Radioactive Waste Management in the United States.The overall commercial radioactive waste management in the United States includes the following activities: - Development and implementation

-4 .

RADIOACTIVE VASTE MANAGEMENT IN THE UNITED STATES

prepared for

Radioactive Waste Management Committee

of the

OECD Nuclear Energy Agency

September 1988

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TABLE OF CONTENTS

Page

A. GENERAL STRATEGY ........................................ 1

1. National Policy ....................................... 12. National Strategies ......................... . 23. Considerations in Strategic Planning .................. .. 54. Implementing Agencies ................................... 55. Overall Schedule ...................................... 66. Total System Costs and Funding .......................... 67. International Co-operation .............................. 7

B. STORAGE SYSTEMS ............. .......................... 7

1. National Policy ....................................... 72. Requirements ......................................... 83. Description and Experience/Status ....................... 94. Schedule ....................................... 115. Costs ............................................. 116. Decommissioning Considerations .......................... 117. Quality Assurance Considerations ........................ 12

C. TRANSPORTATION SYSTEM ...................................... 12

1. National Policy .................................... 122. Requirements ........................................ 143. Description and Experience .............................. 144. Schedule ............ .............................. 155. Costs ...... ................................. 167. Decommissioning Considerations . .......................... 168. Quality Assurance Considerations . ....................... 169. Safety Considerations ................................... 17

D. DISPOSAL SYSTEMS ....................................... 17

1. National Policy .:.... ........... 172. Requirements ....................... 183. Site Selection/Characterization. . . 204. Underground Research. . ... ......... 205. Disposal Concepts .............. . ..... 216. Schedule .. . . . . . . . . . . . . . . . . . . . . . . . 257. Cost. .... 26S. Radiation Protection ....................... ..... 279. Quality Assurance Considerations ............ 27

10. Safety Considerations. . ......... 28

REFERENCES ........................................................ 29

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PREFACE

This overview provides a brief description of the civilianradioactive waste management systems in the United States. Itincludes a description of the policies, strategies, andrequirements to ensure safe and environmentally acceptabledisposal of nuclear waste.

Every effort has been made to present up-to-date information;however, the reader is advised to seek current information as theprograms evolve.

SEP. 196B

GENERAL STRATEGY

OVERVIEW OF CIVILIAN RADIOACTIVE WASTE MANAGEMENTIN THE UNITED STATES

The policies, strategies and programs for managing civilianradioactive waste in the United States are described-in thisoverview. Included is a description of the management of wastesresulting from the production of electricity by nuclear powerplants (commercial wastes). Wastes from uranium mining, milling,conversion and enrichment, as well as fuel fabrication are notincluded.

NATIONAL POLICY

The primary objective of radioactive waste management in theUnited States is to protect: 1) the health and safety of thepublic and 2) the quality of the environment. Management ofradioactive wastes is considered the responsibility of thepresent generation and should not be left for future generations.

The U.S. Congress recognizing that a national problem exists dueto the accumulation of commercial spent fuel and high levelwastes, and that an environmentally acceptable method ofpermanent disposal is needed, enacted the Nuclear Waste PolicyAct Of 1982 (NWPA) and in 1987 amended the act through theNuclear Waste Policy Amendments Act (NWPAA), (hereafter calledthe Amendments Act). The two Acts provide the current bases forthe safe, timely, and effective storage, transport and disposalof spent nuclear fuel and high-level waste (HLM) waste.

The general policy for the disposal of commercial low-level waste(LLW) is provided in the Low-Level Waste Policy Act of 1980(LLWPA) and the 1985 amendment to the Act (hereafter called the

LLWPAA). The LLWPA and the LLWPAA assigned to the individualStates the responsibility for providing disposal capability forall commercial LLW generated within their borders. The Actencourages States to form interstate agreements in order to shareresponsibility for disposal of LLW.

For HLW at the West Valley (New York) facility, the West ValleyDemonstration Project Act of 1980 sets the general policy onactivities to be conducted. While this waste was of commercialorigin, it is now considered to be a Department of Energy (DOE)waste. West Valley was a commercial nuclear fuel reprocessingfacility which was transferred to Federal responsibility in 1980.

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NATIONAL STRATEGIES

The major policies and strategies included in these laws are asfollows:

Nuclear-Waste Policy Act (as amended)

Establishes a Federal program and responsibility for ageologic repository for permanent disposal of spent fueland HLW.

Provides for the permanent disposal of commercial spentfuel and HLW in a manner that ensures the protection ofpublic health and safety, and the environment.

Names the Yucca Mountain site in Nevada for detailedsite characterization to determine its suitability asthe first repository.

Requires a report on the need for a second repositorybetween 2007-2010.

Provides for Nuclear Regulatory Commission (NRC)licensing of repositories for spent fuel and HLW.

Provides for the appointment of a Nuclear WasteNegotiator to seek a volunteer host State(s) for arepository or a Monitored Retrievable Storage (MRS)facility.

Provides for benefits compensation to the host State inwhich a repository or MRS facility is located.

- Authorizes DOE to seek, to enter into, and to negotiatewritten consultation and cooperation agreements with theState of Nevada.

- Authorizes an MRS facility but requires a number ofconditions be met before construction can start.

- Establishes a system for safe transportation of waste toa repository or to other waste management facilities.

- Assigns responsibility for interim storage to theowner/generators of civilian spent fuel. Directs theFederal Government to expedite approval of newtechnologies to expand at-reactor storage. Providesfor limited Federal interim storage capacity.

Provides the State of Nevada and interested parties fulland open evaluation of the civilian radioactive wastemanagement program.

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Provides for costs to be borne by the waste generatorsthrough the establishment of the Nuclear Waste Fund.

West ValleY Demonstration Project Act of 1980

Authorizes DOE to carry out a nuclear waste managementproject at the West Valley facility in New York.

Provides for a demonstration that liquid waste fromreprocessing of spent fuel can be managed safely.

Requires DOE to:

o solidify liquid HIM in a form suitable for transportand disposal.

o develop waste containers suitable for permanentc isposal.

o transport the solidified HIW as soon as feasible toa Federal repository for permanent disposal.

o dispose of low-level and transuranic waste producedby the solidification of the HLW at West Valley.

o decontaminate and decommission the facilities andequipment used in the solidification and temporarystorage of HLW at West Valley.

Low-Level Waste Policy Act of 1980 (as amended)

Requires each State, either alone or in cooperation withother States (referred to as agreement states), toprovide for the disposal of commercial low-levelradioactive (LLW) waste generated within its borders.

Establishes a schedule that the State must meet inproviding the required disposal capability. Criticaldates are: (1) identification of the host stateresponsible for a siting plan by January 1, 1988; (2)submission of a license application by January 1, 1992;and (3) provision of disposal capability by January 1,1993.

Establishes penalties in the form of surcharges forthose States not meeting the schedule. States nothaving disposal capability by 1996 must take title tothe waste.

The 1985 Amendment of the Low-Level Waste Policy Actmade Greater-than-Class C waste disposal a Federalresponsibility.

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WASTE SOURCE AND TYPE

Radioactive wastes are broadly classified as follows:

Spent Nuclear Fuel. Nuclear fuel withdrawn from a commercialnuclear power reactor following irradiation that has not beenreprocessed.

fligh Level Waste (HLW). The product primarily generated fromreprocessing of spent fuel that contains the heat producing andother fission products.

Low-Level Waste (LLW). Low-Level waste is defined by DOE as allwastes which are not classified as spent nuclear fuel, HLW,transuranic waste (TRU), or by-products material, as well as thosewastes that the NRC, consistent with existing law, classifies aslow-level radioactive waste.

In 10 CFR 61.55 (Code of Federal Regulations), the NRC hasclassified LLW into three categories (Class A, Class B, and ClassC). These categories are based on considerations of theconcentration of long-lived radionuclides and the length of timethey could cause exposures, and on the concentration of shorter-lived radionuclides for which requirements on institutionalcontrols, waste form, and disposal methods are effective inisolating the waste.

WASTE INVENTORY

The current and projected inventories of commercial radioactivewaste are shown in Table 1 below.

Table 1, Current and Projected Cumulative Inventories ofCommercial Radioactive Wastes and Spent Fuel (a)

Waste Source and Type 1986 2000 2010 2020

HLW glass canisters 0.0 0.2 0.2 0.2(W. Valley)

LWR spent fuel, MTHMUpper reference case (b) 14,045 41,000 62,900 98,300No new orders case 14,045 40,000 60,000 77,800

Greater-than-Class C, mLLW from operations, mLLW from D&D, m

Classes A, B, and C -- 0.0 93.3 .786.4

(a) DOE/RW-0006. Integrated Data Base for 1986: Spent Fuel andRadioactive Waste Inventories, Projections, andCharacteristics, Tables 0.4 and C.ll, Department of Energy,Washington, D.C., 9/87

(b) Includes all existing reactors (either completed or underconstruction) plus additional new reactors beyond the year 2005.

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0

CONSIDERATIONS IN STRATEGIC PIANNING

The overall commercial radioactive waste management in the UnitedStates includes the following activities:

- Development and implementation of regulations to ensure long-term protection to public health and safety and to ensurecompliance with environmental standards.

- Development of an integrated system(s) for the storage,transport, and disposal of spent fuel and HIR.

- Implementation of joint U.S. industry programs to develop anddemonstrate new technologies and systems for interim storageof spent fuel.

- Establishment of a disposal system(s) for LLW from commercialand institutional sources through the collaboration of Statesand industry, and the Federal Government.

- Demonstration of decontamination and decommissioningtechnologies for nuclear power reactors and other nuclearfacilities.

IMPLEMENTING AGENCIES

Within DOE, the Office of Civilian Radioactive Waste Management(OCRWM) is responsible for implementation of the NWPA and itsamendment. DOE's Office of Nuclear Energy is responsible for thedevelopment and demonstration of methods for "decontamination anddecommissioning" of commercial facilities and for the West Valleyfacility.

The Nuclear Regulatory Commission (NRC) has the primaryregulatory responsibility for OCRWM activities. The NRC isresponsible for setting technical standards and criteria for thecivilian repository and for implementing overall off-site releasestandards set by the Environmental Protection Agency (EPA). Thisincludes requirements for licensing and operating storage anddisposal facilities, as well as, the certification oftransport cask for spent fuel and HLW. The NRC also regulatesLLW waste disposal along with agreement States.

The EPA is responsible for developing generally applicableenvironmental standards for the management and disposal of LLW,HLW, and spent fuel. The EPA is also responsible for settinggeneral standards for the protection of the environment from off-site release of radioactive material after disposal.

The Department of Transportation (DOT) is responsible forregulating transportation of radioactive materials.

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OVERALL SCHEDULE

The key milestones of the U.S. waste management programs include:

Civilian Radioactive Waste Management Program

1987 - DOE is directed to perform detailed sitecharacterization on the Yucca Mountain site, Nevada

1994 - DOE recommends repository site to the President, ifapproved, DOE will then submit an application to theNRC for construction of the repository.

1994 - Select a site for a Monitored Retrievable Storage(MRS) facility.

1998 - Begin construction of geologic repository and an MRSfacility for spent fuel and HLW.

2003 - Begin operations at repository.

Civilian Low-Level Waste Management Program

1988 - Identification of host States for siting.

1992 - Submission of license applications.

1993 - States must have disposal capability available forlow-level waste.

1996 - States not having disposal capability must take titleto the waste.

TOTAL SYSTEM COSTS AND FUNDING

SPENT FUEL AND HLW

The NWPA prescribes that (1) the owners and generators of spentfuel and HLW will pay the full costs of its disposal; and (2)a Nuclear Waste Fund is established to cover the cost of thecivilian radioactive waste management program. This fundreceives revenue from an adjustable on-going fee charged for thenet electricity generated by commercial nuclear power plants,beginning in April 1993, as well as a one-time fee charged forspent fuel generated prior to April 1983. The on-going feefor electricity generated is currently set at 1 mill ($0.001) perkilowatt-hour (net).

The total cost for disposing of commercial spent fuel and HLW hasnot been determined as yet based on the requirements of the 1987Amendments of the NWPA.

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on April 5, 1985, a Presidential decision following a study madepursuant to Section 8 of the NWPA authorized DOE to proceed withplans and arrangements to dispose of DOE HLW in the civilianrepository. QCRWX's cost for the disposal of the waste will bepaid by DOE's Defense Programs, which receives annual defenseappropriations from Congress.

LOW-LEVEL WASTE

The costs for management and disposal of LLW vary due todifferences in disposal concepts, management practices, andcharacteristics of the wastes. Estimates for various assumptionsare presented in the storage, transportation, and disposalsections of this report. Each generator of commercial LLWprovides the funds for storage from its operating budget.

Funding for commercial LLW disposal is provided through currentcharges levied on the waste generator by a disposal site operatorupon receipt of the wastes. Initial cost for developing LLWdisposal facilities are borne by the State (or agreement States)and the facility operator.

INTERNATIONAL COOPERATION

The United States cooperates with foreign nations andinternational organizations to further the development oftechnology for the management and disposal of-radioactive wastes.Presently DOE has bilateral agreements with the Commission of theEuropean Communities and the following countries: Belgium,Canada, Federal Republic of Germany, France, Japan, Spain,Sweden, Switzerland and the United Kingdom. DOE also cooperateswith the Nuclear Energy Agency of the organization of EconomicCooperation and Development, and the International Atomic EnergyAgency in projects, workshops, and meetings.

STORAGE SYSTEMS

NATIONAL POLICY

Spent Fuel and High-Level Wastes

As designated in the NWPA, commercial nuclear power plants areresponsible for interim storage of spent fuel. Commercial powerplants are encouraged to expedite the effective use of existingspent fuel storage facilities and to cooperate with DOE in thedevelopment and demonstration of technology to increase at-reactor storage (wet storage and/or dry storage).

The Amendments Act authorized an MRS facility but established aCommission which will determine the need for such a facility byJune 1, 1989. Several alternative processes for siting the

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facility are specified. The siting alternatives to beimplemented by DOE will provide opportunities for publicparticipation and grant funding for affected parties. In thesiting alternative to be implemented by the Nuclear WasteNegotiator, participation and funding are also provided in aparallel but somewhat different manner.

A construction license for an MRS from the NRC is required.Construction will take about four years to complete. The MRSfacility will store up to 15,000 MTU of spent fuel and HLW.

The proposed MRS facility would receive spent fuel from powerplants, consolidate the spent fuel rods into canisters, andprovide dry storage of the consolidated fuel until shipment tothe repository in large capacity casks transported in multi-car,dedicated trains.

Commercial Greater-than-Class C Low-Level Wastes

The small amounts of commercially generated Greater-than-Class CLLW are stored by the generators until a disposal facility hasbeen specified.

Low-Level Wastes

Generators of commercial LLW generally store the wastes on-site,usually in covered storage areas, in the containers that will beused for transport. Storage is usually for short time periods(e.g., a few weeks to a few months) until enough waste isavailable for a sufficient shipment to a disposal site. Inaddition, because of the rapidly increasing costs for disposal,many commercial LLW generators now reduce the volumes of theirLLW before shipment, by mechanical compaction and other means.

REQUIREMENTS


In general, storage of the commercial spent fuel and HLI is theresponsibility of the generator.

Storage of spent fuel in an MRS facility is to be regulated by theNRC under 10 CFR 72. Various safety features must beincorporated into the design of any storage facility forcommercial spent fuel and HLW to protect the health and safety ofthe facility workers and the public. In addition to the standardindustrial safety regulations, the facility must operate underthe radiation protection standards established by the EPA andNRC. A Safety Analysis Report (SAR) must be submitted with theapplication for a NRC license to construct and operate a storagefacility.

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Commercial Greater-than-Class C Low-Level Waste

No regulatory requirements have been issued by U.S. regulatoryauthorities regarding the duration of interim storage of thesewastes prior to disposal. Storage of commercial wastes at thegenerator's site is regulated through a NRC license or agreementState license for the facility.

Low-Level Wastes

Storage of LLW at commercial generator sites is regulated by theNRC and the agreement State license for the operating facility. Noregulatory requirements have been issued by the regulatoryauthorities in the United States regarding the time period forinterim storage of LLW prior to disposal.

If the commercial waste storage container is to be used fortransport and disposal, then the container must meet therequirements for transportation as set forth in the DOT and NRCregulations.

DESCRIPTION AND EXPERIENCE/STATUS


Since the late 1950's, most commercial spent fuel has been stored"on-site" at the nuclear power plant sites in metal rackssubmerged in water pools. Many power plants are installing highdensity metal racks that incorporate solid neutron absorbers toallow for closer spacing of fuel assemblies and thereby increasethe total storage capacity. Some nuclear power plants areconsidering or demonstrating consolidation of the rods from spentfuel assemblies. Two types of on-site dry storage facilities forcommercial spent fuel have been demonstrated and are licensed bythe NRC. One is using metal storage casks. The casks are storedvertically on an outside concrete pad on-site. The other typeuses a series of modular horizontal concrete chambers placed nextto one another on concrete pads. Each module is cooled passivelyby convection.

A licensed dry metal cask storage facility has been in use at theVirginia Power Surry plant since 1986. At the Carolina Power andLight H.B. Robinson plant, modular concrete vaults for dry-storage will be demonstrated to increase at-reactorstorage. Three modules will be loaded by 1989. At the DukePower Oconee plant, there are plans to install 10 modules using24 intact PWR assemblies per module.

A small scale demonstration was completed in the fall of 1987 atthe Northeast Utilities Milestone 2 nuclear power plant,successfully consolidating six PWR assemblies. Several other

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small scale demonstrations have been completed at Idaho NationalExperimental Laboratory (INEL), West Valley, and BattelleColumbus.

The liquid HLW, alkaline sludge and acid waste, have been safelystored at the West Valley facility in large underground tankssince 1966.


Most of commercial Greater-than-Class C LLW in the UnitedStates is located at the West Valley facility and at the ThreeMile Island nuclear power plant in Pennsylvania. These wastesconsist of trash, spent resins, filters, and contaminatedequipment. Other Greater-than-Class C LLW are very smallquantities of miscellaneous solid materials stored at numerousresearch facilities. These wastes are typically stored in sealedmetal containers, many in 55-gallon drums, in enclosed drystorage facilities. Most of the commercial Greater-than-Class CLLW have been stored at the generator's sites since the 1950's.

Low-Level Wastes

Commercial LLW is stored in a variety of facilities andcontainers since the mid 1950's. Listed below are descriptionsof the typical structures and containers used.

Large Engineered Structures: These are permanent buildingsdesigned specifically for the extended storage of LLW. Theymay be reinforced concrete structures or steel framebuildings with metal siding and roofing. Overhead bridgecranes are used for handling of waste packages that requireremote handling.

Shielded Storace Modules or Bunkers: These are concretestructures with removable covers. Waste Containers areemplaced or retrieved with an overhead crane.

Shielded Storage Casks: These are all-weather concretecontainers, usually cylindrical, that can be placed outdoorson pads and are designed to hold waste drums.

Minimum Unshielded Facilities: These are simple fenced-inoutdoor pads or storage sheds. These facilities aregenerally intended as holding areas for waste packagesawaiting pick-up for transport to disposal or long-termstorage.

Most LLW storage containers are 55-gallons steel drums. Othertypes of container include plastic drums, one-inch thick plywoodboxes (some with and some without fiberglass or plasticreinforcement or lining), resin liners which are cylindricalsteel containers, and "dumpsters" which are large steel boxes.

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SCHEDULE

Spent Fuel and, High-Level Wastes

The NRC has determined that, if necessary, spent fuel generatedin any commercial reactor can be stored safely and withoutsignificant environmental impact for at least 30 years beyond theexpiration of that reactor's operating licenses.

The schedule for an MRS facility includes at least 18-24 monthsfor siting the facility and preparation of associated reports, 30months for the NRC review and granting of a license, andapproximately four years for construction.

Commercial Greater-than-Class C LLW

The small amounts of commercial Greater-than-Class C LLW havebeen stored at the generating sites since the start of theirgeneration in the late 1950's. Storage is expected to continuethere until a decision on disposal is made.

Low-Level Wastes

Storage facilities for commercial LLW are constructed by theindividual waste generators as needs develop.

COSTS

Spent Fuei

The cost of spent fuel storage in a concrete cask isapproximately $50,000-S80,000 per MTU and consolidation andstorage in a metal cask is estimated to be $80,000-$100,000 perMTU. Consolidating spent fuel assemblies is not yet establishedbut is estimated to be between S10,000-20,000 per {TU. The totalcost to site, develop, construct, operate, and decommission theMRS facility as proposed is currently estimated to be between 2.8and 3.2 billion (1986) dollars. The cost of an MRS facilityincludes many activities beyond storage.

DECOMMISSIONING CONSIDERATIONS


Decommissioning storage facilities allows for the responsiblemanagement of radioactively contaminated facilities after theiruseful life. The objective of decommissioning is to release thesite for unrestricted use. The regulation of decommissioningactivities at commercial facilities is the responsibility of theNRC.

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The criteria for licensing of an independent spent fuel storageinstallation (ISFSI) states that such a facility shall bedesigned for decommissioning.


Commercial Greater-than-Class C LLW storage facilities will bedecommissioned when the respective operating facility isdecommissioned. This will be done under NRC decommissioningcriteria for the operating facility.

Low-Level Wastes

Decommissioning of commercial LLW storage facilities will likelyoccur when the operating facility that generates the LLW isdecommissioned. This will also be done under NRC decommissioningcriteria.

QA CONSIDERATIONS


The general quality assurance (QA) criteria in the regulationsfor commercial nuclear power plants and fuel reprocessing plants(NRC 10 CFR 72) apply to all commercial spent fuel storagefacilities. The QA program takes into account the need forspecial controls, processes, test equipment, tools, and skills toattain the required quality, and the need for verification ofquality by inspections and tests.


Commercial facilities are regulated by the NRC. The QA programis developed and monitored by the generator.

Low-Level Wastes

QA for commercial LLW storage facilities is regulated by the NRCand/or the agreement State. The QA program is developed andmonitored by the generator.

TRANSPORTATION SYSTEM

NATIONAL POLICY

The Hazardous Material Transportation Act of 1973 (later amended)established a National policy for the transportation of hazardousmaterials. Radioactive waste is consider in the Act as hazardousmaterial.

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Overall regulation of transportation of radioactive materials inthe civilian sector is the responsibility of the NRC and the DOT.Their requirements are generally consistent with theinternational transportation standards promulgated by theInternational Atomic Energy Agency (IAEA) as of 1979 and arebeing revised to adopt the 1985 IAEA rules. Economic regulationof rail and motor carriers is the responsibility of the FederalInterstate Commerce Commission (ICC).

Transportation of most commercially-generated radioactive wastesis the responsibility of the waste generator (except as discussedin subsequent subsections) using commercial carriers. Commercialradioactive wastes are transported by truck and conventionalrail.


Transportation of commercial spent fuel between nuclearpower plants or to licensed commercial interim storage facilitiesis the responsibility of the waste generator. Thistransportation may be carried out under contract with commercialcarriers or by the waste generator. Transportation is by truckor rail, using exclusive-use shipments in type B transportpackages similar to those designated in the IAEA standards.Spent fuel and HLW that are transported by truck must followpreferred highway routes as specified by the DOT.

Transportation of commercial spent fuel and HLW to Federalstorage and disposal facilities is the responsibility of DOE.


Because there has been so little generated, the transportationof commercial Greater-than-Class C LLW has not occurred exceptfor a few unusual situations. The few shipments of commercialGreater-than-Class C wastes that have taken place, and those inthe future, are the responsibility of the waste generator.Transportation is typically carried out under contract withcommercial carriers under NRC and DOT regulations.Waste is transported by truck or rail, using exclusive-useshipments. Greater-than-Class C wastes can be transportedin Type A or Type B transport packages, depending on theradioactive content and waste form.

The DOE will be responsible for transportation from commercialpower plants and/or Federal storage to the Federal disposal site.These exclusive-use shipments will be transported in Type Btransport packages by truck or rail.

Low-Level Wastes

Transportation of commercial LLW is the responsibility of thecommercial waste generator. These wastes are usually transported

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by truck in exclusive-use shipments under contract withcommercial carriers using equipment that meet regulations of NRCand DOT.

Type A or Type B transport packages are generally used for LLWdepending on the content and form of the waste and on whether ornot other materials are transported in the same shipment.

REQUIREMENTS

The general requirements of a transportation system are totransport the wastes from the source of generation to thedisposal facility within the United States. In some cases, suchas may occur with commercial spent fuel, an additional transportstep to an interim storage facility may be required beforeshipment to the final disposal facility. The packaging andtransportation of radioactive materials is regulated by the NRC(and other affected agencies such as DOT)under 10 CFR 71 andParts 20, 21, 30, 40, 70, and 73.


Spent fuel from commercial nuclear power plants will betransported from reactor sites to the geologic repositories.Transport distance will average about 3000 km if spent fuel andHLW are transported to the Yucca Mountain site in Nevada. In somecases, spent fuel may be first transported between theoriginating nuclear power plant and another power plant or tostorage facility before transport to the repository.

The solidified HLW from West Valley will be transported to thegeologic repository by the DOE.

Low-Level Wastes

LLW is currently being transported from the waste generatingsites to one of three shallow-land burial sites for commercialwastes. When all agreement States or individual States havetheir respective LLW disposal facilities, transport will be inaccordance with the NRC, EPA and host State regulations.

DESCRIPTION AND EXPERIENCE


More than 6,000 spent fuel assemblies have been shipped fromnuclear power stations to other sites in the United States overthe past 30 years.

Currently, DOE is developing procedures, institutionalrelationships, and transportation equipment for shipping spentfuel and HRM to a repository.

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DOE has solicited, received, and evaluated proposals from privateindustry on design concepts for transportation casks. Contractsfor further development have been awarded.

Future casks for transporting commercial spent fuel will bedesigned for fuel that is approximately 10 years old. Thecurrent reference capacities, which are the starting bases forthe development of the future casks, are two PWR or five BWRspent fuel assemblies for legal-weight truck (LWT) casks (doublethat for over-weight truck (OWT) casks), and 14 PWR or 36 BWRassemblies for a rail cask. Cask capacities are expected to behigher than these values, and concepts are being considered thatcould increase the capacities by as much as a factor of two.About 30 percent of the spent fuel shipped from nuclear powerplants is expected to be transported by truck, and up to 70percent is anticipated by rail.

Low-Level Wastes

Commercial LLW have been transported to commercial shallow-landdisposal facilities since 1962. In calendar year 1986, 1,800,000cubic feet of LLW were shipped to the three existing commercialLLW near surface disposal facilities. Total volume of commercialLLW transported to LLW disposal facilities through 1986 is42,000,000 cubic feet.

Non-exclusive-use shipments of commercial LLW which are of low-activity must be transported either in strong-tight packages orin Type A or Type B transport packages, depending on the form andcontent of the waste.

SCHEDULE


1988 - Contract awarded for LWT and Rail/Barge casks

1995 - Certification of LWT and Rail/Barge transport cask

2003 - First shipments of spent fuel to geologic repository

Low-Level Wastes

1993 - First shipments of commercial LLW to agreement Stateor individual State disposal facilities for commercialLLW.

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COSTS


The estimated costs for transporting spent fuel from nuclearpower plants directly to the Yucca Mountain site are listed.Costs are in millions of 1986 U.S. dollars, and are total lifecycle costs for transporting 106,300 MTU equivalent of spent fueland 8000 MTU equivalent of DOE HLW and 600 MTU of HLW from WestValley.

MillionsTotal development costs for transportation system $ 920

Total transportation costs for commercial spent fuel 2,130

Decommissioning costs (decom. costs equal salvage value) 0

Total transportation & development costs, spent fuel and HLW 3,330

Low-Level Wastes

Transportation costs for commercial LLW depend on negotiatedcontracts with the carriers and are highly variable. Inaddition, costs are dependent on the part of the country, whetheror not shielded casks are needed (which incur-costs for a returntrip) and numerous other factors.

DECOMMISSIONING CONSIDERATIONS

Decommissioning of transportation equipment is typically carriedout by decontamination to allow unrestricted use. Thedecontaminated materials are then salvaged for re-use. Fixedtransportation maintenance and operating facilities are typicallydecommissioned in a similar manner.

QA CONSIDERATIONS

Quality assurance (QA) requirements for transportation ofcommercial waste are established by the NRC and DOT. QArequirements are applicable to all aspects of the transportationsystem. Each organization that participates in transportation ofwastes is required to have a regulatory-approved QA program andto execute it to the satisfaction of all applicable regulatorycriteria. The QA programs and activities of all participatingentities must be audited periodically, and records must be keptfor the duration period of the regulatory requirements.

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SAFETY CONSIDERATIONS

Regulations for commercial transport is generally consistent withIAEA Transportation Safety Standards. To obtain certification oftransport packages by the regulatory authorities, safety may bedemonstrated by approved destructive testing or by approvedmethods of analysis, or by a combination of testing and analysis.Each reusable transportation packaging must be recertified by theregulatory authority every five years. Other specific safetyrequirements are identified below.


Currently, truck shipments require communication with thedispatcher every two hours. Rail shipments are followed throughthe standard train tracking system.

Low-Level Wastes

Some truck shipments of commercial LLW may contain sufficientradioactive materials to require control of the highway routing.

Pre-notification of expected arrival time at a State border isrequired. No major additional safety requirements are neededbeyond those in the IAEA transportation regulations.

DISPOSAL SYSTEMS

NATIONAL POLICY

Spent fuel and High-Level Wastes

DOE siting guidelines (10 CFR 960) establish requirements for ageologic repository system, define technical and environmentalqualifications that a candidate site must meet, and specify thesite selection process.

After site characterization, if Yucca Mountain is a suitable sitefor a repository, DOE will then submit to the President a SiteRecommendation Report accompanied by an Environmental ImpactStatement. After Presidential approval of the site, DOE mustthen file an application to NRC for authorization to constructthe repository. Once the repository facility is constructed, DOEmust obtain license from the NRC to operate the repository.

Concurrently, under the NWPAA, DOE may enter into a benefitsagreement with the State of Nevada concerning a repository.However, if the State of Nevada signs an agreement with DOE, theState relinquishes its right to submit to Congress, a "notice ofdisapproval" of the site selection.

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Waste acceptance specifications and requirements for vitrifiedHLW will define the minimum acceptable waste form and canisterrequirements and the documentation required for disposal in therepository.

Low-Level Wastes

The LLW Policy Act of 1980 (as amended) requires that each Statedevelop a disposal system, either through an agreement with morethan one State or individually, according to a defined timetableor incur penalties. States lacking a disposal system by 1996must take title to a generator's waste and assume liability fornot having a disposal facility. Power plants are required underthe Act to meet certain waste volume specifications during aseven-year transition period which is provided for the opening ofnew disposal sites under arrangements by States or agreementStates.

REQUIREMENTS

The EPA is responsible for setting general standards for theprotection of the environment, which includes regulations forradioactive and other hazardous materials. NRC is responsiblefor specific regulations relating to radiation protection andradioactive materials. The NRC radiation protection regulations,which are being amended to be consistent with those of theInternational Commission on Radiation Protection (ICRP), aregiven in 10 CFR 20, "Standards for Protection Against Radiation."These regulations establish the general requirements forradiation protection, including general amounts andconcentrations of radionuclides that may be released to theenvironment or disposed of in the ground.


The EPA issued environmental standards for the management anddisposal of spent nuclear fuel, HLW and TRU waste (40 CFR 191) in1985. These standards limit the radiation dxses to members ofthe public from the management and storage of radioactive wastesat repositories during the preclosure period to the same level asthose for other nuclear fuel cycle operations. These limits are75 mrem/year to the thyroid and 25 mrem/year to the whole bodyand any other critical organ. EPA standards also set a maximumlimit the projected cumulative releases of radionuclides to theaccessible environment for 10,000 years after disposal tospecific numerical values. These values are based on limitingthe resulting premature cancer deaths to no more than an averageof 0.1/year from disposal of each 100,000 MTU equivalent of spentfuel and HLW.

NRC regulations (10 CFR 60) require the preservation of theoption of waste retrieval (50 years) throughout the preclosureperiod. For the postclosure period, the primary specific

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technical requairements are: (1) substantially completecontainment within the waste package for 300 to 1,000 years., (2)a maximum radionuclide release rate from the engineered barriersystem of one part in 100,000/year of the 1,000-year inventory ofthat radionuclide, and (3) -a pre-emplacement ground-water traveltime from the "disturbed zone" around the underground facility tothe accessible environment of at least 1,000 years. 10 CFR 60also contains siting, facility design, and waste packagecriteria; and criteria pertaining to land ownership and controlas well as requirements for the establishment of programs forperformance confirmation, quality assurance, and personneltraining and certification.

The DOE siting guidelines (10 CFR 960) identify the factors to beconsidered in evaluating and comparing sites on the basis of theregulatory preclosure and postclosure requirements.

Low-Level Wastes

The regulations governing the disposal of commercial LLW arefound in the following:

1. NRC 10 CFR 61, "Licensing Requirements for Land Disposalof Radioactive Waste." This regulation applies to alldisposal in the subsurface of the land. Specifictechnical requirements are given for near-surface (up toapproximately 30 meters deep) disposal.

2. EPA Draft of Proposed 40 CFR 193, "EnvironmentalRadiation Protection Standards for Management and LandDisposal of Low-Level Radioactive Waste," September1987. This proposed regulation would provide overallenvironmental standards for disposal of commercial LLWin near-surface disposal facilities.

10 CFR 61 establishes, among other things, (1) performanceobjectives for disposal facilities during operations and afterclosure (including inadvertent intrusion), (2) requirements forinstitutional controls after closure, (3) technical requirementsfor near-surface disposal sites and facilities, and (4)definitions of the upper radionuclide limits for the threeclasses of LLW. Class A wastes require 100-year isolationsClasses B and C wastes require 300 years of isolation; Class Cwastes require additional intruder protection for 500 years.

The proposed EPA standard 40 CFR 193 would (1) define limits onradiation exposure of the public resulting from management andstorage of LLW before disposal, (2) define criteria forclassifying those LLW that have so little radioactivity as to be"Below-Regulatory-Concern," (3) define limits on potentialexposures from LLW disposal systems and establish requirements toensure that these limits will not be exceeded, (4) provide four

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principles for ensuring compliance with the long-term containmentrequirements, and (5) define ground-water contamination limitsfrom LLW management and disposal.

SITE SELECTION/CHARACTERIZATION

Site characterization consists of surface-based investigationsconducted by means of shallow and deep boreholes, laboratorytests, and tests conducted in the host rock at the proposed depthof the repository to determine its suitability as a potentialrepository site.


The NWPA requires DOE to issue a Site Characterization Plan (SCP)for the Yucca Mountain site. In January 1988, a consultativedraft SCP for the Yucca Mountain site was issued. Afterconsultation with the State of Nevada and the NRC, DOE will issuethe SCP, hold a formal comment period and hold public hearings onthe SCP. When site characterization has been completed andassuming the characterization shows the site is suitable, thesite will be selected for development into a repository. DOEwill then issue the Site Recommendation Report with anEnvironmental Impact Statement on the site.

Low-Level Wastes

Selection of a commercial LLW disposal site is the responsibilityof each State, which may conduct the selection as part of acompact with other States. Selection of a site is done through ascreening process which requires characterization of availableland and comparison of the potential sites with the siteselection criteria of NRC in 10 CFR 61.

UNDERGROUND TESTING


The Yucca Mountain site was recognized in the late 70's as apossible site for an underground repository. As a result, theNevada Nuclear Waste Storage Investigations (NNWSI) programwas initiated in 1977. Underground testing was performed in bothtuff and granite. Experiments were conducted to obtain data onradionuclide migration and rock mechanics in tuff. In the early1980's, 11 canisters of spent fuel were placed in a granite testfacility 1400 feet below the surface within the Climax granitestock (Spent Fuel Test - Climax) to evaluate granite as a methodfor deep geologic disposal of spent fuel and HLW.

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During detailed site characterization at the Yucca Mountain site,an exploratory shaft facility (ESF) for in-situ testing will beconstructed. The ESF will consist of two exploratory shafts, adrift that connects the shafts, other drifts and undergroundrooms for testing, and associated surface facilities.

Site characterization will be conducted in two phases. The firstphase, construction testing, is defined as the tests beginningduring shaft construction and continuing until undergroundconnection of the shafts is completed. The second phase, in-situtesting, will begin after excavation of the subsurface facilityand continue until sufficient data have been collected. Thesetests will concentrate on characterizing the rock mass (e.g. in-situ stress and permeability), thermomechanical parameters,geochemical properties, thermal properties, and heat dissipation.

This information is required to support the Site RecommendationReport, the license application to NRC, and the EnvironmentalImpact Statement.

Low-Level Wastes

Extensive R&D has been done to develop an understanding of thecharacteristics of existing disposal sites for commercial LLW andof potential improvements at these sites. No plans currentlyexist for construction and use of a research facility tocharacterize a potential new site. Each State that hosts a LLWdisposal site is responsible for developing its own plans forsite characterization.

DISPOSAL CONCEPTS DESCRIPTION AND EXPERIENCE


The repository for spent fuel and HLM will resemble a mine withboth surface and underground facilities. The surface facilitieswill receive and handle the wastes and transfer the wastes downto the underground disposal galleries.

The underground facilities will consist of the undergroundstructures and components, including engineered barriers notassociated with the waste package such as shaft seals andbackfill, and the host rock that supports them.

In addition to testing experience, the United States has sharedexperience through cooperative programs in underground researchlaboratories in Canada, Sweden, Switzerland, the Federal Repiublicof Germany, and in cooperative studies with the Nuclear EnergyAgency, International Atomic Energy Agency, and the Commission ofEuropean Communities.

SER. 19a

Low-Level Wastes

A total of six shallow-land disposal facilities for commercialLLW wastes have been sited, developed and operated; of these,three were shut down and three are still in operation andexpected to operate at least until replacement facilities can bedeveloped (no later than 1996).

Near-surface disposal in excavated trenches is presently ingeneral use for commercial Class A LLW. Class B and C LLW aredisposed of in similar but separate trenches, or in isolatedparts of the same trenches. Class C LLW are typically back-filled in part with concrete to provide additional intruderprotection.

It should be noted that near-surface disposal has not beenselected by the United States as the preferred method fordisposal of LLW. Several alternative disposal methods arecurrently being considered, such as engineered systems.

DISPOSAL CONCEPTS - WASTE RECEIPT AND HANDLING

Spent Fuel and High-Level Waste

Spent fuel and HLW will be received at the repository by railand/or truck. HLW will be unloaded from the shipping cask andplaced in interim storage racks in a hot call. Subsequently thespent fuel and HLW will be encapsulated in a disposal containerand moved to a gallery room for disposal.

Low-Level Wastes

For current disposal of commercial LLW, the waste packages areusually unloaded from the transport vehicle onto an on-sitetrailer or platform by fork lift and crane. Temporary shieldingmay be used to handle wastes with high radiation levels. Wastepackages with high radiation levels are usually placed near thebottom and center of the trench to allow for shielding fromsurrounding packages. Partially-filled trenches are typicallybackfilled periodically to minimize exposure of the wastepackages to the accessible environment.

DISPOSAL CONCEPTS - WASTE PACKAGE


Until December 1987, site-specific waste packages for eachcandidate waste site were being developed; since then, only wastepackages for the Yucca Mountain site are under development. Aspart of the design effort, reference and alternative materialshave been chosen for the waste container.

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The reference material for the waste container is stainless steelfor a repository in tuff. Copper and selected copper-basedalloys are also being studied for waste containers in tuff.

The HLW waste form is monolithic borosilicate glass that isfilled into the canister to a height of 91 inches. Conceptuallythe canister is 0.375-inch thick stainless steel, 24 inches indiameter and 118 inches in overall length. The canister is a 98-inch-long cylinder with a reverse-dish head on the bottom and anelliptical head on the top that includes a five-inch diameterfilling nozzle. The filling nozzle is sealed with an oversizedplug by pressing with high pressure and fusing electrically.

Low-Level Wastes

Commercial LLW packages disposed of in near-surface disposalfacilities cannot be made of cardboard or fiberboard (NRC,10 CFR 61.56). The most common LLW package is the 55-gallonsteel drum (wall thickness ca. 0.12 cm) that is painted,galvanized, or plastic-coated. In 1981, 55-gallon drumscomprised 84 percent of all the LLW packages, but accounted foronly 26 percent of the waste volumes that were disposed.

Other sizes of steel drums are also used, ranging from fivegallons to 80 gallons. In addition, cylindrical containers madeof plastic, fiberglass-plastic, and reinforced concrete are used,particularly for Classes B and C wastes ranging in size from 30gallons to about 500 gallons.

DISPOSAL CONCEPTS - BUFFER AND BACKFILL


No buffer material will be used around the waste packages (witheither spent fuel or HLW) at the Yucca Mountain site because thewaste package is designed to be surrounded by an air gap. openareas of the repository will be backfilled with crushed tuffduring closure of the repository.

Low-Level Wastes

No buffer materials are used around packages for commercial LLM.Backfill is typically the soil material that was excavated tomake the disposal trenches. In some cases for Class C wastes,cement backfill is used around the waste package to enhanceintruder protection.

DISPOSAL CONCEPTS - TEMPERATURE AND PRESSURE


Near-field temperature limits in a tuff repository are underconsideration. A preliminary goal for near-field is to limit

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the maximum temperature to about 235 C and to limit the wasteheat loading to 57 NW/acre (i.e., room scale). For the far-field (i.e., regional scale), the temperature increases will belimited to temperatures of about 5 C in the aquifer and 0.5 C inthe earth surface. Further evaluation is underway to determineif these tentative limits are appropriate.

Low-Level Wastes

LLW commercial disposal facilities have no temperaturerequirements. Class A LLW have no specific structuralrequirements except they must withstand the forces of normaloperations and should show no deformation before emplacement.Commercial Class B and C LLW are required to maintain grossphysical properties and identity for 300 years, and are requiredto maintain structural integrity from external pressures of 50pounds/sq. inch and from 30 heating-cooling cycles. High-integrity containers for Classes B and C LLW that do not meet thewaste form stability requirements must maintain integrity underthe structural forces from cover material and equipment at thedisposal facility.

DISPOSAL CONCEPTS - DECOMMISSIONING


After the repository has been filled and the caretaker andperformance-confirmation program (about 25 years) has beencompleted, the DOE plans to submit to the NRC an application fora license amendment to close the repository. After NRC approval,the DOE will seal the repository and decommission the surfacefacilities. Repository shafts will be sealed; surface facilitieswill be decontaminated and dismantled; the mined rock that is notused in backfilling will be stabilized or moved off the site; thesurface area will be returned to its original natural conditionto the extent feasible; and permanent markers will be erected.

Low-Level Wastes

The operator or holder of the license for a commercial LLWdisposal facility must dismantle/decontaminata surface facilitiesto the extent defined in the site closure plan provided in theoriginal license application. The disposal facility operatormust show by measurements and modeling that the closed facilitywill met regulatory requirements without active controls.Permanent markers must show locations of all burial trenches. Apassive site security system must be installed that requiresminimum maintenance. The disposal facility is turned over theState for custodial care for the time period requiringinstitutional controls.

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DISPOSAL CONCEPTS - POST-CLOSURE

Spent Fuel and High-Level Waste

The total preclosure time is estimated to be about 90 years forthe repository. Six years of this 90-year period will be usedfor construction and 28 years for repository operation. Therepository design will provide the capability for retrieval atany time for 50 years after the start of waste packageemplacement. The remaining 34 years is the length of timeassumed to be necessary for waste retrieval if waste retrieval isdetermined to be necessary at the end of the 50-yearretrievability period.

10 CFR 60 requires that a description of the program formonitoring of the repository during the post-closure period beincluded in the license amendment for permanent closure.

However, because the performance confirmation program during theretrieval period is expected to provide final assessment offacility performance, additional monitoring subsequent to post-closure is not expected to be necessary.

Low-Level Wastes

For commercial LLW disposal facilities, post-closure activitiesby the State custodian for the duration of institutional controlwill involve periodic visits, inspections, maintenance (if any),and environmental monitoring of the performance of the site. Theperiod of institutional control will be determined by the NRC,but may not be relied upon for more than 100 years in evaluatingthe license application.

SCHEDULE


1988 - Consultative draft of Site Characterization Plan forYucca Mountain site for repository issued

1989 - Exploratory shafts and construction-phase testing ofsite characterization initiated at the Yucca Mountainrepository site

1991 - Start in-situ testing at Yucca Mountain site forrepository

1995 - Submit license application to NRC to construct repository

1998 - Receive construction authorization from NRC forrepository and start construction

2003 - Start Phase 1 operations (400 XTU/year receipt)at repository

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Low-Level Wastes

Three sites are currently operating for commercial LLW and theplans for additional sites vary from state to state. The LowLevel Radioactive Waste Policy Amendments Act of 1985 establishesa schedule that each State must meet for commercial LLW or facepenalties.

COST


The estimated total life-cycle cost to site, develop, construct,operate, and decommission the repository are presented on thefollowing page. The costs are reference case estimates for arepository in an "improved performance" waste management system(i.e., which includes a Monitored Retrievable Storage facility inthe system) containing 70,000 MTU-equivalent of commercial spentnuclear fuel and HLW. The costs are also based on the schedulepresented above.

Estimated Repository Costs inMillions of 1986 Dollars

SelectedRepository in Tuff

Development and Evaluation $ 5,600Socioeconomic Impact Mitigation 300Construction 800Operation 4,200Decommissioning 400

Total $11,300

Low-Level Wastes

Costs for commercial LLW disposal vary due to differences indisposal facility concepts and management practices, and thecharacteristics of the radioactive wastes received.

A recent study comparing alternative disposal systems for8,800,000 cubic feet of commercial LLW over a 30-year perioddeveloped the following cost estimates which includes pre-

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SEP. 1988

operating, operating, closure, and post-operating costs for eachtype of disposal (in millions of 1986 dollars).

Near-surface burial $ 406Intermediate-depth disposal 421Below-ground vault 617

Above-ground vault 790Modular concrete canisters 630Earth-mounded concrete bunker 893

RADIATION PROTECTION

During the operational period, releases of radioactive materialsto the general environment from a repository for spent fuel andHLW and from commercial LLW disposal facilities must not resultin an annual dose to any member of the public in excess of 25millirems to the whole body, 75 millirems to the thyroid, and 25millirems to any other critical organ. Occupational doses atrepositories are limited to 3 rems/calendar quarter and anoccupational lifetime average of 5 rem/yr. However, theprinciple of ALARA must also be applied, and occupational dosessignificantly below this value is anticipated.

QA CONSIDERATIONS


The NRC's 10 CFR 60 mandates that the general Quality Assurance(QA) criteria of NRC's regulation 10 CFR 50, Appendix B, "QualityAssurance Criteria for Nuclear Power Plants and Fuel ReprocessingFacilities," shall be applied to disposal of commercial spentfuel and HLW. An extensive program has been developed by DOE toassure quality in the total commercial waste management system.

A major goal in the commercial waste management activities is tosustain a high level of quality, both technically andadministratively, in all activities. This concept is referred toas "Managing For Quality," and QA is an important aspect of thisbroad concept. QA includes elements of management planning andcontrol, verification, and overview. QA elements aresystematically and selectively applied in a formal and auditableQA program that is designed to: (1) assure compliance withregulatory and other programmatic requirements and standards, and(2) demonstrate technical appropriateness, adequacy, andcompleteness.

Low-Level Wastes

All regulations by NRC, EPA, and the States require that astringent QA plan, approved by the regulatory agencies, be ineffect for all disposal facility siting, verification,evaluation, design and construction, operations, anddecommissioning.

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SAFETY CONSIDERATIONS


Analytical techniques developed for and successfully used in theradiological assessment and licensing of other nuclear facilitiesare being used for estimating public and occupational radiationdoses from waste disposal facilities. For long term safety,performance assessment includes estimation of the potentialrelease of radionuclides to ensure that release levels are belowthe NRC criteria and EPA standards. All commercial spent fueland HLW storage and disposal facilities and activities aremonitored by the NRC.


Stringent industrial and radiological safety requirements aredictated by the Federal, DOE, or State agencies responsible forregulating the various aspects of commercial Greater-than-Class Cwastes.

Low-Level Wastes

All commercial LLW disposal activities are monitored byregulatory personnel from the NRC or the host State, and by otherregulatory and enforcement organizations to ensure that facilityactivities conform to applicable industrial and radiologicalsafety regulations.

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REFERENCES

1. 10 CFR Part 61, "Licensing Requirements for Land Disposal ofRadioactive Waste," December 1982.

2. 10 CFR Part 72, "Independent Spent Fuel Storage FacilityLicenses," November 1960.

3. 10 CFR 50 Appendix B, "Quality Assurance Criteria for NuclearPower Plants and Fuel Reprocessing Facilities," July 1985.

4. 10 CFR Part 20, "Standards for Protection Against Radiation,"amended through 1985.

5. 10 CFR 72, "Packaging and Transportation of RadioactiveMaterial," amended through 1983

6. 40 CFR Part 191, "Environmental Radiation ProtectionStandards for the Management and Disposal of Spent NuclearFuel, High-Level and Transuranic Radioactive Wastes," August1985.

7. 10 CFR Part 60, "Disposal of High-Level Wastes in GeologicRepositories," June 1983.

8. 10 CFR Part 960, "Nuclear Waste Policy Act General Guidelinesfor the Recommendation of Sites for the Nuclear WasteRepositories," December 1984.

9. 40 CFR Part 193, Environmental Radiation Protection StandardsManagement and Land Disposal of Low-Level Waste," September1987.

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Documents

Radioactive Waste Management in the United States.The overall commercial radioactive waste management in the United States includes the following activities: - Development and implementation