Log of Specific Activity (Ci/7m73)

Source:

Exhibit 1-2

LLRW Volume Versus Specific Activity

oO.
4 ~
[waste #32
4 oa
oO
Oo
4 oO ia)
i) o fa}
J a a 5, oo
ial
oo So
4 7 Qo
a a 50 a
7 a Waste #36
7 Qog fa]
is}
o a
T T T T o. T tT
-1 1 3 5 7
Log of Volume (m*3)
IEc analysis of data from Exhibit 2-2.



Exhibit 2-1

Comparison of Low Level Radioactive Waste
Definition for Ocean Versus Land Disposal Programs

(continued)
Other Ocean Land
Speci fications No disposal of transuranic radioactive wastes, as defined No disposal of transuranic radioactive wastes, as defined

in 40 CFR 191.011, (which are wastes with > 100 nano- in 40 CFR 191.011, (which are wastes with > 100 nano-

curies/gram of alpha emitters with half-lives > 20 years.) curies/gram of alpha emitters with half-lives > 20 years.

Limit LLRW disposed so that maximum dose to an individual Disposal of LLRW which presents < 4 millirem annual exposure

from ocean disposal is only a small fraction of 100 dose via less restrictive disposal methods may qualify as

millirem/year. as "Below Regulatory Concern" (BRC) wastes. WRC and DOE will
use EPA's general criterion (4 millirem per year) in conjunction
with their respective requirements to determine which specific
requirements to determine which specific LLRW qualifies as a BRC
waste.

No disposal of free radioactive gases. No disposal of uranium and thorium by-product materials (mill
tailings) as defined in the Uranium Mill Tailings Radiation Control

Unless only present as trace contaminants, LLRW which Act of 1978.

contains the following may not be disposed:

* organohalogen compounds Wo disposal of spent nuclear fuel (considered high level waste).

* mercury and mercury compounds

> cadmium end cadmum compounds Wo disposal of by-product material as defined in section 11e(2) of

> crude oi l/petroleum products and wastes the Atomic Energy Act of 1954.

- persistent and floatable plastics/synthetics.

Source: See text.


pesticides and PCB's, and toxic metals were measured above
detection limits at different locations at the New Jersey sites.
We believe that the presence of co-contaminants in many remedial
action streams is likely; further research is required to
determine the nature of these co-contaminants.

Summary

Co-contamination of LLRW may prevent streams from being
considered as ocean disposal candidates. Because of inadequate
information, IEc was not able to conclude with certainty which
LLRW streams are contaminated by the constituents identified in
the current ocean disposal regulations and Annexes I and II of
the London Dumping Convention. In addition, it is possible that
treatment processes may affect a waste stream's eligibility for
ocean disposal by removing hazardous constituents. Based on
available information, it appears likely that large amounts of
the commercial, DOE/Defense and remedial action LLRW shown on
Exhibit 2-2 include co-contaminants.

Waste Form

EPA is currently considering research provided by Brookhaven
National Laboratory on possible waste form criteria which
includes the following:12/

(1) The specific gravity of the waste package shall
not be less than 1.2 to ensure sinking to the
seabed;

(2) The waste package shall remain intact upon impact
on the ocean floor;

(3) The waste container should have an expected
lifetime of 200 years in the deep sea environment;

12/ An_ updated study of waste package performance criteria is
expected to be available by Fall 1988. Thus, some of the
following specifications may be subject to changes.


Exhibit 2-2

Description of Low-Level Radioactive Wastes

(Continued)
Total
Total Volume Activity Important Radionuclides Potential
Reference 1985-2004 1985-2004 Density (percentage of waste stream) Land BRC
Number Waste Stream (cubic meters) (curies) (a/em3) Ci/tonne radioactivity) Candidate? *
NATURALLY OCCURRING and ACCELERATOR PRODUCED RADIOACTIVE MATERIALS (WARM)
DISCRETE NARM WASTES
32 Radium Sources 0.445 623 4 350.000 Ra-226(16.6); Rn-222(16.6); Y
(R-RASOURC) Bi-214(16.6); Po-210(16.6);
Pb-214(16.6); Pb-210(16.6)
33 Radium Ion 6,600 119 9 0.020 Ra-226(28.6) Y
Exchange Resins
(R-RAIXRSH)
3% Instruments-Diffuse 5,030 1,770 4 0.080 Ra-226(37.2) Y
Widely Distributed
(R-INSTOF1)
35 Instruments-Diffuse 150 5 4 0.008 Ra-226(37.2) Y
Collectible
(R-INSTDF2)
DIFFUSE NARM WASTES
36 Metals 12,000,000 4,092 5 0.000 U-234(43.4); U-238(43.4) N/A

(R-METWAST)

Total WARN: 12,011, 780 6,609


° clean-up/remedial response costs in event of
accident.

Specification of these and other details is necessary to permit
estimation of mass flows throughout the systens and
to allow identification of ppints of possible release of
hazardous materials to the environment. Once release points are
identified, the probability and likely magnitude of releases can
be estimated. Given the high-level of public concern about
accidental releases, especially those involving serious
consequences, it is important to consider possible accident
events as well as releases from continuous or routine operations.

Develop Scenarios

Once the general disposal systems of interest are described,
specific scenarios for analysis must be established. These
scenarios represent actual land or ocean based systems or groups
of similar systems, and are defined by specific combinations of
factors which are important inputs to the risk analysis, such as

° representative LLRW constituents and amounts,

° representative disposal locations and methods,

° representative modes of transport and operating
conditions.

Scenarios are developed from data describing the actual
population of wastes, sites, and other factors of interest. Such
data are available for land disposal of LLRW currently disposed,
but not for other LLRW or for ocean disposal.

If one wished to consider ten representative LLRW streams,
ten representative disposal locations, and five modes of
transport or operating conditions, 500 sets of risk calculations
(10*10*5) would be required. If 90 percent of these possible
combinations are impossible or unrealistic, 50 sets of
calculations would still be required. While these numbers are
examples only, it is likely that the actual scenarios to be
analyzed will of necessity be limited well below the number of
possible, and relevant, combinations of important system factors
which influence risks.


Log of Specific Activity (Ci“m73)

Source:

Exhibit 3-5

Initial Specific Activity Versus
Time to Decay To 1 Percent Level

a

\naste #32

Waste #26—__ a

IEc analysis.

Log of Decay Time (years)



Exhibit 2-6

Commercial LLRW Streams That Are
Potentially Hazardous Mixed Wastes

Group.

Waste

1. LWR Process Wastes

i. Trash

111, Low Specific Activity
Wastes

IV. Special Wastes

lon-Exchange Resins *
Concentrated Liquids *
Filter Sludges *
Filter Cartridges

LWR Compactible Trash **

LWR Non-compactible Trash **
Institutional Trash +
Industrial Source & SNM Trash +
Industrial Low Trash +

Fuel Fabrication Process Wastes
UF6 Process Wastes
Institutional LSv Waste +
Institutional Liquid Waste +
Institutional Biowaste +
Industrial Source & SNM Waste
Industrial Low Activity Waste

LWR Non-Fuel Reactor Components
LWR Decontamination Resins

Waste from Isotope Production
Facilities

Tritium Production Waste

Accelerator Targets

Sealed Sources

* Further subdivided into BWR and PWR.

aed Further subdivided into BWR, PWR and Fuel Fabrication Plant.
+ Further subdivided into large facility and small facility.

Source: Nuclear Regulatory Commission, An Analysis of Low-Level Wastes:
Review of Hazardous Waste Regulations and Identification of

Radioactive Mixed Wastes

Waste Stream
Reference
Number

Wane

2607)
23
15(7)
7

o

18

9

2


Exhibit 2-4

Low-Level Radioactive Wastes that Exceed
Upper Activity Limits

Total
U.S. Total Activity
Reference 1985-2004 1985-2004
Number Waste Stream (cubic meters) (curies) Ci/tonne Activity Limit Exceeded
21 Sealed Sources 582 571,100 2453.18 Exceeds TRU limit, exceeds upper activity Limit
(N+ SOURCES) for alpha and beta-gamma emitters half-life
greater than one year.
26 Uranium/Thor1um 415,796 3,569,945 8.59 Exceeds upper activity limit for alpha emitters.
Note: may be caused by density assumption.
32 Radium Sources. 0.645 623 350.00 ‘Exceeds upper activity Limit for atpha emitters.

(R-RASOURC)

Source: Ec analysis.


CONTAINER LIFETIMES FOR LOW LEVEL
RADIOACTIVE WASTES CHAPTER 3

This chapter presents IEc's evaluation of container
lifetimes for low-level radioactive wastes. The first section of
the chapter describes our calculations of the time required to
allow radioactive decay for each of the waste streams described
in Chapter 2. The second section provides a review of available
containers which might be used, with appropriate modifications,
for ocean disposal of LLRW.

TIME REQUIRED FOR DECAY

BNL criteria for ocean disposal specifies a number of
requirements pertaining to waste container performance. In
particular, BNL suggests that "the waste container shall have an
expected lifetime of 200 years in the deepsea environment." BNL
also specifies criteria for waste package strength, specific
gravity, and impact resistance. The BNL specific criteria are
listed in the Waste Form section of Chapter 2 of this report.

EPA is evaluating container lifetimes based on several
considerations, and is considering in large part
recommendations prepared for EPA by Brookhaven National
Laboratory (6). Brookhaven recommended that "the waste container
shall have an expected lifetime of 200 years or 10 half-lives of
the longest lived radionuclide, which ever is less."
Brookhaven's report goes on to say that:

"The expected lifetime of the container is
contingent on the types and amounts of radioactive
materials in the waste form and the character-
istics of the disposal site. In assuming
isolation as the basic operating philosophy for

3-1


decay objectives for many LLRW streams. Second, for many of the
longer-lived wastes requiring decay to these levels may be
unnecessary given the relatively low initial radioactivity per
unit volume of these wastes (for example, waste streams #10, 11,
12, and 13). Finally, for a few short-lived wastes, the 200 year
lifetime may be overly restrictive as it will allow time for
decay to levels well below 0.1 percent of initial radioactivity
(for example, waste stream #28).

REVIEW OF AVAILABLE CONTAINERS

In addition to the analysis of decay times described above,
IEc briefly reviewed information describing LLRW containers
currently available. The objective of our review was to generate
information about the nature, cost and technical performance of
containers which might be available for use in ocean disposal of
LLRW. The paragraphs below present the results of our review.

EPA is currently evaluating alternative packaging techniques
for ocean disposal of large volumes of soil containing varying
quantities of naturally-occurring radionuclides (i.e., FUSRAP
wastes). EPA is taking into account containment technology,
public safety and risk, economics, societal considerations and
existing and possible regulatory constraints. As this research
is ongoing, EPA has no results available for inclusion in this
study. Later results may assist EPA in any future evaluations of
disposal and containerization scenarios.

While a variety of possible waste containers are available,
we considered only containers approved as "“High-Integrity
Containers" (HIC) by the U.S. Nuclear Regulatory Commission or by
relevant state agencies. HICs are the only containers approved
for land disposal of LLRW. To receive the HIC designation, a
container must meet a variety of requirements concerning
strength; resistance to vibration; puncture resistance;
resistance to physical, chemical and biological degradation
(internal and external); water resistance; and other factors.
The requirements for HIC designation are provided at 10 CFR
61.55-56 and by the U.S. Nuclear Regulatory Commission in its
Branch Technical Position on Waste Form of May 1983.

We could find no information about HIC test results which
would pertain directly to ocean disposal, and thus it is not
possible to evaluate whether currently available HICs would

3-5


Reference
Number

Waste Stream

Exhibit 2-3
Radioactivity By Emitter - Type for Low Level
Radioactive Wastes

(Cont inued)
Beta- gamma
Beta-gamma Emitters
Emitters Half-Lives <1 yr Total TRU's
Alpha Emitters Half-Lives >1 yr and Tritium Present
Ci/tonne Ci/tonne Ci/tonne Ci/tonne

NATURALLY OCCURRING and ACCELERATOR PRODUCED RADIOACTIVE MATERIALS (NARM)

32

3

35

DISCRETE NARM WASTES

Radium Sources
(R-RASOURC)

Radium lon
Exchange Resins
(R-RALARSH)

Instruments-Di fuse
Widely Distributed
(R-INSTDF1)

Instruments-Di f fuse
Collectible
(R- INSTOF2)
DIFFUSE NARM WASTES

Metals
(R-METWAST)

49100.000 0.000 9740.000 No TRU
0.060 0.000 0.010 Wo TRU
0.010 0.000 0.001 Wo TRU
0,010 0.000 0.001 Wo TRU
0.000 0.000 0.000 Wo TRU


There are a number of additional criteria listed on Exhibit
2-1. For example, the ocean program would specifically prohibit
the disposal of free radioactive gases and of low-level wastes
that contain specific contaminants that are deemed hazardous by
the London Dumping Convention. The land program specifically
prohibits disposal of mill tailings, spent nuclear fuel, and by-
product material. 2/

Summa:

The criteria described above serve to define LLRW for the
ocean and land disposal programs. We assembled data on all
radioactive wastes which are considered as LLRW by the
information sources cited at the beginning of this chapter. We
then considered whether each LLRW stream met the criteria listed
for ocean disposal in Exhibit 2-1. The results of these steps
are described below.

DESCRIPTION OF WASTE STREAMS

Exhibit 2-2 identifies and describes waste streams that IEc
examined as possible candidates for ocean disposal. The
following section outlines the information that is provided in
the exhibit and describes the organization of the waste streams.

The reference numbers assigned to each waste stream are
listed in the first column of Exhibit 2-2. The waste streams are
listed in the second column. For waste streams 1 to 25 and 32
to 36 the second column also provides the mnemonic used by EPA
from the NRC Update of Part 61 Impacts Analysis Methodology.

The third and fourth columns of Exhibit 2-2 list the total
volume in cubic meters, and the total activity in curies,
projected for each waste stream for the years 1985 to 2004. The

2 For disposal purposes, mill tailings, spent nuclear fuel,
and by-product material are treated as high-level radioactive
waste.


Total Volume
Reference 1985-2004
Number Waste Stream (cubic meters)
COMMERCIAL WASTES

POWER REACTOR WASTES

1 PWR Compactible 265,285
Trash (P-COTRASH)

2 BWR Compactible 332,217
Trash (B-COTRASH)

3 LWR Noncompactible 478,210
Trash (t-NCTRASH)

4 LUR Ton Exchange 99,128
Resins (L-IXRESIN)

5 PUR Filter 12,833
Cartridges (P-FCARTRG)

6 LWR Filter Sludge 130,770
(L-FSLUDGE)

7 LWR Concentrated 330,646
Liquids (L-CoNcL10)

8 LWR Decontamination 2,261

Resins (L-DECONRS)

Exhibit 2-2
Description of Low-Level Radioactive Wastes

Total

Activity Important Radionuclides Potential
1985-2006 Density (percentage of waste stream Land BRC
(curies) (g/cm) Ci/tonne radioactivity) Candidate? *

17,840 “4 0.170 €-14¢.03); Co-60(35.9); Y
Sr-90¢.06); Cs-137C12.6); Fe-55(19.3)
10,560 3 0.110 €-14¢.03); Co-60(35.9); Sr-90¢ .06); Y
€5-137(12.6); Fe-55(19.3)
160,500 4 0.840 €-14(.04); Co-60(39.1); Sr-90(.07); 4
€s-137(10.6); Fe-55(20.5)
1,330,527 x) %.9 €-14¢.09); Co-60(9.9); Sr-90¢.2); W
€s-137(26.7); Cs-134(26.7); Ba-137m(26.7)
58,240 1.3 3.490 €-14¢.002); Co-60(56.8); Sr-90¢.004); "
€s-137¢.5); Fe-55(29.5)
1,108,000 x) 9.410 €-14¢.019; Co-60(31.0); Sr-90¢ .03); "
Cs-137(16.4); Fe-55(16.4); Cs-134(16.4);
Ba-137m( 16.4)
399,127 1.7 0.710 €+16(.06); Co-60(27.8); Sr-90¢.11); "
(5-137(16.7); Cs-134(16.7); Ba-137m(16.7)
52,430 a 26.000 Co-60(80.8); Fe-55¢11.2) 8


Exhibit 3-4

Number of LLRW Streams Requiring Decay Times

Fraction of Radioactivity Remaining

Decay Period (years) 1 Percent ~ 0.1 Percent
0 to 20 1 1
21 to 100 4 0
101 to 200 6 2
201 to 500 10 6
501 to 1000 t+) 6
1001 to 5000 t+) 3
5001 to 10,000 3 oO
more than 10,000 16 22
Total streams
considered: 40 40

Source: IEc analysis.


TABLE OF CONTENTS

INTRODUCTION AND SUMMARY CHAPTER
BaCkGrOund ...cccccceeccccccecccceenececcescceeescsseees
Summary Of RESUItS ...ceccccccceccennscceesccceeee
Factors Required for Comparative Analysis ............--
Plan Of This Report .....ccccevvovencccccccccvccvccecers

1
1
seoee l
1
1

LOW LEVEL RADIOACTIVE WASTE

ELIGIBLE FOR OCEAN DISPOSAL CHAPTER
Introduction 2... cece ec cece ccc e cece eee nc en cece eneensenes
Definition of LLRW ........ceeecenee
Description of Waste Streams ..
Eligibility for Ocean Disposal ..

2
2
wee 2
2
2
2

CONTAINER LIFETIMES FOR LOW LEVEL
RADIOACTIVE WASTES CHAPTER 3
Time Required for Decay ......ceeescccccccccccccccecesee Sm
3
3

Review of Available Containers

RADIONUCLIDE COMPOSITION OF
LOW-LEVEL RADIOACTIVE WASTES .........+--2+ee-2+e-e+e+++ APPENDIX A


APPENDIX A


Exhibit 3-6

Unit Cost Versus Volume for
High Integrity Containers

5004 8 Polyethylene
—#~ Composite
—*- Stainless Steel
1004 —+- SFPIC
we
ea
0
ie)
Ww 3004
2
oO
J
(3) y
5 2004
a
ov
ad
=
2 s004
® T T T T T 1
i 50 100 150 200 250 300

Volume (cubic feet)

Source: See text.


Radionuclide Composition of Waste Streams (ci /m?)

Ike No. #4 7 16 15 iD 9 Tz m3
Half Life — WCLIDE” L-IXRESIN L-CONCLIQ L-FSLUDGE PLFCARTRG © L-DECONRS © L-NFROONP «F-PROCESS U-PROCESS.

z.3y HB. B.AZE“D 89-21. 36E-2 2, 77-3
5700y c. V.20-2 7.4 8.294 1.02E-4 643-3
2.by FeSS GIS} 1.95E-1.S6EO 1.30 2.6380 5. SAE*I
80,0007 *Mi-89.ONE-A 2206-4 1.62E-31.59-3 3.45E-2
2.6280 2.5860 1.896413. 98861

*
S.27y C060 NAME 8.SRE-

125y Wi-63 = (1.19E-1 596-2 5.32E-2 0 A.QTE-19.96E-1 A. EO
28y Sr-90  2.62E-2-1.4SE-3. 250-3 _2.02E-4
20, 000y M94 -2.82E-5 6. 9BE-6 = S.10E-5—5.03€-5 2.0464
200,000y = te-99 —1.ASE-4B.IZE-6 = 5.36E-S = 8.62E-7
367d u-106. 3.8763 2.16E-4 1.3963 2.30E-S 8. ABE-1
2.7¥ — Sb-125 1. 16E-22.86E-3 2.0882 2.08E-21.8BE-3
100,000, 000y 1-129 A.18E-42.33E-5 SHEA 2.55E-6
2y — cs-1343.87EO 82. NSE-1 1.3802. 30-2
3,000,000¥ = 5-135 1.ASE-ABLIZE-6 «= S.28E-SB.62E-7
30y 137 3.87E 0 2.16E-1 1.398 0° 2. 508-2
are Ba-137m 3.870 © 2.16E-1 1,398 0 2.302
250,007 EATISA SE-B -2.GTE-A2.10E-32.07E-3 9. 766-5
710,000,000, UZ SHEA 9.GZE-G—9.95E-6 2. 366-5 S.206-4 -3.646-4
000, U235 2.5566 9 SME-T—1.60E-T 3198-7 2.306-5 1656-5
2,200,000y —-Np-237 1. 146-9 G.89E-11 7. 14E-11 1698-10
4,500,000,000y = U-238«4.65E-S 2.8286 = -2.92E-6 6. 91-6 O.54E-5  3.64E-4

86y Pu-238 3.29€-3 4.66E-4 4.95E-4 6.05E-4 1, 136-2

24,300y Pu-239 0 -2.30€-3 2.6864 2.1284 9. 1SE-4 1,.S2€-3
13y Pu-241 1. O1E-1 V.21E-2 1.326-2 4,00€-2
458y pm-241 2.35€-3 2. 16E-4 2.086-4 3.95E-4

380, 000y Pu-242 5.04E-6 5.76€-1 5.41E-7 2.01E-6

8000y m-24301.S8E-A 1.86€-5 1,406-5 2.65€-5
35y Qn-243°(1.25E-6 3.16E-7 3.62E-7 4.65€-7 1, 13€-2
17.6y On-244 0 1.738-3 3.0384 2.6384 2.65€-4 3.16€-3

TOTAL 1.45E61 1.296 0 8.46E 0 4.546 0 2.34Ee1 1.006 +2 6.2864 145-4

Source: Adapted by IEc from BID Table 3-5.


upon disposal, they rapidly become non-toxic to marine life and
non-bioaccumulative in the marine environment by chemical or
biological degradation. Disposal of constituents under these
terms is allowed only if they will not make edible marine
organisms unpalatable, or will not endanger the health of humans,
domestic animals, fish, shellfish, or wildlife. 11/

Thus, the presence of co-contaminants may eliminate some
LLRW streams on Exhibit 2-2 from being considered as ocean
disposal candidates. In order to help IEc identify waste streams
which may be contaminated with the constituents listed above, EPA
contracted with Brookhaven National Laboratory. Brookhaven
provided general information about co-contamination of commercial
and DOE wastes.

Co-contamination of Commercial Wastes

IEc used three NRC documents supplied by Brookhaven to make
rough approximations regarding co-contamination of the twenty-
five commercial waste streams on Exhibit 2-2. These documents
include Management of Radioactive Mixed Wastes in Commercial Low-
Level Waste (11); An Analysis of Low-Level Wastes: Review of
Hazardous Waste Regulations and Identification of Radioactive
Mixed Wastes (9); and Document Review Regarding Hazardous Chem-
ical Characteristics of Low-Level Waste (10). These reports
provide general information and classify LLRW into categories
such as wastes containing organic liquids, lead-containing
wastes, chromium-containing wastes, and mercury-containing
wastes. Analysis is difficult as the reports do not specifically
refer to the waste streams listed on Exhibit 2-2, nor do they
address all of the contaminants of concern listed in Annexes I
and II of the London Dumping Convention and current ocean
disposal regulations (40 CFR 227.5 and 227.6).

11/ These provisions are present in order to implement
prohibitions found in the Convention on the Prevention of Marine
Pollution by Dumping of Wastes and Other Matter (London Dumping
Convention) .


LOW LEVEL RADIOACTIVE WASTE
ELIGIBLE FOR OCEAN DISPOSAL CHAPTER 2

INTRODUCTION

This chapter presents IEc's estimates of the quantity and
radioactivity of low-level radioactive waste (LLRW) likely to be
considered for ocean disposal. The first section of the chapter
presents the definition of low-level radioactive wastes and
compares LLRW definitions used by the land versus ocean disposal
programs. The second section of the chapter identifies and
describes all LLRW streams considered for ocean disposal. The
final section of the chapter compares all LLRW streams with a
number of eligibility criteria in order to determine which LLRW
streams might be eligible for ocean disposal.

Data describing LLRW streams are drawn from three sources.
Information about commercial LLRW is from Update of Part 61
Impacts Analysis Methodolo Methodolo: Report (12); and Vol.
2 of the Draft Environmental Impact Assessment (EIA) (8). Inform-
ation about DOE/Defense LLRW and waste from decontamination and
decommissioning of commercial power plants is drawn from Inte-
grated Data Base for 1986: Spent Fuel and Radioactive Waste
Inventories, Projections and Characteristics (4). Finally,
information about naturally occurring and accelerator-produced
radioactive materials (NARM) is from Vol. 2 of the Draft EIA (8)
and from Radiation Exposures and Health Risks Associated with

Alternative Methods of Land Disposal of Natural and Accelera-
tor-Produced Radioactive Materials (2).



segmented waste streams according to volume, source of
generation, waste form, and radionuclide content.

Exhibit 2-2 indicates that an estimated 2,925,702 cubic
meters and 12,744,504 curies of commercial low-level waste are
expected to be generated from 1985 to 2004. Commercial waste
streams are organized into four sub-categories: power reactor
wastes, fuel cycle wastes, industrial wastes, and institutional
wastes. Power reactor wastes account for 59 percent of the total
commercial waste volume and 75 percent of the total activity.

Exhibit 2-2 indicates that the commercial waste category is
diverse. For instance, radioactivity, as measured in Ci/tonne,
ranges from 0.000 Ci/tonne (five waste streams have very small
activity concentrations that are rounded to 0.000 cCi/tonne) to
2453.18 cCi/tonne (reference number 21). Sixteen waste streams
have activities less than 1 Ci/tonne, two waste streams have
activities of 1 to 10 Ci/tonne, and seven waste streams have
activities greater than 10 Ci/tonne. In addition, fourteen
commercial waste streams are identified as potential land BRC
candidates. Each of these waste streams have activities less
than .6 Ci/tonne.

DOE/Defense "General" Waste

The second category in Exhibit 2-2 consists of low-level

wastes generated by DOE/defense activities. These wastes
currently are buried at DOE disposal sites. In Exhibit 2-2, we
use the six waste groups that are defined in DOE's

Integrated Data Base for 1986: uranium/thorium, fission product,
nduced activity, tritium, alpha, and "other". DOE estimates
that 1,831,701 cubic meters and 27,473,055 curies of DOE/defense
low-level wastes will be generated during 1985 to 2004.

Compared to the total volume and activity of commercial
wastes, DOE/defense "general" wastes have about 60 percent of the
volume and more than twice the number of curies. This category of
low-level waste is qualified as "general" because it is comprised
of six broad groups of wastes that are routinely generated.
Information about DOE/defense low-level wastes is less detailed
than commercial wastes because of security restrictions regarding
the sources generating the wastes. The commercial waste streams


An Update (1) is proposing to regulate only those wastes with
activities greater than .002 Ci/tonne. Thus, a lower activity
limit for NARM wastes is established.

Upper Activity Limit

While the upper activity limits for the ocean and land
programs are not entirely consistent with each other, each is
relatively well defined. High-level radioactive waste is clearly
illustrated for both programs, and both definitions of LLRW
designate high-level waste as the upper limit for what qualifies
as LLRW. As Exhibit 2-1 shows, both programs would provide
qualitative definitions of high-level waste. In addition, the
ocean program would provide quantitative upper activity limits
for three distinct categories of emitters. No quantitative
limits are provided by the land program.

Other Specifications

Each program identifies additional criteria that serve to
narrow the definition of low-level wastes. Exhibit 2-1 presents
these other specifications included in the definitions of low-
level waste for the land and the ocean programs. First, both
programs generally prohibit the disposal of wastes with radio-
activity greater than 100 nanocuries per gram (.1 Ci/tonne) from
transuranic alpha emitters with half-lives greater than 20 years.

Second, the EPA is considering additional limits on LLRW
disposed in the ocean to insure that the maximum dose to an
individual is only "a small fraction of 100 millirem/year."
Current information about human exposure pathways from ocean
disposal is not sufficient to allow translation of this exposure
limit into specific activity limits for wastes.

For the land disposal program, EPA is currently considering
general criteria for radioactive wastes whose disposal would
present an annual exposure dose to critical population groups of
less than 4 millirem as "Below Regulatory Concern" (BRC). Wastes
that qualify as BRC could be disposed on land without regard to
radionuclide content. Should a proposed rule concerning BRC go
into effect, BRC may serve as a lower limit for defining which
wastes must be treated as LLRW when disposed on land.

2-3


IEc used the information in these three documents to
identify which commercial LLRW streams potentially include co-
contaminants. Exhibit 2-6 lists these waste streams. As the
exhibit shows, from 19 to 22 of the twenty-five commercial waste
streams may contain contaminants. These co-contaminated LLRW
streams account for 78 to 93 percent of the total commercial
volume and virtually all of the radioactivity contained by
commercial LLRW.

Because the NRC documents do not refer to the specific LLRW
groups used by IEc, our identification of co-contaminated wastes
is uncertain and may be too inclusive. In addition, the NRC
documents did not consider all co-contaminants listed in the
proposed ocean regulations. Thus, a more thorough
investigation is necessary to determine with certainty which
specific commercial wastes are contaminated by the constituents
listed in the proposed ocean regulations and whether these
contaminants exceed trace levels.

Co-contamination of DOE/Defense Wastes

Dr. Peter Colombo of Brookhaven National Laboratory provided
the following information regarding the co-contamination of DOE
low-level wastes. Virtually all DOE waste streams originating
from defense activities or fuel reprocessing consist of mixed
wastes. In addition, unlike commercial wastes streams, DOE low-
level wastes from different origins are often combined into tanks
or other storage facilities. These mixtures of DOE wastes are
not adequately characterized with regard to hazardous chemical
content. Thus, it is likely that most or all DOE/Defense LLRW
streams have co-contaminants present at some level.

Co-Contamination of Other Wastes

IEc was not able to find information describing co-
contamination of the other LLRW categories shown in Exhibit 2-2.
Thus, we are not able to determine the likelihood of co-
contamination for these wastes. However, IEc was able to obtain
detailed information about the co-contamination of a _ single
remedial action waste at the New Jersey FUSRAP_ site.
Concentrations of contaminants such as volatile organics, acid
extractable compounds, base/neutral extractable compounds,

2-16


CH1 EXHIBITS


QQ)

(2)

(3)

(4)

(5)

(6)

(7)

(8)

(9)

REFERENCES

Galpin, Floyd L., James M. Gruhlke, and William F. Holcomb,
Office of Radiation Programs. EPA's Low-Level and _ NARM
Waste Standards: An Update. For presentation at the Annual
Meeting of the Conference of Radiation Control Program
Directors, Inc. May, 1985.

PEI Associates, Inc. Radiation Exposures and Health Risks
Associated with Alternative Methods of Land Disposal of
Natural and Accelerator Produced Radioactive Materials
(NARM) . Prepared for the U.S. Environmental Protection
Agency, Office of Radiation Programs. October, 1985.

U.S. Department of Energy. Final Environmental Impact State-
ment. Long-Term Management of the Existing Radioactive
Wastes and Residues at the Niagara Falls Storage Site.
April, 1986.

U.S. Department of Energy, Oak Ridge National Laboratory.
Integrated Data Base for 1986: Spent Fuel and Radioactive
Waste Inventories, Projections, and__ Characteristics.
September, 1986.

U.S. Department of the Navy. Final Environment Impact State-
ment _on the Disposal of Decommissioned, Defueled Naval Sub-
marined Reactor Plants. May, 1984.

U.S. Environmental Protection Agency, Office of Radiation
Programs. Development of a Working Set of Waste Package
Performance Criteria for the Deepsea Disposal of \ Low-Level
Radioactive Waste. EPA 520/1-82-007. November, 1982.

U.S. Environmental Protection Agency, Office of Radiation

Programs. Draft Environmental Impact Statement, Vol. I,
Background Information Document. August, 1987.

U.S. Environmental Protection Agency, Office of Radiation
Programs. Low-Level and NARM Radioactive Waste, Vol. 2,
Draft Environmental Impact Assessment. EPA 520/1-87-012-2.
April, 1988.

U.S. Nuclear Regulatory Commission. An Analysis of Low-Level
Wastes: Review of Hazardous Waste Regulations and Identi-
fication of Radioactive Mixed Wastes, NUREG/CR-4406.



Appendix A

Radionuclide Composition of
Low Level Radioactive Wastes


Using the equation shown in Exhibit 3-1 and given the decay
constants for the component nuclides and the amount of each
nuclide in the waste stream, we derive the time (t) required to
reduce the initial radioactivity of the total waste stream to any
given proportion (p) of the initial amount. Because the equation
in Exhibit 3-1 has no closed form solution, we solve for t by
iteration.

Exhibit 3-2 provides an example of the spreadsheet used to
accomplish these calculations. Column (1) lists all
radionuclides in waste streams we considered. Column (2) shows
the decay constants for each of these nuclides. Column (3) is
the radionuclide concentration data (Ci/cubic meter) for a
specific waste stream, here I-LQSCNVL. The values in column (4)
are the number of curies of each nuclide and are computed by
multiplying the values in column (3) by the total volume of the
waste stream shown at the top of the exhibit.

Column (5) shows the portion of radioactivity remaining in
each component of the waste stream after t years, where t is set
to value shown at the top of the exhibit. Column (6) shows the
total number of curies remaining of each radionuclide at time t.
The sum of the figures in column (6) is the total number of
curies remaining in the entire waste stream. The sum of column
(6) divided by the original number of curies (the sum of column
(4)) is the percentage of radioactivity remaining in the waste
strean. We solve iteratively for t until this percentage equals
the desired proportion (in this example .50 or 50 percent).

Exhibit 3-3 presents the results of these calculations for
all LLRW for which nuclide composition data are available. The
exhibit shows the years required for the radioactivity of each
LLRW stream to decay to 1 percent and slightly less than 0.1
percent (actually 0.0976 percent) of initial levels.

Exhibit 3-3 shows tremendous variation in the time required
to achieve decay for different waste streams. Times required to
achieve 1 percent of initial activity range from 5 years (waste
28) to 82 billion years (waste 40); times required to achieve 0.1
percent of initial activity range from 17 years to 129 billion
years for these same LLRW streams.

Exhibit 3-4 summarizes the information presented in Exhibit

3-3 by tabulating the number of waste streams which require
similar time periods to reach the specified decay levels. As

3-3


Exhibit 1-2 does not show any strong pattern relating LLRW
volume and specific activity. There appears to be a _ slight
tendency for large volume wastes to have lower specific
activities, but examples of the opposite relationship appear as
well. All of the individual LLRW streams are reviewed in more
detail in Chapter 2.

Data about these LLRW streams suffer from varying degrees of
uncertainty. Wastes which are being generated today on a
relatively routine basis, such as commercial, DOE/Defense and
NARM wastes, have relatively certain information available on
waste quantity, composition, and radioactivity.4/ Information
about wastes which are not being generated on a routine basis
today, such as decommissioning and remedial action wastes, is
much more uncertain. The reader should keep these differences in
mind when evaluating the certainty of information presented.

LLRW Eligible for Ocean Disposal

Estimating which LLRW streams will in fact be eligible for
ocean disposal is a difficult task for several reasons. First,
waste eligibility will depend on a variety of interrelated waste,
disposal site and waste package factors. However, in our work we
have considered waste-specific factors only. Second, some of the
ocean disposal criteria under evaluation would require EPA to use
considerable professional judgement in determining LLRW
eligibility. When requirements are not stated precisely, we have
not been able to make firm judgments concerning a waste's
possible eligibility for ocean disposal. Third, we have
incomplete data for many LLRW streams, which makes it difficult
to establish certain eligibility for these wastes.

Notwithstanding these problems, we compared all 45 LLRW
streams to various eligibility requirements with the following
results. First, all but two (waste streams #21 and #32) of the
40 wastes for which activity data are available meet the upper
activity limit. The volume and radioactivity represented by the
two ineligible wastes account for less than one hundredth of one

4 However, for national security reasons little of this
information is publicly available for DOE/Defense wastes.


concentration of transuranic elements with half-lives greater
than twenty years is also presented in terms of Ci/tonne in
Exhibit 2-3.

Using the information in Exhibit 2-3, Exhibit 2-4 identifies
waste streams that fail to meet the upper activity limits. As
Exhibit 2-4 shows, three of the 45 waste streams do not meet the
proposed criteria. This group of waste streams includes one
commercial waste strean, one NARM waste strean, and one
DOE/defense waste stream. The far right column of the exhibit
shows which of the activity limits is exceeded.

The DOE/Defense LLRW stream which fails to meet the alpha
activity limit is stream 26, entitled uranium/thoriun. As for
all DOE/Defense LLRW, no data on densities are available and thus
we assumed a density of 1 gram per cubic centimeter (that of
water) in completing the activity per tonne calculations. Given
the relatively high densities of uranium and thorium, this waste
in fact may be substantially more dense than water. If the
waste's actual density is greater than water by a factor of 2.15
or more, it would be below the alpha emission limit and would be
eligible for ocean disposal under this set of criteria.

Ambient Concentrations

In addition to using upper activity limits to evaluate waste
stream eligibility, we reviewed limited ambient radioactivity
concentrations in the deep ocean. These ambient concentrations
could serve as lower activity limits to define what constitutes
low-level wastes. If that option were selected, LLRW streams
with an activity concentration less than ambient concentrations
could Pe disposed in the ocean without regard to radionuclide
content.

We were able to find only limited data describing ambient
radioactivity concentrations in deep ocean (>3500 meters) water
and sediments. Exhibit 2-5 lists available ambient
concentrations of selected anthropogenic and naturally occurring
radionuclides measured in the deep ocean within about 100 miles

2-13


Exhibit 3-2

EXAMPLE OF DECAY TIME CALCULATION

Waste Stream: T-LOSCRVL
Volume of Waste Stream (m*3): 15,040
Time (years): te 18.25

iw
Si

C-14 -1.22E-04
Fe-55 -2.67E-01
Ni-59 +8.66E-06
1,32E-01

ccood

4. 34E-

65.276

0
0
0
0
oO
0
0
0
0
ty)
0
0
0
0
0
oO
0
0
oO
0
0

0
0
Qo
0
03
0
0
O
0
o
o
0
oO
0
0
0
O
0
0
Oo
O
9
0
o
)
0
o

eocceecp CCC CO DDC OOOO O0O

Cm-266 +3.90E-02

144.399 72,246

% of radioactivity remaining: 50.031 %

Source: See text.


Exhibit 3-3
(Continued)

Time Required for LLRW Decay

(Years)

Waste -+> Fraction of Radioactivity Remaining ---
Reference ~ 0.1 Percent
Number Waste Stream 1 Percent (10 half-lives)

v7 Industrial Low 11,850 30,950
Activity Waste

18 Isotope Production 180 288
Waste

9 Tritium Waste 8 1,990
Waste Stream

20 Accelerator Targets 82 124

a Sealed Sources 170 37

22 Institutional Com- 12,000 31,400
pactible Trash

3B Biological Waste 12,500 31,800

24 Absorbed Liquids 14,000 30,100

25 Liquid Scintilla- 7,800 27,000
tion Vials

26 Uranium/thoriun 23,000,000,000 40,750,000, 000

27 Fission product 140 258

28 Induced activity 5 7

29° Tritium 81 123

30 Alpha, <10 nCi/g 300 25,100

uv "Other" 240 13, 000,000,000

32 Radium Sources 6,480 11,840

Bx} Radium Ion 7,720 13,090

Exchange Resins


Exhibit 3-3
(Continued)

Time Required for LLRW Decay

(Years)
Waste ++ Fraction of Radioactivity Remaining ---
Reference ~ 0.1 Percent
Number Waste Stream 1 Percent (10 half-lives)
ue Instrunents-Di ffuse 198,000 12,950,000,000
Widely Distributed
3 Instruments Diffuse 240,000 12,950,000, 000
Collectible
36 Metals 27,500,000,000 56,300,000,000
37s Pressurized Water (PWR) 83 379
Boiling Water (BWR) 135 470
DOE “SPECIAL PROJECTS" N/A N/A
(e.g. TMI, West Valley)
40 NJ 82,000,000,000 129,500,000, 000
4“ other N/A N/A
42 Niagra Falls N/A N/A
Storage Site
43 other N/A N/A
4h CERCLA N/A N/A
45 Decommissioned Reactor Plant 500 73,500

(for 100 submarines)

N/A = data on nuclide composition not available.

Source: See text.


implies, they will not be routinely generated over the next 20
years. An estimated 23,690 cubic meters and 801,000 curies will
be generated during 1985 to 2004.7/ 8/

Remedial Action Waste

The fifth category on Exhibit 2-2 represents the low-level
radioactive wastes generated by remedial action programs. Two
DOE programs are responsible for the generation of low-level
radioactive wastes: FUSRAP (Formerly Utilized Sites Remedial
Action Program) and SFMP (Surplus Facilities Management
Program) .9/ In addition, EPA's remedial action program under the
Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) also generates LLRW. At the present time, ten
CERCLA sites with LLRW are estimated to be on the National
Priorities List (NPL). Further investigation may show that
additional sites contain radioactive contamination. We are not
able to estimate the nature or amount of this LLRW with currently.
available EPA information. “As a result, our estimates for the
remedial action category are likely to be understated.

FUSRAP was started in 1974 to decommission sites that were
formerly used to support the nuclear activities of DOE's
predecessor agencies. There are currently 29 FUSRAP sites in 12
states. These wastes are primarily soils containing small
quantities of naturally occurring radioactive materials. The New

yV Niagara Falls Storage Site is included in the remedial
action projections.

s/ The following report may provide additional information on
decontamination and decommissioning LLRW: Sources of Residual

Radioactivity In Decommissioning of Nuclear Facilities, Roy F.
Weston, Inc., and S. Cohen and Associates, prepared for EPA.
Contract No. 68-02-4375, December 1987.

a In addition to FUSRAP and SFMP there are two other remedial
action programs: UMTRAP (Uranium Mill Tailings Remedial Action
Program) and GJRAP (Grand Junction Remedial Action Program).
Because these programs do not generate waste that would qualify
as LLRW, we have not included these volumes in our estimates.

2-10


DOE/DEFENSE "GENERAL" LLW
URANIUM/THORIUM IEc #31

Nuclide Half-Life (years) Ci/m3

T1-208 0.00001 1.46E-4
Pb-212 0.0012 3.86E-4
Bi-212 0.00012 3.86E-4
Po-212 9.6E-15 2.49E-4
Po-216 ~0 3.86E-4
Ra-224 0.0099 3.86E-4
Ra-228 5.75 2.31E-3
Ac-228 0.0007 2.0E-3

Th-228 1.913 3.86E-4
Th-231 0.00291 2.22E-3
Th-232 1.4E+10 2.34E-2
Th-234 0.066 2.85E+0
Pa-234m 0.0007 2.85E+0
Pa-234 0.0008 2.92E-2
U-235 7.0E+08 2.22E-3
U-238 4.5E+09 2.85E+0

Source: IEc chart derived from DOE Tables A.2 and A.3.


provided by the International Atomic Energy Agency
(IAEA), London Dumping Convention (LDC) documenta-
tion, existing ocean disposal regulations, and
reports from Brookhaven National Laboratory (BNL),
and (2) radioactivity limits and other technical
criteria for the ocean disposal program as
suggested in BNL's "Development of a Working Set
of Waste Package Performance Criteria for the
Deepsea Disposal of Low-Level Radioactive Waste".

° Second, EPA asked IEc to review the criteria
suggested in the BNL technical document concerning
container lifetime, and to identify considerations
which might support use of shorter or longer-life
containers.

° Third, EPA asked IEc to identify and discuss
factors which would be required for a comparative
analysis of the human health and environmental
risks associated with ocean versus land disposal
of LLRW.

The remaining sections of this chapter summarize the results of
IEc's work, and describe the organization of this document.
References are cited in the text using the number as shown in the
Bibliography.

SUMMARY OF RESULTS
LLRW Definition

A working definition of LLRW being considered by EPA
includes upper activity limits (which define the demarkation
between low-level and high-level wastes), de facto lower activity
limits based on ambient levels (which define the demarcation
between LLRW and lower activity concentrations not of regulatory
concern), and a variety of other specifications such as limits on
transuranic wastes and wastes containing contaminants. We have
compared radioactive wastes generally identified in a variety of
source documents as "low-level" to the ocean disposal criteria to
determine the volume and activity of LLRW that might be eligible
for ocean disposal.


INTRODUCTION AND SUMMARY CHAPTER 1

BACKGROUND

The Environmental Protection Agency (EPA) is currently con-
sidering revisions to ocean dumping regulations which may include
provisions for the evaluation of permits for deep-ocean disposal
of low-level radioactive wastes (LLRW). These revisions are to
reflect the requirements of the Marine Protection, Research and
Sanctuaries Act (MPRSA, PL 92-532) as amended by the Surface
Transportation Assistance Act (PL 97-424), and may require, among
other things, that applicants perform Radioactive Material
Disposal Impact Assessments (RMDIA) and that a joint resolution
of Congress give approval prior to issuance of any permits by
EPA.

EPA is evaluating criteria for LLRW ocean’ disposal,
including provisions for disposal site designation, waste
packaging performance, the definition of high-level radioactive
wastes, and the requirement that applicants conduct the RMDIA.
As part of its evaluation, EPA is reviewing and considering
siting criteria and waste packaging criteria of the International
Atomic Energy Agency (IAEA), especially for the annual total
limits of radioactivity, and the limits for alpha, beta and
gamma-emitting radioactivity per unit volume of waste.

To assist in developing the LLRW ocean disposal provisions,
EPA's Office of Policy Analysis asked Industrial Economics,
Incorporated (IEc) to complete three research tasks as follows.

° First, EPA asked that IEc estimate the volume and
radioactivity of LLRW that might be eligible for
ocean disposal taking into consideration (1) any
differences in LLRW definition between the
proposed land disposal program and definitions


Summary of Low Level Radioactive Wastes

Exhibit 1-1

That are Potential Candidates for Ocean Disposal,

1985 - 2004

Number of volume Radioactivity
Source Streams (cubic meters) (curies)
Commercial 25 2,925,702 12,744,504
DOE/Defense 6 1,831,701 27,473,055
Naturally Occurring/ 5 12,011,780 6,609
Accelerator Produced
(NARM)
Decommissioning LLRW 3 37,672 903,910
(Nuclear Reactors Only)
Remedial Action 5 3,626,625 -
U.S. Navy Submarine 1 --* 6,200,000
Reactor Plants

Total 45 20,433,480 47,328,078

* The FEIS on the disposal of submarine reactor plants (5)

indicates that there are 362,870 tonnes that may qualify as LLRW.

Source: See text.


° Remedial action LLRW streams include wastes
projected to be generated by future remedial
actions at a variety of sites administered under
EPA and DOE programs. 2/

° Finally, the U.S. Navy must decommission about 100
nuclear submarines over the next 20 to 30 years
and must dispose of the resulting LLRW.

NARM wastes are comprised of a variety of radioactive
materials generated by industrial users and regulated on a state-
by-state basis. According to EPA's Low-Level and NARM Waste
Standards: An Update (1) very little of the quantity of NARM
waste shown in Exhibit 1-1 would be defined as regulated LLRW.
Further, individual states differ in their requirements for these

wastes. Thus, the necessity of regulated disposal for many NARM
wastes is not clear at this time.

The 45 waste streams summarized in Exhibit 1-1 are diverse
in terms of source, generation volume, and specific radioactivity
(defined as radioactivity per unit volume). Exhibit 1-2 presents
a diagram which plots volume versus specific activity for all
LLRWs for which data are available. As shown, volume for these
waste streams varies across 7 orders of magnitude, and specific
activity varies across 10 orders of magnitude. If the two
outlier wastes are ignored, volume varies across 4 orders of
magnitude and specific activity varies across 8 orders of
magnitude. Note that the large ranges in both volume and
specific activity across LLRW streams require use of logarithm
scales for both axes of the graph.3/

2 The estimates shown in Exhibit 1-1 for remedial action do
not include wastes generated by EPA's CERCLA program, which could
be significant in quantity. We have not been able to develop
estimates of CERCLA LLRW for this report.

3/ The two LLRW streams that are identified on Exhibit 1-2 are
described more fully in Chapter 2 of this report.


(10) U.S. Nuclear Regulatory Commission. Document Review Regard-
ing Hazardous Chemical Characteristics of Low-Level Waste,

NUREG/CR-4433.

(11) U.S. Nuclear Regulatory Commission. Management of Radioac-
tive Mixed Wastes in Commercial Low-level Wastes (draft re-
port). NUREG/CR-4450.

(12) U.S. Nuclear Regulatory Commission. Update of Part 61 Im-
pacts Analysis Methodology Report; NUREG/CR-4370, Vol. I.

January, 1986.



DOE/DEFENSE "GENERAL" LLW
INDUCED ACTIVITY IEc #33

Nuclide Half-Life (years) Ci/m3

er-51 0.076 9.74E-1
Mn-54 0.83 7.50E+0
Co-58 0.195 1.09E+1
Fe-59 0.122 9.64E-2
Co-60 5.271 1.71E-1
Zn-65 0.667 3.74E-2

Source: IEc chart derived from DOE Tables A.2 and A.3.


DOE/DEFENSE "GENERAL" LLW
"OTHER" IEc #36

Nuclide Half-Life (years) Ci/m3

H-3 12.28 2.36E-1
c-14 5730 1.16E-2
Mn-54 0.83 1.31E+O
Co-58 0.195 1.21E+0O
Co-60 5.27 3.49E+0
Sr-90 28.6 1.64E+O
Y-90 0.00012 1.64E+0
Tc-99 213000 2.32E-2
Cs-134 2.062 2.71E+0
Cs~-137 30.17 3.71E+0
Ba-137m ~O 3.25E+0
U-238 4.5E+9 1.41E-1

Source: IEc chart derived from DOE Tables A.2 and A.3.

10


density of each of the waste streams is provided in the fifth
column.3/ The sixth column is calculated by using the density to
convert waste volume to waste mass in metric tons (tonnes), and
then dividing activity by the resulting mass to arrive at curies
per tonne.

The seventh column summarizes the radionuclide composition
of the low-level waste streams. At EPA's request, IEc identified
the following radionuclides and their percentage contribution to
the radioactivity in each of the waste streams: carbon 14 (C-14),
radium 226 (Ra-226), cobalt 60 (Co-60), strontium 90 (Sr-90), and
cesium 137 (Cs-137). In addition, we note other radionuclides
that represent a significant portion of the radioactivity in each
waste strean.

EPA's current proposal concerning land disposal of LLRW
allows for the identification of certain waste streams as "Below
Regulatory Concern" (BRC) thereby deeming them suitable for
disposal at sites not regulated as LLRW disposal sites. 4/ The_
proposed rule provides a general criterion that low-level wastes
for which unregulated disposal results in CPG (critical
population group) exposures less than 4 millirem per year be
Classified as "Below Regulatory Concern". The final column of
Exhibit 2-2 indicates if a waste stream is a possible candidate
for BRC given the current land proposal. As discussed below, this
column applies only to commercial waste streams and discrete NARM
wastes.

The low-level waste streams that are listed in Exhibit 2-2
are organized into seven categories:

3/ For most of the wastes, densities were obtained from the
sources mentioned at the beginning of this chapter; however, for
the wastes generated by DOE/defense activities, decommissioning,
and remedial action programs the densities are assumed to be the
density of water (1 g/cm3). This assumption is consistent with
the actual densities of commercial waste, which average .97
g/cm3, and is also used in the DOE data source cited at the
beginning of this chapter.

4 The EPA will not specifically designate which low-level
wastes will become BRC. Such wastes will be classified by NRC
and DOE.


REVIEW OF WASTE ELIGIBILITY AND
CONTAINER LIFETIMES FOR OCEAN
DISPOSAL OF LOW LEVEL
RADIOACTIVE WASTE

INDUSTRIAL ECONOMICS, INCORPORATED

2067 MASSACHUSETTS AVENUE CAMBRIDGE, MASSACHUSETTS 02140


DECONTAMINATION AND DECOMMISSIONING OF
LIGHT WATER REACTORS PWR AND BWR

IEc #37 IEc #38
PWR BWR

Nuclide Half-Life (years) Ci/m3 Ci/m3
c-14 5730 0.00E+0 4.99E~4
Ni-59 80,000 6.62E-4 2.94E-3
Nb-94 20,000 4.49E-6 3.68E-7
Tc-99 213,000 0.00E+0 1.82E-7
Co-60 5.27 1.99E+0 2.60E+O
Ni-63 92 1.08E-1 4.11E-1
Sr-90 28.6 6.88E-5 1.54E-3
Y-90 0.0073 6.88E-5 1.54E-3
Cs-137 30.17 7.86E-2 9.36E-2
Ba-137m 0.000004 7.44E-2 8.86E-2
T(1/2)<5 yr -- 4.76E+0 1.24E+1

Source: IEc chart derived from DOE Tables 7.1, A-8 and A.9.

11


(COMMERCIAL

WASTES:
POWER REACTOR WASTES

PWR Compactible
Trash (P-COTRASH)

BWR Compactible
Trash (B-COTRASH)

LWR Nonconpactible
Trash (L-NCTRASH)

LWR Ton Exchange
Resins (L-IXRESIN)

PWR Filter
Cartridges (P-FCARTRG)

LUR Filter Sludge
(L-FSLUDGE)

LWR Concentrated
Liquids (L-CONCLIQ)

LWR Decontamination
Resins (L-DECONRS)

Alpha Emitters
Ci/tonne

0.001

0.001

0.007

0.120

0.032

0.016

0.008

0.038

Exhibit 2-3
Radioactivity By Emitter - Type for Low Level
Radioactive Wastes

Beta-gamma

Emitters

Beta-gamma
Emitters
Hal f-Lives.

<1 yr

Half-lives >1 yr and Tritium

Ci/tonne

0.250

0.140

0.740

11.300

3.450

7.840

0.620

25.970

Ci/tonne

0.015

0.890

4.700

0.018

1.540

0.130

0,000

Total TRU's
Present
Ci/tonne

0.000

0.000

0.008

0.009

0.001

0.001

0.001

0.034


calculated the time in years required for each LLRW stream to
decay to 1 percent and slightly less than 0.1 percent of initial
radioactivity levels. We selected these levels after review of
BNL's rationale for selecting a 200 year lifetime as one
alternative, which is based in part on the desire to achieve
decay sufficient to reduce activity levels to 1.0 to 0.1 percent
of initial levels.

We found that only 11 of the 40 LLRWs (8 percent by volume)
for which data are available decay to 1 percent of initial
activity within 200 years, and only 3 streams (2 percent by
volume) reach 0.1 percent of initial activity over the 200 year
period. Roughly half of the waste streams considered would
require more than 5000 years to reach either 1 percent or 0.1
percent of initial radioactivity levels. However, for a few
short-lived nuclides a 200 year container lifetime will allow
decay to levels well below 0.1 percent of the initial
radioactivity.

Available LLRW Containers

High integrity containers (HIC), which are approved for land
disposal of LLRW, are available in usable volumes (LLRW capacity)
ranging from 5 to 284 cubic feet and are constructed using one of
four materials: polyethylene, fiberglass/polyethylene composite,
stainless steel alloy, and steel fiber polymer impregnated
concrete. The minimum container cost per cubic foot of usable
volume is $25 to $26, or about $900 per cubic meter of volume.
All of these containers would require modifications and further
testing before being judged suitable for ocean disposal. The
feasibility and costs of developing a container which meets a 200
year lifetime as well as any other future requirements should be
explored further.

FACTORS CONSIDERED FOR COMPARATIVE ASSESSMENT

In order to complete a comparative analysis of the human
health and environmental risks associated with ocean versus land
disposal of low-level radioactive wastes, at least five major
factors could be considered.


percent of volume and about one percent of activity for the
40 LLRW streams considered. 5/ Second, we find that all wastes
appear to be well above the lower activity limits (ambient
levels), although our data on ambient levels are quite limited.

In addition to these activity limits, we considered two
other ocean disposal eligibility factors concerning co-
contamination and waste form. Although data describing hazardous
chemical contamination in LLRW are limited, it appears that the
eligibility of large amounts of commercial, DOE/Defense, NARM,
and remedial action LLRW for ocean disposal must still be
explored in terms of the presence of co-contamination.

Waste form requirements do not appear to limit the
eligibility of the 25 LLRW streams for which sufficient
information to judge was available. Given the lack of data for
the other 20 waste streams we are not able to identify which ones
are ineligible for ocean disposal based on waste form criteria.

In evaluating the eligibility of LLRW for ocean disposal, we
have not given any consideration to the economic desirability of
ocean disposal. In general, data on the cost of disposal of LLRW
is more comprehensive for the land program than for the ocean
program. Two studies that address the cost of ocean disposal are
the Niagra Falls Storage Site FEIS (3) and the Naval Submarine
Reactor Plants FEIS (5). Because each of these studies addresses
a specific type of waste it is very difficult to apply the cost
information to other types of LLRW. Thus, while the framework
exists, no specific evaluation of the economic desirability of
ocean disposal is possible at present.

LLRW Container Lifetimes

Ocean disposal criteria developed by BNL specify a 200 year
lifetime for LLRW containers used for ocean disposal. In order
to consider the adequacy of the proposed 200 year lifetime, we

Sf A third LLRW (waste stream #26) may exceed the upper
activity limits depending upon the assumption employed concerning
the waste's density. This single stream accounts for 2 percent
of volume and 7.5 percent of activity for all 40 streams
considered.


the disposal of radioactive wastes in the ocean,
both engineered and natural barriers contribute to
controlling the release of radioactivity such that
the amounts released would not constitute a
significant hazard to man. This implies that the
life expectancy of the container can be less than
the time required for the radioactive materials to
decay to environmentally acceptable limits, where
acceptable limits are those quantities of activity
which, when the other barriers to migration are
considered, will not pose a significant hazard to
man. A life expectancy of 200 years is presumed
adequate for the container, since the longest
lived radionuclides of importance, Cs-137 and Sr-
90, will have decayed to less than 1% of their
initial activity in this time. (Depending upon
the types of activity contained and their
quantity, some containers may not require a life-
time as long as 200 years.)

Based on the above and discussions with EPA personnel, any
consideration of a 200 year container lifetime is founded
primarily on a desire to allow sufficient time for LLRW to decay
to acceptable activity levels, and in addition represents an
attainable lifetime based on technology available at present.

In order to consider the adequacy of a 200 year container
lifetime, IEc calculated the years required for each LLRW stream
to decay to 1 percent and 0.1 percent of initial radioactivity
levels. 1/ These calculations are based on the half-life and
associated decay constant for each nuclide present in the waste
stream, and consider only the decay of the nuclides initially
present in the waste. The equation used for these calculations
is shown in Exhibit 3-1.

y Our calculations of time required for decay to 0.1 percent
actually use 0.0976 percent as the target decay level, which is
equal to the decay that would occur over 10 half-lives. This is
calculated as 0.5 to the 10th power, which equals 0.000976.


Exhibit 2-2

Description of Low-Level Radioactive Wastes

(Continued)
Total
Total Volume Activity Important Radionuclides Potential
Reference 1985-2004 1985-2004 Density (percentage of waste stream) Land BRC
Number Waste Stream (cubic meters) (curies) (9/cem3) Ci/tonne radioactivity) Candidate? *
INDUSTRIAL WASTES
14 Industrial Special 359,462 4 0.15 0.000 U-238(76.5); U-234(21.7) Y
Source Trash
(H-SSTRASH)
15 Industrial Special 63,435 4% 1 0.000 U-238(76.7); U-234(22.3) Y
Source Waste
(H-SSWASTE)
16 Industrial Low: 101,462 3,705 0.2 0.180 C-14¢4.5); Co-60(8.9); Sr-90(1.2)5 Y
Activity Trash Cs-137(3.9); H-3¢77.7)
(N-LOTRASH)
17 Industrial Low- 60,307 1,332 0.5 0.040 C-14(4.2); Co-60(6.7); Sr-90(5.9); Y
Activity Waste Cs-13764.7)
(N-LOWASTE)
18 Isotope Production 9,967 833,900 0.5 167.330 C-14¢.0001); Co-60(1.8); Sr-90(84.7); N
Waste (N-ISOPROD) Cs-137(5.7); H-3(73.8)
19 Tritium Waste 6,941 1,536,000 0.6 368.820 C-14¢.1); H-3¢99.9) N
(N-TRITIUM)
20 Accelerator Targets 223 173,900 0.4 1949.550 H-3¢100) N
(N-TARGETS)
a Sealed Sources 582 571,100 0.4 2453.180 C-14¢.0005); Co-60(2.3); Sr-90(3.84); N
(M-SOURCES) Cs-137¢45.46)

subtotal: 602,379 3,119,955


DOE/DEFENSE "GENERAL" LLW
TRITIUM IEc #34

Nuclide Half-Life (years) Ci/m3
H-3 12.28 3.70E+2

Source: IEc chart derived from DOE Tables A.2 and A.3.


One of these factors, activity limits, imposes quantitative
limitations on the amount of radioactivity per tonne that can be
disposed in the ocean. Another factor, ambient concentrations,
indicates which waste streams do not have radioactivity
concentrations great enough to qualify as low-level waste. The
third factor, co-contamination of low-level wastes, concerns the
existence of other hazardous constituents in LLRW. Finally, a
fourth criteria concerns a variety of requirements on waste form.

In order to consider the type and magnitude of LLRW which
might be eligible for ocean disposal, IEc compared each LLRW
stream shown in Exhibit 2-2 to the eligibility criteria in each
of these four categories. The sections below describe these
comparisons and the resulting implications about the eligibility
ef specific LLRW for ocean disposal.

Activity Limits

IAEA Safety Series No. 78 designates three upper activity
limits that wastes must meet to be considered for ocean disposal.
A low-level waste stream is ineligible for ocean disposal if its
radioactivity exceeds:

° 1.35 Ci/tonne for alpha emitters,

° 540 Ci/tonne for beta-gamma emitters with half-
lives > 1 year (excluding tritium), and

° 81,000 Ci/tonne for beta-gamma emitters with half-
lives < 1 year and tritiun.

In addition, if transuranic elements with half-lives greater than
20 years exceed 100 nCi/gram (or 0.1 Ci/tonne), the waste stream
would be considered ineligible for ocean disposal.

IEc used data describing the radionuclide content of each
LLRW stream and standard references to calculate the activity per
tonne in each of these categories for each LLRW stream shown in
Exhibit 2-2. The results are presented in Exhibit 2-3, which
presents activities in terms of Ci/tonne for alpha emitters,
beta-gamma emitters with half-lives greater than one year
(excluding tritium), and beta-gamma emitters with half-lives less
than or equal to one year (including tritium) of each of the
waste streams. The basic data describing concentrations of radio-
nuclides for each waste stream (including type of emitter and the
half-life for each radionuclide) are listed in Appendix A. The

2-12


Reference
Number

uu

12

13

Waste Stream

Nuclear Fuel Rod
Components (L-NFRCOMP)

FUEL CYCLE WASTES

Fuel- Fabrication
Compactible Trash
(F-COTRASH)

Fuel-Fabrication
Noncompactible Trash
(CF-NCTRASH)

Fuel -Fabrication
Process Waste
(F-PROCESS)

UF(6) Processing
Waste (U-PROCESS)

Exhibit 2-3

Radioactivity By Emitter - Type for Low Level

Alpha Emitters
Ci/tonne

0.000

0.001

0.000

Radioactive Was:
(Cont inued)

Beta-gamma
Emitters

tes

Beta-ganma
Emitters
Hal f-Lives

<tyr

Half-lives >1 yr and Tritium

Ci/tonne

0.000

0.000

0.001

0.001

Ci/tonne

0.000

0.000

0.000

0.000

Total TRU'S
Present
Ci/tonne

No TRU

Wo TRU

Wo TRU

Wo TRU


Jersey sites are separated from the other FUSRAP sites on Exhibit
2-2 because ocean disposal is currently being considered as a
disposal alternative for the wastes from these sites. FUSRAP
estimates that the total volume and activity for the New Jersey
sites is 382,300 cubic meters and 150 curies.

In addition to FUSRAP, SFMP also generates low-level
radioactive wastes. This program includes 320 radioactively
contaminated DOE-owned facilities that have been declared surplus
to government needs. Ocean disposal was presented as an option
for the Niagara Falls Storage Site in the April 1986 Final

Environmental Impact Statement entitled Long-Term Management of
the Existing Radioactive Wastes and Residues at the Niagara Falls
Storage Site (3). Detailed information on total activities and
radionuclide compositions of the other SFMP wastes has not yet

been compiled. The program estimates that within the next 20
years at least 2,280,740 cubic meters will be generated.

U.S. Navy Decommissioned Reactor Plants

The final category listed on Exhibit 2-2 is the U.S. Navy
decommissioned reactor plants. In the May 1984 final
environmental impact statement, ocean disposal is presented as an
option for the 100 submarines that will be taken out of service
in the next 20 to 30 years (5). Decommissioning 100 submarines
yields 362,870 tonnes of waste (note that no volume estimate in
cubic meters is available) and 6,200,000 curies. According to
U.S. Navy sources, although ocean disposal of the submarine
reactor plants had been explored, it is no longer under
consideration.

ELIGIBILITY FOR OCEAN DISPOSAL

In order for a waste stream to qualify as a candidate for
ocean disposal, it is likely that it would have to conform with
criteria found in LDC, existing ocean disposal regulations, IAEA
and BNL documentation. These criteria include the upper activity
limits, lower activity limits (ambient levels) and prohibition
of co-contaminated wastes discussed in the first section of this
chapter. In addition, to be a candidate for ocean disposal, the
LLRW would likely have to meet the criteria on waste form
developed by BNL.


Exhibit 3-1

Equation to Calculate Time Required for Decay

= k(n) *t
p * y(o) -2 y(n) * e

n
where: Pp = proportion of radioactivity remaining

at time t
n = number of nuclides present in waste
yo) = 22 y(n)

n
y(n) = initial radioactivity for nuclide n (Ci)
k(n) = decay constant for nuclide n
= - (1/half-life(n)) * 1n 2

t = time (years)

Source: See text.


LLRW Volume and Radioactivity

Exhibit 1-1 summarizes the universe of LLRW streams that we
considered. As shown, our research identified an overall
universe of 45 specific waste streams accounting for about 20
million cubic meters and 47 million curies of radioactivity
generated during the 20 year period from 1985 to 2004. 1/
Naturally occurring/accelerator produced wastes comprise slightly
more than half of the total volume considered but only .01% of
the activity. DOE/Defense LLRW comprise slightly more than half
of the total radioactivity.

The LLRW streams shown on Exhibit 1-1 have been grouped into
six summary categories.

° Commercial LLRW streams are those generated by
commercial sources, including nuclear power
reactors, nuclear fuel cycle operations,
industrial sources and _ institutions (e.g.

hospitals, universities).

° DOE/Defense LLRW streams are generated by routine
government operations, and are not as well
characterized as commercial wastes.

° Naturally-occurring and accelerator produced
radioactive materials (NARM) include a variety
of materials currently regulated only ina few
states.

° Decommissioning LLRW streams include wastes
projected to be generated by future
decommissioning activities of power reactors and
related facilities.

1/ Note that volume estimates are available for only 44 wastes,
and activity estimates are available for only 41 wastes. Thus,
estimates for total volume and activity shown in Exhibit 1-1
slightly underestimate the actual figures.


DEFINITION OF LLRW

The precise characteristics which define LLRW are difficult
to establish. In general, low-level radioactive waste is defined
as material that is not high-level radioactive waste.
Definitions of high-level waste are often expressed as lists of
specific waste streams considered to be high-level wastes, and
are not expressed in terms of physical characteristics (e.g.
presence of specific nuclides, radioactivity levels). Because
slightly different high-level waste lists are published in
different sources, the exact boundary between high- and low-level
wastes is difficult to establish.

Exhibit 2-1 compares the definitions of low-level waste for
the ocean and land programs. The primary source for the land
definition of LLRW is Vol. 2 of the Draft EIA (8). The primary
sources for the ocean definition of LLRW are the International
Atomic Energy Agency (IAEA) Safety Series #78, developed for the
London Dumping Convention, and existing ocean disposal regula-
tions.1/

Exhibit 2-1 is organized into three sections: lower
activity limit, upper activity limit, and other specifications.
The following paragraphs highlight differences in each of these
categories. .

Lower Activity Limit

As shown on Exhibit 2-1, the IAEA Safety Series #78 defines
ambient concentrations of (1) naturally occurring radioactivity
and (2) anthropogenic radionuclides attributable to global
fallout from nuclear testing as the lower activity limit for
LLRW.

The land program does not include a similar lower activity
limit for most categories of | LLRW. However, for naturally
occurring and accelerator produced radioactive materials (NARM)
wastes, EPA, as mentioned in EPA's Low-Level and NARM Standards:

Vy The ocean LLRW definition is consistent with legislative
history at HR 97-562 part 1, page 16 and 18; and 128
Congressional Record H107-16.


DOE/DEFENSE "GENERAL" LLW
ALPHA, <10 nCi/g IEc #35

Nuclide Half-Life (years) Ci/m3

Pu-238 87.75 1.02E-2
Pu-239 24130 3.88E-4
Pu-240 6569 2.72E-3
Pu-241 14.4 3.74E-1
Am-241 432.2 1.54E-5
Cm-242 0.447 2.18E-4
cm-244 18.11 7.75E-5

Source: IEc chart derived from DOE Tables A.2 and A.3.


Exhibit 2-7

Wastes Eligible for Ocean Disposal
Based on Waste Form Criteria
(Continued)

- Eligible - Not Eligible
TEc Waste Requires Does not Not Enough
Number Stream as is Pretreatment Meet Criteria Information
32 Radium Sources x
3 Radium lon-Exchange x
Resins
4 Instrument -Dif fuse x
Widely Distributed
35 Instruments-Di ffuse x
Collectible
36 Activated Metals x
7 PWR decon/decom- x
mission
38 BWR decon/decom- x
mission
39 DOE "Special x
Projects"
40 FUSRAP/N.J. x
41 FUSRAP/Other x
42, 43 ‘SFMP x
46 CERCLA x
45 Navy Submarine x
Reactors

Source: Brookhaven National Laboratory.


DOE/DEFENSE "GENERAL" LLW
FISSION PRODUCT IEc #32

Nuclide Half-Life (years) Ci/m3

Co-60 5.27 8.21E-3
Sr-90 28.6 7.97E-1
Y¥-90 0.0073 7.97E-1
Zr-95 0.175 1.30E-1
Nb-95 0.096 2.90E-1
Tc-99 213000 2.05E-3
Sb-125 2.77 3.01E-1
Te-125m 0.159 7.49E-2
Ru-106 1.009 6.55E-1
Rh-106 ~O 6.55E-1
Cs-134 2.062 3.90E-2
Cs-137 30.17 1.81E+0
Ba-137m 0.000004 1.65E+0
Ce-144 0.779 1.50E+0
Pr-144 0.00003 1.50E+0
Pm-147 2.623 6.15E-3
Sm-151 90 1.13E-2
Eu-152 13.6 9.23E-3
Eu-154 8.8 9.23E-3
Eu-155 4.96 6.15E-3

Source: IEc chart derived from DOE Tables A.2 and A.3.


U.S. NAVY DECOMMISSIONED REACTOR PLANTS
(for 100 Submarines) IEc #44

Nuclide Half-Life (years) ci

Co-60 5.27 2,200,000
Ni-63 100 1,800,000
Fe-55 2.69 1,700,000
Co-58 0.19 320,000
Cr-51 0.076 100,000
Mn-54 0.85 65,000
Ni-59 75,000 12,000
Fe-59 0.12 5,100
Zr-95/Nb-95 0.18 104
c-14 5,730 100
8-35 0.24 45
Sc-46 0.23 39
Hf-181 0.12 12
Nb-94 20,300 8.2
Mo-93 3,500 1.3
Tc-99 214,000 ~36

Source: IEc chart derived from FEIS Table 1-1. Information
about volumes was not provided in the FEIS.

12


° stainless steel alloy, and
° steel fiber, polymer impregnated concrete (SFPIC).

Polyethylene and stainless steel alloy are the predominate
materials used, with only a few, relatively small containers
currently available that are constructed from composites or
SFPIC.

To our knowledge, high integrity containers currently are
available in the United States from four sources:

Bondico, Inc. (composite),

Chem Nuclear, Inc. (polyethylene),

Pacific Nuclear, Inc. (stainless steel and SFPIC), and
Westinghouse Hittman Nuclear, Incorporated
(polyethylene).

oooo

We received product literature and list price information from
each of these manufacturers. However, several firms asked that
we not disclose list prices of specific HICs, and we have honored
these requests in this document.

Exhibit 3-6 presents a plot of the price per cubic foot of
usable volume versus usable volume for all HICs considered by
IEc. The exhibit illustrates several aspects of high integrity
containers. First, available HICs range in usable volume from
under 10 to about 280 cubic feet, with greater choice of
containers available in the smaller and mid-range sizes. Second,
stainless steel alloy containers are five to six times more
expensive than polyethylene HICs. Third, composite and SFPIC
containers are available in small sizes only. SFPIC HICs are
more than twice as expensive as similar size polyethylene
containers, while composite HICs appear to be priced similarly to
polyethylene. Finally, the minimum container cost per cubic foot
of usable volume is $25 to $26, or about $900 per cubic meter.

All of these containers have been developed to serve the
demand for handling and land disposal of commercially-generated
LLRW. Thus, their suitability for land or ocean disposal of the
larger waste quantities and lower specific activities of NARM and
remedial action LLRW is not known. In particular, economics may


Brookhaven identified ten waste streams, eight of which are
commercial, as low-level wastes that can be solidified in the
form that the wastes are generated. Fifteen waste streams were
identified as "requires pretreatment". Waste streams in these
categories represent about 20 percent of the total volume and 22
percent of the total activity for all wastes included in Exhibit
2-2.

There are twenty waste streams that Brookhaven was not able
to judge due to lack of information. These wastes account for
the remaining 80 percent of the total volume and 78 percent of
total activity for all wastes included in Exhibit 2-2. Lack of
information means that either the information needed to make a
judgement was not readily available to Brookhaven or that the
necessary information does not exist.

SUMMARY

This chapter has discussed the definitions of LLRW used by
EPA's ocean disposal and land disposal programs, and has
presented our estimates of the quantity and radioactivity of LLRW
likely to be considered for ocean disposal. In addition, the
third section of the chapter used several criteria to review the
eligibility of LLRW streams for ocean disposal. The overall
conclusions of the chapter are summarized in the first chapter of
this report.

2-19


Radionuclide Composition of Waste Streams (Ci/m 3)

(Continued)
IEc No. #25 926 #23 # ne #21 #19 #20
MUCLIDE = I-LQSQWVL =sI-ABSLIQO)=—s1-BIOWAST w-tobaste M-ISOPROD «(N-SOURCES N-IRITIUM N-TARGETS

4-3 5.O1E-3 1.426-1 1, 75€-1 1.63€-2 5.52E-2 2.8BE+1 2.21E+2 7.80E+2
cu 2.514 8. 16E-3 1.01E-2 9.3654 7, 196-5 4.516-3 2. 76E-1

2

Fe-5S 9646-1
wi-s9

0-60 3.122 3.9983 ATE-3 1. MBE 2.241
wi-63 . 1486-2 -1,566-2
Sr-90 4.346-34.34E-38.3%-31.31E-3— 7.0901 3.77841
-94

Tc-99 1028-8 —-6.51E-9 7. 766-105. 108-6

Ru-106 1466-1

Sb-125

1-129 4.2488

€s-134 4.706-1

Cs-135 5. 0-6

€s-137 V.37E-2 © -B.76E-31OME-3 A TBE 4. 45EV2
Ba-137m 1376-2 8.76E-3.-OME-3 TBE 4, ASE
Eu-154

v-236 1.20€-3

0-235 3. 1SE-S

Wp-237 6.206-15

u238 | 3.47E-7

Pu-238 2.206-6 —8.89€-1 -
Pu-239 6.45€-7

Pu-2at 8.25€-S

pe2u 4506-2 1.4760
Pu-242 1. e-9

243 1466-8

On-243 3.35€-9

On-244 1,936-6

TOTAL 9.60€-3 2.138-1 2.15€-1 2.21E-2 8.37E+) 9.8162 2.20642 7.80662
Source: Adapted by IEc from BLD Table 3-5


Source

Lower Activity
Limit

Upper Activity
Limit

Exhibit 2-1

Comparison of Low Level Radioactive Waste Definitions
A Working Definition for Ocean Versus Land Disposal Definitions

Ocean

Land

IAEA, EPA working definition of low-level waste end exist-
ing ocean disposal regulations. (40 CRF 220 et seq.).

LURW does not include "wastes containing only ambient con-
centrations of naturally occurring radioactivity and
anthropogenic radionuclides attributable to global fallout
from nuclear weapons testing."

LLRW cannot be high level radioactive waste defined as:
aqueous wate resulting from the operation of the first
cycle solvent extraction system, or equivalent, and the
concentrated waste from subsequent extraction cycles, or
equivalent, in a facility for processing irradiated reactor
fuels, or irradiated fuel from nuclear power reactors, and
specifically includes the following:

1) Irradiated reactor fuel; liquid wastes from the chemical
reprocessing of irradiated reactor fuel from the first
solvent extraction cycle, or equivalent processes, and the
concentrated wastes from subsequent extraction cycles, or
equivalent process, and solidified forms of such wastes; and

2) any other waste or matter of activity concentration
exceeding:

Gi) alpha emitters: 1.35 Ci/tonne *
(ii) beta-gamma emitters with half-lives > 1 year; *
540 Ci/tonne (excluding tritium)
(iii) tritium and beta-ganma emitters with half-lives = or
<1 year: 81,000 Ci/tonne *

* Converted from IAEA Safety Series No. 78

Draft Generally Applicable Environmental Standards for Management
and Disposal of LLW (40 CFR 193) under AEA Reorganization Plan
3 and Toxic Substances Control Act (40 CFR 764) for NARM.

None for most LLRW. Disposal of naturally-occurring or accelerator
produced material (NARM) with activity <.002 Ci/tonne would not be
regulated by EPA.

LLRW cannot be high level radioactive waste defined as:

1) highly radioactive material resulting from the reprocessing of
Spent nuclear fuel, including liquid waste produced directly in
reprocessing and any solid material derived from such liquid waste
that contains fission products in sufficient concentrations.

2) other highly radioactive material that the Nuclear Regulatory
Commission, consistent with existing law, determines by rule
requires permanent isolation.


Exhibit 2-5

AMBIENT RADIOACTIVITY CONCENTRATIONS
IN THE DEEP OCEAN

(Ci/Tonne)
North North All
Atlantic Pacific Oceans
Radionuclide Water Water Sediments
Anthropogenic
Pu-239 5 E-13 1.5 E-12
Cs-137 1.5 E-11 5 E-12
Sr-90 1 E-11 3 E-12
Am-241 1.5 E-13 5 E-13

Naturally Occurring

U-238 3.4 E-7
Th-230 3.9 E-6
Ra-226 4.0 E-6

Source: See text, page 2-13.


are divided into categories on Exhibit 2-2 according to source;
however, no such organization can be provided for the DOE/defense
waste streams.

Naturally Occurring and Accelerator
Produced Radioactive Material (NARM)

Naturally occurring and accelerator produced radioactive
material (NARM) is the third category listed in Exhibit 2-2. This
waste category includes such materials as radium dials, false
teeth, and radioactive metals. The NARM wastes that we consider
are treated as regulated low-level waste by some states when
disposed on land.

Exhibit 2-2 shows that an estimated 12,011,780 cubic meters
and 6,609 curies of NARM waste are expected to be generated
during 1985 to 2004. Compared to the total volume and activity
of commercial wastes, NARM waste is about four times greater in
volume and has about 0.05 percent of the radioactivity.
Activated metals (reference number 36) accounts for 99.9 percent
of the total volume and 61.9 percent of the total activity.

The activated metals waste stream consists of alloys and
welding rods containing thorium or thoria (Th0O2), aircraft
ballast, and radiation shielding constructed of depleted uraniun.
These items are discarded primarily by the industrial sector and
may or may not be treated as low-level waste when disposed,
depending upon state regulations and the practices of the
generator. The radiation shielding that is sometimes present in
this waste stream may be considered hazardous under RCRA because
of the presence of heavy metals such as lead and mercury. In
addition, Annex I of the London Dumping Convention prohibits
ocean disposal of specific compounds or materials (such as
mercury) that may be present in this waste stream.

Unlike commercial LLRW, NARM waste is currently not
regulated by federal authorities. All of the NARM wastes
considered by IEc are regulated to differing degrees by some
state agencies. Currently EPA, using authority under the Toxic


Exhibit 2-7

Wastes Eligible for Ocean Disposal
Based on Waste Form Criteria
(Continued)

tees Not Eligible
Requires Does not Not Enough
Pretreatment Meet Criteria Information

TEe Waste
Number Stream

15 Industrial special x
Source Waste

16 Industrial Low x
Activity Waste

7 Industrial Low x
Activity Waste

18 Isotope Production x

Waste
19 Tritium Waste x
20 Accelerator x

Targets
21 Sealed Sources x
22 Institutional Com- x

pactible Trash

3 Biological Waste x
2 Absorbed Waste x
re) Liquid Scintillation x
Vials
26 Uranium/Thor ium x
27 Fission Products x
28 Induced Activity x
2 Tritium x

30 "Other" x


require development of less expensive methods of handling and
containerizing larger quantities of relatively low specific
activity wastes before such wastes become economically-viable
candidates for ocean disposal.

SUMMARY

This chapter has reviewed the issue of container lifetimes
for ocean disposal of LLRW by analyzing the time period required
to accomplish alternate degrees of radioactive decay. In
addition, the chapter reviews available information about high
integrity containers which might, with modifications, be
potential containers for ocean disposal. The overall conclusions
of the chapter are summarized in the first chapter of this
report.


ACKNOWLEDGMENTS

Many individuals at EPA participated in the development of
this study and in discussions of issues. The assistance of
Robert Dyer, Elliot Foutes, Jim Gruhlke, Byron Bunger and other
staff in the Analysis and Support Division of the Office of
Radiation Programs; Darrell Brown and John Lishman in the Office
of Marine and Estuarine Protection, Office of Water; Alan Sielen,
Office of International Activities; and John Davidson in the
Office of Policy Analysis, Office of Policy, Planning and
Evaluation, is especially appreciated.


Exhibit 2-2

Description of Low-Level Radioactive Wastes

(Cont inued)
Total
Total Volume Activity Important Radionuclides Potential
Reference 1985-2006 1985-2004 Density (percentage of waste stream) Land BRC
Number Waste Stream (cubic meters) (curies) (g/em3) Ci/tonne radioactivity) Candidate? *
DECOMMISSIONING OF REACTOR AND FUEL CYCLE FACILITIES
37 Pressurized Water (PWR) 13,416 96,181 1 7.0 Co-60(28.4); Sr-90¢.001); w/a
Cs-137€1.12); TC1/2)<5 yr(67.9)
3B Boiling Water (BWR) 566 8,729 1 15.4 C- 14.003); Co-60(16.79; N/A
Sr-90¢.01); TC1/2)<5 yr(79.5)
39 DOE "SPECIAL PROJECTS" 23,690 weeeeeeesHo Datarceseceeeeesecececeeeeees weseseeeee WA
(e.g. THI, West Valley)
Total Decommissioning: 37,672 903,910
REMEDIAL ACTION PROGRAMS
FUSRAP
40 Wd 382,300 150 1 0.000 Ra-226(20); Th-232(60); N/A
U-238(20)
a other 939,895 ser eeec een eee se eeeeeeeeeeeeeeeees No Data--+--+-22eeeeeeee eee seeteese neers N/A
SFMP
42 Niagra Falls Storage Site 123,740 feed erer erent ec en rere eter rere ence No Data---------- sete ee eee ee ee eee eee seeee N/A
43 other 2,157,000 cet eeeececeeeceeeceeeeeeeeee N/A
bb CERCLA ween eet ete eneeeeteceeeteeceneee
Total Remedial Action: 3,626,625
U.S. NAVY
45 Decommissioned Reactor 362,870 6,200,000 1 17.085 Co-60(35.5); Ni-63(29.0); N/A
Plants (for 100 submarines) tonnes Fe-55(27.4)

Source: See text.
* WRC and DOE will determine which LLRW may be classified as BRC waste.


Exhibit 2-2

Description of Low-Level Radioactive Wastes

(Continued)
Total
Total Volume Activity Important Radionuclides Potential
Reference 1985-2004 1985-2004 Density (percentage of waste stream) Land BRC
Number Waste Stream (cubic meters) (curies) (9/cm3) Ci/tonne radioactivity) Candidate? *

INSTITUTIONAL WASTES

22 Institutional Com- 281,747 33,140 2 0.590 C-14€4.5); Co-60(8.8); Sr-90¢1.2); Y
pactible Trash €s-137(3.9); H-3(77.4)
(1-COTRASH)

3 Biological Waste 7,520 1,616 11 0.200 C-14(4.7); Co-60(1.9); Sr-90(3.9); Y
(1-BIOWAST) Cs-137¢6.1); H-3(81.4)

26 Absorbed Liquids 11,126 2,365 1 0.210 C-14(3.8); Co-60(16.6); Sr-90(2.0); Y
(T-ABSLIQD) Cs-137(6.4); H-3(66.7)

23 Liquid Scintilla- 15,040 146 o 0.010 C-14(2.6); Sr-90(45.2); H-3(52.2) y

tion Vials (1-LQSCNVL)

Subtotal: 315,433 37,265
Total Commercial : 2,925,702 12,766,504

DOE/DEFENSE “GENERAL” LLW

2% Uraniuny thorium 415,796 3,569,945 1 8.590 U-238¢33.1); Pa-234m¢33. 1); N/A
Th-236¢33.1)

27 Fission product 774,809 7,947,008 1 10.257 Co-60( .08); Sr-90(7.7); Cs-137017.6); N/A
Ba-137m( 16.1)

Induced activity 329,706 6,487,987 1 19.678 Co-60¢.9); Co-5B(55.4); Hn-54(38.1) WA

Tritium 32,971 12,199,899 1 370.026 4-3¢100) N/A

30 Alpha, <10 nCi/g 239,953 93,129 1 0.390 Pu-261¢96.5) N/A

Fi) "Other" 38,466 745,032 1 19.369 C-14(.06); Co-60(18.0); Sr-90(8.5); N/A

Cs-137(19.1); Ba-137m( 16.8)
Total DOE/Defense: 1,831, 701 27,473,055


Exhibit 3-3

Time Required for LLRW Decay

(Years)
Waste ++ Fraction of Radioactivity Remaining ---
Reference ~ 0.1 Percent
Number Waste Stream 1 Percent (10 half-lives)
1 PUR Compactible 270 BL
Trash
2 BUR Compactible 270 Bh
Trash
3 LR Noncompactible 330 960
Trash
4 LWR Ion Exchange 165 1,960
Resins
5 PUR Filter 400 937
Cartridges
6 LWR Filter Studge 138 392
7 LWR Concentrated 243 1,075
Liquids
8 LWR Decontamination 235 693
Resins
9 Nuclear Fuel Rod 260 735
Components
10 Fuel-Fabrication 16,000,000, 000 32,000,000,000
Compactible Trash
Ww Fuel-Fabrication 15,000,000, 000 32,000,000,000
Noncompactible Trash
12 Fuel-Fabrication 16, 900,000,000 32,000,000, 000
Process Waste
13 UF(6) Processing 25,000, 000,000 40,300,000, 000
Waste
ars Industrial Special 28,000,000,000 28, 250,000,000
Source Trash
15 Industrial Special 28, 000,000,000 43,200,000,000
Source Waste
16 Industrial Low- 12,000 31,350

Activity Trash


In order to make the number of scenarios tractable, it is
important to do the most important combinations first. New
scenarios can then be added as results dictate. In general, it
is best to begin with several realistic scenarios rather than
simplified sets of conditions selected only for analytic
tractability.

Risk estimates developed to support EPA's proposed LLRW land
disposal regulations would provide a basis for specification of
scenarios for the land disposal option. However, no similar
estimates for ocean disposal systems other than for municipal
sewage sludge and liquid hazardous waste incineration exist.

Risk Metrics
The appropriate metrics of "risk" to estimate for a
comparative analysis of ocean versus land disposal of LLRW are
complicated because
° human and environmental effects are included,
° non-threshold and threshold effects may be
included if both radioactive and mixed wastes are
considered, .

° both the level and distribution of risks are
important, and

° descriptions of risks across a range of
probabilities and levels of consequences must be
developed.

To accommodate these requirements, a variety of risk
measures could be used based on the effects of greatest
importance and the available data about those effects.
Information about the human health and environmental effects of
both radiation and mixed wastes is sufficient to allow selection
of the metrics of interest. However, in selecting risk metrics
double-counting of risks must be avoided (e.g. including health
effects from ingestion of tainted fish and economic loss assuming
some fish are no longer captured and sold).

1-10


Exhibit 2-7

Wastes Eligible for Ocean Disposal
Based on Waste Form Criteria

strteees Eligible -------- Not Eligible
lee Waste Solidi fy Requires Does not Not Enough
Number Stream as is Pretreatment Meet Criteria Information
1 PUR Compact ible x
Trash
2 BWR Compactible x
Trash
3 LUR Won-Compactible x
Trash
4 LWR ton Exchange x
Resin
5 PUR Filter x
Cartridges
6 LWR Filter Sludge x
7 LWR Concentrated x
Liquids
8 LWR Decontamination x
Resins
9 Nuclear Fuel Rod = |X
Components.
10 Fuel-Fabrication x
Compactible Trash
W Fuel Fabrication x
Non-Compact ible
Trash
12 Fuel Fabrication x
Process Waste
13 UF6 Processing Waste x
Fuel- Fabrication
Waste
6 Industrial Special x

Source Trash


shown, only 11 of the 40 LLRW streams considered would decay to 1
percent of initial activity within 200 years, and only 3 streams
would reach 0.1 percent of initial activity over a 200 year
period. These wastes account for 1,399,079 cubic meters and
362,900 cubic meters, respectively, over the period from 1985 to
2004. Roughly half of the waste streams considered would require
more than 5000 years to reach either 1 percent or 0.1 percent of
initial radioactivity levels.

Comparison of the decay times in Exhibit 3-3 with specific
radioactivity (i.e., activity per cubic meter of waste)
information in Exhibit 2-2 of Chapter 2 shows that, in general,
LLRW streams with long decay times have relatively low specific
activity. This relationship is illustrated on Exhibit 3-5, which
plots the logarithm of years to achieve 1 percent of initial
radioactivity against initial radioactivity per cubic meter.2/
As shown, with the exception of 2 outliers (wastes 32 and 26)
there is a strong tendency for long-lived wastes to be much less
radioactive per unit of volume.

Waste streams 32 and 26 appear as outliers on Exhibit 3-5.
Waste 32 (radium sources) has a very high specific activity and a
relatively average time required for decay to 1 percent. Note
that this LLRW is generated in extremely small quantities; less
than one cubic meter is expected to be generated from 1985 to
2004. Waste 26 (DOE uranium/thorium) has roughly average initial
radioactivity and a very long time required for decay due to the
presence of a large proportion of uranium-238.

These results about required decay times suggest three
conclusions. First, a container lifetime of 200 years will allow
decay to 1 percent or 0.1 percent levels for relatively few
wastes. We found that only 11 of the 40 LLRWs for which data are
available decay to 1 percent of initial activity within 200
years, and only 3 streams reach 0.1 percent of initial activity
over the 200 year period. Much longer (and probably technically
infeasible) container lifetimes would be required to meet these

2 We did not complete a plot using time to achieve 0.1 percent
of initial activity, since the relationship would be similar to
that shown in Exhibit 3-5.


in the deep ocean water column, uptake by various trophic levels,
bioaccumulation and bioconcentration, and eventual effects on
marine and human life. In addition, these same as well as other
effects resulting from accidental releases (e.g. disposal ship
accidents) would have to be estimated.

Comparative risk assessment would require that some research
be completed on the economic aspects of ocean versus land
disposal. Probabilities and magnitudes of releases, and the
nature of resulting mitigation activities, are all directly
dependent on the level of expenditures for system components,
waste recovery teams, and so forth. In addition, the types of
LLRW most likely to utilize land versus ocean disposal systems
will be determined in large part by economic desirability. Thus,
any comparative risk assessment must be based on analyses which
establish the basic costs and relative economic advantages and
disadvantages of the land and ocean systems under study.

PLAN OF THIS REPORT

The remaining chapters of this report present IEc's findings
in more detail, as follows:

° Chapter 2 presents our estimates of the quantity
and radioactivity of LLRW and discusses which
wastes might be eligible for ocean disposal.

° Chapter 3 presents our review of LLRW container
lifetimes.

° Appendix A presents data on the radionuclide
content of the LLRW streams discussed in Chapter
2.

Exhibits are included at the end of each chapter, following the
text.

1-12


DISCLAIMER

This report was prepared as an account of work sponsored by
the U.S. Environmental Protection Agency. Neither the United
States Government nor any agency thereof, nor any of their
employees, nor any of their contractors, subcontractors, or their
employees, makes any warranty, express or implied, or assumes any
legal liability or responsibility for the accuracy, completeness,
or usefulness of any information, apparatus, product, or process
disclosed, or represents that its use would not infringe
privately owned rights. Reference herein to any specific
commercial product, process or service by trade name, trademark,
manufacturer, or otherwise, does not necessarily constitute or
imply its endorsement, recommendation, or favoring by the United
States Government or any agency, contractor or subcontract
thereof. The views and opinions of authors expressed herein do
not necessarily state or reflect those of the United States
Government or any agency, contractor or subcontractor thereof.


(4) Aqueous wastes should be solidified to form a
homogenous, monolithic, free standing solid
containing no more than 0.5 percent (by volume),
or 1.0 gallon (3.8 liters) of free or unbound
water per container, whichever is less;

(5) Buoyant waste material shall be excluded or
treated to preclude its movement or separation
from the waste form during and after disposal;

(6) The waste form shall have an uniaxial compressive
strength not less than 150 kg/cm2, provided that
it does not contain large voids or compressible
materials;

(7) The leach rate of the waste form shall be as low
as reasonably achievable.

(8) Particulate wastes such as ashes, powders, and
other dispersible materials should be immobilized
by a suitable solidification agent;

(9) No radioactive gaseous wastes shall be accepted
for ocean disposal unless they have been
immobilized into stable waste forms such that
over-burden pressure in the waste package does not
exceed atmospheric pressure; and

(10) Explosive and pyrophoric materials shall be
excluded from LLW ocean disposal sites.

In order to determine which waste streams on Exhibit 2-2 are
not likely candidates for ocean disposal due to the BNL waste
form criteria, EPA requested assistance from Brookhaven National
Laboratory. Brookhaven was asked to identify those waste
streams for which compliance with the waste form criteria is
judged technically infeasible or too expensive. Given the
limited information available, Brookhaven classified LLRW streams
into two "eligible for ocean disposal" categories (entitled
“solidify as is", and "requires pretreatment") and an "ineligible
for ocean disposal" category (entitled "does not meet criteria").
In addition, Brookhaven identified those wastes with "not enough
information". These classifications for each LLRW stream are
presented in Exhibit 2-7.

2-18


Radionuclide Composition of Waste Streams (Ci/m>)

(Continued)

IEe No. 1,72 px FIO FIT W2Z TI 7 Fis Tis
MUCLIDE —L-COTRASH = L-NCTRASH = F-COTRASHF-NCTRASH —I-COTRASH = N-LOTRASH = N-SSTRASH —N-SSWASTE
H3 3.56E-4 3. VE-3 9. 13E-2 2.85E-2

c-14 1.39€-5 1. 196-4 5.268-3 -6ME-3

Fe-55, 9. 196-3 6.87E-2

Wi-S9 1,05€-5, 8.09€-5

Co-60 1. 71E-2 V.31€-1 1.04E-2 3.25€-3

wi-63 2.41E-3 2.246-2

Sr-90 2.96E-5 2.034 1.45E-3 4536-4

W904 3.338-17 2.S6E-6

Te-99 -2.268-1 1.326-6 3.396-9 106-9

Ru-106 —6.O1E-6 3.54E-5,

‘Sb-125 0 1,36E-4 1,05€-3

1-129 6,326-7 3.6266

Cs-134 = 6.01E-3 3.S4E-2

Cs-135 0.2. 26-7 1,336-6

Cs-137 = 6.01E-3 3.54E-2 4.S6E-3 1,42E-3

Ba-137m = 6.01E-3 3.S4E-2 4.S6E-3 1426-3

€u-154 0 1.37E-S 1.05€-4

U-2342..43€-7 2. 196-6 2.606-S 2.56E-S 2.56E-6 4.9TE-5
U-235 = -3.89€-9 3.S2€-8 1, 18E-6 113-6 V.42E-1 2.17E-6
Wp-237 1. 14E-12,1.STE-11

U-238T.1NE-@ = 6.43E-7 4. OE 4208-6 8.80E-6 V.1NE-4
Pu-238 7. 46E-6 6.39€-5

Pu-239 6. 49E-6 5.75E-5

Pu-241 2.85E-4 2. S2E-3

A241 4698-6 AMES 4826-6 1.S1€-6

Pu-24201.41E-8 = 1.26E-7

Wm-2430-3:,338-8 2.806-6

Qn-243 0 (3.84E-9 3.04E-8

Qn-244 3. S0E-6 2.84E-5

TOTAL 4. 16E-2 3.35€-1 3.24E-5 3.096-5 1.1e-1"  3.678-2 1, 1SE-5S 2.23€-4

Source: Adapted by IEc from BID Table 3-5.


Commercial,

DOE/Defense "General",

Naturally Occurring and Accelerator Produced
Radioactive Material (NARM),

° Decommissioned Reactor and Fuel Cycle Facility

Wastes,
° Remedial Action Programs, and
° U.S. Navy Decommissioned Reactor Plants.

ooo

As the following sections suggest, the certainty associated
with our volume and other estimates varies among the waste
categories. Some waste streams are currently routinely generated
while others are not expected to be routinely generated during
the time period 1985-2004. In general, information about low-
level wastes that are routinely generated is more certain than
information about waste streams that are not currently generated
on a consistent basis. An exception to this is data about the
U.S. Navy decommissioned reactor plants. This waste is not
routinely generated; however, detailed information is documented
in a May 1984 final environmental impact statement (5). Thus, on
Exhibit 2-2, estimates for commercial wastes, DOE/defense
"general" wastes, and NARM wastes are relatively more certain
because these wastes are currently generated.

Commercial Wastes

Waste streams 1 through 25 on Exhibit 2-2 describe wastes
that are generated by commercial sources. As previously
mentioned, the primary source of information for these waste
streams is NRC Update of Part 61 ypacts Analysis Methodology
(12). In the NRC document, 148 radioactive waste streams are
identified and described. Seventy of these waste streams are

generated by commercial sources and were aggregated by EPA into
the 25 waste streams that are listed in Exhibit 2-2. 5/ EPA

5/ In addition, 67 waste streams are labelled as "non-routine"
by NRC. The sources of these wastes include Three Mile Island,
West Valley, fuel fabrication, fuel reprocessing, and
decommissioning and decontamination wastes. NRC also lists seven
NARM wastes and two military wastes that are occasionally
disposed of at commercial facilities. These waste streams are
described later in this section.

2-6


REVIEW OF WASTE ELIGIBILITY AND
CONTAINER LIFETIMES FOR OCEAN
DISPOSAL OF LOW LEVEL
RADIOACTIVE WASTE

Prepared for:

Moira McNamara Schoen
EPA Project Officer
Environmental Resource Economics Division
Office of Policy Analysis
U.S. Environmental Protection Agency

Prepared by:

Michael T. Huguenin and Melissa A. Walters
Industrial Economics, Incorporated
2067 Massachusetts Avenue
Cambridge, Massachusetts 02140

June 1988


Reference
Number

Waste Stream

7

18

19

20

21

Industrial Special
Source Trash
(N-SSTRASH)

Industrial Speciat
Source Waste
(N-SSWASTE)

Industrial Low-
Activity Trash
(N- LOTRASH)

Industrial Low-
Activity Waste
(N-LOWASTE)

Isotope Production
Waste (N-ISOPROD)

Tritium Waste
(N-TRETIUM)

Accelerator Targets
(N- TARGETS)

Sealed Sources
(N= SOURCES)

Exhibit 2-3

Radioactivity By Emitter - Type for Low Level

Alpha Emitters
Ci/tonne

0.000

0.000

0.093

0.000

0.000

5.890

Radioactive Wastes

(Cont inued)
Beta-gamna
Emitters
Ci/tonne

0.000
0.000
0.100
0.210
78.700
0.000
0.000
1261.800

Beta-gamma
Emitters
Half-Lives <1 yr
Half-lives >1 yr and Tritium
Ci/tonne

0.000

0.100

0.001

4.900

368.760

1954.380

1183.500

Total TRU's
Present
Ci/tonne

No TRU

0.000

No TRU

0.090

No TRU

No TRU

5.900


of the coast for the North Atlantic and North Pacific oceans. 10/
None of the forty-five waste streams described in Exhibit 2-2
have activity concentrations lower than the ambient  con-
centrations listed in the exhibit. However, ambient concentra-
tions might be larger than presented in Exhibit 2-5 if data on
more nuclides or for a broader range of sites were available.
Thus, it is not possible to state definitively that all LLRW
shown on Exhibit 2-2 would exceed ambient activity levels at all
possible disposal sites.

Co-Contamination

As shown on Exhibit 2-1, Annex I of the London Dumping
Convention outlines general prohibitions on the disposal of the
following substances:

Organohalogen compounds,

Mercury and mercury compounds,

Cadmium and cadmium compounds,

Crude oil and petroleum products, and wastes, and
Persistent and floatable plastics and synthetics.

aoooo0oo

The above constituents are considered "trace contaminants" if the
disposal of these contaminants will not cause significant

undesirable effects. "Undesirable effects" include the
possibility of danger associated with bioaccumulation of
substances in marine organisms. EPA is developing testing

protocols to measure the potential for significant undesirable
effects.

In addition, the limitations on co-contaminants do not apply
when it can be shown that contaminants are present as _ chemical
compounds or forms that are non-toxic to marine life and are non-
bioaccumulative in the marine environment upon disposal, or if

10/ Information about anthropogenic nuclides was obtained from
Dr. Hugh Livingstone from the Woods Hole Oceanographic Institute
in a telephone interview. Information about naturally-occurring
nuclides was obtained from a 6 January 1987 memorandum written by
James Neiheisel, Economics and Control Engineering Branch,
addressed to Kung-Wei Yeh, Environmental Studies and Statistics
Branch, both at EPA.

2-14


Exhibit 2-2

Description of Low-Level Radioactive Wastes

(Cont inued)
Total
Total Volume Activity Important Radionuclides Potential
Reference 1985-2004 1985-2004 Density (percentage of waste stream) Land BRC
Number Waste Stream (cubic meters) (curies) (g/em3)

radioactivity) Candidate? *

9 | Nuctear Fuel Rod 64,510 6,450,000 7.8 12.820 C-14¢.01); Co-60(39.8) Ll)
Components (L-NFRCOMP)

Subtotal: 1,715,840 9,587,224

FUEL CYCLE WASTES

10 Fuel - Fabrication 179,481 6 0.2 0.000 U-236(82.7); U-238(13.6) Y
Compactible Trash
CE-COTRASH)

ob Fuel - Fabrication 31,725 1 0.4 0.000 U-234(82.8); U-238¢13.6) Y

Noncompactible Trash
(F-NCTRASH)

12 Fuel - Fabrication 59,457 37 1.0 0.001 U-234(82.8); U-238(13.6) Y
Process Waste
(F-PROCESS)

13 UF(6) Processing 21,387 16 1.0 0.001 U-234(48.3); U-238(48.3) Y
Waste (U-PROCESS)

Subtotal: 292,050 60


Substances Control Act (TSCA), is considering uniform regulation
of certain NARM wastes. Activated metals are not being
considered for regulation under this concept. 6/

Decommissioning of Reactor and Fuel Cycle Facilities

The fourth category on Exhibit 2-2 represents the wastes
generated from decommissioning reactors and fuel cycle
facilities. The projected volume for these wastes is uncertain
because the data are dependent on the schedule of commercial
light water reactor shutdowns. The timing associated with the
generation of these wastes may vary significantly if reactors are
upgraded to extend operating lifetimes, or if time is allowed for
radioactive decay before decommissioning takes place. DOE
assumes that it takes six years to fully decommission a light
water reactor; the first two years are spent planning and the
following four years are spent decommissioning the facility.
Thus, we assume that low-level wastes are disposed of in equal.
volumes during the four years of decommissioning activities.

Using these assumptions, IEc estimates that 13,982 cubic
meters and 102,910 curies of low-level waste will be generated
from the decommissioning of light water reactors (both
pressurized water and boiling water) from 1985 to 2004. In
contrast, for the twenty year period following 2004 we estimate
that at least 873,491 cubic meters and 8,790,423 curies of low-
level waste will be generated. These figures indicate a 63
percent increase in volume and a 85 percent increase in activity
during the period from 2005 to 2024.

In addition, this category includes low-level radioactive
wastes generated by DOE decontamination activities at Three Mile
Island Unit 1 and West Valley. These wastes are classified as
"non-routine" by NRC Update of Part 61 because, as the name

of The PEI report indicates which of nine aggregate categories
of NARM wastes are treated as low-level wastes when disposed on
land. NARM wastes such as building materials (BLDGMAT) and
boiler ash (BLASH) are disposed in unregulated landfills.
Agricultural NARM is not included by PEI, PHB or IEc.


Ocean and land disposal systems must be described
in sufficient detail to allow relative risk esti-
mation.

Combinations of specific wastes, disposal sites,
and other factors must be specified as scenarios
for analysis.

Geographic and conceptual boundaries for the
analysis must be defined.

Risk metrics of interest for both human health and
environmental damage must be selected.

Methods and data for estimating these risks must
be developed and used to generate risk estimates.

Each of these factors is discussed below.

System Descriptions

In order to complete a comparative analysis of land versus
the physical systems for treating,
transporting and disposing of LLRW in each of these
environments must be described in sufficient detail to allow risk
This requires that numerous details be thought

ocean disposal of LLRW,
packaging,

estimation.

through concerning:

°

°

type and composition of wastes handled,

waste treatment and packaging at the site of
generation (and elsewhere) ,

location of waste sources, routes of transport,
and destinations,

modes of transport,

location and nature of intermediate handling and
storage, if any,

location and manner of final disposal operations,
nature of post-disposal monitoring and maintenance

activities, if any, and

1-8


perform adequately in the deep ocean environment. It is clear
that none of the currently available high integrity containers
alone could withstand the high external pressures inherent in
ecean disposal -- all would require that the solidified waste
form within the container be strong enough and sufficiently free
of voids to allow the overall package to withstand high pressure.
In addition, virtually all available HICs include passive
pressure equalization devices, which are still under
consideration for use in ocean disposal. Despite these problems,
we chose to look only at HICs because these containers are the
strongest that are currently available for LLRW, and in addition
would provide the protection required for handling and
transporting LLRW on land prior to final ocean disposal.

As part of our review of containers, we attempted to develop
information on the costs and technical performance of various
methods used to solidify LLRW. Solidification into a matrix able
to withstand high pressure would be a prerequisite for ocean
disposal, and particularly for ocean disposal using an HIC.
Solidification of LLRW is complex and highly waste-specific, and
we found commercial vendors of solidification services unwilling
to share cost or technical performance information with us.

We did learn that solidification methods are available for
many LLRW streams, and are sufficient in many cases to allow land
disposal of LLRW without any container or with only a mild steel
container (which is used for handling purposes only and is
expected to disintegrate once disposal occurs). However, use of
solidification methods has been declining somewhat, and use of
HICs alone for land disposal has been on the rise. The trend to
HICs has been driven primarily by capacity and disposal cost
considerations, since many solidification methods expand the
volume of waste to be disposed considerably.

High integrity containers are available in a variety of
usable volumes ranging from 5 cubic feet to 284 cubic feet, and
are currently constructed from four alternative materials:

° polyethylene,
° fiberglass/polyethylene composite 3/,

3/ Composite containers have not yet received final approval as
HICs.


Radionuclide Composition of NARM Wastes

(ci/m?)

Radio- Half-

nuclide Life METALS IXRSNS INSTR
U-238 4, 500,000,000 y 3.3 E-4 2.8 E-4
U-234 250,000 y 3.3 F-4 2.8 E-4
Th-230 80,000 y

Ra-226 1600 y 1.8 E-2 1.6 E-2
Rn-222 3.82 d 9.0 E-3 5.3 E-3
Pb-214 26.8 m 9.0 E-3 5.3 E-3
Bi-214 19.7 m 9.0 E-3 5.3 E-3
Pb-210 aly 9.0 E-3 5.3 E-3
Po-210 138.4 d 9.0 E-3 5.3 E-3
Th-232 — 14,100,000,000 y LL E-5 8.0 E-6
Ra-228 5.77 y 1.1 E-5 8.0 E-6
Ac-228 6.13 h 1.1 E-5 8.0 E-6
Th-228 1.91 y 1.1 E-5 8.0 E-6
Ra-224 3.64 d 1.1 E-5 8.0 E-6
Rn-220 55 5 1.1 ES 8.0 E~6
Pb-212 10.64 h 1.1 E-5 8.0 E-6
Bi-212 60.6 m 1.1 E-5 8.0 E-6
71-208 4.78 m 1.1 E+S 8.0 E-6

Source: PEI Table 3-3 adapted by IEc.


Exhibit 2-3
Radioactivity By Emitter - Type for Low Level
Radioactive Wastes

(Continued)
Beta-gamma
Beta-gamma Emitters
Emitters Half-Lives <1 yr
Reference Alpha Emitters half-lives >1 yr and Tritium
Number Waste Stream Ci/tonne Ci/tonne Ci/tonne

22 Institutional Com- 0.000 0.100 0.500
pactible Trash
(1-COTRASH)

23 Biological Waste 0.000 0.000 0.200
(1-BIOWAST)

24 Absorbed Liquids 0,000 0.100 0.100
(1-ABSLIQD)

3 Liquid Scintilla- 0.000 0.011 0.000
tion Vials (1-LQSCNVL)

DOE/DEFENSE "GENERAL" LLW

26 Uranium/thoriun 2.880 0.002 5.730

27 Fission product 0.000 3.650 6.600
Induced activity 0.000 0.170 19.510
Tritium 0.000 0.000 0.037
Alpha, <10 nCi/g 0.400 0.000 0.000

3 “Other 0.000 11,800 7.600

Total TRU's
Present
Ci/tonne

No TRU

No TRU

No TRU

No TRU

No TRU

No TRU

No TRU

0.013

No TRU


Exhibit 2-3
Radioactivity By Emitter - Type for Low Level
Radioactive Wastes

(Continued)
Beta-gamma
Beta-ganma Emitters
Emitters Half-Lives <1 yr Total TRU's
Reference Alpha Emitters —-Half-\ives >1 yr and Tritium Present
Number Waste Stream Ci/tonne Ci/tonne Ci/tonne Ci/tonne

DECOMMISSIONING OF REACTOR AND
FUEL CYCLE FACILITIES

7 Pressurized Water (PWR) 0.000 15.510 0.090 No TRU
38 Boiling Water (BWR) 0.000 6.940 0.074 No TRU

39 DOE "SPECIAL PROJECTS"
(e.g. THI, West Valley)

REMEDIAL ACTION PROGRAMS

FUSRAP
40 NJ No TRU
41 other No data

‘SFMP
42 Niagra Falls No data

Storage Site
43 other No data
4b CERCLA No data
U.S. NAVY

45 Decommissioned Reactor Plants 0.0 1.400 15.700 No TRU

(for 100 submarines)

Source: See text.


Boundary Definitions

Results of risk analyses are strongly influenced by the
boundaries set for the analysis, for example the physical,
chemical, and biological actions included; the exposure areas
modeled; and the human health and environmental effects
considered. Exposure areas and effects are particularly
difficult, because of the need to be consistent between land
versus ocean disposal, and of the need to consider a range of
human health and environmental effects. Different effects of
interest may suggest different exposure area boundaries.

In general, we believe it advisable to use relatively large
boundaries and consider (at least roughly) all likely effects.
Again risk estimates developed to support EPA's proposed LLRW
land disposal regulations would provide a basis for boundary
definition for human health effects from the land disposal
option. However, preliminary ocean disposal risk calculations
would be needed to allow specification of health and
environmental damage boundaries for the full comparative analysis
ef ocean disposal.

Methods for Risk Assessment

Once the above decisions are made, data and methods are
needed to calculate risk estimates for the scenarios and risk
metrics of interest. Estimates exist currently for human health
risks from land disposal of commercial (and presumably for
DOE/Defense) LLRW, and these methods might be useful for
estimating risks from land disposal of NARM and remedial action
LLRW. We are not aware of currently available methods or data to
estimate environmental risks from land disposal of  LLRW.
However, the U.S. Navy's FEIS on the disposal of decommissioned
naval submarine reactor plants (5) does summarize adverse
environmental effects that may be expected from both the land
disposal and ocean disposal options.

Human health and environmental risks from possible ocean
disposal of LLRW have not been explored (except for the U.S. Navy
FEIS), and to our knowledge data and methods to estimate these
risks would have to be developed or adapted from other studies.
Many factors would need to be estimated, including time to and
nature of container/waste form failure, the resulting leach rate,
suspension and resuspension of contaminated sediments, transport

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