nrc yucca mountain report

8/10/2019 NRC Yucca Mountain Report

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Safety Evaluation Report

Related to Disposal ofHigh-Level RadioactiveWastes in a GeologicRepository at Yucca

Mountain, Nevada

Volume 4:Administrative and Programmatic

Requirements

NUREG-1949, Vol. 4


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NRC Reference Material

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Safety Evaluation ReportRelated to Disposal of

High-Level RadioactiveWastes in a GeologicRepository at YuccaMountain, Nevada

Volume 4:Administrative and ProgrammaticRequirements

Manuscript Completed: December 2014Date Published: December 2014

NU


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NOTE TO READER: In June 2008, the U.S. Department of Energy (DOE) submittapplication seeking authorization to construct a geologic repository at Yucca Moun

docketing the DOE license application, the U.S. Nuclear Regulatory Commission (Nbegan documenting its review in a Safety Evaluation Report (SER). In March 2010a motion to withdraw its application before the Atomic Safety and Licensing Board. September 30, 2010, DOEs Office of Civilian Radioactive Waste Management ceaoperations and assigned its Yucca Mountain-related responsibilities to other officesThe Atomic Safety and Licensing Board denied DOEs motion to withdraw, and inSeptember 2011, the Commission announced it was evenly divided on whether to ouphold this decision. The Commission directed the Atomic Safety and Licensing Brecognition of budgetary limitations, to complete all necessary and appropriate case

management activities, and the Atomic Safety and Licensing Board suspended theon September 30, 2011.

In August 2013, the U.S. Court of Appeals for the District of Columbia Circuit issuedgranting a writ of mandamusand directing the NRC to resume the licensing proceslicense application. In November 2013, the Commission directed the NRC staff to issue the SER associated with the NRC staffs review of the license application. Belapse in time and changes within DOE between license application submittal and th

of this SER volume, some information in the application does not reflect current circ(e.g., organizational structure). In addition, scientific information continues to be puareas relevant to the topics considered in the license application. When these situarelevant to the NRC staffs evaluation of the license application in this volume, the Sidentifies and addresses them, as appropriate.

The SER details the NRC staffs review of DOEs license application and supportininformation, consistent with the NRCs regulations and the Yucca Mountain Review(YMRP) (NRC, 2003aa), as supplemented by the Division of High-Level Waste Re

Safety Director's Policy and Procedure Letter 14: Application of YMRP for Review Revised Part 63 (NRC, 2009ab).

This volume is one of five volumes that comprise the SER. Each volume is to be pseparately as it is completed; however, the volume number may not be published in(e.g., Volume 3 was published before Volume 2). The SER volume number and sewithin a volume are based on the YMRP. Use of SER section numbers that corresYMRP section numbers facilitated the NRC staffs writing of the SER and allows the

find the applicable review methods and acceptance criteria within the YMRP. The table provides the topics and SER sections for each volume.


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ChapterSER

Section Title

Volume 1 General Information1 1.1 General Description2 1.2 Proposed Schedules for Construction, Receipt, and Emp

of Waste3 1.3 Physical Protection Plan

4 1.4 Material Control and Accounting Program5 1.5 Description of Site Characterization Work

Volume 2 Repository Safety Before Permanent Closure

1 2.1.1.1 Site Description as it Pertains to Preclosure Safety Analy2 2.1.1.2 Description of Structures, Systems, Components, Equipm

Operational Process Activities3 2.1.1.3 Identification of Hazards and Initiating Events

4 2.1.1.4 Identification of Event Sequences

5 2.1.1.5 Consequence Analyses

6 2.1.1.6 Identification of Structures, Systems, and Components ImSafety; and Measures to Ensure Availability of the Safety

7 2.1.1.7 Design of Structures, Systems, and Components Importa

and Safety Controls8 2.1.1.8 Meeting the 10 CFR Part 20 As Low As Is Reasonably

Achievable Requirements for Normal Operations and CaEvent Sequences

9 2.1.2 Plans for Retrieval and Alternate Storage of Radioactive

10 2.1.3 Plans for Permanent Closure and Decontamination, orDecontamination and Dismantlement of Surface Facilitie

Volume 3 Repository Safety After Permanent Closure

1 2.2.1.1 System Description and Demonstration of Multiple Barrie2 2.2.1.2.1 Scenario Analysis

3 2.2.1.2.2 Identification of Events with Probabilities Greater Than 1

4 2.2.1.3.1 Degradation of Engineered Barriers

5 2.2.1.3.2 Mechanical Disruption of Engineered Barriers

6 2.2.1.3.3 Quantity and Chemistry of Water Contacting EngineeredWaste Forms

7 2.2.1.3.4 Radionuclide Release Rates and Solubility Limits

8 2.2.1.3.5 Climate and Infiltration9 2.2.1.3.6 Unsaturated Zone Flow

10 2.2.1.3.7 Radionuclide Transport in the Unsaturated Zone11 2.2.1.3.8 Flow Paths in the Saturated Zone

12 2.2.1.3.9 Radionuclide Transport in the Saturated Zone

13 2.2.1.3.10 Igneous Disruption of Waste Packages14 2 2 1 3 12 Concentration of Radionuclides in Ground Water


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ChapterSERSection Title

Volume 3 Repository Safety After Permanent Closure20 2.5.4 Expert ElicitationVolume 4 Administrative and Programmatic Requirements

1 2.3 Research and Development Program to Resolve Safety 2 2.4 Performance Confirmation Program

3 2.5.1 Quality Assurance Program

4 2.5.2 Records, Reports, Tests, and Inspections5 2.5.3.1 Training and Certification of Personnel

6 2.5.3.2 U.S. Department of Energy Organizational Structure as iConstruction and Operation of Geologic Repository Oper

7 2.5.3.3 Personnel Qualifications and Training Requirements

8 2.5.5 Plans for Startup Activities and Testing

9 2.5.6 Plans for Conduct of Normal Activities, Including MaintenSurveillance, and Periodic Testing

10 2.5.7 Emergency Planning

11 2.5.8 Controls to Restrict Access and Regulate Land Uses

12 2.5.9 Uses of Geologic Repository Operations Area for Purpos

Than Disposal of Radioactive WastesVolume 5 Proposed Conditions on the Construction Authorization and Prob

Subjects License Specifications

1 2.5.10.1 Proposed Conditions on the Construction Authorization

2 2.5.10.2 Probable Subjects of License Specifications

References

NRC. 2009ab. Division of High-Level Waste Repository Safety Director's Policy aProcedure Letter 14: Application of YMRP for Review Under Revised Part 63. PuMarch 13, 2009. ML090850014. Washington, DC: NRC.

NRC. 2003aa. NUREG1804, Yucca Mountain Review PlanFinal Report. RevML032030389. Washington, DC: NRC.


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ABSTRACT

Volume 4, Administrative and Programmatic Requirements, of this Safety Evaluatio(SER) documents the U.S. Nuclear Regulatory Commission (NRC) staffs review anevaluation of the U.S. Department of Energys (DOE) Safety Analysis Report (SARits June 3, 2008, license application, as updated on February 19, 2009. Specificallystaff reviewed SAR Chapter 3, Research and Development Program to Resolve SaQuestions; Chapter 4, Performance Confirmation Program; and Chapter 5, ManageSystems (except for SAR Section 5.4, Expert Elicitation, which is evaluated in SERRepository Safety After Permanent Closure, Chapter 20). In its application, DOE sauthorization from the Commission to construct a repository at Yucca Mountain. T

also reviewed information DOE provided in response to the NRC staffs requests foinformation and other information that DOE provided related to the SAR. In particuVolume 4 documents the results of the NRC staffs evaluation to determine whetheresearch and development program, performance confirmation program, and otherprogrammatic and administrative controls, systems, and programs meet applicablerequirements. Based on its review, the NRC staff finds, with reasonable assuranceas noted below, DOE has addressed applicable requirements including 10 CFR 63of Application; 10 CFR 63.121, Land Ownership and Control; 10 CFR Part 63, Su

Records, Reports, Tests, and Inspections; 10 CFR Part 63, Subpart F, PerformaConfirmation Program; 10 CFR Part 63, Subpart G, Quality Assurance; 10 CFR PSubpart H, Training and Certification of Personnel; and 10 CFR Part 63, Subpart Emergency Planning Criteria.

The NRC staff is proposing one condition of construction authorization in this SER Vrelated to the description of programs designed to resolve safety questions. Pursu10 CFR 63.32(b)(4), in the event that DOE identifies any safety questions that wouresearch and development programs in the future, the results of those programs m

appropriately reported to the NRC.

The NRC staff finds that DOE has not met the requirements 10 CFR 63.121(a) and10 CFR 63.121(d)(1) regarding ownership of land and water rights, respectively.


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CONTENTS

Section

NOTE TO READER .................................................................................................ABSTRACT ..............................................................................................................EXECUTIVE SUMMARY .........................................................................................

ACRONYMS AND ABBREVIATIONS ......................................................................INTRODUCTION .....................................................................................................

CHAPTER 1 .............................................................................................................

2.3 Research and Development Program to Resolve Safety Questions ..2.3.1 Introduction ...........................................................................2.3.2 Regulatory Requirements ......................................................2.3.3 Technical Evaluation .............................................................

2.3.3.1 Identification and Description of Safety Quest2.3.3.2 Research and Development Programs Relate

Safety Questions ............................................2.3.4 Evaluation Findings ...............................................................

2.3.5 References ............................................................................

CHAPTER 2 .............................................................................................................2.4 Performance Confirmation Program ..................................................

2.4.1 Introduction ...........................................................................2.4.2 Regulatory Requirements ......................................................2.4.3 Technical Evaluation .............................................................

2.4.3.1 General Requirements for Performance Confi2.4.3.1.1 General Description of the Performance

Confirmation Program ....................................2.4.3.1.2 Performance Confirmation Activities ...............2.4.3.1.2.1 Precipitation Monitoring ..................................2.4.3.1.2.2 Subsurface Water and Rock Testing ..............2.4.3.1.2.3 Unsaturated Zone Testing ..............................2.4.3.1.2.4 Saturated Zone Monitoring .............................2.4.3.1.2.5 Saturated Zone Fault Hydrology Testing ........2.4.3.1.2.6 Saturated Zone Alluvium Testing ....................

2.4.3.1.3 Summary of the NRC Staff Evaluation on GenRequirements for Performance Confirmation ..2.4.3.2 Confirmation of Geotechnical and

Design Parameters .........................................2.4.3.2.1 Program for Measuring, Testing, and

Geologic Mapping ..........................................2 4 3 2 1 1 Seepage Monitoring


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CONTENTS (continued)

Section

2.4.3.2.2 Surveillance Program to Evaluate SubsurfaceConditions Against Design Assumptions ........

2.4.3.2.3 Thermally Accelerated Drift Thermal-MechaniMonitoring ......................................................

2.4.3.2.4 Summary of the NRC Staff Evaluation on Conof Geotechnical and Design Parameters ........

2.4.3.3 Design Testing ...............................................

2.4.3.4 Monitoring and Testing Waste Packages .......2.4.3.4.1 Program for Monitoring and Testing the

Condition of Waste Packages ........................2.4.3.4.1.1 Dust Buildup Monitoring .................................2.4.3.4.1.2 Waste Package Monitoring .............................2.4.3.4.1.3 Corrosion Testing ...........................................2.4.3.4.1.4 Corrosion Testing of Thermally Accelerated

Drift Samples ..................................................

2.4.3.4.2 Waste Form Testing .......................................2.4.3.4.3 Summary of the NRC Staff Evaluation of Monand Testing Waste Packages .........................

2.4.4 Evaluation Findings ...............................................................2.4.5 References ............................................................................

CHAPTER 3 .............................................................................................................2.5.1 Quality Assurance Program ...................................................

2.5.1.1 Introduction ....................................................

2.5.1.2 Regulatory Requirements ...............................2.5.1.3 Review Process .............................................2.5.1.4 Technical Review ...........................................2.5.1.4.1 Summary of DOEs QA Program in the

License Application ........................................2.5.1.4.2 NRC Staff Evaluation of DOEs QA Program ..2.5.1.4.2.1 QA Organization .............................................2.5.1.4.2.2 QA Program ...................................................

2.5.1.4.2.3 Design Control ...............................................2.5.1.4.2.4 Procurement Document Control .....................2.5.1.4.2.5 Instructions, Procedures, and Drawings .........2.5.1.4.2.6 Document Control ..........................................2.5.1.4.2.7 Control of Purchased Material, Equipment,

and Services ..................................................2 5 1 4 2 8 Identification and Control of Material Parts


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Section

2.5.1.4.2.16 Corrective Action ............................................2.5.1.4.2.17 QA Records ....................................................2.5.1.4.2.18 Audits .............................................................2.5.1.5 Evaluation Findings ........................................2.5.1.6 References .....................................................

CHAPTER 4 .............................................................................................................

2.5.2 Records, Reports, Tests, and Inspections .............................2.5.2.1 Introduction ....................................................2.5.2.2 Regulatory Requirements ...............................2.5.2.3 Technical Evaluation ......................................2.5.2.4 Evaluation Findings ........................................2.5.2.5 References .....................................................

CHAPTER 5 .............................................................................................................

2.5.3.1 U.S. Department of Energy Organizational Stras it Pertains to Construction and Operation oGeologic Repository Operations Area ............

2.5.3.1.1 Introduction ....................................................2.5.3.1.2 Regulatory Requirements ...............................2.5.3.1.3 Technical Evaluation ......................................2.5.3.1.4 Evaluation Findings ........................................2.5.3.1.5 References .....................................................

CHAPTER 6 .............................................................................................................2.5.3.2 Key Positions Assigned Responsibility for Saf

Operations of Geologic Repository Operations2.5.3.2.1 Introduction ....................................................2.5.3.2.2 Regulatory Requirements ...............................2.5.3.2.3 Technical Evaluation ......................................2.5.3.2.4 Evaluation Findings ........................................2.5.3.2.5 References .....................................................

CHAPTER 7 .............................................................................................................2.5.3.3 Personnel Qualifications and Training Require2.5.3.3.1 Introduction ....................................................2.5.3.3.2 Regulatory Requirements ...............................2.5.3.3.3 Technical Evaluation ......................................2 5 3 3 3 1 Standards for Selection Training Qualificatio


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Section

2.5.3.3.3.4 Operation of Equipment and Controls IdentifieITS is Limited to Trained and Certified Personis Under the Direct Visual Supervision of an InWith Training and Certification in Their Opera

2.5.3.3.3.5 Operator and Supervisor Requalification Progfor SSCs ITS .................................................

2.5.3.3.3.6 Physical Condition and the General Health of

Personnel Certified for the Operation of Equipand Controls ITS ............................................

2.5.3.3.3.7 Methods for Selecting, Training, and QualifyinSecurity Guards .............................................

2.5.3.3.3.8 Methods Used to Evaluate OperatorTesting Procedures ........................................

2.5.3.3.3.9 Qualifications of Personnel .............................2.5.3.3.4 Evaluation Findings ........................................

2.5.3.3.5 References .....................................................

CHAPTER 8 .............................................................................................................2.5.5 Plans for Startup Activities and Testing .................................

2.5.5.1 Introduction ....................................................2.5.5.2 Regulatory Requirements ...............................2.5.5.3 Technical Evaluation ......................................2.5.5.4 Evaluation Findings ........................................2.5.5.5 References .....................................................

CHAPTER 9 .............................................................................................................2.5.6 Plans for Conduct of Normal Activities, Including Maintenanc

Surveillance, and Periodic Testing........................................2.5.6.1 Introduction ....................................................2.5.6.2 Regulatory Requirements ...............................2.5.6.3 Technical Evaluation ......................................2.5.6.4 Evaluation Findings ........................................

2.5.6.5 References .....................................................

CHAPTER 10 ...........................................................................................................2.5.7 Emergency Planning .............................................................

2.5.7.1 Introduction ....................................................2.5.7.2 Regulatory Requirements ...............................2 5 7 3 Technical Evaluation


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Section

2.5.7.3.9 Information To Be Communicated ..................2.5.7.3.10 Training ..........................................................2.5.7.3.11 Safe Condition ................................................2.5.7.3.12 Exercises .......................................................2.5.7.3.13 Hazardous Chemicals (Materials) ...................2.5.7.3.14 Comments on the Plan ...................................2.5.7.3.15 Offsite Assistance...........................................

2.5.7.3.16 Arrangements Made for Providing Informationto the Public ...................................................

2.5.7.4 Evaluation Findings ........................................2.5.7.5 References .....................................................

CHAPTER 11 ...........................................................................................................2.5.8 Controls to Restrict Access and Regulate Land Uses ............

2.5.8.1 Introduction ....................................................

2.5.8.2 Regulatory Requirements ...............................2.5.8.3 Technical Evaluation ......................................2.5.8.3.1 Ownership of Land .........................................2.5.8.3.2 Additional Controls for Permanent Closure .....2.5.8.3.3 Additional Controls Through Permanent Closu2.5.8.3.4 Water Rights ..................................................2.5.8.3.5 Conceptual Design of Monuments ..................2.5.8.4 Evaluation Findings ........................................2.5.8.5 References .....................................................

CHAPTER 12 ...........................................................................................................2.5.9 Uses of Geologic Repository Operations Area for Purposes

Other Than Disposal of Radioactive Wastes .........................2.5.9.1 Introduction ....................................................2.5.9.2 Regulatory Requirements ...............................2.5.9.3 Technical Evaluation ......................................2.5.9.3.1 Proposed Uses for Purposes Other Than Was

Disposal and Effects on Performance............2.5.9.3.2 Procedures for Proposed Activities Other ThaWaste Disposal ..............................................

2.5.9.4 Evaluation Findings ........................................2.5.9.5 References .....................................................

CHAPTER 13


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EXECUTIVE SUMMARY

Background

Volume 4, Administrative and Programmatic Requirements, of this Safety Evaluatio(SER) documents the U.S. Nuclear Regulatory Commission (NRC) staffs review anevaluation of the U.S. Department of Energys (DOE) Safety Analysis Report (SARits June 3, 2008, license application (LA), as updated on February 19, 2009. SpecNRC staff reviewed SAR Chapter 3: Research and Development Program to ResoQuestions; Chapter 4: Performance Confirmation Program; and Chapter 5: ManagSystems (except for SAR Section 5.4, Expert Elicitation, which is evaluated in SERRepository Safety After Permanent Closure, Chapter 20). In its application, DOE sauthorization from the Commission to construct a repository at Yucca Mountain. Talso reviewed information DOE provided in response to the NRC staffs requests foinformation and other information that DOE provided related to the SAR. In particuVolume 4 documents the results of the NRC staffs evaluation to determine whetheresearch and development program, performance confirmation program, and otherprogrammatic and administrative controls, systems, and programs will ensure that tmeets applicable regulatory requirements.

Research and Development Program to Resolve Safety Questions

DOE is required by 10 CFR 63.21(c)(16) to identify those structures, systems, and (SSCs) of the geologic repository, both surface and subsurface, that require researdevelopment to confirm the adequacy of the design. For SSCs important to safety engineered and natural barriers important to waste isolation, DOE is required to prodetailed description of the programs designed to resolve safety questions, including

indicating when these questions would be resolved.

The NRC staff has reviewed the SAR and other information submitted in support ofapplication and finds, with reasonable assurance, that DOE provided an adequate of research and development programs that would resolve safety questions that reresearch and development, should such issues be identified; and therefore, has ad10 CFR 63.21(c)(16). Neither DOE in its SAR nor the NRC staff in its review of theidentified any safety questions that require research and development required in10 CFR 63.21(c)(16). The NRC staff identified a proposed condition of construction

authorization that would require DOE, if it identifies safety questions that result in redevelopment programs being conducted, to report the results of those programs to accordance with 10 CFR 63.32(b)(4).

Performance Confirmation Program


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objectives specified at 10 CFR 63.113(b) and 10 CFR 63.113(c). In addition, DOEthe preclosure performance objectives (i) for the design of the geologic repository oarea such that it would permit implementation of a performance confirmation progra[10 CFR 63.111(d)] and (ii) to retain the ability to retrieve waste until Commission rePerformance Confirmation Program [10 CFR 63.111(e)].

The NRC staff has reviewed the SAR and other information submitted in support oflicense application and finds, with reasonable assurance, that the description requi10 CFR 63.21(c)(17) meets the requirements of 10 CFR Part 63, Subpart F.

Quality Assurance Program

DOE is required by 10 CFR 63.21(c)(20) to describe the quality assurance (QA) proapplied to the SSCs important to safety and to the engineered and natural barriers waste isolation. The description must include a discussion of how the applicable reof 10 CFR 63.142 will be satisfied. DOEs QA program is described in the Quality ARequirements and Description (QARD) (DOE, 2009gt), which DOE incorporated inby reference. DOE described that applicable requirements will be satisfied primarilthrough commitments to Quality Assurance Requirements for Nuclear Plants, NQA(American Society of Mechanical Engineers, 1983aa), and other documents whosestates, the NRC staff finds to be acceptable.

The NRC staff has reviewed the SAR and other information submitted in support ofapplication and finds, with reasonable assurance, that DOEs QA program descript10 CFR 63.21(c)(20) and the applicable 10 CFR Subpart G quality assurance requ

Records, Reports, Tests, and Inspections

DOE is required by 10 CFR 63.21(c)(23) to describe the program to be used to marecords described in 10 CFR 63.71 and 10 CFR 63.72. DOE provided program defor reporting deficiencies to the NRC (10 CFR 63.73), performing tests for the NRCthe NRC to perform tests (10 CFR 63.74), and allowing the NRC to inspect the GeoRepository Operations Area (GROA) and adjacent areas to which DOE has rights o(10 CFR 63.75). DOE described the recordkeeping and reporting programs for rechandling, and disposition of radioactive waste to provide a complete history of the mthe waste from the shipper through all phases of storage and disposal. DOE descr

program to maintain records of construction of the geologic repository operations amanner that ensures their usability for future generations.

The NRC staff has reviewed the SAR and other information submitted in support oflicense application and finds, with reasonable assurance, that the requirements in10 CFR 63.21(c)(23) to provide a description of the program to be used to maintaindescribed in 10 CFR 63 71 and 63 72 and 10 CFR 63 73 10 CFR 63 74 and CFR


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DOE Organizational Structure as it Pertains to Construction and OperaGeologic Repository Operations Area

DOE is required by 10 CFR 63.21(c)(22)(i) to provide information concerning the orstructure pertaining to construction and operation of the GROA and a description ofdelegations of authority and assignments of responsibilities. DOE provided a descorganizational structure for the construction and operations for the GROA, includingdescription of any delegations of responsibilities.

The NRC staff has reviewed the SAR and other information submitted in support oflicense application and finds, with reasonable assurance, that the requirements in

10 CFR 63.21(c)(22)(i) are satisfied.

Key Positions Assigned Responsibility for Safety and Operations of GeRepository Operations Area

DOE is required by 10 CFR 63.21(c)(22)(ii) to provide information concerning the idof key positions that are assigned responsibility for safety at, and operation of, the described key positions, their responsibilities, and qualifications, and identified qua

alternates to act in the absence of DOE staff assigned to the key positions.

The NRC staff has reviewed the SAR and other information submitted in support oflicense application and finds, with reasonable assurance, that the requirement in10 CFR 63.21(c)(22)(ii) is satisfied.

Personnel Qualifications and Training Requirements

DOE is required by 10 CFR 63.21(c)(22)(iii) to provide information concerning the pqualifications and training requirements concerning activities at the GROA. DOEs qualifications and training requirements must address the general requirements, thecertification program, and the physical requirements required by 10 CFR Part 63, STraining and Certification of Personnel. DOE described the management of the trafunction, identification of functional areas requiring training, objectives for training, otraining guides, and evaluation of trainee learning. DOE described on-the-job trainpersonnel qualification and certification, performance evaluations, physical conditiooperational personnel, and QA audits to determine training program effectiveness.

described that operation of systems and components that are important to safety wperformed only by trained and certified personnel or by personnel under the direct sof an individual with training and certification in such operation and that supervisorywill also be certified in the operations they supervise. DOE described that it would program for training, proficiency testing, certification, and requalification of operatinsupervisory personnel, and a program for evaluating the physical condition and gen


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Plans for Startup Activities and Testing

DOE is required by 10 CFR 63.21(c)(22)(iv) to provide the plans for startup activitietesting at the GROA. DOE described the compatibility of testing programs with appregulatory guidance and the use of experience from similar activities. DOE describprocedure development, approval by authorized personnel, and evaluation of test rformat, and content of test procedures. DOE described component testing, systemtesting, cold integrated systems testing, and operational readiness review. DOE altesting for protection of workers and the public, initial startup operations testing, thefor startup activities and testing, and evaluating functional adequacy of new or unte

The NRC staff has reviewed the SAR and other information submitted in support oflicense application and finds, with reasonable assurance, that the requirement in10 CFR 63.21(c)(22)(iv) is satisfied.

Plans for Conduct of Normal Activities, including Maintenance, SurveilPeriodic Testing

DOE is required by 10 CFR 63.21(c)(22)(v) to provide information concerning plans

of normal activities, including maintenance, surveillance, and periodic testing of SSGROA. DOE described its plan and procedure development, testing, and approvalauthorized personnel. DOE described its management systems for operation of thincluding administrative and procedural safety controls; and the specific types of plaprocedures to be developed for normal operations, maintenance, and periodic survtesting. DOE also described experience from other DOE facilities as guidance for plans and procedures for conduct of normal activities.

The NRC staff has reviewed the SAR and other information submitted in support of

license application and finds, with reasonable assurance, that the requirements in10 CFR 63.21(c)(22)(v) are satisfied.

Emergency Planning

DOE is required by 10 CFR 63.21(c)(21) to provide a description of the plan for resand recovering from, radiological emergencies that may occur any time before permclosure and decontamination or decontamination and dismantlement of surface fac

required by 10 CFR 63.161. DOE provided a description of its emergency plan for to, and recovering from, radiological emergencies that may occur any time before pclosure and decontamination or decontamination and dismantlement of surface fac

The NRC staff has reviewed the SAR and other information submitted in support ofapplication and finds, with reasonable assurance, that the requirements in 10 CFR

d 10 CFR 63 161 ti fi d


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Controls to Restrict Access and Regulate Land Uses

DOE is required by 10 CFR 63.21(c)(24) to describe the controls to restrict access regulate land uses at the Yucca Mountain site and adjacent areas, including a concdesign of monuments that would be used to identify the site after permanent closuraccordance with the requirements in 10 CFR 63.121. DOE described the (i) ownerland where the GROA is located and the land being free and clear of significant en[10 CFR 63.121(a)(1) and (2)], (ii) additional controls for permanent closure [10 CF(iii) additional controls through permanent closure [10 CFR 63.121(c)], and (iv) wate[10 CFR 63.121(d)(1) and (2)].

The NRC staff has reviewed the SAR and other information submitted in support oflicense application and finds, with reasonable assurance, that: (i) the requirements10 CFR 63.121(a)(1) and 10 CFR 63.121(a)(2) regarding ownership of the land whGROA is located are not met, because the lands where the GROA would be locatebeen acquired by DOE, are not under the control and jurisdiction of DOE, and are nsignificant encumbrances; (ii) the requirements related to a description of controls fclosure in 10 CFR 63.21(c)(24), 10 CFR 63.121(b), and 10 CFR 63.121(d)(2) are sbecause DOE has provided an adequate description of the type of controls it wouldprevent adverse human actions that could significantly reduce the geologic repositoachieve isolation during the postclosure period; (iii) the requirements at 10 CFR 63and 10 CFR 63.121(c) regarding a description of additional controls through permaclosure are satisfied, because DOE has provided an adequate description of the prrestrictions and controls it would establish outside the GROA to ensure the require10 CFR 63.111(a) and (b) are met; (iv) the requirement at 10 CFR 63.121(d)(1) regrights is not met, because DOE has not obtained such water rights that DOE determbe needed to accomplish the purpose of the GROA; and (v) the requirement at10 CFR 63.21(c)(24) regarding a description of monuments is satisfied because DO

acceptably described its conceptual design of monuments that would be used to idafter permanent closure.

Uses of the Geologic Repository Operations Area for Purposes other thDisposal of Radioactive Wastes

DOE is required, by 10 CFR 63.21(c)(22)(vii), to include information concerning plauses of the GROA for purposes other than radioactive waste disposal, with an anal

effects, if any, that such uses may have on the operation of the SSCs important to the engineered and natural barriers important to waste isolation. DOE described puses of the GROA and analyzed the effects that such uses may have on the operatSSCs important to safety and on the engineered and natural barriers important to wisolation. DOE described its procedures to manage the two ongoing other uses of (protection of cultural resources and protection of flora and fauna).


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References

American Society of Mechanical Engineers. 1983aa. ANSI/ASME NQA11983, Assurance Program Requirements for Nuclear Facilities. New York City, New YorAmerican Society of Mechanical Engineers.

DOE. 2009gt. DOE/RW0333P, Quality Assurance Requirements and Descriptio(QARD). Rev. 21. ML090230236. Las Vegas, Nevada: DOE, Office of Civilian RWaste Management.


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ACRONYMS AND ABBREVIATIONS

ANSI/ASME American National Standards Institute/American Society ofMechanical Engineers

DOE U.S. Department of Energy

EALs emergency action levels

EBS engineered barrier system

ECRB Enhanced Characterization of the Repository Block Cross-D

EP emergency planESF Exploratory Studies Facility

GROA geologic repository operations area

HLW high-level radioactive waste

HLWRS High-Level Waste Repository Safety

ISG interim staff guidance

ITS important to safety

MCO multicanister overpacks

MOX mixed oxide

NRC U.S. Nuclear Regulatory Commission

NWTRB Nuclear Waste Technical Review Board

OCRWM Office of Civilian Radioactive Waste Management

PCSA preclosure safety analysis

QA quality assurance

QARD quality assurance requirements and description

RAI request for additional information

SAR Safety Analysis Report

SSCs structures, systems, and components

SER Safety Evaluation Report

SNF spent nuclear fuel

TSPA total system performance assessment


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INTRODUCTION

Volume 4: Administrative and Programmatic Requirements, of this Safety Evaluati(SER), documents the U.S. Nuclear Regulatory Commission (NRC) staffs review aevaluation of the U.S. Department of Energy (DOE) Safety Analysis Report (SAR), its June 3, 2008, license application (LA) (DOE, 2008ab), as updated on February (DOE, 2009av). The NRC staff also reviewed information DOE provided in responNRC staffs requests for additional information and other information DOE providedto the SAR. In particular, SER Volume 4 documents the results of the NRC staffs to determine whether DOEs research and development program, performanceconfirmation program, and administrative controls, systems, and programs meet ap

regulatory requirements.

Other portions of the NRC staffs safety review have been, or will be, documented ivolumes. SER Volume 1, NUREG1949 (NRC, 2010aa, published August, 2010) results of the NRC staffs review of DOEs General Information. SER Volume 2 wilthe results of the NRC staffs review and evaluation of DOEs compliance with precobjectives and requirements. SER Volume 3 documents the results of the NRC staand evaluation of whether the proposed repository design will comply with the perfoobjectives and requirements that apply after the repository is permanently closed. Volume 5 will document probable subjects of license specifications and proposed cconstruction authorization.

NRCs regulations at 10 CFR Part 63 provide site-specific criteria for geologic dispoYucca Mountain. Pursuant to 10 CFR Part 63, there are several stages in the licenprocess: the site characterization stage, the construction stage, a period of operattermination of the license. The multi-staged licensing process affords the Commissflexibility to make decisions in a logical time sequence that accounts for DOE collec

analyzing additional information over the construction and operational phases of thThe period of operations includes (i) the time during which emplacement would occsubsequent period before permanent closure during which the emplaced wastes arretrievable, and (iii) permanent closure. In addition, 10 CFR Part 63 represents a rperformance-based regulatory approach to the review of geological disposal. This informed, performance-based regulatory approach uses risk insights, engineering a

judgments, performance history, and other information to focus on the most importand to focus the review on areas most significant to safety or performance. Therefincludes discussions regarding how the NRC staff used risk information in its reviewapplication. In conducting its review, the NRC staff was guided by the review methacceptance criteria outlined in the Yucca Mountain Review Plan (YMRP) (NRC, 200supplemented by the Division of High-Level Waste Repository Safety Director's PoProcedure Letter 14: Application of YMRP for Review Under Revised Part 63 (NRC

Research and Development Program to Resolve Safety Questions


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during its own evaluations. If DOE identifies safety questions that result in researcdevelopment programs being conducted, the results of those programs must be repNRC in accordance with 10 CFR 63.32(b)(4). The NRC staffs evaluation of DOEs

of a research and development program to resolve safety questions is in SER Sect

Performance Confirmation Program

The NRC staff evaluates DOEs description of a performance confirmation programPerformance confirmation is the program of tests, experiments, and analyses that ito evaluate the adequacy of the information used to demonstrate compliance with tperformance objectives in 10 CFR 63 Subpart E. The Performance Confirmation P

designed to confirm the adequacy of assumptions, data, and analyses that supportused to permit construction of the repository and waste emplacement. The PerformConfirmation Program evaluates information supporting compliance demonstrationspostclosure performance objectives for individual protection [10 CFR 63.113(b)] angroundwater protection [10 CFR 63.113(c)], as well as consideration of certain precaspects of repository performance [e.g., the ability to retrieve waste addressed in10 CFR 63.111(e)]. The NRC staffs evaluation of DOEs performance confirmationin SER Section 2.4.

Administrative Controls, Systems, and Programs

The NRC staff evaluates DOEs administrative controls, systems, and programs thautilize to control activities to ensure that the repository meets applicable regulatoryrequirements. Administrative controls, systems, and programs are provided for impsafety and important to waste isolation structures, systems, and components to ensmaintained and operated within analyzed conditions, and are capable of performingintended functions. Management systems and procedures implement these admin

procedural safety controls. The NRC staffs evaluation of DOEs administrative consystems, and programs is in the following SER sections:

Section 2.5.1, Quality Assurance Program

Section 2.5.2, Records, Reports, Tests and Inspections

Section 2.5.3.1, DOE Organizational Structure as it Pertains to ConstructionOperation of Geologic Repository Operations Area

Section 2.5.3.2, Key Positions Assigned Responsibility for Safety and OperGeologic Repository Operations Area


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Section 2.5.7, Emergency Planning

Section 2.5.8, Controls to Restrict Access and Regulate Land Uses

Section 2.5.9, Uses of the Geologic Repository Operations Area for PurposDisposal of Radioactive Wastes

References

DOE. 2008ab. DOE/RW0573, Yucca Mountain Repository License Application.

ML081560400, ML081560542. Las Vegas, Nevada: DOE, Office of Civilian RadioWaste Management.

DOE. 2009av. DOE/RW0573, Yucca Mountain Repository License Application.ML090700817, ML090710096. Las Vegas, Nevada: DOE, Office of Civilian RadioWaste Management.

NRC. 2010aa. NUREG1949, Safety Evaluation Report Related to Disposal of HRadioactive Wastes in a Geologic Repository at Yucca Mountain, Nevada. Vol. 1: Information. ML102440298. Washington, DC: NRC.

NRC. 2003aa. NUREG1804, Yucca Mountain Review PlanFinal Report. RevML032030389. Washington, DC: NRC.

NRC. 2009ab. Division of High-Level Waste Repository Safety Director's Policy aProcedure Letter 14: Application of YMRP for Review Under Revised Part 63.Published March 13, 2009. ML090850014. Washington, DC: NRC.


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CHAPTER 1

2.3 Research and Development Program to Resolve Safety Qu

2.3.1 Introduction

Safety Evaluation Report (SER) Section 2.3 provides the U.S. Nuclear Regulatory (NRC) staffs review of the U.S. Department of Energys (DOE or applicant) resedevelopment program to resolve safety questions. This review considers informatioin DOEs Safety Analysis Report (SAR) Chapter 3 (DOE, 2008ab). This SAR chapunchanged in DOEs license application update, submitted to NRC in February 200(DOE, 2009av).

Safety questions requiring research and development programs on the adequacy oof structures, systems, and components (SSCs) of the geologic repository importanboth surface and subsurface, or related to natural and engineered barriers importanisolation could be identified by DOE in the SAR or SAR updates or by the NRC staof its review of the SAR. DOE provided information on identification of safety quesrequiring research and development programs in SAR Section 3.1. DOE discussed

elements that would be contained in a research and development program in SAR Such programs would be separate and distinct from DOEs Performance Confirmatdescribed in SAR Chapter 4 and reviewed by the NRC staff in SER Section 2.4.

2.3.2 Regulatory Requirements

The requirement for a description of research and development programs to resolvsafety questions is specified in 10 CFR 63.21(c)(16), which provides

DOE is required to identify those SSCs of the geologic repository, both surfasubsurface, that require research and development to confirm the adequacy

For SSCs important to safety and for engineered and natural barriers imporwaste isolation, DOE shall provide a detailed description of the programs deresolve safety questions, including a schedule indicating when these questibe resolved.

In addition, if a construction authorization is granted, the Commission shall incorpoaccordance with 10 CFR 63.32(b)(4), provisions in the construction authorization reto provide periodic or special reports on any research and development programs bconducted to resolve safety questions .

In its review, the NRC staff used guidance in the Yucca Mountain Review Plan (YM


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respect to (i) SSCs important to safety or (ii) engineered and natural barriers importisolation (SAR Section 3.1).

The NRC staff reviewed the information DOE provided in SAR Section 3.1 and in SChapters 1 and 2 (preclosure and postclosure) for safety questions that would requand development for (i) SSCs important to safety or (ii) engineered and natural barrimportant to waste isolation. The NRC staff also did not identify any safety questioresearch and development programs. The NRC staffs review of the applicants SSto safety and engineered barriers important to waste isolation is in Volume 3 of thiswill also be documented in Volume 2 of this SER. On the basis of its review, the Nthat DOE has acceptably concluded that there are no safety questions that would r

research and development at this time.

2.3.3.2 Research and Development Programs Related toSafety Questions

DOE stated in SAR Section 3.2 that a specific research and development program developed for each identified safety issue related to SSCs of the geologic repositorto safety, both surface and subsurface, or related to natural and engineered barrierto waste isolation, and that each program would be separate and distinct from DOE

Performance Confirmation Program described in SAR Chapter 4. Further, DOE staresults of research and development programs, including periodic progress updateprovided to the NRC.

The NRC staff evaluated DOEs description in SAR Section 3.2 of how each researdevelopment program would

Identify and describe safety questions

Identify and describe the research and development that will be conducted safety questions

Provide a schedule for completing the activities relative to the projected starepository operations

Provide design alternatives or operational restrictions available if the results

activities do not acceptably resolve the safety questions

Based upon its review, the NRC staff determines that the information in SAR Sectioadequately describes how DOE would develop and implement a research and deveprogram to resolve safety questions should any be identified because the discussioSection 3.2 addresses how DOE would provide (i) a detailed description of the progd i d t l f t ti (ii) h d l i di ti h th ti


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In the event that DOE identifies any safety questions that would require a research development program in the future, and in accordance with 10 CFR 63.32(b)(4), thecondition for construction authorization should be included:

Proposed Condition of Construction Authorization: If DOE identifies safety qurequire research and development programs, the results of those programs must bthe NRC in accordance with 10 CFR 63.32(b)(4). DOE shall furnish such periodic timely manner beginning no later than 6 months following the identification of a safethat requires a research and development program and every 6 months thereafter ucompletion of the research and development program or resolution of the issue.

Section 63.32(b)(4) requires that the specified reports be provided on a periodic or reporting basis. The NRC staff proposes that any results of research and developmprograms being conducted to resolve safety questions be furnished in a timely manbeginning no later than 6 months following the identification of safety questions reqreports. Furnishing periodic reports every 6 months on the results of research andprograms is consistent with the frequency for progress reports during the conduct ocharacterization activities as specified at 10 CFR 63.16.

2.3.4 Evaluation Findings

The NRC staff has reviewed the SAR, which includes information required by10 CFR 63.21(c)(16) that is related to identification of safety questions that require development programs. Because neither DOE in its SAR nor the NRC staff in its rSAR identified any safety questions that require research and development, the NRwith reasonable assurance, that DOE has adequately addressed 10 CFR 63.21(c)(

DOE has provided an adequate description of research and development programs

resolve safety questions that require research and development upon their identificstated that it will provide periodic or special reports on any research and developmbeing conducted to resolve safety questions. In accordance with 10 CFR 63.32(b)(construction authorization should include the following condition:

If DOE identifies safety questions that result in research development progrconducted, the results of those programs must be reported to the NRC in acwith 10 CFR 63.32(b)(4). DOE shall furnish such periodic reports in a timelbeginning no later than 6 months following the identification of a safety quesrequires a research and development program and every 6 months thereaftcompletion of the research and development program or resolution of the is

2.3.5 References

DOE 2009 DOE/RW 0573 Y M t i R it Li A li ti


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CHAPTER 2

2.4 Performance Confirmation Program

2.4.1 Introduction

Safety Evaluation Report (SER) Section 2.4 provides the U.S. Nuclear Regulatory (NRC) staffs evaluation of the U.S. Department of Energys (DOE or applicant) the Performance Confirmation Program, as presented in the Safety Analysis Repor(DOE, 2008ab, Section 4), and references therein. This SAR section was changedLicense Application update, which was submitted to the U.S. Nuclear Regulatory C

(NRC) in February 2009 (DOE, 2009av). DOE also provided additional informationPerformance Confirmation Program in its response to the NRC staffs requests for information (DOE, 2009gm, DOE, 2010ap).

The Performance Confirmation Program is the set of tests, experiments, and analysconducted, where practicable, to evaluate the adequacy of the assumptions, data, supporting DOEs application to construct and operate a high-level waste (HLW) reYucca Mountain. The objective of performance confirmation is to monitor key geot

design parameters, including interactions between natural and engineered systemscomponents throughout construction, operation, and through to closure, to identify changes from the conditions assumed and evaluated in the license application thatpostclosure safety. Changes in parameters and conditions during construction, opthrough to closure are identified by the Performance Confirmation Program by combaseline and expected values. Baseline values are developed for the PerformanceConfirmation Program using assumptions, data, and analyses that DOE provided insupport the license application, and that the NRC evaluates in making its licensing

The performance confirmation program does not confirm preclosure performance in(i.e., testing and monitoring structures, systems, and components important to safeaddresses only those aspects of preclosure performance with interactions betweenengineered and natural systems as might affect postclosure performance objectivesspecial case of retrievability. For a construction authorization, the applicant is requprovide a description of a program for performance confirmation that meets the req10 CFR Part 63, Subpart F.

The Performance Confirmation Program must be explicitly linked to a performance that satisfies 10 CFR 63.113. The Performance Confirmation Program may evolveconstruction and operation as the performance assessment is iteratively updated winformation obtained from ongoing performance confirmation monitoring and testingShould a construction authorization be issued, DOE would have appropriate flexibichange the activities and parameters, as indicated by site and facility conditions an


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by 10 CFR 63, Subpart F, and pertinent to compliance with 10 CFR 63.113. The oretrieve waste, which must be maintained until closure, is linked to the completion operformance confirmation program and update of the performance assessment req

license amendment for permanent closure in 10 CFR 63.51.

The NRC staffs evaluation and regulatory findings are based on DOEs descriptionof proposed performance confirmation activities, schedules, and reporting, as detaiSAR Chapter 4, references contained therein, the applicants responses to RAIs(DOE, 2009gm; DOE, 2010ap), and correspondence and reports pertaining to the p2010 to 2014. DOE is not required to have a finalized plan for performance confirmactivities in the application for a construction authorization, but rather, must providedescription of a program that meets 10 CFR 63, Subpart F.

2.4.2 Regulatory Requirements

The regulatory requirements for performance confirmation are in 10 CFR 63.21(c)(10 CFR Part 63, Subpart F, Performance Confirmation Program. Under 10 CFR the SAR must include a description of the performance confirmation program that mthe requirements of 10 CFR 63, Subpart F. The four areas in 10 CFR 63, Subpart (i) General requirements (10 CFR 63.131), (ii) Confirmation of geotechnical and de

parameters (10 CFR 63.132), (iii) Design testing (10 CFR 63.133), and (iv) Monitortesting waste packages (10 CFR 63.134).

A preclosure performance objective that the geologic repository operations area mdesigned so as to permit implementation of a Performance Confirmation Program i10 CFR 63.111(d). The NRC staff will evaluate the applicants design information ait would permit the implementation of a Performance Confirmation Program in SERSection 2.1.1.2.

The NRC staff reviewed DOEs description of its Performance Confirmation Prograapplicable guidance in the Yucca Mountain Review Plan (YMRP) Section 2.4 (NRThe YMRP acceptance criteria for the performance confirmation program are

General requirements established for such a program

Requirements established for confirmation of geotechnical and design para

Requirements established for design testing

Requirements established for monitoring and testing waste packages

2.4.3 Technical Evaluation

The NRC staff reviewed the DOE description of its Performance Confirmation ProgSAR and additional information describing the Performance Confirmation Program


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parts of 10 CFR 63, Subpart F; General requirements (10 CFR 63.131); Confirmatiogeotechnical and design parameters (10 CFR 63.132); Design testing (10 CFR 63.Monitoring and testing of waste packages (10 CFR 63.134). The NRC staffs revie

description of its Performance Confirmation Program is found in SER Sections 2.4.2.4.3.4.

2.4.3.1 General Requirements for Performance Confirmatio

The NRC staffs technical evaluation of the information DOE provided to meet requ10 CFR 63.131 (General requirements) is discussed in the following three subsecti(i) General Description of the Performance Confirmation Program (SER Section 2.4

(ii) Performance Confirmation Activities that are not generally related to the undergopenings (SER Section 2.4.3.1.2), and (iii) Summary of the NRC Staff Evaluation oGeneral Requirements for Performance Confirmation (SER Section 2.4.3.1.3).

2.4.3.1.1 General Description of the Performance Confirmatio

DOE stated that the performance confirmation will provide data to verify the adequainformation presented in the license application by providing data to confirm that (i)conditions are as expected, and (ii) the behavior of repository system barriers is co

performance assessment results (SNL, 2008aq, Section 1.1). The information in thapplication includes assumptions, data, and analyses that support DOEs postclosudeterminations (SAR Section 4.1). DOE stated that the Performance Confirmation would evaluate the information supporting the performance assessments for individprotection and groundwater protection, as well as consideration of specific preclosurepository performance, such as retrievability (SAR Section 4.1).

DOE identified two objectives for the Performance Confirmation Program. First, DO

that the program will provide information, where practicable, to confirm that subsurfconditions encountered during construction and waste emplacement operations arerange of conditions assumed in the SAR. This includes monitoring subsurface contesting to confirm geotechnical and design assumptions for retrievability. The NRCdocument its review of retrievability in SER Section 2.1.2. Second, DOE stated thaperformance confirmation program will provide information to confirm that the naturengineered barriers are functioning as described in SAR Chapter 2. To accomplishobjectives, DOE described its (i) methodology for identifying systems and componefunctioning as barriers, (ii) planned implementation, and (iii) expected schedule.

Identification of Barriers, Systems and Components, and Activities

DOE identified in SAR Table 4-1 the natural and engineered barriers that DOE conimportant to waste isolation. DOE specified the natural and engineered system ancomponents functioning as part of those barriers and DOE related those barriers t


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(iii) effect on barrier capability; and (iv) core parameter characteristic for each perfoconfirmation activity in its Performance Confirmation Plan (SNL, 2008aq; addendumRevision 5, Table A2[a]).

DOE described the methodology for selecting performance confirmation activities inSection 4.1.1 and SNL (2008aq; Section 1.4.1). DOE stated that the performance activities were selected using a risk-informed, performance-based methodology usapproach described as follows. DOE described an approach to identify geotechnicparameters and determine appropriate testing activities that DOE stated were relevidentified natural and engineered systems and components functioning as barriers.approach consisted of (i) using subject matter experts to identify relevant geotechndesign parameters and (ii) determining appropriate testing activities on the basis ofapplication of the following three criteria:

Sensitivity of barrier capability and system performance to the parameter

Level of confidence in the current knowledge about the parameter

Accuracy of information obtained by a particular test

DOE stated that its analysis was based on its understanding of the performance asand barrier capability that existed prior to completing the DOE total system perform

assessment (TSPA) (SNL, 2008ag) presented in the SAR. Because the models usDOE to develop the TSPA had been updated since the analysis was used to identifperformance confirmation activities, DOE conducted a second review comparing thactivities to the representation of key features and processes in the final TSPA modthe second review, which is described in the Performance Confirmation Plan adden(SNL, 2008aq, Appendix A[a]), DOE compared the final TSPA presented in the SApostclosure nuclear safety design bases (SNL, 2008ad), and the Performance ConPlan. DOE did not identify new performance confirmation activities as a result of it

review, because DOE concluded, based upon this comparison, that the previously activities were sufficient to confirm the license application basis.

The DOE Performance Confirmation Plan identified 20 activities for performance coFrom SAR Section 4.2 and Table 4-1, these 20 activities, grouped by the SER subswhich they are evaluated by the NRC staff, are

SER Section 2.4.3.1.2 Precipitation Monitoring

Subsurface Water and Rock Testing Unsaturated Zone Testing Saturated Zone Monitoring Saturated Zone Fault Hydrology Testing Saturated Zone Alluvium Testing

SER Section 2 4 3 2


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Thermally Accelerated Drift Thermal-Mechanical Monitoring

SER Section 2.4.3.3 Seal and Backfill Testing

SER Section 2.4.3.4 Dust Buildup Monitoring Waste Package Monitoring Corrosion Testing Corrosion Testing of Thermally Accelerated Drift Samples Waste Form Testing

DOE stated that some activities were selected to confirm postclosure performance

and for the special case of retrievability, based on current technical information andperformance assessment results. Other activities were selected to meet specific redescribed in 10 CFR Part 63, Subpart F [e.g., subsurface mapping, thermally accethermal-mechanical response monitoring, seal and backfill (if part of the design) teswaste package monitoring]. DOE stated that periodic reassessment of performancconfirmation activities, based on updated technical information and total system peassessment results, (i) will be performed during construction and operations to asscontinued relevance of the activities, and (ii) may lead to new activities being addedcurrently planned activities being curtailed or deleted (SAR Section 4.1; SNL, 2008

Section 4).

In the description of the 20 candidate activities, DOE included in-situmonitoring, lafield testing, and in-situexperiments that would acquire data to use directly, or in anfor the selected geotechnical and design parameters and natural and engineered sand components.

The NRC Staff Review

The NRC staff reviewed the description that DOE provided for the identification of scomponents functioning as barriers, and the testing and monitoring activities assocthose systems and components, in the Performance Confirmation Program. The Nnotes that the requirements in 10 CFR 63.131 link the Performance Confirmation PDOEs performance assessment, specifically to barriers designed or assumed by Dfunction after permanent closure. Furthermore, the NRC staff notes that the identifdescription of barriers and their capabilities described in the Performance Confirma(SAR Section 4 and SNL, 2008aq) is consistent with the information that the applic

presented in SAR Section 2.1 and DOE (2009an, Expanded Table 2.1-1) and whicstaff evaluates in SER Section 2.2.1.1 (Multiple Barriers). In that section, the NRC concludes that the design features of the engineered barrier system and the naturathe geologic setting that are considered barriers important to waste isolation had beacceptably identified by DOE.


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Confirmation Program. As discussed below, based on (i) knowledge gained from pinteractions with DOE, (ii) the NRC staffs review in SER Sections 2.2.1.3.1 throughand 2.2.1.3.12 through 2.2.1.3.14, and (iii) the NRC staffs review of specific candid

parameters for each test and monitoring activity in SER Sections 2.4.3.1.2 and 2.4.2.4.3.4, the NRC staff finds that the 20 activities in the Performance Confirmation Pacceptably cover risk-important, performance-based assumptions and technical bapresented in the SAR. In addition, the NRC staff finds that the DOE description of Performance Confirmation Program meets the requirement in 10 CFR 63.131(c) beprogram includes in-situmonitoring, laboratory and field tests, and field testing.

The NRC staff notes that during construction and operation, new information and aincorporated into an updated performance assessment may necessitate modificatioof Performance Confirmation Program activities, or to the parameters and methodsany of the activities (NRC, 2001aa), as described in the application and in SNL (20

Implementation of the Performance Confirmation Program

DOE stated in SAR Section 4.1.2 that performance confirmation test plans will provinformation on the 20 activities, including (i) baseline information; (ii) anticipated chobserved or measured during the period of the tests, including those that may be c

site investigations, construction, and operations; and (iii) identification of what consor variations beyond the anticipated range during the monitoring or testing period. DOE stated that it plans to update the Performance Confirmation Plan periodically tthat it is consistent with the SAR and reflects the most current performance assessPerformance confirmation test plans have been written for seismic monitoring (SNLprecipitation monitoring (SNL, 2013aa), and construction effects monitoring (BSC, DOE stated that other test plans will be prepared sequentially, and the PerformanceConfirmation Plan will be revised and updated as program development continues.(2009gm) stated that future performance confirmation test plans will be provided to issuance, prior to test implementation. In its Performance Confirmation Plan (SNL,DOE stated that the Performance Confirmation Program must be flexible, with specthe program evolving as necessary in response to information obtained from perforconfirmation activities. DOE described a phased approach for implementing its PeConfirmation Program. DOE stated that candidate activities remain preliminary untfinalized in the performance confirmation test plans, and that DOE will provide futurperformance confirmation test plans to NRC when the plans are completed.

DOE stated [SAR Section 4.1.2; Performance Confirmation Plan Sections 5.2.2 anDOE (2009gm)] that it would consider potential adverse effects on the natural and eelements of the geologic repository before initiating any in-situmonitoring, test, or eacquire data. DOE stated in its performance confirmation activity descriptions whynot expected to adversely affect the ability of the repository to meet performance obthat any adverse effect is minimized DOE (2009gm) stated that test construction a


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The NRC staff reviewed the description DOE provided for the implementation of the

Performance Confirmation Program. On the basis of information discussed above,staff finds that DOE described an acceptable process for documenting consideratioadverse effects. In particular, the NRC staff finds that the DOE description of proceconsider adverse effects meets the requirement in 10 CFR 63.131(d)(1) because D(2009gm) stated that test construction and performance confirmation activities will bfor their impact to waste isolation prior to test implementation, and that these evaluadocumented for each performance confirmation test activity under the DOE Site PeProtection Evaluation Program.

Schedule and Duration

In SAR Section 4.1, DOE stated that the Performance Confirmation Program begancharacterization, assumes a 100-year preclosure period for performance confirmatand will continue until permanent closure. DOE stated that during the time from iniconstruction until repository closure, performance confirmation activities will includemonitoring and testing and laboratory testing (SNL, 2008aq, Section 1.1). DOE staand information collected during construction and operation would be compared ag

information presented in the license application to confirm that subsurface conditionexpected and behavior of repository system barriers is consistent with performanceassumptions, inputs, and results. Baseline information, which will be derived from presented in the license application, includes site characterization data and assuminputs, and analyses from the performance assessment. DOE provided a timeline performance confirmation activities in SAR Figure 4-2, and provided a schedule fortest plans in DOE (2009gm, Table 1).


The NRC staff reviewed the DOE description of the duration and schedule of the PConfirmation Program provided in SAR Section 4 and the Performance Confirmatio(SNL, 2008aq). The NRC staff reviewed the description of the timeline DOE provideach individual activity in SER Sections 2.4.3.1.2 and 2.4.3.2 through 2.4.3.4 forcompliance with 10 CFR 63.131(c), 10 CFR 63.132(e), 10 CFR 63.133(b),and 10 CFR 63.134(d), as appropriate for the particular activity.

The NRC staff evaluated DOEs description of the duration and schedule of the actconducted under the Performance Confirmation Program to determine whether, in with 10 CFR 63.131(b), the program started during site characterization, and it will permanent closure. As evaluated in SER Section 2.4.3, DOE began its PerformanConfirmation Program during site characterization, and DOE has provided plans andescriptions of performance confirmation activities that will continue until permanen


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tasks (DOE, 2010as). On September 30, 2010, DOEs Office of Civilian RadioactivManagement ceased operations and assigned its Yucca Mountain-related responsother offices within DOE. The cessation of these activities does not affect or alter t

assumptions, data, and analyses DOE has provided in support of its license applicarespect to the Performance Confirmation Program. Should a construction authorizaDOE must implement the approved Performance Confirmation Program.

2.4.3.1.2 Performance Confirmation Activities

In SER Sections 2.4.3.1.2.1 through 2.4.3.1.2.6, the NRC staff reviews the individuperformance confirmation activities that DOE identified for precipitation monitoring, water and rock testing, unsaturated zone testing, saturated zone monitoring, saturafault hydrology testing, and saturated zone alluvium testing. These activities are rethis General Requirements for Performance Confirmation SER Section because theactivities not directly linked to the portion of the natural system that may potentially by construction, operations, and emplacement. Other activities listed in SAR Tablereviewed by the NRC staff in SER Sections 2.4.3.2 through 2.4.3.4.

2.4.3.1.2.1 Precipitation Monitoring

DOE described precipitation monitoring in SAR Section 4.2.1.1; DOE (2009gm); PeConfirmation Plan, Section 3.3.1.1; and SNL (2013aa). DOE stated that the purposprecipitation monitoring is to confirm the water flux input at the ground surface that conceptual and numerical models of the hydrologic conditions described in SAR SeDOE also stated that precipitation represents the predominant input of water into thnatural barrier and that the information collected for this activity will confirm and extprecipitation record for the site. DOE stated that precipitation monitoring began ducharacterization, and DOE stated in SAR Section 4.2 that it will continue until closu

Although DOE identified precipitation rate, quantity, and chemical composition as cparameters in SAR Table 4-1 and Performance Confirmation Plan Table 3-2, DOE clarified that the test plan will specify precipitation rate and precipitation quantity.DOE (2009gm) stated that these two parameters will meet the objectives of the actstated in SNL (2013aa) that the baseline information will be the range of precipitatiofrom the synthetic data records used in the Total System Performance AssessmenIn SNL (2013aa), DOE stated it would compare data from six monitoring stations wbaseline information used in the license application performance assessment. The

analysis will include comparison with the range of precipitation used in the performassessment and trend analysis on the data from each station.


The NRC staff reviewed the description DOE provided for the precipitation monitori


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Based on DOEs description, the NRC staff finds that the proposed precipitation moactivity meets the requirements of the relevant portions of 10 CFR 63.131(a), 10 CFand 10 CFR 63.131(d) because the program would

Provide data that DOE can use in models of the unsaturated zone to demonwhether the Upper Natural Barrier is functioning as anticipated

Provide baseline information and analysis for precipitation parameters so thmonitor and analyze changes from baseline parameters that might affect pethe geologic repository

2.4.3.1.2.2 Subsurface Water and Rock Testing

DOE described the subsurface water and rock testing activity in SAR Section 4.2.1Performance Confirmation Plan Section 3.3.1.3. DOE stated that the purpose of thto evaluate whether the Upper Natural Barrier functions as expected and to confirmsubsurface conditions encountered are consistent with observation and predictionsverifying assumptions for the magnitude and distribution of flow paths used in concnumerical models of the unsaturated zone. DOE stated that it will analyze pore-waderived from rock cores obtained from selected locations for performance confirma

dissolved ions, analyze the rock cores for uranium and strontium isotopes, and obtcoatings from within the drifts and analyze those coatings for isotope geochemistryinitiated sampling and laboratory analysis of water, rock, and fracture-filling materiasite characterization and used the geochemical data to infer present and historicalpercolation fluxes at selected locations (SAR Section 2.3.2). DOE stated that it wilpractice throughout repository construction. DOE stated that the first issuance of thperformance confirmation test plan for this activity is scheduled for completion befosubsurface construction.

In SAR Table 4-1 and Performance Confirmation Plan Table 3-2, DOE identified chconcentration; isotopic composition for U, Sr, and O; H3; Cl/Cl36; Tc-99; and I-12the candidate parameters that will be used to infer water flux distribution and magnstated that baseline information will be identified in a performance confirmation testsubsurface water and rock testing and will be based on scientific analysis from perfassessment input data, analysis, and model information contained in the SAR and cited therein.


The NRC staff reviewed the description DOE provided for the subsurface water andactivity. The NRC staff finds that the suite of candidate parameters is acceptable breflect the behavior of features and processes related to the distribution of flow in thunsaturated zone that would indicate that the relevant portion of the Upper Natural


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Provide data that will indicate whether the actual hydrological conditions enduring construction are within the limits assumed in SAR Section 2.3.2 and cited therein

Provide data that will indicate whether the unsaturated zone water flux comUpper Natural Barrier is functioning as anticipated

Provide baseline information and analysis for geochemical parameters usedwater flux so that DOE can monitor and analyze changes from the baseline parameters that might affect performance of the geologic repository

2.4.3.1.2.3 Unsaturated Zone Testing

DOE described the unsaturated zone testing activity in SAR Section 4.2.1.4 and PeConfirmation Plan Section 3.3.1.4. DOE stated that the purpose of this activity is tosorptive properties of the Topopah Springs Tuff crystal-poor member below the repwithin established limits used in performance assessment models. DOE indicated sorptive properties of rock below the repository are a component of the Lower Natuthat may affect retardation of radionuclides; and thus, can slow movement towards radionuclide levels at the accessible environment. DOE stated that it will use unsa

testing to evaluate transport properties and field sorptive properties of the Topopahcrystal-poor member in ambient seepage alcoves or drifts where there are no wasteThis DOE activity includes in-situexperiments, field mapping, field testing, and laboanalysis of samples collected from the field tests. DOE stated that transport and sotesting will be conducted in two or more seepage-monitoring alcoves located withinrepository. DOE performed similar activities during site characterization to charactecomparable parameters in nonwelded tuffs below the repository. DOE stated that zone testing will begin during construction and will continue to the early stages of th

emplacement period.

In SAR Table 4-1 and Performance Confirmation Plan Table 3-2, DOE identified soparameters, van Genuchten parameters describing fractures and matrix,colloid/colloid-facilitated transport parameters, fracture density, apertures, coatingspermeability, seepage, alcove temperature, and relative humidity as candidate paraDOE indicated that these candidate parameters were used in SAR Sections 2.3.2 ainfer or support conceptual models and input parameters for flow and transport modbe used during performance confirmation for the same purpose but in different geo

DOE stated that baseline information will be identified in a performance confirmatiofor unsaturated zone testing and will be based on scientific analysis from performanassessment input data, analysis, and model information contained in the SAR and cited therein.



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Barrier. These NRC staff findings are also based on the NRC staffs understandingunsaturated zone at Yucca Mountain, obtained from prelicensing experience and thstaffs review in SER Section 2.2.1.3.7 (Radionuclide Transport in the Unsaturated

Based on DOEs description, the NRC staff finds that the subsurface water and rocactivity meets the requirements of the relevant portions of 10 CFR 63.131 becauseactivity would

Provide data that will indicate whether the actual conditions encountered duconstruction are within the limits assumed in SAR Sections 2.3.2 and 2.3.8 cited therein

Provide data that will indicate whether the unsaturated zone portion of the UBarrier is functioning as anticipated

Provide baseline information and analysis for geochemical parameters usedwater flux so that DOE can monitor and analyze changes from the baseline parameters that might affect performance of the geologic repository

2.4.3.1.2.4 Saturated Zone Monitoring

DOE described the saturated zone monitoring activity for the saturated volcanic rocalluvium in SAR Section 4.2.1.5 and Performance Confirmation Plan Section 3.3.1stated that the purpose of this activity is to evaluate hydrologic and chemical paramthe DOE saturated zone flow and transport models and includes monitoring the potpresence of repository radionuclides in downgradient wells and the arrival of radionfrom upgradient sources, such as nuclear testing. The saturated zone flow and tramodels encompass features and processes of the saturated zone that may limit or movement of radionuclides to the accessible environment and is part of the Lower Barrier. DOE stated that (i) this activity began during site characterization, (ii) the tbe completed during construction (DOE, 2009gm, Table 1), and (iii) this activity willduring the repository construction and emplacement periods until permanent closur(SAR Section 4.2.1.5).

DOE stated that saturated zone monitoring includes measuring water levels, Eh, anand Nye County wells, and analyzing radionuclide concentrations in water samplesfrom the wells. In SAR Table 4-1 and Performance Confirmation Plan Table 3-2, D

water level and hydrochemical indicators (Eh, pH, radionuclide concentrations, andcharacteristics) as the candidate parameters. DOE indicated that these candidate were used in SAR Sections 2.3.9 to infer or support conceptual models and input pflow and transport models in the saturated zone, and can be used during performanconfirmation for the same purpose. DOE stated that baseline information will be idperformance confirmation test plan for saturated zone testing and will be based on


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saturated zone that will indicate that the relevant portion of the Lower Natural Barriefunctioning as anticipated. In SER Section 2.2.1.3.9, the NRC staff noted that changeochemical candidate parameter values (particularly Eh and pH), depending on m

direction of the changes, may significantly change transport characteristics and, theestimates of dose. Also, the NRC staff finds DOEs description of baseline developacceptable because it will use information from the performance assessment and threflects the flow and transport barrier capability of the saturated zone portion of the Natural Barrier. These NRC staffs findings are also based on the staffs understansaturated zone at Yucca Mountain, obtained from prelicensing experience and the review in SER Sections 2.2.1.3.8 (Saturated Zone Flow) and 2.2.1.3.9 (Radionuclidin the Saturated Zone).

Based on DOEs description, the NRC staff finds that the subsurface water and rocactivity meets the requirements of the relevant portions of 10 CFR 63.131(a), 10 CFand 10 CFR 63.131(d) because the activity would

Provide data that will indicate whether the saturated zone conditions are witassumed in SAR Section 2.3.9 and reports cited therein

Provide data that will indicate whether the saturated zone portion of the Low

Barrier is functioning as anticipated

Provide baseline information and analysis for hydrochemical parameters usradionuclide transport so that DOE can monitor and analyze changes from tcondition of parameters that might affect performance of the geologic repos

2.4.3.1.2.5 Saturated Zone Fault Hydrology Testing

DOE described the saturated zone fault hydrology testing activity in SAR Section 4Performance Confirmation Plan Section 3.3.1.6. DOE stated that the purpose of thto evaluate fault parameter assumptions used in the saturated zone flow and transpDOE described the tuff portion of the saturated zone barrier as complicated by faulttilting, with faults acting as both barriers to and preferential pathways for flow. DOEits planned tests as similar to tests previously performed by DOE at the C-well testand may include monitoring of water levels, single borehole and cross-hole hydrautests, field sample collection, and laboratory analysis of samples. DOE stated that drill additional boreholes in or near faults to perform the testing. DOE identified the

Canyon Fault system and an undetermined location downgradient of the repositorytest locations, with candidate formations including the Tertiary tuff, the Crater Flat Gthe Paintbrush Group. DOE stated this activity will include several phases, each b3 years in duration, and that it would be initiated by DOE during construction.

In SAR Table 4 1 and in Performance Confirmation Plan Table 3 2 DOE identified


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synthesized from performance assessment assumptions and from published resultsanalogue sites in fractured and faulted rocks (SNL, 2008aq, Section 3.3.1.6).


The NRC staff reviewed the description DOE provided for the saturated zone fault htesting activity.