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Data Sharing in Radiation Biology: Towards FAIR

The value of scientific data depends on their findability, accessibility, integrability and reusability according to the FAIR principles. Together with the sustainability of data preservation and access, these principles underpin the long term benefits of scientific research. Within the domain of radiobiology we have a huge array of data types, themes and complexities which make standardisation of metadata, data structure and data integration very challenging. Moreover, it is clear that, for example, in the area of disaster preparedness, the ready discovery and availability of multiple types of data, for example on biological effects of exposure, climatology, ecology, human behavioural and attitudinal studies, is important for an integrated scientific approach. Because these data are spread over many databases, journal supplementary information resources and even the computers of the investigators, their discovery and reuse can be challenging. Despite exhortations from funding agencies and scientific institutions over the past two decades there is still a serious deficit in the willingness and in some cases the ability of investigators to share data, and although much may not be formally "Public domain“, information about the existence of the data, their metadata, and how to obtain them should always be available. We report the progress of work on three databases, the STORE and the NASA GeneLab and LSDA repositories to leverage the Radiation Biology Ontology (RBO), a structured terminology for metadata that can be used by all radiation biology-relevant databases to unite federated and automated data searches across multiple databases, for example using web services, and through semantic web technologies supporting data discovery. The initial primary use-cases for RBO were archiving data in the STORE database (https://www.storedb.org/), the repository used for the RadoNorm and Pianoforte Projects among others, and in the NASA Open Science Data Repository (https://osdr.nasa.gov/bio). The scope of radiobiology research ranges from basic physics to radiation oncology to sociolegal studies; no existing ontology had the necessary breadth or depth to fulfill this need. In addition, a formal ontology has the advantage of being usable for machine learning and, importantly, for tasks like data integration, knowledge extraction from the scientific literature and for query extension and data classification. Standardisation of metadata is one of the primary objectives of the FAIR principles for open data; RBO is an important landmark for FAIR-compliant radiation biology data sharing. The RBO is developed using the open-source tools of GitHub and the OBO Foundry-led Ontology Development Kit, and published through GitHub and the NIH/NCBI BioPortal website. This initial phase of concept modeling has yielded an ontology that has more than 300 declared concepts, with more than 3500 additional concepts imported from other OBO Foundry ontologies with relevance to radiation biology (for example, concepts from the ISO standard Basic Formal Ontology, the Environment Ontology and the Gene Ontology). We welcome input into the development of RBO and encourage its adoption.

ontologies↗

Elevating the Quality of Space Omics Sequencing Data: Innovations and Methodologies from NASA GeneLab Sample Processing Laboratory

NASA’s GeneLab, part of the NASA Open Science Data Repository, is a space-related database that hosts a diverse range of transcriptomics, proteomics, epigenomics and genomics data. The NASA GeneLab Sample Processing Laboratory (SPL) generates omics data from biological experiments conducted aboard the International Space Station, Space Shuttle and space related ground experiments, this omics data then hosted on the GeneLab repository. Samples generated such experiments pose numerous technical challenges such as small experimental sample size, variance in dissection times, limited tissue preservation methods, prolonged storage time, and more. GeneLab SPL team had developed specialized expertise in nucleic acid extraction, library preparation and sequencing of such biological samples via extensive training and years of experience. In order to ensure data accuracy and consistency across experiments, SPL has developed standardized protocols for each species and tissue type. These protocols in conjunction with quality control metrics and data standards are crucial in generating of high-quality data. SPL protocols and standards have been developed in collaboration with the scientific community and had been made publicly available on the GeneLab portal, guaranteeing comparability of datasets across spaceflight experiments. To ensure reliability of data generation, SPL leverages cutting-edge innovations in laboratory automation for sample processing. By leveraging these state-of-the-art platforms, SPL achieves high levels of data reproducibility while significantly minimizing sources of bias and variability, especially across experiments with large numbers of samples. Over the past few years, the space biology investigator community has accessed SPL-generated data from the Open Science Data Repository for a myriad of data re-analysis and re-use studies. We observe a trend that in-house SPL-generated data consistently outperforms outsourced sequencing data in terms of technical standards, quality control metrics, timeliness of data delivery, and sequencing and reagent efficiency. Superior data generation has and will continue to enable discoveries in disease, diagnostic tools, and the biological effects of long duration spaceflight.

GeneLab↗

HRP Data Management Plan

The purpose of Human Research Program Data Management Plan (DMP) is to define the processes and activities required for the overall management of the research data collected and managed by HRP throughout their life cycle. New updates to the Data Management Plan in 2023 include 1. CAPABILITIES AND SERVICES Data Repositories. Principal Investigators (PIs) funded by HRP may be asked to submit data to one of several NASA data repositories. HRP archives data in the NASA Life Sciences Portal (NLSP) that it considers to be unique and high value. This includes data from human subjects in space flight (ISS and commercial flights) and ground analogs to spaceflight; spaceflight tech demos involving humans; human omics data including the microbiome; parabolic flight studies; and the NASA Space Radiation Laboratory (NSRL). The Open Science Data Repository (OSDR) includes The Ames Life Sciences Data Archive (ALSDA), used to archive non-human biological data (e.g., animal) generated by the Human Research program, and GeneLab, available to HRP PIs to archive non-human omics data. Catalog for search and retrieval. A catalog of non-human HRP life science experiments, with all associated descriptions (mission, payload, hardware, and personnel related information), and biospecimens is provided on the NLSP public web site for search and retrieval. 2. IRB ROLE IN RETURN OF INDIVIDUAL RESEARCH RESULTS The NASA IRB manages the process for incidental findings and for returning results to subjects for studies for which NASA IRB is the IRB of record. Omics data, especially genomics data, may generate information significant to the health of or risk to a research subject. These data potentially hold the keys to understand lifetime risks of chronic diseases, such as cancer, as well as risks associated with exposures common in space flight. 3. UPDATE OF TERMS – IDENTIFIABLE AND ATTRIBUTABLE DATA HRP now follows Federal and NASA policy by using “identifiable” instead of “attributable” for Personally Identifiable Information (PII). 4. POLICY ABOUT INTERNAL NON-RESEARCH USE OF DATA The HRP Chief Scientist grants access to data from HRP-funded research for non-research internal use that includes program management, customer facilitation, strategic planning, and risk research planning. Typical HRP personnel granted access to HRP research data for internal use include the Element Scientist, Subject Matter Experts (SME), and Data/bioinformatics Scientists. If data accessed for Internal Use is provided to an intramural or extramural scientist for hypothesis driven research, all Federal and NASA regulations (e.g., IRB review) regarding human subject research apply.

Data Management Plan↗

Elevating the Quality of Space Omics Sequencing Data: Innovations and Methodologies from NASA GeneLab Sample Processing Laboratory

NASA’s GeneLab, part of the NASA Open Science Data Repository, is a space-related database that hosts a diverse range of transcriptomics, proteomics, epigenomics and genomics data. The NASA GeneLab Sample Processing Laboratory (SPL) generates omics data from biological experiments conducted aboard the International Space Station, Space Shuttle and space related ground experiments, this omics data then hosted on the GeneLab repository. Samples generated such experiments pose numerous technical challenges such as small experimental sample size, variance in dissection times, limited tissue preservation methods, prolonged storage time, and more. GeneLab SPL team had developed specialized expertise in nucleic acid extraction, library preparation and sequencing of such biological samples via extensive training and years of experience. In order to ensure data accuracy and consistency across experiments, SPL has developed standardized protocols for each species and tissue type. These protocols in conjunction with quality control metrics and data standards are crucial in generating of high-quality data. SPL protocols and standards have been developed in collaboration with the scientific community and had been made publicly available on the GeneLab portal, guaranteeing comparability of datasets across spaceflight experiments. To ensure reliability of data generation, SPL leverages cutting-edge innovations in laboratory automation for sample processing. By leveraging these state-of-the-art platforms, SPL achieves high levels of data reproducibility while significantly minimizing sources of bias and variability, especially across experiments with large numbers of samples. Over the past few years, the space biology investigator community has accessed SPL-generated data from the Open Science Data Repository for a myriad of data re-analysis and re-use studies. We observe a trend that in-house SPL-generated data consistently outperforms outsourced sequencing data in terms of technical standards, quality control metrics, timeliness of data delivery, and sequencing and reagent efficiency. Superior data generation has and will continue to enable discoveries in disease, diagnostic tools, and the biological effects of long duration spaceflight.

GeneLab↗

The Nasa SRA Process as It Relates to Open-Source Workflows Developed for GeneLab Data Processing

To release open, standards-compliant processed data sets in the Open Science Data Repository (OSDR), the GeneLab Data Processing team works with the scientific community through the OSDR Analysis Working Groups to design and build open-source data processing pipelines. Once baselined internally, these pipelines are wrapped into workflows and published on the NASA GeneLab Data Processing public GitHub repository along with detailed instructions for installation and use. Each workflow must be approved through NASA's Software Release Authorization (SRA) process prior to publishing. However, the SRA process lacks sufficient documentation and clarity regarding which forms are applicable for new open-source software that utilizes publicly available 3rd party tools, and the SRA process can take several months to complete, making sharing software outside of NASA cumbersome and in contradiction with the concept of Open Science. Furthermore, the SRA process was designed as a one-size fits all approach and thus many of the questions asked are not applicable to our open-source workflows. Here we describe the software provided on the NASA GeneLab Data Processing GitHub repository, summarize our experiences with the SRA process to release these software, and propose a more stream-lined approach for review of open-source projects.

Software Release Authorization↗

The NASA SRA Process as it Relates to Open-Source Workflows Developed for GeneLab Data Processing

To release open, standards-compliant processed data sets in the Open Science Data Repository (OSDR), the GeneLab Data Processing team works with the scientific community through the OSDR Analysis Working Groups to design and build open-source data processing pipelines. Once baselined internally, these pipelines are wrapped into workflows and published on the NASA GeneLab Data Processing public GitHub repository along with detailed instructions for installation and use. Each workflow must be approved through NASA's Software Release Authorization (SRA) process prior to publishing. However, the SRA process lacks sufficient documentation and clarity regarding which forms are applicable for new open-source software that utilizes publicly available 3rd party tools, and the SRA process can take several months to complete, making sharing software outside of NASA cumbersome and in contradiction with the concept of Open Science. Furthermore, the SRA process was designed as a one-size fits all approach and thus many of the questions asked are not applicable to our open-source workflows. Here we describe the software provided on the NASA GeneLab Data Processing GitHub repository, summarize our experiences with the SRA process to release these software, and propose a more stream-lined approach for review of open-source projects.

Software Release Authorization↗

Features, Events and Processes for the Used Fuel Disposition Campaign

The Used Fuel Disposition (UFD) Campaign within DOE-NE is evaluating storage and disposal options for a range of waste forms and a range of geologic environments. To assess the potential performance of conceptual repository designs for the combinations of waste form and geologic environment, a master set of Features, Events, and Processes (FEPs) has been developed and evaluated. These FEPs are based on prior lists developed by the Yucca Mountain Project (YMP) and the international repository community. The objective of the UFD FEPs activity is to identify and categorize FEPs that are important to disposal system performance for a variety of disposal alternatives (i.e., combinations of waste forms, disposal concepts, and geologic environments). FEP analysis provides guidance for the identification of (1) important considerations in disposal system design, and (2) gaps in the technical bases. The UFD FEPs also support the development of performance assessment (PA) models to evaluate the long-term performance of waste forms in the engineered and geologic environments of candidate disposal system alternatives. For the UFD FEP development, five waste form groups and seven geologic settings are being considered. A total of 208 FEPs have been identified, categorized by the physical components of the waste disposal system as well as cross-cutting physical phenomena. The combination of 35 waste-form/geologic environments and 208 FEPs is large; however, some FEP evaluations can cut across multiple waste/environment combinations, and other FEPs can be categorized as not-applicable for some waste/environment combinations, making the task of FEP evaluation more tractable. A FEP status tool has been developed to document progress. The tool emphasizes three major areas that can be statused numerically. FEP Applicability documents whether the FEP is pertinent to a waste/environment combination. FEP Completion Status documents the progress of the evaluation for the FEP/waste/environment combination. FEP Importance documents the potential importance for the FEP/waste/environment combination to repository performance.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

A Fruit of Yucca Mountain: The Remote Waste Package Closure System

Was the death of the Yucca Mountain repository the fate of a technical lemon or a political lemon? Without caution, this debate could lure us away from capitalizing on the fruits of the project. In March 2009, Idaho National Laboratory (INL) successfully demonstrated the Waste Package Closure System, a full-scale prototype system for closing waste packages that were to be entombed in the now abandoned Yucca Mountain repository. This article describes the system, which INL designed and built, to weld the closure lids on the waste packages, nondestructively examine the welds using four different techniques, repair the welds if necessary, mitigate crack initiating stresses in the surfaces of the welds, evacuate and backfill the packages with an inert gas, and perform all of these tasks remotely. As a nation, we now have a proven method for securely sealing nuclear waste packages for long term storage—regardless of whether or not the future destination for these packages will be an underground repository. Additionally, many of the system’s features and concepts may benefit other remote nuclear applications.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Management of Salt Waste from Electrochemical Processing of Used Nuclear Fuel

Electrochemical processing of used nuclear fuel involves operation of one or more cells containing molten salt electrolyte. Processing of the fuel results in contamination of the salt via accumulation of fission products and transuranic (TRU) actinides. Upon reaching contamination limits, the salt must be removed and either disposed or treated to remove the contaminants and recycled back to the process. During development of the Experimental Breeder Reactor-II spent fuel treatment process, waste salt from the electrorefiner was to be stabilized in a ceramic waste form and disposed of in a high-level waste repository. With the cancellation of the Yucca Mountain high-level waste repository, other options are now being considered. One approach that involves direct disposal of the salt in a geologic salt formation has been evaluated. While waste forms such as the ceramic provide near-term resistance to corrosion, they may not be necessary to ensure adequate performance of the repository. To improve the feasibility of direct disposal, recycling a substantial fraction of the useful salt back to the process equipment could minimize the volume of the waste. Experiments have been run in which a cold finger is used for this purpose to crystallize LiCl from LiCl/CsCl. If it is found to be unsuitable for transportation, the salt waste could also be immobilized in zeolite without conversion to the ceramic waste form.

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Irradiated Nuclear Fuel Management: Resource Versus Waste

Management of irradiated fuel is an important component of commercial nuclear power production. Although it is broadly agreed that the disposition of some fraction of the fuel in geological repositories will be necessary, there is a range of options that can be considered that affect exactly what fraction of material will be disposed in that manner. Furthermore, until geological repositories are available to accept commercial irradiated fuel, these materials must be safely stored. Temporary storage of irradiated fuel has traditionally been conducted in storage pools, and this is still true for freshly discharged fuel. Criticality control technologies have led to greater efficiencies in packing of irradiated fuel into storage pools. With continued delays in establishing permanent repositories, utilities have begun to move some of the irradiated fuel inventory into dry storage. Fuel cycle options being considered worldwide include the once-through fuel cycle, limited recycle in which U and Pu are recycled back to power reactors as mixed oxide fuel, and advance partitioning and transmutation schemes designed to reduce the long term hazards associated with geological disposal from millions of years to a few hundred years. Each of these options introduces specific challenges in terms of the waste forms required to safely immobilize the hazardous components of irradiated fuel.

irradiated fuel management↗

Actinide Solubility and Speciation in the WIPP [PowerPoint]

The presentation begins with the role and need for nuclear repositories (overall concept, international updates (Sweden, Finland, France, China), US approach and current status), then moves on to the WIPP TRU repository concept (design, current status--safety incidents of February 5 and 14, 2014, path forward), and finally considers the WIPP safety case: dissolved actinide concentrations (overall approach, oxidation state distribution and redox control, solubility of actinides, colloidal contribution and microbial effects). The following conclusions are set forth: (1) International programs are moving forward, but at a very slow and somewhat sporadic pace. (2) In the United States, the Salt repository concept, from the perspective of the long-term safety case, remains a viable option for nuclear waste management despite the current operational issues/concerns. (3) Current model/PA prediction (WIPP example) are built on redundant conservatisms. These conservatisms are being addressed in the ongoing and future research to fill existing data gaps--redox control of plutonium by Fe(0, II), thorium (analog) solubility studies in simulated brine, contribution of intrinsic and biocolloids to the mobile concentration, and clarification of microbial ecology and effects.

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Sponge

Sponge provides a web interface to Pulp (http://pulpproject.org/) that implements a particular workflow as described in the paper "Staging Package Deployment via Repository Management" (http://www.usenix.org/events/lisa11/tech/full_papers/Pierre.pdf). Namely, it implements a process for intensive management of software repositories to apply more deterministic updates to clients of those repositories.

Pierre, Chris St.↗

Semantic Complex Event Processing over End-to-End Data Flows

Emerging Complex Event Processing (CEP) applications in cyber physical systems like SmartPower Grids present novel challenges for end-to-end analysis over events, flowing from heterogeneous information sources to persistent knowledge repositories. CEP for these applications must support two distinctive features - easy specification patterns over diverse information streams, and integrated pattern detection over realtime and historical events. Existing work on CEP has been limited to relational query patterns, and engines that match events arriving after the query has been registered. We propose SCEPter, a semantic complex event processing framework which uniformly processes queries over continuous and archived events. SCEPteris built around an existing CEP engine with innovative support for semantic event pattern specification and allows their seamless detection over past, present and future events. Specifically, we describe a unified semantic query model that can operate over data flowing through event streams to event repositories. Compile-time and runtime semantic patterns are distinguished and addressed separately for efficiency. Query rewriting is examined and analyzed in the context of temporal boundaries that exist between event streams and their repository to avoid duplicate or missing results. The design and prototype implementation of SCEPterare analyzed using latency and throughput metrics for scenarios from the Smart Grid domain.

Zhou, Qunzhi↗

Apparatus, compositions, and methods for assessment of chronic obstructive pulmonary disease progression among rapid and slow decline conditions

Methods are disclosed for generating and isolating an informative content repository of respiratory related biomarkers to accurately determine whether an individual has normal or abnormal pulmonary function. Specifically, methods are directed to determination of whether individuals have chronic obstructive pulmonary disease, and if so, whether the affected individuals experience rapid long decline or slow lung decline as a result of COPD. Also disclosed is an informative content repository of chronic obstructive pulmonary disease biomarkers, which when linked with other informative content provides a powerful tool for diagnosis, study, therapeutic discovery and development, condition management, health maintenance, and linking chronic obstructive pulmonary disease through pattern of life style, environmental exposure, and genetic susceptibility and inheritance. Disclosed herein is a chronic obstructive pulmonary disease biomarker informative content repository comprising at least one COPD biomarker, apparatus and methods to diagnose, assess, address, and ameliorate related conditions.

Hoidal, John↗

Current Status of the Nuclear Waste Management Programme in Finland - 13441

Pursuant to the Decision-in-Principle of 2001 the Finnish programme for geologic disposal of spent fuel has now moved to the phase of applying for construction licence to build up the encapsulation plant and underground repository. The main objective of former programme phase, underground characterisation phase, was to confirm - or refute - the suitability of the Olkiluoto site by investigations conducted underground at the actual depth of the repository. The construction work of the access tunnel to the rock characterisation facility (ONKALO) started in the late summer of 2004. The site research and investigations work aimed at the maturity needed for submission of the application for construction license of the actual repository in end of 2012. This requires, however, that also the technology has reached the maturity needed. The design and technical plans form the necessary platform for the development of the safety case for spent fuel disposal. A plan, 'road map', has been produced for the portfolio of reports that demonstrates the safety of disposal as required by the criteria set by the government and further detailed by the safety authority, STUK. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Dismantling of Loop-Type Channel Equipment of MR Reactor in NRC 'Kurchatov Institute' - 13040

In 2009 the project of decommissioning of MR and RTF reactors was developed and approved by the Expert Authority of the Russian Federation (Gosexpertiza). The main objective of the decommissioning works identified in this project: - complete dismantling of reactor equipment and systems; - decontamination of reactor premises and site in accordance with the established sanitary and hygienic standards. At the preparatory stage (2008-2010) of the project the following works were executed: loop-type channels' dismantling in the storage pool; experimental fuel assemblies' removal from spent fuel repositories in the central hall; spent fuel assembly removal from the liquid-metal-cooled loop-type channel of the reactor core and its placement into the SNF repository; and reconstruction of engineering support systems to the extent necessary for reactor decommissioning. The project assumes three main phases of dismantling and decontamination: - dismantling of equipment/pipelines of cooling circuits and loop-type channels, and auxiliary reactor equipment (2011-2012); - dismantling of equipment in underground reactor premises and of both MR and RTF in-vessel devices (2013-2014); - decontamination of reactor premises; rehabilitation of the reactor site; final radiation survey of reactor premises, loop-type channels and site; and issuance of the regulatory authorities' de-registration statement (2015). In 2011 the decommissioning license for the two reactors was received and direct MR decommissioning activities started. MR primary pipelines and loop-type facilities situated in the underground reactor hall were dismantled. Works were also launched to dismantle the loop-type channels' equipment in underground reactor premises; reactor buildings were reconstructed to allow removal of dismantled equipment; and the MR/RTF decommissioning sequence was identified. In autumn 2011 - spring 2012 results of dismantling activities performed are: - equipment from underground rooms (No. 66, 66A, 66B, 72, 64, 63) - as well as from water and gas loop corridors - was dismantled, with the total radwaste weight of 53 tons and the total removed activity of 5,0 x 10{sup 10} Bq; - loop-type channel equipment from underground reactor hall premises was dismantled; - 93 loop-type channels were characterized, chopped and removed, with radwaste of 2.6 x 10{sup 13} Bq ({sup 60}Co) and 1.5 x 10{sup 13} Bq ({sup 137}Cs) total activity removed from the reactor pool, fragmented and packaged. Some of this waste was placed into the high-level waste (HLW) repository of the Center. Dismantling works were executed with application of remotely operated mechanisms, which promoted decrease of radiation impact on the personnel. The average individual dose for the personnel was 1.9 mSv/year in 2011, and the collective dose is estimated as 0.0605 man x Sv/year. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

The Full Scale Seal Experiment - A Seal Industrial Prototype for Cigeo - 13106

The Full Scale Seal (FSS) Experiment is one of various experiments implemented by Andra, within the frame of the Cigeo (the French Deep Geological Repository) Project development, to demonstrate the technical construction feasibility and performance of seals to be constructed, at time of Repository components (shafts, ramps, drifts, disposal vaults) progressive closure. FSS is built inside a drift model fabricated on surface for the purpose. Prior to the scale 1:1 seal construction test, various design tasks are scheduled. They include the engineering work on the drift model to make it fit with the experimental needs, on the various work sequences anticipated for the swelling clay core emplacement and the concrete containment plugs construction, on the specialized handling tools (and installation equipment) manufactured and delivered for the purpose, and of course on the various swelling clay materials and low pH (below 11) concrete formulations developed for the application. The engineering of the 'seal-as-built' commissioning means (tools and methodology) must also be dealt with. The FSS construction experiment is a technological demonstrator, thus it is not focused on the phenomenological survey (and by consequence, on the performance and behaviour forecast). As such, no hydration (forced or natural) is planned. However, the FSS implementation (in particular via the construction and commissioning activities carried out) is a key milestone in view of comforting phenomenological extrapolation in time and scale. The FSS experiment also allows for qualifying the commissioning methods of a real sealing system in the Repository, as built, at time of industrial operations. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Consolidated Storage Facilities: Camel's Nose or Shared Burden? - 13112

The Blue Ribbon Commission (BRC) made a strong argument why the reformulated nuclear waste program should make prompt efforts to develop one or more consolidated storage facilities (CSFs), and recommended the amendment of NWPA Section 145(b) 2 (linking 'monitored retrievable storage' to repository development) as an essential means to that end. However, other than recommending that the siting of CSFs should be 'consent-based' and that spent nuclear fuel (SNF) at stranded sites should be first-in-line for removal, the Commission made few recommendations regarding how CSF development should proceed. Working with three other key Senators, Jeff Bingaman attempted in the 112. Congress to craft legislation (S. 3469) to put the BRC recommendations into legislative language. The key reason why the Nuclear Waste Administration Act of 2012 did not proceed was the inability of the four senators to agree on whether and how to amend NWPA Section 145(b). A brief review of efforts to site consolidated storage since the Nuclear Waste Policy Amendments Act of 1987 suggests a strong and consistent motivation to shift the burden to someone (anyone) else. This paper argues that modification of NWPA Section 145(b) should be accompanied by guidelines for regional development and operation of CSFs. After review of the BRC recommendations regarding CSFs, and the 'camel's nose' prospects if implementation is not accompanied by further guidelines, the paper outlines a proposal for implementation of CSFs on a regional basis, including priorities for removal from reactor sites and subsequently from CSFs to repositories. Rather than allowing repository siting to be prejudiced by the location of a single remote CSF, the regional approach limits transport for off-site acceptance and storage, increases the efficiency of removal operations, provides a useful basis for compensation to states and communities that accept CSFs, and gives states with shared circumstances a shared stake in storage and disposal in an integrated national program. (authors)

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