ML20058A834
| ML20058A834 | |
| Person / Time | |
|---|---|
| Issue date: | 07/06/1982 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| TASK-RIA, TASK-SE SECY-82-204A, NUDOCS 8207220055 | |
| Download: ML20058A834 (35) | |
Text
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i
[4>D CE GO k July 6, 1982 i
SECY-82-204A y
u..s p
RULEMAKING ISSUE (Information)
For:
The Commissioners From:
William J. Dircks Executive Director for Operations
Subject:
FINAL EIS FOR 10 CFR PART 61
" LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADI0 ACTIVE WASTE"
Purpose:
Transmit the final EIS for Part 61 Discussion:
SECY 82-204 recommends Commission approval to publish as a final rule 10 CFR Part 61 " Licensing Requirements for Land Disposal of Radioactive Waste."
SECY 82-204 also states that the final EIS for Part 61 would be forwarded to the Comission after June 20 for use in evaluating and approving P, art 61.
Enclosure A is the summary of the final EIS.
The EIS consists of 3 volumes.
Volume 1 contains the summary and main body (Chapters 1-6).
Volume 2 contains Appendices A and B which present the staff's analysis of public comments on the draft EIS and proposed Part 61 rule. Volume 3 contains additional appendices with supporting technical details.
(Copies of Volumes 1, 2 and 3 have been provided to the Secretary for Commission use).
Public comments on both the proposed rule and draft EIS have been analyzed by the staff and used in the preparation of the final EIS.
The tone of the letters was overwhelmingly supportive of the goals and the results of the 10 CFR Part 61 rulemaking effort.
Specific comments covered a wide range of issues and were generally constructive in nature.
Contact:
Dale Smith, NMSS 427-4433 pg5820714 PDR
e 1
2 The changes made to the proposed rule and draft EIS in response to public comments did not involve identification of major new alternatives or principles which required analysis.
In the final EIS, however, an improved cost analysis, a more extensive analysis of the impacts of waste classification and analysis of a new pathway (trench overflow and leachate treatment) were added in response to public comments.
As indicated in SECY 82-204, upon Commission approval to publish Part 61 as a final rule, the EIS will be distributed to EPA, public commenters and others.
A notice of availability will be published in the Federal Register.
Recommendations:
There are no changes to the recommendations contained in SECY-82-204.
William J. Dircks Executive Director for Operations
Enclosure:
A - Summary of final EIS for Part 61 DISTRIBUTION:
Commissioners OGC OPE OCA OIA OPA REGIONAL 0FFICES ECO ELD ACRS ASLBP ASLAP SECY
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ENCLOSURE A l
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SUMMARY
- 1. 0 PURPOSE, SCOPE, AND NEED OF THE FINAL EIS The actiom 6eing considered in this final environmental impact statement is the issuance of a new regulation, Part 61, to the U.S. Nuclear Regulatory Commission (NRC) rules in Title 10, Code of Federal Regulations (10 CFR).
Part 61 provides licensing procedures, performance objectives, and technical requirements for the issuance of licenses for the land disposal of " low-level" radioactive waste (LLW).
Specifically, the regulations establish performance i
objectives for land disposal of waste; technical requirements for the siting, l
design, operations, and closure activities for a near-surface disposal facility; technical requirements on waste form that waste generators must meet for near-surface disposal of waste; classification of waste; institutional requirements; j
financial requirements; administrative and procedural requirements for licensing j
a LLW disposal facility; and a manifest system.
1.1 Purpose i
NRC has a two-fold purpose in preparing this final EIS.
First, it is to fulfill NRC's responsibility under the National Environmental Policy Act of 1969 (NEPA).
Second, NRC has prepared this final EIS to document the. decision processes applied in the development of Part 61.
NRC has analyzed alternative courses of action and requirements were selected with consideration of costs, environmental impacts and health and safety effects to current and future generations.
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- 1. 2 Scope This final EIS analyzes requirements for the land disposal of radioactive waste 1
and specifically, near-surface disposal.
Near-surface disposal involves disposal in the approximate uppermost 30 meters of the earth's surface.
Burial deeper 4'
than 30 meters may also be involved with near-surface disposal technologies.
This final EIS does not analyze other methods of disposal such as ocean disposal.
It is also not a generic EIS in that it does not analyze all of the issues involved in the disposal of LLW.
Rather, this final EIS provides the decision analysis for requirements in Part 61.
- 1. 3 Need for the Proposed Action Current NRC regulations for licensing radioactive materials do not contain suffi-cient technical standards or criteria for the disposal of licensed materials as waste.
Comprehensive standards, technical criteria, and licensing procedures are needed to ensure the public health and safety and long-term environmental protection in the licensing of new disposal sites.
They are also needed with respect to operation of the existing sites and with respect to final closure and stabilization of all sites.
The development of these regulations has been in response to needs and requests expressed by the public, Congress, industry, the States, the Commission and other federal agencies for codification of regulations for the disposal of LLW.
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1.4 EIS Scoping Process NRC has conducted scoping activities for the Part 61 rule and this final EIS since 1978.
Public participation in the development of Part 61 and analyses of the major scoping activities and public comments are discussed in detail in Appendix C of the draft EIS which has been published as NUREG-0782.
In addition, proposed 10 CFR Part 61 was published in the Federal Register on July 24, 1981 for 90 days public comment which was extended to January 14, 1982 to coincide with the 90 day comment period for the draft EIS.
The availability of the draft EIS was announced on October 22, 1981.
- 2. 0 COMMENTS ON DRAFT EIS AND RULE Public comments received on both the proposed rule and draft EIS have been used in preparing this final EIS.
A total of 107 different persons submitted comments on the proposed rule and 42 on the draft EIS.
The concerns expressed by all commenters are discussed in detail in staff analyses of comments which are contained in Appendices A (draft EIS) and B (rule) of this final EIS.
The major concerns are summarized in the supplementary information section of the proposed final Part 61 rule contained in Appendix F of this final EIS.
The staff's consideration of these comments and actions taken in response to them are set out in the various chapters and appendices of this final EIS.
2.1 Comments on the Draft EIS Of the 42 comment letters received on the draft EIS, 21 came from States or State agencies, 8 from federal agencies or national laboratories, 5 from utilities, 3 from industry, 2 from individuals, 2 from disposal firms, and 1 from an individual radiation safety worker.
The tone of the letters was overwhelmingly supportive of the goals and the results of the 10 CFR 61 rulemaking effort.
Criti-ism of the draft EIS was generally constructive in nature.
Of the 42 letters received, 29 contained items which required a response by the staff.
The remaining 13 letters in one l
form or another acknowledged receipt of the draft EIS but contained no items requiring a response.
2.2 Comments on Proposed Part 61 Rule The rule commenters represented a variety of interests.
The topics addressed a wide range of issues and all parts of the rule.
The general response was quite favorable.
Almost half (47) expressed explicit support of the rule or its overall approach.
Many expressed the view that the rule provides a needed and adequate framework for establishing additional low-level waste disposal capacity.
Support was expressed by almost every sector.
Only 15 commenters expressed outright opposition to the rule or some significant part of the rule.
Most (9) were individuals.
No State group or current disposal site operator expressed opposition.
Most of the remaining commenters (47) either offered constructive comments without taking a general position on the rule or offered support with reservations about one or more aspects of the rule.
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- 3. 0 APPROACH AND METHOD OF ANALYSIS USED FOR PREPARATION OF THE FINAL EIS 3.1 Approach Used for Preparation of the Final EIS The approach NRC has followed in preparation of this final EIS is to present, in a concise manner, the final decision bases and conclusions (costs and impacts) which are reflected in the requirements of Part 61.
NRC has chosen not to republish the exhaustive and detailed analysis of alternatives presented in the draft EIS.
Rather, in response to public comments, NRC has reduced the number of alternatives analyzed to a more manageable and understandable number and has used the draft EIS as a resource and reference document in preparing this final EIS.
The changes made to the proposed Part 61 rule and draft EIS in response to public comments did not involve identification of major new alternatives or principles which required analysis.
However, in the final EIS, an improved method of cost analysis, a more extensive analysis of the impacts of waste classification, and analysis of a new pathway (trench overflow and leachate treatment) were added.
Thus, NRC has concentrated in this final EIS on preparing a final analysis of the costs and impacts of a continuation of existing near-surface disposal practices (the no action alternative) and the changes in costs and impacts that would result from application of improvements to existing practices established by Part 61.
An analysis of the unmitigated costs and i,mpacts of implementation of the final requirements selected for Part 61 is also presented.
The final EIS is being published in three separate volumes.
Volume one consists of this summary and the main text.
The main text consists of six chapters described in greater detail below.
Volume 2 contains Appendices A-B which set out details of the analysis of public comments on the draft EIS and Proposed Pa-t 61 Rule.
Volume 3 contains Appendices C-F which set out other supporting technical information to that contained in the main text.
Chapter one of the main text is an introduction which describes the proposed action and presents the purpose, scope, need and structure of the EIS.
Chap-ter two presents background information about LLW and describes the affected environment.
Chapter three presents and analyzes major comments filed on the draft EIS.
Chapter four describes the method of analysis, impact measures used, alternatives analyzed and the results of the analysis of alternatives.
Chapter five presents final conclusions and a discussion of the final requirements selected.
Finally, Chapter six presents the typical and unmitigated impacts of the application of the final requirements selected for the Part 61 rule.
3.2 Performance Versus Prescriptive Requirements In Chapter two of the draft EIS ($ 2.2), NRC analyzed the basic type of require-ments which should oe developed and set out in Part 61 (i.e., performance objec-tive or prescriptive requirements).
Based on this analysis, the preferred approach selected and followed by NRC in the preparation of Part 61 was to develop both performance objective and prescriptive requirements.
Overall performance objectives were developed to define the level of safety that should be achieved in the land disposal of LLW.
Minimum technical performance require-ments were also developed for each of the major components of a LLW disposal S-3
system that should be considered in all cases in the disposal of LLW to help ensure that the overall performance objectives for land disposal would be met.
Finally, prescriptive requirements were established where they were deemed necessary and where sufficient technical information and rationale were avail-able to support them.
Based on public comments on the Part 61 rule and draft EIS and NRC's analysis of these comments (the comments were supportive of this combined approach),
NRC has made no change to this approach and it has been followed in the development of the final Part 61 rule.
3.3 Performance Objectives for Land Disposal In chapter three of the draft EIS (S 3.2), NRC reviewed the need for performance objectives to ensure safety and environmental protection in the disposal of LLW.
In evaluating the level of safety and environmental protection which should be achieved, NRC identified four components for which performance objectives should be established.
These were:
(1) Long-term protection of the public health and safety (and the environment);
(2) Protection of an inadvertent intruder; (3)
Protection of workers and the public during operation of a LLW disposal facility; and (4)
Long-term stability of the disposal site after closure to eliminate the need to actively maintain and care for a disposal facility over the long term.
Based on public comments filed on the rule and draft EIS, no new areas were identified which should be addressed in the Part 61 rule as overall performance objectives for land disposal of LLW.
Commenters supported development of per-formance objectives in the above four areas.
3.4 Technical, Financial and Other Requirements In 6 3.2 of chapter three of the draft EIS, NRC also identified four principal components which collectively make up a LLW disposal system.
Each of these was specifically addressed in the development of the technical requirements and includes:
(1) Site Characteristics - The geohydrological, geomorphological, climatological and other natural characteristics of the site where the disposal facility is located; (2) Design and Operation - The methods by which the site is utilized, the disposal facility designed, the methods of waste enplacement and closure of the site; (3) Waste Form and Packaging - The characteristics of the waste and its packaging; and S-4
(4)
Institutional Controls - The actions which involve a government agency maintaining surveillance, monitoring and control over access and utiliza-tion of the site after closure.
Specific technical requirements for each of these components were developed in chapters four, five, six and seven of the draft EIS.
In addition, NRC analyzed the need for changes to existing administrative and procedural requirements that are applied by NRC in the licensing of LLW disposal facilities (Chapter eight of the draft EIS) and the nee 1 for financial assurance requirements (Chapter 9 of the draft EIS).
Based on public comments filed on the rule and draft EIS, no new major areas were identified in addition to the above that should be addressed in the development of the technical requirements.
New topics identifie<1 by commentors which should be addressed in the Part 62 rule and EIS fell into one of the above areas.
3.5 Method of Analysis The overall method of analysis followed in this final EIS for determination of the technical requirements is as follows:
(1) First, the costs and impacts from the generation, transport, and disposal of waste at a reference near-surface disposal facility are calculated (Alternative 1).
This analysis is termed the " base case" analysis.
(2) Second, a range of three alternatives to the base case are evaluated with respect to their incremental change in mitigating potential impacts and cost over the base case.
One represents today's practices and is the no action alternative (Alternative 2).
The second represents the Part 61 requirements and is the preferred alternative (Alternative 3).
The tilird represents application of extensive improvements over today's practices (Alternative 4).
(3) Third, a comparative evaluation of the alternatives is conducted based on the impacts (radiological and other impacts) and costs, of each alterna-tive.
Based on the evaluation and public comments, conclusions are reached on the final requirements to be codified through the Part 61 rulemaking action.
(4) Finally, application of the requirements selected and incorporated into the final Part 61 rule is evaluated to assess typical unmitigated impacts l
of LLW disposal following the preferred requirements.
The disposal of l
waste according to Part 61 is analyzed on a regional basis at four regionally operated sites and the typical impacts and costs are determined.
The analysis also helps assess the applicability of the Part 61 require-ments to the wide range in site and waste characteristics expected in the regional disposal of LLW.
Based on public comments no change has been made to the overall method of analysis.
The number of alternatives analyzed has been reduced to a more manageable number and NRC has presented the results in a clearer, more concise manner.
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3.6 Description of Impact Measures used and Exoosure Pathways Analyzed NRC has used the same impact measures and with one exception, analyzed the same exposure pathways in this final EIS as in the draft EIS.
In response to public comments, a new pathway, trench overflow and leachate treatment, has been added and a more extensive analysis of the impacts of waste classification was performed.
Also, in response to public comments, the cost analysis has been calculated in a more realistic manner.
These changes have not affected the overall conclusions reached based on the analyses in the draft EIS.
The impact measures used include short-term radiological exposures, long-term radiological exposures, costs, energy use and land use.
They were categorized as they apply to waste processing activities at a waste generator facility, during transportation to the disposal location and during and after disposal at the disposal facility.
As in the draft'EIS, NRC has concentrated on long-term radiological exposures and costs.
Table S.1 Impact Measures Used in Analyses Waste Management Phase Impact Measure Waste processing Costs Energy use Occupational exposures due to waste processing Population exposures due to waste incineration Waste transportation Costs Energy use Occupational exposures Population exposures Waste disposal Costs Energy use Land use Occupational exposures Exposures to individuals and populations due to:
o operational accidents o ground-water migration o
inadvertent human intrusion o overland flow o leachate treatment S-6
l J
3.6.2 Risk From LLW Disposal Facility Operation Several commenters suggested that NRC quantify the risks associated with opera-tion of a LLW disposal facility.
In the draft EIS, NRC expressed radiological impacts associated with operation of a near-surface disposal facility in terms of exposures to individuals and populations.
NRC did not convert or express these exposures in terms of risks because of the difficulty of accurately assessing risks to future populations from exposures incurred at future times and the small number of individuals involved who could receive a potential exposure.
Based on a reexamination of this issue, NRC does not plan to express doses in terms of risk in the final EIS.
This would involve new work and time to prepare which is not war' canted given the urgent need for Part 61 and the limited additional information which would be provided.
In the draft EIS, NRC compared calculated doses on a common basis to existing standards which are expressed in terms of dose quivalent.
The same approach has been followed in the final EIS.
NRC has, however, attempted to express the overall impacts of Part 61 in the final EIS in a clearer manner so that comparison of alternatives and unmitigated impacts are easier to discern and understand.
To place in perspective the potential risk associated with the various doses calculated in this final EIS, NRC has summarized below dose response relation-ships as set forth in ICRP publication 26.
The reader can use these to estimate the level of risk associated with doses calculated for the various alternatives.
In the draft EIS, doses were presented for the whole body and six organs (bone, liver, thyroid, kidney, lung and gastro-intestinal tract).
In the final EIS, doses are generally presented only for the whole body, thyroid and bone.
This has been done in response to public comments to simplify reporting of impacts and since the whole body, thyroid and bone are generally of most significance with respect to the radionuclides involved.
ICRP-26 states that "the risk factors for different tissues are based on the estimated likelihood of inducing fatal malignment disease, non-stochastic changes, or substantial genetic defects expressed in liveborn descendants." The risk factors summarized below, as taken from ICRP 26, are expressed as overall mortality risk factors, except as noted.
For uniform whole body irradiation, the ICRP concludes that for individuals, the mortality risk factor for radiation-induced cancers is about 1 x 10 4 chance of developing a fatal cancer per one rem dose.
This is stated as an average for both sexes and all ages.
A 500-mrem dose would then equate to a risk of potentially developing a fatal cancer of about 5 x 10 5 For bone, the risk factor is lower, 5 x 10 6 potential cancers per rem dose.
Likewise for thyroid, the overall mortality risk factor is lower, 5 x 10 6 potential cancers per one rem dose.
3.6.3 Exposure Pathways As in the draft EIS, NRC has concentrated on long term radiological exposures involving activities such as man potentially contacting the waste af ter disposal (i.e.
inadvertent human intrusion into the disposal facility), potential leaching and transport of the waste through the groundwater; intrusion and dispersion by plants and animals; long-term erosion of the site with eventual uncovering of the waste and surface water and air transport; and release of S-7
gaseous decomposition products from the waste containing radioactive species (e.g., tritiated methane gas).
These are discussed in S 4.2.3 of Chapter 4 of the final EIS.
3.6.4 Costs Costs are calculated and separated in this EIS into three components:
(1) Processing costs - those costs associated with processing and packaging wastes prior to disposal; (2) Transportation costs - those costs associated with transferring the waste to the disposal facility; and (3) Disposal facility costs - those costs associated with design and operation of a disposal facility over a 20 year period as well as closure and institutional control costs.
Additional information is contained in 6 4.2.3 of Chapter 4.
Appendix C also describes the present value analysis used to calculate disposal facility costs.
4.0 DESCRIPTION
OF ALTERNATIVES In the draft EIS, a broad range of waste form properties, facility design, operating procedures and institutional control alternat'ives, directed at helping ensure the performance objectives would be met were analyzed.
A large number of specific cases or combinations of alternatives were analyzed in the draft EIS.
The extent and detail of these analyses and difficulty in their summarization and thus understanding were pointed out in the public comments.
Rather than repeat each of the alternative cases here, NRC has selected four representative alternatives to present the costs and impacts of the Part 61 requirements which are described below.
Based on analysis of the public comments, NRC has also not repeated the analyses which led to derivation of the performance objectives.
The costs and impacts of meeting the performance objectives are reflected in each alternative analyzed.
In addition, based on public comments, NRC has not repeated the extensive analyses that led to the key technical principles which should be addressed in the near-surface disposal of waste (i.e., long-term stability, contact of water with waste and intruder controls).
Rather, NRC has concentrated on showing the incremental changes in costs and impacts resulting from application of the Part 61 requirements over those practices in effect today.
4.1 Alternative 1 - The Base Case Alternative Reflecting Past Practices This alternative represents the level of control and costs which has been historically applied in the disposal of LLW.
This historical level of costs and impacts serves as a basis against which improvements and changes can be evaluated and compared on a common basis.
The analysis of the base case alternative also shows what the costs and impacts would be if the current controls at existing sites were relaxed.
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e The base case alternative reflects past practices with respect to poor waste form characteristics and properties and an absence of facility design or opera-tional practices directed at long term stability.
In the past, it was believed that only a " good site" was neede" for waste disposal.
No credit was given to waste form or containers.
The site is thus assumed to have been selected in accordance with currently accepted site requirements.
Since a site would not have been licensed in the past without adequate health physics procedures, accepted health physics practices and procedures are assumed to be carried out through the operators radiation safety program.
Other assumptions made for this case are set out in 9 4.3.1 of Chapter 4 of the final EIS.
4.2 Alternative 2 - The No Action Alternative Reflecting Today's Practices This alternative characterizes and reflects today's practices in the near-surface disposal of LLW.
As the industry gained experience and as regulatory agencies acted with respect to identified problems in past operations, changes and modi-fications were made in past disposal practices.
These ir & ded limits on the contents, type and form of waste acceptable for disposal ano 'morovements in design and operational practices.
Several waste streams including concentrated liquids, evaporator bottoms, resins and filter sludge waste containing greater than 1 uCi/cm3 of radionuclides with a half life exceeding 5 years are required to be stabilized prior to disposal.
A limit of 10 nCi/gm is placed upon the transuranic content of received waste.
In addition, several design and opera-tional improvements are carried out to reduce contact of waste by water and to improve site stability.
These include compaction of backfill material and trench caps, use of a permeable backfill, use of a thicker (2m) cap and improved surface drainage to reduce infiltration.
Care is taken during operations to maintain occupational exposures and higher activity wastes presenting greater external occupational hazard are placed on the bottom of disposal trenches and shielded with lower activity waste.
Other assumptions made for this case are set out in 6 4.3.2 of Chapter 4 of the final EIS.
4.3 Alternative 3 - The Preferred Alternative Reflecting Part 61 Alternative 3 reflects the final Part 61 requirements as established by the draft EIS analysis and as modified based on public comments.
In the draft EIS, NRC analyzed (in addition to the improvements already in effect at the existing sites) a broad range of other alternatives which could be applied to reduce radiological impacts.
The relative incremental change in impacts and costs for each alternative was calculated and compared in arriving at the requirements selected for Part 61.
This extensive analysis of alternatives is principally set out in Chapters 4, 5 and 6 of the draft EIS.
Also based on the analyses in the draft EIS, three key principles were identified which are of primary significance in ensuring the performance atSctives will be met over the long term.
No new aspects were identified in the public comments.
These principles are:
(1) long-term stability of the disposal facility and disposed waste.
Stabil-ity helps reduce trench cover collapse, subsidence, water infiltration and the need to care for the facility over the long term; S-9
(2) The presence of liquids in waste and the contact of water with waste both during operations and after the site is closed.
Water is the primary vehicle for waste transport and its presence in and contact with waste can contribute to accelerated waste decomposition and increased potential for making the waste available for transport off site; and (3)
Institutional, engineering and natural controls that can be readily applied to reduce the likelihood and impacts of inadvertent intrusion.
The following chart summarizes the relative importance of each in helping to achieve the performance objectives.
PRINCIPLE PERFORMANCE OBJECTIVES Migration Maintenance Intruder Operations Long term Reduces water Reduces need Reduces Reduces stability infiltration for long-term likelihood occupational anc potential maintenance and impacts hazards and for migration of inadvertent offsite intrusion releases in accident l
Reduce Reduces Reduces need Reduces waste Reduces l
contact of potential for active degradation-occupational l
water with for migration maintenance thus intruder hazards I
waste impacts and offsite releases Institutional Custodial care Assures proper Reduces Reduces and other reduces maintenance likelihood occupational l
intruder potential for and impact of hazards controls water inadvertent infiltration intrusion Based on the EIS analyses and public comments, several technical requirements have been identified for codification into Part 61.
Concentration limits are established for important radionuclides as well as transuranic radionuclides which determine the disposal requirements for the waste.
Waste is divided into three waste classes:
Class A, Cla'ss B and Class C.
All higher activity wastes (Class B and Class C) are required to be stabilized.
Stability can be provided by the waste form as generated, processing of the waste to a stable form or by placement in a container or structure that provides stability.
Lower activity compressible wastes (Class A) are required to be disposed of in separate disposal units from stable Class A, B and C wastes.
Class C wastes, which present greater long-term potential hazard to an inadvertent intruder, are required to be disposed of on the bottom of disposal units.
Disposal facility design and operation directed at reducing water contact with waste and achieving long-term stability is the same as the previous no action alternative.
The only major operational difference is the segregation of compressible Class A wastes from stable Class A, B and C wastes.
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Specific assumptions made for this case are set out in S 4.3.3 of Chapter 4 of the FEIS.
Two important assumptions made include the assumption that (except for Cs-137) all Class C concentration limits, as set out in the proposed rule, are raised by a factor of 10 to correspond to limits in the final Part 61 rule; and that Class B and C wastes are stabilized by a combination of solidification and use of containers providing stability.
4.4 Alternative 4 - Upper Bound Reauirements (All Stable Alternative)
In the draft EIS, NRC analyzed many alternatives providing greater controls in disposal at much higher costs.
These were rejected by NRC based on cost / impact considerations.
Aiternative 4 analyzes several of these alternatives which could be required and applied in the disposal of LLW.
Because of the overall importance of long-term stability in reducing impacts and long term costs, the alternatives selected are directed at ways to achieve long term stability.
The principal alternative analyzed is to place all waste into a stable form.
It assumes that stability is achieved through waste solidification or packaging.
The other alternatives considered involve use of several facility design and operation options to achieve stability including grouted disposal, disposal into grouted concrete-walled trenches or extreme compaction.
Other assumptions for these cases are set out in SS 4.3.4 and 4.4.5 of Chapter 4 of the final EIS.
5.0 REGULATORY ANALYSIS
- CONCLUSIONS AND COMPARATIVE EVALUATION This section presents the final conclusions drawn from a comparative evaluation of the alternatives.
The final conclusions are presented as the basic prin-ciples and concepts that should be set out as the minimum technical requirements in the Part 61 rule.
This section has been divided into 2 major subsections.
The first subsection presents the results of Alternative 1 (the Base Case).
The second subsection presents and compares Alternative 2 (The No Action Alternative), Alternative 3 (The Preferred Alternative) and Alternative 4 (Upper Bound Requirements).
5.1 Results of Alternative 1 (The Base Case Reflecting Past Practices)
Table S.2 summarizes the differences in costs and impacts for each alternative.
Principal conclusions for Alternative 1 include:
(1) The disposal facility is calculated to accept one million ma of waste over its 20 year lifetima-No waste shipped for disposal is determined to be unacceptable for lear w-.-face disposal.
(2)
Long-term environmental impacts for the base case are calculated to be high.
Potential impacts to an inadvertent intruder are projected to be 3.3 rem (whole body) and 4.5 rem (bone) at 100 years following the end of the two year facility closure period.
At 500 years, potential inadvertent intruder exposures are reduced, but are still on the order of 0.6 to 1.6 rems to the bone.
These exposures are due to the relatively longer lived radionuclides.
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Table S.2 Results of the Alternatives Analysis 1
2 3
4 Base No Preferred Upper Case Action (Part 61)
Bound I.
Long-Term Individual Exposures (mrem /yr):
Intruder-construction o 100 yrs - Body 3.30E+3*
1.79E+3 1.84E+2 1.75E+1 Bone 4.49E+3 1.80E+3 1.87E+2 1.77E+1 Thyroid 2.16E+3 1.78E+3 1.84E+2 1.74E+1 o 500 yrs - Body 1.14E+2 2.61E+0 3.02E+0 3.07E+0 Bone 1.55E+3 1.16E+1 1.63E+1 1.67E+1 Thyroid 2.70E+1 2.29E+0 2.42E+0 2.45E+0 Intruder-agriculture l
o 100 yrs - Body 2.68E+3 2.21E+3 2.02E+2 0.
Bone 3.64E+3 2.32E+3 2.08E+2 0.
l Thyroid 2.60E+3 2.17E+3 2.01E+2 0.
o 500 yrs - Body 6.66E+1 2.77E+0 3.04E+0 3.09E+0 Bone 6.41E+2 7.19E+0 9.I7E+0 9.38E+0 Thyroid 3.93E+1 9.08E+0 9.02E+0 9.23E+0 Boundary Well o Body 1.58E+2 4.39E-1 1.11E-1 1.09E-1 o Bone 5.61E+0 4.49E-2 3.70E-2 1.47E-2 o Thyroid 1.50E+3 1.11E+1 4.16E+0 3.31E+0 Surface water o Body 3.16E-2 2.90E-4 1.44E-4 8.80E-5 o Bone 4.92E-2 4.29E-4 3.37E-4 1.36E-4 o Thyroid 2.16E+1 1.50E-1 5.99E-2 4.77E-2
{
II.
Short-Term Whole Body Exposures (total man-mrem over 20 yrs):
Occuoational o Waste Processing
+2.50E+5 +4.50E+5
+4.90E+5 o Waste transport 7.58E+6 4.99E+6 4.97E+6 4.97E+6 o Waste disposal 3.33E+6 2.15E+6 2.14E+6 2.15E+6 To population o Waste Processing
+0.
+1.26E+2
+8.93E+1 o Waste transport 7.49E+5 4.78E+5 4.76E+5 4.84E+5 S-12
Table S.2 (Continued) 1 2
3 4
Base No Preferred Upper Case Action (Part 61)
Bound III.
Costs (total $ over 20 yrs):
Waste generation and transport o Waste Processing
+5.90E+7 +8.20E+7
+2.14E+8 o Waste transport 2.64E+8 1.73E+8 1.72E+8 1.70E+8 Waste disposal o Design & op.
3.25E+8 3.41E+8 3.50E+8 3.42E+8 o Post operational 4.55-2.29-2.07-1.38E+7 5.80E+7 4.55E+7 3.57E+7 o Total disp. cost 3.71E+8 3.64E+8 3.71E+8 3.56E+8 a
o Unit cost ($/m )
3.71E+2 5.61E+2 5.7.3E+2 5.64E+2 3
IV.
Waste Volume (m ):
Volume acceptable 1.00E+6 6.47E+5 6.48E+5 6.31E+5 o Unstable 7.47E+5#
4.42E+5# 4.23E+5 0.
o Stable - Regular 2.52E+5#
2.05E+5# 2.21E+5 6.27E+5 o Stable - Layered O.
O.
3.47E+3 3.83E+3 Volume not acceptable 0.
2.56E+4 2.20E+4 2.20E+4 "The notation 3.30E+3 means 3.30 x 103,
- In this EIS, population exposures due to waste processing by waste generators, occupational exposures due to waste processing by waste generators, and costs due to waste processing by waste generators are presented as impacts and costs in addition to those associated with the base case.
- Although much of the waste is or has been stabilized, the fact that for these two cases all the stable waste is disposed comingled with unstable waste tends to negate the potential gain of waste stabilization.
The result is about the same as if all waste was in an unstable form.
m
Groundwater impacts, which are considered over a time period of 10,000 years following disposal facility closure, are also high.
As shown, thyroid exposures are on the order of 1.5 rem at the boundary well and 22 mrem at the surface water location.
These exposures are principally due to migration of I-129.
Whole body exposures are also relatively high at the boundary well--160 mrem--and are principally due to the migration 'f tritium.
It is not likely that doses to actual individuals would ever be this high, notwithstanding the conservatism of the analysis.
For one thing, potholes and depressions created by the unstable site conditions would be filled in by the site owner, thus reducing the percolation.
In addition, groundwater movement of radionuclides would almost certainly be detected through monitoring wells long before appreciable exposures could be received by the public.
A more important point is that a considerable amount of effort and cost to the site owner may be required to prevent such potential exposures from occurring.
This is discussed in more detail below.
(3) Short-term environmental impacts include exposures to radiation workers during waste processing, transport and disposal, as well as population exposures due to waste processing and transport.
All impacts are given in units of man-millirem and are summed over the 20 years of site opera-tion.
Occupational exposures due to waste processing by waste generators, population exposures due i? waste processing by waste generators and costs due to waste processing by waste generators are not calculated for the base case.
They are calculated for the other cases and are presented as incremental impacts from the base case.
The base case represents conditions in which little or no waste processing is performed other than that required to meet safety requirements for transportation and disposal facility waste har.dling operations.
(4) A base case transportation cost of $264 million is estimated for transporta-tion of about 50,000 m3 of waste per year over 20 years ($264 per ma of waste).
(5) Disposal design and operational costs are calculated to be on the order of $325/m3 (9.20/fta),
(6)
Post operational costs are projected to be quite high--i.e., on the order of $46-58 million for the reference disposal facility depending on the level of maintenance required and the need for leachate pumping and treatment.
Better than 90% of the post-operational funds collected would be for the 100 year institutional control period.
These costs translate to a charge to a disposal facility customer ranging from $1.29 to $1.64/ft.
3 The sheer magnitude of the funds that would be needed to be collected over 20 years to ensure long-term care deserves special consideration.
High potential ground-water doses are estimated.
These calculated exposures result from the assumed practice of indiscriminately disposing of easily ccmpressible, degradable waste streams (which frequently have only very low levels of contamination) with higher activity waste streams.
These easily degradable waste streams (e.g., trash) frequently contain chemicals which may increase leaching and reduce retardation of radionuclides during S-14
i
\\
I migration through ground water.
These calculated levels of exposures are not likely to be actually realized.
However, to prevent such potential exposures from occurring, a considerable amount of active site maintenance would be expected on the part of the site owner.
It is difficult to pre-dict how long this extensive site maintenance would be required or how much it would actually cost, although it is seen that many millions of dollars could be potentially involved.
In conclusion, the environmental and long-term cost impacts of this case are clearly excessive and reversion to disposal fascility practices typified by this alternative is an unacceptable alternative.
Leaving a disposal facility in a condition so that extensive active maintenance activities are required to ensure public health and safety could result in a considerable financial burden to the site owner and to future generations.
Such active maintenance activities can continue for long time periods, and in fact tend to become self perpetuating.
Active maintenance activities such as leachate pumping and treatment represent a large source of expense without a tangible corresponding economic gain.
5.2 Comparison of Alternatives 2 (No Action), 3 (Preferred) and 4 (Upper Bound) 5.2.1 M -Term Individual Exposures In comparing the no action and preferred (Part 61) alternatives, it is seen that both intruder and groundwater exposures for the no action alternative are reduced over the base case principally due to the low concentration (10 nCi/gm limit) of transuranic radionuclides disposed and the improved stability of the disposal facility.
The added operational practices, however, for the preferred (Part 61) alternative of segregating st:ble waste streams from unstable waste streams and placing certain high activity waste streams at the bottom of the disposal cells further reduces potential intruder exposures at 100 years for the Part 61 case by an order of magnitude.
Waste segregation is an operational practice that has been and is currently being carried out for particular waste streams at existing sites, so implementing this alternative is well within current waste disposal technology.
Similarly, layering (or other special handling) of certain waste streams has long been a standard practice at disposal facilities and so this alternative is also judged to be well within current waste disposal technology.
Further reduction in impacts are observed for the upper bound all stable alternative in which all waste i
streams are stabilized prior to disposal.
Other design and operation options analyzed for this upper bound alternative are discussed later in this section.
At 500 years, comparable intruder impacts (ranging from 2 to 17 mrem /yr are observed for all three cases.
In fact, due to the raise in the near surface transuranic disposal limits for the Par.t 61 and all stable alternatives from 10 to 100 nCi/gm, intruder impacts for these two alternatives are slightly higher than those for the no action case.
As discussed in 6 4.4 of Chapter 4, however, even this small difference in impacts is probably exaggerated. Waste streams containing transuranic nuclides in concentrations between 10 and l
100 nCi/gm are required in the last two cases to be layered. Waste streams disposed with a minimum of 5 meters of cover (earth and/or low activity waste streams) would still be difficult to contact after 500 years.
In addition, the analysis conservatively takes no credit for the reduction in exposures that l
s-15 I
would result from stabilized waste forms which would tend to reduce potential airborne dispersion and plant root uptake.
With respect to groundwater impacts, as shown, the impacts for the Part 61 case are about a factor of three lower than the no action case for exposures to the thyroid and a factor of about four lower for exposures to the whole body.
For the all stable case potential exposures are somewhat lower than the Part 61 Most of the radioactivity contributing to the calculated impacts is case.
contained in the stabilized waste streams.
One of the main purposes of stabilizing such high activity waste is to provide structural support for disposal cell covers, thus reducing trench cover subsidence and minimizing contact of waste by percolating water.
If, however, the stabilized waste streams are disposed comingled with other unstable waste streams (as is the situation for the no action case), then much of the benefit to be achieved by waste stabilization can be lost.
This is illustrated in S 4.4 of Chapter 4 by the variations in the no action and Part 61 case analysis in which ceduced effectiveness was assumed for improved covers over disposal cells containing unstable waste streams.
If the waste is not segregated, the increased percolation from comingled disposal raised the calculated thyroid impacts to 41 mrem /yr at the site boundary well.
The results of the analysis also suggest that waste stabilization reduces the dependence upon the site to minimize radiological impacts.
This is an important consideration, since there will always be some uncertainty associated with measurements and predictions of site geohydrological properties A stabilized disposal site reduces the concern regarding the impact of these uncertainties on the potential radiological exposures arising from waste disposal.
The staff also notes that for both the no action and Part 61 case, there is still a possibility (althou0h small) of a water accumulation problem at a disposal site having very impermeable soils.
The relative radiological impacts and costs of this phenomenon, however, are much reduced for the Part 61 case as compared to the no action case.
The potential for such impacts is believed to be reduced to minimum levels for the all stable case.
This is presented in Chapter 4.
5.2.2 Short-Term Whole Body Exposures Occupational exposures due to waste processing for the no action alternative are calculated to increase over the base case.
This is due to the increased waste processing performed for this case.
Occupational exposures due to waste transportation and waste disposal are reduced over the base case.
This is principally due to the reduced volume of waste delivered to the disposal facility resulting from increased use of volume reduction techniques.
Popula-tion exposures due to waste incineration are calculated to be zero for the no action alternative.
Releases are only assumed to occur from waste incineration and no volume reduction through incineration is assumed for the no action alternative.
Population whole body exposures due to waste transportation are reduced over that of the base case, which is again a result of the increased use of volume reduction for this case.
5-16
Occupational exposures for the preferred Part 61 alternative are higher than the no action case due to processing additional volumes of waste into a stable form or package.
Such potential exposures, however, are difficult to determine since they are facility-specific and are based on the type of processing performed, facility design and layout, and on other factors.
Population exposures for the Part 61 alternative follow a similar pattern.
Population exposures due to waste incineration are small.
Population exposures due to waste transport are slightly increased due to the slightly increased volume of waste transported to the disposal facility.
Occupational exposures due to waste transport and waste disposal are about the same as those of the previous case.
Occupational exposures for the all stable alternative are judged to be greater than the Part 61 case.
The difference in occupational exposures for waste processing for this case and the previous case are entirely due to the additional waste stabilization requirements.
As shown, this difference is not significant.
5.2.3 Costs Waste processing costs are estimated to be increased $59 million for the no action alternative over the base case.
These costs are presented as total costs over 20 years, the assumed lifetime of the disposal facility.
These additional costs are due to the requirements to stabilize higher activity wastes prior to disposal and the volume reduction activities assumed.
Waste processing costs are also increased for the preferred Part 61 alternativt by an additional $23 million.
This increase is due to stabilizing additionti volumes of waste into a stable form or package and the additional volume reduction activities assumed.
Costs for stabilization would be incurred only by disposal facility customers generating the high activity waste and not by small waste generators who mainly generate waste with only low levels of activity.
Waste processing costs are significantly increased for the upper bound all stable alternative due to the placement of all wastes into a stable form or package.
This cost increase would be borne by all waste generators and is the principal reason this alternative was not selected.
Transportation costs are reduced for the no action, preferred and upper bound alternatives over the base case due to the smaller volume of waste shipped but do not vary much from one to the other.
Relative to the base case, disposal facility design and operating costs for the no action alternative have increased from $325 million to $341 million.
This corresponds to a unit cost of about $527/m3 3
($14.93/ft ).
This increase is due to the many improvements in site operation for the existing case relative to the base case.
These same improvements, however, result in lower long term post-operational costs which range from $23 to $46 million.
With regard to the no action case, the preferred Part 61 case results in increased design and operational costs due to segregation of stable wastes and layering of certain higher activity wastes.
Improved stability results in lower institutional control and post-operational costs.
A low level of maintenance is projected to be required for stable waste streams, since these waste streams are segregated from unstable waste streams.
A higher level of maintenance is S-17
projected for unstable waste streams.
Total post operational costs for the preferred case are projected to range from $21 million to $35 million.
This translates to a unit post-operational charge to be paid by disposal facility customers of from $31.94/m3 ($0.90/fts) to $55.09/m3 ($1.56/fta).
For the preceedicg no action case, total post-operational costs were projected to range from $23 million to $46 million.
These costs did not include costs for an observation and maintenance period following disposal facility closure, and equate to unit post-operational costs of from $35.39/m3 3
($1.00/ft ) to
$79.32/m3
($1.99/fta),
Post operational costs for the all stable alternative are the lowest of the four cases considered.
In conclusion, relative to the no action case, costs incurred for the Part 61 case are projected to include increased waste processing costs, somewhat increased disposal facility design and operation costs, and decreased post-operational costs.
(These costs do not include the cost savings to disposal facility customers for raising the near surface transuranic disposal limit from 10 to 100 nCi/gm.) Most of these additional costs are attributed to additional waste processing costs associated with stabilizing some additional high activity waste streams.
Thus, these costs would only be incurred by disposal facility customers generating the high activity waste and not by small waste generators such as hospitals who mainly generate waste with only low levels of activity.
The additional disposal facility design and operation costs are associated with the additional disposal facility operating practices for the Part 61 case of segregating unstable waste streams from stable waste streams, and of layering certain high activity (Class C) waste streams.
Of these additional disposal facility costs, segregation costs are projected to be incurred by all disposal facility customers.
These costs are estimated to run at about an additional
$12.30/m3 3
($0.35/ft ) in design and operations costs.
Costs for layering certain high activity waste streams are projected to be only incurred by disposal facility customers generating the high activity streams.
l Due to the increased disposal facility stability for the Part 61 case, the level of long-term site maintenance is reduced for the Part 61 case in comparison to the no action case.
Corresponding long-term institutional control costs to be borne by the site owner are also reduced.
This means that the funds collected from the disposal facility cutomers to provide for post-operational activities would be reduced.
Thu, lower post-operational costs to the disposal facility customer are projected for the Part 61 case.
The annual cost differential between the all stable case and both the no action case and the Part 61 case is projected to be greater.
These additional costs are principally due to the increased costs to stabilize all waste streams.
Such costs would be passed on to all disposal facility customers.
Conversely, disposal facility design and operating costs for the all stable case would be reduced relative to the Part 61 case (there would be no waste segregation charge).
Post-operational costs would be less than either c' the other two cases.
The fact that the large additional costs that are projected to occur for the all stable case would be expected to b passed on to all disposal facility S-18
i customers is believed to be significant.
Many disposal facility customers are small entities such as hospitals or small research facilities.
The waste generated by such facilities is generally of very low activity.
Rather than stabilizing all wastes, another option might be to provide stability through variations in disposal facility design and operation--e.g., through such possible techniques as grouted disposal, disposal into concrete walled trenches, or extreme compaction.
The additional disposal facility design and operating costs for these alternatives are projected to run at about $80, $369, and $28 a
respectively per m of unstable waste disposed.
Post-operational costs, however, would be reduced.
Such possible techniques would also have to be developed s
and tested for specific disposal facilities, since past experience regarding these techniques at low-level waste disposal facilities has ranged from occasional to none.
In addition, there are some occupational safety concerns regarding some of the above alternatives.
l NRC staff thus judges that the preferred alternative is the one representing i
the final Part 61 requirements.
Although the Part 61 case involves somewhat higher costs than the no action case, the potential in the Part 61 case for minimizing long-term environmental releases and costs to the site owner is enhanced.
Minimum environmental impacts and costs to the site owner are associated with the all stable case.
NRC staff, however, believe that there are sufficient uncertainties associated with the cost impacts to disposal facility customers that it cannot be implemented generically at this time.
i This decision may change in the future, depending upon cost considerations and the application of newer waste management technologies.
During licensing of specific disposal facilities, however, special attentioh will be given to the possibility of leachate accumulation within disposal cells.
At specific sites where such a possibility can occur, additional measures intended to eliminate i
this possibility will be considered.
I 6.
WASTE CLASSIFICATION The waste classification system developed for the Part 61 regulation follows directly from the performance objectives and technical criteria.
It is intended to ensure as far as possible on a non-site-specific basis that the Part 61 l
requirements are met.
Three classes of waste are established:
1.
Wastes for which there are no stability requirements but which must be l
disposed of in a segregated manner from other wastes.
These wastes, termed i
Class A " segregated" wastes, are defined in terms of maximum allowable I
concentrations of certain isotopes.and certain minimum requirements on j
waste form and packaging that are necessary for safe handling.
2.
Wastes which need to be placed in a stable form and disposed in a segre-gated manner froc unstable waste forms.
These wastes, termed Class B l
" stable" wastes are also defined in terms of allowable concentration of isotopes and requirements for a stable waste form as well as minimum handling requirements.
3.
Wastes which need to be placed into a stable form, disposed in a segre-gated manner from nonstable waste forms, and disposed of so that a barrier i
S-19 4
m ---,-
-v---
, + -,
er.~-
.,-e u
- ~
is provided against potential inadvertent intrusion after institutional controls have lapsed.
These wastes are termed Class C " intruder pro-tected" wastes and are also defined in terms of allowable concentrations of isotopes and requirements for disposal by deeper burial or some other barrier.
Finally, a " fourth" class of waste is established which is that waste which exceeds the classification limits and is generally considered unacceptable for near-surface disposal.
Disposal of this waste at near-surface disposal facil-ities would require case-by-case determinations.
A significant number of comments and issues were raised with respect to the waste classification system.
Major issues raised related to:
Calculated waste classification limits; o
o Isotopes considered; o
Volume reduction; Compliance; o
o De minimis levels for waste; o
Classification by total hazard; and o
Manifest tracking system 6.1 Calculated Waste Classification Limits The numerical basis for the limits calculated for the three waste classes is presented in Chapter 7, Volume 2, of the draft EIS.
The principal basis used for setting the classification limits was limiting exposures to a potential inadvertent intruder, although a number of other considerations went into set-ting the values-principally long-term environmental concerns, disposal facil-ity stability, institutional control costs, and financial impacts to small entities.
Waste classification represents a combination of waste form, radio-isotope characteristics, radioisotope concentrations, the method of emplacement, and to some extent the site characteristics.
[
A number of comments were received on the calculated limits for Class C waste.
l NRC staff has evaluated these comments and has concluded that a rise in the l
Class C limits by a factor of 10 is warranted for all radionuclides.
This is due to consideration of (1) the reduced likelihood of significant intruder exposures with incorporation of passive warning devices at the disposal facil-l ity, (2) the difficulty of contacting waste disposed of at greater depths, l
and (3) average concentrations in waste which would be expected to be con-1 siderably less than peak concentrations.
The effect of the change in the Class C concentration is analyzed in Chapter 5 and summarized below.
i Two cases are analyzed.
In the first case, Class C limits are assumed which correspond to those established for the final Part 61 rule.
For example, the i
l limit for disposal of alpha-emitting (except Cm-242) transuranic radionuclides by near-surface disposal is set at 100 nCi/gm.
The results of this case are obtained from the " preferred case" (Alternative 3) analysis presented earlier.
The second case corresponds to Class C limits which were proposed for the draft Part 61 rule.
Only slight differences are observed between the two cases.
Most of the differences in the calculated impact mea:;ures appear to be derived from the S-20
~,
slightly reduced volume of waste delivered to the disposal facility for the case corresponding to the limits established in the proposed Part 61 rule.
A reduced amount of waste processing is also projected for the proposed rule case relative to the final rule case.
Unit disposal costs are slightly raised for the proposed rule case, however, which is due to the reduced volume of waste delivered to the disposal facility.
6.2 Isotopes Considered for Waste Classification Purposes In the draft EIS, a total of 23 different radionuclides were considered in the numerical analysis.
These nuclides were nearly all moderately or long-lived radionuclides.
Based upon these 23 radionuclides, concentration limits were proposed in the draft EIS for 11 individual radionuclides plus alpha-emitting transuranics, enriched uranium and depleted uranium.
In response to public comments, limits for 13sCs, enriched uranium, and depleted uranium have been eliminated, as have been limits for s9Ni and 94Nb except as contained in activated metal.
A separate limit for 242Cm, a transuranic nuclide with a 162.9 day half-life is provided.
These changes are principally in response to comments on proposed Part 61 regarding the costs and impacts of compliance with the waste classification requirements.
In particular, many commenters were concerned that they would have to directly measure every isotope in every waste package.
This would be difficult since measurement of many of the listed isotopes--which would usually be present only in trace quantities-could not be perforgied except by complex radiochemical separation techniques by laboratories.
Commenters were concerned that costs and personnel radiation exposures would be significantly increased.
Thus to ease the burden of compliance, the number of isotopes treatcd generi-cally in the waste classification table was reduced to those judged to be needed on a generic basis for waste classification purposes.
Other isotopes may be added later either generically or in specific waste streams.
6.3 Volume Reduction Some commenters were concerned that the waste classification requirement w uld discourage volume reduction.
This concern is believed to be alleviated by the increase in the Class C waste disposal limits.
As an illustration, the volumes of waste determined to be unacceptable for near-surface disposal under extreme volume reduction conditions (waste spectrum 4) may be compared against the proposed and final Part 61 limits.
These comparative volumes are as follows:
Percent of Total 3
Unacceptable Volumes (m )
Generated Proposed Part 61 Limits 9.42 E+3 4
Final Part 61 Limits 1.93 E+3 1
S-21
6.4 Compliance with Waste Classificacion Many commenters on the draft Part 61 rule were concerned regarding acceptable procedures for determining compliance with the waste classification require-ments.
It was recognized in the draft EIS that developing a reasonable approach to compliance would be an important consideration.
A balance is needed between the need for knowledge of waste contents and practical limita-tions in measurement.
Based upon discussions with licensees and other interested parties, and comments on the draft EIS, a draft technical position paper has been prepared.
The staff's position is that all licensees must carry out a compliance program to assure proper classification of waste.
Licensee programs to uetermine radionuclide concentrations and waste classes may, depending upon the parti-cular operations at the licensee's facility, range from simpl.e programs to very complex ones.
In general, more sophisticated programs would be required for licensees generating Class B or Class C waste, for licensees generating waste for which minor process variations may cause a change in classification, or for licensees generating waste for which there is a reasonable possibility of the waste containing concentrations of radionuclides which exceed limiting concentration limits for near-surface disposal.
Some licensees, such as nuclear power facilities, are expected to employ a combination of methods.
There are four basic programs, however, which may be potentially used either individually or in combination by licensees:
Materials accountability; Classification by source; Gross radioactivity measurements; or Direct and " inferential" measurement of individual radionuclides.
6.5 "De minimis" Levels of Radioactive Waste Over one-fourth of all commenters on the draft EIS endorsed the concept of setting levels for wastes below which there is no regulatory concern, the so-called "de minimis" level.
The fundamental concern of practically all commenters appeared to be not whether a generic or a case-by-case approach should be taken, but rather that action to develop de minimis standards should be taken as soon as possible.
NRC staff believes that the current policy of examining waste streams on a case-by-case basis to establish "de minimis" levels will result in the quickest and best results.
It is recognized that setting generic limits is a desirable goal, and NRC plans to work toward this. goal over the next few years.
Meanwhile, NRC staff believes that the process of examining a few specific waste streams will facilitate the development of generic requirements and is accelerating its efforts on setting standards for disposal of wastes by less restrictive means.
In this regard, NRC staff is willing to accept petitions for rulemaking from licensees for declaring certain waste streams to be of no regulatory concern.
S-22
6.6 Classification by Total Hazard Several commenters were concerned with materials which may be present in low-level radioactive waste which may be chemically toxic or hazardous.
Some suggested that the Commission's waste classification system incorporate a
" total hazard" approach that would consider both the radiological and chemical hazard of wastes.
One commenter considered the EIS deficient in that it did not consider the health impact of hazardous chemicals in LLW.
At least one comment did not favor the total hazard approach because of the very complex classification system that the commenter perceived would result.
The Commission has stated publicly on several occasions that if it were technically feasible to classify waste by total hazard, then it would make eminently good sense to do so.
NRC does not now know of any scheme for such classification.
The Commission will be studying the chemical-toxicity of low-level waste, with special emphasis on identifying any licensees who generate hazardous wastes subject to requirements of the Environmental Protection Agency.
We will look then at what could be done, perhaps through processing, to minimize the hazard.
Furthermore, the Commission believes that the technical provisions of Part 61 generally meet or exceed those expected in the Environmental Protection Agency's rules for the disposal of hazardous wastes.
Although it is not the Commission's intent to allow disposal of hazardous wastes in & radioactive waste disposal facility, as is noted in the regulation, the Commission recognizes that such wastes may be present in low-level radioactive wastes. 'It is the Commissior.'s view that disposal of these combined wastes in accordance with the requirements of Part 61 will adequately protect the public health and safety.
Such hazardous wastes are expected to be such a small percentage of the total volume that dilution by other wastes would greatly minimize any risks.
The Commission intends to work closely with the Environmental Protection Agency to assure continued compatibility.
Further, EPA in its response to a resolution of the Conference of Radiation Control Program Directors indicated their willingness to work with other Federal agencies to address this problem.
l 6.7. Manifest Tracking System Based on analyses in the draft EIS a new proposed section was added to 10 CFR Part 20 (6 20.311) which established a manifest tracking system for LLW.
The system addressed the need for providing information on the classification and characteristics of waste shipped for disposal, for improved accountability of wastes and for helping establish a better data base about LLW.
The manifest required by S 20.311 is consistent with DOT shipping paper require-ments and the same document may be used by licensees to meet requirements of both agencies.
Section 20.311 requires more comprehensive information about specific nuclides in the wastes their concentration, chemical content and form.
No significant changes were made to the manifest requirements based on public comments.
Copies of proposed Part 61 were distributed to all NRC licensees and copies were also made available to all Agreement States for their licensees.
Only 29 letters commented on the manifest system.
Based on these comments, several clarifying changes were made to the proposed requirements.
Because of the minor nature of the comments received, NRC did not redo the analyses S-23
i presented in draft EIS.
No new alternatives were identified in the comments which would require changes to that analysis or final conclusions derived.
7.0 FINANCIAL ASSURANCE REQUIREMENTS No significant changes have been made to the financial assurance requirements as proposed in 10 CFR Part 61 based on public comments.
These requirements are intended to ensure that:
(1) a licensee has sufficient financial resources to construct and operate the facility and to provide for final closure and post closure care; and (2) a licensee provides financial assurance for the active institutional control period after the site is closed and stabilized.
One of the major points raised by a variety of commenters was that the proposed regulation failed to address financial responsibility for una.nticipated con-tingencies at a LLW disposal site.
These comments cover two different time periods--the post-closure period, when the original licensee is still respon-sible at the site, and the institutional control period, when the license has been transferred to the landowner of the site for a period of up to one hundred years.
In the case of the post-closure care period, the licensee would be responsible for all activities at the site found necessary by the Commission to protect the public health and safety.
Financial responsibility for activ-ities during the institutional control period are a matter to be worked out between the site owner (i.e., the state or federal government) and the licensee in its lease or other legally binding arrangement.
Several commenters considered that the rule should resolve the issue of finan-cial responsibility for contingencies by requiring liability insurance or specific language that licensees would be required to indemnify property owners in case of off-site migration.
Although not proposed in the original rule, the staff evaluation of these public comments indicates there is a need for licensees to provide financial responsibility for liability coverage for off-site bodily injury and property damage.
The four existing LLW disposal facilities currently carry this type of liability coverage.
The Commission has not established a third party liability requirement in Part 61, however, since the Commission's only statutory framework for establishing such a requirement is Section 170 of the Atomic Energy Act, also known as the " Price-Anderson" Act which is designed to cover " catastrophic events." The Commission believes this coverage would be in excess of the risk at a low-level waste facility.
The Commission will strongly encourage licensees to continue to carry third party liability insurance coverage through the conventional insurance market.
8.0 ADMINISTRATIVE AND PROCEDURAL RE00IREMENTS No significant changes were made in the administrative and procedural require-ments for licensing a LLW disposal facility.
Because of this, no additional analysis of these requirements beyand that contained in the draft EIS was included in the final EIS.
One change was made to the provisions for State and tribal participation in the NRC licensing process to provide for a more parallel evaluation of proposals by states and Indian tribes for participation in the NRC licensing process.
The time required for submittal of such proposals from the state in which the site is located was reduced from 120 days to 15 days S-24
l after tendering of the application.
For Indian tribes and other States not covered above, the time was changed to 120 days after tendering.
As set out in the draft EIS, the life cycle of a disposal facility can be divided into five phases.
These are shown and briefly described in Figure 5.1.
9.0 UNMITIGATED IMPACTS OF FINAL PART 61 RULE Both direct and indirect environmental impacts will occur as a result of the final Part 61 rule.
The direct effects of the action fall upon those segments of the human environment whose conduct of affairs will be affected by the change in regulatory requirements including:
Generators and processors; transporters; disposal facility operators; federal agencies and the states; and the public.
The indirect impacts of the final Part 61 rule involving its effect on air and water quality, biota and social impacts are determined based on application of the performance objectives and minimum technical requirements of the rule to four reference disposal facility sites located on a regional basis.
By apply-ing these requirements to a reference facility design and analyzing the bene-fits and residual impacts, an estimate of the "real world" effects of the rule is provided 9.1 Environmental Consequences Occurring Directly as a Result of the Final Part 61 Rule 9.1.1 Beneficial Impacts The requirements of the Part 61 regulation are expected to result in beneficial impacts to the public in three major areas.
First, the implementation and enforcement of the rule will improve the performance of future LLW disposal facilities and thereby reduce the potential hazards of LLW disposal.
Although the benefits of the rule's requirements may not be immediately apparent, the staff believes that in the long term these requirements will improve stability will lessen the potential for radionuclide migration and the need for active long-term maintenance of facilities.
Second, the requirements of the Part 61 rule should assure that near-surface disposal remains a safe viable option for the disposal of LLW.
Therefore, the public can be assured of the continued availability of goods and services whose provision results in generation of LLW.
Among these goods and services are electricity from nuclear power plants, medical diagnostic aids based on nuclear technology, research into causes and cures of debilitating diseases such as cancer, and research into new applications of nuclear technology.
Finally, the Part 61 rule provides public benefits in the form of more explicit provisions for participation in the licensing process for future LLW disposal facilities.
Licensing requirements and procedures have heretofore been frag-mented and somewhat difficult for interested citizens to fathom.
These proce-dures are consolidated in the rule, and expanded provisions for participation by state and tribal governments are set out under Subpart F of the rule.
S-25 l
_J
Figure S.1 Life cycle and financial assurances for a disposal facility following the final 10 CFR Part 61 Time in years Activity Form of financial assurance 1-2 yrs Site Selection and Licensee responsible for costs incurred Characterization 1-2 yrs Licensing Activities Licensee responsible for costs incurred including license fee Site closure plan including cost estimates for closure is submitted as part of license application Lease arrangement with long-term care arrangements for financial responsibility between licensee and state submitted for review to NRC for adequacy Licensee obtains adequate short-term sureties to provide for closure 20-40 yrs License Issued; Site Short-term sureties in place for closure:
is in Active Opera-NRC periodically revihws and requires tion; Waste Received updating to account for changes in inflation, site conditions, etc.
NRC periodically reviews revisions to lease arrangements to ensure that arrangements for financial responsibilities for long-term care are adequate 1-2 yrs Site Closure and Costs covered from short-term sureties, Stabilization if necessary; otherwise, licensee performs I
activities Lease arrangement between site owner and operator for long-term care is still in effect 5-15 yrs Observation and Licensee still responsible for all further Maintenance costs during this period, with short-term assurances still in place 100 yrs License Transferred to Terms' and conditions of lease are met, and Site Owner; " Active either state or licensee provides funds to Institutional Control pay for all required and necessary activities Period" of this period S-26
9.1.2 Adverse Impacts The staff does not expect that implementation of the rule will be without adverse public impacts.
Three primary impacts are expected to occur.
The first of these impacts will be residual environmental and human health hazards resulting from LLW disposal.
Despite the provisions of the Part 61 rule, the variables and processes involved in LLW disposal are sufficiently complex that unmitigated impacts cannot be avoided.
These may include occupa-tional exposure, migration of radionuclides, and subsequent offsite exposures.
(Section 9.2 discusses these unmitigated impacts.)
It should be noted, how-ever, that these impacts are not impacts caused by the rule, but rather impacts which are considered beyond the capability of the rule to eliminate entirely.
Achieving reductions in impacts from LLW disposal will not be without costs in an economic sense.
Implementing the requirements of the Part 61 rule will involve costs to the disposal facility operators, waste transporters, and waste generators.
These costs, of course, will be passed on to the public in the form of increased prices for goods and services whose provision involves the generation of LLW.
It is not expected that the passing on of these costs will create a significant incremental change to the consumer, but rather will appear along with many other costs of doing business in aggregate price increases.
These anticipated increased costs can also be balanced against the likely costs, which would be significantly higher, that could result without the promulgation of a uniform series of criteria for waste disposal.
The current lack of such criteria is believed by many to significantly contribut'e to the current shortage of disposal capacity.
Finally, implementation and enforcement of the provisions of the Part 61 rule will require the allocation of federal and state resources during the opera-tional and postoperational periods of a LLW disposal facility.
To the extent that these public resources are allocated to regulation of LLW disposal, they are unavailable for other purposes.
Conversely, to the extent that the public incurs this cost, it reduces (within limits) the costs of LLW disposal in terms of human health hazards and environmental impacts.
9.2 Environmental Consequences Occurring Indirectly as a Result of the Final Part 61 Rule To estimate these impacts, the performance objectives and minimal technical criteria established in the final rule are applied to four reference disposal facilities assumed to be constructed on four hypothetical regional sites.
Through this analysis, the residual or unmitigated impacts that could occur even with the application of the Part 61 requirements are addressed.
9.2.1 Hyoothetical Regional Sites For the purposes of this final EIS, the conterminous U.S. has been divided into four regions having boundaries based upon the existing five NRC regions (NRC Regions IV and V are treated as one region for purposes of analysis).
A disposal facility is assumed to be located at a hypothetical site within each region.
Each site has been developed from a number of sources and is meant to be consistent with the basic disposal facility siting considerations set forth in the final Part 61 rule and the generic environmental characteristics S-27
within that region.
The regional sites are intended to be representative of reasonable realistic sites--i.e., sites that could be licensed under the Part 61 rule--but are not intended to represent the "best" sites that could be located within the regions.
The disposal facilities and waste forms situated at the four regional sites are intended to provide an example of potential impacts associated with dis-posal of waste according to the minimum requirements of the final Part 61 regulation.
These should not be interpreted as representing the best or the only designs or waste forms which could be implemented in compliance with the rule.
There are a number of ways in which the Part 61 requirements may be n.ut for a specific disposal facility, and compliance with the Part 61 rule, as well as measures which may be implemented to reduce potential impacts to levels as low as reasonably achievable, would be evaluated on a case-by-case basis.
The examples, rather, are intended to illustrate an upper bound range of impacts from implementation of the rule, with tne expectation that actual impacts from implementation of the rule at existing or future disposal facilities would be less.
9.2.2 Results of the Regional Analysis The section is divided into 4 subsections as follows:
9.2.2.1, Long-Term Radio-logical Impacts; 9.2.2.2, Short-Term Radiological Impacts; 9.2.2.3, Costs; and 9.2.2.4, Other Impacts (including non quantifiable impacts such as impacts to biota and cultural resources).
Quantifiable impact measures are summarized on Table S.3.
9.2.2.1 Long-Term Radiological Impacts Long-term radiological impacts for the regional case study as summarized on Table 5.3 include potential individual and population intruder impacts, erosional impacts, and groundwater impacts.
Individual inadvertent intruder impacts are calculated for two scenarios for two time periods (100 and 500 years) following transfer of the disposal facility to the site owner for the whole body, bone, and thyroid.
As shown, the limiting individual inadvertent intruder impacts are to the bane although in all cases the Part 61 performance objective for inadvertent intrusion is met.
Potential impacts from groundwater migration are listed for three different organs (whole body, bone, and thyroid) for two different biota access locations:
1.
A well (boundary well) located at the site boundary which is assumed to be used by a few individuals; 2.
A small stream (surface water access) located down gradient of the dis-posal facility and as;umed to be used by a small population of about 300 persons.
As shown in Table S.3, the highest exposures due to ground-water migration are to the thyroid, although in all cases the Part 61 performance objective for environmental releases is met.
The estimated impacts reflect the differing volumes of waste streams and corresponding radionuclide inventories within S-28
Table S.3 Summary of Quantifiable Impact Measures for Regional Analysis NE Site SE Site MW Site SW Site low perc.
high perc.
low perc.
high perc.
low perc.
high perc.
I. Long-Term Individual Exposures (mrem /yr):
Intruder-construction 100 yrs - Body 1.82E+2*
1.97E+2 2.24E+2 1.27E+2 Bone 1.83E+2 2.01E+2 2.28E+2 1.67E+2 Thyroid 1.82E+2 1.97E+2 2.24E+2 1.24E+2 500 yrs - Body 2.39E+0 3.36E+0 3.68E+0 1.45E+1 Bone 7.92E+0 1.85E+1 2.16E+1 1.71E+2 Thyroid 2.15F+0 2.66E+0 2.91E+0 6.76E+0 Intruder-agriculture 100 yrs - Body 1.95E+2 2.18E+2 2.49E+2 1.38E+2 Bone 2.01E+2 2.23E+2 2.56E+2 1.46E+2 Thyroid 1.94E42 2.17E+2 2.47E+2 1.37E+2 T'
500 yrs - Body 2.87E+0 3.32E+0 3.53E+0 6.03E+0 O!
Bone 8.19E+0 1.01E+1 1.04E+1 2.07E+1 Thyroid 8.58E+0 9.87E+0 1.09E+1 9.96E+0 Boundary well Body 6.78E 8.57E-3 2.61E 5.59E-2 7.90E 1.04E-2 3.84E-3 Bone 6.44E 1.25E-2 3.13E 1.04E-1 9.65E 1.75E-2 1.42E-2 Thyroid 4.29E+0 - 4.97E+0 5.02E+0 - 9.38E+0 4.66E+0 - 5.33E+0 7.82E-1 Surface water Body 1.50E 3.76E-4 Bone 2.90E 1.02E-3 Thyroid 7.23E 1.35E-1
Table S.3 Sumesry of Quantifiable Icpact Measurcs for Regional Analysis (Continued)
NE Site SE Site MW Site SW Site low perc.
high perc.
low perc.
high perc.
low perc.
high perc.
II.
Short-Term Whole Body Exposures (total man-mrem over 20 yrs):
Occupational Process by waste generator #
+1.70E+5
+2.40E+5
+1.70E+5
+1.50E+5 Process by regional process center 1.81E+5 7.25E+4 1.08E+5 9.13E+4 Waste transport 4.70E+6 5.91E+6 4.26E+6 4.48E+6 Waste disposal 2.06E+6 2.58E+6 1.73E+6 1.66E+6 To population Process by waste generator #
+1.26E+2
+1.51E+2
+1.23E+2
+5.83E+1 Process by regional T
process center 0.
O.
O.
O.
E!
Waste transport 3.79E+5 5.86E+5 6.07E+5 1.07E+6 III. Costs (total $ over 20 yrs):
Waste generation and transport Process by waste generator #
+2.20E+7
+2.90E+7
+2.10E+7
+1.60E+7 Process by regional process center 5.29E+7 2.10E+7 3.14E+7 2.66E+7
- Waste transport 1.22E+8 2.04E+8 2.01E+8 3.05E+8 Waste disposal Design & op.
3.51E+8 3.54E+8 3.42E+8 3.29E+8
- Postoperational Closure 3.87E+6 3.87E+6 3.87E+6 3.87E+6 Obs. & maint.
1.13E+6 -
1.42E+6 1.14E+6 -
1.43E+6 1.11E+6 -
1.39E+6 5.86E+5 Inst. Control 1.57E+7 -
3.86E+7 1.57E+7 -
3.06E+7 1.54E+7 -
2.96E+7 9.32E+6 Total post op.
2.07E+7 -
4.38E+7 2.07E+7 -
3.59E+7 2.04E+7 -
3.49E+7 1.38E+7 Total disp. cost 3.72E+8 -
3.95E+8 3.75E+8 -
3.90E+8 3.62E+8 -
3.77E+8 3.43E+8 3
Unit cost ($/m )
5.70E+2 -
6.06E+2 5.03E+2 -
5.24E+2 7.06E+2 -
7.34E+2 6.79E+2
Table S.3 Summary of Quantifiable Icpact Measures for Regional Analysis (Continued)
~
NE Site SE Site MW Site SW Site low perc.
high perc.
low perc.
high perc.
low perc.
high perc.
3 IV. Waste Volume (m ):
Volume acceptable 6.52E45 7.17E+5 4.95E+5 4.88E+5 Class A unstable 4.25E+5 4.72E+5 3.12E+5 3.25E+5 Class A stable 1.56E+5 1.73E+5 1.27E+5 1.28E+5 Class B 6.76E+4 6.70E+4 5.33E+4 3.26E+4 Class C 3.26E+3 4.34E+3 2.97E+3 2.18E+3 Volume not acceptable 1.69E+4 2.80E+4 1.82E+4 1.67E+4
- The notation 1.82E+2 means 1.82x102,
~
- Less than 1.x10 8 millirem / year.
- Impacts at the surface water body are not given for the southwest site due to the intermittent nature of the nearest stream to the site and the extreme depth to groundwater at the site.
- In this EIS, population exposures due to waste processing by waste generators, occupational exposures due to waste processing by waste generators, and costs due to waste processing by waste generators are presented as impacts and costs in addition to those associated with a no action case (i.e., continuance of current disposal practices).
1 each regional facility, as well as the differing environmental characteristics of each regional site.
For the high percolation northeast case, it is possible that the disposal cells containing unstable waste could accumulate water and fill up like a bathtub.
This could lead to overflow of the disposal cells.
Leachate accumulation impacts are, therefore, calculated for the northeast site to demonstrate representative impacts that could potentially occur from such a situation.
Waterborne impacts are calculated assuming that 425,000 gallons of leachate annually overflow the unstable waste disposal cells.
This i
overflow is assumed to be carried to a nearby stream where contaminated water is consumed by an individual.
The impacts to the surrounding population from processing the leachate through an evaporator are also calculated.
The results of this calculation are as follows:
Body Bone Thyroid Individual dose from disposal cell overflow (mrem /yr) 6.64E+1 1.14E+2 4.37E+1 Population dose from leachate treatment (man-millirem /hr) 1.98E+2 7.40E-1 1.98E+2 It would appear that additional efforts to achieve site stability and reduce percolation would be called for at sites in which there is a potential for water accumulation problems.
9.2.2.2 Short-Term Radiological Impacts Short-term radiological impacts are also summarized in Table S.3.
Included are (1) potential impacts to populations (in man-mrem) from transporting waste to the regional facilities, (2) potential occupational impacts (in man-mrem) associated with processing, transporting, and disposing of waste within the region, and (3) potential impacts from incinerating small volumes of waste at the waste generator's facilities.
As shown, transportation impacts over 20 years range from about 380 to 1,070 man-rems, or about 19 to 54 man-rems per year.
Occupational impacts are listed as total impacts over 20 years for waste proc-essing, transportation to the disposal facility, and waste disposal.
Waste processing occupational exposures are presented as additional exposures to those associated with a "no action" situation.
That is, these exposures are presented as incremet;al exposures to those that would be received if existing disposal practices and facility license conditions were continued.
5-32
Also included are the occupational exposures that are estimated to be associated with operation of regional processing centers.
This waste processing is assumed to consist of compaction of compressible waste streams by 1 rge compactor /
shredders.
9.2.2.3 Costs Costs, including waste processing, transport, and disposal costs are listed in Table 5.3.
Similarly to occupational exposures, costs due to processing the waste by the waste generator are presented as additional costs to those asso-I ciated with a continuation of existing disposal facility practices and license conditions.
These costs include costs for waste volume reduction as well as for waste stabilization.
Waste disposal costs are set out into design and operational. costs and post-operational costs, where postoperational costs include costs to waste customers (over 20 years of operation) for providing for:
(1) facility closure, (2) a 5 year observation and maintenance period, and (3) 100 years of institutional control.
Also shown are total disposal costs as well as unit ($/m ) costs.
3 As shown, the largest total design and operational costs are for the northeast and southeast sites, due to the larger volumes of waste delivered to these two sites.
The southwest site is projected to experience a low level of postopera-tional costs, due to the semiarid nature of the site.
~
Postoperational costs for the northeast, southeast, and midwest sites are pre-sented in Table 6.5 as a range from a reasonable to a worst case, corresponding to the variation in percolation into the disposed unstable waste streams.
A low level of postoperational costs is projected for the stable waste streams.
A moderate (reasonable case) to high (worst case) level of postoperational costs, however, is assumed for the unstable waste streams.
The presentation of the worst case here is believed to be very conservative, since it discounts improvements in disposal facility operations which could be implemented to help to reduce water contact with the unstable waste streams.
It also discounts the increased use of compaction for the compressible waste streams.
Sucn compaction wculd tend to retard the rate of subsidence and slumping associated with the unstable waste disposal cells.
Unit costs are seen to vary widely depending upon the c;sumed design and operating practices carried out at the particular disposal facility as well as the volumes of waste delivered to the facility.
For example, the design and operation of the southeast site is essentially the same as the midwest facility.
However, the volume of waste delivered -to the midwest facility is much less than the southeast facility, while the design and operational costs are only slightly less.
This is because capital costs to construct the disposal facility are much less dependent upon the volumes of waste delivered to the facility than the operating costs.
Many of the same expenses to design, build, and operate the facility would be incurred whether a high or a low volume of waste was received.
S-33
9.2.2.4 Other Impacts Air Quality Nonradiological impacts to air quality due to LLW management and disposal would principally arise from two sources:
combustion of fossil fuels during processing, transporting, and disposing of waste and (2) particulate matter (dust) released into the air due to earth moving activities at the diiposal facility.
It is believed that implementation of the Part 61 regulation would
~
have little if any effect upon overall air quality.
Biota The operation of a disposal facility would involve acquiring and fencing in up to a few hundred acres of land.
During this process, impacts to biota could result from destruction of habitat.
Such impacts would again not be caused by the fact that the facility is used for waste disposal, but arise from the decision to change the land from one use to another.
Similar types of impacts would result from other land uses involving construction such as a small industrial concern, a school, a farm, and so forth.
Implementation of the Part 61 rule is expected to have little effect on the potential for impacts to biota.
Land Use Possible future use of a LLW disposal facility after it*has closed is greatly influenced and somewhat circumscribed by the presence of the disposed waste.
This does not mean that land used for LLW disposal is permanently excluded from productive use.
Rather, as long as care was taken to restrict activities to those which would not involve excavating into the disposed waste or bringing contamination to the surface, there may be a number of useful purposes the facility surface may be put to.
These could possibly include use of the facility for golf courses, recreational areas, or light industry.
It is difficult to assess the influence of the Part 61 regulation on this land A range of land uses may be estimated, using the regional analysis as a use.
guide.
Land use for each of the regions is shown below.
1 2 x 105)
Land Use (m Northeast Southeast, Midwest Southwest 2.26 2.49 1.72 1.69 Eneroy use One way in which the effects of a proposed action can be quantified is to estimate the total energy requirements associated with that action.
In terms of LLW management and disposal, this would be a difficult project given the large number of waste generators, the many different types and forms of LLW, and the many possible processing techniques that could be used.
S-34
The estimated increase in energy use due to the Part 61 regulation is listed below in gallons of equivalent fuel for each region for the range of post operational activities projected.
Energy Use (gal x 10s)
Northeast Southeast Midwest Southwest
+0.83 - +0.96
+1.11 - +1.31
+0.90 - +1.00
+0.66 Social Impacts In general, social impacts due to promulgation of the final Part 61 regula-tion are difficult to address.
These impacts are very site-specific and would include such aspects as the effect of bringing a labor force into an area on local utilities, schools, and other services.
These types of impacts are typically of most concern during the siting, construction, and operation of large facilities such as a large nuclear power plant. A low-level waste dis-posal facility is by comparison a very small operation, and the final Part 61 regulation is not expected to result in any significant incremental changes in social impacts associated with operation of LLW disposal facilities.
S-35
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