ML12339A493

Official Exhibit - NRC000049-00-BD01 - Damages from a Major Release of 137 Cs Into the Atmosphere of the United States

ML12339A493
Person / Time
Site:	Indian Point
Issue date:	03/30/2012
From:	Beyea J, Edwin Lyman, Von-Hippel F - No Known Affiliation
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 22152, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12339A493 (12)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit NRC000049 Entergy Nuclear Operations, Inc.

In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3) Submitted: March 30, 2012 ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: NRC000049-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

Science and Global Security, 12:125-136, 2004 Copyright 

C Taylor & Francis Inc.

ISSN: 0892-9882 print DOI: 10.1080/08929880490464775 Damages from a Major Release of 137Cs into the Atmosphere of the United States by Jan Beyea, Ed Lyman, Frank von Hippel We report estimates of costs of evacuation, decontamination, property loss, and cancer deaths due to releases by a spent fuel "re of 3.5 and 35 MCi of 137 Cs into the atmosphere at "ve U.S. nuclear-power plant sites. The MACCS2 atmospheric-dispersion model is used with median dispersion conditions and azimuthally-averaged radial population densities. Decontamination cost estimates are based primarily on the results of a Sandia study. Our "ve-site average consequences are $100 billion and 2000 cancer deaths for the 3.5 MCi release, and $400 billion in damages and 6000 cancer deaths for the 35 MCi release. The implications for the cost-bene"t analyses in Reducing the hazards are discussed.

INTRODUCTION Reducing the hazards from Stored Spent Fuel in the United States (Science &

Global Security 11, pp. 1-51), of which we were coauthors, quoted the results of Received 21 January 2004; accepted 21 January 2004.

Addendum to Reducing the hazards from stored spent power-reactor fuel in the United States, by R. Alvarez, J. Beyea, K. Janberg, J. Kang, E. Lyman, A. Macfarlane, G. Thomp-son, and F. von Hippel, Science & Global Security, 11(2003), pp. 1-51.

Address correspondence to Jan Beyea, Consulting in the Public Interest, 53 Clinton St.,

Lambertville, NJ 08530. E-mail: jbeyea@cipi.com J. Beyea, Consulting in the Public Interest, Lambertville, NJ.

E. Lyman, Union of Concerned Scientists, Washington, DC.

F. von Hippel, Program on Science and Global Security, Princeton University, Princeton, NJ.

126 Beyea, Lyman, von Hippel a 1997 Brookhaven study,1 which estimated the damages from a release of 8-80 MCi of 137 Cs into the atmosphere as $117-$566 billion and 54,000-143,000 cancer deaths. Reducing the hazards also included (in footnote 29) damage estimates calculated using the wedge atmospheric-dispersion model for re-leases of 3.5 and 35 MCi assuming a uniform population density of 250/km2 .

In this note, we present the results of a calculation based on real radial popu-lation density distributions around "ve U.S. reactor sites and using the Sandia MACCS2 atmospheric-dispersion model.2 Population Density We have used year-2000 population distributions averaged azimuthally around "ve sample locations chosen to represent the range of U.S. reactor sites. They are: Catawba, near Rock Hill, South Carolina; Indian Point, on the Hudson River near New York City; LaSalle County near Spring"eld, IL; Palo Verde, near Phoenix, AZ; and Three Mile Island, near Harrisburg, PA.

Figure 1 shows the cumulative populations within a given radius out to 1600 km from each of these nuclear power plants multiplied by a factor of Figure 1: Cumulative population as a function of distance from "ve U.S. nuclear power plants multiplied by a plume-width factor of 0.038.

137 Cs Damages From Atmospheric Release of in U.S. 127 Table 1: EPA unshielded radiation dose limits for long-term occupation of contaminated land and corresponding derived 137 Cs surface contamination levels.

137 Cs contamination level (Ci/km2 )

Period EPA dose limit (rem) EPA4 MACCS25 First year after release 2 44.4 41 Second year after release 0.5 17.2 14.4 Cumulative 50-year dose 5 8.2 6 0.24/(2).3 This factor is used so that the "gure can be used to convey a sense of the size of the population that might be within a downwind plume, which we have approximated for this purpose as a radial wedge with a 0.24-radian opening angle. We do not include the populations of Canada or Mexico.

Contamination Thresholds for Evacuation The EPA has proposed allowable radiation-dose limits for unshielded individ-uals above which relocation would be recommended. These limits are shown in Table 1, along with the corresponding contamination limits calculated by the EPA and in the MACCS2 model.

We have chosen a 137 Cs contamination level of 15 Ci/km2 as our threshold for decontamination. This corresponds approximately to EPAs limit of no more than 0.5 rem unshielded dose in the second year of exposure. This contamina-tion level would give cumulative 50-year doses more than twice the EPAs limit of 5 rem. However, on a threshold of 15 Ci/km2 corresponds to the de"nition of the zone of strict radiation control established within the area contami-nated by the Chernobyl accident. According to a recent U.N. study of the conse-quences of the Chernobyl accident, [w]ithin these areas radiation monitoring and preventative measures have been generally successful in maintaining an-nual effective dose within [0.5 rem/yr].6 An area approximately equal to that contaminated above 50 Ci/km2 by the Chernobyl accident remains evacuated.7 Decontamination The most recent and detailed study of the effectiveness and costs of radioac-tive decontamination was done for Sandia National Laboratories in 1996.8 The study was of the problem of decontamination after plutonium dispersal by a warhead accident but was based mostly on experiments with "ssion prod-ucts. Contamination levels were de"ned as lightly-contaminated (requiring a

128 Beyea, Lyman, von Hippel decontamination factor [DF] of 2-5); moderately-contaminated (DF = 5-10);

and heavily contaminated (DF > 10).9 For heavily contaminated areas, the study "nds that:

we have been unable to discover any practical method that could reliably achieve successful decontamination short of completely demolishing buildings and disposing of the material in a licensed burial facility.10 We assume that, at the edge of heavily contaminated areas there would be a gray zone where a few years of radioactive decay will reduce the contamination to a level where decontamination by a factor of eight would make the area habitable again. However, the value of the property is assumed in the MACCS2 model to depreciate at an exponential rate of 20 percent per year so that, after a few years, the average residual value of the property will be less than the cost of decontamination.

Decontamination in the lightly and moderately contaminated areas is de-scribed in the Sandia report as involving the following measures:11 Lightly-contaminated areas (DF 2-5). [P]rompt vacuuming of all structural ex-teriors [and streets, sidewalks and driveways] followed by detergent scrub-bing and rinsing. Building interiors would be cleaned by . . . for example, re-peated vacuuming followed by shampooing for carpets . . . Turf in lawns [and any paved areas that could not be adequately decontaminated by less costly means] would be removed and replaced . . . Tree foliage would be hosed down, with the wash water collected to prevent runoff, and the trunks would be scrubbed.

Moderately contaminated areas (DF 5-10). Roo"ng would be removed and replaced, all landscape materials, including trees, would be removed, and "ooring furniture and personal effects would be removed from the interior.

The Chernobyl experience suggests, however, that decontamination by a factor of more than three may be unachievable. The U.N. study reports:12 The effect of decontamination procedures on external dose was stud-ied . . . before and after decontamination of the Belarusian village of Kirov. Decon-tamination procedures included replacing road surfaces, replacing roofs on build-ings, and soil removal. The results . . . suggest that decontamination were most effective for school children and "eld workers [decontamination factors of 1.5 and 1.3 respectively] but had limited effect on other members of the population. Simi-lar estimates have been obtained with regard to the decontamination of Russian settlements in 1989. The average external dose ratio measured after and before

137 Cs Damages From Atmospheric Release of in U.S. 129 Table 2a: Per capita contamination costs estimated in the Sandia report.

Decontamination factor 2--5 5--10 >10 Decontamination $19,000 $42,000 $31,000 Compensation $20,000 $30,000 $135,000 Subtotal $39,000 $72,000 $166,000 Waste disposal $14,000-57,000 $15,000-60,000 $32,000-130,000 Total (rounded) $50,000-100,000 $90,000-130,000 $200,000-300,000 decontamination was found to range from 0.70 to 0.85 [DF 1.2-1.4] for different settlements.

Nevertheless, we assume that decontamination by up to a factor of eight would be feasible. In our calculations, the boundary between lightly and mod-erately contaminated areas has been set at a decontamination factor of three and that between moderately and heavily contaminated areas at eight.

Table 2a shows by level of contamination the estimates made in the Sandia report of the per capita costs for decontamination, compensation, and radioac-tive waste disposal in a mixed-use urban area.13 Compensation costs are based on replacement cost for lost property and 3, 6, and 12 months rental for displaced residents during decontamination of lightly, moderately and heavily contaminated areas, respectively.14 For the residents of condemned properties, it was assumed that the properties would be paid for within a year. It was assumed that, in moderately contaminated areas, motor vehicles, furnishings and appliances would have to be replaced.

During the decontamination period, displaced persons would also receive al-lowances for clothing, electronic entertainment items, household articles, and work related tools. It was assumed compensation would be paid to commercial establishments for their complete stocks and for their average payrolls and net income for 3, 6 or 12 months for lightly, moderately or heavily contaminated areas respectively.

The Sandia study found the costs of disposing of radioactive decontamina-tion wastes to be a signi"cant part of the total cleanup costs. Both on-site and off-site disposal were considered. For on-site disposal, it was assumed that the waste would be containerized, cement stabilized, and emplaced in reinforced-concrete lined trenches buried under 5 meters of cemented broken rock and an 0.61 m thick concrete cap. This resulted in a cost estimate of $318/m3 of waste.

This cost would be reduced by approximately a factor of two for a less pro-tective [on-site] disposal system that just met current requirements.15 Off-site disposal was assumed to involve truck shipment in steel containers 1000 miles

130 Beyea, Lyman, von Hippel to a government facility that would accept low-level transuranic waste (recall that this study is for a plutonium contamination accident). The resulting cost estimate was $666/m3 with transportation accounting for slightly over half the cost. The waste-disposal costs shown in Table 2 are for a range of costs from

$167 to $666/m3 . We have used the bottom of this range in making our own cost estimates.16 The authors of the Sandia report state that, [a]lthough in some instances we have chosen parameter values conservatively, the resultant bias is com-pensated to some unknown extent by the many potential costs that have been omitted from our estimates.17 Some of the omitted costs discussed in the report are the following:

 If mistakes or de"ciencies were found, it is possible that some actions might need to be redone or augmented, at additional expense. We have not at-tempted to account for those possible additional costs.18

 Administrative and support costs for the cleanup of Enewetak Atoll were roughly equal to the direct cost of conducting remediation . . . [A]fter the Chernobyl accident, the Swedish governments cost tabulation for its emer-gency response programs showed that indirect administration and support were roughly equal to the cost of direct actions . . . We believe . . . that it might be reasonable to double the cost estimates provided [here] in order to ac-count for indirect costs.19

 [D]econtamination appears to become less effective with the passage of time. Most experiments have been conducted within a few days, or at most a few months of deposition.20

 Possible litigation costs are not addressed . . . Because of the adverse impact of delays, costs could increase even if lawsuits proved unsuccessful.21

 We assumed that properties acquired by the government [for remediation and restoration] would be resold without loss.22

 The cost estimates . . . do not include downtown business and commercial districts, heavy industrial areas, or high-rise apartment buildings. Inclusion of these areas would increase costs.23 The Sandia results dont quite match to the input requirements of the MACCS2 code, which, for example, does not allow for the inclusion of decon-tamination costs in permanently evacuated areas. We have therefore made the changes shown in Table 2b.

137 Cs Damages From Atmospheric Release of in U.S. 131 Table 2b: Per capita contamination cost assumptions used in our MACCS2 runs.

Decontamination factor <3 <8 >824 Decontamination25 $19,000 $42,000 $0-42,000 Compensation $25,00026 $30,000-132,00027 Relocation28 0 $3,600 $3,600 Waste disposal29 $14,000 $15,000 $0-15,000 Total $58,000 $85,600 $90,600-135,600 DAMAGE ESTIMATES Our consequence estimates for the "ve sites, for 3.5 and 35 MCi 137 Cs releases, are shown in Table 3.

The economic damages averaged over the "ve sites for the 3.5 and 35 MCi releases are approximately $100 and $400 billion, respectively. For compari-son, the cost estimates in Reducing the hazards, using the wedge model and assuming a uniform population density of 250/km2 , were $50 and $700 billion, respectively. The economic damages would largely be incurred within a few hundred km of the reactors. The population density within 400 km of the "ve sites averages about 80/km2 .

The "ve-site average of the estimated number of cancer deaths is 1900-5700, much less than the 50,000-250,000 estimated in Reducing the hazards using the wedge model and assuming a uniform population density. The dif-ference is due in large part to the fact that most of the population radiation dose occurs at large distances (small doses to large numbers of people) and the "ve-site average population density beyond 400 km is approximately 20/km2 much less than the 250/km2 assumed in Reducing the hazards. An additional Table 3: Estimates of economic losses ($billions) and cancer deaths.

Release Total Condemned Other Temporary Cancer Site (MCi) costs property losses30 relocation Decontamination31 deaths32 Catawba 3.5 71 10 32 0 29 3,100 35.0 547 145 192 11 199 7,650 Indian 3.5 145 43 42 5 56 1,500 point 35.0 461 282 85 8 86 5,600 LaSalle 3.5 54 2 23 1 27 2,100 35.0 270 10 121 7 131 6,400 Palo Verde 3.5 11 1 5 0 5 600 35.0 80 24 26 2 29 2,000 Three-Mile 3.5 171 13 65 6 87 2,300 Island 35.0 568 278 134 11 144 7,000 Averages 3.5 91 1,900 35.0 385 5,700

132 Beyea, Lyman, von Hippel reduction of about a factor of two can be attributed to the fact that a larger fraction of the 137 Cs deposits on the ground close to the reactor in the MACCS2 plume model than in the wedge-model because of the smaller vertical extent of the plume within the "rst 200 km and correspondingly higher ground-level concentration of the plume. These close-in deposits result in fewer cancers as a result of permanent evacuation and decontamination.

IMPACT ON THE COST-BENEFIT CALCULATION The "ve-site average of costs, including cancer deaths (valued at $4 million each) for releases of 3.5 and 35 MCi is $100 and $370 billion. The corresponding estimates in Reducing the hazards (endnotes 29 and 70) were $250 and $1700 billion. Then we compared the costs of taking spent fuel out of the pool and placing it into dry storage with the potential bene"ts of subsequently avoiding a spent fuel "re. In so doing, we sought to take into account our assumption that the cost of placing the spent fuel in dry storage would on average be incurred 15 years before the probabilistic bene"t of avoiding a spent fuel "re.33 Discounting the accident costs by an extra15 years led to the value of $100-$750 billion that was compared with the cost of transferring the spent fuel to dry storage.

To a large extent, however, discounting re"ects the assumption that soci-ety will be wealthier in the future and that the same expenditures later will therefore be a smaller fraction of this increasing wealth. In the present case, an increasingly wealthy society will also have more to lose from a spent-fuel "re. The two effects work in opposite directions. In this note, therefore, we have not discounted the estimated $100-$400 billion economic damages when comparing with the cost of early partial unloading of the spent fuel pools.

In Reducing the hazards, the cost of a spent-fuel "re was compared with the cost of placing into dry casks all of the spent fuel in the pools older than "ve years (estimated at 35,000 tons in 2010). This cost was estimated as falling in the range $3.5-$7 billion. We then used a mid-range number of $5 billion for our cost-bene"t estimate. Dividing this cost by the $100-$400 billion cost of a spent-fuel "re estimated here gives break-even probabilities for a spent-fuel "re occurring during the 30-year period ranging from 1.3 to 5 percent. The corresponding range calculated in Reducing the hazards (endnote 70) was 0.7 to 5 percent. In reality, the break-even probability would be somewhat higher, since removal of a fraction of the spent fuel would not entirely eliminate the risk of a spent-fuel "re.

It was noted in Reducing the hazards that removing one out of "ve fuel assemblies could result in each of the fuel assemblies remaining in the pool

137 Cs Damages From Atmospheric Release of in U.S. 133 Figure 2: Removal of one "fth of the spent-fuel assemblies could result in every fuel assembly having one side exposed to an empty channel.

having one side exposed to an empty channel in the rack (see Figure 2). If further analysis reveals that such a con"guration could be convectively air cooled, then only 9,000 tons of the 45,000 tons of spent fuel projected to be stored in U.S. spent-fuel pools in 2010 would have to be removed instead of 35,000 tons. In this case, the extra cost of dry spent-fuel storage would go down by approximately a factor of four and the break-even spent-fuel "re probability would go down correspondingly, although, once again, some correction would be needed to account for the residual probability of a "re. In this con"guration, the cesium inventory would not be greatly reduced while it would be reduced by approximately a factor of four if all the spent fuel more than "ve years old were discharged.

NOTES AND REFERENCES

1. A Safety and Regulatory Assessment of Generic BWR and PWR Permanently Shut-down Nuclear Power Plants by R. Travis et al., (Brookhaven National Lab, BNL-NUREG-52498, 1997).

2. D. I. Chanin and M. L. Young, Code Manual for MACCS2: Volume 1, Users Guide, Sandia National Laboratories, Albuquerque, NM, SAND97-0594, March 1997. As in Reducing the hazards, we assume a steady 5 m/sec wind, no rain, a mixing layer

134 Beyea, Lyman, von Hippel 137 height of 1000 meters, median (D-type) atmospheric dispersion conditions and a Cs deposition velocity of 0.01 m/sec.

3. The radial population densities were calculated using year-2000 computerized census-tract data available from GeoLytics, http://www.censuscd.com. According to the Bureau of the Census, census tracts generally have between 1,500 and 8,000 people

http://www.census.gov/geo/www/cob/tr metadata.html.

4. Manual of Protective Action Guides and Protective Actions for Nu-clear Incident (Of"ce of Radiation Programs, U.S. EPA, 1991), Table 7-1,

http://www.epa.gov/radiation/rert/pags.htm.

5. The MACCS2 model calculates the unshielded dose rate from 137 Cs as

[0.032rem/(yr Ci/km2)] x exp[t ln 2/(30)] x [exp(t ln 2/0.5) + exp(t ln 2/88.8)] =

0.032[exp(1.4t) + exp(0.031t)] rem/(yr-Ci/km2) with t measured in years. The 30-year half-life decay factor re"ects the radioactive decay of 137 Cs. The second two-exponential factor takes into account that the 137 Cs sinks into the soilrapidly at "rst and more slowly later. The ratio of the second-year to the "rst-year dose is 0.71. The ratio of the dose for the "rst three months to that of the "rst year is 0.3.

6. Sources and Effects of Ionizing Radiation, Vol. II. Effects, Annex J, Exposures and effects of the Chernobyl accident (U.N., 2000), para. 108, hereafter cited as Sources and Effects.

7. The area within 30 km of Pripyat (the village near the reactor where Chernobyl workers lived) remains evacuated (2800 km2 with a population of 90,000). Some highly contaminated areas outside the 30-km zone with a total population of 3600 were also evacuated. The total area contaminated to greater than 50 Ci/km2 has been estimated at 3100 km2 (Sources and Effects, Annex J) paras. 91-93 and Table 5.

8. Site Restoration: Estimation of Attributable Costs from Plutonium-Dispersal Acci-dents by David Chanin and Walter Mur"n (Sandia National Laboratories, SND96-0957, 1996), p. 5-7, hereafter cited as Site Restoration.

9. The decontamination factor is de"ned as the ratio of the external gamma dose rate before decontamination to that after.

10. Site Restoration, p. F-10.

11. Site Restoration, p. 5-9.

12. Sources and Effects, Annex J, para. 129.

13. Site Restoration, p. F-33, using a population density of 1344/km2 (p. G-23) plus the per capita costs in Tables F-4, F-5, and F-6.

14. Site Restoration, p. F-7.

15. Site Restoration, pp. F-24, F-27.

16. Waste produced as result of decontamination following an hypothetical spent fuel accident will fall into the lowest of the U.S. Nuclear Regulatory Commissions categories of low level radioactive waste, Class A, in which 137 Cs has a concentra-tion less than one Ci/m3 (NRC Regulations, 10 CFR, Part 61.55 -Waste Classi"ca-tion http://www.nrc.gov/reading-rm/doc-collections/cfr/part061/) The U.S. Army Corps of Engineers negotiated contracts with Envirocare for disposal of Class A debris at

137 Cs Damages From Atmospheric Release of in U.S. 135

$320/m3 in 1998 and $559/m3 in 1997, not including handling or transport (The Dis-position Dilemma: Controlling the Release of Solid Materials from Nuclear Regulatory Commission-Licensed Facilities, Washington, DC: National Academy Press, 2002. p. 80, assuming a averaged debris density of 1200 kg/m3 ). However, the total amount of Class-A waste needing disposal following a spent fuel accident is likely to be of the order of 100-million m3 for a 3.5 MCi release (one million affected persons times 90 m3 per person) which exceeds the annual amount of LLRW currently disposed of in the United States each year by a factor of about one thousand. (About 3 million cubic feet (0.08 million m3 ) of DOE and commercial LLRW were disposed of per year in 1998 and 1999, Texas Compact Low-Level Radioactive Waste Generation Trends and Management Alternatives Study: Technical Report, Rogers & Associates Engineering Branch URS Corporation, Salt Lake City, 2000, RAE-42774-019-5407-2, Tables 3.1 and 3.4). Consideration would therefore be given to other land"ll options. Cost of disposal at Resource Conservation and Recovery Act Subtitle C hazardous waste land"lls is typically $90/m3 , exclusive of waste preparation, handling, and transportation (The Disposition Dilemma, p. 78). Once again, however, the projected capacity for such land"lls, both currently and projected to 2013, is only about 1.5 million tons per year (National Capacity Assessment Report:

Capacity Planning Pursuant To CERCLA Section 104(C)(9), Demand for Commercial Hazardous Waste Capacity from Recurrent Land"ll Expected to be Generated In State (tons), at http://www.epa.gov/epaoswer/hazwaste/tsds/capacity/appa lf.pdf (25 March 2004)). Municipal waste (Subtitle D) land"lls, would typically charge $25/m3 (The Dis-position Dilemma, p. 78) but the concentration of 137 Cs is likely to exceed by an order of magnitude the 11 pCi/g concentrations associated with expected doses less than one mrem/yr to critical groups that have been discussed as possible consensus standards for disposal without controls (The Disposition Dilemma, pp. 119, 173). For soil with a bulk density of 1.3 g/cm3 removed to a depth of 10 cm, the average 137 Cs concentration would be 115 pCi/g for a surface contamination level of 15 Ci/km2 . The contamination levels of other types of debris would generally be higher.

17. Site Restoration, p. F-1.

18. Site Restoration, pp. 6-3, 6-4.

19. Site Restoration, p. 6-3. The factor might not be as great in the current case, however, because of economies of scale.

20. Site Restoration, p. 5-7.

21. Site Restoration p. 6-4.

22. Site Restoration, p. 2-5.

23. Site Restoration, p. 6-2.

24. Decontamination by a factor of eight would make regions near the edge of this zone habitable during the few-year period before depreciation reduces the value of the property to the point where decontamination is no longer cost effective. MACCS2 does not include the decontamination costs that Site Restoration estimates would be incurred in areas where structures would be so heavily contaminated that they would have to be condemned.

25. From Site Restoration.

26. MACCS2 allows only one value for all decontaminated areas. We have therefore used the average of the values calculated in Site Restoration for light and medium

136 Beyea, Lyman, von Hippel contamination. Loss of income for a period of 4.5 months would amount to $13,500. (U.S.

per capita income in 2000 was $35,000, Statistical Abstracts of the United States: 2001, U.S. Census Bureau, 2003, Table 646). Site Restoration includes in addition compensa-tion for losses of business inventories, personal property and relocation time beyond 90 days.

27. $30,000 if the property can be decontaminated after a minimal period of depreci-ation. $132,000 if the property is so heavily contaminated that it must be condemned.

The year-2000 average per capita value of U.S. "xed assets was $107,000 and the per capita value of residential land, using the MACCS2 default value of 20% of the value of U.S. housing value in 2001, was $7,000, (Statistical Abstracts of the United States: 2002, U.S. Census Bureau, 2003, Tables 1 and 679). We add six months lost income.

28. 90 days at $40/day in areas where the projected unshielded dose for the "rst year would exceed 2 rem. The 1989 Manual of protective action guides (p. E-9) estimated

$26/day.

29. We have assumed the bottom end of the range given in Site Restoration, i.e., onsite disposal in a facility whose design just met current requirements.

30. Heavily contaminated furnishings, business inventory and vehicles. Also depre-ciation of property when radioactive decay is required in addition to DF = 8 before reoccupation is possible.

31. Including disposal of radioactive decontamination waste at a cost of $167/m3 .

32. Assuming an average dose-reduction factor of one third due to shielding by build-ings and ground roughness and one cancer death per 2000 whole-body rem population dose.

33. Assuming that safety concerns resulted in spent fuel being placed in dry storage 30 years earlier otherwise.