United states
Environmental Protection
Agency
            UTticeof
            Radiation Program*
            Washington DC 20460
                                   EPA 520/1-82-024
                                   December 1982
            Radiation
SEPA
Draft
Regulatory
Impact Analysis
for40CFR 191:

Environmental Standards
for Management and
Disposal of Spent  Nuclear
Fuel, High-level and  '
Transuranic Radioactive Wastes

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                                    EPA 520/1-82-024
                DRAFT




      REGULATORY  IMPACT  ANALYSIS
           40 CFR Part 191
       ENVIRONMENTAL STANDARDS




                 FOR




       MANAGEMENT AND DISPOSAL




                 OF




 SPENT NUCLEAR FUEL,  HIGH-LEVEL AND




    TRANSURANIC RADIOACTIVE  WASTES
            DECEMBER 1982
U. S. ENVIRONMENTAL PROTECTION AGENCY




     Office  of Radiation  Programs

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                                 CONTENTS

                                                                   Page

Chapter 1:  Introduction and Summary                                  1

Chapter 2:  Regulatory Goals                                         11

Chapter 3:  Status of National Program                               13

Chapter 4:  Benefits of Proposed Action                              17

Chapter 5:  Costs of Waste Disposal                                  21

     5.1  Storage                                                    23
     5.2  Transportation                                             23
     5.3  Encapsulation (Canister)                                   24
     5.4  Waste Form                                                 26
     5.5  Repository Construction and Operation                      29
     5.6  Research and Development                                   29
     5.7  Government Overhead and Decommissioning                    31

Chapter 6:  Different Levels of Protection                           33

     6.1  Long-Term Performance Assessments                          33
     6.2  Benefits of Different Levels of Protection                 38
     6.3  Engineering Control Costs and the Level of Protection      42
     6.4  Site Selection and the Level of Protection                 47
     6.5  Economic Impacts of Different Levels of Protection         52
     6.6  Basis for Selecting the Level of Protection                55

Chapter 7:  Effects of Assurance Requirements                        61

Appendix:  The Proposed Standards                                    67

References                                                           83

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                                  TABLES

                                                                   Page
5-1  Total Costs of Waste Management                                 22

5-2  Performance Categories and Assumed Costs for Waste Canisters    25

5-3  Performance Categories and Assumed Costs for Waste Forms        27

5-4  Cost Information on Waste Forms                                 28

5-5  Repository Construction Costs                                   30

6-1  Engineering Controls Associated with Different
         Levels of Protection                                        43

6-2  Relationship of Economic Impacts to Increases in
         Waste Management and Disposal Costs                         54
                                    LI

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                                  FIGURES

                                                                   Page

1-1  Variations in Waste Management Cost vs. Level of Protection
         (Engineering Barrier Costs Only)                             5

1-2  Variations in Waste Management Cost vs. Level of Protection
         (Engineering Barrier Costs and Site Selection Costs)         6

6-1  The Level of Protection                                         36

6-2  Relative Incidence of Residual Risk for a Level of Protection
         at 1,000 Health Effects over 10,000 Years                   39

6-3  Relative Incidence of Increase in Residual Risk Between Levels
         of Protection of 1,000 and 10,000 Health Effects            41

6-4  Variations in Waste Management Cost vs. Level of Protection
         Salt Repository: Engineering Barrier Costs Only             44

6-5  Variations in Waste Management Cost vs. Level of Protection
         Granite Repository: Engineering Barrier Costs Only          45

6-6  Variations in Waste Management Cost vs. Level of Protection
         Basalt Repository: Engineering Barrier Costs Only           46

6-7  Variations in Waste Management Cost vs. Level of Protection
         Salt Repository: Engineering Barrier Costs and
         Site Selection Costs                                        49

6-8  Variations in Waste Management Cost vs. Level of Protection
         Granite Repository: Engineering Barrier Costs and
         Site Selection Costs                                        50

6-9  Variations in Waste Management Cost vs. Level of Protection
         Basalt Repository: Engineering Barrier Costs and
         Site Selection Costs                                        51
                                    111

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                                 Chapter 1




                         INTRODUCTION AND SUMMARY









     This Draft Regulatory Impact Analysis (RIA) addresses the requirements




of Section 2 of Executive Order 12291.  It reviews the projected costs




associated with management and disposal of high-level radioactive waste,




and it evaluates the potential effects of our environmental standards for




disposal of these wastes (40 CFR Part 191)—as proposed for public review




and comment on December 29, 1982 (47 FR 58196).  The proposed standards




are presented in the Appendix of this report, and they are explained in




detail in the Draft Environmental Impact Statement (EIS) prepared for this




action (EPA 82).









     The situation regarding the disposal of high-level waste is unusual




from a regulatory standpoint.  In most cases, a regulation concerns an




ongoing activity.  Any modifications that the regulation causes in the




activity may be considered to be costs that should be outweighed by the




regulatory benefits.  For high-level waste disposal, howeveri the




appropriate regulations must be developed well before the activity to be




regulated can even begin.  Thus, the typical perspectives about balancing




regulatory costs and benefits do not apply.










     To investigate the potential impacts of this proposed action, we




evaluated how the costs of high-level waste management and disposal might




change due to alternative stringency levels for the numerical containment

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requirements of our standards—or due to alterations in our qualitative




assurance requirements.  Because there is no "baseline" program  to




consider, we could not quantify the costs and benefits of our proposed




action compared to the consequences of no regulation.









     The most important benefit of our action should be the assurance that




these wastes will be disposed of with adequate protection of public health




and the environment.  This assurance, in turn, should allow the  Federal




program to proceed expeditiously to develop acceptable disposal  methods  at




appropriate sites.  It may be argued that a further benefit would be the




resolution of a key issue that might lead to expanded commercial use of




nuclear power.  This would be a benefit if nuclear power has clear




advantages, economic and otherwise, compared to alternative methods of




generating electricity; however, we have not analyzed this issue.









     The containment requirements in our environmental standards consist




of limits on potential releases of radioactivity from a disposal system;




these limits are to be used as overall design requirements.  The




containment requirements are stated in terms of projected releases for




10,000 years after disposal of the wastes.  To judge the risks associated




with these release limits, we have used generalized environmental pathway




models to assess the potential health impacts of the releases that would




be allowed by our standards (SMJ 82).  However, calculations of  these




"residual risks" are clearly not reliable as absolute values, since




projections of population distributions, ways of life, and human behavior

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over 10,000 years cannot be meaningful.  Rather,  these calculations  are




valuable only for understanding the relative "residual risks"  from




different sources of radiation exposure  (such as  risks from different




disposal system designs, or risks from natural ore bodies).









     For the containment requirements we have proposed,  the residual risks




projected by these models would be less  than 1,000 premature deaths  from




cancer over the 10,000 year period, an average of one premature death




every ten years.  To judge the effects on disposal costs of changing this




level of protection, we also compared containment requirements




corresponding to residual risk values of: 100, 1000, 5000, and 10,000




premature deaths over the 10,000 year period.  We chose  this range of




residual risks because it appears to represent the range of performance




that may be expected of mined geologic repositories.









     To do this analysis, we evaluated the long-term performance of




generic models of geologic repositories  in three  different geologic media:




bedded salt, granite, and basalt.  We did the analysis in two  steps:









     First, we used our performance projections (SMC 82) to assess the




quality of the engineering controls that would be needed in each of  the




three model repositories to meet each of the four different levels of




protection.  In doing so, we encountered the problem that development of




specific engineered barriers (e.g., waste forms and canisters) has not yet




progressed  far enough to clearly associate the costs of manufacturing

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these engineered barriers with their performance levels.   Thus, we  had  to




make some rather speculative judgements to associate disposal  costs with




alternative stringency levels.  The results of this analysis are  displayed




in Figure 1-1.









     Second, we tried to allow for the possible effect  of  alternative




stringency levels on site selection.  This is particularly relevant




because our analyses indicate that the most important part of  the




protection offered by a mined geologic repository comes from the




hydrological and geochemical characteristics of the site itself.




The costs of using a "good" site rather than a "bad" site  (within the same




type of geologic media) do not involve differences in construction  cost.




Instead, they involve the difficulty of finding a site  that is "good




enough."  Since there are so few data on site characterization, we  have  no




good basis for judging how many sites might have to be  studied to meet




different levels of protection.  However, we did made some  assumptions




about how site selection costs might increase in order  to  meet more




stringent standards.  We then combined these assumptions with  our




evaluations of the variations in engineered barrier costs  to arrive at  our




second set of disposal cost estimates.  The results from this  analysis  are




shown in Figure 1-2.









     The results of these assessments of disposal costs and alternative




stringency levels indicate that the costs are not very  sensitive  to




different levels of protection, particularly for the geologic  media

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S
600






500






400-






300






200






100






  0
         FIGURE 1-1:   VARIATIONS IN WASTE MANAGEMENT COST vs. LEVEL OF  PROTECTION



                                (Engineering Barrier Costs  Only)
          SALT REPOSITORY
                                    600
                                    400-
                                    200
                                     GRANITE REPOSITORY
                                                                   6001
                                                                   400
                                                                   200
BASALT REPOSITORY
             100   1000    5000  10000         100    1000   5000   10000           100   1000    5000   10000




                  ------- level of protection (health effects over 10,000 years) -------

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FIGURE  1-2:   VARIATIONS IN WASTE  MANAGEMENT  COST vs. LEVEL OF PROTECTION



           (Engineering Barrier  Costs and Site  Selection  Costs)
SALT REPOSITORY
GRANITE  REPOSITORY
BASALT  REPOSITORY
600-
500-
400-
300-
200-
100-
n •














600-
400-
200-
n-


















600-
400-
200-
0

















 100    1000   5000   10000          100   1000    5000  10000          100   1000   5000   10000




       	 level of protection (health effects over 10,000 years) 	

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(bedded salt and granite) that are better at reducing  long-term  risks.




Even when we hypothesize increased site selection costs due  to more




stringent levels, the difference in costs for different levels are much




smaller than the overall uncertainties in waste management costs.  For




example, consider the increased costs of complying with the  release  limits




we have proposed, rather than release limits ten times less  stringent.




The potential increase ranges from zero to 50 million  (1981) dollars per




year.  For comparison, the total costs of high-level waste management and




disposal (independent of our action) have been estimated as  between




700 million and  almost 1.5 billion (1981) dollars per year.  Electrical




utility revenues were about 100 billion dollars in 1980.









     These analyses—while indicating that disposal costs appear to be




relatively insensitive to differences in the level of protection—do not




provide a way to determine the acceptability of the residual risks from a




societal perspective, nor do they indicate a level of protection that is




preferable from  a balancing of costs and benefits.  One possible approach




to balancing costs and benefits would be to judge the cost per life saved




by different levels of protection, perhaps taking into account some method




of discounting costs and benefits.  However, our calculations of residual




risks are not reliable as absolute values.  Thus, we have no meaningful




way to calculate an absolute value of the cost per life saved by different




levels of protection.

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     In the absence of the ability to make meaningful cost  and  benefit




comparisons, we have used other tests of economic feasibility and




acceptability of risk to judge the appropriateness of the  level of




protection we have proposed.  As discussed above, setting  the release




limits at the level we chose—as opposed to a level ten  times less  or ten




times more stringent—appears to cause only very minor effects  on the




costs of high-level waste disposal.  To judge the acceptability of  the




remaining long-term risk, we considered the risks that would otherwise  be





caused if the uranium ore used to produce the wastes had not been mined.




The magnitude of the risks from these unmined ore bodies is very uncertain




due, in part, to the wide variety of settings in which uranium  ore  is




found—many of which are closer to the surface than a geologic  repository




would be.  Using the same generalized environmental pathway models  that




were used to assess the risks from our models of geologic repositories,




the risks from a comparable amount of unmined uranium ore are estimated to




range from a few hundred to more than one million health effects over




10,000 years (WI 80).  The lower end of this range is roughly equal to  the




residual risk associated with our proposed release limits.  Thus, the




upper limit of the risk that our standards would allow from the disposal




of high-level wastes appears to pose a threat very close to the minimal




risk posed by nature, had the uranium ore never been mined and  the




high-level wastes never been generated.










     The assurance requirements of our proposed standards provide seven




qualitative criteria which should provide confidence that our containment




requirements will be met in spite of the uncertainties inherent  in

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disposing of wastes that must be isolated for a very  long  time.   The

specific provisions of these assurance requirements are described in  the

Appendix to this report.  Only three of the criteria  have  a  significant

potential to increase the costs of high-level waste disposal.  These  are:

     Criterion 2,  which calls for disposal systems to keep  radioactive
     releases as small as reasonably achievable;

     Criterion 3,  which calls for disposal systems to use multiple
     barriers, both engineered and natural; and

     Criterion 4,  which restricts reliance on active institutional
     controls to a reasonable period after disposal (e.g., a few
     hundred years).

     Each of these three criteria might have the effect of requiring

better engineered barriers  than would otherwise be needed  to meet our

containment requirements.   This would be particularly true for a

repository sited in a relatively good geologic media  (such as our generic

models for bedded salt or granite).  However, even if no engineered

barriers at all appeared to be needed for long-term protection after

disposal, fairly protective canisters and waste forms would  be needed for

other phases of waste management, such as transportation to  and

emplacement in a repository.  Therefore, we believe that these criteria

would require—at most—only moderate improvements in waste  form

performance,  and we judged  that the impact that these improvements might

have on disposal costs should be less than 10 million (1981)  dollars  per

year.  Since this impact concerns improvements to engineered barriers, the

potential cost increase would be duplicative of any engineered barrier

impacts caused by our containment requirements.  Thus, the potential  cost

effects of our containment and assurance requirements should generally not

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be added together.  (For some unusual possibilities, adding  the  effects  of




the two sets of requirements might be appropriate, but  these possibilities




would tend to involve relatively small impacts.)









     The analyses described in this report are intended  to provide  a




realistic estimate of the costs of the various regulatory alternatives we




considered.  In an earlier report (LE 80). we took a different approach—




one that ultimately did not prove useful for evaluating  the  regulatory




impacts of this action.  In that effort, we were trying  to judge how  large




the cost impacts of our action might be if our standards required major




alternations in plans for disposal of high-level waste;  and  we made




several very conservative assumptions to estimate the upper  bound of  such




additional costs.  (For example, we assumed a "baseline" program of




disposal in salt, the cheapest geologic medium, and then assumed that our




action might require use of the most expensive medium -  even though our




performance assessments indicate exactly the opposite.  Also, there is no




longer a justification to consider salt as the "baseline" program.)




Accordingly, in the earlier report, we discussed possible cost impacts of




our action that are much larger than those described here.   Although  we




have retained some of the analytical framework we assembled  before, we do




not believe that the earlier report's quantitative findings  are valid for




the type of analysis called for by Executive Order 12291.
                                    10

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                                 Chapter 2

                             REGULATORY GOALS



     The decision to develop these proposed  standards was  an  administrative

action taken by EPA and was not mandated by  law.  We were  directed  to

prepare standards as part of President Ford's Nuclear Waste Management  Plan

on October 27, 1976.  President Carter established  an Interagency Review

Group  (IRG) on Waste Management in March  1978 to review  existing policies

where  necessary.  The IRG recommended that EPA set  standards  for nuclear

waste  management and disposal  activities and accelerate  its programs  to do

so.  In making its recommendations,  the IRG  noted the following about the

public comment on its draft report (IRG 79):

         "Comment from both the industrial sector and the
     environmental community urged the acceleration of EPA standards
     particularly to instill confidence that proper protection of
     the public's health and safety  is being provided.   They
     expressed the concern that early standards are essential to
     permit the waste management program to  proceed expeditiously."


     President Carter approved the IRG recommendation as part of his

Program on Radioactive Waste Management announced on February 12, 1980.

The Nuclear Regulatory Commission (NRC) has best described the expected

goal of our standards (NRC 80):

         "...(EPA's) standards represent a broad social  consensus
     concerning the amount of radioactive materials and  levels of
     radioactivity in the general environment that are compatible
     with protection of the health and safety of the public."
                                    11

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     Thus, we have two interrelated regulatory goals  in  taking this action:










     (1) to provide quantitative containment requirements  that will limit




long-term radioactive releases from high-level waste  disposal  systems' to




levels which are reasonably achievable, very small, and  adequate  to




protect the health and safety of the public.









     (2) to provide qualitative assurance requirements that will




compensate for the uncertainties inherent in trying to design  systems  that




must meet these containment requirements for a very long time.










     We believe that accomplishing these two goals will help to instill




the confidence needed "to permit the waste management program  to proceed




expeditiously" in order to resolve a long-standing issue.
                                    12

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                                 Chapter 3

                        STATUS OF NATIONAL PROGRAM



     In 1976, also as part of President Ford's Nuclear Waste Management

Plan, the Energy Research and Development Administration  (ERDA) began  the

National Waste Terminal Storage  (NWTS)  program to develop  technology and

provide facilities for the permanant disposal of high-level waste.  As

part of this expanded initiative, the Department of Energy  (DOE)—

successor to ERDA—prepared a generic environmental impact  statement

(GEIS) concerning selection of a strategy for disposal of  commercially

generated high-level waste.  This GEIS, which evaluated a variety of

different disposal methods, was  issued  in draft form for public review and

comment and was published as a final EIS in October 1980.



     On May 14, 1981, DOE issued a Record of Decision (46 FR 26677) based

upon the information developed through  its GEIS process.  This decision

was:

     "(1)  to adopt a strategy to develop mined geologic repositories
     for disposal of commercially-generated high-level and
     transuranic wastes (while continuing to examine subseabed and
     very  deep hole disposal as potential back up technologies) and
     (2) to conduct a research and development program to develop
     repositories and the necessary technology to ensure the safe
     long-term containment and isolation of these wastes."

This  decision to emphasize mined repositories was based on DOE's:

     ".  .  .  commitment to the early and successful solution of the
     Nation's nuclear waste disposal problem so that the viability
     of nuclear energy as a future energy source for America can be
     maintained."
                                    13

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DOE also expects this decision to:

     "... save money by focusing Federal funds on the  further
     development of the most advanced disposal technique."
     Now focused on disposal in mined geologic respositories,  the  overall

goal of the DOE program is to provide the United States with its first

licensed, fully operational repository.  On January 7, 1983, President

Reagan signed the Nuclear Waste Policy Act of 1982 (Public Law 97-425)—

which was passsed by Congress, after lengthy consideration,  in

December 1982.  This Act establishes a series of milestones  for the

national program, oriented towards a January 1, 1989 objective for a

Nuclear Regulatory Commission decision on DOE's first application  for a

construction authorization for a mined geologic repository.



     The NRG is responsible for licensing and regulating the geologic

repositories that will be built and operated by DOE, and,  in doing so,

NRC is responsible for implementing our environmental standards.

On July 8,  1981, NRC proposed the technical criteria it plans  to use  in

regulating  the disposal of high-level wastes in geologic repositories

(46 FR 35280).  When finalized, these requirements will become part of

10 CFR Part 60.  These technical criteria include several  specifications

for waste package and site characteristics.  The two criteria  that involve

factors considered in our regulatory impact analysis of 40 CFR 191 are  the

two that embody NRC's multiple engineered barrier approach to  repository

design: (1) the performance of the engineered system (waste  package and

underground facility) following permanant closure of a repository
                                    14

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is specified to require containment of the wastes within the waste package




for at least 1,000 years following closure, and (2) after the first




1,000 years, the annual release rate of any radionuclide from the




engineered system into the geologic setting is specified to be no more




than one part in 100,000 (10  ) at any time.  These two specifications,




which affect canister lifetime and waste form release rate, are the ones




that are most likely to have significant effects on disposal costs.
                                    15

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                                 Chapter 4




                        BENEFITS OF PROPOSED ACTION









     We believe that these proposed standards will provide adequate




long-term protection of public  health and the environment, and we expect




them to provide a high-degree of confidence  that this protection can  be




attained.   In  turn, this  assurance should allow the national high-level




waste management program  to  proceed with  the key steps needed to develop




and demonstrate a disposal system.  In  the context of the country's




current strategy to focus on mined geologic  repositories, these steps




involve identification, extensive examination, and comparison of potential




repository  sites.  To date,  this part of  the program has been substantially




delayed by  non-technical  problems, including a number of state laws which




restrict or prohibit disposal of high-level waste.









     While  we  can identify this qualitative contribution, we cannot




quantify the benefits of  our proposed standards compared to the




consequences of having no regulation.   We did not attempt to calculate how




much additional protection the  containment requirements provide, because




we cannot specify how these wastes would have been disposed of without our




action.   However,  there are  three qualitative benefits that the




containment requirements clearly provide.  First, they tell system




designers the most important objectives for environmental protection.  For




example, a  system designed to limit releases for 1,000 years could rely




primarily on engineered barriers, whereas a system designed to retain
                                    17

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wastes for 10,000 years also requires good geological and hydrological




characteristics at the site chosen.  Second, they require a  comprehensive





assessment of total system performance to assure that the containment




requirements would not be exceeded.  Finally, they can provide confidence




that good disposal systems can keep the risks to present and  future




generations very small.









     The problem with quantifying the benefits of our qualitative




assurance requirements is quite different than that associated with




assessing the benefits of the containment requirements—and  it would not




be solved even by specification of a "baseline" program.  These seven




criteria are intended to guard against a variety of uncertainties that are




inherent in the disposal of these long-lived wastes.  Quantifying their




benefits is not feasible, since we cannot calculate the risks we might be




preventing due to things we may not be able to anticipate.  Two examples




illustrate this point:










     (1)  One of our assurance requirements calls for use of different,




multiple barriers to guard against releases due to unanticipated failure




of one or more barriers.  The amount of risk prevented depends upon how




(any how many) barriers fail, and our inability to be certain of this is




exactly why we established this requirement in the first place.
                                    18

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     (2)  Another of our assurance requirements states that the wastes




shall be recoverable for a reasonable period after disposal,  in case




future information indicates they should be handled in some other way.




But since we cannot specify what this future information might be, we




cannot quantify the benefits of keeping this option available.









     In spite of our inability to quantify these benefits, the necessary




confidence in achieving the long-term public health and environmental




protection required by our containment requirements is a substantial




benefit of our assurance requirements—the two sets of requirements are




essential complements to each other.  Neither the containment requirements




nor the assurance requirements, by themselves, can accomplish our




regulatory goals.
                                    19

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                                 Chapter 5




                          COSTS OF WASTE DISPOSAL









     There have been many studies of the costs of high-level waste




management and disposal.  However, there are still substantial




uncertainties because disposal  sites have not been selected, operational




facilities have not been built, and some of the technologies for engineered




barriers have not been  fully developed  and tested.  Table 5-1 shows  the




range of costs that we  considered in this analysis.  These estimates were




taken from three different sources (LE  80, ADL 79, and DOE 80) and were




generally chosen so as  to minimize, rather than maximize the range of




estimates shown for each cost  element.  Unless otherwise stated, all costs




are in 1981 dollars, and have  been calculated by using the following




inflation factors, which are based on the Department of Commerce Composite




Construction Cost Index (SA 81):  1.50 for converting 1977 to 1981 dollars;




1.34 for 1978 to 1981 dollars;  and 1.17 for 1979 to 1981 dollars.









     The following paragraphs  discuss the cost estimates for each item,




with particular attention to the  four elements which might be affected by




our disposal standards.  Where  recently available information is relevant




to these estimates, it  is also  included.  In all cases, we discuss the




costs in terms of dollars per  kilogram  of heavy metal (uranium or




plutonium) inserted as  fuel into  a commercial reactor ($/kg HM).  This is




a commonly used unit of cost for waste management and disposal, and  it




allows comparisons of the cost  of disposing of spent fuel or different
                                    21

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                               Table 5-1




            Total Costs of Waste Management  (1981  dollars)





cost element




STORAGE




TRANSPORTATION




ENCAPSULATION (Canister)




WASTE FORM




REPOSITORY CONSTRUCTION AND OPERATION




RESEARCH AND DEVELOPMENT




GOVERNMENT OVERHEAD




DECOMMISSIONING




                        TOTAL
90




17




11




12




66




11




 3




14
                                                                 230




                                                                 41




                                                                 30  *




                                                                 24  *




                                                                 131 *




                                                                 40  *




                                                                 10




                                                                 17
                                                           224 - 523
Cost elements which might be affected by proposed standards:
                                                                 HM
Assumptions about


Assumptions about



Assumptions about
construction

Assumed variation
development
alternative
canister costs:


waste form costs:



repository
costs :

of research and
costs with
stringency levels:
(health effects over 10,000 years)
"very good" =
"good"
"minimum" =
"very good" =
"good"
"fair"
"minimum" =
salt =
granite =
basalt =
10,000
5,000
1,000
100
20 - 30
14 - 23
11 - 20
18 - 24
16 - 22
14 - 20
12 - 18
66 - 73
109 -110
123 -131
11 - 20
14 - 24
17 - 30
22 - 40
                                  22

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forms of high-level waste from reprocessing plants.   When  used  to  describe




disposal after reprocessing, of course,  the unit  $/kg HM does not  mean




that the heavy metal itself is being disposed of—since the  purpose  of




reprocessing spent fuel is to recover and reuse the  unfissioned uranium




and plutonium.









5.1  Storage




     Our previous  study (LE 80) identified a wide range of cost estimates




for spent  fuel storage: from $15  to  $200 per kg HM in either 1977  or 1978




dollars.   The higher end  of this  range  corresponds to significant  use  of




away-from-reactor  (AFR) storage,  which  is more expensive than reactor-site




storage.   The $15/kg HM estimate  appears to be too low, with most  estimates




of reactor-site  storage clustering around $60 to  $80/kg HM in 1977 or  1978




dollars  (LE 80).   For  this analysis  we  chose a range of $60  to  $150/kg HM




(1977 dollars),  allowing  for some use of AFR storage,  and  adjusted the




estimate to $90-230/kg HM in 1981 dollars.









5.2  Transportation




     Two shipments are involved in a fuel cycle that includes reprocessing:




one from the spent fuel storage site to  the reprocessing plant  and another




from the reprocessing plant to the repository.  Arthur D.  Little,  Inc.




(ADL) estimated  the costs of these two  shipments  to  be $8-18/kg HM and




$3-$8/kg HM, respectively, with both estimates in 1977 dollars.  To  develop




the estimate in  Table 5-1, we added  the  costs for both shipments and




converted  to 1981 dollars, for a  cost range of $17-41/kg HM  (1981  dollars).
                                    23

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5.3  Encapsulation (Canister)




     The encapsulation cost element is the first of the four  that may  be




affected by our disposal standards.  Unlike the storage or  transportation




categories, the type of canister used to contain the wastes can affect  the




long-term performance of a repository.  Thus, we estimated  the costs of




using canisters of three different qualities.  These three  categories  are




described in Table 5-2.









     To develop these cost estimates, we first considered ADL's projections




for the costs of spent fuel canisters (ADL 79), but we substituted the




lower material costs that would be associated with the smaller canisters




used for reprocessed waste.  We then assumed that the material for




stainless steel canisters would cost about three times as much as carbon




steel, and that titanium would cost at least seven times as much as carbon




steel.  This resulted in facility, operating and maintenance costs of




$6-12/kg HM, and materials costs of $l/kg HM (carbon steel), $3/kg HM




(stainless steel), and $7-8/kg HM (titanium), with all of these figures in




1977 dollars.  Combining these and inflating to 1981 dollars resulted in




the cost estimates shown in Table 5-2.










     It must be noted that the association of canister performance with




canister material (and cost)  is based upon quite limited information




(ADL 79), and includes considerable engineering judgement.  However,




preliminary information from DOE design studies of long-lived canisters




indicate costs that are roughly comparable to those of Table 5-2 (VI 81).
                                    24

-------
                                 Table  5-2
       Performance Categories and Assumed Costs for Waste Canisters
"very good"   =    canister that would last several thousand years;
                   titanium or even KBS-style copper canisters would be
                   required.
                   Estimated engineering cost = $ 20-30/kg HM.

     (NOTE: NRC's proposed 10 CFR Part 60 would require a waste
     pacakage lifetime of at least 1000 years.)

"good"        =    canister that would last several hundred years; in hard
                   rock repositories, stainless steel canisters would
                   probably be adequate.
                   Estimated engineering cost = $ 14-23/kg HM

              =    canister that would last at least several decades to a
                   few hundred years in hard rock repositories—might only
                   last through operational lifetime for salt
                   repositories; carbon steel and overpack construction
                   assumed.
                   Estimated engineering cost = $ 11-20/kg HM.
                                    25

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5.4  Waste Form




     The physical and chemical properties of the  solidified  high-level





waste from reprocessing also affect the long-term performance  of  a




repository.  However, we are not aware of any published  studies which




relate the waste form behavior (in terms of resistance to  releasing




radioactivity) to the production costs of different waste  forms.   In this




respect, the costs for different waste forms are  more uncertain than the




costs for canisters.










     For this analysis, we postulated costs for different  quality




waste forms, as shown in Table 5-3.  The Arthur D. Little, Inc. study




(ADL 79), DOE's GEIS (DOE 80), and another recent study  (JA  81) conclude




that the costs of different waste forms do not vary substantially  from one




type to another, and the variation that is observed is generally  less than




the overall uncertainty in the cost of any specific waste  form.  However,




preliminary results from newer DOE studies indicate that waste form  costs




may increase substantially if relatively sophisticated processes are




needed to provide very high quality waste forms (WA 81).   In addition to




these qualitative observations, the quantitative cost information  shown in




Table 5-4 is available.










     Based on this information, and the observation that it  should




generally cost more to make better quality waste  forms, we made the  cost




and performance judgements shown in Table 5-3.  As before, the cost




estimates were converted to 1981 dollars.
                                    26

-------
                                 Table  5-3
         Performance Categories and Assumed Costs for Waste Forms
"very good"   =    10-10   parts per year (ppy) leach rate; may be
                   attainable if ongoing technology development programs
                   are successful.
                   Estimated engineering cost = $  18-24/kg HM.

     (NOTE: NRC's proposed 10 CFR Part 60 would require a waste form
     release rate no worse than lO"-* ppy.)

"good"        =    about 10   ppy leach rate; appears attainable by
                   glass technologies already developed.
                   Estimated engineering cost = $  16-22/kg HM.

"fair"        =    about 10   ppy leach rate; clearly attainable by
                   glass technologies, might be attainable by even simpler
                   waste forms.
                   Estimated engineering cost = $  14-20/kg HM.

                           -2
              =    about 10   ppy leach rate; attainable by simple
                   calcine waste forms—the minimum probably needed for
                   transportation safety
                   Estimated engineering cost = $  12-18/kg HM.

     [NOTE:  Available data indicates that cost variations between the
     different  waste forms now being developed is only about $2-4/kg HM
     (less than one per cent of high-level waste disposal costs).
     Relative  values shown above are assignments from the range of
     costs shown below, increased somewhat to reflect DOE comments.]
                                    27

-------
                        Table 5-4

             Cost  Information on Waste Forms
Cost
Source
Comment
$8-15/kg HM
  (1977 dollars)
ADL 79
range excludes  a
low value of  $4/kg  HM
$10-13/kg HM
  (1978 dollars)
DOE 80
$16-18/kg HM
  (1979 dollars)
JA 81
considered some
relatively sophisticated
metal-matrix waste forms.
                           28

-------
5.5  Repository Construction and Operation




     We took our cost estimates for repository construction  and  operation




from DOE's GEIS (DOE 80).  We considered three different geologic media




(salt, granite, and basalt), and we inflated  the GEIS's  1978  dollars  to




1981 dollars.  The range of costs  for each medium results  from the




repository being used either for high-level waste from reprocessing or  for




spent fuel, with the latter being  slightly more expensive  per kg HM.




These cost estimates are shown  in  Table 5-5.









5.6  Research  and Development




     Our  basic estimate  for research and development costs,  $8-14/kg  HM




(1978 dollars), was developed in our earlier  report (LE  80).  Many of




these costs are associated with surveying, identifying and characterizing




appropriate sites for a  repository—these are identified as  "site




selection" costs.  It will be shown in the next section  that much of  the




protection provided by a repository comes from the characteristics of the




particular disposal site (e.g., appropriate geochemistry), although




engineered barriers can compensate for some site deficiencies.  Therefore,




the magnitude of the research and  development costs can  be significantly




affected by the level of protection we choose for our containment




requirements.  For example, current plans call for DOE to  investigate




several sites in detail before selecting one  for the first repository.




If our standards were stringent enough to prevent any of these first  sites




from being acceptable,  then the national program could be  significantly




delayed and site selection costs would probably increase substantially.
                                    29

-------
               Table  5-5









Repository Construction Costs (DOE 80)









                            fe/kg HM




 salt                       66 -  73




 granite                   109 - 110




 basalt                    123 - 131
                  30

-------
     However; until much more information is available about proposed




sites, the magnitude of site selection costs cannot be quantitatively




associated with different levels of protection.  Nevertheless, to provide




some perspective on the potential impacts of changes in  site selection




costs, we postulated a set of research and development costs that increase




with  increasingly stringent levels of protection.  Table 5-1 shows  these




costs, with  the cost for the least stringent level (10,000 health effects)




being our earlier research and development estimate of $8-14/kg HM




(1978 dollars) adjusted to 1981 dollars.









5.7   Government Overhead and Decommissioning




      Government overhead is defined as all expenses to the Government that




are not related to research and development and are not directly




associated with another cost element.  Decommissioning costs are those




associated with final sealing of a repository, decontaminating and




dismantling  surface facilities, and permanently marking  the site of  the




repository.  The estimated costs for these two elements were developed in




our earlier  report (LE 80) as &2-7/kg HM and $10-12/kg HM (1978 dollars),




respectively.  Neither element is likely to be affected by the level of




stringency chosen for our standards.  The estimates shown in Table  5-1 are




the same as our earlier ones, but are recalculated in terms of 1981




dollars.
                                    31

-------
                                 Chapter 6





                      DIFFERENT LEVELS OF PROTECTION









     A number of considerations are applicable  to  the  selection  of  the




level of protection  that  should be provided by  our proposed  environmental




standards.   In  this  Chapter, we describe  several assessments relevant  to




this  selection, including:  (a) the long-term performance  of  different




repository designs,  using various sets of engineering  controls and




geologic media; (b)  the relative  incidence over time of the  residual risks




associated with different levels  of protection; (c) the correlations




between repository performance and cost relative to four  alternative




levels of protection: 100,  1000,  5000, and 10,000  excess  health  effects




over  10,000  years; (d) the  economic impacts of  variations in the cost  of




high-level waste management  and disposal; and  (e)  an evaluation  of  the




long-term risks that  future  generations would be subjected to if the




uranium ore  used in  creating these wastes had not  been mined.  We then




discuss how  we  used  these assessments to select our proposed containment




requirements.   Throughout this Chapter; we often refer to residual  risks




in terms of  excess health effects over 10,000 years.   However, the  reader




should recall the caveats regarding these assessments  discussed  in




Chapter 1.









6.1  Long-Term  Performance Assessments




     We analyzed the  long-term performance of mined geologic repositories




by considering many combinations of waste canister lifetime, waste  form




release rate, geologic media, groundwater geochemistry, and  geologic







                                    33

-------
factors that may vary from site to site (SMC 82).  To do  this, we  used




generic models of repository sites and designs.  Our analyses  are  not




necessarily applicable to any specific disposal site.  However, we believe:




(1) that they indicate the relative importance of the various  parts of a





repository system and (2) that they provide a general understanding of the




protection achievable by different combinations of engineered  and  natural




barriers.









     Our performance assessments considered the excess premature cancers




("health effects") that might occur during the first 10,000 years  after




disposal.  We selected 10,000 years as the assessment period for two




reasons:










     (1)  It is long enough for releases through groundwater to reach  the




environment.  If we had selected a shorter time (such as  1000 years) our




estimates of harm could be deceptively low because groundwater could take




at least 1,000 years to reach the environment at a well-chosen site.




Choosing 10,000 years for assessment encourages selection of sites  where




the geochemical properties of the rock formations can significantly reduce




releases of radioactivity through groundwater.










     (2)  It is short enough that the likelihood and characteristics of




geologic events which might disrupt the repository are reasonably




predictable over the period.  Major geologic changes, such as development




of a faulting system or a volcanic region, take much longer than 10,000




years.
                                    34

-------
     Our assessments considered  five different geologic  media:  bedded



salt, salt domes, granite, basalt and shale.  This  regulatory  analysis



focuses on only three of these (bedded salt, granite,  and  basalt)  because



the results for domed salt are very similar  to those  for bedded salt  and



the results for shale are similar to those for basalt.   Figure  6-1


summarizes the results we obtained by varying canister lifetime, waste



form leach rate, and site geochemistry while holding  the other  factors



constant.  Unless otherwise  indicated, the canister lifetime used  was


                                                                -4
500 years  (100 years in  salt), the waste  form leach rate was 10   parts



per year,  and  the radionuclide solubility limits  and  retardation factors



were those  indicated in  the  detailed report  of these  analyses  (SMC 82).






     Several broad  conclusions can be drawn  from  these performance



assessments:






     First, major changes in the geochemistry at  a  site  can affect



long-term risks much more than major changes in the engineered  barriers.



For example, neglecting  geochemical retardation for a  granite repository



increases the consequences from about 800 health  effects to 38,000.



(This is the "RD" case in Figure 6-1; the "NS" case assumes that solubility



is never limited for any radionuclide, while the  "BC"  case represents



desirable site characteristics—which include both  geochemical  retardation



and solubility limits.)  In  comparison, assuming  that  the waste  form



dissolves very quickly raises risks to a  little more  than 3000,  while



assuming a zero lifetime for  the waste canister increases risks  only
                                    35

-------
                        FIGURE  6-1:   THE  LEVEL  OF PROTECTION
8000 -
7000 -

6000 .
5000-
4000-
3000-
2000-
1000-
0 -
PROJECTED HEALTH EFF
OVER 10,000 YEARS FC
REFERENCE REPOSITOR
IN DIFFERENT
GEOLOGIC MEDIA








"ECTS
R
ES





PROPOSED STANDARDS












-








°?aET Bca?T° GRANITE BASALT SHALE
bAL 1 bAL I
                                                        8000-
                                                        7000-
                                                        6000-
                                                        5000-
                                                        4000-
                                                        3000-
                                                        2000-
                                                        1000-
                                                       PROJECTED HEALTH  fFFECTS
                                                       OVER 10,000 YEARS
                                                       VS.
                                                       DIFFERENT WASTE  /FORM
                                                       LEACH RATES
                                                       (parts per year)/
                                                               10 "   10"    10 "    10  '    10
8000 -
7000 •
6000 -
5000 -
4000 -
3000 -
2000  -
1000  •
PROJECTED HEALTH EFFECTS
OVER 10,000 YEARS
VS.
DIFFERENT CANISTER LIFETIMES
(years)
          BEDDED  SALT
     0     1000    2000   3000    4000   5000

3000-
7000-


6000-


5000-


4000-
3000-
2000-
1000-
0 -
14700 3800°
CD S

PROJECTED HI
OVER 10,000

WITH OIFFERI
ABOUT GEOCHI

BC - base c;
RD - no geoc
NS no soli


PROPOSED ST.
1 	 II 	 1


ALTH
YEAR

NT A
MICA

se a
hemi
bill


iNOAR


EFFECTS


5SUMPTION:
. FACTORS

isumption
:a1 retan
ty limits


)S










atio













i





                                                       BC    RD    NS     BC    RD    NS
                                                     - BEDDED SALT 	 GRAMITE —
                                                36

-------
to about 1000.  Thus,  it appears  that  efforts  to  identify  a  repository




site with appropriate  characteristics  can  have greater  benefits  than




efforts to improve engineering controls.









     Second, comparing  the  two types of  engineering  controls,  variations




of waste form leach rate consistently  have more effect  on  long-term risks




than variations of canister  lifetime.  Improvements  in  waste  form  appear




to provide more benefits than improvements in  waste  canisters.










     Third, good engineering controls, particularly  good waste forms, can




overcome poor site characteristics.  Our generic  model  of  a basalt




repository assumes that relatively  large amounts  of  groundwater  are




available to dissolve  and transport waste.   In spite of this  disadvantage,




our basalt model can achieve risks  comparable  to  those  at  the  low  end of




the range for our granite model if  the waste form used with basalt is




about an order of magnitude  better  than  that used with  granite.









     Finally, sites with very good  geologic  and hydrologic characteristics




might not need any engineering controls  to meet very low risk  levels.  For




example, the projected  impact from  our bedded  salt model—which  includes




very little groundwater—does not exceed about  200 health  effects  even if




the waste form dissolves very quickly  and  the  canisters have  zero  lifetime




(provided that the advantageous site geochemistry and hydrology  perform as





expected).
                                    37

-------
6.2  Benefits of Different Levels of Protection




     In the simplest sense, the benefits of any level of protection  that




is more stringent than another level are the potential deaths averted by




the more stringent level.  (For example, the difference between setting




standards with a residual risk of 1,000 health effects over 10,000 years,




versus setting standards ten times less stringent, can be considered to be




the 9,000 health effects avoided over 10,000 years.)  However, the




benefits of one level of protection compared to another—with regard to




the regulatory goals we identify in Chapter 2—actually involve a variety




of broader societal perspectives.









     One perspective that may be considered is how the risks allowed by




the standards might occur in the future.  Figure 6-2 indicates the




relative incidence of the residual risks over time from three model




repositories that would comply with our proposed containment




requirements.  [Specifically, these three models are: (1) our basic model




for bedded salt, which presents residual risks of about 200 health effects




over 10,000 years, (2) our basic model for granite, with about 700 health




effects, and (3) a model for basalt with improved engineering controls




that bring the risks down to about 700 health effects.]   All three of




these models would meet the release limits associated with 1,000 health




effects.  Particularly for the granite and basalt models, relatively




little of the residual risk occurs in the first 1,000 years.
                                    38

-------
       FIGURE 6-2:   RELATIVE INCIDENCE OF RESIDUAL  RISK FOR A LEVEL OF  PROTECTION


                        AT 1,000 HEALTH EFFECTS  OVER 10,000 YEARS
   30 H
        SALT  REPOSITORY
                                 30-
   20
                                 20
   10
01
u
                                 10
                            GRANITE  REPOSITORY
                                                              30 .
                                                              20
                                                              10
                                                      BASALT REPOSITORY
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§    8
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o    o
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                                      after
                                        (years)
                                                                     o
                                                                     o
                                                                     o
o
o
o
o
o
o
o
o
o

-------
     We then changed each of the three models in different  ways  to allow




the risks to rise to approximately 10,000 health effects  over  10,000 years,




For the model salt repository, we assumed that the solubilities  of all




radionuclides in groundwater were unlimited.  For the granite  repository,




we assumed that geochemical retardation in the surrounding  rock  formations




did not occur.  For the basalt repository, we assumed poorer quality




engineered barriers.  Figure 6-3 shows the relative incidence  of the




increases in the residual risks that occur in going from  the results of




Figure 6-2 to the larger residual risk level of 10,000 health  effects  over




10,000 years.









     In general, there is no consistent pattern in the way  the residual




risks increase for the three different models.  Relaxing  the isolation




provided by different aspects of our model repositories results  in very




different fluctuations in the overall performance of the models.   However,




one common feature can be noted.  In each case,  the relative increase  in




the residual risk over the first 1,000 years is  very small.  This




illustrates a major reason for our choice of 10,000 years—rather  than




1,000 years—as the time period for our standards.  Some of the  site




characteristics of the models used for Figure 6-3 are much worse than




those that we are sure can be relatively easily achieved.  However,




comparing the residual risks over the first 1,000 years would  not  indicate




these deficiencies.  Only by extending the analysis to a much  longer time




do we see the long-term performance ramifications of major differences in



site characteristics.
                                    40

-------
FIGURE 6-3:  RELATIVE INCIDENCE OF INCREASE IN RESIDUAL RISK BETWEEN LEVELS OF
                PROTECTION OF 1,000 AND 10,000 HEALTH EFFECTS
  SALT REPOSITORY
GRANITE REPOSITORY
BASALT REPOSITORY
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-------
6.3  Engineering Control Costs and the Level of Protection




     Using the analyses summarized in section 6-1, we can assess  the  types




of engineered barriers needed to meet different levels of protection




(in each case we assume that the site characteristics offer as much




protection as those associated with our generic model).  Table 6-1 shows




these correlations for salt, granite and basalt.  The different categories




of waste form and canister are those discussed in Chapter 5.










     The information in Table 6-1 can, in turn, be combined with  the other




cost data in Chapter 5 to assign a range of waste management costs to each




level of protection for each of the three media.  For example: for basalt




at 1,000 health effects, the costs include the costs of a "very good"




waste form and a "good" canister; for granite at 1,000 health effects,




the costs include a "good" waste form and a "minimum" canister.  Practical




requirements of handling and transportation will always require canisters




and waste forms with some durability.  Thus, whenever our performance




assessments indicates that no engineering controls would be needed, the




corresponding costs always include a "minimum" waste form and canister.




Whereever only one or the other type of engineered barrier is needed,




the cheaper is selected.










     Figures 6-4, 6-5,  and 6-6 depict the variation in waste management




cost with different levels of protection, assuming that the variation is




due only to using different combination of engineered barriers.  For these




figures, research and development costs are assumed to remain constant at
                                    42

-------
                                 Table 6-1

    Engineering Controls Associated with Different Levels of Protection
                          Level of Health Effects
                            (over 10,000 years)
                       100
                            1,000
                5,000
                10,000
SALT
           Very good
           waste form
           or very good
           canister
           needed
no engineer-
ing controls
needed *
no engineer-
ing controls
needed *
no engineer-
ing controls
needed *
GRANITE
           very good
           waste form
           needed
good waste
form needed
no engineer-
ing controls
needed *
no engineer-
ing controls
needed *
BASALT
           very good
           waste form
           and very good
           canister
           needed
very good
waste form
and good
canister
needed
good waste
form or good
canister
needed
                                                               fair waste
                                                               form needed
     * =
full "cost savings" would not be achievable due to criteria
recommending "multiple barriers" and "ALARA" and due to other
practical requirements of waste transportation and handling.
                                    43

-------
  Figure  6-4:   Variations  in Waste  Management Cost  vs,
                     Level of Protection
600-
500-
400-1
300 H
200-
100 H
SALT REPOSITORY
Engineering Barrier Costs Only
            100           1,000          5,000         10,000

           level of protection (health effects over 10,000 years)
                            44

-------
      Figure 6-5:   Variations in Haste Management Cost  vs

                         Level  of Protection
   600  -
   500 -
   400 -
   300 -
en
it)
c
to  200 -
    100 -
GRANITE REPOSITORJ


Engineering Barrier Costs Only
                100          1,000         5,000        10,000



               level of protection (health effects over 10,000 years)
                                 45

-------
in
o
u

10
      Figure 6-6:   Variations in Waste Management Cost vs.

                         Level  of Protection
   600 H
   500 -\
i  400 -\
4J   300 H
    200 H
    100
BASALT REPOSITORY


Engineering Barrier Costs Only
                100           1,000          5,000        10,000



               level of protection (health effects over 10,000 years)
                                 46

-------
$ll-20/kg HM.  These results  indicate  that waste management and disposal




costs are not very sensitive  to different levels of protection,




particularly for the geologic media  (bedded salt and granite) that are




better at reducing long-term  risks.  The variations in cost for different




levels of protection are considerably  less than the overall uncertainties




in management and disposal costs.  The next section considers possible




cost variations caused by the effects  of different levels of protection on




site selection.









6.4  Site Selection and the Level of Protection




     As we explained earlier, the geological and hydrological character-




istics of the disposal site provide  the most important part of the




protection afforded by a repository  system.  Besides affecting the types




of engineering controls used, changing the level of protection could




determine how difficult it will be to  find adequate sites.









     The "cost" of good site  characteristics can be considered to be the




"site selection" costs needed to identify and evaluate enough sites in




order to find one (or more) that is  adequate.  The procedures called for




by NRC's proposed 10 CFR 60 require  DOE to investigate at least four sites




in detail before selecting one for the first repository.  If our standards




were stringent enough to prevent any of these first sites from being able




to comply, then the national  program could be significantly delayed and




site selection costs would probably  increase substantially.  However, we
                                    47

-------
believe that our generic models of repository performance  include  site




characteristics that can be achieved (or improved upon) by reasonably





careful site selection.









     Until much more information is available about potential  sites, the




costs of site selection cannot be linked to different levels of our




standards.  However, to provide some feeling for the possible  effect of




different site selection costs, we postulated a set of research and




development costs (which include site selection) that increase with more




stringent levels of protection.  These costs were discussed in Chapter 5.




We believe these estimates are probably upper bounds on the potential




effects of our standard on site selection costs.









     Figures 6-7, 6-8, and 6-9 show the effect of considering our




postulated variations in site selection cost as well as the potential




changes in the costs of engineered barriers.  At each level of protection,




the corresponding research and development cost was used in deriving the




range of total costs described in Chapter 5.  As above, the smallest




increase with increased stringency is shown for salt,  followed by granite




and basalt, respectively.   In all cases, even with our hypothesis that




site selection costs increase with more stringent levels,   the variation




with different levels of protection is considerably smaller than the




overall uncertainty in waste management costs.
                                    48

-------
   Figure 6-7:   Variations in Waste Management Cost  vs.
                      Level  of Protection
600 -
500  J
400 -
300 -
200 -
 100 -
SALT REPOSITORY
Engineer-ing Barrier Costs  and Site Selection Costs
             100          1,000         s.ooo        10,000
            level of protection  (health effects over 10,000 years)
                              49

-------
      Figure 6-8:   Variations  in  Waste Management  Cost vs.


                        Level of  Protection
   600-
   500-
   400-
o
o
   300-
   200-
    100-
GRANITE REPOSITORY


Engineering Barrier Costs and Site Selection Costs
                100          1,000          5,000         10,000



               level of protection (health effects over 10,000 years)
                                50

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      Figure  6-9:   Variations in Waste Management Cost  vs.
                         Level of Protection

              BASALT REPOSITORY
    500 -       Engineering Barrier Costs and Site Selection Costs
    500-
    400-
*.   300-
    200-
    100-
                100          1,000         5,000        10,000

               level of protection (health effects over 10,000 years)
                                51

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6.5  Economic Impacts of Different Levels of Protection




     To estimate the potential economic impacts of  the different  costs




which may be caused by different levels of protection, we  first evaluated




the impact of a one dollar increase in the cost per kilogram  of heavy




metal ($/kg HM).  In its GEIS  (DOE 80), DOE developed a  relationship




between the cost of waste management and disposal (in $/kg HM) and  the




increased cost of electricity  generated by nuclear  reactors (in mils per




kilowatt-hour); this conversion factor is one mil/kwh per  $233/kg HM.




This is slightly larger than the conversion factor DOE used in formulating




President Carter's spent fuel  policy, which was one mil/kwh per $250/kg HM




(DOE 78).  Our earlier analysis (LE 80), in turn, developed estimates of




the annual increase in costs to electricity consumers caused  by various




increases in waste management  changes.  There we estimated that a charge




of one mil/kwh would increase  costs to consumers in the  year  1990 by




$825 million/year, assuming that nuclear power would provide  22% of the




nation's electricity with an installed nuclear capacity  of about  150 GWe.




Similar estimates, based on the years 1980 through 1995, indicate that the




average annual increase for a  one mil/kwh charge would be $700 million/year.




Combining these figures, we see that an increase of $l/kg HM  in management




and disposal costs would correspond to an average annual cost increase to




the nation's electricity consumers of about $3 million/year for the years




1980 through 1995.









     To provide some perspective on these costs, total electrical utility




revenues for 1980 were about $100 billion (DOE 81).   Thus, an increase in




waste management and disposal  costs of $l/kg HM would represent about a






                                    52

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0.003% increase in average electricity  rates.   With  respect  to  the




costs of nuclear power, estimated  by  DOE  to  be  about  35-50 mils/kwh




(1981 dollars) for new plants  (DOE  80), an increase  of  $l/kg HM would




represent about a 0.01% increase in the cost of nuclear power.  These




various "conversion factors"  to relate  increases  in  waste management and




disposal costs to economic impacts  are  summarized  in  Table 6-2.










     With these conversion factors, we  can now  look  at  the economic




impacts of choosing different  levels  of protection.   We will focus on  the




changes in costs between  the  level  of protection  we  chose (risks  less  than




1000 health effects over  10,000 years)  and a level of protection  ten times




less stringent.  The reader may wish  to use  the conversion factors in




Table 6-2 to  look at other increments.









     If we consider only  changes in the costs of  engineered  barriers,  the




differences in cost between meeting the proposed  containment requirements




and meeting requirements  that  allow a residual  risk  ten times greater  are




zero for salt, fc4/kg HM for granite,  and  &7/kg  HM  for basalt.  If we then




add our hypothethical increases in  site selection costs, these cost




differences become $6-10/kg HM for  salt,  fclO-14/kg HM for granite, and




$13-17/kg HM  for basalt.  The  total range in these differences, with and




without the possible increases in  site  selection  costs,  is zero to




$17/kg HM.  This range corresponds  to about zero  to  $50 million/year




(1981 dollars) in increased costs  to  electricity  consumers,  a zero to




0.05 percent  increase in  average electricity rates,  and a zero to




0.2 percent increase in the costs  of  nuclear power.






                                    53

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                           Table 6-2

       Relationship  of  Economic  Impacts  (1981  dollars)  to

   Increases  in  Waste Management and  Disposal  Costs  ($  kg/HM)
Average annual cost increase to
electricity consumers for the       $ 3 million/year per $ I/kg HM
years 1980 through 1995
Increase in average electricity
   rates
Increase in nuclear power costs
0.003 percent per $ I/kg HM
 0.01 percent per $ I/kg HM
                                54

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     Within these ranges, we  think  the most  likely  impacts  will  be  below




$10/kg HM, because we think a site  as unattractive  as  our generic model  of




basalt would probably not be  chosen, and because we think our  assumptions




about site selection costs are probably quite  conservative.  Thus,  the




more likely economic impacts  between the 1,000 and  10,000 health effect




levels are:  less than  $30 million/year (1981  dollars)  in increased




consumer costs, less than a 0.03  percent increase in average electricity




rates, and less than a  0.1 percent  increase  in the  costs of nuclear power.









6.6  Basis for Selecting the  Level  of Protection




     The issues involved in selecting the  level of  protection  for our




proposed environmental  standards  are different—either  in kind or in




degree—from those associated with  other decisions  the  Agency  typically




makes.  These differences are caused primarily by two  factors:









     (1)  Absence of established  technologies  and disposal  sites.




The various options for disposal  of high-level waste are still in the




development phase.  No  facility is  now in  place, nor is there any specific




repository design or site identified as a  preferred  approach for disposal.




Consequently, projections of  both cost and performance must be based on




generic site and design models'.   There are substantial uncertainties in




these projections, and we cannot  know how  well they  might reflect actual




disposal systems until  specific sites and  designs are  selected several




years from now.
                                    55

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     (2)  Long time period of interest.  The uncertainties associated




with the performance of disposal systems are exacerbated by  the  long-time




period over which these wastes will remain dangerous.  Our containment




requirements consist of projected radionuclide release limits  for  10,000




years after disposal.  Therefore, our evaluations of the residual  risks




associated with these release limits are highly speculative.   Food chains,




ways of life, and the size and geographical distributions of populations




will undoubtedly change substantially over any 10,000 year period.  Unlike




geological processes, factors such as these cannot be accurately predicted




over long periods of time.









     Thus, in making our residual risk projections, we used general models




of environmental transport of radionuclides and assumed population




distributions and death rates very similar to today's (SMJ 82).




The results of these calculations should not be taken as a reliable




projection of the "actual" or absolute number of health effects associated




with our containment requirements.  Rather, the residual risk  projections




should primarily be used as tools for comparing the performance of one




waste disposal system with another, or with the long-term risks from other




sources of radionuclides—such as uranium ore bodies.









     These inherent limitations, caused by the uncertainties of our




estimates, place significant limitations on the kinds of quantitative




conclusions which can be drawn from our analyses.  For example, without




reliable absolute projections of health effects, there is no valid basis
                                    56

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upon which a cost per life saved can  reasonably be established, nor can




the long-term residual risks  from  these  standards be directly compared to




the near-term risks estimated for  other  regulatory actions.









     In the absence of the ability to directly make cost-benefit comparions




of alternative stringency levels,  we  considered other  tests—measures of




economic feasibility and risk acceptability—in order  to  select a proposed




level of protection.  Our assessments of economic feasibility are




summarized in section 6.4.  Even considering the potential effects of




site selection costs, the differences in costs for different levels of




protection are much smaller than the  overall uncertainties in waste




management costs and would cause very small economic impacts.  For example,




the potential impacts caused  from  selecting the proposed  level of




protection, rather than one ten times less stringent,  are estimated to be:




(1) less than a five percent  increase in waste management and disposal




costs, (2) less than a 0.2 percent  increase in the costs  of nuclear power,




and (3) less than a 0.06 percent increase in average electricty rates.









     Even if we were able to make  quantitative tradeoffs  in terms of the





cost per health effect prevented,  the applicability of these calculations




would be limited by the sharp division in time between the incidence of




the benefits derived from the activities which generated  these wastes and




the incidence of the major risks from disposal of the wastes.  For example,




the direct benefits associated with nuclear power generated over the past




25 years are tied to a few percent of the total electrical power consumed.
                                    57

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Had the nuclear option not been available, other sources of power could




have been substituted fairly easily.  The amount of nonrenewable fossil




fuels lost to future generations would have been, in relative terms, very




small.  Consequently, the benefits associated with the generation of these




wastes are primarily limited to the current generation.









     However, once disposed of in accordance with our proposed standards,




the risks associated with these wastes will be practically non-existent




for the current generation and the next few generations.  Our models




indicate that the major incidence of residual risk will not occur until




more than 1,000 years after disposal.  As a result, a question of




intergenerational equity exists with respect to those who bear the risks




and those who receive the benefits, and this is a question which cannot be




addressed by directly comparing the costs of disposal with the number of




health effects prevented.









     The issue of intergenerational equity is not unique to high-level




radioactive wastes; however^ in this situation a unique avenue for




addressing the question is available.  All high-level wastes have their




origin in naturally occuring radioactive materials mined from the Earth's




crust.  These materials, principally uranium and its decay products, are




subject to many of the geochemical and geophysical factors that will




affect high-level wastes in a geologic repository—and they can cause




health effects through the same environmental pathways that we examined




for high-level wastes.  Because of the long half-life of uranium, these




risks will persist for time periods well beyond the 10,000-year period we







                                    58

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considered.  Therefore, to  provide  perspective  to  the  residual  risks




associated with our proposed  standards,  we modeled the comparable  risks




from unmined uranium ore bodies.










     Using a quantity of uranium  ore  equivalent  to that  needed  to  generate




the quantity of high-level  waste  contained in our  model  repositories, we




projected a range of health effects for  unmined  ore  bodies  that extended




from 300 to more than one million health effects over  10,000 years.  The




lower end of this range is  roughly  equal to  the  residual  risks  associated




with our proposed radionuclide  release limits.   This means  that the wastes




disposed of in compliance with  our  containment  requirements would  pose a




risk very close to the minimal  risk posed by nature, had  these wastes




never been generated.










     In summary, we believe that  the  level of protection  provided  by our




proposed standards meets both of  our  tests:  those  of economic feasibilty




and risk acceptability, even  considering the question  of  intergenerational




equity.  However, the judgements  with respect to the appropiateness of




these standards are ultimately  societal  decisions  on the  degree of




responsibility that the current generation chooses to  take with respect to




the protection of future generations.  The extensive technical  analyses




supporting these standards  primarily  serve to clarify  the tradeoffs




associated with these social decisions.  Because of  the  speculative nature




of both the issues and the  technical  analyses, public  review and comment




is essential to evaluating  the  resonableness and appropriateness of our





proposed action.






                                    59

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                                 Chapter 7

                     EFFECTS OF ASSURANCE REQUIREMENTS



     In addition  to  our  containment  requirements—which  focus  on  providing

an overall  level  of  protection—we are  also  proposing  seven  qualitative

assurance requirements.   We  believe  these  qualitative  criteria are

essential for developing the needed  confidence  that  our  long-term

containment  requirements will be met.   The assurance requirements address

and compensate  for the uncertainties that  necessarily  accompany plans  to

isolate high-level wastes from the environment  for  a very  long time.

They provide the.context necessary for  application  of  our  containment

requirements, and they should ensure very  good  long-term protection of the

environment.  This Chapter evaluates the potential  effects of  each of

these assurance requirements on the  costs  of waste  management  and disposal.



         Criterion 1:  Wastes  shall  be  disposed of  promptly  once
     disposal systems are available  and the  wastes  have  been
     suitably conditioned for  disposal.


     This criterion  is intended to avoid the possibility that  these wastes

will be stored indefinitely  onc-e disposal  systems are  available,  because

we do not believe  that long-term reliance  on active  institutional controls

is the best way to protect public health and the environment.   However;

storage that is a planned part  of a  disposal technique,  such as letting

high-level waste  cool in surface facilities  for ten  years  or more before

disposal,  would not  violate  the intent  of  this  assurance requirement.
                                     61

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The effect of this criterion should be to reduce costs, since  it  should

tend to reduce the expenditures for waste storage—which Chapter  5

indicates is one of the more expensive components of waste management and

disposal costs.
         Criterion 2:  Disposal systems shall be selected and
     designed to keep releases to the accessible environment as
     small as reasonably achievable, taking into account technical,
     social, and economic considerations.
     This criterion provides for designing a disposal system to perform

better than required by our proposed containment requirements if it

appears reasonable to achieve such improved performance.  This will help

guard against possible mistakes in designing or siting a disposal system.

As discussed in Chapter 6, some of our model geologic repository sites

would not require any engineered controls to meet our proposed standards.

In such situations, this assurance requirement would direct that reasonably

capable engineering controls be used anyway.  Since waste forms and

canisters of significant integrity will be needed for other phases of

waste management (particularly for waste transportation to the disposal

site), we estimate that any increased costs caused by this criterion would

be no more than $2-4/kg HM.
                                    62

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         Criterion 3:  Disposal  systems  shall use  several different
     types of barriers to  isolate  the wastes from  the  accessible
     environment.  Both engineered and natural barriers shall be
     included.  Each such  barrier  shall  separately be  designed to
     provide substantial isolation.


     This criterion should also  guard against possible mistakes in

designing or siting a disposal system by directing use of a combination of

different types of barriers  to isolate these wastes.   The way in which

this assurance requirement might lead to increased disposal costs is

essentially the same as for  Criterion 3, and our estimate of the potential

magnitude of the increase  is the same: $2-4/kg HM.  It should be noted

that this is not an increase in  addition to that associated with

Criterion 3.  Rather, either assurance requirement, or both of them

together, would have the same impact.



         Criterion 4:  Disposal  systems  shall not rely upon active
     institutional controls  to isolate the wastes beyond a
     reasonable period of  time (e.g., a  few hundred years) after
     disposal of the wastes.


     Limiting long-term reliance on active institutional controls to

isolate these wastes may have three different kinds of effects on waste

management and disposal costs.   First, as discussed for Criterion 1,

this assurance requirement could tend to reduce expenditures for waste

storage systems and thus reduce  the costs of the most  expensive phase of

waste management.  Second, designing for the possibility of human

intrusion places increased emphasis on the integrity of a disposal

system's engineered barriers, since intrusion can circumvent the

protection provided by the natural characteristics of  a repository site.
                                    63

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Through the same logic we used for Criteria 2 and 3, we estimate  that  the

magnitude of this potential cost increase would be no more  than

$2-4/kg HM.  Again, thus increase would not be in addition  to  those  for

the previous assurance requirements, but would be duplicative.  Finally,

this assurance requirement could rule out certain relatively unusual sites

that would provide adequate protection only if inadvertant  intrusion was

not possible.  (A hypothetical example would be a site in bedded  salt  that

is stable unless drilling inadvertantly creates groundwater flow  patterns

that cause rapid dissolution of the salt strata—a situation that has

occasionally been observed.)  However, such situations appear  to  be

sufficiently unusual that site selection procedures based on this

assurance requirement could easily avoid any delay or extra cost  for the

national program.
         Criterion 5:  Disposal systems shall be identified by the
     most permanent markers and records practicable to indicate the
     dangers of the wastes and their location.
     The costs for permanent markers at disposal sites and comprehensive

public records—to document the nature of the disposal system and its

contents—would appear to be trivial compared to the costs of the disposal

systems themselves.  Thus, we do not attribute any economic impacts to

this assurance requirement.
                                    64

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         Criterion 6:  Disposal systems shall not be located where
     there has been mining for resources or where there is a
     reasonable expectation of exploration for scarce or easily
     accessible resources in the future.  Furthermore, disposal
     systems shall not be located where there is a significant
     concentration of any material which is not widely available
     from other sources.
     This assurance requirement could rule out an otherwise acceptable

site because of the relative liklihood of human intrusion.  For example,

the frequent mining of salt domes either for their relatively pure salt or

for use as storage caverns would argue against locating a repository in

this type of structure.  (This concern would generally not apply to bedded

salt deposits because they are much more common—but the criterion could

rule out specific bedded salt sites if they were associated with

significant occurrences of other resources.)  This assurance requirement

is more likely to rule out an site than Criterion 4 would be.  However, we

still believe that site selection procedures based on Criterion 6 could

avoid any delay or extra cost for the national program.
         Criterion 7:  Disposal systems shall be selected so that
     removal of most of the wastes is not precluded for a reasonable
     period of time after disposal.
     Mined geologic repositories, with their wastes contained in capable

engineered barriers, meet this assurance requirement by their inherent

characteristics.  Since the national program is now focused on this type

of disposal system, we do not foresse any cost effects due to this

requirement.
                                    65

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       Appendix
THE PROPOSED STANDARDS
          67

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     A new Part 191 is proposed to be added to Title 40, Code of Federal




Regulations, as follows:









               SUBCHAPTER F - RADIATION PROTECTION PROGRAMS









PART 191 - ENVIRONMENTAL RADIATION PROTECTION STANDARDS FOR




     MANAGEMENT AND DISPOSAL OF SPENT NUCLEAR FUEL, HIGH-LEVEL AND




     TRANSURANIC RADIOACTIVE WASTES









      Subpart A - Environmental Standards for Management and Storage




191.01   Applicability




191.02   Definitions




191.03   Standards for Normal Operations




191.04   Variances for Unusual Operations




191.05   Effective Date









             Subpart B - Environmental Standards for Disposal




191.11   Applicability




191.12   Definitions




191.13   Containment Requirements




191.14   Assurance Requirements




191.15   Procedural Requirements





191.16   Effective Date









AUTHORITY:  The Atomic Energy Act of 1954, as amended; Reorganization Plan





No. 3 of 1970.






                                    69

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      SUBPART A - ENVIRONMENTAL STANDARDS FOR MANAGEMENT AND STORAGE









191.01  Applicability




     This Subpart applies to radiation doses received by members of the




public as a result of the management (except for transportation) and




storage of spent nuclear fuel, high-level, or transuranic radioactive




wastes, to the extent that these operations are not subject to the




provisions of Part 190 of Title 40.









191.02  Definitions




     Unless otherwise indicated in this Subpart, all terms shall have the




same meaning as in Subpart A of Part 190.




     (a)  "Spent nuclear fuel" means any nuclear fuel removed from a




nuclear reactor after it has been irradiated.




     (b)  "High-level radioactive wastes" means any of the following that




contain radionuclides in concentrations greater than those identified in




Table 1: (1) liquid wastes resulting from the operation of the first cycle




solvent extraction system, or equivalent, in a facility for reprocessing




spent nuclear fuels; (2) the concentrated wastes from subsequent




extraction cycles, or equivalent; (3) solids into which such liquid wastes




have been converted; or (4) spent nuclear fuel if disposed of without




reprocessing.




     (c)  "Transuranic wastes," as used in this Part, means wastes




containing more than 100 nanocuries of alpha emitting transuranic




isotopes, with half-lives greater than one year, per gram of waste.
                                    70

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     (d)  "Storage" means placement of  radioactive wastes with planned




capability to readily retrieve such materials.




     (e)  "Management and storage" means any activity, operation, or




process, except for transportation, conducted  to prepare spent nuclear




fuel, high-level or transuranic radioactive wastes for storage or




disposal, the storage of any of these materials, or activities associated




with the disposal of these materials.




     (f)  "General environment" means the  total terrestial, atmospheric,




and aquatic environments outside  sites  within  which any operation




associated with the management and storage of  spent nuclear fuel,




high-level or transuranic radioactive wastes is conducted.




     (g)  "Member of the public"  means  any individual who is not engaged




in operations involving the management,  storage, and disposal of materials




covered by these standards.  A worker so engaged is a member of the public




except when on duty at a site.









191.03  Standards for Normal Operations




     Operations covered by this Subpart  should be conducted so as to




reduce exposures to members of the public to the extent reasonably




achievable, taking into account technical, social, and economic




considerations.  As an upper limit, except for variances in accordance




with 191.04, these operations shall be  conducted in such a manner as  to




provide reasonable assurance that the combined annual dose equivalent to




any member of the public due to:  (a) operations covered by Part 190,
                                     71

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(b) planned discharges of radioactive material to the general environment




from operations covered by this Subpart, and (c) direct radiation  from





these operations; shall not exceed 25 millirems to the whole body,




75 millirems to the thyroid, or 25 millirems to any other organ.










191.04  Variances for Unusual Operations




     (a)  The implementing agency may grant a variance temporarily




authorizing operations which exceed the standards specified in 191.03 when




abnormal operating conditions exist if: (1) a written request justifiying




continued operation has been submitted, (2) the costs and benefits of




continued operation have been considered to the extent possible, (3) the




alternatives to continued operation have been considered,  and (4)




continued operation is deemed to be in the public interest.




     (b)  Before the variance is granted,  the implementing agency shall




announce, by publication in the Federal Register and by letter to the




governors of affected States: (1) the nature of the abnormal operating




conditions, (2) the degree to which continued operation is expected to




result in doses exceeding the standards, (3) the proposed schedule for




achieving conformance with the standards,  and (4) the action planned by




the implementing agency.









191.05  Effective Date




     The standards in this Subpart shall be effective 12 months from the




promulgation date of this rule.
                                    72

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             SUBPART B - ENVIRONMENTAL STANDARDS FOR DISPOSAL









191.11  Applicability




     This Subpart applies to radioactive materials released into the




accessible environment as a result of the disposal of high-level or




transuranic radioactive wastes,  including the disposal of  spent nuclear




fuel.  This Subpart does not apply to disposal directly  into the oceans or




ocean sediments.









191.12  Definitions





     Unless otherwise indicated  in this Subpart, all terms shall have the




same meaning as in Subpart A of  this Part.




     (a)  "Disposal" means isolation of radioactive wastes with no intent




to recover them.




     (b)  "Barriers" means any materials or  structures that prevent or




substantially delay movement of  the radioactive wastes toward the




accessible environment.




     (c)  "Disposal system" means any combination of engineered and




natural barriers that contains radioactive wastes after  disposal.




     (d)  "Groundwater" means water below the land surface in a zone of




saturation.




     (e)  "Lithosphere" means the solid part of the Earth, including any





groundwater contained within it.
                                    73

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     (f)  "Accessible environment" includes (1) the atmosphere,  (2)  land




surfaces, (3) surface waters, (4) oceans, and (5) parts of the  lithosphere




that are more than ten kilometers in any direction from the original




location of any of the radioactive wastes in a disposal system.




     (g)  "Reasonably foreseeable releases" means releases of radioactive




wastes to the accessible environment that are estimated to have more  than




one chance in 100 of occurring within 10,000 years.




     (h)  "Very unlikely releases" means releases of radioactive wastes to




the accessible environment that are estimated to have between one chance




in 100 and one chance in 10,000 of occurring within 10,000 years.




     (i)  "Performance assessment" means an analysis which identifies




those events and processes which might affect the disposal system,




examines their effects upon its barriers, and estimates the probabilities




and consequences of the events.  The analysis need not evaluate risks from




all identified events.  However, it should provide a reasonable




expectation that the risks from events not evaluated are small in




comparison to the risks which are estimated in the analysis.




     (j)  "Active institutional controls" means (1) guarding a disposal




site, (2) performing maintenance operations or remedial actions at a




disposal site, or (3) controlling or cleaning up releases from a disposal




site.
                                    74

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     (k)  "Passive institutional  controls" means  (1)  permanent markers




placed at a disposal site,  (2)  public  records  or  archives,  (3) Federal




Government ownership or control of  land use, or (4) other methods of




preserving knowledge about  the  location,  design,  or contents of a disposal




system.




     (1)  "Heavy metal" means all uranium, plutonium,  or  thorium placed




into a nuclear reactor.









191.13  Containment Requirements




     Disposal systems  for high-level or transuranic wastes  shall be




designed to provide a  reasonable  expectation that  for  10,000 years after




disposal:




     (a)  Reasonably foreseeable  releases of waste to  the accessible




environment are projected to be less than the  quantities calculated




according to Table 2.




     (b)  Very unlikely releases  of waste to the  accessible environment




are projected to be less than ten times the quantities calculated




according to Table 2.









191.14  Assurance Requirements




     To provide the confidence  needed  for compliance with the containment




requirements of 191.13, disposal  of high-level or  transuranic wastes shall




be conducted in accordance  with the following  requirements:
                                    75

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     (a)  Wastes shall be disposed of promptly once disposal systems are




available and the wastes have been suitably conditioned for disposal.




     (b)  Disposal systems shall be selected and designed to keep releases




to the accessible environment as small as reasonably achievable, taking




into account technical, social, and economic considerations.




     (c)  Disposal systems shall use several different types of barriers




to isolate the wastes from the accessible environment.  Both engineered




and natural barriers shall be included.  Each such barrier shall





separately be designed to provide substantial isolation.




     (d)  Disposal systems shall not rely upon active institutional




controls to isolate the wastes beyond a reasonable period of time (e.g., a




few hundred years) after disposal of the wastes.




     (e)  Disposal systems shall be identified by the most permanent




markers and records practicable to indicate the dangers of the wastes and




their location.




     (f)  Disposal systems, shall not be located where there has been




mining for resources or where there is a reasonable expectation of




exploration for scarce or easily accessible resources in the future.




Furthermore, disposal systems shall not be located where there is a




significant concentration of any material which is not widely available




from other sources.




     (g)  Disposal systems shall be selected so that removal of most of





the wastes is not precluded for a reasonable period of time after disposal.
                                    76

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191.15  Procedural Requirements




     Performance assessments  to determine  compliance  with  the containment




requirements of 191.13 shall  be conducted  in accordance with the following:




     (a)  The assessments shall consider realistic projections of the




protection provided by all of the engineered and natural barriers of a




disposal system.




     (b)  The assessments shall not  assume  that active  institutional




controls can prevent or reduce releases to  the accessible  environment




beyond a reasonable period (e.g., a  few hundred years)  after disposal.




However, it should be assumed that the Federal Government  is committed to




retaining passive institutional control of  disposal sites  in perpetuity.




Such passive controls should  be effective  in deterring  systematic or




persistent exploitation of a  disposal site, and it should  be assumed that




they can keep the chance of inadvertent human intrusion very small as long




as the Federal Government retains such passive control  of  disposal sites.




     (c)  The assessments shall use  information regarding  the likelihood




of human intrusion, and all other unplanned events that may cause releases




to the accessible environment, as determined by the implementing agency




for each particular disposal  site.









191.16  Effective Date




     The standards in this Subpart shall be effective immediately upon




promulgation of this rule; however;  this Subpart does not  apply to wastes




disposed of before promulgation of this rule.
                                    77

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    TABLE 1 - CONCENTRATIONS IDENTIFYING HIGH-LEVEL RADIOACTIVE WASTES
     Radionuclide                                       Concentration

                                                 (curies per gram of waste)
     Carbon-14   	8x10


     Cesium-135	8x 10~4


     Cesium-137	5 x 10~3


     Plutonium-241	3x10

                                                                  -3
     Strontium-90	  7x10


     Technetium-99	  3x10


     Tin-126	7x 10~7


     Any alpha-emitting transuranic


       radionuclide with a half-life -----------  1x10


       greater than 20 years


     Any other radionuclide with a half-life

                                                                  _o
       greater than 20 years ---------------  1x10
     NOTE:  In cases where a waste contains a mixture of radionuclides, it


shall be considered a high-level radioactive waste if the sum of the


ratios of the radionuclide concentration in the waste to the concentration


in Table 1 exceeds one.
                                    78

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     For example, if a waste containing radionuclides A, B, and C in




concentrations Ca,  C^, and Cc, and if the concentration limits from




Table 1 are CLa, CL^, and CLC, then the waste shall be considered




high-level radioactive waste if the following relationship exists:







                  Ca       Cb       Cc
                  CLa      CLb      CL
                                      c
                                     79

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      TABLE  2  -  RELEASE  LIMITS  FOR CONTAINMENT REQUIREMENTS

       (Cumulative Releases to the Accessible Environment

                for 10,000 Years After Disposal)
Radionuclide
     Release Limit
(curies per 1000 MTHM)
Americium-241 ---------------------    10

Americium-243 ---------------------     4

Carbon-14   	   200

Cesium-135	2000

Cesium-137	   500

Neptunium-237	    20

Plutonium-238	______   400

Plutonium-239	100

Plutonium-240	

Plutonium-242 ---------------------

Radium-226	     3

Strontium-90  ---------------------    30

Technetium-99 -----------------____ 1QOOO

Tin-126	    80

Any other alpha-emitting

  radionuclide  -------------_______    ^Q

Any other radionuclide which does

  not emit alpha particles  --------------
                               80

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     NOTE 1:  The Release Limits in Table 2  apply  either  to  the  amount  of


high-level wastes generated from 1,000 metric  tons  of  heavy  metal  (MTHM),


or to an amount of transuranic (TRU) wastes  containing one million curies


of alpha-emitting transuranic radionuclides.   To develop  Release Limits


for a particular disposal system,  the quantities in Table 2  shall be


adjusted for the amount of wastes  included in  the  disposal system.


For example:





     (a)  If a particular disposal system contained the high-level wastes


from 50,000 MTHM, the Release Limits for that  system would be the


quantities in Table 2 multiplied by 50  (50,000 MTHM divided  by 1,000 MTHM).


     (b)  If a particular disposal system contained five  million curies of


alpha-emitting transuranic wastes, the Release Limits  for that system


would be the quantities in Table 2 multiplied  by five  (five  million curies


divided by one million curies).


     (c)  If a particular disposal system contained both  the high-level


wastes from 50,000 MTHM and 5 million curies of alpha-emitting transuranic


wastes, the Release Limits for that system would be the quantities in


Table 2 multiplied by 55:


              50,000 MTHM     5,000,000 curies TRU
              	  +  	  =  55

               1,000 MTHM     1,000,000 curies TRU
                                    81

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     NOTE 2:  In cases where a mixture of radionuclides  is projected




to be released, the limiting values shall be determined  as follows:




For each radionuclide in the mixture, determine the ratio between  the




cumulative release quantity projected over 10,000 years  and  the  limit




for that radionuclide as determined from Table 2 and Note 1.  The  sum




of such ratios for all the radionuclides in the mixture  may  not  exceed




one.









     For example, if radionuclides A, B, and C are projected to  be




released in amounts Qa, Q^, and Q   and if the applicable Release




Limits are RLa, RL^, and RLC,  then the cumulative releases over




10,000 years shall be limited  so that the following relationship exists:







                  Qa       Qb        Qc
                  RLa      RLb      RL
                                      c
                                    82

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                            REFERENCES
(ADL 79)    Arthur D. Little, Inc., 1979.  Technical Support of
            Standards for High-Level Radioactive Waste Management:
            Volume E~:Enginering Controls.U.S. Environmental
            Protection Agency (EPA/520/4-79-007), Washington, D.C.

(DOE 80)    U.S. Department of Energy, October 1980.  Final
            Environmental Impact Statement:  Management of
            Commercially Generated Radioactive Waste.
            U.S. Department of Energy (DOE/EIS-0046F),
            Washington, D.C.

(DOE 81)    U.S. Department of Energy, 1981.  Monthly Energy
            Review.  U.S. Department of Energy (DOE/EIA-0035(81))
            Washington, D.C.

(EPA 82)    U.S. Environmental Protection Agency, 1982.  Draft
            Environmental Impact Statement for 40 CFR 191:
            Environmental Standards for Management and Disposal of
            Spent Nuclear Fuel, High-Level and Transuranic
            Radioactive Wastes.  U.S. Environmental Protection
            Agency (EPA 520/1-82-025), Washington, D.C.

(IRG 79)    Interagency Review Group on Nuclear Waste Management,
            March, 1979.  "Report to the President".  National
            Technical Information Service (TID-28817), Springfield,
            Virginia 22161.

(JA 81)     Jardine, L.J., R.E. Carlton, and M.J. Steindler, 1981.
            Comparison of Costs for Solidification of High-Level
            Radioactive Waste Solutions:  Glass Monoliths vs. Metal
            Matrices.  Argonne National Laboratories (ANL-80-121),
            Argonne, Illinois.

(LE 80)     Leiter; Andrew J., December 1980.  Economic Impacts of
            40 CFR 191:  Environmental Standards for Management and
            Disposal of Spent Nuclear Fuel, High-Level and
            Transuranic Radioactive Wastes.  U.S. Environmental
            Protection Agency (EPA 520/4-80-014), Washington, D.C.

(NRC 80)    U.S. Nuclear Regulatory Commission, 1980.  Advance
            Notice of Proposed Rulemaking, 10 CFR Part 60:
            "Technical Criteria for Regulating Disposal of
            High-Level Radioactive Waste," Federal Register-
            Vol. 45, No. 94, page 31393.
                                83

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(SA 81)     Sandsberry, D.,  Department of Commerce, Bureau of the
            Census.  Personal conversation with Byron Bunger,
            U.S. Environmental Protection Agency, September 1981.

(SMC 82)    Smith, C.B., D.J. Egan,  W.A.  Williams, J.M. Gruhlke,
            C.Y. Hung, and B. Serini, 1982.  Population Risks from
            Disposal of High-Level Radioactive Wastes in Geologic
            Repositories.  U.S.  Environmental Protection Agency
            (EPA 520/3-80-006),  Washington, D.C.

(SMJ 82)    Smith, J.M., T.W. Fowler and  A.S. Goldin, 1982.
            Environmental Pathway Models  for Estimating Population
            Risks from Disposal  of High-Level Radioactive Waste in
            Geologic Repositories.  U.S.  Environmental Protection
            Agency (EPA 520/5-80-002),  Washington, D.C.

(VI 81)     Vieth, D., Department of Energy.  Personal conversation
            with Daniel Egan, U.S. Environmental  Protection Agency,
            October 1981.

(WA 81)     Walton, R., Department of Energy.  Personal conversation
            with Daniel Egan, U.S. Environmental  Protection Agency,
            October 1981.

(WI 80)     Williams, W.A.,  1980.  Population Risks  from Uranium
            Ore Bodies.  U.S. Environmental Protection Agency
            (EPA 520/3-80-009),  Washington,  D.C.
                                84

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