Management of Commercially Generated Radioactive Waste - U.S. ...

7.41
for discrimination in the selection of a disposal program. For example, it can be
argued that the longer period for research and development provided by the alternative
program can in turn reduce the probability of failure by producing more knowledge and
a greater diversity of choice in selecting a disposal method. Such an argument has
merit only if the proposed program:
* failed to maintain R&D programs in place to increase the body of knowledge
* failed to maintain a broad base of investigation of alternative media, geology and
locations so as to increase the available diversity
* failed to require technical conservatism to compensate for uncertainties and ade-
quate factors of safety
* failed to provide for reversibility of current decisions through use of concepts
of retrievability or other step-wise approaches to final decisions. This reversi-
bility allows the increased knowledge which develops over time to be a factor in
near-term decisions.
To the extent that the proposed program provides for use of the above mitigating fac-
tors, it is likely that this program would achieve safety and assurance of effective perm-
anent disposal comparable to that of the alternative program. One purpose of including the
above mitigating factors would be to make it likely that the significant long-term conse-
quences would be indistinguishable relative to an alternative strategy.
Between similar program strategies, then, the issue becomes one of degree rather than
sharp difference. Do the mitigating factors adequately compensate for the existence of
uncertainties? Often such questions can only be resolved by consideration of extensive
detail. In such a case, one must look to the near-term aspects of the strategies, rather
than to their long-term aspects in order to evaluate significant difference which can be
identified with confidence.
Reviews by the Interagency Review Group (IRG) and others indicate that the R&D program
must continue to obtain necessary information before proceeding with any waste isolation
concept. This program of R&D is discussed in Section 5.2 and equivalent sections throughout
the Statement. Longer time spent on R&D does allow the reduction of uncertainty in under-
standing of key processes and parameters but generally only to a certain point. Judgments
need to be made as to when sufficient R&D has been conducted and information is adequate to
proceed with implementing any concept. A comprehensive discussion of the resolution of
uncertainties concerning geologic disposal is contained in paragraph 2D of Appendix A to the
IRG Subgroup I draft report (IRG 1979). Licensing criteria and formal consideration by DOE
and by independent licensing authorities through a step-wise approach will be the mechanism
for making the determination of whether enough R&D has been completed.
Any repository developed after a careful siting investigation that thoroughly examines
the geological considerations discussed in Section 5.2, that proceeds in a stepwise fashion
of development using technically conservative placement at each step, and that is vigorously
scrutinized by independent licensing authorities should not represent a substantially
greater long-term risk than any other concept.