design worked, we would surely be coming up with things that made it -- that -- improvements we wished to incorporate later. So I think that is just your point, Dr. Fairhurst. DR. HORNBERGER: Ray? DR. WYMER: No questions. DR. HORNBERGER: John? DR. GARRICK: I just wanted some clarification, I guess. I thought the prioritization was extremely interesting and helpful of the whole process. The thing that I am not sure about is roots. There is a tremendous effort in establishing an analytical process that manifests the performance of the repository and that effort is culminated through something called a TSPA. And yet I get the sense in this prioritization process that the TSPA played a relatively minor role. In fact, I think I heard you say something to the effect that when you developed the various priority -- prioritization lists, that you didn't do the same thing with respect to the TSPA. Well, what am I missing? I thought the TSPA was the instrument or the logic engine for establishing compliance and, yet, I just don't get the sense that these kinds of information are really strongly rooted in what the analytical process is evolving as the primary issues and priorities. To have priority as a confidence goal minus a current confidence, and to have these confidence on a scale of one to some number, this all sounds relatively conceptual and subjective against a background of tremendous analytical process that is ongoing with very capital-intensive effort. What am I missing? MS. HANLON: I shouldn't have left you with that impression, because the two efforts, the TSPA effort and the prioritization effort, worked very closely together. In fact, the people that were instrumental in working both of them were working closely together. Even as we developed the first prioritization in early drafts, the people working on that were in close communication with the people doing the TSPA, so that information was going back and forth, and that is why, in fact, I did include the one slide on the high, medium and low. Ernie is going to also add something to this. But when we went through the next step of taking the draft and having the DOE review of that, we worked very closely. We had an independent peer review -- if you will excuse me, I shouldn't say independent peer review. But we had an independent review of our prioritization, and in that we pulled in people from Sandia, the performance assessment persons and we looked very carefully at what performance assessment was saying versus what our prioritization was saying to make sure they were entirely in sync and, in fact, TSPA was driving that. So I didn't mean to leave you with that. They were very integrally tied. Ernie, did you want to say something else? DR. HARDIN: I will just add to that real quickly. Ernie Hardin, M&O. Yeah, for the current confidence assessment that we made, the significance of uncertainty to TSPA was included in that. And, also, we recognize that the PA was being used to generate quantitative results based on a set of conceptual and process models, and, yet, that set was not necessarily complete, and so our judgment was needed to establish current confidence. DR. GARRICK: Yeah, go ahead. DR. STEINDLER: Let me make a comment in addition to yours. I looked fairly hard at Volume 4, and I had the same problem you did, John. I thought that DOE confused the ability to obtain data with the priority system, and the things that I was looking for, for example, some measure of how important the seepage issue is, and the models that go with it, you are almost silent on model uncertainties, for example, in the prioritization process. I had a lot of problems trying to figure out just how you got to your priority structure in relation to the output of that performance assessment. Let me give you one example -- I'll give you two examples. The neptunium solubility turns out to be, you know, coming out of the chemistry domain. If you are off by, you know, not only three orders of magnitude, it isn't very clear that the data are really any good. It seems to me -- and neptunium keeps showing us as a fairly important long-term issue. It seems to me somebody would pay some attention to neptunium. You assigned it priority one, and knowing how much you have got to do between now and the three years that are going to pass, it may never see the light of day. And so I look at it from the standpoint of that priority is going to get buried someplace that isn't even arising. The other point that I would raise for you is I am not an expert in this business, but I gather the biosphere transport and uptake activity which you have as a zero priority, because you are convinced that it is correct, was the subject -- MS. HANLON: No, I didn't say that. DR. STEINDLER: Well, your confidence goal is five and your current confidence is five, and I guess my implicit assumption is that you are convinced it is correct. I know you didn't say that. The sense that I get is that, you know, there may be a fair amount of problems with that one, judging by the noise that I have heard out of someone of your review panels. So, I am wondering whether or not this assessment of your confidence, coupled with what I sense to be a disconnect between, basically, the point that John was making, is going to give you a structure for future activities in the upcoming few, very few years, that will lead you to where you want to be when somebody finally says, okay, let's put a staple through that license application and mail it out. I am a little concerned that there needs to be some more in-depth look to see whether those priorities are really likely to meet the needs of the end product. Comment, rather than a question. MS. HANLON: Steve. DR. BROCOUM: This table that Carol talked about has created a lot of discussion, and I would say a lot of controversy. DR. STEINDLER: I'll bet. DR. BROCOUM: I want to make a couple of comments on that table. That table was designed around the reference design in the VA. We will probably modify that design come this May or April. It is my intent also that we revisit that table to see what change that we need. Even as we were completing the VA, in fact, Volume 4 was the hardest volume to complete, we had a lot of difficulty and a lot of internal debate in getting that volume done. But there was a lot of debate about that table because, you know, even in the reference VA, we have different options for drip shields and backfills and ceramic coatings and those kinds of things, and if you add those, that table changes. Yet, we decided that we would stick with our reference design and make that table match the reference design. But as that reference design evolves, or as we add or subtract features, we need to revisit that table. So I just want to make that comment. At the time, it was the best we can do, when we put that together, but we realize there are some weaknesses in the table. We did it in a relatively short period of time, but we did try to balance the people. We had people from both DOE and the M&O on that committee representing, in equal amounts, science, engineering and PA. So, but my expectation, we will revisit that table as we more -- better refine our design. DR. GARRICK: Yeah, our concern is not that you shouldn't try to make the table, in fact, that is a very good idea. The questions that we have are primarily related to the basis. MS. HANLON: I think, Ernie, did you have something else that you would like to add? DR. HARDIN: No. DR. GARRICK: Ray? DR. WYMER: Yeah, I have just a comment, Carol, I don't know that it is a question or not. One of your prioritization factors here is that it should be feasible, whatever you are trying to do, it should be feasible to be accomplished in time for input to the site recommendation and license application. In light of all the discussion about the importance of getting additional data in some areas, it seems to me that maybe the cart and the horse got turned around there a little bit. If you need the data, you ought to go get it, take whatever time it takes to get it. Are you being driven too -- I guess there is a question -- are you being driven too hard by your schedule? MS. HANLON: Well, that is, again, always the question, and that is a controversial -- that was a controversial discussion, you know, the flexibility to accomplish in time for input. So, but in order to meet our milestones, we thought that we needed to look at that, so you are right, it is difficult. DR. HORNBERGER: Other questions? [No response.] DR. HORNBERGER: Okay. Carol, I take it from your comments that Ernie is going to go next. MS. HANLON: Ernie is next. Dr. Hardin will revisit our review of the performance prioritization and introduce seepage and the other discussions. DR. HARDIN: Can everybody hear me okay? Good. I am the -- I have a responsibility for the near-field modeling in the M&O, and Dwight Hoxie and David Stahl have similar responsibilities in the area of UZ hydrology and material science. And that's why we have asked them to come and answer your questions and present that material to you. So I'm going to just quickly revisit the prioritization for the three highest priorities that I talked about in the briefing in December. Recall that this prioritization is for technical work for the postclosure safety case. Other technical work is in the LA plan, particularly for preclosure safety, for design, and for PA. The prioritization is based on the VA design, so it's conditional in that sense. The process, there's really not a whole lot more I can tell you about the process beyond what Carol has reviewed for you this morning, except to say that we had a constituency from the different groups in the M&O, from science, from engineering, from management, and that we applied judgment where we needed to and we tried to make full use of the TSPA analytical models, recognizing their limitations. So I'm going to talk about three priority items on your list -- drift seepage, UZ flow and transport, and integrity of the inner corrosion resistant barrier. As I'm sure you heard yesterday, some of the design alternatives are on the table right now in the design selection process involved waste packages that put the corrosion resistant material on the outside of the package, and David Stahl can address some of the differences between those approaches. For seepage, applying the TSPA model we found that we could get variations of 50-fold in the calculated peak dose rate postclosure, and let me say that the way that the TSPA models -- process models and abstractions were used varies a little bit among the principal factors. In the case of seepage, what we're looking at is an equivalent continuum model in which water percolation is diverted around underground openings. If we look at the range of uncertainty on the input parameters to that model, and if we also include consideration of the intersection of the percolation flux with the intersection area of the opening, this is how you get to 50-fold variation in water that seeps into the drift. Our current confidence in the assessments on seepage is fairly low. The seepage model is calibrated against preliminary data; the model geometry is circular, whereas we know that rockfall will change the opening geometry; and the stochastic models used to describe the variability in properties that represents the fracture network have associated inherent uncertainties. The confidence goal, of course, is moderately high because we have several testing programs that will support those models by the time we get to SR and LA, and so the priority is high, although we recognize that some of the tests will be completed concurrently with preparation of the LA. And what those tests consist of, very briefly, there will be two additional alcoves excavated in the cross-drift, with the recently completed cross-drift in which additional niche studies will be done. Two fracture-matrix interaction tests are also planned for the cross-drift. There's a large-scale seepage test planned where the cross-drift passes over the main tunnel with an intervening distance of about 15 meters. Monitoring of moisture conditions in the wall rock around recent excavations and in at least one drift, alcove 7, that's been closed off, will continue. And geochemical and isotopic measurements that pertain to percolation primarily, and this includes the chlorine-36 program, will continue and be completed. And finally the percolation and seepage models will be updated. For the unsaturated zone flow and transport factor, sensitivity analyses using the TSPA models for VA show that we could obtain 100-fold increase in peak dose rate. And this is particularly true if you consider early time failure, juvenile failures of a few waste packages where you have a localized source and you're trying to capture the performance of the site using a rather coarse -- relatively coarse model. Current confidence is low because of these numerical mixing and dilution effects, and also because the thermally driven coupled process changes in transport properties of the unsaturated zone are not included in the VA assessment. The confidence goal is moderately high, mainly because we do have ongoing and planned testing programs that will help support the models that we take to SR and LA for UZ transport. The priority is high, but again we recognize that some of the testing will be completed concurrently with preparation of the LA. The technical work plans for UZ flow and transport. Well, these include completion of the testing program in the Busted Butte facility, which has been ongoing for more than a year. In addition, transport studies using multiple tracers and multiple injection points and multiple observation points will be completed in the cross-drift. We will take another look, a more comprehensive look, at natural and man-made analogs to radionuclide transport. And we will update the mountain-scale models. For the principal factor for integrity of the inner corrosion resistant waste package barrier, the uncertainty analysis using the TSPA VA showed that we could obtain greater than 100-fold uncertainty in calculated dose rates based on a wide range of uncertainty in the corrosion rates and the mechanisms for barrier corrosion. The current confidence in the TSPA VA model treatment of this barrier is moderate, only moderate, because of process-level uncertainties, and because we're using corrosion data that were developed from laboratory corrosion tests done under a very wide range of chemical conditions including some very aggressive conditions, and those data were composited and combined with expert judgment to formulate the distributions that were used in TSPA. Our confidence goal is high, because we believe that there is strong potential for gains in confidence from the ongoing testing program. So the priority is high, and this is reflected in planning of the technical work. Technical work plans that Dr. Stahl will address include long-term corrosion, continuation of long-term testing of nickel-based and titanium-based alloys and multiple material interactions such as tuff against CRM. In addition, there are models -- predictive models, mechanistic models being developed for localized corrosion and phased segregation effects, and these will be supported to the extent practicable by measurements and observations. Passivation effects are being measured and testing will continue to evaluate microbially-induced corrosion which I understand has not yet been observed on the Alloy-22 CRM material. That is all I have. After any questions you may have for me, I will turn it over to subject matter experts in these two areas. DR. HORNBERGER: Okay. My suggestion is going to be that after we ask Ernie questions we take our break now It's a natural place to break -- and then come back and hear the three technical presentations and keeping in mind that we are going to hear more technical detail on the three items that Ernie outlined, I would suggest that any real detailed technical questions we have would be better left for a little later. With that caution, I invite questions. DR. FAIRHURST: Let me ask this one quickly. Ernie, are you going to be here later? MR. HARDIN: Yes. DR. FAIRHURST: Okay. Then we can ask questions -- we can bring Ernie back on the stand? DR. HORNBERGER: We can bring him back, yes. DR. FAIRHURST: Yesterday people from DOE had to leave. DR. HORNBERGER: Yes. Marty? DR. STEINDLER: When you say fifty-fold variation in dose rate, you are talking peak dose rate? MR. HARDIN: Yes. DR. STEINDLER: You don't say anything about what the shape of that curve looks like in the first, say, 10,000 years where the period of compliance ends. MR. HARDIN: Right. There was -- DR. STEINDLER: Did you pay no attention to that? Is that not a part of the driving force for your prioritization process? MR. HARDIN: Well, let me just say upfront that generally the dose rates associated with the first 10,000 years of the performance period are much lower than the peak dose rates -- as I am sure you have seen from some of our products. DR. STEINDLER: Yes. MR. HARDIN: And that -- but there was a strong, there was considerable attention given to peak dose rates over a million years in this prioritization process. We did, in exercising the TSPA models, we parsed out when -- that being zero to 10,000, 10,000 to 100,000, or up to a million -- when the peak dose rate was calculated to occur. DR. HORNBERGER: And you also, when you parsed that, as I recall, you indicated -- you broke down where the processes were important in giving that dose and my recollection is that these three turn out to be important in the zero to 10,000 year period as well as at the peak dose, is that correct? MR. HARDIN: Yes, that is. DR. STEINDLER: What I am trying to find out is whether that startling factor of 100 or factor of 50 or whatever -- MR. HARDIN: Right. DR. STEINDLER: -- applies in the time, within the time of compliance. DR. GARRICK: Yes, one of the things that I would be interested in is if you look at 50 times with respect to seepage and 100 times with respect to unsaturated zone flow, what do you think is a reasonable goal in each of these cases, because that would certainly tell you which one you want to put the most emphasis on if all you are going to get is reduction from 50 times down to 45 times, say on seepage, and in the case of unsaturated flow you are going to get from 100 times down to 10 times -- then that would certainly suggest where you ought to put your effort. Can you say anything about what is a reasonable expectation here in terms of the uncertainty? Obviously you are not going to eliminate the uncertainty. You are just going to reduce it. MR. HARDIN: Right. These are not confidence interval analyses. DR. GARRICK: Right. MR. HARDIN: We ascribe no quantitative designation to the range. DR. GARRICK: Yes. One of the things that would really help this process is kind of what I think Marty was getting to is that if you could see a PDF of the peak dose before and after and how these programs are expected to impact that peak dose as a function of these, say, three major contributors, and I think all the evidence points to that these are the three major issue, that would be very beneficial. You would see more graphically what is likely to happen by addressing the quantification of the dose where by quantification I mean the curve. MR. HARDIN: Right. In our December briefings, as you may recall, Dr. Dockery showed a correlation analysis had been done, a statistical analysis of the principal factors against peak dose rate which tended to bolster these conclusions. DR. GARRICK: Do you have any sense of what is a reasonable goal with respect to your 50 times and 100 times number within the time period between now and when you submit -- MR. HARDIN: I hesitate to give you a range, let's say, tenfold or twentyfold, that would apply to all the factors. DR. GARRICK: All right. MR. HARDIN: Because clearly some of the factors are going to have more intrinsic uncertainty than others. DR. GARRICK: That's right and that is what I am sort of getting at is where would it be best for the resources to be allocated with respect to, say, just these three issues? MR. HARDIN: And the answer is where it is most desirable and feasible. That is where we interject judgment as to what we can achieve programmatically and include in the SR and LA. DR. HORNBERGER: And of course it is important to keep in mind that with two of these the issue isn't necessarily finding that seepage puts us in the lower 10 percent. Your measurements could put us in the upper 10 percent, near that top 45 to 50, rather than 5 to 10. DR. GARRICK: Yes, right. That's kind of what I was struggling with. If we went from 50 to 49 and 1 and from 100 -- DR. HORNBERGER: But it is still important to know that. DR. GARRICK: Right, right. DR. STEINDLER: One other quick point. The implication here is that you talk about testing to support the seepage model and the same kind of general set of words are found in all of those -- DR. HORNBERGER: Right. DR. STEINDLER: -- which boosts your confidence goals. No place do you seem to address model uncertainties. It seems to me that in some cases you are not even sure you have a clue as to what the mechanism is and so the model itself may be pretty far off. Did you factor this in someplace? MR. HARDIN: Model uncertainty was certainly used as a concern in the current confidence goal and in terms of assessing -- I'm sorry, in the current confidence. In terms of assessing the confidence goal it would be necessary to extrapolate where we think we could be and that also has been done, but I understand your concern in that we have not specified how the models would be changed -- DR. STEINDLER: I don't want to know how the model is going to be changed. The thing I am trying to find out is whether or not this confidence goal, you know -- the argument for the confidence goal being at the level it is seems to be based entirely on the acquisition of data and does not seem to address something that you are going to do to enhance confidence that the model uncertainty can be reduced. It is that difference that I am looking for. I mean you have great data but your model is lousy so general extrapolations -- MR. HARDIN: Well, I have given it that sense, and I would allude to some of our peer reviews which have told us that we don't have enough data. With more data the models will improve and that is really what we are saying. We understand where the models are the thinnest. DR. STEINDLER: We haven't got enough time to work on that one. I'll just let it pass. DR. GARRICK: Well, of course if we get enough data, we can simplify the model and in the limit we don't need a model if we have enough data. DR. FAIRHURST: If you have got the wrong model, the interpretation of the data will be wrong. DR. STEINDLER: Exactly. The acquisition of data is normally driven by some picture that you have called the model. If you continue down that road you probably aren't going to make a whole lot of important changes to the model and the model uncertainty remains as an unresolved issue. That is all I am saying. DR. GARRICK: Yes. Lynn? MS. DEERING: I just wanted to add something to this and this was based on something I heard Abe Van Leuyk say at the NWTRB meeting, and Ernie, tell me if I have got this wrong. He was implying with respect to confidence goals if a low confidence goal is assigned if DOE believes they have already -- there may be a lot of uncertainty but DOE believes it has captured that uncertainty in the current model, therefore it is bounded. A high confidence goal is given to those areas where the modelling is not expected to change much for the worse. In other words, dose could go down if they work on refining the model to their advantage, but it is not -- they are not going to put the money into a model where they feel the dose isn't going to get worse. Does that make sense? That is what I heard out there. MR. HARDIN: I wouldn't say that at all. We are very keenly concerned with defensibility. DR. GARRICK: And also the confidence goal only makes sense if it's rooted in some sort of a measuring process. In other words, if I have six orders of magnitude of uncertainty in a parameter and it doesn't affect the dose, I don't care. I don't care if I have six orders of magnitude of uncertainty, because I'm not concerned about the science of that particular parameter beyond its impact on the bottom line. So that's the only thing that makes any sense as to what the confidence goal should be is what the ultimate impact is on the performance measure. And I think we need to be very careful about the implication that these confidence goals are something that people sit down and make a judgment. If that judgment reflects performance analysis and performance measures, then that's okay. But that should be the driver. And then I hope that's the direction it's going. DR. HARDIN: Yes. DR. HORNBERGER: Okay. With that short answer, thank you, Ernie. We'll take a 15-minute break and reconvene promptly at 10:36. [Recess.] DR. HORNBERGER: Okay. We are reconvened, and I think the schedule has David Stahl doing the next presentation. No? Well -- that's fine. I wasn't sure. We changed it. That's fine. DR. HOXIE: Am I on? I don't hear a voice. DR. CAMPBELL: You're fine. DR. HOXIE: Okay. Sorry. I am going to be talking to you about seepage into drifts. My name is Dwight Hoxie, and I need to explain the kind of curious beast that I am. I am an employee of the United States Geological Survey, but I work within the M&O organization in Las Vegas, and I am responsible for managing the process modeling program which includes UZ flow and transport models, saturated zone flow and transport model, and near field models. And the reason why I'm probably here on the program is because I was told we need to focus on the planned work for SR and the license application, and since I act in the capacity of a manager and planning is one of the things I do, therefore that seems appropriate. So what I'm going to be doing is talking about seepage into drifts, just remind you why this particular issue is of significance, and that is I think it was Steve Brocoum said earlier today, essentially that if we did not have any water seeping into the emplacement drifts, we would have no waste package degradation much to worry about or not as much anyway, we would have no medium by which to mobilize the radionuclides from the waste form, and that we'd have no medium to transport them through the engineered barrier and subsequently into the unsaturated zone and to the underlying water table. So this is why seepage is very important. The work that we have planned actually for the license application is really a set of ongoing work that is being continued and will be completed or at least mostly completed by the time of the license application. And this is essentially a table of contents for my talk. I'm going to be talking about the alcove and niche seepage testing in the main drift of the exploratory studies facility. The testing that is planned in the east-west cross-drift. I will be talking about the geochemical and mineralogical work that is going on or will -- is going on actually in cross-drift. I'll talk about moisture monitoring and talk about update of our seepage and percolation process models. So let me first talk about what is going on and will be going on in the main drift. First of all I think all of you have this. It's not as high a quality map that I would like of the ESF, this being the ESF located here, the main drift going essentially north-south, and then with the cross-drift going across the potential repository block. I'll be talking about alcoves, specifically alcove number 1, which is up here by the north portal. I'll be talking briefly about alcove number 4, which is down on the so-called north ramp. I'll be talking about alcove number 7, which is located down here at the end. I'll also be talking about four of the niches that have been excavated in the ESF. I'll be talking about niche 1 and niche 2, which are very, very close together. They are located very close to the Sundance Fault, which is a structural feature. DR. CAMPBELL: You need your battery changed. DR. HOXIE: I need my battery changed. Where is the bunny when you need him. Okay, is that working? MR. LARSON: Yes. DR. HOXIE: I couldn't even tell. All right. Where was I? Alcove number 7, about the niches, niche 1 and 2, located near the Sundance Fault, niche 3, which is located where the cross-drift crosses over the main drift, and I noticed on this slide very conveniently that niche number 4, which is at station 47 plus 88, which is about right in here, is not shown on this particular map. I might also point out that I'll be talking about the cross-drift. I'm going to be talking about a crossover alcove which is going to be located where the cross-drift goes over the main drift. I'll be talking about the crest alcove, which is located beneath the crest of Yucca Mountain. And also going to be talking about two niches that are planned to be constructed in the cross-drift, niche 5 and niche 6. Their locations shown on this map unfortunately are incorrect. They have been revised I learned on Monday, and I'll try to give you that information as we go along. We have two viewgraphs -- I could just leave this up, but I'll leave it on the side, anyway, and ask you to refer to your handout. Okay. First of all, alcove number 1. I'm going to talk about what has -- the status of this test today. It really was a prototype test. Alcove number 1 is located very near the entrance to the ESF, so the alcove actually is only beneath the surface by about 32 meters. The experiment consisted of applying water on a 91-square-meter area for 158 days at an average rate of 1.7 centimeters today. So this was a controlled infiltration experiment with the idea of trying to see if any water or how much water would ultimately drip into the drift. And if you multiply everything out, you come out with about 240,000 liters was the total amount of water that was applied during 158 days of the test. The modelers, someone was talking about model uncertainty, I think our models actually are very good because the modelers predicted that they should see water entering into alcove 1 four hours after irrigation began at the surface, and they were only off by a little less than 57 days. So I don't know why anyone is concerned about model uncertainty. Anyway, but I think this is actually very important, because what realization was -- so there. I think what the realization was is that it takes a certain amount of water to wet up the rock mass sufficiently to get it to move through. This is a fractured welded tuff, it's the Tiva Canyon tuff. The fractures are probably filled with calcites and soils and so forth, and it just takes a long time for the rock mass to wet up sufficiently to get it to where it percolates down and then can seep into the drift. And of all the water that was applied, about 11 percent was recovered in their network of collectors that was in the drift. This was a prototype test. The work is continuing. A new test is actually about to be initiated, and this test is going to be refined so that they can do a better job of quantifying things. And what we really want to be able to do is to develop some quantitative relationships between how much water and at what rate it seeps into the drift versus the applied infiltration rate at land surface. And the other thing that they want to be able to do is to do tracer testing so that they can get breakthrough curves. This will allow them to develop travel times and also to potentially identify flow pathways within this fractured rock mass. DR. FAIRHURST: Could I just ask -- DR. HOXIE: Sure. DR. FAIRHURST: Your model that was off by 57 minus 4 hours -- but in that, is that a fracture -- DR. HOXIE: Yes, that was a fracture model. DR. FAIRHURST: It's a discrete fracture model. DR. HOXIE: Yes, it's actually -- it's what we call dual-permeability models. DR. FAIRHURST: Ah, it's not a fracture model. DR. HOXIE: Okay. So it's a fracture continuum superimposed on a -- DR. FAIRHURST: It's a fishy fracture. DR. HOXIE: A matrix continuum. DR. FAIRHURST: There aren't any -- just is a bit leakier. DR. HOXIE: All right. Moving to the other end of the SF, at alcove 7, this is also directly a drift seepage test, but this is under ambient conditions, and the alcove was constructed to provide access to the southern Ghost Dance fault. The alcove is about 200 meters below land surface. It's in the Topapah Spring welded unit, which is our potential host rock for the repository. The modeling again is estimating based on the infiltration estimates at land surface that the ambient flux in the vicinity of the drift should be about two millimeters per year. The drift is bulkheaded off so that there's no air exchange with the main drift itself, and actually there are two bulkheaded alcoves, one that encompasses the fault, one that's outside the fault. And the idea here is simply that we're just passively monitoring conditions within the drift. We're measuring the temperature, relative humidity, barometric pressure, and in the rock mass itself, embedded in the rock mass we have devices to measure the water potential in order to see if we can get any seepage events moving down through the rock. And again back to modeling again, we have not detected any inflow into this alcove yet, and the models are estimating that it will be about 10 years before we could anticipate seeing any effects from the recent El Nino event. So this may be a long wait. I want to talk about alcove number 4 before I show the picture. Let me talk about that just -- and then I will show you the picture for actually almost a different reason. Alcove number 4, if you look in your figure, it's actually in the north ramp. It's located in the Paintbrush nonwelded hydrogeologic unit. This is not directly related to seepage into drifts, but it's probably very important for potential seepage into repository drifts because our conceptual model is that the Paintbrush nonwelded unit tends to mediate flow that is moving downward from land surface and into the potential repository host rock. And the mechanism here is that -- our concept is that at land surface above the repository we have the Tiva Canyon welded unit, which is highly fractured. The supposition is that net infiltration from rainfall -- precipitation will enter the fractures, move down through the fractures. They will then impinge on the nonwelded unit which is relatively unfractured, has a very high matrix porosity, has a very high matrix permeability relative to the matrix of the overlying welded unit and so the flow will tend to transform from fracture-dominated flow into matrix-dominated flow, which presumably would tend to homogenize the flow both in space and time. It would tend to dampen out episodic events and perhaps even spatially homogenize the flow, so that this would be that in the underlying Topopah Spring unit, which is the repository host rock, perhaps the flow would be -- we would have a source of water at the top that would be more uniformly distributed and the flow therefore would be more uniform in the Topopah Spring -- again, probably fracture-dominated but probably with many, many fractures participating rather than just discrete fractures conveying the bulk volume of the flow. So far what we have done in this alcove is -- the plan is actually to do air injection testing to determine the permeability of the rock mass and we do liquid release testing to see how water moves through the unit and then we'll monitor the moisture in the rock mass in boreholes and we will be investigating a complex system involving faults, fractures and layered heterogeneous units. I'll just point out that right to date what we have done, we have taken core samples from this alcove and measured hydrologic properties. On the core samples we have have done some preliminary air and liquid release testing to get the hydrologic properties of the rock mass itself. Now there is a diagram here. This is looking at the face at the end of the alcove and all I really want to point out here is that things are fairly complicated. We have a fault here, we have a fracture over here that actually may have been mining-induced -- it is not completely clear. We have different kinds of stratigraphy. Some of this is pretty clayey material. Some of it has been altered into Zeolites so we have a heterogeneous rock mass, but the I really want to make out is that the kind of testing that is being done here is very similar to the kind of testing that is being done in the niches that I will be talking about, with the idea being that we will have multiple boreholes. We will do crosshole tests across these different boreholes. Some boreholes will just have monitoring instruments in them and then in many of the cases where we have a niche study where we actually were trying to determine how water will move down through the rock mass itself, we have a series of boreholes that overlap that essentially create a slot along the bottom and where we can collect samples discretely but distributed in space so that you can do tracer tests or quantify rates of flow in particular localities. This is just an example of the kinds of things that are also going on in the niches, so that when I talk about the niches I want you to kind of have this picture in your mind. I don't want to go into more details on this test other than that. So getting on to the niches, and just to make sure that everyone is very clear, we have two concepts in our testing complex within the ESF. We talk about niches and alcoves and just in case you weren't completely clear, it's just a matter of scale. The axial length of niches are on the order of 10 meters or less; the axial lengths of alcoves are on the order of 10s of meters. That is really the only difference. They are both excavations off of either the Main Drift or North Ramp or South Ramp or wherever, or the Cross Drift. So far we are doing seepage testing in Niches 1, 3 and 4. We have done air injection testing in 3 and 4. All that work has actually been pretty much completed, and that gives us hydrologic properties such as permeabilities of the fracture system. This is all focusing primarily on fracture flow. Then we will be doing both liquid release, which is just flux types of measurements, and then tracer testing, and the idea here is to try to gain some really empirical hard data on, first of all, the effects of capillarity at the boundaries between the niche and the wall rock itself, the idea being that at least according to theory if you have a water front moving down through a porous medium and it encounters a large opening like a niche or an emplacement drift, capillarity effects should tend to deflect the water around the drift, and so it is to test that hypothesis and to how well that works in a fractured medium. I tried to determine what seepage threshold fluxes might be -- that is, the idea being that there must be some minimum flux that you have to have impinging on a drift in order to induce seepage into that drift. Seepage function as a function of the liquid injection flux, this is probably a poor choice of a word. I probably should just simply say seepage percentage because seepage fraction has a usage in TSPA that is different from what I have in mind here. This is simply that, well, what is the fraction of the water that you impinge on a drift that actually seeps into the drift, and how is that a function of whatever that incident flux might be. One of the big uncertainties within our analyses in this fractured rock mass is how does the fractures and matrix interact? That is, how does water exchange between the two? What are the conditions in which you may have dominant fracture flow or dominant matrix flow? And we are also going to try to get a handle from all of this testing on these kinds of effects. I might just say that we have completed testing at Niche 3, testing is ongoing at Niche 4 and we will complete the testing in Niche 1. All right. Now I want to talk about the work that we are planning to do in the Cross Drift. One of the first and perhaps most relevant to a seepage issue is the experiment that we plan at essentially the junction in plan view anyway of the Cross Drift with the Main Drift of the ESF. What we want to do is to construct an alcove above, essentially above Niche 3, which is in the Main Drift and about 15 meters below the cross draft, and conduct an infiltration test, presumably very similar to what was done at Alcove Number 1. We would apply water in the Cross Drift and monitor the flow into Niche 3 as a function of the amount of water that was applied. Again we want to try to look at how the flow might be diverted around the niche as a consequence of the capillarity, and again quantify the seepage percentage anyway of the incident flux that might seep into Niche Number 3. We have, and I have already mentioned this, we have already completed testing there, so we have the hydrologic properties pretty well in hand. I might mention also that concurrent with all of the testing or actually in advance of the testing modeling is being done based on the measured hydrologic properties in order to predict the results of the test and try to gain some validation of our modeling capability. The East-West Cross Drift Crest Alcove is located beneath the crest of Yucca Mountain, which is a region that is predicted by the infiltration modelers to be a region of expected high net infiltration, probably on the order of 10 to 12 millimeters per year versus an average of, as Steve pointed out this morning, of six to seven over the entire repository area. But this is going to be a test that will be very similar to the one that is going on in Alcove Number 7. The alcove will bulkheaded off and we will do passive monitoring within the alcove to see if we detect any inflow as a result of ambient infiltration through the mountain. We also plan to do tests in two niches that are going to be excavated from the Cross Drift. This is going to be very similar to the kinds of testing that we have been doing in the Main Drift. Actually this slide is a little bit of a misnomer. I learned on Monday that the locations of the two proposed Cross Drift niches have been changed, so that actually we can go down to this bullet now and say that Niche 5 and Niche 6 both will be located in rock units that previously had not been tested from the Main Drift. These will be in what is known as the lower lithophysal unit of the Topopah Spring and the lower non-lithophysal unit of the Topopah Spring. These are both potential host rock subunits that were not penetrated by the Main Drift or at least they were not penetrated sufficiently that any testing was done, so that is the purposes of the testing in the two niches in the Cross Drift. I'll talk about geochemical and mineralogical sampling that is actually ongoing within the Cross Drift, although I don't have any results to report at this point in time. From a geochemical point of view, there is systematic sampling of samples to extract pore-water chloride concentrations. The importance here is that if flow through the mountain is dominantly vertical, then the total chloride, pore-water chloride at any particular location should be inversely proportional to the infiltration rate at land surface above that location, so we can test that particular hypothesis. And perhaps of more spectacular interest is looking at the ratios of chlorine-36 to total chloride. And we will be doing this both systematically along the drift, and also at particular features, specifically, for example, the Sundance Fault, where, in the main drift anyway, the Sundance Fault is implicated in an occurrence of so-called bomb-pulse chlorine-36, which, as everybody probably well recognizes, indicates a potential fast pathway for which water had flown from land surface within the past 50 years or so. But there is more to chlorine-36 to total chloride than just bomb-pulse. Actually, the ratio gives us an idea of groundwater residence time. And just for example, the background chlorine-36 to total chloride right now stands at about 500 times 10 to the minus 15, and it is a dimensional-less number, of course. But if the number is much, much less than 500 times 10 to the minus 15th, that indicates a groundwater residence time probably on the order of the half-life of chlorine-36, which is 300,000 years. So that gives us some idea that we would have a very old residence time. Bomb-pulse chlorine-36, of course, would indicate a fast pathway, something where water has been transmitted through the usee down to the collection site within the past 50 years or so. But chlorine-36, it is also now well documented, the ratio -- there was an increase in production of chlorine-36 apparently relative to modern day about 10,000 years ago, so that if we have chloride-36 -- chlorine-36 to chloride ratios in the order of 500 to 1,000 times 10 to the minus 15th, then that indicates water that perhaps is on the order of 10 to 20,000 years old. So it gives us a bit of a handle on flowpaths and residence time within the unsaturated zone. The mineralogic sampling that is planned is very similar to what was done in the main drift. We are particularly going to be looking at the occurrences of secondary hydrogenic minerals, primarily calcite and opal that predominantly occur in the fractures and fault zones. After collecting the samples, we analyzed them using various techniques, carbon-14, thorium to uranium, uranium-lead, to measure ages. And when you are measuring the ages, I remind that you that this is done with very, very microscopic samples and so that you can measure the outer layers of a small crystal and measure the interior layers, and, therefore, get a sequence of ages and an idea of the rate of deposition of the particular mineral. So that is why this is very important. And of course, if you have some idea of the deposition rate, and have -- apply some chemical principles, you can infer back estimates of rates of flow through the UZ. And based on this, from the work in the ESF, people are talking about an average over several millions of years of something like 2 millimeters per year moving down through the fracture pathways. We also look at the stable and radiochemical isotopes. Oxygen fractionation, we look at so-called delta-18, which is essentially a difference between 018 and 016, and what this tell us is that if this -- this ratio is actually a function of depth through the UZ, and it tells us something about how oxygen is being fractionated along the flow pathways. And, by the way, these measurements are on calcite samples, so it is telling us something about the calcite deposition. Carbon-13 tells us something about the soil gas composition from which the biocarbonate originated that ultimately led to the calcite deposition at depth within the UZ. Strontium-87 is a -- strontium is an element that does not actively react strongly with the welded tuffs like the Catiba Canyon, but it does interact, presumably, with the non-welded tuffs. And so if this particular ratio changes with depths, and it does actually make quite a change as it goes across the PTN on welded unit, then this is telling us something about the reaction chemistry along the flow pathway. We also look at the initial uranium-234 to 238 ratios. If you have a very, very long period of time, these ratios ought to be one because you will have -- uranium-234 is a daughter product of uranium-238, so they should come into equilibrium. The fact that we don't have ratios that are equal to one everywhere tells us that there is something happening preferentially is causing that ratio to change along the water pathway. And the way it in which it is changing in the UZ has been interpreted to indicate something about waterflow volumes and flowpath lengths. We have low, we have small waterflow volumes, and long flowpath lengths, and this is taken to support the concept, anyway, that water in the UZ, particularly in the repository host rock, is widely spread out among multiple fractures and perhaps even moving as film flow. That does not discount, of course, that we might not have episodic events such as those that would lead to bring chlorine-36, bomb-pulse chlorine-36 into the drift. Okay. I want to talk about moisture monitoring that is going on in the main drift and in the cross-drift. This has been a long, ongoing program. We are measuring temperature, relative humidity and wind speed at a number of stations within the ESF, and I think everybody understands the station nomenclature, the 7 plus 40 means 740 meters, from -- in the ESF, from the North Portal. And this is all being done at a sampling every 15 minutes. And the idea here is because we are ventilating in the main drift, we want to get some idea of how much moisture actually is being carried out with the ventilation system. And we also have monitoring stations at Alcoves 1 and 5 and at Niches 1 and 2. I think more interesting is the work that's going on in the cross drift itself. We do the same kind of thing to look at what the effects of ventilation there are, so again we have stations where we measure temperature, relative humidity, and wind speed. But to me what is more interesting is that we have a heat-dissipation probe, which is a device to measure water potential in the wall rock. We have one installed every 25 meters from station 0 plus 50 in the cross drift and station 0 for the cross drift is at the intersection with the ESF at the North Ramp, at 25 meter intervals all the way up to Station 25 plus 25. And we're sampling these every four hours. In addition, every 50 meters we have a neutron bore hole, and these extend from Station 50 to Station 25, and we go out and log these bore holes for water content in the wall rock every two months. And both of these holes, the bore holes that are involved, are all two meters deep. So we're relatively well into the rock mass and away from the perturbing effects of the drift itself. And what I think is very, very interesting is that -- I will pass this on -- is that the data that is coming out from these water potential measurements is that the rock mass two meters in from the cross drift is actually quite wet. The potential is about minus .8 bars, and the saturation of the rock mass is about 90 percent. And this is considerably wetter than was found to be the case in the main drift, but in that case we were not able to put probes back more than 50 centimeters from the wall rock itself, from the interface with the drift, and probably therefore we got much, much drier conditions probably as a result of rock dryout from the ventilation system in the drift. So anyway we have a report, a predictive report that was developed about a year ago for what we thought conditions would be in the cross drift, and at least with the water potential we're finding that they're a lot wetter than we had predicted based on extrapolation from -- DR. HORNBERGER: Dwight, we have an awful lot of material to get through. DR. HOXIE: Yes. Okay. DR. HORNBERGER: Perhaps you could speed it up and hit the highlights. DR. HOXIE: I will. Okay. I just wanted to mention something about what we're doing about the modeling program. Our basic drift model right now simulates a five-meter drift in a block that's 50 meters long, 35 meters tall, and 43 meters wide. The grid spacing is .5 meters, and we generate fracture permeability fields, this is a fracture-based model based on map fracture density and permeability test data from the main drift. And the whole idea here is to -- oh, we used the site scale flow model to provide input fluxes as a boundary condition and try to predict using the model what the seepage into a drift would be. We are going to refine and calibrate the model with respect to all of the available drift and alcove test data. The model right now has a circular drift. We're going to alter the geometry to try to simulate the effect of drift collapse and we're going to try to by using finer grids look at things like the effects of wall rock surface roughness and potential film flow around the drift. We also need to allow for the near-field effects of repository heat that could alter the rock mass itself and change the water chemistry of water entering the drift. With the case of our 3D site scale, mountain scale model, I'll talk about that in the next presentation, but we're refining the grid for better spatial resolution for infiltration, calibrate the model. We're going to use simulated -- simulate the chloride transport, chlorine-36 transport, carbon-14 transport as a means to calibrate the model to better predict fluxes through the mountain. And just in summary of this talk, we have our testing program in niches and alcoves, we have work planned for the cross drift, and we are going to take all of this data and try to incorporate it and to improve our models, both their numerical capability and their conceptual basis. So that concludes that talk. DR. HORNBERGER: Okay. Thank you. Okay. Questions. DR. FAIRHURST: Yes. On one of your slides for one of the niches you said this fracture may be mining-induced. You weren't sure. As a general question, how do you take into account the consequences -- I mean, how do you create these niches? By blasting? DR. HOXIE: Let's see. That -- actually the one in the PTN was excavated using an alpine miner. So it's clutching. Oh, when I say that fracture was induced, it was probably a desiccation fracture. This was nonwelded tuff. It was damp when they excavated it. And it's probably dried out. So that's one. DR. FAIRHURST: But there is a potential, I presume, for you to disturb fractures and change their aperture and things like this and -- all your measurements in the excavation damage zone. And yet it seems to me that you don't have any technique. There are techniques available to determine whether you disturb the rock mass during the process of making the niche. DR. HOXIE: Right. DR. FAIRHURST: I just wonder if somebody, evil-minded individual may throw a doubt on -- DR. HOXIE: Okay. What is done -- DR. FAIRHURST: Everything else. DR. HOXIE: Right. What has been done with the niches in particular is that the first thing they do is drill bore holes, do testing in the bore holes, excavate the niche, do more testing, and then try to determine what the effects of mining the niche was on the result. So they do try to take that into account. DR. FAIRHURST: But do you do any attempt to do acoustic emission work in bore holes to see the sources of any movement? DR. HOXIE: I can't answer that question. I don't have that information. But I'm not sure, they may well do. I don't know. DR. HORNBERGER: Ray. DR. WYMER: I was just curious as to -- you're getting a lot of useful information here about how things move through the rock. I wondered to what extent this information will be applied to what happens in the unsaturated zone. DR. HOXIE: In what sense? DR. WYMER: In the sense that you also have water moving through the unsaturated zone. DR. HOXIE: Right. Well, we are talking about the unsaturated -- DR. WYMER: I thought you were talking about seepage into the drift. DR. HOXIE: We're talking -- ah, this is seepage from above. DR. WYMER: Yes. DR. HOXIE: Coming down -- all the drifts are in the UZ, so this would be seepage -- DR. WYMER: So whatever you get you will apply -- DR. HOXIE: Right. DR. WYMER: Across the board. DR. HOXIE: Yes. DR. WYMER: Yes. Yes, when I read seepage, I usually think of what's coming down rather than what's going out the bottom. DR. HOXIE: Okay. Well, that's what I'm talking about. I'm talking about seepage water that's coming down through the UZ, impinging at the drift, and then dripping into the drift. DR. WYMER: Okay. DR. HOXIE: Okay. That's what I mean by seepage. DR. WYMER: Yes. The word "seepage" had a different connotation for me. Okay. DR. FAIRHURST: Looking into transferring this into the SPA model, that model will be looking at seepage into drifts that have undergone a thermal cycle, have cooled back down again. So around them will be a significant large damage zone. So you won't be having seepage directly -- I had an offline conversation with Ernie. He was saying you may consider that as essentially backfill. So do you have a model which shows seepage into a "filled" region with a hole in the middle of it? DR. HOXIE: I don't think we've actually done any so-called backfill modeling at the present time. DR. FAIRHURST: It's sort of pseudo backfill. DR. HOXIE: Pseudo backfill. I see what you're saying. DR. FAIRHURST: Broken rubble is sitting there and inside of it you've got an open drift. DR. HOXIE: Right. But I think this is something that could -- this is an extension that could be done with our current seepage modeling. DR. FAIRHURST: I was just wondering why the reverse isn't the case. You look at what the problems are from a model and then see what tests to do to validate or invalidate the model. At any rate, it's easier to criticize, I know, than do it. DR. HORNBERGER: I'd like to explore that just a little farther. It's pretty clear that the seepage model is -- you are going to have to rely on that, not just because that's what PA does, but because your tests are all done in very wet conditions because you need to make the measurements now. DR. HOXIE: Right. DR. HORNBERGER: Whereas the seepage that you really want to calculate is at the dry end, and if you don't have the physics right, then that extrapolation from wet to dry may not hold water. [Laughter.] DR. FAIRHURST: So to speak. DR. HORNBERGER: I'm curious about what you're doing in terms of evaluating the physical models. As I understand it, you're just using -- you're using an ECM. Do you have any intention to investigate discrete fracture models? DR. HOXIE: Actually I think they are using discrete fracture models to simulate in advance of the tests especially for the niches, because that's such a small scale. And where they can go in and they can map the fractures so they can try to put in discrete fractures, and this is what they've been doing for prediction. But of course we can't -- this is not really feasible, certainly not at the mountain scale, and it may not even really be feasible at an emplacement drift scale where we're having to deal with hundreds and hundreds of fractures. So I think that it's probably a scale problem more than anything else, and I think our expectation is that we have sufficient fracture density within the Topopah Spring that one can justify using a fracture continuum kind of model. And I think there is some basis for that, because the models that are being generated with the stochastic permeability fields are based on air permeability data, which shows a wide range, indicating that you, you know, in the test you're intercepting in some cases many fractures, some cases a few fractures, and so that gives you statistical distribution of permeability. And I think by applying that, then I think you've got some basis on which to proceed. Also, I think that we're going to gain an awful lot of information just from all the niche and alcove studies that are going on. At least we'll better constrain our conceptual model for how seepage might occur. DR. FAIRHURST: Following that up again a little bit, and I -- please don't misunderstand this as being smart-alecky because it is an extremely difficult problem. But in the STREPA studies, they looked at fractures and you go and map the fractures and there's 150, 200 fractures. None of them look any different than the rest, but 90 percent of the water comes out of ten of the fractures or five or one of the fractures. How do we -- we're talking about seepage onto a canister here and the rates of seepage. It's a nasty problem. I just wonder how -- maybe you're just going to do it statistically and say -- DR. HOXIE: That's the current approach, and we also have to discriminate between, you know, some fractures that are -- or fracture networks that are locally more conductive than, say, the overall fracture mass itself. I mean, it does get very, very complicated, and our niche studies are showing just this kind of phenomenon. So -- DR. FAIRHURST: If you get a seismic event from that, you stop someplace and start up somewhere else. DR. HOXIE: I think that's very possible. DR. HORNBERGER: What -- I mean, you started out your presentation with, you know, your observation 57 days versus four hours. How have the models done with regard to your other tests as the data are coming in? DR. HOXIE: I'm sorry, I don't have any information on that. I really don't. I just read a 1998 report, but they didn't discuss the results of the modelling. DR. HORNBERGER: Okay. DR. HOXIE: And I think probably because the tests are still going, so that they don't have results yet that they want to quote. DR. HORNBERGER: Right. And I understand that there has been some criticism of the boundary conditions used in your modelling. Have you considered changes that you might do in the modelling with regard to again exploring different boundary conditions as well? DR. HOXIE: I -- DR. HORNBERGER: You don't know that. Okay. DR. HOXIE: I don't know which boundary conditions -- DR. HORNBERGER: Okay. DR. HOXIE: -- that you're referring to. DR. HORNBERGER: Okay. DR. HOXIE: I mean, in our drift seepage modelling, what we normally do -- well, if you're doing a test, you use the flux that you're going to impose in the test, and in the case of ambient seepage into a drift, we usually use the output from the UZ site scale model as the input flux or some multiple thereof if we want to indicate, you know, or simulate a higher infiltration event, like a climate change. So I would be happy to answer your question if I knew which boundaries you're talking about. DR. HORNBERGER: I understand. Other questions? DR. GARRICK: Amazingly I don't have any. DR. HORNBERGER: Okay. DR. HOXIE: You may have another opportunity. DR. HORNBERGER: Okay. And Dwight, I'll give you the same heads up. DR. HOXIE: I will try to go this one. I will abandon the -- I'm going to talk about our site scale flow and transport. I'll try to make this as brief as I possibly can. What we're really concerned about is the capability of the UZ to reduce concentrations of radionuclides beneath the potential repository. We need to be able to, in doing that, that being our concern, is to look at those kinds of processes that are involved, like adsorption, dispersive mixing with other waters, matrix diffusion -- that is, moving radionuclides out of fractures into the rock matrix -- and also allowing for colloidal facilitated transport. I just have three things to talk about: the experimental evaluation that's going on, our use of natural analogs and manmade analogs, and our mountain scale model. So hopefully this will go very quickly. In terms of experimental evaluation, we have the work at Busted Butte, we have the work that I just talked about in the ESF -- that certainly all folds into this -- plus we have laboratory studies, both of colloids and radionuclides. In Busted Butte, the test is off the repository block, of course, as you all well know. The phase 1 testing was completed in January. The major conclusions. This is a test in a non-welded tuff. It's a tuff that occurs below the potential repository, so it is germane to radionuclide transport. Within the vitric part, so-called vitric part of the Calico Hills, matrix flow is completely dominant. This accords with our conceptual model in this kind of rock. When fracture flow does occur, when it's induced to occur within the non-welded tuffs, the rate of flow is limited by the ability of the water to imbibe back into the rock matrix, and so that fracture flow doesn't -- is generally not sustained unless we have essentially full saturation of the surrounding rock mass. And we also discovered that yes, heterogeneity can deflect flow. Busted Butte, which we're now going into phase 2, which I don't know what the schedule is for that, but certainly within the licensing time frame, and this is actually now going to be a test, a similar test that was done in phase 1, but this time would be looking at the contact between the Topopah Spring welded unit and the upper part of the Calico Hills. The other aspect of the testing that will be done, of course, is to complete the analyses that -- of the phase 1 test results. In terms of ESF field test, I think I have already talked about that in the previous talk, so I won't really say anything more except that there is an Alcove 6, which is also on the Ghost Dance fault, that is actually going to be dedicated -- tests are going to be conducted dedicated to looking at this issue of fracture matrix interaction and trying to quantify that more substantially. In terms of laboratory data, we're doing quite a bit of work at LANL looking at colloids, both those that are generated from the waste and also looking at the development of colloids within the far field, near field of the potential repository that would develop naturally within the system, and the stability of these colloids and the rates at which radionuclides might particulate plutonium, might adhere or adsorb and desorb from them. In terms of other laboratory work, this is probably not so much laboratory, but we're updating our databases for the solubility ranges of those radionuclides that are of particular concern to TSPA, and we're also doing laboratory solubility measurements on neptunium and technetium under higher pHes and reducing conditions to extend the database. Talk briefly about analogs and how those are being implemented. The Yucca Mountain project has a long history of participating in various degrees of -- in numerous natural analog kinds of studies, but the problem has been most of these that have been done have been done in saturated zone environments. We need really to be looking at unsaturated zone environments if we're looking at analogs for the repository. Just to -- and so we have had an on again, off again program. It's on again now. We had a workshop in July, another workshop in February, and I understand there is an Appendix 7 interaction scheduled for March. Particularly for the UZ and SZ as well, but what we're doing is that we're going to generate synthesis report to develop a strategy for how to use natural analogs, both for the LA and probably more relevant to performance confirmation. We're talking about going back to look at a site in Pena Blanca in Mexico, to get some idea on uranium transport and the idea of using the analogs from Hanford and Nevada test site, the Idaho Laboratory to test and perhaps even somewhat validate our models. Talk about the status and what we plan to do with UZ site scale, flow and transport model. The planned work right now is that there is a new edition of our so-called geologic framework model. It says planned work; actually, that has now been incorporated. What I'm talking about here is actually a status since the viability assessment. So this is work that has been done since TSPA-VA. We have included, instead of treating faults as just vertical offsets, we now allow them to be inclined. We have extended our calibration methodology to allow for two-dimensional so-called model inversions, which is a parameter estimation technique that calibrates the model. We have developed a sub-model for the paintbrush non-welded unit itself that can be used for the Alcove 4 testing as well as for testing our hypothesis of how water moves through that non-welded unit. We have also developed a sub-model for the Calico Hills hydrogeologic unit in which we can incorporate the Busted Butte data as it becomes available. We can look at the spacial variability of zeolite abundance and how it affects, for example, the occurrence of perched-water bodies or transport properties through the UZ beneath the potential repository. And we're using reactive chemistry modeling capability to try to incorporate or allow for -- approximate the effects of repository in heat-induced changes in the rock mass itself. In terms of work that is going to be done, it is underway, is that we're going to refine the model grid so that it better matches the grid that was used for resolving the net infiltration distribution over the top of the mountain. Again, we're going to go through an extensive process of model calibration to improve the data, and we will be incorporating virtually all of the data that becomes available from the ESF, Cross Drift and Busted Butte. We will be incorporating data from the mineralogic and petrologic data from boreholes WT-24 and SD-6 that are not in the mineralogy models currently, and we're developing a reactive chemistry module that, in the far field, will be able to look at durable changes in the rock mass that might be induced by repository heat and chemical affects. We are going to be developing and implementing a fully coupled flow and advective/dispersive radionuclide transport model or module essentially within the UZ flow and transport model that will be able to use to compare against the particle tracking methodology that TSPA currently is using and hope to better corroborate that technique. And we're also developing a module that addresses colloidal-facilitated transport through the unsaturated zone for use by TSPA. So this is a summary of this talk, and so we have field tests, laboratory tests, natural analogs, and we're trying to improve our overall site scale model. And that concludes that talk. DR. HORNBERGER: Good. Thank you, Dwight. Questions on UZ? I have, first of all, an overall question. What is the estimate -- what is your estimate for, let's say, an average travel time of water from the repository horizon to the groundwater table. DR. HOXIE: Average, it depends on -- it depends on the conceptual model, really. And I think -- DR. HORNBERGER: Okay. Give me a range. DR. HOXIE: I will give you a range. Okay. They can probably be anywhere from ten years to a thousand years. DR. HORNBERGER: Okay. DR. HOXIE: And it really depends on how big a role the fractures play versus the matrix. DR. HORNBERGER: Okay. And are both -- are the full range of estimates consistent with such things as carbon-14 age dates? DR. HOXIE: I think they are. DR. HORNBERGER: Okay. DR. HOXIE: And even chlorine-36, so I think that -- I think that the real issue is, is that, for example, with the chlorine-36, we know we have fast pathways. DR. HORNBERGER: Right. DR. HOXIE: The question is, do these fast pathways also -- are they capable of carrying significant quantities of water? And that is the big issue. DR. HORNBERGER: Right. And, so, is the work that you just outlined in this talk going to be reduce your uncertainties in that exact question? DR. HOXIE: I think what is actually happening is probably the Busted Butte work is going to enable us to do that. I am hoping. DR. HORNBERGER: And does the unsaturated zone model allow you to simulate the fast pathways? DR. HOXIE: We have what we call a WEEPS model. Yes, it does. DR. HORNBERGER: So the WEEPS model will do that? DR. HOXIE: Essentially, but we can do that. Okay. Probably the big, critical factor here is, and you are probably aware of this, is what TSPA calls their fracture and matrix coupling factor, and this is the idea that you can have water moving down a fracture, okay, it doesn't interact with the matrix, and so there is no coupling. Or you can have it such that the water is moving through the fracture, it is completely in equilibrium with the matrix, in which you have full coupling. And so it is this number which people generally say ranges from zero to one. And it probably depends on your fracture system and so on and so forth, but it is that quantity that I think may come out of some of the niche studies, the Alcove 6 study, and the Busted Butte work, that we might be able to bracket that kind of number. I have got my fingers crossed. Because you have got a number that goes from zero to one, and it has immense consequences. When that is zero, then all your water -- then you have a WEEPS model. DR. HORNBERGER: Right. Then you have a WEEPS model. And, again, my recollection, in reading some of the technical basis documents, unless I misread something, when I looked at the particle tracking, some of those figures showed transport times where 30 percent of the material was arriving at the water table in less than a year. Did I misread those figures? DR. HOXIE: Probably not, because some of those, with the WEEPS concept, you end up with a lot of water going down something like Ghost Dance Fault, which becomes then a major conduit. DR. HORNBERGER: And would that be consistent with the carbon-14 and the chlorine-36 data? DR. HOXIE: I would probably say that it is, because I think you probably have a range. DR. HORNBERGER: Okay. So you really to extend the range you gave me to begin with all the way down to one year, one year to a thousand years. DR. HOXIE: I am not sure about the one year, okay. Maybe some of the TSPA went for a year, but I would have a hard time with that, mostly because of the 57 days versus four hour predictions. So, one year sounds awfully fast. DR. HORNBERGER: Okay. Thank you. DR. FAIRHURST: But what percentage of the total flux -- DR. HORNBERGER: About 30 percent, if I am not mistaken. DR. GARRICK: I just wanted to ask, what is the process of getting the results of your work into the model, into the performance assessment? And is that done continuously or is it done -- DR. HOXIE: Well, it is probably done in stages, but, for example, right now, in April, the UZ flow and transport model has a -- has to have the capability of generating the flow fields for TSPA. That will be used for TSPA SR Rev. 0, as it is being called, the base case. And then, the way that this would work is that the simulations that are actually performed are done by a team composed of TSPA modelers and our site UZ modelers. So that is the interaction that takes place. DR. GARRICK: Given the uncertainties that seem to be -- exist, and that you are probably not going to be able to do a great deal about, do you have any sense of what the impact is going to be on the performance assessment? DR. HOXIE: Impact in what -- DR. GARRICK: In terms of the performance measures, the dose calculations, for example. DR. HOXIE: Well, I think with the information that we have right now, and probably will be going into SR Rev. 0, we are probably going to be about the same as where we were TSPA VA. DR. GARRICK: Yeah. DR. HOXIE: I don't think that we have anything earth-shakingly new. DR. GARRICK: So it is more of a verification. DR. HOXIE: It is more of a verification, I really think, that we are doing right now. Now, the only thing I might argue is that I think -- that is optimistic, is that maybe we are discovering that it really does take quite a bit of water moving down to impinge on a drift in order to seep into a drift. We may -- this capillary deflection may actually be a more dominant mode than we might have first anticipated. DR. GARRICK: So it seems that where we are headed is that seepage is going to be there, water is going to be there. What is different about it is the rate, the flux, and the timing, and what it means is that if it doesn't get there as soon as is now being analyzed, that the peak doses will probably be pushed out further in time? DR. HOXIE: Be pushed out further. That's all, right. DR. GARRICK: And the uncertainties will increase -- DR. HOXIE: Yeah. DR. GARRICK: -- as a function of that time. And, so, one would have to conclude from this, it seems, that the emphasis ought to be on doing whatever can be done to keep that seepage from getting into the fuel assemblies. DR. HOXIE: And I think that is the current strategy. DR. HORNBERGER: Charles. DR. FAIRHURST: You were saying that you thought the Busted Butte studies would be the thing that will give you some help. And I keep coming back to this question, is the excavations of the Busted Butte, you know, alcoves, has that -- have you got any indications whether that will attract flow or divert it, or whether it will, you know -- is your result going to be -- are you fairly confident that it has, if you like, been inserted into this regime without influencing it locally? DR. HOXIE: I don't know that, from the Busted Butte data, that we have kind of information. Of course, we conduct the test and we perturb everything from the background. DR. FAIRHURST: Yeah, but if you, for example, were to say, you have got -- the side of the hill, you have got in situ stress conditions. DR. HOXIE: Right. DR. FAIRHURST: Now, you put something in there -- DR. HOXIE: Oh, okay. DR. FAIRHURST: -- to see whether you are creating tensions which will open the fractures over a region, which means you effectively have got a larger region. DR. HOXIE: Right. DR. FAIRHURST: Or you may actually do the opposite, you may increase the compression, which will push it away. And it is something you could do from a model to say how much of a -- because flow is going to be pretty dependent on an aperture, isn't it? DR. HOXIE: See, I don't think those mechanical things have really been examined in detail. DR. FAIRHURST: Oh, okay. It is jut an indication of the uncertainty. DR. HORNBERGER: Okay. Thanks very much, Dwight. DR. HOXIE: Thank you. DR. HORNBERGER: We are going to go on to the engineering material where there are, essentially, no uncertainties relative to -- I mean corrosion over 100,000 years. DR. FAIRHURST: Not in the next 20 years. Technical work plans that Dr. Stahl will address include long-term corrosion, continuation of long-term testing of nickel-based and titanium-based alloys and multiple material interactions such as tuff against CRM. In addition, there are models -- predictive models, mechanistic models being developed for localized corrosion and phased segregation effects, and these will be supported to the extent practicable by measurements and observations. Passivation effects are being measured and testing will continue to evaluate microbially-induced corrosion which I understand has not yet been observed on the Alloy-22 CRM material. That is all I have. After any questions you may have for me, I will turn it over to subject matter experts in these two areas. DR. HORNBERGER: Okay. My suggestion is going to be that after we ask Ernie questions we take our break now It's a natural place to break -- and then come back and hear the three technical presentations and keeping in mind that we are going to hear more technical detail on the three items that Ernie outlined, I would suggest that any real detailed technical questions we have would be better left for a little later. With that caution, I invite questions. DR. FAIRHURST: Let me ask this one quickly. Ernie, are you going to be here later? MR. HARDIN: Yes. DR. FAIRHURST: Okay. Then we can ask questions -- we can bring Ernie back on the stand? DR. HORNBERGER: We can bring him back, yes. DR. FAIRHURST: Yesterday people from DOE had to leave. DR. HORNBERGER: Yes. Marty? DR. STEINDLER: When you say fifty-fold variation in dose rate, you are talking peak dose rate? MR. HARDIN: Yes. DR. STEINDLER: You don't say anything about what the shape of that curve looks like in the first, say, 10,000 years where the period of compliance ends. MR. HARDIN: Right. There was -- DR. STEINDLER: Did you pay no attention to that? Is that not a part of the driving force for your prioritization process? MR. HARDIN: Well, let me just say upfront that generally the dose rates associated with the first 10,000 years of the performance period are much lower than the peak dose rates -- as I am sure you have seen from some of our products. DR. STEINDLER: Yes. MR. HARDIN: And that -- but there was a strong, there was considerable attention given to peak dose rates over a million years in this prioritization process. We did, in exercising the TSPA models, we parsed out when -- that being zero to 10,000, 10,000 to 100,000, or up to a million -- when the peak dose rate was calculated to occur. DR. HORNBERGER: And you also, when you parsed that, as I recall, you indicated -- you broke down where the processes were important in giving that dose and my recollection is that these three turn out to be important in the zero to 10,000 year period as well as at the peak dose, is that correct? MR. HARDIN: Yes, that is. DR. STEINDLER: What I am trying to find out is whether that startling factor of 100 or factor of 50 or whatever -- MR. HARDIN: Right. DR. STEINDLER: -- applies in the time, within the time of compliance. DR. GARRICK: Yes, one of the things that I would be interested in is if you look at 50 times with respect to seepage and 100 times with respect to unsaturated zone flow, what do you think is a reasonable goal in each of these cases, because that would certainly tell you which one you want to put the most emphasis on if all you are going to get is reduction from 50 times down to 45 times, say on seepage, and in the case of unsaturated flow you are going to get from 100 times down to 10 times -- then that would certainly suggest where you ought to put your effort. Can you say anything about what is a reasonable expectation here in terms of the uncertainty? Obviously you are not going to eliminate the uncertainty. You are just going to reduce it. MR. HARDIN: Right. These are not confidence interval analyses. DR. GARRICK: Right. MR. HARDIN: We ascribe no quantitative designation to the range. DR. GARRICK: Yes. One of the things that would really help this process is kind of what I think Marty was getting to is that if you could see a PDF of the peak dose before and after and how these programs are expected to impact that peak dose as a function of these, say, three major contributors, and I think all the evidence points to that these are the three major issue, that would be very beneficial. You would see more graphically what is likely to happen by addressing the quantification of the dose where by quantification I mean the curve. MR. HARDIN: Right. In our December briefings, as you may recall, Dr. Dockery showed a correlation analysis had been done, a statistical analysis of the principal factors against peak dose rate which tended to bolster these conclusions. DR. GARRICK: Do you have any sense of what is a reasonable goal with respect to your 50 times and 100 times number within the time period between now and when you submit -- MR. HARDIN: I hesitate to give you a range, let's say, tenfold or twentyfold, that would apply to all the factors. DR. GARRICK: All right. MR. HARDIN: Because clearly some of the factors are going to have more intrinsic uncertainty than others. DR. GARRICK: That's right and that is what I am sort of getting at is where would it be best for the resources to be allocated with respect to, say, just these three issues? MR. HARDIN: And the answer is where it is most desirable and feasible. That is where we interject judgment as to what we can achieve programmatically and include in the SR and LA. DR. HORNBERGER: And of course it is important to keep in mind that with two of these the issue isn't necessarily finding that seepage puts us in the lower 10 percent. Your measurements could put us in the upper 10 percent, near that top 45 to 50, rather than 5 to 10. DR. GARRICK: Yes, right. That's kind of what I was struggling with. If we went from 50 to 49 and 1 and from 100 -- DR. HORNBERGER: But it is still important to know that. DR. GARRICK: Right, right. DR. STEINDLER: One other quick point. The implication here is that you talk about testing to support the seepage model and the same kind of general set of words are found in all of those -- DR. HORNBERGER: Right. DR. STEINDLER: -- which boosts your confidence goals. No place do you seem to address model uncertainties. It seems to me that in some cases you are not even sure you have a clue as to what the mechanism is and so the model itself may be pretty far off. Did you factor this in someplace? MR. HARDIN: Model uncertainty was certainly used as a concern in the current confidence goal and in terms of assessing -- I'm sorry, in the current confidence. In terms of assessing the confidence goal it would be necessary to extrapolate where we think we could be and that also has been done, but I understand your concern in that we have not specified how the models would be changed -- DR. STEINDLER: I don't want to know how the model is going to be changed. The thing I am trying to find out is whether or not this confidence goal, you know -- the argument for the confidence goal being at the level it is seems to be based entirely on the acquisition of data and does not seem to address something that you are going to do to enhance confidence that the model uncertainty can be reduced. It is that difference that I am looking for. I mean you have great data but your model is lousy so general extrapolations -- MR. HARDIN: Well, I have given it that sense, and I would allude to some of our peer reviews which have told us that we don't have enough data. With more data the models will improve and that is really what we are saying. We understand where the models are the thinnest. DR. STEINDLER: We haven't got enough time to work on that one. I'll just let it pass. DR. GARRICK: Well, of course if we get enough data, we can simplify the model and in the limit we don't need a model if we have enough data. DR. FAIRHURST: If you have got the wrong model, the interpretation of the data will be wrong. DR. STEINDLER: Exactly. The acquisition of data is normally driven by some picture that you have called the model. If you continue down that road you probably aren't going to make a whole lot of important changes to the model and the model uncertainty remains as an unresolved issue. That is all I am saying. DR. GARRICK: Yes. Lynn? MS. DEERING: I just wanted to add something to this and this was based on something I heard Abe Van Leuyk say at the NWTRB meeting, and Ernie, tell me if I have got this wrong. He was implying with respect to confidence goals if a low confidence goal is assigned if DOE believes they have already -- there may be a lot of uncertainty but DOE believes it has captured that uncertainty in the current model, therefore it is bounded. A high confidence goal is given to those areas where the modelling is not expected to change much for the worse. In other words, dose could go down if they work on refining the model to their advantage, but it is not -- they are not going to put the money into a model where they feel the dose isn't going to get worse. Does that make sense? That is what I heard out there. MR. HARDIN: I wouldn't say that at all. We are very keenly concerned with defensibility. Continuing on, on some of the ongoing tests, we have come crevice corrosion fiber optic probe work that we are developing, trying to understand the chemistry of the crevice between the -- at least currently, the carbon steel and the alloy-22. What we will be doing, and I will mention later some of the work for some of the other combinations of materials. What we have also done here is a kind of quick and dirty test where we have put in some PH papers between the different components after the reactions have taken place. We do that under liquid nitrogen. We allow it to heat up and we measure the PH, and we are getting a relatively good comparison. Some other interesting tests that we are performing are relative humidity tests. As you know, after the repository cools down, the relative humidity rises. We have done some thermo-graphic analysis experiments to determine the critical relative humidities for these materials, and it depends to a large degree on the condition of the surface whether the condition is oxidized, salted, or unsalted, it will change the critical relative humidity at which corrosion will initiate. So those tests are underway in humidity chambers now, and we have just started in the last month drip testing onto some of these heated surfaces to study electrolyte chemistry and follow the corrosion process over time. In addition to that, we have also been working in the last month on some evaporation chemistry, and trying to compare that with what we would determine from calculations. The problem, as you know, is that, as you get to more concentrated solutions, a lot of the analytical modeling breaks down. So we are trying to enhance that and come up with some reasonable comparisons. As I mentioned in the beginning, we do have some microbiologically influenced corrosion work underway. That has been underway for about a year. What we are focusing on is nutrient requirements, biofilm generation and corrosion of the corrosion allowance and corrosion-resistant materials under low and high relative humidity conditions. In fact, in the relative humidity chamber, we are adding some of these biological couples so we can get some information there on the corrosion performance under those high relative humidity conditions. My last bullet here, there was some interest on the part of the design team on coating the carbon steel to enhance its corrosion-resistance, and we have done a series of evaluations with a variety of different oxide ceramics, including aluminum oxide, magnesium aluminate spinel, titanium oxide, and a variety of different plasma spray processes, including standard plasma spray, high velocity oxy-fuel, detonation spraying, et cetera, and we found that the high velocity oxy-fuel process gives us a high density, at least 98 percent density coatings, and we have those testing -- under test, rather, in the corrosion test facility, both in solid condition and with specimens that have saw cuts in them right through the coating. DR. STEINDLER: Did you ever consider using other alloys as coatings, like gold, for example? DR. STAHL: No, we have not. DR. STEINDLER: It has got a fair corrosion resistance, I would think, considering how much money you are spending, as it is. [Laughter.] DR. STAHL: A gold-plated -- DR. STEINDLER: You lost in the noise. It may be a tough sell to the public, though. DR. WYMER: Are you doing any of these tests under radiation fields? DR. STAHL: No for the container materials. What we have done is an analysis of what the radiolitic corrosion rate might be based on the literature and the dose at the surface of the package, and we have just completed a report on that subject, and we find that there is no radiolitic corrosion enhancement that we need to work about. DR. WYMER: But you haven't look at, for example, titanium under those conditions? DR. STAHL: Yes, we have. And, again, there is no impact. DR. WYMER: A little surprising since titanium forms a peroxide complex. DR. STAHL: Actually, I think the -- according to Dr. Shoesmith, the corrosion of titanium improves under a radiation field, but there is a report that he has generated on that subject. Let me talk about the waste package alternative designs. You have heard about those yesterday. One of the primary designs is the 2 CRM design, which is Alloy-22 outer barrier over a titanium inner barrier. Here we are not quite ready to conclude on the thickness of those particular barriers, but we need as a minimum 20 centimeters -- excuse me, two centimeters of Alloy-22 and probably a centimeter-and-a-half of titanium for the corrosion performance, but we may need to enhance those thicknesses in order to provide mechanical rigidity. There is some consideration of going up to perhaps five centimeters for the Alloy-22, that is one -- That's one option. Another option is to put an internal structure of stainless steel to provide additional strength. DR. HORNBERGER: Do you think we should buy nickel futures? DR. STAHL: No. The impact on the market's going to be fairly small. In fact, we've looked at that for titanium as well. Some of the shorter-term tests to address some of these new materials issues. We do have some short-term tests under way, and we do have several more planned to look at these corrosion-resistant materials, particularly to address some of the issues for the alternative waste package designs. If you have titanium and Alloy 22 crevice, for example, what are the impacts there? We've done some preliminary galvanic cell work with those samples, and we feel that the galvanic current is small because they're very close in the galvanic series. But we'll need to evaluate that. Stress corrosion cracking for each of those materials is a concern, although I think those materials are fairly immune under the conditions that we have in the repository. Hydrogen attack is a problem for titanium alloys, but we're currently studying titanium grade 7 which is a palladium alloy and has about .15 to .2 percent to weight percent palladium. Fairly immune to hydrogen attack, but we're going to have to confirm that. The issue that Dr. Hardin mentioned about the Alloy 22, its phase stability, there is the potential for phases to precipitate as a result of thermal aging, mu phases, sigma phases. What we plan to do there is we have a full diameter mockup that has been generated of Alloy 22. This is currently at Lawrence Livermore. It will be sectioned to provide some samples for phase stability studies both in the welded and welded and thermally aged condition. And as a corollary to this, we have some samples that we've obtained from Haynes that have been aged at over 40,000 hours at 427 C. We're looking at the phases that have been formed in that period of time, and we will be subjecting those samples to corrosion testing. Very briefly, for natural analogs, we do have models that describe the potential mechanisms for many of the materials, but for some of the newer materials we're going to need to develop those. For example, particularly with titanium. We'll have to develop those for the site recommendation and the license application. That process will include the evaluation of natural analogs and partially validating the performance models, and in helping to understand the long-term degradation processes. We have reviewed the existing literature, and I have asked the model people, particularly at Lawrence Livermore Lab, for these containment materials to incorporate this information into their models. Last item I want to talk about is Zircaloy cladding performance. We're looking at Zircaloy cladding as part of the performance of the spent fuel waste form. Vapor exposure to defective cladding and drip testing into rod segments are currently under way at Argonne National Laboratory. What we're doing there is we take about six-inch-long segments of spent nuclear fuel rods, we have several that have different ranges of burnup, anywhere from 38,000 to about 70,000 megawatt-days per metric ton. We drill some holes in them and are doing some of these vapor exposure. We also have a similar test which is sealed. It has swage like fittings on each end, and we drip water into those tests. Those tests have just started last month or the month before, so we don't have results there. One interesting thing that we are going to do is in the vapor phase tests where we have an autoclave running at 175 degrees centigrade, we'd like to put a small capsule which has J13 water in it, and the reason for that is we'd like to see whether we can speed up the interaction of any of the silica waters with the fuel. As you may have heard previously in some of my presentations when I addressed the issue of spent fuel dry oxidation, where you can convert UO2 to U308 and hence split the cladding, we want to determine whether any of the silicate phases would do the same thing. So that's the objective of this modified test. There are some tests planned to look at some of these other critical issues with Zircaloy. Hydrogen attack is one which is very important, and the potential for crevice corrosion given that under some conditions you may have some ferric acid chloride creating a crevice with the Zircaloy in those collapsed fuel assemblies. And lastly, models are being developed for the important degradation mechanisms that have been identified. In summary, I've talked about the testing and modeling programs that respond to the key materials corrosion issues that were identified. Those included waste package materials lifetime, use of natural analogs, and cladding performance. DR. HORNBERGER: Thank you, David. Questions. Marty? DR. STEINDLER: You've got something like depending on who you listen to, either three or four years to come up to speed and validate in some fashion or another the corrosion models. Aside from the existing uncertainty as to the environment in which the subject metals are going to corrode, which seems to me casts some doubt as to whether or not you're doing the right experiments, why do you believe that you're going to be able to arrive at models that are demonstrably correct and obtain data that is adequately useful for extrapolation to the time periods you're going to have? DR. STAHL: That's an excellent question. Certainly and unfortunately we've had a late start on doing the corrosion testing that's required to form a sound basis for models and model prediction. Long-term tests have only been going on for about two years. And as I indicated, we'd just be taking some two-year data very shortly. What we hope to do, and have been doing, is a series of accelerated tests to try to understand the mechanistic changes, if any, over the range of conditions that we would expect, and hence give you move confidence that the model that you're based on the performance condition tests basically do the job for you. Hopefully, we will be collecting additional information as we go into performance confirmation, and that would hopefully confirm the results that we've seen. So all of these tests will be continuing. We will be putting additional samples into those tanks so that we can have test data out to perhaps 50 years or so to confirm indeed that the material is behaving the way it should. We also, as I indicated, have some short-term tests looking at electrochemical response. It's not as good as a service condition test because it is under accelerated conditions. But again, that gives you some support that the results that you've seen are reasonable. DR. STEINDLER: What sort of ceramics are you looking at? DR. STAHL: Well, as I mentioned, mostly oxides, the magnesium aluminates. Banel seems to be the best. It has the best coefficient of thermal expansion and has a blackish type finish, so it gives you good emissivity response. But we've looked at some others. As I've mentioned, titanium oxide, aluminum oxide. Hafnium oxide is one that has been suggested, but it's a little more difficult to work with. DR. STEINDLER: Aside from gold, is there any material that will not corrode in the media that you're looking at? DR. STAHL: Well, you can get any material to corrode under aggressive conditions. The key is determining the conditions that you have at the site and relating the material selection to those conditions. What we would hope to do with some of the alternative designs -- for example, with the alloy 22, we had developed previously a model which gave corrosion rate as a function of chloride pH ferric ion concentration, for example, and we're using that same model to look at the corrosion of the outer barrier where you don't have aggressive conditions for the most part, you have benign ground waters. One of the things that you might get is some crevices form because of the salt deposits, and that's the purpose of our relative humidity chamber drip test, to try to evaluate the performance under those conditions. But we think that the current model can be extended to work under what we think the conditions would be for that alloy 22 outer barrier as opposed to the creviced case against iron. DR. HORNBERGER: Charles? DR. FAIRHURST: A couple of things. Steve Broucom mentioned this morning the upper temperature limit of about 350 C. What's the problem at that point? I mean, in other words -- DR. STAHL: The temperature limit of 350 C was generated many, many years ago -- I can't remember the date, but it's prior to 1987 -- and it came about in discussions with the three repository programs, and they came up with that limit based on a fairly cursory examination of the creep rupture data, which they thought was the primary mechanism for failure. DR. FAIRHURST: Okay. DR. STAHL: And we've kept with that limit on our program. The literature out there indicates that for the most part, if you do have some failures, they're going to be fairly localized pinhole failures, and that's part of the key of the Argon test, is to determine whether indeed you have some localized pinhole failures, whether that's going to lead to a cladding failure and hence greater exposure of fuel. Right now, in TSPA-VA, there's a fairly crude model for cladding performance, although some might argue it's non-conservative, but they say that for each patch that you open, you have ten centimeters squared area exposed, and that may be very conservative. On the other hand, they don't look at the total number of failures that could occur in that particular package itself as far as the cladding is concerned. So what I'm suggesting is that the Argon test might shed some light to say it doesn't matter whether you have small pinhole failures; it may be that if it doesn't lead to gross degradation, that you would just have limited area of exposure and you could conservatively assume that they're all failed. DR. FAIRHURST: What are the natural analogs that you -- DR. STAHL: There's a host of natural analogs, certainly for the waste forms -- Pena Blanca, for example, for uraninite; there's a lot of glass analogs that are out there. As far as metallics, you have some iron artifacts. There's the Roman nails, there's cannonballs, there's the Indian obelisk. So we have some information on how some of those materials behave under atmospheric conditions and under submerged conditions. What we don't have is a lot of information on nickel materials. The only thing that's close to it are meteorites, which are iron nickel, and recently people have identified josephinite, again which is an iron nickel mineral. DR. FAIRHURST: All right. Thank you. DR. HORNBERGER: Ray? DR. WYMER: On what basis did you select the upper and lower pH limits? DR. STAHL: That came again from the geochemical workshop that we had. The feeling that most people had was that the range should be about four and a half to ten, and we felt, to be conservative, we would extend that and widen that range. So we went down to about 2.7. It's interesting that subsequent calculations that were done by Joe Farmer and Kevin McCoy indicated that the crevice pH between iron and alloy 22 would be about in the range of two and a half to three, so we were fortunate in that assumption. DR. WYMER: Okay. And the upper limit was based on concrete? DR. STAHL: Yes. DR. GARRICK: You got into it a little bit with Dr. Fairhurst's question, but you didn't say a great deal about the parameter temperature. I assume your tests are varying temperature. DR. STAHL: In the long-term corrosion test facility, we use 60 and 90 degrees centigrade. For some of the localized corrosion electrochemical tests, we do a variety of different temperatures. We have not gone higher than the boiling point at this point, but there is some interest in going up to higher temperatures based on the results of that concentration study that are currently underway. There's the potential with nitrate dominated -- nitrate and chloride dominated salts, that you might have equilibrium boiling point of about 120 degrees centigrade. DR. GARRICK: Yes. DR. STAHL: And if that is confirmed, then it's likely that we'll be doing some additional tests up at that temperature. DR. GARRICK: Thank you. DR. HORNBERGER: Marty? DR. STEINDLER: Yes. Just one other question. When you're using 1,000 XG-13 water, the fluoride concentration is now in the interesting stage. Have you done, you know, a hard look on the role of complexing agents like fluoride, both on the materials -- the metals as well as on the waste form corrosion? DR. STAHL: We have not -- DR. STEINDLER: I couldn't find any of that. DR. STAHL: We have not explicitly done that, but we have essentially looked at the results of the testing that we have with the concentrated salts and have not seen any adverse effects, although the literature is replete with references. If you do concentrate with a chloride solution, for example, or a fluoride solution, it's going to lead to problems. But because of the combination of salts that we have, you do help, I think, with passivating the surface. DR. STEINDLER: Do you believe that? DR. STAHL: Yes, I believe that. DR. HORNBERGER: Do your conversations, your interactions with NRC staff lead you to believe that your work on the cladding will, in fact, result in acceptable data and models to use it in the license application? DR. STAHL: I believe so. We have a recent report by Dr. Tae Ahn, who is in the back, and he had indicated which of the degradation mechanisms were important and which were not. Our position is fairly consistent with his. He suggests some confirmatory tests in some of those areas that I mentioned, and hopefully we will do those tests. DR. HORNBERGER: Other questions? Thanks very much, David. DR. STAHL: Sure. DR. HORNBERGER: We are now going to break for lunch and we will reconvene at 1:15. [Whereupon, at 12:17 p.m., the meeting was recessed, to reconvene at 1:15 p.m., this same day.]. A F T E R N O O N S E S S I O N [1:15 p.m.] DR. HORNBERGER: It is now 1:15 Garrick Standard Time -- and we are going to continue this with the schedule. We have the NRC Staff presentation on VA and Mike Bell is going to do that presentation and we will just go ahead and get started. Mike? MR. BELL: Thank you, Dr. Hornberger. Dr. Michael Bell -- I am Chief, Performance Assessment in High Level Waste Integration Branch in the Division of Waste Management in NMSS. I will be talking to you this afternoon about the Staff's review of DOE's viability assessment, which is still a work in progress, and I will be talking a little bit about the schedule and where we are and where we are headed as I proceed through the talk. First slide, quickly, just an outline of the briefing -- why we reviewed it -- because it is not always obvious -- what we did, where we are in the review, and essentially where we came out. Now the VA, I'd just like to remind people, is not a licensing document. It is a document that Congress asked DOE to prepare in the authorization legislation -- or it was the appropriation legislation in 1997. Congress didn't specify any particular role for NRC in review of the VA. However, we are reviewing it as part of our ongoing prelicensing consultation with the Department of Energy. We also expect to be asked by Congress for our views on it because, as the future regulator, we have a unique perspective on the work DOE is doing, and by statute we have this responsibility to consult with DOE on their site characterization work and to give them feedback on whether they are doing the right things to eventually support a license application. The second bullet -- our focus is mainly on those parts of the VA dealing with their test plans, design concepts, their safety case, and future work plans to develop the license application. Now the VA has four parts. These were actually identified in the legislation by Congress as things that had to be included. NRC is particularly interested in looking at the design concept, the Total System Performance Assessment, the LA plan, and less interested in the costs. In fact, in our review we didn't look at the costs at all and in the cost estimates only looked at things like their Performance Confirmation Test Plans and schedules for some of the work they are planning to do. Now we have actually been preparing to review the viability assessment for quite some time. We have had a series of interactions with the Department on TSPA VA, some of which in fact the ACNW members attended. If you recall, I think it was July a year and a half ago, back in San Antonio. We have also had technical exchanges with the Department on the content of the VA itself and in particular we had an exchange on the LA plan sort of late in the development of the viability assessment. The hard copies of the viability assessment were actually received at NRC on New Year's Eve, and we are due to get a paper to the Commission with Staff comments on the 9th of March. That paper right now is just about to go into internal management review and I'm expecting that maybe next week a predecisional version of it can be provided to the ACNW members to help you get ready for the upcoming Commission briefing, because we are scheduled to brief the Commission on the 16th of March on our comments on the viability assessment. Later that same afternoon the state, the local governments, the Indian tribal representatives will be speaking to the Commission and then the following day the ACNW and the Technical Review Board are being asked to inform the Commission of their views on the viability assessment. I know you are in a difficult situation in that you won't be needing to write your letter until the following week, so perhaps the Staff views will help you prepare for the Commission briefing. In the viability assessment DOE analyzes the probable performance of the repository using its reference design, and we reviewed those analyses of the department. We also conducted our own analysis of the reference design using our own TPS, Total System Performance, code. Based on what we identified -- we did sensitivity analyses as part of this -- and based on what we identified as the parameters and processes that were most important to performance, we used that to focus our review of the LA plan and to look at whether the department was in fact doing the right work and planning to do work on what our analysis showed to be the most significant contributors to dose. In doing our analysis, we, both NRC and the -- well, and the department, in their own analysis, looked at a 25 millirem, all pathways standard to an average member of a critical group living in the Amargosa Valley, 20 kilometers or so from the repository. In Part 63 we currently have a 10,000 year period of performance. Both DOE, in the Viability Assessment, and the NRC staff, in the sensitivity analyses, went out past that. In our analyses, we carried them out to 50,000 years. And, basically, we looked very hard at what DOE's performance assessment said was significant, you know, compared that to ours, and all with a view towards how prepared is DOE to have the data and the analytical capability to prepare a license application. Now, the outcome of our review, essentially, is we don't think we identified any new issues, that any of the post-closure performance issues that surface are things that are already encompassed within the key technical issues the staff has been looking at for the last several years, and most of the concerns are already documented in Issue Resolution Status Reports that the staff has provided to the Department of Energy. The review, in fact, had a number of positive aspects which I will elaborate on on another slide, and we did identify a number of concerns where we think DOE needs to do additional work, or somewhat different work than is currently planned in order to prepare a complete and high quality license application. Some of the positive aspects of the review were that we established a good communication with the department and contractors doing the technical work for the department. There was a good exchange of information during the technical exchanges that we had. DOE did not provide us a copy of the draft VA itself because that would have resulted in it becoming a public document and our placing it in our public document room, but they did provide a large number of supporting references and other documents that facilitated our review. And, certainly, in the meetings and the discussions, we are getting insights into what they were writing in the Viability Assessment. And they recognize many of the areas where additional work is needed prior to licensing and, you know, even since the Viability Assessment has been released, we have continued to have interactions with them on their work plans and the work that Steve Brocoum was describing this morning to develop -- what do you call it? -- a multi-year plan for site recommendation and the license application. In our review of Viability Assessment, there were a number of areas where we don't see any major differences in approach between NRC and DOE. The analyses that are being done, we think are coming to similar conclusions. The data is either -- we don't have, I guess, big disagreements with the assumptions, the data that is being collected. And I have got a list of these areas on these two charts. I don't plan to go through these in detail, because they are the less interesting ones, they are the ones where we are in agreement. Areas where we think there are still things that need to be brought to closure are listed in the next couple of slides. Regarding the preliminary design concept, I sat in on a discussion this morning that I think reflected much the staff's concern. You know, the reference design is not what I would have had in mind as a reference design. There is so much still uncertainty about major parameters of repository design. And then, on top of that, so many additional options that are being considered, it just creates tension between having flexibility and the ability to gather the data to support the design and support the safety case. So, in our view, one of the things that needs to be done quickly, and the department is planning to do it this fiscal year, is to settle on a reference design so that it can focus its program, focus its future total system performance assessments, do the necessary analyses and start focusing on the license application. The next several areas are aspect of the total system performance assessment where we think there is either weaknesses in the models, in the data supporting the models, that is not necessarily being addressed at the rate that we would anticipate it would need to be done to support a license application, roughly three years from now, it is three years next month. And the waste package corrosion is one of the areas. Important decisions still even need to be made about the materials of construction, but if C-22 is the material of choice, there is very limited data and experience with it. Even though there are some corrosion tests being done, there are questions about fabrication and the -- well, the possible failure modes that would result from welding and other fabrication questions that aren't adequate being addressed. A closely related question is the quantity and chemistry of the water that will be in contact with that package. The near field coupled processes that result from a high thermal loading are a very difficult area to model and predict, and I guess we don't see, in the tests that are being planned, the necessary work that will answer -- provide the answers to all these questions. And, again, there was a discussion this morning about you can avoid some of this by going to a lower heat repository design possibly. Then saturated zone flow and transport is another area where data is just very sparse in the saturated zone out to the critical group. There are plans to acquire some of the necessary data in the Nye County drilling program, but there are concerns about whether all the right data will be gathered and whether it will be gathered on a schedule that would support a license application in three years. The last area on the chart, igneous activity, as this Committee knows, the staff feels that it has bounded the probability question, but there are still large differences between the consequence analyses that the department has done in the Viability Assessment and the staff's view of the consequence models for a volcanic event. The staff's view on this was documented in the Revision 1 of the Issue Resolution Status Report on igneous activity, and I would point out that the LA, which doesn't -- the LA plan, which doesn't indicate DOE plans to do very much work in this area, is already out of date because we have had Appendix 7 meetings and workshops with them and discussed the issues identified in the Issue Resolution Status Report, and there are work plans being developed to refine some of these consequence models. Now regarding the LA plan itself, it's a snapshot in time, and as Steve Brocoum told you this morning, you know, they finished work on it August of last year. Since the plan has been issued, DOE continues to focus -- and in fact is very positive. In the viability assessment they take our key technical issues, do the crosswalk between their parameters, show where the KTI's are, you know, addressed in their program, and that was probably another positive aspect of the VA that I should have mentioned earlier. They are using our issue resolution status reports in the planning of their program. They've had workshops to develop work plans where in fact they take the IRSR's and they walk through the NRC concerns and talk about well, what work can we do to address this? And, you know, the question, you know, then will be the implementation of these work plans because, you know, the NRC staff has seen a number of study plans in the past that, you know, never actually got carried out. Now since the VA is not a licensing document, it really wasn't developed under a quality assurance program, but DOE itself in its audits of its programs has identified a number of deficiencies in their quality assurance program, and as you heard from Steve this morning and as we discussed yesterday morning, there is a, you know, certain amount of the data that underlies the models that they've developed, and the analyses that they're doing is of questionable pedigree. The Department, you know, has recognized that, you know, they haven't been successful over a period of years in getting their hands around the quality assurance issue, and to their credit they are giving a lot of senior management attention to the issue. And, you know, NRC is planning to follow very closely how the Department addresses this problem. The next thing we expect to see is a root-cause analysis and a corrective-action program that Steve I think -- is Steve still here? I think he left. Has said he would provide us and meet with us in April of this year. And as Dr. Brocoum mentioned, they are giving very high-level management attention both at the -- within DOE OCRWM program itself and within the M&O and they are relying on obtaining outside assistance as well. And I understand NEI will mention their offer to assist later when they talk to you this afternoon. Where from here? Basically as I mentioned earlier there is a staff paper that we owe the Commission by the 9th of March. The paper will include a draft letter to Lake Barrett with comments on the viability assessment that we're recommending that the Commission forward to the Department. We'll be explaining the basis for these recommendations to the Commission on the 16th of March. And, you know, it's assuming things proceed as we're recommending, then we would continue to interact with the Department in this prelicensing consultation program to make sure DOE has every opportunity to address these concerns before they submit a license application. So, you know, in a general sense that's where we are, and I'm available to answer questions. I've got a number of KTI leads here, as well as Dr. Sager from the Center. DR. HORNBERGER: You brought your backup team; right? Okay. Thanks, Mike. I'm sure that there are some questions. Marty, do you have any you want to start with? Charles? DR. FAIRHURST: I'm interested in this first staff concern about the preliminary design concept impact of flexibility of design on data acquisition. I'm not so sure what that really means. What has really been happening is that the notion of a low-temperature repository has sort of been added because the other one, the high-temperature repository, has always been on the table. And so presumably data acquisition, et cetera, has all been going on on that assumption. If you take the high-temperature part of it out, sure, your data needs change, but a lot of things become simpler. And so I'm wondering what is it -- and, for example, whether you use cement or bolts really doesn't -- MR. BELL: Well -- DR. FAIRHURST: That's all preclosure stuff. MR. BELL: You have many, you know, other aspects that are still unclear, like whether or not the repository will be backfilled, how long they intend to keep it open, you know, really what -- DR. FAIRHURST: But most of those are preclosure issues, right? Like how long it stays open is just a question -- it's a preclosure issue. MR. BELL: Well, it's not entirely separable. I mean, there may be things that have to be done to keep it open for 300 years that would have postclosure impacts, and we don't know enough about the details of designing the repository and maintaining it open for 300 years to know what the impacts are. DR. FAIRHURST: It's still not clear. DR. HORNBERGER: I guess what isn't clear is how that would necessarily impact data acquisition, Mike. DR. FAIRHURST: Right. DR. HORNBERGER: I mean, certainly all of the aspects that you mention will affect performance or could affect performance in some way or other, but your bullet says the impact on data acquisition. MR. BELL: Well -- Jim Firth, he's -- try to help me out. MR. FIRTH: James Firth, NRC. Also, the flexibility of the design also reflects the waste package design in terms of the materials and how they're stacked, so there's the issue in terms of failure modes with the materials and how they are interacting with the natural system and how they'll perform. So it's not just the high-temperature issue, but if new materials or combinations of materials are put in place, then that could also impact data acquisition. DR. FAIRHURST: Data on what, on corrosion rates? MR. FIRTH: Data and failure modes of the waste package. For example, the waste package is a very important component of repository performance, and if you're looking at different combinations in terms of the corrosion-resistant material on the outside versus the inside, you may have different failure modes for the waste package. And in terms of looking at -- in a comprehensive way to look at what are the most likely -- the failure modes of most concern for repository performance, it does take some time to do that. So the concern is that with the range of flexibility in terms of environmental conditions and waste package materials for example that it does take some time to collect the necessary data and to look at the failure modes so that you are not underpredicting or being overoptimistic in your estimates. MS. DAVIS: Mike, if I could ask -- MR. BELL: Okay. Jennifer Davis. MS. DAVIS: Jennifer Davis. I'm team lead for both the container life and source term, KTI, and the waste package corrosion KESA. I think the way that we phrase this is we're concerned with data acquisition for waste package materials even if the design was frozen as a reference design, so that the flexibility in the design simply further complicates that issue. DR. HORNBERGER: So what I heard you say, Jennifer, then, even sticking, let's say, just to the reference design, the staff is concerned about data acquisition to bolster the license application in terms of the materials? MS. DAVIS: Right. Exactly. There is an aggressive plan for testing and what not for the waste package materials. However, we're concerned that if that's not met or if that's not lived up to, we're concerned with backing up some of the data and figures, I mean, excuse me, data and models in the code. DR. STEINDLER: In your assessment of the TSPA as you received it, you listed six or seven different items. Did in any of those the issue arise that your models are drastically different than their models, and you think that their models have serious problems? Exclude for the moment in that discussion the question of how well the models are supported by data, whether data acquisition is adequate to meet your current needs, et cetera. I'm looking for model uncertainties and differences in models between what you think is going on say in corrosion versus what DOE has structured. MR. BELL: Let's see. And just limit it to the corrosion model? DR. STEINDLER: Well, no. To any one of those topics, whether it's, say, water chemistry. MR. BELL: Well -- DR. STEINDLER: Is your water chemistry model drastically different than their water chemistry model? DR. FAIRHURST: If you put the same input, do you get a similar output? MR. BELL: Tim McCardin. MR. McCARDIN: There are contrasting assumptions in models. Probably the -- in the release models probably is the easiest one to typify where for spent fuel they have a much lower or a much higher release rate for dissolution rate for the spent fuel than we have. However, it's bounded by the opposite situation for cladding, where we take no credit for cladding and they are taking a substantial credit for cladding. The net effect almost cancels each other out, but the models are actually quite different. Is that the kind of thing you're -- DR. STEINDLER: Well, I'm trying to distinguish between two people making different assumptions on the same fundamental model of how the world works versus people having two different fundamental assumptions on how the world works. Did I make myself clear? MR. BELL: I'll have to read that in the transcript. [Laughter.] DR. STEINDLER: No, but if you make similar input assumptions you get the similar outputs. MR. McCARDIN: Correct. DR. STEINDLER: If you change your dissolution rate to theirs and so on. MR. McCARDIN: Oh -- if we make the same assumptions, we would see similar kinds of things although there are a lot of other aspects than just those two because it is the amount of water that gets into a waste package and et cetera and we have to make those the same also. DR. STEINDLER: Yes. MR. BELL: Let me try to say how I would explain the difficulty. Basically the department in their analyses of the spent fuel dissolution makes very conservative assumptions about the dissolution rate of the fuel which forces them to rely very heavily on cladding credit and the cladding has to remain intact for very long periods of time under conditions it hasn't been designed for and we don't see them gathering data to support that assumption. DR. STEINDLER: I am trying to back you off that. That is based on some kind of an end-target description, whether it is 25 millirem or not is immaterial. If you just have a look at the spent fuel dissolution kinetics and the model that is used to describe the rate of dissolution of irradiated UO2 -- let's now bear -- we are just focusing on irradiated UO2. Is the sequence of chemical reactions for example that you folks are using, NRC, similar or the same -- which is the model outline -- similar or the same as the one that DOE is using, or is that the fundamental argument that you have about the reaction of spent fuel with water? MR. BELL: Okay -- Brent Leslie? MR. LESLIE: Brent Leslie from the NRC Staff. Basically the TPA code was designed with the flexibility to look at alternate conceptual models of spent fuel behavior, because we have great uncertainty in terms of water chemistry. We include a model that is exactly the same as DOE based upon DOE data which assumes that there are no cations other than carbonate in solution dissolving. DR. STEINDLER: That is what I am after. MR. LESLIE: The second model includes cations calcium and silica. We have another one that is just a straight release rate, a user-applied leach rate, so we do capture that type of uncertainty in models in the TPA code. DR. STEINDLER: So I guess the disagreement between DOE and NRC then boils down to one selecting one of those models that was just outlined and what you think it is and perhaps some underlying assumptions? MR. McCARDIN: If we want to agree that that type of chemistry in the water is representative of Yucca Mountain, we would get the same release rate. DR. STEINDLER: Okay. All right, so at least you are looking at the same universe roughly? MR. McCARDIN: Yes. DR. STEINDLER: Well, that is heartening to know. [Laughter.] MR. McCARDIN: We are on the same planet, yes. DR. STEINDLER: Okay. Onward. DR. WYMER: Marty set the stage for a question that I wanted to ask. Thanks, Marty. DR. STEINDLER: Any time. DR. WYMER: As I am sure you know, Mike, EPRI has quite recently come out with quite a thick report where they also do what amounts to a viability assessment and Total System Performance Assessment and I wondered if you have had time to look at it, then I wonder if you can answer the question are there any significant differences in the results that they get or things that they dredge up that are important different from what you and NRC and the DOE people get? Can you answer that question or have you had a chance to look at it? MR. BELL: Do you know or the Center know? MR. LESLIE: I would answer that we haven't had time. We have been focusing on -- DR. WYMER: I know it came out quite recently, Brent. MR. LESLIE: Brent Leslie from the NRC Staff. We got it in and we will probably take a look at it in terms of revising the IRSRs but we have been focusing primarily on the DOE TSPA VA. DR. WYMER: That's understandable. DR. HORNBERGER: John? DR. GARRICK: The committee is quite familiar with how you are using the TPA to analyze the design, but I was curious in response to the first part of the VA, which is the preliminary design concept, how much beyond the TPA analysis have you gone, and in particular have you done what I would call an engineering design analysis of the design where you look at the details of how they have designed this thing, how they are engineering it, and the impact of operations activities, et cetera, on that design? Now I know one of the things you are going to say is that they don't have a design yet -- DR. HORNBERGER: That is the only thing he is going to say. [Laughter.] DR. GARRICK: But this committee has had some concern about a strong engineering perspective of this project, especially with respect to the engineered barriers and the waste package, because we just haven't heard somebody from the NRC stand up and talk to us from an engineering point of view about the design and talk to us about fabrication, talk to us about materials, except in the context of the TPA. MR. BELL: And that is because our focus in this has really been post-closure. The only aspects of operational and fabrication and all are such that we have even considered are the things that then would have to be considered in post-closure performance. DR. GARRICK: Well, I am thinking post-closure. I am thinking of things that you would do in the design and operations that would impact its long-term integrity, for example. I think you have answered the question and I think the answer is no. MR. BELL: Well -- yes, the answer is no. DR. GARRICK: You said there are no new issues. You have articulated the old issues, so to speak. With respect to the old issues, what is -- if you are able to do that at this point, what are the candidates, if you wish, for show-stoppers in the eyes of the NRC? You can list all of them or three or four of them. You don't have to list just one of them. MR. BELL: I don't think that there is anything that is on this list that given enough time and money -- DR. STEINDLER: That is a cop-out. DR. GARRICK: I am assuming within reason. We have got a job to do and that is to license this thing, and we have heard about a schedule, and I think that should be the general framework within which we answer the question. DR. STEINDLER: Yes, and here sits the taxpayer wanting to see what your answer is. MR. BELL: But there is nothing on this list that is going to cause us to conclude that, well, the site is just unsuitable and they shouldn't even go forward. I mean it just becomes a matter of if they want to be able to prepare a license application that the regulator would docket, be able to review without many rounds of questions and have a very protracted hearing debating all of the assumptions and alternative models. These are the weak areas that we think additional work needs to be done and I think one of the areas of concern is in fact getting the data for the saturated flow model, whether in fact the -- see, the Nye Country drilling program was designed by Nye County for Nye County's purposes. Some of that information will also be useful to DOE for preparing a license application, but it wasn't really designed for the purpose of answering all the licensing questions that DOE may have to address, so that is an area. I think the waste package -- just whether they will have adequate data on corrosion rates and failure modes of the materials of construction to be able to project performance for long times in the future. DR. GARRICK: The only other thing I wanted to say, I don't want to give you any easy questions, is that -- MR. BELL: Why start now? [Laughter.] DR. GARRICK: We kind of know the direction that Part 63 is going, but there's a lot of interest in what happens beyond the time of compliance period, and what is going to be the NRC's position therefore. I am thinking in particular of the dilemma of a highly contained repository that results in a very, very late peak dose and the dilemma that the better the containment, the worse the dose in terms of being further out in time and probably higher in magnitude. Can you share with us what, if anything, NRC is going to do in that arena? Now of course rulemaking would help a lot in dealing with it, but surely this is something that is on your mind and is something very unique about this analysis and license application, and sooner or later we are going to have to deal with it. MR. BELL: Well -- as I indicated, you know, in our analyses we -- for information purposes -- are carrying out the dose calculations to 50,000 years and even at 50,000 years we are within the 25 millirem all pathways. DR. GARRICK: Yes, but it is still going up. MR. BELL: I guess I have difficulty saying that let's carry out analyses to a million years through many glacial cycles, look at super-pluvial conditions hundreds of thousands of years in the future and using that information it seems like it is a very speculative scenario. At least not until now what EPA has considered in the WIPP situation, it's not what is being considered in legislation that's been introduced in Congress and I think the Commissioners themselves feel that 10,000 years is an adequate -- DR. GARRICK: Well, but the committee is already on record with a letter sort of saying that as well, but I guess in the global scheme of things we have to be responsive to questions that come up -- MR. BELL: See, like I am aware that the French have rejected one of their sites because of a scenario where I don't know how many hundreds of thousands or millions of years in the future the Straits of Gibraltar are going to close up and the site, the water level will rise, and -- DR. FAIRHURST: They had two others to choose from and that was the third one. [Laughter.] DR. HORNBERGER: They needed an excuse. DR. FAIRHURST: There were political reasons why they needed it. DR. GARRICK: I didn't expect an answer. MR. BELL: I know for example that there are plate tectonics theories that say that the Western United States is going to split off along West Valley -- DR. FAIRHURST: West Valley? My goodness -- MR. BELL: I'm sorry, Death Valley -- [Laughter.] MR. BELL: And then essentially the discharge point for Yucca Mountain is going to be the Pacific Ocean. DR. FAIRHURST: That helps. [Laughter.] DR. FAIRHURST: Think of the dilution factor. No, but coming back a little bit to WIPP, I think a lot of this is really in the realm of public acceptance. It is not a question -- and at WIPP absent human intrusion you could carry that thing out as long as you want and you couldn't find any release. They didn't do it just to take 10,000. That is a useful calculational figure but the whole calculation is based upon human intrusion. We haven't even started talking about human intrusion at Yucca Mountain. It is a different kettle of fish, I realize, but the other thing is that it was not saying you carry it out for a million years, 10 million years or whatever. It was to the time of peak dose. Now let's suppose you have four or five different scenarios or designs and they all comply with 10,000 years. Presumably they would have different long-term behaviors. Maybe you have an option then to say the one that gives us the most benign result over the long period is preferable to the others. It doesn't have to be an absolute. I think there are some strategies at NRC a regulator could use to make a determination. MR. BELL: And I guess what you are suggesting is, you know, perhaps that is a change, you know, that ought to be considered for Part 63. DR. HORNBERGER: No, I think that John's point isn't necessarily change for Part 63 but that in fact the NRC -- we will have to think about the implications of increasing doses beyond 10,000 years, and I think it is just a question of how one begins that thinking process and what one does. DR. GARRICK: Yes, and as Charles says, we didn't have -- we don't have that problem on WIPP. DR. HORNBERGER: Keith, did you have a comment? MR. McCONNELL: Yes. Keith McConnell. We have been thinking about that and there are a number of -- it's not like the calculations aren't going to be done, so the information is going to be out there and I think there are a number of ways you can incorporate that information into some sort of licensing decision. One way is to look at it as a way of -- as you know, in Part 63 there is also a requirement for multiple barriers. Well, if you have a 12,000 waste package, you still need to demonstrate the contribution of the natural barrier, and if you look beyond the 10,000 year compliance period to help you define what the performance of natural barriers are you can incorporate that information into your licensing decision to provide a reasonable assurance that the whole system works, but that is kind of where we are right now. DR. FAIRHURST: Okay. DR. HORNBERGER: Marty? DR. STEINDLER: Let me get back to your favorite topic of QA. You indicate and probably correctly that much of the data is not, quote, "properly qualified." I would assume that in the light of how much effort it has taken so far to get this non-qualified data that repair of that issue is unlikely, and that I would guess that you could look forward to future efforts on the parts of DOE to make sure that their future activities are appropriately qualified and it remains to be seen how successful they are, scientists being a recalcitrant bunch under any conditions. DR. GARRICK: That's only a few of them. DR. STEINDLER: But a significant -- none of them are chemists. A significant fraction of the data that is currently being used, being incorporated as parameters in models is not going to get redone simply because either the literature from which derive is clearly uncertain about qualifications, or, in fact, it was not done by somebody in DOE under qualified situations. What is your strategy at this stage of the game for allowing that kind of information to be used? MR. BELL: Well, I guess there are, you know, several things that are possibilities. We do have a staff position on how you deal with this situation, and there are several ways that we would -- DR. STEINDLER: Well, let me remind you that that staff position would probably qualify the famous paper on cold fusion that was published in the Electro-Chemical Society Journal, which I think subsequently has turned out to be probably highly incorrect. So I am not so sure that that -- MR. BELL: Which method? DR. STEINDLER: That staff paper -- MR. BELL: Yeah. DR. STEINDLER: -- on how to qualify literature data that you haven't got? MR. BELL: Yeah. Which method is the one you would choose to qualify cold fusion? DR. STEINDLER: I would qualify any of it, is what I would -- I could tell you. MR. BELL: No, I mean -- DR. STEINDLER: The point is if you apply your methods to that kind of a paper, and I assume similar kinds of papers, the assurance of quality is unlikely to be reached. So, you know, I am not too sure that that is going to work. MR. BELL: The methods in the staff position are essentially go out and duplicate the data and get corroborating data. DR. STEINDLER: Yeah, well, I don't mean that. MR. BELL: Which was not able to be done for cold fusion. DR. STEINDLER: Sure. MR. BELL: It is -- you know, to have a peer review of the work, essentially, peer review showed cold -- you know, questioned cold fusion. DR. STEINDLER: No, the paper was peer reviewed. What I am telling you is that -- what I am suggesting to you is that there is a flaw in the staff position at this stage of the game, so I wouldn't rely too -- MR. BELL: What aspect of the staff position? DR. STEINDLER: The peer review aspect. MR. BELL: So I can fix it. Okay. DR. STEINDLER: You can't, it's too late. The point I am making is that you have got a considerable amount of information that is not qualified by your current approach. MR. BELL: Right. DR. STEINDLER: But it is going to have to get used. What are you going to do about that? Are you going to allow it to be incorporated into the DOE models, or are you going to say, fellows, you can't use that information and, therefore, come to the conclusion that you can't even exercise those models? MR. BELL: Well, one of the things that the NRC would allow is a graded QA approach where you would look at the importance of the model, the particular data, et cetera, to total system performance, and then there may be data that is only sort of loosely related, not among the most important parameters, where, you know, we would accept the data of, you know, less pedigree. But, you know, what turns out to be the key models and the key parameters they are relying on for performance, I think, you know, they are either going to have to be corroborated or, you know, some robust way of defending them in the licensing process is going to have to be accomplished. DR. STEINDLER: Well, just as a comment, I would recommend you look at what DOE has done at a very early stage, like tomorrow. See whether or not you can convey to DOE those aspects of their important models that you have some serious question about, that they had best try and do something about, because time is short. Some of those parameters you can't get in two years worth of lab work, for example. MR. BELL: Well, yeah, and I think that's some of the concerns we have been trying to communicate as well. DR. HORNBERGER: Mike, I have a couple of questions, in fact, of that nature. When I look at the staff concerns list, under TSPA, clearly, from what we heard this morning, and communications, DOE certainly agrees that corrosion, waste package corrosion amongst the other aspects of the engineered barrier are important, and the quality and chemistry of water contacting the waste package. The last two on the list, we don't see a complete overlap with the concerns that DOE has put forward in terms of their prioritization. So I would like to take them one at a time. If we look at the saturated zone flow and transport, what is your view as -- suppose DOE didn't do anything else, suppose Nye County just goes with what they have, does this -- would this indicate to the NRC that the DOE could not provide a credible analysis for a license application? MR. BELL: I am not sure we are prepared to go that far yet. I don't know, Tim, do you want to comment? MR. McCARDIN: Well, certainly, the alluvium in the saturated zone path is, in our view, is an extremely important component of the geologic setting, to know exactly whether that -- in the VA, they sampled all the way from zero alluvium to six kilometers. We think that -- we need to know whether it is zero or some other, you know, fairly substantial length like six kilometers. DR. HORNBERGER: But so the point would, if they didn't do any further analyses and simply then, in TSPA LA, used zero for the alluvium, this would be an acceptable kind of calculation? MR. McCARDIN: Well, -- DR. HORNBERGER: I am trying to gauge the strength of your recommendation to DOE that they -- MR. McCARDIN: The standard is still met. DR. HORNBERGER: Yes, of course. That's -- MR. McCARDIN: Yeah, I assume. Yeah. If they can get by with zero alluvium, it would still meet. We can't force them to. I assume -- DR. HORNBERGER: No, no, I realize that. I am just trying to gauge, you know, where we are on this spectrum. MR. McCARDIN: Right. I mean our analyses to date show it to be a very important part of keeping the doses reasonable, that is where are coming from. DR. HORNBERGER: Well, see, now, this goes back to Marty's question, because my impression is that the DOE TSPA does not show that extreme sensitivity. Now, is this a different conceptual model? MR. McCARDIN: Part of that is due to the fact that their waste package corrosion goes way out in time, the 150,000 year waste package lifetime on average. DR. HORNBERGER: So, alluvium for them becomes important only after the 10,000 year? MR. McCARDIN: Oh, absolutely. Yeah. Yeah. Now, you see the -- if you go out to their peak doses, which are 100 millirem and larger, that is where I think you would have to. We have a more severe case where the containers fail a lot sooner than theirs. DR. HORNBERGER: Okay. So then now, again, there is a concatenation of issues here because John raised a question as to how these NRC staff was going to deal with doses beyond the 10,000 years. So if the doses before 10,000 years don't rely on the alluvium, your suggestion then is that that is okay. DOE may have been right in assuming that this is not an important issue. MR. McCARDIN: Well, there is always the requirement for multiple barriers, and if the reliance is completely on one barrier, there is a problem. DR. STEINDLER: Well, it also -- it is also based on the assumption that the cladding holds as long as DOE. See, the big difference, I think I sense is that they take no credit at all for the cladding, I guess, whereas, DOE uses that cladding extensively. If you take the cladding away, and then take the alluvium away, now I think you have got a real problem. DR. HORNBERGER: Okay. Yeah. At any rate, this is pretty much what I -- DR. GARRICK: Well, I am not even clear of that, because it sounded to me like we are offsetting the effects between the cladding and the dilution -- dissolution rate of DOE and the dissolution rate, no cladding, of NRC. MR. McCARDIN: Yeah, our release rates are comparable on EDS given they do compensate. DR. GARRICK: All right. MR. McCARDIN: But if DOE, using their release rate, got rid of cladding and alluvium, you're right, you know, as our -- if we take those same assumptions, our numbers would go up also. MR. McCONNELL: Part of this is the complication I think that arises when you don't have, if I can use the term, subsystem performance objectives. We don't put in any requirements, specific or quantitative requirements on the performance of any single barrier or any component of a particular barrier. What we do ask, at least in Part 63, the proposal, is that they demonstrate it. Now, they can take conservative assumptions like, you know, zero retardation, or zero alluvium, and in some way demonstrate, you know, multiple barriers. But what I am trying to say is the use of conservative assumptions is one way to get to that point. DR. HORNBERGER: Yes. DR. GARRICK: Yeah, but I think that you are also saying that we have to know what the performance capability is of the barriers. MR. McCONNELL: Yes. DR. GARRICK: And the only thing that is absent now is a specification on that performance. DR. STEINDLER: But I would go back and argue that if you move the alluvium contribution from zero to one, you now have at least a nested barrier, so defense-in-depth can be claimed to include a not very efficient alluvium retardation. DR. HORNBERGER: The -- DR. STEINDLER: If it is just a body count, so to speak, of the various barriers included, you know, whatever the numbers are. MR. McCARDIN: The barriers, I mean to be a barrier, you have to get some performance aspect out of it. Just being physically there is not enough. There would have to be some attenuation of -- DR. STEINDLER: Assigned to it. MR. McCARDIN: Yes. We would -- I mean to be -- it is subjective what actually is a barrier, but just physically there would not be enough. DR. STEINDLER: That's all I had. DR. GARRICK: In other words, it is not a barrier unless it can be demonstrated that it has some impact. MR. McCARDIN: Yes. DR. HORNBERGER: I mean there are some still some points to this that we can have further discussion on, because it is -- as you know, I have some concerns as to what it would mean to demonstrate that the alluvium was a barrier, you know, how much data -- we have rendered all this horrendous problem we always face, and, in particular, in the saturated zone at Yucca Mountain, as how much data are enough. But that is perhaps a time for another -- MR. McCARDIN: One very quick response is that, for the vast majority of radionuclides that are in the repository, it is somewhat anticipated that retardation factors in the alluvium would be quite high. DR. HORNBERGER: Yes. MR. McCARDIN: And so just that in itself, the retardation, if you had a border of at least a few kilometers of alluvium coupled with retardation factors that are actually quite large for most of the radionuclides, that's certainly part of that answer. DR. HORNBERGER: Okay. So the last one on the list now, to me, I'm like the saturated zone flow and transport, some of -- or perhaps the major part of your concern actually stems from TPA 3, and we understand this. Now this committee, as far as I know we have not seen any results from TPA 3 that would have suggested the last item, and so you must have done some work that we haven't heard about. Because it's under total system performance assessment. So what is it about igneous activity now that has set you off? You said there's nothing new, but have you run TPA 3 that now suggests that igneous activity is raised to a higher level? MR. BELL: Well, actually if you have, you know, an extremely good engineered system, you can have a situation where, you know, the base case essentially is zero. DR. HORNBERGER: Sure. MR. BELL: The only releases occur when you have some disruptive event to the base case, and, you know, the analyses, you know, that we've been doing, you know, in fact have situations were the contribution to releases during the first 10,000 years do come from igneous events. When you weight them by the probability, the contribution of the mean dose is low and meets the standard, but it can be the only source of release. DR. HORNBERGER: Okay. So then explain to me again now why this is on the list. MR. BELL: It's on the list basically because, you know, at this stage, you know, even though we can do an analysis based on assumptions that we're making and, you know, data that we've been able to gather that shows the standard is met, DOE is going to have to come in with their own analysis and show that, and, you know, we don't think the analysis they're doing at the current time would really stand up to scrutiny. MR. TRAPP: Can I say something? John Trapp. Along with the fact that right now we don't think the analysis could stand up to any type of scrutiny, there are a couple shall we call it kickers, hookers, et cetera, in the whole process that we're trying to evaluate, and we feel DOE's got to evaluate. One of the big areas where we've got a tremendous amount of uncertainty, and right after we got done issuing our first revision of the IRSR we brought in a series of worldwide experts on volcanism to take a look at what we had done, and one of the concerns that they brought up was they thought our assumptions dealing with repository magma interactions were extremely underestimated. It's an extremely complicated series of calculations, et cetera, and we're planning on doing a little bit of more work. But there is a possibility for instance there that we could be talking about increasing the possible dosage by about an order of magnitude. Would this fail the standard? No. By itself it would not. It would start getting to the point where people are starting to scratch their head and say that it might give you some, you know, concerns, but it still wouldn't fail the standard. Now there's another area that's got to be taken a look at, and it's really a question of making sure the DOE does answer the whole concerns. I'm sure you've heard about things like the Wernicke paper and this type of thing. There's questions that are out there as to what is the right recurrence rate and all this other kind of thing. Now if you're doing an analysis where you're talking about total risk, you've got to address these concerns. If you stay with the probabilities we've got right now, no, we probably are not going to have a problem. Let's jack those up an order of magnitude like Warnicke is suggesting. If you jack that up and you end up with these problems with repository interaction as we think they might go, then all of a sudden you are over. Do I realistically think that this is the right answer? No. I don't think it's the right answer, but I think somebody has got to do enough analysis to make sure it's covered. Now that's where we're coming from. If you take a look at what is in the license application plan, because basically say under the area of igneous activity they're not doing anything. That's oversimplifying, but that's basically what they're saying. Mike has already mentioned that since we've had the license application plan, there has been some workshops, et cetera, and DOE has put together some plans, et cetera, which I think have a very good chance of putting this whole problem to bed. What we need to see is are they implemented. If they're implemented, we should be home free. DR. FAIRHURST: Could I just comment, because I read the papers that came from Bristol, I think, right, and Cambridge. MR. TRAPP: Yes. DR. FAIRHURST: And at least from my reading of it, they made the assumption that the drifts were open. MR. TRAPP: Yes. DR. FAIRHURST: And the likelihood of drifts being open is not time-independent. I didn't see a particular time of reference for that analysis. MR. TRAPP: It basically was assumed in there that yes, they're not backfilled drifts. Now if you take -- DR. FAIRHURST: No, but even if they're not backfilled -- MR. TRAPP: Let me carry that a step farther, though. If you take a look at the effects of volcanism, basically volcanism goes totally backwards from anything -- any of the other processes. You've got to worry about volcanism in the first few thousand years postclosure because of the decay, et cetera, and hazardous flows. After you get past say about 5,000 years, the effects have gone down tremendously. By the time you got down to 10,000 years, it's really a very minor significant contributor. So what you're really looking at in this case is what are the initial effects of which case if the thing is not backfilled, hopefully it's still, you know, standing. Now when you're past, you know, 10,000, 30,000 years, no. DR. FAIRHURST: No. If it's not backfilled and it's subject to seismic -- first of all, if it's a no-heat repository, you're in an extensional environment and the roof is the most potent place for anything to fall out. Right? Got very low confined pressure. Shake that a bit and it'll come down. And so it would progressively migrate out, covering the packages, and the open area would be on top. So if there's any magma coming in, I think it's preferred pathway would be above the packages. If you backfill it, then you don't have a preferred entryway down to the packages. MR. TRAPP: Very true. DR. FAIRHURST: So I'm not sure that analysis is fully realistic. You know, to take an open repository, anything beyond 300, 400 years, down to me is stretching it a bit. MR. TRAPP: One of the things -- DR. FAIRHURST: Heat it up, it gets worse. MR. TRAPP: One of the things that they've done on that analysis, and again it's the back-of-the-envelope-type thing, but they assumed that you had a drift that was totally full. DR. FAIRHURST: Right. MR. TRAPP: Of backfill. With the pressure differential between the magma and the backfill, et cetera, you could basically build up almost enough pressure to blow out that whole drift. DR. FAIRHURST: No. No way. No way. Now you're driving -- you're driving that magma up at approximately the horizontal stress, right? And it's coming up vertically. MR. TRAPP: This is coming up at about 8 megapascals. Yes. DR. FAIRHURST: Yes. Okay. And so it's -- if it's backfilled, how can you generate -- you try to move backfill, you're going to have a big pressure drop in just the frictional resistance of moving it. MR. TRAPP: Then you build up the pressure again. DR. FAIRHURST: Yes, but the pressure -- MR. TRAPP: The point it -- DR. FAIRHURST: Can't get anywhere. MR. TRAPP: The point is I will agree with you that if the place is backfilled that the problem diminishes considerably. We're going with a reference design where it's not backfilled. And no, we aren't talking about the falling et cetera -- DR. FAIRHURST: Backfill does not mean not collapse. MR. TRAPP: No, and agree with you totally. But we don't think the thing is going to totally collapse, et cetera, in a couple thousand years. DR. FAIRHURST: Well, we'll see. [Laughter.] MR. TRAPP: It is a big concern. And if somebody can give us an analysis as to how much it's going to fall in, we can do the analysis then. DR. FAIRHURST: This may be taking it to extremes, and you're hedging a very important point, in that most of the sort of estimations of stability of tunnels are based on engineering designs which somebody will tell you they've seen a thing the Romans built still standing, but that was built in a particular material at a particular depth. And there's no doubt that other material, such as tuff and so on, which are not quite -- have a tiny dependence strength. If you take the situation at Yucca Mountain as it stands, it's -- in an extensional environment is the potential of blocks. If you heat it up, you change that dramatically, because that will probably crush the outer rings. But I think if you try to extrapolate the strength for a period of time, to do it over several hundred years it's quite likely that strength is going to -- now the other thing that's a factor of this is the span. The bigger the span. And you've conducted nuclear tests there where you've taken some of that stuff and pit it, and it has come down immediately over a large span with a nuclear collapse. So you can say that over a period of time there's a very good probability, and most of what we're doing in calculations are based on estimates of that thing must -- and if it falls, it's going to fall from the top down. You build up a bulking affair which will fill those drifts whether you put backfill or not. MR. TRAPP: Right. And then you're starting to talk about what is the actual thermal period that you're dealing, which time are you extension, et cetera, this type of thing. DR. FAIRHURST: No, no. MR. TRAPP: And it depends again on the whole design. DR. FAIRHURST: It's an open tunnel, a level of the -- where the canisters are lying is an extremely pessimistic assumption. MR. TRAPP: Which again is why it's -- I'm talking about the fact that we're dealing with a backwards from every other scenario. DR. FAIRHURST: I think you can probably do some calculations. MR. BELL: Well, you see, Dr. Fairhurst, I think this is a good example of the kind of exchange we're not having with DOE on these kinds of issues, because their analysis, you know, makes assumptions that essentially make the problem go away rather than stepping up to the table with good, you know, engineering and scientific arguments. DR. HORNBERGER: But let me turn it around and focus on NRC rather than DOE. I think that from our standpoint, the ACNW, we would be much more convinced if you came to us not with, gee, this might happen or that might happen or this might be a consequence, but if you actually sat down and did some computations and said, yes, it's -- and it can't just be a compounding of well, Brian Wernicke is going to up the probability by an order of magnitude and these drifts are going to be open and magma is going to come into them and, and, and, and, and looking at a worst case consequence, that doesn't give us any confidence that this is an issue. What we would like to see is, my goodness, you know, when we take into account both the probability and the consequence, this is, from a total system performance case, an important issue, and we haven't seen that. And despite what John just said, I mean, that's -- he's saying -- he's speculating and saying, well, this might happen, we need to put this to rest. I would rather see the NRC -- you have your TPA-3 code -- come forward and come to DOE as well as us and say, look, we did this analysis, we think this is a problem, rather than, you know, being in an arm-waving situation where you say, this might be a consequence, go prove to us that it isn't. MR. McCARDIN: Tim McCardin. We have done the calculation with our code, and I thought what Mike was saying, and John also, that we are not aware of a large dose implication, okay? It meets the standard. Generally, our calculations to data, it's around a millirem when it's probability weighted. The issue isn't so much our calculation. DOE is the licensee. We can't do the license application for them. They need to come in with a calculation, and I think that's why it appears more that --it's not a threat, but if you don't calculate it, then it's -- where do we go from there? DR. GARRICK: Yes, but I think the question we're raising is that the issue kind of got back on the table not because of anything DOE did, but because of evidently something that the NRC did. So you sort of put the bait out there for us to raise the questions in this way. MR. BELL: Well, I would say it's never really been off the table as far as the consequence analysis is concerned. I mean, I think when we last interacted with the committee on this issue, we told you that the -- you know, we thought we could bound the probability question, but the -- DR. GARRICK: You can't bound the probability and vary the consequence. It's logical incompatibility. And that's one of the things that causes us concern. You don't go around bounding the likelihood of an event and then change the event. Every different event has a different probability associated with it, so it makes no sense to do that. I mean, if we start decoupling the probability from the consequence, we can come up with any kind of cataclysmic event that will stop this project immediately. So it's a nonsensical approach. MR. McCARDIN: Yes. There wasn't a suggestion we were doing that. I mean, you're right, different events have to have their probabilities factored in, and that would be done. DR. GARRICK: Yes. MR. McCARDIN: Yes. That's absolutely correct. DR. HORNBERGER: Other questions. DR. WYMER: Or comments. DR. HORNBERGER: Or comments. Thanks very much, Mike. Appreciate it. DR. STAHL: Will you take comments from the floor? DR. GARRICK: We'll take a comment from the floor. DR. STAHL: David Stahl from the M&O. Mike, you talked about a limited data set in regard to alloy 22. That's certainly the case because the alloy has only been in existence for about 20 years. I did mention alloy C where we had that exposure plate. That alloy goes back about 60-some-odd years. And stainless steels, of course, only go back some 80 to 100 years, 90 years. So certainly, we do have to get more data. Now, in our plan, at least for the waste package, we plan to use qualified data for our models, but we will utilize and identify unqualified data that we'll use in a confirmatory fashion. So I wanted to make that point. But I did have a question for you. You talked about welding issues for alloy 22, and I thought that we had resolved many of them or were working on many of them and I wondered what specific welding issues you had in mind. MR. BELL: Jennifer, can you help respond to that? DR. HORNBERGER: Jennifer, I would caution you that this is not a technical exchange. MS. DAVIS: Okay. DR. HORNBERGER: So try to give David the brief answer. MS. DAVIS: Okay. The brief answer is not only some of the welding issues, but some of the shrink-fit issues. And we're concerned with the fabrication in general in relation to juvenile failures, which of course you all are a little more optimistic perhaps than we are. So it's a combination of things and I wouldn't say anything, you know, specific as to the welding except of the heat affected zones for the un-heat treated final weld. We're also concerned not solely for the welds with some of the localized corrosion aspects of C-22, which we really haven't mentioned yet in this session today. DR. HORNBERGER: Okay. Thank you. John, I will turn the meeting back to you. DR. GARRICK: Okay. Well, thanks, Mike. That's the way we like it -- plenty of time to ask questions. I think what we'll do now, since we have a little space in our agenda, we're going to squeeze some letter-writing activity in between now and when we have our next agenda item, which is a discussion from the Nuclear Energy Institute. But before that, I think I would like to declare a break. So let's take a 15-minute break. [Recess.] DR. GARRICK: The meeting should come back to order and we are on the record now, I assume. We are going to now hear from the Nuclear Energy Institute and we are going to hear them talk about high level waste initiatives, and I guess it is going to be done by Marvin Fertel and Steven Kraft. And you are going to just talk to us from there, face to face. MR. FERTEL: Face to face. DR. GARRICK: Where are the viewgraphs? MR. FERTEL: Thank you, Mr. Chairman. Well, we figured by now you had probably seen on the order of 200 viewgraphs and we would be nice and gentle and -- DR. GARRICK: All right. Thank you. MR. KRAFT: We don't want to be confused with federal employees either. MR. FERTEL: No, seriously, we appreciate the opportunity to come before the Advisory Committee again. We expect we will be back again as this whole process moves down the road. I think that from the industry's perspective, we were quite pleased with a couple of occurrences over the last 60 days. First of all, we were pleased that the department got the Viability Assessment out on time, almost as a Christmas present, that, fundamentally, they stood behind the science that was there. They recognized the uncertainties that they still had to deal with. And we thought that it represented a pretty good snapshot of at least what they had done to date, and we were pleased that they were willing to stand up tall and challenge them on a number of places, even though there is still a lot of work that they need to do. We were also pleased that they laid out a lot of plans for going forward and the plan probably of most importance, maybe from the NRC's staff's standpoint, was their licensing application plan. And I guess the way our folks that have looked at it have commented, they thought the plan itself was a pretty good plan. The question was could they implement the plan as written. The plan was decent. In licensing space, the other thing that we are certainly very pleased with was that the Commission moved forward and issued Part 63. And our look at the pre-decisional version of Part 63, and our relatively quick review of the version that just came out last week is we think Part 63 is going down the right road, the right way. And while I am sure we will have some comments, and certainly some questions, we are very pleased with Part 63 being out. Part 63, and, clearly, from what the Commission said in issuing it, they recognize the importance of Part 63 as part of the critical path to moving down the road. And we appreciate that, as do all the contract-holders that are sitting there with waste on their sites and want to see things move. So moving down the road right now is really important from the industry standpoint. I think you realize that we are still in the process of working with the Congress towards legislation which we think is still necessary to move waste off of power plant sites. We see the current situation continuing to jeopardize a number of the plants, continuing to be a problem from the standpoint of the shutdown plants that are trying decommission, and, certainly, continuing to be a real problem from the standpoint of the payments that are being made into the waste fund, and, potentially, the lawsuits. And to be honest, we are concerned that the lawsuits could result in tanking the whole program if we don't see a solution to this, because if the government decides to pay the companies out of the waste fund, we don't see the money available to implement both the repository and any sort of early receipt to the repository site. So we see that as a real threat and a real problem if this country is going to have a safe, ultimate disposal. But on the good news, I think Part 63 makes real good progress, and we will talk a little bit in detail on VA and Part 63 and a couple of other things. As far as the DOE program, I understand that at this meeting there were some questions raised about the quality assurance aspects of it. We are certainly concerned about that. I think last time we came and met with this Advisory Committee one of our major concerns was the lack of licensing experience that the department has. And while I think NRC has worked very closely, the staffs have worked very closely with the DOE staff on technical issues, and that has been really good, on the NRC side we are looking for some closure and finality on things that the staff feels should be closed. On DOE's side, what we are truly looking for is for them to make sure that what they submit is defensible in licensing space, and, obviously, an adequate quality assurance program is a necessity for anything they are going to submit. DR. GARRICK: marvin, we raised that question this morning with DOE and, given that you are an association in behalf of the industry, the comment we made was that one of the bright stars of the nuclear power industry, in my opinion, has been the maturing of the approach to the quality assurance and the whole nuclear safety assessment process that comes under that banner, and that there seems to be a tremendous amount of expertise and maturity there that could be an important resource. And we quizzed them on whether or not they were seeking guidance and help from industry in that regard, since this has already been flagged as one of their -- perhaps maybe their Achilles heel. MR. FERTEL: Well, I think DOE is a relatively large organization with a lot of players, and certain parts are seeking. Not all parts. But independent of their seeking, they are going to be offered, and have been offered, basically, the kind of help you are referring to, John. We have looked and said the same thing. You were polite in saying it is a maturing that has gotten us to know what we are doing. We certainly had our own problems in QA at a number of our plants in the past, and that forced maturing. And I think that right now we actually have capability within the industry that has gone through some -- I think even much tougher QA problems than I understand DOE has. So that that expertise and that skill brought to bear on how they need to look at both solving the problems that they face, but, more importantly, solving the cultural issues that created the problems, are the things that we are looking at trying to bring to bear. And we are not looking to go out and do assessments and point out all the things they have done wrong. What we want to do is go in and tell them how we have worked our way through similar or comparable problems, and bring that expertise to help them. And we have had discussions, literally, as recently as a week ago with Lake and others about this, and we are going to proceed to do that in the near term. So, hopefully, we can bring some of this experience. And, again, I think that there are parts of DOE that are seeking. I think there's other parts that feel that they honestly know how to do it, and they can do it. And if they can convince our people that have gone through it that they have their act together, we would like nothing better than to say you are on the right course, your culture is great, your attitudes are right -- just go ahead and do what you are doing, it is the right thing, if that is the case. If that is not the case, I think we can help them maybe make adjustments that will get them through it. Steve, is there anything you want to add on that? MR. KRAFT: Unless you want to know more specifics about what we are planning on doing, John, I think Marvin's pretty well covered it. DR. GARRICK: Thank you. MR. FERTEL: I think, just to sort of pick up on one of the other areas that we are thinking we could offer DOE some assistance right now, and again I understand it may have been a subject that the NRC Staff at least has asked about, which is kind of design flexibility, we'll clearly help DOE understand in licensing space the necessity to have a relatively firm thing for NRC to review. Obviously you can change it as you get smarter, both in design or in science or in safety analysis space, but you can't have a moving target. In fact, from our experience in the past it has almost been the other way at times when we have gone to the Staff. They kept moving the ball on us so we learned that that is not a good strategy for getting anything licensed. We don't want DOE coming in with 35 different design options. We also think that one area where we should bring some of our experience is for actually not the repository post-closure design but to look at the operational aspects over what is probably a 50-year period of handling spent fuel. DOE certainly has experience in handling spent fuel. That is one of the things we keep telling them. They know how to do and they ought to do it sooner rather than later, so I don't want to imply they don't know how to handle it, but the industry certainly has a lot of experience in handling spent fuel at the plants and moving it around, so I think that is another area where we would be looking to bring both the experience from an operational standpoint and certainly the experience from a safety analysis standpoint of what should you look at and how will you defend it, how will you describe it and deal with it. MR. KRAFT: If I could add to that, the designs that we have seen of the service handling facility seems to be done without recognition that you are operating in a regulated environment. There is insufficient lag storage. There are insufficient pathways out of the maze that they have designed, things like that that we think that if they brought greater regulatory expertise into the process they could learn. One of the questions that I have asked continuously over the last year in my visits out there is when you do a design like that, who is the regulatory person sitting in the design team, the way we used to do it at the power plants, saying wait a minute, you know, you could be faced with some sort of order from the NRC telling you you can't operate greater than "x" percent of your capacity. What are you going to do then? Well, they don't do that yet. That is part of the culture issues that relate also to QA, so that is one of the things we want to help them learn how to do. DR. GARRICK: Yes, and the agency is going through two major culture changes. They are going from a research and development organization to a cleanup organization on the one hand, and to a regulated operating organization on the other hand in the waste field, and there are some real chasms that exist there. MR. KRAFT: We agree. MR. FERTEL: I think a comment on Part 63 and the radiation standard. We appreciate the leadership that the Commission and the Staff took in putting a standard in. We understand the role EPA has to play. Clearly as an industry we believe That the 100 millirem standard as contained in H.R. 45 and previous legislation is probably an adequate standard and we understand what the Chairman said at the hearing the other day about ALARA and what you might strive for, and that is certainly consistent with the way we have always operating in power plant or major fuel facility space, so it is not a surprise. We certainly have a problem understanding the EPA argument. Putting aside the fact you can't license anything within their particular construct -- DR. STEINDLER: Sorry, which EPA argument? MR. FERTEL: Well, that is a good question. The fact that you need a separate groundwater standard from a health and safety standpoint. I thought the Chairman explained it pretty simply, as I thought Congressman Barton did in the recent hearing, where if you have an all pathways standard it consumes the groundwater standard and it would seem like we are trying to protect someone, not just the resource. If it is health and safety, I have never seen any data on the health and safety of the water resource as something we protect. It's usually the person that consumes that water, so if we are trying to protect that person, if the entire comes from groundwater, so be it. That's all pathways. Let's look at it that way. So we appreciate both the leadership the NRC has exhibited here. We also appreciate probably the awkward situation they may find themselves in in interagency discussions but anything that we can do to help we would like to and I would say anything ACNW could do to help, which I think you have been probably, would certainly be appreciated. DR. HORNBERGER: That's it? MR. FERTEL: Yes. DR. HORNBERGER: As you know, we also agree with that. EPA is in a rather dicey situation because they have things called drinking water standards and they have a 4 millirem groundwater standard that water supplies have to meet, and it has been very difficult for them to say oh, but for this particular case we will waive the standard. MR. FERTEL: Things are difficult. I mean it is difficult to project what is going to happen 10,000 years from now when they seem to figure out that that can be done. This is a policy call. It would seem real simple to make the right policy call. DR. HORNBERGER: But that is what it is. It is a policy call. MR. FERTEL: Yes, yes -- so we will see what happens but again I would like to compliment the entire NRC organization for the leadership they have exhibited here. I think John Garrick and I wee talking briefly before we started about how you would move into risk-informed space. We are obviously moving aggressively into that space and Part 50 space and we even are talking about it in Part 70 space right now. It is a little different there because we are talking about being risk-informed about what I apply the regulations to, not necessarily how I make the decision, and I think that one of the real roles that ACNW can play, and certainly we would do anything we could to help, would be to foster the dialogue on how to move forward and be able to make the decision once we have a standard that is the standard we are trying to meet and we are doing, you know, hundreds of scenarios and looking at a whole bunch of different probabilistic outcomes. How do you finally say you know the answer from a licensing standpoint and it is an acceptable outcome? My guess is that in Part 50 space, where I think it is a lot easier to do, personally, because there is a lot more information on stuff, we are still having tremendous amounts of dialogue within our own industry to get everybody on the same level of understanding and we learn things when we talk. We certainly have the same experience and when we deal with counterparts in the NRC I think that everybody is striving to do it right and yet in something where we really think we know it pretty well we are struggling. I think here again some leadership, maybe from this particular advisory committee in a dialogue sense, could be very helpful to getting everybody to use the terms the say way, to understand what the terms mean and when we get down to NRC Staff trying to make a decision everybody understanding how that decision is being made, so I again would encourage -- I don't have any silver bullet for this and John had some good ideas when we were talking and I agree with everything he said. My guess is that if we asked everybody in this room to give their version of how this could be done there would probably be 40 different though similar versions of how you would make the decision in risk space on the licensing of Yucca Mountain, so good dialogue there, early, is probably very helpful. I think conceptually the rule does the right thing and I think conceptually everybody wants to do the right thing. One of the things we will probably look at as we go through Part 63 is whether or not the licensing process that is embedded in it allows for some sort of multi-stage licensing, and at the extreme I think that we are beginning to feel that there's probably real value to being able to license the above-ground facility separate from the repository or earlier than the repository if I don't want to use the word "separate." Also there may be value thinking analogy of like a low power test at a power plant even though you never get a low power license. You really get an operating license and they just hold you at low power, whether or not there would be value of allowing the emplacement for testing purposes of waste in the repository early and again I don't think we have firmed up our thinking on this but I think just to plant the seed with the ACNW as you go through it and maybe the Staff as they revisit some of the thinking there may be value of seeing whether or not there's things that could be done within the licensing phase that you are not waiting till the end before you can do anything either above ground or below ground. DR. GARRICK: Yes. There is a little bit of experience in that with respect to WIPP in that DOE had a strategy of an experimental program that required them to have some real waste and unfortunately it backfired because -- MR. FERTEL: Right. DR. GARRICK: -- on examination of what was going on there it was discovered that the experiments were not going to generate the kind of information that was timely and what information it did generate could be generated above ground just as easy and probably easier. So whatever directions are taken in that regard are really going to have to be very carefully planned out. MR. FERTEL: I think what I would say, John, is having the ability to do it doesn't mean you would exercise it or you could justify exercising it, but if it turned out you should exercise it and then didn't have the ability that is probably undesirable. DR. GARRICK: Right. MR. FERTEL: So making sort of contingency planning for having the ability might be a good way to begin to think about it, particularly for something we are going to monitor and do all kinds of stuff at for literally a few hundred years. I think the other thing that jumped out at us right in the Federal Register Notice on Part 63 was the Commission's moving -- at least raising the question of informal hearings, and I can state unequivocally we think that is probably the only way to go for licensing something like this. We think that in most cases in power plant space informal hearings make more sense than adjudicatory hearings, though some places may be both or either would do well. In this case where you have got probably millions of pages of material and thousands of scientists, and they are true scientists -- they are not engineers or people who are doing policy stuff -- they are guys that if you ask them a specific question on the stand they are going to qualify it 35 different ways if they have to answer that question with a yes or no, you will never get it licensed and you are not going to improve the safety analysis, you are not going to improve the decision-making. You are just going to delay the country from moving forward with doing something with the nuclear waste, so I think I could state that when the Commission goes forward in whatever independent proceeding they do on informal hearings for this, we will certainly try and justify strongly why that makes sense and we believe it makes sense, so just as an insight on that. Continuing, again, the Validity Assessment is good and moving forward with Part 63 is great. We are looking forward to suitability, and I think that one of the things that we ought to be doing within the NRC is figuring out how the NRC is going to implement their activities, particularly related to the Environmental Impact Statement that they are going to prepare, what they are going to use from DOE. And I think last time we were here, one of the points we made, and I think it is still valid, is that the DOE and the NRC staff are going to have to transition soon, when they become a licensee, from the collaborative nature of the work they have been doing, which I think is in the best interest of the nation, because what they are doing is putting the best heads together to try and work on the science, to a licensee-regulator relationship. And that transition may not be as transparent or as smooth as one would like, because, again, you have got a licensee that has never been a licensee, and a you have got a regulator regulating something they have never regulated before. So there is going to be comfort level on both sides to want to work together like they have, and I think they are going to have to begin to think -- I know they are thinking, but I think that, just like we said, the culture required for the DOE QA program is different than maybe what they are used to. I think the culture for the licensing phase of this will require both sides to behave a little bit differently in order to certainly maintain the integrity of the process. I don't think they would do anything wrong if they didn't, but I think that there will be a perception. And to do that right, some of the planning will have to take place, literally, over the next 18 months on what can be used, what can't be used, and ER and EIS space. What suitability means to NRC, and what is going to happen with the license application once it gets submitted. Steve, do you want to add anything on that? MR. KRAFT: The only thing, and a question I have raised with NRC staff before, is what their current plan for how they fit into the suitability determination, which is a -- it is the essence of policy. It is a combination of a technical and a political determination, because the President gets to make the decision in the long run, and there was never an assumption that the President would be a geoscientist when the time came. So you have got this decision coming, it is unreviewable, which means the President gets to make whatever decision he wants. The NRC has a role to play under law, they have to say something about the decision or about the DOE work at the time into that process. They have linked it, I believe, to an existing internal NRC process that may or may not be correct. They may be putting too much into what they have to say in that suitability determination, or they may not be putting enough into it. But from I heard about it, I am concerned that NRC is going to make, I think, too much out of -- too much of a licensing type decision out of the input into the suitability process, and they need to recognize what that suitability process is as a combination of a lot of different things, and, in essence, a policy decision as opposed to a pure technical decision. I think that bears some consideration and some discussion in public as to how that gets done. MR. BELL: Would you like a comment from the staff? MR. KRAFT: Go ahead, Mike. MR. BELL: Well, under the statute, our role is only to comment on the completeness of DOE's site characterization and waste forum development work. And we don't see that as entering into the policy arena. It is basically -- given the information they have at the time of the site recommendation, if they then go forward and six months later submit a license application, which is what the statute calls for, we would not reject that application just because it had insufficient information. I would say that is the role we see ourselves playing at that time. I mean, so that the President doesn't then find himself in the position of going to Congress and Congress, you know, potentially overriding a state objection, it all goes forward and it comes to NRC, and then NRC would say, well, they haven't done enough work. I mean that is what I see our role in that, just to avoid that political debacle. MR. FERTEL: Mike raises in his answer, which sounds find, raises an interesting point. As opposed to other projects that at least I am familiar with, licensing, you know, whether it is a plant, which sometimes has taken way, way too long, but, typically, is not a 50 to 100 year licensing overview type thing, we have a situation here where you are going to file -- if all goes right, you are going to get a license application in 2002, and DOE is going to expect that they are going to get an answer a few years later, and then they are going to build something. And whether we agree they can make 2010 or not is probably not relevant, because it is somewhere out in, you know, the 2010 to 2015 time period if they make the 2002 date. But, fundamentally, you are going to then spend about 30 or 40 years loading it. The whole time you are going to be observing it, and testing, and verifying, confirming stuff, and still under a licensing banner. Then you are going to spend another, you know, 50 to 250 years in some sort of confirmatory role as a nation. I don't mean any of us at this point. It seems like you are not going to have, and no one believes we are going to have 100 percent certainty in 2004 or 2005 when the license is issued, and if you did, you would wonder why you are going to spend billions of dollars after that doing all the things we are going to do to make sure that we were right. And I think one thing that we all need to think about, and I certainly don't have the answer, but the question I think is real, is you don't -- you won't have 100 percent certainty, and we shouldn't pretend we will. But you don't need it, because you're still going to have a lot of time, you're doing things. Now you can't be uncertain about the safety and the adequacy, but you're not going to be 100 percent certain. DR. GARRICK: Of course, they're not 100 percent certain about any application on any licensee they have. MR. FERTEL: That's right. That's right, but none of the applications we have today, John, go out beyond 40 years. So it's a very finite thing, it's a very controlled situation, it's a phenomenon that I understand or at least I can portray pretty well whether it's a powerplant or a fuels facility. This is something that it's very hard to explain to folks. It sounds outrageous that we, you know, have the audacity to think we know what's going to happen in 10,000 years or a million years. So I think that part of the challenge when we take the risk, when you have a dialog on how we do this in risk space, is to recognize that it's not like if you make your decision in 2004 you've got to then sit down and go to church every day and pray you were right because oh, my God, it's going to -- the next day this thing gets operational and the world ends. That's not true. There is at least 50 years of loading. And then there is a couple hundred years of verification. Not that anybody wants to find out they're wrong at that point, but -- DR. GARRICK: That brings up something that's getting a lot of discussion now that I'd be curious if industry has an opinion about, and that's the issue of the operating period or the preclosure period, I should say. We're now hearing different numbers, like possibly a 300-year period for keeping the repository open. MR. FERTEL: We heard -- I think Lake Barrett mentioned 300 years two years ago at our fuel cycle conference down in Savannah or Atlanta. And I can't say that as an industry we've sat down and said that we think 100, 200, 300, or 500 is right. As an individual, when he said that, that made some sense to me only because it seemed to be something that most people could somehow relate to a lot better than 10,000 or a million. And whether or not 300 is more than you need to get, you know, the verifications that you need or less than you need, whether or not we're going to determine that global climate change is such a threat to the human race and the planet that a greater use of nuclear worldwide is important, and as such you really do need to reuse this fuel in some way and you need to have access to it, I don't know, but 300 doesn't sound terrible to me. It makes a helluva lot more sense than saying I'm going to shut it up in 50 years or 100 years and it's going to be okay for the millennium, forever. So my personal reaction is that's not bad. Now if they said 250, I'm not sure I'd quibble that that's a big difference. DR. FAIRHURST: Why do you see such a significant difference then between 100 and 300? MR. KRAFT: I don't think we do. MR. FERTEL: Again, I don't think I do. I don't think I do. MR. KRAFT: I think, though, it's a decision that if you do the repository right in accordance with current-day regulations and then you create a confirmatory testing program after 100 years let our great-grandchildren decide what they want to do. DR. FAIRHURST: Fine. I agree with that. MR. KRAFT: And that's fine. There was a report DOE did, Tom Isaacs and Max Blanchard did a couple years ago, that spoke to this issue, and it was largely ignored for a long time. But it's an excellent piece of philosophical work that talks to this question exactly, that what we owe future generations is the ability to dispose. The material may prove to be extremely valuable, and they would want it back, or they may learn something over the next couple of hundred years about geology that we don't know. They may write the perfect saturated zone flow model that we can't write now. Who knows. So let them make the decisions then. DR. FAIRHURST: Let me give you another perspective. There was a recent international conference on retrievability, and that was the first time the rest of the world found out the U.S. had moved to a suggestion of 300 years. And there wasn't another country in the world that had thought to go beyond 100, and they thought the U.S. was defending the fact that institutional controls would disappear after 100 years, and therefore you didn't have any right to plan beyond 100 years. And their view, which I think is quite a good one, is that they thought that the U.S. was crazy to think that institutional controls would disappear in 100 years. And then they saw what happened to control of nuclear materials in Russia. MR. FERTEL: Well, what control of nuclear materials in Russia? DR. FAIRHURST: Because at that time if you listen to the Swiss and the Swedes and so on they were saying 300 years was reasonably fine to go and the U.S. was being overly pessimistic with 100 years. Now they're not even sure that individual countries that exist today in Europe, such as Germany and France, will remain as Germany and France in 300 years. So they have no idea of how to maintain political institutions for any length of time. Look what's happening in Yugoslavia and so on right now. So they feel -- they are becoming very comfortable with the notion that the U.S. had it right the first time and then found out the U.S. had come and said we're going to change it. MR. FERTEL: I think the issues they're raising go far beyond whether we have it right for disposal of nuclear waste, to be honest with you. DR. FAIRHURST: But what I'm saying is if there are good technical reasons for doing it, yes, but I have not heard the technical reasons for doing it. DR. GARRICK: Do you mean to go from 100 to 300? DR. FAIRHURST: Yes. I mean, there are some significant problems in going to 300 years. DR. GARRICK: I'm not sure industry is really aware of those. DR. FAIRHURST: Well, I mean, you're just keeping those tunnels open. MR. KRAFT: You mean keeping the tunnels open for 300 years. Oh, well, again, again -- DR. FAIRHURST: But these are not trivial, and if -- MR. KRAFT: Dr. Fairhurst, absolutely not. But I think, and in that regard, WIPP has a greater problem, because those tunnels will not remain open any significant amount of time like that, so -- DR. FAIRHURST: WIPP has it right, because you want them to close. MR. KRAFT: It's a different design, I agree completely. But my point is that all the sciences evolve, as will underground tunneling, as everything evolves over that period of time. And so in 100 years our great-grandchildren will be a whole lot smarter and a whole lot richer than we are, and they will decide what to do. MR. FERTEL: We hope. DR. GARRICK: Yes. Give your name, et cetera. MR. HAMDAN: My name is Latif Hamdan. I'm with NRC. And I just want to comment on something that Marvin mentioned about the licensing -- the licensee-regulator relationship between DOE and NRC. And while this transition may be difficult, as you say, I just want to point out that this is not going to be a first, because DOE is a general licensee for like two dozen 11E2 mill tailing sites already, and then so -- will be just maybe not a general license but this is not the first time that it's going to happen. DR. GARRICK: Thank you. MR. FERTEL: John, those were only -- those were the comments that we were planning on making today, but we certainly welcome the opportunity to talk about any of the issues or answer any other questions that you all have. DR. GARRICK: Well, we are certainly interested in what industry thinks are the primary problems that lie ahead to get this licensed, and, you know, we've been talking about them when we've talked about design and QA and the preclosure operating period and what have you. Are there any other issues of that nature that -- MR. FERTEL: Well, I think when we think about licensing right now, you've hit them. What the standard is probably is the key issue, what are we trying to meet as far as the radiation standard, of making sure that the license submittal is adequate requires the QA program to be really put together correctly, making sure the application is complete and deals with, and we think that the preclosure issues really do need to be addressed maybe a little bit more than DOE has been giving thought to them. Understanding how we are going to make the final decision on risk, as far as satisfying the standard, in probabilistic space, we think is a bit of a challenge, even though it is only way to do it for this. I am interested in Charles' comment on the 300 years. I am not sure the U.S. policy has changed to 300 years, to be honest with you. DR. FAIRHURST: No, it hasn't. MR. FERTEL: I think there is a lot of trial balloons that are being sent up to see what people think. DR. FAIRHURST: Yes, fire up the balloons. MR. FERTEL: So, I mean right now, those are the issues, and, again, I appreciate that under UMTRA and other places, DOE is a licensee. We think that maintaining the licensing relationship between DOE and NRC, and particularly the longevity that is going to be required for this, is something that really does require stability and good up-front planning. That is just from our own experience. MR. KRAFT: I think, though, that DOE's transition in OCRWM, and also broadly in DOE as they go to external regulation, the way DOE has functioned internally as their own regulator has been one more of negotiation than it has been of adjudication. That is a very different world, because when your internal regulator and your internal doer have the same agency goal in mind, there is a lot of desire to work it out and get to the same place, meet the requirements on the way. NRC doesn't have that same organizational goal, and I think -- that doesn't make it any easier or harder, it makes it different, and DOE doesn't know how to do that yet, and that is something they have to learn how to do, there is evidence in the conversion of their lab sites to external regulation, where they are having exactly the same cultural issues. And I think that is where are seeing some of the problems. That is where the QA issue is coming from. It all stems from that, from a different way of doing business internally. By the way, I should say, they recognize it. We have spent a lot of time with them. They recognize it. What they are not sure about is how to correct it, and how to put certain processes in place to make sure that internally they are getting it right. DR. GARRICK: Yeah, it is an interesting problem. I still am heavily involved in the nuclear power game, and like to play the game at every nuclear power plant I go to of asking different people, whether they be maintenance, operations, engineering, or technical support, what has been the most difficult adjustment for them to make in working at a nuclear power plant? Especially new people. And almost without exception, the answer that comes back is to be willing to be totally accountable and to be watched in everything you do. You know, even the maintenance actions are watched. And I think that might be the key to the underlying cultural change that would -- that might be the most difficult, especially for technical people, or especially for people that have worked in a security environment for decades. I think that might be the most difficult adjustment to make, is to be willing to share what you are doing, the calculations that you make, the decisions that you make, the reports that you write, in a completely open and accountable manner. My database says if I had to point to one thing that would be -- that would contribute most to DOE making that transition, it would be to develop that kind of state of mind. MR. FERTEL: To be honest, John, I think the effort by the NRC staff and the DOE staff working cooperatively over the last four or five years has probably helped move them down that road better than if they were starting fresh, because I think that there has been a lot of openness, at least at the meetings that I have been able to attend and listen to the discussion. And maybe even the fact that everybody is going to Internet web sites to put everything out is going to sort of foster the same kind of openness, because people put things up and it just becomes second nature to do it, which may help. Because I think you are right, that is a challenge in dealing anywhere in the DOE system. DR. GARRICK: Right. MR. FERTEL: And it is just a very different and almost a closed culture because of the weapons background. DR. GARRICK: You see that in other agencies, too. This has been one of the most difficult transitions for NASA to make, is to be increasingly accountable and open in all of their activities from design and analysis to flight readiness reviews. And, of course, the Rogers Commission study revealed that one of the problems they had was that this openness didn't exist, especially between management and engineering with respect to certain technical issues. So, you know, if we had to -- if industry had to push a few buttons as far as helping DOE is concerned, I think the whole mindset of being willing to share and being willing to let people look at your calculations and peer review everything that you do would be a major start in the right direction. Yes, sir? DR. STEINDLER: I don't want to give you the impression that the Department of Energy walks on water, but let me simply point out that the Department of Energy has run quite successfully a very large number of reactors and sundry other facilities for some 50 years. The general notion that the Department is not regulated and therefore doesn't know how to do this simply misses the point of a Secretary of Energy named Watkins who, coming from the Navy, instituted a regime of activities which probably are about as close to internal regulation as you are likely to get and accountability is in fact in the Department. To an outside semi-independent agency they all happen to be Government employees. That is about where it stops on a practical basis. You know, I don't want to go through this litany of things that the Department doesn't know how to do, and Heaven knows there are a lot of things the Department doesn't know how to do, but I don't think we want to paint a picture of a totally incompetent bunch of folks who are largely scientists who can't give you a straight answer yes or no when questioned on the stand -- which may be true in part, since we are all two-handed scientists, but, you know, I have serious difficulties when somebody says the Department doesn't know how to do QA and therefore industry, that runs reactors and some processing facilities, is the outfit that is going to teach them how to do that. I don't think that is quite the way it is going to work because I think that the Department has a fairly good idea of what the issues are, number one, and the QA issues that are currently plaguing DOE are not the same as those you find in operating reactors. That is not where the issues are. The issues are laboratory and technology development and industry doesn't have a hammer-lock on that. Let me make one other question to the speakers. You indicated that H.R. 45 looks like it has a fairly decent attribute to it, and you liked the 100 millirem -- I guess it is millirem per year figure. You surely are aware that that violates the ICRP regulations for reducing the total dose by some factor, usually three, which gets you down to the 33 or 25 millirem which is where we really are. Why is it that you think 100 millirem is that great? MR. FERTEL: Again, let me take a couple of the comments that you made but let me stop at the one you just asked. What I said, and I think it is consistent with what Chairman Jackson said, is that we think the standard ought to be 100 millirem. We think you ought to strive to go -- and I am not sure I have problem with striving for the 25 millirem that Part 63 has -- but we don't see a reason that you wouldn't have 100 millirem as an acceptable standard at a site where there were no other sources of radiation that you are protecting against and it is a unique standard to the Yucca Mountain site, so again we don't see a problem with that, but I am not saying that I would say that you have got to go to to 100 millirem is the test that you are going to meet. We don't do that at power plants. We go down to as low as reasonably achievable. On the comments on DOE, everybody has their own perspective on DOE and I don't want to talk about the entire DOE. We were talking about OCRWM and I haven't said anything here I haven't said to Lake Barrett, and the QA problems that they have on OCRWM relate to laboratories and USGS and other places, and at power plants you have problems with managing contractors and builders and other guys. QA is not a terribly difficult science but it is a terribly difficult experience to learn. In our industry we have learned the hard way. We have had projects that have spent up to $500 million reconstructing their design basis so that they could get an operating license, okay, because we didn't manage the paperwork right because we had people who didn't think they had to do the paperwork. The construction was fine. This is the issue, one of the issues you have, so the experience the industry has is directly relevant even though it was a power plant versus a repository scientific study, so I think it is totally relevant and I don't think, and I have spent time in the DOE complex, that the QA culture within the DOE complex is anywhere near the QA culture that the industry has developed through hard times learning ourselves, so we can disagree on that but I have no problem in the help that we could try and provide them. As far as the regulation, our comment on regulation relates to the fact that DOE has never been a licensee. That is the term I continue to use. That is a lot different than either what I think John Conway on the Defense Nuclear Facility Safety Board does, which is excellent work -- I think they do a good job. It is a lot different than what ES&H does. I have spent time at the DOE complex. It is very different to be self-regulated. I was there doing things when Admiral Watkins sent his tiger teams out. They did some good, they did some bad. They didn't improve a lot in certain places. They shook up a lot of things. They didn't change a lot of things at times, and so our comments relate to a licensee's role and a regulator's role and the Department outside of some of the mill tailing sites, the Hanford tank farms, and a couple of other places have not played that role. They don't have that experience and when you talk to their people they are good people, they are smart people but it is experience you have to gain as a licensee. Power plant guys that weren't licensees didn't do well until they got people that were experienced. It is the nature of the beast. You have to learn how to play the role that you play in this particular game, which is a regulator-licensee game -- so it is not a damnation of the Department. I think they do a lot of things that are good, but there's areas where from our standpoint they need some help. I mean if this program was running smooth they would be taking our waste last year, so it is hard for us to sit here and say we have got tremendous confidence, everything is great, because right now they are telling us 2010 and we don't believe 2010 is real. We don't believe it. We think they need a lot of help to come close to 2010. DR. GARRICK: I don't know why I have this feeling, but I feel I need to respond to Marty. [Laughter.] DR. STEINDLER: I can't understand why. I didn't really want to carry this on much past a quarter to 5:00. DR. GARRICK: We are not going to carry it very much further, but to recapitulate what I was saying was from an industry perspective that it seems that industry after a lot of trial and error has kind of learned how to do it and that they -- while maybe they have only learned how to do QA in recent years they have been under a regulatory environment for a lot longer period of time and the combination of those two things seem to me to be an important resource for DOE to consider, given that they have never been under a regulatory environment of the type we are talking about here and are about to do so. The other thing is I agree with you because I was part of that process that the laboratories have done some remarkable things and we have had many war stories about things that we have done early in our career that we could never do now. And so the change isn't always better. We could make changes in operations and design that now would, in many cases, not be timely by the time we complied with the DOE orders and all of the regulatory requirements. But I have also served on oversight at national labs and for nuclear power plants, and from that perspective, based on the evidence that I saw from that perspective, it was clear to me that the process of implementing a regulatory activity had matured a great deal in the nuclear power industry. I made the point earlier that for the first time U.S. nuclear power plants are finding themselves in the top 10 of world performers. It used to never happen. It used to always be Swiss plants, Japanese plants and French plants, but no so now. Even the most famous reactor name in this country, namely TMI, is now one of the best performers in the world year-in and year-out. And one of the reasons they are one of the best performers in the world is they have a magnificent, in my opinion, QA program, and nuclear assessment activity. And so all I am suggesting is that, as painful as it has been for them to make their transition, and we all know about the pain that took place there, they have made it. And we ought to take advantage of that as much as possible. MR. KRAFT: One last item. I am not going to talk about QA, that is -- thank you. You asked other problems that stand in the way. DR. GARRICK: Yes. MR. KRAFT: A non-regulatory related problem that affects both agencies is money. We pay in, as an industry, our rate-payers, $600 to $630 million a year. Congress appropriates less than a third. DR. GARRICK: And now you are going to sue them and they are going to pay you back, you are going to pay for the suits with your own money. MR. KRAFT: Well, now, you know, that is an interesting question. The Justice Department attorney -- DR. STEINDLER: That is hardly likely and you know it. MR. KRAFT: The Justice Department attorney who appeared before Congressman Barton the other day said that they were still studying the issue, which I think is Justice Department speak for we are having a hell of a fight internally to figure out how we are going to do this. The Court of Appeals, which directed us back to the Court of Claims, in essence, did open the door and said that there is a possibility that what they may decide to do will in itself be illegal, so, you know, come on back. So these are issues that are not settled. But you are right, if they do end up finally paying damages out of the waste fund, that is another pressure on the waste fund. But my point is that the Congress, because of its internal procedures, has difficulty funding the program at the level the program needs to be funded at this point. And if you look at the total system life cycle cost estimate that accompanies the Viability Assessment, forget H.R. 45, the current program cannot be funded on the current funding profile. The amount of money needed to hit 2010 using the current funding profiles that they are assuming in the future of the current Presidential budget is not sufficient to run this program, to meet 2010. So you have got four threats on 2010. You have got money, you have got their licensing ability, their internal QA program and an EPA standard. Those are the four threats to us that make 2010 a questionable date. MR. FERTEL: In probabilistic space, it is a low probability, 2010 date, in our minds, because of those four reasons. DR. GARRICK: Yes. Any other comments or questions? Charles? Ray? George? Marty? DR. STEINDLER: It is two minutes to 5:00. DR. GARRICK: Staff? [No response.] DR. GARRICK: We appreciate your coming by and talking to us. MR. FERTEL: Thank you. MR. KRAFT: Thank you. DR. GARRICK: We like to hear from you. All right. We can go off the record now. [Whereupon, at 4:59 p.m., the meeting was concluded.]
Page Last Reviewed/Updated Friday, September 29, 2017
Page Last Reviewed/Updated Friday, September 29, 2017