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Submitted by Peter De Preter, NIRAS/ONDRAF
   Commenting on behalf of the organisation
Document Radiological Protection in Geological Disposal of Long-lived Solid Radioactive Waste
 

Section 4.1 Paragraph 40, first bullet - the principle of justification


In this paragraph the Commission restates its position (as in Publications 77 and 81) that waste management and disposal operations are an integral part of the practice generating the waste, and that they should not be regarded  as a free standing practice that needs its own justification. This is to my opinion clear and correct. But I do think that one should also add that the assessment of justification of the practice generating the waste has to take due account of all relevant evolutions (in terms of technical developments and scientific understanding, societal aspects, ...) since the time of starting the practice, because these evolutions clearly are important over the long time period of disposal programmes - typically many decades. That is the reason why I propose to add the text in bold underlined in the paragraph on justification.




Waste management and disposal operations are an integral part of the practice generating the waste. It is wrong to regard them as a free standing practice that needs its own justification. The waste management and disposal operations should therefore be included in the assessment of the justification of the practice generating the waste (ICRP 77 §34). This assessment should include considerations of different options for waste management and disposal including the justification of these options. Practices established and assessed in the past may have considered long-term waste management and disposal operations on a conceptual level only. Hence, if the justification of the practice, at the moment of establishing the practice or afterwards, has not sufficiently or not comprehensively addressed the implications of waste management and disposal operations, it may be necessary to reassess the justification of the practice generating the waste, taking due account of the different options for waste management and disposal.


 


Also, if the national waste disposal policy has changed and the practice is continuing, it may be necessary to reassess the justification of the practice. If the practice has ceased, the protection strategy, rather than the practice, has to be considered for justification.


 


Finally, given the long periods of time needed to develop and implement geological disposal programmes and because of scientific, technological and societal evolutions over these periods of time, it is recommended to conduct periodic reassessments of the justification of the practice.