6
Findings and Recommendations

In this chapter the committee summarizes its findings and provides recommendations for the staged development of a generic repository program and specifically for the Yucca Mountain Project. The purpose of this study is to discuss staged approaches to implement a successful repository program. Therefore, findings and recommendations are preceded by the committee’s definition of a successful repository program.

6.1 Committee’s definition of a successful geologic repository program

First and foremost, the absolute measure of success of a geologic repository is the extent to which it isolates the waste from the accessible environment as far into the future as the waste remains hazardous. A more useful definition of success for the implementer is a safe geologic repository that is also cost-effective and is societally acceptable. More concretely and more measurably, a successful geologic repository program is one in which:

  • a geologic site and engineered system, judged to be technically suitable using the particular country’s accepted regulatory, public, and political processes, have been identified;

  • operational and long-term safety aspects are consistent with current scientific understanding of repository systems, safety features are reviewed, and the necessary licenses are granted;

  • an ongoing long-term monitoring and observation program designed to substantiate the current scientific understanding of the safety aspects of the repository system is in progress;

  • sufficient societal consensus is achieved to allow operations to begin and continue;

  • initial waste emplacement has taken place with plans for reversibility; all necessary safety and security measures are set up to emplace additional waste, if decided; and

  • procedures and funding arrangements are agreed to for either:

    • backfilling (if used), closing, and sealing the repository1 (if technical and societal confidence in its long-term isolation properties continues); or

1  

Procedures for closing and sealing the repository include additional measures such as providing longer-term accessibility of records relevant to the site.



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6 Findings and Recommendations In this chapter the committee summarizes its findings and provides recommendations for the staged development of a generic repository program and specifically for the Yucca Mountain Project. The purpose of this study is to discuss staged approaches to implement a successful repository program. Therefore, findings and recommendations are preceded by the committee’s definition of a successful repository program. 6.1 Committee’s definition of a successful geologic repository program First and foremost, the absolute measure of success of a geologic repository is the extent to which it isolates the waste from the accessible environment as far into the future as the waste remains hazardous. A more useful definition of success for the implementer is a safe geologic repository that is also cost-effective and is societally acceptable. More concretely and more measurably, a successful geologic repository program is one in which: a geologic site and engineered system, judged to be technically suitable using the particular country’s accepted regulatory, public, and political processes, have been identified; operational and long-term safety aspects are consistent with current scientific understanding of repository systems, safety features are reviewed, and the necessary licenses are granted; an ongoing long-term monitoring and observation program designed to substantiate the current scientific understanding of the safety aspects of the repository system is in progress; sufficient societal consensus is achieved to allow operations to begin and continue; initial waste emplacement has taken place with plans for reversibility; all necessary safety and security measures are set up to emplace additional waste, if decided; and procedures and funding arrangements are agreed to for either: backfilling (if used), closing, and sealing the repository1 (if technical and societal confidence in its long-term isolation properties continues); or 1   Procedures for closing and sealing the repository include additional measures such as providing longer-term accessibility of records relevant to the site.

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maintaining long-term control and monitoring and capability for retrieving wastes, if this capability is necessary for technical or societal reasons. The committee’s definition of a successful repository program is different from the definition of a successful repository itself. Success of the repository will be known only far into the future, after thousands of years have passed without significant release of radionuclides into the accessible environment. The committee’s definition of a successful program emphasizes the goal of achieving the required degree of technical and societal consensus to begin waste emplacement and the incremental improvement of waste emplacement operations, rather than moving rapidly to full-scale emplacement. Repository implementers often view the latter as a measure of success. 6.2 Adaptive Staging offers a promising approach to successful geologic repository development Compared with other large engineering projects, geologic repositories for high-level waste are peculiar undertakings because (1) they are first-of-a-kind, complex, and long-term projects that must actively manage hazardous materials for many decades during the operational phase; (2) natural and engineered barriers are expected to hold passively safe these hazardous materials for many millennia after repository closure; and (3) they are widely perceived to pose serious risks. As with other complex projects, repository programs should proceed in stages. There are two possible approaches to Staging: Linear and Adaptive. The Adaptive Staging approach laid out in this report is characterized both by specific attributes (see Section 2.3) and by a formal decision-making process between stages (see Section 2.4). These attributes are: commitment to systematic learning, flexibility, reversibility, auditability, transparency, integrity, and responsiveness. Taken separately, these attributes do not constitute the process that the committee calls Adaptive Staging. Only the presence of all these attributes makes the staging process Adaptive. Stages are separated by Decision Points. Decision Points need not be fixed in time: they can be introduced when new information warrants them. Decision Points provide an opportunity to integrate newly acquired knowledge into the program and to evaluate the program’s status. Adaptive Staging anticipates and facilitates integration of such new knowledge and periodic program evaluations. Decision Points are intended to focus the implementer’s attention on the goal of identifying program improvements with respect to, for instance, environmental impacts, safety, costs, or schedule. Adaptive Staging is a cautious, deliberate decision and management process that emphasizes continuous learning, both technical and societal, includes scientific and managerial re-evaluations and responses to new knowledge, and is also reversible by design. Certain criteria can suggest when Adaptive Staging is more promising than Linear Staging for managing complex projects (see Section 2.5). The technical and societal contexts of geologic repository development in most coun-

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tries meet the criteria set out in Chapter 2 for using Adaptive Staging. Adaptive Staging can be applied to all parts of a repository system, affecting scientific, technical, societal, and institutional aspects of the process. Adaptive Staging is not in itself sufficient to guarantee the success of a repository program, but the committee believes it increases the likelihood of success. Previous approaches to repository development, often based on a Linear Staging approach, have encountered serious obstacles. Increased use of staging is apparent worldwide, as described in Appendix D. While the committee believes Adaptive Staging is a promising approach, it also recognizes that Adaptive Staging is a new and unproven process. Nevertheless, the Adaptive Staging strategy is consistent with any project management approach that requires simultaneous attention to societal, institutional, and technical concerns. The Adaptive Staging approach in repository development also has features in common with environmental management concepts proposed in the recent ISO 14000 standards, which also emphasize commitment to systematic learning and to looking beyond simple compliance with regulations. Finally, when the project under consideration meets the criteria for Adaptive Staging (Section 2.5), then the use of Adaptive Staging is consistent with good engineering practices. 6.3 Effective Adaptive Staging involves the entire waste management system Adaptive Staging has an impact not only on repository operations but also on transportation and buffer storage at both reactor and repository sites. Full and transparent consideration must be given for understanding the implications of the staging process on all of these system components. To be effective, Adaptive Staging must involve the implementer, the regulator, stakeholders, and the concerned general public. The success of Adaptive Staging depends on the extent to which involved parties are willing to acknowledge remaining uncertainties and recognize unexpected outcomes and occurrences as learning opportunities to improve the system. Adaptive Staging has a clear impact on the program’s initial schedule because it encourages a slow buildup of activity. However, the longer-term impacts are less clear. Adaptive Staging is a means to bring the new information into the program in a timely fashion, which could result in more timely and informed decision-making, thereby increasing program efficiency. The committee is not in a position to analyze specific cost implications but recognizes the need for cost and decision analysis studies in this domain. The judgment of the committee is that Adaptive Staging need not increase costs; it may do so in the short term, but it may also serve to avoid expensive errors over the long-term or reduce delays (and hence costs) caused by programmatic inefficiencies or societal conflicts. Cost estimates for repository projects often prove unrealistically low because they are based on assumptions that the project will proceed as planned in advance with no deviations, an assumption that is seldom achieved. The use of Adaptive Staging may reduce the time and costs to initial waste emplacement.

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Adaptive Staging may play a more pronounced role in the early stages of the operational phase. As a program progresses through the early stages of the multi-decade operational phase, it is anticipated that early successful stages are likely to lead to subsequently longer stages. Alternatively, unanticipated, significant discoveries or problems would be expected to lead to both careful evaluation of future activities and shorter stage durations. Adaptive Staging will probably not have any major negative impacts on security. It has been argued that the security of nuclear materials is easier to ensure if they are emplaced deep underground; thus, those materials should be emplaced in a geologic repository as soon as they are ready for disposal. Therefore, it is necessary to consider whether adopting Adaptive Staging could greatly affect the time frames during which different types of wastes (defense high-level waste or spent fuel versus commercial spent fuel) are emplaced underground. Independently of the management approach chosen, the time that will elapse before geologic repositories will begin to operate is so long (i.e., decades) that other, more immediate, measures are needed to prevent misuse of radioactive materials by terrorists. Therefore, any plausible delays in moving wastes underground because of Adaptive Staging will not significantly impact the safe and secure geologic disposal of nuclear materials. 6.4 Iteration of the safety case is central to Adaptive Staging for geologic repositories The committee addresses safety using the term “safety case,” in accordance with growing international practices, to mean the integrated collection of all arguments that the implementer produces to demonstrate safety of the repository to all interested parties. Iterative assessment of the safety case is the fulcrum around which decisions are made. This means that the safety case is used in Adaptive Staging as a management tool to guide the implementer’s actions during repository development. The safety case is also used to develop a program with features such as robustness and conservatism and to convince the implementer itself, the regulator, stakeholders, and the general public that there is a sensible and defensible set of arguments showing that the repository will be safe. The safety case includes a broad and understandable (to stakeholders and the general public) explanation of how safety is achieved and a similar discussion of the uncertainties that result from limitations in the scientific understanding of system behavior. Iterative review of the safety case is a key aspect of Adaptive Staging. During a Decision Point, the implementer conducts a systematic re-evaluation of the safety case in view of new information gained during the previous stage and adapts the program, if necessary. This re-evaluation in turn guides data collection in the next stage. Periodic reassessment of the safety case allows fruitful incorporation of new knowledge and guides changes to the program. By reassessing the safety case at each stage of repository development the implementer can evaluate the robustness and reliability of the system concept in light of new data, identify any unresolved technical safety issues, and address issues of concern raised by the regulator, stakeholders,

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or the general public. The safety case is used to convince the implementer itself, the regulator, stakeholders, and the general public that there is a sensible and defensible set of arguments demonstrating that the repository will be safe. A critical aspect of safety case review is that the program not only specifies new data to collect but also allows for hypothesis falsification and testing concerning repository performance. The comparison of observation and prediction may occasionally bring unexpected discoveries that yield useful information on predictions of repository behavior. Over time, as stages are completed, the ability of the program to predict performance should improve. This improvement in turn increases confidence in the robustness of the safety case. Re-evaluation of the safety case implies neither repeated questioning of earlier decisions nor necessarily a pause in program activities, and in no case should this re-evaluation be used to unnecessarily delay decisions. The purpose of the re-evaluation is to examine the current situation and to ensure that any significant changes in original program goals or philosophy are based on new knowledge and understanding of the system and do not result inadvertently from cumulative incremental changes. 6.5 Adaptive Staging requires continuous and active learning in both technical and societal fields The commitment to systematic learning is reflected in an ongoing program monitoring the engineered and natural barriers of the repository system. A concurrent long-term science and technology program is also established to analyze and interpret system behavior; recommend system improvements in response to new information; and address knowledge gaps. Important new scientific and technical information for Adaptive Staging will emerge from technical monitoring of the system, some will arise from specific studies before and during the operational phase, and some will result from experience gained throughout all stages. The long-term science and technology program should include parallel research and monitoring functions in the social sciences and other relevant research fields to enhance the societal and institutional consideration of program development. 6.6 Adaptive Staging encourages opportunities for interactions with stakeholders and the general public Stakeholder input to the decision-making process is of paramount importance for effective implementation of Adaptive Staging. An essential component of systematic learning is proactively seeking stakeholder involvement, rather than limiting involvement to public information meetings such as hearings or comment periods, which are often characteristic of Linear Staging.

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Adaptive Staging encourages and explicitly calls for interaction with stakeholders and the general public at Decision Points (see Figures 2.1a, b, and c). Such involvement holds the potential for advancing social science knowledge and for enhancing public trust. Complete trust is not a prerequisite for Adaptive Staging; however, some trust is required to initiate this approach because the flexibility attribute of Adaptive Staging implies that end points and paths are not rigorously defined at the outset of the program. If stakeholders recognize their right to provide input to program decisions, they may be more likely to acknowledge the benefits of Adaptive Staging, may develop greater trust in the implementer and the process, and may acquire more confidence in the safety of the repository. Adaptive Staging, with its focus on learning, provides increased opportunities for building institutional continuity—an essential requisite for long-term projects in which trust must be built and maintained and information passed on over multiple generations. Adaptive Staging increases the knowledge base in the project through stakeholder involvement. This includes not only technical knowledge augmented by open contacts with the scientific community but also societal knowledge gained from interacting with key stakeholders and the general public. Adaptive Staging can have adverse impacts on program development because it affords increased opportunities for program opponents to delay or hinder progress. Stakeholders and the general public may question the implementer’s motivations for adopting Adaptive Staging. They may view the use of Adaptive Staging as a way to get “a foot in the door,” that is, to begin waste emplacement before important uncertainties have been resolved and as a way to take larger, irrevocable steps to completing waste emplacement. To reduce the likelihood of such assertions, the grounds for Adaptive Staging must be transparently presented, the importance of reversibility (returning to a previous stage) must be stressed with the greatest attention to fairness, and the integrity of the implementer must be high. Stakeholder participation is monitored and evaluated in a formal assessment process (involving stakeholders). Procedures for interactions would be improved based on what is learned from previous stakeholder and public interactions. 6.7 Adaptive Staging can be compatible with current regulatory systems All regulators for geologic repositories face the “regulator’s dilemma,” that is, how to organize a regulatory approach that will enable sound and acceptable regulatory decisions to be made in light of uncertainties, some of which are in fact not resolvable (NRC, 2001). As a result, all regulatory systems for geologic repositories are staged from site selection, through repository development, to closure. Adaptive Staging can be compatible with current regulatory systems if regulators are responsive to the development of new knowledge and reduction of uncertainties at succeeding steps of the repository program. For Adaptive Staging to be effective, the regulatory system

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must allow licensing processes that are not overly complex or long. The licensing process must accommodate the possibility of continuing the repository program during the license amendment process, provided no negative safety impacts result and no irrevocable new developments occur. The staged approach to licensing allows the implementer to develop, and the regulator to review, the knowledge base and the safety case at each stage in the lengthy phases ultimately leading to closed and sealed repositories. Adaptive Staging provides a transparent, traceable record of decisions and their rationales. It also provides a continuous opportunity for stakeholder interaction with the regulator. The previous findings are generic, applicable to any repository program, including the Yucca Mountain project. The following are additional findings and conclusions specific to Yucca Mountain repository program (see details in Chapter 5). 6.8 DOE has recognized potential advantages of staging DOE has recognized advantages of staging its Yucca Mountain Project and has taken some actions consistent with Adaptive Staging. The original DOE justification for the flexible repository design (see Appendix F) was based primarily on cost considerations. Many aspects of the Yucca Mountain Project, however, still reflect a Linear rather than an Adaptive approach to staging. This is, in part, due to the political and legal constraints imposed on the project (see Sections 5.3 and 5.4). DOE is facing many challenges with transportation, interim storage, and interaction with the utilities and the public as it moves into the license application phase for Yucca Mountain. Some of these challenges could be addressed by incorporating Adaptive Staging into the program (see Section 5.4). DOE could introduce Adaptive Staging now. It will take a minimum of two years before a license application for Yucca Mountain is filed. Several years of licensing interaction with the Nuclear Regulatory Commission (USNRC) will then occur. If DOE receives a license for Yucca Mountain, there will be a multiyear buildup to full-scale operations. Operations will last for decades, and DOE has suggested a pre-closure observational period of up to 300 years. Thus, there is time for DOE to adopt Adaptive Staging in the first license application, and there is a long time span over which DOE can continue to follow Adaptive Staging and to specify in detail what the future stages and transitions will be—recognizing that with staging, future learning and adaptation may change the details of the initial plans. The U.S. licensing process already follows a staged approach. Adaptive Staging presumes that a license will be issued based on safety analyses covering the entire proposed inventory (i.e., the application for the construction authorization must present complete safety analyses for pre-closure and post-closure compliance to the USNRC). The regulator, the Nuclear Regulatory Commission, expects the license application to be “as complete as possible in light of information that is reasonably available at the time of docketing” (66 Federal Register, p. 55739). This implies an expectation that

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additional relevant information will become available and be used as the project develops. There is no provision for partial licenses, but the USNRC can impose license conditions requiring subsequent reviews of results obtained in earlier stages before proceeding to the following ones. Even without the imposition of such conditions, there are no restrictions precluding DOE from implementing Adaptive Staging, and DOE has the flexibility to do so voluntarily. 6.9 Specific impacts of Adaptive Staging on the U.S. program Specific changes would result from implementing Adaptive Staging in the U.S. repository program. If adopted, Adaptive Staging would lead DOE to do the following: Highlight the goal of ensuring safety and security at all times more prominently than the specific milestone of emplacing 70,000 MTHM in Yucca Mountain. Focus more strongly on achieving the degree of technical and societal consensus needed to begin waste emplacement, rather than on the emplacement of all waste. Introduce stages that explicitly focus on what can be learned about safety (i.e., re-evaluating the safety case) and about concerns by the regulator, stakeholders, and the general public. Start conservatively in design and operations, with the opportunity to reduce conservatism as new knowledge allows. Plan for early pilot and test facilities along with possible demonstration facilities; clarify with the USNRC how the use of these facilities could affect the licensing process. Focus specifically on assuring and demonstrating retrievability. Focus on explicit thermal load management alternatives. Plan for sufficient buffer storage at or near the site, with transparency about its policy implications, and decouple the rate of waste acceptance from the rate of waste emplacement underground. Place high priority on defining and securing funding for the monitoring and the science (including social science) programs with the intention of modifying and improving the programs as learning progresses. 6.10 Recommendations: general The following are general recommendations concerning the implementation of Adaptive Staging in a generic repository program. 1. Adaptive Staging should be the approach used in geologic repository development. The committee believes that the features of Adaptive Staging have the potential to address the technical and societal challenges of geologic repository development. This belief is based on the committee’s knowledge of repository programs worldwide, considerations of other com-

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plex projects, and the compatibility of Adaptive Staging with the principles of sound project management and good engineering practices. In a first-of-a-kind, controversial, and unique scientific and engineering undertaking, there are obvious benefits in starting slowly; undertaking pilot activities; designing in flexibility and retrievability; looking for alternative paths; learning from experience, science, and monitoring; and seeking and responding to stakeholder concerns. However, Adaptive Staging has not yet been implemented in a geologic repository development program. Adaptive approaches have been applied with mixed and incomplete results in environmental and conservation management. Implementation of Adaptive Staging will likely entail new and significant organizational and institutional challenges. For instance, learning will be minimal unless the implementer actively seeks out alternative viewpoints, openly acknowledges errors and uncertainties, specifically addresses societal issues, and organizes and undertakes relevant research to improve the knowledge base. Moreover, the long time scale of repository operation implies that organizational performance will need to be maintained over decades, and possibly centuries. Stability on this order is not the norm in corporations or governments. Hence, lessons of successful organizations and transferability of these lessons are useful areas of study. Adaptive Staging is clearly helpful with technical matters, but it can also help the program accommodate changing political factors. While there are opportunities for implementing Adaptive Staging throughout the program, these are especially numerous in the early stages leading to full-scale operations. Adaptive Staging will also be of increased importance as repository closure decisions are made. Lacking empirical testing for Adaptive Staging, the committee recognizes that its recommendations must be accompanied by the above caveats. Moreover, the committee identified knowledge gaps in the implementation of Adaptive Staging (Section 4.1). However, the inherently self-correcting nature of Adaptive Staging reduces the risk of using this approach. 2. A repository program should be based on a structured decision-making process that places emphasis on iterative review of safety for the entire repository system. One essential feature of Adaptive Staging is the periodic re-evaluation of safety to guide the program at Decision Points. The committee believes that the safety case, as described in this report, is an appropriate tool for implementing this re-evaluation. The committee recommends that program implementers present a safety case for a full-inventory repository in parallel with the license application. A full-inventory safety case is important to help establish confidence by the regulator, stakeholders, and the general public in the ultimate safety of the entire repository system. 3. The repository program should make full use of learning opportunities offered by in situ testing. Adaptive Staging takes advantage of the learning opportunities during the buildup to full-scale implementation to improve

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operations, enhance safety, or both. Examples of learning opportunities for in situ activities include (see also Section 4.2.1): a pilot facility for learning how operations can be most efficiently and safely performed and for identifying methods to incorporate societal learning into the process; pilot activities can begin with non-radioactive experiments but must ultimately use radioactive materials;2 a test facility for short- and long-term scientific research aimed at reducing residual uncertainties and improving performance in key areas; and a demonstration facility for enhancing the confidence of both stakeholders and the general public in the safety of the actual repository operation and allowing particularly comprehensive monitoring of specific system components during the multi-decade operating life of the repository. Considerations should be given for locating these in situ facilities in the repository horizon to yield maximum information; the pilot and demonstration facilities can be operated in parallel with other underground operational activities. Other pilot or test activities can be carried out in surface facilities. To avoid suspicion that these in situ facilities are tactics intended only to accelerate waste emplacement, it is important that the public be informed of the purposes of, and results from, work in these facilities and that reversibility of any early stage can be demonstrated. If the implementer decides to use pilot, test, and demonstration facilities, the repository initial license application should contain provisions to implement these facilities. 4. The repository implementer should ensure a continuous and active learning process. During the decades of repository operation it is prudent, and it will be expected by the public, that the implementer continues to analyze whether initial safety assumptions remain valid and also continues to improve the system. To support this learning, repository programs should have: a broad, comprehensive, long-term science and technology program that continues throughout the lifetime of repository operations; is targeted and accountable, peer-reviewed, and of sufficient breadth to address key knowledge gaps, including those in social sciences; and also defines learning objectives for each stage; a monitoring program that collects scientific, technical, and societal data from appropriate sources; and a performance confirmation program that builds confidence in the ultimate performance of the repository, and focuses on data acquisition and modeling that is directly related to those issues on which the licensing and 2   The committee acknowledges that pilot activities are unlikely to improve understanding of long-term repository behavior.

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safety case are based, including performance assessment methodology testing.3 These three programs should be integrated but duplications should be avoided. The long-term science and technology program can address more general issues than the repository-focused experimental work in the test facility. Even so, the objective of this program is to improve repository operation and performance and to reduce the uncertainties, not just to perform open-ended science. Accordingly, the studies should be evaluated based on their progress toward filling identified knowledge gaps. The programs should be credible, transparent, and auditable. 5. The repository program should integrate independent technical advice and stakeholder input to the maximum possible extent. An essential component of continuous learning is proactively seeking stakeholder involvement rather than limiting involvement to public information meetings, which are often characteristic of Linear Staging procedures. A promising mechanism for stakeholder involvement, discussed in the National Research Council report Understanding Risk (NRC, 1996), is a structured, analytic-deliberative decision-making, process comprising iterative mutual learning among scientists, technical experts, and managers on the one hand, and representative stakeholders on the other (see Section 2.4). The success of such a process depends on two components: the proactive engagement of stakeholders throughout the repository program, and a structure that elicits stakeholder concerns and develops scientific or other means for addressing them. The implementer should encourage the establishment of a technical oversight group that also includes a social science component and is independent of the government to provide an independent technical analysis and to provide advice on the repository development program. Separately, a stakeholder advisory board consisting of representatives from institutional stakeholders and other stakeholder groups—such as local institutions, local and affected governments, universities, as well as representatives from industry, non-profit, and labor organizations—should provide additional input on stakeholder concerns, establish a venue for regular dialogue and consultation, and take part in Decision Points. The effectiveness of stakeholder involvement in the decision-making process should be evaluated as part of the learning activities of Adaptive Staging. Stakeholders’ awareness of their role in the decision-making process may change their perceptions of decisions taken and reactions to new information. 3   In this context, performance assessment methodology testing emphasizes the application of performance assessment codes to natural systems to test how well these codes model natural systems.

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6.11 Recommendations: U.S. program The following recommendations are specific to the U.S. program and take into account the specific context and constraints that DOE is facing. 1. DOE should adopt Adaptive Staging. Consistent with international trends, two previous National Research Council committees have encouraged DOE to implement a flexible approach in its high-level waste repository development program (NRC, 1990, 2001). Some of the attributes essential for Adaptive Staging are already incorporated into the U.S. program; for example, stakeholders have access to a great amount of documentation and information. DOE is also in the process of introducing other changes in its program consistent with Adaptive Staging, the obvious examples being the increased emphasis on a potential pilot stage (see Appendix F, Section F.1.4), the development of a safety case approach (see Section 5.1.1), and demonstrating the feasibility of waste retrieval (see Section 5.1.3). However, DOE’s program remains essentially Linear (Sections 5.2 and F.2). There are several actions that DOE could take to implement Adaptive Staging. For example, the safety case that DOE is planning to produce should include a description of safety arguments understandable by the general public that would be re-evaluated at all major Decision Points. The corresponding intentions and actions concerning the use of Adaptive Staging should be communicated to, and discussed with, stakeholders. DOE should also communicate the criteria it uses for judging the success of each stage and for deciding whether to change or even to reverse the course of actions. The committee believes that DOE could reduce its vulnerability to discovery of disabling error, improve the prospects of obtaining a license, and increase its opportunities to gain societal acceptance by wholeheartedly embracing Adaptive Staging. 2. DOE should implement in situ pilot and test activities and should examine the possibilities for demonstration activities. The committee recommends the introduction of a pilot stage designed to maximize systematic learning opportunities in the Yucca Mountain Project. However, DOE should make the purpose of these activities clear and understandable by stakeholders and the general public and should ensure that the appropriate licenses are received, if radioactive waste is used. The pilot emplacement stage,4 which need last for only a few years, would consist of the initial emplacement of a fraction of the waste without the requirement of having the entire system (full-scale transport, storage, packaging, and disposal) in place. The learning gained from the pilot stage should help DOE to proceed expeditiously to full emplacement in the next stage unless significantly adverse information is gained or substantial system operation improvements are developed. Pilot trials are also recommended at the surface to assess, 4   The committee envisions different pilot stages with different purposes during repository development; for instance, there could be a pilot stage to test closure, sealing, and long-term containment.

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for example, waste packaging, transport, and canister welding. The decision on whether to conduct a large-scale in situ retrievability test should be made at an appropriate Decision Point. DOE should expand its knowledge outside the bounds of the pilot stage by performing in parallel in situ test activities to develop improved confidence in waste isolation or in the overall performance of the repository. DOE should also examine, in collaboration with stakeholders, the potential benefits of reserving a fraction of the waste disposal area for demonstration purposes. 3. DOE should set up an independent technical oversight group and a stakeholder advisory board. The scientific work in the program must be— and must be recognized to be—subject to and responsive to independent input and review. The long-term science and technology program recently proposed by DOE should be given appropriate institutional status within DOE and should receive stable, long-term funding. Social science research should be included as an integral part of this program. The establishment of a system of independent peer review is important. Results of science and technology and monitoring programs should be published in peer-reviewed journals to the maximum extent possible. Care must be taken, however, not to delay the timely dissemination of data to program stakeholders and the general public through currently established mechanisms as well. Research activities should be relevant to Yucca Mountain and so justified. DOE should also establish an independent technical oversight group and a stakeholder advisory board (see Sections 4.2 and 5.1.3). 4. Even if the U.S. program begins with a reduced-scale pilot stage, DOE should present a safety analysis and a safety case based on the full inventory. If DOE decides to begin its repository program with a reduced-scale pilot stage, it should nevertheless develop both a safety analysis for the Nuclear Regulatory Commission and a safety case for stakeholders and the general public based on a full-inventory repository. A full-inventory safety analysis and a safety case are important to help establish confidence by regulator and the public in the ultimate safety of the complete repository system. The primary differences between the safety analysis and Adaptive Staging’s safety case are that the safety case will be reviewed more often (i.e., at every Decision Point) and that it presents the description of the key safety arguments in a manner accessible to a wider audience. This accessible description is not necessary for the regulator, due to its technical expertise, who can make its judgment on repository safety based on the quantitative and qualitative compliance requirements in the regulations. 5. DOE and the USNRC should work together (without compromising their independence) to ensure that the regulatory process enables the application of Adaptive Staging in the development of the Yucca Mountain Project. The committee believes that the regulatory framework contains adequate flexibility to accommodate Adaptive Staging if the regulator supports this approach. DOE should take the initiative to demonstrate

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the benefits of Adaptive Staging to the USNRC. DOE and the regulator should consider the potential interaction of Adaptive Staging and the regulatory process, including procedures for license amendments. In particular, the USNRC and DOE should have a common understanding of which changes, tests, and experiments can or cannot be made without advance regulatory approval. The USNRC has already identified some changes, tests, and experiments that can be made without advance regulatory approval and has provided decision criteria for these. The USNRC and DOE should consolidate and coordinate broad access to information and stakeholder participation, as well as evaluate opportunities to improve the current practices of DOE public hearings and USNRC licensing actions. Transparency and stakeholder oversight would ensure the independence of the regulating and regulated institutions. 6. DOE should consider the impact of Adaptive Staging on the overall waste management system. Before implementing Adaptive Staging for the entire repository system, DOE should ensure that there is an adequate understanding of the impacts of this approach for buffer storage at the repository and transportation requirements, for activities at reactors, for interim storage elsewhere, and for repository operations. In particular, the requirements for buffer storage at the repository site must be planned in advance. Buffer storage can relieve some pressure on DOE to accept commercial spent fuel as soon as construction authorization is granted. 7. DOE should continue to promote a safety culture throughout the long duration of the Yucca Mountain Project. Adaptive Staging is consistent with the considerable effort that has been devoted to developing a safety culture in the nuclear area (Sections 2.2 and 4.8). The current quality assurance standard for environmental management, ISO 14001, evaluating environmental management systems, has important principles in common with Adaptive Staging. The ISO standard 14001 (implemented at Waste Isolation Pilot Plant) could be an additional useful vehicle for enhancing the safety culture within the Yucca Mountain Project (see Section 4.8). ISO certification could be an important performance incentive for the DOE and its contractors and could be a valuable component in developing public trust by meeting a known and independently accepted standard for environmentally responsible management. 6.12 Concluding remarks The committee debated at great length the originality of Adaptive Staging and the confidence with which it can advocate this approach as beneficial for waste disposal programs in the United States and elsewhere. To the first point, it is important to note that the term Adaptive Staging is used basically as shorthand for a collection of project management components, none of which is new or unique to this approach. Most of the components are to be expected in any major, well-managed project. The committee uses a new term (Adaptive Staging) to emphasize that all of the components should be applied simultaneously within a particular institutional

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culture that encourages continuous learning and that uses iterative review of system safety as the principal guiding mechanism. In discussions about how strongly the committee could advocate the approach described, two opposing arguments recurred. The committee agreed that Adaptive Staging is a prudent approach, in line with the normal tenets of good project management, and can lead to program improvements. The committee recognizes, however, that these improvements will occur only if the implementer’s organizational culture allows changes, and it acknowledges that this approach is untried. These counterbalancing arguments lead to the cautious caveats applied to the committee’s recommendations but should not detract from the consensus reached: because of the distinctive challenges faced in developing a geologic repository program (see Section 1.2.1), and the context in which these must be addressed (see Sections 2.5, 3.1, and 3.2), Adaptive Staging enhances the likelihood of program success.