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region will not affect total costs under a National implementation assumption.
Under Regional implementation, however, costs generally increase since, in
the humid permeable region, a more stringent disposal practice is required
to meet the alternative standards. Since the unit health risks are greater
in the humid permeable region, avoided health effects generally increase for
Case 1. The net effect on marginal cost-effectiveness is mixed, however.
A comparison of the marginal cost-effectiveness ratios associated with the
base case and Case 1 indicates that the ratios change from 10 percent to 30
percent. In particular, the marginal cost-effectiveness under a National
implementation assumption increases from $16 million to $19 million when
moving from a 50 to a 25 millirem standard, or about a 20 percent increase
when the PA/WV Compact is assigned to the humid permeable region.
Segmentation of Wastes
Similar to substream segregation in the BRC analysis, segmentation of
waste substreams is an issue in the LLW analysis. Since the distribution of
specific activity for a waste can vary by a couple of orders of magnitude,
substreams of a particular waste may qualify for NRC classification different
from the aggregate waste stream. As a result, if segmentation is
practiced, the type of disposal treatment could differ across the substreams
for a given waste. For example, L-NCTRASH, a Class A waste, is an
aggregation of two NRC substreams — P-NCTRASH, also a Class A waste,
and B-NCTRASH, a Class B waste. Since L-NCTRASH is characterized by
a significant volume, Class B treatment of the substream B-NCTRASH
(which involves solidification of the waste) would increase costs by $287
million under 10 CFR 61 disposal. Total health effects associated with 10
CFR 61 would not vary significantly, in this example, since L-NCTRASH
accounts for less than one health effect.
This example demonstrates that segmentation of the waste can have a
significant effect on the results. However, if B-NCTRASH is treated as
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Class B waste under current practice, incremental costs and avoided health
effects at the 25 millirem standard will not be affected, since current
practice was demonstrated to be in compliance with this standard. Since
absolute costs for 10 CFR 61 disposal are understated, however, marginal
cost-effectiveness ratios associated with moving from a 50 millirem
alternative to the 25 millirem standard will increase from $16 to $26 million
per avoided health effect.
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DISCUSSION OF OTHER PARTS OF THE STANDARD Chapter 9
In addition to the BRC criterion, the LLW standard, and the regulation
of certain NARM wastes, EPA is proposing two other limits which affect LLW
in this action. These limits include contamination limits expressed as an
annual CPC dose limit for groundwater, graded by aquifer class, and a
pre-disposal waste management limit of 25 millirem per year. Finally, EPA
is also proposing that the implementation of the LLW and BRC standards be
phased in over time, with application to commercial sites taking effect for
any site seeking a new or renewed license, and application to DOE sites
taking effect as of January 1, 1993.
A detailed quantitative analysis with respect to the three provisions
described above has not been undertaken since EPA believes that the
economic impact of these provisions will be small (except perhaps for the
groundwater standard, depending on the option chosen). The purpose of
this chapter is to describe in qualitative terms what the economic impacts
would include if they were quantified and the reasons EPA believes the
impacts will probably be small. Each of the three provisions will be treated
individually in the following discussions.
PROPOSED CROUNDWATER STANDARDS
EPA is proposing two separate options for the groundwater protection
limits for the disposal of low-level radioactive waste. Under either option,
the limits depend on the type of aquifer affected, as follows:
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Aquifer Class
OPTION I:
Class I
Class II --
High Yield (above 10,000 gpd)
«
Low Yield (above 10,000 gpd)
Class III
OPTION II:
Class I
Class II and Class III
Proposed Croundwater Limit
No Degradation (i.e., 0 millirem)
U millirem per year
Less than 25 millirem per year
(covered by LLW standard)
Less than 25 millirem per year
(covered by LLW standard)
No Degradation (i.e., 0 millirem)
millirem per year
As with other EPA groundwater protection strategies, the purpose of a
graded limit is to protect aquifers to a degree commensurate with their
value and potential use. Class I aquifers include essential community water
supplies (sole source aquifers) and, in particular, pure sources of
groundwater. Class III aquifers include groundwaters that generally are
not drinkable due to natural causes (e.g., saline water) or prior manmade
contamination. Class II aquifers, which include the great majority of all
aquifers, include all groundwaters that are not Class I or Class III. Class
II aquifers are further subdivided under Option I according to their
potential yield. An aquifer yield threshold of 10,000 gallons per day is used
to differentiate low and high yield aquifers. This threshold is chosen, in
part, to reflect the average daily consumption of 25 people (at 200 gallons
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per day per person, for a total consumption of 5.000 gallons) and a design
factor of two to account for the difference between the actual yield of the
aquifer and human consumption (which varies on a daily basis).
The 4 millirem per year dose limit, which is proposed under Option I.
for high yield Class II aquifers and under Option II for both Class II and
Class III aquifers, is numerically equal to the National Interim Primary
Drinking Water Standard - Maximum Contaminant Level (MCL) for manmade
radionuclides, which is also 4 millirem per year (whole-body dose
equivalent). This interim MCL (EPA76] was promulgated on July 9, 1976
(41 FR 28404) at 40 CFR 141.15 and 141.16, with additional interim MCLs of
5 picocuries per liter for radium-226 and -228, and 15 picocuries per liter
for gross alpha particle activity (excluding uranium and radon). Under the
interim standards, compliance monitoring is only required for surface water
systems serving more than 100,000 people.
The LLW groundwater standards proposed in this action are designed
to direct siting of LLW disposal facilities away from the most valuable
groundwaters (Class I) and to ensure that no community has to treat its
water supply to remove radionuclides due to a LLW disposal facility.
Impact on LLW Disposal
The proposed groundwater protection standards affect the economic
analysis of LLW disposal only to the extent that they alter the costs and
benefits of LLW disposal specifically as a result of meeting the groundwater
standard. These incremental costs and benefits would accrue in addition to
those already quantified in Chapter 8 for the proposed 25 millirem per year
LLW standard. Thus, under Option I, the groundwater standards would
have no additional economic impact on sites located above Class lit or Class
II low yield aquifers, since the groundwater CPC dose would already be
limited to less than 25 millirem per year by the LLW standard (which covers
all pathways, including groundwater). However, under Option II, the
incremental economic impact of the groundwater standards could be much
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greater since the groundwater pathway often determines the maximum CPC
dose with respect to the LLW standard (i.e.. Option II is tantamount to an
LLW standard of 4 millirem per year).
Incremental Impact of Option I Croundwater Limits
The proposed groundwater standards under Option I could raise the
costs of disposal site selection if a site must be relocated away from a Class
I or Class II high yield aquifer. If an alternative site cannot be found (or
is very expensive to locate or purchase), the proposed groundwater
standards under Option I could require instead a more expensive disposal
technology to limit the groundwater CPC dose to U millirem per year or
lower.
As explained further in EEI84b, normal siting costs are estimated to
equal approximately $263,000 to $530,000 per site for a single disposal
facility; similar costs would be incurred for any of the shallow land disposal
options (i.e., SLD, ISO, and IDD). These siting cost estimates include the
costs especially designated in EEI84b as costs of site selection ($263,000),
and additional costs for legal services and site study that are likely to
begin before a decision to reject a site from further consideration is
reached. For purposes of illustrating potential resiting costs, the estimated
legal costs of $175,000 incurred during the first year of facility con-
struction and about one-half of the first year costs . estimated for
preparation of the Environmental Impact Statement ($91,000) are added to
normal site selection costs ($263,000), to derive the upper-bound estimate
of resiting cost ($530,000). These costs are included since EEI84b assumes
that all activities will begin in parallel in the first year.
Most of the site selection cost reflects the expense of the detailed
hydrogeologic assessments that are needed to characterize the surrounding
aquifer system. If resiting were used to meet the groundwater limit, EPA
estimates that siting costs could increase by as much as a factor of nine,
depending on how many "tries" it takes to locate an acceptable site. This
factor is based on a preliminary study conducted for EPA that concludes
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that for the entire U.S., only 10 percent of all aquifers can be considered
low yield (less than 10,000 gallons per day). Thus, the probability of
randomly choosing a site above a low yield aquifer (an acceptable site) is
also about one in 10. The probability of choosing an acceptable site on a
random basis would, of course, also depend on the prudence of potential
sites above Class I or Class III aquifers, or above no aquifer at all. In
any event, a 10 percent probability of locating an acceptable site implies
that, on average, 10 tries would be required per site, for an incremental
siting cost of nine times the cost per try (since the LLW analysis already
accounts for siting costs at the site eventually chosen). Since at least
some prior knowledge of aquifer type is likely to be available, the proba-
bility of a successful "try" is probably higher than 10 percent. However,
it is also likely that at least two sites will be investigated in parallel, so
that at least one "reject" will occur.
Under these assumptions, resiting could add from one to nine times
normal siting costs ($263,000 to $530,000 per try), or from $263,000 to
$4.77 million per site (i.e., 1 x $263,000 to 9 x $530,000).
*
In contrast to resiting, the incremental cost of using more expensive
disposal technology to meet the groundwater standards (compared to the
cost of 10 CFR 61 disposal, which is required by the 25 millirem disposal
standard under a National Implicit implementation assumption) could range
up to $341 million per site (the incremental cost of concrete canister
disposal). Thus, it is easy to see that the cost of compliance with the
groundwater standards depends strongly on whether resiting (to areas
controlled only by the 25 millirem overall LLW disposal standard) is
necessary. The need for resiting depends on the distribution of aquifer
types at otherwise acceptable site locations. If all of the otherwise
acceptable sites are located above aquifers covered by the 4 millirem limit,
the more expensive disposal technology could be required.
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In general, for either arid permeable or humid impermeable sites, any
disposal technology that is at least as good as current practice is likely to
meet the proposed groundwater limits, even for Class II aquifers. For
these regions, the groundwater standards may not have any economic impact
at all (assuming compliance is judged on a regional or site-specific basis).
A more difficult question is whether suitable sites in humid permeable
regions can be located with only a few attempts, given other political and
engineering constraints on site selection. In these sites, the groundwater
CPC dose can exceed 4 millirem per year, even when 10 CFR 61 disposal is
used to meet the 25 millirem LLW standard. If resiling in humid permeable
regions is not feasible, a more expensive technology may be necessary to
meet the groundwater standard; in this case, the economic impact of the
groundwater limits could be substantial. Of course, implementation of EPA's
standards by the NRC and DOE could also affect the economic impact of the
groundwater standards. For example, if a more expensive technology were
needed to meet groundwater requirements in humid permeable regions and
the NRC and DOE required the same minimum technology everywhere in the
country, as under a National-Implicit implementation assumption, the
economic impact could range up to $5 billion. . If only the sites in humid
permeable regions were affected and disposal practice was allowed to relax
in the other two regions (Regional implementation), the incremental cost
would be $2.1 billion; if current disposal practice is not allowed to relax,
the incremental cost would be $2.5 billion.
EPA does not currently possess the detailed hydrogeologic
characterization of the distribution of aquifers nationwide that is necessary
to evaluate quantitatively the likelihood that more expensive technology
(rather than resiting) would be necessary to meet the groundwater
standards. However, for purposes of estimating economic impacts, EPA
assumes that resiting will be possible, at least within the humid permeable
regions where it is more likely to be necessary. To estimate the potential
magnitude of the proposed groundwater standard impacts, EPA has assumed
that resiting will be necessary between one and nine times per site. If
these assumptions are correct, for 15 ultimate sites nationwide (nine
commercial and six DOE sites, at $263,000 to $4.77 million per site), the
total maximum incremental cost (over the LLW standard) of the proposed
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groundwater protection standards would be $3.9 million to $72 million. Note
that since the potential benefit (health effects reduction) of resiting away
from Class I or Class II high yield aquifers could not be assessed
quantitatively, the cost-effectiveness of the groundwater standard under
Option I could also not be determined.
Incremental Impact of Option II Croundwater Limits
The analysis of the potential aspects of the groundwater standards
under Options I and II are similar, except that while more expensive
disposal technology may not be needed under Option I, it is almost certainly
required under Option II. Since the groundwater pathway controls the CPC
dose in the humid permeable region, a 1 millirem groundwater standard
would require more expensive disposal technology (e.g., concrete
canisters). Relative to 10 CFR 61 disposal practice, the incremental cost
could range from $2.1 to $5 billion (for commercial and DOE sites),
depending on whether the limit is implemented on a Regional or National
basis.
Impact on BRC Disposal
Unlike LLW disposal, it is possible to show that the economic
assessment of alternative BRC criteria is unlikely to be affected by the
proposed groundwater protection standards, at least for the proposed level
of the BRC criterion of 4 millirem per year. Except for the relatively rare
Class I aquifers, the proposed groundwater standards under both Option I
and Option II are equal to or above the M millirem per year MCL and the
proposed BRC.criterion. Furthermore, the contribution of the groundwater
pathway to the estimated CPC dose from unregulated disposal is always less
than U millirem (in the worst hydrogeologic region, even for higher BRC
alternatives, including 15 millirem per year). For BRC criteria of 1 millirem
and above, the controlling CPC dose pathway is direct gamma radiation to
onsite workers or transportation workers. The CPC dose from the
groundwater pathway is less than 1 millirem per year at the proposed U
millirem per year BRC criterion.
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1861A/09
PROPOSED PREDISPOSAL MANAGEMENT STANDARD
EPA is proposing a 25 millirem per year CPC dose limit for low-level
radioactive waste management operations prior to disposal. This standard
applies to the cumulative dose from all exposure pathways measured at the
boundary of facilities managed by DOE or licensed by the NRC.
Predisposal management is the preparation of the waste for disposal
and includes packaging, compaction, incineration, and solidification
processes, either current or future. These activities could be carried out,
for example, at LLW generator sites (power plants, industrial sites,
hospitals and medical centers, DOE sites), at or adjacent to LLW disposal
facilities during operation, or at future regional facilities designed to serve
a State or an entire Compact.
Several existing EPA regulations already limit the CPC dose from
certain exposure pathways and certain LLW facilities to 25 millirem per year
or less. The existence of these regulations is a principal reason why EPA
believes that the additional impact of the proposed predisposal management
standard is likely to be small. The Radionuclide Emissions Standards for
Hazardous Air Pollutants [EPA73], which were promulgated under the Clean
Air Act and are codified in UO CFR 61, Subparts H (DOE facilities) and I
(NRC licensed facilities), limit radiation exposures from air emissions of
radionuclides to 25 millirem per year at the facility boundary (excluding
radon-220 and -222 and their decay products). This standard would apply
to airborne emissions at LLW facilities both before and after disposal. The
Uranium Fuel Cycle Standard, which was promulgated under the Atomic
Energy Act in. 1977 and is codified at 40 CFR 190, is also a 25 millirem
annual dose limit and covers all pathways from facilities in the Uranium Fuel
Cycle, including uranium milling facilities, uranium hexafluoride conversion
facilities, enrichment facilities, fuel fabrication plants, commercial nuclear
power plants, and commercial fuel reprocessing plants. This standard does
cover waste processing facilities onsite at the fuel cycle facilities.
However, the Fuel Cycle Standard does not cover mines, transportation of
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radioactive waste, or offsite waste processing facilities. The latter category
would be covered under EPA's proposed Predisposal Management standard.
Hence, the exposures most obviously affected by the Predisposal
Management standard include those from spills and direct radiation at LLW
surface storage or volume reduction facilities (e.g., biomedical waste
incinerators), or regional storage, transfer, or treatment facilities. Certain
DOE facilities could also be affected; however, specific facility types have
not been identified.
Impacts on LLW Predisposal Management
Although EPA has not performed the quantitative cost or risk
assessments that would be necessary to assess the economic impacts of the
proposed Predisposal Management standard, such assessments would first
require identification of potential exposure pathways that are not already
limited by existing regulations or standards. Since the proposed standard
represents a limit on the cumulative dose from all pathways, the
contribution of the air pathway, even though limited by the Clean Air Act
emissions standards, would need to be quantified, including exposure
resulting from surface spillage, followed by air entrainment and offsite
transport.
Permanent emplacement of waste at facilities covered by either 10 CFR
190 or this Predisposal Management standard is not contemplated.
Therefore, groundwater releases resulting from normal waste leaching
processes (such as occur at disposal sites) are unlikely, although they
could conceivably result from spillage during operations. Similarly, it is
theoretically possible that offsite contamination could occur as a result of
spillage and surface runoff during a rainstorm (or flood). Finally, if waste
treatment or storage vessels are located close to the boundary of the site,
external direct gamma radiation could also cause exposure to individuals at
the site boundary in excess of 25 millirem per year.
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In summary, the additional costs of meeting the proposed 25 millirem
Predisposal Management standard would probably result from actions to
control spillage (e.g., by the use of good housekeeping practices and
proper design of handling equipment) or to limit direct gamma radiation
(e.g., by placing storage bins away from the facility boundary).
Conceptually, reduction of air emissions could also be used to meet the
predisposal standard, if such reduction proved to be a less expensive
means of meeting the standard. The costs of specific measures that may be
necessary to meet the proposed Predisposal Management standard have not
been quantified, but due to the small additional measures that are
envisioned to be required, these costs can be expected to be minimal.
PROPOSED EFFECTIVE DATE OF THE STANDARDS
EPA is proposing that its Post- and Predisposal Management standards
be applied at commercial facilities as soon as such facilities seek new or
renewed licenses. Application of these standards is proposed to commence
three years after promulgation (January 1, 1993) for new or present DOE
facilities if they are to continue operation.
Deferral of the effective date of these standards has both cost and
benefit implications. First, until the standards take effect, some disposal
practices may continue to exceed the standards (this is most likely for DOE
facilities, which currently employ a disposal technology which may exceed a
25 millirem per year CPC dose in humid permeable hydrogeologic regions).
The second impact is that short-term costs (in excess of the costs already
included in the cost-effectiveness analysis of alternative LLW standards) are
avoided. The cost analysis presented in Chapter 8 implicitly assumes that
disposal site operators and engineers will design and build a new facility
that complies with the standard. No costs are considered "sunk" costs
(i.e., costs that are already incurred), such as the capital costs at an
existing site; sunk costs would not be included in the assessment of the
incremental costs of the standard. On the other hand, transitional costs
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(e.g., the lost value of the remaining capacity at existing sites) are
reduced by delaying the effective date, as are unusual costs that reflect
current conditions that will change by 1993 (e.g., transportation of the
waste as much as 2,000 miles, for generators located far away from the
three disposal facilities now accepting waste, and disposal tariffs under
LLWPA85, for generators located outside of Compacts that host one of the
three operating commercial sites). Were it possible to quantify both the
short-term costs (avoided by deferral of the effective date) and the interim
short-term risks, it would be possible to construct a cost-effectiveness ratio
that compared immediate implementation to the proposed deferred
implementation. However, based on the foregoing qualitative discussion,
this ratio appears likely to be large (high transitional costs, low incremental
risks).
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DISTRIBUTIONAL IMPACTS Chapter 10
As part of its regulatory analysis, EPA considers the economic impact
of its regulations on small businesses and, in particular, whether small
businesses would be substantially or disproportionately affected. To
support EPA's analysis, the overall objective of this chapter is to evaluate
the distribution of costs among various groups resulting from the
implementation of EPA's proposed standards.
The incremental costs borne by commercial enterprises resulting from
the implementation of EPA's standards package — which includes a 25
millirem LLW standard, a 4 millirem BRC limit, a 2 nanocurie per gram and
0.05 millicurie NARM limit, a zero to 25 or zero to U millirem groundwater
limit (depending on groundwater option), and a 25 millirem predisposal limit
*
— are expected to be either very small or negative (i.e., a net savings).
Accordingly, this analysis will address the distributional impacts associated
with EPA's proposed standards package in a qualitative manner only.
The discussion will focus first on the overall impacts expected from the
implementation of each component of the standards package. Next, the
types of industries expected to bear these impacts will be identified.
Finally, the distribution of the impacts among the parties will be specified
to the extent possible, with particular consideration given to whether
additional costs will be imposed upon small businesses.
As discussed in Chapter 9, the impact on commercial LLW disposal of
groundwater Option II could be significant since it might require more
expensive disposal technology.
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IMPACTS OF THE STANDARDS PACKAGE
The LLW Disposal Standard
The proposed 25 millirem per year LLW disposal standard is not
expected to change current disposal practice (i.e., 10 CFR 61 disposal) in
the commercial sector. As a result, the economic impacts associated with
implementing this standard are zero for commercial LLW disposal. However,
current practice at DOE waste sites, as defined by EPA, involves shallow
land disposal which will not always meet (i.e., in all regions) the proposed
25 millirem LLW standard. However, the additional cost borne by DOE sites
is not a distributional issue since this incremental cost will ultimately be
borne by taxpayers and, therefore, will be widely distributed.
Furthermore, the overall impact on DOE waste disposal is expected to result
in a net savings to society as a result of the savings associated with the
BRC criterion.
The BRC Criterion
The proposed U millirem BRC criterion is expected to produce
substantial savings for the economy — approximately $400 million for
commercial LLW disposal and $220 million for DOE LLW disposal under
National Implicit implementation, or $310 million for commercial and $180
million for DOE under National Explicit implementation. The estimated
savings of $220 or $180 million for DOE waste are based on EPA assumptions
explained in Appendix C. As discussed below, the BRC criterion will
produce substantial revenue increases for some businesses, but may also
result in revenue losses for others.
The NARM Limit
The combined 2 nanocurie per gram (specific activity) and 0.05
millicurie per package (total activity) NARM limit will result in an additional
cost to society ranging from zero to $23 million, depending on base case as
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explained in Chapter 6. Current disposal practice for NARM waste, which
is somewhat difficult to define given the different regulatory treatment by
the states, is assumed to range from unregulated disposal to disposal in an
Improved Shallow Land Disposal (ISO) site in the solidified waste form for
both R-RASOURC and R-RAIXRSN. All other NARM waste is assumed to be
disposed at an unregulated disposal site. Since the unregulated disposal of
R-RASOURC and R-RAIXRSN will not meet the NARM limit, generators of
these wastes could bear the additional cost of regulated disposal if they had
otherwise planned on unregulated disposal. These generators would include
municipal water systems using filters to remove radium or uranium from
water (for R-RAIXRSN), and laboratories, hospitals, and academic
institutions currently possessing radium sources (R-RASOURC).
The Croundwater Standards
As discussed in Chapter 9, the proposed groundwater standards will
have no additional economic impact on sites located above Class III aquifers
or Class II low yield aquifers under Option I, since the groundwater CPC
dose would already be limited to less than 25 millirem per year under the
LLW standard. However, under Option I, additional costs associated with
either resiting or more expensive disposal could result if an otherwise
acceptable site is above a Class I aquifer (where no degradation is
permitted) or a Class II high yield aquifer (which is subject to a H millirem
per year limit). Under Option II, additional costs are likely to be
significant (ranging from $2.1 billion to $5 billion, depending on
implementation) since the groundwater standards (4 millirem or below under
this option) would constitute effectively a lower LLW standard, since
groundwater is often the controlling pathway. In Chapter 9, the analysis
demonstrates that resiting costs are small (ranging from $3.9 million to $72
million) relative to the additional costs associated with an alternative way to
meet the groundwater standard — i.e., using a more expensive disposal
technology to meet the groundwater standard. The groundwater standards
under both Option I and Option II are expected to have little or no impact
on the generators of BRC waste since all of the groundwater standards are
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equal to or above the 4 millirem proposed BRC criterion, with the exception
of the relatively rare Class I aquifers. In any event, generators of
commercial LLW would bear the additional impacts; these generators include
electric utilities (with nuclear power plants), institutional, industrial, and
fuel cycle generators or commercial LLW, and DOE LLW generators.
The Predisposal Management Standard
Finally, as mentioned in Chapter 9, EPA expects that the 25 millirem
predisposal management standard will result in little additional cost since
several existing EPA regulations already limit the CPC dose from certain
exposure pathways and certain LLW facilities [CAA67, DOT83, EPA73,
EPA76, EPA77, SDWA7U], The additional costs of meeting this standard
would probably result from actions to control spillage (e.g., by the use of
good housekeeping practices and proper design of handling equipment) or
to limit direct gamma radiation (e.g., by placing storage bins away from the
facility boundary).
IDENTIFICATION OF INDUSTRIES BEARING THE IMPACTS
Social Versus Out-of-Pocket Costs
The previous discussion summarized the incremental societal costs
associated with the standards package. As explained in Chapter 3, these
costs are based on estimates of the before-tax cash costs paid by the
generator. Cash costs are based either on engineering estimates (e.g., for
disposal or processing) or on market rates, and are used as a proxy for
the cost of real resources (capital, labor, etc.) used in the disposal of the
waste. Throughout the El A, and in this chapter, only incremental costs
are considered as impacts, i.e., only those additional costs which are
attributable to this standards package. These estimates of social (real
resource) cost may diverge from disposal costs paid by generators for a
variety of reasons.
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One reason for this difference between social cost and prices paid
involves the distortion of societal costs by the introduction of taxes into the
analysis. In the case of inter-Compact waste shipments, where a
substantial surcharge will be imposed under the LLWPA Amendments, actual
disposal costs paid by the waste generator will exceed those estimated in
this El A. As discussed in Chapter 8, the segregation of waste into lower
activity substreams could result in additional BRC savings .to some
generators. As disposal costs rise, the role of volume reduction may
become more significant. Volume reduction is important in estimating the
distributional impact since wealth would be transferred from disposal site
operators and waste transporters (which would lose volume) to the LLW
processing business. Finally, determining who will bear the costs or
savings (i.e., the actual price paid by a given firm) depends on how much
can be passed through from seller to buyer. This pass-through of the
BRC savings or the additional costs associated with the other components of
the standards package is a function of the demand and supply elasticities in
a given industry.
In summary, the out-of-pocket expenses (or savings) for those
industries that are affected by EPA's proposed standards package may not
necessarily be equivalent to the societal costs presented above. Assuming
this divergence is small, however, the following discussion identifies the
industries that will be affected by the proposed standards package.
Industries That Benefit Financially
The most significant impact will be on those industries currently
generating wastes that are expected to meet the BRC criterion. Under
either National Implicit or National Explicit implementation, fuel cycle wastes
will meet the U millirem BRC criterion, resulting in a $106 million savings
for the fuel fabrication industry and a $7 million savings for the two firms
engaged in uranium hexafluoride conversion. Industrial facilities outside the
nuclear fuel cycle which generate source and special nuclear material
(N-SSTRASH and N-SSWASTE), generally those facilities that process and
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fabricate depleted uranium and manufacture chemicals or products containing
uranium, will also realize a $146 million savings. Electric utilities operating
pressurized water reactors using ion-exchange resins in their secondary
condensate polishing systems (P-CONDRSN) or light water reactors
generating low activity waste oils (L-WASTOIL) will collectively realize a $35
million savings. Institutional facilities (e.g., hospitals) using liquid
scintillation vials (I-LQSCNVL) will save $25 million. Generators of
consumer wastes will not be affected by the proposed standards package.
Under National Implicit implementation, two additional institutional wastes
will also meet the 4 millirem BRC criterion (I-BIOWAST and I-ABSLIQD),
resulting in a $27 million savings for the institutional facilities generating
this waste, e.g., universities and medical schools engaged in research. In
addition, two low activity industrial wastes (N-LOTRASH and N-LOWASTE)
will meet the BRC criterion, resulting in a $56 million savings to firms
generating this waste, e.g., pharmaceutical companies, independent testing
laboratories, and analytical laboratories.
Another industry for which business volume should increase due to the
*
proposed BRC criterion is unregulated waste disposal, facilities. In
comparison to the overall volume of solid waste handled by these facilities,
this business volume increase is not expected to be significant.
As mentioned earlier, although not considered to be a distributional
issue, EPA believes that, except for the potential impact of the groundwater
limits under Option II, the net impact on DOE waste disposal is expected to
be positive since the BRC savings are expected to more than offset the
additional costs associated with complying with the 25 millirem LLW
standard.
Other industries that potentially benefit from the implerrfentation of
EPA's standards package are owners of waste processing and storage
Unregulated with respect to radiation hazards.
•
10-6
-------
facilities. If, due to surcharges, disposal costs are higher than the
estimates used in this study, the business volume of facilities engaged in
either volume reduction or interim storage should increase. This increase
would be offset by the potential loss of business at existing processing
facilities due to implementation of the BRC criterion which', by allowing
unregulated disposal, would reduce the volume of waste that must be
processed.
Industries That Lose Financially
Industries that bear additional costs or lose revenues due to
implementation of the standards package include, as a result of the NARM
limit, municipalities engaged in the use of ion-exchange media for purposes
of removing radium or uranium from groundwater supplies, as well as
current holders of radium sources. The incremental cost of disposing
R-RAIXRSN in a regulated fashion is $20 million. This negative impact is
not expected to significantly affect small businesses in the local community
since the additional cost is likely to be spread widely through a tax or
water fee increase. The incremental cost of the NARM limit with respect to
R-RASOURC is at most $3.3 million. This cost represents an average
incremental cost per source on the order of $530, although some sources
could cost as much as $2,000 to dispose, as noted in Chapter 6. Since no
single generator is assumed to hold a large number of sources, this cost is
not believed to have an important impact. As noted earlier, the NARM
limit impacts could be much smaller (perhaps zero), depending on the choice
of base (i.e., what current practice really is).
Current transporters of LLW could lose $160 million in total revenues
(1985 present value over 20 years) as a result of the BRC criterion, since
roughly 25 percent of LLW volume could meet the 4 millirem criterion. This
revenue loss (which is equal to $18.8 million per year) represents less than
3.6 percent on average of the total revenues of companies involved in LLW
transport. LLW transport is dominated by a few relatively large companies,
some of which are involved in other phases of LLW disposal and other
10-7
-------
business activity. 1985 revenues for four such companies — Tri-State
Transit Co., Chemical Waste Management (Chem-Nuclear), Pacific Nuclear
Systems, and American Ecology (U.S. Ecology) — were $521 million. The
total revenue loss to the industry of $18.8 million represents 3.6 percent of
the revenues for these four companies ($521 million).
As noted earlier, impacts due to the LLW standard are not assumed to
present distributional issues since only DOE would bear additional costs.
However, the groundwater limits could require significant costs if a more
costly disposal technology is required (more likely under Option II, as
explained in Chapter 9). While a quantitative analysis was not performed,
it is likely that many generators would be able to pass these costs on to
customers (this is especially true for electric utilities). In addition, small
business are very unlikely to be large generators of radioactive wastes;
hence, impacts on small businesses are unlikely to be large. For utilities,
some institutional generators, and some industrial generators, BRC savings
could partially affect cost increases.
Summary
In summary, businesses that may benefit (by reducing cost or raising
revenue) from implementing the EPA standards package include waste
generators and unregulated disposal site operators, largely as a result of
the BRC criterion. Businesses that may bear additional costs or lose
revenue are limited to current transporters of LLW, municipalities using
ion-exchange resins as a media to remove radium from the community water
supply, and current holders of NARM sources. However, these impacts are
unlikely to be material. Finally, significant costs could arise if Option II
were chosen as the groundwater standard. These costs are unlikely to
pose distributional issues and would be offset by BRC savings.
10-8
-------
WASTE VOLUME PROJECTIONS Appendix A
This appendix documents the assumptions used to estimate the as
generated volumes for each waste considered in this analysis, for the period
between 1985 and 2004, inclusive. Volume projections for each
hydrogeologic region and for the U.S. in total were presented in Chapters
5 and 6 for 37 different wastes. For the purpose of describing the volume
projection assumptions, these wastes have been grouped as follows:
A. Twenty-five low-level wastes as defined by EPA, including power
•
reactor, fuel cycle, institutional, and industrial wastes;
B. Two LLW substreams (L-WASTOIL and P-CONDRSN);
C. Two consumer wastes (C-TIMEPCS and C-SMOKDET);
D. Six NARM wastes;
E. BIOMED waste (already deregulated by the NRC); and
F. DOE low-level waste.
In general, the volume estimation procedure captures as much
location-specific and waste-specific information as was available regarding
the current rates of waste generation and the source of the waste.
Volumes were assigned to three hydrogeologic regions which reflect
- «
different soil permeabilities (permeable, impermeable) and meteorological
conditions (humid, arid). The overall volume estimation methodology
includes five steps:
A-1
-------
1. Estimation of the current (1985) rate of waste generation.
2. Projection of the total U.S. waste volume over the 1985 to 200U
period, incorporating explicit assumptions about the average
growth in waste generation rates (using current generation rate
as a base).
3. Allocation of U.S. waste volumes to individual States based on
historical State-by-State waste generation. U.S. population, or
waste-specific information, depending on the waste.
U. Aggregation of State-by-state volumes to Compact volumes, based
on the composition of Compacts ratified in LLWPA85, or on EPA
assumptions (for States not yet belonging to ratified Compacts).
5. Assignment of each Compact to a hydrogeologic region based on
EPA assumptions regarding the hydrogeology typical of States
within each Compact. This fifth step is necessary in order to
project total health effects, since health effects differ among the
three hydrogeologic regions included in EPA's risk assessment.
In the following paragraphs, each of these steps is described in more detail
for each of the six waste groups listed above.
TWENTY-FIVE LOW-LEVEL WASTES
In genera.l, most of the assumptions used to develop volume estimates
for these wastes were derived from DM86, DM84, or DM81, and from
compilations of actual LLW generation for the years 1978, 1982, and 1983
[CRCPD83, CRCPD84, NUS80]. Detailed assumptions for each t>f the five
steps in the general methodology are listed below.
A-2
-------
Step 1: Estimate current generation rates: DM86 lists generation
rates for each of 1U8 wastes as defined by the NRC. Sixty-eight of the
NRC wastes were aggregated to form the 25 LLW streams analyzed by EPA.
The remaining 80 NRC wastes, which include DsD waste and other special
waste categories, have been excluded 'from the analysis, as explained in
Chapter 3. The correspondence between the 25 EPA and the 68 NRC
low-level wastes was listed in Table 3-1 (for the. first 25 EPA wastes
listed). For three EPA wastes, a large number of NRC wastes were
aggregated. The correspondence between these three EPA wastes and their
NRC waste counterparts is shown in Table A-1 . For each of the 68 NRC
wastes, waste volumes were first projected by State and then aggregated to
the EPA waste categories. In two cases, the generation rate listed in DM86
was not used in the analysis:
• For the 11 NRC source wastes, tfie waste volume as generated
was assumed to be equal to the volume of a drum (one 55 gallon
drum per source), and a total generation of 110 sources per year
was assumed, based on both DM86 data and EPA assumptions.
Since the volume of a drum is 0.208 cubic meters, the annual
generation rate is 29.12 cubic meters per year, in aggregate over
the 11 wastes.
• For P-FSLUDGE, DM86 implied a near zero volume generation
rate (no rate was actually listed in DM86). Since a quantitative
estimate was desired, the earlier estimate from DM81 was used in
the analysis (0.002 cubic meters per MW(e) year).
The generation rate for all power reactor wastes and for fuel cycle
wastes as listed in DM86 depends on the capacity of nuclear power plants
operating in a given year, and on the type of reactor. DM86 distinguishes
five reactor types for the purpose of waste generation rate" estimates.
Assumptions regarding the location, capacity, type, and on- and off-line
dates for each nuclear power reactor were derived from Appendix E of
DM84, which uses a similar methodology to derive volume estimates.
A-3
-------
The NRC generation rates for each of the 68 NRC wastes are listed in
Table A-2. The assumptions regarding nuclear power plant on-line dates
and reactor type are listed in Table A-3.
Step 2: Project 20-year volumes: Estimation of waste generation
growth is included implicitly for fuel cycle and power reactor wastes since
the generation rate depends on the number and mix of reactors operating in
a given year. Thus, the aggregate growth rate for these wastes is
determined by the reactor on-line dates listed in Table A-3. As noted in
Chapter 5, Table A-3 includes fairly optimistic assumptions regarding the
operation of plants now under construction, since the future operation of a
number of nuclear power plants under construction has been questioned by
utility rate commissions, and a few reactors have been cancelled. With
respect to other LLW (institutional and industrial wastes), a zero generation
rate was assumed for most wastes since the generation is tied to specific
activities at specific manufacturing sites, or relates to institutional wastes
for which volume reduction (including less generation) is being practiced or
which have been partially deregulated by the BIOMED rule. The analysis
includes 11 exceptions to this "no growth" assumption, including
institutional trash and absorbed liquids, industrial low and high activity
wastes and trash, and special source waste and trash. For these wastes,
the historical rate of increase for industrial wastes between 1982 and 1983
*
(about three percent) was assumed to continue through 2001.
Thus, in order to calculate total waste volume over 20 years for wastes
with no growth, the generation rate listed in Table A-2 was simply
multiplied by 20. For wastes growing at three percent per year, a factor
of about 27.7 was used (which reflects the compound growth in generation
**
rate of three percent per year). To simplify actual calculations, all
At the time of this analysis, data on actual waste generation in years
after 1983 were not available.
Algebraically, 27.7 -- (1.03)"
n=1
A-U
-------
annual generation rates (except power reactor and fuel cycle 'wastes) were
multiplied by 20; wastes growing at three percent per year were then
multiplied by 1.383 (i.e., 27.7 divided by 20). This factor (1.383) appears
in the row labeled "growth factor" in Table A-2; the factor equals one for
•
wastes for which a zero growth rate is assumed.
Step 3: Allocate U.S. volume projections to States: State-by-State
allocation of waste generation was determined by the location of the nuclear
power plants for all power reactor wastes (the State is indicated in Table
A-3). Generation of fuel cycle wastes was allocated to the States in which
the fuel cycle processing plants reside, in proportion to fuel cycle plant
capacity (listed in EEI84b).
Generation of institutional wastes was allocated to States based on
historical waste generation, as listed in NUS80, CRCPD83, and CRCPD81.
Since waste generation within a State is often small, the allocation for each
State was determined by a weighted sum of waste generated in that State
over the three years for which data were available at the time of the
analysis (1978, 1982, and 1983), divided by the total U.S. generation (also
a three-year weighted sum). Since the BIOMED rule deregulated a
significant portion of institutional wastes (which thereby changed the mix of
institutional wastes disposed in regulated facilities), more recent years were
weighted more heavily. The following weighting was assumed: 100 percent
x 1983 + 50 percent x 1982 + 25 percent x 1978. The State-by-state
"generation rates" (actually, waste received at commercial disposal facilities)
are shown in Table A-U for institutional waste.
For most- of the industrial wastes, an estimate (from DM86) of the
fraction of waste generated in each NRC region (as defined in DM86) was
also included. In order to allocate U.S. generation to States, first, the
DM86 estimates by NRC region were used to allocate generation* to one of
the five NRC regions (the NRC regional breakdowns are also listed in Table
A-2; NRC region is also noted next to the name of each State in Table
A-5). Within NRC regions, an unweighted sum of the total actual 1978,
A-5
-------
1982, and 1983 State-by-State industrial waste generation was used to
allocate generation to each State. These State-by-state industrial waste
volumes are shown in Table A-5. In several cases, wastes were identified
in DM86 (or its references) as originating from a specific plant. In such
cases, the location of the plant was used to determine the State in which
the waste was generated.
Table A-6 summarizes the estimated volumes for each of the 68 NRC
wastes in each State, using the procedures described above. Table A-7
summarizes the State-by-state volumes for 24 EPA wastes (where
P-COTRASH and B-COTRASH have been aggregated to form L-COTRASH).
Step U: Aggregate State-by-state volumes into Compact volumes:
Table A-8 lists the States assumed to be in each of 12 Compacts, as used in
the analysis. The Compact definitions correspond to those assumed in
LLWPA85 for ratified Compacts, and otherwise represent EPA assumptions
regarding the likely composition of Compacts as ultimately ratified. It is
emphasized that Compact composition is still in a state of flux; these
Compact definitions are used for illustration purposes only. Chapter 8
considers a sensitivity analysis wherein these definitions are changed in
order to determine the degree to which estimates of cost and health risk are
affected by these assumptions (the impact is shown to be small). Compact
volumes were calculated simply by summing the State volumes within each
Compact.
Step 5: Assign each Compact to a hydrogeologic region: Table A-8
also lists the hydrogeologic region assigned to each Compact in order to
derive estimates of total waste volume by region. The final volume
estimates by region for each waste were presented in Chapter 5, Table 5-1.
Regional volumes are calculated simply by summing the volumes for the
Compacts within the region for each waste. - -
A-6
-------
TWO LLW SUBSTREAMS
Waste volume generation rates for two LLW substreams (L-WASTOIL
and P-CONDRSN) were not provided in DM86. From OTHA83 and EEI84c,
estimates of the average waste oil generation by BWRs and PWRs,
respectively, were calculated to be about 4,600 gallons per year (BWR) and
1,100 gallons per year (PWR).- These figures were divided by the average
plant size for BWRs and PWRs (837 MW and 937 MW, respectively) to
determine an average generation rate of 2.08 E-2 cubic meters per MW-year
for BWRs, and U.44 E-3 cubic meters per MW-year for PWRs. Similarly,
Appendix E of DM84 lists the average generation rate of P-CONDRSN as
0.335 cubic feet per MW-year (resins plus pre-coat filter sludge), and
assumes that 51 percent of the PWRs will be equipped with secondary
condensate polishing systems. These assumptions imply an average
generation of about 4.84 E-3 cubic meters per MW-year per PWR.
Once the generation rates are determined, the remainder of the
estimation procedure is identical to that used for the 25 LLW, using the
nuclear plant data in Table A-3.
TWO CONSUMER WASTES
EPA's analysis of a BRC standard considers two consumer wastes in
order to provide a reference point for the risk analysis. The two wastes
are americium smoke detectors (C-SMOKDET) and tritiated time pieces
.(C-TIMEPCS). For both wastes, base generation rates were determined
from assumptions listed in EEI84c. The derivation of U.S. total annual
generation rates for each waste is as follows:
A. C-SMOKDET: EEI84c notes that 100 million detectors will be in
operation by the year 2000. Assuming a 10-year life per detector,
A-7
-------
this figure (which is assumed to be a steady state number and which
implies about 1.2 detectors per single family dwelling) results in a
disposal rate of about 10 million detectors per year. At a unit volume
of 460 cubic centimeters per detector, the annual disposal volume is
4,600 cubic meters per year.
B. C-TIMEPCS: EElSUc assumes that 6.6 million watches per" year (at 30
cubic centimeters per watch) and 0.5 million clocks per year (at 630
cubic centimeters per clock) will be disposed. These assumptions are
equal in aggregate to an annual disposal rate of 520 cubic meters per
year.
The annual rate of waste generation of both C-SMOKDET and
C-TIMEPCS is assumed to remain constant, so 20-year volumes are 92,000
and 10,400 cubic meters, respectively (i.e., current rates are simply
multiplied by 20). The U.S. waste volume was distributed among the States
based on 1983 State populations. Aggregation to Compacts and regions
follows the procedure used for the 25 commercial LLW (i.e., by summing the
State volumes within each Compact). 4
SIX NARM WASTES
The total volumes for each of the six NARM wastes analyzed in
Chapter 6 were presented in Table 6-2, together with an assumed density.
U.S. total volumes were derived by multiplying annual generation rates
(converted to cubic meters per year), as listed in various tables in PEI85a,
by 20. This procedure implicitly assumes that the rate of NARM generation
will not increase. This assumption is plausible since the most important
•
NARM wastes, i.e., those which EPA is proposing to regulate, are either
not yet generated, as for R-RAIXRSN, or are no longer manufactured in a
significant quantity, as for R-RASOURC.
A-8
-------
In order to estimate health effects-by region, regional NARM volumes
were also estimated. The allocation of U.S. volume to States, Compacts,
and hydrogeologic regions was performed by assuming that NARM generation
is proportional to 1983 State population, except for R-RASOURC.
R-RAS"OURC volumes were first allocated to NRC region based on data
provided in DM86, which in turn were drawn from the actual volume of
'sources collected at EPA's Eastern Environmental Radiation Facility in
Montgomery, Alabama. 1983 State population was then used to allocate
R-RASOURC volumes within an NRC region to each State. Table A-9 lists
the estimated NARM generation by Compact and hydrogeologic region.
BIOMED WASTE
Since disposal of BIOMED waste is no longer regulated, statistics
regarding the volume of waste generated or disposed are not available. An
estimate of the total volume of this waste over the next 20 years was
derived from the Value/Impact Statement that accompanied the NRC BIOMED
rule (10 CFR Part 20.306). The Value/Impact Statement estimates the
annual waste volume of liquid scintillation vials deregulated by the rule at
11,031 cubic meters, and the volume of biomedical waste at 2,294 cubic
meters. Thus, in aggregate, 13,328 cubic meters of waste per year were
deregulated. Empirical evidence seems to support these volume estimates.
The volume of institutional waste shipped to commercial disposal sites
declined from 21,248 cubic meters in 1978 to 10,658 cubic meters in 1982,
1,916 cubic meters in 1983, and 2,870 cubic meters in 1984. While other
factors may have contributed to this decline, such as increased volume
reduction or reduced levels of biomedical research, the figures seem to
indicate that the BIOMED rule resulted in a decrease of between 5,000 to
15,000 cubic meters per year in the amount of institutional waste sent to
regulated disposal sites. - •
A-9
-------
The 20-year waste volume for BIOMED was estimated assuming no
growth in the estimated annual deregulated generation rate; thus, total
volume is 266,560 cubic meters (20 times 13,328). This volume was not
allocated to State or Compact. However, BIOMED waste was allocated to
hydrogeologic region based on the regional volumes of the scintillation vial
and biomedical waste components of BIOMED, respectively. The regional
volumes are listed in Table 5-1.
DOE WASTE VOLUME
Relative to the methodology of estimating waste generation for the
other wastes, the methodology used to estimate DOE waste volume was
considerably abbreviated. In essence, total U.S. DOE waste generation was
taken directly from DOE86, Table 1-13, where the generation between 1985
and 2004, inclusive, was summed. The generation of saltcrete at the
Savannah River Plant was not included in the estimate. In general, the
DOE estimates of future waste generation assume no growth in annual
generation rate, although historical generation rates have increased.
DOE waste generation by State and hydrogeologic region was
determined based on the location of DOE facilities. Tables A-10, A-11, and
A-12 illustrate the calculations and procedure. Table A-10 shows the DOE
projection of aggregate future generation (the left two columns of Table
A-10, which are based on Table 4.13 of DOE86) and the historical
generation of the six major DOE facilities (from Table 4.3 of DOE86) over
the period 1981-1985. Historical generation is used to allocate future
generation to specific facilities. Since facility-specific five-year data on the
facilities in the "All Other" category are not listed, total cumulative volume
for these facilities (from Table 4.U in DOE86 and shown in Table A-11) Is
used to allocate "All Other" generation to specific facilities. Finally, Table
A-12 summarizes the State, hydrogeologic region, and waste volume
assigned to each DOE "generator" facility, using allocation percentages from
A-10
-------
Tables A-10 (for major DOE facilities) an'd A-11 (for "All Other" DOE
facilities). Note that since DOE LLW is assumed to be disposed in facilities
separate from commercial LLW disposal sites, designation of a Compact for
each facility is unnecessary.
A-11
-------
Table A-1
CORRESPONDENCE BETWEEN SELECTED
EPA AND NRC WASTE CATEGORIES
Waste Category
1. Isotope Production
Waste
EPA Mnemonic
N-ISOPROD
NRC Mnemonics
2. Tritium Waste
N-TRITIUM
3. Sealed Sources
N-SOURCES
N-ISOPROD
N-ISOTRSH
N-SORMFC1
N-SORMFC2
N-SORMFC3
N-SORMFCU
N-NECOTRA,
N-NESOLIQ,
N-NENCGLS,
N-NETRGAS,
N-NECARLI.
N-MWABLIQ,
N-MWWASTE,
N-TRITGAS,
N-TRILIQD,
N-NEABLIQ,
N-NEVIALS,
N-NEWOTAL,
N-NETRILI,
N-MWTRASH,
N-MWSOLIQ,
N-TRIPLAT,
N-TRISCNT,
N-TRITRSH
N-TRITSOR, N
N-COBLSOR, N
N-STROSOR, N
N-PLU8SOR. N-
N-AMERSOR, N
N-AMBESOR
CARBSOR,
-NICKSOR,
-CESISOR,
PLU9SOR.
-PUBESOR,
SOURCE: Putnam, Hayes & Bartlett, Inc., June 1987. NRC mnemonics are
listed in Table B-1 of DM86.
A-12
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