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4 Impacts of Adaptive Staging on a Repository Program The criteria presented in Chapter 2 (Section 2.5) suggest that a geologic repository program could benefit from Adaptive Staging. Previous approaches to repository development, often based on a Linear approach, have met serious obstacles (see Section 2.7). As noted previously, the committee believes that Adaptive Staging is a promising approach that can increase the likelihood of a program’s success, as defined in Chapter 1. Adaptive Staging is in important ways unproven, both in the context of complex, first-of-kind projects, and for natural resource programs (in which the concept was initially developed). At the same time, Adaptive Staging is similar to staged development of other complex projects, such as the approval of pharmaceuticals, structural designs, and is parallel in logic to open-source software development. The advantages of learning in all these arenas are apparent. The difficulty of implementing Adaptive Staging is not that learning makes sense and is advantageous as compared to Linear Staging. Instead, what is difficult is assuring that learning can be obtained over long time periods and that learning can be used in implementation, and in the face of organizational and political commitments to a Linear model. In addition, deliberate learning requires greater expense for gathering information; it is unclear, however, whether Linear development of a repository under intense scrutiny and conflict incurs any less costs for information gathering and management. The statement of task directs the committee to discuss Adaptive Staging in terms of: repository program, safety, security, regulatory context, and institutional and societal context. The committee identified below knowledge gaps to consider when adopting Adaptive Staging. 4.1 Knowledge gaps There are several knowledge gaps that must be considered when judging whether to apply the principles of Adaptive Staging in repository development. These fall into three categories related to: the effectiveness of Adaptive Staging;
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implementation procedures; and the behavior of the technical and societal environment. 4.1.1 Effectiveness of Adaptive Staging Adaptive Staging is an untried approach. The effectiveness of adaptive approaches, as applied to natural resources management, has been evaluated by Lee (1993, 1999). Lee examined the conceptual, technical, equity, and practical strengths and limitations of adaptive management and arrived at the following conclusions: (1) adaptive management has been more influential, so far, as an idea than as a practical means of gaining insight into the behavior of ecosystems utilized and inhabited by humans; (2) adaptive management should be used only after disputing parties have agreed to an agenda of questions to be answered using the Adaptive approach (this is not how the approach has been used to date); (3) efficient, effective societal learning of the kind facilitated by adaptive management is likely to be important in managing ecosystems as humanity searches for a sustainable economy (Lee, 1999). Hence, though promising in principle, Adaptive Staging has yet to be demonstrated. In addition, there are knowledge gaps on technological, organizational, policy, and managerial factors associated with the ultimate effectiveness of Adaptive Staging. Section 2.6.2 addresses institutional requirements for effective implementation of Adaptive Staging. Examples of key questions are: What is the initial level of public trust and institutional constancy in the implementer? What is the relationship between institutional constancy and public trust? What are the institutional requirements for implementation of Adaptive Staging? What does the implementer need to do to assure that unnecessary delays do not result from Adaptive Staging? What changes does it imply within the culture of the implementer and the regulators? 4.1.2 Implementation procedures In addition to generic knowledge gaps of any geologic repository development program,1 there are gaps concerning the implementation of Adaptive Staging, particularly from an institutional perspective. Examples of key questions are shown here: 1 Examples of knowledge gaps common to Linear and Adaptive Staging are: (1) Will the technology needed to monitor key parameters of repository behavior be available? (2) How extensive, spatially and temporally, should a monitoring program be? (3) Are mechanisms for effective stakeholder and public participation available?
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How are the criteria for moving to a forward stage or reverting to a previous stage determined? How can the implementer and the regulator collaborate to ensure the requisite regulatory flexibility? How are costs estimated compared to a Linearly Staged program? How are public acceptance and institutional performance monitored? How is institutional constancy ensured? How can public trust be maintained and enhanced? How is transparency maintained over time? How might political leaders assure the integrity and constancy of the implementing and regulating institutions? 4.1.3 Behavior of the technical and societal environment Knowledge gaps in the behavior of the technical environment include unknowns about the behavior of the repository and its surroundings and how changes introduced by Adaptive Staging might affect that system. These gaps might lead the implementer to introduce research programs explicitly aimed at clarifying such issues at various stages of repository planning and implementation. Knowledge gaps in the behavior of the societal environment include two main issues. First, there is widespread agreement that public acceptance is indispensable to the success of any program to manage high-level nuclear waste, but there is little agreement on how to obtain it. Examples of remaining key questions are: What is “public acceptance” or “public support”? When is public acceptance attained? What is the relative standing of respective stakeholders? Should all who are recognized by the implementer have equal standing in the decision-making process? If so, by what procedures should preferences be aggregated to inform decisions? (For example, should each citizen’s views be given the same weight as long-standing institutional actors? Or, how are the value differences that define and separate stakeholder groups to be aggregated?) If not all who are recognized by the definition have equal standing, by what principles are different standings accorded to the variety of stakeholders? As for the second issue, there have been few geologic repository programs in which stakeholders or the general public have been engaged in technological decision-making.2 A mechanism for including them in the decision-making process remains untested and thus unknown. However, mechanisms are being debated in many countries (NEA, 2002). In France and England, a neutral institution has been selected or established to act as a mediator between various stakeholders (Depeche Meusienne, 2002; UKCEED, 2000). There is need to investigate organiza- 2 Although there are instances, e.g., in Finland, where stakeholders have taken part in repository site selection.
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tional and social processes important to public trust, institutional constancy, and the sustaining of political support for a decades-long program that will be expensive but virtually invisible unless the program is failing. The committee had neither the information nor the time to identify all knowledge gaps or to propose approaches to address them. Some of the knowledge gaps related to these issues have been discussed in previous National Research Council reports (NRC, 1996, 2001). None of these uncertainties prevents the implementer from applying Adaptive Staging. The knowledge gaps of the last two categories are present whether the implementer uses Adaptive Staging or Linear Staging. A primary reason for adopting an Adaptive Staging approach is that the implementer facing first-of-a-kind challenges can gain experience and thereby improve its program. A guiding principle of Adaptive Staging is that opportunities should be grasped to implement specific scientific or social science research aimed at filling the knowledge gaps, reducing uncertainties, and improving safety. 4.2 Impact on repository program’s phases3 Adaptive Staging affects repository operations, costs, schedules, buffer surface storage, waste transportation, monitoring, and the long-term science and technology program. Just as the individual attributes of Adaptive Staging are not unique to this management approach, some of the impacts discussed below can also result when other approaches are employed. Adaptive Staging also raises important issues concerning safety, security, regulatory processes, institutional requirements, and societal interactions. The committee assesses whether this impact is advantageous for geologic repositories. In some cases the impact of Adaptive Staging may be empirically determined through implementation rather than by theoretical studies. Both Linear and Adaptive Staging begin with a planned a course of action divided into stages. Unlike Linear Staging, Adaptive Staging uses a reference framework that is flexible and incorporates Decision Points between stages (see Section 2.3). Throughout Adaptive Staging and in particular during the consultation and evaluation processes at Decision Points, the implementer incorporates all attributes of Adaptive Staging: commitment to systematic learning, flexibility, reversibility, transparency, auditability, integrity, and responsiveness. New knowledge, continuously incorporated into the program, is used to guide the formulation of a next stage most suited to moving the program toward its goals. Planning also includes defining roles and mechanisms for interested and affected parties (e.g., implementer, regulator, stakeholders, and the general public) involved in the program. From the beginning, these parties must be aware of the definition of program success, acknowledge that there may be a number of unresolved issues at each stage, and recognize that program adjustments may result as knowledge is improved. The roles of implementer and regulator are described throughout this chapter. Possible roles for stakeholders are sketched below. 3 The statement of task directs the committee to address operational phases, beginning with licensing. The impact of Adaptive Staging on site characterization and selection are not addressed.
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The implementer could work with the affected state(s) and/or with regional or local communities to establish a technical oversight group and a stakeholder advisory board; both groups are independent from the national government. These groups can provide independent technical and non-technical analyses of, and advice on, the repository development program. The technical oversight group and the stakeholder advisory board differ in scope of responsibility and nature of membership. The stakeholder advisory board could work in an advisory capacity to the implementer and serve as a forum to allow project management to engage in dialogue with members of external communities, to improve mutual understanding, and to promote consensus on issues of concern. The technical oversight board would advise on scientific and technical aspects of the program, such as implementation stages (e.g., repository construction and waste emplacement) and the long-term science and technology program. In these roles, both groups would participate as needed in Decision Points. The work of the technical oversight board would, perhaps, overlap to some degree with that done by existing review groups appointed by the national governments (e.g., the Nuclear Waste Technical Review Board in the United States, the Radioactive Waste Management Advisory Committee in the United Kingdom, the National Council for Nuclear Waste in Sweden, and the Commission Nationals d’Evaluation in France). However, the independent technical oversight group would focus on local and regional issues and its input would be directly integrated into Decision Points by the implementer. Membership of the technical oversight group could include independent technical experts in disciplines relevant to repository development, including the social sciences, appointed by and reporting to an entity not directly connected with the program. The identity of this entity would be determined for example, through negotiation with affected local institutional stakeholders and the national government. On the other hand, stakeholder advisory board would represent stakeholder interests. Membership could include representatives from institutional stakeholders and other stakeholder groups—such as local institutions, local and affected governments, universities, as well as representatives from the industry, non-profit, and labor organizations—with the choice of members being made by these institutions. As with Linear Staging, the implementer presents to the regulator a reference repository design to obtain construction authorization. With Linear Staging this design is fixed and does not account for the possibility that knowledge gained can change the design (unless an event makes the change unavoidable). With Adaptive Staging there are different possible end points in a reference framework. Parties acknowledge that the design can be changed and optimized as experience is gained. The reference design with Adaptive Staging can include test and pilot facilities where reference and alternative design can be tested. Both Linear and Adaptive Staging reference designs can be changed through license amendments, but under Adaptive Staging the regulator acknowledges the possibility of changing the repository design after the first license is granted. Another difference between Adaptive and Linear Staging is that with Adaptive Staging if flexibility and reversibility are maintained in the reference framework, agreement on goals is sufficient. In the planning that leads to the reference framework the implementer performs careful analysis of the implications of proposing alternatives (including reversibility) at each Decision Point. There are at least two types of planning involved. The first type concerns programmatic goals; analysis of each alternative is integrated with such considerations as costs, schedules, buffer storage requirements, and transportation plans. The second type addresses the technical and societal environment
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in which the project must be developed (regulatory constraints and institutional and societal considerations). The committee terms this planning “systemic.” Examples of planning activities that the implementer undertakes to establish the reference framework using Adaptive Staging are as follows: Programmatic planning Planning stages and Decision Points (with the understanding that they may be changed). Identifying foreseeable alternatives in the reference framework and their implications. Considering reversibility and implications thereof.4 Planning the licensing strategy. Identifying foreseeable knowledge gaps and learning opportunities. Planning a long-term science and technology program to address technical knowledge gaps. Expanding the monitoring program to assess pre-closure and post-closure performance and to address technical, societal, and institutional knowledge gaps. Integrating the transportation program with the reference framework and its alternatives. Considering the surface storage capability needed to ensure flexibility and reversibility. Planning incorporation of new knowledge from in the program and from outside sources. Systemic planning Working out an agreement with the regulator on licensing strategy. Identifying safeguard vulnerabilities. Identifying learning opportunities, including social and institutional sciences. Planning research in social sciences to address societal and institutional knowledge gaps (see Sidebar 4.1). Identifying roles of a stakeholder advisory board and a technical oversight group as well as mechanisms for input in decision-making (see Sidebar 4.2). Of course, Linear Staging also can involve similar programmatic and system planning. The key difference with Adaptive Staging is that, although the reference framework is the most likely path to program’s success, at the outset of the program all parties acknowledge the possibility for changes in light of new knowledge, if warranted. 4.2.1 Impact on licensing, construction, and the early operational phase Adaptive Staging has impacts on the licensing, construction, and early operational phases through: 4 The Nuclear Energy Agency suggests: “Reversibility may be facilitated, for example, by adopting small steps and frequent reviews in the program, as well as by incorporating engineering measures” (NEA, 2001 b, p. 11).
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Sidebar 4.1. Focused Social Science Research as an Integral Component of Adaptive Staging The implementation of Adaptive Staging emphasizes continuous, systematic learning in both technical and societal areas. Indeed, key features of Adaptive Staging are its explicit provision for societal and institutional learning, in parallel with scientific and technical learning, and the incorporation of the combined learning into the Decision Points. Consequently, various sections of this report outline a range of societal and institutional issues that need to be addressed to implement Adaptive Staging most effectively. Operationally, the inclusion of these societal and institutional issues requires a social science research and development (R & D) effort parallel to the science and engineering R&D. The social science research program is intended to provide information and analyses on: organizational and operational characteristics of a radioactive waste management program, institutional characteristics that are needed to ensure confident performance for many management generations, institutional and organizational factors affecting cost and risk estimates, and budgetary and regulatory accountability, and processes for public engagement, input, and feedback. The program comprises study of the following key elements: Operational characteristics, focusing particularly on the information, data, and other evidence to assess the administrative character of the overall repository system. Specific research tasks include the study of: The extent to which high levels of reliability in operations are required throughout the repository system, and the changes in current practices (including the provision for a continuous, committed management structure) needed to develop sustained and safe operations. The mechanisms most appropriate for societal monitoring of repository development, performance confirmation, and ensuring the transparency and auditability of repository construction and operations. The changes that may be needed in the affected regulatory and oversight communities to accommodate the increased movement of radioactive materials in a long, extended process that will challenge multiple management generations. This would include the potential changes in waste transportation systems and the special accommodations, if any, for current and future vehicles, rail yard master systems, and highway management systems. Institutional Characteristics, emphasizing the contexts, rules, and practices that determine organizational effectiveness and the significant role
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played by the external environment in shaping organizational performance. An understanding of these characteristics can be pursued through study of: The institutional conditions necessary to sustain trust throughout the decades of repository operations and the centuries following repository closure. The incentives and processes needed to assure stakeholders, the implementer, and governmental agencies that contractors and operators will rise to the level of competence and transparency that are needed to gain and maintain trust across the generations inherent in radioactive waste management systems. Baseline levels and trends in the external social, cultural, and political environment, such as: the levels of public trust or the activity of social movements, the shared beliefs about technology, or the changing dynamics of geopolitics (e.g., terrorist threats) likely to impact repository construction or operations. The institutional and organizational factors affecting the basis for costs and risk estimates, and budgetary and regulatory accountability, including the capacity to make reasonable estimates and to take appropriate actions. Specific lines of research include: The means to develop a credible data basis for cost estimates (including social costs) and for repository system performance evaluation that take life cycle operations into account. The assembly and collection of data and analyses of perceptions of risks and institutional trust, the changes in such perceptions, and the sources of those changes. Public understanding and engagement, emphasizing a two-way process of communication and transparency to enhance chances of public acceptability. Research could be devoted to the following tasks: Determining the relative efficacy of alternative methods for engaging independent bodies and stakeholders to assess the development and operational phases of radioactive waste management programs. Identifying the most effective communication mechanisms for the sharing of relevant information among institutional stakeholders, stakeholders, and the public. Managing and coordinating the different streams of knowledge and learning—technical, procedural, and social. Determining the most effective mechanisms of public engagement, based upon systematic field experiments. Establishing baselines followed by continuous monitoring of public attitudes towards the repository and its operations, while tracking the sources of change and their responsiveness to performance confirmation, to management practices, and to other elements of transparency. How can a social science research program, such as the one above, contribute to the success of Adaptive Staging? It can contribute to the learning
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process, inform caution, supply perspective, provide understanding of necessary institutional enhancements, and establish procedures for improving the chances of public acceptance. The unprecedented time during which the repository will remain open—likely longer than the entire history of industrial economies—provides an unusual opportunity for social and institutional learning. Social science data and analyses can point to social and political fault lines that caution against misguided beliefs about institutional capability and public acceptance. The continual engagement of stakeholders and the public in the process of Adaptive Staging will ensure that their interests and concerns are not ignored at Decision Points about directions between stages. The success of Adaptive Staging is highly dependent upon institutional constancy and management continuity, requisites with an incipient understanding in the social science literature and amenable to more focused research. The extended time over which the repository will remain open affords the opportunity to experiment with, and adopt mechanisms of, public participation that ensure broad enfranchisement and legitimacy, thereby improving chances of public acceptance. Social science research has already contributed significantly to an understanding of the dynamics of the application of science and technology in the public sphere. It has demonstrated the importance of transparency and sustained engagement with concerned stakeholders to avoid policy gridlock while establishing the trajectory of future research. For example, it can provide economic and decision analyses to estimate the costs of Adaptive Staging, can point to its legal vulnerability, and can estimate the savings from avoiding path dependent, large-scale mistakes. There is, too, a sizable and rapidly growing literature on the translation of science into public policy and on mechanisms of public participation in that policy. Based on the above reasoning, the proposed program of social science research, with its provision for societal and institutional learning, for increasing trust in implementing institutions, and for testing methods for stakeholder and public involvement, can enhance knowledge of the societal and institutional context of Adaptive Staging and thus increase the chances of repository program success. test facilities; pilot facilities; and demonstration facilities. Test, pilot, and demonstration facilities are discussed below (see also Appendix G). Test facilities. The test facility is devoted to short- and long-term scientific experimentation aimed at improving scientific understanding, testing repository behavior, and providing contingency options without disrupting operations or compromising the integrity of the repository (EKRA, 2000, 2002). Test activities are also designed to anticipate changes in the characteristics of waste (e.g., different radioactivity content or thermal output). Repository-specific test facilities are located in the same host formation as the repository, but they are kept physi
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Sidebar 4.2 Mechanisms of Public Engagement and Participation The social science component of the pilot stage could be devoted to testing alternative mechanisms for public participation. The evaluation process should lead to informed decisions over which mechanism or mechanisms might best satisfy the need for public involvement in implementing a geologic repository. The mechanisms selected would be incorporated into the full-scale operational phase. Pilot social science research should include evaluations of testing mechanisms for stakeholder participation and the development of techniques for monitoring changes in public confidence, trust, and institutional constancy (see Sidebar 4.1). Examples of learning opportunities about participation mechanisms and techniques for stakeholder engagement are: The continued engagement of the stakeholder advisory board during the pilot, the demonstration, and subsequent stages that would: interact with the technical oversight group; review new information collected and take part in the evaluations of stage performance; have input at decision points about how to proceed when a stage is completed; and advise on the pilot experiments of public involvement mechanisms. The establishment of a social science component to the overall science program to: systematically monitor the societal, economic, and political contexts of stage implementation (thereby providing an early warning system of potential fault lines); and develop the program of experiments in the pilot stage to narrow down the number of public involvement mechanisms that would be implemented in the demonstration stage. cally separate from the actual disposal areas to avoid compromising the integrity of the repository or interfering with construction or operations. Tests begin before the design is completed and can continue throughout the repository program until no further significant knowledge can be gained. Example activities may include testing of: alternative repository designs waste configurations thermal operating modes and strategies to change them new technologies for waste handling and emplacement operations thermal effects on the host rock stress response of the system (by using temperatures beyond the reference design) repository failure modes and weaknesses new materials for engineering barriers and backfills new monitoring technologies.
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Tests can stress the components of the safety system beyond their design envelope or even to failure. The purpose is to study a full range of system behaviors. Parallel to the scientific experiments should be societal research whose goal is to test alternative mechanisms for public participation. To ensure transparency, results from such a research program are shared with the stakeholder advisory board and the technical oversight group, who can also provide input on research activities. • Pilot facilities. The purpose of a pilot facility is to test and evaluate the selected design and operating mode and to gather operational experience that can help to optimize full-scale construction and operation. The pilot allows improvement of safety and efficiency, as well as incorporating societal learning into the process. Pilot tests are not intended to deliver significant information on the long-term behavior of the repository system. Pilot activities are carried out in configurations increasingly close to those foreseen for the final facility. For instance, pilot activities can begin with non-radioactive waste before the license is obtained and continue with radioactive waste thereafter. At the end of the pilot stage a decision is made to affirm or revise the reference design and operation mode. This process may require a temporary delay in waste emplacement activities or even another pilot stage to confirm the expectation of the revised design and operation mode, if the information gathered during the pilot deviates from expectation. The full-scale operation may continue without any delay if the system performs as expected. A delay in the pilot stage need not delay waste shipments from generator sites if the implementer plans for a sufficient surface buffer storage capacity at the repository site. Pilot activities cease with the selection of the reference design and operation mode. To ensure transparency, the decision-making process to begin and cease pilot activities is shared with stakeholders, the technical oversight group, and the regulators. Engineering pilot-scale activities are a normal feature of major technology developments. The committee uses the expression “pilot activities in social sciences” to indicate social science work taking place during pilot engineering activities (such as pilot construction, emplacement, or closure). Pilot activities in this sense could include experimentation to determine the public involvement mechanisms most likely to be effective. • Demonstration facilities. Test and pilot activities are performed primarily to help the implementer develop and/or optimize the repository system. Demonstration activities, on the other hand, aim at increasing technical and public confidence in the chosen design and operation mode. The purpose of such a facility is to demonstrate a realization of the intended design of the repository and to allow particularly comprehensive monitoring of components and systems (e.g., emplaced canisters or borehole and tunnel seals) during the multi-decade operating life of the repository. Demonstration activities occur in parallel with repository operation until final closure. Demonstration activities can be initiated only when the reference disposal configuration has been defined (i.e., after the pilot stage). The pilot facility itself may become a demonstration facility. Demonstration facilities may be separated from the main disposal areas to carry out intensive monitoring activities that could otherwise compromise the integrity or operation of the full repository. Examples of demonstration activities include: monitoring to demonstrate that the waste or the surrounding rock is not being subjected to unacceptable thermal effects; monitoring to demonstrate that no unanticipated corrosion mechanisms affect the containers; and monitoring to
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integrating the scientists’ input into the monitoring program. In Linear Staging the role of a science and technology program, particularly after licensing, might be viewed as minimal. While some research might continue to confirm repository behavior, the emphasis is on implementation of the reference case with the minimal changes. For example, the choice of a waste packaging material becomes fixed once a license is issued. Therefore, further research on packaging material is not needed. With Adaptive Staging, the waste packaging material compositions and properties become the subject of review if new information justifies it. The four possible outcomes of the review are: (1) judging the previously chosen materials to still be the best available; (2) using a different or a better material in the future; (3) replacing material already in place in the repository; or (4) taking no action until more information is available. A better material can be one that yields substantial savings, even if overall repository performance is not improved. A robust, sustained science and technology program is consistent with the commitment to the systematic learning attribute of Adaptive Staging. The long-term science and technology program reflects the implementer’s questioning attitude, searching for vulnerabilities and better approaches to achieving repository goals. In Adaptive Staging, a long-term science and technology program is needed to: (1) reduce known uncertainties;11 (2) develop the capability for responding to “surprises” (i.e., unknown uncertainties or discoveries);12 and (3) improve or identify weaknesses of the safety case (and help address them) by providing additional evidence that the repository is behaving as predicted; and (4) further develop, refine, or test aspects of the performance assessment methodology.13 The long-term science and technology program focuses in part on hypothesis falsification. If the hypotheses14 are not verified and new information has a significant effect on safety or confidence in safety, then either a) the program is revised, possibly by reverting to an earlier stage, or b) the safety case is changed in light of new information (e.g., showing that a worrisome failure scenario is in fact impossible). A viable science program will assess the consequences of an unverified hypothesis. If consequences have no bearing on safety or are only of academic interest, then no response is needed. Making changes in light of evidence that casts 11 Examples of known uncertainties include: corrosion of spent fuel and glass; thermodynamic properties of geologic materials; behavior of geologic materials and natural barriers; and processes, mechanisms, and pathways that control groundwater flow. 12 Examples of research capabilities for responding to unknown uncertainties include: research on new types of waste forms and waste packages materials, monitoring technologies, storage and retrieval of data over long time scales, and/or new types of public involvement mechanisms. 13 For example, some underlying conceptual models can be tested and evaluated by analysis of natural systems that are analogs to the repository system. Examples of natural systems used for comparison include the groundwater composition at the uranium ore deposit of Bangombé (Jensen et al., 2002) and the loss of minerals at the Peña Blanca uranium ore deposit (Murphy and Cadell, 1999). An extensive database that can be used to compare code results with observed data is available in the literature. 14 For example, hypotheses in geohydrology, engineering, societal context, security, and costs can be subject to hypothesis falsification.
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doubt on a hypothesis is a matter of standards of disproof; these standards could be established by mechanisms such as peer review or repeated testing and re-assessment within the scientific community. The science and technology program can also assist in improving institutional relations, and perhaps public confidence, by obtaining information important to stakeholders and the general public. In the committee’s opinion, a strong science and technology program is needed not only at the beginning of a program but also throughout the entire project, at least until closure and possibly after closure as well. Continued improvement of methods and techniques will likely allow better data to be included in the program. Adaptive Staging acknowledges the possibility for unanticipated events during the course of repository development and is prepared to address them by maintaining a research capability throughout the repository program. Research capability means that the implementer has an ongoing program that focuses on the most likely areas of need. To be effective, the science and technology program must be a long-term effort that maintains continuity of purpose and encourages tenure of technical and management personnel. Therefore, Adaptive Staging requires leadership to maintain the institutional capability to conduct such a science and technology program over the relevant time periods. It also requires hiring and retaining qualified scientific staff to function as a sustainable pool of knowledge for long-term science and technology programs. It requires a highly qualified staff to analyze and interpret data collected by the monitoring program and to provide input and feedback into the monitoring program. Hiring and retaining a body of highly qualified scientists increases program costs. Maintaining a long-term science and technology program can be challenging when competing with budget allocations for pressing operational issues. 4.8 Impact on safety Adaptive Staging has the following impacts on safety: it raises the importance and requires frequent updates of the safety case and encourages continuing open review of the safety case, leading to improvements of the repository system or even to rejection of an unsuitable site; and it takes a more cautious approach to radiation exposure control and accident risk for workers. Safety refers here to worker and public safety. A key feature of Adaptive Staging is the iterative review of the safety case. At Decision Points between stages, the implementer conducts a systematic re-evaluation of the safety case when relevant new information is gained during the previous stage. Even when no new negative information is gained, the review provides additional confidence that the adopted design is satisfactory. When improvements are in order, they can be implemented as part of the normal course of operations and not viewed as a detrimental deviation from previous plans. The re-evaluation of the safety case, in turn, serves to guide the collection of data in a subsequent stage. A critical aspect of safety case review is that the program not only specifies new data to collect but also allows for hypothesis falsifica-
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tion and testing concerning repository performance. Over time as stages are completed, the ability of the program to predict performance improves. This improvement, in turn, increases confidence in the robustness of the safety case. The committee re-emphasizes that the re-evaluation of the safety case neither implies repeated questioning of earlier decisions, nor necessarily leads to a pause in program activities, and in no case is it an excuse for unnecessarily delaying decisions. Its purpose is to examine the current situation to know how to proceed, not to belatedly question how one arrived at the current situation. The implementer ensures that any major changes in original program goals or strategy are based on new knowledge and new understanding of the system and not from incremental changes. The activities associated with the construction and operation of a geologic repository are extensions of familiar industrial activities in mining, handling heavy equipment, and handling substances that emit strong ionizing radiation. The unique aspects in repository operations are that the heavy waste packages that emit the radiation must be removed from a controlled shielded environment at the surface to the underground drifts (shielded or unshielded). To some extent remote-handling techniques may be required. These activities can begin in a pilot stage, first using simulated waste and then actual waste to develop the best techniques for handling the waste effectively, while keeping worker radiation exposure as low as reasonably achievable (ALARA). These techniques are then used for the full-scale waste handling and emplacement. The use of pilot facilities is also valuable for minimizing the risk of industrial accidents, a serious concern for heavy operations in a repository. The development of low-risk designs and procedures requires the development of a safety culture in repository management and workforce (see Section 2.2). Experience with large industrial operations and with operating repositories, such as the Waste Isolation Pilot Plant, show that hazards and accidents can be minimized when the management and workforce adopt a safety culture that puts safety at the forefront of operations. With Adaptive Staging this safety culture permeates the management of the implementer and its workforce, and contractors. Management implements incentives for the workforce to ensure that employees remain involved in the safety program. Safety management tools already exist; for instance, the environmental management standard ISO 14001 is used in a number of facilities (e.g., in the Waste Isolation Pilot Plant in the United States and in the Swedish program). These tools incorporate many of the attributes of Adaptive Staging. They promote continuous learning and periodic re-evaluation, provide for independent auditing and reporting, and are a way to provide transparency in the important issue of operational safety (ISO, 1996a, b). When these attitudes are instilled into the physical aspects of the operation, they become part of the safety culture of the organization, leading to a pervasive questioning attitude about how and why things are done. Management and workers look for vulnerabilities in the present mode of operation and develop a conduct of operations that will ensure continuous safe behavior. 4.9 Impact on security The committee identified no significant negative impacts of Adaptive Staging on security. There are two fundamental issues to address when considering the impact
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of Adaptive Staging on the security of any country. First, for countries whose national security depends on nuclear activities there must be a secured management process in place for handling waste. Thus, there are national security implications arising from the disposal of some defense-related high-level radioactive waste when such waste contains such materials as highly enriched uranium or plutonium. The Adaptive Staging approach offers additional flexibility before emplacement to choose or blend wastes according to their security requirements or their radioactivity content and thermal throughput. Following the tragic events of September 11, 2001, attention must be given to the impacts on program goals and objectives that relate to security of radioactive wastes and the increased awareness of their vulnerability to terrorism. A number of organizations and individuals have raised issues with regard to security that may have a direct or indirect bearing on repository programs. Among these are potential vulnerabilities at generator sites, particularly spent fuel in pool storage at nuclear power plant sites, and vulnerabilities during transportation of spent fuel from plant sites either to a consolidated interim storage facility or a repository. These issues have been discussed in a recent National Research Council report on counter-terrorism (NRC, 2002b). As noted previously, Adaptive Staging can slow the initial pace of underground waste emplacement. At the very least, it removes the certainty of placing the high-level waste underground by a given date. The inevitable pressures to accelerate the emplacement of waste, due to nuclear proliferation or terrorist concerns, counters the tendency of Adaptive Staging to proceed in a more deliberate and cautious manner. Adaptive Staging may lead to longer periods in which the waste is more accessible to humans. If the time scales become very long (decades to centuries), then institutional stability cannot be guaranteed. In this case, security could become a concern. However, even under the most optimistic waste emplacement schedules, significant amounts of wastes are likely to remain at reactor storage sites for decades.15 Furthermore, waste must be transported to the repository site regardless of how the repository program is organized. If rapid removal of high-level waste from surface storage at reactor sites is considered to be necessary to address terrorist threats, then other solutions beyond a geologic repository program will have to be considered. From this perspective there appears to be no significant difference in impact on security between Adaptive Staging and Linear Staging. 4.10 Impact on the regulatory framework Adaptive Staging has the following impacts on the regulatory framework: it increases regulatory review steps; it requires flexibility from the regulator in formulating and applying regulation; it requires flexibility in the license amendment process; it provides the regulator with increased flexibility to amend regulations if experience warrants; and 15 In the United States anticipated quantities of spent nuclear fuel exceed the statutory limit of the proposed repository at Yucca Mountain (see Chapter 5).
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in enhances stakeholder confidence in the regulatory process by increasing transparency. To the extent that repository design, construction, and operation options are kept open beyond the initial license application, the licensing process with Adaptive Staging might become more complex for both the implementer and the regulator— for example, if the implementer builds into the license application mechanisms to change the repository design and operating modes on the basis of information gathered during the early operational phase. In spite of the added complexity, Adaptive Staging may be beneficial to the regulatory framework. Regulating a first-of-a-kind repository is a process of gradual learning and refinement. This is recognized by the French safety authorities who have prepared a series of non-mandatory basic safety rules (règles fondamentales de sûreté) designed to evolve as new information becomes available. It is unrealistic to expect that a regulator can set forth regulations that would govern activities for over a century with no need for modification. For example, in the U.S. during the 20 years since enactment of the Nuclear Waste Policy Act, there have been at least two major changes16 in statutory requirements and major changes in the regulations promulgated by the Environmental Protection Agency, the Nuclear Regulatory Commission, and the Department of Energy. The knowledge available at the time of construction authorization is less complete than in subsequent phases. The Adaptive Staging approach encourages the acquisition of additional knowledge and allows regulations to develop and to take account of new knowledge gained during the multi-decade repository development program. Adaptive Staging may, therefore, address the challenge of the “regulator’s dilemma,” which refers to the challenge of making regulatory decisions in the presence of uncertainties, some of which are not resolvable (NRC, 2001). The staged approach to licensing allows the implementer to expand, and the regulator to review, the knowledge base and the safety case at each licensing phase. Adaptive Staging emphasizes the importance of providing a traceable and auditable record of decisions, thereby increasing the transparency of the licensing process. The regulator and implementer, therefore, have the opportunity to strengthen stakeholder confidence that the program is based on a robust disposal concept, good engineering and technology, and a suitable site. Even when a particular country’s legal system requires prescriptive regulations for a repository, there is normally sufficient scope for flexibility at the level of detailed regulatory guidance, decision-making, and inspection programs. Adaptive Staging can be compatible with a regulatory system if that system is flexible and responsive to change. Adaptive Staging can be effectively applied only if the license amendment process is not overly complex or long, and the implementer has the possibility, if justified, to continue the program during the amendment process. 16 The statutory changes are the 1987 amendment of the Nuclear Waste Policy Act and the Energy Policy Act of 1992.
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4.10.1 Regulatory obstacles Adaptive Staging may place obstacles in the regulatory process for both the implementer and regulator (e.g., NRC, 2001). From the implementer’s point of view, Adaptive Staging may be seen as causing more intensive regulatory oversight, which may delay the repository program. From the regulator’s point of view, Adaptive Staging requires flexibility and acceptance of the uncertainty involved in permitting or licensing individual stages in a somewhat open-ended program, albeit one supported by a safety case for a full repository. The following are examples of regulatory drawbacks: the alternative designs proposed in the license application may generate controversy about when construction would be considered substantially complete; and if the licensing process freezes the repository design and its safety case, the implementer cannot further develop this design during the regulatory review process. If new information warrants a change to the reference design, the implementer must then request a license revision, which could extend significantly the review schedule. 4.10.2 Regulatory advantages Adaptive Staging also has several regulatory advantages (e.g., NRC, 2001): It may bring additional information to the regulator about the strengths and weaknesses in the safety case, thereby allowing the regulator to make decisions on the basis of better evidence. As stated in regulatory documents from many countries (USNRC, 1998; ERA, 1999; HSK/KSA, 1993), proof that the proposed geologic repository meets any specific set of regulatory standards cannot be demonstrated in the ordinary sense of that word. In Adaptive Staging, this fact is accepted and communicated to regulators, implementers, stakeholders, and the general public. In turn, these parties can help identify additional uncertainties and suggest ways to address them. In this context, Adaptive Staging may provide additional confidence to stakeholders. The openness inherent in Adaptive Staging may increase public trust in the regulator and by extension in the repository program. The regulatory body’s ability to adopt and utilize a less prescriptive system that involves more judgment is tied to the degree of trust that body enjoys with the broad public. The more trust, the more deference is afforded the regulatory body to exercise judgment instead of relying on prescriptive “yes or no” findings, and the more likely is public acceptance of the regulator’s decisions. 4.11 Impact on the institutional and societal context Adaptive Staging has the following impacts on the institutional and societal context:
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opportunities for societal and institutional learning; opportunities to increase trust in the implementing institution; and opportunities to test mechanisms for stakeholder and public involvement. A change of the implementer’s organizational culture may be required to implement Adaptive Staging in the repository program. 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. In recent decades, managers of large-scale technological systems have often encountered societal and political resistance, which generates gridlock. The management of nuclear waste is an example of technology gridlock. No country has achieved a satisfactory solution to the disposal of high-level waste, despite considerable and costly efforts (NRC, 2001; Rosa and Clark, 1999). However, sustained progress in some countries provides indications that programs may succeed. One cause of gridlock is lack of public trust. Public acceptance of the choice for disposal of high-level nuclear waste depends on trust in the implementer and the regulator. Lack of trust is, in part, a result of the gap in technological understanding between scientists and lay people. One of the challenges to implementers and regulators is the inherent asymmetry in trust. 4.11.1 Mechanisms for stakeholder involvement Stakeholder input to the decision-making process is of paramount importance for effective implementation of Adaptive Staging. Adaptive Staging encourages and explicitly calls for interaction with stakeholders and the general public at Decision Points (see Figures 2.1a, b, and c). The 1996 National Research Council report, Understanding Risk, concluded that active public participation from the outset and throughout the decision-making process is essential to managing risks (NRC, 1996). That report makes explicit the delineation of the relationship between analysis and deliberation and the central role played by interested and affected parties. Adaptive Staging’s Decision Points have elements in common with the deliberative-analytic process described in the 1996 report. The same report also discusses challenges of including stakeholders in the decision-making process. This challenge is summarized in the recommendation to “get the right participation and get the participation right.” Getting the right participation means that the decision-making process should have sufficiently broad participation to ensure that important, decision-relevant information enters the process, that all important perspectives are considered, and that the parties’ legitimate concerns about inclusiveness and openness are met. Getting the participation right means that the decision-making process should satisfy most parties, including stakeholders, that it is responsive to their needs; that their information, viewpoints, and concerns have been adequately presented and taken into account; that parties have been adequately consulted; and that their participation has been able to affect the way risk problems are defined and understood (NRC, 1996; p. 7). The need for public confidence to achieve successful implementation of radioactive waste management is also recognized by the International Association for the Environmentally Safe Disposal of Radioactive Materials (EDRAM):
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“There seems to be a widespread awareness among EDRAM members that greater public confidence is needed for the successful implementation of radwaste [radioactive waste] management. The stepwise approach has been adopted to varying degrees, and there is a growing awareness that it will facilitate the work involved in gaining public confidence… Most of the EDRAM countries share an emphasis on the need for public acceptance of the radwaste management system, and different methods are suggested for creating public confidence: good relations with the public, creation of local partnership with different stakeholders at local level, transparency in the decision-making process, public review of documents and plans, distribution of materials to all parties and the creation of information strategies, local information offices at feasibility study sites and site tours, changes in internal organisation to make openness the key concept for all employees, feedback mechanisms for every phase of the process, issue-specific voting and the creation of ad-hoc groups for discussion, stepwise and flexible approach involving discrete and explicit implementation steps, progressivity and reversibility of the implementation process, retrievability of the waste, postponed final decisions, which means that there is ample opportunity for knowledge dissemination, discussion, and reflection” (EDRAM, 2002; pp. 13–14). The above list bears many similarities to Adaptive Staging. Adaptive Staging can address the issue of public acceptance because of its cautious approach, its structured flexibility, its scheduled periods for reflection and decision-making, and its openness to assimilating all relevant data—including societal and political data. Specifically, Adaptive Staging’s attributes of flexibility, transparency, auditability, and responsiveness provide a set of principles and a mechanism for interactive, iterative stakeholder involvement. The committee is not in a position to specify the appropriate “mechanisms” ensuring effective stakeholder and general public participation. Adaptive Staging provides opportunities to test the effectiveness of possible methods for stakeholder involvement. The committee suggests that a stakeholder advisory board be formed and a research program formulated for determining the optimum mechanism for public participation (see Sidebar 4.2). The committee acknowledges that changing methods of stakeholder and/or general public involvement can undermine the implementer’s or regulator’s reputation for constancy and consistency. Parties who are not already involved in the program are an important audience for an organization’s behavior. It is especially difficult to educate this more distant audience about the experimental character of an organization’s behavior. Therefore, social science work needs to be an integral component of the overall process of developing a successful repository program. In parallel with engineering activities and throughout the program phases, social science work is also included in Adaptive Staging.
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Adaptive Staging addresses the challenge of public concern and controversy by providing opportunities for the implementer to demonstrate competence and integrity. Adaptive Staging can also provide additional opportunities to build public trust in the capabilities of the implementing institution to fulfill very long-term responsibilities. Finally, Adaptive Staging’s commitment to systematic learning in the social sciences recognizes directly that implementing a repository presents both societal and technical challenges. It is impossible to foresee the outcome of Adaptive Staging on public concerns, any opposition, or controversy. The following are examples of possible negative outcomes: Adaptive Staging may be perceived as self-serving. That is, stakeholders may perceive Adaptive Staging as a stratagem to develop a specific site or to begin waste emplacement prematurely, thus decreasing trust. Experimentation with mechanisms of stakeholder involvement may undermine public trust by showing the implementer to be an organization that lacks constancy. Adaptive Staging provides stakeholders opposed to the repository program additional opportunities to deliberately delay the program (with obstructions at Decision Points). Public trust in the institution may never be achieved, even if adaptable staging is implemented, especially if there already exists a climate of institutional distrust. 4.12 Summary of potential benefits and drawbacks of Adaptive Staging Do the benefits of Adaptive Staging outweigh the potential drawbacks for the implementer? Potential benefits and drawbacks of Adaptive Staging compared to Linear Staging are summarized below. 4.12.1 Potential Benefits of Adaptive Staging The committee’s position in favor of Adaptive Staging is based upon the following considerations: Programmatic: Adaptive Staging is a logical approach for managing complicated projects. When the project is divided into smaller stages with the possibility of reversal, the decision-making process can become more manageable. Adaptive Staging allows decision-making only on those stages of repository development where knowledge is available (near-term stages), thus keeping options open for the future. Its flexibility attribute could help the implementer react to unavoidable “technical surprises” and unavoidable political, economic, or societal surprises. Its incremental nature could also help the implementer identify problems early, problems that may become difficult to rectify at later stages. It also allocates sufficient effort and time for quantification and analysis of the relative risks of different options.
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Technical: Adaptive Staging allows for learning and incorporating new technical data not only throughout repository development, but also after the waste is in place. For instance, it encourages the implementer to develop long-term monitoring and science and technology programs. Data from these long-term programs could improve scientific and engineering understanding of the repository system behavior. Regulatory: Because of Adaptive Staging’s increased number of transparent, auditable Decision Points, regulators are able to evaluate the program more often. Adaptive staging provides the regulator with better oversight of the repository design, operations, and safety. Institutional: Adaptive Staging could help build public trust in the capabilities of the implementing institution to fulfill very long-term responsibilities because it allows many opportunities for the implementer to demonstrate competence and integrity. Societal: Allowing stakeholder participation in the decision-making process can make the repository program more credible and trustworthy. Previous National Research Council committees have discussed the benefits of broad public participation in governmental agencies’ decision-making processes (NRC, 1994, 1996, 2001). 4.12.2 Potential Drawbacks of Adaptive Staging The committee also has identified potential programmatic, technical, regulatory, institutional, and societal drawbacks of Adaptive Staging: Programmatic: Adaptive Staging calls for financial investments without a “guarantee” that any of the potential future stages in the process will be reached. Adaptive Staging may also extend the time scale needed for full-scale operation of the repository, thereby changing surface buffer storage requirements and other factors, such as costs. Adaptive Staging may also encourage funding organizations to release funding only in limited allocations that can make the implementer’s planning more difficult. Technical: Adaptive Staging may lead to longer periods in which the waste is more accessible to humans. If the time scales become very long (centuries) then institutional stability cannot be guaranteed. In this case, workers could be exposed to higher doses of radiation and security concerns could increase. Regulatory: More intensive regulatory oversight may delay the repository program. Moreover, Adaptive Staging requires flexibility and acceptance of the regulatory risks involved in permitting or licensing individual stages in an open-ended program. Institutional: Stakeholders may perceive Adaptive Staging as a stratagem to develop a specific site or to begin waste emplacement prematurely, thus decreasing trust. Public trust in the institution may never be achieved, even if Adaptive Staging is implemented, especially if there already exists a climate of institutional distrust. Adaptive Staging may require changes in the culture and management practices of the implementer that may be difficult to achieve in practice. Societal: Implementers are often strongly technically oriented; therefore, commitment to social science research and to the development of effective
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mechanisms of public participation may require efforts by both the implementer and stakeholders. Stakeholders opposed to the repository project may have additional opportunities to deliberately delay (physically or legally) the program. On balance, the committee judges that the potential advantages of Adaptive Staging outweigh these potential drawbacks. As noted in Section 1.2, the committee believes that the features of Adaptive Staging (e.g., its attributes and Decision Points) can address the technical and societal challenges of a geologic repository program. This belief is based on the committee’s knowledge of repository programs worldwide, its comparisons with other complex projects, and its perception of the compatibility of Adaptive Staging with the principles of sound project management. The inherently self-correcting nature of Adaptive Staging reduces the risk of using such an approach. Given the limited successes of Linear Staging, and given Adaptive Staging’s use of multiple Decision Points for addressing Linear Staging’s limitations, the committee judges that a successful repository program is more likely with Adaptive Staging.
Representative terms from entire chapter: