svEPA
United States
Environmental Protection
Agency
Air and Radiation
(6602J)
402-R-92-007«3-
November 1992
Economic Impact Analysis for Amend-
ments to EPA's Radioactive Waste
Standards (40 CFR Part 191)

\
/

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Economic Impact Analysis for Amendments
to EPA's Radioactive Waste Standards
(40 CFR Part 191)
402-R-92-007*
November 1992
Office of Radiation Programs and Indoor Air
Office of Air and Radiation
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460

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TABLE OF CONTENTS
Chanter	Pace
TABLE OF CONTENTS 	 i
EXECUTIVE SUMMARY 	 iii
1	INTRODUCTION 	 1
1.1	OVERVIEW		1
1.2	REQUIREMENTS OF PROPOSED AMENDMENTS TO 40 CFR PART 191 . .	2
1.3	SOURCES OF TRU WASTES		2
1.4	ANALYTICAL APPROACH 		5
1.5	DATA SOURCES AND LIMITATIONS		6
1.6	DISCOUNTING OF COSTS AND HEALTH EFFECTS 		6
1.7	CAVEATS ON MODELING		7
2	ANALYSIS OF COSTS AND HEALTH EFFECTS OF TRU DISPOSAL	 8
2.1	TRU RISKS	 8
2.1.1	Pathways	 8
2.1.2	Understanding the Individual Dose 	 8
2.2	DEFINING THE OPTION 	 9
2.3	POPULATION AND INDIVIDUAL RISKS 	 9
2.4	COST OF TRU WASTES 	 10
2.4.1	General Elements 	•	 10
2.4.2	Detailed Cost Components	 12
2.4.2.1	Selection of Reference System Costs 	 12
2.4.2.2	Reference Costs	 	 13
2.4.2.3	Design of Repository and Waste Packages for TRU Waste .... 17
2.5	COSTS OF DEMONSTRATING COMPLIANCE WITH INDIVIDUAL
AND GROUNDWATER REQUIREMENTS	 19
2.6	REAL IMPACT OF 40 CFR 191 AMENDMENTS	 19
3	SENSITIVITY ANALYSIS	 21
3.1	VARYING THE DOSE LEVEL 	 21
3.2	1,000 VERSUS 10,000 YEAR PERIOD OF PERFORMANCE 	 21
4	GENERAL ECONOMIC IMPACTS OF TRU DISPOSAL	 23
REFERENCES 	 25

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EXECUTIVE SUMMARY
This Economic Impact: Analysis (EIA) assesses the economic
impacts of the U.S. Environmental Protection Agency's proposed
amendments and additions to 40 CFR Part 191, standards for disposal
of radioactive wastes. These amendments are being proposed under
the authority of the Waste Isolation Pilot Plant Land Withdrawal
Act. They apply to spent reactor fuel, high-level radioactive
wastes, and transuranic wastes. However, they do not apply to
sites developed under Public Law 97-425, the Nuclear Waste Policy
Act of 1982. Under this act, the containment requirements portion
of 40 CFR Part 191, previously vacated by the Court, were
reinstated. With this reinstatement and the exclusion of sites as
specified, the only sites to which the individual dose requirements
and the groundwater protection requirements currently apply are for
transuranic (TRU) waste disposal. This is the focus of this EIA.
This analysis is unusual in that it does not contain a formal
cost-benefit or cost-effectiveness analysis of TRU waste disposal
due to the nature of the standard. For a cost-effectiveness
analysis it is necessary to have options to compare. For TRU
disposal there are no disposal options to consider. A single
geologic media, salt, is characterized and subject to environmental
pathway modeling. There are no canisters or improved waste forms
to examine. A cost-benefit analysis is not conducted due to the
absence of any historically acceptable option for TRU disposal
other than geologic*. This analysis can only assess the impact in
absolute terms and relative to the containment standards reinstated
by the legislation.
In absolute terms, the cost of building a salt repository for
TRU waste similar to the Waste Isolation Pilot Project is $2.3
billion (1990 dollars, present value). Current modeling suggests
that over the 10,000 year period of the analysis, less than one
statistical health effect would occur from the waste projected to
be emplaced there.
Because of the reinstatement of the containment portion of 40
CFR Part 191, there is no economic impact of this amendment for
similar sites in a salt media. Modeling results for a TRU disposal
site in a salt media indicate that when the containment
requirements contained in 40 CFR Part 191 are met, individual dose
requirements and ground water requirements are automatically met.
In fact, for the TRU salt site modeled, groundwater and individual
doses were zero. This results from the fact that the measures used
to ensure that the containment requirements are met (and retard
nuclides from entering the environment outside of the repository)
also act to protect groundwater and the individual. There may,
however, be small additional costs to demonstrate compliance with
the standard.
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Data are unavailable for the disposal of TRU in other types of
media of serious interest: tuff, basalt, or granite. Because of
this it is currently impossible to say with certainty whether or
not the same circumstances apply for these other media and what the
impact might be at alternate sites for the imposition of
groundwater and individual dose requirements.
iv

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CHAPTER 1
INTRODUCTION
1.1 OVERVIEW
This Economic Impact Analysis (EIA) assesses the economic
impacts of the U.S. Environmental Protection Agency's proposed
amendments and additions to 40 CFR Part 191, standards for disposal
of radioactive wastes. These amendments are being proposed under
the authority of the Waste Isolation Pilot Plant Land Withdrawal
Act. They apply to spent reactor fuel, high-level radioactive
wastes, and to transuranic waste. However, they do not apply to
sites developed under Public Law 97-425, the Nuclear Waste Policy
Act of 1982. Under this act, the containment requirements portion
of the 40 CFR Part 191, previously vacated by the Court, were
reinstated. With this reinstatement and the exclusion of sites as
specified, the only sites to which the individual dose requirements
and the groundwater protection requirements currently apply are for
transuranic (TRU) waste disposal. This is the focus of this EIA.
The U.S. Environmental Protection Agency (EPA) is responsible
for developing generally applicable environmental standards for the
management and disposal of spent nuclear fuel, high-level waste,
and TRU radioactive wastes. To this end, EPA promulgated standards
on August 15, 1985 (40 CFR Part 191). In 1987, however, following
a legal challenge, those parts of the standards dealing with
disposal (Subpart B) were remanded to the Agency for further
consideration by a U.S. Court of Appeals. Recently enacted
legislation, known as the Waste Isolation Pilot Plant Land
Withdrawal Act, reinstates those portions of the 1985 disposal
standard not specifically identified as faulty by the court. As
such, the current amendment to 40 CFR Part 191 addresses both this
legislation and issues raised by the court pertaining to individual
and groundwater protection requirements. However, the proposed
amendment does not apply to the characterization, licensing,
construction, operation, or closure of any site .required to be
characterized under the 1982 National Waste Policy Act. Thus, the
impact of the amendments to 40 CFR Part 191 will primarily be to
institute groundwater protection and individual dose requirements
specific to TRU disposal.
Due to the nature of this amendment, a Regulatory Impact
Analysis (RIA) in accordance with Executive Order (EO) 12291 is not
required. E.O. 12291 requires an RIA be done only in those cases
of significant impact. Due to the reinstatement of the containment
part of the standard it can be shown the amendments have no
economic impact. The only planned TRU repository is in a salt
media similar to the one discussed in the Background Information
Document (BID) (EPA92C) and this EIA.
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The EIA is divided into four chapters. The remainder of this
chapter briefly describes the groundwater and individual dose
requirements, the processes by which the wastes are generated, the
volumes of waste that must be disposed of, the assumptions on which
the EIA is based, and the analytical approach to the estimation of
the impacts of the proposed regulation. Chapter Two defines the
options for disposing of wastes and describes the health and cost
effects associated with each option. Chapter three is a brief
sensitivity analysis on the level of the standard. Chapter four
assesses the distributional impact of TRU disposal.
1.2 REQUIREMENTS OF PROPOSED AMENDMENTS TO 40 CFR PART 191
The individual protection portions of the proposed amendments
require that disposal systems for TRU waste shall be designed so
that, for 10,000 years after disposal, undisturbed performance of
the disposal system shall not cause the annual committed effective
dose, received through all potential pathways from the disposal
system, to any member of the public in the accessible environment,
to exceed 15 millirems. The groundwater protection requirements
proposed limit radioactive contamination in both public and private
sources of drinking water to the Maximum Contaminant Levels (MCL's)
found in the Agency's proposed National Primary Drinking Water
standards (40 CFR 141) over the same 10,000 year period.
1.3 SOURCES OF TRU WASTES
Radioactive wastes are the result of governmental and
commercial uses of nuclear fuel and material. For regulatory
purposes EPA defines five main categories of radioactive wastes:
spent nuclear fuel, high-level wastes other than spent fuel, TRU
wastes, uranium mill tailings, and low-level wastes. Spent nuclear
fuels, high-level wastes, and TRU wastes are the categories covered
by the original 40 CFR Part 191. These amendments and additions to
40 CFR Part 191 are concerned primarily with TRU waste.
Information on the sources and processes that produce these wastes,
and on the current and projected quantities of the waste that must
be disposed of, is provided in this section.
TRU wastes, as defined in this rule, are materials containing
elements having atomic numbers greater than 92 in concentrations
greater than 100 nanocuries of alpha-emitting TRU isotopes, with
half-lives greater than twenty years, per gram.
Wastes resulting from reprocessing plutonium-bearing fuel or
fabricating nuclear weapons consists of materials contaminated with
radioactive isotopes of plutonium and americium, but also contains
other TRU isotopes. The waste form varies widely, but most of the
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waste can be described as contaminated plastic, rags, equipment,
tools, contaminated organic and inorganic sludges, wood, rubber,
metal, cloth, paper, and laboratory trash. Exhibit 1 lists the 11
facilities that generate TRU wastes along with the volume of wastes
stored at each site as of December 1990. Two of the facilities,
Lawrence Livermore National Laboratory and Argonne National
Laboratory East generate waste but ship it elsewhere for storage.
Two additional facilities, the Mound Plant and the Rocky Flats
Plant, have stored waste on site in the past, but will be sending
future wastes to one of the seven other facilities listed, which
have been designated by DOE as TRU waste storage sites (ORNL 91).
Certain factors must be considered in interpreting Exhibit 1.
First, early disposal practices did not include the current
requirements for waste identification and categorization. As the
efforts to identify and characterize the wastes continue,
significant changes in estimates of the quantity of TRU waste are
anticipated. Second, prior to 1970, all DOE-generated TRU wastes
were disposed of in several landfill-type configurations at the
facilities. This is the "buried" waste shown in Exhibit 1. After
1970, when the Atomic Energy Commission concluded that these wastes
should have greater confinement, TRU wastes began to be placed in
"retrievable" storage to enable eventual placement in a long-term
storage facility (ORNL 91). At this time, only this retrievable
waste is intended to be removed eventually to a DOE-designated
storage site. Therefore, the projections in Exhibit 2 of wastes to
be accumulated through 2013, which are intended to indicate the
magnitude of the disposal problem, include only retrievably stored
wastes. Total volumes of TRU waste, including buried waste, may be
calculated by adding the estimated 191,000 cubic meters of total
buried waste as of 1990 to each of the volumes in Exhibit 2.
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EXHIBIT 1
ACCUMULATED VOLUMES OF TRANSURANIC WASTES
December 31, 1990
FACILITY
BURIED
WASTES
(cubic meters)
RETRIEVABLY
STORED WASTES
(cubic meters)
Hanford Reservation
109,000
8,870
Idaho National Engineering Laboratory
57,100
37,500
Los Alamos National Laboratory
14,000
7,580
Oak Ridge National Laboratory
6,200
1,970
Sandia National Laboratory
3
—
Savannah River Site
4,530
3,990
Mound Plant
—
222
Rock Flats Plant
—
915
Nevada Test Site
—
587
Lawrence Livermore National Laboratory1
—
—
Argonne National Laboratory1
—
—
TOTAL
190,833
60,634
Source: ORNL 91
'This facility generates transuranic wastes but ships them to
other facilities for storage.
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EXHIBIT 2
PROJECTED TRANSURANIC WASTE INVENTORIES, 1990-2013
(by volume, radioactivity, and thermal power)
YEAR
VOLUME
(cubic meters)
RADIOACTIVITY
(thousand curies)
THERMAL POWER
(thousand watts)
19902
60,608
4,779
74.57
1995
72,108
7,863
157.01
2000
83,608
9,774
228.62
2005
95,108
11,581
295.78
2010
106,608
13,291
358.96
2013
113,508
14,276
395.14
Source:
DOE/Energy Information Administration projections as presented in
ORNL 91, Table 3.1.
1.4 ANALYTICAL APPROACH
This EIA provides an economic analysis of the long-term
disposal of the current and projected quantities of TRU wastes
described in section 1.3. The EIA takes a generic approach to the
analysis of the costs, population risks,and individual exposures
associated with disposal of TRU wastes. As such, the options
described are not intended to characterize any particular planned
or existing facility. However, certain costs and characteristics
of existing facilities are used to analyze TRU disposal in a
generic fashion. The current cost and risk assessments have used
data generated by DOE as part of its effort to develop TRU
repositories. The general approach to the analysis, basic
assumptions, and data sources and limitations are discussed below.
This EIA considers no options for disposal of TRU wastes.
Emplacement only in a salt media is considered. Cost and
especially performance data for alternate media as pertains to TRU
disposal are not currently available, although they will be
included in the next iteration of this EIA. Engineered barriers,
which include any barrier devised by man that in some way retards
the release of radioactive materials, fall into two categories:
those associated with the longevity of the canisters that would be
used to store the wastes, and those associated with the rate at
which the waste would leak from the canister. As TRU waste is
2Data for 1990 are actual, not predicted, accumulations.
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disposed of without the use of special canisters or improved waste
forms for a slower leach rate, costs and health effects associated
with engineered barriers are not considered.
Costs, projected statistical health effects, and individual
exposures are developed only for the salt media as a method of
disposing of TRU. These are based on an assumption that the
repository will contain the amounts and types of TRU waste
characterized in the BID. No cost-effectiveness analysis is
performed as a consequence of the lack of options.
For the EIA, it is recognized that the cost of disposal will
be borne by the Federal government. However, the discussion of
impacts of the cost of disposing of TRU wastes is qualitative and
is mentioned in Chapter four. Quantification of the government
impacts is not attempted because, given the small size of the waste
disposal expenditures relative to the Federal budget, determination
of the origin of the funds, their impacts, or their opportunity
costs is not possible.
This analysis is unusual in that is does not contain a formal
cost-benefit or cost-effectiveness analysis disposal due to the
nature of the standard. For a cost-effectiveness analysis it is
necessary to have options to compare. For TRU disposal there are
no disposal options to consider. A single geologic media, salt, is
characterized and subject to environmental pathway modeling. There
are no canisters or improved waste forms to examine. A cost-
benefit analysis is not conducted due to the absence of any
historic acceptable option for TRU disposal other than geologic.
This analysis can only assess the impact in absolute terms and
relative to the containment standards reinstated by the
legislation.
1.5 DATA SOURCES AND LIMITATIONS
The cost data for TRU waste disposal used in this EIA were
obtained from the DOE (Hunt 1) and are 1990 figures. More recent
cost estimates were unavailable from DOE for disposal of TRU in
salt. Data on population risks and individual exposures are from
modeling presented in the BID. Details on the model are provided
in Chapter Two.
1.6 DISCOUNTING OF COSTS AND HEALTH EFFECTS
All costs are expressed in constant 1990 dollars. After
deflating the costs, a discount rate of 2 percent is then applied
to future costs to obtain the present value. This 2 percent rate
is intended to reflect the real social cost of money.
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Projected statistical health effects and individual exposures
are not discounted as are the costs of disposal. This simplifies
the analysis. It is unnecessary to present the analysis with
tables for alternate discount rates as the application of any
positive discount rate over the 10,000-year period of analysis to
health effects, which are already small, reduces them to very near
zero.
1.7 CAVEATS ON MODELING
Because of the generic nature of the assessment, the results
for the risk calculations are not intended to project actual risks
expected at particular sites. Such projections will only be
possible after the potential sites are more fully characterized.
Modeling efforts that extend over a period of 10,000 years require
a number of assumptions to be made that inherently have varying
amounts of uncertainty.
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2 ANALYSIS OF COSTS AND HEALTH EFFECTS OF TRP DISPOSAL
2.1 TRU RISKS
Salt deposits, located in several regions of the country, are
viable candidates for a TRU repository because their very existence
precludes groundwater flow. Qualitative problems with salt do
exist and are discussed in the BID. These include the fact that if
groundwater flow does change in the future such that water contacts
the salt deposits, then the salt will dissolve and be carried away.
Therefore, stability of existing groundwater flows is essential,
and candidate sites must be expected to remain intact for thousands
of years. Additionally, the probability of inadvertent drilling
into the repository is higher for salt, as compared to other media,
because salt formations are usually located in areas that contain
commercially valuable resources. The waste disposal system
considered in the risk assessment accompanying this EIA and the
source of risk information for this EIA is based on national plans
to develop mined geologic repositories for disposal of TRU wastes.
Such repositories consist of underground mines or excavations with
working levels between 300 and 1000 meters below the surface.
Wastes would be packaged in metal drums and stacked in the mined
waste disposal rooms. After emplacement of the waste, the disposal
facility would be backfilled to enhance its mechanical stability
and to retard the movement of fluids.
2.1.1 Pathways
Radionuclides may travel from the repository to the accessible
environment in three general ways: 1) direct pathways to the land
surface, such as might occur if future generations penetrated the
repository during an exploratory drilling program and accidentally
contacted the wastes, 2) vertical migration in slowly moving ground
water to an aquifer and then to the surface, and 3) transport of
radioactive gases to the ground surface from a repository in the
unsaturated zone.
2.1.2 Understanding the Individual Dose
Individual exposures are estimated as the annual radiation
dose an individual receives from consuming two liters of
groundwater per day at a distance of 2000 meters from the boundary
of the repository. Since the nuclear wastes will slowly migrate
from the repository after the canister fails, the primary
determinant of an individual's exposure is time. For a given waste
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form and canister life, the longer the time after placement of the
TRU wastes, the greater the number of radionuclides in the
groundwater. The low-probability events of drilling, seismic
activity, and volcanic activity are ignored for individual exposure
measures.
2.2 DEFINING THE OPTION
This report analyzes only one option for TRU waste disposal.
It assumes that the waste forms will have unlimited leach rates,
the wastes will be placed in canisters with zero-year lives and the
repository will be constructed in salt. No alternative medium,
canister life, or waste form leach rate is modeled. Also, costs
are available for only this option. Since health effects,
individual exposures, and cost information exists only for one
option, this EIA must limit its analysis to that option. Section
2.4 provides further details on this option.
2.3 POPULATION AND INDIVIDUAL RISKS
Estimates of population risks and individual exposures for a
TRU waste repository in this EIA are from the BID. For the
population risk estimates, the BID uses the concept of
"complementary cumulative distribution functions" (CCDF) to show
projected health effects for a variety of repository choices. For
individual exposures, it estimates the annual radiation dose,
measured in millirems per year, from consuming two liters per day
of groundwater two kilometers from the boundary of the repository.
The CCDF concept and the individual risk measure are discussed in
the following sections.
The presentation and analysis of health risks for the TRU
waste repository shows only one option presented for the TRU
facility. Population risks are measured as projected statistical
health effects while individual exposures (that is, millirem
doses) are measured as the maximum annual dosage over 10,000 years.
The expected number of health effects for a repository with
the characteristics of the one modeled is less than one over 10,000
years for the 5.42 million curies emplaced. Low probability events
such as volcanic eruptions, earthquakes and inadvertent drilling
are considered.
Since the repository is assumed to be mined in bedded salt
with no accessible groundwater pathway under undisturbed
conditions, no nuclides are expected to reach a groundwater system.
Gaseous release is not possible from bedded salt because of the
saturated condition of the surrounding rock. Because groundwater
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is also the pathway to the individual, the maximum individual
millirem dose over 10,000 years will also be zero.
2.4 COST OF TRU WASTES
2.4.1 General Elements
The TRU waste management system upon which the cost estimates
in this report are modeled consists of two major elements —
transportation system costs and the repository costs. The
transportation system will use trucks to ship TRU wastes to the
repository via pre-approved routes. This EIA does not consider the
transportation system risk, but only analyzes the repository itself.
The repository is projected to contain 5.42 million curies of TRU
wastes consisting of the types and quantities of nuclides as
specified in the BID.
The repository for TRU wastes is designed to receive, inspect,
and dispose of contact-handled and remote-handled TRU wastes.
(Contact-handled wastes are those that can be handled directly
since the shielding provided by the waste package prevents
exposure. Remote-handled wastes are those that have enough
contamination for beta, gamma, or neutron activity to require
remote handling.)
Exhibit 3 presents the costs of the TRU waste repository.
Information is given for each year over the projected 44-year life
of the facility. Specific cost components are given in section
2.4.2. Total costs over the life cycle of the TRU waste repository
are shown. Costs are given in undiscounted 1990 dollars. Briefly,
total undiscounted costs for a repository constructed in salt are
estimated to be $3.8 billion. Discounting this cost stream to
achieve a present value cost at 2 percent yields a total discounted
cost of $2.3 billion for such a facility.
Costs for canisters and waste forms are assumed to be zero.
Generally, the waste form is simply the form of the wastes as they
leave the site where they were generated and/or stored. No
particular engineered waste form will be considered. Similarly, no
particular engineered canister will be considered — the TRU wastes
will be emplaced in the repository in the packages in which they
arrive from the TRU waste generators and/or storage facilities.
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Exhibit 3
Annual TRU Waste Management system costs
	(in 1,000's of 1988 $)	
WIPP Transportation Repostitory Total System
Fiscal
Year Phase
(See note 1.)
(See note
2.)
(in $1,000'S)
1976
construction

6
700
6,700
1977
construction

11
547
11,547
1978
construction

29
431
29,431
1979
construction

31
461
31,461
1980
construction

24
986
24,986
1981
construction

16
928
16,928
1982
construction

38
845
38,845
1983
construction

110
296
110,296
1984
construction

121
000
121,000
1985
construction

67
945
67,945
1986
construction

13
773
13,773
1987
construction

35
566
35,566
1988
construction

115
302
115,302
1989
construction

127
424
127,424
1990
transition

106
504
106,504
1991
pilot plant
2,484
111
460
113,944
1992
pilot plant
2,484
107
461
109,945
1993
pilot plant
2,484
101
369
103,853
1994
pilot plant
2,484
95
188
97,672
1995
pilot plant
2,484
89
981
92,465
1996
full operation
4,969
98
333
103,301
1997
full operation
4,969
98
801
103,769
1998
full operation
4,969
98
801
103,769
1999
full operation
4,969
98
801
103,769
2000
full operation
4,969
98
801
103,769
2001
full operation
4,969
98
801
103,769
2002
full operation
4,969
98
801
103,769
2003
full operation
4,969
98
801
103,769
2004
full operation
4,969
98
801
103,769
2005
full operation
4,969
98
801
103,769
2006
full operation
4,969
98
801
103,769
2007
full operation
4,969
98
801
103,769
2008
full operation
4,969
98
608
103,576
2009
full operation
4,969
98
124
103,093
2010
full operation
4,969
97
641
102,609
2011
full operation
4,969
97
157
102,126
2012
full operation
4,969
96
481
101,449
2013
phase out
4,969
84
590
89,558
2014
phase out
4,969
76
566
81,534
2015
phase out
4,969
64
868
69,837
2016
decommission

65
694
65,694
2017
decommission

60
641
60,641
2018
decommission

53
566
53,566
2019
decommission

42
449
42,449
Total

$111,792
$3,484
698
$3,596,490
Note 1:
Transportation costs
computed based
on WIPPc.


They are for CH waste only.
Note 2s Repository costs from WIPPd. They include a contingency factor.

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2.4.2 Detailed Cost Components
The DOE plans to dispose of TRU waste from national defense
programs in a geologic.repository located in bedded salt in Eddy
County, New Mexico. The TRU waste repository is designated as the
Waste Isolation Pilot Plant (WIPP). The construction of the WIPP
was authorized by the Department of Energy National Security and
Military Applications of Nuclear Authorization Act of 1980 (Public
Law 96-164) (DOE79) and is classified as a defense activity of the
DOE, exempt from Nuclear Regulatory Commission regulations.
The life-cycle of the TRU waste management system began in
1976 when conceptual design work on the WIPP was initiated. The
period from Fiscal Year 1976 (FY 1976) until FY 1989 can be
generally characterized as a period of research and development
(R&D) and construction of WIPP facilities. The TRU waste
management system is currently entering a six year transition and
pilot plant phase that extends from FY 1990 to FY 1995. The full
operations phase is expected to last for seventeen years (FY 1996
to FY 2012) . Full operations will then be phased out over a three-
year period (2013 to 2015). The TRU waste management system life-
cycle will end in 2019 after a four-year decontamination and
decommissioning phase.
The major elements of the TRU waste management system are the
transportation system and the WIPP. It is expected that TRU waste
from ten sites will be shipped to the WIPP for disposal. The
estimated volume of TRU waste to be disposed of is 175,640 cubic
meters of contact-handled waste and 7082 cubic meters of remote
handled waste. (FEIS90)
2.4.2.1 Selection of Reference System Costs
A significant portion of the TRU waste management system
currently exists as facilities and equipment at . the WIPP site.
Consequently, sunk costs for these existing facilities and
equipment were used as reference costs. In addition to costs for
currently existing facilities and equipment, estimates of future
capital and operating expenditures were needed to identify the
life-cycle costs for the reference TRU waste management system.
The reference WIPP sunk costs and estimates of future expenditures
were provided for this EIA by the DOE. (WIPPa, WIPPb)
Transportation reference costs are based on current WIPP life
cycle projections which were provided by the DOE as well.
Currently, figures are only available for contact-handled waste,
which comprises 97 percent of the waste going into WIPP. These
figures cover the amount WIPP will pay to its trucking contractor
to haul the waste, the WIPP costs to handle waste packages, fees
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paid to states in transit, maintenance costs, and the cost of
purchasing the waste packages themselves.
It should be noted here that the costs for Type A TRU waste
disposal inner packages (55-gallon drums, 30 gallon drums, standard
waste boxes, etc.) containing the contact-handled and remote-
handled TRU waste at the sites are not currently part of the cost
of the WIPP or transportation elements of the TRU waste management
system. The cost of the waste disposal packages will be absorbed
by the individual TRU waste storage and/or generator site that
ships TRU waste to the WIPP. The cost for the outer Type B
packages (TRUPACT-II and the remote-handled package) and a Type B
package maintenance facility are included in the WIPP repository
costs. Thus, the cost for Type A waste packages are additional to
the estimates provided below for the TRU waste management system.
2.4.2.2 Reference Costs
The major cost categories during the life-cycle of the TRU
waste management system are transportation and WIPP repository.
The summary of reference costs for the TRU waste management system
are contained in Exhibit 4. These costs are undiscounted. The
total system life cycle cost, discounted at 2 percent, is $2.3
billion. The costs, in constant 1990 dollars, for the TRU waste
management system are expressed on an annual basis in Exhibit 3.
EXHIBIT 4
SUMMARY OF TRU WASTE MANAGEMENT SYSTEM COSTS
COST CATEGORY
MILLIONS OF
1990 DOLLARS
Repository (WIPP)
3,786.6
Transportation
121.5
Total System
3 ,908
Transportation
The WIPP is designed to dispose of a waste inventory
consisting of 175,640 cubic meters of contact-handled TRU waste and
7082 cubic meters of remote-handled TRU waste that is currently in
retrievable storage or projected to be generated through the year
2013. The sites that are expected to send contact-handled TRU
waste and/or remote-handled TRU waste to the WIPP are Idaho
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National Engineering Laboratory, Idaho; Rocky Flats Plant,
Colorado; Hanford Reservation, Washington; Savannah River Plant,
South Carolina; Los Alamos National Laboratory, New Mexico; Nevada
Test Site, Nevada; Oak Ridge National Laboratory, Tennessee;
Argonne National Laboratory-East, Illinois; Lawrence Livermore
National Laboratory, California; and Mound Plant, Ohio.
The current plan is that all shipments of contact-handled and
remote-handled TRU waste to the WIPP will be by truck. Trucks will
pick up the TRU waste at the respective sites around the country
and transport the waste to the WIPP via pre-approved routes.
The contact-handled TRU waste will be placed in Type A
packages at the waste sites. The contact-handled TRU packages are
expected to be Type A 55-gallon drums or standard waste boxes for
transport to the WIPP. Type A and B packing specifications are
contained in NRC regulations, under 10 CFR 71. The proposed design
of the Type B package for the contact-handled TRU waste is the
TRUPACT-II. The TRUPACT-II has a capacity of fourteen 55-gallon
drums or two standard waste boxes. A "low-boy" trailer carrying
three TRUPACT-II packages per trip will transport the contact-
handled TRU waste to the WIPP.
The package in which the remote-handled TRU waste will be
transported to the WIPP will also be able to meet TYPE B design
criteria. The DOE is currently developing the Type B package that
will be used for the remote-handled TRU waste. The remote-handled
TRU waste will be contained at the sites in 55-gallon drums, 30-
gallon drums, or similar containers that will be loaded into the
Type B packages designed for transportation of the remote-handled
TRU waste to the WIPP.
Transportation costs for WIPP are projected over a 2 5 year
life cycle, and broken down into four components:
1)	Trucking Contract Cost. This is the cost that the
trucking company charges to haul the waste, and includes
the cost of drivers, driver training, fuel, and the cost
to lease the tractors which haul the trailers on which
the Type B waste packages are placed. A total of
40,905,000 miles will be covered hauling all the waste
from the sites to WIPP, at a shipping cost of $1.86 (1990
dollars) per mile.
2)	Fleet Purchase. This is the cost of the TRUPACT-II waste
containers and the cost of the trailers on which they are
placed. The cost for one TRUPACT-II is around $313,490
in 1990 dollars. The current plan is to purchase 17 of
them.
3)	Operational Cost. This is estimated to cost $1,268 per
shipment in 1990 dollars, and WIPP is using a figure of
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16,763 shipments to move all the wastes from the sites to
WIPP. Operational costs cover state fees incurred in
transit and the cost of loading and unloading the Type B
packages from the trailers at the origin sites and at the
destination.
4) Maintenance Cost. This covers spare parts and other
miscellaneous costs.
The total life-cycle cost for transportation to and from WIPP
is an estimated $121,475,000 or $2.97 per mile in 1990 dollars over
a total distance of 40,905,000 miles. Note again that this figure
only covers contact-handled waste.
Exhibit 5 contains a summary of the transportation costs of
the TRU waste management system.
EXHIBIT 5
REFERENCE TRU WASTE TRANSPORTATION COST ESTIMATES
COST CATEGORY
THOUSANDS OF 1990
DOLLARS
Trucking Contract Cost
73,219
Operational Cost
21,427
Fleet Purchase
17,900
Maintenance
8,930
Total Transportation Costs
121,475
Repository
The WIPP is designed to receive, inspect, and dispose of
contact-handled and remote-handled TRU waste in a repository mined
in the bedded salt underlying the WIPP site. The surface
facilities at the WIPP include the waste handling building, shaft
filter building, warehouses, etc. The underground facilities
include the shafts that connect the surface to the underground
repository horizon, the waste-disposal area, an experimental area,
and an equipment and maintenance support area.
All TRU waste is received at the waste handling building of
the WIPP where it is inspected, inventoried, and prepared for
disposal. From the waste handling building, the TRU waste is
transported via the waste shaft to the underground facilities for
disposal.
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The figures given are considered to be conservative: when
multiplied by the contingency rates of 0 percent in the Pilot Plant
Phase, 10 percent in the Full Operation and Operation Phase-Out
periods, and 15 percent in the Decontamination and Decommissioning,
the grand total rises from $3,567,420,000 in 1990 dollars to
$3,907,530,000.
Exhibit 6 contains a summary of the capital, waste operating,
waste capital equipment, general plant projects, and contingency
costs for the WIPP. Also included in the summary WIPP costs are
expenditures related to the development, testing, manufacture, and
maintenance of TRUPACT-II and remote-handled TRU waste Type B
packages.
EXHIBIT 6
REFERENCE REPOSITORY COST ESTIMATES
COST CATEGORY
THOUSANDS OF
1990 DOLLARS
Capital Costs
444,354
Waste Operating
2,915,312
Waste Capital Equipment
160,385
General Plant Project
47,373
Contingency
219,123
Total Repository Costs
3,786,549
Waste Disposal Packages
As discussed above, the cost of the disposal waste packages
containing the TRU are not included within the reference costs of
the transportation and repository elements of the TRU waste
management system. Waste package costs are absorbed by the TRU
waste generators and/or storage facilities. Unit costs for TRU
disposal waste packages are contained in Exhibit 7.
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EXHIBIT'7
REFERENCE UNIT COST FOR TRU WASTE
DISPOSAL PACKAGES:
WASTE DISPOSAL PACKAGE
1990 DOLLARS
CH TRU 55 Gallon Drum
$79
CH TRU Standard Waste Box
$1,475
RH Disposal Canister
n/a
2.4.2.3 Design of Repository and Waste Packages for TRU Waste
The elements of the TRU waste management system most likely to
be impacted by 40 CFR 191 are the repository and waste packages.
This section discusses in detail the repository facility and the
waste packages that will be used for TRU disposal.
Repository Design
The WIPP site is located in Eddy County in southeastern New
Mexico. The site is about 2 5 miles east of Carlsbad, New Mexico
and about 45 miles southwest of Hobbs, New Mexico. The site is in
an area known as Los Medanos which is relatively flat, and sparsely
populated. The land the WIPP site occupies is owned by the Bureau
of Land Management.
The WIPP site boundary is defined by a 16 square mile area.
There are two control zones within this boundary. Control Zone I
contains most of the surface facilities and occupies approximately
100 acres. Control Zone II covers about 1,800 acres that overlies
the maximum limit of the underground facilities.
Surface Facilities
The principal surface structure is the waste handling
building. All TRU waste is routed through this building. The
building has separate areas for the receipt, inventory, and
transfer of the contact-handled and the remote-handled TRU waste to
the waste shaft.
The areas for the contact-handled waste include shipping-and-
receiving, receiving-and-inspect ion, inventory-and-preparation, and
a overpack-and-repair room for damaged waste packages. The
separate facilities for the remote-handled waste include shipping-
and-receiving areas, shipping-cask preparation and decontamination,
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an area for unloading casks, and a hot cell. The contact-handled
and remote-handled TRU waste is transferred to the waste shaft
through separate air-locks. In addition to the TRU waste
facilities, the waste handling building also contains change rooms,
a health physics laboratory, eguipment for ventilation and
filtration, and an attached facility for the maintenance of Type B
packages. Some of the other surface facilities at the WIPP site
include a shaft filter building, warehouses, a construction
management and maintenance complex, a safety and emergency services
building, a security building, etc.
Underground Facilities
The underground facilities of the WIPP are constructed beneath
the surface facilities in the bedded salt of the Salado Formation
(the underground repository horizon), approximately 2,150 feet
(655.5 meters) beneath the surface. The underground facilities
consist of the shafts that connect the surface facilities to the
underground repository horizon and the facilities excavated in the
underground repository horizon.
There are four shafts at the WIPP. These shafts are used for
air intake, salt-handling, TRU waste handling, and air exhaust,
respectively.
The facilities in the underground repository horizon include
the waste disposal area, an experimental area, an equipment and
¦maintenance area, aftd connecting drifts. The waste disposal area
will consist of emplacement and access drifts laid out in a "room-
and-pillar" configuration. The total waste disposal area needed to
emplace the 175,640 cubic meters of contact-handled TRU waste and
the 7,082 cubic meters of remote-handled TRU waste is estimated to
be about 100 acres. To date, only about 15 acres of this area has
been completed. The experimental area and the equipment and
maintenance areas are located to the north of the waste disposal
area and are largely complete.
Contact-handled TRU waste will be transported to the
underground repository horizon via the waste shaft. It is
expected that the contact-handled TRU waste arriving in the
repository horizon will be contained in 55-gallon drums or standard
waste boxes placed on pallets. The pallets on which the TRU waste
has been placed will be transported to an emplacement drift where
the pallet will be placed on the floor of the drift or stacked on
top of previously emplaced contact-handled TRU waste packages.
Emplacement drifts are to be backfilled with salt.
Remote-handled TRU waste will be transported to the
underground facilities via the waste shaft in a facility cask
holding one canister of remote-handled TRU waste. The canister is
horizontally emplaced in steel-lined holes in the salt pillars.
The holes will then be capped with a shielded steel plug. These
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drifts will not be backfilled until a decision on retrieval of the
remote-handled TRU waste has been made.
Waste Packaging Design
Package designs are developed for two types of wastes:
contact-handled wastes and remote-handled wastes. With respect to
contact-handled waste, storage containers are 55-gallon steel drums
and standard waste storage boxes. Descriptions of remote-handled
waste storage containers are not available.
2.5 COSTS OF DEMONSTRATING COMPLIANCE WITH INDIVIDUAL AND
GROUNDWATER REQUIREMENTS
Computer modeling of environmental pathways to determine nuclide
releases to the accessible environment is performed as part of the
general containment requirements. Such modeling is also a first
step, and a major step, in determining releases to groundwater and
doses to individuals. Additional modeling is performed on releases
to the accessible environment, through specific pathways, to
determine compliance with individual and groundwater requirements.
Thus, the cost of demonstrating compliance with these requirements
is likely only to be slightly incremental to those efforts already
required to be undertaken to show compliance with the containment
requirements. The total additional cost is likely to be only a
small percentage of the total cost of modeling and an insignificant
fraction of the total cost of disposal. EPA experience in
environmental pathway modeling suggests that the cost of this
effort should not exceed $1 million.
Additionally, with the reinstatement of the containment
requirements, any costs of the characterization of a TRU disposal
site should fall under the satisfaction of demonstrating compliance
with those requirements. The geological information required to be
collected to adequately characterize the site is identical for both
the containment requirements and for the individual and groundwater
requirements.	Therefore few, if any, of the costs of
characterization can be said to fall to the groundwater and
individual containment requirements.
2.6 REAL IMPACT OF 40 CFR 191 AMENDMENTS
Because of the reinstatement of the containment portion of 40
CFR Part 191, there is no economic impact of this amendment.
Modeling results for a TRU disposal site in a salt media indicate
that the groundwater, individual dose requirements, and the
containment requirements contained in 40 CFR Part 191 are met
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concomitantly. In fact, for the TRU salt site modeled, groundwater
and individual doses were zero. This results from the fact that
the measures used to ensure that the containment requirements are
met and retard nuclides from entering the environment outside of
the repository (in this case, the salt media) also act to protect
groundwater and the individual, at least in the instance modeled.
Data are unavailable for the disposal of TRU in other types of
media of serious interest. Because of this it is currently
impossible to say with certainty whether or not the same
circumstances apply for these other media and what the impact might
be at alternate sites for the imposition of the groundwater and
individual dose requirements. However, a multimedia study is
planned to address the impact of the amendments on alternative
media in the next iteration of this analysis.
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CHAPTER 3
SENSITIVITY ANALYSIS
The preceding analysis has looked at the impact of the
amendments as they currently exist. A sensitivity analysis is
performed to determine the result of a change in the level of the
standard, either relaxing or becoming more stringent, on the cost
of the standard. This indirectly examines the cost-effectiveness
of the standard. The effect of varying the period of performance
is also examined.
3.1 VARYING THE DOSE LEVEL
As developed previously, the modeling results demonstrated
that over the 10,000 year period of the analysis, there was zero
discharge to any groundwater pathway. Individual dose was zero and
groundwater contaminant levels were also zero. If these results
were to be interpreted as applying to all salt media repositories,
the implication would be that the level of a standard could be set
at zero for both individual dose and groundwater radionuclide
contaminants. This would have no cost impact as it requires no
improvement in containment technology. Likewise, the same result
holds for setting the standard at any level between the current
level and zero.
Conversely, the impact of setting the level of the standard
higher than currently proposed is also zero, if the difficulty of
showing compliance with the standard can be ignored (it may be that
there is some correlation between the difficulty of showing
compliance with a standard and the cost of this demonstration and
the stringency of the standard). The same disposal technology is
used regardless of the level of the standard.
3.2 1,000 VERSUS 10,000 YEAR PERIOD OF PERFORMANCE
A 1,000 year time frame for the period of performance was
previously considered by EPA as part of this amendment, as opposed
to the current 10,000 year form of the standard. This was
discarded for reasons discussed in the Preamble to the proposed
rule. The economic impact of a 1,000 versus 10,000 year standard
is believed to be small. As discussed in Chapter 2, for the media
best characterized and for which modeling results are available
(salt), there are zero releases over the entire 10,000 year period
of the analysis. Therefore, extending the period of performance
from 1,000 years to 10,000 years requires no additional engineering
controls to achieve the standard.
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Additional efforts, including modeling, necessary to
demonstrate compliance with the standards over the 10,000 period
(versus the 1,000 time period) are believed to be small. The
efforts to demonstrate compliance with the 1,000 year time period
are not believed to be large relative to overall effort and the
analysis for the 10,000 year period would only be slightly
incremental to that for a 1,000 year period.
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CHAPTER 4
GENERAL ECONOMIC IMPACTS OF TRU DISPOSAL
The previous chapters have discussed the costs expended on
repository development for the single option of disposing of TRU
wastes and the health effects, individual exposures, and
groundwater contamination associated with TRU disposal. The focus
was on the extent to which the amendments to 40 CFR Part 191 impose
additional costs over and above existing regulatory requirements.
This chapter takes a broader view. Ignoring the fact that
there is no incremental impact of the amendments to 40 CFR Part
191, a viable question to ask is that of the impact of TRU
disposal on the economy.
The $2.3 billion cost of TRU disposal will fall to DOE. These
costs then fall to the Federal government. The evaluation of the
economic impacts of Federal government expenditures to comply with
waste disposal are not developed through the use of a quantitative
model. Instead a qualitative discussion is provided. A
quantitative model is not analytically useful because, given the
small size of the waste disposal expenditures relative to the
Federal budget, determining the origin of the funds, their impacts,
or their opportunity costs is not possible.
Perhaps funds would be raised by increased taxation or
government borrowing. In the absence of a direct tax or bond
issuance to fund this specific program it will be impossible to
trace the impact of increased funding in anything more than the
most general terms. Consequently, it will also be impossible to
identify the alternative uses to which these funds would have been
put in the private sector. Thus the impact as well as the
opportunity cost of diverting the funds to public use cannot be
accurately quantified. Conversely, there seems to be no reason to
assume that the impacts will fall disproportionately on any
particular group in society.
Perhaps funds would be raised at the expense of other
government programs. There could be a slight change in funding
over an unspecified group of programs or a larger change in
specific programs. It might be argued that DOE nuclear programs
would be the most likely victims of such cuts. Again, it will be
impossible to determine the exact origin of funds and thus the
impacts or opportunity costs.
Regardless of the origin of the funds, the most useful way of
analyzing the expenditures are as transfer payments in that the
expenditures are generated through taxation or some other means and
are spent on the waste disposal program. This transfer of funds by
the Federal government is likely to have a positive impact on
certain regions and industries. The impacts are the result of
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fiscal injections and could be measured in costs for particular
goods and services, which are specified in Chapter Two. These
costs could also be converted to associated impacts on employment
(which may increase) and income although this is not done in
Chapter Three. The local area chosen for the waste disposal site
will most certainly receive increased infusions of Federal dollars.
There should be no disproportionate increase, however, in Federal
taxes paid by the affected localities or industries involved.
Beyond the positive benefits accruing to certain localities
and industries, no discernible patterns of economic impacts should
occur. Since expenditures will be derived from general revenues,
no negative impacts on particular industry segments or small
businesses should occur.
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REFERENCES
DOE 79 U.S. Department of Energy, National Security and
Military Applications of Nuclear Energy Act of 1980.
Public Law 96-164, December 29, 1979.
EPA 9 2A Environmental Protection Agency, Environmental Standards
for the Management and Disposal of Spend Nuclear Fuel,
High-Level and Transuranic Radioactive Wastes, Draft
preamble to the proposed rule, August 14, 1992.
EPA 92B Environmental Protection Agency, Draft Federal Register
Notice for 40 CFR Part 191, August 14, 1992.
EPA 92C Environmental Protection Agency, Background Information
Document for Amendments to 40 CFR Part 191, October,
1992.
FEIS 9 0 U.S. Department of Energy, Office of Environmental
Restoration and Waste Management, Final Supplement—
Environmental Impact Statement. Waste Isolation Pilot
Plant, January 1990.
Hunt 1 Letter from Mr. Arlen Hunt, Acting Project Manager of the
Waste Isolation Pilot Plant Project Office, Albuquerque
Operations Office, Department of Commerce, to Mr. Elliott
Foutes, Environmental Protection Agency, March 15, 1990.
ORNL 91 Oak Ridge National Laboratory, Integrated Data Base for
1991: Spend Fuel and Radioactive Waste Inventories,
Projections and Characteristics, DOE/RW-0006, Rev. 5,
October 1991.
WIPPa	Letter from Mr. Arlen Hunt, Acting Project Manager of
the Waste Isolation Pilot Plant Project Office.
Albequerque Operations Office, Department of Energy,
to Mr. Dan Egan, Environmental Protection Agency,
January, 31, 1990.
WIPPb	Letter from Mr. Arlen Hunt, Acting Project Manager of
the Waste Isolation Pilot Plant Project Office,
Albuquerque Operations Office, Department of Energy,
to Mr. Elliott Foutes, Environmental Portection
Agency, March 31, 1990.
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