EPA/402/R-92/007
              rotection
Air And Radiation
(6602J)
4O2-R-92-O07
September 1992
              jlatory Impact Analysis
         For EPA's High-level Waste
         Standard (40 CFR Part 191)


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Regulatory Impact Analysis
For EPA's  High-level Waste
Standard (40 CFR Part 191)
         402-R-92-007
          August 1992
    Office of Radiation Programs
     Office of Air and Radiation
U.S. Environmental Protection Agency
       401 M Street, S.W.
      Washington, DC 20460

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                        TABLE OF CONTENTS

Chapter                                                      Page

Table of Contents	     i
List of Exhibits	   v
List of Abbreviations   	   vii
Executive Summary 	    ix

1    INTRODUCTION 	   1

     1.1  OVERVIEW	   1
     1.2  SOURCES OF RADIOACTIVE WASTES 	   1
          1.2.1     Origin and Current Locations of
                    High-Level and Transuranic Wastes ....   2
          1.2.2     Current and Projected Quantities of
                    Wastes Generated by Commercial Nuclear
                    Power Plants	   4
          1.2.3     Current and Projected Quantities of
                    High-Level Wastes Generated by DOE
                    Non-Commercial Facilities 	   4
          1.2.4     Current and Projected Quantities of
                    Transuranic Wastes  	   7
     1.3  ANALYTICAL APPROACH 	   7
          1.3.1     High-Level Wastes 	  10
               1.3.1.1   Data Sources and Limitations ....  11
               1.3.1.2   Discounting of Costs and
                         Health Effects 	  12
          1.3.2     Transuranic Wastes  	  12

2    ANALYSIS OF COSTS AND EFFECTS OF OPTIONS FOR DISPOSING OF
     WASTES	13

     2.1  HIGH-LEVEL WASTES 	  13
          2.1.1.    Defining the Options  	  13
               2.1.1.1.  Geologic Media 	  13
               2.1.1.2.  Waste Form	."  14
               2.1.1.3   Canister Life	14
               2.1.1.4   An Array of Options	14
          2.1.2     Population Risks and Individual
                    Exposures	15
               2.1.2.1   Understanding the CCDF Measure of
                         Population Risks 	  15
               2.1.2.2   Understanding the Individual Dose  .  18
               2.1.2.3.  Measuring the Population Risks ...  18
               2.1.2.4   Measuring the Individual Doses ...  24
          2.1.3     Costs	24
               2.1.3.1   Data Sources	25
               2.1.3.2.  Tuff	25
               2.1.3.3   Salt and Basalt	27
               2.1.3.4.  Granite  	  28
               2.1.3.5   Comparison of Costs of Repositories

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                        TABLE OF CONTENTS
Chapter                                                      Page
                         by Medium	29
               2.1.3.6   Canister and Waste Form Costs   ...   29
               2.1.3.7   Total Cost by Options	31
               2.1.3.8   Summary of Costs, Population Risks,
                         and Individual Doses 	   31
     2.2  TRANSURANIC WASTES  	   34
          2.2.1.    Defining the Option 	   34
          2.2.2     Population and Individual Risks  	   35
          2.2.3.    Cost of Option	35

3    LEAST-COST OPTIONS AND COST-EFFECTIVENESS  	   37

     3.1  HIGH-LEVEL WASTES 	   37
          3.1.1.    Least-Cost Options for Achieving Limits
                    on Health Effects	36
               3.1.1.1   Costs and Effects of Varying the
                         Medium	40
               3.1.1.2   Costs and Effects of Varying the
                         Leach Rate and Canister Life ....   43
          3.1.2.    Least-Cost Options for Achieving Limits
                    on Individual Doses 	   43
          3.1.3     Conclusions	46
     3.2  TRANSURANIC WASTES	46

4    40 CFR PART 191 AND RELATED REGULATIONS	47

     4.1  REQUIREMENTS OF 40 CFR PART 191	47
          4.1.1.    The Containment Requirement 	   47
          4.1.2     Assurance Requirements  	   48
          4.1.3     Individual Protection Requirements   ...   50
          4.1.4     Options for Meeting the Proposed
                    Standard	50
               4.1.4.1   High-Level Wastes  	   50
               4.1.4.2   Transuranic Wastes 	   51
     4.2  RELATIONSHIP OF 40 CFR PART 191 TO NUCLEAR
          REGULATORY COMMISSION RULES 	   51

5    THE IMPACTS OF GASEOUS RELEASES  	   55

6    THE IMPACTS OF 40 CFR PART 191	59

     6.1  ASSESSING THE STRINGENCY OF 40 CFR PART 191 ....   59
     6.2  PROFILES OF WASTE GENERATORS  	   62
          6.2.1.    Generators of High-Level Wastes  	   62
6.2.1.IThe Commercial Nuclear Power
                         Industry	62
               6.2.1.2.  DOE Non-Commercial Generators
                         of High-Level Wastes 	   66
          6.2.2     Generators of Transuranic Wastes  ....   66

                                ii

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                        TABLE OF CONTENTS
Chapter                                                      Page

     6.3  IMPACTS OF ALL COSTS ASSOCIATED WITH OPTIONS  ...  66
          6.3.1     Cost to DOE of Demonstrating Compliance .  66
          6.3.2     Costs to Generators of High-Level Wastes   70
               6.3.2.1   Fees Charged to Commercial Waste
                         Generators	70
          6.3.2     Impacts of Costs on Generators of Defense
                    High-Level and Transuranic Wastes ....  82


REFERENCES	84
Appendix A	A-l
                               ill

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IV

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                         LIST  OF  EXHIBITS

Exhibit                                                      Page

1-1     Commercial Nuclear Power Reactors  in the
        United States 	 3
1-2     Projected Accumulation of Permanently
        Discharged Spent Fuel  	 5
1-3     Projected High-Level Waste Inventories,  1990-2020 ... 6
1-4     Accumulated Volumes of Transuranic Wastes 	 8
1-5     Projected Transuranic  Waste Inventories,  1990-2013  .  . 9

2-1     Policy Options for a High-Level Waste Repository  .  .  16
2-2     Hypothetical Complementary Cumulative Distribution
        Function (CCDF)   	  17
2-3     Complementary Cumulative Distribution Function by
        Medium	19
2-4     Comparison of Complementary Cumulative Distribution
        Functions	21
2-5     Total Expected Health  Effects and  Individual Doses for
        Each Policy Option  	22
2-6     Summary of Development and Evaluation Costs  for DOE
        Option Two   	26
2-7     Present Value of Cost  Elements by  Medium	30
2-8     Costs by Medium, Leach Rate and Canister Life ....  32
2-9     Summary of Costs and Health Effects 	  33

3-1A    Least-Cost Options for Meeting Six Hypothetical
        Limits on Health Effects   	  38
3-1B    Least-Cost Options for Meeting Six Hypothetical
        Limits on Health Effects After Eliminating Disposal
        in Tuff	39
3-1C    Least-Cost Options for Meeting Six Hypothetical
        Limits on Health Effects After Eliminating Disposal
        in Tuff or Salt	41
3-2     Costs and Health Effects of Least-Cost Options
        by Medium	42
3-3     Cost-Effectiveness of  Salt Options	44
3-4     Costs and Individual Doses of Least-Cost Options by
        Medium	45

4-1     The Containment Requirement  	  49
4-2     Effects of 40 CFR Part 191 and 10  CFR Part 60 on
        the Options for Disposing of High-Level and
        Transuranic Wastes  	  52
4-3     Options Meeting All Requirements of 40 CFR Part 191
        and 10 CFR Part 60  	54

5-1     Sensitivity of Health  Effects to Changes in  Leach Rate
        and Canister Life	56
5-2     Sensitivity of Cost-Effectiveness  to Performance of
        Canister   	58

                                 v

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                         LIST  OF EXHIBITS

Table                                                        Page

6-1     Nuclear Capacities and Market Shares for the Ten Largest
        Nuclear Utilities 	  64
6-2     Comparisons of Projections of U.S.  Commercial
        Nuclear Capacity  	  65
6-3     1992 Budgets and Employment of Facilities Generating
        Non-Commercial HLW and TRU Waste	67
6-4     Long Run Price Elasticity  of Demand by Sector and Regiofl2
6-5     Commercial Generation  of Electricity in the United States
          	73
6-6     Sales of Electricity to Ultimate Customers by Sector and
        Region, 1990  	74
6-7     Average Revenue by Sector  and Region,  1990	75
6-8     The Economic Impact Model	77
6-9     Summary of Economic Impacts of Three Configurations and
        Two Increments for High-Level Waste Facilities for the
        United States 	  79
6-10    Incremental Cost of Regulation by Region	81
                               VI

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                      LIST OF ABBREVIATIONS
CCDF

CFR
c/kWh
Com
D&E
DOE
EPA
HLW
Ind
kWh
MGDS
MRS
MTHM
MWe
NRC
NWPA
R&D
Res
RIA
TRU
TSLCC
WIPP
Complementary  Cumulative  Distribution
Function
Code of Federal Regulations
Cents per kilowatt hour
Commercial
Development and Evaluation
U.S. Department of Energy
U.S. Environmental Protection Agency
High-level wastes
Industrial
Kilowatts of electricity
Mined Geologic Disposal System
Monitored Retrievable Storage
Metric tons of heavy metal
Megawatts of electricity
U.S. Nuclear Regulatory Commission
Nuclear Waste Policy Act
Research and Development
Residential
Regulatory Impact Analysis
Transuranic wastes
Total System Life-Cycle Costs
Waste Isolation Pilot Plant
                               VII

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Vlll

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                        EXECUTIVE SUMMARY


This Regulatory Impact Analysis (RIA) weighs the costs and benefits
of  the  U.S.  Environmental  Protection  Agency's  standards  for
disposing of spent nuclear fuel, high-level  wastes, and transuranic
wastes, as proposed in 40 CFR  Part 191, Subpart B.   Subpart B has
three  components:  a  containment   requirements,   an  assurance
requirements, and  an  individual exposure requirement.   The first
and the last of these are examined here.
      *
      «>
Two repositories are envisioned: one for spent fuel and high-level
wastes, and one for transuranic wastes.  Data availability allows
the  development  of  costs,   population  risks,   and  individual
exposures for 48 options for disposing  of the former.  Disposal in
four geologic media is examined: tuff,  salt, basalt, and granite.
Two types of engineered  barriers are also  considered:  waste form
and canister life.  The  rate at which  the  radioactive wastes are
released to the repository environment depends on the waste form.
Four  of  these  release,  or  leach,  rates  are  evaluated.   Three
canister lives, ranging from 300 to  3,000 years are also examined.
Data limitation s preclude this type of analysis for a repository
for transuranic wastes.  For transuranic wastes, only one option is
considered.

The results of  the analysis are unusual.   The least-cost options
for disposing of spent fuel and high-level wastes  are also the most
effective  in  reducing health effects  and limiting  individual
exposures.  These  are the  options based  on a  repository in tuff.
The lowest cost of the tuff option results in predicted statistical
health  effect   over  10,000  years  and an   individual  dose of  0
millirem per year at  a cost of  $12.5  billion for a 100,000 MTHM
repository (discounted 1990 dollars).

Among the costs examined as part of  the analysis are the costs DOE
may incur to demonstrate compliance with 40  CFR Part  191.  Although
no firm data exist, costs  of related activities  are that include
all  or portions  of  the  cost of demonstration  compliance.   An
extreme upper bound of $7 billion is created by assuming that all
of the costs DOE  will incur to develop and evaluate the facility
(D&E costs) are cost of demonstrating compliance.  An alternative,
but still  conservative,  approach is to  assume  that the  cost is
equal to the cost of  various models that would be needed plus the
full  cost  of  the   Nuclear   Regulatory  Commission's  licensing
proceedings, estimated at about $160 million.  The actual costs of
demonstrating compliance are likely only a  portion of this.
                                IX

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                           CHAPTER ONE
                           INTRODUCTION

                          1.1  OVERVIEW


     The U.S.  Environmental Protection Agency (EPA) is responsible
for developing generally applicable environmental standards for the
management and disposal of  spent  nuclear  fuel,  high-level waste,
and transuranic radioactive wastes.  To this end,  EPA promulgated
standards on August 15,  1985 (40 CFR Part 191).  In 1987, however,
following a legal challenge, those parts of the standards dealing
with disposal (Subpart B)  were remanded to the Agency for further
consideration by a U.S. Court  of  Appeals.   Since  then the Agency
has been in the  process of reproposing  these disposal standards,
and  adapting  them   to   respond   to   programmatic  changes  and
information that have become available since the 1985 proposal was
developed.  The resulting  revised  Subpart B is the subject of this
Regulatory Impact Analysis (RIA).

     The RIA is divided into six chapters.   The remainder of this
chapter briefly  describes the processes by which  the wastes are
generated, the  volumes of  waste  that must  be disposed  of,  the
assumptions on which the RIA is based, and the analytical approach
to  the estimation  of the  impacts of  the proposed  regulation.
Chapter  Two  defines  the  options for  disposing  of  wastes  and
describes the health and cost effects  associated with each option.
Chapter Three assesses the cost-effectiveness of the options.

     Chapter Four contains further detail on the requirements of 40
CFR  Part  191  and  describes  its  relationship to U.S.  Nuclear
Regulatory Commission (NRC)  and  U.S.  Department  of  Energy (DOE)
regulations.    Chapter Five  discusses special issues  related  to
gaseous  releases  such  as  carbon  14  from  unsaturated,  porous
material.  Chapter Six concludes the report with an analysis of the
economic impacts  of  40 CFR  Part  191  on those who will  bear its
cost,  and  includes  a discussion  of  the  cost of  demonstrating
compliance.
                1.2   SOURCES  OF  RADIOACTIVE WASTES
     Radioactive  wastes  are  the  result  of  governmental  and
commercial  uses  of  nuclear  fuel and  material.    For  regulatory
purposes EPA defines  five  main  categories of radioactive wastes:
spent  nuclear  fuel,  high-level  wastes  other  than spent  fuel,
transuranic  (TRU)  wastes,  uranium  mill  tailings,  and  low-level
wastes.  Spent nuclear  fuels, high-level  wastes,  and transuranic
wastes are the  categories covered by the proposed 40 CFR Part 191.
Information on  the sources and processes that  produce these wastes,

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and on the current and projected quantities  of the waste that must
be disposed of,  is provided in the following sections.


        1.2.1  Origin and Current Locations of High-Level
                      and Transuranic Wastes


     Fissioning of nuclear fuel in nuclear reactors creates what is
known  as  "spent" or  irradiated  nuclear fuel.    Sources  of spent
nuclear fuel include fuel discharged  from commercial nuclear power
plants;  fuel  elements  generated  by  government-sponsored  R&D
programs,  universities,  and  industry;  fuels  from  experimental
reactors (for example,  liquid metal fast breeder reactors and high-
temperature   gas-cooled  reactors);   U.S.   Government-controlled
nuclear weapons  production  reactors;  and  naval  reactor fuels and
other  U.S.  Department   of  Defense  (DOD)  reactor  fuels.   Fuel
discharged  from  commercial nuclear  power  plants  accounts  for
largest portion by far.   Most spent fuel is currently being stored
in water pools at reactor sites where  it is produced (EPA 92A) .
Exhibit 1-1 provides a map of the locations of commercial nuclear
reactors in the United States.

     Spent  nuclear  fuel  from  defense  reactors  is  routinely
reprocessed to recover unfissioned uranium and plutonium for use in
weapons  programs.    Most of the  radioactive material goes  into
acidic  liquid wastes that  will  later be converted  into  various
types of solid materials. These highly radioactive liquid  or solid
wastes from reprocessing spent nuclear fuel have traditionally been
called  high-level wastes.   No  commercial   spent  fuel is  being
reprocessed in the United States at this time.   High-level wastes
derived  from  reprocessing  activities  are   presently stored  on
Federal  reservations in South  Carolina,  Idaho,  and  Washington.
High-level wastes  are also stored at the Nuclear  Fuel  Services
Plant  in New York,  a  facility  for reprocessing spent fuel  that
closed in  1972 and  is no longer  accepting new  shipments  of spent
fuel or any other radioactive waste (EPA 92A).

     Transuranic wastes,  as defined  in this rule,  are materials
containing  elements having  atomic  numbers  greater  than 92  in
concentrations  greater  than  100  nanocuries  of  alpha-emitting
transuranic isotopes, with  half-lives  greater than  twenty years,
per gram of  waste (EPA  92B) .   Most  transuranic  wastes are  items
that have become contaminated as a result of activities associated
with  the  production  of nuclear  weapons   (for  example,  rags,
equipment,  tools, and contaminated organic and inorganic sludges).
These wastes are currently being stored on Federal reservations in
Washington, Idaho, New Mexico,  Tennessee,  South  Carolina,  Nevada,
and Colorado  (ORNL 91).

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  1.2.2  Current and projected Quantities of Waste Generated bv
                 Commercial Nuclear Power Plants


     The quantities of waste generated at commercial nuclear power
plants can be measured  in several ways.  The first is in terms of
size,  including metric  tons  of initial heavy metal (MTHM), cubic
meters,  and  number of  fuel  rods.   The MTHM measure  is the most
commonly employed  measure  of spent fuel quantities,  although the
cubic meters measure  is useful in comparing volumes of spent fuel
with volumes of other types of radioactive waste.  As of December
31,  1990,  there  were  21,868  MTHM   of commercial  spent  fuel
assemblies.  Converted  to  cubic  meters and including the spacing
between the fuel rods, the quantity amounts  to 9,895 cubic meters.

     The   quantities  of   wastes  may   also   be  measured  in
radioactivity.  While spent fuel  accounts for only a small share of
the total volume of radioactive wastes, it accounts for most of the
radioactivity.  For example,  spent fuel in 1990 made up 2.4 percent
of the combined volume of spent fuel and high-level wastes in cubic
meters but accounted  for 95.7 percent of the radioactivity.

     A third measure of the quantities  of  radioactive  wastes is
thermal  power.   Thermal power is  a measure of the rate  of heat
energy  emission that results from  the  radioactive  decay  of  a
material.  Because facilities must be designed to manage the amount
of thermal power produced by the wastes the facilities contain,
this measure is an important parameter in building a nuclear waste
storage facility (ORNL 91).

     Exhibit 1-2 provides information  on the current and projected
mass,  radioactivity,   and  thermal  power  of  the   cumulative
inventories of  spent fuels generated by U.S. commercial  nuclear
power plants between 1990 and 2020.  The data provided  are based on
a  scenario  prepared by the  U.S. Department of Energy  (DOE)  for
nuclear power capacity in which there  are no new orders of nuclear
power  plants.    Additional  information  on  this  and  alternative
scenarios is provided in the discussion of the prospects for growth
in the nuclear  power  industry in Chapter Six.


   1.2.3   Current and Projected Quantities of High-Level Waste
           Generated by DOE  Non-Commercial  Facilities
     DOE operates four sites that generate high-level waste.  Two,
the Savannah River  Site  and the Hanford Reservation,  manufacture
nuclear materials  for weapons.  Two  others,  the  Idaho National
Engineering Laboratory and the West Valley Site, engage in nuclear
fuel reprocessing and research. Exhibit 1-3 lists the current and
projected quantities of high-level  wastes accumulated at the four
sites in terms  of their  volume, radioactivity,  and thermal power

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EXHIBIT 1-2
PROJECTED ACCUMULATION OF PERMANENTLY DISCHARGED
SPENT FUEL, 1990-2020
(by mass, radioactivity, and thermal power)
YEAR
19901
1995
2000
2005
2010
2015
2020
MASS
(metric tons of
heavy metal)
21,868
31,600
41,300
50,900
60,300
69,700
75,900
RADIOACTIVITY
(million curies)
23,351
26,700
30,600
35,300
39,300
39,000
35,200
THERMAL POWER
(million watts)
86.6
99.8
112.9
130.9
146.3
142.5
126.7
Source: DOE/Energy Information Administration projections for the
No New Orders Case as presented in ORNL 91, Table 1.3.
1
 Data for 1990 are actual accumulations.

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EXHIBIT 1-3
PROJECTED HIGH-LEVEL WASTE INVENTORIES, 1990-2020
(by volume, radioactivity, and thermal power)
YEAR
19902
1995
2000
2005
2010
2015
2020
VOLUME1
(thousand cubic meters)
399.2
354.0
334.2
320.2
328.2
335.2
336.2
RADIOACTIVITY
(million curies)
1,045.3
1,227.5
1,355.0
1,487.0
1,213.4
1,185.5
1,138.8
THERMAL POWER
(thousand watts)
2,965
3,222
4,079
4,580
3,620
3,588
3,461
Source: DOE/Energy Information Administration projections as presented in
ORNL 91, Tables 2.7-2.9.
   1 Volume decreases between 1990-2005 owing to the use of glass. This process allows the same
wastes to be stored in smaller volume.  In 1990, no glass was used.
   fj
    Data for 1990 are actual accumulations.

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for five-year intervals from 1990 through 2020 (ORNL 91).


  1.2.4  Current and Projected Quantities of Transuranic Wastes


     Transuranic wastes are the result of reprocessing plutonium-
bearing fuel or  fabricating nuclear weapons.  Exhibit 1-4 lists the
11  facilities  that  generate  transuranic  wastes  along with  the
volume of wastes stored at each site as of December 1990.   Two of
the facilities,  Lawrence Livermore National Laboratory and Argonne
National Laboratory East generate waste but ship it elsewhere for
storage.  Two additional facilities,  the Mound Plant and the Rocky
Flats Plant, have  stored waste on site in the past,  but  will be
sending future wastes to one of the seven other facilities listed,
which have  been designated  by  DOE  as TRU  waste  storage  sites
(ORNL 91).

     Certain factors  must be  considered  in  interpreting  Exhibit
1-4.  First, early disposal practices did not include the current
reguirements for waste identification and categorization.   As the
efforts  to  identify   and  characterize   the  wastes  continue,
significant changes in estimates of the quantity of TRU waste are
anticipated.  Second, prior to 1970,  all DOE-generated TRU wastes
were disposed of  in several landfill-type configurations  at the
facilities.    This  is  the "buried"  waste  shown in Exhibit 1-4.
After 1970,  when the Atomic Energy Commission concluded that these
wastes  should  have greater confinement,  TRU wastes began  to be
placed in "retrievable" storage to enable eventual placement in a
long-term storage  facility  (ORNL 91) .   At this time,  only this
retrievable waste  is  intended  to  be  removed  eventually to a DOE-
designated storage  site.  Therefore, the projections in Exhibit 1-5
of wastes to  be accumulated through  2013, which are  intended to
indicate  the magnitude  of the  disposal  problem, include  only
retrievably stored wastes.  Total volumes of TRU waste, including
buried waste, may  be calculated by  adding the  estimated  191,000
cubic meters  of total  buried  waste  as  of  1990  to each  of" the
volumes in Exhibit 1-5.


                     1.3   ANALYTICAL  APPROACH
     This RIA provides an economic analysis of alternatives for the
long-term disposal of the current and projected quantities of spent
fuel,  high-level  wastes,  and  transuranic  wastes  described  in
section 1.2.  For  purposes of  the discussion and analysis in the
remainder of the RIA,  spent fuel and high-level wastes are combined
into a single group that will be referred to as high-level wastes
(HLW) as the disposal techniques for these wastes are similar, and
they are  likely to be stored in  the  same  facility.   Transuranic
wastes will continue to be discussed separately.

                                7

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EXHIBIT 1-4
ACCUMULATED VOLUMES OF TRANSURANIC WASTES
December 31, 1990
FACILITY
Hanford Reservation
Idaho National Engineering
Laboratory
Los Alamos National
Laboratory
Oak Ridge National
Laboratory
Sandia National Laboratory
Savannah River Site
Mound Plant
Rock Flats Plant
Nevada Test Site
Lawrence Livermore
National Laboratory1
Argonne National
Laboratory1
TOTAL
BURIED WASTES
(cubic meters)
109,000
57,100
14,000
6,200
3
4,530
—
—
—
—
—
190,833
RETRIEVABLY STORED WASTES
(cubic meters)
8,870
37,500
7,580
1,970
—
3,990
222
915
587
	
	
60,634
Source: ORNL 91
is facility generates transuranic wastes but ships them to other facilities for storage.

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EXHIBIT 1-5
PROJECTED TRANSURANIC WASTE INVENTORIES, 1990-2013
(by volume, radioactivity, and thermal power)
YEAR
19901
1995
2000
2005
2010
2013
VOLUME
(thousand cubic meters)
60,608
72,108
83,608
95,108
106,608
113,508
RADIOACTIVITY
(million curies)
4,779
7,863
9,774
11,581
13,291
14,276
THERMAL POWER
(thousand watts)
74.57
157.01
228.62
295.78
358.96
395.14
Source: DOE/Energy Information Administration projections as presented in
ORNL 91, Table 3.1.
*Data for 1990 are actual, not predicted, accumulations.

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     The RIA takes a generic approach to the analysis of the costs,
population risks, and individual exposures associated with disposal
of  high-level  and  transuranic  wastes.    As  such,  the  options
described are not  intended to characterize any particular planned
or existing facility.  The general approach to the analysis, basic
assumptions, and data sources  and limitations are discussed below.


                     1.3.1 High-Level  Wastes


     This RIA considers a variety of options for disposal of high-
level wastes.  All are based on geologic disposal.  Other options,
such as ocean disposal, are not considered.

     Given  geologic disposal, this RIA  considers  four  media in
which the high-level wastes may be emplaced:  tuff, salt, basalt,
and granite.  Data, especially cost data,  for other geologic media
are not available.   For  each  of  the  four geologic media,  the RIA
evaluates the  costs and  health  effects  associated  with  sets of
manmade, or "engineered",  barriers.  The engineered barriers, which
include any  barrier devised  by  man that  in some  way retards the
release of radioactive materials, fall  into two categories:  those
associated with the  longevity of the canisters that would be used
to store the wastes, and  those associated with  the rate at which
the waste would leak from the canister.

     For  the rate  of  leakage,   called the leach  rate,  the  RIA
considers four options:  1 part in 1,000 per year,  1  part in 10,000
per year, 1 part in  100,000 per year,  and 1 part in 1,000,000 per
year.  For the longevity  of canisters,  lifetimes of 300, 1,000 and
3,000 years  are considered.   Discussions are also  included,  as
Chapter Five, on a special canister that reduces the release of. a
highly radioactive gas,  carbon  14, that can sometimes  occur in
certain media.   Since this canister  is  designed to last 10,000
years, it can in  fact  be  used in any media to  reduce releases to
near zero.

     Costs,  projected  statistical health  effects,  and individual
exposures are then developed for  each of the options for disposing
of  high-level  wastes  created  by the various  combinations  of
geologic media,  canister  life, and leach rate.  These are based on
an assumption that  the repository will contain  the equivalent of
100,000 MTHM of spent fuel.  The cost-effectiveness of each option
is next examined,  with  the least-cost option for meeting a variety
of limits on health  effects and  individual exposures within each
geologic medium identified and compared with the other options for
that medium.   The  lowest cost  option of all  media  is  compared
across media, completing the cost-effectiveness analysis.
                               10

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     For the economic impact analysis,  it  is  recognized that the
cost of disposal  will  be borne by both commercial  generators of
nuclear power and the Federal government.  Since the processes by
which the costs  of  a regulation are translated  into  impacts are
quite dissimilar for these two groups, the economic impacts on each
group are discussed  separately.  With appropriate assumptions, the
impacts of  regulations  on  the private  sector  can be  quantified;
however, the  discussion of impacts  of  the cost of disposing of
defense high-level  wastes  is qualitative.   Quantification of the
government impacts  is not attempted because, given the small size
of the waste disposal expenditures relative  to the Federal budget,
determination of the origin of the funds, their impacts, or their
opportunity costs is not possible.

     For  those  impacts  that  are  quantified,  that  is,  for  the
impacts of  costs  associated with disposal  of  nuclear waste from
commercial  power  plants,  two methods  are  presented.    The first
reflects the  simplest  assumptions  possible.   It  compares annual
costs of the regulation with total  industry revenue to determine
the change  required in average electricity rates while assuming
that consumers do not change their purchasing patterns as a result
of the increased price.  The second method incorporates an estimate
of the  elasticity of demand to calculate the  change  in economic
welfare caused  by the  fees charged  to  commercial  nuclear power
plants  to pay for  the  high-level  waste repository.   The second
method  also shows  the economic  burdens  by  state  and  type  of
consumer.
              1.3.1.1  Data Sources and Limitations


     The cost data for high-level waste disposal used in this RIA
were obtained from the DOE.  The data are not of uniform quality.
The most up-to-date and complete information is on the costs of the
limited  number  of  engineered barriers  and  disposal  techniques
currently being considered by  DOE  for  implementation.   For other
disposal techniques, cost  studies  were  discontinued in the early
1980's and  cost  information  is out of date.   In these instances
ratios are developed on  items for which both old and new cost data
are available and are used to adjust the dated costs.

     Estimates of  population risks and  individual  exposures are
based on an EPA  model used by Rogers  and  Associates  Engineering
Corporation  to  study the  health-related effects of disposal  of
radioactive  wastes,  referred to hereafter  as the  Rogers  report
(Rogers 92).  The  assumptions and predictions of  the  model  are,
like any model,  subject to uncertainty.  Details on the model are
provided in Chapter Two.
                                11

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         1.3.1.2  Discounting of Costs  and  Health Effects


     All costs are expressed in constant 1990 dollars to remove the
effects  of  anticipated inflation.   After  deflating the  costs, a
discount  rate of  2  percent is then applied to  future  costs to
obtain the  present value.   This 2  percent rate  is  intended to
reflect the real social cost of money.

     Projected statistical health effects and individual exposures
are not discounted.  This decision is in accordance with standard
practice  in  regulatory impact analysis.    It is  supported by the
fact that the rule itself uses a discount rate of  zero by allowing
by inference  a  certain number of health effects  over the 10,000
years for a  given  amount  of wastes  and not differentiating those
effects by the year in which they occur.


                    1.3.2  Transuranic Wastes


     Along  with the  regulatory impact  analysis  for high-level
wastes,  this  RIA  analyzes  disposal  of transuranic wastes.   The
discussion of transuranic wastes, however,  is not as detailed due
to data  limitations.   Cost  data  provided  by DOE in  1990  are
available for just one geologic medium  (Hunt  1).  Although DOE was
asked for updated  costs,  none  were  provided.   Data on population
risks  and individual  exposures,  provided  in  the  Rogers  report
(Rogers  92) ,  are available for only one combination of  geologic
medium, canister life, and leach rate.   No other alternatives are
modeled by Rogers.  Thus only one option for disposal of TRU wastes
could be evaluated by this RIA.

     Costs  are  adjusted  for  inflation  and  converted to present
values using  the same procedures as those applied to costs  for
high-level  waste disposal.   As with  high-level  wastes,  costs,
population risks, and individual doses  of radiation are presented
assuming a repository containing the equivalent of  100,000 MTHM of
spent fuel.
                               12

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                            CHAPTER  2;
            ANALYSIS  OF COSTS AND EFFECTS OF OPTIONS
                     FOR DISPOSING OF WASTES
                      2.1   HIGH-LEVEL WASTES


     The management  system for  high-level  wastes consists  of a
transportation  system,  a  monitored  retrievable  storage   (MRS)
facility, and a mined geologic disposal system (MGDS).  Discussion
here is  limited to the MGDS, and  is  organized as  follows.   The
first subsection  defines  the options  for disposal.   The second
examines the  population risks and individual exposures  for each
option,   and  explains how  these  estimates are developed.   Next,
costs are developed for each option.  The  section concludes with a
summary  of the  costs,  population risks,  and individual exposures
for each option.


                   2.1.1.   Defining the Options


     The  Department   of  Energy  (DOE),  the  agency charged  with
disposal  of   radioactive  wastes,  can  choose,  within limits,  a
variety of parameters for the design of nuclear waste management.
This study focuses on three  parameters:   the geologic  media in
which the facility will be located, the leach rate associated with
the waste form, and the life of the canister containing the waste
form.
                     2.1.1.1.   Geologic Media


     Four possible  geologic media  for  the repository  are tuff,
salt, basalt and granite.  The tuff formation assumed for the study
hypothetically  planned  in Nevada, consists of  airborne volcanic
debris fused into an  unsaturated  mass with high porosity and low
permeability" (Rogers 1992).  Since the tuff is unsaturated, flow
of water through the rock  formations is very slow.  The unsaturated
character of this  tuff  also  means, however,  that  there  is  a
potential for  gaseous release  of radioactivity.   However,  time
periods before this possible gaseous release can be quite long if
a canister with a long life is used.

     Salt deposits,  located in  several regions of the country, are
viable candidates for a  repository  because their  very existence
precludes groundwater  flow.   If,  however,  groundwater  flow does
change in the future  such that water contacts  the  salt deposits,
then  the salt  will  dissolve  and be carried  away.    Therefore,
stability of existing groundwater  flows is essential, and candidate

                                13

-------
sites  must be expected to remain  intact  for thousands of years.
One  other problem more pronounced with salt than with the other
three  media is the probability of  inadvertent drilling into the
repository;   probabilities  are  higher  for   salt  because  salt
formations  are usually  located in areas that contain commercially
valuable  resources.

     Located  primarily in  the Pacific Northwest,  basalt  "is a
dense,  dark,  fine-grained rock  formed by  the solidification of
volcanic  lava"  (Rogers 1992).   All basalt  formations have some
fractures even in  their  most dense  parts, and  these fractures
increase the probability of groundwater flows.  This condition does
not  make  basalt  unacceptable as  a host  rock,  but   it  must be
considered  in choosing  a site.

     The  fourth host rock formation being considered for the high-
level waste repository  is granite.  Since fractures also occur in
granite formations,  it  is  important that  the sites considered be
very dense with fractures tightly closed.  As is true with basalt,
groundwater migration through granite will almost certainly occur
over  a  long  period.   By  itself,  this  does  not make  granite
unacceptable, but the possibility must be modeled.


                       2.1.1.2.   Waste  Form
     Choice  of  the waste  form  determines  the rate  at  which the
waste will leach into the surrounding environment.  This study uses
the four waste forms  considered in the Rogers report (Rogers 92).
These are:  concrete, with  an annual leach rate of 1 part in 1,000;
a hypothetical waste  form  with  an  annual  leach rate  of 1 part in
10,000; glass, with an annual leach rate of  1 part  in 100,000; and
ceramic, with an annual leach rate of 1 part in 1,000,000.


                      2.1.1.3  Canister Life
     An important option in the choice of engineered barriers for
a high-level  waste  repository  is  the choice  of canister.   The
Rogers report  (Rogers 92) studied three canister designs on which
this RIA is based.   Canister  A  contains  the waste for 300 years,
canister B for 1,000 years, and Canister C for 3,000 years.


                   2.1.1.4   An Array of Options


     The four  geologic  media, four leach rates,  and  three basic
canister  designs  constitute  the  policy  variables  that,  when
considered  in  all  possible  combinations,  provide DOE with  48

                                14

-------
choices for disposing of high level wastes.  Exhibit 2-1 summarizes
these  choices  and  also   shows  the  three-character  code  used
throughout this document to represent  each of the 48 choices.  The
first  part of  the code  consists  of  a letter  to indicate  the
geologic  media.    'T' indicates  tuff,   'S'  indicates salt,  'B'
indicates basalt,  and  'G'  indicates granite.   The  second part of
the code  is a  numeral:   3 to indicate  an annual leach  rate of 1
part in 1,000  (10~-3),  4 to indicate an annual  leach rate of 1 part
in 10,000 (10~-4) ,  5 to indicate  an annual leach rate of 1 part in
100,000 (10^-5), or 6 to indicate an annual  leach rate of 1 part in
1,000,000 (10~-6).   The third character  is a letter indicating the
choice of canister.  The code uses A for the 300-year canister A,
B for the 1,000-year canister B,  and C for the 3,000-year canister
C.   For example,  a  policy option coded B5C  refers to  a basalt
geologic medium, an annual  leach rate of 1 part  in 100,000 (10^-5),
and canister C.
         2.1.2   Population Risks  and  Individual Exposures


     Estimates of population risks and individual exposures for a
high-level waste repository are based in this RIA entirely on the
Rogers report  (Rogers 92) .   For the population  risk estimates,
Rogers uses the concept of "complementary cumulative distribution
functions" (CCDF)  to show  projected health effects for  a variety of
repository choices.   For  individual exposures,  it  estimates the
annual  radiation  dose,   measured  in  millirems   per  year,  from
consuming two liters per day of groundwater two kilometers from the
boundary of the repository.   The CCDF  concept  and the individual
risk measure are discussed in the following sections.


   2.1.2.1  Understanding  the CCDF Measure of Population Risks


     Exhibit 2-2  shows a  hypothetical  CCDF reproduced  from" the
Rogers report (Rogers 92).  It is presented here to illustrate the
concept  of  a CCDF.   Basically,  the CCDF technique constructs a
probability  distribution   from a set of  paired  probability and
consequence  levels.   The consequence levels (that  is,  number of
health effects) arise  from the various  scenarios modeled.   These
scenarios include normal groundwater  flow as well  as events such as
exploratory  drilling,  seismic activity,   or volcanic  activity.
Probabilities are assigned based on the likelihood of the scenario.
Each consequence level is  paired  with a corresponding probability,
and  the  pairs  are  arranged  in  decreasing order of  consequence
level.  The result is a CCDF such as  that depicted in Exhibit 2-2.
                                15

-------
EXHIBIT 2-1
POLICY OPTIONS FOR A HIGH-LEVEL WASTE REPOSITORY
Geological
Medium
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Tuff
Salt
Salt
Salt
Salt
Salt
Salt
Salt
Salt
Salt
Salt
Salt
Salt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Basalt
Granite
Granite
Granite
Granite
Granite
Granite
Granite
Granite
Granite
Granite
Granite
Granite
Leach Rate
(parts per year)
10~-3
10^-3
10"-3
10^-4
1CT-4
icr-4
10^-5
10^-5
icr-5
10~-6
icr-6
10"-6
icr-3
10~-3
10"-3
10^-4
10^-4
10^-4
10"-5
10~-5
10~-5
icr-6
10"-6
10~-6
10~-3
10^-3
1CT-3
10^-4
10"-4
10^-4
10^-5
10^-5
10"-5
10^-6
10^-6
10"-6
1CT-3
10^-3
10"-3
10"-4
10"-4
10A-4
10^-5
10"-5
10^-5
10"-6
10^-6
10"-6
Canister Life
(years)
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000
300
1000
3000

Code
T3A
T3B
T3C
T4A
T4B
T4C
T5A
T5B
T5C
T6A
T6B
T6C
S3A
S3B
S3C
S4A
S4B
S4C
S5A
S5B
S5C
S6A
S6B
S6C
B3A
B3B
B3C
B4A
B4B
B4C
B5A
B5B
B5C
B6A
B6B
B6C
G3A
G3B
G3C
G4A
G4B
G4C
G5A
G5B
G5C
G6A
G6B
G6C
16

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                              EXHIBIT 2-2
     HYPOTHETICAL COMPLEMENTARY CUMULATIVE DISTRIBUTION FUNCTION(CCDF)
        10
          -1
O)
O)  >
O  o
       10-
   en
Q_
   o   10-
       10
         -4
                     D
                      10
100
1000      10,000      100,000
                        Health Effects over 10,000 Years
            Source: Rogers92
                                 17

-------
     Point  A,  the event  with  the  largest  consequence,  has a
probability  of 10"4  (0.0001).   Point B pairs  the consequence of
event B with the sum of the probabilities  of events A and  B  (hence
the term cumulative).

     Point C is the pair  of  the consequence of  event  C and  the
summed probabilities of events A through C.  Any point on the curve
can  be interpreted  as follows:   the  probability  shown is  the
probability  of obtaining  a consequence exceeding the value shown
(Rogers 92) .

     Multiplying  these  same   sets  of  paired  probabilities   and
consequence  levels  and summing their products yields  another
measure  of  population risk — total expected  number  of health
effects  from  all release scenarios.    Note  the  two types  of
information obtained by constructing a  CCDF.  Not only does a CCDF
describes an entire distribution of probability-consequence pairs,
but it also gives  an expected  value for that distribution.


            2.1.2.2  Understanding the  Individual Dose


     Individual exposures  are estimated as the annual radiation
dose  an   individual   receives  from  consuming  two  liters  of
groundwater per day at a distance of  2000 meters  from the  boundary
of the repository.   Since  the nuclear  wastes  will slowly migrate
from  the  repository  after   the  canister  fails,   the  primary
determinant of an  individual's exposure is time.  For a given waste
form and canister life, the longer the time after placement of  the
HLW, the greater  the  number of radionuclides  in the groundwater.
The  low-probability events  of  drilling,  seismic activity,   and
volcanic activity  are  ignored  for individual exposure measures.


             2.1.2.3.   Measuring the  Population  Risks


     Exhibit 2-3  presents  a CCDF with  for one  option  within each
geologic medium.     The point represented by  the ordered pair
(100,10 )  should   be  interpreted as a  0.01 chance  of an  event
occurring that results in more than 100 health effects per 100,000
MTHM emplaced.

     All four  are  first constructed assuming a  leach rate of  10"*
and a canister life of 1,000 years.   This  is the base case in the
Rogers report  (Rogers 92) .   However,  since uncertainty  exists,
alternative scenarios are constructed by Rogers to illustrate the
range  of  outcomes.   These are  developed by randomly  selecting
different  leach rates  between  1 part  in  1,000 and  1  part  in
1,000,000,  and different  canister lives  (between 300  and  3,000


                                18

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                                        EXHIBIT 2-3
                 COMPLEMENTARY CUMULATIVE DISTRIBUTION FUNCTION
                                        BY MEDIUM
                    TUFF
                                                                               SALT
Probability of Exceeding
Consequence Level
0 3 0 0
i* U Nt i

-^

S P^


V —

^ 	


Oasc
Case
	 \




•^



«P~0.,
S






.a.



11




1
        1      10
                     100     1.000   10.000    100,000


                 Health Effects over 10,000 Years
                                                                 I S P«ro«
-------
years) to generate another 100 scenarios.  The graphs in Exhibit 2-
3 therefore give the base case as well as the CCDFs corresponding
to the 5th and 95th percentiles.  This places uncertainty bounds on
the base case.  Any point on the  graph (x,y)  may be interpreted by
observing that  the probability that  the number of health effects
represented by x will be exceeded, is equal to y.   For example,- the
point  represented  by  the  ordered  pair  (100,   10"2)  should  be
interpreted as a 0.01 chance of an event  occurring that results in
more  than 100  health  effects per  100,000  MTHM  emplaced.   The
interpretation of the intervals (also shown on the graph) would be
that  there  is a 90 percent chance that  the actual  release would
fall within the limits  marked by the 5th and 95th  percentile.

     Exhibit 2-4 combines the base case results for the four media
for comparison purposes. The exhibit indicates that tuff generally
has fewest health  effects,  followed  by salt, granite and basalt.
For tuff, there is a  0.1 chance of a  consequence with between 1 and
10 health effects  or more per 100,000 MTHM.  For salt, there is a
0.1 chance of health effects about 10  times  greater than for tuff.
For granite and basalt,  the same 0.1 chance corresponds to almost
1,000 health  effects or more per  100,000 MTHM,  with  the basalt
having slightly  more health effects.   However, at  low levels of
probability  (approaching 0.0001)  the consequence of  an  event is
greater for tuff than for any of the other media.   Salt  is the only
media to have less than  a 100 percent chance that an event with a
consequence of at least 1 health  effect per  100,000 metric tons of
heavy metal will occur.

The Rogers  report (Rogers  92) also  provides another  measure of
population risk, total  expected  health effects  over 10,000 years
for each  of the 48  options if  100,000 MTHM  are  emplaced .   The
first  two  columns  of   Exhibit  2-5  present these  data.    Two
conclusions emerge from  the table.   First, geologic medium is the
most  important  determinant  of total  expected health effects over
10,000 years.   Tuff has the  smallest number of  expected health
effects; further, the tuff results are not sensitive to leach rate
or canister life.   Salt  provides the  next smallest  number of health
effects for each  of  the combinations of  leach rate  and  canister
life.   Health effects in salt range  from 39 to 5.   While canister
life  has  some influence on expected health effects,  leach  rate
exerts  greater influence.   Although  granite performs  somewhat
better than  basalt,  neither perform  well compared with  tuff or
salt.    The  best result  for basalt,  option B6C with  43  expected
health effects, has more health effects than any salt option or any
tuff option.  For granite, only one  option (G6C with 30 health
       CCDFs for each of  the 48 options are not constructed.  They
are constructed for only the reference case for each of the media.
                                20

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                         EXHIBIT 2-4

COMPARISON OF COMPLEMENTARY CUMULATIVE DISTRIBUTION FUNCTIONS
 CD <1>
 CD >
 O <>>
 X —'
UJ CD
«*- O
 O C


£ I


1 |
J3 ^

 25
0.
       10-1
       10-2
       1O-3
       10-4
                    10
                             100
1,000     10,000
                                                         100,000
                       Health Effects over 10,000 Years
                                21

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EXHIBIT 2-5
TOTAL EXPECTED HEALTH EFFECTS AND INDIVIDUAL DOSES
FOR EACH POLICY OPTION
Policy
Option
T3A
T3B
T3C
T4A
T4B
T4C
T5A
T5B**
T5C
T6A
T6B
T6C
S3A
S3B
S3C
S4A
S4B
S4C
S5A
S5B**
S5C
S6A
S6B
S6C
B3A
B3B
B3C
B4A
B4B
B4C
B5A
B5B**
B5C
B6A
B6B
B6C
Expected Health
Effects (over
10,000 years)
1
1
1
1
1
1
1
1
1
1
1
1
39
37
32
20
18
13
7
6
6
5
5
5
11,600
108,00
8,800
4,900
4,400
3,160
662
583
393
73
64
43
Individual Dose
(maximum dosage
during 10,000 years)*
0
0
0
0
0
0
0
0
0
0
0
0
***
***
***
***
*.**
***
***
***
***
***
***
***
100,000
100,000
100,000
10,000
10,000
10,000
1,000
1,000
1,000
100
100
100
22

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EXHIBIT 2-5
TOTAL EXPECTED HEALTH EFFECTS AND INDIVIDUAL DOSES
FOR EACH POLICY OPTION
Policy
Option
G3A
G3B
G3C
G4A
G4B
G4C
G5A
G5B**
G5C
G6A
G6B
G6C
Expected Health
Effects (over
10,000 years)
9,350
8,630
6,780
3,910
3,470
2,320
516
449
284
54
47
30
Individual Dose
(maximum dosage
during 10,000 years)*
100,000
100,000
100,000
10,000
10,000
10,000
1,000
1,000
1,000
100
100
100
**
Individual dose  is  measured as maximum exposure  during the
10,000 year  period.   The Rogers report presents  individual
doses in  graphical  form only.  These  numbers  are estimated
from those graphs.

Used as a base case in the Rogers report.
***  The Rogers report did not calculate individual doses from salt
     because  of  the absence  of  a  groundwater  pathway  under
     undisturbed conditions.  Essentially,  the dose is 0.

     Source:  Rogers 92
                                23

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effects)  has fewer  health effects  than the  worst of  the salt
results (S3S with 39 health effects) .  All tuff options have fewer
health effects than any granite option.

     The second conclusion  is that for any geologic medium except
tuff,  leach rate is  the  primary determinant  of  expected health
effects.   Canister  life  has a  relatively  smaller impact.   For
example, assuming disposal  in basalt in a waste form with a leach
rate of 10  ,  a  change from a 1,000-year canister (option B5B) to
a 3,000-year canister (option B5C) yields 190 fewer expected health
effects.    However,   improving  the  leach  fate  rather  than  the
canister life, from  10"5" (option B5B)  to 10"6 (option B6B) , yields
519 fewer health effects.


             2.1.2.4  Measuring the Individual Doses


     The  third  column of  Exhibit  2-5 lists individual  doses of
radiation  for each  option.  The  doses shown do not  take into
account  low-probability   events,   such  as  drilling,  volcanic
eruptions,  and  seismic activity.   Again,  tuff and  salt greatly
outperform basalt and granite.  During the 10,000 years both tuff
and salt yield a maximum  dosage of zero.   Basalt yields the same
dosage for the various disposal  methods  as granite.  Canister life
has no effect on individual dose of either medium; only the leach
rate of the waste form influences individual dosage.


                           2.1.3 Costs
     There are two major cost components of building a repository
(DOE 90) .  The  first is the repository itself,  which consists of
surface and underground facilities at the mined geologic disposal
site.    Surface  facilities  include excavated  material-handling
facilities, the waste handling building, support buildings, and so
on,  while  the underground  facilities  consist of  shafts,  ramps,
support  facilities,   and  access and  waste emplacement  tunnels.
Repository  costs  cover  engineering,   construction,  operation,
closure and decommissioning.

     The second major cost component of repository construction is
development  and  evaluation  (D&E)  costs.    The  D&E  category,  as
developed  by  DOE,   covers  all  the siting,  preliminary  design
development,   testing,  regulatory   and  institutional  activities
associated  with  the  repository,   the  facility  for  monitored
retrievable storage  (MRS),  and the  transportation system.  The D&E
category also  includes administration  activities by the Federal
government and Nuclear Regulatory Commission activities related to
licensing  the waste  management  facilities  and  certifying  the


                                24

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transportation containers.  For this analysis, however, only that
part  of  D&E costs  attributable  to  the repository  itself  is
considered.
                      2.1.3.1  Data Sources
     The Nuclear Waste Policy Act (NWPA) as amended requires DOE to
submit a report to Congress each year which assesses the adequacy
of the fee  charged to utilities to cover  the  entire  cost of the
waste management  program (GAO 89) .   To support  this  effort, DOE
publishes detailed life-cycle cost estimates  for  an assumed set of
reference systems.  This analysis, referred to  as the Total System
Life-Cycle Cost (TSLCC) Analysis, represents the official long-term
financial plan  for the program and reflects the most up-to-date
program plans,  policies,  designs,  and data  available.   The most
recent TSLCC document is a preliminary estimate  dated December 1990
that  serves as  an addendum  to the most recent complete  TSLCC
analysis, which is dated May 1989 (DOE 1990).  This addendum is a
primary source of costs for the high-level  waste management system
in this RIA.

     The addendum considers three  repository  options:    (1)  one
repository  in  tuff  designed  to   store   96,300  MTHM;   (2)  two
repositories, with the  first  storing 70,000  MTHM in  tuff and the
second  storing  26,300  MTHM  in a  generic medium;  and  (3)  two
repositories, with the  first  storing 70,000  MTHM in  tuff and the
second storing 36,400 MTHM in a generic medium  (DOE 90).  For this
RIA, costs  associated with a  first repository of 70,000 MTHM as
noted in option two above, referred to hereafter as DOE Option Two,
were  chosen  and  then  scaled  to  approximate  a  100,000  MTHM
repository.   The choice of DOE Option Two over  the  alternatives
allows a better comparison with cost data for the other media, as
explained in subsequent sections.

     Costs  in  the  TSLCC  addendum  focus  on tuff  because  of  a
decision by Congress  in 1987 to restrict future study to the tuff
formations  in  Yucca  Mountain,  Nevada.   Thus,  data on  costs for
repositories in other media are developed using other sources and
approaches.  Costs of repositories in salt and  basalt are based on
older DOE studies.  Costs of repositories in granite are based on
a  variety  of  approaches  and  sources,  as little information is
available that is specific to this medium.   Details are provided in
the following sections.


                          2.1.3.2.   Tuff
     Consider tuff  formations first.  Exhibit  2-6  displays each
component  of  the D&E costs  in  1990 dollars for DOE  Option Two.

                                25

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                           EXHIBIT 2-6
  Summary  of  Development and  Evaluation Costs for DOE Option Two
 	 	(millions of  1990  dollars)        	
                Cost Category
                                           Cost
                                    (millions of 1990
                                         dollars)
 First Repository
 Second Repository
 MRS Facility
 Transportation
 Systems Integration
 NRC Fees
 Program Management

 Total D&E Costs
                                                 7,014
                                                 3,315
                                                   326
                                                 1,329
                                                   327
                                                   937
                                                 3,087

                                                16,335
Source:
DOE 90
                                26

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Since this RIA  analyzes  only the costs of the repository itself,
only those elements of D&E expense explicitly attributable to the
repository are considered.  D&E costs for  a 70,000 MTHM repository
are  estimated  as  43  percent  of  total  D&E  costs  for the  two
repository case  ($7,014 divided by $16,335) (DOE 90).

     The second  component of costs  is the cost of the repository
itself.  This cost, plus the relevant D&E costs, are provided in
Exhibit A-l of Appendix A.  The costs in Exhibit A-l are the total
life-cycle costs of  the 70,000 MTHM repository,  from  the  most
recent TSLCC  (the  addendum dated December 1990).  The  costs are
inflated to  1990 dollars using the  gross domestic product (GDP)
implicit price  deflator.   Transportation and MRS costs  are not
included.

     The next step in developing the  total cost of the repository
is the scaling  of  costs  for a 70,000 MTHM repository to estimate
costs  for  a  100,000  MTHM repository.  The  scaling  was  done by
assuming a linear relationship and simply multiplying  by 1.43 (that
is, 100/70).   There are undoubtedly both  fixed and variable costs
for  the  70,000  MTHM  repository,  and the cost of expanding the
repository by  30,000  MTHM  would  probably not cost  as much as
implied by this technique.  D&E costs, for example, are not likely
to be  much affected  by  this increase in capacity.   However, no
better method for  estimation is possible  with the data  provided.
The  last  step  is  the discounting of the costs to find  the net
present value of the  cost stream.  The discount rate  applied is 2
percent.   Summing these  yields a  net present value of $11,225
million.
                     2.1.3.3  Salt and Basalt
     Although   DOE  does   not   currently  estimate   costs   for
repositories  located in  salt  or basalt,  it  did so  in analyses
before 1988.  Previous volumes of TLSCC analysis provide cost'data
on tuff, basalt and salt repositories.  These data are used as the
basis of our basalt  and salt cost estimates.  However, these data
must be adjusted to  make  them comparable to the tuff estimates in
the most recent TLSCC analysis.  Emphasis is on providing data that
allow a valid comparison.

     The June 1987 TSLCC (DOE 87) presents cost estimates for tuff,
salt and basalt.   In each  case,  it  gives  repository  costs  for a
two-repository case with the first repository holding 70,000 MTHM.
The same method of cost analysis is  used  for both salt and basalt.
Development of estimates  of costs for repositories in these media
begins  with  the calculation of  D&E costs.   Total D&E  costs are
given in the June 1987 TSLCC for salt and basalt,  but these are not
separated  by  component.   Instead, to exclude costs  not directly
related to the repositories themselves,  the 43  percent  ratio of

                                27

-------
repository  D&E to total  D&E for tuff  in  1990  (Exhibit  2-6) is
applied  to  the  DOE's  estimates of  total  D&E  for each  type of
repository.  These are  then  added to the cost of each repository
and scaled to  convert to a 100,000 MTHM repository by multiplying
by 1.43.  Finally, yearly costs are inflated to 1990 dollars, and
the total cost stream is discounted at two  percent.

     Exhibits  A-2 and A-3  of Appendix A present life-cycle costs
for salt and basalt  respectively.  These are comparable to life-
cycle  costs  for  tuff  as  presented  in  Exhibit  A-l.    Total
undiscounted life-cycle costs in 1990 for a  100,000 MTHM repository
built  in  salt  are $23,461 million.   Discounting  this  stream of
future costs at  2 percent yields a net  present value of $14,254
million.  Total  undiscounted-life cycle  costs for  a 100,000 MTHM
repository built  in  basalt are  $27,763  million; discounting this
stream of future costs at 2 percent yields  a net present value of
$16,727 million.


                        2.1.3.4.  Granite
     Costs for a  granite  repository are  also  estimated with data
from the  latest TSLCC  analysis  (again, this  is from the addendum
dated December 1990).   Since  granite  is  the medium for which the
least  cost information  exists,  necessary  assumptions make  the
granite cost estimates  the most tenuous.   No particular information
about D&E costs for granite are available; hence D&E costs for tuff
are used as a proxy.  The fact that the TSLCC gives two cases for
a two-repository system allows the approximation of costs for the
repository itself in granite.   In each of the two cases, the TSLCC
models the second repository as a generic  medium; the costs of this
generic medium are  used as  the costs  for granite.  Also,  in one
case the  second  repository  has a capacity of  26,300 MTHM  with a
total undiscounted 1988 dollar cost of $6,551 million while in the
second case the  second repository  has a capacity  of  36,400 MTHM
with a  total  undiscounted  1988  dollar  cost  of $7,299  million.
Straight-line  extrapolation from these  two points  gives a total
undiscounted life cycle cost of $12,009 million  for a 100,000 MTHM
repository.  The  size of the repository is assumed not to influence
the relative expenditures per year.   Each  year's  repository cost
can then  be  scaled  by  the  ratio of  the incremental  cost  for a
100,000 MTHM repository to the cost of  a 26,300 MTHM repository, or
1.8 (12,009 divided by 6,551).

     Exhibit A-4 of  Appendix A presents  an estimate of the costs
for a  100,000  MTHM repository built  in  granite.    D&E  costs  are
assumed to be the same  as  tuff D&E costs but are scaled to 100,000
MTHM.   Repository costs are estimated  for each year as the  TSLCC-
reported repository  costs for the 26,300 MTHM repository multiplied
by 1.8 (as explained in the preceding paragraph).   All costs  are
inflated to 1990  dollars.  Total undiscounted life-cycle costs for

                               28

-------
a 100,000  MTHM repository  built in granite are  $30,379 million
(1990  dollars);  discounting  this  stream  of future  costs  at 2
percent yields a net present value  of $19,504 million.


      2.1.3.5 Comparison of Costs of Repositories by Medium


     One adjustment  to the total discounted repository costs is
needed before costs by medium can be compared.  Estimates of costs
of repositories  in salt and basalt are based on  1986 data.   The
tuff and granite estimates are based on 1988 data and incorporate
more recent information and program changes, such as improvements
in technology.   Tuff cost estimates decreased by 6 percent from
1986 to 1988,  and  it is assumed that salt and  basalt costs would
have done the same.  After applying  the  6 percent  decline to costs
for repositories in  salt and basalt, costs for each medium are as
follows:   tuff,  $11,225 million; salt,  $13,450  million; basalt,
$15,784 million; and granite, $19504 million.   The costs used in
this RIA for a 100,000 MTHM repository built in basalt, salt, tuff,
and granite are $15,784 million, $13,450 million, $11,225 million
and $19,504 million  respectively  (Exhibit 2-7).


              2.1.3.6  Canister and  Waste Form Costs
     Total cost estimation requires calculating canister and waste
form costs, in addition to the repository costs.   The  1985 RIA  (EPA
85) provides  the basis for estimating costs  of  the  canister and
waste  form.    Nominal dollar costs are assumed  to  be  the   same
regardless  of  the choice  of  geologic  media  even  though,  for
example, a stainless steel container will not  last as long in  salt
as in  basalt.   However, the present values of the  costs do  vary
across  media   over  the life  cycle of  a  repository because  the
emplacements of wastes  are assumed  to proceed at differing rates.
These rates were obtained by calculating the transportation costs
per year  as a  percentage of  total transportation costs  for the
repository  (DOE 90).  The volume of heavy metal emplaced per  year
is estimated by applying  this percentage to total volume of heavy
metal;  the waste  form and canister cost of emplacing that volume
for each year  is then  calculated.  Finally,  present values over the
life  cycle of  the repository  are  calculated using a  2  percent
discount rate.

     Included  in Exhibit 2-7 is  the  present value  of the total  cost
of achieving various leach rates.   In the 1985  RIA, a  leach rate of
1 part in 100,000 (10~5)  corresponds to the lower limit of the "very
good" category while  1 part in  1,000,000 (10~^) corresponds to the
upper limit.  These are assumed  to cost $14  and $20 per kilogram of
heavy metal in the original substance.  In addition,  leach  rate


                                29

-------
EXHIBIT 2-7
PRESENT VALUE OF COST ELEMENTS BY MEDIUM
(millions of 1990 dollars)
Cost Element
REPOSITORY
LEACH RATE
10"-3
10~-4
10"-5
1CT-6
CANISTER LIFE
300
1,000
3,000
Geologic Medium
Tuff
11,225

649
779
923
1,318

659
989
2,596
Salt
13,450

677
813
964
1,377

688
1,033
2,710
Basalt
15,784

694
832
987
1,409

705
1,057
2,774
Granite
19,504

649
779
923
1,318

659
989
2,596
30

-------
costs of  1 part in  1,000  (10*3) and  1  part in 10,000  (10"4)  are
assumed to be $10 and $12 per kilogram of heavy metal.  Costs are
inflated  to  1990  dollars.    Caution should  be  used with these
estimates, however.  Though almost all the high-level waste to be
emplaced  is  in  the  form of  intact  spent  fuel  rods,  the costs
developed  are   based   on   DOE  high-level   wastes.     Telephone
conversations with DOE officials (WAL 92)  indicate that waste form
costs for spent fuel rods are  generally  expected to be higher than
for DOE high-level wastes;  however,  no  specific  estimates exist.
Therefore, these waste form costs should be considered lower bound
estimates.

     Exhibit 2-7 also gives the present  value of the total cost of
various canister lives.  Again,  the 1985  RIA serves  as the basis
for current estimates.   The 300 year canister corresponds to the
"minimum" category described in the 1985 RIA, where it is assumed
to cost $10 per kilogram of  heavy metal  in the original substance.
The  1,000 year  canister corresponds to the  1985 RIA's  "good"
category and is assumed to cost $15 per  kilogram of heavy metal in
the original substance.  The  10,000 year canister corresponds to
the 1985 RIA's "very good"  canister and  is assumed to cost $40 per
kilogram of heavy metal  in  the original substance.   The 1985 RIA
gave  no cost  for a 3,000  year  canister.   Recent  information
indicates that a 1,000 year canister now costs $31 per kilogram of
heavy metal in the original  substance while a 10,000 year canister
costs $77  per  kilogram of heavy metal  in the original substance
(SAIC 92) .   These two  points  allow  an approximation of  $20 per
kilogram for a 300 year canister and  $48 per kilogram for a 3,000
year canister.  Applying these new dollar  costs to the time stream
of heavy metal  emplacement  yields  the canister  cost  estimates in
Exhibit 2-7.   Since  no information was given  for granite, costs
associated with tuff were used to approximate granite cost.


                  2.1.3.7 Total Cost  by Options


     Costs for each of  the 48 options are presented in Exhibit 2-8.
Total cost is the present value of the cost stream  over the life of
the repository.   It is  the sum of repository costs,  waste form
costs and canister costs.


           2.1.3.8 Summary of Costs,  Population Risks,
                       and  Individual Doses


     Exhibit 2-9 summarizes the population risks (health effects),
individual doses,  and  costs for each option.  The  second column
lists expected health effects, the third column contains individual
doses in  millirems  per year,  and  the fourth column  provides the


                                31

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EXHIBIT 2-8. COSTS BY MEDIUM.  LEACH  RATE AND CANISTER LIFE
                 (millions of  1990  dollars)
Option
T3A
T3B
T3C
T4A
T4B
T4C
T5A
T5B
T5C
T6A
T6B
T6C
S3A
S3B
S3C
S4A
S4B
S4C
S5A
S5B
S5C
S6A
S6B
S6C
B3A
B3B
B3C
B4A
B4B
B4C
B5A
B5B
B5C
B6A
B6B
B6C
G3A
G3B
G3C
G4A
G4B
G4C
G5A
G5B
G5C
G6A
G6B
G6C

Repository
Cost
11225
11225
11225
11225
11225
11225
11225
11225
11225
11225
11225
11225
13450
13450
13450
13450
13450
13450
13450
13450
13450
13450
13450
13450
15784
15784
15784
15784
15784
15784
15784
15784
15784
15784
15784
15784
19504
19504
19504
19504
19504
19504
19504
19504
19504
19504
19504
19504

Leach
Rate
Cost
649
649
649
779
779
779
923
923
923
1318
1318
1318
677
677
677
813
813
813
964
964
964
1377
1377
1377
694
694
694
832
832
832
987
987
987
1409
1409
1409
649
649
649
779
779
779
923
923
923
1318
1318
1318
32
Canister
Cost
659
989
2596
659
989
2596
659
989
2596
659
989
2596
688
1033
2710
688
1033
2710
688
1033
2710
688
1033
2710
705
1057
2774
705
1057
2774
705
1057
2774
705
1057
2774
659
989
2596
659
989
2596
659
989
2596
659
989
2569

Total
Cost
12533
12863
14470
12663
12993
14600
12807
13137
14744
13202
13532
15139
14815
15160
16837
14951
15296
16973
15102
15447
17124
15515
15860
17537
17183
17535
19252
17321
17673
19390
17476
17828
19545
17898
18250
19967
20812
21142
22749
20942
21272
22879
21086
21416
23023
21481
21811
23418


-------
EXHIBIT 2-9
SUMMARY OF COSTS AND HEALTH
Option
T3A
T3B
T3C
T4A
T4B
T4C
T5A
T5B
T5C
T6A
T6B
T6C
S3A
S3B
S3C
S4A
S4B
S4C
S5A
S5B
S5C
S6A
S6B
S6C
B3A
B3B
B3C
B4A
B4B
B4C
B5A
B5B
B5C
B6A
B6B
B6C
G3A
G3B
G3C
G4A
G4B
G4C
G5A
G5B
G5C
G6A
G6B
G6C
Number of
Health Effects
in 10,000
Years
1
1
1
1
1
1
1
1
1
1
1
1
39
37
32
20
18
13
7
6
6
5
5
5
11,600
10,800
8,800
4,900
4,400
3,160
662
583
393
73
64
43
9,350
8,630
6,780
3,910
3,470
2, 320
516
449
284
54
47
30
EFFECTS
Indi- Present Value
vidual of Cost
Doses for Option
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
100000
100000
100000
10000
10000
10000
1000
1000
1000
100
100
100
100000
100000
100000
10000
10000
10000
1000
1000
1000
100
100
100
12533
12863
14470
12663
12993
14600
12807
13137
14744
13202
13532
15139
14815
15160
16837
14951
15296
16973
15102
15447
17124
15515
15860
17537
17183
17535
19252
17321
17673
19390
17476
17828
19545
17898
18250
19967
20812
21142
22749
20942
21272
22879
21086
21416
23023
21481
21811
23418
       33

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present value of the total life-cycle cost.   Exhibit 2-9 summarizes
all  pertinent  information  on  high-level  waste  used  for  the
remainder of this RIA.  These values  can be  used to identify which
options meet any  standard,  to determine  the least-cost method of
meeting any standard, to calculate cost-effectiveness in changing
from one standard to  another, and to estimate who bears the costs
of any  option.   Applying these data to Yucca  Mountain,  a 70,000
MTHM repository in tuff with 300  year canisters and  a proposed
leach rate limit of  1 part  in 100,000,  the cost of the repository
alone is $9.0 billion, or $12.3  billion for  the whole system.  The
number of predicted statistical health effects is less than one and
the individual dose  is zero.
                     2.2  TRANSURANIC WASTES
     The transuranic waste management system consists of two major
elements —  transportation   system   and   the   repository.     The
transportation will  use  trucks  to  ship  transuranic wastes to the
repository via pre-approved routes.   However, as was the case with
the high-level waste management system, this RIA does not consider
the transportation system but only analyzes the repository itself.
Although this  RIA presents  a generic analysis,  cost  and health
effects  estimates are based  on the Waste Isolation  Pilot Plant
(WIPP) currently being constructed in Eddy County, New Mexico.  The
previous estimation technique used by EPA calculated an equivalent
of 5.42 MTHM of TRU wastes were to be emplaced; a newer technique
estimates them instead at 0.7 MTHM  (RUS 92).

     The repository for transuranic  wastes is designed to receive,
inspect,  and  dispose  of   contact-handled   and  remote-handled
transuranic wastes.  (Contact-handled wastes are those that can be
handled directly since the shielding provided by the waste package
prevents exposure.    Remote-handled wastes are  those that  have
enough  contamination  for  beta, gamma,  or neutron activity  to
require  remote  handling.)    The repository is to  be  mined "in a
suitable  geologic  formation.   The  surface   facilities  at  the
transuranic waste repository  include the waste handling building,
shaft filter building,  and warehouses.  The underground facilities
include  the  shafts that connect the surface  to the  underground
repository horizon, the waste-disposal area, an experimental area,
and an  equipment  and maintenance support area.  All  transuranic
wastes are to be received at the waste handling building where they
will be  inspected,  inventoried,  and prepared  for disposal.   From
the waste handling building, the transuranic wastes are transported
via the waste shaft to the underground facilities for  disposal.


                   2.2.1.  Defining the Option
                                34

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     The  Rogers  report  to  EPA  analyzes  only one  option  for
transuranic waste disposal (Rogers 92) .   It  assumes that the waste
forms will have unlimited leach rates, the wastes will be placed in
canisters  with  zero-year  lives  and  the  repository  will  be
constructed  in  salt.    No alternative medium,  canister  life,  or
waste form  leach  rate is modeled.   Costs are available  for only
this option also.  Since health effects,  individual exposures,  and
cost information exists only for  one option,  this  RIA must limit
its analysis to that option.  The option is referred to hereafter
as TRU1.
              2.2.2   Population and Individual  Risks


     The  presentation  and  analysis  of health  risks  for  the
transuranic waste repository by Rogers parallels the presentation
and analysis for the high-level waste repository, except that there
is  only  one  option  presented  for  the  transuranic  facility.
Population  risks  are  measured as projected  statistical  health
effects while individual exposures   (that is, millirem doses) are
measured as the maximum annual dosage during 10,000 years.

     The expected number of  health effects  for a  repository with
the characteristics  of option TRU1  is 27 over 10,000  years for
every 100,000 MTHM emplaced  (Rogers 92).  There is an expectation
of some  health  effects due  to  the nature of  the modeling.   Low
probability   events   of  volcanic   eruptions,  earthquakes  and
inadvertent  drilling  are considered.   Since  there  are non-zero
probabilities for these events,  there is an expectation  of some
health effects over the time frame modeled.

     Since the repository is  assumed to be mined in bedded salt, no
individual  exposures  are predicted  over 10,000 years.   Gaseous
release is not possible from bedded salt because of the saturated
condition of the surrounding rock; further, no groundwater pathways
exist in  bedded salt under undisturbed  conditions.   The  maximum
individual millirem dose over 10,000 years will be zero.


                      2.2.3.   Cost of Option


      Exhibit  A-5  of  Appendix  A  presents   the  costs  of  the
transuranic waste repository.  Information is given for each year
over  the  projected   44-year  life  of  the   facility.    Original
estimates were for a  repository designed  to emplace the equivalent
of  .7 MTHM in 1988 dollars.   To make the analysis  generic,  the
dollar amounts are scaled to reflect a 100,000 MTHM repository by
assuming a linear cost relationship.   A 100,000 MTHM repository is
thus assumed to cost  about 143  (100/0.7) times as much as a . 7 MTHM
repository.  Undoubtedly, costs for the smaller repository include

                                35

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some  fixed  costs  that would  not  increase  To any  extent  as
repository size increases.   This technique therefore overestimates
the cost of a larger repository.  However, data limitations prevent
any other approach.

     Exhibit A-5 of Appendix A presents total costs over the life
cycle of  the transuranic waste  repository.   Costs are  given in
undiscounted 1990 dollars.  Total undiscounted costs of a 100,000
MTHM repository constructed in salt are $558 billion;  discounting
the cost stream at 2 percent yields a total discounted cost of $352
billion.   These costs are likely inflated  because  fixed costs —
costs that  would not change  with  volume stored — are  scaled up
along with variable costs.   This was  done because no breakdowns of
costs were provided.

     Costs for  canisters and  waste  forms are assumed  to be zero.
Generally, the waste form is simply  the form  of the wastes as they
leave the site where  they  were generated and/or stored.    No
particular engineered waste  form will be considered.  Similarly, no
particular engineered canister will be considered —the transuranic
wastes will be emplaced in the repository in  the packages in which
they arrive  from  the  transuranic waste generators and/or storage
facilities.

     Thus  total   discounted   cost   for  long-term  disposal  of
transuranic wastes consists only of  the  cost for the  repository.
The $352  billion  costs  of the repository is used throughout the
rest of this RIA  as a measure of cost of a  generic disposal site
for transuranic wastes.   The  actual  cost  of WIPP is  about  $2.3
billion in 1990 dollars discounted at 2 percent.
                                36

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                          CHAPTER THREE
            LEAST-COST OPTIONS AND COST-EFFECTIVENESS
                      3.1  HIGH-LEVEL WASTES


     Chapter Two presented the  costs of 48 options for long-term
geologic  disposal  of high-level  wastes,  and the  health effects
associated with each. Chapter Three uses this information to study
two questions:  (1) for any given health effect limit, what is the
least-cost  option  available and  (2)  for any given  limit  to the
individual dose, what is the least cost option available.


3.1.1.  Least-Cost Options  for Achieving Limits on Health Effects
     In  order  to  examine  the  first  question,   a  set  of  six
hypothetical  limits  on  the health  effects caused  by a high-level
waste  repository is proposed.   These  range  from  100,000  to 1,
accumulated over a 10,000 year period.   Exhibit 3-1A lists the six
limits, the least-cost option that  can  achieve each  limit, and the
health effects  and  costs  of the  least-cost options.  The exhibit
demonstrates  that  for any  limit greater than 1,  the least cost
option is disposal  in tuff in a  300 year canister with an annual
leach rate of 1 part in 1,000 (option  T3A) .   In  other words, the
option of choice does not change  regardless of the limit set on
health effects.  The least stringent limit costs  the same as the
most stringent.  It should be noted that none of the  48 options can
meet a  limit of  only one  health  effect during  the  10,000 year
period.   Only  an  option  where less  than one health  effect was
predicted would have been accepted  to meet the health effect limit
of one.  Therefore,  although option T3A is associated with only one
health effect,  it is not  an  acceptable option in  this case.

     The analysis continues by examining what choice would be" made
if no tuff site were available for the repository.  The result is
shown in Exhibit 3-1B.  The  option of choice in this case for any
limit of 100 or more health effects would be S3A — disposal in salt
in a 300 year canister in a waste form  with a leach  rate of 1 part
in 1,000 per year.   The  exhibit shows for this example too that no
additional costs are incurred as the limit is reduced from 100,000
to 100 health effects.  To achieve a limit of 10  health effects,
the least cost option would shift to S6A, disposal  in salt  in a 300
year canister in a waste  form with an annual leach rate of 1 part
in 1,000,000.   The  result would be a reduction in health effects
from 39  to  5,  at an incremental cost of $20.6 million per health
effect avoided.  Both total costs and the number of expected health
effects are higher  in this scenario for any given limit than they
are when tuff is used as  the  geologic media.  Again, no option is
available that  can  meet a limit of  one  health effect during the

                               37

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                           EXHIBIT 3-1A
LEAST-COST OPTIONS FOR MEETING SIX HYPOTHETICAL LIMITS ON HEALTH EFFECTS



Limit on
Health Effects
100.000
10,000
1.000
100
10
1



Least Cost
Option
T3A
T3A
T3A
T3A
T3A
NA
Description of Least-Cost Option


Expected
Individual Dose
0
0
0
0
0
NA

Expected
Health
Effects
1
1
1
1
1
NA
Expected
Cost
(in millions of
1990 dollars)
12,533
12,533
12.533
12.533
12.533
NA
NA=Not available. None of the 48 options can meet this limit.

Source: Exhibit 2-9.
                                 38

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                           EXHIBITS-IB
LEAST-COST OPTIONS FOR MEETING SIX HYPOTHETICAL LIMITS ON HEALTH EFFECTS
               AFTER ELIMINATING DISPOSAL IN TUFF



Limit on
Health Effects
100.000
10.000
1.000
100
10
1



Least Cost
Option
S3A
S3A
S3A
S3A
S6A
NA
Description of Least-Cost Option


Expected
Individual Dose
0
0
0
0
0
NA

Expected
Health
Effects
39
39
39
39
39
NA
Expected
Cost
(in millions of
1990 dollars)
14.815
14.815
14.815
14.815
15.515
NA
NA=Not available
                                  39

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10,000 year period.

     The  analysis concludes by  examining what options  would be
chosen if  both  tuff  and salt were eliminated from consideration.
The results are shown in Exhibit 3-1C.  The exhibit shows that when
disposal  in  tuff and  salt is eliminated  from  consideration,  no
options  remain that  can satisfy a  limit of  10  or  less health
effects.   The options  that can satisfy a standard of 100 or more
are all  based  on disposal in  basalt in  300  year  canisters, with
decreasing  leach  rates  as  the  limit  becomes  more  stringent.
Decreasing the leach rate, however, adds  a relatively small amount
to the cost of achieving the limit.  A  reduction in health effects
from 11,600  to 73 can  be achieved  with an  increase  of  only 4.8
percent in the total  cost of the repository.  Thus, it may again be
seen that the stringency  of the limit has  little effect on costs.


         3.1.1.1  Costs and Effects of  Varying the Medium


     As shown in Exhibit 3-2, choice of a medium makes the greatest
difference in both cost and health effects. The exhibit highlights
the fact that,  regardless of the limit set, tuff  is both the lowest
cost medium and the most  effective at minimizing health effects.

     The second choice is salt.  However,  to  achieve a limit of 10
or fewer  health effects in salt for a medium costs  $2.6 billion
more  than for  tuff.    (For  100  or  more  health effects,  the
difference in costs drops to $2.3 billion.) Nevertheless, any salt
option costs less than any granite or basalt option.  Furthermore,
referring also to Exhibit 2-9, the highest number of health effects
associated with any salt option (39 under option S3A) is less than
the lowest number associated  with any  basalt or granite-based
option (43 under option B6C).

     For  limits on  health effects of 100  or  more,  basalt  and
granite become options, though  their costs  are clearly higher'than
those for salt or tuff.  Achieving a limit of 100  health effects,
for example,  in basalt  would cost $3.1 billion more than to achieve
this limit in  salt,  while health effects would  almost  double.
Achieving a limit of  100 health effects in  granite would cost $6.7
billion more  than in salt, while health  effects would increase from
39 to  54.   In  comparing granite and  basalt,  it  can be  seen  in
Exhibit 2-9 that the highest cost basalt option costs less than the
lowest cost granite option.  Some granite options however,  as  in
the example,  have  lower health effects  than  some  basalt  options.
However,  as Exhibit 3-2 shows,  in comparing granite and basalt for
any given  limit, the  lowest  cost option will be  one based  in
basalt.
                                40

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                          EXHIBIT 3-1C
LEAST-COST OPTIONS FOR MEETING SIX HYPOTHETICAL LIMITS ON HEALTH EFFECTS
               AFTER ELIMINATING DISPOSAL IN TUFF OR SALT



Limit on
Health Effects
100,000
10.000
1.000
100
10
1



Least Cost
Option
B3A
B3A
B3A
B3A
NA
NA
Description of Least-Cost Option


Expected
Individual Dose
100.000
10,000
1,000
100
NA
NA

Expected
Health
Effects
11.600
4.900
662
73
NA
NA
Expected
Cost
(in millions of
1990 dollars)
17,183
17,321
17.476
17,898
NA
NA
NA=Not available
                              41

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                                         EXHIBIT 3-2
                        COSTS AND HEALTH EFFECTS OF LEAST-COST OPTIONS
                                         BY MEDIUM





Limit on
Health Effects
100,000
10,000
1.000
100
10
1
Tuff
Cost of
Lowest
Cost
Option
(millions of
1990 dollars
12,533
12.533
12,533
12,533
12.533
NA



Projected
Health
Effects
1
1
1
1
1
NA
Salt
Cost of
Lowest
Cost
Option
(millions of
1990 dollars
14.815
14,815
14.815
14.815
15,515
NA



Projected
Health
Effects
39
39
39
39
5
NA
Basalt
Cost of
Lowest
Cost
Option
(millions of
1990 dollars
17.183
17.321
17.476
17.898
NA
NA



Projected
Health
Effects
11.600
4,900
662
73
NA
NA
Granite
Cost of
Lowest
Cost
Option
(millions of
1990 dollars
20,812
20,812
21.086
21,481
NA
NA



Projected
Health
Effects
9,350
9,350
516
54
NA
NA
NA= Not applicable. No option satisfies the proposed limit.

Source: Exhibit 2-9
                                              42

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       3.1.1.2  Cost and Effects of Varying the Leach Rate
                        and Canister Life


     As noted  above,  the choice of leach rate  and  canister life
makes no  significant difference  with  respect to health effects
where the repository is  in tuff.  The costs increase  if the life of
the  canister  is   lengthened  or  the  leach  rate   is  decreased.
However,  no  benefits in the  form of reduced health  effects are
realized by doing so.

     With  salt,  however,  a pattern  is apparent.   Exhibit 3-3
compares each of the 12  salt options to  all other salt options and
presents the cost per health effect avoided of moving between the
two.  Comparing options S3A  and  S3B shows that  lengthening the
canister life from 300 to 1,000 years reduces health effects from
39 to 37  at  a  cost of $172.50 million  per health effect avoided.
As a second example, decreasing the leach rate of 1  part in 1,000
in  option S3A to  1  part in  10,000 (option  S4A) reduces  health
effects from 39 to 20 at an incremental cost  of $7.2  million per
health effect avoided.  Close  examination of Exhibit 3-3 reveals a
general rule:   reducing leach rates is more  cost-effective than
increasing canister life.


         3.1.2.  Least-Cost Options for Achieving Limits
                       on Individual Doses
     In  order  to  examine  which are  the least-cost  options  for
achieving limits on individual doses, a set of seven hypothetical
limits is proposed on  individual exposures  to radiation due to a
high-level waste repository.   These  range from an annual committed
effective dose of 200 to an annual committed effective dose of 5.
Exhibit 3-4 lists  each  of  the seven limits  and,  for each medium,
the least-cost  option  that can achieve the limit and the health
effects of each option.

     Constructing a repository  in granite or  basalt will clearly
lead  to  a  greater number of  health effects,  a   large  maximum
individual dose, and higher cost than choosing salt or tuff.  The
exhibit also demonstrates that a maximum annual committed effective
dose of 100  millirem or  less is available only  in  salt  or tuff.  No
basalt or granite option can achieve,  among the limits proposed, a
more stringent limit than  200 millirem.  Any tuff or salt option,
on the  other  hand, can  achieve any  limit;  the  annual committed
effective dose associated  with all tuff and salt options is zero.
Of the two media, tuff is preferable as it has  the lower cost, $2.3
billion less than for salt. It is clear that for salt and tuff the
choice  of  canister  and   leach  rate  is not important  to  the
individual dose.
                                43

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                                              EXHIBIT 3-4
                          COSTS AND INDIVIDUAL DOSES OF LEAST-COST OPTIONS
                                            BY MEDIUM
Limit on
Individual
Dose
(annual
committed
effective
dose in
millirem)
200
100
50
25
15
10
5
Tuff

Cost of
Least
Cost
Option
(millions of
1990 dollars)
12,533
12,533
12,533
12,533
12,533
12,533
12,533




Projected
Individual
Dose
0
0
0
0
0
0
0
Salt

Cost of
Least
Cost
Option
(millions of
1990 dollars)
14,815
14,815
14,815
14,815
14,815
14,815
14,815




Projected
Individual
Dose
0
0
0
0
0
0
0
Basalt

Cost of
Least
Cost
Option
(millions of
1990 dollars)
17,898
NA
NA
NA
NA
NA
NA




Projected
Individual
Dose
100
NA
NA
NA
NA
NA
NA
Granite

Cost of
Least
Cost
Option
(millions of
1890 dollars)
21,481
NA
NA
NA
NA
NA
NA




Projected
Individual
Dose
100
NA
NA
NA
NA
NA
NA
NA= Not applicable. No option satisfies the proposed limit.

Source: Exhibit 2-
                                                 45

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                        3.1.3   Conclusions


     Constructing  a  repository in  tuff  or salt  will lead  to a
smaller number of  health  effects,  lower  maximum individual dose,
and lower costs than  choosing basalt or granite.  Likewise, tuff is
clearly preferable to salt in all three measures.   Performance in
tuff is not improved either by reducing leach rate or lengthening
the canister  life.  The  most cost-effective means  of improving
performance in other media is to reduce the leach rate.


                     3.2  TRANSURANIC WASTES
     Because the health effects and individual doses were computed
for only one configuration  of  a TRU  repository,  a detailed cost-
effectiveness analysis  cannot  be developed.   However,  the small
number of health effects and the zero  individual doses indicate
that so long as the model for  the TRU  repository established in
salt is valid, more  stringent measures for reducing leach rates and
increasing canister life are not likely to be necessary.
                               46

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                           CHAPTER  FOUR
             40 CFR PART 191 AND RELATED REGULATIONS


     Chapter Two of this report identified the various combinations
of geologic media, leach rates,  and  canister  lives  that could be
used for long-term disposal  of  high-level  and transuranic wastes
and  examined  the  costs,   and   health  effects,  and  individual
exposures associated with each.   Chapter Three compared the costs
and effects  of  the  various options and determined  which are the
most  cost-effective.    In  this  chapter,  the  findings  of  these
previous chapters are examined in light of the requirements of the
proposed  40  CFR  Part  191 and  the  options  that  can  meet  the
standards are identified.

     This  chapter also  compares 40  CFR  Part  191  to  a Nuclear
Regulatory Commission rule  that imposes related — and  to  some
extent overlapping — requirements on repositories for the long-term
disposal of high-level wastes.  Since any repository  for high-level
wastes  would also  have  to  meet  the  requirements  of  the  NRC
regulation, 10 CFR Part 60, the options for disposal are examined
for their ability to satisfy both regulations.
               4.1   REQUIREMENTS  OF  40  CFR  PART  191


     The following sections describe the requirements of Subpart B
of  40  CFR Part  191,  as proposed on August 14, 1992  (EPA 92B) .
Subpart B addresses  environmental needs by mandating that long-term
disposal of high-level and transuranic wastes satisfy three types
of  requirements:     a   containment requirement,   an  assurance
requirement, and an individual dose requirement.  The limitations
imposed by each are discussed below.


               4.1.1.  The Containment Requirement


     The containment  requirement of 40 CFR Part  191  states that
"the  cumulative  releases  of radionuclides  to  the  accessible
environment for 10,000 years after disposal .  .  . shall (1) have a
likelihood of less than  1 chance in 10"  of exceeding the quantities
calculated according to  the procedure described below and presented
in  Appendix A,  Table 1 of  the  proposed  rule;  "and (2)  have a
likelihood of  less  than  1  chance in 1,000  of  exceeding  ten times
those quantities."   It is further required that the standard be met
despite any human-initiated  or natural event  that may affect the
disposal system, such as human intrusions,  volcanic  activity, and
seismic events (EPA 92B).
                                47

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     The rule was  set  by assuming that no more than 1,000 health
effects attributable to  the facility should be allowed during the
10,000-year  period  commencing   with   its  opening,   and  "back
calculating" to determine the  allowable  release  of  each  of 22
radionuclides  based on  the  assumption that  the  equivalent of
100,000 MTHM is to  be stored in the repository.  The release limits
are expressed in curies  "per  1,000 MTHM or other unit of waste."
In other words, for each 1,000 metric  tons of spent fuel stored,
compliance with the  limits would lead to  no more  than 10 health
effects over  10,000 years owing  to all expected  and unexpected
occurrences.    Thus,   for the  high-level waste  facility,  the
containment requirement  may be restated as follows, assuming the
facility is storing the equivalent of 100,000 metric tons of spent
fuel:  over the 10,000-year period, there must be a likelihood of
less than 1 chance in  10 of  exceeding  1,000 health effects and a
likelihood  of  less than 1 chance  in  1,000 of  exceeding 10,000
health effects.  The rule may  also be described graphically, using
the concept of  the CCDF introduced in  Chapter Two,   Exhibit 4-1
presents the CCDF  for the proposed containment requirement.

     For transuranic wastes,  the rule must  be restated differently
when expressing it in  terms of allowable health  effects.   The 40
CFR Part 191 release limits are  based  on 1,000 cumulative health
effects from a 100,000  MTHM spent  fuel  inventory.  Since the waste
unit is 1,000 MTHM, this is equivalent to  ten health  effects per
unit.  This factor can be applied to  the  TRU  waste inventory to
determine the  acceptable  number  of health effects  over  10,000
years.  Under the waste unit definition used in the 1985 version of
40 CFR Part 191,  the  TRU inventory is  5.42 waste  units,  and the
allowed number  of  health effects  would be about 54  (5.42 waste
units x 10 health effects per waste unit).  Under the definition of
waste units currently used by EPA,  the TRU inventory  is only 0.7
waste units and the allowable number of health  effects  would be
seven (Rogers 92).


                   4.1.2  Assurance Requirements
     The  assurance  requirements  proposed  in  40  CFR  Part  191
describe methods for  ensuring that the containment requirements are
met.  These requirements, which are stated in general terms, seek
to  reduce the  likelihood of  intrusion and  forbid  reliance  on
institutional   and   physical   mechanisms  that  require   active
intervention  by humans  for  long-term  security.   The  assurance
provisions  also  require  that a  combination  of  geologic  and
engineered barriers be used to  isolate the wastes, that the site be
monitored until  it  is clear that it is  performing as  predicted,
that truly long-term considerations be used in selecting the site,
and that recovery of wastes from the sites be feasible  (EPA 92B) .
Since all options considered in Chapter  Two are assumed to be able
meet the assurance requirement, this requirement is  not discussed

                                48

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further  in this chapter.


            4.1.3   Individual Protection Requirements
     The  individual protection requirements, in  contrast to the
containment   requirements,   refer  to  deleterious   effects  of
radioactive wastes  on  individuals as opposed to populations.  The
limits  proposed by EPA  result from an analysis  of  the expected
performance of the disposal  system over time and  consider all types
of radioactive material.  The standard also deals with how  long the
requirements would  apply and sets the  appropriate  dose level.  The
duration for the standard is set at 10,000 years.  The standard for
individual exposures, referred to in 40 CFR Part  191 as "the annual
committed  effective  dose,"  is  15  millirem,  representing  "an
acceptable level  of risk for a multi-pathway exposure limit (EPA
92) ."


         4.1.4  Options for  Meeting  the Proposed Standard


      The  data  presented in  Chapter  Two indicate the  number  of
health  effects  and the  individual  doses  attributable  to  each
option,  first  for  high-level  wastes  and  then  for transuranic
wastes.   In the following sections,  these data are compared to the
requirements of 40  CFR Part  191.


                    4.1.4.1   High-Level Wastes


     As discussed in Chapter Two, this study considers 48 options
for the  long-term disposal  of high-level wastes.   Comparing the
standard  with  the  health effects associated with each  of  these
options reveals that some meet the  requirements and  some do not.
Using the data  on health effects  in Exhibit 2-9 and  applying the
containment requirement  that  the  number  of  health effects caused
over 10,000 years must not exceed 1,000, options B3A-B4C,  as well
as G3A-G4C, must be eliminated.  All other options for high-level
waste disposal,  however, satisfy this portion  of the  standard.
This includes the least  costly option,  T3A,  discussed in Chapter
Three.

     The individual  protection requirements of 40 CFR  Part 191 hold
that  the annual  committed   effective  dose  shall  not exceed  15
millirems at any time during the 10,000-year  period.  Applying this
standard  to all options for high-level wastes  yields the result
that no option that uses granite or  basalt as the geologic medium
(B3A-B6C and G3A-G6C)  satisfies  the requirement.   Although  large
numbers of options  are  eliminated by  this rule,  the  least costly

                                50

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ones  are not.    Results  of  the  comparison  of  options to  the
containment requirement and the individual dose requirement  of 40
CFR Part 191 are summarized in the first three columns of Exhibit
4-2.
                   4.1.4.2  Transuranic Wastes


     The number of health  effects  expected  under the sole option
evaluated for  disposing of TRU wastes  is less than  one.   Thus,
whether the TRU waste inventory is defined as 5.4  waste units as in
past practice or as 0.7 waste units as in the current definition,
option TRU1  results  in  less  than  the  allowed number  of health
effects and satisfies the standard.  As shown in Exhibit 2-9, given
the individual exposures for  TRU1  described in Chapter Two,  this
option also satisfies the individual dose requirements  (Rogers 92).
               4.2   RELATIONSHIP OF 40  CFR  PART  191
              TO NUCLEAR REGULATORY COMMISSION RULES
     The  Nuclear Waste  Policy Act  of  1982  and  its  amendments
authorize the Nuclear Regulatory Commission to promulgate technical
requirements and criteria to apply to repositories for high-level
wastes  (NWPA  83a,  NWPA 83b,  and NWPA 87) .  The requirements set
forth by  the NRC are  delineated  in  10 CFR Part  60  (Disposal of
High-Level  Radioactive Wastes  in Geologic Repositories),  which
prescribes   rules   governing  the  DOE   licensing  of  geologic
repositories (NRC 82) .   Some  of these rules are  related  to those in
40 CFR Part 191.  Any disposal  system will need  to  be able to meet
the requirements  of both.   One requirement of  10  CFR  Part 60 is
that  the  leach  rate  shall  not  exceed  1  part  in  100,000.
Consequently, high-level waste options T3A-T4C, S4A-S4C, B3A-B4C,
and G3A-G4C can be  rejected,  as these are based on leach rates of
I part  in 1,000, or  1 part in  10,000.   This  list  includes the
least-cost  option,  T3A,  which  would  result  in  1  predicted
statistical health  effect  and  an individual dose  of  0 mrems per
year.

     A second portion of 10  CFR Part 60 relating to canister life
further reduces the number  of  options available  by  requiring a
canister  life of  at least  300  to 1000 years (NRC  82).   Thus any
options with a canister life  of 300 years  (represented  in the list
of  options as  those  with  an   "A"  as the  third  character)  are
presumed to be unacceptable.  This eliminates options B3-B6(A), G3-
G6(A), S3-S6(A), and T3-T6(A).

     Exhibit 4-2  summarizes  the  effects  of 10  CFR Part 60 on the
list of options that  can be used to satisfy 40 CFR  Part 191 for
high-level  wastes.    Only eight  options  out   of  a  possible  48

                                51

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                                     EXHIBIT 4-2
EFFECTS OF 40 CFR 191 AND 10 CFR 60 ON THE OPTIONS FOR DISPOSING OF HIGH-LEVEL AND TRANSURANIC WASTES




OPTION
High-Levef Wastes
T3A
T3B
T3C
T4A
T4B
T4C
TSA
T5B
TSC
T6A
T6B
T6C
S3A
S3B
S3C
S4A
S4B
S4C
S5A
S5B
SSC
S6A
S6B
sec
B3A
B3B
B3C
B4A
B4B
B4C
B5A
BSB
B5C
B6A
B6B
B6C
G3A
G3B
G3C
G4A
G4B
G4C
G5A
G5B
G5C
G6A
G6B
G6C
Transuranic Wastes
TRIM
40 CFR 191
Options
Eliminated
By Containment
Requirement

























X
X
X
X
X
X






X
X
X
X
X
X








Options
Eliminated
By Individual
Dose Requirement

























X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X


10 CFR 60
Options
Eliminated
By Leach Rate
Requirement

X
X
X
X
X
X






X
X
X
X
X
X






X
X
X
X
X
X






X
X
X
X
X
X







NA
Options
Eliminated
By Canister
Requirement

X


X


X


X


X


X


X


X


X


X


X


X


X


X


X


X



NA
NA=Not Applicable-10 CFR 60 does not apply to disposal of transuranic wastes.
                                           52

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simultaneously  meet all  requirements.   These  are options  that
dispose of waste in either tuff or salt,  have leach rates of 1 part
in 100,000  or  less,  and have canister  lives of  greater  than 300
years (Exhibit 4-3).  In a comparison of the eight final options,
tuff appears to  be the medium of choice.   All tuff  options  have
fewer expected health effects than any of those for salt, and have
considerably lower costs.
                                53

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                   EXHIBIT 4-3
OPTIONS MEETING ALL REQUIREMENTS OF 40 CFR 191 AND 10 CFR 60
              High-level Wastes


Option Code
T5B
T5C
T6B
T6C
S5B
S5C
S6B
S6C
Description

Media
Tuff
Tuff
Tuff
Tuff
Salt
Salt
Salt
Salt
Leach Rate
(parts per year)
10A-5
10~-5
10~-6
10^-6
10~-5
10~-5
10~-6
10~-6

Canister Life
1000
3000
1000
3000
1000
3000
1000
3000
             Transuranic Wastes

TRU1
Salt
Unlimited
0
                     54

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                           CHAPTER  FIVE
                 THE IMPACTS OF GASEOUS RELEASES

     The information presented  in  Chapter  Two  on  the effects and
costs associated with the 48 options does not account for gaseous
releases.  Such gaseous releases can occur under certain conditions
in which the medium is porous and unsaturated.  Other factors such
as airflow patterns combine to create  a  circumstance  in which
substantial radioactive releases may occur.  The gas that, due to
its nature and its quantity in the  waste  stream, has the potential
to cause the greatest number of health effects is carbon 14.

     The modeling for gaseous releases is based on a repository in
tuff (Rogers 92).   It is  only an  example since the conditions of
unsaturated porous rock could possibly occur in another medium.

     Two modes of gaseous releases are modeled in tuff: diffusion
and advection.   For 100,000 MTHM of wastes stored  in  tuff,  in a
1,000 year canister and  with a leach rate of 1 part in 100,000 per
year (option  T5B) ,  the  number  of  health effects is 470  for the
advection model and less than 1 for the diffusion model.

     The  advection model   is  considered  further  by  performing
sensitivity analyses with respect  to canister life and leach rate.
The leach  rate has the  strongest  impact on the number of health
effects as indicated in  Exhibit  5-1.   Decreasing the leach rate to
1  part  in  1,000,000  (option T6B)  reduces  the number  of health
effects to  7.  Increasing  it again to 1  part  in 10,000 (T4B) per
year raises  health effects to  4,700; increasing it to  1  part in
1,000  per year  (option T3B)  raises them to  8,300.  Costs for these
options are included in Exhibit 5-1.

     Canister life has  a  much  smaller  impact  on the  number of
health  effects,   at  least  for  the  range  of  canister  lives
considered.   Increasing  canister  life from 1,000  years to 3,000
years (option T5C) reduces the number of health effects to 305, a
much smaller decrease than  results from  changing   the  leach"rate
variable.   However,  it  should be  noted  that  introducing  a super
canister with a  10,000-year life  can reduce  the number of health
effects to near zero.

     There are several reasons to consider a super canister.  Other
modeling shows that if engineered barriers fail and all carbon 14
stored  in  the systems  is released,  the  number  of  health effects
from a  100,000 MTHM repository  in  tuff  will  reach 12,400  (Rogers
92) .   If a  10,000 year canister is  successfully employed the number
of health effects will drop  to one.

     In anticipation of the availability of  a 10,000-year canister,
its  costs  and  benefits  of technological  barriers are  briefly
examined.  Two studies have been performed  to estimate the cost of
engineered barriers to prevent the release of  carbon 14 within the

                                55

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                           EXHIBIT 5-1

              SENSITIVITY OF HEALTH EFFECTS TO CHANGES
                  IN LEACH RATE AND CANISTER LIFE
                                                         Net Present Value
              Health Effects                                   of Total
               of Gaseous      Other        Total              Cost
    Option       Advection    Health Effects  Health Effects  (millions of 1990 dollars)

     T3B             8830             1          8831                 12,863
     T4B             4700             1          4701                 12,993
     T5A              538             1          539                 12,807
     T5B              470             1          471                 13,137
     T5C              304             1    .     305                 14,744
     T6B               47             1            48                 13,532
Sources:  Rogers 92, and Exhibit 2-9
                                    56

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10,000 year period proscribed by 40 CFR Part 191.   It must be noted
however that a large amount of uncertainty is associated with the
cost and health effect estimates of both.

     The DOE, in  a June  17,  1992  presentation to the EPA Science
Advisory Board Subcommittee on carbon 14, presented results based
on DOE assumptions of carbon 14 inventories and release (SAIC 92) .
The posited engineered barrier was  a  ceramic metal canister that
remained airtight for 10,000 years.  An estimated 25,000 of these
would be required for a  100,000 MTHM repository.  The total system
cost  for  this is  estimated  to  be $3.25  billion  (undiscounted) .
This cost is in addition  to the original cost of a canister to meet
10 CFR Part 60.   After applying a  2 percent discount rate, the net
present value of the cost is $2.1 billion.

     The  EPA, in a  similar study  using  a  10,000  year  super
canister, estimated the  incremental total life-cycle cost as $2.1
billion (SCA 92).  Discounted over the 50-year operating period of
the  repository  at  2 percent the  present  value  would be  $1.4
billion.

     Health effect projections  for a super canister  have  a high
degree  of  uncertainty because  the canisters  are untested.   To
address  this  a   range   of   assumptions   is  made:  from  perfect
performance for the technology to total failure.  No health effects
would occur from gaseous releases if the canister lasted the full
10,000  years.    In the   worst case,  approximately  12,400  health
effects will result from total failure of  the canisters to contain
the gaseous releases  (SCA 92).

     These  outcomes  suggest  a  range  for the cost-effectiveness
ratio of reducing emissions  of carbon 14  (Exhibit 5-2).  Combining
high cost assumptions ($2.1  billion) with poorest performance of
the  barrier  (reduction  of   1 health  effect)  leads  to a  cost-
effectiveness ratio of $2.1 billion per statistical health effect
averted.  Combining low  cost assumptions  ($1.4 billion)  with best
performance  (12,400  statistical  health effects  averted)  for the
other end of  the  range gives a  bound  of $117,000 per statistical
health effect averted.  A midpoint between the two estimates gives
a value of $289,000 per  health effect averted.
                                57

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                           EXHIBIT 5-2
                 SENSITIVITY OF COST-EFFECTIVENESS
                   TO PERFORMANCE OF CANISTER




Worst Case
Intermediate Case
Best Case
Net Present Value
of Incremental
Costs
(billions of 1990 dollars)
2.1
1.8
1.4
Incremental
Health
Effects
Averted
1
6,201
12,400

Cost-
Effectiveness
(millions of 1 990 dollars)
2142.534
0.289
0.117
Note: All dollar values are in 1990 dollars discounted over 50
years at 2 percent


Sources: Rogers 92, SAIC 92, and SCA 92.
                                       58

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                           CHAPTER SIX
                  THE IMPACTS OF 40  CFR PART 191


     The previous five chapters have discussed the costs expended
on repository development, waste forms, and canisters for various
options for disposing of high-level and transuranic wastes; and the
health  effects,  and  individual  exposures to radiation  for each
option.  The focus was on the cost-effectiveness of each option and
on the extent to which 40 CFR Part 191 and 10 CFR Part 60 limited
the available options.

     This  chapter takes a broader  view.   It first  assesses the
stringency  of  40 CFR Part 191,  reviewing the cost-effectiveness
results  of previous chapters and anticipating the  discussion of
distributional impacts that  follows.  The generators of the high-
level and  transuranic wastes are then profiled,  as they will bear
the direct  costs of  any increased stringency in the specification
of waste forms and canisters.  Next,  the distributions of the cost
burdens borne by the various generators of radioactive wastes are
considered.    Finally,   conclusions  are  drawn  regarding  the
stringency  of 40  CFR Part  191  and  the magnitude  of  its impact on
those directly affected.
         6.1  ASSESSING THE STRINGENCY OF 40  CFR PART  191
     In  this  discussion five criteria are proposed  to  judge the
stringency  of  a  standard.    Those  criteria  offered  are  the
implementational flexibility allowed by the rule; the tightness of
the standard, that is, the reguired reduction of contaminants from
current or baseline levels; the cost-effectiveness of and cost per
averted  health effect  implied by  the  standard;  the ability  of
current  engineering  and technology to meet  the  standard;  and the
impact of the standard  on consumers and producers.   It  is argued
below that 40 CFR Part 191 is not stringent in terms of its effects
on the choice  of available  options  for disposal of high-level and
transuranic wastes.

     Criterion  1,   flexibility,  considers  how  much  the  rule
constrains the choice among options by eliminating easier options
that would  have  been acceptable otherwise.    That  is,  the  more
flexible the rule, in terms of allowing options for meeting it, the
less binding it is, and the less costly it should be on average to
implement.   In this regard, note that 40 CFR Part  191  relies  on
performance standards rather than technological reguirements.  The
rule does  not eliminate  any  category of geological  formation a
priori.  It does not require any specific engineered barrier,  only
that some  form of  engineered  barrier be used.   Hence the  rule
allows flexibility  to choose  the most cost-effective alternative
and allows the use of new  techniques developed after the rule is in

                                59

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place.   In  contrast 10 CFR Part 60 requires that  leach rates be
less than 1 part in 100,000 (10~5) and canisters last at least 300
to 1,000 years.  This observation is not to suggest a defect with
10 CFR Part 60.  But  from a purely economic standpoint, the less
explicit the form of the technology and the more freedom given for
implementation of a rule,  the  more cost-effective  on average the
rule will be.  In this  respect,  40 CFR  Part 191 allows an option
that costs $604 million less than  the least-cost  option under 10
CFR Part 60.

     Criterion  2,   the  tightness   of  the  rule,  is  frequently
described by  its requirements for the  reduction of  pollution,
emissions, releases, and so on, from current levels.   A rule that
requires pollution to be  reduced by 99  percent is  more demanding
than one that  stipulates only a 95 percent reduction.  The question
then  becomes,  "What   reduction   from   current  levels  is  EPA
requiring?"  In considering this  question it is noted that NRC has
promulgated and  DOE  has  formulated  and undertaken  containment
strategies that, according to EPA's modeling efforts, can more than
meet the requirements of 40 CFR Part 191.  The minimum acceptable
disposal scenario (acceptable to  the scientific community, many in
the disposal  community,  and the general  public)  appears  to  be
geologic.  Therefore, for large volumes  of  radioactive wastes the
listing of possible disposal media  would  start with geologic media
and become  increasingly stringent  from  there.   To buttress this
argument  we  note  the  following:    geologic  disposal has  been
recommended by several  scientific  bodies,  including  the National
Academy  of Sciences/National Research Council  (NAS-NRC)  Advisory
Committee in 1957,  the NAS-NNRC Advisory Committee on Radioactive
Waste Management  (CRWM)  in 1968,   the  Federal Energy Resources
Council  (FERC) in 1976, the Interagency  Review Group  in 1980, and
the Bureau on Radioactive Waste  Management (BRWM 90).   For both
high-level waste and transuranic wastes,  Congress has decreed that
geologic repositories be evaluated  and has specified locations for
those repositories  (NWPA  87).  And lastly  tuff, while being the
cheapest disposal medium, is also the  most  protective of the four
examined here.  In  short,  high-level waste  disposal  in saturated
tuff or  salt with only minor engineered barriers meets the standard
for containment required by 40  CFR  Part  191.

     Criterion 3,  the  cost per  averted  health effect  is,  in
general, related to the effects  of the  first two criteria.   The
cost per  averted health effect generally increases and  the rule
becomes  less  cost-effective as a rule's  flexibility  is decreased
and as  the  standard it implies  is  tightened.   Cost per  averted
health effect  has an advantage  over  the first two criteria in that
it can typically be stated in more  concrete terms.  Comparing the
cost per averted health effect of  the possible  options to a base
case  or to  each  other allows  for a  discussion of  the  cost-
effectiveness   of   the  options.     This  is  the  basic  approach
economists use:  to compare the incremental cost of moving to the


                               60

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next most stringent option with the  incremental benefits  realized
from such a move.

     This cost-effectiveness comparison  is  used  here rather than
the more familiar  cost-benefit analysis  for several  reasons.   It
allows a comparison of several different disposal options so that
the cost-effectiveness and stringency of the  preferred standard may
be  placed  in  context.     Cost-effectiveness  analysis  is  also
appropriate when the costs and benefits are measured in different
ways.  In the  high-level  waste analysis  two factors  prohibit the
direct comparison  of  costs and benefits  in  a formal  cost-benefit
framework.  One,  the costs are discounted,  but  the  benefits are
not.   Discounting  of benefits  over the  long  periods  involved
(10,000 years for the health effects in this case)  or even over a
relatively short period, such as several hundred years, will give
a present value  of  zero,  for  any  reasonable discount rate.   Two,
the costs and benefits are expressed in different terms,  costs in
dollars,  benefits  in  averted health   effects.    There  is  no
monetization of health effects  that would be lost  or saved with the
choice of options.  And lastly the costs  and benefits of the least
stringent option,  tuff with  no canisters,   are  not  known.   The
absolute  costs of  such  a  repository  are  known,  but the  costs
incremental to what may have occurred in the  absence of  10 CFR Part
60  or  40  CFR  Part  191 are not known.   The  same applies  for the
health effects.  To confront this  problem, the various options are
compared  to  suggest  what  the  most  cost-effective  level  of
stringency might be.   As  demonstrated  in Chapter Three,  the most
cost-effective option examined  is T3A — constructing the repository
in  tuff, using a  300  year  canister  and  a waste form  with a leach
rate of 1 part per  1,000.   This is also the least-cost option and
has the lowest number of predicted statistical health effects and
the lowest individual dose of any option.

     Criterion  4  is  the  ability  of   current  engineering  and
technology  to meet  the standard.   According  to  EPA's  generic
modeling all  geologic media,   saturated  tuff,  salt,   basalt,  and
granite, meet EPA's containment standard.  Geologic vaults are not
technologically  daunting.    EPA  modeling  shows   that  a  more
sophisticated approach such as canisters or engineered barriers,
while  offering  additional assurance  of  containment,  are  not
necessary to meet  the  reguirements  of  the standard.   Only if the
preferred media  of tuff and  salt are unavailable,   or a  porous,
unsaturated medium is selected such  that gaseous emissions  may
escape, are advanced canister technologies reguired.

     Criterion  5,  the last  criterion  to   be  applied  in  this
stringency  assessment,  is the  impact  the  rulemaking  has  on
producers and consumers.   In other words,  what is  the  impact on the
economy itself and on the  standard of living, and what burden does
it  place on those  who  must pay for  it?   This is  not  a measure of
efficiency and simply  by  virtue of its  size does not  justify an
action.  However,  in the face of uncertain benefits it is important

                                61

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to be aware of the relative size of the impact being imposed by a
regulation in relation to the economy or a sector of the economy.
As will  be seen below,  the  economic  impacts of the rule  on any
single individual are likely to be small.


                6.2  PROFILES OF WASTE GENERATORS


     Nuclear waste generators, as defined in Chapter One, include
producers of both high-level wastes and transuranic wastes.  This
section discusses characteristics of these generators relevant to
an economic analysis of  the impact of 40 CFR Part 191.


              6.2.1.   Generators  of High-Level Waste


     Generators of  high-level wastes  are divided again  into two
types for purposes of the discussion in Section 6.2.1:  commercial
nuclear  power  plants that  generate  spent  fuel  and  DOE  non-
commercial generators of high-level waste.


          6.2.1.1   The Commercial Nuclear  Power Industry


     In 1988,  the commercial nuclear power industry's 108 operating
plants   provided   approximately  95   gigawatts  of   generating
capability,  about  14   percent  of  the  U.S.   total  generating
capability of  678  gigawatts.   In actual output, nuclear  plants
accounted for approximately 19 percent of the U.S. total.  The high
percentage of  output relative to capacity  is  due  to the lower
variable operating costs of nuclear power plants and the resulting
use of nuclear plants as baseload generating capacity (EIA 88A) .

Financial Characteristics of the Industry

     Two aspects of industry finance and ownership are important in
understanding and  analyzing impacts  of  40  CFR  Part  191  on the
commercial  nuclear  power  industry.    The  first  concerns  the
ownership  and  market shares  of  the  individual  utilities.   The
concentration of  nuclear power  plant  ownership  is an  important
policy factor because the costs of regulatory policy may fall most
heavily  on  the owners  of these  utilities  and their  customers.
According to  information  provided by DOE,  56  utilities held the 108
commercial nuclear power  plants that were operable as of the end of
1988 (EIA 89).

     This is  only part of the picture,  however, as some plants vary
in size,  and  some  utilities own more than one plant.   In fact, the
ownership  of  nuclear  power  industry  capacity   is   relatively

                               62

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concentrated, as only 10 utilities hold approximately 50 percent of
the capacity.  The nuclear capacities and market shares for these
10 utilities  are shown in  Exhibit  6-1.   Commonwealth  Edison of
Illinois is by far the largest with just over 12 percent of total
industry capacity. The next largest utility has only about half as
much market share. The Tennessee Valley Authority, which currently
has four plants  in the construction pipeline,  will be  almost as
large as Commonwealth when and if these plants become operable.  At
that time over 20 percent of the nuclear capacity will be held by
two utilities (EIA 89).

     A  second  topic  of financial  interest  concerns the  cost of
nuclear  plants  compared with  other baseload  generating  plants.
Since nuclear power plants  are  relied on for baseload capacity, as
opposed  to  peaking   capacity,   such   comparisons   are  generally
established in comparison with large coal plants which are the main
alternative for  baseload power.  One study  of this  issue by G.R.
Corey (Corey 84),  based on  comparisons of six large coal and six
large nuclear baseload power plants in 1979,  found that the nuclear
plants provided power for only 16.9 mils per  kWh compared with 30.2
mils per kWh for coal plants.   Even when the figures were adjusted
to a  60 percent capacity  factor, as the nuclear units  were more
heavily used because  of their cost-efficiency,  the nuclear plants
still cost only  16.8 mils per kWh compared with 27.3 mils per kWh
for the coal plants.   The study concludes that nuclear power would
most  probably  enjoy  a 15  to  20 percent cost advantage  in  the
future.

Prospects for Growth

     The commercial nuclear power industry is currently in a period
of stagnant growth.  Of the 14 plants ordered since 1974,  10 were
canceled, 2 were  rejected by state governments, and the remaining
2 have not  yet entered the construction phase.   While the long lead
times associated with new  construction make clear  the short-term
prospects for the nuclear power industry,  long-term prospects are
less predictable.  Accordingly, DOE has  constructed three different
forecasts of future generating  capacities through 2020.  The first
case  assumes no  new orders,  and  the second  (called the  lower
reference case)  that  only a limited amount of newly ordered nuclear
capacity will become operable  between 2005  and 2020.   The third
case (called the upper reference case)  assumes a higher growth rate
in newly ordered  capacity brought about by factors  such as strong
growth  in  electric demand  and environmental  concerns  related to
coal.

     DOE forecasts based on the three scenarios  are  illustrated in
Exhibit 6-2.  Under the no  new  orders case, capacity will decrease
to 52 gigawatts  of electricity (gWe) in. 2020.  Capacity under the
lower reference  case will  be  123  net gWe,  and under  the  third
scenario will be  182 net gWe.  The no new orders scenario and the
lower reference  are considered the most likely to occur.

                               63

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                               EXHIBIT 6-1
NUCLEAR CAPACITIES AND MARKET SHARES FOR THE TEN LARGEST NUCLEAR UTILITIES




Utilities
Commonwealth Edison
Public Service E&G
and Philadelphia Electric
Tennessee Valley Authority
Duke Power
Arizona Public Service
Virginia Electric and Power
Connecticut L&P
Carolina P&L
Florida P&L
Georgia Power
Total for Top Ten Utilities
Total for All Utilities


Capacity
(Net Megawatts
of Electricity)
11,713

6,426
5,497
4,880
3.799
3.392
3,196
3.105
3,010
2,603
47,621
95,901
Percent
of Total
Nuclear
Industry
Capacity
12.21

6.70
5.73
5.09
3.96
3.54
3.33
3.24
3.14
2.71
49.66
100
        Source: EIA 89
                                      64

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                          EXHIBIT 6-2
COMPARISONS OF PROJECTIONS OF U.S. COMMERCIAL NUCLEAR CAPACITY. 1990-2000
                          (Net Gigawatts)

Growth Scenario
No New Orders Case
Lower Reference Case
Upper Reference Case
Projected Capacity
1990
99
100
101
1995
101
103
105
2000
102
104
105
2010
97
101
136
2020
52
123
182
Source: El A 89
                                     65

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   6.2.1.2.  DOE Non-Commercial Generators of High-Level Waste


     DOE operates four sites that generate high-level waste.  Two,
the  Savannah River  Site  and the  Hanford Reservation,  produce
nuclear materials for  weapons and  two  others,  the Idaho National
Engineering Laboratory and  the West Valley Site,  perform nuclear
fuel reprocessing and research. Annual budgets and employment for
each of the sites are  provided in Exhibit 6-3.


             6.2.2  Generators of Transuranic Wastes


     Transuranic wastes are generated at 11 sites, all government
owned.  Four of the sites also generate  high-level  wastes.  Budgets
and employment at each of the sites for 1992 are listed in Exhibit
6-3.
        6.3  IMPACTS OF ALL COSTS ASSOCIATED WITH OPTIONS
     The costs of implementing 40 CFR Part 191 will fall on DOE, as
well  as  the generators  of  high-level and transuranic  wastes
described above.  The following sections consider the distribution
of those costs, and, where possible, their magnitudes.


          6.3.1   Cost to  DOE  of Demonstrating Compliance


     In accordance  with  the  requirements  of  10 CFR  Part  60,  DOE
must demonstrate to the Nuclear Regulatory Commission that any DOE
high-level  waste  repository will  comply   with  all  applicable
regulations,  including EPA's (NRC  82).   EPA recognizes  that" the
requirements to demonstrate  compliance with  40  CFR Part  191  may
impose some costs on DOE  and add to the cost of high-level waste
disposal.    However,  it should  be  noted that  this  is  just  one of
many regulations for which compliance  must be demonstrated.

     Components of the cost to DOE of demonstrating compliance with
40 CFR Part 191 include the following:

     •    Modeling  to  predict  the  expected  release  of  each
          constituent of  the stored wastes;

     •    Modeling to predict the  number of  projected statistical
          health effects;
                               66

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EXHIBIT 6-3
1992 BUDGETS AND EMPLOYMENT OF FACILITIES
GENERATING NON-COMMERCIAL HLW AND TRU WASTE
FACILITY
West Valley, NY
Los Alamos, NM
Oak Ridge, TN
Mound Plant, OH
Savannah River, SC
Idaho National, ID
Rocky Flats, CO
Nevada Test Site, NV
Lawrence Livermore, CA
Argonne, IL
Hanford, WA

BUDGET FOR FISCAL YEAR 1992
(million dollars)
Operating
Capital
104
1,024
370
183
1,440
NA
700
NA
1,008
NA
1,430

Capital
NA
121
30
11
460
NA
NA
NA
109
NA
61

Total
104
1,145
400
194
1,900
1,200
700
996
1,117
350
1,491

TOTAL
EMPLOYMENT
963
11,200
5,000
1,600
24,024
12,175
8,100
10,312
11,500
4500
16,200

NA: not available
Source: Corporate communications, September 1992.
                                            67

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     •    Modeling to predict the releases of radionuclides through
          groundwater flows;

     •    Modeling  to  predict  the   expected   dose  to  nearby
          individuals;

     *    Developing and presenting DOE-'s testimony;

     •    Developing rebuttals to arguments against DOE's case; and

     •    Interest on the cost of fixed investments that have been
          developed in advance of the hearing but may not be used
          until after the license is granted.

     Probably  many,  if not  all,  of these  costs will  have been
incurred  in the  development  of  the  facility  itself  or  as  an
unavoidable part of the licensing hearing.  The remainder of this
discussion  focuses  on those aspects of  demonstrating compliance
that may  be affected by  decisions  EPA made when  developing its
rule.

     Throughout this document the stringency of 40 CFR Part 191 is
discussed.   The  conclusion  is reached that  the  rule  is  not
stringent in terms of  setting standards difficult to meet.  This is
because  the  excavation  of  a  repository  in  tuff or  salt  is
sufficient   with   little  additional   effort   needed  for  the
construction of engineered barriers to meet both the containment
standard and the  individual  dose  requirement of 40  CFR Part 191
with a wide margin of  safety.  Appropriate engineered barriers are
not technically hard to design or fabricate.

     Two  aspects  of  the design of the  waste  disposal  system,
however,  pose  some challenges  to   DOE's ability to demonstrate
compliance.  First, predicting how a geologic barrier will perform
over 10,000 years  is difficult.  Such prediction requires assessing
the  normal  rates  of  release  of radionuclides  and  analyzing the
nature  and probability  of events  such  as  volcanic  eruptions,
earthquakes, and  intrusion by  humans.   Second, predicting  how
engineered  barriers  will  perform  over long  periods  is  also
difficult.  The forms of  the  wastes and  the canisters into which
they will  be  placed  must be analyzed.   In most  circumstances,
however, owing to the lack of  stringency of 40 CFR Part 191,  the
canister   is   not  required  to  last  more   than   300   years.
Demonstrating  that a  canister will  last  300 years  is much easier
than proving that  it  will  last  3,000 or  10,000 years.   Also,  the
rule does not demand extremely low leach rates.  Demonstrating that
the leach rate of  a waste form is  less than 1 part  in  1,000 per
year is again  simpler than demonstrating that  it is  less  than 1
part in 1,000,000 per year.

     Hence the  biggest difficulty in  predicting compliance with the
rule is predicting the performance of  geologic media over  a long

                                68

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period and predicting the probabilities of low probability events.
The fact  that EPA  states the containment rule  in probabilistic
terms does not complicate the demonstration of compliance so long
as the probabilities and consequences  of these  events have been
studied.    Such  considerations should be part of the  design of a
repository  in any  event.   If a  site is subject to  very high
probabilities of  volcanic or seismic  activity,  it should not be
proposed for a high-level waste repository.

     Two approaches to estimating costs are included here.  The
most  simplistic is  to assume that  all of  DOE's  D&E  costs for
repositories are attributed to demonstrating compliance with 40 CFR
Part 191.  This  amount is estimated  in Chapter Two for a 100,000
MTHM repository at  about  $7 billion  (undiscounted)  (Exhibit 2-6).
This  represents  an  extreme   outer  boundary    on the cost  of
demonstrating compliance with 40 CFR Part 191.

Second, it could be argued that most  of the D&E costs  will have to
be spent  regardless of what  the standard is.   Under  this assumption
the cost  of demonstrating compliance would be the  cost  of preparing
geologic models of the proposed system, plus a portion  of the costs
of the NRC licensing procedure.  The EPA has spent $1 million to $2
million on minimal geologic modeling in the course of developing 40
CFR Part 191.  The DOE's cost for  modeling will be  more than EPA's
however,  because  DOE will have to model a particular site while
EPA's models can be generic (FEHR).

The total cost of the  NRC licensing procedure  depends on the length
of the process,  number of  persons committed to  this  effort, and
associated support costs.  The total cost is estimated  here at $160
million,  based  on a  4-year process  involving  a large  number of
employees  and   contractors,   plus  costs   for   transportation,
equipment, and support.  While this estimate is  not  a rigorous one,
it reflects the view  of NRC staff that the licensing of the high-
level waste repository will be the largest such hearing ever held
and that DOE typically brings  a large staff to hearings and employs
numerous  contractors  in  its  support   (FEHR).    However,   only  a
fraction of  these costs will be  for  demonstration of compliance
with 40 CFR  Part  191, and only a  fraction  of that  amount will be
determined by the form and  stringency of the rule.

     For disposal of  transuranic wastes, DOE does not incur costs
of demonstrating  compliance to either  EPA or  NRC.   If,  at some
future time,  DOE is required to demonstrate compliance to EPA, the
costs  would  be expected  to  be similar to those  for high-level
wastes.
                                69

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         6.3.2  Costs to Generators of High-Level Wastes


     DOE bears the burden of constructing the repository for high-
level  wastes.   However,  the generators  of  those wastes  will
reimburse DOE.  The costs to these parties are discussed next.


       6.3.2.1  Fees Charged to Commercial  Waste  Generators


     Two methods of measuring the impact of waste disposal  fees on
the industry and the private sector are examined.  Both are rather
rudimentary owing  on  one hand to the fairly small  cost of high-
level waste disposal in  comparison with the much larger size of the
electric  generation  industry and  on  the  other  hand   to  the
difficulties in modeling the impact of increases in energy costs as
they are incorporated as inputs to intermediate  and final goods and
eventually passed, in varying degrees, along to the consumer.

     The  first method  employed  reflects  the  simplest  possible
assumptions and is  identical  to  the methods  utilized in the 1985
high-level waste RIA.   In  this method it  is  assumed that  impacts
can be determined by comparing annual  costs of the regulation with
total  industry  revenues  to  determine  the  change  in   average
electricity rates.    Consumers  are assumed  not  to  change their
purchasing patterns  as  a result  of the increased price,  and the
impact for a given consumer is merely  the product of the change in
average rates times the number of units purchased.

     The second method makes use  of  more complex economic concepts
to derive  a more  accurate portrayal of  the changes in  welfare
resulting from  the imposition of  disposal fees.   Specifically,
empirical estimates of elasticity of demand are employed to model
the impact  of the fee  on  the quantity of electricity  demanded.
This also allows calculation of the impact of the fee on consumer
surplus and thus on economic welfare.

Comparison of Annual Costs of 40  CFR Part 191
with Total Industry Revenue

     The exact  costs  of the  HLW storage  facility that DOE  will
select are  not known.   As described in  Chapter Two,  the costs
depend on the geologic  medium  selected, canister life,  and leach
rate.   Thus, three sets of costs  for the repository are  presented
here to provide a  range.  The  first  represents the lowest possible
cost and is based on  a  repository  in  tuff  with no  restriction on
canister life or leach rate.   The net  present value of the cost of
this configuration is  $11,225 million, or $257 million per year for
105 years (Exhibit 2-8).   The  second  set of  repository  costs are
those for the least-cost alternative for meeting  the requirements
of both 40 CFR  Part  191 and 10 CFR Part 60.   This  repository is

                               70

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located in tuff and uses 1,000 year canisters and a leach rate of
1  part in  100,000 per  year.   The  net present  value of  this
repository is  $13,137 million (Exhibit  2-9),  or $200 million per
year.   The  third repository  evaluated  is the  most costly option
that meets the  standard.   In this  option, wastes are stored in a
salt formation,  in a  waste  form with a leach rate of  1  part in
1,000,000 per  year and  a canister lasting 3,000 years.   The net
present value of this  third repository is $17,537 million, or $401
million per year (Exhibit 2-9).  All three configurations meet the
requirements of 40 CFR Part  191.  Health effects in the first two
options are limited to  1  in 10,000 years.   Health effects in the
third, more costly option equal 5 in  10,000 years.

     Total revenues of the electric utility industry in the United
States were approximately $179 billion in 1990  (EIA 90) .  The $257
million annualized cost of  the  least  stringent option in tuff is
0.14 percent of those  total revenues.  The annualized costs of the
more stringent configurations are, respectively, $300 million, or
0.17 percent, and  $401 million, or 0.22 percent of total revenue.
Incremental increases in cost are,  from  the first configuration to
the second,  $43.7 million,  or 0.024 percent,  from the second to the
third, $100.6 million, or 0.056 percent of the total revenue, and
from the first to the  third, $144.3 million or  0.08 percent of the
total revenue.

Application of a Model Based  on
Elasticity of Demand for Electricity

     This section  discusses the  second  approach to analyzing the
effects of 40 CFR Part 191 on electric  utilities: modeling consumer
surplus, welfare cost, and changes in total revenue  associated with
the regulation.   The  model  uses  as inputs  estimates  of the price
elasticity of demand for residential,  commercial,  industrial, and
other  consumers  of  electricity  (Exhibit  6-4);  the  amounts  of
electricity  generated  by   nuclear   and  non-nuclear  generators
(Exhibit 6-5);  quantities  of electricity sold (Exhibit 6-6); and
average revenues (Exhibit  6-7).   These data  are  shown  for"each
state.   The  model provides all  of  its results  at  the  state,
regional, and national levels. The primary calculations are at the
state level.

     Measuring  changes  in  consumer and producer  surpluses  is a
widely  accepted operational method of  evaluating  welfare losses
because of  changes in  the  price  or  availability of  a  product.
There  are   theoretical   and  practical considerations   in  the
application  of  this  technique.    One  theoretical issue  in  the
measurement of consumer  surplus concerns the implicit change of the
consumer's income as the price of the commodity is changed.  In the
case of this regulation, the  imposition of the waste disposal fee
will  raise  the  price  of electricity  and  thus reduce  income of
electric  power consumers.   Although the  impact  of  this  income
change on consumer surplus is an  interesting conceptual issue, its

                                71

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                              EXHIBIT 6-4
         LONG RUN PRICE ELASTICITY OF DEMAND BY SECTOR AND REGION

Total U.S.
New England
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Middle Atlantic
New Jersey
New York
Pennsylvania
East North Central
Illinois
Indiana
Michigan
Ohio
Wisconsin
West North Central
Iowa
Kansas
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
South Atlantic
Delaware
D.C.
Florida
Georgia
Maryland
North Carolina
South Carolina
Virginia
West Virginia
East South Central
Alabama
Kentucky
Mississippi
Tennessee
West South Central
Arkansas
Louisiana
Oklahoma
Texas
fountain
Arizona
Colorado
Idaho
Montana
Nevada
New Mexico
Utah
Wyoming
Dacific ' "
California
Oregon
Washington
Pacific Noncontiguous
Alaska
Hawaii
Total
-1.05
-0.99
-0.97
-1.04
XJ.88
-1.01
-0.97
-1.00
-1.02
-1.00
-1.01
-1.05
-1.16
-1.13
-1.18
-1.17
-1.18
-1.14
-1.12
-1.14
-1.11
-1.18
-1.09
-1.09
-1.10
-1.08
-O.98
-1.04
-1.09
-0.88
-1.01
-1.01
-1.01
-1.07
-O.96
-1.06
-1.06
-1.07
-1.09
-1.00
-1.05
-1.07
-1.05
-1.08
-1.03
-1.07
-0.99
-0.93
-0.95
-1.01
-1.08
-0.97
-1.01
-1.02
-1.18
-0.98
-0.97
-0.97
-1.03
-0.91
-1.05
-1.06
Res.
-0.69
-0.62
-O.62
-0.62
-0.62
•0.62
-0.62
-0.62
-0.62
-0.62
-0.62
-0.62
-0.93
-0.93
-0.93
-0.93
-0.93
-0.93
-0.93
-0.93
-0.93
-0.93
•0.93
-0.93
-0.93
-0.93
-0.62
-0.62
-0.62
-0.62
-0.62
-0.62
-0.62
-0.62
-0.62
•0.62
•0.62
-0.62
-0.62
-0.62
-0.62
-0.74
•0.74
-0.74
-0.74
-0.74
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.50
-0.22
-0.93
-0.50
Comm.
-1.05
-1.05
-1.05
-1.05
•1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.O5
-1.05
-1.05
-1.05
-1.O5
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
Ind.
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.4O
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
-1.40
Other
-1.05
-1.05
-1.05
-1.O5
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.O5
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.O5
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
-1.05
Source: RFF 84
                                    72

-------
                            EXHIBIT 6-5
COMMERCIAL GENERATION OF ELECTRICITY IN THE UNITED STATES, 1890
Nation and Region
Total United States
New England
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Middle Atlantic
New Jersey
New York
Pennsylvania
East North Central
Illinois
Indiana
Michigan
Ohio
Wisconsin
West North Central
Iowa
Kansas
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
South Atlantic
Delaware
D.C.
Florida
Georgia
Maryland
North Carolina
South Carolina
Virginia
West Virginia
East South Central
Alabama
Kentucky
Mississippi
Tennessee
West South Central
Arkansas
Louisiana
Oklahoma
Texas
Mountain
Arizona
Colorado
Idaho
Montana
Nevada
New Mexico
Utah
Wyoming
Pacific
California
Oregon
Washington
Pacific Noncontiguous
Alaska
Hawaii
Total
Generation
(gigawatt
hours)
2,808,151
94,092
32.156
9,064
36,479
10,810
592
4,993
330,827
36,489
128,655
165,683
485,835
126,977
97,738
89,059
126,510
45,551
218,360
29,048
33,869
41,550
59,01 1
21,631
26,824
6,427
533,816
7,100
361
123,624
97,565
31 ,497
79,845
69,260
47,200
77,364
246,866
76,262
73,807
22,924
73,903
374,332
37,053
58,168
45,063
234,047
247,355
62,289
31,313
8,618
25,719
19,286
28.491
32.260
39,378
264,179
114,526
49,172
100,479
12,489
4,493
7,996
Nuclear
Generation
(gigawatt
hours)
576,862
37,404
19,776
4,861
5,070
4,081
0
3,616
105,181
23,770
23,623
57,787
115,388
71,887
0
21,610
10,664
11,226
38,535
3,012
7,874
12,139
7,998
7,511
0
0
140,434
0
0
21,780
24,797
1,251
25,905
42,881
23,820
0
33,477
12,052
0
7,422
14,003
41,338
1 1 ,282
14,197
0
15,859
20,598
20,598
0
0
0
0
0
0
0
44.509
32,693
6,074
5,742
0
0
0
Nuclear
Generation
(%)
20.5
39.8
61.5
53.6
13.9
37.8
0.0
72.4
31.8
65.1
18.4
34.9
23.8
• 56.6
0.0
24.3
8.4
24.6
17.6
10.4
23.2
29.2
13.6
34.7
0.0
0.0
26.3
0.0
0.0
17.6
25.4
4.0
32.4
61.9
50.5
0.0
13.6
15.8
0.0
32.4
18.9
11.0
30.4
24.4
0.0
6.8
8.3
33.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
16.8
28.5
12.4
5.7
0.0
0.0
0.0
 Source: EEI 89
                                73

-------
                                     EXHIBIT 6-6
     SALES OF ELECTRICITY TO ULTIMATE CUSTOMERS BY SECTOR AND REGION, 1990
Nation and Region
Total United States
New England
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Middle Atlantic
New Jersey
New York
Pennsylvania
East North Central
Illinois
Indiana
Michigan
Ohio
Wisconsin
West North Central
Iowa
Kansas
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
South Atlantic
Delaware
D.C.
Florida
Georgia
Maryland
North Carolina
South Carolina
Virginia
West Virginia
East South Central
Alabama
Kentucky
Mississippi
Tennessee
West South Central
Arkansas
Louisiana
Oklahoma
Texas
Mountain
Arizona
Colorado
Idaho
Montana
Nevada
New Mexico
Utah
Wyoming
Pacific
California
Oregon
Washington
Pacific Noncontiguous
Alaska
Hawaii
Total
(gigawatt
hours)
2,712,555
104,273
27,187
11,529
45,442
8,980
6,419
4,716
306,932
62,857
129,324
114,751
459,589
111,577
73,982
82,367
142,465
49,198
188,894
29,437
27,149
47,167
53,925
17,868
7,014
6,334
533,046
8,284
9,848
143,535
80,440
49,534
89,924
55,652
72,696
23,132
230,294
59,926
61,097
32,127
77,145
371,111
27,365
63,826
42,504
237,415
160,735
41,470
30,795
18,003
13,125
16,352
13,821
15,402
11,769
345,117
21 1 ,093
42.977
91,046
12,564
4,254
8,311
Res.
(gigawatt
hours)
924,019
37,518
10,376
3,932
15,581
3,444
2,376
1,809
97,236
20,498
38,574
38,164
134,576
32,871
22,111
25,319
37,889
16,385
69,158
10,513
9,515
14,858
21,652
6,800
2,954
2,866
211,390
2,651
1,480
71,115
29,933
19,102
33,144
18,258
28,130
7,578
78,555
20,719
16,814
12,266
28,757
131,616
10,558
21,434
17,077
82,548
49,221
15,378
9.787
5,626
3,358
5,540
3,566
4,246
1,720
110,763
66.575
15,380
28,809
3,985
1,661
2,324
Comm.
(gigawatt
hours)
751,027
37.567
10,342
2,673
18,565
2,010
2,492
1,484
102,919
26,839
46,921
29,159
111,085
31,734
15,502
20,610
30,541
12,698
60,782
6,727
9,169
8,086
18,469
5,086
1,795
1,450
153,011
2,311
5,073
51,342
22,868
10,452
23,835
11,927
20,213
4,991
39,105
10,979
9,252
6,746
12,128
93,761
6,075
13,814
11,634
62,238
49,936
13,731
13,553
4,894
2.738
3,866
4,464
4,515
2,176
108,693
79,691
11.319
17,683
4,167
1,972
2,194
Ind.
(gigawatt
hours)
945,522
27,161
6,100
4.750
10,157
3,418
1,354
1,381
92,962
15,041
31,929
45,992
199,190
39,299
35,743
35,062
69,682
19,405
63,949
11,392
8,087
23,497
12,937
4,618
1,760
1,657
151,712
3,272
2,976
16,605
26,717
19,308
31,265
24,701
16,399
10,469
107,928
27,618
32,543
12.454
35.313
131,839
10,126
25,862
11,764
84,087
54,487
10,034
6,587
7,165
6,529
6,263
4,413
5,766
7,729
112.102
55,892
15,498
40,712
4,193
459
3,734
Other
(gigawatt
hours)
91.988
2,026
369
174
1,138
107
196
42
13,814
479
11,900
1,435
14.739
7,672
626
1,376
4,354
710
5,005
804
378
727
866
1,364
506
361
16,932
50
319
4,473
922
672
1,681
766
7,955
94
4,707
610
2,488
661
947
13,894
606
2,716
2,029
8,542
7,092
2,327
867
318
499
684
1,378
875
144
13,558
8,935
780
3,842
220
161
58
Note: In the United States, electric generation is significantly greater than sales since just over 8 percent of
   total electric energy generation is lost or unaccounted for(EEI 90).

Source: EEI 89
                                               74

-------
                                  EXHIBIT 6-7
                      AVERAGE REVENUE BY SECTOR AND REGION, 1990
Nation and Region
Total United States
New England
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Middle Atlantic
New Jersey
New York
Pennsylvania
East North Central
Illinois
Indiana
Michigan
Ohio
Wisconsin
West North Central
Iowa
Kansas
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
South Atlantic
Delaware
D.C.
Florida
Georgia
Maryland
North Carolina
South Carolina
Virginia
West Virginia
East South Central
Alabama
Kentucky
Mississippi
Tennessee
West South Central
Arkansas
Louisiana
Oklahoma
Texas
Mountain
Arizona
Colorado
Idaho
Montana
Nevada
New Mexico
Utah
Wyoming
Pacific
California
Oregon
Washington
Pacific Noncontiguous
Alaska
Hawaii
Total
(cents per
kilowatt hour)
6.60
8.80
9.20
7.60
8.80
9.10
9.10
8.30
8.70
9.10
9.40
7.70
6.40
7.50
5.40
7.10
5.80
5.40
6.00
5.90
6.60
5.30
6.50
5.60
5.70
6.10
6.40
6.50
5.90
7.00
6.60
6.30
6.40
5.60
6.00
4.70
5.30
5.60
4.50
6.10
5.30
5.80
6.70
6.00
5.50
5.80
5.90
7.80
5.90
3.80
4.00
5.40
7.10
5.50
4.20
6.80
8.80
4.20
3.40
9.20
9.50
9.00
Res.
(cents per
kilowatt hour)
7.80
9.80
10.00
9.30
9.70
10.30
9.50
9.30
10.30
10.40
11.40
9.20
8.10
9.90
6.90
7.80
8.00
6.60
7.20
7.80
7.80
6.80
7.40
6.20
6.30
6.90
7.50
8.40
6.10
7.80
7.50
7.20
7.80
7.10
7.20
5.90
6.10
6.60
5.70
6.90
5.70
7.20
8.10
7.40
6.60
7.20
7.30
9.00
7.00
4.90
5.40
5.70
8.90
7.10
6.00
7.80
10.00
4.70
4.40
10.20
10.10
10.30
Comm.
(cents per
kilowatt hour)
7.30
8.70
9.10
8.00
8.50
9.50
8.90
8.50
9.40
8.90
10.50
8.10
7.30
7.80
6.00
8.10
7.40
5.80
6.30
6.30
6.60
6.00
6.50
5.70
6.40
6.70
6.60
6.90
6.30
6.70
7.30
6.70
6.40
6.20
6.10
5.40
6.30
6.70
5.40
7.20
6.10
6.30
6.90
7.00
5.70
6.20
6.50
8.30
5.70
4.20
4.70
6.20
8.10
6.30
5.20
8.10
9.50
4.80
4.10
9.60
9.00
10.20
Ind.
(cents per
kilowatt hour)
4.70
7.40
4.60
6.00
7.90
7.50
8.30
8.60
6.10
7.40
5.80
6.00
4.60
5,40
4.10
5.90
4.00
4.00
4.40
4.00
4.90
4.10
4.90
4.20
4.80
4.70
4.60
4.50
5.20
5.10
4.80
5.10
4.80
4.20
4.30
3.60
4.30
4.30
3.60
4.60
4.70
4.10
5.10
4.20
3.60
4.00
4.10
5.60
4.50
2.60
2.90
4.70
5.00
3.80
3.50
4.90
7.30
3.20
2.40
7.60
7.90
7.60
Other
(cents per
kilowatt hour)
6.40
11.20
12.80
10.90
10.90
12.70
9.10
12.10
8.50
16.00
8.00
10.80
6.90
6.70
8.10
10.00
6.10
6.50
6.10
6.00
8.20
6.70
6.80
6.40
3.70
45.10
6.20
10.30
5.80
6.80
8.10
8.30
7.00
5.50
5.30
8.20
5.70
5.60
4.70
8.00
6.90
6.30
7.10
6.90
5.30
6.20
5.40
5.40
7.30
4.70
4.30
4.50
5.80
4.20
7.90
4.10
4.50
4.80
3.10
12.20
13.20
9.40
Source: EEI 89
                                    75

-------
impact  on  the  measurement  of consumer  surplus  is  negligible.
Therefore, implicit changes in consumer income are  ignored in this
analysis.

     A  second theoretical issue  that  is less easily  ignored is
whether  to approach  the  measurement  of consumer surplus  in a
partial or general equilibrium framework.  The partial equilibrium
framework  assumes that the  prices  of  goods and  services remain
constant even though  there is a second-order shift in the demand
for them.  General equilibrium analysis is more complex because the
effects  of the initial shift must  be  traced through  the entire
economy.  Only a partial equilibrium model is considered here owing
to the  small  size of  the fees compared with the  electric power
industry  and  the difficulties  in   tracing such  a widely  used
intermediate  input through the economy.

     A  third  theoretical  issue concerns the shape of  the demand
curve,  which  raises  the issue of the  size  of a  perturbation for
which the  empirical  measures of elasticity  can  be expected to
remain valid.  Two specifications of the demand curves that might
be derived are constant elasticity demand  curves and linear demand
curves.   Constant  elasticity  demand curves have the  same elasticity
at all  points  on the demand curve,  and thus,  as the  quantity
demanded gets smaller, the  downward slope  of these curves  gets
steeper.   On  the  other hand,  linear demand curves have constant
slope, but the elasticity of  demand  is different at each point on
the curve.    Regardless of the nature of the  curve,  it  must be
assumed that  the  empirically  estimated elasticities hold over the
area under consideration.   Given the small changes  in demand to be
caused  by  the   imposition   of  the  waste  disposal  fees,   the
assumptions on  the shape  of  the demand curves are not  likely to
cause inaccuracies in  the measurements of welfare loss.   Constant
elasticity demand curves are  used in this study.

     Perhaps  the  most  crucial assumption utilized in the economic
impact model is that of a horizontal  supply curve.   This assumption
is based on two considerations.   One,  the change in the quantity
demanded caused  by the imposition  of  waste disposal fees  is so
small that  it will not cause a significant  change  in  the average
costs of producing electricity.  Two, a fair amount of evidence in
the economic  literature  shows that  long-run average cost curves
have relatively large  flat sections on their  bottoms.  That is, the
marginal cost of  production is constant and  equal to  long-run
average cost  through a relatively wide  range.

     A  graphical  representation of  the economic impact  model is
provided in Exhibit 6-8.  S|S] is  the supply curve  and DjDj is the
demand curve  for  electricity.   An increase  of the  fee  charged to
electric utilities for the storage  of  high-level waste  causes an
upward  shift  in  the  horizontal supply curve to  S2S2.    PI  is the
initial price and Qj is the initial quantity.  The upward shift of


                                76

-------
    LJJ
    O
    o
CD
eg o
x ^
xo
    o
    o
    LJJ
    LU
    X
    h-
             0)
             o
                                                     CM
                                                     co
CVJ
CO
           CO
                                                                CO
                           CO


                           CO
                           O)
                           O


                           CM
                           O
                                                        CM  T-
                                                        CL  Q.
                                         77

-------
the supply curve from  S^Sj to S2S2 causes the price of electricity
to increase to P2 and the  quantity demanded to decrease to Q2«  The
points G, H, I, J,  K, L, M, and N will be used below in discussing
other concepts  related to the model,  including consumer surplus,
producer surplus, change  in total revenue, and deadweight welfare
loss.

     Consumer  surplus  is  defined  as  the total  expenditure that
consumers would have been willing and able to make in excess  of the
total expenditure they did in fact make to obtain a given  amount of
electricity.   Graphically the consumer  surplus  is the area under
the demand curve and above the price paid.  This area is undefined
given that we are assuming constant elasticity of demand.  That is,
for the consumer surplus to be well-defined,  point N would have to
be placed  where the demand curve crosses the  vertical axis, but
with constant elasticity  demand  curves,  the demand curve does not
intersect  the axes.   In  Exhibit  6-8  the magnitude  of  consumer
surplus  is  initially  approximated  by  area  LIN.    When  price
increases to P2, consumer  surplus becomes MKN.   Although consumer
surplus is poorly defined, the change in consumer  surplus is well-
defined as LIKM.  This area is composed  of  two other areas: JLMK
and UK.  Consumer surplus is decreased by this amount when supply
shifts upward from SjSj to S2S2.

     Producer  surplus  is  defined  as  the difference  between the
lowest total revenue for which the firm would have produced a given
quantity of the electricity and the total revenue the firm actually
received.  Graphically it is represented  by the area between the
price and the supply curve.  Because the supply curve is horizontal
there is no producer surplus  in  this model.  However,  there is a
change  of  revenues  that  just equals  the change in costs.   The
change in revenues  is because  of the decrease of revenue attributed
to reduced production (GHIJ) and  the increase of revenue because of
increased  price (JLMK).    The amount  JLMK  is  transferred from
consumers to producers.   However the amount IJK is just lost.  It
is referred to as the  deadweight welfare loss.

     Exhibit  6-9  summarizes  the economic  impacts  of the  three
configurations and the incremental  differences  between the first
configuration and the second and  between the  second and the third.
There  are  five  categories  of   impact  evaluators.    Costs  of
regulation are presented  in  millions of dollars  and  are  the same
values that were discussed above.  These are the initial costs of
the regulation that induce the other effects  shown in Exhibit 6-9.
Costs to nuclear power  generators are computed under the assumption
that they alone bear all  costs of  high-level waste  disposal.  The
incremental impact on  rates  charged to users of  nuclear  power of
going  from configuration 1  to  2  is   .00000758  cent/kWh  while
proceeding to  the  most  stringent option  adds another  .0000174
cent/kWh.   The impact on rates  is  smaller if  spread  over  all
electric power regardless of its  source.  For the first increment,


                               78

-------
                                             EXHIBIT 6-0
             SUMMARY OF ECONOMIC IMPACTS OF THREE CONFIGURATIONS AND TWO INCREMENTS
                    FOR HIGH-LEVEL WASTE FACILITIES FOR THE UNITED STATES
Impact Evaluators
Annual Cost of Regulation
($, mil.)
Nuclear(cents/kwh)
All Fuels(cents/kwh)
Sales
Before Regulation(gwh)
After Regulation(gwh)
Percent Change
Average Revenue
Before Regulation(cents/kwh)
After Regulation(cents/kwh)
Percent Change
Welfare Measurements
Deadweight loss($, mil.)
Change in Consumer Surplus($, mil.)
Change in Producer Revenue($, mil.)
Other
Number of Customers(OOO)
Cost of Regulation Per Customer($)
Configuration
1
(See Note 1.)

256.6
0.00004448
0.00000946

2712555
2712551
-0.000150

6.600000
6.600009
0.000143

-0.000193
-256.577
-1 2.2230

1 1 0561
2.32
2
(See Note 2.)

300.3
0.00005205
0.00001107

2712555
2712550
-0.0001 76

6.600000
6.60001 1
0.000168

-0.000264
-300.281
-14.3050

1 1 0561
2.72
3
(See Note 3.)

400.9
0.00006949
0.00001478

2712555
2712549
-0.000235

6.600000
6.60001 5
0.000224

-0.000470
-400.855
-19.0961

110561
3.63
Increment
2-1

43.7
0.00000758
0.00000161

2712555
271 2554
-0.000026

6.600000
6.600002
0.000024

-0.000006
-43.704
-2.0820

110561
0.40
3-2

100.6
0.00001743
0.00000371

2712555
271 2553
-0.000059

6.600000
6.600004
0.000056

-0.000030
-100.574
-4.7912

110561
0.91
3-1

144.3
0.00002501
0.00000532

2712555
2712553
-0.000084

6.600000
6.600005
0.000081

-O.000061
-144.278
-6.8732

110561
1.30
Note 1: Zero year canister, leach rate of 10 ~ -3, repository in tuff.
Note 2: 300 year canister, leach rate of 10 ~ -5, repository in tuff.
Note 3: 1000 year canister, leach rate of 10 " -6, repository in salt.
                                                79

-------
the electric rate would increase by .00000161 cent/kWh and for the
second by  .00000371  cent/kWh.

     The effects on sales and average revenues are also very small.
The most  stringent  option  would cost the  110  million consumers
(including   industrial,  residential,   commercial,  and   other
consumers)  each  only $3.63  per year  on  average.   The  annual
incremental cost per customer of advancing from the least stringent
to  the most  stringent  of  these  options  is about $1.31.   The
customer is unlikely to  notice costs of these magnitudes.

     Regarding  the  welfare  measures,  the  annual deadweight loss,
which measures  inefficiencies to the economy, is $470 for the most
stringent option.  The other welfare measures show that consumers
are assumed to  shoulder the entire burden.   The loss in consumer
surplus is just equal to  the cost of each configuration.  Because
producer profits  are unchanged,  the changes in producer revenues
just equal the  changes  in producer costs.

     The impacts  of  expenditures to implement 40 CFR Part 191 are
not uniform across the various regions of the United States.  Since
the costs are borne  only  by utilities that have nuclear capacity,
18  states  will not  be  directly affected  because they have  no
nuclear  capacity  (Exhibit  6-5).   The region  with the  highest
percentage of electric generation provided by nuclear power is New
England, with 39.8  percent.   The region of  the contiguous states
with the lowest percentage of  generation provided by nuclear power
is the mountain region with 8.3 percent.

     Exhibit  6-10 shows  how these  considerations  translate into
regulatory costs  by  state.  The case shown in Exhibit 6-10 is for
an increase from configuration 2 to configuration 3,  the total U.S.
cost of which  is shown  to  be  $43.7 million in Exhibit  6-9.   As
shown in Exhibit 6-10, the annual direct cost of the regulation in
states with  no  nuclear power is  zero.   There will be  no  direct
economic impact on  those states.   Annual  impacts to other states
will vary depending  on the proportion of electricity they produce
using nuclear power.  The highest cost, $1.79 million, is borne by
Illinois and the  lowest  for states with nuclear generation,  $312
thousand, by Maryland. When costs are spread over all consumers of
electricity generated by all fuels in a state, the highest cost in
cents per  kilowatt hour  (c/kWh)  is .00002.  This  rate increase
would apply to  Connecticut, Vermont, and South Carolina.
                               80

-------
                                 EXHIBIT 6-10
                       INCREMENTAL COST OF REGULATION BY REGION
Nation and Region
Total United States
New England
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Middle Atlantic
New Jersey
New York
Pennsylvania
East North Central
Illinois
Indiana
Michigan
Ohio
Wisconsin
West North Central
Iowa
Kansas
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
South Atlantic
Delaware
D.C.
Florida
Georgia
Maryland
North Carolina
South Carolina
Virginia
West Virginia
East South Central
Alabama
Kentucky
Mississippi
Tennessee
West South Central
Arkansas
Louisiana
Oklahoma
Texas
fountain
Arizona
Colorado
Idaho
Montana
Nevada
New Mexico
Utah
Wyoming
Pacific
California
Oregon
Washington
sacific Noncontiguous
Alaska
Hawaii
Cost of
Regulation
($)
144,277,701
9,355,033
4,946,132
1,215,774
1 ,268,047
1 ,020,690
0
904,390
26,306,591
5,945,063
5,908,297
14,452,981
28,859,442
17,979,501
0
5,404,830
2,667,150
2,807,710
9,637,905
753,325
1 ,969,349
3,036,059
2,000,362
1 ,878.560
0
0
35,123,642
0
0
5,447,348
6,201.924
312,885
6,479,043
10,724,874
5,957,568
0
8,372,860
3,014,300
0
1,856,300
3,502,260
10,338,957
2,821,716
3,550,781
0
3,966,460
5,151,721
5,151,721
0
0
0
0
0
0
0
11,132,049
8,176,775
1,519,155
1,436,119
0
0
0
Cost of
Regulation
Nuclear
(cents per kilowatt hour)
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
no nuclear
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
no nuclear
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
no nuclear
no nuclear
0.000025
no nuclear
no nuclear
0.000025
0.000025
0.000025
0.000025
0.000025
0.000025
no nuclear
0.000025
0.000025
no nuclear
0.000025
0.000025
0.000025
0.000025
0.000025
no nuclear
0.000025
0.000025
0.000025
no nuclear
no nuclear
no nuclear
no nuclear
no nuclear
no nuclear
no nuclear
0.000025
0.000025
0.000025
0.000025
no nuclear
no nuclear
no nuclear
Cost of
Regulation
all Fuels
(cents per kilowatt hour)
0.000005
0.000009
O.OOO018
0.000011
0.000003
0.000011
0.000000
0.000019
0.000009
0.000009
0.000005
O.OOOO13
O.OOOO06
0.000016
o.oooooo
0.000007
0.000002
0.000006
0.000005
0.000003
0.000007
0.000006
O.OOOO04
O.O00011
0.000000
0.000000
0.000007
o.oooooo
0.000000
0.000004
0.000008
0.000001
O.OOOO07
0.000019
0.000008
0.000000
0.000004
O.OOOO05
o.oooooo
O.O00006
0.000005
O.O00003
O.OOOO10
0.000006
0.000000
0.000002
0.000003
0.000012
o.oooooo
o.oooooo
0.000000
0.000000
o.oooooo
o.oooooo
o.oooooo
0.000003
0.000004
0.000004
0.000002
0.000000
0.000000
0.000000
Source: Exhibits 6-5, 6-6, 6-7, 6-8, 6-9.
                                         81

-------
             6.3.2  Impacts of Costs on Generators of
             Defense High-Level and  Transuranic Wastes


     The  evaluation of  the  economic impacts of Federal government
expenditures to  comply with  waste disposal  are  not developed
through  the use of a quantitative  model.   Instead a qualitative
discussion  is provided.  A  quantitative model is  not analytically
useful  because,  given  the  small   size  of  the  waste  disposal
expenditures relative to the Federal budget, determining the origin
of  the  funds,  their  impacts,  or their opportunity costs  is not
possible.

     Perhaps funds  would  be raised  by  increased taxation or
government  borrowing.    In  the absence of  a  direct tax  or  bond
issuance to  fund this specific program, as is the case with the fee
charged  to  utilities to cover their share  of  waste disposal, it
will be  impossible to  trace  the impact of increased  funding in
anything more than  the  most general terms.  Consequently,  it  will
also be impossible to identify the alternative uses to which these
funds would  have been put in the private sector.  Thus the  impact
as  well  as  the  opportunity  cost  of diverting  the funds to  public
use cannot be accurately quantified.  Conversely,  there  seems to be
no  reason to assume that the impacts will fall disproportionately
on  any particular group  in  society.

     Perhaps funds  would  be  raised  at  the expense  of other
government  programs.   There could  be a slight  change  in  funding
over  an  unspecified  group of  programs  or a  larger change in
specific programs.   It  might  be  argued  that DOE nuclear programs
would be the most likely victims of such cuts.  Again,  it will be
impossible  to  determine the exact  origin  of  funds  and  thus the
impacts or opportunity costs.

     Regardless of the origin  of  the funds, the most useful  way of
analyzing the  expenditures  are as  transfer payments in  that the
expenditures are generated through taxation or  some other means and
are spent on the waste disposal program.  This transfer of funds by
the Federal  government  is  likely to have  a  positive impact on
certain  regions and industries.   The  impacts are  the result of
fiscal injections  and  could be measured in costs for  particular
goods and  services,  which  are specified  in Chapter Two.   These
costs could  also be converted to associated impacts on employment
(which may   increase) and   income although  this  is  not  done in
Chapter Three.  The local area chosen for  the  waste disposal site
will most certainly  receive  increased infusions of Federal dollars.
There should be no disproportionate increase,  however,  in Federal
taxes paid by the affected  localities or industries involved.

     Beyond  the positive benefits accruing  to  certain  localities
and industries,  no discernible patterns of economic impacts should
occur.   Since expenditures will be derived from general revenues,

-------
no  negative impacts  on  particular  industry  segments  or  small
businesses should occur.
                               83

-------
                                     REFERENCES

BRWM 90     Rethinking High-Level Radioactive Waste Disposal. Board on Radioactive Waste
              Management, Commission on Geosciences, Environment, and Resources, National
              Research Council, 1990.

Corey 84      Corey, G.R., "The Comparative Costs of Nuclear and Fossil Fuelled Power Plants
              in An American Electricity  Utility," in The Economics of Nuclear Energy. Edited
              by Leonard G. Brookes and Homa Motamen, Chapman and Hall, New York, 1984.

DOE 87       U.S. Department of Energy, Office of Civilian Radioactive Waste Management,
              Analysis of the Total System Life Cycle. Cost for the Civilian Radioactive Waste
              Management Program. DOE/RW-0047, June 1987.

DOE 89       U.S. Department of Energy, Office of Civilian Radioactive Waste Management,
              Analysis of the Total System Life Cycle. Cost for the Civilian Radioactive Waste
              Management Program. DOE/RW-0236, May 1989.

DOE 89       U.S. Department of Energy, Office of Civilian Radioactive Waste Management,
              Transportation System Data Base. Reference Transportation Data for the Civilian
              Radioactive Waste Management Program. Washington D.C., December 1989.

DOE 90       U.S. Department of Energy.  Preliminary Estimates of the Total-System Cost for
              the Restructured Program:  An Addendum to the May 1989 Analysis of the Total-
              System Life Cycle Cost for the Civilian Radioactive Waste Management Program.
              DOE/RW-0295P, December 1990.

EEI 89        Edison Electric Institute.  Statistical Yearbook of the Electric  Utility Industry.
              1989

EIA 88a       Energy Information Administration.  Electric Power Annual.  1988.

EIA 89        Energy Information Administration.  Commercial Nuclear Power 1989: Prospects
              for the United States and  the World.  DOE/EIA-0438(89), September 1989.

EIA 90        Energy Information Administration.  Commercial Nuclear Power 1990: Prospects
              for the United States and  the World.  DOE/EIA-0438(90), September, 1990. "

EPA 85        Environmental Protection Agency, Office of Radiation Programs. "Final
              Regulatory Impact Analysis". 40 CFR Part 191—Environmental Standards for the
              Management and Disposal of Spent Nuclear Fuel. High-Level and Transuranic
              Radioactive Waste.  EPA 520/1-85-027, August 15, 1985.

EPA 92A      Environmental Protection Agency. Environmental Standards for the Management
              and  Disposal  of Spent Nuclear Fuel. High-Level and Transuranic Radioactive
              Wastes.  Draft preamble to the proposed rule.   August 14, 1992.

EPA 92B      Environmental Protection Agency. Draft Federal Register Notice for 40 CFR Part
              191.  August  14, 1992.

FEHR 92      Telephone conversation with Mr.  Don Fehringer of the Nuclear Regulatory
              Commission,  September 25,  1992.
                                           84

-------
GAO 89       United States Government Accounting Office. "DOE's Program to Prepare High-
              Level Radioactive Waste for Final Disposal."  GAO/RCED-90-46FS, November
              1989.

HUNT 1       Letter from Mr. Arlen Hunt, Acting Project Manager of the Waste Isolation Pilot
              Plant Project Office, Albuquerque Operations Office, Department of Energy, to
              Mr. Elliott Foutes, Environmental Protection Agency, March 15, 1990.

NWPA 83a    Nuclear Waste Policy Act of 1982. Public Law 97-425, January 7, 1983.

NWPA 83b    Nuclear Waste Policy Act of 1982. Amendments. Public Law 100-507. Senate
              Report No. 100-517 (Legislative History).

NWPA 87     Nuclear Waste Policy Amendments Act of 1987. Public Law 100-203, December
              22, 1987.

ORNL 91      Oak Ridge National Laboratory.  Integrated Data Base for 1991: Spent Fuel and
              Radioactive Waste Inventories. Projections  and Characteristics.  DOE/RW-0006,
              Rev.5, October 1991.

RFF 84       Bohi, Douglas R. and Mary Beth Zimmerman. Resources For The Future. "An
              Update on Econometric Studies of Energy Demand Behavior."  Ann. Rev. Energy
              1984.

Rogers 92     Rogers and Associates Engineering Corporation.  Unpublished report to EPA on
              the health effects and individual exposures associated with options for disposing of
              radioactive wastes,    September 1992.

SAIC 92       "The U.S. Department of Energy's (DOE) Position on Carbon-14 Releases  from a
              Geologic Repository."  Presented to EPA Science Advisory Board Subcommittee on
              Carbon-14, 1992.

SCA 92       Sanford Cohen and Associates, "Issues Associated with Gaseous  Releases of
              Radionuclides for a Repository in the Unsaturated Zone," July 20, 1992.

WAL 92       Telephone conversation with Mr. Henry Walter of the Department of Energy,
              September 15, 1992.
                                           85

-------

-------
Appendix A

-------

-------
                       EXHIBIT A-1
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
               WITH INTACT DISPOSAL IN TUFF
                   (millions of 1990 dollars)
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
Repository
Portion of
Development
and
Evaluation
97
145
162
200
228
179
164
175
160
264
286
252
210
190
176
177
171
158
133
121
115
115
113
107
107
106
101
57
23
22
21
21
21
21
26
33
45
57
68
68
83
114
148
171
137
Repository
Cost
0
0
0
0
0
0
0
0
0
0
0
0
0
7
13
27
40
27
23
17
23
21
120
203
244
243
208
136
146
154
164
197
242
242
240
240
242
238
237
243
240
243
237
238
235
Total
Cost for
70,000
MTHM
Repository
97
145
162
200
228
179
164
175
160
264
286
252
210
196
189
204
211
185
156
139
138
136
232
310
351
349
309
192
169
177
186
218
264
264
266
273
287
295
305
312
323
357
385
409
372
Total
Cost for
100.000
MTHM
Repository
138
207
231
286
326
256
235
250
229
376
409
360
300
280
270
292
301
264
223
198
197
194
332
442
501
499
441
275
241
252
265
312
377
377
380
390
410
421
436
445
461
510
550
585
532

-------
                    EXHIBIT A-1(CONTD)
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
               WITH INTACT DISPOSAL IN TUFF
                    (millions of 1990 dollars)




Year
46
47
48
49
SO
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
Total
Net Present Value
Repository
Portion of
Development
and
Evaluation
117
104
94
91
91
87
87
86
83
84
46
27
14
14
14
14
14
14
14
14
14
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
6,867
4,420



Repository
Cost
233
237
229
215
202
193
160
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
22
38
39
39
39
39
39
39
39
39
21
21
21
21
21
7,598
3,438
Total
Cost for
70,000
MTHM
Repository
349
341
324
306
293
281
247
108
104
105
68
49
35
35
35
35
35
35
35
35
35
30
30
30
30
30
30
30
30
30
30
30
46
47
47
47
47
47
47
47
47
29
29
29
29
29
14,465
7,858
Total
Cost for
100,000
MTHM
Repository
499
487
462
437
419
401
353
154
149
151
97
70
50
50
50
50
50
50
50
50
50
42
42
42
42
42
42
42
42
42
42
42
66
67
67
67
67
67
67
67
67
41
41
41
41
41
20,664
11,225
Source: DOE 90

-------
                       EXHIBIT A-2
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
               WITH INTACT DISPOSAL IN SALT
                   (millions of 1990 dollars)
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
Repository
Portion of
Development
and
Evaluation
117
146
162
200
255
301
333
319
332
338
370
319
131
109
106
126
119
115
117
144
119
78
76
75
74
94
208
259
266
318
302
194
86
69
60
78
73
71
Repository
Cost
0
0
0
0
0
0
0
0
0
0
0
0
12
52
52
196
386
486
489
403
168
174
162
169
195
276
278
277
278
270
271
268
269
275
274
247
244
241
Total
Cost for
70.000
MTHM
Repository
117
146
162
200
255
301
333
319
332
338
370
319
143
162
159
321
505
601
607
547
287
251
238
244
268
370
486
536
544
588
574
462
355
344
333
325
317
312
Total
Cost for
100,000
MTHM
Repository
167
209
232
286
364
429
475
456
475
483
528
456
204
231
227
459
721
859
867
781
410
359
339
348
383
529
695
766
778
840
819
660
507
492
476
464
452
446

-------
                 EXHIBIT A-2(CONTD)
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
              WITH INTACT DISPOSAL IN SALT
                  (millions of 1990 dollars)




Year
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
Total
Net Present Value
Repository
Portion of
Development
and
Evaluation
70
70
50
13
13
13
13
13
13
13
13
13
13
13
13
13
13
8
8
8
8
14
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
7.188
5,057



Repository
Cost
241
244
244
227
226
213
213
169
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
50
80
80
80
80
30
9.235
4,922
Total
Cost for
70,000
MTHM
Repository
311
314
294
240
239
226
226
181
39
39
39
39
39
39
39
39
39
34
34
34
34
41
34
34
34
34
34
34
34
34
34
34
58
88
88
88
88
38
16,423
9,978
Total
Cost for
100.000
MTHM
Repository
445
448
419
342
341
322
322
259
56
56
56
56
56
56
56
56
56
49
49
49
49
58
49
49
49
49
49
49
49
49
49
49
82
126
126
126
126
54
23,461
14,254
Source: DOE 87

-------
                       EXHIBIT A-3
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
                WITH INTACT DISPOSAL IN BASALT
                   (millions of 1990 dollars)
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
Repository
Portion of
Development
and
Evaluation
117
146
162
200
255
301
333
319
332
338
370
319
131
109
106
126
119
115
117
144
119
78
76
75
74
94
208
259
266
318
302
194
86
69
60
78
73
71
70
70
50
13
13
Repository
Cost
0
0
0
0
0
0
0
0
0
0
0
0
9
84
84
365
656
818
828
694
142
141
146
189
249
352
352
352
352
351
353
353
355
355
345
311
305
302
302
299
299
291
291
Total
Cost for
70.000
MTHM
Repository
117
146
162
200
255
301
333
319
332
338
370
319
141
193
190
490
775
933
946
838
261
219
221
263
323
446
560
611
618
668
655
547
441
424
404
389
378
373
372
370
350
304
304
Total
Cost for
100,000
MTHM
Repository
167
209
232
286
364
429
475
456
475
483
528
456
201
276
272
701
1107
1333
1351
1197
373
312
316
376
461
637
800
873
883
955
936
781
630
606
578
555
541
533
531
528
499
434
434

-------
                  EXHIBIT A-3(CONTD)
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
               WITH INTACT DISPOSAL IN BASALT
                  (millions of 1990 dollars)




Year
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
Total
Net Present Value
Repository
Portion of
Development
and
Evaluation
13
13
13
13
13
13
13
13
13
13
13
13
8
8
8
8
14
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
7,263
5.071



Repository
Cost
274
246
167
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
23
40
40
40
40
40
40
40
40
40
40
40
33
33
33
33
33
12.171
6.638
Total
Cost for
70.000
MTHM
Repository
286
258
179
36
36
36
36
36
36
36
36
36
31
31
31
31
37
31
31
31
31
31
31
31
31
31
31
47
47
47
47
47
47
47
47
47
47
47
40
40
40
40
40
19.434
11.709
Total
Cost for
100.000
MTHM
Repository
409
369
256
51
51
51
51
51
51
51
51
51
44
44
44
44
53
44
44
44
44
44
44
44
44
44
44
67
67
67
67
67
67
67
67
67
67
67
57
57
57
57
57
27.763
16.727
Source: DOE 87

-------
                      EXHIBIT A-4
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
             WITH INTACT DISPOSAL IN GRANITE
                    (millions of 1990 dollars)
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Repository
Portion of
Development
and
Evaluation
225
337
376
465
530
416
382
406
373
613
666
587
488
442
410
412
398
367
310
283
268
267
262
248
248
246
236
202
160
158
85
38
38
38
38
38
38
38
38
38
Repository
Cost
0
0
0
0
0
0
0
0
0
0
0
0
0
41
160
160
84
98
98
340
505
563
728
786
645
552
471
655
657
651
651
657
624
536
286
76
68
68
53
53
Total
Cost for
100,000
MTHM
Repository
321
481
537
664
758
595
546
581
532
876
952
838
697
673
746
749
652
622
540
744
888
945
1102
1140
999
902
808
944
885
876
772
712
678
590
340
131
123
123
107
107

-------
                    EXHIBIT A-4(CONTD)
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
             WITH INTACT DISPOSAL IN GRANITE
                    (millions of 1990 dollars)




Year
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
Total
Net Present Value
Repository
Portion of
Development
and
Evaluation
38
38
38
38
38
38
38
38
38
38
38
38
38
35
35
35
35
30
30
30
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
12.296
8,905



Repository
Cost
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
92
151
151
121
121
61
12.813
6,783
Total
Cost for
100.000
MTHM
Repository
107
107
107
107
107
107
107
107
107
107
107
107
107
102
102
102
102
96
96
96
78
78
78
78
78
78
78
78
78
78
78
78
78
78
78
117
175
175
146
146
85
30,379
19,504
     Source: DOE 90

-------
                      EXHIBIT A-4
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
             WITH INTACT DISPOSAL IN GRANITE
                    (millions of 1990 dollars)
Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Repository
Portion of
Development
and
Evaluation
225
337
376
465
530
416
382
406
373
613
666
587
488
442
410
412
398
367
310
283
268
267
262
248
248
246
236
202
160
158
85
38
38
38
38
38
38
38
38
38
Repository
Cost
0
0
0
0
0
0
0
0
0
0
0
0
0
41
160
160
84
98
98
340
505
563
728
786
645
552
471
655
657
651
651
657
624
536
286
76
68
68
53
53
Total
Cost for
100.000
MTHM
Repository
321
481
537
664
758
595
546
581
532
876
952
838
697
673
746
749
652
622
540
744
888
945
1102
1140
999
902
808
944
885
876
772
712
678
590
340
131
123
123
107
107

-------
                    EXHIBIT A-4(CONTD)
ANNUAL TOTAL-SYSTEM COSTS FOR THE SINGLE-REPOSITORY SYSTEM
             WITH INTACT DISPOSAL IN GRANITE
                    (millions of 1990 dollars)




Year
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
Total
Net Present Value
Repository
Portion of
Development
and
Evaluation
38
38
38
38
38
38
38
38
38
38
38
38
38
35
35
35
35
30
30
30
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
12,296
8.905



Repository
Cost
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
53
92
151
151
121
121
61
12,813
6.783
Total
Cost for
100.000
MTHM
Repository
107
107
107
107
107
107
107
107
107
107
107
107
107
102
102
102
102
96
96
96
78
78
78
78
78
78
78
78
78
78
78
78
78
78
78
117
175
175
146
146
85
30,379
19.504
     Source: DOE 90

-------
                       EXHIBIT A-5
     LIFE CYCLE COSTS FOR TRANSURANIC WASTES




Year
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
Total
Net Present Value

Cost for a
5.6 MTHM
Repository
(1988 dollars)
6.700
11,547
29.431
31.461
24.986
16,928
38,845
110,296
121,000
67.945
13.773
35,566
115,302
127,424
106,504
1 1 1 .460
107,461
101,369
95,188
89.981
98.333
98,801
98,801
98.801
98.801
98.801
98.801
98.801
98.801
98,801
98,801
98,801
98,608
98.124
97.641
97.157
96,481
84,590
76,566
64,868
65.694
60.641
53.566
42,449


Cost for a
100.000
MTHM
Repository
(1988 dollars)
119,643
206.196
525,554
561.804
446,179
302,286
693,661
1.969,571
2,160,714
1.213,304
245,946
635.107
2.058,964
2.275.429
1,901,857
1.990.357
1.918,946
1,810,161
1 .699.786
1 ,606,804
1,755,946
1 ,764.304
1,764,304
1 .764,304
1 .764,304
1 .764,304
1,764,304
1,764,304
1,764,304
1,764,304
1,764.304
1.764.304
1 .760,857
1,752,214
1 ,743,589
1,734,946
1 .722,875
1,510,536
1,367,250
1,158,357
1,173,107
1.082.875
956,536
758,018


Cost for a
100,000
MTHM
Repository
(1990 dollars)
130,007
224,058
571 .078
610,468
484.827
328.470
753.747
2.140,179
2.347,879
1.318,402
267.251
690,121
2,237.315
2,472,530
2,066,599
2,162,765
2,085,169
1 ,966,960
1 ,847,024
1 .745,988
1 ,908,050
1.917,131
1,917,131
1,917.131
1.917.131
1.917,131
1,917,131
1,917.131
1,917,131
1.917,131
1,917,131
1.917.131
1,913.386
1.903,994
1.894,622
1,885,231
1,872.113
1,641,381
1,485,684
1 ,258,696
1,274.724
1,176,676
1 ,039.393
823,679
67.616.901
42.759.323
Source: Rogers92 for cost for 5.6 MTHM Repository in 1988 dollars.

-------