By FRANK L.PARKER
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5. The Department of Energy should make greater use of conservative engineering design instead of using unproven engineering design based on scientific principles. 6. The Department of Energy should participate more actively in international studies and forums, such as those sponsored by the International Atomic Energy Agency, the Nuclear Energy Agency, and the Commission of European Communities, and should subject its plans and procedures to international scientific review, as Sweden, Switzerland, and the United Kingdom have already done.
The combination of a conservative engineering approach and designed-in maximum flexibility, to allow unanticipated problems to be corrected, should reassure both technical experts and concerned nonexperts. S. program is dictated by a governmental structure that separates regulation from implementation. Within the present program, for example, “quality assurance” has become the bete noire of frustrated field personnel, who are trying to work within a system that is hostile to surprises in a world that is full of them.
All other countries use only a dose requirement. In setting regulatory standards and licensing requirements, the EPA should consider using only dose requirements. 3. S. Nuclear Regulatory Commission, likewise, should reconsider the detailed licensing requirements for the repository. For example: • What level of statistical or modeling evidence is really necessary, obtainable, or even feasible? • To what extent is it necessary to prescribe engineering design, rather than allowing alternatives that accomplish the same goal?