ORP/CSD-77,1
PROCEEDINGS:
A WORKSHOP ON ISSUES PERTINENT TO THE
DEVELOPMENT OF ENVIRONMENTAL PROTECTION
CRITERIA FOR RADIOACTIVE WASTES
RESTON, VIRGINIA
FEBRUARY 3-5, 1977
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THE UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RADIATION PROGRAMS
WASHINGTON, D.C. 20460
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A
WORKSHOP
ON
ISSUES
PERTINENT TO THE
DEVELOPMENTOF
ENVIRONMENTAL PROTECTION CRITERIA
FOR RADIOACTIVE WASTES
3-5 February 1977, Sheraton Inn/International Conference Center, Reston, Virginia
Sponsored by the Office of Radiation Programs, U.S. Environmental Protection Agency
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This workshop was sponsored by the
Environmental Protection Agency to provide
the opportunity for additional public
involvement in the Agency's process for
developing proposals for guidance and
standards for radioactive waste disposal.
The views expressed by the authors in both
their original contribution and in various
summarized forms throughout these pro-
ceedings do not necessarily represent the
views of the Agency, but are those of the
participants in the workshop.
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A WORKSHOP ON
ISSUES PERTINENT TO THE
DEVELOPMENT OF ENVIRONMENTAL
PROTECTION CRITERIA FOR
RADIOACTIVE WASTES*
CONTENTS
Preface vii
Introduction ix
Summary and Overall Assessment of the Workshop xiii
Opening Address. William D. Rowe xvii
WORKING GROUP 1. APPROACHES TO RADIOACTIVE WASTE
MANAGEMENT CRITERIA DEVELOPMENT
Approaches to Radioactive Waste Criteria Development:
A Statement of Issues and Objectivest 1-3
Approaches to Criteria Development.
Joseph A. Lieberman and Ian A. Forbes 1-9
Geologic Aspects of Criteria Development for
Radioactive Waste Management.
Konrad B. Krauskopf 1-17
Public Ethics and Radioactive Wastes: Criteria for
Environmental Criteria. Margaret N. Maxey 1-23
Approaches to Radioactive Waste Management Criteria
Development: Summary and Conclusions of Working
Group 1 1-39
Response of Workshop Participants to Summary and
Conclusions of Working Group 1 1-45
* This document is the result of a Workshop sponsored by
the Environmental Protection Agency, and held on February
2-5, 1977, in Reston, Virginia.
t These sections of this document were produced prior to
the Reston Workshop by the EPA.
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WORKING GROUP 2. RISK CONSIDERATIONS OF RADIOACTIVE WASTE
MANAGEMENT
Risk Considerations of Radioactive Waste Management:
A Statement of Issues and Objectivest 2-3
Risk Assessment Methods for Nuclear Waste Management
Systems.
P.J. Pelto, J.W. Bartlett, and T.H. Smith 2-11
Economics of Radioactive Waste Disposal.
Stephen 0. Andersen 2-45
Analyzing the Decision on Radioactive Waste Management.
Stephen M. Barrager and D. Warner North 2-55
Remarks for the EPA Workshop on Environmental Protection
Criteria for Radioactive Wastes.
John W. Bartlett 2-69
Risk Considerations of Radioactive Waste Management:
Summary and Conclusions of Working Group 2 2-75
Response of Participants to Summary and Conclusions
of Working Group 2 2-87
WORKING GROUP 3. LONG-TERM IMPLICATIONS OF RADIOACTIVE WASTE
MANAGEMENT
Long-Term Implications of Radioactive Waste Management:
A Statement of Issues and Objectivest 3-3
Control of Radioactive Waste; Issues, Problems, and
Questions.
Terry R. Lash 3-11
The Legacy of Radioactive Wastes: Infinity and Zero.
G. Hoyt Whipple 3-23
Long-Term Waste Management: Criteria or Standards?
Gene I. Rochlin 3-29
The Legacy Question.
H.W. Healy 3-39
Long-Term Implication of Radioactive Waste Management:
Summary and Conclusions of Working Group 3 3-43
Response of Workshop Participants to Summary and Conclusions
of Working Group 3 3-47
IV
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PREPARED STATEMENTS FROM THE PUBLIC
Bruce Rosenthal 4-1
Frederick Forscher 4-7
Pacific Legal Foundation 4-9
Myra Cypser 4-13
W.L. Boeck 4-15
Closing Remarks. William D. Rowe 5-1
APPENDIX A
High-Level, Long-Lived Radioactive Wastes: Concepts and
Comparisonst
APPENDIX B
Attendees at the Reston Workshop
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PREFACE
The authority of the Federal Radiation Council to provide
radiation protection guidance was transferred to the Environ-
mental Protection Agency (EPA), on December 2, 1970, by
Reorganization Plan No. 3. Prior to this transfer, the
Federal Radiation Council developed radiation protection guid-
ance which it recommended to the President for use by Federal
agencies in developing standards for a wide range of radiation
exposure circumstances. In keeping with this function, the
EPA, through its Office of Radiation Programs, will develop
guidance in the form of environmental protection criteria for
radioactive waste to assure protection of the public health
and general environment.
In order to provide a means for interested members of the
public to participate in the criteria development process, the
EPA has arranged to hold a series of public Workshops to
address both the long-term implications and risks associated
with radioactive waste management and disposal. The first
Workshop, entitled "Issues Pertinent to the Development of
Environmental Protection Criteria for Radioactive Wastes," was
held at the Sheraton Inn/International Conference Center,
Reston, Virginia, 3-5 February 1977.
This Workshop was attended by over 250 persons from diverse
backgrounds including the general public, government,
industry, academies. All who attended the Workshop were
afforded the opportunity to participate. The purpose of this
document is to record in summarized form the proceedings of
the Reston Workshop.
VII
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INTRODUCTION
Radioactive wastes (radwastes) are present in a variety of
forms, concentrations, and quantities. These include high-
level (HLW) and transuranic-contaminated waste (TRU), both
produced through activities associated with military weapons
production and nuclear power generation; wastes from medical
and dental radioisotopic applications; uranium mill tailings
and waste products associated with decommissioning activities;
and mining activity wastes, such as phosphate tailings, in
which appreciable quantities of naturally occurring
radioisotopes are redistributed. While present concern
centers strongly about the problem of high-level waste, the
criteria and standards to be formulated must address all forms
of radioactive waste.
In order to establish the ground rules for the discussion to
follow, it is necessary to assign specific definitions to the
terms radioactive waste and radioactive waste management.
Radioactive waste refers to all retained radioactive materials
of no immediate or foreseeable value generated as by-products
of man's activities. Management, as used here, is a generic
term to describe the entire range of options available as to
what to do with the radioactive waste materials and how to
implement the selected options. The management options may be
divided into two basic categories: storage and disposal. The
difference between storage and disposal lies mainly in the
degree of institutional control required to maintain isolation
of the waste from the biosphere. Isolation through' storage
will depend upon engineered facilities and institutional
activities, while isolation through disposal will be achieved
by utilizing the long-term stability of barriers occurring in
nature (e.g., deep geologic stata, such as subsurface salt
deposits, or seabeds).
There is considerable public concern over the technical feasi-
bility and economic practicability of providing environmentally
adequate permanent disposal for all radwastes. Consequently,
the United States is faced with an urgent need for a solution
to this problem. Key questions arise: How soon can we
have acceptable permanent disposal methods for the radwastes
already on hand? How effective will those methods be?
How much will they cost?
To provide answers to these questions, the development and
demonstration of at least one environmentally acceptable
method for the permanent disposal of commercial high-level
radwastes is essential. The first method may not be the one
ultimately or exclusively used, but it should demonstrate that
such wastes can be contained in an environmentally sound
manner.
Future increases in the amount of various radioactive waste
materials in the United States will depend upon the specific
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research policies the country adopts regarding energy pro-
duction, mineral utilization, research, and other activities.
However, regardless of future policies, it may be best
to expeditiously find suitable solutions so that disposal
of all radioactive wastes can take place in a manner which
will ensure adequate protection of the environment and
public health.
Currently, a variety of waste disposal methods appear
technologically attainable. However, careful consideration
must be given to developing the means to evaluate the environ-
mental impacts of the technical alternatives, thus providing
a basis for knowledgeable decision-making, to assure that
those methods selected for implementation will acceptably meet
environmental objectives.
Translating these environmental and public health objectives
into practical solutions requires the active participation and
interaction of the public, industry, and the responsible
Federal and state agencies. Within this framework the U.S.
Environmental Protection Agency (EPA) is conducting a program
to develop environmental radiation protection criteria and
generally applicable environmental standards. In addition to
these activities, specific standards and regulations will be
developed as required by the Ocean Dumping Act, Federal Water
Pollution Control Act, and the Safe Drinking Water Act. The
environmental radiation standards (numerical limits) will be
implemented by the Energy Research and Development
Administration (ERDA) and the Nuclear Regulatory Commission
(NRC) through their respective responsibilities in the field
of radioactive waste management.
The purpose of "A Workshop on Issues Pertinent to the Devel-
opment of Environmental Protection Criteria for Radioactive
Wastes" was to address in-depth issues relevant to the devel-
opment of environmental criteria for all radioactive waste.
Further, the question of standards for high-level radioactive
wastes was also addressed. The information thus developed
will constitute one of the major imputs into formal develop-
ment of environmental criteria by the EPA. This input will be
used, together with technical data, to ultimately formulate
the criteria for radioactive wastes and specific standards
for high-level radioactive waste.
The program provided for a series of formal presentations to
identify possible subjects for discussions and then a division
of the Workshop into small working groups which strove to
develop a consensus on various topics. No relevant subject
was excluded nor were the participants required to address any
prescribed list of points. Rather, material was prepared and
distrubuted to stimulate discussion and then the members of
each working group themselves developed in their first ses-
sions an agenda to be addressed relevant to their own topic.
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There were three formal discussion topics at the Workshop:
Approaches to Radioactive Waste Management Criteria Develop-
ment; Risk Considerations of Radioactive Waste Management; and
Long-Term Implications of Radioactive Waste Management. The
sessions were designed to address key issues in each of the
above three topical areas from all points of view. The format
of the Workshop was kept as informal as practicable, in order
to provide for maximum input from all participants.
Most of the first day consisted of a plenary session during
which invited speakers provided their opinions on key issues
in each of the topical areas. The speakers selected to
provide a well-balanced approach. Additionally, members of
the public who wished to present a formal statement were
allowed to do so, and these presentations are included in this
document.
The remaining day and a half was devoted to the small
participative working sessions, each addressing a specific
topic as described above. Each working group prepared a sum-
mary report on their respective issues, including minority or
dissenting opinions. These Executive Summaries are included
in this document.
This document is a record of the proceedings of the Reston
Workshop. The formal papers of the first day (presented in
their entirety) are included. The Executive Summaries that
were developed in each Working Group at the conclusion of the
Workshop, the Issues and Objectives Statements developed by
EPA prior to the Workshop, and the response of Workshop par-
ticipants to the Executive Summaries as elicited in the dis-
cussion sessions on the last day of the Workshop are all
presented under the appropriate working group topic areas.
Prepared statements from the public are presented in a
section of their own. Finally, a Summary and Overall Assess-
ment of the Workshop is included to highlight the points that
were felt to be of particular relevance to the question of the
development of radioactive waste criteria.
XI
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SUMMARY AND OVERALL ASSESSMENT OF THE WORKSHOP
The major part of the first day of the Reston Workshop con-
sisted of formal presentations by invited participants. These
presentations were, for the most part, fairly general, readily
understandable,and representative of the diversity of opinions
on factors to be included in criteria, as well as approaches
to the problem of development of criteria and standards. The
only exception to this were the presentations on the second
topic, which dealt more with the technical aspects of risk
assessment than with general approaches to the problem.
The first Working Group sessions met at the end of the first
day of the Workshop. Generally, the discussions in these
first meetings were far-ranging, finally focusing on the
problem of identifying points that the group should address
on the second day of Working Group sessions.
After the first Working Group session, the moderator and
selected participants prepared a list of items to be covered
based on discussion held in the first Working Group sessions.
This list was presented to each group on the second day of the
Workshop, discussed and amended as needed. In its final form,
this list was the basis of subsequent Working Group
discussion.
A consensus was developed in each working group on many
points. Opinions also seemed to overlap somewhat from Working
Group to Working Group and are therefore summarized below
without specific reference to the Working Group from which
they evolved.
1. There was a clear consensus that there is now
sufficient information available for the development
of criteria and standards and that the EPA should
thus begin to develop them immediately. This feeling
evolved out of various discussions on disposal
methodologies and techniques and out of the fact that
a significant waste storage problem is waiting for a
solution, i.e., the large amount of high-level waste
which has resulted from the weapons program. Along
these same lines, it was recognized that to develop
one set of criteria applicable to all waste may be
difficult. Therefore, the criteria may have to be
categorized according to some division based on such
factors as concentration, relative hazard, waste
form, and/or disposal techniques. No specific recom-
mendation in this regard evolved. Rather, it was
simply recognized by the participants that one single
overall criterion for all wastes may not be feasible.
2. There was a clear consensus that isolation of high-
level wastes in suitable geological formations was
desirable. It was further recognized, in.this
regard, that any repository would remain the period
Xlll
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when it was receiving the waste. During this period,
monitoring should be carried on and assumptions on
isolation and storage techniques should be checked.
Once the repository is sealed, however, the monitoring
should be unnecessary.
There was a clear consensus that the radioactive
waste disposal method should be independent of the
stability of society. The participants felt that it
is impossible to predict the future and, therefore,
disposal should be carried out in such a manner that
isolation from the biosphere would not depend on any
society.
It was generally felt by the participants that safety
of future generations should be a major factor in
criteria development. Along these same lines, it was
felt that by protecting future generations, we also
adequately protect the present generation. Cost was
felt by the majority to be of secondary importance to
safety, although most felt it could not be ignored.
A few did express the opinion that protection of
present generations and cost were more important than
the protection of future generations. However, it
was also generally felt that the costs of the several
disposal options presently under consideration were
all reasonable. Thus, cost need not be a major
concern if we use any of the presently identifinable
disposal options.
There was considerable discussion about the concept
of "zero" release and "zero" dose. Zero was felt by
some attendees to be desirable as a goal. However,
there was apprehension among other participants who
felt that "zero" should not appear in a criteria or
standard, since it is impossible to attain. Most
participants seemed to agree that the criteria should
specify levels of control which isolate wastes from
the biosphere for the period of concern.
There was a consensus among the participants that
criteria should not be keyed to any one method of
disposal or form of radioactive waste. it was recog-
nized, however, that forms and methods need to be
considered in the formulation of the criteria and
standards.
There was a consensus among the participants that
accidents and unplanned releases should be considered
in the formulation of criteria. Furthermore, it was
felt that traditional risk analysis techniques which
are quantitative in nature should be used to the
extent feasible, although with full recognition of
the fact that quantitative risk analysis is, at best,
an imperfect tool.
It was felt by participants that, to the extent
possible, criteria should take into account the
international implications of radioactive waste dis-
posal. It was recognized that there was little other
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that could be done to control the practices of other
nations. However, it was felt that it should be clear
to all that whatever the United States did should have
no safety implications for other nations and thus our
criteria could serve as an example for others.
9. The question of acceptability of risk was discussed at
great length. This discussion centered around calcu-
lated versus perceived risk. Calculated risk was seen
as important, although it was strongly felt that per-
ceived risk must also be taken into account when estab-
lishing criteria.
10. It was felt by some participants that the risks
associated with radioactive wastes should be placed
in the context of other risks from similar pollutants
or environmental hazards. Further, to the degree
possible, the context should be familiar to the public
so they can see radioactive waste risks in relation
to otheii risks. It was also recognized that the
risks associated with radioactive wastes were in
general, better understood, and that the regulations
controlling it were more restrictive than for other
environmental hazards. Efforts should be made to
improve the controls of other environmental hazards
rather than relax those on radioactive wastes.
11. There was a clear consensus among Workshop partici-
pants that the public, and state and local governments,
should be involved in the decision-making process
on radioactive waste criteria and other such future
regulation and criteria-forming efforts. The clear
expression of the group's sentiment was that "the
decision-making process should be open in fact
as well as in appearance."
The Workshop seemed to achieve its goal of eliciting public
concerns about radioactive wastes. A unique aspect to the
Workshop process was that groups with diverse and often
opposing backgrounds and opinions were able to develop a con-
sensus on certain issues. The net result seemed to be the
feeling that the differences were not so great as one might at
first have believed.
Despite efforts to the contrary, it was apparent that most of
the discussion in this workshop centered around high-level
wastes. It was therefore stressed by the participants that
the next Workshop should more adequately cover other waste
forms, since these disposal problems can be as significant to
public health as those of high-level wastes.
Finally, it was clear that public involvement and public ac-
ceptance were key points to be considered in any process of
setting criteria or standards. The next Workshop should more
fully attempt to deal with these questions.
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OPENING ADDRESS
William D. Rowe
Deputy Assistant Administrator for Radiation Programs
United States Environmental Protection Agency
Washington, D.C. 20460
Ladies and gentlemen, it is my pleasure to welcome you here
today. We appreciate your participation in this endeavor to
address in a fully open working forum, public policy issues
involved in the development of environmental protection crite-
ria for radioactive waste.
I would like to address three particular areas related to the
conduct and purpose of this Workshop. First, I will briefly
describe the Environmental Protection Agency's waste manage-
ment program so you may see how these Workshops and other
types of public participation fit into our overall standards-
setting program for radioactive wastes. Secondly, I would
like to discuss how this workshop will be conducted and how
the material developed will be used. Finally, I will address
the types of issues in waste management that I think must
receive public input.
WASTE ENVIRONMENTAL STANDARDS PROGRAM OF
THE ENVIRONMENTAL PROTECTION AGENCY
The Environmental Protection Agency (EPA), through the Atomic
Energy Act and the Reorganization Act of 1970, has two basic
authorities for setting radiation protection standards that
involve nuclear energy activities: (1) the responsibility to
set generally applicable environmental standards for radioac-
tive materials or exposures outside the site boundaries of
nuclear facilities, and (2) the functions of the former
Federal Radiation Council to provide Federal radiation gui-
dance for all radiation directly or indirectly affecting
health. In the first instance, EPA promulgated in final form
in the Federal Register °f January 13, 1977, generally appli-
cable environmental standards for the uranium fuel cycle.
These standards (which are to be implemented over the next few
years by the Nuclear Regulatory Commission) do not include the
disposal of radioactive waste because they were limited to
planned releases from the cycle and generally involve the
balancing of short-term benefits against similar-term risks.
Waste disposal was excluded from the uranium fuel cycle
standard for at least two reasons. First, up to this time the
objective of waste management has been that there would be no
planned releases to the environment. Second, a different
balancing of risks, costs, and benefits is required for waste
disposal considerations. Any impacts or risks from the waste
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are likely to occur well past the generation in which the
benefits are accrued due to the production of energy. The
risks involved, therefore, exist not only for the present
generation but also involve deferred risks for many years into
the future.
President Ford's message on reprocessing and the export of
nuclear technology specifically required EPA to set numerical
standards for high-level waste by the middle of calendar year
1978. Our program is aimed at achieving that goal. There are
two distinctly interrelated program efforts under way as is
illustrated in Figure 1. The first of these is to develop
criteria on which to base the standards for waste management.
Since we have a new problem in balancing costs, risks, and
benefits, we must ask ourselves how should standards be set in
the waste management area? For example, what is our objective
towards release; are we covered for 100 years, a thousand
years, or for how long; what do concepts such as "as low as
practicable" mean in this context, what things must be taken
into account in setting standards in this area? The issues
that we are addressing today can be most easily focused on
such questions with respect to developing environmental pro-
tection criteria.
In parallel and sometime after the criteria are developed, a
technical environmental assessment of high-activity, long-
lived wastes will be used within the framework of the criteria
to arrive at numerical standards for these wastes. I should
note at the outset that many standards the EPA sets will be
neither site- nor method-specific. The regulation of waste
management operations rests with the Nuclear Regulatory Com-
mission (NRC) whose regulations, when promulgated, will assure
that EPA standards are met. The Energy Research and Develop-
ment Administration (ERDA) is responsible to develop the tech-
nology and operate high-level waste sites in conformance with
NRC regulations. The Energy Research and Development
Administration is also responsible for managing all of the
defense-related radioactive waste throughout the country.
WORKSHOP ON PUBLIC ISSUES
The purpose of this Workshop is to begin to address the issues
involved in setting environmental protection criteria for ra-
dioactive wastes. We hope to elicit maximum participation by
all interested parties, including industry, Federal agencies,
academia, public interest groups, and members of the general'
public. An issue paper has been developed by the EPA staff to
focus on many of the kinds of issues that we expect to be con-
sidered at this Workshop. This document does not profess to
cover all issues; further, it has deliberately not tried to
provide answers to those issues raised. The main purpose of
the issue paper is to identify some topics that ought to be
discussed. This is also the purpose of most of this first
day. People with different points of view have been invited
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CRITERIA
DEVELOPMENT
WORKSHOPS
PROPOSED CRITERIA
/ COMMENTS
PUBLIC \
HEARINGS\
1
1
FINAL
CRITERIA
1
\
ERDA DRAFT
EIS
\ PROPOSED
\
HIGH LEVEL WASTE
ENV.STDS.
L
COMMENTS
FINAL STANDARD
PROMULGATION
PUBLIC
HEARINGS
JAN
APRIL
JULY
OCT
JAN
MAR
JULY
Figure 1. Environmental Protection Agency milestones:
and criteria for radwaste.
environmental standards
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to discuss issues that we ought to be considering as a minimal
agenda before we break up into working sessions.
We have also provided an opportunity (in accordance with the
announcement) for additional issues and points of view to be
developed in written statements. Those received will be
presented either in a working session or, time permitting,
near the end of the plenary session and, of course, will be
published in the proceedings of the Workshop.
The major purpose of the Workshop is to address, in small
participative groups, specific sets of issues from all points
of view in order to derive suggested approaches for solving
these issues. Each working session will have a discussion
leader and all attendees of the session will be equal partici-
pants. The discussion leader's role is to assure that there
is order and that the results are recorded.
Each working session will meet later this afternoon and all
day tomorrow. A summary paper on each session's deliberations
will be prepared by a small representative committee chosen by
the Workshop from volunteers and will include any recommenda-
tions or conclusions arrived at by the group. Majority and
minority conclusions are expected, since many issues probably
will not be resolved to a consensus.
At the last day of the session (Saturday morning) a representa-
tive of each working session will present its findings to a
plenary session so that everybody may know the results of the
various efforts. Further opportunity for discussion will be
provided.
ISSUES FOR DISCUSSION
Any issue may be raised before this Workshop as long -as it
deals with development of environmental protection criteria
for radioactive wastes. There are only two issues for which
I want to provide EPA's position. One issue is institutional;
the other philosophical. First, EPA's role in setting envi-
ronmental standards for radioactive waste is clear and should,
as a matter of policy, not be a subject for consideration at
this Workshop. The Agency has established precedents for
carrying out its responsibility for such environmental
standards in the form of the uranium fuel cycle standard
issued on January 13, 1977, and in both specific and general
Federal radiation protection guidance. The guidance for ura-
nium miners and recent guidance issued on medical x-rays are
examples of the latter.
Although the authority to set generally applicable standards
for high-level waste is definitive, the methodologies and
rationale are open to input on which questions are pertinent,
and suggestions for approach will be given due consideration.
An open process such as this is being used for development of
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these criteria and will, we believe, assure that this occurs.
We believe that this type of open but formal process in
standards is essential for resolution of the radioactive waste
problem. The EPA is convinced that the public should be fully
aware of the difficulties and pitfalls in such problems and
should contribute to understanding of the problem and the de-
velopment of environmental protection criteria that must be
satisfied in its solution.
The second issue involves the need to set environmental
standards for wastes versus decisions on further generation of
wastes particularly by nuclear power operations. There_is no
question that considerable amounts of wastes already exist and
that these must be disposed of by environmentally acceptable
means. Thus, the Agency believes that a program to establish
the necessary criteria and standards for such wastes is
essential regardless of whether any more are generated. At
issue is whether a pragmatic solution for existing wastes
should be applicable to future wastes or whether existing
wastes should meet the same criteria that may be achievable in
the future. In our view, the risks from either should be low
enough to be acceptable, especially when those risks are
imposed with some degree of inequity. We will not, therefore,
cover the question of whether we should stop generating
wastes, because we think the problem is sufficient to require
early attention on its own. The EPA has no regulatory
authority in this area; the question is a broad one and must
involve all branches of government. Without diminishing the
importance of such a question, I will rule out its
consideration at this Workshop, since its discussion here
would only be diversion from our major and amply justified
task of developing environmental protection requirements for
such wastes whether present now or generated later. However,
the factors basic to acceptability of risks may be pertinent
to this Wo-rkshop. Environmental protection requirements
should, after due consideration of such factors, be stated
and these will then determine how future wastes will be
generated and handled according to environmental and public
health requirements established in a public process. If
future activities can meet these requirements, then the
Agency would have no reason to oppose their existence.
All other substantive issues which affect the setting of waste
management criteria are fair game. I hope we can go forward
with the Workshop with a spirit of identifying all the issues,
discussing them openly to get all points of view, defining
where different parties agree and disagree, and devising
fruitful approaches for solutions.
SUMMARY
To sum up, I hope you will keep in mind that this is our first
Workshop for this area and we have a lot to learn; but we
sincerely want to provide the best forum we can to obtain
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public impact before a single environmental protection
criterion is drafted. We would welcome suggestions, which I
am sure we will get during the course of the Workshop, on how
we can better attack such issues with maximum participation.
We will certainly try to rectify any findings at the next
Workshop, which is scheduled for mid-April in Albuquerque,
New Mexico. Thank you.
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WORKING GROUP 1
APPROACHES TO RADIOACTIVE WASTE
MANAGEMENT CRITERIA DEVELOPMENT
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APPROACHES TO RADIOACTIVE WASTE CRITERIA DEVELOPMENT:
A STATEMENT OF ISSUES AND OBJECTIVES
Stated briefly, the environmental radiation protection
criteria for waste management will be a generalized Agency
policy statement detailing the basic philosophy, conditions,
and issues that must be considered and reflected in the devel-
opment of generally applicable environmental radiation
standards and in the selection of appropriate waste disposal
technologies and sites.
For the most part, the environmental criteria will be quite
broad and applicable to all forms of radioactive waste. The
generally applicable environmental radiation standards are
envisioned as numerical limits pertaining to certain types of
radioactive wastes such as high-level radioactive waste.
However, both the environmental criteria and generally appli-
cable environmental radiation standards will be neither site-
nor method-specific.
BASIC PHILOSOPHY FOR ENVIRONMENTAL CRITERIA
The overall goal of EPA with respect to radioactive waste man-
agement is to minimize the adverse health impact to present
and future generations as well as to minimize degradation of
environmental quality. In its efforts to attain this goal,
its actions to date have been based upon the philosophy that
proper waste management is the containment or isolation of
radioactive waste materials until they have decayed to
"innocuous" levels. In this context, containment or isolation
may involve burial, storage, or some other form of assurance
that intolerable dispersion into the biosphere does not take
place. Continuation of this philosophy appears logical unless
it can be satisfactorily demonstrated that selected alterna-
tives (such as certain forms of dispersal to the environment)
would result in less total environmental and public health
impact. If this could be shown, the premise of containment
for all wastes might be unnecessarily restrictive as a basic
philosophy in criteria and standards development and could
require modification. This question should be considered
before the philosophy of the criteria is established.
The development of environmental criteria will have to
consider several philosophical issues, including acceptable
risk and how to determine it, the question of the legacy of
radioactive wastes due to their long lifetime, and to what
extent emphasis should be given to minimizing long-range
impact, potentially at the expense of immediate impact or
vice-versa. Each of these issues has many facets which may
require consideration to differing degrees. If environmental
criteria are to be meaningful, it is necessary that substan-
tial input and discussion be focused around basic philosophical
issues in order to provide a sound foundation for public
policy and action.
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Another important factor to be weighed in selecting radioac-
tive waste disposal technologies and sites is economic cost.
While this may appear to be a practical consideration, it also
strongly relates to the philosophy upon which environmental
criteria and generally applicable numerical radiation stan-
dards would be based. For example, should environmental and
public health protection be fundamental, with cost of disposal
a secondary consideration to be examined after technologies
which would result in acceptable radiation protection have
been identified? Is cost consideration as important as envi-
ronmental protection, with both factors to be considered
simultaneously in seeking a reasonable balance between the
two?
Recognizing that less expenditure may result in less public
health assurance, perhaps the appropriate philosophy would be
to establish a minimally acceptable level of radiation protec-
tion for any disposal of radioactive waste. Resource expendi-
tures necessary to achieve this level should then be accepted
by society. Once this is attained, increased protection could
be obtained to the extent practically and economically achievable.
As a result of the numerous alternatives available in dealing
with cost-risk evaluations, the specific degree to which cost-
effectiveness should form the philosophy for environmental criteria,
standards, and disposal technologies must be clearly delineated.
Further, perhaps it is advisable for the environmental crite-
ria to provide guidance on how to utilize cost-effectiveness
in the development of standards and disposal alternatives.
Guidance might include recommended values for the worth of
averted health effects such as $100,000 to $500,000 per health
effect, or at least a methodology for evaluating such worth.
Further, it might include suggested methodology for uniformly
evaluating cost-benefit or cost-risk.
PRAGMATIC CONSIDERATIONS
Once the philosophical bases for the environmental criteria
have been established, it becomes necessary to translate the
philosophy to practical conditions for the development of
generally applicable environmental radiation protection stan-
dards and the selection of appropriate technological methods
and disposal sites. It is anticipated that acceptable radio-
active waste disposal should be achievable through the combined
use of techniques involving waste processing; containerization;
engineering controls in site selection, construction, and
operation; judicious use of carefully selected environmental
barriers such as geological strata; and preplanned monitoring
programs and emergency response procedures.
While the environmental criteria should not be site- or method-
specific, the conditions and policy positions they establish
should be definitive guidance as to which aspects of waste
disposal are considered of primary importance from the standpoint
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of public protection. The criteria may require definitive
policy positions on aspects such as:
1. The retrievability of the waste over the short- and
the long-term.
2. The relative importance of environmental barriers
such as geological strata versus engineering controls
such as containers.
3. Requirements for long-term care.
4. The need for preplanned emergency response procedures
and monitoring.
5. Methodology for estimating and quantifying potential
environmental and public health impacts.
6. Compatibility of disposal techniques with various
types and forms of radioactive waste.
Clearly all of the topics for consideration in the development
of criteria conditions are not limited to those listed above.
It is anticipated that open discussion of such topics and
others will lead to selecting those of primary public health,
social, political, and economic importance which will provide
for government and industry the information base to achieve
public health protection from radioactive wastes.
In dealing with the long-term management of radioactive
wastes, standards as implemented to date may not be entirely
applicable. The equivalent of routine releases is not neces-
sarily the major problem of concern as much as the potential
for unplanned events (both man-made and natural) which could
alter the functioning of the respository in such a way that
large-scale releases to the biosphere might occur. The
uncertainties regarding long-term institutional stability may
preclude placing reliance on remedial action to recover from
such an incident many years in the future.
To circumvent this problem, a possible approach could be the
promulgation of what may be referred to as "Radiological
Impact Limitation Guides (RILG) .'' The differences between the
concepts of these guides and the present form of standards are
subtle but real, and the distinction should be made. The
guides would apply basically at the design and implementation
stages of waste management facilities to assure that the
conditions described in the RILGs, i.e., the minimally accept-
able upper level radiological impact limit, will be satisfied
over the entire lifetime of a repository, and to assure that
a repository will be designed in such a way as to accommodate,
into perpetuity, all conditions and potential intrusions without
dependence on the existence of institutional capability to
cope with such situations. In this way minimum reliance on
future institutions would be necessary. However, higher economic
costs may result from attempts to provide such assurance.
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SUMMARY OF CONSIDERATIONS
This section has addressed issues, topics, considerations, and
approaches that could be used in developing and establishing
environmental radiation criteria for radioactive waste manage-
ment. It does not necessarily reflect all topics or approaches
but rather is designed to facilitate discussion and evaluation.
Questions which focus on these issues, considerations, and
approaches are listed below to stimulate in-depth discussion:
1. Can and/or should environmental radiation protection
criteria be established on a generic basis addressing
all forms and types of radioactive wastes if
possible?
2. For what kind of wastes or what conditions might
generic criteria not apply? How could these best be
addressed?
3. To what extent should the Agency's basic waste man-
agement philosophy espouse containment or isolation
until decay to "innocuous" levels? Can such a
philosophy be used for all radioactive wastes?
4. How should the criteria consider risk? Should the
Agency recommend methodology for risk evaluation?
5. Should the criteria establish umbrella-type limits on
planned individual and population risks, both for
present and future generations? Standards would
probably then reflect these risk limits as numerical
dose or release values. Should the criteria contain
an assessment of planned risks to individuals and the
population by the most probable release modes?
6. How should the criteria consider legacy? Are
instabilities of institutions paramount in this
consideration?
7. What are the trade-offs between the impacts on
present, near-future, and far-future generations from
radioactive wastes and from waste management deci-
sions made in the present? Is environmental and
public health impact to present, near-future, or
far-future generations most important in criteria and
standards development?
8. How should cost-effectiveness be considered in the
basic philosophy? Is public health protection of
greater importance than cost? Should a minimum
public health protection level be established
regardless of cost? Is geologic disposal too expen-
sive? Is it the only practical approach at present?
9. Should the criteria provide guidance on how to
perform cost-effectiveness and/or benefits versus
risk evaluations? Should a value for health effects
averted be established?
10. How can criteria and standards factor in both the
normal and "accidental" impact factors?
11. Should waste retrievability be maintained for some
time period? For how long and at what cost?
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12. What is the relative importance of environmental
barriers such as geological strata versus engineered
barriers such as containers and waste form?
13. How should long-term care and monitoring be planned
or is it necessary?
14. Should the availability of remedial measures in
the event of an accident be preplanned or, because
of potential institutional instabilities in the
future, should this approach be avoided?
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APPROACHES TO CRITERIA DEVELOPMENT
Joseph A. Lieberman
Nuclear Safety Associates
Bethesda, Maryland 20016
Ian A. Forbes
Energy Research Group, Inc.
Framingham, Massachusetts 01701
Issues related to management of radioactive wastes as
perceived by many members of the public and spokesmen for spe-
cial interest groups currently represent a major obstacle to
more generalized public acceptance of nuclear power. There is
no question that we have already produced substantial quanti-
ties of radioactive waste materials, that production of radio-
active wastes is inherent in the nuclear power fuel cycle, and
that questions related to these materials must be resolved.
The management of existing radioactive waste accumulations and
a wide variety of waste streams in the gaseous, liquid, and
solid state which involve a broad spectrum of radioactive
material and chemical characteristics is obviously required.
Implicit in the term "management" is the requirement of
acceptability in terms of public health protection and envi-
ronmental quality. In this context there are two major
points. First, defining acceptability of risk to radiation
exposure in some quantitative fashion and, similarly, defining
acceptable levels of environmental quality is required.
Second, the physical means for treating, processing, or
otherwise handling the waste materials in ways that the
defined levels of acceptability are met is necessary. From
these two basic requirements evolve the broad variety of sci-
entific, technical, economic, social, and institutional issues
that relate with varying degrees of importance to the subject
of radioactive waste management.
The announcement of this Workshop stated that the Environmen-
tal Protection Agency (EPA) intends to develop environmental
protection criteria and standards for radioactive wastes to
insure protection of the public health and general environ-
ment. Further it states that EPA will concentrate on "general
protection criteria for all radioactive wastes and a specific
numerical standard for high-level, long-lived radioactive
wastes" from the nuclear fuel cycle.
The Issues and Objectives Statements prepared by EPA for this
Workshop also state that "the Agency's overall goal with
respect to radioactive waste management is to minimize
degradation of environmental quality." They further state
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that "its actions to date have been based upon the philosophy
that proper waste management is the containament or isolation
of radioactive waste materials until they have decayed to
'innocuous' levels."
In this connection it is believed important to examine briefly
at the outset some significant implications of these state-
ments, particularly as they relate to the long-term aspects of
management of radioactive wastes. In examining the issue of
long-term potential risk associated with the storage/disposal
of radioactive wastes, including high-level wastes in geologic
formations, the central consideration is not so much the
specific longevity of the wastes or their constituents as it
is the potential mode or pathway of exposure risk for the
population or an individual at any point in time. The nature
of the risk of exposure via a particular pathway is related to
factors of quantity and concentration of radioactive material
and, of course, to time as it affects these factors. However,
pragmatically one might just as well consider the very long-
lived radioactive materials, the transuranics, as stable (like
arsenic or mercury). In simple terms the objectives of
radioactive waste management are:
1. To assure that populations are adequately protected
in relation to their air, water, and food supplies.
2. To assure that individuals (intruders) who might
somehow come in contact with the disposed materials
are adequately protected.
In the former case, for essentially all the waste streams of
concern (with the exception of pure, very long-lived materi-
als) , the situation is clearly dominated by the fission prod-
uct content—more specifically by strontium-90. One must be
assured that there is sufficient containment in the system
so that if or when the material does get into air, water or
food supplies, the concentrations of the critical radionuclide
(strontium-90) will be within acceptable levels.
After about 300 to 400 years (with the hazard to air, water,
and food supplies reduced by two or three orders of magnitude)
the transuranics are controlling. However, it is difficult to
see how, if it can be concluded that the disposal system
provides the degree of protection to the public for the few
hundred years required for the fission products, more rapid
transport and dispersal of the disposed material could take
place without involving tremendous amounts of dilution,
energy, time, or all three in a way that would result in
unacceptable concentrations of radioactive material in air,
water, or foods. In essence, this first objective is,
comparatively speaking, short-term and relates to the quantity
of disposed fission product material available for potential
transport and dispersal, and the specific characteristics of
the transport and dispersal mechanisms and pathways.
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With regard to the second objective, assuming contact with the
waste by a single (or a few) individuals is prevented for the
few hundred years noted above, the protection requirements of
the disposal system are then controlled by the very long-lived
radioactive material and, as noted earlier, we might as well
consider their longevity as though they were stable materials.
We are now concerned with assuring that the individual in-
truder coming in contact with the disposed material will not
take in unacceptable amounts of the material through inhala-
tion or ingestion. This is related entirely to the concentra-
tion of the very long-lived constitutents in the disposed
material. If small quantities of the disposed material, which
might be ingested or inhaled by an intruder, would result in
unacceptable doses; i.e., high concentrations of the long-
lived constituents, then a high degree of isolation—not con-
tainment—(for practical purposes forever) would be necessary.
Hence, the motivation for disposal in geologic formations such
as bedded salt, which have been in place for geologic periods
of time.
In the above comments a distinction is made between "contain-
ment" and "isolation." Containment means keeping the radioactive
material within defined confines of whatever place the
material is put. Isolation means selecting a place where it
would be hard to intrude accidentally upon the material
disposed there. In connection with the first objective
identified above, absolute containment is not required. It
does require, as indicated, a degree of containment high
enough so that any movement of radioactive materials from the
location of disposal will be small enough and slow enough
that, as stated, if and when the radioactive material does get
into air, potable water supplies, or food supplies, the con-
centrations of all radioisotopes will clearly be within ac-
ceptable levels.
Therefore, in general terms we have this two-faceted
situation—protection of air, water, and food supplies of pop-
ulations, which involves the inventory or quantity of fission
products (strontium-90) with a time-frame of a few hundred
years, and the protection of individual intruders from
ingesting or inhaling unacceptable quantities of material,
which involves the concentration of very long-lived
constituents in the disposed material with a time-frame compa-
rable, for practical purposes, to that associated with stable
toxic materials, i.e., of no material significance in
assessing the risk to potential overexposure. Incidentally,
it might be pointed out that when considering the question of
protection of individual intruders against the very long-lived
constituents the limiting levels would be significantly higher
than for protection of populations against the fission product
(specifically strontium-90) content.
With respect to the general protection criteria for all radio-
active wastes it would be useful to elaborate on the
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description and quantification of levels of releases from ra-
dioactive waste sources associated with the range of activ-
ities listed in the Introduction of the Issues and Objectives
Statements prepared by EPA for this Workshop. Specifically,
wastes from weapons manufacturing, military propulsion sys-
tems, research laboratories, hospital facilities, commercial
isotope production as well as the operations comprising the
entire nuclear fuel cycle might well be amenable to the devel-
opment of an impact ranking similar to that of health effects
associated with major radiation sources that EPA has devel-
oped. Such an elaboration would presumably focus on what
waste treatment is currently being applied or is planned, the
risk of adverse effect from waste releases, the costs of
control by source of waste, the benefit of the source, and the
benefit to be derived from incremental levels of control.
This kind of analysis would serve to put the various facets or
segments of the radioactive waste picture in perspective as
well as elucidating the relative risk and potential for public
risk reduction in each area. One might also consider
including naturally occurring radioactivity levels in drinking
water in such an analysis since, at least theoretically, they
are potentially amenable to reduction.
Again within the context of general environmental protection
from all radioactive wastes, it would seem that a reasonable
approach or first cut could be quite similar to that taken by
EPA in its promulgation of Part 190-Environmental Radiation
Protection Standards for Nuclear Power Operations.
Without attempting here to determine or justify a numerical
value of annual dose equivalent to a member of the public not
to be exceeded as a result of waste management operations
(some reasonable increment to the 25 mrem/year of Part 190
might be one suggestion), such an approach would serve to
significantly facilitate the current phase of federal agency
waste management programs. The requirement to assure that
this limit is not exceeded over an extended period of time is,
of course, recognized. This includes the need for analyzing
long-term dose commitments and, where deemed necessary, for
the Energy Research and Development Administration (ERDA) or
the Nuclear Regulatory Commission (NRC) to base control re-
quirements on the results of such analyses. The minimization
of adverse health impact noted in EPA's overall goal with
respect to radioactive waste management previously alluded to
is directly related to the ALARA (As-Low-As-Reasonably-
Achievable) approach which is currently integral to the NRC's
regulatory function. It would appear that the application of
ALARA would be logically carried out by NRC in its development
of specific operational guidance or standards.
This approach is also believed to be consistent with the
responsibility assigned to EPA under the President's Reorgani-
zation Plan No. 3, under which EPA was established and with
EPA's statement of its Radiation Protection Program Strategy
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and its Development Plan for Environmental Protection Crite-
ria for Radioactive Waste Management.
Since EPA has a responsibility for overall environmental
radiation impacts and effects, it is logical that it supply
the broad quantitative guidance to other agencies on the over-
all allowable levels of radiation in the environment
consistent with acceptable risk to the population. This
involves large-scale national and international criteria
and/or standards designed to protect against national or
world-scale buildup of long-lived radioactive products in the
ambient environment. Such concern for potential long-term
impacts of environmental radiation might be considered as an
important focal point for EPA's basis for setting overall en-
vironmental criteria for radiation protection. The general
strategy suggested by EPA, "to focus in order of priority on
controlling exposure to those radiation sources that present
the greatest actual or potential risk for adverse health
effects to the population," is reasonable. The guidelines for
implementation of that strategy need to be more systematic and
quantified, and it is in that context that the need noted ear-
lier for the elaboration of the description, quantification,
means for and level of required control, etc., for all radio-
active waste sources is believed important. This importance
is reflected in EPA's listing of estimated potential health
effects associated with major sources of radiation. Of the
annual total of 10,224 health effects (excluding natural back-
ground and including 8,000 from the healing arts, 1,000 from
construction materials, 800 from weapons, 200 from consumer
products, 100 each from air travel and occupational exposure)
only 24, or slightly over 0.2 percent are estimated to be
associated with the nuclear fuel cycle for power generation.
From this tabulation there clearly arises the question of
relative emphasis being placed on Federal radiation protection
efforts and programs.
The second subject area covered in this Workshop—namely, a
specific numerical standard for high-level, long-lived radio-
active wastes—should also be considered in the light of the
above tabulation. It is indicated by EPA that nuclear power
is a small fractional source of potential radiation risk and
there are analytic indications that high-level wastes from
commercial nuclear power are likely to be but a fraction of
the source of radiation exposure associated with radioactive
wastes overall. Again, the question of relative emphasis on
radiation protection programs is raised.
Before getting into approaches to criteria and standard devel-
opment in the area of high level wastes, it might be well to
recount in simplified fashion the institutional framework
within which the criteria, standards, etc., are being
addressed and by whom. For present purposes the institutional
framework is somewhat narrowly defined as the major federal
agencies having assigned responsibilities and authorities
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relating rather directly to management of high-level wastes.
The government policy as described in the White House Fact
Sheet released October 28, 1976, is probably as good a basis
for such definition as any and specifically indentifies ERDA,
NRC, and EPA as having specific roles in the "President's Nu-
clear Waste Management Plan" and time lines for accomplishing
their assignments, all culminating in "initial commercial-
scale operation" of a federal high-level waste repository in
1985. In separate actions not under the "President's Plan,"
ERDA also plans to have a waste repository for defense wastes
in place by 1983. While other federal agencies such as U.S.
Geological Survey, U.S. Coast and Geodetic Survey, and Bureau
of Land Management, will undoubtedly be involved in the
program in one way or another, and perhaps importantly with
some specific guidelines, criteria, or standards, their
detailed participation need not concern us for the moment.
As currently reflected in the federal commercial high-level
waste management program, ERDA has the responsibility for the
research, development, and testing for the high-level waste
solidification, packaging, transport, and emplacement in a
federal repository. It also has the job of locating,
designing, constructing, and operating the federal repository.
Although all detailed decisions may not yet have been made, it
is reasonably clear that the commercial high-level waste man-
agement system being implemented in this program consists of
solidification (calcination and/or vitrification) of high-
level liquid wastes, appropriate packaging, transport, and
emplacement in a deep halite (salt) formation. In light of
the current uncertainty regarding spent fuel reprocessing, the
capability of handling spent fuel in the repository obviously
must also be an integral part of this program. This would
entail among other things appropriate consideration of the
effect of larger quantities of plutonium contained in the
disposed material.
The NRC has the job of "licensing" this system. Licensing is
in quotes only because at present it is not quite clear as to
the procedures by which such a licensing process will be
carried out.
The EPA is indicated as having the responsibility of this year,
i.e., 1977, to "draft generally applicable standards for per-
manent storage of high-level wastes," and by mid-1978 issuing
"final general ambient standards for high-level waste disposal."
It is apparent then that ERDA will have to be engaged in
developing a broad variety of guidelines, criteria, standards,
and specifications in order to assure that the entire system
performs in accordance with design specifications. The NRC
somewhat similarly will have to develop a set of guidelines
criteria, standards, etc., as a basis for "licensing" the sys-
tem, i.e., presumably the bases for concluding that it can, or
cannot, be located, built, and operated "without undue risk or
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hazard to the public." The EPA in effect defines the environ-
mental levels of radiation that might be considered as equiva-
lent to "without undue risk or hazard to the public."
In addition, ERDA must prepare its general and specific envi-
ronmental impact statements and NRC has to prepare its envi-
ronmental impact statement. The EPA has a responsibility for
reviewing and commenting on the environmental impact
statements. The EPA in its preparatory paper recognizes the
significance of economic costs in relation to the environmen-
tal criteria and generally applicable numerical radiation
standards. This recognition suggests that it might be
appropriate for EPA to prepare an economic impact statement in
connection with its proposed criteria and standards.
There are, of course, a wide range of specific issues related
to a specific high-level waste management system for which
suitable (i.e., acceptable) criteria must be developed by ERDA
and/or NRC. A brief and certainly not all-inclusive listing
serves our current purpose.
1. Waste Solidification Facility (WSF):
a. Secondary waste stream D.F. requirements, ALARA
requirements for WSF
b. Solid waste product specifications—leachability,
thermal stability, temperature limits, etc.
2. Packaging:
a. Package specifications-canister size, temperature
limitations, heat density, shock resistance, sec-
ondary containment requirements, etc.
b. Design considerations-stress imitations closures,
leak detection, QA requirements, accident
considerations.
3. Transport:
a. Cask design and operational requirements—
shielding, heat dissipation, shock resistance,
weight-size limitations.
4. Repository:
a. Site selection and approval criteria—
geophysical, environmental, demographic
b. Environmental and safety assessment—bases,
models, allowable levels
c. Design basis accidents
d. Operational criteria and standards—halite forma-
tion temperature limitations, ALARA requirements,
retrievability requirements, surface land use
criteria.
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Within the institutional and issues framework briefly de-
scribed, the role of EPA and its approaches to criteria devel-
opment relative to high-level waste is addressed.
First of all, it is pertinent to differentiate between EPA's
criteria/standards setting role and its review/comment/
advise/compliance role. With respect to the former, it seems
reasonable to suggest that an approach quite analogous to that
previously noted for the overall waste picture would be in
order. That is, an equivalent annual dose limitation to
persons and populations outside the control of the facility
could be applied to the management of high-level wastes. The
application of the ALARA philosophy could be carried out as
previously noted. Indeed, in a quantitative sense the values
for high-level waste management might well be included under
the umbrella developed for the overall waste picture. Adher-
ence to these standards and application of ALARA would then be
a question of compliance by ERDA and NRC in carrying out their
location, design, construction, operation, and licensing
functions.
With respect to the latter review/comment function, EPA should
not require completely independent detailed pathway/dose/risk
assessment models and analytical methods. While EPA might
well need the capability to examine the validity of various
assumptions and bases inherent in assessment models and ana-
lytical methodology, it seems reasonable to suggest that this
function, and the development of appropriate models, can most
effectively be discharged through a preferably formalized,
coordinated interagency effort. Such a coordinated interagency
effort would also ensure timely resolution of philosophical or
methodological differences. This is particularly important in
the development of appropriate models and their application to
potential long-term impacts.
Another point related to the long-term cost-benefit aspects of
the generation of commercial nuclear wastes is that the
benefits derived from nuclear power generation include, among
other things, not only the conservation of our coal and
hydrocarbon resources for future high-value use, but also the
reduction of wastes resulting from the combustion of these
resources. Accordingly, long-term cost or cost-benefit
assessments of wastes from commercial nuclear power should
include consideration of the long-term cost associated with
equivalent fossil fuel use, i.e., the C02, SOX, NOX, heavy
metals, and solid wastes.
Finally, I would state the strong conviction that we have the
capability to establish nuclear waste management systems that
can and will protect the public health and our environment. It
sorely behooves us to take the implementing actions, both
technically and administratively, and get on with the job in
an expeditious and effective manner.
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GEOLOGIC ASPECTS OF CRITERIA DEVELOPMENT FOR RADIOACTIVE
WASTE MANAGEMENT
Konrad B. Krauskopf
Geology Department
Stanford University
Stanford, California 94305
My background is in geology, and my comments in this paper
will be directed to geological considerations involved in
establishing criteria for radioactive waste management. Geol-
ogy affects the setting of criteria in two principal ways:
first, by providing data on natural background radiation; and
second, by giving a basis for judgment about the certainty of
containment of radioactive waste in disposal sites.
The radiation from waste, dangerous as it may be, is only an
augmentation of natural radiation to which we are all expsoed
every day of our lives. This fact is widely known, but often
not sufficiently emphasized. The kinds of radiation are the
same, and the effects on organisms are the same. In seeking
to reduce waste-generated radiation to a minimum, we are not
dealing with a new and necessarily evil product of technology.
We are rather trying to control a gross increase in one of the
factors in our natural environment. In setting standards for
acceptable limits of exposure, we cannot hope to reduce
radiation below natural levels.
Natural levels prove to be very diverse. Radiation in our
environment comes from many sources: cosmic rays from outer
space; radioactive elements widely distributed in rocks, soil,
and water; and radioactive carbon and potassium in our own
bodies. In civilized society these are augmented by radiation
used in medical and dental diagnoses and treatments, and minor
amounts from television sets, luminous watch dials, and air
travel at high altitudes. Exposure of individuals to all
these sources varies widely from time to time and place to
place. The average individual exposure to purely natural
radiation in the United States, for example, is about 130
millirems (mrem) per year, but fluctuates within about 15
percent of this figure at any one place. The amount varies
over the country from an average of 250 mrem/year for Colorado
and Wyoming to 100 mrem/year for Louisiana and Texas. The
amount of medical and dental radiation obviously varies
greatly from one individual to another. People who live in
brick or stone houses receive about 40 mrem more per year than
those whose houses are made of wood, because of the traces of
radioactive elements in such materials. Individuals in
certain types of occupations receive much more radiation expo-
sure than the average person: crew members of high-altitude
jet aircraft, for example, are exposed to an average of 670
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rarem/year, and uranium miners are exposed to considerably
more.
There is not the slightest evidence that those exposed to the
higher levels of natural radiation are thereby harmed. That_
harm is actually done but is not apparent in the statistics is
possible. On one side are those who feel that any radiation
whatsoever is harmful, and that the lack of evidence merely
reflects difficulty in obtaining statistics about small
effects in large populations over long periods. This argument
depends on extrapolation from data on the very damaging
effects of large doses of radiation. If, for example, the
probability of dying from cancer is 20 percent after exposure
to 1 million mrems of radiation, the probability after expo-
sure to 100 mrems would be 0.002 percent. The validity of
such an extrapolation is not known. On the other side of the
argument are those who question the extrapolation on the
grounds that human beings have lived in the presence of low-
level radiation for something like 3 million years, and that
living tissue is well known to be capable of repairing damage
that may occasionally be done by brief exposure to low-level
radiation. The argument is impossible to settle on the basis
of present knowledge. Conceivably humankind would suffer
fewer ills if people could live in a completely radiation-free
environment, but this is a hypothesis that would be very
difficult to prove.
From a geologic point of view, the hypothesis that very low-
level radiation is harmful seems strained. A geologist is
acutely aware of the extreme differences in amounts of the
radioactive elements uranium, thorium, and potassium contained
in different parts of the earth's crust, and also of the
extraordinary adaptability of organisms to their surroundings.
He can look back over the 600 million years during which
higher organisms have evolved, and note that at the beginning
of that time radiation on the earth's surface was considerably
more intense than it is today. He may even wonder whether
radiation in small amounts might not actually be beneficial to
living things, since they have evolved in its presence. But
clearly again this is another unsubstantiated hypothesis.
The constant presence of natural radiation in widely varying
amount makes the setting of criteria for radioactive waste
management very difficult. Ideally, we could set up a "zero-
release" criterion, requiring that waste should be so
effectively isolated that it could make no addition to natural
radiation. But what level of natural radiation: The average
for the country, the amount in the immediate vicinity of the
disposal site, or the higher intensities characteristic of
some large areas? Does a zero-release requirement make sense
when slight additions to the ambient radiation would not bring
the total even close to amounts characteristic of some parts
of the country where the population shows no ill effects?
These are questions that have no scientific answer, because
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the data on which an answer could be based are lacking and
will be lacking for a long time to come. Prejudice based on
geologic orientation would suggest a fairly relaxed criterion,
to the effect that radiation from wastes should not be
permitted to increase the total radiation exposure in a
given area to more than some of the higher natural values,
say 200 or 300 mrem/year to an individual. But this geological
bias must be weighed against prejudices of many different
sorts.
The second way in which geology can have a bearing on the
establishment of criteria is in evaluating the probable
effectiveness of various proposed methods for long-term
isolation of radioactive wastes from the biosphere. A geolo-
gist is more accustomed than most to thinking about the long
time periods, up to at least a few hundred thousand years,
during which the wastes must remain isolated. Perhaps just
for this reason—because of his intimate acquaintance with the
kinds of geologic disturbances that can occur in. such long
intervals—he is more cautious than many in making pronounce-
ments about the absolute safety of any disposal method.
The suggested method currently in greatest favor for handling
high-level wastes involves solidification of liquids and buri-
al of the resulting solids in caverns excavated in rock at
depths of 300 to 1,500 m. Such burial sites would be subject
to the usual kinds of geologic calamities—exposure by
erosion, and disturbance by earthquakes or volcanic activity.
A geologist can give almost complete assurance against this
sort of occurrence simply by recommending sites where erosion
over the next million years will be slow and where rocks and
rock structures indicate that earthquakes have been minor and
volcanic eruptions nonexistent for a long time in the past.
The greatest danger is none of these, but the possibility that
groundwater may penetrate to the entombed waste, dissolve some
of the radionuclides, and transport them to the surface. Once
they reach the surface, the radionuclides can contaminate
drinking water, be taken up by food plants and animals, or
become part of soil and dust to be transported by wind. The
picture of active radionuclides flowing to the surface in
large quantities from a breached bedrock cavern can be made to
look very grim.
No geologist can make a firm statement regarding the
possibility of some leakage from underground storage in the
course of a million years. However secure a given site may
look at present, changes in climate, minor rock movement, or
human activity might conceivably permit access of water. Cur-
rent thinking favors salt, either bedded or in domes, as
material in which waste could be most safely disposed, on the
grounds that salt has desirable mechanical and heat-conduction
properties as well as great impermeability to water. Another
promising material is shale, also known to be highly
impermeable. Some kinds of crystalline bedrock—carbonate
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rock, granite, basalt—are also under active investigation.
It seems probable that all of these materials, in carefully
selected localities, will prove suitable for waste disposal.
If this is true, a multiplicity of disposal sites consisting
of different materials and in different parts of the country
might be preferable to a single site. Large numbers of sites
would be advantageous in that only a small amount of waste
need be placed in each one, so that even an unforeseen catas-
trophe could not lead to contamination of a large area. With
regard to selection of sites and probabilities of groundwater
contamination, a geologist can give good advice, but he can
never state categorically that no leakage whatever will occur
from any given place.
Suppose that groundwater does reach an underground disposal
site and then percolates through rock to emerge in a seepage
some kilometers distant. What would be the consequences? In
this situation, a geologist can speak with more assurance. He
knows the rate of groundwater movement under various condi-
tions, and he would surely have selected the site at a place
where movement was slow, say a few centimeters per day at the
most. Ke would also have chosen a site where any conceivable
path of movement to the surface would be long—certainly tens
of kilometers. This means that any water that had been in
contact with waste would not reach the surface for hundreds of
years at a minimum. The solid material in which the waste was
incorporated (glass or ceramic) would be extremely insoluble,
so that leaching of the radionuclides would be slow. The ions
that did get into the moving groundwater would be, for the
most part, absorbed on mineral surfaces in the rocks through
which they move. Actual measurements at Hanford show that the
most dangerous of the fission products (strontium-90 and cesi-
um-137) would move at least a hundred times more slowly than
the groundwater because of absorption, and plutonium at least
10,000 times more slowly. Thus a geologist can say
confidently that a little groundwater and a tiny amount of
radioactive material might conceivably reach the surface in
the course of a million years, but that a massive movement of
radionuclides from the disposal site is all but impossible.
We therefore come back to the question of how much addition to
ambient radiation would be tolerable. Disposal of waste in
bedrock can be made so secure that any leakage at all would be
exceedingly unlikely. Complete assurance cannot be given that
a tiny fraction of the radioactive material will not appear at
the surface after a very long time; if such assurance is
demanded, the whole nuclear energy enterprise may as well be
abandoned. The maximum amount that might be released can be
estimated with considerable confidence, and it would assuredly
be minor in comparison with natural radiation. The setting of
criteria must involve judgment about the amount of possible
release that would be permissible and about the degree of
confidence that can be placed in estimates of possible ground-
water movement. From the standpoint of the author, the chance
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of escape of radionuclides in amount sufficient to harm future
generations seems completely negligible.
A confirmed skeptic can always maintain, of course, that geo-
logic predictions of future events are necessarily unsure,
that unexpected climatic changes or rock movements might
breach the most carefully designed bedrock cavern, that the
nonleachability of solidified waste cannot be guaranteed for
a million years, that future mining or drilling operations
might by intent or by accident expose the stored waste, and
that the long-term effects of radiation exposure are so little
known that no addition to ambient radiation for this or future
generations can be tolerated. An extremist on the other side
can point out that escape of radionuclides from a properly
constructed bedrock disposal site is extremely unlikely, that
it can be made even more unlikely by providing paths for
groundwater around the site and by adding materials that would
be more effective adsorbents than ordinary rock, that bedrock
sites would presumably be monitored so that corrective action
could be taken at the first sign of difficulty, and that any
remote chance of massive escape can be avoided by dispersing
waste in many disposal sites rather than only a few. This
argument has gone on for many years, and will doubtless
continue for many more.
Basically the question is how much risk society is willing to
assume to gain the benefits of a technological innovation,
with the added complication that the benefits will be enjoyed
by this generation while the risk is assumed by generations to
follow, into a remote future. The setting of criteria
involves weighing this risk in a context where some of the
basic data for evaluating the risk are imperfectly known. How
much radiation in addition to that already present on the
earth's surface is acceptable, given that the ambient
radiation varies widely in time and space, and that firm data
on the long-term effects of low-level radiation are
unavailable? How much assurance is needed for the integrity
of geologic burial sites, and what estimated radionuclide
release would be tolerable in case of remotely possible
accidents, given that geologic knowledge does not permit firm
extrapolation for times on the order of a million years? These
are questions that must enter any assessment of risk and any
attempt to set criteria for waste management.
They are difficult questions, and their answers can come only
from a balance of many viewpoints. The author has suggested
answers but they are necessarily those of a prejudiced scien-
tist. Even among scientists there is wide diversity of
opinion, so that science can provide no sure guidance. Scien-
tists can describe the available data and point out their lim-
itations as has been attempted in this paper, but decisions
about criteria involve subjective aspects beyond the purview
of science.
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PUBLIC ETHICS AND RADIOACTIVE WASTES:
CRITERIA FOR ENVIRONMENTAL CRITERIA
Margaret N. Maxey
Associate Professor of Bioethics
University of Detroit
Detroit, Michigan 48221
An ethicist has recently remarked that whenever someone
announces that the public needs to define and consider "the
ethical and moral issues," the phrase usually "heralds the
frustrated end of a discussion, or the beginning of a muddled
argument" (Ref. 1). Judging from my experience to date, both
as spectator and participant in radwaste discussions, the
remark can be verified to a disquieting degree. I use the
term "disquieting" not to impugn the competence or intentions
of any person involved, but rather to call attention to a fun-
damental problem.
Many of those who invoke the phrase "ethical and moral issues"
have a feeling that there is something worrisome about an
action or social policy, but they also feel frustrated--unable
to define precisely what it is, or why they feel it is
bothersome, much less how to go about resolving it (Ref. 1).
INTERPRETATIONS
At least two interpretations of this state of affairs have a
direct bearing on the subject of this Workshop. One inter-
preter, Hans Jonas, has made a compelling case that the root
of this disquieting problem lies in the very concept of ethics,
which many practitioners take for granted when attempting to
define issues and devise criteria for their resolution
(Ref. 2). This concept has assumed that the effective range
of consequences of human action—hence human responsibility--
is confined to the here and now, to known and intended
effects, to defining "the human good" as a manifestation
of the moral quality of "neighbor values"--justice, truth-
telling, freedom, respect for individuals. Ethical codes
for behavior in public and private life are a reflection
of this value system. So conceived, ethics is anthropocentric,
with the nonhuman world of nature serving as a backdrop,
an ethically neutral instrument subject to human purposes.
But science, technology, and a population explosion have
drastically changed the causal scale of human activities, as
well as our integration within nature's complex, delicate web.
As a consequence, traditional ethics has become increasingly
problematic, because it is too individualistic, too short-
sighted and piecemeal in its definition of issues, goals,
and moral responsibility. When confronted with awesome
changes in the range and power with which human actions have
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global effects continuing into future generations, a tradi-
tional "neighbor ethic" is inadequate to the task of defining
criteria for effecting "the human good."
Instead of succumbing to frustration or paranoia, Prof. Jonas
urges us to recognize that nothing less than a new concept of
ethics commensurate with the new scope of human action is
necessary. We must enlarge our perspective, not only with a
more comprehensive time horizon, but also with a moral calcu-
lus shaped by a new set of imperatives. For example: "Act so
that the effects of your action are compatible with the
permanence of genuine human life;" or, "Do not compromise the
conditions for an indefinite continuation of humanity..."; or
again, "In your present choices include the future wholeness
of human persons among the objects of your decisions" (Ref. 2).
These imperatives imply, of course, a primary obligation:
namely to acquire and disseminate an unprecedented degree
and quality of accurate knowledge—both presently verifiable
and predictive.
According to a second interpretation, the current problem
about defining ethical issues should likewise be traced to an
inadequate concept of ethics—but with an important differ-
ence. The difficulty is not simply that classical ethics is
too individualistic and limited in its time horizon to
identify and balance competing short- and long-term social
values. Its principles are also too remote and theoretical,
too generic, vacuous and indefinitely interpretable. Not only
is a new genus of ethics required by changes in the scale of
human action, but also a new subspecies—"public ethics" (Ref. 1)
Conventional social ethics deals with issues about what
constitutes the "good" or "right" ordering of human communities,
and shaping long-term changes in social policies. By contrast,
public ethics must meet a different set of exigencies:
1. It must deal with a precise problem about which a
particular public decision must be made.
2. This matter of public concern is pressing; the
problem must soon be resolved and implemented.
3. The decision to be made is, as a matter of prudential
judgment, neither intended nor expected to force
profound structural changes in the social order.
Current practitioners of public ethics have (with deceptive
modesty) set forth three tasks for themselves:
1. They propose to confront vague, confused assertions
about "moral and ethical issues" by exposing the
hidden principles or reasons or conflicting values
that lie at the root of a public concern, so
as to transform them into an ethical argument
that clarifies what can or cannot be justified.
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2. Secondly, they endeavor to identify policy options,
and then defend or criticize them by appealing to justifying
reasons.
3. Finally, they propose to rank these policy alterna-
tives in some order of ethically and morally
preferable choices.
The practitioner of public ethics hastens to insist: the
process of ranking policy alternatives necessarily involves
assessing risks (personal and collective) over against
benefits; weighing social and economic costs over against
compensations; balancing a hypothetically fanciful, versus a
verifiably predictable, erosion of the quality of life in the
biosphere. Far from being merely crass utilitarian "trade-
offs," these exercises in human judgment are the sine_gua_non
of responsible ethical decision-making. They are antidotes to
moralizing apprehensions. They tranquilize emotional
prejudgments. Above all, they reflect the harsh necessity of
enduring the uncertainty and risks entailed in making unprece-
dented policy decisions.
Since it is situated at the interface between ethics and poli-
tics, public ethics cannot indulge in the luxury of rarefied
abstractions, indefinitely interpretable criteria, or vapid
precepts. To the extent that politics is "the art of the pos-
sible," public ethics endeavors to practice "the art of discerning
the morally preferable among the practical possibilities" (Ref. 1).
In order to be translated into actions and social arrangements,
public ethics must meet three criteria. (1) Whenever values or
principles are in conflict, the test of adequate and accurate
knowledge of both risks and benefits must be met in an attempt
to bring a balanced perspective to the conflict. (2) Secondly,
since its purpose is to facilitate rather than postpone or
impede action, an assessment of alternative policies must be
based on practicable, demonstrable possibilities, not ficti-
tious or fanciful scenarios. (3) Third, in ranking policy
options, the criterion for moral preference among practicable
possibilities must recognize our obligations to future
generations, but not at the expense or to the neglect of a
bias toward two priorities. One is that the obligations we
owe to the living outweigh any claims of future generations,
and our duty is to protect, not simply "mere survival," but
also those conditions fundamental to human dignity and
fulfillment. The second is that the fundamental needs of
living persons are the justifying reason for preserving a
sustainable environmental quality; those needs ought not to be
sacrificed or subordinated to the pursuit of some ecological
Utopia (Ref. 3).
Having outlined this conceptual framework, I would like to
underscore two reasons why interpretations about the problem
of identifying "ethical issues" have a bearing on the discus-
sion at hand.
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In the first place, if indeed the confusion and disagreement
about ethical issues raised by radioactive wastes ought to be
traced to two different conceptions of how ethics should go
about defining "the human good" (one of which centers upon
individualistic, short-term, piecemeal considerations, whereas
the other insists upon global, interdependent, long-range
imperatives) clearly, that conflict cannot be debated or
resolved in this setting. Its importance is certainly to be
recognized and reckoned with—but as a factor limiting the
satisfactoriness of my comments.
In the second place, if one is persuaded (as I am) that the
task of developing environmental criteria for radioactive
wastes is more proper to public ethics (because it is closer
to the realm of action and practicable possibilities) , then
the ethical issues to be raised will reflect the particular
exigencies of that methodology.
PUBLIC ETHICS AND THE PROBLEM OF RADWASTES
From the perspective of public ethics, therefore, I propose to
turn to the first order of business, namely, how to formulate
the problem of radwastes. An extensive review of the litera-
ture should convince anyone that there is little or no consen-
sus about what the parameters are or how to delimit the prob-
lem. Since the formulation of any problem will predetermine
the criteria for what counts as an acceptable solution, the
primary ethical task is pivotal.
The origins, locations, and volume of radioactive wastes are
matters of fact. It is also a matter of scientifically
established fact that adverse health effects, somatic and
genetic, may result from exposure to sources of ionizing
radiation under conditions where the dose is in excess of
certain levels. Mounting public concern over radioactive
wastes (from the commercial nuclear fuel cycle, from military
weapons manufacturing, from uranium and phosphate mining, and
from hospitals and laboratory research facilities) is also a
matter of fact. But it is a matter of value judgment that
these wastes ought to be considered as a potential source of
unacceptable, hazardous risks to the environment.
In the interest of definitional clarity, the term "wastes"
deserves to be applied with a modicum of technical precision
as well as respect for ordinary usage. The term denotes
anything that is unproductive, or has exhausted its value, or
is without immediate or foreseeable utility for fulfilling
human needs. So understood, the term "wastes" is ambiguous at
best when applied to spent reactor fuel that can be
reprocessed so as to recover additional fuel resources. (To
establish that spent fuel ought to be reprocessed requires
ethical justification within another context.)
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Further distinctions between high-level wastes, transuranic
wastes, and low-level wastes have been made on the basis of
two factors: the degree of concentrations of radionuclides,
and the quantity of radioactivity present as expressed in the
"half-life" (rate of decay) of certain actinides or isotopes.
Both in popular and scientific literature, it is increasingly
fashionable to derive at least three lines of argument about
the radwaste problem from this one factor: namely, the mind-
boggling time scale measured by the half-lives of certain
actinides and long-lived fission products. Using this single
yardstick, radioactive wastes are perceived in the public
arena to be an unprecedented, unique, man-made problem—"a
matter of life and death," (according to the media) "a
million-year risk," "a Faustian bargain" or "technical fix"
made by energy junkies and bequeathed to defenseless future
generations.
In the first instance, because invisible yet potentially
adverse health effects are associated with them, the terms
"radioactivity," "radiation," "toxicity," and "radiological
impact" have been used (sometimes interchangeably) to argue
that nuclear wastes emit levels of radiation, the environmen-
tal and public health impact of which constitute unique and
unprecedented risks. As the inventory of radioactive wastes
increases—both in volume and curies—a risk-benefit mode of
analysis allegedly breaks down. The present generation reaps
tangible benefits from nuclear power sources, but the risks
attached to the radwastes are exported far into the future.
The risks are not only associated with, but are measured
in terms of, the long half-lives of radioactive elements.
Unless and until the wastes are reduced to innocuous levels by
natural radioactive decay processes, the risks to the environ-
ment and public health will perdure. This line of argument
has issued in an ethical judgment that when a risk-benefit
assessment is applied, the production of radwastes is a
violation of distributive justice. Trade-offs between present
benefits to living persons versus risks to future generations
are ethically unjustifiable.
In a second instance, the yardstick of radioactive half-life
pervades the legacy-longevity question. Are radwastes a
"million-year problem" or a "thousand-year problem"? In
either case, no knowledgeable person would ever rely on expec-
tations about the stability and longevity of social institu-
tions. Presumably it is an ethical imperative that our legacy
to future generations be safeguarded. That is, we ought to
define and standardize a "Radiological impact Limitation
Guide," defined as a "minimum acceptable upper level radiolog-
ical impact limit" (Ref. 4). Its intent would be to minimize
any "dose"commitment" to a population from radiation sources,
on the assumption that there would be some spewing forth from
a repository, either as a result of accidental disruptions, or
intentional intrusions. Moreover, the technology applied to
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radwastes should strive to reduce the "million-year problem"
either in duration or volume—that is, by containment and
geological isolation or by processes of partitioning,,f rac-
tionation, and transmutation. Here again, the longevity of
radioactive half-life dictates the problem and proposals for
a solution. It would appear that our ethical responsibility
to future generations is not sufficiently fulfilled by seques-
tering wastes indefinitely; we must also set regulatory stan-
dards that limit a potential radiological impact on populations
from a hypothetical radiation release.
In a third instance, the literary imagery of Faust has become
an appealing device for arguing that short-sighted technical
fixes have unleashed a demonic power to destroy humanity.
Once again, radioactivity as measured in thousands of years of
half-life, infuses with enormous symbolic power the reprehen-
sible consequences of our "Faustian bargain." In exchange for
short-term materialistic benefits from more and better hardware,
man has created a long-term radioactive monster against which
our descendants must protect themselves for centuries.
Underlying these three versions of the problem about radwastes
is a common denominator. The risk-assessment, the legacy-
longevity problem, and the short-term versus long-term
"Faustian bargain" are each predicated on one assumption:
that the mere existence of a potential source of radiation
constitutes, or is equivalent to, an unprecedented biohazard.
Moreover, the perceived risks are identified in such terms
that the measure of their magnitude is taken as equivalent to
the million-year rate of decay associated with actinides and
isotopes. Hence the risks and unprecedented biohazards exist
in the environment "until the natural radioactive decay reduces
the waste to innocuous levels."
FIRST ETHICAL ISSUE
The first ethical issue is this: should the formulation of the
problem of radwastes be derived from this assumption? If unac-
ceptable risks to environmental quality are measured in terms
of the half-life or rate of decay of toxic elements, then we
should immediately suspend the present program for this Workshop
and instead concentrate on the problem of permanent geological
disposal of arsenic and chlorine, the half-lives of which are
infinite. They are not radioactive and will never decay to harm-
less levels. They have been and will continue to remain in the
biosphere—not for a thousand or a million years—but forever.
Arsenic trioxide, a pesticide whose toxicity when ingested is
50 times greater than plutonium, is not sequestered in
geologically stable regions. It is dispersed where food is
grown. Note well: although this pesticide is not very
commonly used, "more of it (in weight) is imported every year
than all the nuclear wastes would amount to if all United
States [electricity generation] were nuclear" (Ref. 5).
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To balance our judgment in another way: the quantity of ar-
senic imported into the United States each year is enough to
constitute one billion lethal doses (Ref. 6). If risk is
quantified as equivalent to a potential for lethal "dose
commitments" to a population, the hazards to our population of
213 million are of a frightening magnitude. Why is this
biohazard not the subject of this conference? Because it is
familiar, and there is no public concern over it. As a toxic
substance, arsenic has for centuries been treated accordingly,
and is strictly controlled in industry or wherever it is
available in the marketplace.
Dr. Ralph Lapp has offered still another perspective from
which to view the assumption in question (Ref. 6). Radium is
present wherever natural uranium occurs in the earth's crust
and may be carried off in surrounding water. According to
studies at Argonne National Laboratory, persons exposed to
such water at various locations in New England, Illinois,
Iowa, etc., have exhibited what is called "a significant
retention of radium." According to a 1976 Environmental
Protection Agency (EPA) survey, some 500 United States commu-
nity water systems "exceed a level of 5 millionths of a
microcurie of radium-226 per liter." (Parenthetically, it
should be noted that when ingested, earth-locked radium is
2,000 times more deadly than the same weight of plutonium-
239.)
In July 1976, EPA promulgated a ruling that all water
systems serving United States communities will have to be
monitored for radium, and those with more than 5
picocuries (i.e., a millionth of a microcurie) per liter
will be required to remove the radium by chemical means.
According to EPA estimates, such radium removal will cost some
$10 million. The reduction in radium exposure is expected to
save almost four lives per year (Ref. 6).
Here we have not only an underlying assumption that a
naturally occurring source of radiation in drinking water,
measured in a millionth of a microcurie, constitutes an
unacceptable biological hazard to public health; but the
applied risk assessment reveals a startling inconsistency.
If a Federal regulation requires certain communities to spend
over $2 million to save one life from exposure to radiation
risk, should not the EPA be consistent and compel the medical
facilities in every American community to spend far greater
sums of money to eliminate excessive exposure to diagnostic
X-rays and radiopharmaceuticals? According to one estimate,
medical X-rays exact a cancer toll of 2,700 deaths per year
(Ref. 6).
Clearly, there is a serious conflict between the problem-
formulation and risk-assessment of radiation hazards conducted
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by a Federal regulatory agency, and the risk assessment of
an American taxpayer.
How shall public ethics endeavor to clarify and perhaps
resolve this conflict in values? I have suggested that an
ethical obligation to acquire more adequate knowledge might
ensure a more balanced perspective.
It is instructive that our federal government has spent over
$1 billion in the past three decades to research the biolog-
ical effects of nuclear radiation. Is there not a fairly
obvious correlation between the massive information flow to
the public about radiation hazards, and the mounting public
concern to which regulatory agencies want to appear respon-
sive, protective, and indispensable? Judging from my
professional experience, the public is more knowledgeable (at
least, superficially) about the potential adverse health
effects from radiation (or to be more accurate, the relation-
ship between conditions of exposure, dosage, and related
effect) than about many highly toxic chemical agents in common
industrial use. Should it not also be a potential public
concern that drinking water supplies contain chemical and
biochemical poisons? The undetected yet cumulative health
effects of these poisons could prove more damaging than a few
picocuries of radium. Should not taxpayers' money be spent on
more extensive research into these toxic chemicals?
Such research might turn up alarming data. Scientists have so
increasingly refined their instrumentation that, whereas chem-
ical concentrations once were detected in terms of parts per
thousand, it is now possible to detect parts per billion, and
even parts per trillion of a chemical in our food or water.
Are such numerical measurements any automatic index of the
magnitude of a risk to health and the environment? Certainly
not to a technical expert; but they can and have been used to
bemuse the so-called "plain man" for ulterior purposes.
Among others, William Lowrance urges us not to succumb to his-
torical amnesia. When many environmentalists deplore the deg-
radation that technology and its energy applications have (in
their eyes) wrought on this planet, he suggests that we
remember what life at the turn of the century was really
like—spoiled food, impure water, boiling laundry kettles, the
backyard lye pot; nutritional deficiencies and poisoning from
many natural/organic vegetables. Rivers were so filthy with
raw sewage and wastes, that according to the saying of the
time, "Bait died on the hooki" The major pesticide, sprayed
indiscriminately on anything from apples and grapes to
potatoes and strawberries, was lead arsenate or "Paris green."
Red food coloring was produced by lead chromate—a horror to
today's biochemist. Have the hazards increased in fact, or
only in our levels of perception? Lowrance puts the case well:
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We now have the luxury to worry about subtle hazards
which at one time, even if detected, would have been
given only low priority beside the much greater hazards
of the day (Ref. 7).
More refined and extrapolated technical data about biohazards
are clearly not sufficient. Risks are in the eye of the
beholder. Clarity at the level of perception is an ethical
imperative.
Let me recapitulate my argument. Contrary to public percep-
tion of the unique, unprecedented biohazards introduced into
the environment by radwastes, neither mere presence, nor
million-year rates of decay, nor numerical calculations of the
lethal doses contained in a substance based on half-lives or
parts per million should be used as an ethical basis for form-
ulating a problem about any biohazard, especially radioactive
wastes. Moreover, to protect the ethical canons of informed
consent, no adequate risk-assessment can or should be made
exclusively by a regulatory agency subsidized by taxpayers
and/or consumers. It is an ethical anomaly, to say the very
least, that the agency mandated to protect our environment has
not been required to submit for public review any socioeconomic
impact statement justifying its targets for regulation, and the
expenditure of public monies.
In the interest of a more balanced perception, I offer three
contentions about formulating the ethical problem of radwastes.
First, the degree of risk from any alleged biohazard must be
measured as the coefficient of clearly defined conditions
under which exposure can be calculated. The risk exists in
relation to concrete individuals, not hypothetical populations.
The index of risk is not "mere presence" in any environment
for however many years, but likelihqqd of exposure.
Second, the risk cannot be said to exist unless or until a
potential biohazard is able to penetrate and enter into, travel
along, remain unobstructed and undiluted by environmental path-
ways to life. The reference case to be used in predicting these
pathways should be naturally occurring, familiar pathways for
toxic substances—including natural radiation sources—which
human beings have lived with in their environment throughout
history. Those who insist upon imaginative scenarios about
descendants who are technologically primitive yet able to dig
a thousand meters underground into geologically interesting
terrains should also be required to compose imaginative sce-
narios about future dispersals of arsenic and chlorine in a
food chain or water supply, or about carbon-dioxide poisoning
of the atmosphere if we are forced to burn coal at projected
rates for 400 to 500 years. Such scenarios would restore
balance to any risk-assessment.
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Third, any potential adverse health effects must be defined in
relation to a significant dose received by individuals. Those
who might presume to have the competence to determine for
future populations their so-called "dose commitment" or its
numerical limits certainly project an aureola of responsible
concern. The idea is philosophically attractive. But
returning to the real world, how does a regulatory agency
expect to arrive at a number? To be significant to the
public, would it not have to be exaggerated? Considering the
variations in natural background radiation in different geo-
graphic regions and altitudes on this planet, the different
medical expectations and practices of urban or rural
communities, and the impossibility of enforcement—what
possible social good is to be served by expending public money
on this kind of health protection? If any standard can be
set, it should be an Ambient Radiation Standard for specific,
occupational fields that exist where individual persons go who
can be monitored for any noteworthy health effects. If a dose
in relation to ambience is high, it is measurable; if it is
low, it is lost in the background. Moreoever, "future
populations" do not make intentional intrusions into an
underground repository; individuals do. They would be exposed
to the source of radiation, not populations.
On the basis of these contentions, I suggest that the problem
of radioactive wastes is neither unique and unprecendented,
nor has it been properly formulated from an ethical perspec-
tive. We have always lived with toxic elements in our envi-
ronment, and they have not been sequestered with the skill,
forethought, and planning applied to radwastes. From an ethi-
cal perspective, public concern has not only been inflated for
political purposes, but it has been aimed in the wrong
direction. To exercise ethical responsibility, the public
should focus its concern on a proliferation of regulatory
agencies whose flawless bureaucratic logic has paralyzed the
process of decision-making. That paralysis has prevented
anyone from implementing one of several feasible disposal
options for which the technology already exists in fact, if
not in execution.
Furthermore, because the present volume is small and the
evolution of improved technologies is to be expected, some
visionaries insist on a prior demonstration now of what will
be perfected 50 years from now. Instead of tailoring the
method to the present volume, paralysis reigns.
From the perspective of public ethics, the morally preferable
among present practicable options should be the one that
will—in the technical judgment of those competent to make
it—provide maximum, multiple barriers between radioactive
materials and such pathways to life as can now be foreseen.
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CRITERIA FOR ENVIRONMENTAL PROTECTION
In my judgment, four criteria for protecting our total social
and physical environment against harm from wastes have already
been met:
1. The technology for deep mining in salt or rock is
well known and in use.
2. Geologically stable regions can, with as much
certainty as accepted in other long-term decisions,
replace our reliance on the stability of any future
social institutions.
3. Demonstrable methods of solidification, transporta-
tion, and disposal can occur without any more threat
to environmental degradation than exists from the
handling and transport of much more toxic substances
in common use.
4. If not obstructed by interminable costly delays in
the process of implementing an option, the economic
cost is only a small percentage of the total amount
already invested.
But it is a fact of life that all criteria are not created
equal. Some are created to facilitate action. Others are
created to paralyze it by being infinitely interpretable.
Some are created by lawyers and professional interveners who
(for their own purposes) want them to be amenable to the
constraints of a formalized legal structure and an intermina-
ble process of adjudication. Others are created by ordinary
citizens who must worry about social and economic hazards to
their environment, having little to do with esoteric and
comparatively insignificant quantities of contaminants which
they will rarely encounter—but which are attractive objects
of research and regulation for those who are in a position to
make a case for massive funding.
SECOND ETHICAL ISSUE
And so we are confronted with a second, major ethical issue.
How is the public decision-making process to be made more eth-
ically responsible in serving the common social good—that is,
a more just and balanced protection of public health and safety?
How can a corrective be applied to a paralyzing social mechan-
ism? Persons with far greater wisdom than any I possess are
convinced, from the record of the last hundred years, that reg-
ulatory agencies are inherently deficient. Problems are seg-
mented, proliferated, and the current of accountability gets
passed along only one way: downstream. Costs are externalized
and passed on to angry taxpayers. Enforcement of regulations
has to be turned over to the judicial system with interminable,
irreversible delays. The best intentions in the world even-
tually come to grief in a creeping Parkinsonianism. Frustra-
tions within the system are mobilized into empire-building.
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What instrument will cut the Gordian Knot that ties regulatory
proliferation to unending conflicts of interest vested in
government agencies and professional interveners? Surely one
does not waste time untying the knot. One severs it once and
for all. But how? By proposing and insisting upon morally
preferable options.
Any preferable option would have to reckon with a central
question. Why has the concept of regulatory agencies been
accepted for so long, despite its glaring intrinsic
deficiencies? The major reason seems to be that the public
has labored under a profound misconception—never more appar-
ent than in the debate over the disputed "safety" of nuclear
reactors and of radwaste disposal options. The "plain man"
thinks (or is led to believe) that "safety" is an intrinsic,
unconditional, measurable property that some system or product
can and should possess. Consequently the regulator is
appointed and paid to measure approximations to that intrinsic
property. It is the business of the watchdog regulator to
make more stringent regulations, presumably to come ever
closer to that property by "reducing risks." But t!he only
risks he is expected to monitor and minimize are a small
percentage of the total risks tolerated by members of the
public. His job is not to be reasonable or to worry about the
social and economic impacts of his ever-changing regulations.
Just what value judgment does a regulator use when he demands
more and more costly levels of safety? Is he only giving the
public what it wants? Not at all. To paraphrase Tobias
Burnett (Ref. 8), a regulator can no more admit that what he
regulates is "safe" than any other professional can admit that
his job is finished and he has become unnecessary. No matter
how minor a risk is, it can always be reduced. There is no
number that cannot be divided by 10.
The public has yet to realize, apparently, that safety is not
an intrinsic property, measured by approaching zero risks. It
is a relativistic, subjective, evolving, shifting judgment
based on one's values. It can never divest itself of risks.
It can only judge their acceptability. There are as many
judgments of "safety" as there are people and value systems.
Furthermore, the public has not yet been forced to wrestle
with the ultimate question: just how much safety are we
willing and able to pay for? Zero risk and absolute safety
are costly illusions.
If a system of proliferating regulations is bankrupt and needs
to be replaced, a morally preferable option would have to
restore a balance between the public's misconceptions about
safety, and its willingness to pay the social and economic
costs.
There is another possible explanation for our tolerance of the
regulatory agency-system. That mechanism is a reflection of
our basic commitment to legalistic, individualistic values.
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Based on the belief that we are special, and that more of
anything is better, Americans have inflicted upon themselves
what Jerold Auerbach calls "a plague of lawyers (Ref. 9).
Unlike the divinely imposed Biblical plagues, this one is the
incarnation of our basic American values: "our consuming
individualism, unrelenting contentiousness, and discordant
heterogeneity." Seen in our public mirror, we are "one
divided nation, under lawyers, with liberty and justice for
some" (Ref. 9).
Despite a sustained crisis of legal authority in recent years,
our response has been, quite characteristically, to make new
laws and regulations, and breed more lawyers. The unresolved
tension between legalistic formalism and substantive justice
is acute, says Professor Auerbach, but it is likely to remain.
The plague may be our terminal illness, but Americans
probably prefer the disease to any cure that would purge
us of our individualistic, materialistic, competitive
traits....Modern America could not easily survive the
absence of lawyers. They not only sustain and profit
from its rapacious individualism; simultaneously, they
commit the society to legalistic values, which offer the
only thin veneer of unity that Americans can tolerate
(Ref. 9).
On this view, if a system of regulatory agencies is to be
replaced by a morally preferable option, it would have to
leave intact a legal system available to individuals for
settling conflicts between competing value systems and
relativistic judgments of safety.
The fact remains that there is an urgent need for a social
mechanism that can be independent, and do its work of auditing
and enforcing standards that will protect our total social
environment with as few conflicts of interest as gossjible.
One of our most pressing social issues is the so-called
"crisis of public confidence" in professional experts. The
more arcane and complex a scientific or technological devel-
opment becomes, the more constrained is the "plain man" to
fortify himself against erosions of his own level of under-
standing and his familiar world. Unable to stop the world and
get off, he has little recourse except to turn to the
government and its regulators to stop the whole process.
The crisis is not generated by professional incompetence of
experts, but by the social mechanism for enforcing rules and
regulations through which that expert testimony is forced to
pass. Perhaps a Science Court could serve, in certain cases,
to process an increasingly sophisticated technical knowledge,
and then determine what the "scientific truth" is. But the
setting of standards, and the certifying that they have been
met, will have to be carried out by an entirely new social
mechanism.
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I will not repeat here the persuasive arguments for the
creation of a new profession—one that replaces government
regulatory agencies—namely, the certified public profession-
al. Like his financial counterpart, the certified public
accountant, the certified professional (in whatever profession)
would be mandated to audit and submit to public review the
work of scientists, engineers, and technicians as they function
in education, industry, and business. Certified public pro-
fessionals would have their own standard-setting and regulatory
peer review. Their professional judgment would establish stan-
dards for safeguarding public health and our total social envi-
ronment from encroachments of technology.
Instead of an external regulation and externalized costs borne
by taxpayers, this would be an internal mechanism. It would
internalize the costs of regulating industry and business,
just as occurs with financial audits. It would internalize
accountability. The threat of litigation from investors,
shareholders, or others—upon disclosure of failure to meet
professionally-established standards for safe-guarding public
health and the environment—would regulate any profit-making
corporation with far greater effectiveness than an external
government agency.
Is there any hope that this morally preferable option for
protecting our total environment can be implemented? Yes.
The public is being persuaded, although in qualified terms,
that there are limits to growth. It is a question of time,
but eventually Americans will realize that there are liniits
to 3I2wth °f undue Elijocess. Slowly but surely, we are be-
ginning to understand the impact on our total social environ-
ment, in both economic and social deprivations, of regulatory
overkill and legalistic power plays.
The public concern over radioactive wastes is primarily
perceived as a concern for public health and safety. But is
it not more fundamentally a symbol of the never-ending
conflict between individualism and civilization? Americans
may never surrender their basic commitment to legalistic,
individualistic values. At the same time, we are bound to be
persuaded by the language of massive social deprivations that
"the limits to growth of undue process" have already been
overreached. The burden of resonsibility for having inflicted
unnecessary and unjust social deprivations by costly delays
will not be easy for us to carry.
Whatever else may be said in this or any other public discus-
sion, the final word on radioactive wastes properly belongs to
Madame Curie: "Nothing in life is to be feared. It is to be
understood."
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REFERENCES
Jonsen, Albert and Lewis Butler. 1975. Public ethics
and policy making. Hastings Center Report 5(4):19-31.
Jonas, Hans. 1973. Technology and responsibility:
reflections on the new tasks of ethics. Social Research
40(1) :31-54.
Golding, Martin P. 1972. Obligations to future generations.
The Monist 56 (1) .
Callahan, Daniel. 1971. What obligations do we have
to future generations? American Ecclesiastical Review
164 (4) .
U.S. Environmental Protection Agency (EPA). 1977.
Issues and Objectives Statement. A Workshop on issues
Pertinent to the Development of Environmental Protection
Criteria for Radioactive Wastes. pp. 3-5 (February).
Beckmann, Petr. 1976. The Health Hazards of Not Going
Nuclear. Golem Press, Boulder, Colorado. p. 102.
Lapp, Ralph. 1977. Radioactive Waste—Society's Problem
Child. Reddy Communications, Greenwich, Conn.
Lowrance, William. 1976. Of Acceptable Risk. William
Kaufmann, Inc., Los Altos, California.
Burnett, Tobias. 1976. The Human Cost of Regulatory
Delays. Lecture to the American Nuclear Society, Annual
Meeting, Toronto (June).
Dr. Burnett amasses evidence for an astonishing fact:
"The safety objective for a nuclear plant is a factor
of more than 30,000 more restrictive than the best
that can be achieved with a fossil plant."
Auerbach, Jerold. 1976. A plague of lawyers. Harpers
253(1517) :37-44.
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APPROACHES TO RADIOACTIVE WASTE MANAGEMENT
CRITERIA DEVELOPMENT:
SUMMARY AND CONCLUSIONS OF WORKING GROUP 1
APPROACHES TO RADIOACTIVE WASTE MANAGEMENT
CRITERIA DEVELOPMENT
Working Group 1 reached a general conclusion that, although
desirable, environmental protection criteria may be extremely
difficult to establish, especially in a form that would be
effective for all types of waste. It was also generally
agreed that although sufficient data may exist to set numeri-
cal criteria, they have not been brought together as yet.
Despite these limitations, environmental protection criteria
should be achievable, protect the general population that may
be at risk, mitigate against unacceptable exposure of individ-
uals for several generations, be measurable, be economically
feasible, recognize both the operational and disposal phases
of waste management, protect this and future generations, be
flexible (that is, leave room for improvements- such as new
technology), and provide more assurance of environmental
protection from most wastes than now exists.
DEFINITIONS
To clarify the meaning of any developed criteria and the
materials to which they apply, certain terms will need to be
defined. One of the first such terms is "radioactive wastes."
It was agreed that EPA should not develop or define specific
and detailed categories of radioactive waste. The following
broad definition of radioactive waste (offered in full recog-
nition of the existence of more detailed definitions) is
proposed for the purpose of environmental protection criteria:
radioactive waste is all that radioactive material with
respect to which a decision has been made by the cognizant
authority to place the same in permanent storage or a
permanent mode of disposal at discrete sites designated for
those purposes, and shall exclude radioactive material for
which a determination to withhold has been made. Also
excluded are radioactive releases from facilities involved in
production or reprocessing of nuclear fuel and the generation
of electricity from nuclear fuel, which are subject to federal
and state licensing and regulation. (Note: This definition
does not preclude the possibility that materials designated as
"waste" may or may not have value now or in the future.)
BASIS, FORM, AND METHODOLOGY FOR CRITERIA
In addition to the broad requirements for environmental
protection criteria for wastes noted above, more detailed
bases may also need to be examined. The working session
generally agreed that the basic philosophy should espouse
containment and/or isolation; basing such a philosophy on
1-39
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"decay to innocuous levels" was rejected because the meaning
of such a phrase is too imprecise for any practicable use.
Regardless of the type of the radioactive waste, the criteria
should be applicable to any exposure of people, that is, they
should be generic for mitigating risks due to radiation expo-
sure. A number of participants expressed the view that the
criteria should result in umbrella-type numerical standards
for anticipated exposure of individuals and population groups,
and that within these umbrella-type requirements criteria
should also require the application of cost-effectiveness
considerations to reduce risks for specific sites, methods, or
wastes. The desirability of a zero release, zero dose re-
quirement was discussed. Three views were apparent. First,
although it may be desirable goal, it presents great problems
from the standpoint of engineering and criteria. A second
viewpoint was that some members of the public will expect a
principle of zero release and zero dose from the management of
radioactive waste. A third view expressed was that some
members of the public expect some release and dose as a trade-
off for the benefits attained.
In order to facilitate cost-effective evaluations, criteria
should contain a requirement that an assessment be made using
established methodologies of anticipated risks to both indi-
viduals and populations. The criteria should not provide
guidance on these methodologies. The concepts of acceptable
or unacceptable risks, and criteria for risk reduction in a
cost-effective manner, should be employed uniformly for all
categories and sources of radioactive wastes. It was recog-
nized, however, that any subsequent protection standards,
expressed in numerical terms of any kind, may need to be
different for the various categories and sources of radio-
active wastes.
Within these overall considerations it was agreed that at
least a certain minimum level of public health protection
should be assured and that this assurance is more important
than cost. Waste disposal was believed to be capable of being
conducted within any requirements that assure public health
protection in the broad meaning of the term.
Risks due to accidental circumstances were thought to be
outside EPA's purview to state criteria for radioactive waste
disposal. It was recognized that risk needs to be addressed
by those responsible for regulating site-specific applications
in the interests of environmental protection. Because of this
interest, general environmental protection criteria should
include the articulation of a philosophical approach which
reflects:
1. An obligation under generally accepted radiation
practices to keep exposure levels as low as are
reasonably achievable below such reference limits as
may be identified.
1-40
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2. An obligation to assess the potential accidental
events which might occur.
LONG-TERM CONSIDERATIONS IN CRITERIA
The extent to which the need for long-term care must be con-
sidered in establishing environmental protection criteria for
radioactive waste disposal was discussed, and the following
concepts were agreed upon:
1. This generation has a responsibility to future
generations to ensure that they will not be deprived
of the possibility of reasonable progress. It was
agreed, however, that we cannot presume to protect
all future populations against their own actions and
all contingencies. The risk assessment of any
radioactive waste disposal method or facility should
consider the consequences of potential intrusion,
either deliberately or accidentally, by an individual
or a population group.
2. The criteria should not require a consideration of or
make any assumptions about the form or stability of
future social institutions. The criteria should re-
quire identification of positive as well as negative
legacies related to radioactive wastes and their
origins.
3. The criteria should address the risks and disposal
standards associated with radioactive wastes in the
broad context of the comparable risks and disposal
considerations for all biologically hazardous wastes.
Any criteria developed should be commensurate with
the hazards. (The members of the working session
suggested specifically that a high degree of
coordination within EPA is important, for example,
between the Office of Radiation Programs, the
Office of Solid Wastes, and other appropriate groups.)
4. The criteria should be based on assessments or
projections of possibilities of real risk (e.g.,
health effects) to real individuals and/or
populations. In addition to direct effects on humans
(e.g., health effects), the criteria must consider
possible effects on the utilization of natural
resources in the future.
PHYSICAL AND OPERATIONAL CONSIDERATIONS FOR CRITERIA
In considering the relative importance of environmental
barriers such as geologic formations, as opposed to engineering
controls (e.g., matrices, containers), the consensus was that
the barrier provided by a geologic formation is more important
when considering long-term care for all types of wastes.
There are, however, situations where engineered controls are
necessary. For example, it is essential that .high-level and
transuranic wastes be contained (e.g., either by matrix and/or
1-41
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container) during the validation phase or retrievable time
period of the repository (e.g., 50 years). In addition, there
are numerous specific criteria which can be imposed on classes
of wastes or disposal sites. For example, non-transuranic
low-level wastes should be placed in media that are unfrac-
tured, have low permeability and are amenable to study. The
medium should also be large enough so that concentrations of
radioactivity in surface and ground waters at the boundary
will be within established standards. For shallow land dispos-
al of low-level wastes engineering controls are also necessary
to keep water from penetrating to the waste. It is believed
that geologic disposal is not too expensive; however, other
methods which may prove practical must continually be examined
and reviewed. It was concluded that high level waste should
be retrievable until it can be demonstrated that the isolation
is secure. This time period cannot be defined at this writ-
ing. However, it is assumed that the institutional controls
established in the future will be responsible for complying
with this criterion. Low-level waste disposal facilities need
not be constructed on a retrievable basis. It was felt that
the question of costs could not be addressed at this time.
There is definitely a need for preplanned emergency response
procedures for credible accidents. There is also a need for
monitoring both during the operational lifetime of a facility
and until safe isolation can be demonstrated. The time period
for monitoring after facility closure was not ascertained.
However, it was felt that for low-level waste burial sites,
monitoring should continue until the migration rate has been
determined. If effluent is found to exceed established pro-
tection standards, remedial measures should be available to
protect groundwater. Also any monitoring after the closing of
a facility should be done without violating the integrity of
the facility. In addition, it should be demonstrated that any
effluent reaching the biosphere will be at or below drinking
water standards. This should be ascertained by competent
scientists and engineers.
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WORKING GROUP 1 EXECUTIVE COMMITTEE
APPROACHES TO RADIOACTIVE WASTE MANAGEMENT
CRITERIA DEVELOPMENT
NAME
James E. Martin*
Stanley Lichtmant
Edward Struxness
William Holcomb'1'
McDonald E. Wrenn
Judith Johnsrudf
Keith J. Schiagerf
AFFILIATION
Environmental Protection Agency
unaffiliated
Oak Ridge National Laboratory
Environmental Protection Agency
New York University
Environmental Coalition on Nuclear
University of Pittsburgh
Power
* Moderator.
t Panelists for Plenary Workshop Session, 5 February, 1977.
1-43
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RESPONSE OF WORKSHOP PARTICIPANTS TO SUMMARY
AND CONCLUSIONS OF WORKING GROUP 1
Second Plenary Workshop Session
JAMES E. MARTIN (Environmental_Prate^t^on_A2encXi_Washingtoni
D-iC-i) : My name is James Martin and I am chairman of this
Workshop and moderator of Working Group I. The other panel-
ists in this group are William Holcomb, from The Environmental
Protection Agency in Washington, D.C.; Judith Johnsrud,
from the Environmental Coalition on Nuclear Power, State
College, Pennsylvania; Keith Schiager, from the University
of Pittsburgh, Pittsburgh, Pennsylvania; and Stanley Lichtman,
from Ann Arbor, Michigan. The first question is from William
Lochstet.
WILLIAM A. LOCHSTET lEnvironmental_Coalition_on_Nuclear
Pow^Ll: Tne definition of waste presented gives some
"cognizant authority" the ability to define it later. It
would be better to use concrete examples including those
currently in existence and those expected. Group 2 considered
"waste" to be what is generally called high-level waste from
the fuel reprocessing operation. I think I found the whole
definition unmeaningful. We felt we knew what high-level
waste was and we clearly understood it and we did not bother
to pussyfoot around about trying to say what it might be. We
have high-level waste and we have to deal with it. To
legislate it out of existence does not solve the problem.
This is what I am trying to say.
JAMES E. MARTIN: I might comment that as I reflect on the
layout of Working Group I it was broader, or at least it had
a broad subject to try to address areas where criteria may be
needed. I think I recognize that there is probably going to
be quite a bit of redundancy between these reports; but that
is just the natural consequence, I guess, of dividing into
threes because there is going to be presentation of some kind
of information but certainly from different views. How we are
going to sort that out I do not know, but we will just have to
make an attempt to do so. We were not trying to preempt the
other groups, either defining or commenting, but to state what
the consensus of that group was. Dr. Schiager, did you want
to comment?
KEITH SCHIAGER: I think the thing we were brought back to a
number of times in our Working Group was the fact that we are
not dealing only with high-level waste. The entire spectrum
of radioactiave waste was to be the subject of the Workshop
and therefore we were looking for a definition that covered
that entire range. This is why we worked on a definition even
though there are plenty of definitions in existence for vari-
ous categories.
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STANLEY LICHTMAN: It seems unclear to many people what
waste is. Some people would be very offended if you disposed
of what you call high-level waste. They would want to
remove things from it first. So we feel that waste becomes
waste when a decision is made to get rid of it regardless
of its value. There was a great deal of dicussion on that
point.
LOCHSTET: I think that that is inherent in deciding what
quantity of material this meeting is all about. I do not have
any quarrel with the high-level/low-level problem, and I think
we all would agree with you, at least from my point of view.
This whole question of whether it is desirable or somebody is
going to want it later begs the question of what the problem
is we are talking about here.
MARTIN: Mr. Lawrence Jones.
MR. LAWRENCE JONES
___
Thank you, Dr. Martin. I would like to have that
added comment regarding zero release repeated. I have
some strong feelings about concepts of zero emission.
SCHAIGER: Zero dose requirement was discussed with two views
apparent. First, although it may be desirable to attempt to
achieve, it gives great problems from the standpoint of
engineering and criteria. A second viewpoint was that some
members of the public will expect a principle of zero release
and zero dose from the management of radioactive wastes.
JONES: I would like the record to reflect that it is my
conviction that some members of the public would expect a
third outcome. I believe that there is a significant segment
of reasonably well-informed public who recognize that it is
mandatory to accept some release as a trade-off for the
benefits coming from nuclear energy. I do not think the
record would be complete without reflecting that fact. I do
not purport to speak for the entire public but I do speak for
some of it. I believe that it is an insult to the nuclear
technologist's intelligence to expect him to design a system
that will result in zero emissions. If this is even going to
be considered then we must abandon nuclear technology in
total, and that to my way of thinking is unreasonable. I
believe that if the public is given the facts surrounding the
effects of ionizing and radiation they will make an intelligent
and reach a reasonable conclusion on the question.
MARTIN: I will be sure that the record reflects your view.
Next speaker is Mr. Peter Littlefield.
MR. PETERS. LITTLEFIELD ( Yankee .Atomi c_Elec t r i c_Co . ,
Wf § tbo£o_,__Mas£> . ) : Comment on Working Group 1 Summary and
Conclusions, page 1-40, second paragraph, first sentence.
This sentence does not express the consensus of the working
1-46
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group as I understood it. The group stated that some level of
public safety should be assured regardless of cost. Beyond
that level further reduction of dose, etc. must be on a cost-
effective basis. That was an attempt to be a clarification of
what I understood we agreed upon in the working group; that
is, there was some minimum level of safety that should be
assured, but beyond that, any further reductions should be on
a cost-effective basis.
MARTIN: Is there any disagreement with that consensus?
PANELIST: I think that is a fair representation.
MARTIN: We will reflect that as such. The next comment is
from Dr. Kim.
DR. KYO S. KIM
PllLiadeJ.pJiia^^a^ : I was in Working Group 1 and I do not
remember defining a waste in such a manner as page number
1-39 says, excluding the waste involved in the production
of reprocessing nuclear fuel or generating electricity.
Well, granting this to be the definition that Working Group
1 has made up — which I do not quite believe is so — in other
places in the Summary it consistently and repeatedly says
that the criteria should be umbrella-type generic, applicable
to all waste. I think this contradicts itself and also
40 CFR part 190. This is just one of my thoughts that
is not quite clear.
LICHTMAN: May I comment?
MARTIN: Yes. Dr. Lichtman will comment. Maybe he can clear
it somewhat.
LICHTMAN: The reason for excluding for present purposes, for
the purposes of this meeting and the EPA's present task —
excluding releases from production facilities and power
generating facilities — these are releases. Effluents and
releases of that type are first of all not contemplated to be
subject to the kind of storage that we are discussing here;
and secondly, they are covered by other standards and
regulation. So we excluded them from the definition we are
discussing here.
KIM: But we are now making criteria for radioactive wastes
regardless of origin or where it is produced. The whole sen-
tence sounds like it is umbrella-type generic and applicable
to all waste, so whatever criteria we are setting here will be
interpreted in the future as applicable to all waste.
LICHTMAN: I hope not and one should try to avoid that. The
waste we are considering here excludes waste that is released
in effluents by these other facilities.
1-47
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MARTIN: Mr. Chauncey Kepford.
CHAUNCEY KEPFORD (Envi1ronmental_Coalitj.on_on _Nuclear Powerj,
§tate_Co]:legei_Pa^) : In the long-term criteria on page
1-41, criterion 2 (as a criterion) should not require a
consideration or make any assumptions of the former stability
of future social institutions. That is fine. I am in
Working Group 3 and we concluded essentially the same thing.
Yet on the next page it says it was concluded that high-
level waste should be retrievable until it can be demonstrated
that the isolation is secured. Does this not impose quite
a burden on future societies and generations? And how
long are they going to have to stick around to insure that
these wastes are indeed secure?
SCHAIGER: Well, I might comment on that, at least to what the
intent of the working session was as I understood it. When we
were talking about not placing any reliance on future
institutions we are talking in generations beyond our own.
When we were talking about monitoring, assuring the
containment situation we were really speaking in terms of what
is done in the generation that produced the waste. That was
the intent I believe, of the working session, whether or not
it is stated very well.
KEPFORD: Then, my criticism still stands because as I
understand it our first repository will not be sealed until
after the year 2000, which is essentially beyond this
generation. Is that not right?
SCHAIGER: I do not know what is going to happen to the first
repository. People have said what they are going to do. That
discussion did come up in the Working Group, though, and what
I am saying, is the response was that we were here to put down
some criteria that we thought were proper regardless of what
someone may or may not have planned.
MARTIN: I will move on to the next question; I have to wrap
this up. I will give you one more minute to get a card up
here, and I have to close it off here so we can move on to the
next report. The next comment is from Mr. R.L. Shoup.
R. L. SHOUP lUnign Carbide Cor p. L/Nuclear ._Div._x __.
Tenn^j_: I had a comment or a question on page 1-5. You made
the statement that high-level waste should be retrievable
until it can be demonstrated that isolation is secure. I
would like a little clarification as to how can retrievability
and demonstrated isolation be achieved simultaneously. They
seem to be incompatible concepts.
MARTIN: Mr. William Holcomb.
WILLIAM HOLCOMB: As I understood from the group and also
from the Energy Research and Development Administration
1-48
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(ERDA), they are going to establish or operate a repository
probably on what they call a validation phase for a number
of years to make sure that everything they thought about
and designed xis going to work properly. We are, of course,
under the impression that, (and I think ERDA is going along
the same line) they want to have everything that they put
in the repository contained in such a way that they can
remove it if they find that, perhaps that repository, that
location, or their operational methods are not acceptable
to their findings over a number of years. Now ERDA has
not yet totally defined how many years they are going to
, what you might say, experiment with this repository until
they gather enough data to determine if it is an accept-
able place to store. Once they do that they intend probably
to go on and fill up the facility and when it is full then
they will close it down. Therefore, I think the viewpoint
of our group was, okay, as long as they are in this validation
phase, we hardly recommend that they do maintain retrievablility
because if something happens—something unpredictable that
they did not consider—they still have the option of pulling
it out and going to another repository. In addition ERDA
is considering looking at more than one geological media
or formation. Perhaps somewhere along the line they may
find another formation that they feel is much better than
their first one. I cannot speak for ERDA but that is a
possibility.
MARTIN: Does that clarification satisfy you? Okay. The next
speaker is W. H. Millerd.
W. H. MILLERD (Centej: for Science in the Public Interest,
W^§hi52t2Di_O^.C) : My questions reflect on page 1-41 number
4, which is a criterion that clearly reflects Dr. Maxey's
evaluation of the situation. Although that is a very good
philosophical question, it has a lot of practical
implications; namely, it could be a request by the nuclear
industry to be allowed to do as poor a job as the worst of our
industries has done in the past, or it could be a support for
the EPA's efforts to do a very good job on cleaning up the
other wastes, in which case it could also be a request for a
delay in handling their wastes until everybody cleans up their
own house. As I suggest, making that the base of our
criterion is extremely ambiguous and I would like some clari-
fication, if there is any, from the panel.
Panelist: I think the feeling there was that we used the word
that these risks should be addressed in the context of other
comparable risks and so on. There is nothing in that
paragraph that implies a delay, there is nothing there that
says we should not follow the rest of the criteria which we
feel are directed toward good radioactive waste disposal
practices? but we do feel it is important that basic
philosophies within EPA on waste management should not run
countercurrent.
1-49
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MARTIN: Thank you. The next comment is from MrTH. Bryant
Brooks, Tennessee Valley Authority.
H. BRYANT BROOKS (Chattanoogai_Tenn^): On page 1-39 it is
stated that environmental protection criteria do not exist. I
submit that such criteria have existed for years, based on
large data bases, and waste standards must simply be fitted in
the existing framework.
MARTIN: Anyone want to respond or comment?
I will go to the next one. Dr. Frederick Forscher.
FREDERICK FORSCHER (Energy__consultanti_Pittsburghi_Pai) : You
can read my comment.
MARTIN: Comment. What is meant by permanent storage or mode
of disposal, that is, why call innocuous levels imprecise?
FORSCHER: It is aimed at the question of definition. There
was a comment made in the paper on innocuous levels, and it is
not precise enough. But before there were statements like,
"We have to go to permanent disposals and permanent
repositories." What do we mean by permanent? If we must
define, let us define them all. The conclusion one reaches
from this type of reasoning is that you cannot get away with
imprecise words, either innocuous, or permanent, or secure, or
as low as practical or economically feasible. You have to get
to numbers, and numbers can never be zero.
MARTIN: I think you made yourself fairly clear on that.
Mr. Loring Mills, do you want to state your point or shall I?
LORING MILLS (EdjLson_Electric_Institutei_Washin3toni_D^Ci) :
I was looking for clarification on two statements on page
1-42, the first one being on line 11 and 12 of the first
paragraph. That paragraph appears to address both high- and
low-level waste, and it also says, "it is believed that
geologic disposal is not too expensive." I am curious as to •
what was really meant there in "geologic disposal," because in
some people's minds the saltbed or the rock formation is the
geologic disposal and it might not be a geologic disposal if
it is the shallow land burial area. I was just looking for a
clarification on that.
HOLCOMB: We define geological formation as anything in the
earth's crust, be it shallow land, deep mines, deep
excavation, or whatever. So if you are going to put it in the
shallow land that is also a geological formation, that is a
that is a burial.
MILLS: Okay, that clarified it. The second clarification was
in the next to the last sentence on the bottom of the page.
"In addition it should be demonstrated that any effluent
reaching the biosphere will be at or below drinking water
1-50
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standard." I suggest that there might be some areas in the
country where there are effluents adjacent to these
repositories that would not meet drinking water standards from
a natural standpoint. Thus, are you suggesting that the re-
pository should purify those waters?
MARTIN: Thank you for the comment, and for pointing out the
pitfall. Mr. Owen Davis, do you want to quickly state both of
your
OWEN DAVIS (PG&Ex_San_Franciscoi_California): The first one
was for clarification on page 1-41 item 1, we have the
statement that "It was agreed, however, that we cannot presume
to protect all future populations against their own actions in
all contingencies." Yet in item 4, the second sentence says,
"The risk assessment of any radioactive waste disposal method
or facility should consider the consequences of potential
intrusion either deliberately or accidentally by an individual
or a population group." Those two statements did not seem to
jive.
SCHAIGER: There are probably a lot of things in here that do
not really hang together, but the point of this was that you
cannot necessarily guarantee protection but you can ask
yourself "What if someone does get into a repository, how se-
rious would the consequences be?" You can analyze it and at
that point in the risk assessment phase of waste management
you can in fact make a further decision of additional
protective measures.
DAVIS: I think that sentence, then, should be tied to item 1,
as a follow-on part of it. It would be logical to put it
there. My second comment was on top of page 1-42 where we are
giving examples of the waste form by saying it should be in a
matrix or a container during the validation period or, further
down, that non-transuranic low-level waste should be placed in
a media that are unfractured low permability and amenable to
study. I think these are site-specific criteria and represent
a judgement on what would be required and not a part of
criteria that, as I understand it, EPA is supposed to be
setting.
MARTIN: Mr. Robert B. Shainker
ROBERT B. SCHAINKER (Systems Control, Inc., Palo Alto,
California): Some of my points were covered earlier but basi-
cally~the~~def inition of nuclear waste as defined here seemed
to be a moving target depending upon legislative decisions and
I did not even get a definition of what decisions had occurred
in the past in this sense to really get a handle on what it
means today. I was really left in an uneasy state of mind in
terms of what your definition of radioactive waste was. One
clear point—is a spent plant, as an example, radioactive
waste?—came up in Workshop 3 and we felt it was.
1-51
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The second point is the third paragraph on page 1-40 starting
with "Risks due to accidental circumstances were thought
to be out of EPA's purview to state requirements for criteria
for radioactive waste." I just do not understand that
sentence. Could someone clarify that for me?
JUDITH JOHNSRUD: ....the uses of the terms criteria and
standards, which seem to give us trouble all the way through
the Workshop, are involved here but perhaps if the word,
"standard" is used instead of "criteria" in that statement, it
might help a little.
SCHAINKER: I think definitely the words, "criteria" and
"standard" could be defined and I think it has been in EPA
literature, but the general public should understand what the
working definitions are. I am really concerned about the ac-
cidental circumstances. What was the meaning of that?
Stating that something—whatever the accidental circumstance
be—is outside EPA's purview just sort of strikes a cop-out
chord on my part.
MARTIN: That is not necessarily EPA's view. That was the
view of the people in the working session. We have not heard
from the other two working sessions. I personally think the
statement is rather clear; it was a conclusion that EPA should
not in development of criteria address accidental
circumstances; it was outside of its purview.
SCHAINKER: I just do not understand that. Give me an example
of accidental circumstances, I am missing the point. A
meteor, is that what you mean?
MARTIN: No, for example, one might establish the probability
of an earthquake that is supposedly site-specific, it is a
determination that has to be made in the licensing of that
particular place, and the design, and other requirements. So
from the standpoint of being outside of EPA's purview, that
was really the function of the regulatory agency, which in
this case is the Nuclear Regulatory Commission. The advice of
the group was that EPA, as reflected by the group, should stay
the hell out of the considerations of accidents in terms of it
enunciating them in criteria.
SCHAINKER: Okay, so the criteria should be focused on the end
product rather than any site-specific fault zone, or meteor
accident, or whatever; its end product minimize risk, improved
health and safety, whatever those terms mean, and not focus on
the details of a potential accident at any one type of site.
MARTIN: We are just reporting the reflection of the working
group.
SCHAINKER: Okay, I just did not understand the sentence as
indicated.
1-52
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MARTIN: Thank you. I think we will have to call this ses-
sion, or this report, completed. I would like to make one
comment. I think you see that there is a tendency here by
people who are in the working group who were supposed to have
appeared earlier this morning to make these kinds of expres-
sions to the small session to use this larger form for cor-
recting things that probably should have been corrected earli-
er. We are not behind schedule, but we may fall behind sched-
ule on the longer reports from Groups 2 and 3-if we do the
same thing. I would hope there would be more cross-flow
between others here who were not in those groups rather than
a particular member of the group trying to get a phrase or
something changed that he did not like, that he supposedly had
an opportunity to accomplish earlier. I think a certain
amount of that is tolerable. I did not really pick it up
until we got too far into it in this one to really scotch it.
I think these things have to be edited and cleaned out and
there are going to be consistencies pointed out. I really
think it is important to appreciate what did go on here last
night. People worked very hard into the night and our cont-
ractor, Ecological Analysts, did a marvelous job of taking
garbage and getting it into reasonably good format and hav-
ing a copy for everybody. It took them all night. Without
further ado, let us retire this group. You can have a stand-
up break if you'd like for about two minutes.
1-53
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WORKING GROUP 2
RISK CONSIDERATIONS OF
RADIOACTIVE WASTE MANAGEMENT
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RISK CONSIDERATIONS OF RADIOACTIVE WASTE MANAGEMENT:
A STATEMENT OF ISSUES AND OBJECTIVES
Risk, which has been denoted as the probability of radio-
nuclide release times the consequence, constitutes a key issue
in the management of radioactive waste. In addition, there is
a broader connotation to the issue involving the perception,
acceptance, and personal valuation of risks. Measurement and
expression of such factors is complicated by whether risk is
voluntary or involuntary, individual or group-focused, current
or projected, chronic or catastrophic. More extensive discus-
sions of these topics are contained in recent works on risk by
Okrent, Rowe, National Academy of Engineering, and Barrager et
al. (Refs. 4, 5, 3, 1) .
This section identifies three major areas fundamental to the
question of risk from the management of radioactive wastes:
1. Methodology for identification and assessment of risk
(emphasis on methodology).
2. Risk associated with the management of radioactive
wastes (emphasis on product of risk assessment
efforts) .
3. Incorporation of risk and risk acceptance in deci-
sion-making .
Waste management in the context of radiation protection is
characterized by several outstanding differences compared with
other radiation sources:
1. Risk and costs are probably shared disproportionately
by present and future generations, whereas present
generations derive the benefits.
2. Balancing of benefit and risk over the period wastes
remain toxic is difficult, hence traditional
radiation protection standards and underlying
philosophies may not be directly applicable.
3. Calculation of risks to present and future genera-
tions is clouded in uncertainties stemming from tech-
nical limitations in the sciences and engineering and
by the very long time-frames over which protective
controls are expected to operate.
4. Basic ethical and moral questions permeate the
intergenerational risk issue and are not amenable to
technical solution.
METHODOLOGY FOR IDENTIFICATION AND ASSESSMENT OF RISK
Ideally, geologic disposal systems and engineered storage
facilities or other disposal techniques should be designed and
operated to fully contain radioactivity. Practicality, how-
ever, may necessitate allowing releases at predetermined
levels. Concerns for unplanned releases in the short-term or
operational phase are most directly related to mechanical
2-3
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failures and human activities involving transportation, site
preparation, waste preparation and emplacement, backfilling or
covering, etc. In the case of phosphate mining by open pit or
stripping, concern in this phase would be with management
techniques for water and solids containing radioactivity and
with land restoration upon completion of mining. These
short-term aspects constitute the principal risk to present
populations. There is need to compare risks associated with
the operational phase to long-term risks in order to define
the principal relationships of cost versus dose versus risk
versus benefit, etc., associated with various management
options.
Long-term safety (related to the inverse of long-term risk) is
directly tied to radionuclide movement from a disposal site
and the consequences of such movement. The time-frame of
greatest concern commences with cessation of disposal
operations and ends when the stored or released radioactivity,
if any, is no longer a threat to the populace. Long-term
safety must result primarily from natural stability (or at
least known and acceptable variability) of geologic,
hydrologic, or other processes that might adversely affect
wastes. The assessment of such stability ca'n be tested or
field-verified to a limited degree beforehand and through
early stages of operation. Geoscience evaluations or
predictions of what is likely to happen (versus what will.
happen) seem to be possible for the long time periods over
which high-level wastes require containment. However, the
adequacy of present-day knowledge of earth processes under
natural and waste-affected conditions is of prime concern in
predicting the magnitude and timing of future releases. At
the bare minimum, envelope or maximum credible event approaches
should be utilized. There are other questions and concerns.
For example, to what extent should risk assessment be conducted
(preliminary or refined)? Are event-tree diagrams and sensi-
tivity studies applicable to disposal concepts which are
largely untried or at least unaccompanied by failure
statistics?
Lower concentrations of radionuclides are of concern in low-
level wastes put into land burial or associated with uranium
and phosphate mining and milling. The same fundamental
questions and considerations apply, although because the
periods over which the radionuclides may be toxic (or in
otherwise hazardous concentrations) greatly exceed the
operational phase of the disposal facility.
In geologic disposal, failure data for individual components
are largely unavailable and therefore the probability of se-
quential component failure producing a release is also
difficult to construct. In light of these deficiencies, the
applicability of probabilistic risk assessment methodology to
geologic disposal needs to be reviewed.
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RISKS ASSOCIATED WITH MANAGEMENT OF RADIOACTIVE WASTE
Risks due to human activities may represent a greater threat
to the long-term safety of a repository than has been
presented to date by existing waste management practices. The
disposal of radioactive waste in an area of mineral deposits
(including fuel and water) increases the probability of acci-
dental penetration of the waste containment in the future. It
must be assumed that usable mineral accumulations will
continue to be sought by future populations, but^what minerals
or fuels will be sought, the locations, the timing, and the
related technology are unknown. Comparison of the last 100
years of the fuels and minerals industries to their last 200
years provides some idea of the dramatic and revolutionary
changes in fuel policies and technologies that are possible.
Considering the foregoing, risks associated with accidental
penetration of waste repositories in mineralized and
nonmineralized areas could be difficult to assess.
Besides penetration, other mineral-related impacts affecting
the stability of a repository and the migration of wastes
therefrom would be even more problematical to predict in terms
of occurrence and severity. Perhaps only risk comparisons of
repositories in mineralized areas to those in nonmineralized
areas are warranted. At issue is the predictability of
impacts of human activities in an increasingly technological,
mineral-dependent society.
In addition, there is a problem of communication in calculat-
ing and comparing risks. For many, if not most people, it is
impossible to formulate an accurate concept of a probability
of 10~6, and it is also perhaps beyond human comprehension to
visualize and actually grasp with our senses and intellect
predictions extending millennia and tens of millennia into the
future. Therefore, even if technically correct, there is a
question whether such mathematical expressions are relevant to
the public and the decision makers. Such predictions need to
be evaluated and placed in perspective so as not to be
misleading.
Evaluating immediate and future risks associated with
different waste management concepts so as to determine which
concepts have minimal total risk probably requires use of
future weighting factors. An obvious question is, Which
weighting factor is appropriate? Should future risks be
treated as equal to present risks? Should future risks be
discounted, as in economic cost comparisons? How is the loss
of natural resources in future time-frames valued considering
the increasing value of such resources with depletion and
burgeoning demands? Are future health effects comparable in
value to present ones? How are low-probability, high-
consequence events equated to high-probability, low-
consequence events?
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Perception and acceptance are likely to vary even if the
objective (calculated) risks are identical. Recognizing that
societal judgments and attitudes, as well as technological
judgments, have a role in waste management decisions, there is
uncertainty about the proper role or weight to be assigned to
each. Risk acceptance by the public and estimated or calcu-
lated acceptability for future societies must be significant
considerations in the development of alternatives and eventual
implementation of a management plan. Preferably, the method-
ology for risk identification and acceptance should also be
publicly acceptable.
On the general question of "unacceptable risks," regardless
of the probability of occurrence, a National Academy of
Engineering (Ref. 3) committee believed that risks and
benefits must be regarded as a continuity, and consideration
of incremental changes across the whole range must be part
of the analysis.
INCORPORATION OF RISK ASSESSMENT IN DECISION-MAKING
A complex of social, economic, moral, and technical factors
surround the risk issue in radioactive waste management. It
is likely or reasonable to expect that differences in study
findings and dearth of consensus may exist among the
technologists working in the area. Measurement of risk and
risk acceptance requires an interplay of the physical and
social sciences, both of which are faced with serious concep-
tual and technical limitations and problems. Even if such
limitations and problems did not exist, there is an unknown
quantity and quality to human behavior wherein man acts,
reacts and, in general, responds highly subjectively and
perhaps intuitively. Response is often not predictable on the
basis of objective, hard-fact inputs alone. If risk could be
identified precisely in terms of radionuclide releases and
resulting health and environmental effects, there is no
certainty as to public and decision-maker acceptance of an
implicit or explicit "right" course of action. Recent studies
(Starr, Barrager et al., Hammond and Adelman; Refs. 6, 1, 2)
have shown that making decisions in the public and political
arenas is possible even under such trying conditions.
The role of risk assessment and acceptance methodology in the
subject area of nuclear waste disposal calls for more
attention as a means to reach an acceptable solution. One
school of thought regards the conduct of and output from such
efforts as essential to decision-making and somewhat binding
as to the latitude allowable. Another viewpoint is that such
exercises are always simply one of several inputs to the over-
all decision-making process. Analysis of risk falls in the
category of all mathematical, simulation-related modeling
efforts, i.e., a useful, quantitative tool to understand a
complex system in terms of input, output, and functional
interactions. It may be a systematic approach to
2-6
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simultaneously or at least sequentially examine a large and
diverse data base, often characterized by measurements of
dissimilar type, accuracy, and significance to the processes
of interest.
Identification of risks and acceptable levels of risk, as may
be incorporated in an active waste management program, is not
subject to rigorous, objective proof. A multiplicity of study
methods may be necessary to examine risk and risk acceptability.
Decision making from such studies and other considerations
should seek some balance of the risk issue with other aspects
such as technical feasibility, present and future social
acceptance, and economics. In view of these considerations,
must acceptable geologic disposal alternatives incorporate
£®trj.evabi].i;tY options? Should disposal programs have minimal
short-term risk with provision for cessation or modification
of a disposal program if changed conditions warrant and
if retrieval can be justified on economic, societal, short-
versus long-term risk considerations, etc? Inadequate
performance and/or availability of new, improved alternatives
must be recognized in the retrievability issue.
The criteria and methods used to determine socially acceptable
risks should be explicitly developed and reviewed by origi-
nating agencies and the public and other private sectors
affected by risk-related decisions. Actions with particularly
long-term implications should be undertaken or permitted only
after study of the alternatives and associated risks, benefits,
and acceptability in the context of possible future shifts
in values (Ref. 3) .
SUMMARY OF CONSIDERATIONS
In summary, the following issues are appropriate to the
consideration n risk in the development of environmental
criteria and standards for radioactive waste management. As
such, they shall be included among the topics to be examined
in this Workshop:
1. Should the probabilities and/or consequences of
abnormal or unplanned events associated with
radioactive waste management plans be considered in
the development of criteria and standards? If so, in
what manner?
2. The time-frames of interest in the management of
transuranic radioactive wastes are larger than those
associated with any previous risk analysis. In addi-
tion, a number of geological disposal systems are now
largely conceptual and unaccompanied by failure
statistics. Considering these facts, to what extent
should quantitative risk analysis of long-lived
radioactive waste management plans be attempted in
support of environmental criteria and standards?
What about other categories of radwaste?
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3. When quantitative analyses are to be made of the
risk, what analytical methods should be applied to
various phases associated with waste management
(i.e., transportation, repository operations, re-
trievable storage, ultimate long-term disposal,
etc.)?
4. Given that appropriate methods have been selected,
what data should be considered in quantifying the
probabilities and consequences of abnormal or
unplanned events?
5. What consequences are of concern in the risk
assessment? For example, should the analysis be
restricted to health effects of the types considered
in the Reactor Safety Study? Or should questions
such as the risks of compromising future resources of
valuable minerals be considered?
6. Can one reasonably predict throughout the time-frame
of interest what resources might be considered valua-
ble? Can one assess the possibility of radioactive
releases being caused by penetration of a repository
by persons pursuing mineral resources?
7. How should the acceptability of the risks associated
with radioactive waste management be determined?
8. Regardless of the types of consequences that are
considered, how should future risks be equated with
present risks?
9. How should the risks from low-probability, high-
consequence events be valued in comparison to the
risks from high-probability, low-consequence events?
10. If risk assessments are performed, should an environ-
mental criteria for irretrievable geological disposal
be established that allows such disposal only when
the risks are reasonably quantifiable through the
period of significant waste radioactivity? Should
retrievability of stored radioactive waste be
required until such time as enough data have been
collected to make such reasonably quantitative
risk analyses?
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REFERENCES
1. Barrager, S.M., B.R. Judd, and D.W. North. 1976. The
Economic and Social Costs of Coal and Nuclear Electric
Generation. Stanford Research Institute Report Under
Contract, National Science Foundation, OEP-75-06564, p.
127.
2. Hammond, K.R. and L. Adelman. 1976. Sci'ence, values, and
human judgment. Science 194:389-396.
3. National Academy of Engineering. 1972. Perspectives on
Benefit-Risk Decision Making: Committee on Public
Engineering Policy, Wash., D.C., p. 157.
4. Okrent, D. (ed.) 1975. Risk-Benefit Methodology and
Application. University of California - Los Angles School
of Engineering and Applied Science, Conference Proceedings
UCLA-ENG-7598, prepared for National Science Foundation
under grants GI-39416 and OEP-75-20318, p. 644.
5. Rowe, W.D. 1975. An Anatomy of Risk (draft): U.S. En-
vironmental Protection Agency, Washington, D.C., p. 209.
6. Starr, C. 1970. Benefit-cost relationships in socio-
technical systems: In Environmental Aspects of Nu-
clear Power Stations, A Symposium Proceedings. International
Atomic Energy Agency, Vienna, Austria. STI-PUB/261,
pp. 895-916.
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RISK ASSESSMENT METHODS FOR NUCLEAR WASTE
MANAGEMENT SYSTEMS
P. J. Pelto and J. W. Bartlett
Battelle, Pacific Northwest Laboratories
Richland, Washington 99352
T. H. Smith
Weyerhaeuser Company
Tacoma, Washington 98401
INTRODUCTION AND SUMMARY
Radioactive waste is generated in a variety of forms by
operations in the nuclear fuel cycle. Numerous management
systems have been devised to immobilize and isolate these
wastes. Such systems include multisite processing operations,
transportation, and storage/isolation.
Evaluation of waste management systems is a complex process.
Assessments of proposed systems involve consideration of
technical feasibility, research and development needs, timing,
cost, national and international policies, environmental
impact, and both the calculated and the publicly perceived
safety.
Risk analysis is a method of assessing the safety of proposed
systems. Through such an analysis, consequences of postulated
releases of radioactive material can be placed in perspective
by viewing the events relative to their probability of occur-
rence.
This paper reviews risk assessment methods and their potential
application to nuclear waste management systems. Previous and
ongoing studies on the risk/safety of high-level waste manage-
ment systems are discussed along with their limitations and
potential improvements.
BACKGROUND
In general, a risk analysis of a nuclear related system
consists of the following basic steps:
1. Definition of the inventory of radioactive material
and its containment/confinement barriers
2. Identification of potential failure modes
3. Estimation of the probability and amount of radioac-
tive material released by the potential failure
modes
2-11
-------
4. Analysis of the consequences of the radioactive
material released
5. Estimation of the system risk.
Figure 1 shows the information flow and calculational steps
for a typical risk analysis. More detail is given in the fol-
lowing section.
GENERAL RISK ASSESSMENT METHODS
Various approaches for performing risk analyses have been
developed. These methods are discussed as related to two
major areas of risk analysis: (1) analyses of potential
release sequence probabilities; and (2) consequences analysis.
ANALYSES OF POTENTIAL RELEASE SEQUENCES
Included in this category are the identification of the
potential release sequences and the estimation of their
probabilities for the system studied. The release sequences
can be postulated directly, derived by inductive ("what
happens if?") techniques, or deductive ("how can something
happen?") techniques. Some of the techniques available in-
clude hazards analysis, failure modes and effects analysis,
decision trees (event trees), and fault trees. A good survey
of these methods is given by H. E. Lambert (Ref . 2) . Each
approach has its advantages and limitations and often a
combination of techniques is advantageous.
Methods discussed in this paper include: event trees alone;
event trees with fault trees used to supply most of the branch
probabilities (Ref. 3); the similar cause consequence analysis
(Refs. 4,5) in which a fault tree feeds into an event tree
through a common critical event and in which fault trees again
supply most of the branch probabilities; and various fault-
tree techniques.
Inductive methods such as event trees (Refs. 2, 3) start with
an assumed initial failure. Additional component failures
required to obtain a release (system failure) are then
identified. Fault-tree analysis (Refs. 2, 6) is a deductive
process. The analyst assumes the occurrence of an event
selected as the top, undesired event as constituting system
failure. He then systematically works backward to identify
component faults that could cause or contribute to the
undesired events. Brief summaries of three recent approaches
for analysis of potential release sequences are given below.
A more detailed treatment is given in Appendix A.
Combinations of an initiating event and the response of the
various engineered safety features are modeled on event trees
The probabilities of key events in the event trees are
2-12
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DEFINITION OF CONFINED SOURCE
DEFINITION OF MANAGEMENT SYSTEM,
CONTAINMENT/ CONFINEMENT BARRIERS
IDENTIFICATIONS
POTENTIAL RELEASE SEQUENCES
CONSEQUENCES
PROBABILITY
DEFINITION OF
DISPERSED SOURCE
LI QUID TRANSPORT
POPULATION
DISTRIBUTION
AIRBORNE TRANSPORT
CONTAMINATED
ENVIRONMENT
1
PLANT, ANIMAL,
SEAFOOD UPTAKE
DOSE TO MAN
DEFINITION OF MAN'S
DIETS AND HABITS
PROBABILITY
OF RELEASE
Figure
1. Risk analysis calculation flow (Ref. 1)
-------
evaluated by means of fault trees. Each key event is defined
as the top, undesired event of a fault tree (Ref. 3).
D diagram
The cause-consequence diagram is similar to the event tree -
fault tree method. A critical intermediate event is selected
for study. Preceding events are analyzed by fault-tree analy-
sis with the critical event being the top of the fault tree.
Events subsequent to the critical event are handled by event
trees (Ref. 5) .
Fault-Tree Method
A large fault tree is drawn with the top event being release
from the facility. This fault tree traces the flow of radio-
active material through the system (usually a facility or
major operation) and all the events within the system appear
on the same fault tree. An event tree type of treatment is
used to model environmental transport and human exposure. The
binary limitation of fault trees (i.e., faults must be "on-
off") is circumvented by treating each release sequence (cut
set) separately and using a distribution of releases where
necessary (Refs. 7, 28).
The probabilities of the identified release sequences must be
calculated, as little or no statistical data are available.
Probabilities for the release sequences can be obtained from
estimates of the frequency of each component fault within the
release sequence. Sources of informaiton for assigning fault
probability values are: (1) experience with the component or
similar components, (2) testing, (3) engineering analysis, and
(4) engineering judgment. Care must be taken to account for
any potential dependency among component faults in the release
sequence.
The basic approaches described have both common and separate
strengths and limitations. A major limitation is that no
method can assure that all potential release sequences have
been identified. A physically realizable sequence may be
omitted because of simplification, oversight, lack of under-
standing of the system, or inability to envision all possible
sequences. Other basic limitations are the necessary data
requirements, potential dependencies (common cause failures),
and difficulties in modeling potential human interaction with
the system.
The fault-tree approach (Ref. 7) has some advantages and
weaknesses when compared with the similar event tree and
cause-consequence analysis. No assumption of an initiating
event or a critical event is necessary in the fault-tree meth-
od. This is an advantage for systems where the key initiators
are not known. Other possible advantages include more direct
treatment of common cause failures because all events appear
2-15
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on one fault tree, and potentially a more complete analysis
because the system is treated as a whole. A disadvantage of
this approach is the required analysis of very large fault
trees.
The event tree and cause-consequence analysis better facili-
tate and display the detailed analysis (particularly time
phasing) of accidents involving a common initiating critical
event. Using these techniques a complex problem can often be
divided into manageable segments. However, there is a disadvantage
in that there is no formal procedure to develop the required key
initiating events and no formal construction procedures for the
event trees or cause-consequence diagrams themselves. Diffi-
culties often arise in the ordering and the treatment of
dependencies of the branch operators (key events or decision
points in the event trees or cause-consequence diagrams).
Most safety analysts will agree that there is no best method.
A combination of the above complementary approaches is often
advantageous. A fault tree would be used as indicated above
to provide the most comprehensive coverage of potential
accidents and to separate those of prime interest. Detailed
analysis of such classes of accidents could follow by means of
event trees or cause-consequence analyses. If the key
initiating events are known with confidence, the comprehensive
type of fault-tree analysis may not be necessary.
CONSEQUENCE ANALYSIS
For nuclear systems, risk analyses consequences have typically
been analyzed in terms of amount of radioactivity released,
dose, health effects, and property damage.
The consequence analysis is usually accomplished in two
stages. The amount and physical-chemical characteristics of
the radioactive material released from the identified release
sequences are estimated. Then the transport of this release
by various pathways through our environment and the resulting
consequences to man and the environment are examined. Both of
these stages often require complicated mathematical modeling
and are subject to large uncertainty.
The first stage is very specific to the system studied and
general models have not been developed. The type of informa-
tion required includes volatility, solubility, and frangibility
data for the form of radioactive material in the system under
study, the degree of confinement system failure, and transport
and deposition of the release within the facility. The basic
sources of required information are existing experimental
data, test programs, engineering analysis, and engineering
judgment.
2-16
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Several general models exist for analyzing the transport of
radioactive material in the environment. Major pathways in-
clude atmospheric, groundwater, and surface water transport.
The output of these models is combined with dose models which
calculate the resultant dose to man. Strenge et al. (Ref. 8)
review the strengths and limitations of calculational models
and computer programs for evaluating the dose assessment of
radioactive releases. Figure 2 shows the consequence model
used in WASH-1400 (Ref. 3). The details of the atmospheric
pathway and the dose assessment models are not discussed here
and the reader is referred to the two references mentioned
above.
Risk assessment of nuclear operations sometimes requires
analysis of groundwater pathways (Ref. 9). Marino (Ref. 30)
reviews the literature in this area. A unified computerized
model of geosphere (Refs. 10-12) and biosphere (Refs. 13, 14)
transport has been developed (Ref. 15). For chains of radio-
nuclides des cursors and decay products) the equations devel-
oped for transport through geologic media include effects of
convection, diffusion, sorption, and generation and decay.
Simultaneous solutions of equations for all precursor radio-
isotopes as well as for the chain member of interest are
obtained. Solutions have been obtained for both impulse and
band releases. Transport through both salt and nonsalt media
has been studied. Typical results of geosphere transport
analysis appear in Burkholder et al. (Ref. 15). The geosphere
transport model links with the biosphere model (food chain,
etc.) at the point where the radionuclides enter a body of
surface water or an underground well.
If the consequences from a radioactivity release sequence are
expressed in terms of dose, there are three possible outputs:
(1) individual dose, (2) population dose, and (3) environmen-
tal dose. In past risk analyses relatively little quantifi-
cation has been done of the environmental dose commitment.
This dose commitment represents the sum of all doses to
individuals over the time period during which the released
material remains in the environment in a state available
for interaction with humans (Ref. 16). This concept, as
suggested by the Environmental Protection Agency (EPA)
(Ref. 29), needs consideration.
By use of the techniques described by the U.S. Atomic Energy
Commission (U.S. AEC) and the National Academy of Sciences,
National Research Council (Refs. 3, 17), the calculated dose
commitments can be combined with estimates of the health
effects from individual and population exposure to radiation.
Knowing both the consequences and the probability, a risk
expression can be generated. The most general definition of
risk is that it is some function of the probability and the
consequences of a release sequence. A frequently used defini-
tion of risk is the product of the anticipated frequency of a
2-17
-------
Release
Weather Data
Atmospheric
Dispersion
Cloud Depletion
Ground
Contamination
Dosimetry
Population
Evacuation
Health Effects
Property Damage
Figure 2. Outline of consequence model (Ref. 3).
-------
release sequence and its consequences. That is, risk is the
mathematically expected consequences of a release sequence.
Recognizing the subjective nature of risk and its perception
by the public, many studies (Refs. 3, 7, 16, 18) have avoided
the use of a specific risk expression and simply report curves
of probability versus consequences.
As indicated in the above discussion of risk assessment
methods, various degrees of sophistication of method and
output are possible. Safety analysis programs have different
objectives and different constraints on time (work completion
date) and cost. They therefore differ in breadth and precision
of analysis. Some programs involve existing systems with a
great deal of applicable system definition and safety-related
data. Safety/risk analyses of these systems can be performed
in considerable depth and with good accuracy if time and cost
constraints are not severe. On the other hand, studies made
during conceptual phases of system design preclude detailed
analysis. Other things being equal, the later in the system
life-cycle the study is performed, the more information is
available and the greater the accuracy of the results.
However, the sooner the analysis is made, the easier it is to
effect any safety-related changes in the system under study or
its conceptual design. A trade-off is involved between the
timeliness and the depth of accuracy of the analysis. Other
programs require a trade-off between the cost and the depth
and accuracy of analysis. A variety of analytic methods and
data retrieval systems is needed to satisfy the particular
requirements of different safety analysis programs.
APPLICATION OF RISK ASSESSMENT METHODS TO NUCLEAR
WASTE MANAGEMENT SYSTEMS
Nuclear waste management operations are divided into two
stages: (1) the short-term operating steps, and (2) long-term
isolation. A typical system for high-level waste is given in
Figure 3. The discussions in this section will deal strictly
with high-level waste. However, much of the information given
can be analogously applied to other waste streams. Figure 4
shows the other potential waste streams of the light water
reactor (LWR) fuel cycle.
SHORT-TERM WASTE MANAGEMENT OPERATIONAL ACTIVITIES
For high-level waste management, short-term operational steps
include three phases at a reprocessing plant (liquid storage*,
solidification and canning, and solid storage); transporta-
tion; possible interim storage; and emplacement operations at
a geologic repository.
* Liquid storage is planned to be minimized.
2-21
-------
REFERENCE HIGH-LEVEL WASTE MANAGEMENT SYSTEM
REPROCESSING PLANT
LIQUID
STORAGE
(3 YEAR INV.)
i
L
SOLIDIFICATION
& CANNING
LIQUID TRANSFER
(7 YEAR INV.)
RETRIEVABLE
SURFACE STORAGE
ULTIMATE
DISPOSAL
CANISTER HANDLING
(TRANSFER, LOADING,
— I—1^ "OFF-SITE" SHIPPING
Figure 3. Reference high-level waste management system.
-------
WASTE
STREAM
FUEL
PREPARATION
AND FABRICATION-
MINING
MILLING
CONVERSION
Figure 4. Potential LWR fuel cycle wastes,
-------
The basic methods described earlier have direct application to
these short-term operating phases. Safety/risk analyses of
waste management system operations have been performed to var-
ious depths; however, none has been attempted at the detailed
level comparable to WASH-1400 (Ref. 3).
McGrath (Ref. 19) reviewed waste management strategies and
discussed risk and risk reduction. Detailed analyses were not
performed, but an interesting approach was presented based on
an expected risk criterion. Using this criterion and
postulating upper limit consequences for liquid waste storage,
waste solidification, and solid waste storage, he estimated
permissible upper limit accident probabilities. The
conclusion was that the most stringent safety requirements
apply to liquid waste storage.
Studies are in progress at Battelle, Pacific Northwest Labora-
tories (Ref. 20) using the fault-tree method described earlier
for a conceptual high-level radioactive waste management sys-
tem. This system is assumed to consist of operations involv-
ing (1) liquid storage, (2) solidification, (3) water basin
storage, (4) rail transport, and (5) retrievable surface stor-
age.
Dominant failure sequences for the accidental release of
radionuclides have been tentatively identified for the various
activities of the reference system. Dominant sequences are
defined as those with the highest mathematical product of
probability and consequences, the latter in terms of quanti-
ties of waste released. The initial assessment revealed that
dominant scenarios that could conceivably have significant
public health and safety impact are highly improbable, e.g.,
on the order of 10~6 per year of operation.
Accidental releases of radioactive material initiated by both
process operating events and events external to the plant
(e.g, earthquakes) were found to contribute to total system
risk. Except for the mechanically or electrically induced
interruption of cooling water to stored liquid and solidified
waste, postulated release scenarios contributing the bulk of
the risk generally involved sequences intitiated by external
events.
Dominant scenarios with conceivable significant public health
and safety impact were associated with the passive storage
activities rather than with the relatively active modes of
solidification and transportation. This is primarily due to
the large radionuclide inventories associated with the storage
activities. Dominant scenarios were associated with airborne
pathways.
Reevaluation of this initial assessment is underway to ensure
that insights obtained by comparisons are valid. Areas of
future work include: (1) performing sensitivity studies,
2-27
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(2) establishing error bounds, and (3) performing more
detailed analyses on the dominant potential release sequences.
Smith and Kastenberg (Ref. 16) give a background discussion on
risk analysis and waste management and perform a brief risk
analysis for extraterrestrial disposal and interim surface
storage. The release scenarios analyzed were postulated
directly and the results indicate, within the assumptions
used, that the risks of these management schemes are small
compared with that of natural background radiation.
Several basic problem areas exist in assessing the risk of the
operational steps in waste management systems. An important
one is perhaps the lack of direct and readily available data.
In the performance of safety analyses of conceptual high-level
waste management systems, information gaps will be
encountered. This is expected, as there has been little
operating experience for high-level waste management activ-
ities. Only a relatively small amount of experimental work
has been done in identifying and analyzing the consequences of
potential accidents.
The basic information needs for improving existing safety
assessments and their usefulness can be placed in the follow-
ing closely related categories: (1) Additional information on
the probability of breaching containment/confinement barriers
versus the severity of the breach; (2) data on the quantity,
transport mechanism, and the chemical-physical form of the
radioactive material released from failed barriers; (3) more
information on system characteristics and interactions in the
accident environment; and (4) more information characterizing
the solidified high-level waste form.
Another factor that limits the detail and accuracy of risk
assessments of waste management operational steps is the con-
ceptual nature of present designs. This results in a limited
treatment of common cause failures and human error. It also
results in difficulties in treating severe external environ-
ments (e.g., earthquakes).
LONG-TERM WASTE ISOLATION
Present programs in the United States and elsewhere for com-
mercial high-level waste are aimed at isolation in deep geo-
logic formations. To assess the risk of a geologic repository,
methods must account for a spectrum of events that could
cause loss of geologic integrity and subsequent adverse
consequences. Four types of potential causes of loss of
isolation have been identified:
1. Sudden natural events such as meteorite impact
2. Geologic processes such as faulting or ice ages
2-28
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3. Changes in local geology caused by creating the re-
pository and by introducing thermal and radiation
sources
4. Human intrusion.
Some safety assessments have been made in each of the above
categories. Approaches based on probabilistic techniques,
consequence analysis, risk analysis, and hazard indices have
all been used. Work remains, however, to expand the scope of
the studies and to evaluate past assessments. The factors
involved pose difficult challenges and clearly demand
assessment techniques beyond those conventionally used. Some
of the unique challenges anticipated include:
1. Consideration of geologic mission times and slow geo-
logic processes
2. Consideration of events where the resulting radiolog-
ical consequences could be delayed by hundreds of years
3. Consideration of events that are orders of magnitude
less likely to occur than those normally associated
with what could be termed major accidents
4. Consideration of natural events so catastrophic that
the release of radioactive material as the result of
loss of geologic isolation could be of secondary
concern
5. The use of existing radiological consequence
(pathway) models for estimating dose to far-future
generations
6. The use of assessments where results are not subject
to demonstration
7. Consideration of life styles and technological
capabilities of future civilizations
8. The need for effective communication of information
on risk situations that could be beyond current human
cognition and perspective.
The above considerations make it difficult to apply the risk
analysis methods discussed earlier to geologic isolation. A
major problem is the absence of predictive data and the fact
that the application of failure data (rates) and radiological
consequence (pathway) models to the very long time periods
involved can become highly speculative.
The above concerns do not necessarily imply that existing risk
analysis methods will be without value in evaluating the safe-
ty of geologic isolation activities. Fault trees can be used
in the systematic identification and graphic illustration of
factors that could cause the accidental release of radio-
nuclides. Schneider and Platt (Ref. 21) present a generic
fault tree related to geologic concepts.
Most past safety studies of geologic isolation have analyzed
either the probability or the consequences of selected
2-29
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potential release sequences. No in-depth systematic studies
have been performed.
Claiborne and Gera (Ref. 22) analyzed selected containment
failure mechanisms and their consequences for a bedded salt
repository. Causes of containment failures examined included
drilling through the geologic disposal formation, impact of a
meteorite, volcanic activity, a fault intersecting a reposito-
ry, sabotage, nuclear warfare, increase in salt dissolution
rates, and waste disinterment by erosion of the overburden.
The primary conclusion was that a serious breach of contain-
ment for such a repository is only a very remote possibility.
Consequence estimations were made only for a meteorite impact.
Probability estimates were given for meteorite impact and for
faulting. Other events were analyzed qualitatively.
Gera and Jacobs (Ref. 23) gave a qualitative discussion of
natural geologic processes relevant to waste disposal. These
include faulting, erosion, leaching and transport by ground-
water, and plastic deformation of the disposal formation.
The toxicity or hazard index approach has been used to assess
the potential consequences of geologic disposal. From the
concept of maximum permissible radionuclide concentrations in
water, a typical Relative Hazard Index (RHI) can be defined
for radionuclide i:
(RHI). = ?i__
1 (MPCW)i
where Q^ is the radioactivity in curies of radionuclide i, and
(MPCW)i is the maximum permissible concentration of radionu-
clide i in drinking water (curies/m^) (Ref. 24). The total
RHI of a mixture is the sum of the (RHI)^'s. Several authors
have used this or a modified hazard index approach (Refs.
16, 19, 25, 26). Hamstra {Ref. 25) has shown that after
a few hundred years the waste from a metric ton of spent
pressurized water reactor (PWR) fuel presents a smaller
total hazard than that of the ore required to produce the
fuel.
The limitations of the hazard index approach include the
inability to take into account waste form and insolubility,
storage facility design, remoteness from man's environment,
food chain buildup, or even the pathway into the water supply
(Ref. 27). It is only a measure of potential hazard under 100
percent transport conditions.
A more detailed consequence analysis approach is that by use
of transport models. Burkholder (Ref. 15) has developed one
such model that can be applied to geologic repositories. The
basic features of this model were discussed earlier in the
section on consequence analysis. Nuclide release to an
underground water stream that flows directly through the
2-30
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geologic medium to a surface water body was assumed. The time
of release initiation, the nuclide release rate, and the
migration distance to the biosphere were parametrically var-
ied. Sorption equilibrium is assumed at all points along the
migration path. Doses were calculated for a maximum individu-
al and the results of this study show that for reasonable
storage conditions, the potential incremental radiation doses
would be of the same order as, or less than, doses from
natural sources.
Additional work is required in both release sequence analysis
and consequences analysis for geologic repositories. At this
point in time a detailed probabilistic risk analysis (i.e.,
WASH-1400) of geologic isolation does not seem feasible. How-
ever, basic methods are in place to assist in identifying
potential release sequences and in estimating probabilities
and consequences. Analyses can be performed for specific
release sequences of concern, drawing on existing data and
extrapolation of past experience. The degree of confidence in
the results depends on the availability and applicability of
data and the validity of the extrapolations.
CONCLUSION
Methods and background information from previous studies are
available to assist in quantifying the risk of waste manage-
ment systems. The degree of detail in any risk analysis is
limited by the conceptual nature of many waste management sys-
tems, lack of detailed failure data, and by the special prob-
lems encountered with geologic isolation. Risk methods
continue to evolve and research and development programs are
being established to supply needed information. Table 1 sum-
marizes some ongoing work on the safety of high-level waste
management.
Potential benefits from a systematic risk assessment of waste
management systems incude: (1) systematic identification of
conceivable failure modes, (2) development of perspective on
the relative safety of system components, (3) identification
of research and development needs for supplying missing data,
(4) preliminary input for management decision-making and
improved system design, and (5) establishment of a rational
basis for choosing between alternative waste management sys-
tems.
2-31
-------
Table 1. Ongoing Safety Studies of Kigh-Level Waste Management
Radioactive Waste Management
Systems Model
Technical Support for
Environmental Radiation
Protection Standards
Concerning High-Level
Radioactive Waste
Management
Environmental Survey of the
Reprocessing and Waste
Management Portions of the
LWR Fuel Cycle
Determination of Performance
Criteria for High-Level
Solidified Nuclear Waste
Risk Methodology for the
Evaluation of Radioactive
Waste Disposal
Waste Management Studies
Waste Management Safety
Waste Isolation Safety
Assessment
Generic Waste Management EIS
Transportation Safety Studies
Alternatives for Long Term
ofDefense_Waste
Sponsoring
Agjen,c_y_
EPA
EPA
Contractor
Lead
Individual
NRC
Univ. of New Mexico S.E. Logan
(RFP Recently
sent out)
Task Force
NRC
NRC
ERDA
ERDA
ERDA/OWI
ERDA
ERDA
ERDA
LLL
Sandia
PNL
PNL
PNL
PNL
PNL
Hanford, Savannah
River & INEL
Jerry Cohen
P.E. McGrath
J.W. Bartlett
L..D. Williams
G.J. Dau
C.M. Unruh
L.D. Williams
-------
APPENDIX
THE WEB OF EVENTS
Figure A-l, a simplified diagram of the generalized web
of events for facility release sequences, facilitates comparing
the methods reviewed for sequence identification (Ref. 7).
The points in Figure A-l represent types of events,
some of which are linked by lines to indicate a nonzero
probability of occurring in the same release sequence.
Time increases along the horizontal coordinate. The vertical
coordinate provides a way to plot distinct types of events.
Across the top of the diagram are listed five general classifications
of events as they might occur in a release sequence. Initiating
events are typically those leading to exposure of the
primary containment of the radioactive material to severe
mechanical, thermal, and/or chemical environments. For
example, a loss of cooling accident for water basin storage
of encapsulated, solidified waste might involve power outage,
pump failures, pipe failures, or various combinations of these.
Next are the types of events that actually negate the
primary containment, resulting in release of radioactive
material within the facility. Examples are waste canister
failure or, for a liquid source, a vessel breach.
The events related to a release from a facility are those
that might occur immediately following the failure of primary
containment. They typically involve passage of radioactive
material through various segments of the ventilation or
off-gas systems, culminating in exit from the building.
Thus, the first three categories involve events occurring
almost exclusively within the facility.
The last two categories involve events that generally occur
outside the facility. Events related to the environmental
transport and deposition of the radioactive material are
governed primarily by conditions such as weather and topography
near the facility. Considerations such as land use factors
lead into the final classification, irradiation. This
involves events of actual exposure, influenced chiefly
by population density and radiological factors.
HOW VARIOUS SYSTEMS SAFETY METHODS HANDLE THE WEB
OF EVENTS
Listed down the left side of Figure A-l are several ways
of studying the release sequences. Model A is intended
to indicate the total web of possible events. Models B,
C, D, and E indicate four ways of dividing the problem into
smaller pieces, to be followed by integrating the web back
together so as to obtain the total result.
2-35
-------
BETTER BUT
MORE COMPLEX
FAULT TREE
APPROACH
FAILURE
OF PRIMARY
CONTAINMENT
RELEASE
FROM
FACILITY
ENVIRONMENTAL
TRANSPORT AND
DEPOSITION
IRRADIATION
EVENT TYPE |
ANALYSIS TYPE
INITIATING
EVENTS
ACTUAL SEQUENCES
EVENT TREE
CAUSE/CONSEQUENCE
DIAGRAM
PNL FAULT
TREE APPROACH
Figure A-l.
A simplified diagram of the generalized web of events
of accidential releases from facilities.
for analysis
-------
In Model B, which is intended to illustrate the event-tree
approach, one of the mutually exclusive initiating events
(the point enclosed by the box in Model A) is followed
along a widening path to the final events. For analysis
of loss-of-cooling accidents, a pipe break might be selected
as an initiating event (Ref.3).
Model C is an attempt to depict a typical application of
cause-consequence analysis. One of the mutually exclusive
intermediate events involving or preceding release of radio-
active material from primary containment is selected for
study. All paths leading to this event, termed the "critical"
event, are analyzed by fault-tree analysis. The critical
event is the top event of the fault tree. All subsequent
events are handled as in the event-tree analysis of Model B.
The problem is neatly divided into two parts, the interface
being the selected critical event.
If, in the example for Model B, a pipe break were the result
of preceding initiating events, then the analysis would
probably be performed as in Model C. In both methods,
the event tree branch probabilities are often obtained
by means of separate fault trees. The top events of such
fault trees are the branch events or decision points.
Model D represents a Pacific Northwest Laboratories (PNL)
fault-tree technique. Each mutually exclusive, terminating
point for Model A related to a release from a facility
is "clipped" or isolated. Events leading to and proceeding
from each point are analyzed. The two parts of the web
are then rejoined to give the total flow of events.
In the application of Model D, the system fault tree is
drawn with the top event representing a release from a
facility by any pathway. The mutually exclusive interface
events described in the preceding paragraph are generally
drawn as the next-to-top level events. They represent
the various release modes out of the final containment
barrier(s). Examples are airborne release up the stack,
airborne release through the walls of the building, and
release into a stream. The preceding events related to
a release from a facility represent the flow of radioactive
material through the ventilation and off-gas systems of
the facility. These events, as well as the primary containment
failure events and the initiating events, all appear on
the same fault tree. Following the interface events, an
event tree type of treatment is used to model environmental
transport and deposition of the material and human exposure.
The prerelease (from the facility's outer barrier) occurrences
generally involve electrical, mechanical, and/or chemical
events related to engineering. Postrelease occurrences generally
involve environmental and biological events associated
with those scientific disciplines. If a complete set of
2-39
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mutually exclusive events (consisting of the release of
certain types of radioactive materials in certain modes)
can be determined and the probability and radiological
consequences of each type of release calculated, then a
value of risk can be estimated.
In Model E, one of the mutually exclusive final events
is selected for study. All paths leading to it are studied
by means of fault-tree analysis.
SELECTION OF A SYSTEMS SAFETY METHOD
A potential weakness of any systems safety method exists
in the process of uncoupling the web of events, performing
independent calculations on these segments, and then recoupling,
Interactions among the uncoupled portions of the web are
easily overlooked.
The approaches of Models B and C are vulnerable to interactions
occurring within the facility. In Model C, the uncoupling
occurs within the facility. In both Models B and C, the
use of separate fault trees to develop the branch probabilities
of the event tree could result in missed interactions between
basic events in different fault trees. For example, a
fire that fails the primary containment might also lead
to failure of the ventilation system. Extreme caution
is required in these methods to guard against missing such
common-cause failures.
An advantage of Model D over Model C is that in-facility
events are treated on the same fault tree rather than on
several fault trees and an event tree. This tends toward
a reduced possibility of overlooking in-facility common-
cause failures. The disadvantage is a more complex fault
tree.
Model E may be the most rigorous model, at least on one
point: in progressing from Model C, to D, to E, the top
event of the fault tree comes closer to our ultimate interest—
exposure of man. Also, Model E guards against undiscovered
coupling between prerelease and postrelease events, to
which the other models are vulnerable. Examples of such
events are earthquakes, which could alter aquifers in the
release area, and tornadoes, which could temporarily alter
local meteorology. Unfortunately, Model E is generally
too complex to be considered currently feasible.
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REFERENCES
1. Smith, T. H. et al. 1974. A Methodology for Risk
Analysis of Nuclear Waste Management Systems. Presented
to the American Nuclear Society 20th Annual Meeting,
BNWL-SA^-4899, Battelle, Pacific Northwest Laboratories,
Richland, Washington (June).
2. Lambert, H. E. 1973. Systems Safety Analysis and Fault
Tree Analysis. UCID-16238, Lawrence Livermore
Laboratory, University of California (May).
3. U.S. Atomic Energy Commission (U.S. AEC). 1975. Reactor
Safety Study, An Assessment of Accident Risks in
Commercial Nuclear Power Plants. WASH-1400 (October).
4. Nielsen, D. S. 1971. The Cause/Consequence Diagram
Method as a Basis for Quantitative Reliability Analysis.
Presented at the ENEA/CREST Meeting on Applicability of
Quantitative Reliability Analysis of Complex Systems and
Nuclear Plants in its Relation to Safety. Munich (May).
5. Burdick, G. R. and J. B. Fussell. 1975. On the
adaptation of cause consequence analysis to U.S. nuclear
power systems reliability and risk assessment, in: A
Collection of Methods for Reliability and Safety
Engineering. Aerojet Nuclear Company, ANC 1273, Idaho
Falls, Idaho (June).
6. Haasl, D. F. 1965. Advanced concepts in fault tree
analysis. In: Proc. Systems Safety Symp. Univ. of
Wash, and the Boeing Co., Seattle, Washington.
7. Smith, T. H. and P. J. Pelto et al. 1976. A Risk Based Fault
Tree Analysis Method for Identification, Preliminary
Evaluation, and Screening of Potential Release Sequences
in Nuclear Fuel Cycle Operations. BNWL-1959, Battelle,
Pacific Northwest Laboratories, Richland, Washington
(January) .
8. Strenge, D. L. et al. 1976. Review of Calculational Models
and Computer Codes for Environmental Dose Assessment
of Radioactive Releases. BNWL-B-454, Battelle, Pacific
Northwest Laboratories, Richland, Washington (June).
9. Smith, T. H. et al. 1976. Analytic methods for fuel cycle
safety sources. In: IEEE Transactions on Reliability.
R-25 (3) :184-190.
10. Lester, D. H., G. Jansen, and H. C. Burkholder. 1975.
Migration of radionuclide chains through an
adsorbing medium. AlChE Symposium Series No. 152.
Adsorption and Ion Exchange 71:202.
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11. Burkholder, H. C. 1976. Methods and Data for predicting
Nuclide Migration in Geologic Media. Proceedings of the
International Symposium on the Management of Wastes from
the LWR Fuel Cycle. Energy Research and Development
Administration. CONF-76-0701:658.
12. Gibbs, A. G. and H. C. Burkholder. 1975. Radionuclide
Migration From Salt Formations. Nuclear Waste Management
and Transportation Quarterly Progress Report. BNWL-1936,
Battelle, Pacific Northwest Laboratories. Richland,
Washington (September), pp. 4-5.
13. Soldat, J. K. et al. 1974. Models and Computer Codes
for Evaluating Environmental Radiation Doses. BNWL-1754.
Battelle, Pacific Northwest Laboratories, Richland,
Washington.
14. Denham, D. H. et al. 1973. "Radiological Evaluations
for Advanced Waste Management Studies. BNWL-1764.
Battelle, Pacific Northwest Laboratories, Richland,
Washington.
15. Burkholder, H. C., M. 0. Cloninger, D. A. Baker, and G.
Jansen. 1976. Incentives for partitioning high-level
waste. Nuclear Technology 31:202.
16. Smith, C. F. and W. E. Kastenberg. 1976. On risk
assessment of high level radioactive waste disposal.
Nuclear Engineering and Design 39:293-333.
17. National Academy of Sciences, National Research Council.
1972. The Effects on Population Exposure to Low Levels
of Ionizing Radiation. Washington, D.C. (November).
18. McSweeney, T. I. and R. J. Hall et al. 1975. An
Assessment of the Risk of Transporting Plutionium Oxide
and Liquid Plutonium Nitrate by Truck. BNWL-1846,
Battelle, Pacific Northwest Laboratories, Richland,
Washington (August).
19. McGrath, P. R. 1974. "Radioactive Waste Management
Potentials and Hazards from a Risk Point of View. KFK-
1992.
20. Winegardner, W. K. et al. Systems safety evaluation.
In: Quarterly Progress Report Research and Development
Activities Waste Fixation Program, January through March
1976. BNWL-2080, Battelle, Pacific Northwest
Laboratories. Richland, Washington.
21. Schneider, K. J. and A. M. Platt, eds. 1974. High-Level
Radioactive Waste Management Alternatives. BNWL-1900,
Batelle, Pacific Northwest Laboratories. Richland,
Washington (May).
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22. Claiborne, H. C. and F. Gera. 1974. Potential
Containment Failure Mechanisms and Their Consequences at
a Radioactive Waste Repository in Bedded Salt in New
Mexico. ORNL-TM-4639 (October) .
23. Gera, F. and D. G. Jacobs. 1972. Considerations in the
Long-Term Management of High-Level Radioactive Wastes.
ORNL-4762 (February).
24. U.S. Nuclear Regulatory Commission (NUREG-0116). 1976.
Environmental Survey of the Reprocessing and Waste
Management Portions of the LWR Fuel Cycle (October).
25. Hamstra, J. Radiotoxic hazard measure for buried solid
radioactive waste. Nuclear Safety 16:2.
26. Claiborne, B.C. 1975. Effect of Removal on the Long-
Term Hazard of High-Level Waste. ORNL-TM-4724 (January).
27. Jansen, G. et al. 1974. Chemical toxicities of high-
level wastes generated through the year 2000. In:
Advanced Waste Management Studies Progress Report
(April-June). BNWL-B-223-11 (July).
28. Fullwood, R. R. and R. C. Erdmann. On the use of leak
path analysis in fault tree construction for fast reactor
safety. Proceedings of the Fast Reactor Safety Meeting.
U.S. AEC, CONF-740401-P3:1493-1507.
29. United States Environmental Protection Agency (EPA).
1974. Environmental Radiation Dose Commitment: An
Application to the Nuclear Power Industry. EPA
520/4/73-002 (February).
30. Marino, M. A. 1974. Distribution of Contaminants in Porous
Media Flow. Water Resources Research 10:1013.
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ECONOMICS OF RADIOACTIVE WASTE DISPOSAL
Stephen 0. Andersen
Sierra Club Research
San Francisco, California
The Environmental Protection Agency (EPA) is under substantial
pressure to promulgate regulations for secure storage of radio-
active waste. This pressure is in part from the biophysical
risks of temporary storage in admittedly inadequate facilities,
and is in part a response to successful citizen intervention
that demands acceptable waste disposal as a precondition to
further nuclear power plant licensing.
The government has responded to these demands by mandating
strict timetables for health regulations, site identifica-
tions, and disposal facilities development. This paper
addresses the economic implications of waste disposal on util-
ity choice of new power plants and the substantial uncertainty
that secure storage can be developed on a prescribed
timetable.
ECONOMICS OF EXISTING AND ANTICIPATED RADIOACTIVE WASTE
For existing radioactive waste, prudent and economic disposal
is determined by the balancing of cost and benefit. The
benefit is measured by the reduction in risk achieved by
isolation from the biosphere. Because the consequences of
waste dispersal are so serious, it is anticipated that
extraordinary engineering efforts will be employed. If the
best available disposal merely meets minimum standards of
safety, very little economic trade-off will occur. In any
case the selection of the first disposal site will probably
occur before a large inventory of comparable and possibly
superior sites are identified.
Economic analyses of waste disposal from operating nuclear
power plants, and particularly from planned nuclear plants
offers a much broader set of choices. In this case the analy-
sis can identify changes in each step of the fuel cycle (from
uranium mining to radioactive waste disposal) such that total
costs of delivering electricity are minimized. For example,
Kubo and Rose (1973) and Rose (1974) suggested that repro-
cessing could reduce long-term radioactivity by a factor of 100
at a cost of 0.02<:/kWh. If this were less expensive than
achieving the same level of safety through more protective
storage, it is in the interest of economy to encourage that
processing.
The full spectrum of fuel cycle choices is influenced by
assumptions about the cost of waste disposal. For instance,
the design of the reactors assumes a certain price and avail-
2-45
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Table 1. Cost Incidence Categories of Power Plant Assessment
~I7 Coits~Included "In 'Utility ~Eltiriiates""of^Erictr Ic rty"froiii"New~Plants
A. Direct Financial Costs of Capital, Fuels, and Management Paid by Electricity Consumers
1. Residential
2. Commercial (Direct financial costs of capital, fuel, labor and other operating
3. Industrial expenses including return to utility stockholders)
II. Costs Paid By American Society but not Included in Public Utility Estimates
A. Utility, Utility Supply Industry and Resource Owners (^ (cost overruns, utility cost of faulty
plants before inclusion in rate base, equipment supplier cost overruns, and inability to recover
research expense, loss to landowners whose land is condemned and purchased at less than nuclear
site value, uncompensated restrictions on land use adjacent to plants, costs of delay from
political controversy, etc.)
B. Public
1. Federal taxpayers'2) (research, technical assistance, management, manpower training, fuel
subsidy, fuel processing subsidy, waste disposal, antitrust concessions, tax exemptions,
accelerated depreciation, insurance subsidy and liability limitation, etc.)
2. State taxpayers (2) (tax exempt bonds, foregone development, investment credits, monitoring
and administrative costs, other tax breaks, etc.)
3. Public health (worker safety, cancer, and other radiation-induced diseases, etc.)
4. Environmental (agricultural and wildlands damage, animal kills, etc.)
5. Private enterprise (3) (risk of plant failure and unreliability, sensitivity to price increases,
cost of standby equipment and fuel, etc.)
6. Personal freedom (police power infringement to protect plants, costs of dissenting citizens,
etc.)
C. Costs With Uncertain Incidence (disposal costs for wastes from American-built foreign reactors,
military expense to balance new threats by foreign nuclear powers, police assistance to guard
_______ foreig_n_nuclea£_industries_f rom_glujtqnium_a^ ________ _
(1) These are the costs to utility stockholders from bad investments, to utility management from bad
decisions, to nuclear plant manufacturers who cannot recover expenses, etc. Since this category
does not include expenses that are recovered from electricity sales (Category I) , no double counting
occurs when the four categories are summed.
(2) Government leasing policies, which reduce revenue from publicly owned energy sources, lower the
ability to provide government services and/or increase the rates of taxation. Energy pricing
structures do not distribute this sort of energy subsidy on a per capita basis.
(3) Including the costs of power shortages due to nuclear plant unreliability.
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ability of fuel; the operators choose an optimal fuel
deterioration before refueling; the development of breeder
technology is dependent on both availability and favorable
price of reprocessed waste; and the rate of implementing any
nuclear technology depends on the opportunity cost of each
developmental sequence. To the extreme, a very high cost of
radioactive waste disposal might make fossil-fuel systems a
less expensive utility choice. The substitution of fossil-
fuel units would be particularly evident in locations where
they are already very competitive options. For a more thor-
ough discussion of these relationships, see Andersen (Ref. 1).
As economists and risk analysts identify social costs that
have been previously ignored by utility planners and incorpo-
rate those costs in electric rates, a healthy economic process
ensues. Consumers react to the higher prices by increased
insulation, improving appliance and machine efficiency, and
through readjustment of their consumption priorities. These
substitutions, among energy sources and between conservation
and supply options, are the mechanisms that a free society
uses to allocate resources.
Both the substitution of one energy source for another by the
cost minimizing utility and the consumer decision to conserve
energy are constructive economic changes prompted by the
inclusion of a cost in the price. The cost of radioactive
waste disposal is inherent in nuclear technology even if it is
paid by taxpayers rather than by electricity users. Econo-
mists advocate the full inclusion of costs in the prices of
products and services so customers can have accurate price
signals to guide their spending decisions. It is uneconomic
to sell electricity from nuclear plants at a subsidized price
and to charge the incidental cost of waste disposal to citi-
zens through taxes. If decisions to protect the public from
radiation increase the cost of nuclear technology to the point
that society will not buy the electricity, so be it.
The economic regulation of waste allows utilities and other
radioactive waste generators to seek out whatever means
achieve mandated safety assurance at least cost. If we assume
that the disposal is not completely failsafe and that a
positive element of risk (as a function of probability and
consequences) remains, a two-part service charge is necessary
to encourage economic efficiency. The first charge is set to
recover the actual expense of building and operating the
facility. The second surcharge is set equal to the expected
health and property damage over the interval of waste storage.
Because our estimates of release may not be correct, it is
appropriate to require utility funded insurance to accumulate
financial reserves sufficient to protect future generations
against unacceptable expense of remedial actions. This two-
part charge to the utility should be treated like any other
cost of doing business.
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The goals of efficient resource allocation are pursued by
continual efforts to identify and incorporate neglected costs
in decision calculations. For nuclear electric power plants,
waste disposal costs are merely one element of the external-
ities. Table 1 presents an outline of these currently
neglected expenses.
The process of increasing the price of nuclear technology to
approach its real cost will encourage nuclear advocates to
join with governmental agencies in constructive efforts to
raise the price of alternative energy to reflect its full
social costs. This process is a sharp contrast from current
industry arguments to maintain subsidies via unaccounted envi-
ronmental costs for all hazardous energy sources. Higher
overall energy prices will dramatically encourage America's
energy conservation goals.
ENGINEERING AND GEOLOGIC UNCERTAINTY IN SITE SELECTION
John Bartlett's paper (in these proceedings) offers an
excellent overview of risk assessment in uncertain environ-
ments. I cannot improve upon his presentation but I would
suggest several additional concerns:
1. Now that the resolution of radioactive waste storage
is a major physical and legal barrier to expansion of
the nuclear power plant industry, how can we isolate
scientists from the substantial pressure to choose a
"solution" prior to comprehensive investigations?
2. Given the limited geological mapping outside mineral-
ized areas in the United States and other developed
countries and the even more limited understanding of
the remainder of the earth, how can we be sure that
the first sites selected within our country are ac-
ceptable relative to the potential for safe storage?
3. If the earth's crust includes only a few acceptable
sites for safe disposal, how will we allocate the
limited capacity among those nations who elect to
produce the waste? Is it judicious to signal a go-
ahead to the nuclear industry after identifying a
single tentative plan for disposal when substantial
undisposed radioactive waste already exists?
4. How can current and unanticipated scientific
discoveries of man's impact on geologic stability
(such as the recent correlation of increased seismic-
ity from reservoir foundation loading) be factored
into site selection?
CONCLUSION
Economic regulation of radioactive waste disposal can guide
the choice of sites, select the level of engineered protec-
tion, and provide the proper incentives for modification or
rejection of the nuclear fuel cycle. Such regulation must
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specify the conditions of safe disposal and assign the program
plus the storage hazard costs to the originators of new radio-
active waste.
The choice of cost-effective disposal must be made
independently of the financial impact on nuclear power plants.
If that technology cannot pay its own way, society is better
served by postponement of its use.
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REFERENCES
1. Andersen, Stephen 0. 1976. Economics of electricity
generation: the context of the 1976 California nuclear
powerplant initiative. In: California Energy: The
Economic Factors. Federal Reserve Bank of San Francisco.
2. Kubo, A. S. and D. J. Rose. 1973. Disposal of nuclear
wastes. Science 182:1205.
3. Rose, D. J. 1974. Nuclear electric power. Science
184:351-359.
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ANALYZING THE DECISION ON RADIOACTIVE
WASTE MANAGEMENT
Stephen M. Barrager and D. Warner North
Decision Analysis Group
Stanford Research Institute
Menlo Park, California 94025
INTRODUCTION
Radiation waste management is not a problem that can be
avoided by withdrawing the commitment to use fission reactors
to produce electric power. The reactors already deployed and
the military weapons program imply that society must now
decide what to do with large quantitites of radioactive waste
material. Further development of nuclear electric generation
will add more to the quantity but the necessity for decision
has already arrived.
Why is radiation waste management such a difficult area of
public policy? There are several contributing factors. The
waste is extremely toxic, and it retains its poisonous charac-
teristics for a time period far longer than human institutions
are thought to endure. It can be transmuted into an inert
form only at great cost and difficulty. How can these poisons
be contained for a long enough period, considering the
multitude of potential future events that might cause the con-
tainment to be breeched? How can we be sure that for the next
million years the monster will remain in its cage?
Radiation waste management therefore involves assessing the
small probability of a potentially catastrophic event, for
which the information available to base the assessment is
scanty and complicated by the vagaries of human nature: human
error or human malevolence might lead to release.
How can quantitative analysis possibly deal with such problems
in a way adequate for public policy? It is an awesome task,
and we could spend many years discussing all the aspects that
make it so difficult. But in the meantime, we have already
accumulated a great deal of radioactive waste, and we are
committed to accumulate more. What are we going to do with
it?
THE ROLE OF ANALYTICAL METHODOLOGY
The focus of our discussion becomes much clearer if we agree
at the outset on a starting point: the United States and
other industrialized countries face a decision on how to
manage radioactive wastes. Whatever the methods, rational or
irrational, quantitative or qualitative, the decision exists
and society must deal with it. Postponement or pretending the
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decision is not there are possible alternatives, of course. If
we wait for perfect decision criteria or for all of the ana-
lytical 1 fficulties to be resolved, we choose the postpone-
ment alternative by default. Let us agree that the need for
decision on radiation waste management exits, and that we want
our decision makers to do the best job they can to confront
this need and act in society's interest, consistent with the
information that is available now or that can be made avail-
able in the immediate future.
The role of quantitative analysis is not to provide perfect
cut-and-dried answers, but to try to help decision makers,
experts, and concerned citizens in arriving at a decision. We
cannot expect quantitative analysis to magically resolve our
uncertainty about the evolution of technology, society, and
human nature over the next million years. We can only use it
as a framework for integrating the available information and
judgment, and for pointing out where differences in judgment
are most significant.
Critics of quantitative analysis are fond of stating that the
problems are so complex and the available information so
inadequate that "we do not know enough" to do a quantitative
analysis. This viewpoint misses an understanding of what the
role of analysis is, but this criticism has much justifica-
tion. Most of us have seen calculations that summarize very
complex issues into a "bottom line" number. Given that these
calculations exist, there is a temptation to take that number
out of context and treat it as "gospel." "The government had
XYZ Research, Inc., do a risk analysis and the answer was six
chances in a million." The analyst responsible for calculat-
ing that number may cringe as his carefully thought out cave-
ats and assumptions are passed over in the rush to find that
bottom line, which is then treated like a mysterious pro-
nouncement from the Delphic Oracle. This is a mode of deci-
sion-making that has been common in complex technological
matters: leave it to the specialists who understand the
subtle technical issues involved. Unfortunately, this
approach does not always prove satisfactory. The specialists
are not without biases, their specialization may not be broad
enough to encompass the full range of issues involved, and
they often fall prey to the weakness of leaving out or
glossing over those aspects of the problem that they do not
understand very well.
Therefore, it is said, let us force these specialists to tell
us how they arrived at their recommendations, and let us
subject them to cross-examination and adversary proceedings
against other specialists who hold differing views. What
emerges from this process is also frequently unsatisfactory:
Each side presents detailed arguments, scenarios, statistics,
and examples in which some issues are examined ad nauseum and
others are ignored. Laymen and public officials may be
confused by the complex and conflicting testimony. The deci-
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sion process may reduce to lengthy and inconclusive hearings
in court, or popular referendums on which the opposing inter-
est groups hire clever ad agencies to compete for the voter's
attention, so as to resolve the issues on which the technical
experts and political leaders cannot agree. The process is
inefficient and frustrating, and many on both sides assert
that the decisions are being arrived at for the wrong reasons.
But it is a democratic process, and what better alternative
process do we have?
Let us take another look at analysis, but as a framework for
integrating the issues affecting a decision rather than as a
formula for computing an answer—a bottom line. The role of
the analysis should be in communicating the process—how to
get to the bottom line, and how various judgments or items of
information might affect it, and hence, affect the decision.
If we do not perform any explicit calculations, the many
complex factors bearing on the decision must be integrated
another way, such as through the subjective judgment of
specialists.
The role of the analysis is not to provide an answer, but
rather to provide insight that will assist the political
leadership, the technical experts, and concerned citizens in
the process of reaching a decision. In other words, the anal-
ysis should never assume the responsibility of the decision.
That responsibility should remain with the people who had it
originally. Analysis is useful only if it helps those people
to understand better the decision for which they have respon-
sibility. As society confronts difficult decisions such as
what to do with radioactive waste, there is a temptation to
wish for an analysis that would make the decision obvious, and
ease the burden of responsibility. Despite the enthusiasm of
the analyst to assume responsibility and the tendency of some
of our leaders to shun their responsibility by seizing the
bottom line the analyst develops, the responsibility for
social decisions must remain with the people and institutions
that have been set up for the purpose—the electorate, elected
officials, their appointees and advisees, and the courts.
ANALYSIS AS A FRAMEWORK FOR INTEGRATING
THE ISSUES RELEVANT TO THE DECISION
The caveats mentioned above on the role of analysis should
tell us that we should not be wasting our time debating wheth-
er all the important factors related to waste disposal and
storage can be included in an analytical framework. Rather,
let us assume we are setting out to do the best job we can to
help decision makers discharge their responsibilities to deal
with the radiation waste management problem. If the analyst
is successful, the decision maker will feel he has been
helped. To the extent that the analysis is unsuccessful in
dealing with an issue, the decision maker is going to have to
confront it anyway with whatever means are at his disposal.
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Let us now turn our attention to the analytical tools and try
to achieve a perspective on them. In order to address an
issue like radioactive waste management, we need to have the
means to model complex causal sequences, to deal with uncer-
tainties, and to characterize the trade-offs among conflicting
objectives that the decision may entail. Fortunately, there is
a developing body of knowledge on how to apply analysis to
personal, corporate, and social decisions involving uncertain-
ty, complexity, and conflicting objectives. The approach is
called decision analysis, and it has been applied to social
decisions in weather modification, fire protection, pollution
control, energy policy, electrical system capacity planning,
and other areas (Refs. 1-8).
We will draw heavily on the concepts of decision analysis in
the discussion that follows. We will first discuss the
elements of the waste management decision and how they are
related. We will then discuss the role of the various
parties—technical experts, decision makers, and concerned
citizens—involved in the decision. Finally, criteria for
choosing among alternatives will be discussed.
Associated with every decision are alternatives, information,
and preferences. A good decision, in a personal context, is
one that is logically consistent with the decision maker's
available alternatives, his state of information, and his
preferences. Both information and preferences are subjective.
The principal differences between social and personal deci-
sions relate to the way information and preferences are
incorporated in the process. The interested parties or
shareholders in the same decision can have widely differing
values (preferences), differing degrees of uncertainty, and
even differing models of the way events are related. For
example, some people are confident that if our wastes are bur-
ied at a reasonable depth in a salt bed, they will stay buried
for at least the next 1,000 years. Furthermore, some people
would be unwilling to pay even a few cents to avoid a prema-
ture death due to a reemergence of the waste in the year 2978.
Other people might assign a high probability that experts are
wrong and assess a much higher probability to early release or
they might wish to assign a much higher value to the health of
distant generations. But in spite of these differences or
complications, let us examine the elements of the waste man-
agement decision and their interrelation. At a minimum we can
use a decision analytic framework to organize and clarify the
issues.
The decision structure is sketched in Figure 1. The alterna-
tives include the processing, transportation, and the storage
or disposal options. Associated with each alternative are the
possible significant outcomes measured in appropriate terms.
For the waste decision, the outcome measures are mortality and
morbidity resulting from voluntary exposure, involuntary
health risk, damage to biota, property damage, and the contri-
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bution of waste management to the cost of electricity. The
outcome associated with each management alternative is uncer-
tain because of geologic, economic, and social factors that
are beyond our control. For the purposes of identification
(classification), we call these influential but uncontrollable
factors "state variables." They include such things as the
timing and intensity of earthquakes, the economic value of any
valuable elements that might be extracted from the waste, the
location of future population concentrations, the size and
timing of meteor impacts, and the size and timing of any human
efforts to penetrate a waste disposal site.
INFORMATION AND JUDGMENT
Information and judgment enter the decision in two places:
(1) in describing what is known about the relationship between
decision, state, and outcome variables; and (2) in describing
our knowledge or lack of knowledge about the values of the
state variables. Our knowledge of radioactive decay pro-
cesses, containment integrity, dispersion, population expo-
sure, and health effects may be summarized in quantitative
models. The accuracy of these models depends, of course, on
the skill of the modeler, the knowledge of the experts in-
volved, and the resources allocated to the modeling effort.
In most cases such models can be improved and refined through
critical adversary review.
If used properly, quantitative models can serve several im-
portant functions in a social decision. Firstly, they can be
used to identify those state variables and model elements that
significantly influence the decision. Public review can then
be focused on the issues that matter. Second, the model
organizes the information in a concrete form so that it can be
constructively reviewed by all interested parties. Specific
areas of disagreement can be identified and the implications
of disagreements can be measured.
Even if we had perfect models, outcomes associated with each
decision alternative would still be questionable because of
uncertainty in the state variables. No amount of experi-
menting or analysis can remove all this uncertainty. The best
we can do is describe probabilistically what we know about
these quantities or events and make a decision that is consis-
tent with this judgment.
In the social decision context, the question arises, "Whose
information or knowledge do we use?" In many cases the
probability distributions describing the uncertainty cannot be
estimated experimentally, and therefore we rely on purely
subjective assessments. For instance, what is the probability
that a cure for radiation-induced cancer will be discovered
before the year 2100? There is no known way of resolving
subjective differences among experts. If the difference of
opinion has an impact on the choice among waste management
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STATE VARIABLES
• GEOLOGICAL
• ECONOMIC
• SOCIAL
OUTCOME
VARIABLES
DECISION
ALTERNATIVES
• PARTITIONING '
• RETRIEVABLE STORAGE
• ENCAPSULATION
SYSTEM MODEL
EFFECTS
VOLUNTARY
INVOLUNTARY
COST OF ELECTRICITY
PRODUCTION AND WASTE
DISPOSAL OR STORAGE
MORTALITY AND
MORBIDITY
RESULTING FROM
VOLUNTARY
EXPOSURE
DAMAGE TO
BIOTA
INVOLUNTARY
HEALTH RISK
PROPERTY
DAMAGE
CONTRIBUTION
TO THE
COST OF
ELECTRICITY
VALUE
MODEL
• WILLINGNESS TO
MAKE TRADEOFFS
AMONG OUTCOMES
AND TIME PERIODS
WILLINGNESS TO
ACCEPT RISK
ALTERNATIVES
(TECHNOLOGY)
INFORMATION
("EXPERTS")
PREFERENCES
/^DECISION MAKINGN
; SOCIETY J
Figure 1. Anatomy of a decision.
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alternatives, then the decision maker or decision-making body
must ultimately pick the source of information upon which to
base the decision. Differences of opinion can be judiciously
ignored if they do not affect the best choice among alterna-
tives. One cannot help but wonder how many hotly debated
issues could be defused if we had a logically consistent frame-
work for testing their importance in the decision at hand.
PREFERENCES
The outcome of any waste management decision is measured in
several dimensions, it is distributed over a long time span,
and it is uncertain. The "value model" on the right-hand side
of Figure 1 includes an explicit expression of the decision-
making body's willingness to make trade-offs between outcome
measures. For example, how much are we, as a society, willing
to increase the cost of electricity to avoid exposing a person
living near a storage site to one chance in 10 million of
contracting cancer induced by the waste? It is also necessary
to express society's willingness to trade outcomes between
time periods. Usually this is treated by choosing a reasona-
ble discount rate. This may be inappropriate in the case of
extremely long-lived hazards. Society might be willing to pay
a great deal today to avoid jeopardizing the well-being of
societies existing in the far distant future. This poses no
conceptual difficulty. The value model is simply a statement
of the weights to be assigned to the outcomes for purposes of
making the decision. However, these values should be consis-
tent with the trade-offs society is willing to make in other
decisions. It is certainly possible, for instance, that the
use of fossil fuels by present generations will also jeopard-
ize future generations. In these decisions, appropriately or
not, a simple discount rate is used to weigh future outcomes.
Few people would be naive enough to assume that specifying
values to be used for decision-making is a simple, straight-
forward orward It could well require all the legislative pro-
cesses associated with routine law making. In other cases it
could require the soul searching of a politically appointed
decision maker performing his administrative duties.
In a well-organized decision-making framework, such as that
represented in Figure 1, many value differences or conflicts
may be avoided by demonstrating that the rational choice is
the same regardless of one's position on a particular value
assessment. Explicit expression of the trade-offs together
with a system model can focus the effort on those differences
that matter.
It should be noted that mortality and morbidity outcomes are
separated into two categories: (1) mortality and morbidity
attributed to voluntary exposure, and (2) risk associated with
involuntary exposure. The first is measured in terms of the
number of'actual premature deaths or harmful health effects.
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The second is different; it can be measured as a total number
of persons involuntarily exposed to the particular risk (prob-
ability of effect). The social value of the bad outcome from
voluntary exposure might well be thought about in terms of lost
productivity or families without bread winnners. The second,
however, is more subtle. It is related to the compensation that
each of us could require to induce us to voluntarily participate
in a risk situation that we would ordinarily try to avoid.
DECISION CRITERIA AND RISK ATTITUDE
The decision criteria become especially difficult to formulate
when the consequences of the decision include catastrophic
outcomes. How do we make the trade-off between a slight
increase in the probability of catastrophe and a modest but
still significant saving in cost?
The simplest approach is to use expected value as a criterion,
with a monetary equivalent assigned to the catastrophe. This
approach has become widely accepted in some areas such as
transportation safety planning, and values of life such as
$200,000 to $500,000 are used (Ref. 9). More sophisticated
calculations may employ von Neumann-Morgenstern utility (Refs.
10, 11) to include the effect of risk aversion, but this
approach does not address the most difficult issue—how to
assign value to the catastrophe. Hirshleifer (Ref. 11) and
Howard (Ref. 12) have pointed out the need to directly address
the trade-off between increments of probability of the cata-
strophic outcome and a decision maker's willingness to pay (or
accept payment). This trade-off can then.be used to establish
a value to the catastrophe for decision-making purposes valid
for small probabilities. For example, the judgment that soci-
ety would be willing to pay $10 million per reactor year to
reduce the chance of a nuclear reactor accident from 2 X 10~6
to 1 X 10~6 implies a value of $107/(2-l) X 10~6 = $1013
assigned to the accident, for calculations with probabilities
in the range of a few chances in a million. But this judgment
should not be taken to imply that society would tolerate reac-
tor or ident probabilities in the range of 1 to 10 percent,
even if trillions of dollars in economic gain could be real-
ized. A model for assessing the probability of death versus
willingness to pay trade-off will be described in a forthcom-
ing paper by Howard (Ref. 13). Howard's approach incorporates
both time preference (preferred distribution of consumption)
and a von Neumann-Morgenstern utility function.
Despite the difficulty of the assessment, a formulation in
terms of a trade-off between the probability of catastrophe
and the economic cost (or willingness to pay) associated with
each decision alternative seems to be useful and appropriate.
This approach has been used not only in safety applications
involving the value of life, but also in space exploration
where biological contamination of planets is the low
probability catastrophe to be avoided (Ref. 14).
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The alternative to using an explicit assessment of the trade-
off between economic gain and probability of catastrophe are
criteria such as best practical technology, or probability
constraints that must be met irrespective of economics. The
weakness of probability constraints is that they give no in-
centive to reduce a probability below the constraint thresh-
old, and they may induce a negative value to information that
could show the constraint to be violated. As a hypothetical
example, one might "rather not know" whether the chance of
water penetrating the salt dome in the next million years is
one in 10 million, or one in 10 thousand, if in the latter
case the constraint would be violated. Without the informa-
tion the probability might be one in a million — above the
constraint. Examples and further discussion of the weaknesses
of a constraint formulation are found in a report by Howard
et al. (Ref . 14) .
Qualifiers such as "low as practical," "safe enough," and
"adequate safety" avoid the difficulty of assessing the
trade-off, but besides suffering from ambiguity, they suffer
from the same problems as probability constraints. Unless
some balance is struck between the probability of release and
the economics of waste management, a negative incentive exists
for the development of new technologies for waste storage and
disposal, and for obtaining more information about the effec-
tiveness of the approaches to guaranteeing containment. Any
new technology that appears safer may be mandated, regardless
of cost or side effects; any new information showing that a
technology is less safe than previously supposed causes wide-
spread alarm and perhaps costly rejection of that technology.
Explicit trade-offs may be difficult to establish, but they
provide the reference point to keep the decision process from
being whipsawed by every new bit of information that is developed.
A PERSPECTIVE ON WASTE MANAGEMENT CRITERIA
We shall conclude with a short personal perspective on the
problem of developing criteria for radiation waste management.
We will direct our remarks primarily at high-level waste
instead of lower-level waste, where routine emissions may be
more of a problem. For high-level wastes the problem is
primarily one of containment — making sure that the probability
of catastrophic release is acceptably low.
. _ _ __ ^ --.--.-. _.
dif f _icul t_iob_that~wril~never_be_entirelY_f ioi§hed . Ongoing
modeling is needed to assess the probability of release and
insure that all cost-effective means of lowering this
probability will be employed. The modeling exercise itself
may be highly subjective, particularly in those areas where
our understanding of the release mechanisms is weakest, e.g.,
the deliberate actions of governments or individuals. A good
decision is one that is logically consistent with the informa-
tion available to the decision maker. In many cases the best
2-65
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information available to us is the informed subjective judg-
ment of experts. As new information is obtained, the models
and probability assessments should be revised accordingly.
Qbs^.IY.^tion^g^ __ The_conseguences_of _gossible__releases_should
be_asses£edi_and_used_as_g_u^delines_tq_boun^ for
E£2^§^iitY_versus_cost_tra^e-off_assessment.' Is it true, for
example, that a" major release caused by a direct meteor impact
at a waste burial site would be no worse than the cumulative
effects from atmospheric weapons testing? (Ref . 15) . What
are we willing to pay to reduce the probability of this out-
come from 2 X 10"1-3 to 1 X 10~13 per year?
_3£ __ Is_there_a_potential_consensus? If indeed we
can agree that for some waste storage technologies the prob-
ability of release is small (1 chance in 10^ or 10^) , the con-
sequences of release are less than infinite (we do not destroy
life on earth or even over a substantial region) , so the present
value of the catastrophe is agreed to be of the order of a tril-
lion dollars or less (in the context of 1 x 10~8 level probabil-
ities) , and if the cost of the storage/disposal alternatives is
moderate (the order of one billion dollars or less) , then it
may be that we have a relatively straightforward decision situ-
ation. The potential consensus is that various waste disposal
or storage technologies are acceptable. If more quantitative
analysis can help to show that such a consensus is possible,
then let us get on with this analysis. Hopefully this will
help decision makers to end their indecision and to clarify
the radioactive waste storage/disposal question in the larger
social decision on the future role of nuclear power generation.
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REFERENCES
1. * Howard, Ronald A. 1966. Decision Analysis: Applied De-
cision Theory. Proceedings of the Fourth International
Conference on Operational Research. (D-B. Hertz and J.
Melese, eds.) Wiley-lnterscience, New York. pp. 55-71.
2. * Howard, Ronald A. 1975. Social decision analysis.
Proceedings of the IEEE. 63 (3) :359-371.
3. * Howard, Ronald A., James E. Matheson, and D. Warner
North. 1972. The decision to seed hurricanes.
Science 176:1191-1202. Letters appeared in Science,
179:744-747, 1973 and 181:1072-1973, 1973.
4. * North, D. Warner, Fred. L. Offensend, and C.N. Smart.
1975. Planning wildfire protection for the Santa Monica
mountains: an economic analysis of alternatives. Fire
Journal (January).
5. North, D. Warner and M. W. Merkhofer. 1975. Analysis of
alternative emissions control strategies. In: Air
Quality and Stationary Source Emission Control. Report
to the U.S. Senate Committee on Public Works. (Available
from the U.S. Government Printing Office, #052-070-
02783-5, $8.60.)
6. Cazalet, Edward G. et al. 1975. Recommendations for a
synthetic fuels commercialization program. In: Cost/Benefit
Analysis of Alternate Production Levels. Report submitted
by the Synfuels Interagency Task Force to the President's
Energy Resources Council. Includes a decision analysis
of synthetic fuels commercialization program alternatives.
(Available from the U.S. Government Printing Office,
#041-001-00111-3, $4.30.)
7. Barrager, Stephen M., Bruce R. Judd, and D. Warner North.
1976. The Economic and Social Costs of Coal and Nuclear
Electric Generation: A Framework for Assessment and Il-
lustrative Calculations for the Coal and Nuclear Fuel
Cycles. Prepared by SRI for the National Science Founda-
tion. (Available from the U.S. Government Printing
Office, #038-000-00293-7, $2.05.)
* Reprinted in Readings in Decision Analysis. Decision Analy-
sis Group, Stanford Reserach Institute. 1976.
-------
8. Judd, Bruce, R. et al. 1976. Decision analysis
framework for future electrical planning. In: Electricity
Forecasting and Planning Report. Prepared by Office
of Planning and Analysis Energy Assessment Division,
California Energy Resources Conservation and Development
Commission (November).
9. Linnerooth, J. 1975. The Evaluation of Life-Saving: A
Survey. IIASA RR-75-21. Laxenburg, Austria,
International Institute for Applied Systems Analysis.
10. von Neumann, J. and 0. Morgenstern. 1947. Theory of
Games and Economic Behavior. Second Ed. Princeton Uni-
versity Press, Princeton, New Jersey.
11. Luce, Duncan R. and Howard Raiffa. 1965. Games and
Decisions. Wiley and Sons, New York.
12. Hirshleifer, J. 1975. The Economic Approach to Risk-
Benefit Analysis. Risk-Benefit Methodology and
Application: Some Papers Presented at the Engineering
Foundation Workshop, September 22-26, Asilomar, California.
(D- Okrent, ed.) Prepared for National Science Foundation.
Energy and Kinetics Department School of Engineering
and Applied Science. University of California, Los
Angeles, California.
13. Howard, Ronald A. Life and Death Decision Analysis.
Department of Engineering-Economic Systems, Stanford
University (forthcoming publication). Stanford,
California.
14. Howard, Ronald A., D. Warner North, and J. P. Pezier.
1975. A New Methodology to Integrate Planetary
Quarantine Requirements into Mission Planning, with
Application to Jupiter Orbiter. Final Report, SRI
Project MSD-3685. Prepared in the Jet Propulsion Labo-
ratory under contract to the National Aeroneutics and
Space Administration (August).
15. U.S. Atomic Energy Commission (U.S. AEC). ORNL-TM-4639.
1974. Potential Containment Failure Mechanisms and
Their Consequences at a Radioactive Waste Repository in
Bedded Salt in New Mexico (October).
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REMARKS FOR THE EPA WORKSHOP ON ENVIRONMENTAL PROTECTION
CRITERIA FOR RADIOACTIVE WASTES
John W. Bartlett
Battelle, Pacific Northwest Laboratories
Richland, Washington 99352
These informal comments are directed to the use of risk
assessment in the process of setting generally applicable en-
vironmental radiation standards for radioactive waste manage-
ment. My comments presume that risk assessment will have a
role in the process; they are addressed to what that role
might be. The comments are allocated to three topical areas:
viability of risk assessment for these purposes, risk trade-
offs, and risk assessment in the public arena.
VIABILITY OF RISK ASSESSMENT IN RADIOACTIVE WASTE MANAGEMENT
You have previously heard that risk assessment methods have
been developed for and applied to some waste management
operations. Are these methods necessary; are they sufficient;
and in particular, do the results provide a firm base for
decisions and environmental protection criteria?
Let me first state (without necessarily endorsing) the
viewpoint that risk assessment serves to quantify and confirm
what we already know. The "already know" part of this
assertion comes from the fact that we usually have, through
experience, reliability data on performance of system
components. What risk analysis does is quantify expected
performance of a particular system of components. Implicitly,
then, risk assessment requires explicit system designs, site,
conditions, and scenarios in order to quantify probabilities
and consequences of accidents and system failures.
At present, radioactive waste management seems to be lacking
the system elements needed to produce viable results from risk
analysis. Sites for waste management operations have not been
selected, and specific designs for waste management systems
have not been developed. I believe, however, that these
deficiencies are temporary. As soon as sites are selected and
system designs are promulgated, it will be possible to perform
conventional risk analyses for all waste management operations
with the exception of geologic isolation, which I will discuss
later. Results of such analyses can serve their usual role of
supporting licensing and environmental impact statement needs.
In the meantime, how can risk assessment help meet the needs
of the (EPA) Environmental Protection Agency? One can assume
a generic or reference environment. But the important things
with respect to setting and meeting generally applicable envi-
2-69
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ronmental radiation standards are the inputs and outputs of
radioactive materials and the extent to which they put the
inhabitants of that environment at risk. On a nuclide-by-
nuclide basis, the key element of risk is the interaction of
inhabitants with radioactivity in the environment; allowable
levels of radioactivity in the environment will depend on the
mechanisms and extent of interactions.
It seems to me, therefore, that a key role for risk assessment
with respect to EPA's needs is to derive allowable environmen-
tal standards on the basis of "acceptable levels of risk" (a
topic I won't presume to address) and the mechanisms of
interaction that can produce risk. The concepts of risk as-
sessment can be applied to a system wherein the radioactivity
in the environment is the source term and the biosphere
pathways constitute the system elements for which fault trees
and the like can be derived and evaluated. Currently avail-
able models for estimating radiation dose are, in essence,
risk analysis models. The problems for EPA are related to
setting the allowable dose (i.e., risk), validating the
models, and working backward through the models to derive the
source term.
After a generally applicable environmental standard has been
set, the requirement for waste management operations is to
constrain releases so that allowable limits are not exceeded.
This means, in general, that inputs from waste management
operations to the environment must balance outputs so that
steady-state concentrations are at or below the standard. One
output from the environment is radioactive decay, which, for
the long-lived nuclides, is negligible for the risk period of
a given population. Are there other outputs, in the form of
immobilization mechanisms, that render some fraction of the
radioactivity inventory insignificant as a source of risk?
Such outputs will have to be defined and evaluated in order
to set performance requirements for the waste management
operations.
The waste management operation of key concern is geologic
isolation. Can isolation be maintained for as long as
necessary? Does risk assessment have a role in determining
capability to maintain isolation? How can we deal with the
fact that loss of isolation or change of repository config-
uration does not necessarily produce risk to population?
Conventional risk analysis methods may have a role in eval-
uating long-term safety for geologic repositories. For exam-
ple, they can be, and have been used to generate and evaluate
geologic fault trees. However, such methods deal only with
mechanisms and probabilities of loss of repository integrity.
They also are limited in their scope; other probability-
oriented scenarios must be dealt with, such as human intrusion.
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in general, the problems associated with attempting to apply
risk analysis to long-term repository safety are these:
1. The scenarios for risk tend to be unbounded
2. Error bands on consequence analyses are extremely
broad
3. Probabilities of geologic change tend to integrate to
unity
4. Results cannot be verified.
There have been no complete (probabilities and consequences)
long-term risk assessments, for geologic repositories. Typi-
cal scenarios have been investigated, but the spectrum has not
been fully defined and evaluated. At present, the prognosis
is that conventional methods might be used, but error bands on
results will be very large. Supplementary and refined methods
(e.g., probability density functions) may be needed. In any
event, validation and acceptance of results of risk
assessments for long-term safety of geologic repositories will
be a difficult and challenging task.
RISK TRADE-OFFS
This portion of my remarks deals with the question, who's at
risk, and how does it matter? Waste management options
produce opportunities to trade or shift risks from one portion
of the population to another, and from one generation to
another. Assuming the existence of radioactivity is immutable
and a measure of (at least) risk potential, how should poten-
tial risks be allocated?
Fundamentally, options for waste management technologies
provide options for discharging radioactive or other effluents
to the environs or containing the wastes for isolation from
the biosphere. The ultimate containment or isolation concept
is geologic isolation, which raises issues of export of
risk to future generations. Note that if geologic isolation
is successful and practiced to the limit, radioactivity-
related risks to present populations are confined to occupational
exposure and accidents, and such risks to future populations
are limited to those associated with intrusion scenarios.
The problem of risk trade-offs, is rather subtle and involves
cost-benefit considerations. In general, preparation of wastes
for geologic isolation requires a waste treatment operation to
change the form of the waste to one suitable for transport and
isolation. The treatment process will usually generate effluents
and proliferate waste forms. For example, combustion of process
trash will generate gaseous effluents. Such effluents would
be rendered essentially nonradioactive by installing HEPA
filters; the HEPA filters become a waste form not present if
simple compaction is used as the treatment operation. The
effluents, although nonradioactive, contribute (however
imperceptibly) to carbon dioxide discharges to the atmosphere.
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Another example of a waste type that provides trade-off issues
is krypton-85. If this gas is released to the environment, no
capital and operating costs for capture and other waste man-
agement operations are incurred. If the krypton is captured,
such costs are incurred, occupational exposure is increased,
and with present technology, a concentrated source of radio-
activity contained in high-pressure gas cylinders is created
and subject to accidents during transportation, storage, and
handling. Furthermore, the processing equipment becomes a
waste to be disposed of when the facility is decommissioned.
In my opinion, the optimum distribution of risk as reflected
by isolation philosophy, discharges to the environment, and
environmental standards is not at all obvious. Comprehensive
cost-risk-benefit methods for determining an optimum seem to
be required. However, a further problem exists, which I have
previously termed "beneficiary bias." You can always get the
answer you want with regard to the consequences of a waste
management action that changes the at-risk population element,
depending on which group (increased risk or decreased risk)
you side with. In sum, this is another problem for which ob-
taining a consensus will be a difficult and challenging task.
RISK ASSESSMENT IN THE PUBLIC ARENA
Risk assessment as a means of evaluating potential impacts of
technology on society is a relatively new art; impacts of
technology on society are old hat. Where and how can risk
assessment actually affect decisions and standards that
anticipate potential adverse effects of technology?. In other
words, how much weight can and should risk assessment have?
In a first-order attempt to answer this question, I reviewed
qualitatively past societal experience with major impact
technologies. In my own mind, the only consistency I found
was inconsistency.
In the past, without risk assessment and an Office of Technology
Assessment, we seemed to always misestimate the impacts
of technology on society. We therefore tended to misset
the standards that reflect control of the technology to
the benefit of society. Consider, for example, this table
relating projections to impacts on society:
Overproject SST? WASH-740? Rocket travel
Underproject Thalidomide Auto and air travel
Microelectronics
Computers
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It is difficult to find entries for such a table in the
overprojection-of-bad-impacts category because such technologies
never even get started. For those that do, we usually find
some need to revise and accommodate the unexpected. But
our approach to revision and accommodation is also apparently
inconsistent. For example:
1. Continued despite disaster (Titanic): luxury
liner sea travel
2. Terminated by disaster (Hindenberg): commercial
dirigible travel
3. Revised by disaster: earthquake design of structures,
design codes for steam engine systems
4. Revised (introduced) by perceived potential disaster:
automobile exhaust emissions.
On this basis, there appears to be some sort of subconscious
risk-benefit evaluative system that affects society's use of
technology. Is it consistent? Can it be quantified
sufficiently so that "proper" values of environmental
standards for radioactive waste management can be established?
To investigate and answer such questions would require a
multi-disciplinary study of major proportions.
One possible way to use risk assessment in this context is to
take a "bound-the-problem" approach. This could require two
types of effort: one to evaluate the magnitudes of our past
underestimates of technology's impacts, and the other to
estimate comprehensively an upper bound of potential impacts
and risks of waste management options on the basis of known
information. We might then show the consequences of present-
day underestimation of potential risks: if waste management
risk estimates extended by worst-case underestimates for past
technologies still fall below "acceptable" levels, we could
conclude that our technology is "safe."
In broadest terms, our current problem is to determine if and
how the illusions of certainty created by the analytic methods
of risk assessment can be accommodated in a society that
distrusts computers and perceives risk subjectively. For this
problem especially, there are no easy answers.
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RISK CONSIDERATION OF RADIOACTIVE WASTE MANAGEMENT:
SUMMARY AND CONCLUSIONS OF WORKING GROUP 2
RISK CONSIDERATION OF RADIOACTIVE WASTE MANAGEMENT
The function of Working Group 2 was to determine how risk
considerations should come into play in the setting of crite-
ria and standards for radioactive waste management. The
nine-member panel was composed largely of professional deci-
sion analysts, engineers, and economists. The working group
itself, numbering about 20, was composed of government employ-
ees and consultants, with some representation from academia
and public interest groups.
The Working Group initially selected the issues that should be
discussed. One immediate concern was the definition of impor-
tant terms, such as "standard," "criteria," and "risk
methodology." Although no consensus developed concerning
precise definitions for these terms, there was agreement on
the general proposition that "criteria" were rules that should
be used in establishing a "standard" and that standards should
probably be numerical in nature. Throughout the discussion,
the group agreed that the ultimate goal was to incorporate
risk analysis into the process of setting generally applicable
standards for nuclear waste management.
The questions and topics addressed by the group were for the
most part those posed on pages 2-7 and 2-8 of the document
"Issues and Objectives Statements," distributed at the com-
mencement of this Workshop. Of these 10 questions, numbers 1
through 9, or slight modifications of them, were discussed.
Because of time considerations, number 10 was omitted. Prior
to the conclusion of the session, however, one additional
question was treated.
In the ensuing discussion, the questions, as formulated by the
group, are presented, followed by the range of opinions
expressed and the extent to which a consensus (if any) was
reached.
1. Should the probabilities and/or consequences of abnormal
or unplanned events associated with radioactive waste man-
agement plans be considered in the development of criteria
and standards? If so, in what manner?
Group discussion and a paper presented by Dr. Bartlett ex-
plored this issue. Quantification of risk under operational
and accidental situations is possible; however, the technique
for incorporation of low-probability, high-consequence risks
in criteria is problematical. Nevertheless, there was a clear
consensus that environmental criteria and standards, and in
particular the high-level and transuranic wastes standards,
should address unplanned or accidental events. It was noted
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that such an accident standard would differ from the EPA
radiation standards for the uranium fuel cycle. A related
view also held that if accidents and unplanned events are to
be included for high-level waste criteria and standards, then
the intent must be to make a general practice of this for all
radioactive wastes and for all EPA radiation criteria and
standards.
Discussion focused on how low-probability, high-consequence
events, whether natural catastrophes or accidents, can be
considered. It was generally agreed that risk was a function
of probability and consequence, but expression as a simple
product, i.e., Risk = Probability X Consequence, may not be
applicable. As a supplement, explicit discussion of probabil-
ity and consequence was deemed desirable. Maximum credible
accident approaches and Delphi analysis were considered to be
inappropriate methodologies in comparison to fault tree, event
tree, and consequence analysis techniques.
2. Should quantitative risk analysis be attempted in support
of environmental criteria and standards?
The discussion centered on the topic of high-level waste dis-
posal. There was clear consensus that quantitative risk anal-
ysis should be attempted to the extent possible, but that it
should be regarded as an imperfect tool. It can, however, at
least be used to indicate direction and magnitude.
It was recognized that assembling actual data for such
analyses would be an extremely complex and, in some cases, an
impossible task. For cases where data cannot be obtained
(e.g., longevity of geologic stability), it was agreed that
solicitation of opinions and projections from a wide range of
knowledgable persons (e.g., a Delphi technique) must be used.
Opinion on the range of disposal techniques (e.g., geologic,
extraterrestrial, transmutation) that needed to be analyzed
was varied. Several participants believed that more options
than geologic disposal needed in-depth risk analysis. A
consensus evolved that geologic isolation should receive
priority for analysis, with other options being considered to
the extent that information is available.
Some discussion focused on factors that can diminish effective
use of risk assessment. One item mentioned was the enforce-
ment difficulty inherent in failing to consider variability of
background, a fact that supports the concept of a locally
oriented standard. However, it was pointed out that we do not
know the health effects of background levels.
Another question raised was whether to treat the population as
a whole or to segment it. If it is to be segmented, should this
be done on an occupational or nonoccupational exposure basis,
or some other basis? This question was not pursued or resolved.
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Quantitative risk assessment methods should be used for
categories of radioactive waste other than high-level. It was
recognized, however, that techniques and requirements might
differ according to the type of waste considered.
It was the consensus of the group that quantitative risk anal-
ysis should be prepared to support criteria and standards for
all radioactive waste management plans. For high-level waste,
emphasis must be placed on geologic disposal, but all viable
alternatives should be analyzed to the extent feasible. All
such risk analyses should be recognized as an imperfect tool
to aid decision-making.
3. What analytical methods should be applied to various
phases associated with waste management, such as transpor-
tation, repository operations, retrievable storage, and
ultimate long-term disposal?
A possible method for performing quantitative analysis of risk
was outlined for the above operations. This approach would
consist of identifying initiating events of concern with fault
trees and analyzing consequences with event trees.
Comments from the Working Group indicated that this, or
similar approaches, may be applicable to short-term opera-
tional steps such as transportation and repository operations.
Members of the group also pointed out that many risk/safety
studies have been performed for transportation and that ap-
plicable models exist. The suggestion was made that in
performing an evaluation of transportation, use of actual ex-
perimental data may be feasible. A point was made that
general risk assessment models can be developed. These
general models can vary the choice of logic structure and
input parameters.
It was indicated that it may be difficult to apply existing
risk assessment models to geologic isolation. One suggested
approach is to identify a spectrum of events for consideration
by consensus opinion or other means. Having generated this
list, the probabilities and consequences can be estimated by
the best means available.
While no real consensus was achieved, no major objections were
raised to any of the points in the above discussion.
4. Given that appropriate methods have been selected, what
data should be considered in quantifying the probabilities
and consequences of abnormal or unplanned events?
No objection was raised to the suggestion that appropriate
programs sponsored by ERDA and NRC be relied upon as the
primary data source for the risk analysis. The following
paragraphs briefly review the data requirements and avail-
ability.
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The potential causes of breaching the containment of a nuclear
waste repository in a geologic medium can be divided into two
classes, man-made and natural. In the case of a man-made
breach, data will be required on breach probabilities such as
intrusion by intentional or unintentional drilling or mining
through the disposal horizon by future generations.
Estimation of these probabilities seem to be generally within
current capability and are partially site-dependent.
The natural events capable of breaching the formation can be
sudden and catastrophic incidents or gradual geologic
processes such as erosion and successive vertical displacement
by tectonic activity. The geologic data on catastrophic
events, such as the impact of giant meteorites, of both the
stoney and metallic type, are available but need a determin-
ation as to the "best values." The other potentially serious
breach, large faulting, can be approached from both a
deterministic and probabilistic viewpoint. General data on
faulting are available, but site-specific data are required in
the selected geologic basin or region. A thorough under-
standing of the site area is required. From this information,
erosion and denudation characteristics of the region and the
effects of large and successive faulting can be estimated.
Estimation of leakage from the disposal region resulting from
water intrusion requires data on leaching rates of the waste
for water or brine that is characteristic of the region. Fur-
ther information is required on the absorption characteristics
and flow through the geologic medium in order to evaluate
transport through the geosphere.
The risk to the populace can be estimated at any time for a
particular type and quantity of waste located at the disposal
horizon by incorporating these data into a suitable model.
The foregoing discussion refers to the disposal phase—that
is, after the repository has been back-filled and sealed. The
operational phase is similar to the operation of a chemical
processing plant from a safety analysis standpoint, and
sufficient information for the specific equipment involved is
available or can be obtained in a relatively short time.
Intrusion of the repository by man at some time in the future
seemed to be of great concern. Consequently, additional
effort should be made to respond to this concern by fortifying
existing data to assess this risk.
5. What consequences are of concern in the risk assessment?
For example, should the analysis be restricted to health
effects of the types considered in the Reactor Safety
Study? Or should questions such as the risks of compro-
mising future resources of valuable minerals be
considered?
2-78
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There was a general consensus that the potential health
effects to present and future generations constitute the most
important consequences of concern in the risk assessment.
However, the analysis should not be restricted to health
effects, nor was the analysis so restricted in the Reactor
Safety Study (RSS). The RSS considered the economic costs
associated with property damage, which should also be consid-
ered in any risk assessment associated with radioactive waste
management. Additionally, consideration should be given to
the value of contamination of land, the loss of ecological
species, the economic loss to the area associated with
industrial output and employment, and the loss of natural
resources (including minerals and water resources) . Many of
these attributes may not be expressible in monetary or
commensurate units, but an effort should be made to provide
estimates of these consequences in whatever units are
appropriate.
The issue of international implications from the potential
release of wastes to the oceans was also raised. Although
there was some disagreement as to the nature of these implica-
tions and the responsibilities of EPA'relative to them, it was
generally agreed that this is an issue worthy of some
consideration. Likewise, the ambient radiation levels arising
from foreign nuclear activities should also be considered in
the ultimate development of environmental protection criteria.
6. Can one reasonably predict through the time frame of in-
terest what resources might be considered valuable? Can
one assess the possibility of radioactive releases being
caused by penetration of a repository by persons pursuing
mineral resources?
Some members felt that the resources which will be valued in
the future could be reasonably predicted. Others disagreed.
The predictions of future mineral value can be attempted by
substitution analysis presently used by the Department of the
Interior, by data on existing mineral deposits, and by
consideration of the cost effectiveness of removal of these
minerals. Site selection presently considers the mineral
content of the area under investigation (e.g., an area with
present mineral value would not be considered). It was
suggested that the site chosen should be a low-risk and low
mineral content area. Sites with low projected mineral value
would presumably have low probability of intrusion by mining
operations of future generations. In light of this opinion,
the second part of Question 6 was not further developed.
It was recognized that although the above discussion sounded
reasonable, there is no guarantee that the projections would
be accurate. General consensus about the ability to
accurately predict future mineral value was not obtained.
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7. How should the acceptability of the risks associated with
radioactive waste management be determined?
This question was generally construed to concern the
translation of waste-related risk assessments into a framework
that would provide understanding to the decision makers and
the general public in the establishment of criteria and stan-
dards. In this context there was agreement that acceptability
has to be determined by decision makers and/or the public.
Some questions were raised as to what was meant by "decision
maker," but the consensus appeared to be that the decision
maker was the Administrator of EPA (with broad input and
subject to public acceptance).
Discussion concentrated around the comparison of waste man-
agement risks with other risks. It was agreed that such' other
risks should be involuntary, and recommended that several
relatively comparable risks be used to provide illumination.
Candidates for these included (1) commonly understood risks,
(2) fossil-fuel risks, (3) balance of the nuclear fuel cycle,
(4) direct impact of geologic events, (5) natural background
levels, and (6) other waste sources. Subsequent discussions
focused on the first two, and in particular on coal-to-nuclear
fuel cycle comparisons. There was disagreement over the value
of comparing nuclear to fossil, both for wastes alone and the
entire fuel cycle. It was agreed that such comparisons should
not be used as the basis for setting standards, per se; but
there did not appear to be a consensus on the question of
using nuclear/fossil comparisons even for illumination of
waste disposal risks using current assessments. Comparison
with commonly accepted risks seemed to be a generally approved
method for aiding the determination of acceptable risk.
However, several speakers cautioned against a trap of
suggesting that risks lower than those of commonly understood
occurrences implied acceptability. The question of present
wastes versus those that might be generated in the future was
again raised. Discussion focused on the use of cost-benefit
ratios as cost per unit reduction in consequences, and the
relative cost of reduction from one source to another, but it
was not agreed that either of these increased the level of
understanding of the issue.
There was consensus that risk assessment has to be presented
in a framework which provided the best possible understanding
of radioactive disposal risks to decision-makers and the
public in order to determine acceptability. There was also
consensus that this required comparison to other relevant and
comparable risks, but that this comparison was not the only
basd.s for decisions. There was no consensus on what the com-
parable risks should be.
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8. How should future risks be compared with present risks?
The majority of the working group participants agreed that the
concept of "discount rate" from financial calculations is
inappropriate for intergenerational comparison of health and
property risk. In the absence of a better role, the group
generally agreed that all benefits and costs should be treated
equally regardless of incidence. The group assumed that waste
disposal systems will be designed to provide roughly equiva-
lent minimal levels of risk throughout the toxic life of the
waste, and that sites will be selected to minimize the value
of foregone economic activity around the site.
It was also argued that if the technological and resource leg-
acy passed on to future populations because of increased reli-
ance on nuclear power plants were more valuable than obliga-
tions ions isks of waste storage, a lesser value of future
life was valid. Alternately, it was suggested that the
benefits of nuclear activities largely accrue to current gen-
erations, while only costs and risks accrue to future popula-
tions. This belief would support the selection of a disposal
technology which shifts the bulk of cost and risk to the cur-
rent citizens. Successful disposal in outer space might serve
this goal. The variation of estimated risks could be calcu-
lated by sensitivity analysis using alternate values of life
in each time interval.
9. How should risks from low-probability, high-consequence
events be valued in comparison to the risks from high-
probability, low-consequence events?
Since this question was raised late in the session, discussion
was limited. One opinion expressed was that the direct impact
might be much greater than the radiological impact for low-
probability, high-consequence events asssociated with geologic
storage or disposal. For example, the damage caused by
vulcanism or a meteorite impact might far outweigh the loss of
life or health effects from radiation release initiated by
these events. For purposes of evaluating radwaste management
strategies, the important aspects would be the difference in
radiation release (and other effects) given different waste
management strategies. For example, deeper disposal might
lead to less release of radiation, even if the damage caused
by this radiation would be small compared to the direct damage
caused by the meteorite impact or volcanic eruption.
A note of caution was raised that in comparing low-
probability, high-consequence events and high-probability,
low-consequence events, a simple expected value criterion of
multiplying the probability times a value assigned to the
consequence may not be adequate. This problem becomes partic-
ularly acute if significant probabilities are associated with
high-consequence or catastrophic events. For example, for
probabilities in the range of 10~6 to 10~4, it may be
2-81
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appropriate for decisions on highway safety to use a value
for loss of life on the order of $300,000. On the other
hand, for a decision on medical treatment, where the probability
of death is in the range of 10~2 to 10"1 it might not be
appropriate to use this value. A recommended procedure
is to compare different decision alternatives directly
in terms of (1) the effect in changing the probability,
and (2) the effect on the magnitude of the consequence
for both the low-probability, high-consequence events and
the high-probability, low-consequence events. References
on assessing low-probability, high-consequence events (such
as loss of life) include Hirshleifer (Ref. 1) and a forthcoming
paper by Howard (Ref. 2). There was general consensus
on the need for caution in comparing by means of a single
numerical index the low-probability, high-consequence events
and the high-probability, low-consequence events in a quantitative
risk assessment; however, within appropriate ranges such
comparisons can be very useful.
10. How should the risks from various radioactive wastes be
considered? (By waste type? By source of waste? Should
they be ranked?)
Numerous and diverse opinions characterized the response to
this question. Some questioned whether EPA should be issuing
such criteria and standards in the first place. One position
was that a single standard, regardless of waste type, is
appropriate ("a rem is a rem is a rem"), but economic and
technical realities dictate that control of dose per dollar
invested is highly variable and that a variety of criteria and
standards are probably more appropriate. Priority should be
given to commercial high-level waste, but ultimate inclusion
of all waste sources using a uniform approach is recommended.
Priority of control should be established according to
consequence or risk and the potential for routine and acciden-
tal releases. An alternative approach suggested was to define
an acceptable level of radiation in the environment and to
design for releases not to exceed the standard. This touches
on the distinctions between performance standards and specifi-
cation standards or between ambient standards and effluent
standards. The EPA role would seem to be clearly oriented
toward the former, whereas ERDA and NRC criteria are perfor-
mance-oriented on site- and/or process-specific bases.
Not all risks are equal in perception, in acceptance, and as
input for decision-making at technical and political levels.
It was recommended that EPA actively cooperate with other
Federal agencies to develop the criteria and standards
relating to commercial-fuel-cycle- and ERDA-generated wastes
and that EPA not act in a vacuum.
Multiple approaches to criteria and standards development now
in use such as risk-benefit, ALARA, and environmental dose
2-82
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commitment are not inappropriate nor are they fully adequate.
The subject of imponderables, which surfaced frequently,
underscored the consensus that such philosophical approaches
are only a partial guide. Despite much debate there was no
consensus that rigorous comparison of risk within the full
fuel cycle (vs. only waste management) and between fuel cycles
would be possible or productive with respect to developing
criteria and standards. It was suggested that study of com-
parative risks of nuclear and nonnuclear would perhaps give a
better perspective on the waste management issue. The
methodologies of benefit-cost, benefit-risk, fault tree, event
tree, and consequence analysis provide guidance but not neces-
sarily precision with respect to waste management decisions.
This, plus the fact that waste management has associated with
it future risk uncertainties suggests that other consider-
ations and measures are appropriate for evaluating and
reducing risks associated with permanent, long-term disposal.
REFERENCES
1. Hirshleiter, J. The economic approach to risk-benefit
analysis. In: Risk-Benefit Methodology and Application:
Some Papers Presented at the Engineering Foundation
Workshop, September 22-26, 1975, Asilomar, California.
Edited by D. Okrent. Prepared for the National Science
Foundation. Energy and Kinetics Department, School of
Engineering and Applied Science, University of California,
Los Angeles, California.
2. Howard, Ronald A. Life and death decision analysis.
Forthcoming publication, Department of Engineering
Economic Systems, Stanford University, Stanford, California.
2-83
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WORKING GROUP 2 EXECUTIVE COMMITTEE
RISK CONSIDERATIONS OF RADIOACTIVE WASTE MANAGEMENT
NAME
Ian A. Forbes'''
William A. Lochstet1'
Dan Egan*
Stanley E. Logan
Warner North
Pete Pelto
Peggy Eddy
David G. Blair
Sanford Cohen
Stephen Andersen
John Bartlett1"
H. C. Claiborne1"
Stephen J. Hammalian
Steven Jinks
Thomas McGarity*
Robert Kaufmann"1"
AFFILIATION
Energy Research Group
Environmental Coalition on Nuclear Power
Environmental Protection Agency
University of New Mexico^
Stanford Research Institute
Battelle Pacific Northwest Laboratories
University of Pittsburgh
University of Pittsburgh
Teknekron, Inc.
Sierra Club Research
Battelle Pacific Northwest Laboratories
Union Carbide Corp.
Ecological Analysts, Inc.
Ecological Analysts, Inc.
Environmental Protection Agency
Environmental Protection Agency
* Moderator.
t Panelists for Plenary Workshop Session, 5 February, 1977.
-------
RESPONSE OF WORKSHOP PARTICIPANTS TO
SUMMARY AND CONCLUSIONS OF
WORKING GROUP 2
Second Plenary Workshop Session
JAMES E. MARTIN: (Environmental_Pr_qtect^on_AgencYi_Washin2tqn
D^CO: I would like to introduce Tom McGarity from the Envi-
ronmental Protection Agency in Washington, B.C. Tom is the
moderator of Group 2, and he will present their findings.
THOMAS 0. McGARITY: Let me first introduce the panel that we
have picked from Working Group 2. At the far end is Bob
Kaufman, from the Environmental Protection Agency in Las
Vegas, Nevada; next to him is William Lochstet, from the Envi-
ronmental Coalition on Nuclear Power, State College,
Pennsylvania; next to him is Ian Forbes, from the Energy
Research Corporation in Framingham, Massachusetts; then, Clyde
Claiborne from Union Carbide in Oak Ridge, Tennessee; John
Bartlett from Batelle, Pacific Northwest Laboratories in
Richland, Washington; and Dan Egan, from the Environmental
Protection Agency in Washington, D.C.
McGARITY: The first question, by William C. Remini, (Energy
Research and Development Administration, Washington, D.C.) is
"Using probabilities and/or consequences of abnormal or
unplanned events, both natural and man-made, in the develop-
ment of criteria and standards, precludes and rules out
setting a zero release standard. Because one can develop a
scenario of these high and low probability events to
sequentially occur until there is some finite probability of
release greater than zero, does this not then rule out the
desire of some Group 1 panelist's views that zero release be
established as the EPA standard?"
DAN EGAN: I think your comment that inclusion of probability
and consequences ruling out a zero release standard under any
situation is correct. I am sure you will note from the two
presentations that there is a difference of opinion in the
conclusions reached by Group 1 and Group 2 regarding the
appropriate considerations of risk in the setting of criteria
and standards. All we can offer as an explanation is that we
were in two different rooms and Group 1 did not talk to Group
2 until about 1 a.m. this morning.
H. CLYDE CLAIBORNE: We, that is the Office of Waste
Isolation, have plans for a repository. Our intention is to
design for zero release. That is, when all the geological and
hydrological factors indicate that this formation will be leak
tight and stable for millions of years, then we will say that
it is a suitable site. We do not expect any release at all.
You might say we are designing for a zero release. However,
we recognize the fact that there is a probability that some of
the evidence or some of the data were insufficient to make an
2-87
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accurate prediction and some occurrence could happen.
Therefore, we undergo the risk assessment to answer the "What
if" question. Thus, we have a zero release design. I am
speaking, of course, of the sealed phase, the long-term phase.
Yet one is trapped by the semantics in saying it is not a zero
release design because we are considering the "What if," that
is, the accident.
McGARITY: The next comment I have is from E. W. Murbach.
E. W. MURBACH (Allied General_Nuclear__Servicesi_Barnwell,
§^O : First of all I would like to commend you for this
paper. I think you did a good job. I have three minor
comments. At the bottom of page 2-76 you say it was pointed
out that we do not know the health effects of background
levels. Well last year I looked at a cancer map of the United
States and frankly I could not see a bit of difference between
the Colorado/Wyoming area, where the people live at twice the
natural background, and that of South Carolina where I live.
I think that goes back to what is considered one of the dis-
asters—the linear, no-threshold hypothesis.
McGARITY: Would anyone like to address that?
WILLIAM A. LOCHSTET: I think most of the group felt that to
redo the BEIR report was not our project. That would be put
into the body of knowledge which EPA would use in setting the
standard.
MURBACH: Then on the top of page 2-79, I would like somebody
to amplify. You say "likewise the ambient radiation levels
rising from foreign nuclear activity should also be considered
in the ultimate development." Can somebody amplify what you
mean by that?
ROBERT KAUFMANN: I think the thought behind our raising
this issue and all the issues is not that we hold to any
of them, but that they are concerns we have on our mind.
We are using this forum to see if the feeling is to amplify
or reject them. I believe the environmentalists are concerned
that international activity will cause ambient radioactivity
to increase, and that it would be ridiculous—case in point,
the recent Chinese atmospheric testing—to just deny that
in our standard. I think we are becoming increasingly
aware that we affect other countries and that they affect
us.
MURBACH: I agree, but let us take an extreme case—suppose
that by shooting something off, a country managed to increase
the natural background by 10 percent for the next five years.
Does that mean that we would have to shut down and not do
anything?
KAUFMANN: No.
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IAN A. FORBES: Maybe it might be worth briefly summarizing
where this came from. It was a long, involved discussion;
I will not go into detail. A question was raised in our
discussions whether standards ought to consider releases
to the ocean, and whether that meant leaching from a geologic
repository out into the ocean or ocean burial. From that
question of ocean burial we got into consideration of ocean
burial by other nations and whether that should be con-
sidered in these standards. There was no consensus other
than that we felt it was worthy of further consideration.
McGARITY: There was a point on which we reached a consensus
that is not reflected in this report.
STEPHEN ANDERSEN (Sierra_Club_Research, San_Francisco,
California)' The consensus was that we would not~relax
standards because of increases in ambient levels of radiation.
If anything, it would mean what you said originally: that if
levels got too high from external sources, we would curtail
releases in the United States.
MURBACH: My last point—the middle of page 2-81 says, "It
was suggested that benefits of nuclear activities largely
accrue to current generations. Well, it is my feeling that if
all of us do our job right, we have perhaps offered something
of benefit for better than 1,000 years, assuming the breeder
ever comes to fruition. That figures out to something on the
order of 30 to 40 generations that could have the benefit of
nuclear power.
McGARITY: The next comment we have is from Stan Lichtman. He
says, "Please describe the reasoning for giving 'priority to
commercial high-level waste' on page 2-82."
FORBES: We actually discussed at one point what we meant by
the term priority and recognized that there are two types of
priorities. One is the schedule in which one has to take the
various standard and criteria setting; the other is the
priority that one might assign to the potential consequences
from different sources of waste. What we mean in this
instance is the recognition that the waste management programs
at this time require that EPA give first attention to the
setting of standards for high-level geologic disposal.
McGARITY: The next question is from Robert Schainker.
ROBERT B. SCHAINKER: Two items; one a little on philosophy
and one just a very simple matter. The first item is that in
general the topics of this particular panel were extremely
more technical than some of the other panels. Consequently,
a lot more jargon and technical terms were used. In terms of
the general acceptance of the methods, the approaches, and
letting the public understand our ideas, I think we have to
find even simpler ways of explaining ourselves than what has
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been presented. I was talking earlier to a journalist,
and we have a very, very difficult problem, but we should
at least attack it to bring some of these concepts into
very simple language. I think you did a phenomenal job
but it still went over the heads of a lot of people. One
way of simplifying things is that when you come with a
question you are addressing, put your answer up front and
your description later. It takes quite a while to understand
whether there was a "yes", a "no," or a "maybe." One way
of settling this problem is by stating your answer first.
I read the question after I listen to what you wrote and
I am still not sure if you answered the question. Or they
gave me a lot of good information, and that is good informa-
tion but it answers a different question. It is just an
observation of mine. Now to the simple matter; on the
very last page, you used the word "precision," and I think
you really mean the word "accuracy." Both terms are well
defined in statistics. But you say here, "The methodolgies
of benefit cost, benefit-risk, fault tree, event tree,
and consequence analysis provide guidance but not necessarily
precision with respect to waste management decisions."
You really mean "accuracy" because they all have great
precision but they are not necessarily accurate at all.
JOHN BARTLETT: We mean precision.
SCHAINKER: Let me define my terms, gentlemen. Accuracy is
referred to as the truth, a deviation from some hypothetical
true solution to a given problem; whereas precision is a rep-
resentation of the, shall I say, small amount of uncertainty
about using a given calculation approach. You could think of
it as a needle on an instrument. The needle may vibrate very
little and have very good precision, but the instrument may
not be calibrated correctly. Therefore, it may be entirely
inaccurate and yet have great precision. Now which term do
you mean?
BARTLETT: Precision, in the sense that the error bands are
anticipated to be large even though you have come up with a
highly deterministic number. The error bands are large. But
we do anticipate that the accuracy in sense of order of magni-
tude is pretty good.
SCHAINKER: I think you may then want to define your word
precision. It turns out the word you are using for precision
is the word I use for accuracy.
BARTLETT: No, I am quite confident that we know the defini-
tion of accuracy and precision, and that we prefer precision.
SCHAINKER: Well, I think I will discuss this matter with you a
little later. But one point is that you could define your terms.
There is a whole set of terms called "fault tree," "event
tree, and "cost-benefit." I have been aware of'such terms
2-90
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some of these papers but I am sure the general public does not
know what those particular techniques mean, although they are
in WASH-1400 and some other documents. Thank you.
KAUFMANN: I would like to comment on that. Some of the ideas
that were behind making up the issue paper and assemblying the
panel to take on those issues I will take credit or blame for.
I was extremely pleased with the cooperation we got from the
floor and from the panel. Trying to put seven people together
that are exemplary of the issue area is impossible.
Hopefully, if there are shortcomings, we can make up for it in
Albuquerque. The environmentalists on the floor and one or
two that are here now are quite educated. I think that
when we look at their growth we have come down perhaps to a
slightly less technical level, but they have done a tremendous
job in coming up to our level. They ask good questions, they
expect good answers. I do not think we can address our work
to the person reading the Daily News; it is just impossible.
Now, I feel that the consensus that the American public is
looking for is going to come from the Federal agencies pulling
together, and I believe that consensus of Federal agencies
will also carry the legislators. I think the decision and the
agreement have to be reached at the Federal agency level and,
of course, with industry, and that will carry the public and
the legislators. That is my own opinion. But that was behind
the way we organized and our willingness to take on tough
questions and to try to develop consensus on tough questions.
I do not think you can reduce a lot of these things to the
public, any more than when I go to a medical doctor for
treatment, I can understand every last thing he does for me,
with me, to me.
McGARITY: I would point out that there was no attempt made to
do that, to reduce this to...
SCHAINKER: I appreciate the efforts involved and the
intentions and I understand that. But I think that there are
some philosophical points that you raised right now that
.should be brought up as very important items to be considered
at the next Workshop, one of them being: Is it really
impossible to inform the general public about these issues?
You just stated that in your opinion it is impossible. I can
respect your opinion, but that issue may be at the foundation
of some of the acceptability points of view of this entire
nuclear issue. And that is a very, very important issue that
should be brought up.
McGARITY: That point was raised, I can say, and it is
discussed in the paper when we talked with regard to question
7 on acceptability. The consensus was that it should be
phrased in terms—whatever the output of this risk analysis
was—that are understandable to the decision-makers and/or the
general public.
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FORBES: I think that is an important point to stress, and I
think you should read question 7 in more detail because we
construed risk assessment to mean that detailed calculation of
probabilities and consequences, which is by necessity a fairly
detailed, technical subject. We said, however, that for the
purposes of determination of acceptability and translating the
detailed, technical methodology to the public, that was
another step again, and that required such things as comparing
the risk of waste disposal to other things. We recognize
that, and I think you will see that attacked in question 7.
McGARITY: There is something that did not come out, though,
which there was consensus on: that the assumptions that went
into these should be made clear to the decision maker and/or
the public.
McGARITY: The next question came from Mr. Meyer. "It was
suggested that study of comparative risks of nuclear and
nonnuclear ... would perhaps give a better perspective on the
waste management issue."
SCHAINKER: Thank you, gentlemen.
G. LEWIS MEYER (Environmental Protection Agency, Washington,
D.C.): Well, that sentence did not seem clear to me. Nuclear
or nonnuclear what0
McGARITY: There is evidently a word left out. It would
probably be power generation or something of that sort.
MEYER: Not necessarily.
McGARITY: Slightly prior to that we discussed whether we
meant that the comparison should be between just the waste
cycles of either cycle or between the full cycles and there
was no consensus on that issue. Maybe that clarifies it.
The next comment is from Frederick Forscher.
FREDERICK FORSCHER (Energy Consultant, Pittsburgh
Pennsylvania): I really wanted to say the same thing that Mr.
Schainker has brought up before, and that is that too much
emphasis was placed on the quantitive risk analysis. It is
nice to recognize that there are techniques to analyze these
risks, but it must be realized that, from the decision-maker's
point of view, and from the point of view of the public which
has to accept the decisions, risk analysis can only be about
25 percent of this decision. There is the perceived risk,
there is the quantified risk, there is the perceived benefit,
and the quantified benefit. We have concentrated in this
paper too much on the quantified risk analysis. Only in the
last page do we get into the realization that it is not as
complete and as satisfying philosophically as well as
quantitatively as one would like to have it, and therefore
there are other inputs necessary. One, for instance, is the
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suggestion of compared fuel cycles, nonnuclear and nuclear.
I would like to see this too. This again depends not only
on the quantified risk but on the perceived risk in fossil-
fuel cycles as well as the perceived benefits of the fossil-
fuel cycles.
McGARITY: Any comment on that?
LOCHSTET: I think from the point of view of setting
standards, what you are interested in is the way nature is,
not the way people think nature is.
FORSCHER: It is possibly philosophical, but scientists are
trying to find out what nature is all about. Yet in certain
criteria and standards they are making decisions. A criterion
is a decision; as much a decision as the law is a decision.
Congress makes decisions. We hope that the congressional de-
cisions as well as the ones made by regulatory agencies on
criteria are acceptable. And what we are talking about from
the public point of view is the acceptability of these
decisions. Acceptability is the balance of benefits to risks.
The public will accept the decision if the benefits exceed the
risks.
BARTLETT: I think if you look at this issue in its entirety
and if you had attended this session, you would find that
indeed there runs through the whole thing the thread of rec-
ognition that risk assessment is by far not the total answer
to the question. The session was specifically addressed to
the question of what methods of risk assessment might be used
and the variations within the uses of those methods. I think
we did have a proper perspective of its limitations but we had
to report for purposes of this being a tool to EPA as what we
think in terms of its use as a tool.
FORBES: I think that is important to stress....Just to read
the title, "Risk Consideration of Radioactive Waste
Management" emphasizes that we were constrained in this ses-
sion to look at risk analysis. As far as we could, we tried
to stick to that topic. We got off it frequently, but cer-
tainly tried to point out that risk analysis was not the basis
for decision making.
McGARITY: There is another comment by Mary Nightlinger
(t§§2U§_of_Women_Votersi_Fairfaxi_Vir_3inia) that seems to be
pretty~much of the same order." Would you like to address it
nevertheless? Okay, I will read your comment. "Most of the
recommendations of this session centered on systems analysis
approaches. These methods try to reduce all issues to numeri-
cal comparisons. As many of the necessary comparisons are not
truly capable of being expressed in numerical terms, the
resulting comparisons are sometimes not very meaningful. When
these numerical comparisons are addressed by the press and the
public, any warnings will fall through the cracks. Therefore
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the potential to mislead is very great. The Envrionmental
Protection Agency should be very careful that in its effort to
make things clear and simple, they do not end up making
misinformation clear and simple."
Finally, the last question was from Judith Johnsrud
(lDYil2Dmi:Dt §l_Coal i t ion_on_Nuclear _Powerz _S ta te_
ZkUDsy 1 vani^a)_. "The question" was "Did your" group distinguish,
in setting priorities, between military and commercial
wastes?"
LOCHSTET: I think some of us tried to talk about the
difference in the way in which decisions after the standard
was set might make a difference. That is, this was something
where we sometimes thought of the difference and sometimes did
not. A curie is a curie, regardless of where it came from.
But there are curies which are here, and there are curies
which are not yet here. I think we had some of that in mind.
McGARITY: There was some discussion of it; it was mentioned
but it really—and it was probably my fault—got muddled a
bit. The place where it should have been considered is in a
risk-benefit context, and we did not really get into that too
much.
KAUFMANN: I would comment that I think there was a feeling in
the room, and please tell me if I am not representing that
feeling, that we were trying to find out if we should take on
all wastes simultaneously with the same emphasis...or should
there be some order of priorities? And the order of
priorities that I feel was expressed by more than one member
was that we look at high-level wastes, and that a clear
distinction between commercial and Energy Research and Devel-
opment Administration was not in order but that a clear
distinction between high-level and other type wastes, was
in line with Dr. Maxey's comments on the opening day and
others. Let us get the worst problem in order first.
FORBES: I am not sure we concluded that high-level waste was
necessarily the...well, perhaps "worst problem" is a difficult
thing to define. We agreed that in terms of schedule, that
had to be tackled first. We did not spend time discussing
exactly on what basis, perhaps because we got consensus and
that was good enough so that there was no point in trying to
find out why. We agreed in terms of schedule but let me
stress that we tried to differentiate between that priority in
terms of the order in which one would tackle things and a
priority in terms of which most needed tackling. It was
agreed that all wastes should be treated on an equitable
basis—whatever that phrase means—that there would be the
intention to go on to subsequent wastes. I think it wasn't
always clear. Certainly in our session, I think in some cases
we were discussing all wastes and in some cases we were
discussing only commerical, high-level, and even specifically
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geologic wastes. But certainly the intention was that all
wastes should be considered on an equitable basis and that the
first item that has to be tackled is high-level waste. But
that does not mean that everything else should not be consid-
ered in terms of another priority for the need to be tackled.
McGARITY: That concludes our presentation.
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WORKING GROUP 3
LONG-TERM IMPLICATIONS
OF RADIOACTIVE WASTES
-------
LONG-TERM IMPLICATIONS OF RADIOACTIVE WASTE MANAGEMENT:
A STATEMENT OF ISSUES AND OBJECTIVES
This working paper identifies the long-term radiological con-
siderations for radioactive waste which will have a direct
bearing on the proposed criteria and subsequent standards. Two
specific areas are to be addressed: (1) institutional longev-
ity (or lack thereof) and its potential impact on radiological
exposure levels, and (2) the dose commitment to future generations
which would result from present decisions regarding the range
of available waste management alternatives. While present
wastes pose an immediate problem, the unavoidable reality
of physical half-life (in some cases a very long half-life)
will leave future generations with a potentially very real
and long-term future problem. Though gazing into the future
a million or even a thousand years is at best a speculative
exercise, it should be remembered that the aim of this
effort remains the identification of those factors contributing
to the long-term radiological impact of radioactive waste
management activities.
INSTITUTIONAL LONGEVITY
The previous generation has left a legacy of large amounts (in
terms of both volume and^curies) of radioactive waste
material. This waste is primarily high-level waste and
transuranic-contaminated waste from weapons development
programs, although it does include waste of the entire range
described in the previous section. With the expansion of
energy generation by nuclear means (an activity generally
foreseen to continue for at least the next few generations),
the present generation is adding, at a significantly
increasing rate, to the expanding inventory of radioactive
waste material on hand. The question yet remains unanswered
as to precisely what is to be done with it. The choice
is one of whether to make the decisions now to somehow
commit the radioactive waste to long-term management or
merely pass it on to the next and future generations, much
as this generation has inherited the waste of the previous
generation.
A common approach used in assessing the impact of a proposed
or projected activity is cost-benefit, risk-benefit analysis.
When dealing with radioactive waste management, this mode
of analysis seems to break down. The more tangible benefits
of nuclear and nuclear-related activities, i.e., those
resulting in the generation of radioactive waste products,
appear to be realized only in the present and immediate
future, while the risks associated with the resulting wastes
extend far into the future. The argument that future
generations will benefit from present technological development
assumes continuing technological growth, but this may be
of little consolation if we leave to the future the responsibility
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for handling both the present waste and that which will
be generated in the course of the expansion.
Another argument is that by present utilization of existing
nuclear resources, valuable fossil fuel resources will
be conserved for future applications, perhaps more specific
and beneficial than merely using these resources for their
heat content. This implies that there might indeed be
a future benefit associated with present activities generating
radioactive waste. However, this argument too may not
be entirely valid, for while such a scenario will conserve
fossil fuel resources for use by future generations, these
resources are limited and will in all likelihood be consumed
long before the risks associated with nuclear waste (past,
present, and immediate future) will have been reduced by
natural radioactive decay processes to acceptable levels.
Also, there remains the question of whether "buying time"
in terms of the overall energy picture by developing and
utilizing the nuclear fission economy is worth the price
of the resulting and unavoidable thousand to million years
during which waste management may be required. Regardless
of the future of nuclear activities, however, a waste disposal
problem remains, primarily in the form of the stored ERDA
wastes and uranium mill and phosphate benefaction tailings.
These considerations lead to the realization that present
indecision will only prolong the problem of radioactive
waste management and compound future risks. The implication
here is that while state-of-the-art technology may lead
to less than perfect solutions to the waste problem, the
present generation should make a concerted effort to formulate
and implement a waste management program. Failure to do
so would only perpetuate the risk of waste release and resultant
population exposures.
A question arises as to the duration of the radioactive
waste problem. As a general rule of thumb, it can be
assumed for the most part that transuranics pose a "million-
year" problem, while fission and activation products pose
a "thousand-year" problem, and that after these respective
periods the wastes will have decayed to acceptable levels.
Carbon-14 and iodine-129, both long-lived fission products,
are two principal exceptions. The duration and magnitude
of the problems associated with radioactive waste can be
reduced by partitioning (separation of transuranics from
other isotopes), fractionation (separation of short- and
long-lived products), and subsequent transmutation. Through
such processes, the overall waste management problem could
possibly be reduced from a million-year one to a thousand-
year one.
One option which has been proposed as being applicable to
both the relatively short-term and long-term problems is
isolation via placement in geologically stable formations.
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Subsurface salt beds have been identified as having many
advantages necessary for such isolation including long-
term stability, ability to recrystalize upon fracturing,
and ability to withstand heat stress. However, the evaluations
by the Atomic Energy Commission of disposal in an abandoned
salt mine near Lyons, Kansas, pointed out the uncertainties
associated with this disposal option. Although such geological
formations provide relatively good stability against the
forces of nature, the effect of the various activities of
man on such stability is less certain.
Two other basic options have been offered as potential
solutions to the million-year problem: transmutation and
disposal in outer space. There are uncertainties, however,
associated with each of these alternatives. An integral
step in transmutation is partitioning. However, it is
uncertain as to whether the waste volume will be reduced
or whether the required chemical processing will actually
result in an even greater, although separated, volume of
waste to be handled. Efficiency of separation processes
is another area of uncertainty; some of the long-lived
products will be carried over into the short-lived waste
stream. Transmutation is a concept that is yet to be proven
on a production scale. There is uncertainty as to the
energy input required to achieve transmutation and the
types and amounts of additional waste products that would
result. In disposing of the long-lived materials in outer
space, there are doubts as to payload capabilities and
our ability to provide adequate safeguards to assure that
launch pad failures and/or reentries either will not occur
or, if they should occur, would not result in releases
of radioactive materials to the biosphere.
While projections or speculations can be made on further
technological advances to overcome these obstacles, such
technology does not presently exist. Because of the pressing
need to address the problem of radioactive waste management
in the present, utilizing state-of-the-art technology, it
is the million-year program which has received the most attention
to date. This does not imply that all future waste will
necessarily be committed to the million-year concept ultimately
to be formulated. As technological advances are made, it can
be assumed that the waste management program will correspondingly
evolve. Concomitant with this assumption should be the under-
standing that the long-term integrity of wastes disposed
of by the various methodologies discussed cannot, for the
most part, be assured for the hundreds of thousands or millions
of years required. At best, it would be a probabilistic
assurance of containment integrity. It has been suggested
that it would be more reasonable to ensure that in the
event of a containment failure, the length of time required
for the material to impact the biosphere would be sufficient
to allow the vestigial radioactivity to decrease to background
levels. This is the "return to a natural state" concept.
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An area of great speculation concerns the state of
intelligence and technology which will prevail in future
generations. Three basic positions are commonly put forth:
future intelligence will be at least equal to present
intelligence and, thus, be able to cope with and manage our
waste repositories; the intelligence of future generations
will surpass that of present generations and therefore our
waste management problems should be deferred to them; and
intelligence in the future will regress and therefore future
generations must be protected from our waste.
None of these views has gained full support as representing
the approach which should be taken with regard to radioactive
waste management, but at the same time each position has been
viewed as encompassing at least a part of what the overall
approach should be. There is no way of accurately forecasting
either the future stability of institutions or the future
state of intelligence and/or technology. Due to the uncertain-
ties in these areas, it has been suggested that all decisions
regarding waste management should be made independently
of any and all speculation with regard to these questions.
While it is possible that future generations may be better
able to handle the waste problem than the present generation,
it is questionable whether the present generation has the
right to make this assumption and merely defer the problem
unsolved. At the same time, if the waste management problem
is passed on unsolved, the risk is run that it will remain
unsolved.
The implications of these considerations are that the present
generation, to the best of its technological capabilities,
should establish and implement a waste management program
which would isolate past and present radioactive waste from
the biosphere and minimize the environmental impacts resulting
from such a program. Moreover, these goals should be achieved
without dependence upon the future stability of human institu-
tions. If this were possible, the present generation would
remove itself from all involvement in speculation as to future
conditions and would protect future generations from our ra-
dioactive waste. This is based upon two basic assumptions:
(1) that a disposal concept can be designed and implemented in
such a way that the probability of natural or accidental disruption
will be minimal, and (2) that intentional intrusion will not
be attempted by future generations (the latter assumption
perhaps quite optimistic).
There have been various arguments as to what conceptual
approach should be taken to guarantee the effectiveness of
these efforts. One opinion holds that the adopted concept
should be such that accessibility and retrievability of
committed waste would be, for all intents and purposes,
impossible. While this solution, in time, may not prove to be
the best, and while future technological advances may result
in better methods for waste disposal, the argument is that at
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least the present generation will ultimately protect itself
and future generations from our own waste, and do so in
such a way that future generations are not relied upon
to either achieve or continue this goal. At the same time,
however, the concept of retrievability has gained support
as permitting the present generation to manage its waste,
while leaving the options left open to future generations
to perhaps better handle the waste.
The question of institutional longevity is a major one
in the determination of the nature of the waste management
concepts to be pursued. In considering a concept in which
human interaction over long periods is involved, there
are uncertainties as to: (1) the stability, continuity
and perpetuity of recordkeeping; (2) the ability to assure
long-term caretaking and safeguarding of a respository
site; (3) the ability to assure continued capability for
surveillance and accident response; and (4) the long-term
accessibility and capability for retrieval. These areas
of uncertainty are associated with any long-term "storage"
concept. While it may be argued that the necessary institutions
will continue to exist in perpetuity, the other side of the
argument may be just as easily advanced: Can one reasonably
assume that such institutions as governments and national
boundaries will survive the time periods over which the
waste must remain isolated? In either case such arguments
may result only in unnecessary and unsubstantiated speculation.
Over the relatively substantial time periods relevant to
the long-term management of radioactive waste material,
it has been generally accepted that nature has been more
stable than human institutions. Rather than designing a
waste management program around the uncertainties of human
institutions, it may be more advisable to design the system
in sueh a way that the isolation of the radioactive waste
material is entrusted to nature. After an initial validation
period, human involvement will become peripheral (though
perhaps desirable)—not a necessary activity in assuring the
isolation of the disposed waste from the biosphere.
DOSE COMMITMENT TO FUTURE GENERATIONS
With regard to the dose commitment to future generations
resulting from waste management activities (or lack thereof),
one is faced with the fundamental question: To what maximum
level of radiation exposure are future generations to be
exposed? There is first a fundamental problem associated with
the determination of such a level, for no guidelines have been
developed for current population exposure from this source.
Assuming the existence of such guidance, however, there are
basically three possible answers to this question: more, less,
or the same as allowed the present generation. In weighing
these possibilities, a consideration that should again be kept
in mind is that the more tangible benefits derived from the
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activities responsible for generation of the wastes are
enjoyed primarily by the present generation and in the
immediate future.
While the arguments seem almost entirely philosophical,
it is generally accepted that to commit future generations
to higher levels of radiation exposure than the present
generation is willing to accept is unjustifiable. To do
so would be even more unconscionable in view of the complete
lack of derived benefits to future generations from present
waste. Further, by passing on this commitment without
benefit, future generations are perhaps deprived- of the
option to develop future activities from which they might
derive direct benefits.
To say that future generations should be exposed to the
same level of radiation from the storage or disposal of
radioactive waste as is allowed the current generation
is a specious statement. For with the exception of the "as
low as practicable" guidance, there is no presently existing
guidance to apply to such exposures (assuming extrapolation
of this guidance to the waste management area is even valid).
Assuming there were an established numerical limit for
radiation exposure due to waste management activities analogous
to the uranium fuel cycle and drinking water standards,
there remain several areas that require consideration.
These include the question of projected exposures, the potential
for buildup of radiation-induced genetic defects, and the
irreversibility of dose pathways.
If dose commitments due to waste management activities
to future generations either in excess of or equal to presently
acceptable levels are deemed unacceptable, the question
arises as to just how low the future dose commitment must*
be before it will gain acceptability. One approach would
be to start with a management concept which would yield
a relatively high dose commitment and through application
of technological improvements reduce that dose level.
Another more conservative approach which could be taken
in formulating a waste management program would be to start
from the basis of zero-release and zero-dose.
The first step in analyzing the zero-release, zero-dose
concept would be to establish the feasibility (or lack
thereof) of achieving these goals. It can be assumed that
over the geological time-frame which must be considered
for any waste management program, it would be impossible
to assure, beyond doubt, that no releases and no resultant
dose commitment would occur. The problem then becomes
one of determining what minimum upper limit level can be
feasibly achieved within the scope of presently existing
or foreseeable technology. Here, there are basically two
factors operating in opposite directions: the increased
cost required to achieve lower limits versus the societal
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pressure to achieve levels as low as technically possible.
Cost-benefit analysis in the classical sense would not seem to
apply, for again the "benefits" derived from a waste manage-
ment program are of a somewhat negative, or at best, passive
nature. It appears the solution will be more costly than what
would be generally considered "cost-effective." But it will be
one which should result in release and dose levels that, while
not absolutely zero, will be close enough to zero to gain
support as being "not unacceptable."
SUMMARY OF CONSIDERATIONS
The considerations which have been identified and discussed in
the preceding text are summarized in addition to others
expressed in various papers and reports in order to facilitate
review. They are not necessarily listed in order of priority,
and as they reflect merely one group's efforts (i.e., EPA's),
they obviously do not represent a complete list:
1. Should the present generation commit itself to formu-
lating and implementing a waste management program
based upon a disposal concept or will long-term stor-
age suffice?
2. Should the proposed program use state-of-the-art
technology, or should yet-to-be developed technologi-
cal capabilities (e.g., partitioning, transmutation,
deep-space disposal, etc.) be relied upon as near-
future realities?
3. How should waste immobilization be achieved?
4. Should past and present waste be committed to irre-
versible disposal or should options be left open for
future generations to improve upon our program for
the management of these wastes?
5. Should the proposed waste management program be
designed in such a way as to be operable—to the
greatest extent possible—independent of institutional
surveillance and control? Should institutional
activities beyond an initial "proof-of-effectiveness"
period be viewed as peripheral convenience, if
available, but not necessary for the continued
safe functioning of a repository into perpetuity
(such activities would include recordkeeping,
caretaking, safeguarding, surveillance, accident
response)?
6. It is EPA policy to assume that all levels of
radiation dose result in detrimental effects.
Accepting such a policy, should the goal of the waste
management program be zero-release, zero-dose?
7. Should reliance be placed upon nature for the stable
isolation of the disposed waste rather than upon
societal institutions?
8. Should achieving minimum upper level release and dose
limits which can be considered as being "not
unacceptable" be the overriding design consideration
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rather than cost-benefit considerations?
9. Should waste management criteria be generally
applicable to all forms of existing and future
radioactive waste material?
10. Should consideration of potential long-term hazards
for various management options take priority over
present concerns over near-term risk and cost?
11. Should the concepts of multiplicity of sites and
diversity of options be implemented as a means
of limiting the impact on future generations due
to the potential failure of a particular disposal
site and/or technology?
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CONTROL OF RADIOACTIVE WASTES:
ISSUES, PROBLEMS, AND QUESTIONS
TERRY R. LASH
Natural Resources Defense Council
2345 Yale Street
Palo Alto, California 94306
The Environmental Protection Agency (EPA) is to be applauded
for convening this Workshop and exercising its proper role in
the establishment of criteria and standards regulating the
storage and disposal of radioactive wastes. The EPA is virtually
alone among Federal agencies with programmatic responsibil-
ities in vigorously seeking meaningful public input. Unfortunately,
because the Office of Radiation Programs has been unable to
obtain appropriate funding, citizen participation in this
Workshop will be less than desirable. The new administration
is urged to correct the past imbalance created by the financial
difficulties for ordinary citizens to attend and participate
in workshops such as this one.
The two Federal agencies principally responsible for the
promotion and regulation of nuclear power, the Energy Research
and Development Administration and the Nuclear Regulatory
Commission, respectively, are focused exclusively on how to
provide facilities permitting rapid growth of nuclear power
and on how to license more nuclear facilities. The recent
actions of the Nuclear Regulatory Commission in trying to
circumvent and overturn the findings and order of the United
States Court of Appeals for the District of Columbia Circuit
are particularly troubling. That court, in its July 1976
opinion, stated that:
The Commission's action in cutting off consideration of
waste disposal and reprocessing issues in licensing
proceedings based on the cursory developments of the
facts which occurred in this proceeding (generically
considering the environmental costs of radioactive
wastes) was capacious and arbitrary.
Instead of trying to correct the serious deficiencies
identified by the court, the NRC response has been first, to
ignore the plain meaning of the court's opinion by issuing an
interim rule and permitting full power licensing without more
than a superficial notice and comment proceeding, and, second,
to appeal to the U.S. Supreme Court, even though the U.S.
Department of Justice decided an appeal was not appropriate.
Indeed, the Department of Justice has filed a legal brief with
the Supreme Court urging that it not accept the NRC's appeal
for review. With this kind of disregard for the law and the
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public interest at the NRC, the Environmental Protection
Agency's activities are particularly important.
My presentation is divided into two parts. The first part
reviews very briefly some of the more important general issues
and problems associated with the need to exercise extreme con-
trol over radioactive wastes. The second part addresses the
specific questions raised by the Environmental Protection
Agency in its background statement for this Workshop.
Current programs for handling radioactive wastes in the United
States stand in disturbing disarray. The situation has
reached a critical point in determining the viability of the
nuclear power industry and the safety of future generations.
Unless substantial improvements are implemented in conjunction
with the proposed rapid development of the nuclear option, the
risk of releases of radioactive wastes to the environment may
become unacceptable.
A total management policy for radioactive wastes must deal
with varied and voluminous wastes, all posing different and
difficult handling and storage problems:
1. The nuclear fuel cycle begins with the mining and milling
of uranium ore, a process which yields a semirefined
compound of uranium (U30s) for use in the fabrication of
fuel rods, but leaves behind massive piles of "mill
tailings." These tailings consist of a sand-like residue,
containing the hazardous and long-lived natural radionu-
clides thorium-230 and radium-226, in a form relatively
easily dispersed by wind and water. Methods must be
devised to prevent natural processes from dispersing this
dilute but dangerous material.
2. Low-level wastes result from the routine operation of nu-
clear facilities. They in general consist of discarded
materials that have been contaminated in the course of
normal operation of plants handling radioactive materials.
Some government agencies have estimated that the nuclear
power industry will produce hundreds of millions of cubic
feet of this radioactive "garbage" by the year 2000. To
date, disposal practices have indiscriminately mixed
materials contaminated with extremely hazardous, long-
lived radionuclides with materials contaminated with
shorter-lived radioactivity. Moreover, management
practices at many disposal areas have been notoriously
inadequate, allowing some radioactivity to migrate away
from one-third of the existing commercial disposal sites.
Contaminated equipment has even been smuggled away from
another commercial disposal site. Only recently has the
government recognized the need to segregate contaminated
materials according to their toxicity and the need to
improve the safety of disposal operations.
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3. Radioactive gases, containing iodine, carbon, tritium, and
krypton, are released during the operation of power reac-
tors and fuel reprocessing plants. There is no doubt that
the proliferation of nuclear power plants requires that
the bulk of these gases be trapped and not released to the
environment. Precise containment plants have yet to be
formulated, however, and obvious difficulties in storing
dangerous gases intact over long periods of time have also
yet to be resolved.
4. The radioactivity in "high-level" wastes, which have
received the most public attention, are produced in the
nuclear fuel rods during the course of the fission
reaction in the reactor core. After these rods have been
"burned" in the reactor for about three years, the
industry plans to have the rods "reprocessed" to recover
unused uranium and plutonium. Plutonium is a
"fiendishly toxic" element with a half-life of over 20,000
years, which can also be used to fuel reactors or to
make nuclear bombs. By dissolving the reactor's ceram-
ic fuel, however, reprocessing also produces a highly
radioactive liquid waste product that must be isolated
from the biosphere for hundreds of thousands of years.
A precise plan for converting the high "burn-up" commercial
liquid wastes to a solid form has yet to be developed.
Indeed, the nuclear industry has asked the Federal
government to build the first "commercial" solidification
facility in order to demonstrate to industry that
solidification can be accomplished safely and economically.
Evidently, the uncertainties are too great for the
industry to risk its own funds. Continuing government
efforts to identify an acceptable site to bury these
wastes deep within the earth have also yet to be successful.
All we have now are past failures and milestones on
charts indicating current plans and future hopes.
5. Finally, the need to decontaminate and decommission all
nuclear facilities will also produce significant amounts
of radioactively contaminated material. Virtually no work
has been done by either government or industry to identify
acceptable means of disposing of these materials.
No fully acceptable disposal means is currently available for
handling any of these categories of wastes. Beyond the sig-
nificant technical obstacles to devising acceptable disposal
methods, major barriers to implementation of adequate waste
management programs come from institutional and human
failings. A brief review of America's nuclear development
reveals frequently ill-advised and, at least in hindsight,
irresponsible decisions by the Federal government which have
caused unnecessary delay and expense as well as unwarranted
health hazards.
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The Hanford Reservation in eastern Washington illustrates the
lack of planning inherent in the former Atomic Energy
Commission's (AEC) program for waste management. High-level
wastes generated during the production of nuclear weapons have
been stored at Hanford for the last thirty years, mainly in
the form of liquids and "wet" solids. When these wastes were
pumped into underground "mild" steel tanks, AEC officials and
scientists purportedly recognized the short-term nature of
such storage. Although the waste managers soon realized that
the tanks had an effective containment lifetime of only 10 to
20 years, they continued to store the wastes in a form that
could not be easily recovered. The net result has been sever-
al major releases of radioactivity into the ground; official
predictions of future leaks from the disintegrating tanks; and
no easy, safe way to retrieve the wastes for safe permanent
storage.
The lack of adequate planning and analysis in the past is also
reflected in the history of the government's weak efforts to
establish a permanent repository for commercially generated,
long-lived radioactive wastes. The search for the "ultimate"
solution to the problem of perpetually storing high-level
radioactive wastes from the commercial sector began shortly
after passage of the Atomic Energy Act of 1954. From the
outset, the AEC and its advisors focused on bedded salt
deposits as the most likely geological formation in which to
dispose of the long-lived wastes. In 1957, for instance, a
special committee of the National Academy of Sciences-National
Research Council agreed that "[d]isposal in salt is the most
promising method for the near future." After several years of
investigation and study on bedded salt, the AEC selected an
abandoned salt mine near Lyons, Kansas, as the location for a
pilot repository. The repository would have been a Federal
facility because an AEC regulation that became effective in
February 1971 required Federal custodianship of high-level
radioactive wastes produced in nuclear power plants. (The
need for Federal control is a testament to the long-term
hazard posed by the wastes.) If tests verified the
government's predictions of .safety, the Lyons mine was
supposed to become the first national repository for high-
level radioactive wastes. For a number of technical and
political reasons, however, the AEC formally killed its
proposal for the Lyons salt mine on May 18, 1972.
The AEC then turned its attention to similar formations near
Carlsbad, New Mexico. During the drilling of a third
exploratory well at a tentatively-selected site for the pilot
repository, scientists discovered a brine solution containing
pressurized quantities of hydrogen sulfide, a very poisonous
gas, and methane, a potentially explosive gas. The presence
of the brine solution raises serious doubts about the long-
term integrity of the salt formation and its ability to
prevent migration of the waste materials. The pressurized
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gases possibly pose a very serious hazard to miners who would
build the repository.
In response to this development the Energy Research and Devel-
opment Administration (ERDA) has de-emphasized the importance
of the Carlsbad area in its program for commercial wastes.
Testing for a safer site in the Carlsbad area has recently
begun again, however, while other types of geological forma-
tions are investigated throughout the country. At least
initially, ERDA's intent appears to be to emplace only
government transuranic wastes in the proposed Carlsbad reposi-
tory.
First the Atomic Energy Commission and now the Energy Research
and Development Administration have continued to underestimate
the facilities and management techniques required for storage
of high-level wastes. There are presently about 600,000
gallons of high-level wastes stored at the Nuclear Fuel
Services reprocessing plant in West Valley, New York. These
wastes were produced during the plant's operation from 1966
until 1972, at which point it was shut down for modification
and expansion. But there are still no plans for disposal of
the accumulated wastes. Recently, the Nuclear Fuel Services
Company has informed the State of New York that it wishes to
transfer ownership of the high-level wastes to the state.
This decision follows the release of a Nuclear Regulatory
Commission report that retrieving the wastes from the tanks
and solidifying them may cost 500 million dollars, or far more
than the income from reprocessing and the worth of the plant.
There are essentially two possible underlying explanations for
the lack of an adequate means or plan for the disposal of all
kinds of radioactive wastes. Either the Federal bureaucracy
is to a large degree incompetent or the radioactive waste dis-
posal problem is considerably more difficult than has been
publicly admitted by the nuclear power industrial complex.
Both explanations are largely supported by a careful examina-
tion of the record.
As the country prepares to turn to nuclear reactors for much
of its energy requirements, there is ample reason for concern
that it may be tragically short-sighted to generate wastes
irrevocably now on the optimistic assumption that a solution
to the threats posed will be found in the future. There
should be no delay in undertaking a wide-ranging, in-depth
review of ERDA's proposed waste management program and the
reasonable alternatives to it. The following recommendations
deserve careful consideration.
First, we should slow the production of radioactive wastes
until an adequate analysis of their hazards and management
possibilities can be made. Since we cannot permanently
dispose of these wastes now, prudence suggests that we mini-
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mize the amount of waste that must be handled until an accept-
able disposal program can be developed.
Second, no reprocessing to extract plutonium from irradiated
fuel rods should be permitted until several uncertainties are
resolved. Trace amounts of plutonium have been shown to cause
cancer in laboratory animals. Twenty pounds of purified
plutonium is sufficient to construct an atomic bomb. Until
serious questions regarding our ability to guarantee that
plutonium will not pose an unacceptable health hazard and that
it will not be diverted by terrorist or other groups for
improper uses, we should not permit it to be recycled.
Furthermore, no reprocessing of spent nuclear fuel should be
permitted unless the liquid wastes will be solidified
immediately in a format at least as secure as the fuel rods.
The reprocessing of fuel rods and fabrication of new fuel
containing plutonium will generate a large number of waste
streams that cannot be permanently disposed of now. The pro-
duction of these wastes should wait until the NRC completes a
thorough review of the overall waste management problem, as
ordered by the U.S. Court of Appeals for the District of Co-
lumbia. It is far from clear that the complicated set of
diverse waste forms originating in reprocessing plants and
mixed-oxide fuel fabrication plants can be handled safely. If
we are to continue reliance on nuclear power, the best alter-
native from a waste management perspective alone may be to
forego the plutonium recycle option. At the least, this no
recycle option is deserving of careful study, including public
review, before the nuclear industry is allowed to expand on
the assumption that recycle of plutonium will be permitted.
Third, we must improve our technical analyses and scientific
review of alternative waste management options. There is a
desperate need to decide explicitly the goals of waste manage-
ment and to develop precise criteria for determining the
likelihood that options under consideration will achieve these
goals. The establishment of goals and criteria must involve
a broad spectrum of scientific analysis. Experts in the rele-
vant disciplines who are not now a part of the nuclear indus-
trial complex must be given an adequate opportunity to review
the research projects associated with the development of a
waste management program. The purpose of this review is to
insure that an adequate technical basis will exist for
selecting a preferable waste management option that is
consistent with the goals. The failure to allow the scien-
tific peer review system to function in the past has lead
to the current insufficiencies of the government's research
program.
Again, I emphasize that EPA's program is very important in
this regard. Increased review by both EPA and non-
governmental groups is required, however.
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An example of the fundamental deficiencies in the data base is
the lack of information about the geological behavior of
radionuclides in a strong thermal gradient, such as will exist
if containers of concentrated wastes are emplaced underground.
Other serious deficiencies involve, for instance,
solidification of liquid wastes and the decontamination and
decommissioning of nuclear facilities.
Fourth, the Federal government should develop a "model" waste
management program using its own millions of gallons of high-
level radioactive wastes. These wastes will have to be stored
securely regardless of the future of nuclear power. But
before the commercial nuclear power industry expands further,
the Federal government should demonstrate to the nation that
it has the technical capability and the willingness to take
care of its own wastes.
Fifth, there is a great need, and opportunity, to improve our
decision-making process. Nuclear power, and energy policy in
general, are social issues that cannot be decided by bureaucrats
and technocrats alone. The public has demonstrated a growing
interest in the future of nuclear power. Citizens and
legislators must work with the scientists and bureaucrats
who have traditionally determined our nuclear policy in
order to establish a comprehensive set of objective criteria
for judging the acceptability of various options. I hope
that NRC and ERDA will follow and, indeed, improve on the
example being set by EPA at this Workshop.
Radioactive waste management poses a classic trade-off of
short-term versus long-term environmental^quality. Actions
taken to isolate radioactivity from the immediate environment
have often proved to be tragically short-sighted when measured
against long-term goals, as in the case of high-level wastes
at Hanford and the Nuclear Fuel Service's West Valley plant.
To achieve an acceptable social and technical consensus on the
best course of action, there must be regional, state, and
local government and citizen participation in the review of
alternatives for radioactive waste disposal. Until there is
thorough consultation with the varied concerned segments of
local and state governments, universities, and citizens'
groups about the goals and criteria of waste management, the
Federal program will continue to be embroiled in controversy.
Had the government involved the public sooner in its decision
to build a national waste repository at Lyons, Kansas,
considerable expense and wasted effort might have been
avoided.
Each state, particularly if it has or plans to have a nuclear
power plant, should raise the important societal issues
regarding radioactive waste disposal. The radioactive waste
issue is too important for a state to define its interests
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Regulatory Commission to consider fully the handling of
radioactiave wastes during the licensing of nuclear power
plants the states have a convenient opportunity for
considering this issue.
Finally, we must examine the moral dilemma posed by knowingly
creating such a long-lived and potentially lethal hazard to
future generations. Frequently proponents of nuclear power
point out that higher standards of safety and reliability are
applied to nuclear power than to any other power source. This
is, in fact, true, and can be justified for two reasons.
First, the toxicity of radioactive materials is much higher
than other likely environmental pollutants. The long-lived
nature of this radiotoxicity demands that we consider not only
the environmental quality of our generation, but also that of
generations a thousand or even a hundred thousand years hence.
It appears untenable to assume that society will remain
sufficiently stable to monitor and maintain our waste disposal
sites for the requisite hundreds of thousands of years.
Second, nuclear power is a recent development, and one that
has not yet proliferated beyond control. We have the opportu-
nity at this point to plan our progress and avoid irrevocable
commitments for ourselves and future generations. If we are
to continue our quest for improved environmental quality, we
must demand more of new technologies. It is not too late to
decide, after careful examination and thought, that nuclear
power is not worth the costs and risks of rapid development at
this time.
To facilitate the exchange of information and viewpoints at
this Workshop, EPA has prepared background statements that
identify some of the important issues that should be consid-
ered by the discussants. Each background statement also
includes a list of questions that need to be addressed
by participants. In order to initiate the dialogue on
these questions and to provide EPA with the information
it is seeking, I list my initial answers to each question
concerning the "Long-term Implications of Radioactive Waste
Management" below.
Quest^ion_l. Should the present generation commit itself to
formulating and implementing a waste management program based
upon a disposal concept or will long-term storage suffice?
Answer_l. The major thrust of the government's waste manage-
ment program should be to establish a waste disposal facility
at the earliest possible time consistent with~a thorough
investigation of alternatives and site characteristics. For
too long the government and the nuclear power industry have
postponed selection of a waste disposal means. The current
interim storage of long-lived wastes is wholly inadequate for
protecting the environment and public health. The full cost
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of nuclear power must be clearly identified for those
consuming electricity and internalized in the price of elec-
tricity. This can be partially accomplished by taking
appropriate measures to dispose of radioactive wastes in the
near future. Postponing the decision on ultimate disposal
will only continue to externalize waste disposal costs.
Question 2. Should the proposed program use state-of-the-art
technology, or should yet-to-be developed technological
capabilities (e.g., partitioning, transmutation, deep-space
disposal, etc.) be relied upon as near-future realities?
Answer 2. The available studies and data strongly suggest
that existing technology is adequate for disposing of the
existing and near-term production of long-lived radioactive
wastes. We should not postpone the decision to dispose of
wastes and the establishment of an actual disposal facility
until so-called improved by speculative technologies are de-
veloped.
Question 3. How should waste immobilization be achieved?
Answer 3. For reasons only partially related to radioactive
waste management, my opinion is that the preferred waste form
is spent fuel. However, if the societal decision is to have
reprocessing, then there should be immediate solidification of
the high-level liquid waste into an inert, relatively non-
leachable form, such as glass. The existing regulations
should be changed to prohibit the scheduled storage of high-
level wastes as liquids.
Question 4. Should past and present waste be committed to
irreversible disposal or should options be left open for
future generations to improve upon our program for the manage-
ment of these wastes?
Answer 4. If the waste form is spent fuel, then for perhaps
one to three decades, the spent fuel should be relatively eas-
ily retrieved for a deep geological formation. However, the
storage conditions must allow human control to be lost without
there being a significant possibility for release for large
amounts of radioactivity. If the wastes are in a form other
than spent fuel, then there should be no planning for the
possible retrieval of the wastes after initial tests are
completed.
Question 5. Should the proposed waste management program be
designed in such a way as to be operable—to the greatest
extent possible—independent of institutional surveillance and
control? Should institutional activities beyond an initial
"proof-of-effectiveness" period be viewed as peripheral
convenience, if available, but not necessary for the continued
safe functioning of a repository into perpetuity (such activ-
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ities would include recordkeeping, caretaking, safeguarding,
surveillance, accident response)?
Answer_5. The proposed waste management program must be
designed in a manner permitting containment of the wastes in-
dependent of institutional surveillance and control. In my
view, there is much greater certainty in predicting the future
course of geological events than institutional or societal
events. Institutions can be severely disrupted in the event
of revolutions, economic depressions, war, etc. Over a period
of many decades, institutions can also evolve into something
that was not originally intended. Such modified institutions
may actually be counter-productive in protecting the radioac-
tive wastes. We simply don't know. We should not conduct the
experiment to find out.
.6 • Jt is EPA policy to assume that all levels of
radiation dose result in detrimental effects. Accepting such
a policy, should the goal of the waste management program be
zero release, zero dose?
_6 . For deep geological waste repositories containing
long-lived radioactivity, the answer is yes. While I do not
hold that small releases of radioactivity would necessarily be
unacceptable, there is no means by which we can reliably
predict the magnitude of such releases from deep geological
repositories. Therefore, we should design the high-level
waste disposal facilities such that under likely conditions in
the future there will be no releases whatsoever. Furthermore,
there should be safety factors involved such that in the
unlikely event some breach of containment does occur, the
releases will be small. It makes no sense to me to establish
a particular numerical limit other than zero for the reason
that it would be entirely arbitrary and there would be no way
of confirming that a facility could meet the proposed
standard.
Question^?. Should reliance be placed upon nature for the
stable isolation of the disposed waste rather than upon
societal institutions?
Answer 7. Yes.
- _8 . Should achieving minimum upper level release and
dose limits which can be considered as being "not acceptable"
be the overriding design consideration rather than cost-
benefit considerations?
Answer_8. We need both types of standards for radioactive
waste management facilities. First, we should recognize that
there are unacceptable levels of release that cannot be
permitted under any circumstances. In effect, of course,
existing regulations do establish such maximum permissible
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releases of radioactivity. Second, those measures that would
be cost-effective in reducing radioactive releases even fur-
ther than the minimum acceptable standard, should be
undertaken. The analysis should be based on a comparison of
the benefits of the proposed action in comparison to the cost
There is no rational basis for making comparisons to other
ways that the same amount of money could be spent to achieve
higher levels of human safety, as has been suggested by some.
Such suggestions are simply red herrings. There is no mecha-
nism for transferring monies that can be spent on improving
the margin of safety for waste disposal facilities to other
types of programs.
_^* Should waste management criteria be generally
applicable to all forms of existing and future radioactive
waste material?
Answe£_9 . Yes. In particular, the new EPA criteria and
standards should be applied to the existing military wastes in
storage at government facilities.
Que_stiqn_10. Should consideration of potential long-term
hazards for various management options take priority over
present concerns over near-term risk and cost?
Answe_r__10 . I strongly believe that future hazards should be
compared to near-term hazards on a nondiscounted basis. In
other words, if saving 10 lives at any time in the future
means that we would have a cost of one life now, then we
should save the 10 future lives.
Question _11. Should the concepts of multiplicity of sites and
diversity of options be implemented as a means of limiting the
impact on future generations due to the potential failure of
a particular disposal site and/or technology?
Ariswer 11. At the present time it appears to me that we
cannot "have a sufficient number of sites such that the magni-
tude of a major release from any one of those sites would be
acceptable. Furthermore, my guess is that the greatest
possibility for failure of a waste repository will be due to
the human failings in selecting a site and in designing,
constructing and operating a repository, rather than in the
deficiencies of properly selected geologic formations. I
would rather have the country's best waste management talent,
and, unfortunately, there just isn't enough of that, focused
on only a few repositories to insure that they meet the
highest possible standards. In this way, I would hope that
there would be no significant possibility of a large release
of radioactivity at any time in the future. If we were to go
to the multiplicity of sites concept, the available expertise
would be thinly spread. Certainly there would be less
detailed oversight for each facility which professional
societies and citizens' groups could provide. In my view,
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chis lack of adequate oversight is likely to lead to less de-
sirable facilities and, consequently, a great likelihood of an
unacceptable release of radioactivity.
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THE LEGACY OF RADIOACTIVE WASTES: INFINITY AND ZERO
G. Hoyt Whipple
University of Michigan
Ann Arbor, Michigan 48109
INTRODUCTION
My assigned topic is the legacy of radioactive wastes.
In return for agreeing to talk on this subject, I received
drafts of several Environmental Protection Agency (EPA)
working papers. None had an author and each stated that it
did not present an official EPA position.
The working draft on the long-term implications of radioactive
wastes mentions two matters that may prove to be traps for the
unwary criterion-setter. These matters are referred to in the
working draft as the "million-year problem" and the "zero-
release concept."
The long half-lives of radioactive wastes and managing these
wastes in a way that permits no release are crucial to the
legacy that we leave to our descendants. It is therefore
appropriate that we consider these two matters here and now.
PERSISTENCE OF RADIOACTIVE WASTES
Consider first the persistence of radioactive wastes. You are
all aware that some of the constituents of the radioactive
wastes from nuclear power generation have very long half-
lives. For example, iodine-129 has a half-life of 17 million
years, but even this is not the full picture. Radioactivity,
like Zeno's paradoxical arrow, gets half-way to zero in one
half-life, three-quarters of the way in two half-lives,
seven-eighths in three half-lives, and so forth. Like Zeno's
arrow, which never reaches the target, radioactive waste never
decays completely away. Viewed in this way, radioactive
wastes present an almost infinite problem in that they never
decay completely; hence the word "infinite" in the title of
this paper. Fortunately, or unfortunately, depending on your
point of view, it is not that simple.
One instructive way to consider the period of time important
for radioactive wastes is to compare the toxicity of the
wastes produced by a nuclear power reactor with the toxicity
of the uranium ore from which the reactor fuel was obtained.
To make this comparison, the toxicity of the radioactive waste
is expressed in terms of the quantity of water that will
dilute the radioactive material to the concentration consid-
ered suitable for public drinking water (Ref. 1). These so-
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called maximum permissible concentrations have the merit of
putting all radioactive materials on a common basis. Further,
this is an appropriate way to express the toxicity of these
materials. If they do reach the biosphere and man they will
do so by being leached by groundwater, whether they come from
buried wastes or uranium ore. Calculations of this kind have
been made (Ref. 2,3) and show several interesting things.
The toxicity of the undisturbed uranium ore remains unchanged
for many millions of years because it is controlled by the
major radioactive parent, uranium-238, which has a half-life
of some 4,000 million years.
For the first several hundred years after leaving the reactor,
the toxicity of the nuclear wastes exceeds that of the ore,
initially by many thousands of times. At just about 1,000
years the toxicity of the reactor wastes falls below that of
the original ore.
But go back to the beginning for a moment. When the uranium
was extracted from the ore, a small amount of unrecoverable
uranium and essentially all of the radioactive daughters are
left behind in the so-called tailings. The toxicity of the
tailings, like the toxicity of the original ore, is dominated
by radium-226. However, the decay of radium-226 is controlled
not by its own half-life of 1,600 years, but by the half-life
of its parent, thorium-230, which has a half-life of 80,000
years. As a consequence, the toxicity of the tailings decays
with an overall half-life of about 80,000 years.
Adding the toxicity of the tailings to that of the reactor
wastes gives the total for nuclear power. This total does not
fall below the toxicity of the undisturbed uranium ore until
somewhat more than 10,000 years after the power was generated,
at which time one can say that the world contains less toxic
material than it did originally, thanks to nuclear power. At
about 1,000 years there is about twice as much toxic material
in both the tailings and the reactor waste as there was in the
original uranium ore.
At this talk of thousands of years leads quite naturally to
one of two conclusions: either it is too long to risk, or it
is too long to worry about. Before you chose between these,
consider one further aspect of radioactive wastes.
Whatever is finally done with these wastes, they will be in a
chemical and physical form far less likely to be dispersed in
the environment than are the naturally radioactive materials
in uranium ore. Further, they will be placed in geological
formations far less likely to be leached by groundwater or
otherwise disturbed geologically than is uranium ore. As a
consequence of this care, the nuclear wastes are much less
likely to reach the biosphere, even during the several thou-
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sand years before they become less toxic than uranium ore,
than are the radioactive materials from the ore itself.
We do not have a million-year problem. With a modest amount
of care, we do not even have a thousand-year problem. Infini-
ty, or forever, is not as long as it seemed at first.
ZERO RELEASE
No method of confinement or containment is absolute forever.
Water will dissolve even quartz in time, as the crystals
inside a hollow geode attest. Forever is a long time and zero
is a very small release. The criterion of zero release, if it
is interpreted literally, will forbid any method of managing
radioactive waste or for that matter any other waste.
Dr. Cohen (Ref. 4) of the University of Pittsburgh has
estimated the cancer deaths, which might result from the
random burial at 2,000 foot depths of all the radioactive
wastes resulting from the production of 400 million kilowatt
years of electrical energy (about twice the present annual
consumption of electricity in the United States). He
concludes that under these rather casual conditions there will
be less than one cancer death in the first million years fol-
lowing such burial. He goes on to point out that the uranium
which is consumed in producing this energy will reduce the
amount of radium to which we are exposed and, as a result,
will reduce the number of cancer deaths attributable to
natural uranium by a number greater than the number of deaths
attributable to nuclear waste. Here again, the world is
better off for the fissioning of uranium.
Although less than one cancer death in a million years is
about as close to zero as we are ever likely to get, it is not
zero release. To paraphrase Lord Acton: Zero corrupts, and
absolute zero corrupts absolutely.
Dr. Cohen concludes his article with a statement that goes to
the heart of legacy.
...As our distant progeny look back on the late twentieth
century, they will never notice the tiny amount (one part
in IQlu in our model for each year of all-nuclear power)
by which we will have increased the radioactivity in
their environment. We will rather be remembered as the
ones who consumed all the high-grade mineral ores-^all of
the copper, nickel, zinc, tin, lead, mercury, and so on-
-and worse than that, literally burned up at a rate of
millions of tons per day those once plentiful hydrocar-
bons—coal, oil and gas—that are valuable as feedstocks
for producing petrochemicals. The only thing that might
save us in their eyes would- be supplying them with a
technology that will allow them to live in reasonable
comfort without those resources; if we fail to do this,
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we are indeed deserving of their curses. The key to such
technology is, clearly, cheap and abundant energy, and
unless great economies can be achieved in harnessing the
radiation from the sun, the only source we have for
this is nuclear energy.
SUMMARY
In summary, let us recognize that the criteria of infinite
storage of radioactive wastes under conditions that guarantee
zero release cannot be attained. Let us also recognize that
there is no justification for either criterion. A reasonable
expenditure of care and effort will assure that releases and
any effects that they may cause will be entirely insignifi-
cant. Under these conditions, the legacy of radioactive
wastes we leave to our descendants is a trivial problem,
either in absolute terms, or in comparison to other burdens
we are likely to leave them.
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REFERENCES
1. U.S. Nuclear Regulatory Commission. Rules and
Regulations, Title 10, Chapter 1, Code of Federal
Regulations—Energy Part 20 Standards for Protection
Against Radiation, Appendix B, Table II, Column 2.
2. Blomeke, J.O. , C.W. Kee, and J.P. Nichols. 1974.
Projections of Radioactive Wastes to be Generated by
the U.S. Nuclear Power Industry. Oak Ridge National
Laboratory Report ORNL-TM-3965.
3. Bell, M.J. 1973. ORIGEN—The ORNL Isotope Generation
and Depletion Code. Oak Ridge National Laboratory
Report ORNL-4628.
4. Cohen, B.L. 1976. Environmental hazards in radioac-
tive waste disposal. Physics Today 1:10-15.
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LONG-TERM WASTE MANAGEMENT: CRITERIA OR STANDARDS?
Gene I. Rochlin
Institute of Governmental Studies
University of California
Berkeley, California 94720
The topic of this section of the Workshop is long-term impli-
cations of radioactive waste management. I pre'sume that the
public is aware of what radioactive waste is. However, there
is some disagreement as to what constitutes the "long term."
It is conventional when discussing nuclear wastes, and partic-
ularly high-level wastes (HLW), to speak of the bulk of the
fission products as the short-lived components (Ref. 1).
This is taken to mean that they will decay to "innocuous"
levels in times less than a thousand years. With the notable
exceptions of iodine-129 and technetium-99, the wastes said to
present a long-term problem are alpha-emitters such as
plutonium-239 or radium-226.
From a social or political perspective, it is difficult to
think of 1,000 years as the short term. If we were to organ-
ize the management of wastes according to our ability to
predict with some degree of reliability the course of human
institutions, the time periods would be better divided as
follows:
1. Short term - less than 50 years. Over this time,
reasonably sure predictions can be made, not only about
the stability, goals, and operation of human institutions,
but also as to the degree of uncertainty in our
projections of their behavior.
2. Intermediate term - one to two hundred years. Predictions
can be made with some limited degree of confidence. These
predictions are, like the previous case, based largely on
extrapolation or projection of present trends. But, over
such periods, the cumulative error owing to new
circumstances and unforeseen developments can result in
radical structural and policy changes. The degree of
uncertainty in our projections also increases sharply,
particularly with regard to events that are not
predictable from the past or from present conditions.
3. Long term - greater than one to two hundred years.
Uncertainties dominate predictive ability. For more than
a few thousand years, there is only uncertainty.
These intervals are based on consideration of social structure
and political and organizational lifetimes. The division
based only on policy would be drawn at much shorter times.
This division also corresponds reasonably well to three
different ways of evaluating the intertemporal distribution of
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costs and benefits. In the short term, cost-benefit or risk-
benefit ratios suffer from no more than the usual limitations:
definitional problems with cost, risk, and benefit; equity;
quantification of intangibles; and so on. These are exten-
sively discussed in the literature (Ref. 2) and are included in
the appropriate section of this Workshop. In the intermediate
term a new element enters: intergenerational equity. Not only
the distribution of benefits, but also the ethics of passing
along risks and costs to our children and collateral descend-
ants must be considered. There does exist, however, an ethi-
cal basis for evaluating our obligations. Those generations
are our direct descendants. Our ethical obligation to them is
based on an extension of our own obligation to our parents and
our peers, and to the continuity of social, family, and
political relations (Ref. 3).
In the long term both the intergenerational distribution of
benefit, risk, and cost, and the ethical basis for our
obligation to consider them, become less sure. The ethics of
dealing with the future are, at best, imperfect. They have no
basis in the traditional philosophic terms of reciprocity and
self-interest (Ref. 3). Neither can we base our treatment of
the future on economic or political equity (Ref. 4). If any
finite discount rate is used, the present value of future harm
is always nil for long periods of time. If all generations
have the opportunity to vote, ours could never act at all on
issues affecting large numbers.
The internal processes by which decisions are made cannot and
do not systematically provide a form for taking into account
the rights of the future. Even with the most open and public
debate, there is no voice that can speak for the concern of
future generations, their desires, or their evaluation of good
and harm. The only principles that can be used for bringing
the future into our decisions are moral and ethical ones, and
even these are difficult to apply. One suggestion for this
purpose is the extension of two ethical principles usually
defined in a more limited context. The first is to provide
the fullest information possible as to future risks and costs
(Ref. 5). That the future may not be able to act upon this
information does not remove our obligation to supply it. A
minimum ethical principle for exporting risks is to do so
openly. The second principle is to act so as to minimize ir-
reparable harm. Every action has consequences for the future.
As Hannah Arendt has pointed out (Ref. 6), this distinguishes
actions taken in the context of human plurality from those
actions that deny it. We do not have to draw back from taking
action; however, we must accept responsibility for the
consequences.
These principles have led to the suggestion that primacy must
be given to minimization of long-term risks in establishing a
framework for organizing waste management options. Immediate
and short-term risks and costs will be borne by the generation
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that derives the benefits, and their descendants. Risk and
benefit can be weighed and decisions made fairly, as the risk
cannot be exported to other populations or the future. Costs
are the least important. They are unlikely to be prohibitive,
and can be used to select options that are acceptable on other
grounds. If society decides it cannot or will not pay for the
best system it can devise, this decision will at least be made
openly.
The United States is currently engaged in attempting to deter-
mine the technical options for and the goals of waste management
policy. Once these are defined, criteria can be established,
based on empirical data, to provide a quantitative basis for
choice. In the usual circumstances, these criteria would then
be translated into standards, such as allowable releases in
Ci/year, that are based on normative judgments as to relative
risk and benefit to society.
Unfortunately, even if there were general agreement on the
basis for protecting the future, this would not necessarily
lead to the selection of appropriate waste management stan-
dards. However, it might lead to the rejection of some
inappropriate ones. Zero release - zero dose, for instance,
sounds impressive. Given our uncertainties abut long-term
institutional and geologic stability, however, can it ever be
more than an idealistic phrase? Can it take into account
anthropogenic intrusion? Such problems do not vanish if a
specific low, but nonzero, release rate is used.
I believe that regulatory action will have to be based on
criteria for disposal practices and sites, rather than stan-
dards for release or dose. These criteria may in themselves
not be wholly adequate or easy to define, and may involve much
uncertainty, but to fall back on the goals themselves would
lead to no program at all. There must be some interpretation
of the goals into operational specifications if judgments are
to be made.
A general goal, for instance, is the interposition of barriers
between nuclear wastes and living things. These barriers can
be physical, such as geological emplacement; technical, such
as vitrification to prevent leaching; or institutional, such
as a monitoring and repair team. In listing them in this
order, the author has deliberately performed a ranking that
reflects not only his own judgment as to the order of impor-
tance, but also correlates with the time scales previously
defined. Geology can, if carefully chosen, provide a secure
and not too uncertain barrier over very long times. Low leach
rate appears to be reliably predictable over hundreds of years
but, for glass at least, is less sure over longer periods of
time. Institutions are to be used for error correction and
detection, and are not relied upon to provide a secure barrier.
If institutions were reliable and long-lived; if their perfor-
mance and objectives were stable over time; if we knew how a
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waste management institution would respond to changes in the
scale of operations, to public confidence, and to the defined
importance of its tasks, then we might begin to consider
institutional solutions adequate for the intermediate term. In
that case, a very retrievable surface storage facility would
be acceptable. Error detection and correction, monitoring,
and future alterations in disposal method would all be
facilitated. But even under the most stringent assumptions as
to future stability, there is no ethical justification for
imposing upon the future an obligation to take care of our
wastes for no benefit, a responsibility to maintain their
institutions at a level of stability and performance that we
define, in order to protect themselves from the consequences
of our actions (Ref. 7).
Technical barriers should not be relied upon for primary
containment. There are limitations to our technical know-
ledge, many of them as yet unperceived. The behavior of some
materials, such as concrete or glass, over many thousands of
years under the conditions of thermal and mechanical stress
that may be encountered, may be accurately modeled by short-
term experiments. However, we have no way of knowing for sure
without a verified physical theory for their behavior. More
importantly, reliance upon technical barriers alone implies
accessibility. As with institutional barriers, this provides
the ability to repair or replace a system that shows signs of
failure. However, without even attempting to judge whether
future beings will be more or less technically competent or
intelligent than ourselves, or whether they will be able to
detect or understand a release of radiation, the burden of
keeping the site free from intrusion and providing for
monitoring and repair will be transferred to them for no
benefit. If institutions or information should disappear,
such a method might prove to be an "attractive nuisance"--
drawing uninformed but intelligent beings to it by the inex-
orable force of intelligent curiosity.
Therefore, I argue for placing primary reliance on physical
barriers such as deep geologic implantation. These are the
most secure against uncertainty and natural accident. If
properly chosen, away from mineral deposits and features that
draw the interest of scientists or mineral explorers, they can
also be fairly secure against anthropogenic intrusion.
Recently, the author advanced two social criteria—technical
irreversibility and multiplicity—that attempted to address a
mixture of natural and anthropogenic causes of failure (Ref. 8).
They were constructed specifically to address the reduction
of future risk in the face of inherent uncertainty as to
social and political developments over required isolation
times, and to provide for safe disposal without requirements
for future ability to recognize, repair, or detect errors
or failures. Technical irreversibility is defined by a
combination of social and physical elements that measure both
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the size and the sophistication of the technology or natural
mechanism that would be necessary to return the wastes to the
biosphere in quantities that would be harmful to life. It is
intended to correlate with the degree of scientific or techni-
cal aptitude that would be required for deliberate waste re-
covery by a society of intelligent beings, and with the size
and cost of the required effort.
Technical irreversibility measures resistance to both social
and physical intervention. It does not correlate precisely
with scientifically defined irreversibility. Irreversibility
can be expressed mechanically, as with a ball rolling down a
hill set in the middle of a flat plain. The application of a
little intelligence and energy can easily restore the ball to
the top of the hill. The irreversibility embodied in the
second law of thermodynamics is based on the difficulty in
restoring an initial situation in the face of statistical
improbabilities, and the unlikelihood that a specified event
or set of conditions will spontaneously occur if it is but one
of a large number of accessible outcomes. The presence of
intelligence, however, allows the creation of improbable
circumstances; reversibility may be expensive, but it is not
in principle impossible.
There are parallel examples of social irreversibility. An
example of almost purely social irreversibility is the
fabulous pirate practice of burying a treasure in a remote or
obscure location and then killing those who know of it.
Mechanically, the burial is very reversible; retrieving the
treasure is simple once its location is known. However, it is
socially irreversible, since accidental discovery is highly
unlikely and a deliberate, but unguided, search has a very low
probability of success.
Multiplicity is defined in two ways. Site multiplicity is
intended to provide security against site-specific failures,
providing some degree of damage limitation. Diversity of
option is intended to provide security against generic
failures. Although not much actual damage limitation could be
provided by only having a few options available, it would be
valuable to have alternates in operation if one of the methods
should suffer from a generic problem that rendered it unsuit-
able.
Taken together, I suggested that these criteria could be used
to screen waste management options according to the degree of
security against natural and social intervention to provide
for a minimum acceptance level for irreversibility. In that
paper (Ref. 8) it was also suggested that complete irreversi-
bility may not be desirable, in that it precludes options for
the future (Ref. 9). Future generations may desire to recover
our wastes as a resource, or to remove and reemplace them in a
more secure manner. If the wastes were not emplaced more
irreversibly than present ores, a technically and scientific-
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ally advanced future could recover them. Yet, in the absence
of adequate technical sophistication and information, they
would remain safely out of reach.
It must be emphasized that, in the author's view, there is no
simple dichotomy between storage and disposal, but rather a
continuum stretching from retrievable surface storage to
irrecoverable disposal. With all humility as to my ability to
predict the future, I believe that engineered storage can be
provided over the short and intermediate term in such a way
that the wastes are recoverable at costs that are not
prohibitive, yet, should institutions fail, the site will
revert itself to a secure and acceptable method of ultimate
disposal.
If, for instance, mining were required, recovery from the site
would be more costly than it would for purely retrievable
methods. However, we can and do mine uranium ores at concen-
trations of only 0.2 percent, and are prepared to mine even
poorer grades. Information as to site location can be
provided in such a way that it will not be accessible to those
incapable of understanding the risks involved. One suggestion
is to tag the sites or containers with a low-level radioactive
source. Such provisions may be difficult; however, they are
not impossible.
In view of the broad scope of this Workshop, I believe a word
needs to be said about the uniqueness of the mill tailings
problem. Other types of radioactive waste can be dealt with
in a manner similar to the high-level wastes, at least
generically. Criteria such as irreversibility are generally
applicable, and only need to be modified according to the
lifetime and toxicity of the waste in question.
Mill tailings, however, cannot be compacted. There appears to
be little possibility of their emplacement in repositories.
The primary hazardous chain is the decay series of thorium-230,
which contains as its first decay product radium-226, an alpha-
emitter that is soluble in water and readily taken up through
the intestine. Since the half-life of thorium-230 is about
76,000 years, this problem is even longer term than that of
the plutonium series in high-level wastes. Radon-222, the
daughter of radium-226 is a radioactive noble gas with a
3.8-day half-life that diffuses out through the pile and is
spread on the wind. As it decays, it may deposit its alpha-
emitting daughters, particularly polonium-210, on plant life
and buildings (Ref. 10).
How are these tailings to be included within the framework of
criteria for disposal of other wastes? Shall they be dumped
in the oceans or dispersed? This is highly irreversible and
very multiple but guarantees a maximum dose commitment. If
they are to be buried or covered over with asphalt or dirt,
what provision can be made against the type of anthropogenic
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actions that led to houses being built on foundations made
with tailings in Grand Junction, Colorado? How are we to
balance the distributed but certain dose commitment of disper-
sal, against the possible dose limitation of burial with the
attendant risk of concentrated exposure? It is not clear what
the basis for judging methods of mill tailings management
should be, or what the implications are of giving them criteria
that differ from those accorded other wastes. It is clear,
however, that the criteria will have to differ. unfortunately
this points out the limitation on our intention to apply ethi-
cal standards uniformly.
To summarize, the author can offer no suggestion as to how to
convert this melange of criteria into a simple and uniform
set, let alone convert them into standards. Several of the
criteria appear to be generally usable—the absence of water,
seismic stability, irreversibility, and others that have not
been discussed in this paper. Any disposal method chosen will
undoubtedly have other criteria specific to the type of waste
or the operational conditions.
The author cannot envision boiling these criteria down to a
set of simple standards for release rate and dose commitment
without trivializing both the criteria and the ethical basis
for their establishment. Using criteria that evaluate perfor-
mance and design of specific sites is not so simple as
establishing a set of numerical standards. However, in the
face of uncertainty, simplicity may be more a vice than a
virtue.
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REFERENCES
1. U.S. Energy Research and Development Administration
(ERDA). 1976. Alternatives for Managing Wastes from
Reactors and Post-Fission Operations in the LWR Fuel
Cycle. ERDA-76-43, NTIS. Springfield, Virginia.
2. Hoos, I. R. 1972. Systems Analysis in Public Policy.
University of California Press. Berkeley, California.
3. Jonas, H. 1973. Technology and responsibility: reflections
on the new task of ethics. Social Research 40:31.
4. Georgescu-Roegen, N. 1975. Energy and economic
myths. Southern Economic Journal 41:347.
5. Arrow, K. 1973. Social responsibility and economic
efficiency. Public Policy 21:303.
6. Arendt, H. 1958. The Human Condition. University
of Chicago Press. Chicago, Illinois.
7. Weinberg, A. 1972. Social institutions and nuclear
energy. Science 177:27.
8. Rochlin, G.I. 1977. Nuclear waste disposal: two
social criteria. Science 195:23.
9. Golding, M. P. and D. Callahan. 1972. What is Our
Obligation to Future Generations? Working Paper
Series, Number 2. Hastings Center Institute of Society,
Ethics, and the Life Sciences. Hastings-on-Hudson,
New York.
10. Swift, J. J., J. M. Hardin, and H. W- Galley. 1976.
Potential Radiological Impact of Airborne Releases
and Direct Gamma Radiation to Individuals Living Near
Inactive Uranium Mill Tailings Piles. U.S. EPA (January).
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THE LEGACY QUESTION
H. W. Healy
Los Alamos Scientific Laboratory
of the University of California
Los Alamos, New Mexico 87544
The management of nuclear wastes is a major issue in the
possible use of nuclear energy to aid in alleviating our
present energy situation. The transuranics, in particular,
are a focus of attention because of their long half-lives and
the concomitant need to control them for thousands of years—
a period unthinkable to most of us. There appears to be an
implicit assumption among many, that such disposal means as-
sured containment until the isotopes have decayed. This is a
task that the engineer designing the disposal site will find
extremely difficult to fulfill and may require the expenditure
of resources that could be used to fill other needs. In this
paper, I will recommend that a priority need in the management
of very long-lived wastes is a criterion that will set forth
the proper concern for both future risk and present needs. With
such a criterion, the engineer can assess the suitability of
various proposals and provide a rational design. Without it,
he is left to his own judgment and the inevitable second-guessing
and tug-of-war between differing views that have plagued, not
only nuclear energy, but other industries in this country.
The broad objectives for nuclear waste disposal, as for other
potentially hazardous wastes, are to place the unwanted
materials in a position where they are safe, but by a method
that does not impose an excessive burden on the resources that
are so imperative for other needs. Once again we are faced
with the problem of defining "safe"; however, this time in the
context of the long time periods for which many of the
radioactive species will survive. I would note in passing
that this problem is not unique to radioactive materials but
must also be considered for the stable chemical wastes,
particularly the toxic metals that cannot be degraded to less
toxic or nontoxic forms. Thus, the considerations from this
workshop and the resulting criteria from the EPA should be
considered as applicable, in a large degree, to these other
materials. It is my feeling that we should keep this broader
potential application in mind as we discuss these issues, and
I would hope that any criteria would be derived in cooperation
with the EPA people working on other hazardous wastes.
The legacy question in my title refers to the definition of
appropriate actions in this generation to provide a world that
will allow future generations to use the earth without exces-
sive limitations cause by our use and disposal of potentially
hazardous materials. While this question is, on the surface,
deceptively simple, there are many ramifications that must be
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explored. For example, if our concern is with mankind, our
first and foremost obligation is to survive so that there will
be future generations. Not only must we survive, many of us
feel that we should preserve and extend many of the amenities
and present technologies that extend both our span of life and
quality of life. Thus, at the very beginning there is con-
flict between preserving the environment in its present form
and providing the wherewithal to survive and extend that which
we want to leave. The present cold winter heightens our
appreciation for the need to take action on the energy
supplies that we all depend on for survival.
We do have a starting point for our deliberations in the Dec-
laration of National Environmental Policy from the National
Environmental Policy Act of 1969. This states that it is the
policy of both governmental and private organizations "to use
all practicable means and measures...in a manner calculated to
foster and promote the general welfare, to create and maintain
conditions under which man and nature can exist in productive
harmony, and fulfill the social, economic, and other require-
ments of present and future generations of Americans." The
act then specifies that all practicable means consistent with
other considerations of national policy shall be used so that
the Nation may "fulfill the responsibilities of each genera-
tion as trustee of the environment for succeeding generations."
These statements outline the general policy in a manner that
should be acceptable to most people. However, as is common
with many policy statements, it is very general and it is the
job of this workshop to provide input that will allow more
specific criteria to be developed that will meet the general
policy in regard to trusteeship of the future in relation to
the present needs and policies. The remainder of this paper
discusses a few of the points that I feel should be considered
in establishing a criterion.
There does seem to be agreement among those studying the
problem that containment for the next several hundred years or
even longer can be obtained by several of the methods now
being considered. However, the more distant future is a
different question. We know from past history that changes in
the climate have led to ice ages, and the courses of rivers
and positions of lakes have changed. Thus, we can expect
future changes that will have impact not only on the disposal
site, but will bring about drastic changes in population dis-
tributions and, perhaps, the character of the civilization. A
requirement to provide facilities that will have the continued
assurance against risk in the time-period that we will require
for the next several hundred years is not only difficult, but
in the long run, may be counterproductive because of our ex-
penditure of present resources to protect against unknown
conditions in the future.
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To further illustrate the problems of setting policy for the
future, let me introduce several scenarios as to the future of
civilization. These are very general and lacking in detail
but they will illustrate the problem.
1. In the most optimistic view of the majority of the
public we will continue to develop both technology
and social knowledge so that the future generations
will have access to living conditions and controls
far beyond anything we could imagine. For example,
if this scenario is fulfilled, then the probability
of effective treatments for the biggest risk from
radiation—cancer—appears to me to be a realizable
achievement within the next hundred years or so.
2. A scenario that appears to guide many of us in our
decisions is that the status quo will be maintained;
that is, that our social institutions and technology
will remain as they are now with only minor
perturbations. In my opinion, this is a very
unlikely course since most static systems of any
complexity eventually regress.
3. The current civilization regresses to a point where
modern medicine, public health, transportation, and
agriculture are no longer available. The degree of
regression depends upon the cause, but to the ex-
treme, could be to a primitive, village society. A
number of causes could be expounded but it is noted
here than one could well be a shortage of energy to
grow food and to tie the governmental institutions
together. Of course, an alternate extreme would be
the complete elimination of the human species with
another species starting the long road to
civilization.
4. In the final scenario, the human race is destroyed by
a natural or man-made cataclysm and no new species
replaces him.
We do not know which of these the future will bring but it is
important that we attempt to minimize the probability of the
last two by making wise use of all of our resources, including
nuclear energy, and not setting such excessively stringent
criteria that we forego the use of any of our resources.
In conclusion, I would like to urge a criterion as to accepta-
ble risk in the future, including the distant future, suffi-
ciently well defined that it can be used by the engineers in
design of facilities. I recognize the difficulty in obtaining
a consensus among the many viewpoints in the country, but
believe that a wise resolution of this question will be bene-
ficial in conserving our vitally needed rsources of coal and
hydrocarbons so necessary in the near future for medicinals,
mobile fuels, and fertilizers.
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LONG-TERM IMPLICATIONS OF RADIOACTIVE
WASTE MANAGEMENT:
SUMMARY AND CONCLUSIONS OF WORKING GROUP 3
LONG-TERM IMPLICATIONS OF RADIOACTIVE WASTES
The topic of Working Group 3 was "Long-Term Implications of
Radioactive Waste Management." Thirty people participated in
the discussions. The affiliation in the group included
government employees, industry representatives and consul-
tants, public interest groups and citizens representing
themselves. This variety of affiliations enabled the group to
consider a wide spectrum of viewpoints in their deliberations.
The following consensus opinions were developed by the group
and are presented to summarize our principal conclusions.
1. We should get on with the process of developing criteria
for radioactive waste disposal.
It was the feeling of the group that the criteria are
needed now so that those groups involved in the design of
facilities and their regulation can proceed with their
work without delay. Further, it was felt that current
technology is now adequate for this effort to go forward.
2. Waste disposal risks and benefits, both calculated and
perceived, should be factors in the development of crite-
ria.
"Perceived" risks and benefits were defined as those which
the public, by fact of their own knowledge, experience, or
beliefs, view as real. People may believe in risks which
do not exist, but they may also recognize risks which
regulators have overlooked. In addition, the calculation
of risk is inexact and thus it should be tempered by
judgment.
3. Criteria should take into account impacts on the
international community.
It was felt by the group that the need for such a
consideration in the development of criteria was fairly
obvious and little discussion was necessary to reach a
consensus on this opinion.
4. The public, and state and local governments should be
involved in the decision-making process.
Several examples where a lack of public involvement
created problems of public acceptance were discussed in
the group. Included in these examples were the Windscale
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accident, the proposed Lyons, Kansas, depository, and the
proposed Michigan core drilling. All were characterized
by oversights on the part of scientists and/or regulators
which created problems of public acceptance. Accordingly,
the decision-making process should be open in fact as well
as in appearance.
5. The criteria should take into account the fact that radio-
active waste disposal solutions should be independent of
the stability of societal institutions.
It was assumed that institutional controls would remain in
effect until the repository was sealed. At this point,
reliance should no longer be placed on institutions. Con-
cerns of the groups ranged from the possibility of acci-
dental or purposeful intrusion into a repository to the
failure of institutions to carry out necessary surveillance.
6. It seems reasonable to assume that there exist suitable
geological formations which will remain stable for the
period of concern in the disposal of radioactive wastes.
Various viewpoints were considered in the development of
the consensus. These viewpoints included:
a. That we could probably identify suitable formations,
although no consensus of a suitable depth or a final
waste form was reached.
b. That the problem of high-level wastes was primarily a
1,000-year problem and thereafter the average concen-
tration of the transuranics is similar to pitchblende
although there is still the possibility of "hot spots"
or small areas of high activity.
c. That the term "geological stability" implies isolation
from the biosphere for the period of concern.
7. Risks to future generations must be included in the devel-
opment of criteria.
The working group felt that the following order represents
a ranking of the priorities that should be used in
establishing criteria: (1) minimizing long-term risks,
(2) minimizing short-term risks, and (3) minimizing costs.
Viewpoints expressed in the development of this consensus
include:
a. In any reasonable management scheme risks to present
and future generations are so small, relatively and
absolutely, as to be negligible.
b. Zero release and zero dose were discussed. It was
felt that this is a desirable goal. However, it was
also felt that the word "zero" should not appear in a
criterion.
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c. It is possible to trade-off future versus present
risks. Plutonium recycling and transmutation were
cited as examples of such a possible trade-off.
d. Some members of the group felt cost was less important
than technical considerations of the integrity of the
repository.
e. Some risks have to be borne to accrue benefits.
8. If feasible, options should be left open for future
generations to improve upon our program of waste manage-
ment. However, in doing this, safety should not be
compromised.
Viewpoints expressed in the group on this consensus
incude:
a. This is a moot point; that is, if we make waste in any
way retrievable, we compromise safety.
b. Options for change will be available until the reposi-
tory is closed.
c. Costs are important and cannot be ignored.
d. Repositories should not be located in areas where
minerals or resources are likely to be found.
9. Both the form of the radioactive waste and method of dis-
posal need to be considered in the establishment of radio-
active waste management criteria. But the criteria should
certainly not be keyed to any single waste form or dispos-
al method.
Several viewpoints were expressed in the development of
this consensus:
a. Wastes should be categorized on the basis of toxicity
and concentration. Other criteria such as solubility,
depth of burial, requirements for geological stabili-
ty, and possibly others should be applied to each
category of waste.
b. It will be difficult to meaningfully address all waste
forms with a single set of generic criteria.
c. Criteria should not be limited by current technology
and should specify performance goals rather than dis-
posal methods.
10. Other opinions presented but not discussed fully
included:
a. Any criteria which are developed need to be reviewed
periodically in the light of developing technologies.
b. Future generations should be informed to the extent
possible of the risks passed on by present
generations.
c. Toxic wastes should be examined in the same context
as radioactive wastes.
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d. Consideration of the risks of management of any
combination of type of waste and disposal technique
should also include the transportation risks.
e. It was also noted that wastes arising out of
decommissioning nuclear facilities are considered
another waste form.
Our discussions focused on geological disposal of high-level
wastes. We recommend that in the next Workshop more
consideration be given to the safe disposal of other radioac-
tive wastes.
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RESPONSE OF WORKSHOP PARTICIPANTS TO SUMMARY AND
CONCLUSIONS OF WORKING GROUP 3
Second Plenary Workshop Session
JAMES E. MARTIN (EnvJ.ronniental_Protection_AgencYi_Washj.ngtoni
S^C-O : The moderator for Group 3 is .Susan Lepow from the En-
vironmental Protection Agency in Washington, D.C.
SUSAN LEPOW: I would first list to introduce the panel for
Working Group 3: Chauncey Kepford, from the Environmental
Coalition on Nuclear Power, State College, Pennsylvania; Evan
Vineberg, from the Environmental Protection Agency in Washing-
ton, B.C.; Robert Schainker , from Systems Control Inc., Palo
Alto, California; Robert Shoup, from Union Carbide, Oak Ridge,
Tennessee; Jerry Swift, from the Environmental Protection
Agency, Washington, D.C.; and G. Hoyt Whipple, from the Uni-
versity of Michigan in Ann Arbor, Michigan. The first
question is from William Lochstet, "Should or will future
generations be expected or required to monitor for leaks?"
EVAN VINEBERG: Considering the primary issue, high-level
wastes, I think it was the consensus of the group that once
the wastes were put in the ground they should stay there and
be kept from the biosphere. I think that was the goal we were
all working for.
WILLIAM A. LOCHSTET (Envi.£onmental_Coalition__on_Nuclear
iZ^L^ELL-L^DD^YlY^H!3.) : The question is, you expect it to stay
there but do you keep checking to make sure that it does? I
mean that is what you would do when you go looking, and you
hope you do not find anything.
VINEBERG: I think the answer is no, because we are not
anticipating societies to be able to look after these wastes
indefinitely and I do not think we can therefore expect them
to be able to monitor them. That is why we want them to stay
there once they are put there.
JERRY SWIFT: I think this point itself was not directly
addressed but our point of view was that the design should
be such that no release would be expected and that there
should be no demand for institutional surveillance of the
repositories. Naturally we would expect some surveillance
as long as the Nuclear Regulatory Commission continues
to regulate.
LEPOW: Next comment from Stanley Logan, University of New
Mexico. To aid in public understanding of the proceedings, it
is recommended that a glossary of terms be included. A glos-
sary was included in the "Issues & Objectives Statement."
Missing terms such as "fault tree," "dose," "rem," etc. should
3-47
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be added. I suggest reviewing the texts for other terms that
should be included for clarity.
Don Williams, page 3-44, question 7. Let the record state that
there is disagreement with the ranking of priorities
indicated, namely, long-term, short-term, cost savings. I
would propose short-term, cost, long-term. Would you like to
add anything to that comment?
DON WILLIAMS (Battelle, Pacific Northwest Laboratories,
Richland, Washington): I guess I will elaborate a little bit.
My concern is that I do not agree with the Apriority that
somebody else has made. My personal opinion is that self-
preservation is the first law of nature and I would like to
see that extended in the criteria.
VINEBERG: One immediate comment that comes to my mind is that
it is very difficult to quantify in dollar terms what one
means by self-preservation.
PANELIST: For the record I would like to indicate that the
working group on this whole panel did discuss the factors that
you just mentioned, the survival issues being primary, but the
general concensus of the entire panel was the order that we
indicated. I just wanted to make sure that after due discus-
sion of the point you considered, that we did rank them in the
order presented.
SWIFT: Also a view was presented that survival of the species
is sometimes given more consideration than self-preservation.
PANELIST: I participated in the deliberations of Group 3 and
I think some of us felt that it does not really make any
difference which priority you put first because if you put
priority on either one of them, you automatically are taking
care of the other. By giving long-term priority you certainly
have protected yourself.
LEPOW: I think that is a fair representation of the Group.
The next question is from Ed Toombs. What is "irretrievable"?
A. E. TOOMBS (Stone_& _Webster _Engineer;i.ng_Corp_J_i_Bethesdax
Maryland): That is in reference to the statement on page
3-4, item 8a. There you say that this is a moot point,
that if we make waste in any way retrievable, we compromise
safety. It appears that when we are talking of retrievability
we are going toward the absolute again. I am not sure that we
can make anything absolutely irretrievable by keeping it
intact and burying it in a geological formation. Would anyone
care to comment?
PANELIST: I think basically we agree with that. You never
obtain absolute irretrievability but you want to go to a point
where you maximize your isolation, which is contradictory to
3-48
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having some type of retrievability. In other words we want to
make it as difficult as possible for some future generation to
have any reason to go back in there by selecting a site that
is unattractive as far as resources and make the waste form as
unattractive as possible.
LEPOW: And the last question is from William Remini (Energy
Research & Development Administration, Washington, B.C.) Was
there any discussion as to the magnitude of the possible costs
in carrying out your recommendation. And if so, who should
carry the burden of supplying these funds?
SWIFT: I think the opinion was expressed that the cost of the
proposed technologies all appeared to be within reason.
G. HOYT WHIPPLE: I concur with the statement that has
just been made and the answer to who pays, which was part
of your question—I am presenting no consensus when I give
this answer, it is my own opinion—all I can think of is
to paraphrase Mr. Truman's comment and reverse it—the
buck starts here. Why quibble? Whether it is industry,
government, or the ratepayer, we pay it. I do not see
that anything is gained by discussing that; perhaps you
meant something more than I see in your question.
LEPOW: If there are no further comments, we are finished.
Thank you.
3-49
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WORKING GROUP 3 EXECUTIVE COMMITTEE
LONG-TERM IMPLICATIONS OF RADIOACTIVE WASTES
NAME AFFILIATION
Chauncey Kepford1" Environmental Coalition on Nuclear Power
Susan Lepow* Environmental Protection Agency
Thomas W. Philbin Ecological Analysts, Inc.
Evan Vinebergt Environmental Protection Agency
Robert B. Schainker1" Systems Control, Inc.
Robert Shoup"1" Union Carbide Corp.
Jerry Swiftt Environmental Protection Agency
G. Hoyt Whipple"1" University of Michigan School
of Public Health
* Moderator.
t Panelists for the Plenary Workshop Session, 5 February,
1977.
3-51
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PREPARED STATEMENTS FROM THE PUBLIC
STATEMENT BY BRUCE ROSENTHAL*
Radioactive wastes from uranium mining and the atomic reactor
fuel cycle are becoming an increasingly large blemish for the
pro-atomic establishment. Senator John Pastore, chairman of
the Joint Congressional Committee on Atomic Energy and a
staunch nuclear advocate, says, "The most important problem
facing nuclear power is waste management."
Not only have the government, the utilities, and the atomic
industry spent vast sums of money and been unable to devise a
permanent means of storage for these wastes, but many of the
storage sites are also leaking like sieves, emitting
radioactive particles. And the U.S. Court of Appeals has
recently chastised the Nuclear Regulatory Commission (NRC) for
failure to adequately consider the problems of wastes in
licensing nuclear plants.
CRITICAL MASS has highlighted instances of radioactive
emissions from the remains (tailings) at uranium mining and
waste storage areas (see CM Oct. 1975, p. 3; Feb. 1976, p. 1;
May 1976 p. 30}, but similar occurrences have become more
prevalent in recent months. For example:
—In June 1976 workers wearing protective jumpsuits and
using respirators began a yearlong task of removing 400 cubic
yards of radioactive dirt contaminated by plutonium at the
Rocky Flats (Colo.) nuclear weapons plant. The contamination
was caused by corrosion in 55-gallon metal drums used in the
storage field. The yearlong effort will be necessary to
clear an area the size of an average living room. The dirt
will now be shipped to Idaho for storage in another form.
—A park in Chicago was closed in July 1976 as a result of
apparent dumping of radioactive materials there in the 1930s
and 1940s by the now defunct Light and Chemical Co. The
100-acre Reed-Kempler Park has been closed for further
testing. The NRC discovered the abnormally high radiation
levels as the result of an anonymous telephone call to a
newspaper reporter.
—Traces of radioactive substances were recently
discovered in the ocean 120 miles east of Ocean City,
Maryland, a prime tourist and vacation area. Traces of
plutonium were found 40 miles from San Francisco near the
Farallon Islands in another underwater waste disposal site.
The area is inhabited by sablefish, which are sold
commercially by fishermen.
—Leaks of radioactive wastes at the Turkey Point atomic
reactor near Miami, Fla. exemplify many of the problems
surrounding waste storage. Although leaks were known to exist
*~Taken~fFom: Rosenthal, Bruce. 1976. Radioactive waste
disposal problems mount. Critical Mass 2:5.
4-1
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in the storage pits in 1972 before the reactor began
operations, Florida Power and Light considered the problem
"minor" and made no repairs. Today, water that surrounds the
radioactive wastes has itself become contaminated and is
leaking from the storage area at the rate of 90 gallons per
hour .
Attempts to repair the leaks have not been successful thus
far, partly due to the high concentration of radioactivity in
the area. And since permanent storage sites and waste
reprocessing facilities have not been developed in the United
States, even though 58 power plants are operating, the
radioactive wastes cannot be emptied from the storage tanks so
that the leaks can be repaired.
STORAGE AT SEA
In the early days of this country's atomic program, offshore
sites were used to dispose of radioactive wastes. Beginning
in 1946, more than 28,000 55-gallon drums were dumped into the
Atlantic and 47,000 into the Pacific Ocean as a result of the
government's atomic weapons and research programs.
The Environmental Protection Agency (EPA) is currently
searching for these drums in an attempt to develop "effective
controls on any ocean dumping of low-level radioactive wastes,
and in order to assess the effectiveness of past packaging
techniques," according to Robert S. Dyer of the EPA's
radiation office. One of the problems facing the EPA effort
is that it is not certain where the drums were dumped.
Although the dump sites are designated in the records,
apparently* a minimal effort was made to use the specified
sites. The EPA investigation has thus far discovered the
radioactive releases near Ocean City, Md. and the Farallon
Islands in California.
STORAGE ON LAND
Attempts to find suitable land storage of radioactive
substances have taken several forms. Some of the radioactive
remains from uranium mining - uranium tailings - have been
stored at 21 sites in the west. In other areas, the tailings
have been neglected by officials and used by contractors as
land fill or have been washed away by erosion or rain water.
The EPA and the NRC are presently investigating the extent of
the contamination and the possible solutions from these
careless activities (see accompanying list).
Wastes from the reactor fuel cycle are often stored in pools
of water on site due to the lack of sufficient permanent
storage facilities and reprocessing systems.
Some temporary storage facilities have been constructed for
waste disposal. Some of these 19 sites are for high-level
4-2
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wastes and some are for low-level wastes (see accompanying
list) .
Another aspect of the controversy revolves around the question
of how to prevent future generations perhaps thousands of
years from now from accidentally stumbling across
underground atomic waste vaults. Carl Kuhlman, an Energy
Research and Development Administration nuclear waste
official, suggests constructing monuments over waste sites to
warn unsuspecting persons. Professor George Kistiakowsky,
former science advisor to President Eisenhower, counters that
over a period of many thousands of years, "the English
language probably would disappear" and an ice age "would smash
all monuments."
COURT DECISION
The NRC has contended that when approving new atomic reactors,
the issue of waste disposal need not be considered. A U.S.
Court of Appeals court in Washington, D.C. on July 21 ordered
the NRC to consider waste disposal in future decisions.
The court ruling was in response to a Natural Resources
Defense Council suit against the NRC in connection with the
Vermont Yankee atomic reactor. (A similar ruling in a
separate case ordered the NRC to consider energy conservation
aspects when approving reactors.)
In the waste disposal case, U.S. Circuit Chief Judge David L.
Bazelon said: "Not only were the generalities relied on in
this case not subject to rigorous probing - in any form - but
when apparently substantial criticisms were brought to the
commission's attention, it simply ignored them, or brushed
them aside without answer."
CONGRESSIONAL OVERVIEW
Members of Congress are becoming skeptical of the waste
disposal situation. Although there have been repeated
assurances for decades that government and industry could
resolve the waste disposal dilemma, a report released on June
30, 1976 by the Subcommittee on Conservation, Energy and
^Natural Resources Subcommittee of the House Committee on
Government Operations points out that "progress toward
resolution of this problem has been sketchy."
The report, entitled "Low-Level Nuclear Waste Disposal" is
based on hearings and an investigation conducted by
Subcommittee chairman Rep. Leo J. Ryan (D-CA). In view of the
fact that "some of these (storage) sites are now releasing
radioactivity to the environment, in some instances only 10
years following their selection as facilities designed for the
containment of radioactivity for hundreds of years," the
4-3
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subcommittee contends that the problem should "be considered
in all its gravity."
As the Federal government and the atomic industry continue
their search for a safe, reliable disposal method for
radioactive wastes, the Subcommittee reports that Federal
officials estimate the volume of wastes which will need to be
stored by the year 2000 will cover a four-lane highway, one
foot deep, coast to coast. Much of this waste would be low
level and therefore less concentrated than high-level wastes
on a unit-by-unit basis, but low-level wastes are just as
dangerous as high-level wastes. Also, low-level wastes cannot
be reprocessed they must be stored.
4-4
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Radioactive Storage Sites: Where Are They?
1. Low-level wastes stored at 17.
Hanford, Wash, (stored on-
site at operating atomic 18,
reactors)
2. Inactive uranium mill site 19,
at Lakeview, Oreg.
3. Low-level waste at Lawrence- 20,
Livermore Lab, Livermore,
Calif. 21.
4. Inactive uranium mill site
at Lowman, Idaho 22.
5/6.High and low-level wastes
stored at Idaho National 23.
Engineering
7. Low-level wastes stored at
the Nevada Test Site
8. Inactive uranium mill site 24.
at Salt Lake City, Utah
9. Inactive uranium mill site 25.
at Green River, Utah
10. Inactive uranium mill site 26.
at Mexican Hat, Utah
11. Inactive uranium mill site 27,
at Monument Valley, Ariz.
12. Inactive uranium mill site 28.
at Tuba City, Ariz.
13. Inactive uranium mill site at 29.
Converse County, Spook, Wyo.
14. Inactive uranium mill site
at Maybell, Colo.
15. Two inactive uranium mill 30.
sites at Rifle, Colo.
16. Inactive uranium mill
site at Grand Junction,
Colo.
Inactive uranium mill site 31.
at Naturita, Colo.
Inactive uranium mill site
at Gunnison, Colo.
Inactive uranium mill site 32.
at Durango, Colo.
Two inactive uranium mill
sites at Slick Rock, Colo. 33,
Inactive uranium mill site
at Shiprock, N.Mex.
Inactive uranium mill site 34.
at Ambrosia Lake, N.Mex.
Low-level waste storage at 35.
Los Alamos Scientific
Laboratory, Los Alamos,
N.Mex.
Low-level waste storage at
Sandia, N.Mex.
Low-level Waste Storage at 36.
PANTEX, Amarillo, Tex.
Inactive uranium mill site
at Ray Point, Tex. 37.
Inactive uranium mill site
at Falls City, Tex.
Low level waste storage at 38.
Paducah, Ky.
Low-level waste storage at
Oak Ridge National 39.
Laboratory, Oak Ridge,
Tenn.
Low-level waste storage at 40.
Oak Ridge Gaseous Diffusion
Plant, Oak Ridge, Tenn.
Low-level waste storage at
Y-12, uranium enrichment
building near Oak Ridge,
Tenn.
High and low-level waste
storage at Savannah River
Plant, Savannah River, Ga.
Low-level waste storage at
Fernald, Ohio (Feed
Materials Plant)
Low-leve.". ^waste storage at
Portsmouth', Ohio
High-level7 ERDA waste
storage £:t Richland, Wash.
Low-level commercial waste
storage by Nuclear
Engineering Co. at Richland,
Wash.
Low-level solid waste
storage at Beatty , Nev.' by
Nuclear Engineering Co.
Low-level solid waste
storage at Sheffield, 111.
by Nuclear Engineering Co.
Low-level solid waste
storage at Morehead, Ky. by
Nuclear Engineering Co.
Low-level solid waste
storage at West Valley, N.Y.
by Nuclear Fuel Services
Low-level solid waste
storage at Barnwell, S.C.
by Chem-Nuclear Services,
Inc.
-------
STATEMENT BY FREDERICK FORSCHER*
Nuclear Waste Management is a complex social-economic-technical
subject. There seems to be general agreement that a public
policy should ensure exclusion of radioactive waste from
the biosphere, effectively, for long times and below acceptable
risks. There is, however, no consensus on what constitutes
effective, long times and levels of acceptable risks.
To reach consensus on these issues requires structured
and informed public participation, such as is employed
in the formulation of criteria and standards by the voluntary
standards movement, utilizing ANSI's procedures. Political
reality requires the active participation of the public
in the decision-making process. The trend in this direction
has become quite clear during the October 1976 meeting
in Chicago, on Nuclear Waste Management, and is being carried
forward by EPA's workshop on Radioactive Waste Management
in Reston (February 1977) .
I am proposing to address primarily the process of arriving
at criteria and standards, so that the substance of the
resulting document represents the best interdisciplinary
consensus. I am proposing to employ the time-tested method
of developing consensus type technical standards. This
process cannot be done "in-house" at the NRC, nor at any
other governmental agency. No single organization, private
or public, industrial or academic, has the know-it-all
competence to develop criteria and standards that require
complex trade-offs (judgments) in social-economic-technical
matters.
A National Academy of Science panel found recently, that
in order to ensure effective waste management, the Federal
government must exert strong leadership in assigning authority
for setting and implementing standards, and ensuring coordination
between Federal, state, and local agencies and private industry.
The process of developing a consensus type technical document
can be divided into three consecutive steps:
1. Develop the scope and, if necessary, definitions
and time frames.
2. Select and recruit a representative (interdisciplinary)
writing group of about 7 to 13 specialists.
3. Schedule and chair the necessary committee meetings.
Criteria and standards will play an increasingly important
role in the development of a regulatory framework for nuclear
waste management. The ANSI process allows judgmental and
interdisciplinary input on a timely basis.
* Energy management consultant,
4-7
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STATEMENT OF PACIFIC LEGAL FOUNDATION*
Pacific Legal Foundation (PLF) submits the following statement
concerning the proposal by the United States Environmental
Protection Agency (EPA) to develop environmental radiation
protection criteria and standards for radioactive waste (41
Fed. Reg. 53363 [December 6, 1976], 42 Fed. Reg. 2331 [January
II, 1977]). Pacific Legal Foundation, a nonprofit, public in-
terest legal corporation, seeks to provide a balance of inter-
ests in administrative and judicial proceedings involving en-
vironmental controls, land use, national defense, and
government regulations.
In this matter of developing environmental radiation protec-
tion standards and criteria for radioactive waste, PLF has
certain concerns. First, no standards or criteria should be
promulgated that would severely restrict the development of
U.S. nuclear power and its beneficial applications. Second,
criteria and standards adopted should be promulgated only
after a careful examination of the risks and benefits to soci-
ety and the impact such a proposed program would have on these
factors. Third, PLF believes that the activity proposed by
EPA is not within that Agency's statutory authority. It is a
duplication of similar programs being developed by the Energy
Research and Development Administration (ERDA) and the Nuclear
Regulatory Commission (NRC).
Finally, for these workshops to be truly effective they must
be conducted in an objective atmosphere without the usual
rampant emotionalism that has all too frequently surrounded
discussions about nuclear power. In the words of a recent
columnist, "Hysteria about the very notion of domestic devel-
opment of nuclear power has blocked out all rational discus-
sion of the need for and the feasibility of safeguards.
Agitation has supplanted engineering."t
Any standards developed to regulate the disposal of radioac-
tive wastes must be realistic and not unduly restrictive upon
the development of nuclear power in the United States. The
importance of this statement is underscored by the present
dependence of our economy on petroleum, and more specifically
its growing dependence on foreign sources of petroleum.
* Ronald A. Zumbrun, Raymond M. Momboisse, and Robert K. Best.
Pacific Legal Foundation, 455 Capitol Mall, Suite 465,
Sacramento, California 95814 (Telephone: (916) 444-0154).
Albert Ferri, Jr., and Lawrence P. Jones. Pacific Legal
Foundation, 1990 M Street, N.W., Suite 550, Washington, D.C,
20036 (Telephone: (202) 466-2686) .
t Janeway. "On Nuclear Front, Russia is Realistic," Washing-
ton Star, Jan. 23, 1977, at E-l, E-12.
4-9
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The development of alternate energy sources to the point of
large-scale commercial applications will take several decades,
as a result of which this nation will continue to rely upon
both its own fossil fuel resources and uranium fuel.* In this
context inflexible and unrealistic regulations would render
the use of nuclear power, one of the safer forms of energy,
either impossible or economically infeasible and discourage
industry from further development of this source of energy.
Moreover, regulations that would lead to delays in the uses of
nuclear power will cost society substantially.1"
The development of criteria and standards for dealing with
radioactive wastes will obviously have a substantial impact on
the utilization of nuclear power and its development. A
Federal agency entrusted with such a task has an affirmative
duty to analyze the broad public interest affected by the
proposed regulations. This analysis cannot be conducted in a
vacuum; at a minimum it requires a careful review of the risks
and benefits, in this instance, of nuclear power and nuclear
wastes.
A critical part of this process is the recognition that no
source of energy is risk free. To begin from the position
that there must be zero risks, particularly in the area of
nuclear power, will frustrate at the outset any meaningful
dialogue about the development of nuclear power and important
issues such as radiation protection criteria. More
significantly, the long term result of this kind of
emotionalism will be substantial harm to the public good.
~Forbes, et al., The_Nuclear_Debate^ A_Cal]._to_Reason_2,
Energy Research Group, Inc., Framingham, Mass., 1976, at 8-
9.
For example, one month's delay of a single 1,000 MWe nuclear
station can lead to 38,000 equivalent person-days of illness
if the replacement electricity is generated by oil and
coal fired stations representative of current practice.
Burnett, The_Human_Cost_qf_Reg_ulatqrY_DelaYS , Westinghouse
Electric Corporation, Pittsburgh,, Pa., 1976, at 1. Environmental
costs are even more significant. In one study dealing
with the licensing of thirteen nuclear power stations,
the Nuclear Regulatory Commission estimated that a one
year delay in issuing them could result in 6 to 700 additional
deaths from utilization of coal for makeup energy. See
Impact_of_Later Reversj-ng §_5§^i.sion_to_Adogt_or_Not_to
Adogt_an^InteriLm_Rule Pe£mttinj2_Cqrist£uctiqn_qr_Ogeratiqn
°f_Nuclea£_Power Plants, Office of Nuclear Reactor Regulation,
U.S. Nuclear Regulatory Commission, October, 1976, at
9.
4-10
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In addition, assessments need to be made as to what would be
the most beneficial approaches to be taken in dealing with the
issues. These assessments must be squarely based on a broad
understanding of the public interest and not upon undisclosed
assumptions or prejudgments about the value of risks of nucle-
ar power. Nor must they reflect the bias of any particular
group or organization. Any such assumptions must be stated
fully at the outset of workshops such as these and the basis
for making such assumptions needs to be explained.
Finally, Pacific Legal Foundation believes that EPA should
carefully review its statutory authority in this area to
ensure that it is authorized to proceed and that such activ-
ities will not duplicate or be in conflict with the activities
of other Federal agencies. Reorganization Plan No. 3 of 1970
transferred to EPA authority to establish "generally applica-
ble environmental standards for the protection of the general
environment from radioactive material." Yet the Energy
Reorganization Act of 1974, 42 U.S.C. Section 5801, et seq.
provided ERDA and NRC with authority to develop waste manage-
ment programs designed to facilitate the safe disposal of
radioactive wastes. Pursuant to this, both NRC and ERDA have
been engaged in preparing detailed programs for the safe
disposal of radioactive wastes.* These programs necessarily
encompass environmental protection issues. As a result, the
present proposal may well be in conflict with the purpose of
the Energy Reorganization Act.
Furthermore, it should be noted that NRC prepares an environ-
mental impact statement (EIS) in connection with each construction
permit or operating license it issues. It has also prepared
generic EISs dealing with the reprocessing and waste manage-
ment portions of the nuclear fuel cycle for uranium-fueled
reactors. The Energy Research and Development Administration
is, moreover, presently in the process of preparing a draft
generic EIS on its commercial nuclear waste management pro-
grams to be issued in the spring of 1977. Efforts by EPA at
this time in light of the activities by NRC and ERDA would be
a duplication by one Federal agency of the activities of others,
and confuse the statutory mandates of these agencies.t
* See, e.q., Enj7^r_onm^ntal_Sur_vey_of^_the Reprocessing and
Waste Manag^ement~Portions of _the LWR Fuel^Cyc^e, NUREG-0116,
Office of Nuclear Material and^Safeguards, U.S. Nuclear Regu-
latory Commission, Washington, B.C., 1976, Appendices B and C,
t See specifically 42 U.S.C. Section 5820.
4-11
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STATEMENT OF MYRA CYPSER*
The nuclear waste isolation techniques, (a) isolation by
permanent geologic storage and (b) isolation by disposal in
geologic media, will require surveillance for as long as the
wastes are environmentally hazardous. Surveillance is
necessary because the waste repository must be protected
against any human activities which could either directly or
indirectly endanger the integrity of the containment site.
It cannot be assumed that people living hundreds or thousands
of years from now will still know about the locations of our
nuclear waste repositories or that they will have any knowl-
edge of radiation physics and radioactive waste management
techniques. It is possible that they could unknowingly cause
serious damage to the integrity of a repository. Therefore,
some system of surveillance would have to be implemented in
order to protect the waste site and to prevent future
generations from unknowingly harming their environment.
Currently, some radioactive wastes are disposed of in "burial
grounds." Portions of these buried wastes contain long-lived
plutonium and high activity fission products and consequently
need to be completely contained. It is doubtful that these
burial grounds can provide long-term containment for the
wastes because they are subject to environmental surface
phenomenon and are particularly subject to human activity.
Because of the wastes' vulnerability to natural and human
events, constant surveillance is necessary in order to ensure
their containment. This surveillance will have to be provided
for the lifetime of the wastes.
A plan for surveillance of the waste disposal or permanent
waste storage site must be developed. The development of such
a plan at this time is imperative, because it would be irre-
sponsible to proceed with waste management plans without a
provision for guarding the wastes from impacts caused by human
activity.
This surveillance system would have to last for the lifetime
of the wastes, hundreds of thousands of years, essentially a
perpetual surveillance system. Because of the length of time
involved, this surveillance system could not be dependent on
human action for its continuation. For example, it could not
be dependent on government management.
Because the human values, institutions, and technologies of
the far future cannot be predicted with great accuracy, this
* Office of Enforcement, Environmental Protection Agency
(EPA) .
4-13
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surveillance system could not be dependent on assumptions made
about them. For example, it could not be dependent on the
assumption that a particular waste site would be safe from
disturbance by future generations because they would consider
it worthless in terms of natural resources.
The implementation of a perpetual surveillance system may have
an impact on our technology and social systems. There should
be an analysis made of: (a) the monetary costs involved, (b)
the magnitude and characteristics of social and institutional
changes which would take place, and (c) the commitments of
resources and the technologies needed to maintain surveillance
for the lifetime of the wastes.
The environmental impacts of possible accidents, both natural
and anthropogenic, which could affect the integrity of a waste
repository should be investigated. Such accidents may in-
clude: sabotage, drilling or mining, attack by nuclear
weapons, earthquakes, changes in climate, and changes in
surface and sub-surface hydrology. The probability of such
accidents occurring and the risk involved should be indicated.
The calculations and assumptions used to determine probability
and risk should be included in the criteria documents and not
merely footnoted. In designing an environmental standard, EPA
should also consider the maximum possible environmental impact
which would result from the release of all the accumulated
nuclear wastes (no matter what the mechanism of release).
In designing a standard for protecting the environment from
the impact of radioactive wastes, EPA will have to consider
how the standard will be enforced. Because of the long-lived
nature of the wastes, it would be impossible to enforce a
standard during the entire period the wastes are environ-
mentally hazardous. Consequently, a standard will have
to be developed which could ensure protection of the environ-
ment by being enforced over a reasonable time period.
In developing criteria, EPA should not only consider available
information, but should also summarize all the areas of
nuclear waste management where information is incomplete or
missing, and where technologies and strategies are partially
or totally undeveloped. Such areas might incude: (a) technol-
ogy for sealing the access shafts to the respository after
waste emplacement, (b) experimental data on sorption of
specific radioactive nuclides in geologic media, (c) informa-
tion on the thermal and radiation effects of emplaced wastes
on surrounding rock formations, and (d) strategies for
perpetual surveillance of the waste. A summary would provide
an overview of the amount of uncertainty which would be inher-
ent in the evaluation of potential environmental impacts.
4-14
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STATEMENT OF W.L. BOECK
I think that the Environmental Protection Agency (EPA) should
begin to develop criteria for protection of the inanimate en-
vironment. These criteria should respond to the hypothesis
that an accumulation of atmospheric krypton-85 poses a risk of
climate change. This krypton-85 risk hypothesis has been
presented to a wide scientific audience through publication
193:195-198). In my opinion, the present base of
evidence for the krypton-85 risk hypothesis is comparable to
a finding or "probable cause" in the legal sense. Such a
finding moves the legal process from the Grand Jury proceeding
to the pretrial and trial phase. The lack of published
counterarguments to the krypton-85 hypothesis may either
indicate an implicit judgment that cause exists for further
investigation or simply lack of interest.
A regulatory response is necessary because the publication in
Science clearly states that present criteria and standards
will allow krypton-85 concentration at levels where a risk is
hypothesized. An appropriate response would be to draft cri-
teria and standards that would prevent any atmospheric effects
of krypton-85 from becoming significant compared to the
effects of natural background ionizing radiation. This would,
in effect, establish a tolerance level for additional ionizing
radiation in the atmospheric environment. Once a tentative
tolerance level were proposed, interested parties could
examine the economic or social costs to ensure that releases
of radioactivity would not exceed the tolerance level. Once
costs were estimated, there would appear three options:
(1) Assume the cost of krypton-85 control to prevent the con-
ditions necessary for any risk due to krypton-85; (2) make a
quantitative assessment of the probability of the validity of
the krypton-85 risk hypothesis and an estimate of the cost of
social, environmental, and climatic consequences; or (3) allow
krypton-85 concentrations to exceed the tolerance level and
accept the risk of climatic change. The last option is noth-
ing less than an experimental test of the krypton-85 hypothe-
sis.
Any decision EPA makes to reduce the size of atmospheric re-
leases of krypton-85 on the basis of biological criteria will
increase the time available before the tolerance level is
exceeded. A decision not to respond to the krypton-85 risk
hypothesis could ultimately be identical to a conscious choice
of the third option.
* "Department of Physics, Niagara University, Niagara, New
York.
4-15
-------
CLOSING REMARKS
William D. Rowe
Deputy Assistant Administrator for Radiation Programs
United States Environmental Protection Agency
Washington, D.C. 20460
First I want to thank all of you for your participation. At
the outset of this Workshop, I stated that my intended purpose
was to listen rather than talk myself. However, I found that
very difficult because there were a lot of things I would have
liked to remark on myself, but I suspect I will have ample
opportunity in the future.
There were a number of things discussed at this meeting that
should be addressed further in the Albuquerque Workshop, and
I want all the people here to help us formulate the kinds of
things we should cover. The only time I did speak up at this
Workshop was in regard to definitions. In that instance, we
were discussing what is meant by "zero release." I feel that
at the Albuquerque Workshop there ought to be some discussion
of definitions of terminologies. The EPA staff will address
such definitions in an issue paper which will serve as a
starting point. Hopefully, we will not have to re-invent the
wheel for these.
The second thing that came up which I think is a topic for
fair game is how do we present these highly technical matters
to the public. There have to be ways of taking information
and treating it not from the expert's point of view but from
the point of view of the public, to say what is meaningful and
what is not meaningful. I do not know how to do it. I do not
think anybody knows how to do it well. But we certainly would
like to learn.
Another thing that was not brought up but should be discussed
is the philosophical question of what price should we pay for
credibility. How far do we lean one way or the other to make
sure that everybody thinks what we are doing is credible, if
at all? At least that is one of the issues that I think has
not yet been addressed, at least from the point of view of
environmental standards. And, of course, there is the whole
problem of these broad philosophical questions to which we
will never find answers, but which still ought to be addressed
as philosophical issues.
The most important thing which I think I want to point out is
as we go forward to ask ourselves how we should set standards.
We are trying to make this an open process from the very be-
ginning. We are going to take the reports that came in today,
and the next Workshop, and any other comments people have at
any time during the process, and they will all be given due
5-1
-------
consideration as we develop these criteria. If we have strong
suggestions or various suggestions made to us, we will attempt
to put those into use. If we adopt some of them, we will say
why. If we do not adopt them, we will also say why. The
point is, this is not a sterile exercise. This is the kind of
input that we are going to use in every issue that is brought
up. We will have to consider, adopt, reject, modify, or do
something with it, and explain why we have done it and how we
have done it. I am not suggesting that every one of them will
be accepted or every one of them will be rejected, but,
nevertheless, we will give every one of them due
consideration.
With that I want to express the fact that the Albuquerque
Workshop will be held on the 12th, 13th, and 14th of April and
is again going to be an open Workshop. I do not know what
everybody is going to cover because it is the Workshop itself
that will lead us to where we go, except that we will try to
address some of these things in the issue papers. I invite
all of you to attend if you can and to let people know about
it. I hope at the next Workshop we will not be duplicating
what we have done here particularly but will go on to new
things.
With that I want to thank all of you for your participation
and hard work. Thanks very much.
5-2
-------
APPENDIX A*
HIGH-LEVEL,LONG-LIVED RADIOACTIVE
WASTES: CONCEPTS AND COMPARISONS
Materials presented in this Appendix were produced
through consultation with Dr. Keitn Schiager,
University of Pittsburgh, for the U.S.E.P.A.
-------
SOURCES
Three major categories of radioactive wastes that exist
in the United States at the present time are compared:
..^EI.o^ucts generated by chemical processing
of nuclear reactor fuel to extract plutonium for
nuclear weapons for the national defense program.
(These are generally referred to as high-level
defense wastes.)
2- TllB^ianic."0.!-.!.!^6.3. (man-made nuclides heavier
than uranium-238) that remain in the high-level
wastes, including the unextracted fraction of
the plutonium.
contained in wastes from
_
mining and milling of uranium and phosphate ores.
These three categories were selected for comparison because
they represent both the high-level and long-lived radioactive
wastes that are of primary concern to many individuals.
The sources and forms of these wastes are described and
compared in order to emphasize elementary concepts that
must be considered .in radioactive waste management and
disposal.
The comparisons have been simplified by considering, within
each category, only the most critical nuclides, i.e., those
that contribute or control essentially all of the potential
radiation dose to humans. In the fission product category,
only strontium-90 and cesium-137 are included; other products
are of much lesser significance, either because of their
much shorter half-lives or because of the much smaller
activities and/or relative hazards.
The transuranics considered in these comparisons are the
plutonium nuclides 238, 239, and 241, and amer icium-241.
Of the naturally occurring radionuclides , only thorium-230
and radium-226 are included in the comparisons. This was
done simply because the only condition used for comparison
of relative risk was the dissolution of waste nuclides in
water. The comparisons do not include external irradiation
or inhalation of airborne radionuclides that would result
from the radionuclides following radium in the uranium decay
series, as would occur if these wastes were left exposed
on the earth's surface.
High-level radioactive wastes are presently stored at the
three major Energy Research and Development Administration
(ERDA) laboratories: Hanford Reservation in Richland,
Washington; Savannah River Plant in Aiken, South Carolina;
and Idaho National Engineering Laboratory in Idaho Falls,
-------
Idaho.* The high-level waste is stored in various forms of
solids (salt cake, sludge, calcined solids), and in liquid
awaiting calcination or in the process of self-concentration
by evaporation due to decay heat (Refs. 1-3). The wastes from
uranium and phosphate mining are located near the mining and
milling sites. These sites are primarily in Florida for
phosphates and in the western states for uranium (Refs. 4-6).
In the following sections, the volumes and activities of the
wastes currently in storage are summarized. Materials not
presently classified as wastes are not included even though
they may fall into the same categories. For example, fission
products and transuranics contained in unreprocessed reactor
fuel elements are not included, nor are the large quantities
of depleted uranium currently stored at enrichment facilities.
Inclusion of these additional sources would change specific
numerical values, but would not significantly change the
general concepts addressed in the following sections. In
particular, the relative hazard comparison, presented in the
final section, would remain essentially the same.
VOLUMES
The current total volumes of radioactive waste from the three
sources under consideration are depicted in Figure 1 (Refs.
1-6) . For purposes of comparison, all volumes are expressed
in gallons even though all wastes are not in liquid form. The
processes that generate the wastes are summarized for each of
the major sources in the following sections.
PHOSPHATE INDUSTRY
Wastes from the phosphate industry are generated during sever-
al different steps of the production process as shown in
Figure 2. The greatest quantities of wastes are generated
during beneficiation and are in the form of sand tailings
and slimes. Lesser amounts of gypsum from the production
of fertilizers and electric furnace wastes (mostly slag)
from the production of elemental phosphorus are also produced.
The total volume of all wastes from the phosphate industry
is nearly as large as the initial volume of the phosphate
ore mined and is estimated to be approximately 4.4 X IQll
gallons. This volume would cover Washington, D.C. , to
a depth of 35 ft.
*Waste~from commercial reprocessing of reactor fuel consists
of 0.6 million gallons contained in one tank at Nuclear
Fuel Services, Inc., West Valley, New York. This is less
than 1 percent of the total defense wastes and is not included
in this evaluation.
-------
Phosphate Industry
4.4 X1011 gallons*
(Th-230, Ra-226, U-nat
Uranium Mining
and Milling
2.1 X 1010 gallons*
(Th-230, Ra-226)
High-Level Defense Wastes
74.2 X 106 gallons*
(fission products and
transuranics)
Figure 1. Volumes of radioactive wastes. *AII numerical values contained in this summary represent the
best approximation that could be derived from the referenced materials. The uncertainty
associated with some of the values, however, may be as large as + 25%.
-------
Mined Ore
Sand
Tailings: 43%
(U,Th,Ra)
Beneficiation
Marketable Rock
Slimes: 27%
(U,Th, Ra)
Fertilizer
(U,Th)
\
Total volume of wastes:
Approximately 4.4 X 10^ gallons
Figure 2. Sources and relative volumes of phosphate industry wastes.
-------
The significant radionuclides in these wastes (U-natural,
Th-230, and Ra-226) are distributed among the sand tailings,
slimes, and slag in approximately the same proportions
and concentrations as found in the original ore. (If secular
equilibrium exists in the ore, then the activities of U-238,
Th-230, and Ra-226 would be approximately equal in three
of the four waste fractions.)
In the wet chemical processes used for making phosphate
fertilizers, some fractionation of the radioactivity occurs,
with the result that uranium and thorium tend to stay in
the fertilizer and radium is preferentially rejected to
the gypsum waste. Reduced concentrations of uranium and
thorium are also found in the gypsum, however, since the
separation is not complete.
URANIUM MINING AND MILLING
The radioactive wastes from the uranium mining industry
are predominantly in the form of mill tailings. After
extraction of the uranium, the principal radionuclides
in the tailings are Th-230 and Ra-226, which are nearly in
equilibrium. The tailings consist of two fractions: slimes
containing a large portion of the radioactivity and sand
tailings comprising most of the volume. However, these
fractions are not necessarily separated during the milling
process and may simply be mixed together for disposal.
The volume of the tailings is about the same as the total
volume of ore mined because the uranium content of the
ore is a very small percentage. The total current volume
of tailings, at both active and inactive mill sites, is
assumed to be equal to the total volume of ore mined to
date, or approximately 2.1 X lO-^0 gallons (Ref. 4). This
is approximately the volume of the Empire State Building.
HIGH-LEVEL DEFENSE WASTES
The high-level defense wastes are produced and stored at
the three ERDA production facilities previously identified
(Hanford, Savannah River, and Idaho Falls). The high-level
wastes may be in liquid or in one of three solid forms
containing fission products and transuranic nuclides.
Figure 3 illustrates the distribution of the high-level
wastes among the three locations and the liquid and solid
forms (Refs. 1-3, 7). The total volume of the high-level
defense wastes is approximately 74.2 X 10^ gallons, which
is roughly equivalent to the capacity of an oil supertanker.
All of the high-level wastes are initially generated as
liquids. At Hanford and Savannah River the solid wastes
are in the form of sludge and salt cake. The sludge is
precipitated out of the liquid, and the salt cake results
from partial evaporation of the liquid. This process results
in about a 3.5-to-l volume reduction from liquid to solid.
-------
57.7 X 106 gallons total
Savannah River
10.7X 106 gallons liquid
9.0 X 106 gallons solid
19.7 X106 gallons total
Idaho Falls
2.4 X106 gallons liquid
0.4 X106 gallons solid
2.8 X 106 gallons total
High-level waste total volume: 74.2 X 10^ gallons
Figure 3. Distribution of high-level defense waste of volumes.
-------
Both the sludge and the salt cake are relatively soluble. The
major nuclide in the sludge is Sr-90, while in the salt cake
the major nuclide is Cs-137. Some of the liquid waste at
Hanford has been reprocessed to remove Sr-90 and Cs-137. The
extracted nuclides are metallized and doubly encapsulated and
are not, thereafter, included in the "waste" inventory. To
date, approximately 22 percent of the Sr-90 and Cs-137 activ-
ities have been removed from liquid waste inventories by this
method.
At Idaho Falls, the solid wastes are calcined from the liquid.
Calcination results in about an 8-to-l volume deduction.
These calcined solids are less soluble than the other solids
(Ref. 13). There is no separation of radioisotopes in the
calcination. Due to the various solidification processes
employed, the remaining liquid wastes contain varying amounts
of Cs-137 and Sr-90.
ACTIVITY
The activities of the radionuclides of interest are listed in
Table 1. The activities were derived from the summation of
the waste inventories at the three ERDA facilities and for the
entire uranium and phosphate mining industries (Refs. 1-7).
All activities listed have been corrected for decay through
1976. The activities of Sr-90 and Cs-137 shown in Table 1
were derived from an inferred Cs:Sr activity radio of 3:2
(Refs. 1-3). The activity estimates for the individual
transuranic nuclides were made by applying the isotopic ratios
of the spent fuels at Hanford and Savannah River to the
proportionate fractions of the total mass of 625 kg of
plutonium waste. Although the total/mass of plutonium waste
is known to within +25 percent (Ref. 1), the uncertainties in
the estimates of individual activities of the transuranic
nuclides are somewhat greater.
In order to illustrate the changing nature of radioactive
wastes, the activities remaining after 500 years are also
included in Table 1. In that period of time, the activities
of Sr-90 and Cs-137 will decrease by more than 100,000 times.
Plutonium-238, the major constitutent of the transuranic waste
today, will decrease in 500 years to less than 2 percent of
its present activity. Plutonium-241 will disappear in 500
years, but since it decays to Am-241, it will add a small
amount to the americium inventory (Figure 4).
The waste activities of the uranium and phosphate mining and
milling industries are comparable to each other, both at the
present and also after any decay period. The relative
activities of all of the wastes are illustrated in Figure 5.
13
-------
Table 1 Radioactivity Content of Existing Wastes
Isotopic Activity
(a)
High-Level
Fission
products
Trans-
uranics
Phos-
phate
mining
Uranium
mining
Nuclides
Sr-90
Cs-137
Pu-238
Pu-239
Pu-241
Am-241
Ra-226
U-nat
Th-230
Ra-226
Th-230
Total
Present 500
1
2
1
3
1
1
7
6
6
7
7
.8
.6
.0
.3
.8
.0
.9
.8
.9
.1
.1
X
X
X
X
X
X
X
X
X
X
X
10
10
10
10
10
10
10
10
10
10
10
8
8
6
4
5
b
4
4
4
4
4.4 X 108 1
£*
1
1.3 X 106 3
1
2.2 X 105
1. 4 X 105
.1
.7
.8
.3
.1
Years in Future
X
X
X
X
X
103
103
3.8 X 103
\
104
104
10b
1.5 X 105
2.2 X 105
1.4 X 105
Activity^ 4.4 X 10° 5.2 X 10
(a) Source: Refs. 1-7.
-------
O Sr-90
loo- U
Pu-241 Qcs-137
10-
,0)
6
I '-
'o
a
CO
0.1 -
0.01-
O Pu-238
O Am-241
O Ra-226
O Pu-239
O Th-230
102 103 104
Half-life (years)
Figure 4. Specific activity versus half-life.
105
-------
Current cumulative waste inventory
4.4X108C;
Uranium waste: 0.04%
0.4% Phosphate waste: 0.06%
Transuranic waste: 0.3%
Total waste inventory
at 500 years from today
5.2 X 105 C:
Fission
Products
Figure 5. Percentage activities of current waste inventories at present and after 500 years.
-------
RELATIVE HAZARD INDEX
In order to compare the radiation hazards that may be
represented by the various categories of radioactive wastes,
a single index of hazard is desirable for simplification (Ref.
10). The index selected for this analysis is the volume of
water that would be needed to dilute all of the radioactivity
in the wastes to the concentration limit for continuous expo-
sure of the general public, as specified in 10 CFR 20 (Ref.
11). Thus, a relative hazard index (RHI) is defined as the
total activity of a particular constituent of the radioactive
waste inventory divided by the radioactivity concentration
guide (RCG) for that constitutent in water. The values of the
RHI (in gallons) for current inventories of radioactive
wastes, and for the same wastes at a time 500 years in the
future, are shown in Table 2 and Figure 6.
The short-lived high-level wastes, primarily Sr-90 and Cs-137,
require the most dilution today, with Sr-90 being the primary
hazard. They require much more dilution than the long-lived
high-level wastes Pu-239 and Am-241. For comparison, the
water needed to dilute present mine wastes is about one half
the volume of Lake Superior. In 500 years the situation
changes dramatically. Cesium-137 and Sr-90 have decayed to a
very small fraction of the total hazard, with the hazard from
the other nuclides essentially unchanged. The greatest
relative hazard is then uranium and phosphate wastes, over
both fission products and transuranic wastes.
GENERAL CONCEPTS
1. In recently separated reactor wastes the radiation hazard
from fission products will be orders of magnitude greater
than that from transuranic nuclides.
2. Within a few centuries after the production of reactor
wastes, the fission products will have decayed to the
point that their contribution to the total radiation
hazard is a very small fraction of the total.
3. In terms of total radioactivity potentially available to
the biosphere, the corresponding relative hazard index,
the wastes from mining and milling of radioactive ores are
of far greater significance than the transuranic nuclides
produced in nuclear reactors.
4. If the linear, nonthreshold model of radiation effects is
assumed to be correct, the cumulative radiation dose
potentially available to the total population (represented
by the RHI) is a valid measure of the relative toxicity
and risk associated with each category of radioactive
waste. The particular distribution of the waste materials
and specific modes of entry into the biosphere would be of
lesser importance.
-------
Table 2 Relative Hazard Index (RHI) for Current Inventories
of Radioactive Wastes
RCG Present Activity Relative Hazard Index
Nuclide (Ci/gallon) (Ci) (qallons)
Sr-90
Cs-137
Pu-238
Pu-239
Pu-241
Am-241
Ra-226
Th-230
U-natural
1.1
7.6
1.9
1.9
1.1
1.5
1.1
7.6
1.1
X
X
X
X
X
X
X
X
X
10-9
10-8
10-8
10-8
10-6
10-8
10-10
10-9
10-7
1
2
1
3
2
1
7
7
7
6
6
.8
.6
.0
.6
.3
.0
.1
.9
.1
.9
.8
X
X
X
X
X
X
X
X
X
X
X
108
108
106
104
105
105
104(a)
104(b)
lQ4(a)
lQ4(b)
104
1
3
5
1
2
6
6
7
9
9
5
.6
.4
.3
.9
.1
.6
.3
.0
.4
.1
.9
X
X
X
X
X
X
X
X
X
X
X
1017
1015
1013
1012
ion
1012
1014
1014
1012
1012
ion
(a) Uranium.
(b) Phosphate.
-------
CURRENT WASTE INVENTORY
Fission Product Waste: 99%
(Sr-90, Cs-137)
Phosphate Waste: 0.4%
(Ra-226, Th-230
U-nat.)
Uranium Waste: 0.4%
(Ra-226, Th-230)
This wedge is equivalent in volume to one half of Lake Superior
or 12 years flow volume of the Mississippi River.
Transuranic Waste: 0.04%
(Pu-238, 239, 241
Am-241)
CUR RENT WASTES AFTER 500 YEARS
Entire volume is approximately
equal to one half the volume of
Lake Superior
Fission
Products: 0.08%
(Sr-90,
Cs-137)
Phosphate Waste: 52%
{Ra-226, Th-230, U-nat.)
Uranium Waste: 47%
(Ra-226, Th-230)
Transuranic
Waste: 0.7%
(Pu-239, Am-241)
Figure 6. Percentage relative hazard index (RHI) based on water volume required to dilute to RCG.
-------
GLOSSARY
Activity - A measure of the rate at which nuclear disintegrations
occur, usually expressed in curies (Ci) .
Benef iciation - A process that increases the concentration
of a desired mineral in an ore.
Calcination - Solidification method for disposal of liquid
wastes involving atomizing and coating of liquid on
small granular solids and heating to drive off moisture.
Concentration - The activity per unit volume of any material.
Curie (Ci) - The basic unit of radioactivity of a material.
One curie is approximately 37 billion disintegrations
per second or approximately the radioactivity of 1 g
of radium.
De^£ay_ - The spontaneous radioactive transformation of one
nuclide into another.
Half-life - The time in which half the atoms in a radioactive
substance disintegrate.
High-level wastes (as used by ERDA) - Wastes from the operation
of the first cycle extraction system consisting of essentially
all of the nonvolatile fission products, small amounts
of uranium and plutonium, and other heavy elements.
Nuclide - Any atomic nucleus specified by its atomic weight,
atomic number, and energy state.
Radioactivity - The spontaneous decay or disintegration
of unstable atomic nuclei accompanied by the emission
of radiation.
Radioactivity concentration guide (RCG) - The maximum concen-
tration of radioactive materials in air or water to
which an individual may be continuously exposed without
exceeding an established dose limit.
Specific activity - The activity per gram of a nuclide,
~ an~eTement, or of a chemical compound.
Tailings - The portion of ore remaining after a mineral
has been extracted.
27
-------
REFERENCES
(APPENDIX A)
1. Environmental Impact Statement. Waste Management Operations,
Hanford Reservation, Richland, Washington. ERDA-1538,
December 1975.
2. Environmental Impact Statement. Waste Management Operations,
Savannah River Plant, Aiken, S.C. ERDA-1537, October 1976.
3. Environmental Impact Statement. Waste Management Operations,
Idaho National Engineering Laboratory, Idaho Falls,
Idaho. ERDA-1536, June 1967.
4. National Uranium Resource Evaluation, Preliminary Report.
ERDA, GJO-111 (76), June 1976.
5. Guimond, Richard J. The Radiological Impact of the
Phosphate Industry—A Federal Perspective. U.S. EPA,
May 1976.
6. Guimond, Richard J. and Samuel T. Windham. Radioactivity
Distribution in Phosphate Products, By-Products, Effluents,
and Wastes—Technical Note ORP/CSD-75-3-U.S. EPA, August 1975.
7. High-level Defense Waste—Inventories at ERDA's Production
Sites as of October 1, 1976. Personal communication from
D. Saire, Chemical Processing Branch, Division of
Environmental Control Technology, November 1976.
8. High-Level Radioactive Waste Management Alternatives.
U.S. Atomic Energy Commission, WASH-1297, May 1974.
9. Management of Commercial High-Level and Transuranium-Contam-
inated Radioactive Waste. U.S. Atomic Energy Commission,
WASH-1539, September 1974.
10. Hamstra, J. 1975. Radiotoxic hazard measure for buried
solid radioactive waste. Nuclear Safety 16 (2) :180-189.
11. Title 10, Code of Federal Regulation, Part 20, as amended.
12. Calcined Solids Storage Additions. National Reactor
Testing Station, Idaho. U.S. Atomic Energy Commission,
WASH-1529, April 1973.
13. Blomeke, J. 0. and J.P. Nichols. Commercial High-Level
Waste Projections. ORNL-TM-4224, May 1973-
-------
APPENDIX B
ATTENDEES AT THE RESTON WORKSHOP
-------
Dr. Achilles Adamantiades
Electric Power Research Institute
Bob Adamson
McGraw-Hill Publishing Co.
Jeanne Agee
League of Women Voters
Philip M.> Altomare
Mitre Corp./Metrex
Ralph Andersen
University of Maryland
Radiation Safety Office
Steve Andersen
Sierra Club Research
Denton C. Anderson
Teledyne Energy Systems
Robert Baker
U.S. Nuclear Regulatory Commission
Steve Barrager
Stanford Research Institute
John Bartlett
Battelle, Pacific Northwest
Laboratories
David Bauer
SCS Engineers
Harold Bernard
Information Transfer Inc.
Donald J. Binder
Long Island Lighting Co.
David G. Blair
University of Pittsburgh
Robert Borsum
Babcock & Wilcox
James Boyd
Greensboro Daily News
H. Bryant Brooks
Tennessee Valley Authority
Joyce Brooks
Thomas Bustard
Hittman Nuclear & Development Corp.
Donald M. Caldwell
U.S. Nuclear Regulatory Commission
Bob Campbell
Cal Tech/JPL
Daniel E. Caulk, Jr.
Radiation Service Organization
George H. Chase
U.S. Geological Survey
Alan Chockie
Cal Tech/JPL
Gene Christie
TRW, Inc.
H. C. Claiborne
Union Carbide Corp.
James Clark
Nuclear Fuel Services, Inc.
Jerry J. Cohen
Lawrence Livermore Laboratory
Sanford Cohen
Teknekron, Inc.
Martha Cole
Associated Press
Bill Colglazier
U.S. House of Representatives
Gerald L. Combs
U.S. Energy Research and
Development Administration
Frank Conte
U.S. General Accounting Office
Myra Cypser
Environmental Protection Agency
John C. Darrin
Hittman Nuclear & Development Corp.
Owen Davis
Pacific Gas and Electric Co.
-------
John Davis
Potomac Electric Power Co.
Nadia J. Dayem
U.S. Nuclear Regulatory Commission
George D. DeBuchananne
U.S. Geological Survey
Sue Delos
Virginia League of Women Voters
Ronn Dexter
Environmental Protection Agency
Jim Dieckhoner
U.S. Energy Research and
Development Administration
Joseph J. Dinnunno
NUS Corp.
William Dornsife
Commonwealth of Pennsylvania
Department of Environmental Resources
Charles F. Eason
Nuclear Engineering Co.
Peggy Eddy
University of Pittsburgh
Don A. Edling
Monsanto Research Corp.
Dan Egan
Office of Radiation Programs
Environmental Protection Agency
S. F. Eilperin
U.S. Nuclear Regulatory Commission
Warren Eister
U.S. Energy Research and
Development Administration
Kathleen Ellett
League of Women Voters of
Montgomery County
Jerry Ellis
Gilbert/Commonwealth
Jeff Elseroad
Ecological Analysts, Inc.
David N. Enegess
Combustion Engineering Co.
Albert Ferri, Jr.
Pacific Legal Foundation
Joe Fitzgerald
Office of Radiation Programs
Environmental Protection Agency
Ian A. Forbes
Energy Research Group
Frederick Forscher
Energy Consultant
Cynthia T. French
Rachel Carson Trust
Abe Goldin
Office of Radiation Programs
Environmental Protection Agency
W. Mark Grayson
U.S. Nuclear Regulatory Commission
I. Gutmanis
National Planning Association
Dutch Hamester
Donovan, Hamester and Rattien, Inc.
Alan S. Hanson
Yankee Atomic Electric Co.
Charles Hardin
Conference of Radiation
Control Program Directors
Dave Harward
Atomic Industrial Forum, Inc.
Denise F. Hawkins
Office of Air & Waste Management
Environmental Protection Agency
Edward F. Hawkins
U.S. Nuclear Regulatory Commission
Jack Healy
Los Alamos Scientific Laboratory
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Bill Hewitt
Waste Management Program
U.S. Nuclear Regulatory Commission
Bill Holcomb
Office of Radiation Programs
Environmental Protection Agency
Betty Lu Holland
League of Women Voters
John Hollis
Office of Radiation Programs
Environmental Protection Agency
Donald Jacobs
Oak Ridge National Laboratory
Judith Johnsrud
Environmental Coalition on
Nuclear Power
LaMar J. Johnson
Los Alamos Scientific Laboratory
Lawrence Jones
Pacific Legal Foundation
Robert F. Jones
Teledyne Energy Systems
Sybil M. Kari
U.S. Nuclear Regulatory Commission
Bob Kaufmann
Office of Radiation Programs
Environmental Protection Agency
Chauncey Kepford
Environmental Coalition on
Nuclear Power
Fran Kieffer
League of Women Voters
Kyo Kim
United Engineers & Constructors Inc.
Caleb Kincaid
Bureau of Radiological Health
Food and Drug Administration
Joseph Kivel
Environmental Protection Agency
Arnold Kramish
R&D Associates
Konrad Krauskopf
Stanford University
Deborah Kronsteiner
Ecological Analysts, Inc.
Bob Kuechenber,g
Control Data Corp.
Thomas J. Kuehn
Cal Tech/JPL
Jim Lang
N.Y. State Attorney General's Office
Terry R. Lash
National Resources Defense Council
Robert B. Leachman
U.S. Nuclear Regulatory Commission
George W. Leddicotte
Florida Power & Light Co.
Susan Lepow
Environmental Protection Agency
Robert G. Levesque
ATCOR Inc.
Dr. Stanley Lichtman
Joe Lieberman
Nuclear Safety Associates
Peter S. Littlefield
Yankee Atomic Electric Co.
William A. Lochstet
Environmental Coalition on
Nuclear Power
S. E. Logan
University of New Mexico
Earvin K. Loop
U.S. Energy Research and
Development Administration
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James E. Martin
Waste Environmental Standards Program
Environmental Protection Agency
E. J. Martin
Environmental Quality Systems, Inc.
Dr. Margaret N. Maxey
University of Detroit
J. A. McBride
E. R. Johnson Associates Inc.
Elizabeth McCarthy
Office of State Programs
U.S. Nuclear Regulatory Commission
Tom McGarity
Office of the General Council
Environmental Protection Agency
Edward McGrath
Cotter Corp.
Terrance McLaughlin
Environmental Protection Agency
Richard B. McMullen
U.S. Nuclear Regulatory Commission
Dr. Peter J. Mellinger
Exxon Nuclear Company
Research & Technology Center
Calvin Menzie
Fish & Wildlife Service
Department of Interior
Bob Mervine
Ecological Analysts, Inc.
Eric L. Meyer
U.S. Geological Survey
G. Lewis Meyer
Environmental Protection Agency
William Millerd
Center for Science in
the Public Interest
Loring E. Mills
Edison Electric Institute
Richard Milstein
National Academy of Sciences
Brenda Moore
League of Women Voters
Ragnwald Muller
U.S. Nuclear Regulatory Commission
Larry Munnikhuysen
Newport News Shipbuilding
and Drydock Co.
E. W. Murbach
Allied General Nuclear Services
Nora Natof
Environmental Coalition
on Nuclear Power
Charles F. Nealon
League of Women Voters
K. G. Nealon
League of Women Voters
Dr. DeVaughn Nelson
Environmental Protection Agency
Neal S. Nelson
Office of Radiation Programs
Environmental Protection Agency
Mary Nightlinger
League of Women Voters
Warner North
Stanford Research Institute
Bob O'Hara
Duquesne Light Co.
Bruce S. Old
Arthur D. Little, Inc.
Larry Oliva
SCS Engineers
Lawrence Oresick
University of Pittsburgh
Kevin 0'Sullivan
NAI
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J. F. Pang
General Accounting Office
Peter Pelto
Battelle, Pacific Northwest
Laboratories
Harry Pettengill
Office of Radiation Programs
Environmental Protection Agency
Helen Pfuderer
Oak Ridge National Laboratory
John H. Pomeroy
National Academy of Sciences
National Research Council
John E. Razor
Nuclear Engineering Co.
Mark M. Reis
Friends of the Earth
William Remini
U.S. Energy Research and
Development Administration
George Rey
Office of Research & Development
Environmental Protection Agency
James Richard
E. R. Squibb & Sons
John Rieke
Science Applications
Barney Roberts
Southwest Nuclear Company
Gene I. Rochlin
University of California
Stephen B. Ross
Charles Yulish Associates
William D. Rowe
Office of Radiation Programs
Environmental Protection Agency
Jack Russell
Office of Radiation Programs
Environmental Protection Agency
Brian Sasaki
U.S. Office of Management and
Budget
Robert B. Schainker
Systems Control, Inc.
Keith Schiager
University of Pittsburgh
Robert G. Seth
Howard Sheldon
Environmental Protection Agency
N. C. Shirley
General Electric Co.
Robert Shoup
Union Carbide Corp.
Jay Silhanek
Environmental Protection Agency
Kenneth Skilling
Bureau of National Affairs
E. L. Slaggie
U.S. Nuclear Regulatory Commission
David Smith
Office of Radiation Programs
Environmental Protection Agency
Harvey Soule
U.S. Energy Research and
Development Administration
Jim Spahn
National Council on
Radiation Protection
George Stoentz
U.S. Geological Survey
Edward G. Struxness
Oak Ridge National Laboratory
Ferman E. Stubblefield
U.S. Energy Research and
Development Administration
Ren Jen Sun
U.S. Geological Survey
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Jerry Swift
Office of Radiation Programs
Environmental Protection Agency
Tsuneo Tamura
Oak Ridge National Laboratory
A. E. Toombs
Stone & Webster Engineering Corp.
Steve Topp
E. I. DuPont
Newell J. Trask
U.S. Geological Survey
Ralph Ubico
Control Data Corp.
Evan Vineberg
Office of Radiation Programs
Environmental Protection Agency
Edward Virzi
Bechtel Power Corporation
Dr. Bruce W. Wachholz
U.S. Energy Research and
Development Administration
C. L. Wakamo
Environmental Protection Agency/
Region IV
James Walpole
American Mining Congress
Robert K. Weatherwax
Science Applications, Inc.
Isabell Webber
League of Women voters
Jim Wells
U.S. General Accounting Office
G. Hoyt Whipple
University of Michigan
L. D. Williams
Battelle, Pacific Northwest
Laboratories
Robert K. Wilson
Cal Tech/JPL
Isaac Winograd
U.S. Geological Survey
David G- Wood
Office of Air Force Surgeon General
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