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.
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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."
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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.
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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."
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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
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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.
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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
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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.
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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.
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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
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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
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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).
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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).
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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.
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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
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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
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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
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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
o
o
o
o
o
o
§ 8
o
o
o
o
o o
o o
o o
(£> 00
o
8
o
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
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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
-------
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
-------
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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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Appendix
THE PROPOSED STANDARDS
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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.
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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.
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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,
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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.
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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.
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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.
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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:
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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.
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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.
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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.
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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
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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 --------------
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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
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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
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(SA 81) Sandsberry, D., Department of Commerce, Bureau of the
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