REVIEW OF WASTE ELIGIBILITY AND CONTAINER LIFETIMES FOR OCEAN DISPOSAL OF LOW LEVEL RADIOACTIVE WASTE INDUSTRIAL ECONOMICS, INCORPORATED 2067 MASSACHUSETTS AVENUE CAMBRIDGE, MASSACHUSETTS 02140 ------- 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- CHI EXHIBITS ------- 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. ------- < \ O < u a m O) o Exhibit 1-2 LLRW Volume Versus Specific Activity D 5 - 4 - 3 - 2 - 1 _, 0 - 1 - 2 - 3 - 4 - 5 CL ^^H ^-Waste #32 n n n a a o n D ° Q a B n an 0 an n D D Waste #36 V D D 0 D D D I I I I — I 1 — — I — -11 357 Log of Volume (m~3) Source: lEc analysis of data from Exhibit 2-2. ------- 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). 2-1 ------- 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. 2-2 ------- 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. 2-3 ------- 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. 2-4 ------- 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. 2-5 ------- 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. 2-6 ------- 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 2-7 ------- 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 2-8 ------- 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. 2-9 ------- 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. 2-10 ------- 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. 2-11 ------- 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 2-12 ------- 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 2-13 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- 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, ------- 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 ------- 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 ------- 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, ------- 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, ------- 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, ------- 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 ------- 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 ------- 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 ------- 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. ------- (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. ------- |