Uniteo States       Office of        EPA 520/1-85-027
Environmental Protection    Radiation Programs      August 1985
Agency         Washington, D.C. 20460
Radiation 	             '
Final Regulatory Impact
Analysis
40 CFR Part 191
Environmental Standards for
the Management and
Disposal of Spent Nuclear
Fuel
High-Level and Transuranic
Radioactive Wastes

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                                        EPA 520/1-85-027
                FINAL
     REGULATORY  IMPACT ANALYSIS
           40 CFR PART 191
       ENVIRONMENTAL STANDARDS
               FOR THE
       MANAGEMENT AND DISPOSAL
                 OF
 SPENT NUCLEAR FUEL, HIGH-LEVEL AND
   TRANSURANIC RADIOACTIVE WASTES
             AUGUST 1985
U. S. ENVIRONMENTAL PROTECTION AGENCY
     Office of Radiation Programs

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                                 CONTENTS
Chapter 1: Introduction and Summary                                  1-1

       1.1 Analytical Framework                                      1-2
       1.2 Containment Requirements                                  1-3
       1.3 Individual and Ground Water Protection Requirements       1-6
       1.4 Summary                                                   1-9
Chapter  2: Regulatory Goals and Benefits                             2-1


Chapter  3: Costs of Waste Disposal                                   3-1

       3.1 Storage                                                   3-4
       3.2 Transportation                                            3-4
       3.3 Encapsulation  (Canister)                                  3-4
       3.4 Waste Form                                                3-6
       3.5 Repository Construction and Operation                     3-6
       3.6 Research and Development                                  3-10
       3.7 Government Overhead and Decommissioning                   3-10

Chapter  4: Different Levels of Protection for
                   the Containment Requirements                      4-1

       4.1 Long-Term Performance Assessments                         4-1
       4.2 Benefits of Different Levels of Protection                4-4
       4.3 Engineered Control Costs and the Level of Protection      4-6
       4.4 Economic Impacts of Different Levels of Protection        4-6
Chapter 5: Duration of the Individual and
                   Ground Water Protection Requirements              5-1

       5.1 Long-Term Performance Assessments                         5-1
       5.2 Engineered Controls and Individual Protection             5-3
       5.3 Engineered Control Costs and the
                   Duration of Individual Protection                 5-3
References                                                           R-l

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                         LIST OF FIGURES

Figure      	Title	

 1-1        Waste disposal  costs as a function of               1-4
               various levels of protection assuming
               non-compliance with  10 CFR  60

 1-2        Waste disposal  costs as a function of               1-5
               various levels of protection assuming
               compliance with 10 CFR 60

 1-3        Waste disposal  costs as a function of               1-7
               the duration of the  individual  dose
               standards assuming non-compliance
               with 10 CFR  60

 1-4        Waste disposal  costs as a function of               1-8
               the duration of the  individual  dose
               standards assuming compliance with
               10  CFR  60

 4-1        Health effects  as a  function of waste form           4-3
               leach rate

 4-2         Relative incidence of residual risk for              4-5
              model repositories

 4-3        Relative incidence of increases in                   4-7
              residual risk up to  1,000 health effects

5-1        Individual doses from ground water use               5-2
              at two kilometers

5-2        Annual individual dose from drinking ground          5-4
           water as a function of canister lifetime
           and waste form  leach  rate
                              11

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                            LIST OF TABLES
Table                          Title
 3-1        Total costs of waste management                     3-2

 3-2        Total costs of waste disposal                       3-3

 3-3        Performance categories and assumed costs            3-5
               for waste canisters

 3-4        Performance categories and assumed costs            3-7
               for waste forms

 3-5        Cost information on waste forms                     3-8

 3-6        Repository construction costs                       3-9

 4-1        Engineered controls associated with                 4-8
            different levels of protection

 4-2        Waste disposal costs associated with                4-9
            different levels of protection
            assuming non-compliance with 10 CFR 60

 4-3        Waste disposal costs associated with                4-10
            different levels of protection
            assuming compliance with 10 CFR 60

 4-4        Relationship of economic impacts to                 4-12
            increases in waste management and
            disposal costs

 5-1        Engineered controls associated with                 5-6
            different durations of individual and
            ground water protection requirements

 5-2        Waste disposal costs associated with                5-7
            different durations of individual and
            ground water protection requirements
            assuming non-compliance with 10 CFR 60

 5-3        Waste disposal costs associated with                5-8
            different durations of individual and
            ground water protection requirements
            assuming compliance with 10 CFR 60
                                  111

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                                   Chapter 1

                           INTRODUCTION AND SUMMARY


     This Final Regulatory Impact Analysis  (RIA) addresses the requirements
of Section 2 of Executive Order No. 12291.  It reviews the projected costs
associated with management and disposal of the high-level radioactive wastes
(or spent nuclear fuel) generated by nuclear power plants.  It then evaluates
the potential effects on the program for mined geologic repositories, as
called for by the Nuclear Waste Policy Act of 1982 (NWPA), of the Agency's
final environmental standards for disposal of these wastes.  These standards
are located in Part 191 of Title 40 of the Code of Federal Regulations
(40 CFR 191).  This Final RIA is based on the Draft RIA (EPA 82) that was
published with the version of these standards proposed for public review and
comment on December 29, 1982 (47 FR 58196).  The Final RIA reflects changes in
the standards made after considering the comments received, and it also takes
into account several recommendations made by the subcommittee of the Agency's
Science Advisory Board (SAB) that reviewed the technical basis of the proposed
rule (SAB 84).

     The situation regarding the disposal of high-level wastes is unusual from
a regulatory standpoint.  In most cases, a regulation addresses an ongoing
activity.  Any modifications that the regulation causes in the conduct of that
activity may be considered to be costs that should be outweighed by the
corresponding regulatory benefits.  For high-level waste disposal, however,
the Executive branch has long assumed—and the Congress has now mandated—that
the appropriate environmental 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.  There is no ongoing
"baseline" program to consider.

     Instead, this Final RIA uses the current and planned programs of the
Department of Energy (DOE) and the Nuclear Regulatory Commission (NRC) to
provide a framework for investigating the potential regulatory impacts of
these environmental standards.  The RIA evaluates how the costs of high-level
waste disposal might change: (1) due to alternative stringency levels for the
numerical containment requirements of the disposal standards, and (2) due to
alternative levels and durations for the individual and ground water
protection portions of the disposal standards.  This evaluation uses
information about potential disposal sites that DOE has1already collected
through its site evaluation programs, and the evaluation reflects several
provisions of the technical criteria that the NRC has already promulgated for
geologic disposal of high-level wastes (10 CFR 60).

     Like most environmental regulations, the benefits of these standards can
be discussed in terms of damages to public health and the environment that are
avoided (or allowed) at various levels of stringency.  While the analyses
described in this RIA associate potential health impacts (in terms of
premature fatal cancers and serious genetic effects) with different levels of
the disposal standards, assessing the benefits of these standards in such
terms may be misleading because of the very long time frames considered.


                                      1-1

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 Calculations  of  the  residual  risks  allowed  by  the  standards are not reliable
 as  absolute values,  since  projections  of population  distributions,  life
 styles,  and human behavior over  10,000 years can only  be  based on conjecture.
 Instead,  these calculations are  valuable only  for  understanding the relative
 residual  risks from  different sources  of radiation exposure (such as risks
 from different disposal  designs  or  risks from  natural  uranium ore bodies).

      However, the most important benefit of these  standards does not depend
 upon the  absolute validity of these quantitative calculations.   Instead,  this
 benefit  consists of  the  general  confidence  these standards  provide  that
 management and disposal  of these wastes will be accomplished with exceptional
 protection of the environment and with residual risks  that  are clearly very
 small.  This confidence  should,  in  turn, facilitate  the national program to
 evaluate, select,  and construct  acceptable  disposal  methods that will reduce
 the risks and costs  of indefinite storage of the materials  covered  by these
 standards.  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 advantages,  economic and otherwise,
 compared  to alternative  methods  of  generating  electricity;  however,  this RIA
 does not  analyze the comparative benefits of nuclear power.

 1.1 Analytical Framework
      To investigate  the  potential effects of the standards  on the costs of
 waste disposal,  the  Agency assembled analytical models of three of  the
 disposal sites being considered  by  the Department  of Energy:  the site in
 basalt flows on  the  Hanford reservation in  Washington  and two sites in bedded
 salt  formations,  one in  the Palo Duro  Basin in Texas and  the other  in the
 Paradox formation  in Utah.  These models evolved from  much  more generic models
 that  were used for the development  of  the proposed standards.   Although the
 Agency has not assembled models  for all of  the nine  sites that  the  Department
 is  now evaluating  in accordance  with the site  selection process established by
 the NWPA, the three  sites  considered appear representative  of the range of
 performance that might be  expected  from any of the sites.   The  two  models for
 bedded salt sites should represent  the  performance of  any of the seven sites
 in  salt formations,  within the accuracy of  these analyses.   Other analyses
 reported in the Background Information  Document (EPA 85)  for this rule
 indicate that performance  of  the unsaturated tuff  site in Nevada also appears
 to be similar to that of the  bedded salt models.

      Furthermore, the Agency  considered the effects  of the  engineered barriers
 that  are to be used  in building disposal systems for high-level wastes.   The
NRC has required that waste packages contain the wastes for  300 to  1,000  years
 after disposal and that the release rate after that  time  be  no  more  than  one
part  in 100,000 for  important radionuclides (10 CFR  60).  These requirements
are used as a baseline for the analyses in  this RIA, although the effects of
alternative assumptions for package lifetimes  and waste form release rates are
also examined.
                                      1-2

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 1.2  Containment  Requirements
     The  containment  requirements in the disposal standards consist of limits
 on projected  releases of radioactivity from a disposal system for 10,000 years
 after  disposal of  the wastes.   To evaluate the risks associated with these
 release limits,  generalized environmental pathway models were developed to
 assess the  potential  health risks of such releases (SM 85).  For the
 containment requirements in the final rule, the residual risks projected by
 these  models  would be less than 1,000 deaths from cancer over the 10,000-year
 period, an  average of one premature cancer death every 10 years.  This is the
 same residual risk that was associated with the proposed rule.  To judge the
 effects on  disposal costs of changing this level of  protection,  the Agency
 also considered  containment requirements with residual risk values of 100 and
 10,000 premature cancer deaths over the 10,000-year  period.  This range of
 residual  risks was chosen because it corresponds to  the range of performance
 expected  of mined  geologic repositories.

     Two  types of  effects were investigated.   First,  long-term performance
 assessments were used to evaluate the quality of engineered controls that
 would  be  needed  in each of the three model repositories to meet  each of the
 three  different  levels of protection.   Assessing the  costs of engineered
 controls  of different quality was difficult,  however,  because development of
 specific  technologies (canisters,  waste forms,  etc.)  has not yet progressed
 far  enough  to clearly associate the costs of  manufacturing these engineered
 barriers  with their performance levels.   Thus,  rather  tentative  judgments had
 to be  made  to associate engineered barrier costs with alternative stringency
 levels.

     Second,  potential effects of the level of  protection on the costs of
 demonstrating compliance with the standards were considered.   Reliable
 perspectives  on  such  costs cannot be developed  until  the national program has
 proceeded to  characterize potential sites and the implementing agencies have
 had  an opportunity to consider compliance with  the types of data collected at
 such sites.   Accordingly,  this RIA can only speculate  on the effects of the
 standards on  such  costs.   To carry out this analysis,  it has been assumed that
 the  costs of  research and development  at a site could  be increased by
 50 percent  when  the projected  performance of  the disposal system is less than
 an order  of magnitude below the residual risks  allowed by the standards.
 Thus,  for the risk level of 1,000  cancer deaths over  10,000 years,  it is
 assumed that  research and development  costs increase when a disposal system
 (site  characteristics plus engineered  barriers)  projects risk levels above 100
 cancer deaths over 10,000 years.

     Figures  1-1 and  1-2  display  the results  of these  analyses for the
 basalt and bedded  salt model sites considered.   These  figures show the
 results with  and without  the assumption that  the engineered barrier
 requirements  in  10 CFR 60 are  met.   These analyses demonstrate that the costs
of disposal are  not very  sensitive to  different levels of protection.   In
fact,  if  it is assumed that the requirements  of 10 CFR 60 are met,  there are
no additional costs for any of the model sites  to meet the level of
protection called  for  by  the containment requirements—compared  with a level
of protection ten  times less stringent.   If the requirements of  10 CFR 60 are
                                      1-3

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     30CH
     200-
I
    100-
                      Salt Repositories
                100       1,000      10,000
     Basalt Repository
100
1,000      10,000
                                    Health effects over 10,000 years
            Figure 1-1.   Waste disposal costs as a function of various levels of protection
                         assuming non-compliance with 10 CFR 60
                                         1-4

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     300-1
                     SaH Repositories
£    200-
o>
     100-
                100
1,000      10,000
                                   Basalt Repository
100
1,000     10,000
                                    Health effects over 10,000 years
            Figure 1 -2.  Waste disposal costs as a function of various levels of protection
                         assuming compliance with 10 CFR 60
                                       1-5

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 not considered, there still appear to be no additional costs to meet_the
 chosen  level of protection at the bedded salt sites.  However, additional
 costs for engineered barriers would be projected for the basalt site  at  a
 residual risk level of 1,000 deaths over 10,000 years, compared to a  level  of
 10,000  deaths.  These additional costs would be about 6 to 12 million (1984)
 dollars per year.  For comparison, the total costs of high-level waste
 disposal (independent of this action) are estimated to be between 400 million
 and 700 million (1984) dollars per year.  Electrical utility revenues were
 about 150 billion dollars in 1984, of which about 20 billion dollars  were
 generated by sales of electricity generated by nuclear power plants (DOE 85).

 1.3  Individual and Ground Water Protection Requirements
      These sections of the final rule, which were added in response to
 comments received on the proposed standards, limit both concentrations of
 radionuclides in certain ground waters and exposures of individuals for  1,000
 years after disposal.  Unlike the containment requirements, which apply  to  a
 wide range of unlikely or unplanned releases, these provisions apply  only to
 undisturbed performance of the disposal system.   The three models of  geologic
 repositories used to evaluate the containment requirements were also  used to
 assess  the effects of setting these standards at different levels and for
 different periods of time.  As described in Chapter 5, there appear to be
 virtually no practical effects due to varying the level of protection afforded
 by these requirements over a reasonable range of protection and- considering
 the expected range of engineered barrier performance.  However, there can be
 significant effects associated with different durations of these requirements.
 These impacts were investigated by comparing individual and ground water
 protection requirements established over durations of 100, 1,000, and 10,000
 years.

      Figures 1-3 and 1-4  illustrate the results  of these analyses in  terms of
 potential cost impacts of different durations of the individual and ground
 water protection requirements.   Because engineered barrier performance appears
 to be the most sensitive  variable in determining compliance with these
 provisions,  only the costs of  different qualities of waste packages and waste
 forms were  considered.  From this perspective, there are significant
 differences in the performance  of the different  types of geologic media.
 Because  the natural  characteristics of the salt  sites appear to prevent any
 release  of  radioactivity  due to normal ground water flow for tens of thousands
 of years, there  appear to be no cost  effects associated with setting these
 individual  and ground water protection requirements at any point within the
 range of durations considered.   However,  for the basalt site,  there can be
 major impacts.   If compliance with 10 CFR 60 is  assumed (particularly with a
 1,000-year waste package  lifetime),  there do not appear to be  differences in
 cost between durations of 100 and 1,000 years.   However,  if 10  CFR 60  is not
 considered, then it may cost up  to 15 million dollars per  year  for these
 provisions to extend for  1,000 years  rather than 100 years at  the  basalt
 site.  Whether or  not 10  CFR 60  is considered, the impacts of extending the
 ground water and individual protection requirements to 10,000 years appear  to
 be quite large at  the basalt site.  Waste packages that assured containment
 for almost all of  the 10,000-year period  would be needed,  and these are
estimated to add almost 100 million dollars per  year  to the cost of disposal.
                                      1-6

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    300n
 o>
    200-
1
    100-
                     Salt Repositories
                100
1,000     10,000
                                    Basalt Repository
100
1,000      10,000
                               Duration of individual dose standards (years)
               Figure 1 -3.   Waste disposal costs as a function of the duration of the
                             individual dose standards assuming non-compliance with
                             10CFR60
                                        1-7

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     3CXH
o>
    200-
I
    100-
                     Salt Repositories
                                    Basalt Repository
                100
1,000      10,000
100
1,000      10,000
                               Duration of individual dose standards (years)
          Figure  1 -4.  Waste disposal costs as a function of the duration of the individual
                       dose standards assuming compliance with 10 CFR 60

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     1.4 Summary
     These regulatory impact analyses indicate that the various disposal
standards in the final rule should not cause any increases in disposal cost
when compared to significantly less stringent levels of protection, assuming
that the existing requirements of 10 CFR 60 are met.  For geologic
repositories at the two bedded salt sites considered, there appear to be no
potential increases in costs even if the engineered barrier provisions of
10 CFR 60 are not taken into account.  Only for the basalt site do potential
cost impacts appear when neglecting 10 CFR 60, and these are relatively small:
about 6 to 12 million dollars per year, a value substantially smaller than the
uncertainty in the total costs for disposal of these wastes, which range
between 400 and 700 million dollars per year.
                                      1-9

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                                   Chapter 2

                         REGULATORY GOALS AND BENEFITS


      The program to develop these environmental standards was begun as part
 of  President  Ford's Nuclear Waste Management  Plan,  which was announced on
 October 27, 1976.  President Carter  formed an Interagency Review Group (IRG)
 on  Nuclear Waste Management in March 1978 to  review existing policies.  This
 group recommended that EPA maintain  its  responsibility  to set standards for
 nuclear waste management and disposal and that  the  Agency should accelerate
 its programs  to  do so.  In making its recommendations,  the IRG emphasized the
 public comments  it had received on a draft of its report:

      "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." (IRG 79)

 Shortly after these standards were proposed for public  review and comment
 (on December  29,  1982),  the Nuclear  Waste Policy Act of 1982 (NWPA)  was signed
 by  President  Reagan on January 7,  1983.  The NWPA reiterated EPA's
 responsibilities to develop these standards and called  for their promulgation
 by  January 7,  1984.   The Agency did  not  meet  this deadline,  and the Natural
 Resources Defense Council and four other environmental  interest groups brought
 suit  in February 1985 to compel compliance with the NWPA mandate.   This
 litigation was resolved when the Agency  and the plaintiffs agreed to a consent
 order  requiring  promulgation not later than August  15,  1985.

     This brief  history illustrates  the  general consensus  that creation of
 appropriate environmental standards  is a necessary  preliminary step in the
 national program to develop and demonstrate disposal systems  for  spent nuclear
 fuel and high-level radioactive wastes.  The Agency began its program  to
 develop these  standards  by planning a series of public  workshops  that  were
 conducted in  1977 and 1978 to better  understand the technical issues and
 public concerns  surrounding disposal  of  these dangerous materials.   Based on
 the outcome of these  workshops and its subsequent studies  and interactions
 with the public,  the  Agency has  formulated the  following interrelated
 regulatory goals  that are  addressed by 40 CFR 191:

     (1)   To ensure very good  long-term  isolation of these wastes  from present
 and future populations.  Although these  wastes  are  produced  in relatively
 small quantities,  they are  much  too dangerous to disperse  in  the  environment.
Therefore,  the primary disposal  standards in 40 CFR 191 are  quantitative
containment requirements that  limit projected releases  from  these  disposal
systems over 10,000 years  to levels that appear reasonably achievable
                                      2-1

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 through the current program and that provide ample protection of public
 health and the environment.   The containment requirements apply to
 potential releases from expected performance of  the disposal system and
 to a wide range of possible disruptive events as well.

      (2)  To limit the potential risks caused by the uncertainties^
 inherent in designing disposal  systems that  must keep releases very small
 for such a long time.  The containment requirements in 40 CFR 191 are
 complemented by six qualitative assurance requirements (and by
 corresponding provisions in NRC and  DOE regulations)  that should
 compensate for these uncertainties by calling for cautious procedures and
 design principles to be used for disposing of these wastes.  The Agency
 believes that these qualitative requirements are important for developing
 the necessary confidence that the long-term  containment requirements will
 be met.

      (3)  To accomplish these objectives through limited reliance on
 institutional controls.   Because these wastes will remain dangerous for
 so long, the national program is based upon  disposal systems that should
 not require long-term maintenance and surveillance by future
 generations.   One of the assurance requirements  in 40 CFR 191 limits
 reliance on any contributions from active institutional controls to no
 more than 100 years after disposal.   In addition,  although some potential
 benefits of passive institutional controls (e.g.,  markers, records,
 regulations,  and other methods  of passing on knowledge  about these
 wastes) may be considered,  the  Agency has based  40 CFR  191 on the
 assumption that such passive institutional controls will periodically
 fail to deter inadvertent human intrusion into the disposal systems.

      (4)  To provide protection for  future individuals  in the vicinity of
 disposal systems that is compatible  with the previous objectives.
 Although several of the  assurance requirements serve to reduce the
 chances that  individuals will inadvertently  receive significant exposures
 from these disposal systems,  the proposed rule did not  contain any
 quantitative  design requirements  to  limit individual exposures.  After
 evaluating the comments  received on  the proposed rule,  the Agency has
 supplemented  the containment and  assurance requirements with provisions
 that limit individual  exposures and  radionuclide concentrations in
 certain ground waters  for  1,000 years  after  disposal.   These new
 requirements  apply  to  the  undisturbed  performance of the disposal system
 and  not  to potential  releases from unplanned disruptions.

      In  the simplest sense,  the benefits of  these  standards are the
 health  effects and  radiation exposures  that  might  be avoided if the
 standards were set  at  less stringent  levels.   Such potential benefits can
 be quantified by comparing the  alternative levels  of  protection
 considered in this RIA.  For example,  the benefits of containment
 requirements that limit  long-term health effects  to 1,000  premature
deaths over 10,000 years—compared to  requirements that would  correspond
to 10,000 deaths over 10,000 years—would be the  9,000 deaths  avoided.
                                   2-2

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However, as explained in Chapter 4, the  likely  benefits  from the  chosen level
of protection could also consider the  likelihood  that  relaxing  the  standards
would not actually lead to larger health risks—since  many  of the mined
repositories being considered appear to  keep projected risks well below 1,000
premature deaths by virtue of their inherent characteristics.

     A more important benefit of this  rule, although it .cannot  be quantified,
should be the confidence fostered by environmental  standards that require
disposal of these wastes to be accomplished with  very  good  protection  of
public health and the environment for  many thousands of  years.  In  turn, this
confidence should enable the national  high-level  waste disposal program to
proceed with the key steps needed to develop and  demonstrate a  disposal
system.  In the context of the program mandated by  the NWPA,  these  steps
involve identification, characterization, and comparison of potential  geologic
repository sites.  This part of the program has been delayed for  many  years
(dating back well before the NWPA) by  a  variety of  non-technical  problems,
including State laws that restricted or  prohibited  disposal of  high-level
wastes.  Eventually, once acceptable disposal systems  have  been developed and
demonstrated, the long-term costs and  potential risks  of indefinite storage of
these materials can be avoided.
                                      2-3

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                                   Chapter  3

                            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.   Further,  none  of these  technologies has been
transferred to full-scale production.   Table 3-1 shows the range of costs,  in
units of  dollars per kilogram of heavy metal (uranium or plutonium inserted as
fuel  into a commercial reactor), for the various elements of waste disposal
considered  in  this  analysis.   This framework was assembled from three major
sources  (LE 80,  ADL 79,  and  DOE 80)  for the Draft RIA, and the estimates have
been  updated from a number of more recent studies (WA 82, EN 82, and SC 83)
for this  Final RIA.   To  avoid understating  any relative cost impacts that the
standards might  have on  the  total costs of  disposal,  the cost estimates were
generally chosen so as to minimize (rather  than maximize) the range of
estimates shown  for each element of  the total disposal cost.  Unless otherwise
stated, all costs are in 1984 dollars  and have been  converted from earlier-
year  dollars by  using inflation factors based on the Department of Commerce
Composite Construction Cost  Index (BU  85).

      Table  3-2 shows the same information as Table 3-1, except that the costs
are now displayed as the present value  discounted at two different discount
rates:  2 percent and 10 percent.  These discounted  costs have been included
in response to one  of the comments of  the SAB panel  that reviewed the
technical basis  for the  proposed rule.   The relative effect of different types
of disposal standards will vary for  different discount rates because some of
the costs potentially affected by the  standards occur at different times
during the  process  of selecting, building,  and operating the high-level waste
disposal  system.  To assess  this variation  over time, it was assumed:  (1) that
the earliest costs  (for  research and development)  began to accrue in 1982;
(2) that  two repositories are constructed and begin  accepting waste by 1998;
(3) that  these two  repositories continue accepting waste until 2027—by which
time  they will have  accepted  all the high-level waste projected to be
generated by 2014;  and (4) that these  repositories are decommissioned over  the
years 2028  through  2032.   This time  line ignores the  fact that one of the two
geologic  repositories called  for by  the NWPA should  start accepting wastes  a
few years before  the other, and it assumes  that the  national program will
overcome  delays that  have been encountered  to date and will begin disposing of
waste by  the 1998 deadline set by the NWPA.   However,  these simplifying
assumptions  should  not significantly affect  the conclusions drawn from this
RIA.

     The  following paragraphs discuss the cost estimates for each element of
the waste disposal costs, with particular attention to the four elements that
might be  affected by  the  disposal standards.   In all  cases,  costs are stated
in terms  of dollars per  kilogram of heavy metal ($/kg HM).   This is a commonly
used unit of cost for waste management  and  disposal,  and it allows comparisons
                                      3-1

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                                  Table 3-1

                TOTAL COSTS OF WASTE MANAGEMENT (1984 DOLLARS)
Cost element^

STORAGE

TRANSPORTATION

ENCAPSULATION (Canister)

WASTE FORM

REPOSITORY CONSTRUCTION AND OPERATION

RESEARCH AND DEVELOPMENT

GOVERNMENT OVERHEAD

DECOMMISSIONING
                   Probable*
                     range
                   ($/kg HM)

—not considered in Final RIA
                   24 - 33

                    6 - 15  **

                   10 - 20  **

                   64 -120  **

                   28 - 34  **

                    3-11
                    4-6
                        TOTAL
                                                             139 -239
*Range of costs judged to be likely for the national program  (excludes
  parts of the ranges shown below that probably will not be incurred).

**Cost elements which might be affected by the standards:

                                              $/kg HM  (1984 dollars)
   Assumptions about canister costs:
 very good
 good
 minimum
20 - 40
10 - 15
 6-10
   Assumptions about waste form costs:
 very good
 good
 minimum
14 - 20
12 - 18
10 - 16
   Assumptions about repository
         construction costs:
salt
basalt
64 - 80
71 -120
   Assumed variation of research and
         development costs with
         alternative stringency levels:
 baseline       =     28-34
 [if  risks  within
  factor of 10  of
  standards]    =     42-51
                                    3-2

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                                   Table 3-2

                 TOTAL COSTS OF WASTE  DISPOSAL  (1984 DOLLARS)


                                       Undiscounted          Present value*
                                         costs              discounted at
Cost element                            ($/kg HM)         2%/yr         10%/yr

STORAGE                                     — not included  in Final RIA —
TRANSPORTATION                           24-33         13-18      1.8-2.5

ENCAPSULATION  (Canister)                 6  - 15**        3- 8      0.5-  1.1

WASTE FORM                               10  - 20**        5-11      0.8 -  1.5

REPOSITORY CONSTRUCTION  & OPERATION      64  -120**       38-72      8.4-15.8
RESEARCH AND DEVELOPMENT                28  - 34**       24-29     14.6-17.7
GOVERNMENT OVERHEAD                      3-11          2-6      0.2 -  0.8
DECOMMISSIONING                          4-6          2-2      0.1 -  0.1


                         TOTAL           139  -239         87 -146     26.4 - 39.5


*  Some ranges may be affected by  rounding  approximations.

** Cost elements which might be affected by the standards:

                                         $/kg HM (1984  dollars) discounted at:
                                                          2%/yr       10%/yr

Assumptions about canister costs:        very good   =   11-22    1.5 -  3.0
                                         good        =   10-15    0.8 -  1.1
                                         minimum     =    6-10    0.5-  0.8


Assumptions about waste  form costs:      very good   =    8-11    1.1 -  1.5
                                         good        =    7-10    0.9 -  1.4
                                         minimum     =    5-  9    0.8-  1.2
Assumptions about repository             salt        =   38-48    8.4-10.6
              construction costs:        basalt      =   43-72    9.4-15.8
Assumed variation of research and        baseline    =   24-29   14.6-17.7
     development costs with              [if risks within
     alternative stringency levels:      factor of 10 of
                                         standards]  =   36-43   21.9 - 26.6
                                      3-3

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of the cost of disposing of spent fuel or different forms of high-level  waste
from reprocessing plants.  When used to describe disposal after reprocessing,
the unit $/kg HM does not mean that the heavy metal itself is being  disposed
—since the basic objective of reprocessing spent fuel is to recover and reuse
the unfissioned uranium and plutonium.  Rather, the waste resulting  from the
processing of the spent fuel containing the heavy metal is.disposed  of.   For
each cost element, the anticipated distribution of cost over time is also
shown to support the analyses of discounted costs.

3.1  Storage
     The Draft RIA included waste storage as part of the costs of waste
management and disposal.  The SAB panel recommended that storage costs not  be
considered because they were not affected by the disposal standards  and
because their inclusion tended to reduce the relative (i.e., percentage  of
total cost) effects of different types of disposal standards.  The Agency
agrees with this recommendation, and the Final RIA considers only waste
disposal costs, eliminating the costs of storage from consideration.

3.2  Transportation
     For an average shipping distance of 1,500 miles, including security
precautions, Engel and White (EN 82) estimate $27/kg HM for transporting spent
fuel and $23/kg HM for reprocessed solidified wastes (in 1982 dollars).   These
estimates were based on a blend of rail and truck shipments.  Using  the  larger
of these figures (since transportation of spent fuel should predominate),
correcting for inflation up to 1984, and allowing for uncertainty in these
estimates, this RIA considers transportation costs to range from $24 to
$33/kg HM.  These costs are assumed to be evenly distributed over the time
period that the repositories are accepting wastes for disposal (1998-2027).

3.3  Encapsulation (Canister)
     The encapsulation cost element is the first of the four that may be
affected by the disposal standards.  Unlike the transportation category,  the
type of canister used to contain the wastes can affect the long-term
performance of a repository.  Thus, the costs of using canisters of  three
different qualities were estimated.  These three categories are described in
Table 3-3.

     Waddell, et al.  (WA 82) assume the canisters for the standard,  long-lived
"Westinghouse Package" (steel clad with TiCode-12) cost $8/kg HM for spent
fuel and $6/kg HM in 1982 dollars for solidified reprocessed waste.  This RIA
conservatively assumes that these canisters correspond only to the minimum
performance category shown in Table 3-3.  To meet the requirements of
10 CFR 60, it is assumed that the extra materials and fabrication costs  needed
to make these canisters out of stainless steel and/or titanium would bring  the
total canister cost to $10 to $15/kg HM.  Finally, the RIA considers the costs
of canisters that might be likely to last up to 10,000 years.  The thick
copper canisters considered in the Swedish "KBS" study (KBS 78) are  assumed,
with materials costs that would raise the overall canister costs to  at least
$20 to $40/kg HM.   Even these canisters would not be likely to last  for  so
long in the relatively corrosive environment of a salt repository—but,  as
                                     3-4

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                                   Table 3-3

         PERFORMANCE CATEGORIES AND ASSUMED COSTS FOR WASTE CANISTERS
Very good      =    canister lifetime approaches 10,000 years;
                    KBS-style copper canisters are assumed to be required.
                    Estimated engineering cost = $20-$40/kg HM.


Good           =    canister that would last several hundred years in salt
                    repositories and 1,000 years or more in hard rock
                    repositories—stainless steel canisters would probably be
                    adequate.

                    Estimated engineering cost = $10-$15/kg HM

          [NOTE: NRC's 10 CFR Part 60 requires a waste package lifetime of 300
          to 1000 years. ]


Minimum        =    canister that would last 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 = $6-$10/kg HM.
                                      3-5

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will be seen in Chapter 4, such long-lived canisters do  not  appear to be
needed in a salt repository under any circumstances.   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 judgment.  The costs of the cansiters are  assumed  to be incurred
evenly over the period of waste acceptance (1998-2027).

3.4  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, no published studies are available that 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.

     Recent Rockwell Hanford projections (SC 83) provide a figure of $15/kg HM
(1984 dollars) for a defense-waste-to-glass operation  in a new plant designed
for 180-day-cooled irradiated fuel.  This estimate is  used as  a  basis for  the
Good waste form described in Table 3-4, although it is possible  that this  type
of glass waste form will meet the 10 CFR 60 requirements (which  would then
categorize it as a Very Good form in Table 3-4).  An Arthur  D. Little study
(ADL 79), a DOE study (DOE 80), and another comparative  study  (JA 81)  all
conclude that the costs of different waste forms do not  vary substantially
from one type to another, and the variation that is expected will generally be
less than the overall uncertainty in the cost of any specific  waste form.   To
allow for the potential costs of requiring better waste  forms  in this RIA,
Table 3-4 shows the judgments made about the costs of waste  forms better and
worse than those studied by Rockwell Hanford.  The data  available for
consideration is summarized in Table 3-5.  The $2/kg HM  gaps between these
three ranges probably overestimates the differences in the costs of various
waste forms.  As for the canisters, the costs of the waste form  are assumed to
be incurred evenly over the period of waste acceptance (1998-2027).

3.5  Repository Construction and Operation

     This is the largest single category of costs for waste  disposal.   The
primary uncertainties in these estimates result from the various degrees of
uncertainty concerning costs of mining in the various geologic media.   The
data of Engel and White (EN 82) have been used to arrive at  the  ranges of
repository construction and operation costs shown in Table 3-6 in 1982
dollars.  The decommissioning costs included by Engel and White  have been
subtracted for Table 3-6 because these costs are considered  separately in  this
RIA.  About one-third of the costs shown in the table are assumed to be for
capital construction occurring over the period 1993 through  2001.   The rest
are operating costs occurring more or less uniformly over the  operational
period from 1998 through 2027-  These costs were converted to  1984 dollars for
use in Table 3-1.
                                      3-6

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                                 Table 3-4

         PERFORMANCE CATEGORIES AND ASSUMED COSTS FOR WASTE  FORMS


Very good     =    10~6 -  10~5 parts per year  (ppy)  leach  rate;
                   attainable if ongoing technology  development programs
                   are successful.
                   Estimated engineering cost  = $14  to $20/kg HM.

              [NOTE: NRC's 10 CFR Part 60 requires a long-term waste form
              release rate no worse than 10~^  ppy. ]
Good          =    about 10~^ ppy leach  rate; attainable by glass
                   technologies already  developed and by spent fuel
                   without any special packaging.
                   Estimated engineering cost = $12 to $18/kg HM.


Minimum       =    about 10~3 ppy leach  rate; clearly attainable by
                   glass technologies and spent fuel, might be attainable
                   by very simple waste  forms, such as calcines.
                   Estimated engineering cost = $10 to $16/kg HM.


              [NOTE: Available data indicates that cost variations between
              the different waste forms  now being developed is only about
              $2 to $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 in Table 3-5. ]
                                    3-7

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                         Table 3-5

              COST INFORMATION OF WASTE  FORMS
      Cost
Source
      Comment
   to $15/kg HM
   (1977 dollars)
ADL 79
Range excludes a
low value of $4/kg HM
$10 to $13/kg HM
  (1978 dollars)
DOE 80
$16 to $18/kg HM
  (1979 dollars)
JA 81
Considered some
relatively sophisticated
metal-matrix waste forms.
$15/kg HM
  (1984 dollars)
SC 83
Based on defense waste-to-
glass conversion with
180-day-cooled fuel.
                           3-8

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                        Table 3-6

          REPOSITORY CONSTRUCTION COSTS (EN 82)


                             $/kg HM (1982 dollars) for:

Geologic media            Spent fuel     Reprocessed waste

     Salt                  65 - 77            62 - 70

     Basalt                68 -115            68 - 99
     (taken to be
     similar to tuff)
                           3-9

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 3.6   Research  and Development
      Engel  and White  also  summarize  research and development  cost  estimates in
 their report.  These  include costs of site identification,  site
 characterization, site  approval, construction authorization,  a testing
 facility, technological development, and  related programs.  Stating their
 estimate  on an annual basis, correcting for inflation,  and  allowing for
 uncertainties  produces  a range of $28 to  $34/kg HM  (1984  dollars).   The
 incidence of these  costs over time is assumed to be as  follows:  53  percent
 from 1982 through 1989; 42 percent from 1990 through 2000;  and the  remaining
 five percent from 2001  through 2006.  As  expected, this distributes the
 research  and development costs towards the earlier years  of the  program far
 more than any  other cost element.

      Since  the Draft  RIA was prepared, DOE has identified nine potential sites
 for  the first  high-level waste repository, and the Agency's performance
 assessments offer no  reason to think that more or better  sites need to be
 identified  to  meet  the  disposal standards.  Thus, the possibility that
 different disposal  standards could cause more or less effort  to  identify sites
 no longer seems relevant.  However, the costs of demonstrating compliance with
 the  standards  at a  particular site might be significantly increased if there
 did  not appear to be  a  substantial margin between the standards  and initial
 estimates of projected  performance.  This RIA represents  such costs by
 assuming that  the costs of research and development are increased- by
 50 percent  if  the Agency's performance projections for  a  particular disposal
 system are  within an  order of magnitude less than the standards  of  interest.
 (For  example,  for standards based on 1,000 cancer deaths  over 10,000 years,
 this  RIA assumes the  increase in R&D costs if the performance assessments
 indicate more  than  about 100 deaths—after appropriate  adjustments  for
 engineered controls and other mitigating factors.  This increase was not
 assumed, however, if  there appeared to be a cheaper way to  accomplish  the same
margin of compliance  (by making the waste form better,  for  example).

 3.7   Federal Government Overhead and Decommissioning

     Government overhead is defined as all expenses to the  Federal  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 government overhead were developed  in the Agency's
earliest economic impact study (LE 80) and, corrected for inflation, now range
from  $3 to $ll/kg HM.  Government overhead costs are assumed  to  be  evenly
distributed over the  operational life of the repositories (1998-2027).
Decommissioning costs were estimated to be about four or  five  dollars  per
 kg HM (1982 dollars)  by Engel and White.  A range of $4 to  $6/kg HM has  been
used  in this RIA, assumed to be spent from 2024 through 2032.  Neither of
these cost elements is likely to be affected by the level of  stringency  chosen
for the disposal standards.
                                     3-10

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                                   Chapter 4

        DIFFERENT LEVELS OF PROTECTION FOR THE CONTAINMENT REQUIREMENTS


     A number of considerations are  applicable to  the  selection  of  the  level
of protection provided by  the  containment  requirements (Section  191.13)  of  the
disposal standards.   In this Chapter,  several assessments  relevant  to this
selection are described, 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 repository performance; (c) the correlations  between  repository
performance and cost  relative  to three alternative levels  of protection
(100, 1000, and 10,000 excess  health effects over  10,000 years); and (d) the
economic impacts of variations in  the  cost of high-level waste management and
disposal.  Throughout this Chapter,  residual risks are often referred to in
terms of excess health effects over  10,000 years.   However,  the  reader should
recall the caveats regarding these assessments discussed in  Chapter 1.

4.1  Long-Term Performance Assessments

     The long-term performance of  mined  geologic repositories was analyzed  by
considering many combinations  of waste canister lifetime, waste  form release
rate, geologic media, groundwater  geochemistry, and geologic factors that may
vary from site to site (EPA 85).   To do  this, the  Agency used generic models
of repository sites and designs that are representative of conditions expected
in several of the areas now being  evaluated by DOE as  potential  sites for the
first high-level waste repository.   For  this Final RIA, sites in three
different areas were considered: (1) basalt flows  on the Hanford reservation
in Washington; (2) bedded  salt formations  in the Paradox formations in Utah;
and (3) bedded salt formations in  the Palo Duro basin  in Texas.  These
analyses are intended to provide conservatively high estimates of the risks
from repositories in these areas;  more precise estimates cannot  be made until
specific sites have been selected  and characterized in accordance with the
Nuclear Waste Policy Act.  However,  the  Agency believes that these analyses:
(1) indicate the relative  importance of  the various parts of a repository
system, and (2) provide a  general  understanding of the protection achievable
by different combinations  of engineered  and natural barriers.

     These performance assessments considered the  excess premature cancer
deaths (health effects) that might occur during the first 10,000 years after
disposal.  Ten thousand years  was  used as  the assessment period  for two
reasons:

     1. It is long enough  for  releases through ground  water  to reach the
        environment.  If a shorter time  (such as 1000  years) had been used,
        these estimates of harm could be deceptively low, because ground water
        would take at least 1,000  years to reach the environment at most
        sites.  Choosing 10,000 years for  assessment encourages  selection of
        sites where the geochemical properties of  the  rock formations can
        significantly retard movement of radionuclides through ground water.
                                      4-1

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      2. It  is  short  enough  that  the  likelihood  and  characteristics
        of  geologic  events  that  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.

      These  assessments considered only two different geologic media:
bedded salt and basalt.  Of the  nine sites being considered  by DOE
for the first  repository, seven  are  in salt formations  (four in salt
beds  and three in salt domes), one is in basalt, and one  is  in
unsaturated volcanic tuff.  The  Agency believes that the  performance
projected for  the two bedded-salt models considered in  this  RIA is
probably representative of the approximate behavior to  be expected
of any of the  seven  salt sites.  Analyses that  the  Agency has
recently performed for the tuff  site indicate that  its  projected
releases should be comparable to those associated with  the salt
locations.

      Figure 4-1 summarizes the projections of long-term population
risks obtained by varying canister lifetimes and waste  form  leach
rates while holding  the other factors constant  for  the  models of
bedded salt and basalt.  In evaluating these results, it  should be
remembered that 10 CFR 60 requires:  (1) that waste  packages
(canisters) have lifetimes of at least 300 to 1,000 years and
(2) that waste forms release radioactivity no more  rapidly that one
part  in 100,000 per year.

      Several broad conclusions can be drawn from these  performance
assessments.   First, the geological, hydrological, and geochemical
characteristics of a site can affect long-term population risks more
than major changes in the engineered barriers.  For example,  the
risks associated with using no engineered controls  in one of the
bedded-salt sites are approximately the same as the risks associated
with  using the NRC-required engineered barriers (which  are fairly
stringent) at the much wetter basalt site.  Thus, it appears that
efforts to identify a repository site with appropriate  character-
istics can have greater benefits than efforts to improve  engineered
controls.

     Second, comparing the two types of engineered  controls,
variations of waste form leach rate tend to have more effect on
long-term population risks than variations of canister  lifetime.
Improvements in waste form appear to provide more benefits than
improvements in waste canisters.

     Third, good engineered controls, particularly  better waste
forms, can overcome relatively poor site characteristics.  The
generic model of a basalt repository assumes that relatively large
amounts of ground water are available to dissolve and transport
waste.  In spite of this disadvantage, our basalt model can  achieve
risks well below the limits set by the disposal standards if_ the
                                 4-2

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   10,000-,
   1,000-
2
o
m
o>
     100-
      10-
                                                        1,000 Years
                                    i
       - Existing NRC Waste Form Requirement
             10-6
  T

10-5
10-4
                             Waste form leach rate (parts per year)
10-3
           Figure  4-1.   Health effects as a function of waste form leach rate
                                           4-3

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waste  form used with basalt meets the criteria  set forth  by  10  CFR 60.

     Finally, sites with very good geologic and hydrologic characteristics
apparently do not need any engineered controls  to meet  very  low risk levels.
For example, the projected impacts from our bedded-salt models—which include
very little ground water—do not exceed about 100 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).

4.2  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 requirements.  (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
identified 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 4-2 indicates the  relative
incidence of the residual risks over time from the three  model  repositories
considered in this RIA, assuming compliance with the engineered barrier
requirements of 10 CFR 60 (a 300-year canister lifetime was  assumed  for the
salt media,  a 1,000-year lifetime for the basalt repository model  and a waste
form release rate of 10~^ per year).  All three of these  models would easily
meet the release limits associated with 1,000 health effects.   In  fact,  the
expected health effects are only about 8 for the salt models and 140 for the
basalt model.  For the basalt model, very little of the residual risk occurs
in the first 1,000 years.

     Each of the models was then changed in different ways to allow  the risks
to rise to approximately 1,000 health effects over 10,000 years.   For the
model salt repositories, we assumed that the solubilities of all radionuclides
in ground water were unlimited.  For the basalt repository, we  assumed  poorer
quality engineered barriers than those called for by 10 CFR 60.  Figure 4-3
shows the relative incidence of the increases in the residual risks  that occur
in going from the results of Figure 4-2 to the larger residual  risk  level of
1,000 health effects over 10,000 years.

     In general, there is no consistent pattern in the way the  residual risks
occur for the different models.  Relaxing the isolation provided by  different
aspects of our model repositories results in 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 small.   This illustrates a major reason for the  choice  of 10,000
years—rather than 1,000 years—as the time period for the disposal  standards.
Some of the  characteristics of the models used for Figure 4-3 are  considerably
                                      4-4

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ys
c
8
£
         30i
                            Salt Repositories
         20-
                         Total Risk - 8 Cancers
10-
                                                 30-i
                                                 20-
10-
                                                                 Basalt Repository
                                                               Total Risk ~ 120 Cancers
                   CM
                                          CO      O"
                                                                    CM
                                                                                          CO      O
                                          Time after disposal (years)
                 Figure 4-2. Relative incidence of residual risk for model repositories
                                               4-5

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worse than those that the Agency is confident  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 the long-term  performance  ramifications  of major
differences in site characteristics become  apparent.

4.3  Engineered Control Costs and  the Level of Protection
     Using the analyses summarized in Section  4-1,  the types of engineered
barriers needed to meet different  levels of protection can be  assessed.
Table 4-1 shows the categories of  engineered controls needed to meet the
various levels of protection considered for the salt  and basalt model
repositories.  The different categories of  waste forms and canisters are those
discussed in Chapter 3.

     The information in Table 4-1  can, in turn, be  combined  with the cost data
in Chapter 3 to assign a range of  waste disposal costs to  each level of
protection for each of the two media.  This has been  done  in two ways:
(1) assuming compliance with 10 CFR 60, and (2) neglecting the requirements of
10 CFR 60.  Thus, any effects of the disposal  standards on disposal  costs can
be considered independently of the NRC regulations.   For example,  for basalt
at 1,000 health effects and ignoring 10 CFR 60, the total  costs include the
costs of a "good" waste form and a "minimum" canister;  for basalt at 1,000
health effects and assuming compliance with 10 CFR  60,  the costs include a
"good" waste form and a "good" canister.  (The "good"  canister would be
required by 10 CFR 60.)  Practical requirements of  handling  and transportation
will always require canisters and  waste forms  with  some durability.   Thus,
whenever the performance assessments indicates that no engineering controls
would be needed, the corresponding costs always include a  "minimum"  waste form
and canister.  Wherever only one or the other  type  of  engineered barrier is
needed, the lower cost one is selected.

     Tables 4-2 and 4-3 display the variation  in waste disposal costs with
different levels of protection for both the salt and  basalt  models,  with
Table 4-2 ignoring the requirements of 10 CFR  60 and Table 4-3 assuming
compliance.  The costs of waste forms and canisters are for  those indicated as
necessary by the Agency's performance assessments,  for those required by
10 CFR 60, or for the "minimum" canister and waste  form needed for
transportation and handling—whichever costs are the  least for each
situation.  Also, extra research and development costs  are included  whenever
the projected risks of the disposal system being studied are within  about an
order of magnitude of the level of protection  being evaluated.   These results
indicate that waste management and disposal costs are  not  very sensitive to
different levels of protection, particularly for the geologic  media  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.

4.4  Economic Impacts of Different Levels of Protection

     To estimate the potential economic impacts of  the  different costs that
may be caused by these different levels of protection,  the Agency  first
                                      4-6

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i
£
20-
       10-
                           Salt Repositories
                      Total Risk ~ 1,000 Cancers
                        ^ar"      10      to      o
                                                       30
                                                20'
                                                10-
                                                                Basalt Repository
                                                            Total Risk -1,000 Cancers
                                                         CM"
                                                                               «o
                                          Time after disposal (years)
               Figure 4-3.    Relative incidence of increases in residual risk

                               up to 1,000 health effects
                                          4-7

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                                Table  4-1

    ENGINEERED CONTROLS ASSOCIATED WITH DIFFERENT LEVELS OF PROTECTION
                                 Level of Health Effects
                                   (over 10,000 years)

                       100                1,000              10,000
                    "Good"
                    waste form         No engineer-        No engineer-
SALT                or "good"          ing controls        ing controls
                    canister           needed*             needed*
                    needed
                    "Very good"        "Good" to
                    waste form         "v.g." waste        No engineer-
BASALT              needed             form needed         ing controls
                    (better than       (as req.  by         needed*
                     10 CFR 60)         10 CFR 60)
     *Complete "cost savings"  cannot occur since the practical
       requirements of waste transportation and handling will always
       involve canisters and waste forms with some durability.
                                   4-8

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                             Table 4-2

WASTE DISPOSAL COSTS ASSOCIATED WITH DIFFERENT LEVELS OF PROTECTION

[$/kg HM assuming noncompliance with the requirements of 10 CFR 60]
                       100
Level of Health Effects
  (over 10,000 years)

         1,000
10,000


SALT




BASALT



RC&O
Encap.
W.Form
Balance
TOTAL
RC&O
Encap.
W.Form
ex R&D
Balance
TOTAL
64- 80
6- 10
12- 18
59- 84
141-192
71-120
6- 10
14- 20
14- 17
59- 84
164-251
64- 80
6- 10
10- 16
59- 84
139-190
71-120
6- 10
14- 20
	
59- 84
150-234
64- 80
6- 10
10- 16
59- 84
139-190
71-120
6- 10
10- 16
	
59- 84
146-230
 RC&O    =   repository construction  and  operation costs
 Encap.  =   costs for encapsulation  of waste  (canisters)
 W.Form  =   costs for preparing waste form
 ex R&D  =   extra research  and development  costs because projected
               performance  would be  close to  level  of  standards
 Balance =   other costs,  including transportation,  basic research and
               development, decommissioning costs,  and government
               overhead.
                                4-9

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                             Table 4-3

WASTE DISPOSAL COSTS ASSOCIATED WITH DIFFERENT LEVELS OF PROTECTION

            [$/kg HM assuming compliance with 10 CFR 60]
                            Level of Health Effects
                              (over 10,000 years)

                   100              1,000               10,000


SALT




BASALT



RC&O
Encap.
W.Form
Balance
TOTAL
RC&O
Encap.
W.Form
ex R&D
Balance
TOTAL
64- 80
10- 15
14- 20
59- 84
147-199
71-120
10- 15
14- 20
14- 17
59- 84
168-256
64- 80
10- 15
14- 20
59- 84
147-199
71-120
10- 15
14- 20
	
59- 84
154-239
64- 80
10- 15
14- 20
59- 84
147-199
71-120
10- 15
14- 20
	
59- 84
154-239
 RC&O    =  repository construction and operation costs
 Encap.  =  costs for encapsulation of waste (canisters)
 W.Form  =  costs for preparing waste form
 ex R&D  =  extra research and development costs because projected
               performance would be close to level of standards
 Balance =  other costs, including transportation, basic research and
               development, decommissioning costs, and government
               overhead.
                               4-10

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evaluated  the  impact  of  a 1-dollar increase in the  cost  per  kilogram of  heavy
metal,   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  1 mil/kwh per $233/kg  HM.  This  is  slightly larger  than
the conversion factor DOE used in  formulating  the Carter Administration's
spent-fuel policy, which was 1 mil/kwh  per  $250/kg  HM (DOE 78).  EPA's
earliest 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 it  was  estimated that a  charge of 1 mil/kwh would
increase costs to consumers in the year 1990 by $825  million/year,  assuming
that nuclear power would provide 22 percent 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
1-mil/kwh  charge  would be $700 million/year.   Combining  these figures, an
increase of $l/kg HM  in  management and  disposal  costs corresponds to an
average  annual cost increase to the nation's electricity consumers  of about
$3 million per year for  the years  1980  through 1995.

     To provide some  perspective on these costs, total electric  utility
revenues for 1984 were about $150  billion (DOE 84).   Thus, an increase in
waste management  and  disposal  costs of  $l/kg HM would represent  about a
0.002 percent  increase in average  electricity  rates.  Electricity generated  by
nuclear power  plants  accounted for about $20 billion  of  utility  revenues in
1984.  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)— or with respect
to these gross revenues  from nuclear-generated electricity,  an increase  of
$l/kg HM would represent about a 0.01 percent  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  4-4.

     With  these conversion factors,  the economic impacts of  choosing different
levels of  protection  can now be evaluated.   This assessment  will focus on  the
changes in costs  between the level of protection chosen  for  the  final rule
(risks less than  1000 health effects over 10,000 years)  and  a level  of
protection ten times  less stringent.  As Tables  4-2 and  4-3  show, there  is
only one case  in  which disposal costs change at  all between  the  risk levels  of
1,000 and  10,000  health  effects.   This  occurs  for the basalt model when  the
existing requirements of 10 CFR 60 are  ignored.  In this situation,  the  extra
costs for  an improved waste form to meet the more stringent  level with
confidence are about  $4/kg HM,  which translates  to  an economic impact of about
$12 million dollars per  year.   This  same confidence could be achieved—in  the
structure  of this model—by spending more money  for site characterization
(extra R&D in  Table 4-2);  however,  this would  be substantially more  expensive
than using a better waste form.  Therefore,  the  step  corresponding  to the
lesser economic impact has been assumed.  This potential economic impact can
also be expressed as  an  increase in  average electricity  rates of no more than
0.01 percent and  an increase in the  costs of nuclear  power of less  than  0.05
percent.   Again,  it should  be  emphasized that  this  nonzero impact appears  for
only one of the nine  sites  that DOE  is  currently considering, and then only  if
there is noncompliance with the NRC's existing regulations.
                                     4-11

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                            Table 4-4

       RELATIONSHIP OF ECONOMIC IMPACTS (1984 DOLLARS) TO
        INCREASES IN WASTE MANAGEMENT AND DISPOSAL COSTS
Average annual cost increase to
electricity consumers for the       $3 million/year per $l/kg HM
years 1980 through 1995

Increase in average electricity
    rates                             0.002 percent per $l/kg HM

Increase in nuclear power costs       0.01  percent per $l/kg HM
                             4-12

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                                   Chapter  5

      DURATION OF THE  INDIVIDUAL AND GROUND WATER PROTECTION REQUIREMENTS

      The models  of  geologic repositories in bedded salt and basalt considered
 in Chapter 4 were also used to assess  the effects of choosing different types
 of individual and ground water protection requirements (Sections 191.15 and
 191.16)  for the  disposal standards.   Individual exposures from use of ground
 water at a distance of 2 kilometers  from the edge of the repository were
 projected for a  variety of assumptions regarding waste package lifetime and
 waste form release  rate (EPA 85).   It  turns out that varying  the level of
 stringency of these requirements over  a reasonable range appears to have no
 effect on the costs of mined repositories.   However, the duration over which
 these requirements  are applicable  can  have  significant impacts on the choice
 of geologic media and/or engineered  controls.   Therefore,  this Chapter
 develops estimates  of  the changes  in waste  disposal costs for  establishing the
 individual and ground  water protection requirements over 100,  1,000,  or 10,000
 years after disposal.

 5.1  Long-Term Performance Assessments
      As  in Chapter  4,  sites in three different areas were considered:
 (1)  basalt flows on the Hanford reservation in Washington;  (2) bedded-salt
 formations in the Paradox formations in Utah;  and (3)  bedded-salt formations
 in the Palo Duro basin in Texas.   Individual  exposures from using ground water
 near the repository (at a distance of  2 kilometers) were projected for the
 expected ground  water  flow patterns  at the  site after  the repository  was built
 and filled with  waste.   Unlike the analyses used for the containment
 requirements, no events that could disrupt  the repository or  its geologic
 setting  were considered.   For the  basalt repository, flow through the somewhat
 permeable basalt flows  and the surrounding  aquifers was projected,  taking  into
 account  the thermal stress and temperature  effects caused by  the heat from the
 emplaced wastes.  For  the bedded-salt  repositories, where no  normal ground
 water flow through  the  salt formations is expected, ground water was  assumed
 to flow  down one of the repository shafts,  along the tunnels  of the mine,  and
 then back up another shaft down-gradient from the  first.  Relatively
 conservative assumptions  were made in  a number of  areas (particularly
 regarding the speed and likelihood of  the ground water flow pathway for the
 salt  repositories),  which probably overestimate the amount of  exposure and
 underestimate the time  by which such exposures may begin to appear.

      Figure 5-1  displays  one set of  results from these analyses, showing the
 occurrence of individual  doses over  the first  100,000  years after disposal.
 For  these results,  compliance with the NRC's engineered barrier requirements
 in  10 CFR 60  was assumed  (the waste  package lifetime was taken to be  1,000
 years).    Even with  the  conservative  assumptions made,  individual exposures do
 not  begin to appear for the bedded salt models until well after 10,000 years.
 (The  results  for the Paradox Basin model are shown  as  a dotted line because
 the aquifer  considered  appears to  be so small  that  it  would not qualify for
protection under Section  191.15 as a "significant  source of ground water.")
Therefore,  setting  the  duration of the requirements in Sections 191.15 and
                                      5-1

-------
     100-1
      10-
ra
o>
                                             Basatt
8.     1-
0)

DC
     0.1-
    0.01-
                                                                Paradox Basin
   0.001-
                        1,000
10,000
100,000
                                         Time after disposal (years)
               Figure 5-1.  Individual doses from ground water use at two kilometers
                                             5-2

-------
191.16 at  any  of  the three alternatives considered would not  cause any changes
in the design  of  these bedded-salt repositories  and,  hence, would not  have any
effect on  waste disposal  cost.

     The situation for the basalt model is quite different.   For  the baseline
analysis shown in Figure  5-1,  individual doses begin  to appear  at about 1,500
years after  disposal and  quickly rise to about 2 rems per year  due to
migration  of iodine-129 and carbon-14.   They remain at this level for  about
8,000 years.   They then start  increasing,  as long-lived alpha-emitters that
move more  slowly  through  the ground water  (due to geochemical retardation)
begin to appear at the 2-kilometer point used in the  analyses.  That point was
chosen because it probably will  be typical of the average distance that will
be established between a  repository and the boundary  of the controlled area).

5.2  Engineered Controls  and Individual Protection

     To examine the potential  effects of choosing different types of
individual protection requirements,  the analyses for  the basalt repository
were repeated  with a variety of  assumptions about the canister  lifetime and
the waste  form release rate.   These analyses are summarized in  Figure  5-2.
The initial  dose  rate can be seen to be roughly  proportional  to the waste  form
release rate.  Thus,  for  a release rate of no more than one part  in 1,000,000
per year,  the  initial dose rate  would be about 200 millirems  per  year.   Since
the Agency believes that  this  is still  much higher than any reasonable dose
limitation (and because this is  about the  best waste  form performance  the
Agency thinks  it  is reasonable to project—particuarly for a  spent-fuel
repository), it does not  appear  that choosing different waste forms has any
effect on  the  achievability of reasonable  dose rate limitations.   Similarly,
the lifetime of the canister does not appear to  have  a significant effect  on
the dose level that can be achieved after  the time that the containment
provided by  the canister  is lost.   On the  other  hand,  the lifetime of  the
waste package  clearly has a direct influence on  the amount of time that any
reasonable dose limitation can be achieved.  Thus, the most sensitive  variable
in formulating the individual protection requirements is not  the  level of
these standards,  but the  duration over  which they apply.  Achieving any
reasonable level  of protection depends  upon the  amount of time  over which
waste package  integrity can be assumed.  Thus, the analyses in  Figure  5-2
indicate that—for the basalt model—a  canister  lifetime of many  hundreds  of
years would  be needed to  meet  a  1,000-year duration,  and a canister lifetime
of almost 10,000  years would be  needed  to  meet a 10,000-year  duration.  (On
the other hand, no canister at all appears necessary  to meet  either duration
for the salt models.)

5.3  Engineered Control Costs  and the Duration of Individual  Protection

     The same  steps used  in Chapter  4 have been  used  in this  Chapter to assess
the costs of achieving different durations of individual protection for the
two media considered.   Table 5-1 indicates the different engineered controls
needed to achieve the three durations studied.  Using the assumptions  about
engineered control costs  developed in Chapter 3,  Tables 5-2 and 5-3 display
the variation  in  waste disposal  costs with different  durations  for both the
salt and basalt models, with Table 5-2  ignoring  the requirements  of 10 CFR 60
and Table 5-3  assuming compliance.


                                      5-3

-------
  1,000-1
   100-
g.
0)
     1-
    0.1-
   0.01-
                                        ^^^

                    300 Years
                                                           BASALT REPOSITORY
        Canister
        Lifetime
1,000 Years
      100
              I
           1,000

Time after disposal (years)
                       10,000
            Note: There are no doses associated with bedded salt repositories within this time period
       Figure 5-2.   Annual individual dose from drinking ground water as a
                     function of canister lifetime and waste form leach rate
                                       5-4

-------
     As expected, there is no variation for the salt media, since no
engineered controls of any kind appear necessary to prevent individual
exposures from undisturbed performance for well beyond 10,000 years.  However,
there are substantial cost variations for different durations associated with
the basalt model,  if the requirements of Part 60 are ignored, it would cost
about $5/kg HM to achieve a  1,000-year duration rather than one of 100 years
(or about $15 million per year, using the economic impact factors described in
Chapter 4).  There are no expected additional costs for a 1,000-year duration
if 10 CFR 60 is followed.  To achieve a 10,000-year duration, exceptionally
good canisters would be required.  No such canisters have been considered  in
the U.S. program, so the costs of such canisters can only be a subject of
speculation.  However, based on the probable material costs to make the copper
canisters considered in the  KBS study (KBS 78), an estimate of at least $20 to
i40/kg HM for these canisters has been used.  This would add at least $10  to
lj>25/kg HM to the waste disposal costs, for an annualized cost increase of  $30
to $75 million per year, with a good likelihood that the extra costs would be
even greater (because of quality control considerations in producing canisters
expected to last almost 10,000 years).  In summary, a cost increase of up  to
$100 million per year to achieve individual protection standards near a basalt
repository appears to be a reasonable approximation.
                                      5-5

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                                 Table 5-1

          ENGINEERED CONTROLS ASSOCIATED WITH DIFFERENT DURATIONS
          OF INDIVIDUAL AND GROUND WATER PROTECTION REQUIREMENTS
                                  Duration of Requirements
                                  	(years)	

                       100                1,000              10,000
                    No engineered      No engineered       No engineered
SALT                  controls           controls            controls
                      needed*            needed*             needed*
                                       Good                Very good
                    No engineered      canister            canister
BASALT                controls         needed              needed
                      needed*          (max req. of        (better than
                                        10 CFR 60)          10 CFR 60)
     *Complete cost savings cannot occur since the practical
       requirements of waste transportation and handling will always
       involve canisters and waste forms with some durability.
                                   5-6

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                             Table 5-2

      WASTE DISPOSAL COSTS ASSOCIATED WITH DIFFERENT DURATIONS
       OF INDIVIDUAL AND GROUND WATER PROTECTION REQUIREMENTS

[$/kg HM assuming non-compliance with the requirements of 10  CFR 60]
                    100
Duration of Requirements
	(years)	

         1,000
10,000


SALT




BASALT


RC&O
Encap.
W.Form
Balance
TOTAL
RC&O
Encap .
W.Form
Balance
TOTAL
64-80
6-10
10-16
59-84
139-190
71-120
6- 10
10- 16
59- 84
146-230
64-80
6-10
10-16
59-84
139-190
71-120
10- 15
10- 16
59- 84
150-235
64-80
6-10
10-16
59-84
139-190
71-120
20- 40
10- 16
59- 84
160-260
  RC&O    =  repository construction and operation costs
  Encap.   =  costs for encapsulation of waste (canisters)
  W.Form  =  costs for preparing waste form
  Balance =  other costs,  including transportation, basic  research and
                development,  decommissioning costs, and government
                overhead.
                                 5-7

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                            Table 5-3

    WASTE DISPOSAL COSTS ASSOCIATED WITH DIFFERENT DURATIONS
     OF INDIVIDUAL AND GROUND WATER PROTECTION REQUIREMENTS

          [$/kg HM assuming compliance with 10 CFR 60]
                            Duration of Requirements
                            	(years)	

                  100               1,000              10,000


SALT




BASALT


RC&O
Encap.
W.Form
Balance
TOTAL
RC&O
Encap.
W.Form
Balance
TOTAL
64-80
10-15
14-20
59-84
147-199
71-120
10- 15
14- 20
59- 84
154-239
64-80
10-15
14-20
59-84
147-199
71-120
10- 15
14- 20
59- 84
154-239
64-80
10-15
14-20
59-84
147-199
71-120
20- 40
14- 20
59- 84
164-264
RC&O    =  repository construction and operation costs
Encap.  =  costs for encapsulation of waste (canisters)
W.Form  =  costs for preparing waste form
Balance =  other costs, including transportation, basic research and
              development, decommissioning costs, and government
              overhead.
                               5-E

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                             REFERENCES


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

(BU 85)      Bunger, Byron, U.S.  Environmental Protection Agency.
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            Protection Agency, June 1985.

(DOE 80)    U.S. Department of Energy, October 1980.  Final
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(DOE 85)    U.S. Department of Energy, April  1985.   Monthly Energy
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(EN 82)      Engel, R., and M. White, December 1982.   Fiscal Implications
            of a 1-Mil/kWh Waste Management Fee.  Battelle Pacific
            Northwest Laboratory (PNL-4513),  Richland, Washington.

(EPA 82)    U.S. Environmental Protection Agency, December 1982.
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(EPA 85)    U.S. Environmental Protection Agency, August 1985.
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            Environmental Standards for Management  and Disposal  of  Spent
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            Wastes.  U.S. Environmental Protection  Agency
            (EPA 520/1-85-023),  Washington, D.C.

(IRG 79)    Interagency Review Group on Nuclear Waste Management, March,
            1979.  "Report to the President".  National Technical
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(JA 81)      Jardine, L.J., R.E.  Carlton,  and  M.J. Steindler,  1981.
            Comparison of Costs for Solidification  of High-Level
            Radioactive Waste Solutions:   Glass Monoliths vs. Metal
            Matrices.  Argonne National Laboratories (ANL-80-121),
            Argonne, Illinois.

(KBS 78)    Karn-Bransle-Sakerhet, 1978.   Handling  and Final  Storage of
            Unreprocessed Spent Nuclear Fuel.  Karn-Bransle-Sakerhet,
            Stockholm, Sweden.
                                R-l

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

(SAB 84)    High-Level Radioactive Waste Disposal Subcommittee, Science
            Advisory Board, January 1984. Report on the Review of
            Proposed Environmental Standards for the Management and
            Disposal of Spent Nuclear Fuel,  High-Level and Transuranic
            Radioactive Wastes  (40 CFR 191).  U.S. Environmental
            Protection Agency,  Washington, D.C.

(SC 83)      Schulz, W., M.  Kupfer, and J. Sloughter,  December 1983.
            Evaluation of Process and Facility Options for Treatment of
            Double-Shell Tank Wastes.  Rockwell Hanford Operations
            (SD-WM-ES-023), Richland, Washington.

(SM 85)      Smith,  J.M., T.W. Fowler and A.S.  Goldin,  August  1985.
            Environmental Pathway Models for Estimating Population Risks
            from Disposal of High-Level Radioactive Waste in  Geologic
            Repositories—Final Report.   U.S.  Environmental Protection
            Agency (EPA 520/5-85-026),  Washington, D.C.

(WA 82)      Waddell, J., D. Dippold,  and T.  McSweeney,  December 1982.
            Projected Costs for Mined Geologic Repositories for Disposal
            of Commercial Nuclear Wastes.  Office  of  NWTS Integration
            (ONI-3), Columbus,  Ohio.

(WI 80)      Williams,  W.A., 1980.   Population  Risks from Uranium Ore
            Bodies.  U.S.  Environmental Protection Agency
            (EPA 520/3-80-009),  Washington,  D.C.
                                R-2

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