REVIEW OF WASTE ELIGIBILITY AND
                   CONTAINER LIFETIMES FOR OCEAN
                       DISPOSAL OF LOW LEVEL
                        RADIOACTIVE WASTE
INDUSTRIAL ECONOMICS, INCORPORATED
                    2067 MASSACHUSETTS AVENUE     CAMBRIDGE, MASSACHUSETTS 02140

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        REVIEW OF WASTE ELIGIBILITY AND
         CONTAINER LIFETIMES FOR OCEAN
             DISPOSAL OF LOW LEVEL
               RADIOACTIVE WASTE
                 Prepared for:

             Moira McNamara Schoen
              EPA Project Officer
   Environmental Resource Economics Division
           Office of Policy Analysis
      U.S. Environmental Protection Agency
                  Prepared by:

Michael T. Huguenin and Melissa A. Walters
       Industrial Economics, Incorporated
           2067 Massachusetts Avenue
        Cambridge, Massachusetts  02140
                 June 1988

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                           DISCLAIMER
     This  report was prepared as an account of work sponsored by
the  U.S.  Environmental Protection Agency.   Neither the  United
States  Government  nor  any agency thereof,  nor  any  of  their
employees, nor any of their contractors, subcontractors, or their
employees, makes any warranty, express or implied, or assumes any
legal liability or responsibility for the accuracy, completeness,
or usefulness of any information,  apparatus, product, or process
disclosed,   or  represents  that  its  use  would  not  infringe
privately  owned  rights.    Reference  herein  to  any  specific
commercial product,  process or service by trade name, trademark,
manufacturer,  or otherwise,  does not necessarily constitute  or
imply its endorsement,  recommendation, or favoring by the United
States  Government  or  any  agency,  contractor  or  subcontract
thereof.   The  views and opinions of authors expressed herein do
not  necessarily  state  or reflect those of  the  United  States
Government or any agency, contractor or subcontractor thereof.

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                         ACKNOWLEDGMENTS


     Many  individuals at EPA participated in the development  of
this  study  and in discussions of  issues.   The  assistance  of
Robert Dyer,  Elliot routes,  Jim Gruhlke, Byron Hunger and other
staff  in  the  Analysis and Support Division of  the  Office  of
Radiation Programs;  Durrell Brown and John Lishman in the Office
of Marine and Estuarine Protection, Office of Water; Alan Sielen,
Office  of  International Activities;  and John Davidson  in  the
Office  of  Policy  Analysis,  Office  of  Policy,  Planning  and
Evaluation, is especially appreciated.

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                        TABLE OF CONTENTS
INTRODUCTION AND SUMMARY                              CHAPTER 1
     Background 	 1-1
     Summary of Results 	 1-2
     Factors Required for Comparative Analysis 	 1-7
     Plan of This Report 	 1-12


LOW LEVEL RADIOACTIVE WASTE
ELIGIBLE FOR OCEAN DISPOSAL                           CHAPTER 2
     Introduction 	 2-1
     Definition of LLRW 	 2-2
     Description of Waste Streams 	 2-4
     Eligibility for Ocean Disposal 	 2-11
     Summary 	 2-17


CONTAINER LIFETIMES FOR LOW LEVEL
RADIOACTIVE WASTES                                    CHAPTER 3
     Time Required for Decay 	 3-1
     Review of Available Containers 	 3-5
     Summary 	 3-8


RADIONUCLIDE COMPOSITION OF
LOW-LEVEL RADIOACTIVE WASTES 	 APPENDIX A

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INTRODUCTION AND SUMMARY                                CHAPTER 1
BACKGROUND

     The  Environmental Protection Agency (EPA) is currently con-
sidering revisions to ocean dumping regulations which may include
provisions  for the evaluation of permits for deep-ocean disposal
of low-level radioactive wastes (LLRW).   These revisions are  to
reflect  the requirements of the Marine Protection,  Research and
Sanctuaries  Act  (MPRSA,  PL 92-532) as amended by  the  Surface
Transportation Assistance Act (PL 97-424),  and may require, among
other  things,   that  applicants  perform  Radioactive  Material
Disposal  Impact Assessments (RMDIA) and that a joint  resolution
of  Congress  give approval prior to issuance of any  permits  by
EPA.

     EPA   is  evaluating  criteria  for  LLRW  ocean   disposal,
including   provisions  for  disposal  site  designation,   waste
packaging performance,  the definition of high-level  radioactive
wastes,  and  the requirement  that applicants conduct the RMDIA.
As  part  of its evaluation,  EPA is  reviewing  and  considering
siting criteria and waste packaging criteria of the International
Atomic  Energy  Agency (IAEA),   especially for the  annual  total
limits  of  radioactivity,  and the limits for  alpha,  beta  and
gamma-emitting radioactivity per unit volume of waste.

     To  assist in developing the LLRW ocean disposal provisions,
EPA's  Office  of  Policy Analysis  asked  Industrial  Economics,
Incorporated (lEc) to complete three research tasks as follows.

     o    First,  EPA asked that lEc estimate the volume and
          radioactivity of LLRW that  might be eligible  for
          ocean  disposal taking into consideration (1)  any
          differences   in  LLRW  definition   between   the
          proposed  land  disposal program  and  definitions
                               1-1

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          provided by the International Atomic Energy Agency
          (IAEA), London Dumping Convention (LDC) documenta-
          tion,  existing  ocean disposal  regulations,  and
          reports from Brookhaven National Laboratory (BNL),
          and   (2) radioactivity limits and other  technical
          criteria   for  the  ocean  disposal  program   as
          suggested  in BNL's "Development of a Working  Set
          of  Waste  Package Performance  Criteria  for  the
          Deepsea Disposal of Low-Level Radioactive Waste".

     o    Second,  EPA  asked  lEc to  review  the  criteria
          suggested in the BNL technical document concerning
          container lifetime, and to identify considerations
          which  might support use of shorter or longer-life
          containers.

     o    Third,  EPA  asked  lEc  to identify  and  discuss
          factors which would be required for a  comparative
          analysis  of  the human health  and  environmental
          risks  associated with ocean versus land  disposal
          of LLRW.

The  remaining sections of this chapter summarize the results  of
lEc's  work,  and  describe the organization  of  this  document.
References are cited in the text using the number as shown in the
Bibliography.
SUMMARY OF RESULTS

LLRW Definition

     A  working  definition  of  LLRW  being  considered  by  EPA
includes  upper  activity  limits (which define  the  demarkation
between low-level and high-level wastes), de facto lower activity
limits  based  on ambient levels (which  define  the  demarcation
between  LLRW and lower activity concentrations not of regulatory
concern), and a variety of other specifications such as limits on
transuranic wastes and wastes containing contaminants.   We  have
compared  radioactive wastes generally identified in a variety of
source documents as "low-level" to the ocean disposal criteria to
determine the volume and activity of LLRW that might be  eligible
for ocean disposal.
                               1-2

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LLRW Volume and Radioactivity

     Exhibit  1-1 summarizes the universe of LLRW streams that we
considered.    As  shown,  our  research  identified  an  overall
universe  of  45 specific waste streams accounting for  about  20
million  cubic  meters  and 47 million  curies  of  radioactivity
generated  during  the  20  year period from  1985  to  2004.  I/
Naturally occurring/accelerator produced wastes comprise slightly
more  than half of the total volume considered but only  .01%  of
the activity.   DOE/Defense LLRW comprise slightly more than half
of the total radioactivity.

     The LLRW streams shown on Exhibit 1-1 have been grouped into
six summary categories.


     o    Commercial  LLRW  streams are those  generated  by
          commercial   sources,   including  nuclear   power
          reactors,    nuclear    fuel   cycle   operations,
          industrial    sources   and   institutions   (e.g.
          hospitals, universities).

     o    DOE/Defense  LLRW streams are generated by routine
          government  operations,   and  are  not  as   well
          characterized as commercial wastes.

     o    Naturally-occurring   and   accelerator   produced
          radioactive materials  (NARM)  include  a  variety
          of  materials currently  regulated  only  in a few
          states.

     o    Decommissioning   LLRW   streams  include   wastes
          projected    to    be    generated    by    future
          decommissioning  activities of power reactors  and
          related facilities.
I/  Note that volume estimates are available for only 44  wastes,
and  activity estimates are available for only 41 wastes.   Thus,
estimates  for  total volume and activity shown  in  Exhibit  1-1
slightly underestimate the actual figures.
                               1-3

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     o    Remedial   action  LLRW  streams  include   wastes
          projected  to  be  generated  by  future  remedial
          actions  at a variety of sites administered  under
          EPA and DOE programs. 2/

     o    Finally, the U.S. Navy must decommission about 100
          nuclear  submarines over the next 20 to  30  years
          and must dispose of the resulting LLRW.


     NARM  wastes  are  comprised  of a  variety  of  radioactive
materials generated by industrial users and regulated on a state-
by-state  basis.  According  to  EPA's  Low-Level  and NARM Waste
Standards;  An Update  (1)  very little of the quantity  of  NARM
waste  shown in Exhibit 1-1 would be defined as  regulated  LLRW.
Further, individual states differ in their requirements for these
wastes.   Thus, the necessity of regulated disposal for many NARM
wastes is not clear at this time.

     The  45 waste streams summarized in Exhibit 1-1 are  diverse
in terms of source, generation volume, and specific radioactivity
(defined as radioactivity per unit volume).  Exhibit 1-2 presents
a  diagram  which plots volume versus specific activity  for  all
LLRWs for which data are available.    As shown, volume for these
waste streams varies across 7 orders of magnitude,  and  specific
activity  varies  across  10 orders of  magnitude.   If  the  two
outlier  wastes  are ignored,  volume varies across 4  orders  of
magnitude  and  specific  activity  varies  across  8  orders  of
magnitude.   Note  that  the  large  ranges in  both  volume  and
specific  activity across LLRW streams require use  of  logarithm
scales for  both axes of the graph. 3/
2/    The  estimates shown in Exhibit 1-1 for remedial action  do
not include wastes generated by EPA's CERCLA program, which could
be  significant in quantity.   We have not been able  to  develop
estimates  of CERCLA LLRW for this report.

3/   The two LLRW streams that are identified on Exhibit 1-2  are
described more fully in Chapter 2 of this report.
                               1-4

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     Exhibit  1-2 does not show any strong pattern relating  LLRW
volume  and  specific activity.   There appears to  be  a  slight
tendency   for  large  volume  wastes  to  have  lower   specific
activities,  but examples of the opposite relationship appear  as
well.   All  of the individual LLRW streams are reviewed in  more
detail in Chapter 2.

     Data about these LLRW streams suffer from varying degrees of
uncertainty.   Wastes  which  are  being  generated  today  on  a
relatively  routine basis,  such as commercial,  DOE/Defense  and
NARM  wastes,  have  relatively certain information available  on
waste  quantity,  composition,  and radioactivity.4/  Information
about  wastes  which are not being generated on a  routine  basis
today,  such  as decommissioning and remedial action  wastes,  is
much more uncertain.  The reader should keep these differences in
mind when evaluating the certainty of information presented.


LLRW Eligible for Ocean Disposal

     Estimating  which LLRW streams will in fact be eligible  for
ocean disposal is a difficult task for several  reasons.   First,
waste eligibility will depend on a variety of interrelated waste,
disposal site and waste package factors.  However, in our work we
have considered waste-specific factors only.  Second, some of the
ocean disposal criteria under evaluation would require EPA to use
considerable   professional   judgement   in   determining   LLRW
eligibility.  When requirements are not stated precisely, we have
not  been  able  to  make firm  judgments  concerning  a  waste's
possible  eligibility  for  ocean  disposal.    Third,   we  have
incomplete data for many LLRW streams,  which makes it  difficult
to establish certain eligibility for these wastes.

     Notwithstanding  these  problems,  we compared all  45  LLRW
streams  to  various eligibility requirements with the  following
results.   First,  all but two (waste streams #21 and #32) of the
40  wastes for which activity data are available meet  the  upper
activity limit.   The volume and radioactivity represented by the
two  ineligible wastes account for less than one hundredth of one
4/   However,  for  national  security  reasons  little  of  this
information is publicly available for DOE/Defense wastes.
                               1-5

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percent of volume and about  one  percent  of  activity  for  the
40  LLRW  streams considered.  5/ Second, we find that all wastes
appear  to  be  well  above the lower  activity  limits  (ambient
levels), although our data on ambient levels are quite limited.

     In  addition  to these activity limits,  we  considered  two
other   ocean   disposal  eligibility  factors   concerning   co-
contamination and waste form.  Although data describing hazardous
chemical contamination in LLRW are limited,  it appears that  the
eligibility  of large amounts of commercial,  DOE/Defense,   NARM,
and  remedial  action  LLRW  for ocean  disposal  must  still  be
explored in terms of the presence of co-contamination.

     Waste   form  requirements  do  not  appear  to  limit   the
eligibility   of  the  25  LLRW  streams  for  which   sufficient
information to judge was available.   Given the lack of data  for
the other 20 waste streams we are not able to identify which ones
are ineligible for ocean disposal based on waste form criteria.

     In evaluating the eligibility of LLRW for ocean disposal, we
have  not given any consideration to the economic desirability of
ocean disposal.  In general, data on the cost of disposal of LLRW
is  more  comprehensive for the land program than for  the  ocean
program.  Two studies that address the cost of ocean disposal are
the  Niagra Falls Storage Site FEIS (3) and the  Naval  Submarine
Reactor Plants FEIS (5).  Because each of these studies addresses
a  specific type of waste it is very difficult to apply the  cost
information  to other types of LLRW.   Thus,  while the framework
exists,  no  specific evaluation of the economic desirability  of
ocean disposal is possible at present.


LLRW Container Lifetimes

     Ocean  disposal criteria developed by BNL specify a 200 year
lifetime for LLRW containers used for ocean disposal.   In  order
to  consider the adequacy of the proposed 200 year  lifetime,  we
5/    A  third  LLRW  (waste stream #26)  may  exceed  the  upper
activity limits depending upon the assumption employed concerning
the  waste's density.   This single stream accounts for 2 percent
of  volume  and  7.5  percent of  activity  for  all  40  streams
considered.
                               1-6

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calculated  the  time in years required for each LLRW  stream  to
decay  to 1 percent and slightly less than 0.1 percent of initial
radioactivity  levels.  We selected these levels after review  of
BNL's  rationale  for  selecting  a  200  year  lifetime  as  one
alternative,  which  is  based in part on the desire  to  achieve
decay sufficient to reduce activity levels to 1.0 to 0.1  percent
of initial levels.

      We found that only 11 of the 40 LLRWs (8 percent by volume)
for  which  data  are  available decay to 1  percent  of  initial
activity  within  200 years,  and only 3 streams  (2  percent  by
volume)  reach 0.1 percent of initial activity over the 200  year
period.   Roughly  half  of  the waste streams  considered  would
require  more  than 5000 years to reach either 1 percent  or  0.1
percent  of initial radioactivity levels.   However,  for  a  few
short-lived  nuclides  a 200 year container lifetime  will  allow
decay   to   levels  well  below  0.1  percent  of  the   initial
radioactivity.


Available LLRW Containers

     High integrity containers (HIC), which are approved for land
disposal of LLRW, are available in usable volumes (LLRW capacity)
ranging from 5 to 284 cubic feet and are constructed using one of
four materials:  polyethylene, fiberglass/polyethylene composite,
stainless  steel  alloy,  and  steel  fiber  polymer  impregnated
concrete.   The  minimum container cost per cubic foot of  usable
volume  is $25 to $26,  or about $900 per cubic meter of  volume.
All of these containers would require  modifications and  further
testing  before being judged suitable for ocean  disposal.    The
feasibility and costs of developing a container which meets a 200
year  lifetime as well as any other future requirements should be
explored further.


FACTORS CONSIDERED FOR COMPARATIVE ASSESSMENT

     In  order  to complete a comparative analysis of  the  human
health  and environmental risks associated with ocean versus land
disposal  of low-level radioactive wastes,  at least  five  major
factors could be considered.
                               1-7

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     1.   Ocean and land disposal systems must be  described
          in  sufficient detail to allow relative risk esti-
          mation.

     2.   Combinations  of specific wastes,   disposal sites,
          and  other factors must be specified as  scenarios
          for analysis.

     3.   Geographic  and  conceptual  boundaries  for   the
          analysis must be defined.

     4.   Risk metrics of interest for both human health and
          environmental damage must be selected.

     5.   Methods  and data for estimating these risks  must
          be developed and used to generate risk estimates.

Each of these factors is discussed below.

System Descriptions

     In  order to complete a comparative analysis of land  versus
ocean  disposal  of  LLRW,  the physical  systems  for  treating,
packaging,  transporting  and disposing of LLRW in each of  these
environments must be described in sufficient detail to allow risk
estimation.  This  requires  that  numerous  details  be  thought
through concerning:

     o    type and composition of wastes handled,

     o    waste  treatment  and  packaging at  the  site  of
          generation (and elsewhere),

     o    location  of waste sources,  routes of  transport,
          and destinations,

     o    modes of transport,

     o    location  and nature of intermediate handling  and
          storage, if any,

     o    location  and manner of final disposal operations,

     o    nature of post-disposal monitoring and maintenance
          activities, if any, and


                               1-8

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     o    clean-up/remedial   response   costs  in  event of
          accident.

Specification  of these and other details is necessary to  permit
estimation   of   mass   flows   throughout   the   systems   and
to  allow  identification  of  points  of  possible  release   of
hazardous  materials to the environment.  Once release points are
identified,  the probability and likely magnitude of releases can
be  estimated.   Given  the high-level of  public  concern  about
accidental   releases,   especially   those   involving   serious
consequences,  it  is  important  to consider  possible  accident
events as well as releases from continuous or routine operations.


Develop Scenarios

     Once the general disposal systems of interest are described,
specific  scenarios  for  analysis  must  be  established.  These
scenarios represent actual land or ocean based systems or  groups
of  similar systems,  and are defined by specific combinations of
factors which are important inputs to the risk analysis, such as

     o    representative LLRW constituents and amounts,

     o    representative disposal locations and methods,

     o    representative  modes of transport  and  operating
          conditions.

Scenarios   are   developed  from  data  describing  the   actual
population of wastes, sites, and other factors of interest.  Such
data are available for land disposal of LLRW currently  disposed,
but not for other LLRW or for ocean disposal.

     If  one wished to consider ten representative LLRW  streams,
ten   representative  disposal  locations,   and  five  modes  of
transport or operating conditions,  500 sets of risk calculations
(10*10*5)  would  be required.  If 90 percent of  these  possible
combinations   are  impossible  or  unrealistic,   50   sets   of
calculations  would  still be required.  While these numbers  are
examples  only,  it  is likely that the actual  scenarios  to  be
analyzed  will  of necessity be limited well below the number  of
possible,  and relevant, combinations of important system factors
which influence risks.
                               1-9

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     In  order to make the number of scenarios tractable,  it  is
important  to  do  the most  important  combinations  first.  New
scenarios can then be added as results dictate.   In general,  it
is  best  to begin with several realistic scenarios  rather  than
simplified   sets  of  conditions  selected  only  for   analytic
tractability.

     Risk estimates developed to support EPA's proposed LLRW land
disposal  regulations would provide a basis for specification  of
scenarios  for  the land disposal  option.  However,  no  similar
estimates  for  ocean disposal systems other than  for  municipal
sewage  sludge  and  liquid hazardous waste  incineration  exist.


Risk Metrics

     The  appropriate  metrics  of  "risk"  to  estimate  for   a
comparative  analysis  of ocean versus land disposal of LLRW  are
complicated because

     o    human and environmental effects are included,

     o    non-threshold   and  threshold  effects   may   be
          included  if both radioactive and mixed wastes are
          considered,

     o    both  the  level  and distribution  of  risks  are
          important, and

     o    descriptions   of   risks  across   a   range   of
          probabilities  and levels of consequences must  be
          developed.

     To  accommodate  these  requirements,   a  variety  of  risk
measures  could  be  used  based  on  the  effects  of   greatest
importance   and   the  available  data  about   those   effects.
Information  about the human health and environmental effects  of
both  radiation and mixed wastes is sufficient to allow selection
of the metrics of interest.  However,  in selecting risk  metrics
double-counting  of risks must be avoided (e.g.  including health
effects from ingestion of tainted fish and economic loss assuming
some fish are no longer captured and sold).
                               1-10

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Boundary Definitions

     Results  of  risk  analyses are strongly influenced  by  the
boundaries  set  for  the analysis,  for  example  the  physical,
chemical,  and  biological actions included;  the exposure  areas
modeled;   and   the  human  health  and  environmental   effects
considered.   Exposure   areas  and  effects   are   particularly
difficult,  because  of  the need to be consistent  between  land
versus  ocean  disposal,  and of the need to consider a range  of
human  health  and environmental effects.  Different  effects  of
interest may suggest different exposure area boundaries.

     In general,  we believe it advisable to use relatively large
boundaries  and consider (at least roughly) all  likely  effects.
Again  risk  estimates developed to support EPA's  proposed  LLRW
land  disposal  regulations  would provide a basis  for  boundary
definition  for  human  health effects  from  the  land  disposal
option.  However,  preliminary  ocean disposal risk  calculations
would   be   needed   to  allow  specification  of   health   and
environmental damage boundaries for the full comparative analysis
of ocean disposal.


Methods for Risk Assessment

     Once  the  above decisions are made,  data and  methods  are
needed  to  calculate risk estimates for the scenarios  and  risk
metrics of interest.  Estimates exist currently for human  health
risks  from  land  disposal  of commercial  (and  presumably  for
DOE/Defense)  LLRW,   and  these  methods  might  be  useful  for
estimating  risks from land disposal of NARM and remedial  action
LLRW.  We are not aware of currently available methods or data to
estimate   environmental  risks  from  land  disposal  of   LLRW.
However,  the U.S.  Navy's FEIS on the disposal of decommissioned
naval   submarine  reactor  plants  (5)  does  summarize  adverse
environmental  effects  that may be expected from both  the  land
disposal and ocean disposal options.

     Human  health  and environmental risks from  possible  ocean
disposal of LLRW have not been explored (except for the U.S. Navy
FEIS),  and  to our knowledge data and methods to estimate  these
risks  would have to be developed or adapted from other  studies.
Many  factors would need to be estimated,  including time to  and
nature of container/waste form failure, the resulting leach rate,
suspension and resuspension of contaminated sediments,  transport


                               1-11

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in the deep ocean water column, uptake by various trophic levels,
bioaccumulation  and bioconcentration,  and eventual  effects  on
marine and human life.  In addition,  these same as well as other
effects  resulting from accidental releases (e.g.  disposal  ship
accidents) would have to be estimated.

     Comparative risk assessment would require that some research
be  completed  on  the  economic aspects  of  ocean  versus  land
disposal.   Probabilities  and  magnitudes of releases,  and  the
nature  of  resulting mitigation  activities,   are  all  directly
dependent  on  the level of expenditures for  system  components,
waste recovery teams,  and so forth.   In addition,  the types of
LLRW  most  likely to utilize land versus ocean disposal  systems
will be determined in large part by economic desirability.  Thus,
any  comparative risk assessment must be based on analyses  which
establish  the basic costs and relative economic  advantages  and
disadvantages of the land and ocean systems under study.


PLAN OF THIS REPORT

     The remaining chapters of this report present lEc's findings
in more detail, as follows:

     o    Chapter  2 presents our estimates of the  quantity
          and  radioactivity  of  LLRW and  discusses  which
          wastes might be eligible for ocean disposal.

     o    Chapter  3 presents our review of  LLRW  container
          lifetimes.

     o    Appendix A  presents  data  on  the   radionuclide
          content  of the LLRW streams discussed in  Chapter
          2.

Exhibits  are included at the end of each chapter,  following the
text.
                               1-12

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CHI EXHIBITS

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                             Exhibit 1-1

               Summary of Low Level Radioactive Wastes
          That are Potential Candidates for Ocean Disposal,
                           1985 - 2004
Source
Commercial
DDE/Defense
Naturally Occurring/
Number of
Streams
25
6
5
Volume
(cubic meters)
2,925,702
1,831,701
12,011,780
Radioactivity
(curies)
12,744,504
27,473,055
6,609
Accelerator Produced
(NARM)

Decommissioning LLRW
(Nuclear Reactors Only)

Remedial Action

U.S. Navy Submarine
Reactor Plants
     Total
                                  37,672
                    903,910
5
1
3,626,625
-- *
6,200,000
                   45
20,433,480
47,328,078
*     The  FEIS on the disposal of submarine reactor  plants  (5)
indicates that there are 362,870 tonnes that may qualify as LLRW.
Source:
See text.

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                            Exhibit  1-2


               LLRW Volume Versus Specific  Activity
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                            Log of Volume (m~3)
Source:   lEc  analysis of data from Exhibit  2-2.

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LOW LEVEL RADIOACTIVE WASTE
ELIGIBLE FOR OCEAN DISPOSAL                             CHAPTER 2
INTRODUCTION

     This  chapter  presents lEc's estimates of the quantity  and
radioactivity of low-level radioactive waste (LLRW) likely to  be
considered for ocean disposal.   The first section of the chapter
presents  the  definition  of low-level  radioactive  wastes  and
compares  LLRW definitions used by the land versus ocean disposal
programs.   The  second  section of the  chapter  identifies  and
describes  all LLRW streams considered for ocean  disposal.   The
final  section  of the chapter compares all LLRW streams  with  a
number  of eligibility criteria in order to determine which  LLRW
streams might be eligible for ocean disposal.

     Data  describing LLRW streams are drawn from three  sources.
Information  about  commercial  LLRW is  from  Update of  Part 61
Impacts  Analysis Methodology, Methodology Report  (12); and  Vol.
2 of the Draft Environmental Impact Assessment (EIA)  (8). Inform-
ation about DOE/Defense LLRW and  waste from  decontamination and
decommissioning  of  commercial power plants is drawn from  Inte-
grated  Data Base for 1986;  Spent  Fuel  and  Radioactive  Waste
Inventories,   Projections   and  Characteristics  (4).   Finally,
information  about naturally occurring  and  accelerator-produced
radioactive materials (NARM) is from Vol.  2 of the Draft EIA (8)
and  from Radiation Exposures  and  Health Risks Associated  with
Alternative  Methods of Land  Disposal  of Natural and  Accelera-
tor-Produced Radioactive Materials (2).
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DEFINITION OF LLRW

     The precise characteristics which define LLRW are  difficult
to establish.  In general, low-level radioactive waste is defined
as   material   that  is   not  high-level   radioactive   waste.
Definitions  of high-level waste are often expressed as lists  of
specific  waste streams considered to be high-level  wastes,  and
are  not  expressed  in terms of physical  characteristics  (e.g.
presence of specific nuclides,  radioactivity  levels).   Because
slightly  different  high-level  waste  lists  are  published  in
different sources, the exact boundary between high- and low-level
wastes is difficult to establish.

     Exhibit  2-1 compares the definitions of low-level waste for
the  ocean and land programs.   The primary source for  the  land
definition of LLRW is Vol.  2 of the Draft EIA (8).   The primary
sources  for  the ocean definition of LLRW are the  International
Atomic Energy Agency (IAEA) Safety Series #78,  developed for the
London  Dumping Convention,  and existing ocean disposal  regula-
tions.I/

     Exhibit  2-1  is  organized  into  three  sections:    lower
activity limit,  upper activity limit,  and other specifications.
The  following paragraphs highlight differences in each of  these
categories.


Lower Activity Limit

     As shown on Exhibit 2-1,  the IAEA Safety Series #78 defines
ambient  concentrations of (1) naturally occurring  radioactivity
and   (2)  anthropogenic  radionuclides  attributable  to   global
fallout  from  nuclear  testing as the lower activity  limit  for
LLRW.

     The  land program does not include a similar lower  activity
limit  for  most categories of   LLRW.   However,  for  naturally
occurring  and accelerator produced radioactive materials   (NARM)
wastes,  EPA, as mentioned in EPA's Low-Level and NARM Standards;
I/    The  ocean LLRW definition is consistent  with  legislative
history  at  HR  97-562  part  1,   page  16  and  18;   and  128
Congressional Record H107-16.


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An Update  (1),  is proposing to regulate only those wastes  with
activities greater than .002 Ci/tonne.   Thus,  a lower  activity
limit for NARM wastes is established.
Upper Activity Limit

     While  the  upper  activity limits for the  ocean  and  land
programs  are  not entirely consistent with each other,  each  is
relatively well defined.  High-level radioactive waste is clearly
illustrated  for  both programs,  and both  definitions  of  LLRW
designate  high-level waste as the upper limit for what qualifies
as  LLRW.   As  Exhibit 2-1 shows,  both programs  would  provide
qualitative definitions of high-level waste.   In  addition,  the
ocean  program  would provide quantitative upper activity  limits
for  three  distinct categories  of  emitters.   No  quantitative
limits are provided by the land program.


Other Specifications

     Each  program  identifies additional criteria that serve  to
narrow the definition of low-level wastes.  Exhibit 2-1  presents
these  other specifications included in the definitions  of  low-
level waste for the land and the ocean programs.     First,  both
programs  generally  prohibit the disposal of wastes with  radio-
activity greater than 100 nanocuries per gram (.l Ci/tonne)  from
transuranic alpha emitters with half-lives greater than 20 years.

     Second,  the  EPA  is considering additional limits on  LLRW
disposed  in  the  ocean to insure that the maximum  dose  to  an
individual  is  only  "a small fraction  of  100  millirem/year."
Current  information  about human exposure  pathways  from  ocean
disposal  is not sufficient to allow translation of this exposure
limit into specific activity limits for wastes.

     For the land disposal program,  EPA is currently considering
general  criteria  for radioactive wastes  whose  disposal  would
present  an annual exposure dose to critical population groups of
less than 4 millirem as "Below Regulatory Concern" (BRC).  Wastes
that  qualify as BRC could be disposed on land without regard  to
radionuclide content.   Should a proposed rule concerning BRC  go
into  effect,  BRC may serve as a lower limit for defining  which
wastes must be treated as LLRW when disposed on land.


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     There  are a number of additional criteria listed on Exhibit
2-1.   For example, the ocean program would specifically prohibit
the  disposal  of free radioactive gases and of low-level  wastes
that  contain specific contaminants that are deemed hazardous  by
the  London Dumping Convention.   The land  program  specifically
prohibits disposal of mill tailings,  spent nuclear fuel, and by-
product material. 2/


Summary

     The  criteria described above serve to define LLRW  for  the
ocean  and  land disposal programs.   We assembled  data  on  all
radioactive   wastes   which  are  considered  as  LLRW  by   the
information sources cited at the beginning of this  chapter.   We
then  considered whether each LLRW stream met the criteria listed
for  ocean disposal in Exhibit 2-1.   The results of these  steps
are described below.
DESCRIPTION OF WASTE STREAMS

     Exhibit 2-2 identifies and describes waste streams that  lEc
examined   as  possible  candidates  for  ocean  disposal.    The
following  section outlines the information that is  provided  in
the exhibit and describes the organization of the waste streams.

     The  reference  numbers  assigned to each waste  stream  are
listed in the first column of Exhibit 2-2.  The waste streams are
listed in the second column.    For waste streams 1 to 25 and  32
to 36 the second column also provides the  mnemonic  used  by EPA
from the NRC Update of Part 61 Impacts Analysis Methodology.

     The  third and fourth columns of Exhibit 2-2 list the  total
volume  in  cubic  meters,  and  the total  activity  in  curies,
projected for each waste stream for the years 1985 to 2004.   The
2/    For disposal purposes,  mill tailings,  spent nuclear fuel,
and  by-product  material are treated as  high-level  radioactive
waste.
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density  of  each of the waste streams is provided in  the  fifth
column.3/  The sixth column is calculated by using the density to
convert waste volume to waste mass in metric tons  (tonnes),  and
then  dividing activity by the resulting mass to arrive at curies
per tonne.

     The  seventh column summarizes the radionuclide  composition
of the low-level waste streams.  At EPA's request, lEc identified
the  following radionuclides and their percentage contribution to
the radioactivity in each of the waste streams: carbon 14 (C-14),
radium 226 (Ra-226), cobalt 60 (Co-60), strontium 90 (Sr-90), and
cesium 137 (Cs-137).   In addition,  we note other  radionuclides
that represent a significant portion of the radioactivity in each
waste stream.

     EPA's  current  proposal concerning land  disposal  of  LLRW
allows  for the identification of certain waste streams as "Below
Regulatory  Concern"  (BRC)  thereby deeming  them  suitable  for
disposal at sites not regulated as LLRW disposal sites.  4/   The
proposed  rule provides a general criterion that low-level wastes
for   which  unregulated  disposal  results  in   CPG   (critical
population  group)  exposures  less than 4 millirem per  year  be
classified  as "Below Regulatory Concern".  The final  column  of
Exhibit  2-2 indicates if a waste stream is a possible  candidate
for BRC given the current land proposal. As discussed below, this
column applies only to commercial waste streams and discrete NARM
wastes.

     The  low-level waste streams that are listed in Exhibit  2-2
are organized into seven categories:
3/   For  most of the wastes,  densities were obtained  from  the
sources mentioned at the beginning of this chapter;  however, for
the wastes generated by DOE/defense activities,  decommissioning,
and remedial action programs the densities are assumed to be  the
density  of water (1 g/cm3).   This assumption is consistent with
the  actual  densities of commercial  waste,  which  average  .97
g/cm3,  and  is  also  used in the DOE data source cited  at  the
beginning of this chapter.

4/    The  EPA will not specifically  designate  which  low-level
wastes  will become BRC.   Such wastes will be classified by  NRC
and DOE.
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     o    Commercial,
     o    DOE/Defense "General",
     o    Naturally Occurring and Accelerator Produced
            Radioactive Material (NARM),
     o    Decommissioned Reactor  and  Fuel  Cycle  Facility
            Wastes,
     o    Remedial Action Programs, and
     o    U.S. Navy Decommissioned Reactor Plants.

     As the following sections suggest,  the certainty associated
with  our  volume  and  other estimates varies  among  the  waste
categories.  Some waste streams are currently routinely generated
while  others are not expected to be routinely  generated  during
the  time period 1985-2004.  In general,  information about  low-
level   wastes that are routinely generated is more certain  than
information  about waste streams that are not currently generated
on  a consistent basis.  An exception to this is data  about  the
U.S.  Navy  decommissioned  reactor plants.   This waste  is  not
routinely generated; however,  detailed information is documented.
in a May 1984 final environmental impact statement (5).  Thus, on
Exhibit  2-2,  estimates  for  commercial   wastes,   DOE/defense
"general"  wastes,  and  NARM wastes are relatively more  certain
because these wastes are currently generated.


Commercial Wastes

     Waste  streams  1 through 25 on Exhibit 2-2 describe  wastes
that   are  generated  by  commercial  sources.   As   previously
mentioned,  the  primary  source of information for  these  waste
streams  is  NRC   Update of Part 61 Impacts Analysis Methodology
(12).   In  the NRC document,  148 radioactive waste streams  are
identified  and  described.  Seventy of these waste  streams  are
generated  by commercial sources and were aggregated by EPA  into
the  25  waste streams that are listed in Exhibit  2-2.  5/   EPA
5/   In addition,  67 waste streams are labelled as "non-routine"
by  NRC.   The sources of these wastes include Three Mile Island,
West   Valley,   fuel   fabrication,   fuel   reprocessing,   and
decommissioning and decontamination wastes.  NRC also lists seven
NARM  wastes  and  two  military  wastes  that  are  occasionally
disposed  of at commercial facilities.  These waste  streams  are
described later in this section.
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segmented   waste   streams  according  to  volume,   source   of
generation, waste form, and radionuclide content.

     Exhibit  2-2  indicates that an  estimated  2,925,702  cubic
meters  and  12,744,504 curies of commercial low-level waste  are
expected  to  be generated from 1985 to  2004.  Commercial  waste
streams  are organized into four sub-categories:   power  reactor
wastes,  fuel cycle wastes,  industrial wastes, and institutional
wastes.  Power reactor wastes account for 59 percent of the total
commercial waste volume  and 75 percent of the total activity.

     Exhibit  2-2 indicates that the commercial waste category is
diverse.   For instance,  radioactivity, as measured in Ci/tonne,
ranges  from 0.000 Ci/tonne  (five waste streams have very  small
activity  concentrations that are rounded to 0.000  Ci/tonne)  to
2453.18  Ci/tonne  (reference number 21).  Sixteen waste  streams
have  activities less than 1 Ci/tonne,  two waste  streams   have
activities  of  1 to  10 Ci/tonne,  and seven waste streams  have
activities  greater  than 10  Ci/tonne.   In  addition,  fourteen*
commercial  waste  streams are identified as potential  land  BRC
candidates.   Each  of these waste streams have  activities  less
than .6 Ci/tonne.


DOS/Defense "General" Waste

     The  second  category in Exhibit 2-2 consists  of  low-level
wastes   generated  by  DOE/defense  activities.   These   wastes
currently are buried at DOE disposal sites.   In Exhibit 2-2,  we
use   the  six  waste   groups  that  are   defined   in    DOE's
Integrated  Data Base for 1986; uranium/thorium, fission product,
induced activity,  tritium,  alpha,  and "other".   DOE estimates
that 1,831,701 cubic meters and 27,473,055 curies of  DOE/defense
low-level wastes will be generated during 1985 to 2004.

     Compared  to  the  total volume and activity  of  commercial
wastes, DOE/defense "general" wastes have about 60 percent of the
volume and more than twice the number of curies. This category of
low-level waste is qualified as "general" because it is comprised
of  six  broad  groups of wastes that  are  routinely  generated.
Information  about DOE/defense low-level wastes is less  detailed
than commercial wastes because of security restrictions regarding
the sources generating the wastes.   The commercial waste streams
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are  divided into categories on Exhibit 2-2 according to  source;
however, no such organization can be provided for the DOE/defense
waste streams.
Naturally Occurring and Accelerator
Produced Radioactive Material (HARM)

     Naturally  occurring  and accelerator  produced  radioactive
material (NARM) is the third category listed in Exhibit 2-2. This
waste  category  includes such materials as radium  dials,  false
teeth,  and radioactive metals.   The NARM wastes that we consider
are  treated  as  regulated low-level waste by some  states  when
disposed on land.

     Exhibit 2-2 shows that an estimated 12,011,780 cubic  meters
and  6,609  curies  of NARM waste are expected  to  be  generated
during  1985 to 2004.   Compared to the total volume and activity
of commercial wastes,  NARM waste is about four times greater  in
volume   and  has  about  0.05  percent  of  the   radioactivity.'
Activated metals (reference number 36) accounts for 99.9  percent
of the total volume and 61.9 percent of the total activity.

     The  activated  metals waste stream consists of  alloys  and
welding  rods  containing thorium  or  thoria  (Th02),   aircraft
ballast, and radiation shielding constructed of depleted uranium.
These  items are discarded primarily by the industrial sector and
may  or  may  not be treated as low-level  waste  when  disposed,
depending  upon  state  regulations  and  the  practices  of  the
generator.   The radiation shielding that is sometimes present in
this waste stream may be considered hazardous under RCRA  because
of  the  presence of heavy metals such as lead and  mercury.   In
addition,  Annex  I  of the London Dumping  Convention  prohibits
ocean  disposal  of  specific compounds  or  materials  (such  as
mercury) that may be present in this waste stream.

     Unlike  commercial  LLRW,   NARM  waste  is  currently   not
regulated  by  federal  authorities.   All  of  the  NARM  wastes
considered  by  lEc  are regulated to differing degrees  by  some
state agencies.   Currently EPA,  using authority under the Toxic
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Substances Control Act (TSCA),  is considering uniform regulation
of   certain  NARM  wastes.    Activated  metals  are  not  being
considered for regulation under  this  concept. 6/


Decommissioning of Reactor and Fuel Cycle Facilities

     The  fourth  category on Exhibit 2-2 represents  the  wastes
generated   from   decommissioning   reactors  and   fuel   cycle
facilities.  The  projected volume for these wastes is  uncertain
because  the  data are dependent on the  schedule  of  commercial
light  water reactor shutdowns.    The timing associated with the
generation of these wastes may vary significantly if reactors are
upgraded to extend operating lifetimes, or if time is allowed for
radioactive  decay  before  decommissioning  takes  place.    DOE
assumes  that  it takes six years to fully decommission  a  light
water  reactor;  the first two years are spent planning  and  the
following  four  years  are spent decommissioning  the  facility.
Thus,  we  assume that low-level wastes are disposed of in  equal
volumes during the four years of decommissioning activities.

     Using  these assumptions,  lEc estimates that  13,982  cubic
meters  and  102,910 curies of low-level waste will be  generated
from   the   decommissioning  of  light  water   reactors   (both
pressurized  water  and boiling water)  from  1985  to  2004.   In
contrast,  for the twenty year period  following 2004 we estimate
that  at  least 873,491 cubic meters and 8,790,423 curies of low-
level  waste  will be generated.   These figures  indicate  a  63
percent  increase in volume and a 85 percent increase in activity
during the period from 2005 to 2024.

     In  addition,  this category includes low-level  radioactive
wastes  generated by DOE decontamination activities at Three Mile
Island  Unit 1 and West Valley.  These wastes are  classified  as
"non-routine"  by  NRG  Update of Part 61 because,  as  the  name
6/   The PEI report indicates which of nine aggregate  categories
of  NARM wastes are treated as low-level wastes when disposed  on
land.   NARM  wastes  such  as building materials  (BLDGMAT)  and
boiler  ash  (SLASH)  are  disposed  in  unregulated   landfills.
Agricultural NARM is not included by PEI, PHB or lEc.
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implies,   they will not be routinely generated over the next  20
years.   An estimated 23,690 cubic meters and 801,000 curies will
be generated during 1985 to 2004.7/ 8/


Remedial Action Waste

     The  fifth category on Exhibit 2-2 represents the  low-level
radioactive  wastes generated by remedial action  programs.   Two
DOE  programs  are responsible for the  generation  of  low-level
radioactive  wastes:  FUSRAP  (Formerly Utilized  Sites  Remedial
Action   Program)   and  SFMP  (Surplus   Facilities   Management
Program).9/  In addition, EPA's remedial action program under the
Comprehensive Environmental Response,  Compensation and Liability
Act  (CERCLA)  also generates LLRW.   At the  present  time,  ten
CERCLA  sites  with  LLRW are estimated to  be  on  the  National
Priorities  List  (NPL).   Further  investigation may  show  that
additional sites contain radioactive contamination.    We are not
able to estimate the nature or amount of this LLRW with currently.
available EPA information.   As a result,  our estimates for  the
remedial action category are likely to be understated.

     FUSRAP  was started in 1974 to decommission sites that  were
formerly  used  to  support  the  nuclear  activities  of   DOE's
predecessor agencies.   There are currently 29 FUSRAP sites in 12
states.   These  wastes  are  primarily  soils  containing  small
quantities of naturally occurring radioactive materials.  The New
7/    Niagara  Falls  Storage Site is included  in  the  remedial
action projections.

8/    The following report may provide additional information  on
decontamination  and decommissioning LLRW:  Sources of  Residual
Radioactivity In Decommissioning of Nuclear Facilities,   Roy  F.
Weston,  Inc.,  and S.  Cohen and Associates,  prepared for  EPA.
Contract No. 68-02-4375, December 1987.

9/    In addition to FUSRAP and SFMP there are two other remedial
action programs:   UMTRAP (Uranium Mill Tailings Remedial  Action
Program)  and  GJRAP  (Grand Junction Remedial  Action  Program).
Because  these programs do not generate waste that would  qualify
as LLRW, we have not included these volumes in our estimates.
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Jersey sites are separated from the other FUSRAP sites on Exhibit
2-2  because  ocean disposal is currently being considered  as  a
disposal  alternative  for the wastes from these  sites.   FUSRAP
estimates  that the total volume and activity for the New  Jersey
sites is 382,300 cubic meters and 150 curies.

     In  addition  to  FUSRAP,   SFMP  also  generates  low-level
radioactive  wastes.   This  program includes  320  radioactively
contaminated DOE-owned facilities that have been declared surplus
to  government needs.  Ocean disposal was presented as an  option
for  the  Niagara Falls  Storage Site in  the  April  1986  Final
Environmental  Impact Statement entitled Long-Term Management  of
the Existing Radioactive Wastes and Residues at the Niagara Falls
Storage  Site (3).  Detailed information on  total activities and
radionuclide  compositions of the other  SFMP wastes has not  yet
been  compiled.   The program estimates that within the  next  20
years at least 2,280,740 cubic meters will be generated.


U.S. Navy Decommissioned Reactor Plants

     The  final category listed on Exhibit 2-2 is the  U.S.  Navy
decommissioned   reactor   plants.    In  the  May   1984   final
environmental impact statement, ocean disposal is presented as an
option  for the 100 submarines that will be taken out of  service
in  the next 20 to 30 years (5).   Decommissioning 100 submarines
yields  362,870 tonnes of waste (note that no volume estimate  in
cubic  meters is available) and 6,200,000 curies.   According  to
U.S.  Navy  sources,  although  ocean disposal of  the  submarine
reactor  plants  had  been  explored,   it  is  no  longer  under
consideration.
ELIGIBILITY FOR OCEAN DISPOSAL

     In  order  for a waste stream to qualify as a candidate  for
ocean  disposal,  it is likely that it would have to conform with
criteria found in LOG,  existing ocean disposal regulations, IAEA
and BNL documentation.  These criteria include the upper activity
limits,  lower  activity limits (ambient levels) and  prohibition
of  co-contaminated wastes discussed in the first section of this
chapter.   In addition, to be a candidate for ocean disposal, the
LLRW  would  likely  have  to meet the  criteria  on  waste  form
developed by BNL.


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     One of these factors,  activity limits, imposes quantitative
limitations on the amount of radioactivity per tonne that  can be
disposed  in the ocean.  Another factor,  ambient concentrations,
indicates   which  waste  streams  do  not   have   radioactivity
concentrations  great enough to qualify as low-level  waste.  The
third factor,  co-contamination of low-level wastes, concerns the
existence of other hazardous constituents in LLRW.    Finally,  a
fourth criteria concerns a variety of requirements on waste form.

     In  order to consider the type and magnitude of  LLRW  which
might  be  eligible for ocean disposal,  lEc compared  each  LLRW
stream  shown in Exhibit 2-2 to the eligibility criteria in  each
of  these  four categories.   The sections below  describe  these
comparisons  and the resulting implications about the eligibility
of specific LLRW for ocean disposal.


Activity Limits

     IAEA  Safety Series No.  78 designates three upper  activity
limits that wastes must meet to be considered for ocean disposal.
A  low-level waste stream is ineligible for ocean disposal if its
radioactivity exceeds:

     o    1.35 Ci/tonne for alpha emitters,
     o    540 Ci/tonne  for beta-gamma emitters  with  half-
          lives > 1 year  (excluding tritium), and
     o    81,000 Ci/tonne for beta-gamma emitters with half-
          lives £ 1 year and tritium.

In addition, if transuranic elements with half-lives greater than
20 years exceed 100 nci/gram (or 0.1 Ci/tonne),  the waste stream
would be considered ineligible for ocean disposal.

     lEc  used data describing the radionuclide content  of  each
LLRW stream and standard references to calculate the activity per
tonne  in each of these categories for each LLRW stream shown  in
Exhibit  2-2.   The results are presented in Exhibit  2-3,  which
presents  activities  in  terms of Ci/tonne for  alpha  emitters,
beta-gamma  emitters  with  half-lives  greater  than  one   year
(excluding tritium), and beta-gamma emitters with half-lives less
than  or  equal  to one year (including tritium) of each  of  the
waste streams. The basic data describing concentrations of radio-
nuclides for each waste stream (including type of emitter and the
half-life  for each radionuclide) are listed in Appendix  A.  The


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concentration   of transuranic elements with  half-lives  greater
than  twenty  years  is also presented in terms of   Ci/tonne  in
Exhibit 2-3.

     Using the information in Exhibit 2-3, Exhibit 2-4 identifies
waste  streams that fail to meet the upper activity  limits.   As
Exhibit 2-4 shows,  three of the 45 waste streams do not meet the
proposed  criteria.   This  group of waste streams  includes  one
commercial  waste  stream,   one  NARM  waste  stream,   and  one
DOE/defense  waste stream.  The far right column of  the  exhibit
shows which of the activity limits is exceeded.

     The  DOE/Defense LLRW stream which fails to meet  the  alpha
activity  limit is stream 26,  entitled uranium/thorium.   As for
all DOE/Defense LLRW, no data on densities are available and thus
we  assumed  a density of l gram per cubic  centimeter  (that  of
water) in completing the activity per tonne calculations.   Given
the relatively high densities of uranium and thorium,  this waste
in  fact  may  be substantially more dense than  water.   If  the
waste's actual density is greater than water by a factor of  2.15
or more,  it would be below the alpha emission limit and would be
eligible for ocean disposal under this set of criteria.


Ambient Concentrations

     In addition to using upper activity limits to evaluate waste
stream  eligibility,  we reviewed limited  ambient  radioactivity
concentrations  in the deep ocean.   These ambient concentrations
could  serve as lower activity limits to define what  constitutes
low-level  wastes.   If that option were selected,  LLRW  streams
with  an activity concentration less than ambient  concentrations
could  be  disposed in the ocean without regard  to  radionuclide
content.

     We  were able to find only limited data  describing  ambient
radioactivity  concentrations in deep ocean (>3500 meters)  water
and   sediments.     Exhibit   2-5   lists   available    ambient
concentrations  of selected anthropogenic and naturally occurring
radionuclides  measured in the deep ocean within about 100  miles
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of the coast for the North Atlantic and North Pacific oceans. 10/
None  of  the forty-five waste streams described in  Exhibit  2-2
have   activity  concentrations  lower  than  the  ambient   con-
centrations listed in the exhibit.   However,  ambient concentra-
tions  might be larger than presented in Exhibit 2-5 if  data  on
more  nuclides  or for a broader range of sites  were  available.
Thus,  it  is  not possible to state definitively that  all  LLRW
shown  on Exhibit 2-2 would exceed ambient activity levels at all
possible disposal sites.


Co-Contamination

     As  shown  on Exhibit 2-1,  Annex I of  the  London  Dumping
Convention  outlines general prohibitions on the disposal of  the
following substances:

     o   Organohalogen compounds,
     o   Mercury and mercury compounds,
     o   Cadmium and cadmium compounds,
     o   Crude oil and petroleum products, and wastes, and
     o   Persistent and floatable plastics and synthetics.

The above constituents are considered "trace contaminants" if the
disposal  of  these  contaminants  will  not  cause   significant
undesirable   effects.    "Undesirable   effects"   include   the
possibility   of   danger  associated  with  bioaccumulation   of
substances  in  marine  organisms.   EPA  is  developing  testing
protocols  to measure the potential for  significant  undesirable
effects.

     In addition, the limitations on co-contaminants do not apply
when  it can be shown that contaminants are present  as  chemical
compounds or forms that are non-toxic to marine life and are non-
bioaccumulative  in the marine environment upon disposal,  or  if
10/   Information about anthropogenic nuclides was obtained  from
Dr.  Hugh Livingstone from the Woods Hole Oceanographic Institute
in a telephone interview.   Information about naturally-occurring
nuclides was obtained from a 6 January 1987 memorandum written by
James  Neiheisel,   Economics  and  Control  Engineering  Branch,
addressed  to Kung-Wei Yeh,  Environmental Studies and Statistics
Branch, both at EPA.
                              2-14

-------
upon  disposal,  they rapidly become non-toxic to marine life and
non-bioaccumulative  in  the marine environment  by  chemical  or
biological  degradation.   Disposal  of constituents under  these
terms  is  allowed  only  if they will  not  make  edible  marine
organisms unpalatable, or will not endanger the health of humans,
domestic animals, fish, shellfish, or wildlife, ll/

     Thus,  the  presence  of co-contaminants may eliminate  some
LLRW  streams  on  Exhibit 2-2 from  being  considered  as  ocean
disposal candidates.  In order to help lEc identify waste streams
which may be contaminated with the constituents listed above, EPA
contracted   with  Brookhaven  National  Laboratory.   Brookhaven
provided general information about co-contamination of commercial
and DOE wastes.
Co-contamination of Commercial Wastes

     lEc  used three NRC documents supplied by Brookhaven to make
rough  approximations regarding co-contamination of  the  twenty-
five  commercial waste streams on Exhibit 2-2.   These  documents
include Management of Radioactive Mixed Wastes in Commercial Low-
Level  Waste (11); An  Analysis of  Low-Level Wastes:  Review  of
Hazardous  Waste  Regulations and Identification  of  Radioactive
Mixed Wastes (9);  and Document Review Regarding Hazardous  Chem-
ical  Characteristics  of  Low-Level  Waste (10).   These reports
providegeneralinformation and classify LLRW  into  categories
such  as  wastes  containing  organic  liquids,   lead-containing
wastes,   chromium-containing   wastes,   and  mercury-containing
wastes.  Analysis is difficult as the reports do not specifically
refer  to the waste streams listed on Exhibit 2-2,  nor  do  they
address  all of the contaminants  of concern listed in Annexes  I
and  II  of  the  London Dumping  Convention  and  current  ocean
disposal regulations (40 CFR 227.5 and 227.6).
ll/   These   provisions  are  present  in  order  to   implement
prohibitions found in the Convention on the Prevention of  Marine
Pollution  by Dumping of Wastes and Other Matter (London  Dumping
Convention).
                              2-15

-------
     lEc  used  the  information  in  these  three  documents  to
identify  which  commercial LLRW streams potentially include  co-
contaminants.   Exhibit  2-6 lists these waste  streams.  As  the
exhibit shows,  from 19 to 22 of the twenty-five commercial waste
streams  may contain contaminants.   These  co-contaminated  LLRW
streams  account  for  78 to 93 percent of the  total  commercial
volume  and  virtually  all of  the  radioactivity  contained  by
commercial LLRW.

     Because  the NRC documents do not refer to the specific LLRW
groups used by lEc,  our identification of co-contaminated wastes
is  uncertain and may be too inclusive.    In addition,  the  NRC
documents  did  not consider all co-contaminants  listed  in  the
proposed   ocean   regulations.      Thus,   a    more   thorough
investigation  is  necessary to determine  with  certainty  which
specific  commercial wastes are contaminated by the  constituents
listed  in  the  proposed  ocean regulations  and  whether  these
contaminants exceed trace levels.
Co-contamination of DOE/Defense Wastes

     Dr. Peter Colombo of Brookhaven National Laboratory provided
the  following information regarding the  co-contamination of DOE
low-level  wastes.   Virtually all DOE waste streams  originating
from  defense  activities or fuel reprocessing consist  of  mixed
wastes.   In addition, unlike commercial wastes streams, DOE low-
level wastes from different origins are often combined into tanks
or  other storage facilities.   These mixtures of DOE wastes  are
not  adequately characterized with regard to  hazardous  chemical
content.    Thus,  it is likely that most or all DOE/Defense LLRW
streams have co-contaminants present at some level.


Co-Contamination of Other Wastes

     IEC   was  not  able  to  find  information  describing  co-
contamination  of the other LLRW categories shown in Exhibit 2-2.
Thus,  we  are  not  able  to determine  the  likelihood  of  co-
contamination for these wastes.   However, lEc was able to obtain
detailed  information  about  the co-contamination  of  a  single
remedial   action   waste   at  the  New  Jersey   FUSRAP   site.
Concentrations  of contaminants such as volatile  organics,  acid
extractable   compounds,   base/neutral  extractable   compounds,


                              2-16

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pesticides  and  PCB's,  and  toxic metals  were  measured  above
detection limits at different locations at the New Jersey  sites.
We  believe that the presence of co-contaminants in many remedial
action  streams  is  likely;   further research  is  required  to
determine the nature of these co-contaminants.
Summary

     Co-contamination  of  LLRW may prevent  streams  from  being
considered  as ocean disposal candidates.  Because of  inadequate
information,  lEc  was not able to conclude with certainty  which
LLRW  streams are contaminated by the constituents identified  in
the  current  ocean disposal regulations and Annexes I and II  of
the London Dumping Convention.  In addition,  it is possible that
treatment  processes may affect a waste stream's eligibility  for
ocean  disposal  by removing hazardous  constituents.   Based  on
available  information,  it appears likely that large amounts  of
the  commercial,  DOE/Defense and remedial action LLRW  shown  on
Exhibit 2-2 include co-contaminants.
Waste Form

     EPA is currently considering research provided by Brookhaven
National   Laboratory  on  possible  waste  form  criteria  which
includes the following;12/

     (1)  The  specific  gravity of the waste package  shall
          not  be  less than 1.2 to ensure  sinking  to  the
          seabed;

     (2)  The  waste package shall remain intact upon impact
          on the ocean floor;

     (3)  The  waste  container  should  have  an   expected
          lifetime of 200 years in the deep sea environment;
12/  An  updated study of waste package performance  criteria  is
expected  to  be  available by Fall  1988.   Thus,  some  of  the
following specifications may be subject to changes.
                              2-17

-------
      (4)  Aqueous  wastes  should be solidified  to  form  a
          homogenous,   monolithic,   free   standing  solid
          containing  no more than 0.5 percent (by  volume),
          or  1.0  gallon  (3.8 liters) of  free  or  unbound
          water per container, whichever is less;

      (5)  Buoyant   waste  material  shall  be  excluded  or
          treated  to  preclude its movement  or  separation
          from the waste form during and after disposal;

      (6)  The waste form shall have an uniaxial  compressive
          strength  not less than 150 kg/cm2,  provided that
          it  does not contain large voids  or  compressible
          materials;

      (7)  The  leach rate of the waste form shall be as  low
          as reasonably achievable.

      (8)  Particulate  wastes such as  ashes,  powders,  and
          other  dispersible materials should be immobilized
          by a suitable solidification agent;

      (9)  No  radioactive  gaseous wastes shall be  accepted
          for   ocean   disposal  unless  they   have   been
          immobilized  into  stable waste  forms  such  that
          over-burden pressure in the waste package does not
          exceed atmospheric pressure; and

      (10) Explosive   and  pyrophoric  materials  shall   be
          excluded from LLW ocean disposal sites.

     In order to determine which waste streams on Exhibit 2-2 are
not  likely  candidates for ocean disposal due to the  BNL  waste
form criteria,  EPA requested assistance from Brookhaven National
Laboratory.   Brookhaven  was  asked  to   identify  those  waste
streams  for  which  compliance with the waste form  criteria  is
judged  technically  infeasible  or  too  expensive.   Given  the
limited information available, Brookhaven classified LLRW streams
into  two  "eligible  for ocean  disposal"  categories  (entitled
"solidify as is", and "requires pretreatment") and an "ineligible
for ocean disposal" category (entitled "does not meet criteria").
In addition,  Brookhaven identified those wastes with "not enough
information".   These  classifications for each LLRW  stream  are
presented in Exhibit 2-7.
                              2-18

-------
     Brookhaven identified ten waste streams,  eight of which are
commercial,  as  low-level  wastes that can be solidified in  the
form  that the wastes are generated.  Fifteen waste streams  were
identified  as "requires pretreatment".    Waste streams in these
categories represent about 20 percent of the total volume and  22
percent  of the total activity for all wastes included in Exhibit
2-2.

     There  are twenty waste streams that Brookhaven was not able
to  judge due to lack of information.   These wastes account  for
the  remaining 80 percent of the total volume and 78  percent  of
total  activity  for all wastes included in Exhibit 2-2.  Lack of
information  means that either the information needed to  make  a
judgement  was  not readily available to Brookhaven or  that  the
necessary information does not exist.
SUMMARY

     This  chapter has discussed the definitions of LLRW used  by
EPA's  ocean  disposal  and  land  disposal  programs,   and  has
presented our estimates of the quantity and radioactivity of LLRW
likely  to be considered for ocean disposal.   In  addition,  the
third  section of the chapter used several criteria to review the
eligibility  of  LLRW streams for ocean  disposal.   The  overall
conclusions of the chapter are summarized in the first chapter of
this report.
                              2-19

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                                                                      Exhibit 2-1

                                                 Comparison of Low Level Radioactive Waste Definitions
                                            A Working Definition for Ocean Versus Land Disposal Definitions
                    Ocean
Source               IAEA, EPA working definition of low-level waste and exist-
                     ing ocean disposal regulations.  (40 CRF 220 et seq.).
Lower Activity      LLRW does not include "wastes containing only ambient con-
Limit               centrations of naturally occurring radioactivity and
                    anthropogenic radionuclides attributable to global fallout
                    from nuclear weapons testing."

Upper Activity      LLRU cannot be high level radioactive waste defined as:
Limit               aqueous wate resulting from the operation of the first
                    cycle solvent extraction system, or equivalent,  and the
                    concentrated waste from subsequent extraction cycles,  or
                    equivalent, in a facility for processing irradiated reactor
                    fuels, or irradiated fuel from nuclear power reactors, and
                    specifically includes the following:

                    1)  Irradiated reactor fuel; liquid wastes from  the chemical
                    reprocessing of irradiated reactor fuel from the first
                    solvent extraction cycle, or equivalent processes,  and the
                    concentrated wastes from subsequent extraction cycles, or
                    equivalent process, and solidified forms of such wastes; and

                    2)  any other waste or matter of activity concentration
                    exceeding:
                                                                                    Land
        Draft Generally Applicable Environmental Standards  for  Management
        and Disposal of LLU (40 CFR  193)  under AEA Reorganization Plan
        3 and Toxic Substances Control Act (40 CFR 764)  for NARH.

        None for most LLRU.  Disposal of naturally-occurring or accelerator
        produced material (NARH) with activity <.002 Ci/tonne would not be
        regulated by EPA.
        LLRW cannot be high level radioactive waste defined as:
        1) highly radioactive material resulting from the reprocessing  of
        spent nuclear fuel, including liquid waste produced directly in
        reprocessing and any solid material derived from such  liquid waste
        that contains fission products in sufficient concentrations.

        2) other highly radioactive material that the Nuclear  Regulatory
        Comnission, consistent with existing law, determines by  rule
        requires permanent isolation.
                    (!)  alpha emitters:   1.35 Ci/tonne *
                    (ii) beta-gamma emitters with  half-lives > 1  year;  *
                         540 Ci/tonne (excluding tritium)
                    (iii) tritium and beta-gamma emitters  with half-Lives
                         < 1 year:  81,000 Ci/tonne •
or
                    * Converted from IAEA Safety Series  No.  78

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                                                                       Exhibit 2-1

                                                        Comparison of  Low  Level Radioactive Waste
                                                   Definition for  Ocean Versus Land Disposal Programs
                                                                       (continued)
Other
Specifications
Ocean
No disposal of transuranic radioactive wastes, as defined
in 40 CFR 191.Oli, (which are wastes with > 100 nano-
curies/gram of alpha emitters with half-lives > 20 years.)

Limit LLRU disposed so that maximum dose to an individual
from ocean disposal is only a small fraction of 100
mi Ui ran/year.
                                                                Land
                    No disposal of free radioactive gases.

                    Unless only present as trace contaminants, LLRU which
                    contains the following may not be disposed:
                    -  organohalogen compounds
                    •  mercury and mercury compounds
                    -  cadmium and cadmium compounds
                    -  crude oil/petroleum products and wastes
                    -  persistent and floatable plastics/synthetics.
No disposal of transuranic radioactive wastes, as defined
in 40 CFR 191.Oli, (which are wastes with > 100 nano-
curies/gram of alpha emitters with half-lives > 20 years.

Disposal of LLRU which presents < 4 milLirem annual exposure
dose via less restrictive disposal methods may qualify as
as "Below Regulatory Concern" (BRC) wastes.  NRC and DOE will
use EPA's general criterion (4 millirem per year) in conjunction
with their respective requirements to determine which specific
requirements to determine which specific LLRU qualifies as a BRC
waste.

No disposal of uranium and thorium by-product materials (mill
tailings) as defined in the Uranium Hill Tailings Radiation Control
Act of 1978.

No disposal of spent nuclear fuel  (considered high level waste).

No disposal of by-product material as defined in section 11e(2) of
the Atomic Energy Act of 1954.
Source:   See text.

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                                                                           Exhibit 2-2
                                                         Description of Lou-Level Radioactive Wastes
                                                             Total
Reference
Number Waste Stream
Total Volume
1985-2004
(cubic meters)
Activity
1985-2004
(curies)
Density
(g/cntt) Ci/tonne
Important Radionucl ides
(percentage of waste stream
radioactivity)
Potential
Land BRC
Candidate? *
COMMERCIAL WASTES

                POWER  REACTOR WASTES
         1       PUR  Compactible
                Trash  (P-COTRASH)

         2       BWR  Compatible
                Trash  (B-COTRASH)

         3       LWR  Noncompactible
                Trash  (L-NCTRASH)

         4       LWR  Ion Exchange
                Resins (L-IXRESIN)

         5       PWR  Filter
                Cartridges (P-FCARTRG)

         6       LWR  Filter Sludge
                (L-FSIUDGE)
        7      LWR Concentrated
               Liquids (L-CONCLIO)

        8      LWR Decontamination
               Resins (L-OECONRS)
265,285
332,217
478,210
 12,833
330,646
  2,241
 17,840        .4       0.170
 10,560        .3       0.110
160,500        .4       0.840
 99,128        1,330,527        .9        14.9
 58,240       1.3       3.490
130,770        1.108.000        .9       9.410
399,127       1.7       0.710
 52.430
.9      26.000
C-14(.03); Co-60(35.9);                     Y
Sr-90(.06); Cs-137(12.6); Fe-55(19.3)

C-14(.03); Co-60(35.9); Sr-90(.06);         Y
Cs-137(12.6); Fe-55(19.3)

C-14(.04); CO-60C39.1); Sr-90(.07);         H
Cs-137(10.6); Fe-55(20.5)

C-14(.09); Co-60(9.9); Sr-90(.2);           N
Cs-137(26.7); Cs-134(26.7); Ba-137m(26.7)

C-14(.002); Co-60(56.8); Sr-90(.Q04);       N
Cs-137(.5); Fe-55(29.5)

C-K(.OI); CO-60C31.0); Sr-90(.03);         N
Cs-137(16.4); Fe-55(16.4); Cs-134(16.4);
Ba-137m(16.4)

C-14(.06); Co-60(27.8); Sr-90(.11);         M
Cs-137(16.7); Cs-134(16.7); Ba-137m(16.7)

CO-60C80.8);  Fe-55(11.2)                    N

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                                                                         Exhibit 2-2

                                                        Description of Lou-Level Radioactive Wastes
                                                                        (Continued)
Reference
 Number
               Waste Stream
Total Volume
1985-2004
(cubic meters)
Total
Activity
1985-2004    Density
(curies)     (g/emS)
                                                                                      Ci/tonne
Important Radionuclides              Potential
(percentage of waste stream)         Land BRC
radioactivity)                       Candidate' *
               Nuclear Fuel Rod
               Components (L-NFRCOHP)

               Subtotal:
       64,510
                                              1.715,840
  6,450,000       7.8      12.820      C-14(.OD;  Co-60(39.8)
                     9,587,224
               FUEL CYCLE WASTES
       10      Fuel-Fabrication
               Compactible Trash
               (F-COTRASH)

       11       Fuel-Fabrication
               Honcompactible Trash
               (F-NCTRASH)

       12       Fuel-Fabrication
               Process Waste
               (F-PROCESS)

       13       UF(6)  Processing
               Waste  (U-PROCESS)
      179,481
       31,725
       59,457
      21,387
          6       0.2       0.000       U-234(82.7); U-238(13.6)
          1        0.4       0.000      11-234(82.8); 11-238(13.6)
         37       1.0       0.001      11-234(82.8); U-238(13.6)
         16       1.0       0.001      U-234(4B.3>; U-238(48.3)
               Subtotal:
                                                292,050
                           60

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                 Exhibit 2-2

Description of Low-Level Radioactive Wastes
                 (Continued)
     Total
Reference
Number

14

15

16
17
18
19
20
21
Waste Stream
INDUSTRIAL WASTES
Industrial Special
Source Trash
(H-SSTRASH)
Industrial Special
Source Waste
(N-SSWASTE)
Industrial Low-
Activity Trash
(N-LOTRASH)
Industrial Low-
Activity Waste
(N-LOWASTE)
Isotope Production
Waste (N-ISOPROD)
Tritium Waste
(N-TRITIUN)
Accelerator Targets
(N-TARGETS)
Sealed Sources
(N-SOURCES)
Subtotal:
Total Volume Activity Important Radionuclides Potential
1985-2004 1985-2004 Density (percentage of waste stream) Land BRC
(cubic meters) (curies) (g/cm3) Ci/tonne radioactivity) Candidate? *

359,462 4 0.15 0.000 U-238(76.5); U-234(21.7)

63,435 14 1 0.000 U-238C76.7); U-234(22.3)

101,462 3,705 0.2 0.180 C-14(4.5); Co-60(8.9); Sr-90(1.2);
Cs- 137(3. 9); H-3(77.7)
60,307 1,332 0.5 0.040 C-14(4.2); Co-60(6.7); Sr-90(5.9);
Cs- 137(4. 7)
9.967 833,900 0.5 167.330 C-14(.Q001); Co-60(1.8); Sr-90(84.7);
Cs-137(5.7); H-3(73.8)
6,941 1.536,000 0.6 368.820 C-14(.1); H-3C99.9)
223 173,900 0.4 1949.550 H-3(100>
582 571,100 0.4 2453.180 C-14(.OOOS); Co-60(2.3); Sr-90(3.84);
Cs- 137(45. 4)
602,379 3.119.955

Y

Y

Y
Y
N
N
N
N

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                 Exhibit 2-2
Description of Lou-Level Radioactive Wastes
                 (Continued)
     Total
Reference
Number

22
23
24
25
DOE/DEFENSE
26
27
28
29
30
31
Waste Stream
INSTITUTIONAL WASTES
Institutional Com-
pact ible Trash
(I-COTRASH)
Biological Waste
(I-BIOUAST)
Absorbed Liquids
(I-ABSLIQD)
Liquid Scintilla-
tion Vials (I-LQSCNVL)
Subtotal :
Total Commercial:
"GENERAL" LLW
Uranium/thoriun
Fission product
Induced activity
Tritiun
Alpha, <10 nCi/g
"Other"
Total DDE/Defense:
Total Volume Activity Important Radionuclides Potential
1985-2004 1985-2004 Density (percentage of waste stream) Land BRC
(cubic meters) (curies) (g/cro3) Ci/tonne radioactivity) Candidate? *

281.747 33. HO .2 0.590 C-14(4.5); Co-60(8.8); Sr-90(1.2);
Cs-137(3.9); H-3(77.4)
7,520 1.616 1.1 0.200 C-14(4.7); Co-60(1.9); Sr-90(3.9);
Cs-137(4.1); H-3(81.4)
11,126 2,365 1 0.210 C-14(3.B); Co-60(14.6); Sr-90(2.0);
Cs-137(6.4); H-3(66.7)
15,040 144 .9 0.010 C- 14(2. 6); Sr-90(45.2); H-3(52.2)
315,433 37,265
2,925,702 12.744,504

415,796 3,569,945 1 8.590 U-238(33.1); Pa-234m(33.1>;
Th-234(33.1)
774.809 7,947.008 1 10.257 Co-60(.08); Sr-90(7.7); Cs- 137(17. 6);
Ba-137m(16.1)
329,706 6.487.987 1 19.678 Co-60(.9); Co-58(55.4); Hn-54(38.1)
32.971 12,199,899 1 370.024 H-3(100)
239,953 93.129 1 0.390 Pu-241(96.5)
38,466 745,032 1 19.369 C-14(.06); Co-60(18.0); Sr-90(8.5);
Cs-137(19.1): Ba-137m(16.8)
1,831,701 27.473,055

Y
Y
Y
Y

N/A
N/A
N/A
N/A
N/A
N/A

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                                                                  Exhibit 2-2

                                                 Description of Lou-Level Radioactive Wastes
                                                                  (Continued)
                                                      Total
Reference
Nimber
Waste Stream
NATURALLY OCCURRING and ACCELERATOR
DISCRETE HARM WASTES
32 Radiun Sources
(R-RASOURC)
33 Radium Ion
Exchange Resins
(R-RAIXRSN)
Total Volume Activity
1985-2004 1985-2006 Density
(cubic meters) (curies) (g/cm3) Ci/tonne
PRODUCED RADIOACTIVE MATERIALS (HARM)
0.445 623 4 350.000
6.600 119 .9 0.020
Important Radionuclides Potential
(percentage of waste stream) Land BRC
radioactivity) Candidate? *
Ra-226(16.6); Rn-222(16.6); Y
Bi-214(16.6); Po-210(16.6);
Pb-214(16.6); Pb-210(16.6)
Ra- 226(28. 6) Y
34      Instruments-Diffuse
        Widely Distributed
        (R-INSTDF1)

35      Instruments-Diffuse
        Collectible
        (R-INSTDF2)
                                   5,030
                                     150
1.770
                                                                          0.080
                                                                          0.008
Ra-226(37.2)
                                 Ra-226(37.2)
36
DIFFUSE NARN WASTES

Metals
CR-METWAST)
                                      12.000,000
4,092
                                                                                 0.000
U-234(43.4); U-238(43.4)
                                                                                                                                       N/A
        Total HARM:
                                      12.011.780
                                                    6.609

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                                                                          Exhibit 2-2

                                                         Description of Low-Level Radioactive Wastes
                                                                          (Continued)
                                                              Total
Total Volume
Reference 1985-2004
Number Waste Stream (cubic meters)
DECOMMISSIONING OF REACTOR AND FUEL CYCLE FACILITIES
37 Pressurized Water (PWR) 13.416
38 Boiling Water (BUR) 566
(e.q. TMI. West Valley)
Total Decommissioning: 37,672
REMEDIAL ACTION PROGRAMS
FUSRAP
40 NJ 382,300
SFMP
42 Niagra Falls Storage Site 123,740
other e,nf, \HI\J
44 CERCLA 	
Total Remedial Action: 3,626,625
U.S. NAVY
45 Decommissioned Reactor 362.870
Plants (for 100 submarines) tonnes
Activity Important Radionuclides Potential
1985-2004 Density (percentage of waste stream) Land BRC
(curies) (g/crn3) Ci/tonne radioactivity) Candidate? *

94,181 1 7.0 Co-60(28.4>; Sr-90(.001); N/A
Cs-137(1.12); T(1/2)<5 yr(67.9)
8,729 1 15.4 C-14(.003); Co-60(16.7); N/A
Sr-90(.01); T(1/2)<5 yr(79.5)

903,910

150 1 0.000 Ra-226(20); Th- 232(60); N/A
U- 238(20)

	 • 	 • 	 No Data 	 N/A

	 No Data 	 • 	

6,200,000 1 17.085 Co-60<35.5); Ni -63(29.0); N/A
Fe-55(27.4)
Source:  See text.
*  NRC and DOE will determine which LLRW may be classified as BRC waste.

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                                            Exhibit 2-3
                         Radioactivity By Emitter - Type for  Low Level
                                       Radioactive Wastes
                                                             Beta-gamma
                                            Beta-gamma       Emitters
Emitters Half-Lives <1 yr
Reference Alpha Emitters Half- lives >1 yr and Tritium
Number Waste Stream Ci /tonne Ci/tonne Ci/tonne
COMMERCIAL WASTES
POWER REACTOR WASTES
1 PWR Compatible 0.001 0.2SO 0.015
Trash (P-COTRASH)
2 BWR Compact ible 0.001 0.140 0.020
Trash (B-COTRASH)
3 LWR Noncompactible 0.007 0.740 0.890
Trash (L-NCTRASH)
4 LUR Ion Exchange 0.120 11.300 4.700
Resins (L-IXRESIN)
5 PWR Filter 0.032 3.450 0.018
Cartridges (P-FCARTRG)
6 LWR Filter Sludge 0.016 7.840 1.540
(L-FSLUOGE)
7 LWR Concentrated 0.008 0.620 0.130
Liquids (L-CONCLIQ)
8 LWR Decontamination 0.038 25.970 0.000
Total TRU's
Present
Ci/tonne


0.000
0.000
0.008
0.009
0.001
0.001
0.001
0.034
Resins (L-OECONRS)

-------
                                                      Exhibit 2-3
                                        Radioactivity By Emitter -  Type for Lou Level
                                                      Radioactive Wastes
                                                      (Continued)
Reference
 Number
               Waste Stream
Alpha Emitters
Ci/tonne
                 Beta-gamma
Beta-gamma       Emitters
Emitters         Half-Lives <1  yr      Total  TRU's
Half-lives >1 yr and Tritium           Present
Ci/tonne         Ci/tonne              Ci/tonne
               Nuclear Fuel Rod
               Components (L-NFRCOMP)
        0.000
                             12.820
                                                                                      0.000
                                                                                                       No TRU
               FUEL CYCLE WASTES
       10      Fuel-Fabrication
               Compactible Trash
               (F-COTRASH)

       11      Fuel-Fabrication
               Noncompactible Trash
               (F-NCTRASH)
        0.000
        0.001
                              0.000
                              0.000
                                               0.000
                                               0.000
                                                                                                       No TRU
                                                                No  TRU
       12      Fuel-Fabrication
               Process Waste
               (F-PROCESS)
        0.000
                              0.001
                                                                                      0.000
                                                                                                       NO TRU
       13      UF(6>  Processing
               Waste  (U-PROCESS)
        0.000
                              0.001
                                              0.000
                                                                                                       No TRU

-------
                                                      Exhibit 2-3
                                        Radioactivity By Emitter -  Type for  Low  Level
                                                      Radioactive Wastes
                                                      (Continued)
Reference
 Number        Waste Stream
                         Alpha Emitters
                         Ci/tonne
                            Beta-gamma
           Beta-gamma       Emitters
           Emitters         Half-Lives <1 yr      Total  TRU's
           Half-lives >1 yr and Tritium           Present
           Ci/tonne         Ci/tonne              Ci/tonne
       U      Industrial Special
               Source Trash
               (N-SSTRASH)
                                 0.000
                                                                      0.000
                                                                        0.000
                                                                                                       No TRU
       15      Industrial Special
               Source Waste
               (N-SSWASTE)
                                 0.000
                                                                      0.000
                                                                                      0.000
                                                                                                       NO TRU
       16
               Industrial Lou-
               Activity Trash
               (N-LOTRASH)
                                 0.000
                                                                      0.100
                                                                                      0.100
                                                                                         0.000
       17
Industrial Lou-
Activity Waste
(N-LOWASTE)
0.000
                                                                     0.210
                                                                       0.001
                                                                                                       No TRU
       18      Isotope Production
               Waste (N-ISOPROO)
                                 0.093
                                                                     78.700
                                                                       4.900
                                                         0.090
       19
Tritium Waste
(N-TRITIUH)
0.000
                                                                     0.000
                                                                                    368.760
                                                                                                       No TRU
       20      Accelerator Targets
               (N-TARGETS)
                                 0.000
                                                       0.000
                                                                                   1954.380
                                                                                                       No TRU
       21
               Sealed Sources
               (N-SOURCES)
                                 5.890
                                                    1261.800
                                                                                   1183.500
                                                                                                        5.900

-------
              Exhibit 2-3
Radioactivity By Emitter  -  Type  for  Lou Level
              Radioactive Wastes
              (Continued)
                                    Beta-gamma
                   Beta-gamma        Emitters
Reference
Number
22
23
24
25
JOE /DEFENSE
26
27
28
29
30
31
Emitters Half-Lives <1 yr
Alpha Emitters Half-lives >1 yr and Tritium
Waste Stream Ci/tonne Ci/tonne Ci/tonne
Institutional Com- 0.000 0.100 0.500
pactible Trash
(I-COTRASH)
Biological Waste 0.000 0.000 0.200
(I-BIOWAST)
Absorbed Liquids 0.000 0.100 0.100
(I-ABSL1QD)
Liquid Scintilla- 0.000 0.011 0.000
tion Vials (I-LQSCNVL)
"GENERAL" LLU
Uranium/thorium 2.880 0.002 5.730
Fission product 0.000 3.650 6.600
Induced activity 0.000 0.170 19.510
Tritium 0.000 0.000 0.037
Alpha. <10 nCi/g 0.400 0.000 0.000
"Other" 0.000 11.800 7.600
Total TRU's
Present
Ci/tonne
0.000
No TRU
No TRU
No TRU

No TRU
No TRU
No TRU
No TRU
0.013
No TRU

-------
                                                       Exhibit 2-3
                                         Radioactivity By Emitter - Type for Low Level
                                                       Radioactive Wastes
                                                       (Continued)
 Reference
  Number
                Waste Stream
Alpha Emitters
Ci/tonne
                 Beta-gamma
Beta-gamma       Emitters
Emitters         Half-Lives <1 yr      Total TRU's
Half-lives >1 yr and Tritium           Present
Ci/tonne         Ci/tonne              Ci/tonne
NATURALLY OCCURRING and ACCELERATOR PRODUCED RADIOACTIVE MATERIALS (HARM)

                DISCRETE NARH WASTES
        32      Radium Sources
                (R-RASOURC)

        33      Radium Ion
                Exchange Resins
                (R-RAIXRSM)

        34      Instruments-Diffuse
                Widely Distributed
                (R-INSTDF1)

        35      Instruments-Diffuse
                Collectible
                (R-INSTDF2)

                DIFFUSE NARH WASTES

        36      Metals
                (R-HETWAST)
    49100.000
        0.060
        0.010
        0.010
        0.000
                              0.000
           0.000
                              0.000
                              0.000
                              0.000
                                            9740.000
                                               0.010
                                               0.001
                                               0.001
                            0.000
                                                                No TRU
                                                                No TRU
                                                                No TRU
                                                                No TRU
                                                                NO TRU

-------
 Reference
  Number
                Waste Stream
                                       Exhibit 2-3
                         Radioactivity By Emitter - Type for Lou Level
                                       Radioactive wastes
                                       (Continued)

                                                             Beta-gamma
                                            Beta-gamma       Emitters
                                            Emitters         Half-Lives <1  yr
                         Alpha Emitters     Half-lives >1 yr and Tritium
                         Ci/tonne           Ci/tonne         Ci/tonne
                                                    Total  TRU's
                                                    Present
                                                    Ci/tonne
DECOMMISSIONING OF REACTOR AND
FUEL CYCLE FACILITIES

        37      Pressurized Water (PUR)

        38      Boiling Water (BUR)

        39      DOE "SPECIAL PROJECTS"
                (e.g. THI, Uest Valley)

REMEDIAL ACTION PROGRAMS

                FUSRAP

        40         NJ

        41         other

                SFMP
        42


        43

        44

U.S. NAVY

        45
                                 0.000

                                 0.000
   Niagra Falls
   Storage Site

   other

CERCLA
                Decommissioned Reactor Plants
                (for 100 submarines)
No data



No data


No data

No data



    0.0
                       15.510

                        6.940
0.090

0.074
                                                       1.400
                                                                       15.700
                                                                                        No TRU
                                                          No  TRU
                                                                                        No TRU
                                                                                        No TRU
Source:   See text.

-------
                                                         Exhibit 2-4

                                           Low Level  Radioactive Wastes  that Exceed
                                                   Upper Activity Limits
Reference
Number
Waste Stream

 Sealed Sources
(N-SOURCES)
U.S. Total
1985-2004
(cubic meters)

     582
Total
Activity
1985-2004
(curies)
                                                      571,100
                                                                             Activity Limit Exceeded
               2453.18    Exceeds TRU limit,  exceeds upper activity limit
                          for alpha and beta-gamma emitters half-life
                          greater than one year.
26
             Uranium/Thorium       415,796          3,569,945         8.59   Exceeds  upper activity  limit  for alpha emitters.
                                                                             Note:  may be caused by density assumption.
32
             Radium Sources
             (R-RASOURC)
   0.445
      623       350.00   ' Exceeds upper activity limit for alpha emitters.
Source:   IEc analysis.

-------
                           Exhibit 2-5

              AMBIENT RADIOACTIVITY CONCENTRATIONS
                        IN THE DEEP OCEAN
                           (Ci/Tonne)
     Radionuclide

Anthropogenic

       Pu-239
       Cs-137
       Sr-90
       Am-241
 North
Atlantic
 Water
  5 E-13
1.5 E-ll
  1 E-ll
1.5 E-13
  North
 Pacific
  water
1.5 E-12
  5 E-12
  3 E-12
  5 E-13
   All
 Oceans
Sediments
Naturally Occurring

        U-238
       Th-230
       Ra-226
                               3.4 E-7
                               3.9 E-6
                               4.0 E-6
Source:   See text, page 2-13.

-------
                                    Exhibit  2-6

                         Commercial  LLRU  Streams  That Are
                        Potentially  Hazardous  Mixed Wastes
Group
1.   LUR Process Wastes
                                Waste
Ion-Exchange Resins *
Concentrated Liquids *
Filter Sludges *
FiIter Cartridges
Waste Stream
Reference
Number

    4
    7
    6
    5
11.  Trash
                                LWR Compactible Trash **
                                LWR Non-compactible Trash **
                                Institutional Trash +
                                Industrial Source & SNH Trash +
                                Industrial Lou Trash +
                                            1,2
                                              3
                                             22
                                             16
III. Lou Specific Activity
     Wastes
 IV. Special wastes
Fuel Fabrication Process Wastes
UF6 Process Wastes
Institutional LSV Waste +
Institutional Liquid Waste *
Institutional Biowaste +
Industrial Source & SNH Waste
Industrial Low Activity Waste

LWR Non-Fuel Reactor Components
LWR Decontamination Resins
Waste from Isotope Production
 Facilities
Tritium Production Waste
Accelerator Targets
Sealed Sources
   12
   13
   25
   24(7)
   23
                                                                             17
                                                                             18
                                                                             19
                                                                             20
                                                                             21
      Further subdivided into BWR and PUR.
      Further subdivided into BWR, PWR and Fuel Fabrication Plant.
      Further subdivided into large facility and small facility.
Source:  Nuclear Regulatory Commission, An Analysis of Lou-Level Wastes;
         Revieu of Hazardous Waste Regulations and Identification of
         Radioactive Mixed wastes

-------
                                       Exhibit  2-7

                           Wastes Eligible for  Ocean Disposal
                              Based on Waste  Form Criteria
lEc
Number
Waste
Stream
          PWR Compactible
          Trash
	 Eligible 	    Mot Eligible
Solidify      Requires        Does not        Not Enough
                                as is
                                    Pretreatment

                                         X
                                                   Meet Criteria   Information
          BWR Compactible
          Trash

          LUR Non-Compactible
          Trash
4

5

6
7

LWR Ion Exchange
Resin
PWR Filter
Cartridges
LWR Filter Sludge
LWR Concentrated
Liquids
X

X

X
X

          LWR Decontamination
          Resins
10
Nuclear Fuel Rod
Components

Fuel-Fabrication
Compactible Trash
11        Fuel Fabrication
          Non-Compactible
          Trash

12        Fuel Fabrication
          Process Waste

13        UF6 Processing Waste
          Fuel-Fabrication
          Waste
14        Industrial Special
          Source Trash

-------
IEC       Waste
Number    Stream
                                      Exhibit 2-7

                           Wastes  Eligible  for Ocean Disposal
                              Based  on Waste  Form Criteria
                                      (Continued)
	 Eligible 	     Not  Eligible
Solidify      Requires        Does not         Not  Enough
as is         Pretreatment     Meet Criteria   Information
15        Industrial Special
          Source Waste
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Industrial Lou
Activity Waste
Industrial Low
Activity Waste
Isotope Production
Waste
Tritium Waste
Accelerator X
Targets
Sealed Sources
Institutional Com-
pactible Trash
Biological Waste
Absorbed Waste
Liquid Scintillation
Vials
Uranium/Thorium
Fission Products
Induced Activity
Tritium
"Other"
X
X
X



X
X
X
X





                                                                                   X

                                                                                   X

                                                                                   X

                                                                                   X

                                                                                   X

-------
                                       Exhibit  2-7

                            Wastes  Eligible for Ocean Disposal
                               Based on Waste Form  Criteria
                                       (Continued)
IEC       Waste
Number    Stream
32        Radium Sources

33        Radium Ion-Exchange
          Resins
                      	 Eligible  	    Not Eligible
                      Solidify      Requires        Does not        Not Enough
                      as  is         Pretreatment    Meet Criteria   Information
34        Instrument-Diffuse
          Widely Distributed

35        Instruments-Diffuse
          Collectible
36
          Activated Metals
37
          PWR decon/decom-
          mission
38        BUR decon/decom-
          mission
39


40

41
DOE "Special
Projects"

FUSRAP/N.J.

FUSRAP/Other
42, 43    SFHP

44        CERCLA
45
          Navy Submarine
          Reactors
Source:   Brookhaven National Laboratory.

-------
CONTAINER LIFETIMES FOR LOW LEVEL
RADIOACTIVE WASTES                                      CHAPTER 3
     This   chapter   presents  lEc's  evaluation  of   container
lifetimes for low-level radioactive wastes.  The first section of
the  chapter describes our calculations of the time  required  to
allow  radioactive decay for each of the waste streams  described
in Chapter 2.   The second section provides a review of available
containers  which might be used,  with appropriate modifications,
for ocean disposal of LLRW.
TIME REQUIRED FOR DECAY

     BNL  criteria  for  ocean  disposal specifies  a  number  of
requirements  pertaining  to  waste  container  performance.   In
particular,  BNL suggests that "the waste container shall have an
expected lifetime of 200 years in the deepsea environment."   BNL
also  specifies  criteria for waste  package  strength,  specific
gravity,  and  impact resistance.   The BNL specific criteria are
listed in the Waste Form section of Chapter 2 of this report.

     EPA  is  evaluating  container lifetimes  based  on  several
considerations,    and    is   considering    in    large    part
recommendations   prepared   for  EPA  by   Brookhaven   National
Laboratory (6).  Brookhaven recommended that "the waste container
shall have an expected lifetime of 200 years or 10 half-lives  of
the   longest   lived   radionuclide,   which  ever   is   less."
Brookhaven's report goes on to say that:

          "The   expected  lifetime  of  the  container   is
          contingent on the types and amounts of radioactive
          materials  in  the waste form and  the  character-
          istics   of  the  disposal  site.    In   assuming
          isolation  as  the basic operating philosophy  for


                             3-1

-------
          the  disposal of radioactive wastes in the  ocean,
          both engineered and natural barriers contribute to
          controlling the release of radioactivity such that
          the  amounts  released  would  not  constitute   a
          significant hazard to nan.   This implies that the
          life  expectancy of the container can be less than
          the time required for the radioactive materials to
          decay to environmentally acceptable limits,  where
          acceptable limits are those quantities of activity
          which,  when  the other barriers to migration  are
          considered,  will not pose a significant hazard to
          man.   A life expectancy of 200 years is  presumed
          adequate  for  the container,  since  the  longest
          lived radionuclides of importance,  Cs-137 and Sr-
          90,  will  have  decayed to less than 1% of  their
          initial  activity in this time.   (Depending  upon
          the   types  of  activity  contained   and   their
          quantity,  some containers may not require a life-
          time as long as 200 years.)

Based  on  the  above and discussions  with  EPA  personnel,  any
consideration  of  a  200  year  container  lifetime  is  founded
primarily  on a desire to allow sufficient time for LLRW to decay
to  acceptable  activity levels,  and in addition  represents  an
attainable lifetime based on technology available at present.

     In  order to consider the adequacy of a 200  year  container
lifetime,  lEc calculated the years required for each LLRW stream
to  decay  to 1 percent and 0.1 percent of initial  radioactivity
levels.  I/   These calculations are based on the  half-life  and
associated  decay constant for each nuclide present in the  waste
stream,  and  consider  only the decay of the nuclides  initially
present in the waste.   The equation used for these  calculations
is shown in Exhibit 3-1.
I/    Our calculations of time required for decay to 0.1  percent
actually use 0.0976 percent as the target decay level,  which  is
equal to the decay that would occur over 10 half-lives.   This is
calculated as 0.5 to the 10th power, which equals 0.000976.
                             3-2

-------
     Using the equation shown in Exhibit 3-1 and given the  decay
constants  for  the  component nuclides and the  amount  of  each
nuclide in the waste stream,  we derive the time (t) required  to
reduce the initial radioactivity of the total waste stream to any
given proportion (p) of the initial amount.  Because the equation
in  Exhibit  3-1 has no closed form solution,  we solve for t  by
iteration.

     Exhibit  3-2 provides an example of the spreadsheet used  to
accomplish   these   calculations.     Column   (1)   lists   all
radionuclides  in waste streams we considered.   Column (2) shows
the  decay constants for each of these nuclides.   Column  (3)  is
the  radionuclide  concentration  data  (Ci/cubic  meter)   for  a
specific waste stream,  here I-LQSCNVL.  The values in column (4)
are  the  number of curies of each nuclide and  are  computed  by
multiplying  the values in column (3) by the total volume of  the
waste stream shown at the top of the exhibit.

     Column  (5) shows the portion of radioactivity remaining  in
each component of the waste stream after t years,   where t is set
to value shown at the top of the exhibit.    Column (6) shows  the
total  number of curies remaining of each radionuclide at time t.
The  sum  of  the figures in column (6) is the  total  number  of
curies remaining in the entire waste stream.   The sum of  column
(6)  divided by the original number of curies (the sum of  column
(4))  is  the percentage of radioactivity remaining in the  waste
stream.   We solve iteratively for t until this percentage equals
the desired proportion (in this example .50 or 50 percent).

     Exhibit  3-3 presents the results of these calculations  for
all LLRW for which nuclide composition data are  available.   The
exhibit  shows  the years required for the radioactivity of  each
LLRW  stream  to decay to 1 percent and slightly  less  than  0.1
percent (actually 0.0976 percent) of initial levels.

     Exhibit  3-3 shows tremendous variation in the time required
to achieve decay for different waste streams.   Times required to
achieve  1 percent of initial activity range from 5 years  (waste
28) to 82 billion years (waste 40); times required to achieve 0.1
percent  of initial activity range from 17 years to  129  billion
years for these same LLRW streams.

     Exhibit 3-4 summarizes the information presented in  Exhibit
3-3  by  tabulating  the number of waste  streams  which  require
similar  time periods to reach the specified  decay  levels.   As


                             3-3

-------
shown, only 11 of the 40 LLRW streams considered would decay to 1
percent of initial activity within 200 years,  and only 3 streams
would  reach  0.1  percent of initial activity over  a  200  year
period.   These  wastes  account for 1,399,079 cubic  meters  and
362,900 cubic meters,  respectively, over the period from 1985 to
2004.  Roughly half of the waste streams considered would require
more  than 5000 years to reach either 1 percent or 0.1 percent of
initial radioactivity levels.

     Comparison  of the decay times in Exhibit 3-3 with  specific
radioactivity   (i.e.,   activity  per  cubic  meter  of   waste)
information  in Exhibit 2-2 of Chapter 2 shows that,  in general,
LLRW  streams with long decay times have relatively low  specific
activity.  This relationship is illustrated on Exhibit 3-5, which
plots  the  logarithm of years to achieve 1  percent  of  initial
radioactivity  against  initial radioactivity per cubic  meter.2/
As  shown,  with the exception of 2 outliers (wastes 32  and  26)
there  is a strong tendency for long-lived wastes to be much less
radioactive per unit of volume.

     Waste  streams 32 and 26 appear as outliers on Exhibit  3-5.
Waste 32  (radium sources) has a very high specific activity and a
relatively  average time required for decay to 1  percent.   Note
that this LLRW is generated in extremely small  quantities;  less
than  one  cubic meter is expected to be generated from  1985  to
2004.  Waste 26 (DOE uranium/thorium) has roughly average initial
radioactivity and a very long time required for decay due to  the
presence of a large proportion of uranium-238.

     These  results  about  required decay  times  suggest  three
conclusions.  First, a container lifetime of 200 years will allow
decay  to  1  percent or 0.1 percent levels  for  relatively  few
wastes.  We found that only 11 of the 40 LLRWs for which data are
available  decay  to  1 percent of initial  activity  within  200
years,  and  only 3 streams reach 0.1 percent of initial activity
over the 200 year period.   Much longer (and probably technically
infeasible)  container lifetimes would be required to meet  these
2/   We did not complete a plot using time to achieve 0.1 percent
of initial activity,  since the relationship would be similar  to
that shown in Exhibit 3-5.
                             3-4

-------
decay objectives for many LLRW streams.   Second, for many of the
longer-lived  wastes  requiring  decay to  these  levels  may  be
unnecessary  given  the relatively low initial radioactivity  per
unit volume of these wastes (for example,  waste streams #10, 11,
12, and 13).  Finally, for a few short-lived wastes, the 200 year
lifetime  may  be overly restrictive as it will  allow  time  for
decay  to levels well below 0.1 percent of initial  radioactivity
(for example, waste stream #28) .
REVIEW OF AVAILABLE CONTAINERS

     In  addition to the analysis of decay times described above,
lEc  briefly  reviewed  information  describing  LLRW  containers
currently available.  The objective of our review was to generate
information about the nature,  cost and technical performance  of
containers  which might be available for use in ocean disposal of
LLRW.  The paragraphs below present the results of our review.

     EPA is currently evaluating alternative packaging techniques
for  ocean  disposal of large volumes of soil containing  varying
quantities  of naturally-occurring  radionuclides  (i.e.,  FUSRAP
wastes).   EPA  is  taking into account  containment  technology,
public  safety and risk,  economics,  societal considerations and
existing and possible regulatory constraints.   As this  research
is  ongoing,  EPA has no results available for inclusion in  this
study.  Later results may assist EPA in any future evaluations of
disposal and containerization scenarios.

     While a variety of possible waste containers are  available,
we   considered  only  containers  approved  as   "High-Integrity
Containers" (HIC) by the U.S. Nuclear Regulatory Commission or by
relevant  state agencies.   HICs are the only containers approved
for  land disposal of LLRW.   To receive the HIC  designation,  a
container   must  meet  a  variety  of  requirements   concerning
strength;   resistance   to   vibration;   puncture   resistance;
resistance  to  physical,  chemical  and  biological  degradation
(internal  and external);  water resistance;  and other  factors.
The  requirements  for  HIC designation are provided  at  10  CFR
61.55-56  and by the U.S.  Nuclear Regulatory Commission  in  its
Branch Technical Position on Waste Form of May 1983.

     We  could  find no information about HIC test results  which
would  pertain  directly to ocean disposal,  and thus it  is  not
possible  to  evaluate  whether currently  available  HICs  would


                             3-5

-------
perform  adequately in the deep ocean environment.   It is  clear
that  none of the currently available high  integrity  containers
alone  could  withstand the high external pressures  inherent  in
ocean  disposal  — all would require that the  solidified  waste
form  within the container be strong enough and sufficiently free
of voids to allow the overall package to withstand high pressure.
In  addition,   virtually  all  available  HICs  include  passive
pressure   equalization   devices,    which   are   still   under
consideration for use in ocean disposal.  Despite these problems,
we  chose to look only at HICs because these containers  are  the
strongest that are currently available for LLRW,  and in addition
would   provide   the  protection  required  for   handling   and
transporting LLRW on land prior to final ocean disposal.

     As part of our review of containers, we attempted to develop
information  on  the costs and technical performance  of  various
methods used to solidify LLRW.  Solidification into a matrix able
to  withstand  high  pressure would be a prerequisite  for  ocean
disposal,  and  particularly  for ocean disposal  using  an  HIC.
Solidification of LLRW is complex and highly waste-specific,  and
we found  commercial vendors of solidification services unwilling
to share cost or technical performance information with us.

     We  did learn that solidification methods are available  for
many LLRW streams, and are sufficient in many cases to allow land
disposal  of LLRW without any container or with only a mild steel
container  (which  is  used for handling  purposes  only  and  is
expected to disintegrate once disposal occurs).   However, use of
solidification  methods has been declining somewhat,  and use  of.
HICs alone for land disposal has been on the rise.   The trend to
HICs  has  been  driven primarily by capacity and  disposal  cost
considerations,  since  many  solidification methods  expand  the
volume of waste to be disposed considerably.

     High  integrity  containers  are available in a  variety  of
usable volumes ranging from 5 cubic feet to 284 cubic  feet,  and
are currently constructed from four alternative materials:

     o    polyethylene,
     o    fiberglass/polyethylene composite 3/,
3/  Composite containers have not yet received final approval  as
HICs.
                             3-6

-------
     o    stainless steel alloy, and
     o    steel fiber, polymer impregnated concrete (SFPIC).

Polyethylene  and  stainless  steel  alloy  are  the  predominate
materials  used,  with  only a few,  relatively small  containers
currently  available  that  are constructed  from  composites  or
SFPIC.

     To  our knowledge,  high integrity containers currently  are
available in the United States from four sources:

     o    Bondico, Inc. (composite),
     o    Chem Nuclear, Inc. (polyethylene),
     o    Pacific Nuclear, Inc. (stainless steel and SFPIC), and
     o    Westinghouse Hittman Nuclear, Incorporated
          (polyethylene).

We  received  product literature and list price information  from
each of these manufacturers.   However,  several firms asked that
we not disclose list prices of specific HICs, and we have honored
these requests in this document.

     Exhibit  3-6 presents a plot of the price per cubic foot  of
usable  volume  versus usable volume for all HICs  considered  by
lEc.   The  exhibit illustrates several aspects of high integrity
containers.    First,  available HICs range in usable volume  from
under  10  to  about  280 cubic  feet,  with  greater  choice  of
containers available in the smaller and mid-range sizes.  Second,
stainless  steel  alloy  containers are five to  six  times  more
expensive  than polyethylene HICs.   Third,  composite and  SFPIC
containers  are  available in small sizes only.   SFPIC HICs  are
more  than  twice  as  expensive  as  similar  size  polyethylene
containers,  while composite HICs appear to be priced similarly to
polyethylene.  Finally, the minimum container cost per cubic foot
of usable volume is $25 to $26, or about $900 per cubic meter.

     All  of  these containers have been developed to  serve  the
demand  for handling and land disposal of  commercially-generated
LLRW.   Thus, their suitability for land or ocean disposal of the
larger waste quantities and lower specific activities of NARM and
remedial action LLRW is not known.   In particular, economics may
                             3-7

-------
require  development  of less expensive methods of  handling  and
containerizing  larger  quantities  of  relatively  low  specific
activity  wastes  before such wastes  become  economically-viable
candidates for ocean disposal.
SUMMARY

     This  chapter has reviewed the issue of container  lifetimes
for ocean disposal of LLRW by analyzing the time period  required
to  accomplish  alternate  degrees  of  radioactive  decay.    In
addition,  the  chapter reviews available information about  high
integrity   containers  which  might,   with  modifications,   be
potential containers for ocean disposal.  The overall conclusions
of  the  chapter  are summarized in the  first  chapter  of  this
report.
                             3-8

-------
                      Exhibit 3-1

     Equation to Calculate Time Required for Decay
                                    k(n) * t
              y(o)  = *£_,  y(n) *  e
                       n
where:   p     =   proportion of radioactivity remaining
                   at time t
         n     =   number of nuclides present in waste
         y(o)  =         y(n)
                      n
         y(n)  =   initial radioactivity  for nuclide  n  (Ci)

         k(n)  =   decay constant for nuclide n
                   -  (l/half-life(n) ) * In 2

         t     =   time  (years)
Source:   See text.

-------
                                              Exhibit  3-2

                             EXAMPLE OF  DECAY  TIME  CALCULATION
Waste Stream:
Volune of Waste Stream
Time (years):
           (1)
        Nuclide
        H-3
        C-14
        Fe-55
        Mi-59
        Co-60
        HI-63
        Sr-90
        Nb-94
        Te-99
        Ru-106
        Sb-125
        1-129
        Cs-134
        Cs-135
        Cs-137
        Ba-137m
        Eu-154
        U-234
        U-235
        Mp-237
        U-23B
        Pu-238
        Pu-239
        Pu-241
        Am-241
        Pu-242
        Am-243
        Cm-243
        Cm-244

I):
t=
(2)
Decay
Constant
-5.60E-02
-1.22E-04
-2.67E-01
-8.66E-06
•1.32E-01
-6.00E-03
-2.50E-02
-3.47E-05
-3.47E-06
-6.89E-01
-2.57E-01
-6.93E-09
-3.47E-01
-2.31E-07
-2.30E-02
-1.43E+05
-4.30E-02
-2.77E-06
-9.76E-10
-3.15E-07
•1.54E-10
-8.00E-03
-2.85E-05
-5.30E-02
-3.00E-03
•1.82E-06
-B.66E-OS
-2.00E-02
-3.90E-02
I-LOSCNVL
15,040
18.25
(3)

Ci/nT3
5.01E-03
2.51E-04
0
0
0
0
4.34E-03
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
                                     Ci
                                         75.350
                                          3.775
                                              0
                                              0
                                              0
                                              0
                                         65.276
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                              0
                                                           (5)
0.360
0.998
0.008
1.000
0.090
0.896
0.634
0.999
1.000
0.000
0.009
1.000
0.002
1.000
0.657
0.000
0.456
1.000
1.000
1.000
1.000
0.864
0.999
0.380
0.947
1.000
0.998
0.694
0.491
                  (6)
              total
                                                              144.399
27.117
 3.767
     0
     0
     0
     0
41.361
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0
     0

72.244
                                                                     X of radioactivity remaining:
                                                                               50.031  X
       Source:
See  text.

-------
                                      Exhibit  3-3

                            Time Required for  LLRU Decay
                                        (Years)
  Waste
Reference
 Hunter
                   Waste Stream
  Fraction of Radioactivity Remaining
                       - 0.1 Percent
  1  Percent           (10 half-lives)
        1    PWR Compactible
             Trash

        2    BUR Compactible
             Trash

        3    LUR Noncompactible
             Trash

        4    LWR Ion Exchange
             Resins

        5    PWR Filter
             Cartridges

        6    LWR Filter Sludge

        7    LWR Concentrated
             Liquids

        8    LWR Decontamination
             Resins

        9    Nuclear Fuel Rod
             Components

       10    Fuel-Fabrication
             Compactible Trash

       11    Fuel-Fabrication
             Noncompactible Trash

       12    Fuel-Fabrication
             Process Waste

       13    UF(6) Processing
             Waste

       14    Industrial Special
             Source Trash

       15    Industrial Special
             Source Waste

       16    Industrial Low-
             Activity Trash
           270


           270


           330


           165


           400


           138

           243


           235


           260


16,000,000,000


15,000,000,000


16,900,000,000


25,000,000,000


28,000,000,000


28,000,000,000


        12,000
           844


           844


           960


         1,960


           937


           392

         1,075


           693


           735


32,000,000,000


32,000,000,000


32,000,000,000


40,300,000,000


28,250,000,000


43,200,000,000


        31,350

-------


Waste
Reference
Number
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33

Time
Waste Stream
Industrial Low-
Activity Waste
Isotope Production
Waste
Tritium Waste
Waste Stream
Accelerator Targets
Sealed Sources
Institutional Com-
pactible Trash
Biological Waste
Absorbed Liquids
Liquid Scintilla-
tion Vials
Uranium/ thorium
Fission product
Induced activity
Tritium
Alpha, <10 nCi/g
"Other"
Radium Sources
Radium Ion
Exhibit 3-3
(Continued)
Required for LLRW Decay
(Years)
--- Fraction of Radioactivity Remaining •-•
- 0.1 Percent
1 Percent (10 half -lives)
11,850 30,950
180 288
83 1,990
82 124
170 317
12,000 31,400
12,500 31,800
11,000 30,100
7,800 27.000
23,000,000.000 40.750,000,000
140 258
5 17
81 123
300 25.100
240 13,000,000,000
6,480 11,840
7.720 13,090
Exchange Resins

-------
                                      Exhibit 3-3
                                      CContinued)

                            Time Required for LLRU Decay
                                        (Years)
  Waste
 Reference
  Number
                   Waste Stream
--  Fraction of  Radioactivity Remaining
                        - 0.1  Percent
   1  Percent           (10 half-lives)
        34     Instruments-Diffuse
              Widely Distributed

        35     Instruments-Diffuse
              Collectible
        198,000
        240,000
12,950,000,000
12,950,000,000
36
37
38
39
40
41
42
43
44
Metals
Pressurized Water (PUR)
Boiling Water (BUR)
DOE "SPECIAL PROJECTS"
(e.g. TMI, West Valley)
NJ
other
Niagra Falls
Storage Site
other
CERCLA
27,500,000,000
83
135
N/A
82,000,000,000
N/A
N/A
N/A
N/A
56,300,


N/A
129.500,
N/A
N/A
N/A
N/A
000,000
379
470

000,000




        45    Decommissioned Reactor Plant
              (for 100 submarines)

N/A  =  data on nuclide composition not available.
            500
        73,500
Source:   See text.

-------
                           Exhibit 3-4

          Number of LLRW Streams Requiring Decay Times
Decay Period (years)
0 to
21 to
101 to
201 to
501 to
1001 to
20
100
200
500
1000
5000
5001 to 10,000
more than 10,000

     Total streams
     considered:
Fraction of Radioactivity Remaining

  1 Percent         ~ 0.1 Percent
      1
      4
      6
     10
      0
      0
      3
     16
 1
 0
 2
 6
 6
 3
 0
22
     40
40
Source:   TEc analysis.

-------
                            Exhibit 3-5



                 Initial Specific Activity Versus

                 Time to Decay To 1 Percent Level
K)

<


£




0
 a
 VI
 0
       4 -
      -5
D


8
                                        #32
                                          Waste #26
           D

              —I—  —I—


           4          6




        Log of Decay Time (years)
                                                           a
                                                          10
Source:   lEc analysis.

-------
                              Exhibit 3-6

                     Unit  Cost Versus Volume for
                      High Integrity Containers
   5001
^400 -\


-f
 o

L 300
,g

 D
u

 15200
 CL
 ID
                                       Polyethylene

                                       Cornpoafte

                                       Stainless Steel

                                       SFPIC
              50
100
         150     200

Volume (cubic feet)
250
300
Source:   See  text.

-------
APPENDIX A

-------
         Appendix A

 Radionuclide Composition of
Low Level Radioactive Wastes

-------
                     Radionuclide Composition of Waste Streams (Ci/m  )
Half Life
12. 3y
5700y
2.6y
SO.OOOy
5.27y
125y
28y
20,000y
200,000y
367d
2.7y
lOO.OOO.OOOy
2y
3,000,000y
30y
2.55m
16y
250,000y
710,000,000y
2,200,000y
4,500,000,000y
86y
24,300y
13y
458y
380,000y
8000y
35y
17. 6y
lEc No.
NUCLIOE

H-3
C-14
Fe-55
Mi-59
Co-60
Ni-63
Sr-90
Nb-94
Tc-99
Ru-106
Sb-12S
1-129
Cs-134
Cs-135
Cs-137
Ba-137m
Eu-154
U-234
U-23S
H>-237
U-238
Pu-238
Pu-239
Pu-241
An-241
Pu-242
ftn-243
Cm-243
Qn-244
#4
L-IXRES1N

3.42E-1
1.2BE-2
8.19E-1
8.99E-4
1.44E 0
1.19E-I
2.62E-2
2.82E-S
1.45E-4
3.87E-3
1.16E-2
4.18E-4
3.87E 0
1.45E-4
3.87E 0
3.87E 0
1.16E-3
1.S9E-4
2.55E-*
1.14E-9
4.65E-5
3.29E-3
2.30C-3
1.01E-1
2.3SE-3
5.04E-6
1.S6E-4
1.2SE-6
1.73E-3
97
l-CONCLIQ

I.89E-2
7.IOE-4
I.9SE-1
2.20E-4
3.58E-1
4.59E-2
1.45E-3
6.9BE-C
8.I2E-4
2.16E-4
2.86E-3
2.33E-5
2.16E-1
8.12E-*
2.16E-1
2.16E-1
2.87E-4
9.62E-«
1.S4E-7
6.89E-11
2.82E-«
4.66E-4
2.6BE-4
1.21E-2
2.76E-4
5.76E-7
1.96E-5
3.16E-7
3.03E-4
/?6
L-FSLUOGE

1.36E-2
8.29E-4
1.56E 0
1.62E-3
2.«2E 0
5.32E-2
2.50E-3
5.10E-5
5.36E-5
1.39E-3
2.09E-2
1.39E-4
1.39C 0
S.24E-S
I.39E 0
1.39E 0
2. 10E-3
9.95E-6
1.60E-7
7.I4E-1I
2.92E-6
4.95E-4
2.72E-4
1.32E-2
2.08E-4
5.41E-7
1.40E-5
3.62E-7
2.63E-4
//5
P-fCARTRG

2.77E-3
1.02E-4
1.34E 0
1.59E-3
2.S8E 0
4.91E-1
2.02E-4
S.03E-S
8.62E-7
2.30E-5
2.06E-2
2.55E-4
2.30E-2
8.62E-7
2.30E-2
2.30E-2
2.07E-3
2.36E-5
3.79E-7
1.69E-IO
6.91E-6
6.05E-4
9.15E-4
4.00E-2
3.95E-4
2.01E-*
2.6SE-S
4.65E-7
2.65E-4
#8 #9 tf!2
L-CEOONRS L-NFROOHP F-PROCESS


6.43E-3
2.63E 0 5.S4E*1
3.45E-2
1.89E*! 3.98E»1
9.96E-1 4.76E 0

2.04E-4

8.46E-1
l.BBE-3





3.76E-S
5.20E-4
2.30E-S

8.54E-5
1.13E-2
7.52E-3




1.13E-2
3.76E-3
//13
U-PfiOCESS


















3.64E-4
1.65E-S

3.64E-4








           TOTAL
1.4SE»I
1.29EO    8.46E 0
4.54E 0    2.34E+1
I.OOE+2
6.28E-4
                                                                                              7.45E-4
Source: Adapted by lEc  from BID Table  3-5.

-------
                    Radionuclide Composition of Waste  Streams   (Ci/m  )
                                    (Continued)
lEc No. 025 024 023
NUCLIOE I-LQSCNVL I-ABSLIQO I-8IOMST
H-3 5.01E-3 1.42E-1 1.15E-1
C-U 2.51E-4 B.16E-3 1.01E-2
F»-55
Ni-59
Co-60 3.12E-2 3.99E-3
Mi -63
Sr-90 4.34E-3 4.34E-3 8.33E-3
Nb-94
Tc-99 1.02E-8 6.51E-9
Ru-106
Sb-12S
I- 129
Cs-134
Cs-135
Ct-137 1.37E-2 B.76E-3
Ba-I37m I.37E-2 B.76E-3
Eu-154
U-234
U-235
H>-237
11-238.
Pu-238
Pu-239
Pu-241
Am-241
Pu-242
A»-243
Qi>-243
Qn-244
//17 *18 021 019 020
N-LOMSTE M-ISOPROO N-SOJRCES N-TRITIIM N-TARGETS
1.63E-2 5.52E-2 Z.SBEtl 2.2)E»2 7.80E*2
9.36E-4 7.79E-S 4.57E-3 2.76E-1
9.64E-1

1.47E-3 1.48E 0 2.24E+1
1.48E-2 1.56E-2
1.31E-3 7.09E+1 3.77Efl

7. 766-10 5.10E-6
1.46E-1

4.24E-8
4.70E-1
5.10E-4
1.04E-3 4.78E 0 4.45E»2
1.04E-3 4.7BE 0 4.45E*2

1.20E-3
3.1SE-5
6.20E-1S
3.47E-7
2.29E-6 8.89E-1
6.45E-7
8.2SE-S
4.50E-2 1.47E 0
1.11E-9
1.46E-8
3.35E-9
1.93E-*
            10IAL    9.60E-3     2.I3E-I    2.15E-I
Source: Adapted by lEc  from BID Table  3-5
2.2IE-2
8.37E*!
9.81E+2
2.21E*2
7.80E»2

-------
T
Radionucllde Composition of Waste Streams (Ci/m )
(Continued)
I EC No
NUCLIOE
H-3
C-M
Fe-55
Hi -59
Co-60
Nl-«3
Sr-90
Nb-94
Te-99
Ru-106
Sb-125
1-129
Cs-134
Cs-135
Gs-137
Ba-137m
Eu-154
U-234
U-235
Hp-237
U-238
Pu-238
Pu-239
Pu-241
ftn-241
Pu-242
An-243
Cm-243
Oiv-244
91,92
L-COTRASN
3.56E-4
1.39E-5
9.196-3
1.05E-5
1.71E-2
2.41E-3
2.96E-5
3.33E-7
2.26E-7
6.01E-*
1.36E-4
6.32E-7
6.01E-3
2.26E-7
6.01E-3
6.01E-3
1.37E-5
2.43E-7
3.89E-9
1.74E-12
7.11E-8
7.46E-4
6.49E-6
2.95E-4
4.69E-6
1.41E-8
3.33E-8
3.84E-9
3.50E-6
113 ViO Vli Vii IfiO ' jjfj^^
L-NCTRASH F-COTRASH F-NCTRASH I-COTRASH N-LOTRASH N-SSTRASH
3.17E-3 9.13E-2 2.85E-2
1.19E-4 5.26E-3 1.64E-3
6.87E-2
8.09E-5
1.31E-1 1.04E-2 3.25E-3
2.24E-2
2.43E-4 1.45E-3 4.S3E-4
2.5«E-6
1.32E-S 3.39E-9 1.06E-9
3.S4E-5
1.05E-3
3.82E-6
3.54E-2
1.33E-6
3.S4E-2 4.56E-3 1.42E-3
3.54E-2 4.56E-3 1.42E-3
1.05E-4
2.J9E-6 2.68C-5 2.56E-5 2.56E-6
3.S2E-0 1.18E-& 1.13E-6 1.42E-7
1.57E-11
6.43E-7 4.40E-6 4.20E-6 8.80E-6
6.39E-S
5.75E-S
2.52E-3
4.14E-S 4.82E-* l.SIE-6
1.26E-7
2.80E-6
3.04E-8
2.84E-5
#15
N-SSUASTE

















4.97E-5
2.77E-*

1.71E-4








          TOTAL
4.I6E-2
3.35E-1
3.24E-5     3.09E-5
1.18E-1
3.67E-2
1.15E-5
2.23E-4
Source:  Adapted by lEc from  BID Table 3-5.

-------
                         Radionuclide Composition of  NARM Wastes
                                         (Ci/m3)
Radio-
nuclide
U-238
U-234
Th-230
Ra-226
Rn-222
Pb-214
Bi-214
Pb-210
Po-210
Th-232
Ra-228
Ac-228
Th-228
Ra-224
Rn-220
Pb-212
Bi-212
Tl-208

Half-
Life
4,500,000,000 y
250,000 y
METALS
3.
3.
3
3
E-4
E-4
IXRSNS



1NSTR
2
2
.8
.8
E-4
E-4
80,000 y





1600 y
3.82 d
26.8 m
19.7 m
21 y















138.4 d
14,100,000,000 y
5
6
1
3

10
60
4
.77 y
.13 h
.91 y
.64 d
55 s
.64 h
. 6 m
.78 m
1.
1.
1.
1.
1.
1.
1.
1.
1.
1
1
1
1
1
1
1
1
1
E-5
E-5
E-5
E-5
E-5
E-5
E-5
E-5
E-5
1
9
9
9
9
9









.8
.0
.0
.0
.0
.0









E-2
E-3
E-3
E-3
E-3
E-3









1
5
5
5
5
5
8
8
8
8
8
8
8
8
8
.6
.3
.3
.3
.3
.3
.0
.0
.0
.0
.0
.0
.0
.0
.0
E-2
E-3
E-3
E-3
E-3
E-3
E-6
E-6
E-6
E-6
E-6
E-6
E-6
E-6
E-6
Source: PEI Table 3-3 adapted by lEc,

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               DOE/DEFENSE "GENERAL" LLW
                URANIUM/THORIUM IEC #31
Nuclide

Tl-208
Pb-212
Bi-212
Po-212
Po-216
Ra-224
Ra-228
Ac-228
Th-228
Th-231
Th-232
Th-234
Pa-234m
Pa-234
U-235
U-238
Half-Life (years)

    0.00001
    0.0012
    0.00012
    9.6E-15
    ~0
    0.0099
    5.75
    0.0007
    1.913
    0.00291
    1.4E+10
    0.066
    0.0007
    0.0008
    7.0E+08
    4.5E+09
 Ci/m3

1.46E-4
3.86E-4
3.86E-4
2.49E-4
3.86E-4
3.86E-4
2.31E-3
2.0E-3
3.86E-4
2.22E-3
2.34E-2
2.85E+0
2.85E+0
2.92E-2
2.22E-3
2.85E+0
Source:  lEc chart derived from DOE Tables A.2 and A.3

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               DOE/DEFENSE "GENERAL" LLW
                FISSION PRODUCT lEc #32
Nuclide

Co-60
Sr-90
Y-90
Zr-95
Nb-95
Tc-99
Sb-125
Te-125m
Ru-106
Rh-106
Cs-134
Cs-137
Ba-137m
Ce-144
Pr-144
Pm-147
Sm-151
Eu-152
Eu-154
Eu-155
Half-Life (years)

    5.27
    28.6
    0.0073
    0.175
    0.096
    213000
    2.77
    0.159
    1.009
    -0
    2.062
    30.17
    0.000004
    0.779
    0.00003
    2.623
    90
    13.6
    8.8
    4.96
 Ci/m3

8.21E-3
7.97E-1
7.97E-1
1.30E-1
2.90E-1
2.05E-3
3.01E-1
7.49E-2
6.55E-1
6.55E-1
3.90E-2
1.81E+0
1.65E+0
1.50E+0
1.50E+0
6.15E-3
1.13E-2
9.23E-3
9.23E-3
6.15E-3
Source:  lEc chart derived from DOE Tables A.2 and A.3

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               DOE/DEFENSE "GENERAL" LLW
               INDUCED ACTIVITY IEC #33
Nuclide

Cr-51
Mn-54
Co-58
Fe-59
Co-60
Zn-65
Half-Life (years)

    0.076
    0.83
    0.195
    0.122
    5.271
    0.667
 Ci/m3

9.74E-1
7.50E+0
1.09E+1
9.64E-2
1.71E-1
3.74E-2
Source:  JEc chart derived from DOE Tables A.2 and A.3,

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               DOE/DEFENSE "GENERAL" LLW
                    TRITIUM IEC #34
Nuclide
 H-3
Half-Life (years)

     12.28
 Ci/m3
3.70E+2
Source:  lEc chart derived from DOE Tables A.2 and A.3,

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               DOE/DEFENSE "GENERAL" LLW
               ALPHA, <10 nCi/g IEC #35
Nuclide           Half-Life  (years)            Ci/m3

Pu-238                87.75                   1.02E-2
Pu-239                24130                   3.88E-4
Pu-240                6569                    2.72E-3
Pu-241                14.4                    3.74E-1
Am-241                432.2                   1.54E-5
Cm-242                0.447                   2.18E-4
Cm-244                18.11                   7.75E-5
Source:  IEC chart derived from DOE Tables A.2 and A.3,

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               DOE/DEFENSE "GENERAL" LLW
                   "OTHER"  IEC #36
Nuclide

H-3
C-14
Mn-54
Co-58
Co-60
Sr-90
Y-90
Tc-99
Cs-134
Cs-137
Ba-137m
U-238
Half-Life (years)

    12.28
    5730
    0.83
    0.195
    5.27
    28.6
    0.00012
    213000
    2.062
    30.17
    -0
    4.5E+9
 Ci/m3

2.36E-1
1.16E-2
1.31E+0
1.21E+0
3.49E+0
1.64E+0
1.64E+0
2.32E-2
2.71E+0
3.71E+0
3.25E+0
1.41E-1
Source:  JEc chart derived from DOE Tables A.2 and A.3
                         10

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             DECONTAMINATION AND DECOMMISSIONING OF
                LIGHT WATER REACTORS PWR AND BWR
Nuclide

C-14
Ni-59
Nb-94
TC-99
Co-60
Ni-63
Sr-90
Y-90
Cs-137
Ba-137m
T(l/2)<5 yr
Half-Life (years)

      5730
      80,000
      20,000
      213,000
      5.27
      92
      28.6
      0.0073
      30.17
      0.000004
IEC #37
  PWR
 Ci/m3

O.OOE+0
6.62E-4
4.49E-6
O.OOE+0
1.99E+0
1.08E-1
6.88E-5
6.88E-5
7.86E-2
7.44E-2
4.76E+0
IEC #38
 BWR
 Ci/m3

4.99E-4
2.94E-3
3.68E-7
1.82E-7
2.60E+0
4.11E-1
1.54E-3
1.54E-3
9.36E-2
8.86E-2
1.24E+1
Source:  lEc chart derived from DOE Tables 7.1, A-8 and A.9,
                             11

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        U.S. NAVY DECOMMISSIONED REACTOR PLANTS
             (for 100 Submarines)  lEc #44
Nuclide           Half-Life  (years)               Ci

Co-60                 5.27
Ni-63                 100
Fe-55                 2.69
CO-58                 0.19
Cr-51                 0.076
Mn-54                 0.85
Ni-59                 75,000
Fe-59                 0.12
Zr-95/Nb-95           0.18
C-14                  5,730
S-35                  0.24
Sc-46                 0.23
Hf-181                0.12
Nb-94                 20,300
Mo-93                 3,500
Tc-99                 214,000
Source:  lEc chart derived from FEIS Table 1-1.  Information
         about volumes was not provided in the FEIS.
                         12

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                           REFERENCES
(1)  Galpin,  Floyd L.,  James M.   Gruhlke,   and William F.  Holcomb,
     Office of Radiation  Programs.    EPA's  Low-Level  and  NARM
     Waste Standards:   An Update.   For presentation at the Annual
     Meeting  of  the  Conference of  Radiation  Control   Program
     Directors, Inc.   May, 1985.

(2)  PEI Associates,  Inc.  Radiation Exposures  and  Health  Risks
     Associated  with  Alternative  Methods of Land  Disposal  of
     Natural   and  Accelerator  Produced  Radioactive  Materials
     (NARM).   Prepared  for  the U.S.   Environmental  Protection
     Agency, Office  of Radiation Programs.  October, 1985.

(3)  U.S.  Department  of Energy.   Final Environmental Impact State-
     ment .   Long-Term Management   of  the  Existing  Radioactive
     Wastes and Residues at the  Niagara  Falls   Storage   Site.
     April,  1986.

(4)  U.S.  Department  of  Energy,  Oak  Ridge  National Laboratory.
     Integrated Data  Base for 1986;   Spent Fuel  and  Radioactive
     Waste   Inventories,   Projections,    and   Characteristics.
     September, 1986.

(5)  U.S.  Department  of the Navy.  Final Environment Impact State-
     ment on the Disposal of Decommissioned,  Defueled  Naval Sub-
     marined Reactor  Plants.  May,  1984.

(6)  U.S.  Environmental Protection  Agency,  Office  of  Radiation
     Programs.    Development  of  a Working Set of Waste   Package
     Performance  Criteria for the Deepsea Disposal of ' Low-Level
     Radioactive Waste.   EPA 520/1-82-007.  November, 1982.

(7)  U.S.  Environmental Protection  Agency, Office  of   Radiation
     Programs.    Draft Environmental Impact  Statement,   Vol.  I,
     Background Information Document.  August, 1987.

(8)  U.S.  Environmental  Protection Agency,  Office  of  Radiation
     Programs.   Low-Level  and NARM  Radioactive Waste,   Vol.  2,
     Draft Environmental Impact Assessment.   EPA 520/1-87-012-2.
     April,  1988.

(9)  U.S.  Nuclear Regulatory Commission.  An Analysis of Low-Level
     Wastes;   Review  of Hazardous Waste Regulations and Identi-
     fication of Radioactive Mixed Wastes, NUREG/CR-4406.

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(10)  U.S.  Nuclear Regulatory Commission.   Document Review Regard-
      ing  Hazardous Chemical Characteristics of  Low-Level Waste,
      NUREG/CR-4433.

(11)  U.S.  Nuclear Regulatory Commission.    Management of Radioac-
      tive Mixed Wastes in Commercial Low-level Wastes (draft re-
      port) .   NUREG/CR-4450.

(12)  U.S.  Nuclear Regulatory Commission.   Update of Part  61  Im-
      pacts Analysis  Methodology Report;   NUREG/CR-4370,   Vol.  I.
      January,  1986.

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