Is it Possible to Demonstrate Compliance with the Regulations for High-Level-Waste Repositories?
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IS IT POSSIBLE TO DEMONSTRATE COMPLIANCE WITH THE REGULATIONS FOR HIGH-LEVEL-WASTE REPOSITORIES? FELTON W. BINGHAM Department 6312, Sandia National Laboratories, Albuquerque, NM 87112 ABSTRACT The regulations that currently govern repositories for spent fuel and high-level waste require demonstrations that are sometimes described as impossible to make. To make them will require an understanding of the current and the future phenomena at repository sites; it will also require credible estimates of the probabilities that the phenomena will occur in the distant future. Experts in many fields--earth sciences, statistics, numerical modeling, and the law-have questioned whether any amount of data collection can allow modelers to meet these requirements with enough confidence to satisfy the regulators. In recent years some performance assessments have begun to shed light on this question because they use results of actual site investigations. Although these studies do not settle the question definitively, a review of a recent totalsystem assessment suggests that compliance may be possible to demonstrate. The review also suggests, however, that the demonstration can be only at the "reasonable" levels of assurance mentioned, but not defined, in the regulations. WHY THE QUESTION ARISES When the U.S. Environmental Protection Agency issued its standard for repositories containing radioactive wastes, the technical community immediately raised questions about it. Indeed, the questions had been under discussion for years, and the issuance of the standard (as 40 CFR 191 in the U.S. Code of Federal Regulations) simply brought them to the attention of more people. One of the most frequently asked questions was whether anyone could show convincingly that a proposed repository would comply with the standard. This question arose not merely because the standard was complex. It arose mainly because to show compliance with it would require the gathering and analysis of information in ways that much of the technical community was not comfortable with. To see why the technical community was concerned, it is helpful to review the standard briefly. Under U.S. law, the Environmental Protection Agency (the EPA) was required to issue a standard for use in determining whether a proposed repository, constructed deep underground, would adequately protect the general environment from offsite releases of radioactive material. The law required this standard to be "generally applicable." The EPA therefore wrote a standard that could be used in determining the safety of repositories holding different kinds of waste in different locations. (That standard will be changed, at least in part, because of actions by the U.S. courts and the Congress. After modification during the next two years, its details will differ from those of the original standard. The basic principles that give rise to the question about compliance are, however, likely to remain.) Mat. Res. Soc. Symp. Proc. Vol. 294. 61993 Materials Research Society
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