Analysis of the Treatment, by the U.S. Department of Energy, of the FEP Hydrothermal Activity in the Yucca Mountain Performance Assessment

The U.S. Code of Federal Regulations, 10 CFR Part 63, stipulates that the expected performance of the geological high‐level nuclear waste repository must be demonstrated through a total system performance assessment (TSPA). The TSPA represents an analysis that identifies all features, events, and processes (FEPs) that might affect the disposal system and examines the effects of the identified FEPs upon the performance of the system. Secondary minerals from the thick unsaturated zone of Yucca Mountain were deposited from waters with temperatures up to 70–90°C. U‐Pb dating constrained the ages of the elevated temperatures to the period between 10 and 5–6 million years ago. Relatively youthful circulation of thermal waters (hydrothermal activity) would be of concern for the safety of the disposal facility. A phenomenological model was advanced by the U.S. Department of Energy (DOE), which proposed that the minerals were deposited by infiltrating meteoric waters that were heated upon contact with the bedrock; it was hypothesized that the latter was conductively heated by a shallow silicic magma body. The model rendered processes responsible for elevated water temperatures inconsequential for the safety of the proposed nuclear waste facility. However, attempts by DOE at validating the model by means of numeric thermal simulations and analogue system observations were unsuccessful. Regulations specify two criteria for exclusion of a FEP from consideration in the TSPA: low probability and low consequence. The lack of a plausible phenomenological model makes it impossible to apply either of these two criteria to the FEP Hydrothermal Activity. Despite the lack of a valid criterion for exclusion, it was excluded from the TSPA. Both the development of DOE's thermal model and the formal FEP analysis were associated with deviations from DOE's quality assurance regulations.