Final Comparative Environmental 

Evaluation of Alternatives for 

Handling Low-Level Radioactive Waste 

Spent Ion Exchange Resins from 

Commercial Nuclear Power Plants 

Final Report 

U.S. Nuclear Regulatory Commission 

Office of Federal and State Materials and Environmental 

 Management Programs 

September 2013 
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i 

FINAL COMPARATIVE ENVIRONMENTAL EVALUATION OF ALTERNATIVES FOR 

HANDLING LOW-LEVEL RADIOACTIVE WASTE SPENT ION EXCHANGE RESINS FROM 

COMMERCIAL NUCLEAR POWER PLANTS 

CONTENTS

EXECUTIVE SUMMARY .............................................................................................................vii

ACRONYMS AND ABBREVIATIONS ......................................................................................... xix

1 INTRODUCTION AND PURPOSE................................................................................. 1-1

2 CURRENT STATUS OF THE GENERATION AND DISPOSAL OF SPENT ION 

EXCHANGE RESINS FROM COMMERCIAL NUCLEAR POWER PLANTS ................ 2-1

2.1 Generation of Spent Ion Exchange Resins at NPPs ...................................................... 2-1

2.1.1 Ion Exchange Resin Composition and Use ........................................................ 2-1

2.1.2 Spent IER Generation and Management ........................................................... 2-1 

2.1.3 Estimated Annual Spent IER Volumes ............................................................... 2-3

2.2 Disposal Options for the Spent Ion Exchange Resins ................................................... 2-4

3 SCOPE OF THE EVALUATION ..................................................................................... 3-1

3.1 Alternatives Evaluated ................................................................................................... 3-1

3.1.1 Brief Descriptions of the Alternatives.................................................................. 3-1

3.1.2 Additional Assumptions Associated with the Alternatives .................................. 3-4

3.2 General Evaluation Assumptions and Approach ............................................................ 3-6

3.3 Issues Eliminated from Detailed Consideration ............................................................. 3-7

4 DETAILED DESCRIPTIONS OF ALTERNATIVES FOR HANDLING THE SPENT ION 

EXCHANGE RESINS ..................................................................................................... 4-1

4.1 Common Elements of the Alternatives ........................................................................... 4-1

4.1.1 Dewatering of Spent IERs .................................................................................. 4-1

4.1.2 Handling, Packaging, and Offsite Shipment of Spent IERs ................................ 4-1

4.1.2.1 Handling and Packaging ......................................................................... 4-2

4.1.2.2 Offsite Shipment ..................................................................................... 4-3

4.1.2.3 Estimated Annual Truck Shipments for the Six Alternatives ................... 4-3

4.1.3 Disposal of Untreated and Treated Spent IERs ................................................. 4-3

4.2 Specific Elements of the Alternatives ............................................................................. 4-4

4.2.1 Alternative 1A—Disposal of Blended Class A, B, and C Spent IER LLRW 

from a Central Processing Facility (using Mechanical Mixing) ........................... 4-4

4.2.2 Alternative 1B—Disposal of Blended Class A, B, and C Spent IER LLRW 

from a Central Processing Facility (using Thermal Processing) ......................... 4-5

4.2.3 Alternative 2—Direct Disposal of Class A, B, and C Spent IER LLRW .............. 4-7

4.2.4 Alternative 3—Long-Term Onsite Storage of Class B and C Concentration 

Spent IERs, then Disposal ................................................................................. 4-7

4.2.5 Alternative 4A—Volume Reduction of Class B and C Concentration Spent 

IERs at a Processing Facility, Long-Term Storage, then Disposal ..................... 4-8

4.2.6 Alternative 4B—Volume Reduction of Class B and C Concentration Spent 

IERS at a Processing Facility, then Disposal ................................................... 4-10
ii 

5 COMPARATIVE ENVIRONMENTAL EVALUATION ..................................................... 5-1

5.1 Potential Environmental Impacts .................................................................................... 5-1

5.1.1 Overview ............................................................................................................ 5-1

5.1.2 Resource and Impact Area-Specific Methodologies and Assumptions .............. 5-2

5.1.2.1 Air Quality Impacts .................................................................................. 5-2

5.1.2.1.1 Radiological Impacts ......................................................................... 5-2

5.1.2.1.2 Non-radiological Impacts .................................................................. 5-3

5.1.2.2 Ecological Resource Impacts ................................................................. 5-3

5.1.2.3 Historic and Cultural Resource Impacts ................................................. 5-4

5.1.2.4 Noise Impacts ......................................................................................... 5-4

5.1.2.5 Public and Occupational Health Impacts ................................................ 5-5

5.1.2.6 Soil Impacts ............................................................................................ 5-5

5.1.2.7 Transportation Impacts ........................................................................... 5-5

5.1.2.7.1 Impacts on Local and National Traffic .............................................. 5-7

5.1.2.7.2 Radiological Impacts of Routine Transportation ............................... 5-8

5.1.2.7.3 Non-radiological and Radiological Impacts of Transportation 

Accidents ........................................................................................ 5-11

5.1.2.8 Waste Management .............................................................................. 5-15

5.1.2.9 Water Resources .................................................................................. 5-15

5.1.3 Mitigation Measures for Potential Environmental Impacts ................................ 5-15

5.1.4 Evaluation of Potential Impacts ........................................................................ 5-16

5.2 Summary and Discussion of Comparative Environmental Evaluation ......................... 5-47

5.2.1 Air Quality ......................................................................................................... 5-47

5.2.2 Ecological Resources ....................................................................................... 5-47

5.2.3 Historic and Cultural Resources ....................................................................... 5-48

5.2.4 Noise ................................................................................................................ 5-48

5.2.5 Public and Occupational Health ....................................................................... 5-48

5.2.6 Soil ................................................................................................................... 5-49

5.2.7 Transportation .................................................................................................. 5-49

5.2.7.1 Local and National Traffic Impacts ....................................................... 5-49

5.2.7.2 Radiological Impacts of Routine Transportation ................................... 5-49

5.2.7.3 Non-radiological and Radiological Impacts of Transportation 

Accidents .............................................................................................. 5-50

5.2.8 Waste Management ......................................................................................... 5-51

5.2.9 Water Resources .............................................................................................. 5-51

6 REFERENCES ............................................................................................................... 6-1

APPENDIX A TRANSPORTATION ANALYSIS: METHODOLOGY, ASSUMPTIONS, AND 

POTENTIAL IMPACTS ................................................................................................. A-1

A.1 Introduction ................................................................................................................... A-3

A.1.1 Overview ........................................................................................................... A-3

A.1.2 Key General Assumptions Used in This Transportation Analysis ..................... A-5

A.1.3 Organization of the Remainder of this Appendix ............................................... A-6
iii 

A.2 Estimated Annual Number of Truck Shipments by Alternative...................................... A-6

A.2.1 Volume and Classification of Spent IERs Generated Annually ......................... A-6

A.2.2 Spent IER Shipping Requirements .................................................................... A-6

A.2.3 Annual Numbers of Truck Shipments ................................................................ A-9

A.3 Potential Transportation Impacts ................................................................................ A-14

A.3.1 Impacts on Local and National Traffic ............................................................. A-15

A.3.1.1 Impacts on Local Traffic ....................................................................... A-15

A.3.1.2 Impacts on National Traffic .................................................................. A-17

A.3.2 Radiological Impacts of Routine Transportation .............................................. A-19

A.3.2.1 Impacts on Individual Receptors .......................................................... A-20

A.3.2.1.1 Impacts to Individuals from One Routine Shipment ....................... A-23

A.3.2.1.2 Impacts to Individuals from All Routine Shipments by 

Alternative ...................................................................................... A-23

A.3.2.2 Impacts on Populations ....................................................................... A-26

A.3.2.3 Potential Impacts from Routine Transportation ................................... A-27

A.3.2.3.1 Impacts from Moving Trucks .......................................................... A-27

A.3.2.3.2 Impacts from Trucks at Rest and Refueling Stops ........................ A-31

A.3.3 Non-radiological and Radiological Impacts of Transportation Accidents ......... A-35

A.3.3.1 Non-Radiological Impacts of Transportation Accidents ....................... A-35

A.3.3.2 Radiological Impacts of Transportation Accidents ............................... A-41

A.3.3.2.1 Accidents with No Release of Radioactive Materials ..................... A-41

A.3.3.2.2 Accidents in Which Radioactive Material Could Be Released ....... A-44

A.4 References .................................................................................................................. A-56

APPENDIX B NRC RESPONSE TO PUBLIC COMMENTS ON THE DRAFT 

COMPARATIVE ENVIRONMENTAL EVALUATION OF ALTERNATIVES FOR 

HANDLING LOW-LEVEL RADIOACTIVE WASTE SPENT ION EXCHANGE RESINS 

FROM COMMERCIAL NUCLEAR POWER PLANTS ................................................... B-1

B.1 Introduction ................................................................................................................... B-3

B.2 Public Comments on the Draft Report and NRC Responses ........................................ B-3

B.2.1 Commenter 1—Kenneth Gunter (Member of the Public) .................................. B-4

B.2.2 Commenter 2—J. Scott Kirk (Waste Control Specialists LLC (WCS)) .............. B-4

B.2.3 Commenter 3—Rusty Lundberg (Utah Department of Environmental Quality, 

Division of Radiation Control (DRC)) ............................................................... B-22

B.2.4 Commenter 4—Joseph DiCamillo (Studsvik, Inc.) .......................................... B-29

B.2.5 Commenter 5—Thomas Magette (EnergySolutions, Inc.) ............................... B-29

B.2.6 Commenter 6—Michael Dooley (Phoenix Energy of Nevada, LLC and 

Kurion, Inc.) ..................................................................................................... B-37

B.3 References ....................................................................................................................... B-38

 
iv 

FIGURES 

Figure 1 Photograph of Ion Exchange Resin Beads ........................................................... 2-1

Figure 2 Graphical Presentation of the Six Alternatives Considered for Handling 

LLRW Spent Ion Exchange Resins ...................................................................... 3-2

Figure 3 Type A Shipping Cask on Flatbed Trailer ............................................................. 4-2

Figure 4 Type B Shipping Cask on Flatbed Trailer ............................................................. 4-2

Figure 5 Low-Level Radioactive Waste Disposal Vaults in a Disposal Trench ................... 4-4

TABLES 

Table 1 Average Annual Volume of Spent IERs Generated by Reactor Type................... 2-3

Table 2 Estimated Average Annual Volumes of Spent IERs from All U.S. Operating 

Commercial NPPs ................................................................................................ 2-4

Table 3 Component Activities of the Six Alternatives for Handling LLRW Spent Ion 

Exchange Resins .................................................................................................. 5-2

Table 4 Examples of Typical Mitigation Measures for Potential Environmental 

Impacts of Component Activities Comprising the Six Alternatives for Handling 

LLRW Spent Ion Exchange Resins .................................................................... 5-17

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for 

Handling LLRW Spent Ion Exchange Resins ..................................................... 5-23

Table A-1 Specifications of Type A and Type B Shipping Casks ......................................... A-8

Table A-2 Annual Number of Truck Shipments by Alternative ........................................... A-14

Table A-3 Estimated Additional Numbers of Trucks on Local Roads near Spent IER 

Processing and Disposal Facilities by Alternative ............................................. A-17

Table A-4 Annual Spent IER Truck Shipments as Percentages of Total U.S. TractorTrailer Truck Shipments, Based on Freight Weights ......................................... A-18

Table A-5 RADTRAN Input Parameters for Calculating Radiation Doses to Individual 

Receptors from Routine Transportation ............................................................. A-22

Table A-6 Additional RADTRAN Input Parameters for Calculating Radiation Doses to 

Individual Receptors near Truck Stops .............................................................. A-23

Table A-7 Estimated Radiological Impacts to Individual Receptors from a Single 

Routine Spent IER Shipment ............................................................................. A-24

Table A-8 Estimated Radiological Impacts to Individual Receptors from All Routine 

Spent IER Shipments for Each Alternative ........................................................ A-25

Table A-9 Rural, Suburban, and Urban Route Lengths and Population Densities for the 

Representative Transportation Routes .............................................................. A-29

Table A-10 Collective (Population) Doses by Cask Type for One Routine Shipment of 

Spent IERs for Representative Transportation Routes (Moving Trucks) ........... A-31
v 

Table A-11 Annual Radiological Impacts on Populations from Routine Transportation of 

All Spent IER Shipments for Each Alternative by Representative 

Transportation Route (Moving Trucks) .............................................................. A-32

Table A-12 Average Number of Truck Stops for Each Representative Transportation 

Route (Trucks Carrying Full Casks of Spent IERs) ........................................... A-34

Table A-13 Average Rural and Suburban Population Densities and Populations near 

Truck Stops for Each Representative Transportation Route ............................. A-35

Table A-14 Annual Radiological Impacts to Populations near Truck Stops from Routine 

Spent IER Shipments for Each Alternative ........................................................ A-36

Table A-15 Estimated Tractor-Trailer Truck Accident Rates in the Contiguous States and 

District of Columbia ............................................................................................ A-37

Table A-16 Estimated Annual Tractor-Trailer Accidents and Fatalities for Representative 

Transportation Routes to Disposal by Alternative (Full and Empty Casks) ....... A-39

Table A-17 Estimated Collective Population Doses and LCFs for an Accident with an 

Undamaged Cask for Representative Transportation Routes to Disposal by 

Alternative .......................................................................................................... A-43

Table A-18 Radionuclide Inventories of BWR and PWR Spent IERs and Calculation of 

the A2 Values of the Mixtures ............................................................................. A-47

Table A-19 Estimated Doses and LCFs to an Individual Receptor for an Accident 

Involving a Damaged Type A Cask by NPP Reactor Type ................................ A-49

Table A-20 The Six Accident Scenarios and Associated Conditional Probabilities and 

Release Fractions .............................................................................................. A-52

Table A-21 Calculated Curie Inventories of a Single BWR and Single PWR Type B 

(CNS 8-210B) Cask Shipment ........................................................................... A-55

Table A-22 Consequences of Dispersion of Spent IERs from Accidental Release from a 

Type B Cask for Accident Scenario Index 6 from Table A-20 ........................... A-56

Table B-1 Draft Report Commenter Identification ................................................................ B-3

 
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EXECUTIVE SUMMARY 

INTRODUCTION AND PURPOSE 

This report presents a comparative environmental evaluation of six alternatives for handling 

low-level radioactive waste (LLRW) spent ion exchange resins (IERs) from commercial nuclear 

power plants (NPPs). An NPP is defined as a thermal electric power generating station in which 

the heat source is one or more nuclear power reactors. Currently, there are 104 operating 

nuclear power reactors located at 65 commercial NPPs in the United States. The evaluation has 

been conducted consistent with Option 2 in the U.S. Nuclear Regulatory Commission (NRC) 

staff’s paper for the Commission, SECY-10-0043, “Blending of Low-Level Radioactive Waste,” 

April 7, 2010, which identified policy, safety, and regulatory issues associated with LLRW 

blending, provided options for an NRC blending position, and made a recommendation for a 

future blending policy. Option 2 proposed that the staff revise the Commission position on 

blending to be risk-informed and performance based. Option 2 was approved by the 

Commission in the October 13, 2010, Staff Requirements Memorandum, SRM-SECY-10-0043, 

“Staff Requirements - SECY-10-0043 - Blending of Low-Level Radioactive Waste.” 

Additionally, in consideration of stakeholder concerns expressed regarding potential 

environmental impacts associated with the blending of certain LLRW, as documented in the 

NRC’s Official Transcript of its January 14, 2010, “Public Meeting on Blending of Low-Level 

Radioactive Waste,” in SECY-10-0043, Option 2, the staff also proposed that “...disposal of 

blended ion exchange resins from a central processing facility would be compared to direct 

disposal of the resins, onsite storage of certain wastes when disposal is not possible and further 

volume reduction of the Class B and C concentration resins.” The purpose of this report is to 

address this comparison of alternatives in the form of a comparative environmental evaluation of 

these IER waste handling options. The six alternatives evaluated in this report include the four 

identified by the NRC staff in SECY-10-0043, plus two additional alternatives that represent 

variations on the disposal of blended ion exchange resins from a central processing facility and 

volume reduction of the Class B and C concentration resins alternatives. 

In the comparative environmental evaluation, the six alternatives are described and potential 

environmental impacts of the alternatives are: (1) identified for a range of resource or impact 

areas (e.g., air quality, ecological resources, public and occupational health, transportation, 

waste management, water resources); and (2) compared in terms of their relative potential 

effects on human health and the environment. For reasons discussed in the report, the six 

alternatives are generic and not location-specific, in that they generally are not intended to 

represent any actual actions or facilities; and the comparative environmental evaluation of these 

alternatives is largely qualitative, with measures of potential environmental impacts expressed 

as characteristics as opposed to specific quantities or numerical magnitudes. An exception is 

that potential transportation impacts are assessed both quantitatively (based on numerically 

calculated or modeled consequences) and qualitatively. Potential radiological impacts during 

transportation of spent IERs on public roadways were estimated using the RADTRAN 6 model, 

which is the nationally accepted, standard computer program for calculating the risks of 

transporting radioactive materials. 
viii 

Furthermore, the evaluation is based on a number of conservative, often bounding assumptions 

regarding the alternatives and various aspects of the analysis. This approach is consistent with 

the assessment of generic, non-location-specific alternatives, for which exact data and 

information would not be available. Consequently, the staff used its professional knowledge, 

experience, and judgment to establish reasonable technical considerations, estimations, and 

approximations with regard to how the alternatives were described, would be implemented, and 

would potentially affect human health and the environment. The staff also took care not to 

underestimate the potential environmental effects and instead worked to bound the possible 

range of outcomes in most cases. Thus, the impacts of the six alternatives, if implemented in 

actual practice, would be expected to be of lesser magnitude than described in this report. 

Ion exchange resins are powdered or small, bead-like materials used by commercial NPPs to 

capture radioactive contaminants dissolved in water used in plant operations. Over time, the 

IERs lose their ability to remove the contaminants from the water and the resins become “spent” 

and must be removed and replaced. The average total volume of spent IERs generated 

annually by commercial NPPs in the United States is about 2568 cubic meters (90,620 cubic 

feet) (see Table 2 in Section 2.1.3 of this report). The NRC defines three classes of LLRW—

Class A, Class B, and Class C—in its regulations in Title 10 of the Code of Federal Regulations

(10 CFR) 61.55. Of the three classes, Class A LLRW is the least hazardous and Class C is the 

most hazardous. Disposal facilities for LLRW are licensed to accept one or more of these 

classes of waste. Waste that exceeds the Class C limits is not generally acceptable for nearsurface disposal. Licensees do not allow IERs to exceed the Class C limits, and waste at 

greater-than-Class C limits is not considered in this report. Spent IERs are managed as LLRW, 

and are classified as Class A, Class B, or Class C LLRW when shipped for disposal, depending 

on the radioactivity of the radionuclides present. 

Currently, there are four licensed, operating LLRW disposal facilities in the United States—

located near Richland, Washington, near Barnwell, South Carolina, in Clive, Utah, and near 

Andrews, Texas. The Clive facility is licensed to dispose of, and could accept, Class A LLRW 

from all 50 states.1

 The Richland and Barnwell facilities are licensed to dispose of Class A, B, 

and C LLRW, but can accept these wastes only from a limited number of states. The Andrews 

facility, which commenced operations on April 27, 2012, can accept Class A, B, and C LLRW 

from Texas and Vermont and from individual generators in out-of-compact states on a case-bycase basis and subject to annual limits. As a result, all U.S. commercial NPPs (which currently 

include 104 operating nuclear reactors at 65 NPP locations) can dispose of their Class A LLRW 

spent IERs, and potentially have access to a disposal facility for their Class B and C spent IERs 

at this time. Note, however, that the scope of the evaluation presented in this report was 

established at an earlier time when the majority of NPPs had no access, or limited access, to 

Class B and C disposal. 

 

1

 Although the Clive facility in the Northwest Compact could accept Class A LLRW from all 50 states, the Rocky 

Mountain and Northwest Compacts require their generators to send Class A LLRW to the facility located near 

Richland, Washington. 
ix 

LLRW processing and waste disposal companies are exploring alternatives for managing Class 

B and C concentration spent IERs.2

 One of these alternatives is to use a centralized processing 

facility to blend small volumes of higher-activity Class B and C concentration spent IERs with 

larger volumes of low activity Class A concentration spent IERs to produce Class A waste. The 

potential environmental impacts of this alternative, as compared to the potential impacts of the 

other alternatives, are presented in this report. 

On September 20, 2012, the NRC staff published a notice in the Federal Register requesting 

public comments on the “Draft Comparative Environmental Evaluation of Alternatives for 

Handling Low-Level Radioactive Waste Spent Ion Exchange Resins from Commercial Nuclear 

Power Plants” (Draft Report). The 120-day public comment period ended on January 18, 2013. 

This Final Report has been prepared considering, and providing responses to, all the comments 

received, and includes revisions to the report based on some of these comments. 

SCOPE OF THE EVALUATION 

The six alternatives evaluated in this report are: 

 Alternative 1A—Direct disposal of blended Class A, B, and C spent IER LLRW from a 

central processing facility where mechanical mixing would be used to blend the spent 

IERs to produce Class A waste. 

 Alternative 1B—Direct disposal of blended Class A, B, and C spent IER LLRW from a 

central processing facility where thermal processing would be used to blend the spent 

IERs to produce Class A waste. 

Alternatives 1A and 1B represent variations on the “disposal of blended ion exchange resins 

from a central processing facility” alternative in SECY-10-0043, Option 2. Both of these 

alternatives are included in this evaluation because both mechanical mixing and thermal 

processing are assumed for this evaluation to be available technologies for the blending of 

Class A, B, and C concentration spent IERs. 

 Alternative 2—Direct disposal of the Class A, B, and C spent IER LLRW (without 

blending). 

 Alternative 3—Direct disposal of the Class A spent IERs, with long-term (20-year) onsite 

storage of the Class B and C concentration spent IERs at the NPPs (including 

construction (expansion) of the waste storage facilities at the NPPs), followed by 

disposal of the Class B and C spent IERs at the end of the long-term storage period. 

 

2

 Throughout this report, spent IERs that are not yet being shipped for disposal are referred to as Class A, B, or C 

concentration spent IERs, rather than as Class A, B, or C waste. The Class A, B, and C designations are related to 

the hazards that the waste presents to an inadvertent human intruder after closure of a LLRW disposal facility, and 

are not related to the hazards at intermediate points in handling. NRC regulations in 10 CFR Part 20 Appendix G do 

not require LLRW to be classified until it is shipped for disposal. 
x 

 Alternative 4A—Direct disposal of the Class A spent IERs, with volume reduction (by 

thermal processing) of the Class B and C concentration spent IERs, followed by 

long-term (20-year) storage of the volume-reduced Class B and C concentration spent 

IERs (including construction of a storage facility at an existing LLRW disposal site), and 

then disposal at the end of the long-term storage period. 

 Alternative 4B—Direct disposal of the Class A spent IERs, with volume reduction (by 

thermal processing) of the Class B and C concentration spent IERs, then disposal of the 

volume-reduced Class B and C spent IERs. 

Alternatives 4A and 4B represent variations on the “further volume reduction of the Class B and 

C concentration resins” alternative in SECY-10-0043, Option 2. Both of these alternatives are 

included in this evaluation because a disposal option for Class B and C wastes from all 50 

states may or may not be available in the near-term, and long-term storage of these wastes 

would be necessary if a disposal facility is not immediately available (as in Alternative 4A). 

Detailed descriptions of these alternatives and the assumptions used in this evaluation are 

included in the full report. For example, the baseline for this evaluation is current land use. This 

means that, with the exception of the construction of the long-term waste storage facilities 

considered in Alternatives 3 and 4A, this evaluation assumes that no new IER storage, 

handling, processing, and disposal facilities will be constructed and, therefore, this evaluation 

does not revisit the impacts of construction of any of these facilities. In addition, the evaluation 

assumes that these facilities operate under licenses from the NRC or an Agreement State3

, and 

that all activities conducted in the alternatives would be in compliance with all applicable 

Federal, State, and local legal and regulatory requirements. 

Additionally, each alternative is considered individually in the evaluation (i.e., each alternative is 

assumed to be implemented at the exclusion of all the other alternatives). There is no mix of 

alternatives, and all spent IERs generated at all 65 NPPs are assumed to be managed under 

each alternative. It is recognized that Agreement State requirements or other factors could 

prevent some NPPs from using some alternatives, and that in actual practice all spent IERs 

generated at all 65 NPPs would not be managed under any single alternative. Therefore, the 

assumption that all spent IERs are managed under each alternative results in conservative 

estimates of the potential impacts of each alternative. 

The assumptions used in this evaluation, such as those described above, are reasonable and 

consistent with SECY-10-0043, Option 2, which established the basis for this comparative 

environmental evaluation. These assumptions are also necessary to place all six alternatives on 

a relatively equal footing, which helps avoid bias in the results of the comparative evaluation. 

 

3

 Agreement States are states that have assumed specific regulatory authority under the Atomic Energy Act of 1954, 

as amended (AEA). Section 274 of the AEA provides a statutory basis under which the NRC relinquishes to the 

Agreement States portions of its regulatory authority to license and regulate byproduct materials (radioisotopes), 

source materials (uranium and thorium), and certain quantities of special nuclear materials. 
xi 

The assessment of potential environmental effects of the six alternatives evaluated the following 

resource or impact areas: air quality, ecological resources, historic and cultural resources, 

noise, public and occupational health, soil, transportation, waste management, and water 

resources. Other resource and impact areas were eliminated from detailed consideration for 

reasons discussed in Section 3.3. In addition, to the extent practicable, the evaluation of 

potential environmental impacts identifies and accounts for generally accepted impact mitigation 

measures in each resource or impact area that would typically be employed in general industry 

practice. In accordance with the standard of significance that has been established by the NRC 

for assessing environmental impacts, using the standards of the Council on Environmental 

Quality’s regulations in 40 CFR 1508.27 as a basis, each impact for each alternative was 

assigned one of the following three significance levels: SMALL, MODERATE, or LARGE. 

SUMMARY OF COMPARATIVE ENVIRONMENTAL EVALUATION 

The evaluation concludes that the potential environmental impacts of all six alternatives in all 

resource and impact areas would be SMALL, with the exception of potential impacts on historic 

and cultural resources from construction of long-term waste storage facilities in Alternatives 3 

and 4A, which could be SMALL to MODERATE. As summarized below for each resource and 

impact area, there are several reasons why these potential environmental impacts would be 

mostly SMALL. 

Air Quality 

Nearly all of the radiological and non-radiological air emissions would come from the blending 

(mechanical mixing, thermal processing) and volume reduction facilities in Alternatives 1A, 1B, 

4A, and 4B. Note that among Alternatives 1A, 1B, 4A, and 4B, air emissions from the ambient 

temperature mechanical mixing (blending) process in Alternative 1A could be less than those 

from Alternative 1B (blending using thermal processing) and Alternatives 4A and 4B (volume 

reduction by thermal processing), which would involve treatment of spent IERs at elevated 

temperatures (800 ̊C) with resulting increased volatilization of constituents. However, emission 

controls (e.g., off-gas filtration equipment in the case of the thermal processing options) would 

be employed at these facilities as necessary to maintain compliance with applicable air quality 

regulations and keep emissions within regulatory limits (e.g., under the National Emission 

Standards for Hazardous Air Pollutants (NESHAPs) and National Ambient Air Quality Standards 

(NAAQS)). Non-radiological air emissions from equipment usage and fugitive dust generation 

during spent IER handling and disposal, and during construction of relatively small, long-term 

spent IER storage facilities in Alternatives 3 and 4A, would be temporary and intermittent in 

nature and would also be subject to air quality regulations. Non-radiological emissions would 

also be minimized and controlled using emissions controls, best management practices (BMPs), 

and other mitigation measures as necessary. 

Ecological Resources 

The analysis assumes that existing NPPs and spent IER processing and disposal facilities 

would operate within existing facility footprints. There would be minimal or no additional ground 

disturbance or other activities during spent IER handling and processing activities, and none 
xii 

during spent IER transport. Therefore, any impacts on wildlife and plants from these operations 

would be minimal. Any air emissions and wastewater discharges would be within regulatory 

limits and noise mitigation measures would keep noise levels and any associated ecological 

impacts to a minimum. Potential impacts from construction of long-term spent IER storage 

facilities in Alternatives 3 and 4A would be SMALL due to the very small sizes of these facilities; 

and would be avoided, minimized, or mitigated where possible, based on threatened and 

endangered species surveys and consultations with the U.S. Fish and Wildlife Service and 

corresponding State agencies. 

Historic and Cultural Resources 

The existing NPPs and waste processing and disposal facilities would be operating within 

existing facility footprints. There would be minimal or no additional ground disturbance during 

spent IER handling, processing, and disposal, and none during spent IER transport. Therefore, 

no destruction of, or other adverse effects on, historic or cultural resources would be expected 

as a result of these activities. Construction of long-term spent IER storage facilities in 

Alternatives 3 and 4A could possibly encounter and destroy, or otherwise adversely affect, 

resources that are listed or determined eligible for listing in the National Register of Historic 

Places (i.e., historic properties). However, the footprints of these storage facilities would be 

relatively small, and conduct of cultural resource inventories and surveys, consultation with 

State Historic Preservation Officers and Tribal Historic Preservation Officers, as required, and 

implementation of appropriate impact avoidance, minimization, or mitigation measures would 

keep the impacts to these resources at SMALL to MODERATE levels. 

Noise 

Noise resulting from spent IER handling, processing, storage, and disposal would occur at 

existing, licensed facilities in compliance with applicable noise regulations; and noise mitigation 

measures would be employed as necessary. Noise impacts during construction of long-term 

spent IER storage facilities in Alternatives 3 and 4A would be temporary and intermittent in 

nature, and could be minimized in populated areas, if necessary, through suitable scheduling of 

construction activities or other measures. 

Public and Occupational Health 

Worker activities for handling, processing, storage, and disposal of spent IERs must comply with 

NRC, Agreement State, Occupational Health and Safety Administration (OSHA), and other 

worker protection requirements and standard operating procedures, as applicable (e.g., as low 

as reasonably achievable (ALARA)). Compliance with these regulations would limit any 

radiological and non-radiological occupational exposures to acceptable levels. The nature of 

facility operations, facility access limitations, applicable air quality, noise, water quality, and 

waste management regulatory requirements (e.g., air quality standards under NESHAPs and 

NAAQS, water quality requirements under the National Pollutant Discharge Elimination System 

(NPDES), and dose-based requirements under 10 CFR 20.1301), emissions control and 

mitigation measures at the NPPs and waste processing and disposal facilities, and 

implementation of maintenance and monitoring programs at long-term spent IER storage 
xiii 

facilities would result in minimal or no exposure of members of the public to radiological and 

non-radiological constituents. 

Soil 

Except for construction of long-term spent IER storage facilities at the NPPs in Alternative 3 and 

at the waste disposal site in Alternative 4A, essentially no activities would take place during 

spent IER handling and processing at the existing facilities, and during spent IER transport, that 

would result in soil disturbance or contamination, other than accidental spills that would be 

addressed in accordance with spill prevention, control, and countermeasures (SPCC) plans. 

Construction of long-term spent IER storage facilities at the NPPs and the waste disposal site in 

Alternatives 3 and 4A, respectively, and waste disposal activities, would involve application of 

BMPs (e.g., earth berms, dikes, sediment fences) to reduce soil erosion and implementation of 

SPCC plans for cleanup of accidental spills. 

Transportation 

A brief explanation of some of the assumptions, methodologies, and terminology used in the 

transportation analysis in this report is necessary to understand the results summarized below. 

Spent IERs would be transported to waste processing and disposal facilities on public roadways 

in special shipping casks (assumed for reasons discussed in the report to be Type A or Type B 

certified casks) loaded on tractor-trailer trucks. This evaluation assumed that lower-activity 

Class A concentration spent IERs would be shipped in Type A casks, and higher-activity Class 

B and C concentration IERs would be shipped in the more robust Type B casks. Depending on 

the alternative, there would be shipments of full casks of spent IERs from the NPPs to waste 

processing (blending, volume reduction) facilities or waste disposal facilities and from waste 

processing facilities to waste disposal facilities, and return shipments of empty casks from waste 

processing and disposal facilities. 

Three categories of potential transportation impacts were assessed in this evaluation, which 

represent the range of reasonable impacts to the public from the transportation of spent IERs 

(full and empty casks): (1) impacts on local and national traffic; (2) radiological impacts of 

routine transportation4

 on individuals and populations; and (3) non-radiological and radiological 

impacts of transportation accidents. Note that exposures of “radiation workers” (e.g., truck 

crews, package handlers, and inspectors) are not considered in this analysis because these 

workers are specially trained in, and knowledgeable of, necessary radiation safety requirements 

and procedures, and are monitored and have radiation exposure limits stipulated by NRC 

regulation in 10 CFR 20.1201. 

Radiological impacts to individual human receptors are expressed in terms of radiation dose, or 

simply dose, which is a measure of the biological damage to an individual from ionizing radiation 

 

4

 Routine transportation takes place without incident. A transportation incident is any event that interferes with 

transportation between origin and destination. A transportation accident is an event that results in death, injury, or 

enough damage to an involved vehicle that the vehicle cannot move under its own power. All accidents are incidents. 
xiv 

measured in units of millisieverts (mSv) or millirem (mrem). Individual receptors are persons at 

various locations along transportation routes traveled by trucks carrying radioactive materials 

(e.g., spent IERs from NPPs). Radiological impacts to populations are expressed in terms of the 

“collective dose” (expressed in units of person-mSv5

), by integrating the average radiation dose 

over the area occupied by the population (using the RADTRAN 6 model). Populations are 

groups of residents along the transportation routes. For this evaluation, individual and collective 

doses were calculated on an annual basis. Radiological impacts to individuals and populations 

were also assessed in terms of latent cancer fatalities (LCFs), which are the expected number 

of additional cancer fatalities that may occur during the lifetime of individuals because of 

(or latent to) an exposure to ionizing radiation. LCF values are derived from the dose and 

collective dose results.6

 Non-radiological transportation impacts assessed in this evaluation are 

associated with the effects of spent IER transport on local and national traffic volumes and 

associated traffic congestion, air quality, noise levels, and road surface wear, and on 

transportation accident (e.g., vehicle collisions) frequencies and associated traffic fatalities. 

As discussed below, for the three categories of potential transportation impacts assessed in this 

evaluation, the quantitatively estimated, potential non-radiological and radiological impacts to 

members of the public from the shipment of spent IERs and empty casks would be small to 

negligible in magnitude. 

 Local and National Traffic Impacts. On a local level, the numbers of trucks transporting 

spent IERs or empty casks on local roads near the waste processing or disposal 

facilities were estimated to range from about one truck per 8-hour operating day near the 

spent IER processing (volume reduction) facilities in Alternatives 4A and 4B, to about 

one truck per operating hour near the spent IER processing (blending) facilities in 

Alternatives 1A and 1B. This range in the numbers of trucks traveling on local roads 

represents very small additions to local traffic in the vicinities of industrial sites. On a 

national level, total annual spent IER freight shipments (full and empty casks) would 

constitute approximately 0.0002 to 0.0005 percent (depending on the alternative) of the 

total annual U.S. freight weight carried by tractor-trailer trucks. These percentages would 

be even smaller (negligible) as compared to total annual national vehicle traffic 

(tractor-trailer trucks plus all other vehicles). Corresponding to these small local and 

national traffic impacts, there would be SMALL impacts on associated traffic congestion, 

air quality, noise levels, and road surface wear.

 

5

 Person-mSv is a unit of dose that represents an individual dose integrated over an area that is occupied by a 

population. It can be thought of as an average individual dose multiplied by the number of people over which it is 

averaged. 

6

 To put the annual doses to individuals in perspective, the annual doses are compared in this report with the average 

annual U.S. background dose, from natural sources, of 3.11 mSv/year (311 mrem/year), as a percentage of the 

background dose. For populations, the annual collective dose is compared to 3.11 mSv (311 mrem) multiplied by the 

affected population. The use of the annual U.S. background radiation level assumes that the background level would 

be the same for all receptors. Also, the calculated latent cancer fatalities (LCFs) are expressed as a fraction 

(percentage) of the American Cancer Society’s 2010 total estimated cancer fatalities in the U.S. of 569,495. 
xv 

 Radiological Impacts of Routine Transportation. For individuals, the highest estimated 

doses (as calculated using RADTRAN 6) and corresponding LCFs would be to the 

“maximally exposed individual”, or MEI7

, and to residents near truck rest and refueling 

stops, although these would all be low. However, the radiological impacts of the 

alternatives would be similar to each other. The MEI dose from moving trucks carrying 

all spent IER shipments annually in the six alternatives would range from approximately 

0.03 to 0.08 percent of the average annual U.S. background radiation dose; and the 

corresponding LCFs would be negligible, ranging from about 1 × 10-11 to 3 × 10-11

percent of 2010 total estimated U.S. cancer fatalities. For an average resident near a 

truck stop, the dose from trucks carrying all spent IER shipments annually would range 

from approximately 0.058 to 0.14 percent of the background dose, and the 

corresponding LCFs would range from 2 × 10-11 to 5 × 10-11 percent of 2010 estimated 

cancer fatalities. Radiation doses and LCFs to all other types of individual receptors 

considered in the analysis—i.e., average persons along transportation routes in rural, 

suburban, and urban settings—would be orders of magnitude lower. 

For populations along the transportation routes and near truck rest and refueling stops,

the maximum annual collective population doses and LCFs from moving and stationary 

trucks, respectively, from all annual spent IER shipments for each of the six alternatives, 

would also be similar. Collective population doses from moving trucks would range from 

about 5 × 10-5 to 10-4 percent of the U.S. average annual background radiation dose; and

corresponding LCFs would be negligible, ranging from about 1 × 10-10 to 3 × 10-9 percent 

of 2010 total estimated U.S. cancer fatalities. For trucks at rest and refueling stops, 

maximum annual collective population doses from stationary trucks would range from 

about 0.1 to 0.2 percent of background; and corresponding LCFs would be negligible, 

ranging from about 1 × 10-8 to 4 × 10-8 percent of 2010 estimated cancer fatalities. 

Note that in actual practice, impacts to both individuals and populations would be lower 

than estimated because not all residents would be at the same locations for an entire 

year and not all trucks carrying spent IERs would stop at the same rest and refueling 

stops. 

 Non-radiological and Radiological Impacts of Transportation Accidents. Regarding 

non-radiological impacts of transportation accidents, in the most conservative case 

evaluated in the transportation analysis, there would be about 2.6 accidents per year 

involving trucks carrying spent IERs or empty casks, which is 0.0007 percent of the 2009 

U.S. annual tractor-trailer truck accident rate. From these accidents, there would be 

about 0.02 traffic fatality per year, which is equivalent to 1 fatal accident every 50 years 

and represents 0.004 percent of 2009 U.S. tractor-trailer truck accident fatalities. There 

 

7

 The maximally exposed individual (MEI) is the individual receiving the maximum exposure to a moving truck 

carrying a radioactive cargo. RADTRAN 6 models the MEI as a person standing as close as possible (30 meters from 

the center of the highway) to the moving truck, when the truck is moving slowly (about 24 kilometers per hour (15 

miles per hour)) past the MEI. 
xvi 

is little variation between these results for the various alternatives and transportation 

routes evaluated. 

Potential radiological impacts as a result of transportation accidents could occur under 

scenarios in which radioactive materials are and are not released from the casks. 

Regarding radiological impacts of transportation accidents in which no radioactive 

materials are released, in the most conservative case evaluated in the analysis, the 

collective population dose as a percentage of U.S. average annual background dose 

would be 0.01 percent, and the corresponding collective LCF as a percentage of 

estimated annual traffic fatalities involving spent IER shipments and of 2010 estimated 

U.S. cancer fatalities would be 0.136 percent and 7.7 × 10-9 percent, respectively. 

Again, there is little variation between these results for the various alternatives and 

representative transportation routes. 

Regarding radiological impacts of transportation accidents in which radioactive materials 

are released from their shipping casks, the analysis separately examined the 

consequences of accidents involving Type A and Type B casks in which radioactive 

material is released. Due to design differences between these two types of shipping 

casks and the different classes of waste they would carry, the consequences of 

accidents involving these two cask types would be different. For the Type A cask 

accident scenario, the MEI dose and LCF as percentages of U.S. average annual 

background and 2010 U.S. total estimated cancer fatalities would be 36 percent and 

1 × 10-8 percent, respectively. For the Type B cask accident scenario, at most, the MEI 

dose and LCF as percentages of background and 2010 estimated cancer fatalities would 

be 19 percent and 6 × 10-9 percent, respectively; and the corresponding collective dose 

and LCF percentages would be 0.25 percent and 2 × 10-7 percent, respectively. 

Waste Management 

Spent IER handling, transport, processing, and disposal, and construction of relatively small 

long-term spent IER storage facilities, would not result in substantial generation of radioactive, 

hazardous, mixed, or non-hazardous solid waste that would adversely affect safety, waste 

disposal capacity, or other resources. Liquid effluents (including stormwater) from facility 

operations and construction activities would be managed in accordance with applicable Federal 

and State regulations, including discharging within permitted limits (e.g., NPDES requirements 

and dose-based requirements under 10 CFR 20.1301). 

Water Resources 

With regard to water quality, only permitted liquid effluent discharges, within regulatory limits, 

would be allowed at all facilities, as applicable. Sediment discharges during construction of the 

relatively small long-term spent IER storage facilities in Alternatives 3 and 4A would be 

controlled through implementation of BMPs (e.g., earth berms, dikes, sediment fences). 

Accidental spills would be immediately addressed in accordance with SPCC plans. With regard 

to potential impacts on water supply, the small quantities of water that would be used at the 
xvii 

spent IER processing facilities, and for dust suppression and other activities (e.g., equipment 

washing) at the waste disposal facilities and during construction of the relatively small long-term 

spent IER storage facilities in Alternatives 3 and 4A, would be expected to result in SMALL 

impacts to water supply. 
xviii 

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xix 

ACRONYMS AND ABBREVIATIONS 

AEA Atomic Energy Act of 1954, as amended 

ALARA as low as reasonably achievable 

BMPs best management practices 

BTP Branch Technical Position 

BWR boiling water reactor 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

Ci curie 

CNS Chem-Nuclear Systems 

CO carbon monoxide 

CO2 carbon dioxide 

CT computed tomography 

CWF Containerized Waste Facility 

DOE U.S. Department of Energy 

DOT Department of Transportation 

DRC Division of Radiation Control [of the Utah Department of Environmental Quality] 

DWS drinking water standards 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

EPRI Electric Power Research Institute 

FHWA Federal Highway Administration 

HAP hazardous air pollutant 

HDPE high density polyethylene 

HEPA High Efficiency Particulate Air 

HIC High Integrity Container 
xx 

IAEA International Atomic Energy Agency 

IER ion exchange resin 

IP Industrial Package 

ISCORS Interagency Steering Committee on Radiation Standards 

LCF latent cancer fatality 

LLRW low-level radioactive waste 

LSA low specific activity 

MEI maximally exposed individual 

MIMS Manifest Information Management System 

MVS modular vitrification system 

NAAQS National Ambient Air Quality Standards 

NEPA National Environmental Policy Act of 1969 

NESHAPs National Emissions Standards for Hazardous Air Pollutants 

NHPA National Historic Preservation Act 

NO2 nitrogen dioxide 

NPDES National Pollutant Discharge Elimination System 

NPP nuclear power plant 

NRC U.S. Nuclear Regulatory Commission 

NRHP National Register of Historic Places 

OSHA Occupational Health and Safety Administration 

PENV Phoenix Energy of Nevada, LLC 

PL Public Law 

PM10 particulate matter less than 10 microns in diameter 

PWR pressurized water reactor 

Q quantity, as in Q system 

ROI region of influence 
xxi 

SC DHEC South Carolina Department of Health and Environmental Control 

SCO surface contaminated object 

SDW Safe Drinking Water 

SHPO State Historic Preservation Officer 

SIER spent ion exchange resins 

SNF spent nuclear fuel 

SNL Sandia National Laboratories 

SO2 sulfur dioxide 

SOP standard operating procedure 

SPCC spill prevention, control, and countermeasures 

SRM Staff Requirements Memorandum 

T&E threatened and endangered 

THPO Tribal Historic Preservation Officer 

TI transport index 

TRAGIS TRAnsportation Geographic Information System 

TRU transuranic 

UCA Utah Code Annotated 

USDOT U.S. Department of Transportation 

USFWS U.S. Fish and Wildlife Service 

VR volume reduction 

WAC waste acceptance criteria 

WCS Waste Control Specialists LLC 

 
xxii 

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1-1 

1 INTRODUCTION AND PURPOSE

This report presents a comparative environmental evaluation of six alternatives for handling 

low-level radioactive waste (LLRW) spent ion exchange resins (IERs) from commercial nuclear 

power plants (NPPs). It was prepared with assistance from the Environmental Safety and 

Testing Department and the Risk and Reliability Analysis Department of Sandia National 

Laboratories, Albuquerque, New Mexico. The evaluation has been conducted consistent with 

Option 2 in the U.S. Nuclear Regulatory Commission (NRC) staff’s paper for the Commission, 

SECY-10-0043, “Blending of Low-Level Radioactive Waste,” April 7, 2010 (NRC, 2010a). An 

NPP is defined as a thermal electric power generating station in which the heat source is one or 

more nuclear power reactors. Currently, there are 104 operating nuclear power reactors located 

at 65 commercial NPPs in the United States. 

SECY-10-0043 identified policy, safety, and regulatory issues associated with LLRW blending, 

provided options for an NRC blending position, and made a recommendation for a future 

blending policy. Option 2 proposed that the staff revise the Commission position on blending to 

be risk-informed and performance based, the principal consideration being whether a final 

blended waste form could be safely disposed of. Proposed changes and clarifications to the 

existing blending positions included: (a) clarification that a site-specific intruder analysis must 

be performed to determine whether an intruder could be protected, or that the conditions 

necessary for protection must be present; (b) development of criteria defining acceptable 

homogeneity and sampling considerations; and (c) elimination of the “factor of 10 rule” for 

mixing of wastes that can be blended into a homogeneous mixture because the concentration of 

the final mixture will be relatively uniform in the context of a site-specific intruder scenario. The 

staff further proposed that this option would be implemented through a combination of 

rulemaking and issuance of guidance. Option 2 was approved by the Commission on October 

13, 2010, in Staff Requirements Memorandum, SRM-SECY-10-0043, “Staff Requirements - 

SECY-10-0043 - Blending of Low-Level Radioactive Waste” (NRC, 2010b). 

Additionally, in consideration of stakeholder concerns expressed regarding potential 

environmental impacts associated with the blending of certain LLRW, as documented in the 

NRC’s Official Transcript of its January 14, 2010 “Public Meeting on Blending of Low-Level 

Radioactive Waste,” (NRC, 2010c), the staff also proposed that “...disposal of blended ion 

exchange resins from a central processing facility would be compared to direct disposal of the 

resins, onsite storage of certain wastes when disposal is not possible and further volume 

reduction of the Class B and C concentration resins” (NRC, 2010a). The purpose of this report 

is to address this comparison of alternatives in the form of a comparative environmental 

evaluation of these IER waste-handling options. The six alternatives evaluated in this report 

include the four identified by the NRC staff in SECY-10-0043, Option 2, plus two additional 

alternatives that represent variations on the disposal of blended IERs from a central processing 

facility and volume reduction of the Class B and C concentration resins alternatives. 

In the comparative environmental evaluation, the six alternatives are described and potential 

environmental impacts of the alternatives are: (1) identified for a range of resource or impact 

areas (e.g., air quality, ecological resources, public and occupational health, transportation, 
1-2 

waste management, water resources) typically addressed in environmental assessment 

documents such as those prepared by the NRC staff under the National Environmental Policy 

Act of 1969 (NEPA), and the NRC’s NEPA-implementing regulations in Title 10 (Energy) of the 

Code of Federal Regulations (10 CFR) Part 51; and (2) compared in terms of their relative 

potential effects on human health and the environment. To the extent practicable, this

evaluation identifies and accounts for generally accepted impact mitigation measures in each 

resource and impact area. As discussed in Section 3 (Scope of Evaluation) of this report, the 

six alternatives are generic and not location-specific—they are generally not intended to 

represent any actual actions or facilities. In addition, the evaluation of these alternatives is 

largely qualitative, with measures of potential environmental impacts expressed as 

characteristics as opposed to specific quantities or numerical magnitudes. An exception is that 

potential transportation impacts are assessed both quantitatively (based on numerically 

calculated or modeled consequences) and qualitatively. Note, however, that this report is not a 

NEPA environmental document because its purpose is not to assess the potential 

environmental effects of a proposed Federal (i.e., NRC) action and alternatives to a proposed 

action—it includes no staff finding or recommendation regarding a preferred alternative. 

Furthermore, as discussed in Section 3 of this report, the evaluation is based on a number of 

conservative, often bounding assumptions regarding the alternatives and various aspects of the 

analysis. This approach is consistent with the assessment of generic, non-location-specific 

alternatives, for which exact data and information would not be available for use. Consequently, 

the staff used its professional knowledge, experience, and judgment to establish reasonable 

technical considerations, estimations, and approximations with regard to how the alternatives 

were described, would be implemented, and would potentially affect human health and the 

environment. The staff also took care not to underestimate the potential environmental effects 

and instead worked to bound the possible range of outcomes in most cases. Thus, the potential 

impacts of the six alternatives, if implemented in actual practice, would be expected to be of 

lesser magnitude than described in this report. 

At commercial NPPs, IERs are used for water purification. These resins are powdered or small, 

bead-like materials that continuously remove dissolved radionuclides and other dissolved 

contaminants from the water. After some period of use, the IERs lose their ability to remove the 

contaminants from the water and must be replaced with fresh resins. In the industry, these 

used IERs are called “spent” IERs. Spent IERs contain radionuclides and are managed as 

LLRW.

The NRC divides LLRW into three classes—Class A, Class B, and Class C—depending on the 

concentrations of the different radionuclides in the waste and the long-term hazard those 

radionuclides present.1

 These LLRW classes are found in 10 CFR 61.55. Class A LLRW is the 

lowest activity and least hazardous and Class C LLRW is usually the highest activity and most 

 

1

The LLRW classifications are related to the hazard that the wastes present after closure of the disposal facility and 

not the hazard at intermediate points in waste handling. 
1-3 

hazardous of the three classes.2

 Waste that exceeds the Class C limits is generally not 

acceptable for near-surface disposal. Licensees do not allow IERs to exceed the Class C limits, 

and waste at greater-than-Class C limits is not considered in this report. In accordance with 

10 CFR Part 20, Appendix G, LLRW is not required to be classified until shipped for disposal. 

Thus, in this report, spent IERs that are not at the point of being shipped for disposal are 

referred to as “Class A, B, or C concentration spent IERs” and spent IERs being shipped for 

disposal are referred to as “Class A, B, or C LLRW.”

Disposal facilities for LLRW in the U.S. are licensed by Agreement States3 or the NRC to 

dispose of one or more classes of LLRW (Low Level Radioactive Waste Policy Amendments 

Act of 1985, 42 U.S.C. § 2021b),4 and may also be subject to Low Level Radioactive Waste 

Compacts5 that may restrict a facility’s ability to accept waste from outside of a LLRW Compact. 

Currently, there are four Agreement State licensed LLRW disposal facilities--located near 

Richland, Washington, near Barnwell, South Carolina, in Clive, Utah, and near Andrews, Texas, 

all of which are subject to LLRW Compacts.6

 The Clive facility can accept and dispose of 

Class A LLRW from all 50 states.7

 The Richland and Barnwell facilities accept and dispose of 

Class A, B, and C LLRW, but only from a limited number of states. (Tran and James, 2008; 

Waste Control Specialists, 2009; Waste Control Specialists, 2012; Herness, 2012a) The 

Andrews facility, which commenced operations on April 27, 2012, can accept Class A, B, and C 

LLRW from Vermont and Texas as well as from individual generators in out-of-compact states 

on a case-by-case basis and subject to annual limits (see Section 2.2 for details) (Herness, 

2012a; Herness, 2012b; Herness, 2013). Thus, all 65 operating commercial NPPs can currently 

dispose of their Class A LLRW spent IERs, and potentially have access to a disposal facility for 

their Class B and C LLRW spent IERs at this time. Note, however, that the scope of the 

evaluation presented in this report was established at an earlier time when the majority of NPPs 

had no access, or limited access, to Class B and C disposal. 

 

2 Activity is the level of radioactive emissions of a radionuclide, measured in becquerels (internationally) or in curies 

(in the U.S.).

3 Agreement States are states that have been granted certain NRC regulatory authority under the Atomic Energy Act 

of 1954 (AEA), as amended. Section 274 of the AEA provides a statutory basis under which the NRC relinquishes to 

the Agreement States portions of its regulatory authority to license and regulate byproduct materials (radioisotopes), 

source materials (uranium and thorium), and certain quantities of special nuclear materials.

4 The U.S. Department of Energy (DOE) also operates LLRW disposal facilities for wastes from DOE facilities and 

operations. DOE LLRW disposal facilities are not licensed by Agreement States or the NRC. Only Agreement State 

or NRC licensed LLRW disposal facilities are discussed in this evaluation because the commercial nuclear power 

reactor sites (NPPs) do not have access to DOE LLRW disposal facilities.

5 The LLRW Compacts are congressionally approved entities that have been granted the authority to limit out-ofcompact import and export of LLRW (Low Level Radioactive Waste Policy Amendments Act of 1985, Pub. L. No. 99-

240, 99 Stat. 1842).

6 Additionally, certain very low activity wastes may be disposed in industrial landfills as allowed under 10 CFR 

20.2002, and if the receiving facility either possesses a disposal license issued by the NRC or obtains an exemption 

from the NRC. 

7 Although the Clive facility in the Northwest Compact can accept Class A LLRW from all 50 states, the Rocky 

Mountain and Northwest Compacts require their generators to send Class A LLRW to the licensed LLRW disposal 

facility located near Richland, Washington. The only commercial nuclear power plant to which this applies is the 

Columbia Generating Station, in Richland, Washington.
1-4 

NPPs and LLRW processing and disposal companies are exploring alternatives for managing 

the Class B and C concentration spent IERs. One of these alternatives is to blend Class B and 

C concentration spent IERs to Class A concentrations. For this alternative, LLRW processing 

companies have proposed to use centralized processing facilities to blend, or mix, small 

volumes of higher-activity Class B and C concentration spent IERs with larger volumes of 

low-activity Class A concentration spent IERs to produce Class A waste (Anderson, 2009; 

2011). 

On September 20, 2012, the NRC staff published a notice in the Federal Register (77 FR 

58416) requesting public comment on the draft of this report, “Draft Comparative Environmental 

Evaluation of Alternatives for Handling Low-Level Radioactive Waste Spent Ion Exchange 

Resins from Commercial Nuclear Power Plants” (Draft Report) (NRC, 2012). The 120-day 

public comment period and ended on January 18, 2013. This Final Report considers all of the 

comments received, and includes revisions to the Draft Report based on some of these 

comments. 

The remainder of this report is organized as follows:

• Section 2 discusses the current status of the generation and disposal of spent IERs from 

commercial NPPs.

• Section 3 outlines the scope of the comparative environmental evaluation.

• Section 4 presents detailed descriptions of the six alternatives evaluated in this report for 

the handling of LLRW spent IERs.

• Section 5 presents the comparative environmental evaluation of the six alternatives.

• Section 6 is the list of references cited in this report.

• Appendix A provides the analysis of potential transportation impacts.

• Appendix B presents all the comments received on the Draft Report and the staff’s 

response to each of those comments.
2-1 

Figure 1 Photograph of

Ion Exchange Resin Beads

Source: Wikipedia, 2012

2 CURRENT STATUS OF THE GENERATION AND DISPOSAL OF SPENT ION 

EXCHANGE RESINS FROM COMMERCIAL NUCLEAR POWER PLANTS

This section provides background information on the nature and use of IERs at existing 

commercial NPPs, the generation of spent IERs and management and disposal of these as 

LLRW, and alternatives being considered by industry for managing Class B and C concentration 

spent IERs that currently have no direct disposal pathway.

2.1 Generation of Spent Ion Exchange Resins at NPPs

2.1.1 Ion Exchange Resin Composition and Use

Ion exchange resins used by commercial NPPs are typically powdered or small, bead-like 

materials composed of polystyrene and divinyl 

benzene. They are manufactured by several 

companies based on customer specification and 

application (Purolite®, 2011). Figure 1 is a 

photograph of IER beads. 

Ion exchange resins remove impurities and improve 

the chemistry of water that is used in NPPs. In 

typical applications, IERs may be used for reactor 

water cleanup, pH adjustment, boric acid recovery, 

condensate polishing, spent fuel pool water 

cleanup, and removing contaminants from makeup 

water. Specific water chemistry is essential for 

keeping radiological exposure rates low, and for 

optimum heat transfer and equipment performance 

(DOE, 1993). 

At NPPs, the IERs are contained in tall cylindrical tanks known as resin beds. These beds vary 

in size depending on the system in which they are used, expected flow rate, and desired 

decontamination or demineralization factor. Resin beds are typically 0.85 m3 (30 ft3

) each in 

volume and used in series (a combination of anion, cation, and mixed bed). Activated charcoal 

may also be added to the resin beds to remove impurities from water. Resin beds used for 

primary reactor coolant water cleanup are normally good for a fuel cycle (18 to 24 months). 

Some resin exchange systems are designed for reuse, employing a process called 

regeneration. This process involves reconditioning the resins for reuse similar to the backwash 

of a swimming pool filter. Resin beds are changed when they decrease in efficiency or can no 

longer be regenerated. (IAEA, 2002a)

2.1.2 Spent IER Generation and Management

The IERs are considered “spent” when they lose their ability to remove contaminants from the 

water and must be replaced with fresh resins. At this point, the spent IERs are sluiced from the 
2-2 

resin beds into special containers, typically High Integrity Containers (HICs) or other appropriate 

liners.8

 After being sluiced to HICs or liners, the resins are bulk dewatered to remove 

free-standing liquid. Additional information on spent IER dewatering is presented in 

Section 4.1.1. 

Construction materials for spent IER containers are selected to be appropriate for storage, 

shipment, and disposal. These materials may consist of stainless steel, polyethylene 

impregnated concrete, high density polyethylene (HDPE), fiberglass–polyethylene, or coated 

carbon steel (NRC, 1989a). 

The spent IERs may contain significant quantities of radionuclides, including fission, activation, 

and corrosion products. Radionuclides that may be present include barium-133, cesium-137, 

cobalt-58, cobalt-60, iron-55, manganese-54, nickel-63, technicium-99, and zinc-65 

(NRC, 2007). The concentrations of radionuclides in the spent IERs are such that these IERs 

are managed as LLRW. For characterization purposes (in accordance with 10 CFR 61.55), 

spent IERs are sampled during the sluicing operations and analyzed to determine their isotopic 

identification, radionuclide-specific activities,9 and other waste characteristics. There are many 

sizes (volumes) of the HICs or liners used for spent IER containerization. These HICs or liners 

are typically placed inside special shipping casks or shipping containers for offsite transport. 

The type of shipping cask or container used depends on a number of factors, including the mix 

of radionuclides in the material to be transported and the specific activity of the material. 

Section 4.1.2.1 and Section A.2.2 of Appendix A provide additional information on the types of 

containers used for shipping the spent IERs. For reasons detailed in Section A.2.2, this report 

assumes that the spent IERs are transported in Type A and Type B shipping casks. 

Type A casks would be used for transporting lower activity spent IERs whereas Type B casks 

would be used for higher-activity spent IERS. These two types of shipping casks differ in size, 

with the Type A cask being the larger of the two. For this evaluation, it is assumed that the 

liners shipped in Type A and Type B casks have volumes of 5.29 m3 (187 ft3

) and 3.17 m3

(112 ft3

), respectively (see Table A-1 in Section A.2.2, Appendix A). Following the dewatering 

process, spent IER containers are normally placed inside shielded concrete containers and 

staged in shielded areas at the NPPs, where they are prepared for onsite storage or offsite 

shipment. Spent IERs from systems with low radiological constituent concentrations, such as 

make-up water, condensate polishing, and raw water purification, may not require shielded 

storage or special shipping considerations (NRC, 1985). When spent IERs are stored at NPPs 

for short periods of time, certain storage requirements must be met, such as the posting of 

warning signs, access control, inventory control, freeze prevention, radiological monitoring, and 

spill control measures. In addition, spent IER containers in storage must be inspected 

 

8 At some NPPs, spent IERs are intermediately stored in a spent resin storage tank before being transferred to HICs 

or liners. Spent IERs of differing concentrations may be mixed in such tanks as part of normal operations.

9 Specific activity of a radionuclide means the radioactivity of the radionuclide per unit mass of that nuclide. The 

specific activity of a material in which the radionuclide is essentially uniformly distributed is the radioactivity per unit 

mass of the material.
2-3 

periodically to verify integrity. Long-term storage of spent IERs at NPPs is discussed in 

Section 4.2.4. 

2.1.3 Estimated Annual Spent IER Volumes

Annual volumes of spent IERs generated by NPPs vary by plant design, with boiling water 

reactor (BWR) plants typically generating more spent IERs than pressurized water reactor 

(PWR) facilities (EPRI, 2007).10 Table 1 presents the average spent IER volumes generated 

annually, as estimated by EPRI, by reactor type and waste class (EPRI, 2007). The volumes 

shown in Table 1 are for a single nuclear reactor of each type, based on the average for all 

reactors of each type. 

Table 1 Average Annual Volume of Spent IERs Generated by Reactor Type

(m3

/year (ft3/year))

REACTOR TYPE

AVERAGE ANNUAL VOLUME BY

LLRW CLASSIFICATIONa,b TOTAL 

VOLUMES

Class A Class B Class C

Pressurized Water 

Reactors 12.2 (431) 3.1 (108) 0.4 (14) 15.7 (553)

Boiling Water

Reactors 42.3 (1494) 3.5 (123) 0.2 (7) 46 (1624)

a For a single reactor of each type, based on the average for all reactors of each type.

b Based on four years of waste shipping records collected from 2003 through 2006 (EPRI, 2007).

Table 2 presents the average spent IER volumes, by reactor type and waste class, 

generated annually by all operating commercial NPPs, as estimated by EPRI using four 

years of waste shipping records from 2003 through 2006 (EPRI, 2007). For this 

evaluation, the volume estimates in Table 2 are assumed to be representative of current 

and future volumes, by waste class, of spent IERS from the fleet of 65 operating NPPs. 

These volumes were selected as being representative because the 2007 EPRI study is 

the most recent and comprehensive report available containing data on LLRW generation 

in the nuclear power industry. Thus, from Table 2, the average total volume of spent 

IERs generated annually is estimated to be 2568 m3 (90,620 ft3

); and of that volume 

approximately 86 percent of the spent IERs contain Class A concentrations of 

radionuclides, 12 percent contain Class B concentrations, and 2 percent contain Class C 

concentrations.

It is estimated that approximately 4 percent of the total volume of commercial LLRW generated 

in the U.S. annually is from NPP spent IERs. This is based on the estimated total average 

annual volume of spent IERs from all commercial NPPs from Table 2 (2568 m3 (90,620 ft3

)) 

 

10 This is because BWRs generally circulate more primary water through the reactor core than the PWRs. With more 

water moving through the core, there are more metals and fission products that must be removed from the water and, 

therefore, more spent IERs are generated.
2-4 

divided by the total volume of commercial LLRW disposed of in the U.S. in 2010 (approximately 

60,770 m3 (2,146,000 ft3

) from the U.S. Department of Energy’s (DOE’s) Manifest Information 

Management System database (DOE, 2011).

Table 2 Estimated Average Annual Volumes of Spent IERs

from All U.S. Operating Commercial NPPs

(m3

/year (ft3/year))

REACTOR TYPE

AVERAGE ANNUAL VOLUMES BY 

LLRW CLASSIFICATIONa TOTAL 

VOLUMESa

Class A Class B Class C

Pressurized Water 

Reactors 818 (28,866) 204 (7210) 27 (944) 1049 (37,020)

Boiling Water 

Reactors 1397 (49,316) 115 (4048) 7 (236) 1519 (53,600)

Total Volumes by 

LLRW 

Classification

2215 (78,182) 319 (11,258) 34 (1180) 2568 (90,620)

a Based on four years of waste shipping records (2003 through 2006) collected by EPRI from 65 operating 

nuclear reactors (41 PWRs and 24 BWRs s) at 41 NPPs, and extrapolated by EPRI to all 65 operating 

commercial NPPs. EPRI rounded to 100 reactors rather than the actual 104 reactors (EPRI, 2007). 

2.2 Disposal Options for the Spent Ion Exchange Resins

As discussed in Section 1, the spent IERs are classified as Class A, B, or C LLRW when 

shipped for disposal. Tables 1 and 2 in the NRC’s regulation in 10 CFR 61.55 are used to 

determine if a container of spent IERs is classified as Class A, B, or C.11 The distinction 

between Classes A, B, and C LLRW in 10 CFR 61.55 Tables 1 and 2 is based on the presence 

and specific activity of certain long- and short-lived radionuclides, and the hazard those 

radionuclides pose to an inadvertent human intruder after closure of the LLRW disposal facility. 

Class A LLRW is the least hazardous of the three classes, posing a potential hazard to an 

inadvertent intruder for up to 100 years after closure of a disposal facility. Class B LLRW is 

more hazardous than Class A, and poses a potential hazard to an intruder for up to 300 years. 

Class C LLRW is the most hazardous of the three classes, and poses a potential hazard to an 

intruder for up to 500 years. (10 CFR 61.7(b) and 10 CFR 61.55(a)(2))

Currently, there are four licensed, operating LLRW disposal facilities in the United States—

located near Richland, Washington; near Barnwell, South Carolina; in Clive, Utah; and near 

Andrews, Texas (Tran and James, 2008; Waste Control Specialists, 2009; Waste Control 

Specialists, 2012; Herness, 2012a).12 All four of these facilities were licensed and are regulated 

 

11 The NRC’s 1995 Branch Technical Position on Concentration Averaging and Encapsulation (NRC, 1995) provides 

additional guidance for determining the classification of LLRW when being shipped for disposal.

12 Additionally, certain very low activity wastes may be disposed in industrial landfills as allowed under 10 CFR 

20.2002, and if the receiving facility either possesses a disposal license issued by the NRC or obtains an exemption 

from the NRC.
2-5 

by Agreement States and are subject to Compacts that restrict LLRW generators’ access to 

certain disposal facilities for certain classes of LLRW (Tran and James, 2008; Nuclear Power 

Daily, 2010). 

The Richland facility currently provides disposal services for Class A, B, and C LLRW generated 

in the eight member states of the Northwest Compact (Alaska, Hawaii, Idaho, Montana, Oregon, 

Utah, Washington, and Wyoming) and the three member states of the Rocky Mountain Compact 

(Colorado, New Mexico, and Nevada). The Barnwell facility accepted Class A, B, and C LLRW 

from all 50 states until June 30, 2008, when access to this facility was restricted to LLRW 

generators in the three states in the Atlantic Compact (Connecticut, New Jersey, and South 

Carolina). The Clive facility accepts Class A LLRW from all 50 states, with the exception of 

those states in the Rocky Mountain and Northwest Compacts, which require their generators to 

send Class A LLRW to the Richland facility. (Tran and James, 2008; Nuclear Power Daily, 

2010) The newest facility, near Andrews, Texas, which commenced operations on 

April 27, 2012, accepts Class A, B, and C LLRW from the two states in the Texas Compact 

(Texas and Vermont) (Herness, 2012a). In addition, the Texas Compact has approved 

individual applications (import petitions) from individual LLRW generators in out-of-compact 

states to dispose of Class A, B, and C LLRW at the Andrews facility (Herness, 2012b); and

effective September 1, 2013, the Texas legislature increased the annual curie limit from 220,000 

to 275,000 for Class A, B, and C LLRW imported from out-of-compact states (Herness, 2013). 

Thus, all 65 operating commercial NPPs have access to a disposal facility for their Class A 

LLRW spent IERs, and potentially have access to a disposal facility for their Class B and C 

LLRW spent IERs at this time. Note, however, that the scope of the evaluation presented in this 

report was defined by the Commission at an earlier time when the majority of NPPs had no 

access, or limited access, to Class B and C disposal.

NPPs and LLRW processing and disposal companies are exploring alternatives for managing 

Class B and C concentration spent IERs from NPPs. One alternative that is currently available 

to NPPs is to store their Class B and C concentration spent IERs onsite at their own facilities 

until a disposal facility becomes available. Another alternative is for a LLRW processing 

company to volume-reduce the Class B and C concentration spent IERs using a thermal 

process, and ship the processed wastes for long-term storage at a licensed storage site pending 

the availability of a Class B and C LLRW disposal facility (Anderson, 2009). A third alternative 

is disposal of the Class B and C LLRW spent IERs at an appropriately licensed facility with 

compact approval to accept these wastes. 

A fourth alternative is to blend the Class B and C concentration spent IERs to Class A 

concentrations. For this option, LLRW processing companies have proposed to use centralized 

processing facilities to blend, or mix, small volumes of higher-activity Class B and C 

concentration spent IERs with larger volumes of low-activity Class A concentration spent IERs 

to produce a homogeneous Class A waste that would be suitable for disposal as a Class A 

LLRW. LLRW processing companies have proposed that waste blending could be 

accomplished by mechanical mixing or thermal treatment processes (Anderson, 2009; 2011). 
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3-1 

3 SCOPE OF THE EVALUATION

This section describes the scope of the comparative environmental evaluation presented in this 

report. It introduces the six alternatives for handling LLRW spent IERs (Section 3.1) and 

discusses the general assumptions and approach used for the evaluation (Section 3.2). In 

addition, resource or impact areas eliminated from detailed consideration in this report are 

identified (Section 3.3).

3.1 Alternatives Evaluated

3.1.1 Brief Descriptions of the Alternatives

The six alternatives for handling LLRW spent IERs from commercial NPPs are listed and briefly 

described below. Figure 2 graphically presents these alternatives. As discussed in Section 1, 

these six alternatives are adapted from, and are consistent with, the four basic alternatives 

defined for evaluation by the NRC staff in Option 2 of SECY-10-0043 (NRC, 2010a) and 

approved by the Commission in SRM-SECY-10-0043 (NRC, 2010b). The alternatives are 

described in detail in Section 4.

The six alternatives evaluated are generic and not location-specific. A generic approach was 

taken since: (a) some of the alternatives (in particular Alternatives 1A and 1B, described below) 

are not currently in operation and may or may not be implemented; (b) actual implementation of 

alternatives could be at presently undetermined locations or employ somewhat different 

processes from what is currently proposed; and (c) some of the alternatives could be precluded 

by the implementation of others. However, for the purposes of this evaluation, it is assumed 

that any of the alternatives could be implemented. Additional assumptions regarding the six 

alternatives are included below and in the detailed descriptions in Section 4.

The six alternatives are:

• Alternative 1A—Disposal of Blended Class A, B, and C Spent IER LLRW from a Central 

Processing Facility (using Mechanical Mixing). In Alternative 1A, the NPPs would 

package the Class A, B, and C concentration spent IERs in HICs or liners, which would 

be placed in shielded shipping casks (described in Section 4.1.2) and transported to a 

central processing facility for blending. At the central processing facility, the Class A and 

Class B and Class C concentration resins would be blended together in a mechanical 

mixing process and then dewatered in HICs or liners to create a final homogeneous 

mixture that meets Class A waste concentration requirements. The HICs or liners would 

then be placed in shielded shipping casks, as appropriate, and transported to a Class A 

LLRW disposal facility for disposal. Blending provides a disposal pathway for Class B 

and C concentration spent IERs in the absence of access to Class B and C disposal 

facilities.
NOTE: Solid lines represent trucks carrying spent ion exchange resins, and dashed lines represent trucks returning with empty shielded casks.

Figure 2 Graphical Presentation of the Six Alternatives Considered for Handling LLRW Spent Ion Exchange Resins

3-2
3-3 

• Alternative 1B—Disposal of Blended Class A, B, and C Spent IER LLRW from a Central 

Processing Facility (using Thermal Processing). Alternative 1B is similar to Alternative 

1A except that the central processing facility would use a thermal, superheated steam 

treatment process instead of mechanical mixing to blend Class A concentration spent 

IERs with Class B and Class C concentration spent IERs to create a waste form that 

meets Class A waste concentration requirements. The high temperature steam 

decomposes the organic resins and produces a more stable waste form (see Section 

4.2.2).

Alternatives 1A and 1B represent variations on the “disposal of blended ion exchange resins 

from a central processing facility” alternative in SECY-10-0043, Option 2 (NRC, 2010a). These 

two alternatives are included in the comparative environmental evaluation because both 

mechanical mixing and thermal processing are assumed for this evaluation to be available 

technologies for the blending of Class A, B, and C concentration spent IERs.

• Alternative 2—Direct Disposal of Class A, B, and C Spent IER LLRW. For Alternative 2, 

it is assumed that a disposal facility would be immediately available to receive Class A, 

B, and C LLRW so that all spent IERs could be sent directly from the NPPs for disposal 

without long-term storage at the NPPs or intermediate, offsite processing. Handling and 

packaging of the spent IERs at the NPPs for offsite shipment would be conducted as in 

Alternative 1A. Alternative 2 represents the “direct disposal of the resins” alternative in 

SECY-10-0043, Option 2.

• Alternative 3—Long-term Onsite Storage of Class B and C Concentration Spent IERs, 

then Disposal. In Alternative 3, it is assumed that all Class A spent IERs could be 

directly disposed at existing Class A disposal facilities, but long-term storage of Class B 

and C concentration spent IERs at NPPs would be necessary after which disposal of 

these wastes could occur when a Class B and C disposal facility becomes available. It 

is further assumed that the long-term storage would require expansion of existing waste 

storage facilities and implementation of maintenance and monitoring programs for the 

stored wastes at NPPs. For this evaluation, long-term storage of the Class B and C 

concentration spent IERs is reasonably assumed to occur for a period of 20 years. At 

the end of the storage period, handling and packaging of the Class A, B, and C 

concentration spent IERs for offsite shipment would be conducted as in Alternative 1A. 

Disposal of Class B and C spent IERs is included in Alternative 3 to put it on an equal 

footing, from a comparative standpoint, with the other five alternatives, all of which 

include the ultimate disposal of all spent IERs. Because it is likely that a disposal facility 

licensed to accept Class B and C LLRW would become available in the future, all 

commercial NPPs could eventually have a disposal pathway for their Class B and C 

resins. Alternative 3 represents the “onsite storage of certain wastes when disposal is 

not possible” alternative in SECY-10-0043, Option 2.

• Alternative 4A—Volume Reduction of Class B and C Concentration Spent IERs at a 

Processing Facility, Long-term Storage, then Disposal. Alternative 4A would use a 

nearly identical thermal treatment process to that in Alternative 1B, with the exceptions 
3-4 

that (a) only dewatered Class B and C concentration spent IERs would be processed in 

Alternative 4A to attain volume reduction of these wastes rather than blending these 

wastes with Class A concentration spent IERs to Class A concentrations; and 

(b) Alternative 1B includes no volume reduction. The final, volume-reduced waste form 

would be greatly improved and chemically stabilized as in Alternative 1B (see Section 

4.2.2). As for the Class A spent IERs, it is assumed in this alternative that all of those 

wastes would be directly disposed at an existing Class A LLRW disposal facility. As 

discussed in Section 4.2.5, it is also assumed that the Alternative 4A thermal treatment 

process results in an average volume reduction of 5 to 1 of the Class B and C 

concentration spent IERs (Lowman, 2011), and that the volume reduction facility would 

control the process to ensure that the final waste forms do not exceed Class C limits. 

However, a further premise of this alternative is that there is no immediate disposal 

option for the processed (volume-reduced) Class B and C concentration spent IERs, and 

that the processing facility would ship the treated wastes directly to a licensed LLRW 

storage facility, which is also a disposal facility seeking an Agreement State or NRC 

license or permission from the governing compact to dispose of Class B and C LLRW 

from all 50 states.13 As in Alternative 3, it is assumed that 20 years of storage would 

take place prior to disposal; therefore, construction of a new waste storage facility or 

expansion of an existing storage facility at the waste disposal site would be necessary to 

accommodate long-term storage of the volume-reduced Class B and C concentration 

spent IERs. Handling and packaging of the spent IERs at the NPPs and the volume 

reduction facility for offsite shipment would be conducted as in Alternative 1A.

• Alternative 4B—Volume Reduction of Class B and C Concentration Spent IERs at a 

Processing Facility, then Disposal. Alternative 4B is similar to Alternative 4A except that 

it assumes that an LLRW disposal facility that can accept Class B and C wastes would 

be available for immediate transport and disposal of the processed (volume-reduced) 

spent IERs, and no long-term storage of the processed waste would be required.

Alternatives 4A and 4B represent variations on the “further volume reduction of the Class B and 

C concentration resins” alternative in SECY-10-0043, Option 2. Both of these alternatives are 

included in this evaluation because a disposal option for Class B and C wastes from all 50 

states may not be available in the near-term, and long-term storage of these wastes would be 

necessary if a disposal facility is not immediately available (as in Alternative 4A).

3.1.2 Additional Assumptions Associated with the Alternatives

Additional key assumptions forming the basis of the descriptions of the alternatives and the 

evaluation of their potential environmental impacts in this report include:

 

13 Although the NRC staff believes that Alternative 4A represents a viable option for handling the Class B and C 

concentration spent IERs, the staff recognizes the possibility that some or all of the stored IERs might need to be 

shipped to an alternate disposal site at the end of the 20-year storage period if the disposal site with the long-term 

storage facility does not receive the necessary license or permission to accept the Class B and C spent IER LLRW 

for disposal. 
3-5 

• Each alternative is considered individually in the evaluation, i.e., each is assumed to be 

implemented at the exclusion of all the other alternatives; and all spent IERs generated 

at all 65 NPPs would be managed under each alternative. 

• The current number of operating commercial nuclear reactors at the current number of 

NPP locations in the U.S. (104 operating reactors at 65 NPP locations), and the volumes 

and characteristics of the spent IERs generated at these NPPs, remain constant for the 

evaluation period.14

• All transportation of the untreated and treated (processed) spent IERs and returns of 

empty shipping casks would be by truck (because this is likely to be the most common 

mode of transport of spent IERs).

• All shipping casks are full when carrying spent IERs from an origin to a destination, and 

then always return empty to the origin; and separate shipping casks would be used to 

ship processed (blended or volume-reduced) spent IERs between the waste processing 

facilities and waste disposal sites (see Section A.1.2 of Appendix A for further 

explanation and additional consideration associated with this assumption).

• Only one centralized processing facility is considered to be in existence in Alternative 1A 

for blending by mechanical mixing, in Alternative 1B for blending by thermal processing, 

and in Alternatives 4A and 4B for volume reduction.15

• Ultimate disposition of all spent IERs in each alternative would be at a single Class A 

and a single Class B and C LLRW disposal facility. 

• Sufficient numbers of Type A and Type B shipping casks are available to implement 

each of the alternatives. 

The above seven assumptions are necessary to establish a reasonable baseline for conducting 

the comparative environmental evaluation of the six generic, non-location specific alternatives. 

The use of these assumptions results in conservative estimates of potential impacts of each 

alternative in this evaluation because, if these alternatives were to be implemented in actual 

practice: (1) No single alternative would be selected by all 65 NPPs for managing all of their 

spent IERs; (2) Agreement State restrictions or other factors could prevent some NPPs from 

utilizing certain alternatives; (3) transport of some portion of the untreated and treated spent 

 

14 This is a reasonable assumption because the timing of siting, financing, licensing, construction, and startup of 

operations of any new reactors cannot be predicted with certainty, some existing reactors may be shut down as new 

reactors come online (again uncertain), and any increase in the total number of operating reactors during the 

evaluation period is not expected to be large enough to significantly affect the environmental evaluation conclusions 

made in this report.

15 This assumption is based on the consideration that the total volume of spent IERs generated annually at the 

currently existing 65 NPPs is relatively small (i.e., only approximately 4 percent of the total volume of commercial 

LLRW generated annually in the U.S. (see Section 2.1.3)), and the corresponding assumption that single central 

processing facilities would have sufficient capacity to handle all of the spent IERs.
3-6 

IERs and of returned empty casks could be by some mode other than by truck (e.g., by rail); 

and (4) there may be insufficient Type A and Type B shipping casks available to transport all 

spent IERs generated annually. Thus, the actual impacts of the alternatives, if implemented, 

would be of lesser magnitude because, for example, the environmental impacts would be 

divided among more than one alternative, or there could be fewer possible annual shipments of 

untreated and treated spent IERs. 

3.2 General Evaluation Assumptions and Approach

As discussed earlier, the six alternatives evaluated in this report are generic and not 

location-specific. Also, the environmental analysis presented herein is largely qualitative, which 

is necessary and appropriate for a comparative environmental evaluation of generic, nonlocation-specific alternatives. An exception is that the assessment of potential transportation 

impacts is initially conducted quantitatively based on factors such as estimated numbers of 

shipments of full and empty shipping casks and representative transportation routes, as 

summarized in Section 5 and detailed in Appendix A (Transportation Analysis: Methodology, 

Assumptions, and Potential Impacts). 

Furthermore, the baseline for this evaluation is current land use. This means that, with the 

exception of the long-term spent IER storage facilities considered in Alternatives 3 and 4A, this 

evaluation assumes that no new spent IER storage, handling, processing, and disposal facilities 

will be constructed and, therefore, does not revisit the impacts of construction of any of these 

facilities. This also means that all activities in the six alternatives would occur within existing 

facility footprints and boundaries. Where additional capacity would be needed for long-term 

storage of untreated or treated (processed) spent IERs in Alternatives 3 and 4A, it is assumed 

that this additional capacity could be created within the existing facility boundaries of the NPPs 

(Alternative 3) or the waste disposal site (Alternative 4) under existing operating licenses. In 

addition, it is assumed that all LLRW storage, processing, and disposal facilities considered in 

this evaluation operate under licenses from the NRC or an Agreement State, and that all 

activities conducted in the alternatives would be in compliance with all applicable Federal, State, 

and local legal and regulatory requirements. 

Finally, the potential environmental impacts of closing and decommissioning any of the types of 

facilities considered in this report (i.e., NPPs and spent IER storage, processing, and disposal 

facilities) are not assessed. This is because those would be future impacts that are too 

uncertain to predict in a qualitative environmental evaluation of generic, non-location-specific 

alternatives.

The above assumptions and conditions are consistent with the statement in SECY-10-0043, 

Option 2 (see Section 1), which established the basis for conducting this evaluation. The 

assumptions and conditions are necessary to place all six alternatives on a relatively equal 

footing so as to avoid any bias in the results of the comparative evaluation.

Potential environmental impacts of the six alternatives are identified and evaluated in Section 5 

of this report for the following resource or impact areas: air quality, ecological resources, historic 

and cultural resources, noise, public and occupational health, soil, transportation, waste 
3-7 

management, and water resources. Information on resource and impact area-specific 

methodologies and assumptions used in this evaluation are presented in Section 5.1. For 

reasons discussed in Section 3.3, the following resource or impact areas were eliminated from 

detailed consideration in this report: accidents and other off-normal conditions, environmental 

justice, geology and minerals, land use, socioeconomics, and visual and scenic resources.

A standard of significance has been established by the NRC for assessing environmental 

impacts, using the standards of the Council on Environmental Quality’s regulations in 

40 CFR 1508.27 as a basis (NRC, 2003). The NRC staff has implemented this standard for this 

evaluation and, as such, has assigned each potential impact one of the following three 

significance levels:

• SMALL. The environmental effects are not detectable or are so minor that they would 

neither destabilize nor noticeably alter any important attribute of the resource.

• MODERATE. The environmental effects are sufficient to noticeably alter, but not 

destabilize important attributes of the resource.

• LARGE. The environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource.

Note also that this generic, qualitative comparative environmental evaluation examines only the 

more important potential environmental impacts (i.e., it does not consider minor impacts that 

would have little effect on the natural or human environment, either individually or when 

combined with each other). In addition, to the extent practicable, the evaluation of potential 

environmental impacts identifies and accounts for generally accepted impact mitigation 

measures in each resource or impact area that would typically be employed in general industry 

practice. Cumulative impacts are not assessed in this report because there is no basis for 

determining the past, present, and reasonably foreseeable future actions on which such an 

analysis could be based. 

3.3 Issues Eliminated from Detailed Consideration

Based on the assumptions discussed above, the NRC staff has determined that certain 

resource or impact areas would either not be affected or would sustain negligible impacts from 

implementation of the six alternatives, or that impacts could not be assessed. These resource 

or impact areas and the reasons for their elimination from further consideration in this report are 

as follows:

• Accidents and Other Off-Normal Conditions. Spent IER processing-, storage-, and 

disposal-related accident impacts and impacts due to other types of off-normal 

conditions (e.g., extreme weather events, earthquakes) were not evaluated because it is 

assumed that analyses of credible accident scenarios and other off-normal credible 

events would have already been conducted and reviewed by Federal and State 

regulatory agencies for licensed and permitted LLRW processing, storage, and disposal 

facilities, and that appropriate controls and mitigation measures (e.g., fire and radiation 
3-8 

protection systems) would have been considered when evaluating the consequences 

associated with these events.

Note, however, that the potential environmental impacts from radiological and nonradiological transportation accidents are addressed in this report, in Section 5.1 and 

Appendix A.

• Environmental Justice. This is not considered in the evaluation because the presence of 

minority and low-income populations cannot be established for non-location-specific 

alternatives.

• Geology and Minerals. As discussed earlier, the baseline for this evaluation is current 

land use and, as such, activities in the six alternatives would take place within the 

footprints and boundaries of existing facilities, established when these facilities were 

originally licensed and constructed. Also, it is anticipated that there would be minimal or 

no potential effects on geology and minerals due to the construction and operation of the 

relatively small long-term spent IER storage facilities considered in Alternatives 3 and 4A 

(see Sections 4.2.4 and 4.2.5). No additional activities would take place during facility 

operations in any of the alternatives that would affect regional or local geology or access 

to mineral resources.

• Land Use. Under the current land use assumption used in this evaluation, the primary 

land use impacts would have already occurred due to facility construction, and activities 

that would take place during facility operations would occur within existing facility 

footprints and boundaries. As a result, no activities during operations would further 

conflict with or otherwise affect onsite or nearby existing or proposed land uses.

• Socioeconomics. Only very small incremental increases in the numbers of employees at 

existing NPPs and LLRW processing and disposal facilities would be expected for the 

six alternatives, if any. Although construction of additional facilities for long-term spent 

IER storage in Alternatives 3 and 4A could result in larger numbers of workers, these 

increases would still be very small and would be temporary and of relatively short 

duration. Therefore, there would be little need for additional community services and 

negligible, if any, changes in regional and local economic conditions under these 

circumstances. Thus, socioeconomic impacts of the six alternatives would be extremely 

small.

• Visual and Scenic Resources. For the most part, the six alternatives would involve no 

new activities or land disturbances beyond existing facility footprints and boundaries. 

Construction of additional facilities for long-term waste storage in Alternatives 3 and 4A 

would occur within existing site boundaries with minimal visual impacts as compared to 

those of the existing NPP and waste disposal facilities at which they would be 

constructed. Therefore, minimal or no additional impacts to visual and scenic resources 

would be anticipated.
4-1 

4 DETAILED DESCRIPTIONS OF ALTERNATIVES FOR HANDLING 

THE SPENT ION EXCHANGE RESINS

This section provides detailed descriptions of the six alternatives that are identified in 

Section 3.1 and evaluated in Section 5 of this report. The six alternatives share a number of 

common elements or steps, and Section 4.1 describes the elements that are common to some 

or all of the alternatives. Section 4.2 provides the detailed descriptions of the elements that are 

unique to each alternative.

4.1 Common Elements of the Alternatives

4.1.1 Dewatering of Spent IERs

Dewatering removes free-standing liquid from spent IERs, and would be conducted at both 

NPPs and waste processing facilities as necessary. It is an NRC regulatory requirement in 

10 CFR 61.56(b)(2) that waste must be converted into a form that contains as little free standing 

and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed 

1 percent of the volume of the waste when the waste is in a disposal container designed to 

ensure stability, or 0.5 percent of the volume of the waste for waste processed to a stable form. 

For spent IERs not being shipped offsite for direct disposal, bulk dewatering would be 

employed. Bulk dewatering also removes free-standing liquid; however, there is no regulatory 

requirement to verify the final water content, and resins subjected to bulk dewatering could have 

water contents of >0.5 to 1 percent free-standing liquid.

In either case, dewatering is accomplished by a series of pumping and settling cycles. The 

HICs and liners used for spent IER containerization frequently have pre-installed dewatering 

equipment, commonly referred to as dewatering trees. A dewatering tree is connected to a 

dewatering skid containing hoses, pumps, valve actuators, instrumentation, and sample ports 

for monitoring (DTS, 2011). Even when dewatered to <0.5 to 1 percent free-standing liquid, the 

dewatered spent IERs may still have more than 50 percent of their initial water content because 

these resins absorb significant amounts of water.

4.1.2 Handling, Packaging, and Offsite Shipment of Spent IERs

The information in this section applies to both untreated and treated (processed) spent IERs 

from NPPs and waste processing facilities, respectively. Information on preparations for offsite 

transport and about offsite transport itself is included. Offsite transport from NPPs would be to a 

waste processing facility (Alternatives 1A, 1B, 4A, and 4B) or to a LLRW disposal facility 

(Alternatives 2 and 3). Offsite transport from a waste processing facility would be to a LLRW 

disposal facility (Alternatives 1A, 1B, and 4B) or to a facility for long-term storage of the 

processed waste located at a waste disposal facility site (Alternative 4A).

Offsite shipment of radioactive materials must meet the applicable regulatory standards. The 

NRC regulates packaging of radioactive materials for transportation under 10 CFR Part 71. The 

U.S. Department of Transportation (USDOT) regulates highway routing, placarding, 

occupational exposure and working conditions, and certain packaging requirements under 49 

CFR Part 173 Subpart I.
4-2 

4.1.2.1 Handling and Packaging

Because of the radioactivity levels of the 

spent IERs, HICs or liners containing these 

materials are placed and transported in 

special transportation containers. As 

discussed in Section 2.1.2, the type of 

shipping container, or cask, used depends on 

a number of factors, including the mix of 

radionuclides in the material to be transported 

and the specific activity of the material. Spent 

IERs with certain limited specific activities can 

be shipped as Low Specific Activity (LSA) 

material.

16 The NRC radioactive material 

packaging and transportation regulations in 

10 CFR Part 71 set the boundary for LSA

material. Spent IERs that have a specific 

activity greater than the LSA limit are 

shipped in shielded Type A or Type B 

certified shipping casks (shown in Figure 3 

and Figure 4, respectively), depending on 

the A2 value17 of the material being 

shipped (10 CFR Part 71, Appendix A). 

Spent IERs that exceed the A2 value are 

shipped in Type B shipping casks, which

are more robust than Type A casks. If the 

specific activity of the spent IERs exceeds 

the LSA limit, and if the total radioactivity 

of the spent IERs in the HIC or liner is less 

than or equal to the A2 value, the spent 

IERs may be shipped in a Type A certified 

cask; and if the activity of the spent IERs 

exceeds the A2 value, the spent IERs are 

usually shipped in a Type B certified cask. 

Additional information on the LSA limit, the A2 limit, and Type A and B casks and their use for 

shipment of Class A, B, and C concentration and LLRW spent IERs is provided in Appendix A,

 

16 Low Specific Activity (LSA) material means radioactive material with limited specific activity that is nonfissile or is 

excepted under 10 CFR 71.15, and satisfies the descriptions and limits for LSA-I, LSA-II, and LSA-III materials set 

forth in 10 CFR 71.4. Shielding materials surrounding the LSA material may not be considered in determining the 

estimated average specific activity of the package contents. (10 CFR 71.4)

17 The A2 value is the maximum amount of radioactive material (measured in becquerels or curies), other than special 

form, Low Specific Activity (LSA), and Surface Contaminated Object (SCO) materials, permitted in a Type A package. 

This value is either listed in 10 CFR Part 71, Appendix A, Table A-1, or may be derived in accordance with the 

procedures prescribed in 10 CFR Part 71, Appendix A. (10 CFR 71.4) (See complete definitions of LSA and SCO 

materials in 10 CFR 71.4.)

Figure 3 Type A Shipping Cask

on Flatbed Trailer

Source: SC DHEC, 2007

Figure 4 Type B Shipping Cask

on Flatbed Trailer

Source: DOE, 2012
4-3 

Section A.2.2. For reasons detailed in Section A.2.2, this evaluation assumes that all the spent 

IERs are shipped in Type A or Type B shielded casks. 

Prior to shipment from an NPP or a waste processing facility, the HICs or liners holding the 

spent IERS would be moved from their storage areas and placed in shipping casks, as 

appropriate, which are mounted on appropriate trucks for offsite transport (see below). The 

HICs or liners would be handled using remote tools for lifting, but some worker contact would be 

necessary to verify proper rigging and placement. 

4.1.2.2 Offsite Shipment

The loaded shipping casks would be transported on large, legal weight or overweight trucks 

(usually tractor-trailer trucks with semi-detached flatbed trailers). As discussed in Section A.2.2 

of Appendix A, a truck can carry one Type A or one Type B shielded cask. Truck shipments of 

spent IERs in Type A and Type B casks are generally transported on interstate highways, and 

on limited-access or other primary highways where interstate highways are not available. 

4.1.2.3 Estimated Annual Truck Shipments for the Six Alternatives

For the quantitative evaluation of potential transportation impacts in Appendix A, the NRC 

estimated the annual numbers of truck shipments for each of the six alternatives. For this 

evaluation, the NRC assumed that the shipping casks are full when carrying untreated or 

treated (processed) spent IERs and return empty to the shipment origin, and that there is one 

truck carrying a single Type A or Type B cask per shipment. The total number of annual 

shipments (or trips) per year for each alternative depends on factors such as the annual volume, 

the A2 value of the spent IER shipments, and capacities of the shipping containers. The 

approximate numbers of these shipments for each alternative are estimated in Section A.2.3 of 

Appendix A.

4.1.3 Disposal of Untreated and Treated Spent IERs

The information in this section applies to all six alternatives, in which either untreated or treated 

(processed) spent IERs would ultimately be disposed of at appropriately licensed LLRW 

disposal facilities.

At disposal facilities licensed for disposal of Class A, B, and C LLRW, the HICs or liners would 

be removed from the shielded Type A or Type B shipping casks by crane and placed in the 

disposal system. Several types of disposal systems are used for LLRW spent IERs, depending 

on the waste classification and the nature of the disposal facility. To protect disposal site 

workers from radiation and to provide long-term waste stability, many LLRW disposal facilities 

place the HIC or liner inside a concrete container. Spent IERs that are managed in HICs may 

not have to be placed in concrete containers because the HICs provide the structural stability 

that is required by 10 CFR 61.56 for Class B and C LLRWs. Several concrete containers or 

HICs may be arranged in the disposal area or disposal trench. The concrete containers are
4-4 

Figure 5 Low-Level Radioactive Waste

Disposal Vaults in a Disposal Trench

Source: SC DHEC, 2007

sometimes referred to as silos or disposal 

vaults. Figure 5 is a photograph of a set of 

disposal vaults in a trench being used for 

disposal of Class B and C LLRW. Once a 

disposal area or trench is filled with concrete 

containers and HICs, the voids between the 

containers are backfilled with flowable sand 

or soil. 

Sand, soil, stabilized Class A LLRW, or 

Class B LLRW may be placed on top of the 

concrete shells and HICs. After a trench or 

disposal cell is filled, a partial cover or cap is 

placed on the cell to prevent water 

infiltration. After a set of cells is filled, a final 

cover could be built over them, or the final 

cover could be built during closure of the entire disposal facility. The final cover would 

incorporate design elements protective of human health and the environment, including features 

to limit water infiltration and prevent bio-intrusion and inadvertent human intrusion 

(10 CFR 61.12(b)).

4.2 Specific Elements of the Alternatives

4.2.1 Alternative 1A—Disposal of Blended Class A, B, and C Spent IER LLRW from a 

Central Processing Facility (using Mechanical Mixing)

In Alternative 1A, the Class A, B, and C concentration spent IERs would first be dewatered in 

HICs or liners at the NPPs and then transported to the central processing (blending) facility as 

described in Sections 4.1.1 and 4.1.2, respectively. At the processing facility, the Class B and C 

concentration spent IERs would be mechanically mixed with Class A concentration resins in the 

proper proportions to create a homogeneous mixture that meets Class A requirements.

At the blending facility, the incoming HICs or liners containing the spent IERs would first be 

transferred into a shielded loading bay, and their contents would then be transferred into 

blending input holding tanks that are segregated by spent IER activity levels. If the spent IERs 

were left in HICs or liners for extended periods of time before arriving at the processing facility, 

the resins may have compacted in the bottoms of the containers. If compaction occurs, the 

spent IERs may require agitation, either hydraulically or mechanically, before they can be 

completely removed from the HICs or liners. (IAEA, 2002a)

Next, the Class A and Class B, and C concentration spent IERs would be pumped from the 

input holding tanks into the blending tank in the proper proportions such that the final blended 

mixture would meet Class A LLRW requirements. The IERs would be mechanically mixed in 

this tank to eliminate hot spots caused by the clumping of Class B and C concentration spent 

IERs. The chemical structure of the spent IERs does not change in the blended resin waste 

form because the mechanical mixing process is conducted at ambient temperature (i.e., without 
4-5 

artificial heating or cooling), and this process does not change the volume of the spent IERs 

(EnergySolutions, 2009). 

Mechanical blending has not been used on a commercial scale, but the NRC believes that 

mechanical blending would produce little ancillary waste because (1) the same input tanks and 

mixing tank could be used for each batch (thus little incidental waste would be produced 

between batches) and (2) mechanical mixing does not increase or decrease the volume of the 

spent IERs or transfer the radioactivity to other media. Additionally, a mechanical blending 

facility would use small quantities of water; and because of the high cost of managing 

radioactive water, a mechanical blending facility would minimize the use of water in the 

processing areas. Also, as with any small industrial facility, water may be needed for 

maintenance, domestic purposes and cooling, and it is anticipated that the amounts of water 

used for these purposes would not be significant. 

When the final spent IER mixture is homogeneous, it would be transferred directly into HICs or 

liners for additional dewatering (see Section 4.1.1), or transferred into a tank for dewatering and 

then transferred to HICs or liners. Ion exchange resins readily absorb water, thus potentially 

requiring dewatering before leaving the mechanical mixing facility, even if they were dewatered 

at the NPPs (IAEA, 2002).

Handling and packaging of the blended waste for offsite transport from the central processing 

facility, transportation of the waste from the processing facility to the LLRW disposal facility, and 

disposal of the blended waste would be conducted as discussed in Sections 4.1.2 and 4.1.3 

above. 

4.2.2 Alternative 1B—Disposal of Blended Class A, B, and C Spent IER LLRW from a 

Central Processing Facility (using Thermal Processing)

Alternative 1B is essentially the same as Alternative 1A in the following areas: spent IER 

dewatering and packaging at the NPPs; offsite transport from the NPPs to the central 

processing (blending) facility; pre- and post-processing operations at the blending facility 

(excluding dewatering of the processed spent IERs); transport of processed spent IERs from the 

blending facility to the LLRW disposal facility; and subsequent waste disposal operations. 

Where the two alternatives differ, however, is in the blending process used, in that Alternative 

1B involves the addition of mixing agents and thermal treatment of the resins with superheated 

steam rather than mechanical mixing as in Alternative 1A. In Alternative 1B, the Class A and 

Class B and C concentration spent IERs would be pumped from their segregated input holding 

tanks to a pyrolyzer (the primary thermal treatment tank used in the thermal processing), along 

with various mixing agents (such as oils, charcoal, graphite, sludges, nitrates, and phosphates) 

that are added to promote formation of a stable final waste form (Mason et al., 1999). 

Specifically, the mixing agents are added to supply the reactants required to chemically 

transform the spent IERs into a chemically stable waste form. In the process, the quantity of 

these agents would be closely monitored to ensure that the volumes of the final waste forms 

match the input volumes and that the final waste forms meet Class A requirements (Lowman, 

2011). This mixture will henceforth be referred to in this section as “waste.” 
4-6 

High-temperature (800o

C (1,472oF)) steam would be introduced into the bottom of the pyrolyzer 

and flow upward through the waste. The flow of steam through the waste transforms the waste 

from a slurry into a fluidized bed with almost no thermal gradient and extremely efficient mixing 

properties. The organic components of the waste, which include the resins, are chemically 

transformed through a process known as destructive distillation, which superheats and 

vaporizes all absorbed water and then decomposes the organic resins into a solid residue 

(weighing approximately one third of the original resin weight) and a combination of off-gases 

and vapors (IAEA, 2002a). The solid residue chemically reacts with the mixing agents 

described above to begin the formation of the chemically stable waste form. Gases released 

from this process, including carbon dioxide (CO2), carbon monoxide (CO), hydrogen, steam, 

and acidic off-gasses (e.g., halogens and sulfur vapors), are separated from the solid waste by 

ceramic filters and then processed in an off-gas handling system.

Once the thermal processing in the pyrolyzer is complete, the mixture (consisting of 

99.7 percent of the spent IERs’ radionuclides, carbon, metals, and oxides) would be passed 

through an electrically heated reformer (a secondary pyrolyzer) where high-temperature steam 

is again introduced creating another fluidized bed (Mason et al., 1999). The reformer gasifies 

the remaining carbon into CO2 and CO, which are separated from the solid waste by ceramic 

filters and processed through the off-gas system (IAEA, 2002a).

The off-gas system transfers the separated gases through a heater–evaporator, which would 

oxidize any organic synthesis gases into steam, CO2 and CO, and vaporize excess scrubber 

water. The vaporization process is used to keep the scrubbing water solution at between 10 

and 20 percent dissolved salts. The wet gases then pass through a rotary atomizer scrubber to 

convert halogens and sulfur from a vapor to a salt solution, which is then passed back through 

the scrubber water. The scrubbed gases then pass through a High-Efficiency Particulate Air 

(HEPA) filter before being released to the atmosphere. The salts from the evaporator and 

scrubber are then combined and dried for direct disposal as LLRW separate from the primary 

solid waste form (i.e., the Class A LLRW) (Mason et al., 1999). These incidental wastes 

(e.g., ceramic filters, HEPA filters, and contaminated salt wastes) are relatively small in volume

when compared to the volume of materials processed, and contain less than one-half of one 

percent of the incoming radioactivity (Mason et al., 1999; THORsm, 2006). The thermal process 

produces no liquid releases and no secondary solid wastes, except the mercury adsorber media 

(THORsm, 2006), a hazardous waste stream that would be managed in accordance with Federal 

and State regulations. As with any small industrial facility, water may be needed for 

maintenance and domestic purposes. Steam requirements would require roughly 10 gallons 

per minute (THORsm, 2006) when operating, and this use would equate to slightly more than 

1 million gallons per year, which would not be unusual for a small industrial facility.

The thermal processing creates a greatly improved, more stable waste form over the original, 

unprocessed spent IER waste form. This final waste form appears to be granular to powdery 

(Studsvik, 2012). Gas production in the stabilized waste form would decrease by many orders 

of magnitude as compared to that in the unprocessed spent IERs or would potentially stop 

altogether. The metals and oxides in the new waste form would not absorb water; thus, the 

potential for swelling is removed and the lack of water in the solid final waste form improves 
4-7 

chemical compatibility with the HICs or liners and considerably reduces the leachability of the 

radionuclides in a disposal system. (Mason et al., 1999)

4.2.3 Alternative 2—Direct Disposal of Class A, B, and C Spent IER LLRW

In Alternative 2, all Class A, B, and C concentration spent IERs would be dewatered and 

packaged at the NPPs and then transported to an LLRW disposal facility for direct disposal, as 

described in Sections 4.1.1, 4.1.2, and 4.1.3.

4.2.4 Alternative 3—Long-Term Onsite Storage of Class B and C Concentration Spent 

IERs, then Disposal

Alternative 3 comprises three separate time periods, or stages: (1) “Years 1–20,” during which 

all Class A LLRW spent IERs are shipped from the NPPs for direct disposal and all Class B and 

C concentration spent IERs are stored onsite at the NPPs; (2) “Year 21,” during which all Class 

A LLRW spent IERs continue to be shipped for direct disposal and all of the stored Class B and 

C concentration spent IERs are also shipped for disposal; and (3) the period “After Year 21,” 

during which all Class A, B, and C LLRW spent IERs are shipped for direct disposal. The basis 

for the 20-year long-term storage assumption is discussed in Section 3.1. 

Long-term storage at the NPPs would be in on-site storage facilities. For long-term storage, it is 

assumed that the HICs or liners at each NPP would be placed in concrete shielding cells that 

are inside a heated building to prevent the spent IERs from freezing. Some expansion of 

existing LLRW storage facilities at each of the NPPs would likely be required to store 20 years’ 

accumulation of Class B and C concentration spent IERs. To provide a sense of the scale of 

these long-term storage facilities, the area (“footprint”) that a typical storage building would 

occupy at an NPP is estimated below. 

As shown in Table 1 in Section 2.1.3, the average PWR and BWR units produce 3.5 m3 and 

3.7 m3

, respectively, of Class B and C concentration spent IERs per year. Thus, on average, 

BWRs produce more Class B and C concentration spent IERs per year than PWRs. To bound 

the results, the calculations that follow are conservatively based on the average annual volume 

of spent IERs generated by BWRs. 

As discussed in Sections 2.1.2 and A.2.2, at the NPPs, the spent IERs are placed in special 

containers (HICs or liners) that differ in size. For this evaluation, it is assumed that the higher 

activity Class B and C concentration spent IERs would be placed, stored, shipped, and 

disposed in L8-120 liners with an internal volume of 3.17 m3 (112 ft3

) and a diameter of 1.55 m 

(5.08 ft) (see Table A-1 in Appendix A).18 Therefore, the average BWR unit would produce 

24 liners of Class B and C concentration spent IERs over 20 years (3.7 m3 of spent IERs per 

year ÷ 3.17 m3 of spent IERs per liner x 20 years = 24 liners). Based on this average 

accumulation of 24 liners per year for an average BWR unit, conservatively, the average NPP 

would accumulate 39 liners of Class B and C concentration spent IERs over a 20-year period 

 

18 The model L8-120 liner is used for illustrative purposes in the evaluation. Other liner types are available for use for 

containing spent IERs.
4-8 

((24 liners per reactor unit over 20 years x 104 reactor units) ÷ 65 NPP locations = 39 liners per 

NPP location). The results are rounded up to the next whole number. 

For long-term storage, each liner would be placed in a cylindrical concrete cell to provide 

shielding. Based on the estimated activity of the Class B and C spent IERs and MicroShield 

calculations (Grove, 2005), it is conservatively estimated that the concrete cells would need to 

be about 0.61 m (2 ft) thick. With 0.61-m (2-ft) thick walls, the cells would have an outer 

diameter of 2.77 m (9 ft) (1.55 m liner diameter + (2 x 0.61 m) = 2.77 m). Assuming an aisle 

width of 3 m (10 ft) between the cells to allow for equipment movement and inspections, the 

“footprint” of storage space for each shielding cell would be about 5.8 m by 5.8 m (19 ft x 19 ft), 

or about 33.6 m2 (360 ft2

). Thus, it is estimated that the 39 shielding cells, on average per NPP, 

could be stored in an expanded building space with a footprint of about 1440 m2 (about 15,500 

ft2

), allowing for the 39 cells plus 10 percent for the walls and ancillary parts of the storage 

structure. It is possible that such storage facilities at the NPPs could be constructed in stages 

over the 20-year period rather than all at once. Since NPPs occupy sites of about 200 to 400 

hectares (500 to 1000 acres) (Gonveau, 2005), a 1440-m2 (15,500-ft2

) building expansion would 

occupy a very small portion, about 0.04 to 0.07 percent, of the total NPP site area, on average.

Long-term storage of the Class B and C concentration spent IERs would also require an 

ongoing storage facility monitoring and maintenance program at each NPP. Several technical 

factors would need to be considered in the monitoring and maintenance program, such as gas 

generation in the storage containers, swelling of the IERs due to water absorption (IAEA, 

2002a), IER compaction, and container integrity. Spent IER containers prepared for long-term 

storage require a venting system due to possible build-up of flammable gasses, including 

hydrogen gas (URS, 2009). Also, because the IERs absorb water from the atmosphere, they 

may have to be dewatered multiple times over their extended storage period. Enough empty 

space must be available in the HICs or liners to allow for swelling of the IERs due to absorption 

of water. Furthermore, if compaction occurs, the stored IERs must be mechanically or 

hydraulically agitated. The integrity of the containers would need to be examined periodically to 

ensure that no undesirable performance degradation occurs and that no water is leaking from 

the storage containers. (IAEA, 2002a) HDPE HICs and liners that are not reinforced are not 

approved for long-term storage due to chain scission and cross-linking in the polymer from the 

high radiation levels (NRC, 1989b).

After the 20 years of storage, the Class B and C concentration spent IERs would be prepared 

as necessary and transported from the NPPs to the Class B and C LLRW disposal facility as 

described in Section 4.1.2, and disposed as described in Section 4.1.3.

4.2.5 Alternative 4A—Volume Reduction of Class B and C Concentration Spent IERs at 

a Processing Facility, Long-Term Storage, then Disposal

In Alternative 4A, the Class A LLRW spent IERs would be sent from the NPPs for direct 

disposal, and the Class B and C concentration spent IERs would be transported from the NPPs 

to a central processing facility for volume reduction by thermal treatment, followed by transport 

of the processed Class B and C concentration spent IERs to a disposal site where they would 

be stored until disposal at that site is possible (assumed to be 20 years for this evaluation; see 
4-9 

Section 3.1). The Class A, B, and C concentration spent IERs would first be dewatered and 

packaged at the NPPs, after which the Class A resins would be transported to the Class A 

LLRW disposal facility and the Class B and C concentration resins would be transported to the 

processing (volume reduction) facility, as described in Sections 4.1.1 and 4.1.2. Direct disposal 

of the Class A resins would be conducted as described in Section 4.1.3.

The thermal waste processing technology used in Alternative 4A is nearly identical to that in 

Alternative 1B, with the exceptions that (a) in Alternative 4A, the Class B and C concentration 

spent IERs are not mixed and blended with Class A concentration spent IERs, and the process 

is altered to result in a reduction in waste volume. An average volume reduction of five to one in 

the treatment process is assumed (Lowman, 2011), and the volume reduction facility would 

control the process to ensure that the final waste forms do not exceed Class C limits. The 

resulting waste form would need to be disposed in a facility licensed to accept Class B and C 

LLRW. The final, volume-reduced waste form would be greatly improved and stabilized as in 

Alternative 1B (see Section 4.2.2).

Packaging and transportation of the Class B and C concentration processed waste forms from 

the volume reduction facility to the waste disposal site where the waste would be stored for 

20 years would be conducted as discussed in Section 4.1.2.

Storing a 20-year accumulation of processed (volume-reduced) Class B and C concentration 

spent IERs from all 65 NPPs would require the construction of a waste storage facility or 

expansion of an existing storage facility at the disposal site awaiting a license or other 

permission to dispose of Class B and C LLRW. Containerization and shielding of these spent 

IERs would be as described in Section 4.2.4 for long-term storage of Class B and C 

concentration resins at the NPPs, except that storage of the processed Class B and C 

concentration resins at the waste disposal site could be on concrete pads without freeze 

protection (i.e., without needing to be in a building) since the thermally-treated spent IERs would 

neither contain nor absorb water (see Section 4.2.2). 

It is estimated that about 2227 containers (liners) of Class B and C concentration spent IERs 

would be generated by the 65 NPPs over 20 years (353 m3 of Class B and C concentration 

spent IERs per year (from Table 2) ÷ 3.17 m3 of spent IERs per liner x 20 years = 2227 liners). 

With a volume reduction factor of five in processing, a total of about 446 containers of 

processed Class B and C concentration spent IERs would be produced over the 20-year period 

(2227 containers ÷ 5 ≈ 446 containers). Based on the estimated 33.6 m2 (360 ft2

) of required 

storage space per shielded cell (see discussion in Section 4.2.4), it is estimated that the 446 

shielding cells could be stored in an area with a footprint of about 16,500 m2 (about 177,000 ft2

), 

allowing for the cells plus 10 percent for the edges and ancillary parts of the storage facility. It is 

likely that such a storage facility would be constructed in stages over the 20-year period rather 

than all at once. Assuming that the LLRW disposal site occupies a total area of about 500

hectares (1240 acres),19 the storage facility would occupy less than 1 percent of the total site 

area. 

 

19 For example, the recently licensed LLRW disposal facility near Andrews, Texas, occupies an area of about 542

hectares (1338 acres) (Waste Control Specialists, 2011).
4-10

As in Alternative 3, long-term storage of the wastes at the waste disposal site would require an 

ongoing monitoring and maintenance program. However, for Alternative 4A, the maintenance 

and monitoring requirements would be minimal as compared to those at the NPPs discussed in 

Section 4.2.4. This would be the case due to the improved, stabilized waste form produced in 

the thermal volume reduction process, which is not subject to conditions such as gas generation 

and swelling due to water absorption. At the conclusion of the 20-year storage period, the 

processed Class B and C spent IERs would be disposed of as discussed in Section 4.1.3.

4.2.6 Alternative 4B—Volume Reduction of Class B and C Concentration Spent IERS at 

a Processing Facility, then Disposal

Alternative 4B is identical Alternative 4A with the exception that the thermally processed Class B 

and C spent IERs produced in the volume reduction process would be transported for 

immediate disposal at a licensed Class B and C LLRW disposal facility without any intermediate 

storage.
5-1 

5 COMPARATIVE ENVIRONMENTAL EVALUATION

This section presents the comparative environmental evaluation of the six alternatives identified 

by the NRC staff for handling LLRW spent IERs. This evaluation was performed based on the 

assumptions and approach described in Section 3 and the detailed descriptions of the 

alternatives presented in Section 4. In the discussion that follows, Section 5.1 presents 

potential environmental impacts of the six alternatives, preceded by discussions of the resource 

and impact area-specific methodologies and assumptions used to assess the environmental 

effects and possible mitigation measures that could be employed to minimize or mitigate 

potential impacts. Section 5.2 summarizes the comparative environmental evaluation results.

5.1 Potential Environmental Impacts

5.1.1 Overview

The NRC staff’s general analytical, stepwise approach to the assessment of potential 

environmental impacts in this evaluation was to: (1) identify the set of component activities that 

comprise the various alternatives; (2) identify and assess the nature of the potential 

environmental effects of each component activity on each resource or impact area; (3) consider 

generally accepted measures that could be employed where necessary to mitigate potential 

environmental impacts; and (4) evaluate the potential impacts of each of the six alternatives by 

considering the individual environmental effects of their activities and associated mitigation 

measures. For each alternative, for each resource or impact area, an impact significance level 

of SMALL, MODERATE, or LARGE is assigned as discussed in Section 3.2, and the rationale 

for each rating is discussed. This approach provides a consistent measure of potential 

environmental impacts across the alternatives.

As discussed above, the NRC staff initially identified a set of component activities that comprise 

each of the six alternatives. Some of these activities may be common to some or all of the six 

alternatives, while others may be unique to specific alternatives. Component activities include 

individual, specific actions (e.g., blending of spent IERs at a central processing facility) and 

combinations of several actions having similar types of environmental consequences 

(e.g., spent IER “handling”, which includes packaging, staging, loading, or unloading of 

untreated or treated (processed) spent IERs). Seven component activities were identified and 

considered in this evaluation for identifying potential environmental impacts of the six 

alternatives. These activities and the alternatives in which they are included are shown in 

Table 3.

Resource or impact area-specific methodologies and assumptions used in this evaluation are 

described in Section 5.1.2, and possible mitigation measures that could be employed to 

minimize or prevent potential impacts are discussed in Section 5.1.3. This is followed by the 

evaluation of potential environmental impacts of the six alternatives in Section 5.1.4. 
5-2 

5.1.2 Resource and Impact Area-Specific Methodologies and Assumptions

The methodologies and assumptions used in the evaluation of potential impacts for each 

resource or impact area considered are described in this section.

Table 3 Component Activities of the Six Alternatives for

Handling LLRW Spent Ion Exchange Resins

COMPONENT ACTIVITIES

INCLUDED IN ALTERNATIVES:

1A 1B 2 3 4A 4B

1. Handling of untreated or treated (processed) spent IERs at 

NPPs, waste processing (blending or volume reduction) 

facilities, long-term storage facilities, or LLRW disposal facilities 

(includes activities related to packaging, staging, loading, and 

unloading of spent IERs). Also includes short-term storage that 

may occur at NPPs, waste processing facilities, and LLRW 

disposal facilities.

X X X X X X 

2. Blending of Class A, B, and C concentration spent IERs at a 

central processing facility using mechanical mixing.

X 

3. Thermal processing (blending or volume reduction) of spent 

IERs at a central processing facility (i.e., blending of Class A, 

B, and C concentration spent IERs and volume reduction of 

Class B and C concentration spent IERs). 

 X X X 

4. Construction (expansion) of long-term spent IER storage 

facilities at existing NPPs or at a waste disposal sitea X X 

5. Long-term storage of untreated or treated spent IERs and 

associated inspection and maintenance activities.

 X X 

6. Offsite transport of untreated or treated spent IERs from NPPs 

to waste processing facilities, NPPs to LLRW waste disposal 

facilities, or waste processing facilities to LLRW disposal 

facilities, and return shipping of empty casks from shipment 

destinations.

X X X X X X 

7. Disposal of untreated or treated LLRW spent IERs. X X X X X X 

a At NPPs, existing LLRW storage facilities would be expanded for the storage of spent IERs rather than new storage 

facilities being constructed for this purpose.

5.1.2.1 Air Quality Impacts

Air quality impacts could consist of potential effects on ambient air quality from activities 

conducted in the alternatives. For this evaluation, radiological and non-radiological air quality 

impacts are discussed separately. Spent IER handling, processing, storage, and disposal 

facilities and trucks transporting spent IERs would be subject air quality regulations, as 

applicable.

5.1.2.1.1 Radiological Impacts 

The radiological air quality impact evaluation examined potential releases of radionuclides due 

to air emission-producing activities in the alternatives. The degree of hazard to the public is 
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directly related to the type and quantity of radioactive materials released, and the extent of 

exposure of individuals to the released materials. The evaluation reasonably assumes that 

applicable regulatory standards for air quality would not be exceeded because the facilities 

would be in compliance with all applicable regulatory requirements and would employ physical 

controls (e.g., air pollution control equipment) and other mitigation measures as necessary to 

meet air quality criteria. Atmospheric releases of radiological constituents must comply with the 

National Emissions Standards for Hazardous Air Pollutants (NESHAPs) (40 CFR Part 61) or 

stricter state requirements. The radiological requirements in NESHAPs specify that the total 

radiological emissions from a facility cannot cause any member to the public to receive an 

annual dose of radiation in excess of 0.1 millisieverts/year (mSv/year) (10 millirem/year 

(mrem/year)).20 Off-gas monitoring is required under NESHAPs if the predicted annual dose to 

a member of the public is more than 1 percent of the 0.1 mSv/year limit (40 CFR Part 61, 

Subpart H).

5.1.2.1.2 Non-radiological Impacts 

The non-radiological air quality evaluation examined whether component activities comprising 

the alternatives could cause emissions of criteria air pollutants or hazardous air pollutants 

(HAPs). Criteria air pollutants under the National Ambient Air Quality Standards (NAAQS) 

(40 CFR Part 50) consist of particulate matter less than 10 microns in diameter (PM10), sulfur 

dioxide (SO2), carbon monoxide (CO), nitrogen dioxide (NO2), lead, and ozone. HAPs are 

NESHAPs-defined chemical emissions in 40 CFR Part 61. The evaluation examined the 

emissions that could occur as a direct result of activities at a facility. It was assumed that if 

criteria air pollutants or HAP emissions could exceed applicable regulatory standards, air 

pollution controls and mitigation measures would be employed as necessary to bring the 

emissions into compliance.

5.1.2.2 Ecological Resource Impacts

Impacts on ecological resources could include potential effects on plants and animals that live 

on, or otherwise rely on, lands at a facility and contiguous lands for their continued existence. 

Evaluation of potential ecological impacts generally addresses potential effects on the habitats 

where plant and animal species live, as well as on plants, animals, and ecosystems that the 

U.S. Fish and Wildlife Service (USFWS) and corresponding State agencies specifically address 

as threatened, endangered, or otherwise deserving of special protection or consideration.

The ecological resource impact evaluation in this report examined whether activities in the 

alternatives could result in plant or wildlife habitat loss, direct vegetation or wildlife mortality, or 

disturbances (e.g., noise) affecting reproduction. For the generic, non-location-specific 

alternatives considered in this report, it was assumed that the impacts of any activities 

potentially affecting Federal or State special-status species or habitats would be avoided, 

 

20 Radiation dose, or simply dose, is a measure of the biological damage to an individual from ionizing radiation.

Millisieverts (mSv) or millirem (mrem) are the units of measure of the effect ionizing radiation has on people. As a 

point of reference, the average annual background dose from natural sources of radiation received by a person in the 

U.S. is about 3.11 mSv (311 mrem) (NCRP, 2009).
5-4 

minimized, or mitigated through appropriate actions determined in consultation with the USFWS 

and cognizant State agencies. The evaluation also assumes that air emission and water 

discharge regulatory standards that are protective of human health would also be protective of 

ecological resources.

5.1.2.3 Historic and Cultural Resource Impacts

Historic and cultural resources may include prehistoric and historic archaeological sites, 

buildings, structures, districts, or other places or objects considered important to a culture or 

community for historical, traditional, religious, scientific, or other reasons. The evaluation of 

impacts on historic and cultural resources includes assessment of potential effects to these 

resources from activities conducted in the alternatives. Impacts would result if any of the 

following were to occur from these activities: damage to, or loss of, a site of archaeological, 

tribal, or historical value that is listed, or eligible for listing, on the National Register of Historic 

Places (NRHP); loss or degradation of a traditional cultural property or sacred site, or if the 

property or site is made inaccessible for future use; adverse effects to the qualities of a resource 

that render it eligible, as a historic property, for listing in the NRHP; or disturbance to any human 

remains, including those interred outside of formal cemeteries. For the generic, non-locationspecific alternatives considered in this evaluation, the presence of such resources cannot be 

determined. 

Because the six alternatives are assumed to be implemented at existing NPPs, LLRW 

processing facilities, and LLRW disposal facilities, and within the existing site boundaries and 

licensed scopes of operation, it is assumed that impacts to sensitive historic or cultural 

resources would be minimal. Where new activities are conducted, the impacts to sensitive 

historic and cultural resources would be minimized by their identification through cultural 

resource inventories and surveys, and subsequent avoidance, minimization, or mitigation of any 

potential impacts in accordance with the requirements of the National Historic Preservation Act 

(NHPA) Section 106 regulations (36 CFR Part 800) and through consultations with the State 

Historic Preservation Officers (SHPOs) and Tribal Historic Preservation Officers (THPOs), as 

appropriate.

5.1.2.4 Noise Impacts

Noise impacts could occur due to the potential effects of noise from project activities on the 

human and natural environment. Noise is sound that is undesirable because it interferes with 

speech, communication, or hearing; is intense enough to damage hearing; or is otherwise 

annoying.

The evaluation in this report examined whether activities conducted in the alternatives could 

result in noise impacts, and the relative magnitude of those impacts, if any. Potential noise 

impacts could result from any of the following: exceedance of applicable local, state, or Federal 

noise regulations or guidelines in the vicinity of sensitive receptors such as residences, 

hospitals, or schools; permanent increase of at least 10 decibels in ambient noise levels at the 

nearest sensitive receptors within the project vicinity; or exposure of persons to, or generation 

of, excessive ground-borne noise levels where people live, work, or participate in recreational 
5-5 

activities. Impacts of noise on animal species and habitats were considered under ecological 

resource impacts.

5.1.2.5 Public and Occupational Health Impacts

Public and occupational health impacts could consist of the potential effects of project activities 

on public and worker health and safety. These impacts could result from public exposure to 

radioactive or hazardous constituents through inhalation, ingestion of water or food, or direct 

contact with water or soil; occupational injuries; or illnesses of workers who could be affected by 

radiological and non-radiological releases.

The evaluation in this report qualitatively examined how each alternative would contribute to 

public and worker health and safety risk. Radiological and non-radiological effects were 

evaluated separately for workers and the public. Impacts could result from any of the following: 

creation of worker health hazards beyond limits set by health and safety regulatory agencies 

(e.g., the Occupational Health and Safety Administration (OSHA)) or that endanger human life 

or property; serious injuries to workers, visitors, or nearby land users; changes in traffic patterns 

that result in hazardous situations for motorists or pedestrians; spills or releases of hazardous 

materials, hazardous substances, or petroleum products at or above reportable quantities within 

a project area that would pose a threat to public health or the environment in the project vicinity; 

or impaired implementation of, or physical interference with, an adopted emergency hazardous 

materials spill response plan or emergency evacuation plan. It is assumed that activities would 

comply with Federal, State, and local requirements to protect human health and safety 

(e.g., OSHA regulations in 29 CFR Part 1910).

Radiological and non-radiological impacts to public health from incident-free transportation and 

transportation accidents are addressed below under Transportation Impacts.

5.1.2.6 Soil Impacts

Impacts on soil could consist of contamination, or compaction or erosion of soils resulting in 

reduced productivity or significantly altered drainage characteristics. The soil impact evaluation 

in this report examined whether activities conducted in the alternatives could cause soil 

disturbance or contamination. It was assumed that these activities would comply with Federal, 

State, and local requirements (e.g., National Pollutant Discharge Elimination System (NPDES) 

stormwater requirements and 10 CFR 20.1301 dose-based requirements) to reduce, control, or 

avoid soil impacts.

5.1.2.7 Transportation Impacts

The analysis of potential transportation impacts in this report focuses entirely on the potential 

impacts of transportation of the spent IERs, primarily because the bulk of potential 

transportation impacts of the six alternatives would result from the shipment of these wastes. It 

is recognized that there would also be impacts resulting from transportation of operational 

workforces, raw materials, supplies, and incidental process wastes to and from the waste 

processing and disposal facilities. Transportation impacts related to the operations of the NPPs 
5-6 

are not addressed because these impacts have already been assessed by the NRC in the 

environmental impact statements prepared in association with the licensing of these facilities.

Spent IER transportation activities for the various alternatives consist of the shipment of 

untreated or treated (processed) resins on public roadways in Type A and Type B shipping 

casks and return shipment of empty casks between the NPPs, waste processing facilities, and 

waste disposal facilities. The potential effects of routine transportation21 of spent IERs and 

empty casks in the various alternatives on traffic volumes and patterns (e.g., traffic congestion) 

nationally and in areas local to the waste processing and waste disposal facilities are 

considered in the analysis. Routine transportation of radioactive materials could also affect air 

quality, noise, and road surface wear. Also, transporting radioactive and hazardous materials 

under any conditions could pose inherent risks and impacts to members of the public due to 

possible radiation exposure during routine transportation or as a result of transportation 

accidents. Facilities and transporters that handle radioactive materials must comply with 

regulatory requirements and have standard operating procedures (SOPs) in place to minimize 

these risks and protect worker and public health and safety. Note that exposures of “radiation 

workers” (e.g., truck crews, package handlers, and inspectors) are not considered in this 

analysis because these workers are specially trained in, and knowledgeable of, necessary 

radiation safety requirements and procedures, and are monitored and have radiation exposure 

limits stipulated by NRC regulation in 10 CFR 20.1201. 

Three categories of potential transportation impacts were assessed in this evaluation, which 

represent the range of reasonable impacts to the public from the transportation of spent IERs 

(full and empty casks):

• Impacts of spent IER shipments on local traffic near centralized waste processing 

facilities and LLRW disposal facilities, and on total traffic in the U.S.;

• Radiological impacts to members of the public from routine, incident-free transport of 

spent IERs; and

• Non-radiological and radiological impacts to members of the public from transportation 

accidents involving spent IER shipments.

The transportation impact evaluation used quantitative information such as estimated numbers 

of shipments of full and empty Type A and Type B casks, quantities of waste transported in 

shipments, and trip lengths and population densities based on representative transportation 

routes. Results are correspondingly expressed quantitatively, although they are limited by the 

generic, non-location-specific nature of the six alternatives and, therefore, are also assessed 

qualitatively in this report. 

 

21 Routine transportation takes place without incident. A transportation incident is any event that interferes with 

transportation between origin and destination. A transportation accident is an event that results in death, injury, or 

enough damage to an involved vehicle that the vehicle cannot move under its own power. All accidents are incidents.
5-7 

The transportation analysis methodologies and assumptions are summarized below, and the 

analysis results are summarized in Table 5. This information is presented in detail in 

Appendix A. Note that, different from the other five alternatives, potential transportation impacts 

of Alternative 3 were evaluated for three separate time periods, or stages of this alternative (see 

Section 4.2.4): (1) “Years 1-20,” (2) “Year 21,” and (3) the period “After Year 21”. Also, for 

reasons detailed in Section A.2.3 and further discussed in Section A.3 of Appendix A, potential 

transportation impacts from the “Year 21” spent IER transportation scenario of Alternative 3 

were estimated and reported in Appendix A for the sake of completeness only; and those 

potential impacts are neither summarized in the text nor in Table 5 of the main report nor are 

they discussed at any length in the detailed discussions of potential transportation impacts in 

Appendix A. To summarize, the Alternative 3 in Year 21 scenario is fundamentally a special 

case, or outlier, in relation to all of the other transportation scenarios evaluated for the six 

alternatives because potential impacts of this transportation scenario were substantially 

overestimated for justifiable purposes and, therefore, comparison of those impacts with those of 

the other alternatives would not be representative of actual practice. Note also that the potential 

transportation impacts of Alternative 3 in the period “After Year 21” were not separately 

estimated because those impacts would be identical to those of Alternative 2. 

5.1.2.7.1 Impacts on Local and National Traffic 

The evaluation examined the potential effects on local and national traffic caused by the 

transportation of the spent IERs (full and empty casks) in each alternative.

Impacts on Local Traffic 

Potential impacts on local traffic near spent IER processing facilities (for blending or volume 

reduction) and LLRW disposal facilities, from trucks carrying spent IERs and empty shipping 

casks, were evaluated using estimated numbers of annual truck shipments for each alternative 

(see Table A-2 in Section A.2.3 of Appendix A). Trucks would enter and leave these facilities 

only during their normal working hours. Thus, for this analysis, the annual numbers of 

shipments (trips) for each of the alternatives were divided by the number of operating hours per 

year for a waste processing or disposal facility (assumed to be 2000 hours per year, based on 

fifty 40-hour work weeks), to obtain an average number of trucks per hour on local roads 

entering and leaving these facilities.

Impacts on National Traffic 

Potential traffic impacts on a national level were evaluated by comparing the estimated annual 

weight of spent IER shipments (full and empty casks) in each alternative to the total annual U.S. 

truck freight weight carried by tractor-trailer trucks, expressed as a percentage. The USDOT 

Bureau of Transportation Statistics estimates the freight transported annually by heavy trucks in 

the U.S. at 1.13 × 1010 metric tons per year (1.25 × 1010 tons per year) (USDOT, 2011). For the 

purposes of this evaluation, the full and empty cask weights for each cask type were 

conservatively assumed to be the same.
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5.1.2.7.2 Radiological Impacts of Routine Transportation

Potential radiological impacts from routine, incident-free transportation of spent IERs in Type A 

and Type B shipping casks were evaluated for individual receptors and for populations, for 

various scenarios involving moving and stationary trucks. Individual receptors are persons at 

various locations along transportation routes traveled by trucks carrying radioactive materials 

(e.g., spent IERs from NPPs). Populations are groups of residents along the transportation 

routes. During routine transportation, external radiation from the shipping casks used to 

transport radioactive materials, such as the spent IERS from NPPs, is the source of the 

radiation dose to the various potential receptors. In this evaluation, potential radiological 

impacts due to possible exposures of various individual human receptors to this external 

radiation, in terms of doses of radiation in mSv (or mrem), are estimated using the RADTRAN 6 

model (Weiner et al., 2009) (hereafter called the “RADTRAN model” or “RADTRAN”). For a 

radiation dose to a population, RADTRAN calculates the “collective dose” (expressed in units of 

person-mSv22), by integrating the average radiation dose over the area occupied by the 

population. RADTRAN is the nationally accepted, standard computer program for calculating 

the risks of transporting radioactive materials. 

In modeling radiological impacts from routine transportation, RADTRAN models the external 

radiation dose rate23 from the shipping cask as if the radiation were emitted from a point source 

located where the center of the cask would be. When the actual external radiation dose rate 

from the shipping cask is not specifically known, as is the case for the Type A and Type B 

shipping casks containing spent IERs in this evaluation, the maximum external dose rate for a 

shipping cask allowed by NRC regulation is used in RADTRAN to assess radiation doses to 

individuals and populations. NRC regulations allow shipping containers, or casks, that hold 

radioactive materials to emit minor amounts of ionizing radiation from the external cask 

surfaces. The Type A and Type B casks used to transport spent IERs, as all containers certified 

for use to transport radioactive materials, must meet the NRC standard for external radiation 

during normal transport. In the case of flat-bed style trucks such as those used to transport 

casks of spent IERs, by NRC regulation in 10 CFR 71.47(b)(3), the dose rate from this external 

radiation must not exceed 0.1 mSv per hour (10 mrem per hour) at a distance of 2 meters (m) 

(6.6 feet (ft)) from the vertical planes projected by the outer edges of the trailer carrying the 

cask. Basing the RADTRAN modeling on this maximum, legally allowable dose rate is 

conservative because actual dose rates from shipping casks would generally be much lower 

than the allowable limit.

The radiation doses from the various alternatives are estimated based on annual numbers of 

spent IER shipments; therefore, these estimated doses are the doses from exposures over a 

period of one year. Thus, to put the annual doses to individuals in perspective, they are 

 

22 Person-mSv is a unit of dose that represents an individual dose integrated over an area that is occupied by a 

population. It can be thought of as an average individual dose multiplied by the number of people over which it is 

averaged.

23 Radiation dose rate, or dose rate, is the radiation dose per unit time, expressed as millisieverts (mSv) per hour (or 

millirem (mrem) per hour).
5-9 

compared with the average annual U.S. background dose, from natural sources, of 

3.11 mSv/year (311 mrem/year) (NCRP, 2009), as a percentage of this background dose. For 

populations, the annual collective dose24 is compared to 3.11 mSv/year (311 mrem/year) 

multiplied by the affected population, since each member of the population sustains this annual 

average background dose. The use of the annual average U.S. natural background radiation 

level allows for the assumption that the background level would be the same for all receptors. 

Also, from the estimated radiation doses, the corresponding probabilities of fatal cancers 

resulting from exposure to these radiation doses, or latent cancer fatalities (LCFs), are derived. 

Specifically, LCFs are the expected number of additional cancer fatalities that may occur during 

the lifetime of individuals, because of (or latent to) an exposure to ionizing radiation. LCF 

values are derived by multiplying the dose by a conversion factor, 6 × 10-5 LCF per mSv 

(ISCORS, 2002). The calculated LCFs are also expressed as a fraction (percentage) of 2010 

estimated total cancer fatalities in the U.S. of 569,495 (American Cancer Society, 2010).25

Impacts on Individual Receptors 

Potential radiological impacts are calculated using RADTRAN for the following types of 

individual receptors: 

• Individual maximally exposed to a moving truck (maximally exposed individual, or MEI) 

• Average person along the transportation route: rural–suburban

• Average person along the transportation route: urban

• Average resident near a truck stop: rural–suburban26

The MEI shown above is the individual receiving the maximum exposure to a moving truck 

carrying a radioactive cargo. T he MEI is modeled as a person standing as close as possible 

(30 m from the center of the highway) to the moving truck, when the truck is moving slowly 

(about 24 kilometers per hour (kph) (15 miles per hour (mph)) past the MEI. 

Potential radiological impacts to individuals (radiation doses) calculated using RADTRAN were 

first estimated for one routine shipment of spent IERs of each cask type (full casks). The results 

of those calculations were then used to estimate the potential radiological impacts to individuals 

from all routine shipments per year for each of the six alternatives. Return trips were not 

modeled because there would be negligible or no radiological impacts from routine shipments of 

empty casks. The total annual dose for each alternative, for the various types of individual 

receptors, were calculated by multiplying the dose from a single shipment by the annual number 

of shipments carrying spent IERs (full casks). This approach is based on the conservative 

 

24 See Section A.3.2.2 for definition of collective dose.

25 2010 total estimated cancer fatalities in the U.S. derived by the American Cancer Society from U.S. mortality data, 

1969-2007.

26 Truck stops would be for rest and refueling. Truck stops are not modeled in urban areas because stops used by

trucks carrying radioactive materials would generally be away from heavily populated areas.
5-10

assumptions that (1) each individual receptor is exposed to every spent IER shipment for a 

given alternative27, and (2) the doses from exposures to multiple shipments are additive28. 

Thus, actual exposures would be lower than are estimated in this evaluation. LCFs were 

calculated from the radiation doses as discussed earlier.

Impacts on Populations

Potential radiological impacts, in terms of collective doses, from routine spent IER shipments 

(full casks) on populations were also estimated. For the six alternatives considered in this 

evaluation, the transportation routes would be between NPPs and waste processing facilities 

(for blending or volume reduction), between NPPs and LLRW disposal facilities, and between 

waste processing facilities and LLRW disposal facilities. 

The RADTRAN calculation of collective (population) dose required identification of specific 

transportation origins and destinations, and data on the route miles and populations and 

population densities for the transportation routes between these origins and destinations. For 

this analysis, a number of “representative” origins and destinations were identified for use in the 

modeling. These were selected to be representative of origins of untreated or treated 

(processed) spent IERs and destinations for spent IER processing or disposal. The 

representative origins and destinations selected, although generally based on actual, existing 

facility locations, were used for illustrative purposes only for calculating potential radiological 

impacts on populations; they were not meant to designate actual spent IER shipment origins 

and destinations for the six alternatives because actual routes cannot be identified for generic, 

non-location-specific alternatives such as those considered in this evaluation. 

TRAnsportation Geographic Information System, the routing code maintained by Oak Ridge 

National Laboratory (Johnson and Michelhaugh, 2003), is typically used to provide 

transportation route parameters for use in RADTRAN. However, for this evaluation, the choice 

of representative origins and destinations and corresponding transportation routes between 

them was severely constrained because TRAGIS is shut down and unavailable for an 

undetermined time period (Johnson, 2011). TRAGIS, when available, provides the most recent 

census data of population densities along routes, a listing of every road and every intersection 

by highway route number, and the rural, suburban, and urban fractions of the total routes 

through each state. Thus, since TRAGIS was not available, representative transportation 

origins and destinations and corresponding transportation routing data were constructed from, 

and limited by, the availability of relevant information on transportation routes in the library of 

TRAGIS routings maintained by SNL. Within these constraints, transportation origins and 

destinations were selected to allow for the analysis of potential radiological impacts to 

populations along a range of transportation routes spanning the U.S. Potential radiological 

 

27 In actual practice, this would not occur since not all individuals would be located in the same place at the same 

time over a period of one year. 

28 In reality, multiple radiation doses over time are not additive. For example, in calculating medical therapeutic and 

diagnostic doses, the patient’s prior history of radiation exposure is not usually considered or summed (Shleien et al., 

1998; Chapter 10).
5-11

impacts on populations from routine transportation were separately estimated for moving trucks 

and for trucks at rest and refueling stops. 

• Impacts from Moving Trucks. Potential radiological impacts to populations from routine, 

incident-free movement of spent IER shipments along transportation routes defined by 

representative origins and destinations were estimated for each alternative. The 

collective dose from a spent IER shipment (full cask) for each representative 

transportation route was calculated as the sum of the collective doses for the rural, 

suburban, and urban route segments in all of the states traversed on the route. This 

summed result was multiplied by the number of spent IER shipments (full casks) per 

alternative to obtain the total collective doses for each of the six alternatives. 

• Impacts from Trucks at Rest and Refueling Stops. Truck stops that serve the 18-wheel 

tractor-trailer trucks that carry Type A or Type B casks containing spent IERs would 

mostly be located in rural or suburban areas near freeway access ramps. Each truck 

stop is surrounded by a different resident population. The analysis conservatively 

assumed that the resident population at each truck stop would be exposed to all of the 

shipments in each alternative. Potential radiological impacts to populations residing 

near the truck stops were estimated for each alternative based on such factors as 

numbers of truck stops on each representative transportation route, population densities 

near the truck stops in rural and suburban setting along these routes, sizes of areas 

where potentially affected populations would reside, previously estimated individual 

external doses, and numbers of spent IER shipments (full casks) by alternative. 

5.1.2.7.3 Non-radiological and Radiological Impacts of Transportation Accidents 

Trucks carrying spent IERs or empty casks are as likely to be involved in traffic accidents as any 

other similar heavy trucks. Potential non-radiological and radiological impacts of transportation 

accidents as a result of traffic collisions involving trucks carrying spent IER shipments were 

evaluated. Non-radiological impacts of transportation accidents were measured in terms of the 

number of traffic accidents and the number of traffic accident fatalities from the transport of both 

full and empty casks. Radiological impacts were assessed from traffic accidents in involving 

trucks carrying full shipping casks of spent IERs, under scenarios in which radioactive materials 

are and are not released from the casks. 

Non-radiological Impacts 

In this evaluation, non-radiological impacts of transportation accidents were assessed in terms 

of the estimated number of traffic accidents and number of traffic accident fatalities from 

shipments of spent IERs in each alternative. These potential impacts were estimated using 

tractor-trailer truck traffic accident and accident fatality rate information (adapted from 2009 

USDOT (2010; 2011) state and national transportation statistics, the most recent data 

available), coupled with the total distances driven under each alternative with full and empty 

casks. To put the estimated potential non-radiological impacts in perspective, the annual 

numbers of potential truck accidents and associated traffic accident fatalities for each alternative 
5-12

were compared with the annual total numbers of tractor-trailer truck accidents and accident 

fatalities in the U.S., respectively, as reported by USDOT (2011).

Radiological Impacts 

The potential radiological impacts (consequences) of two types of transportation accidents 

involving the transport of untreated and treated (processed) spent IERs in Type A and Type B 

shipping casks (full casks) were evaluated: (1) accidents in which there is no impact on the 

cask and, therefore, no release of radioactive material; and (2) accidents in which there is an 

impact on the cask, and radioactive material could be released. The distinction between the two 

types of accidents is made because more than 91 percent of all accidents involving trucks 

carrying radioactive material and more than 99 percent of accidents involving Type B casks do 

not result in any damage to the cargo and therefore would not involve a release of radioactive 

material (NRC, 1977; Table 5-3; Sprung, et al, 2000; Chapter 7, pp. 7-73 to 7-76). 

• Accidents with No Release of Radioactive Materials. For accidents in which there is no 

impact on the shipping cask, the collective radiation dose and corresponding LCF are 

calculated using RADTRAN for all representative transportation routes and alternatives. 

The dose to the nearest member of the public (the MEI) and corresponding LCF are also 

calculated, which would be the same regardless of transportation route, accident 

location, or alternative. In addition to comparing the collective LCFs with 2010 total 

estimated U.S. cancer fatalities, they are measured against the potential traffic fatality 

risks from spent IER shipments for the same routes and alternatives (i.e., the nonradiological impacts of traffic accidents from above) to compare predicted cancer deaths 

from radiological exposures to truck accident-related fatalities from non-radiological 

causes. Since no radioactive materials would be released, exposure would be from the 

external radiation from the casks; and the analysis is conservatively based on the 

legally-defined maximum external dose rates from the Type A and Type B casks, which 

are the same for both cask types (see Section 5.1.2.7.2). Further, the modeling is 

conducted based on a suburban truck stop because that is more conservative than 

modeling for a rural truck stop (due to higher populations near suburban truck stops). 

However, the time at the accident location would be longer than at a normal truck rest 

and refueling stop because the accident may require removal of the cask, either by 

transferring it by crane to another vehicle or by removing the truck and cask from the 

accident scene. Considering the size and weight of the full casks (see Table A-1 in 

Appendix A), it could take several hours to bring appropriate equipment for this purpose 

to the accident location; and 10 hours is assumed for the RADTRAN assessment.

• Accidents in Which Radioactive Material Could Be Released. The analysis separately 

examined the consequences of accidents involving Type A and Type B casks in which 

radioactive material could be released. Due to design differences between these two 

types of shipping casks and the different classes of waste they would carry, the 

consequences of accidents involving these two cask types would be different. Type A 

casks are the least robust in design of the two and, therefore, more likely to be damaged 

in an accident, but would carry the lower activity Class A spent IERs. Type B casks, 
5-13

which would carry the higher activity Class B and C resins, are very robust and designed 

to withstand severe accidents. Accident consequences were examined separately for 

accidents involving spent IERs from BWRs and PWRs because the radionuclide 

inventories from these two sources could be different and the public would be exposed 

to the actual radionuclide inventory.29 Note also that accident consequences for each 

cask type are evaluated for a single accident of each kind and not for each of the six 

alternatives. This is because, as illustrated in Section A.3.3.1 of Appendix A, the 

numbers of tractor-trailer truck accidents that occur is extremely low, and the likelihood 

of even one such accident occurring is extremely small. 

o Accidents in Which a Type A Cask Would Be Impacted—For Type A casks, the 

analysis examined the potential impact on members of the public if a cask of this 

type is in an accident that is severe enough to damage and expose the public to 

the entire spent IER contents of the cask. The radionuclide inventory that can be 

carried in a Type A cask is limited by regulation; specifically, the radionuclide

inventory that can be transported in a Type A cask cannot not exceed the A2

value defined in 10 CFR 71, Appendix A, Table A-1. The A2 values were 

calculated using the “Q system” defined by the International Atomic Energy 

Agency (IAEA, 2002b; Appendix I, Section I.11, pp. 216 et seq.), which is based 

on a set of exposure scenarios called the “Q series”. The Q system defines the 

quantity limits of radionuclides (e.g., in terms of A2 values) that are allowed in a 

Type A package. The present analysis uses the Q system to define the basis for 

exposure to a release of spent IERs from a Type A cask severely damaged in a 

transportation accident. The IAEA Q system is based on a person exposed to an 

A2 quantity of radioactive material receiving a radiation dose no greater than 

50 mSv (5000 mrem) if that person is located one meter from the A2 quantity for 

30 minutes. Thus, if a Type A cask carrying an A2 quantity of material is in an 

accident so severe that a person standing one meter from the cask is exposed to 

the entire contents of the cask for 30 minutes, he or she would receive a dose of 

ionizing radiation that is at most 50 mSv. This information was used to calculate 

the dose to a receptor at a specific distance from the source (e.g., the A2 amount 

potentially released from a damaged Type A cask in an accident) for a specific 

period of time. Radiation dose is inversely proportional to the square of the 

distance of the receptor from the radiation source and directly proportional to the 

amount of the receptor time spends at that distance. The dose to a receptor is 

also directly proportional to the total radioactivity to which the receptor is 

exposed. 

o Accidents in Which a Type B Cask May Be Impacted—Spent IERs that exceed 

the A2 limit must be carried in Type B casks. Type B casks are designed to be 

sufficiently robust that they are not likely to be damaged in a traffic accident 

(10 CFR 71.73). Release of radioactive material from a Type B cask could occur 

 

29 Radionuclide inventory is the list of radionuclides in a particular material and the activity of each, expressed in 

curies.
5-14

only in accidents considerably worse than almost all traffic accidents. Such 

accidents would involve extremely severe impacts of casks onto hard targets, or 

a very long-lasting, very hot fire, or both. Even such extreme conditions would 

not damage the body of the cask, and releases of radioactive material, if any, 

could occur only through the cask seals and then only in very small quantities 

(Sprung et al., 2000; Chapters 7 and 8). Thus, the only way in which spent IER 

material released from a Type B cask could result in a radiation dose to a 

member of the public is if the material could be dispersed from damaged cask 

seals as very small, aerosol-sized particles. From among the six alternatives, the 

only spent IERs that could potentially be released through damaged Type B cask 

seals as aerosolized particles could be those that are thermally processed 

(blended or volume-reduced) and transported to a waste disposal site in 

Alternatives 1B, 4A, and 4B. These thermally processed resins would be the 

only materials to be transported that would be dry (water free) and in powdery, 

small particle form that might be aerosolized. 

There is no published model for the accidental release of spent IERs, or similar 

LLRW, in aerosolized form from damaged seals of a Type B cask. The only 

current published model of such releases of radioactive material from a Type B 

cask is that of potential release of NPP spent nuclear fuel particles and of 

corrosion products that are on the outer surface of SNF elements (Sprung et al., 

2000; Chapter 7). This model was adapted for in this analysis and used in 

association with the RADTRAN accident model to assess potential radiological 

impacts of spent IER releases from Type B casks.30 Following the practice first 

used by the NRC in NUREG-0170, “Final Environmental Impact Statement for 

the Transportation of Radioactive Material by Air and Other Modes” (NRC, 1977), 

and used subsequently in other environmental impact assessments and studies 

of this type (Fischer et al., 1987; Sprung, et al, 2000; DOE, 2002, Appendix J), 

six different types of accidents, of varying severity and a range of release 

fractions31, were postulated in this analysis. These accident scenarios are 

intended to include most of the extremely severe transportation-related accidents 

possible (DOE, 2002, Appendix J). The RADTRAN accident analysis was 

conducted only for the most severe accident scenario (truck fire exposing the 

cask with high-speed impact into hard target) because that is the scenario with 

the highest release fraction of the six and, therefore, would yield the most 

conservative impact analysis results. 

 

30 It is important to note that although there may be certain physical similarities between thermally processed spent 

IERs and spent nuclear fuel (SNF) particles and corrosion products that allow us to apply this model in this case, the 

radioactivity levels of the Class A, B, and C LLRW spent IERs are orders of magnitude lower than that of SNF 

materials. For example, Cesium-137 (Cs-137) is present in SNF in concentrations on the order of 105 Ci per fuel 

assembly (DOE, 2002; Appendix A, Tables A-8 and A-9), whereas the Ci content of Cs-137 in a spent IER shipment 

in a Type B cask would be about one curie or less and the total curie content in a Type B cask carrying BWR Class B 

and C resins would be about 52 Ci (see Table A-21, Section A.3.3.2.2 of Appendix A). 

31 Release fraction is the fraction of total radioactivity in the cask released for a particular accident scenario. 
5-15

5.1.2.8 Waste Management

Waste management impacts consist of the effects of generation, management, storage, and 

preparation for offsite disposal of wastes on safety, regulatory compliance, or waste storage, 

treatment, and disposal capacities. Wastes generated in performance of activities in each of the 

six alternatives may include radioactive, hazardous, mixed radioactive and hazardous, and 

nonhazardous solid waste, and process wastewater. The handling and disposal of waste 

materials are governed by various Federal, State, and local regulations. Waste management 

programs in place at operating facilities are generally intended to minimize the generation of 

waste through reduction, reuse, and recycling, and include systems and procedures for the 

collection, removal, and proper disposal of waste materials.

The waste management evaluation in this report, a subpart of the full evaluation, examined how 

each component activity of each of the alternatives could add to or alter existing waste and 

materials management operations (e.g., land disposal facilities). Adverse impacts could result 

from reduction in physical safety, non-adherence to regulatory requirements, or significant 

reduction of waste storage, treatment, or disposal capacities. 

Note that the analysis of waste management impacts in this report specifically addresses 

wastes that are “incidental” to the management of spent IERs, as impacts from the management 

of spent IERs are the focus of this entire evaluation. As discussed in Section 2.1.3, the 

commercial NPP spent IERs themselves account for only about 4 percent of the total volume of 

commercial LLRW generated in the U.S. annually and, therefore, disposal of these wastes 

would have a relatively small impact on U.S. LLRW disposal capacity.

5.1.2.9 Water Resources

Impacts on water resources could consist of the potential effects on the groundwater and the 

surface water system at and in the vicinity of a project or facility. Adverse effects could include 

degradation of water quality and reduction of water supply.

The evaluation of water resource impacts in this report assessed the potential effects on 

groundwater and surface water quality and water supply (water use). This evaluation 

considered activities that could degrade groundwater or surface water quality, alter drainage 

patterns, or change the quantity of groundwater or surface water resulting in altered water table 

or surface water body characteristics and water supply availability.

5.1.3 Mitigation Measures for Potential Environmental Impacts

As discussed in Section 3.2, the analytical approach also includes consideration of whether 

generally accepted impact mitigation measures could reduce adverse environmental impacts in 

the various resource and impact areas, and accounts for applicable mitigation measures in 

assessing potential impacts. Examples of typical impact mitigation measures that could be 

implemented are listed in Table 4 for each resource or impact area. 
5-16

Since this evaluation focuses mainly on the impacts of operations at existing facilities, many of 

the mitigation measures listed in Table 4 relate to operations at the NPPs, spent IER processing 

facilities, long-term spent IER storage facilities, or LLRW disposal facilities, although some of 

the measures listed would apply to mitigation of impacts during construction of long-term spent 

IER storage facilities (Alternatives 3 and 4A) and for transportation of untreated and treated 

(processed) spent IERs. Also, as discussed in Section 3.2, it is assumed for the purposes of 

this evaluation that all activities in the six alternatives would be in compliance with applicable 

Federal, State, and local legal and regulatory requirements. This means that all necessary 

equipment and procedures would be in place for licensed or permitted activities at all of the 

NPPs and spent IER storage, processing, and disposal facilities, and during shipment of spent 

IERs between these facilities, for protection of human health and the environment. The actual 

mitigation measures and regulatory controls employed would vary depending upon the activities 

and processes at specific geographic locations and in specific environmental settings, and 

based on factors such as feasibility of implementation, effectiveness, reliability, and cost.

5.1.4 Evaluation of Potential Impacts

Potential environmental impacts of the six alternatives are described and compared in Table 5. 

The environmental impact assessments are presented in tabular format to facilitate a concise 

discussion and comparison of potential impacts of the alternatives in each resource or impact 

area. 

As discussed in Section 3.2, the assessment of potential impacts in this evaluation is qualitative, 

except for the assessment of transportation impacts, which is largely quantitative. Further, with 

the exception of transportation-related accidents, impacts of accidents and other off-normal 

conditions are not considered, for reasons discussed in Section 3.3. Other resource and impact 

areas not included in the impact evaluation in Table 4 are also identified in Section 3.3. Note 

also that, as discussed in Section 3.2, the six alternatives are assumed to be implemented at 

existing NPPs, spent IER processing facilities, and LLRW disposal facilities, and within existing 

facility footprints and site boundaries and licensed and permitted scopes of operations at those 

facilities.

Note also that as discussed earlier, conservative, often bounding assumptions are made 

throughout the evaluation, consistent with the generic, non-location-specific alternatives 

evaluated. Thus, in actual practice, any potential environmental effects associated with the six 

alternatives would, for the most part, be expected to be lower in magnitude than those 

described in this report.

Section 5.2 (Summary and Discussion of Comparative Environmental Evaluation) follows 

Tables 4 and 5 below.
5-17

Table 4 Examples of Typical Mitigation Measures for Potential Environmental Impacts of Component Activities

Comprising the Six Alternatives for Handling LLRW Spent Ion Exchange Resins

RESOURCE OR

IMPACT AREA MITIGATION MEASURES

APPLIES TO:

Processing

Facility 

Operations

Waste 

Storage 

Facility

Construction

Waste 

Storage 

Facility 

Operations

Waste

Transportation

Waste 

Disposal

Air Quality

Maintenance of internal combustion 

engines and their pollution control devices 

in good working order

X X X X 

Use of engineered controls to minimize 

radiological and non-radiological air 

emissions or concentrations (e.g., off-gas 

systems, HEPA filters, air handling 

systems, containment)

X X X

Prompt cleanup of all spilled materials X X X X X

Watering of soils to control fugitive dust X X

Ecological 

Resources

Use of native plant species to re-vegetate 

disturbed areas and enhance wildlife 

habitat

X X 

Implementation of recommendations of 

Federal and State natural resource 

agencies, e.g., USFWS

X X

Scheduling of construction activities to 

minimize disturbance to protected wildlife 

species

X X
5-18

Table 4 Examples of Typical Mitigation Measures for Potential Environmental Impacts of Component Activities

Comprising the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR

IMPACT AREA MITIGATION MEASURES

APPLIES TO:

Processing

Facility 

Operations

Waste 

Storage 

Facility

Construction

Waste 

Storage 

Facility 

Operations

Waste

Transportation

Waste 

Disposal

Historic and 

Cultural 

Resources

Training of workers on the regulations 

governing protection of cultural resources X X 

Use of onsite cultural resource monitors 

during ground disturbing activities X X

Implementation of procedures to address 

unexpected discoveries of archaeological 

materials and human remains

X X

Development of specific mitigation 

measures in the event of discovery of 

resources eligible for listing on the National 

Register of Historic Places (e.g., 

professional excavation and data recovery)

X X

Noise

Use of engineered and administrative 

controls for equipment noise abatement 

(e.g., equipment and vehicle mufflers, 

acoustic baffles, shrouding, barriers, noise 

blankets)

X X X X X 

Mitigation of operational noise sources by 

facility design, whereby cooling systems, 

valves, transformers, pumps, generators, 

and other equipment are located mostly 

within plant structures and the buildings 

absorb or contain the majority of the noise

X

Establish preventative maintenance 

programs that ensure all equipment is 

working at peak performance

X X X X
5-19

Table 4 Examples of Typical Mitigation Measures for Potential Environmental Impacts of Component Activities

Comprising the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR

IMPACT AREA MITIGATION MEASURES

APPLIES TO:

Processing

Facility 

Operations

Waste 

Storage 

Facility

Construction

Waste 

Storage 

Facility 

Operations

Waste

Transportation

Waste 

Disposal

Public and 

Occupational 

Health

Facility design features to minimize 

gaseous and liquid effluent releases, and 

maintain the impacts to workers and 

surrounding populations below regulatory 

limits

X X X 

Use of administrative controls, practices, 

and procedures (including training) to 

ensure compliance with an established 

Health, Safety, and Environmental Program

X X X X X

Implementation of radiological practices 

and procedures to achieve and maintain 

radiological exposure to levels that are as 

low as reasonably achievable (ALARA)

X X X X X

Conduct of routine facility radiation and 

radiological surveys to characterize and 

minimize potential radiological dose and 

exposure

X X X X

Monitoring of all radiation workers by use of 

dosimeters and area air sampling to ensure 

that radiological doses remain within 

regulatory limits and are ALARA

X X X X X

Environmental surveillance to ensure public 

safety X X X X

Implementation of other maintenance and 

monitoring procedures, as applicable. X X X X 
5-20

Table 4 Examples of Typical Mitigation Measures for Potential Environmental Impacts of Component Activities

Comprising the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR

IMPACT AREA MITIGATION MEASURES

APPLIES TO:

Processing

Facility 

Operations

Waste 

Storage 

Facility

Construction

Waste 

Storage 

Facility 

Operations

Waste

Transportation

Waste 

Disposal

Soil

Follow requirements of Spill Prevention 

Control and Countermeasures (SPCC) 

Plan to reduce the potential impacts from 

chemical spills or releases

X X X X 

Follow waste management procedures to 

minimize impacts on soils from solid waste 

and hazardous materials

X X X X X

Implementation of soil sampling program to 

check for deposition of contaminants 

released from the facility via airborne 

pathways

X X

Use of best management practices (BMPs) 

to reduce soil erosion (e.g., earth berms, 

dikes, sediment fences)

X X

Re-vegetate or cover bare areas with 

natural materials promptly X

Reuse excavated materials whenever 

possible X X

Transportation

Scheduling of waste and return shipments 

to minimize impacts on local roadways X 

Perform regular vehicle inspections X 

Adhere to all regulatory requirements 

related to transportation of radioactive and 

hazardous materials

X 
5-21

Table 4 Examples of Typical Mitigation Measures for Potential Environmental Impacts of Component Activities

Comprising the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR

IMPACT AREA MITIGATION MEASURES

APPLIES TO:

Processing

Facility 

Operations

Waste 

Storage 

Facility

Construction

Waste 

Storage 

Facility 

Operations

Waste

Transportation

Waste 

Disposal

Waste 

Management

Design and implementation of system 

features and practices to minimize 

generation of solid waste, liquid waste, and 

gaseous effluent

X X X 

Storage of waste only in designated areas 

of the facility X X X X

Shipment of incidental waste offsite to 

licensed disposal facilities X X X 

Control of process effluents by careful 

application of basic principles for waste 

handling in all systems and processes

X

Segregation of different waste types in 

separate containers to minimize 

contamination of one waste type with 

another

X X X

Administrative procedures and practices in 

waste management systems that provide 

for collection, temporary storage, 

processing, and disposal in accordance 

with BMPs and regulatory requirements

X X X X
5-22

Table 4 Examples of Typical Mitigation Measures for Potential Environmental Impacts of Component Activities

Comprising the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR

IMPACT AREA MITIGATION MEASURES

APPLIES TO:

Processing

Facility 

Operations

Waste 

Storage 

Facility

Construction

Waste 

Storage 

Facility 

Operations

Waste

Transportation

Waste 

Disposal

Water 

Resources

Use of low-water consumption practices X X X 

Incorporation of closed-loop cooling 

systems eliminating evaporative losses X

Employing BMPs to control the use of 

hazardous materials and fuels X X X X X

Control and mitigation of spills in 

conformance with SPCC plans X X X X

Ensure all discharges meet the standards 

for stormwater management X X X X

Handle any hazardous materials by 

approved methods and ship offsite to 

approved disposal sites

X X X X
5-23

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME 

REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

AIR QUALITY: 

Radiological

SMALL. Minimal or no 

radioactive air emissions 

and associated impacts 

would be expected during 

handling, transport, and 

disposal of spent ion 

exchange resins (IERs), 

primarily because of safety 

procedures implemented 

during these activities and 

the types of waste 

containers, shipping casks, 

and disposal methods used.

There would be source 

radioactive air emissions 

from the mechanical mixing 

(blending) process, but 

these emissions would be 

within regulatory limits 

because stack emissions 

must comply with the 

National Emissions 

Standards for Hazardous air 

Pollutants (NESHAPs) and 

other permit or license 

requirements, with 

emissions controls 

employed as necessary. 

Note also that these 

emissions would be 

expected to be less than 

those from the thermal 

SMALL. Radiological 

air emissions 

impacts during spent 

IER handling, 

transport, and 

disposal would be 

similar to those 

described for

Alternative 1A.

There would be 

source radioactive 

air emissions from 

blending by thermal 

processing, which 

would be expected 

to be greater than 

those from blending 

by mechanical 

mixing (Alternative 

1A) due to increased 

volatilization in the 

thermal (heating) 

process. However, 

emissions controls 

would be employed 

to maintain 

compliance with 

NESHAPs and other 

permit or license 

requirements.

SMALL. Radiological 

air emissions 

impacts during spent 

IER handling, 

transport, and 

disposal would be 

similar to those 

described for 

Alternative 1A. This 

alternative involves 

no waste processing 

and associated 

radiological air 

emissions.

SMALL. Radiological air 

emissions impacts during 

spent IER handling, 

transport, and disposal 

would be similar to those 

described for Alternative 1A. 

This alternative involves no 

waste processing and 

associated radiological air 

emissions.

There would be no 

radiological air emissions 

resulting from construction 

of the onsite long-term 

spent IER storage areas at 

the 65 nuclear power plants 

(NPPs) because no 

radioactive materials would 

be used during construction. 

Maintenance and monitoring 

of these storage facilities, 

when in use, would serve to 

minimize any radiological air 

emissions.

SMALL. Radiological air 

emission impacts during 

spent IER handling, 

transport, thermal 

processing (volume 

reduction), and disposal 

would be similar to those 

described for Alternative 1B 

because these alternatives 

employ similar thermal 

processing technologies, 

and all other component 

activities of the two 

alternatives would be 

essentially the same. 

There would be no 

radiological air emissions 

resulting from construction 

of the onsite long-term 

spent IER storage area at 

the waste disposal site 

because no radioactive 

materials would be used 

during construction. 

Maintenance and monitoring 

of the storage facility, when 

in use, and the stabilized 

nature of the waste form in 

storage, would serve to 

minimize any radiological air 

emissions.

SMALL. Radiological 

air emissions during 

spent IER handling, 

transport, thermal 

processing (volume 

reduction), and 

disposal would be 

similar to those 

described for 

Alternative 1B because 

these alternatives 

employ similar thermal 

processing 

technologies, and all 

other component 

activities of the two 

alternatives would be 

essentially the same.
5-24

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

AIR QUALITY: 

Radiological

(Cont.)

processing alternatives 

(1B, 4A, and 4B) that 

involve heating of the 

spent IERs and resulting 

increased volatilization.

AIR QUALITY: 

Non-radiological

(NOTE: Nonradiological air 

quality impacts 

associated with 

the transport of 

spent IERs are 

addressed later in 

this table, under 

Transportation: 

Local and National 

Traffic.)

SMALL. Minor impacts 

from emissions of nonradiological air pollutants 

would result from 

equipment usage for spent 

IER handling at the NPPs 

and the mechanical mixing 

(blending) and disposal 

facilities, as exhaust 

concentrations must 

comply with National 

Ambient Air Quality 

Standards (NAAQS), 

NESHAPs, Occupational 

Safety and Health 

Administration (OSHA), 

and other permit or license 

requirements. Emissions 

controls and other 

measures would be used 

to minimize air emissions 

from this equipment. 

Non-radiological air 

emissions from the 

mechanical mixing 

SMALL. Nonradiological air 

emissions impacts 

during spent IER 

handling, and 

disposal would be 

similar to those 

described for 

Alternative 1A.

There would be 

non-radiological air 

emissions from 

blending by thermal 

processing, which 

would be expected 

to be greater than 

those from blending 

by mechanical 

mixing (Alternative 

1A) due to 

increased 

volatilization in the 

thermal (heating) 

process. Filtration 

systems would be 

SMALL. Nonradiological air 

emissions impacts 

during spent IER 

handling, and 

disposal would be 

similar to those 

described for 

Alternative 1A. This 

alternative involves 

no waste processing 

and associated nonradiological air 

emissions.

SMALL. Non-radiological 

air emissions impacts 

during spent IER handling, 

and disposal would be 

similar to those described 

for Alternative 1A. This 

alternative involves no 

waste processing and 

associated non-radiological 

air emissions.

Construction of small, 

onsite facilities for longterm storage of spent IERs 

would take place at 65 

NPPs, at geographically 

dispersed locations 

nationwide. At each NPP, 

impacts from construction 

equipment emissions (i.e., 

vehicle exhaust) on air 

quality and worker and 

public health would be 

minor because exhaust 

concentrations would 

comply with NAAQS, 

SMALL. Non-radiological 

air emissions impacts 

during spent IER handling, 

thermal processing 

(volume reduction), and 

disposal would be similar 

to those described for 

Alternative 1B because 

these alternatives employ 

similar thermal processing 

technologies, and all other 

component activities of the 

two alternatives would be 

essentially the same.

Construction of a relatively 

small, long-term spent IER 

storage facility at the waste 

disposal site would be 

required. Impacts from 

construction equipment 

emissions on air quality 

and worker and public 

health would be minor 

because exhaust 

concentrations would 

SMALL. Impacts of air 

emissions during waste 

handling, thermal 

processing (volume 

reduction), and disposal 

would be similar to 

those described for 

Alternative 1B because 

these alternatives 

employ similar thermal 

processing 

technologies, and all 

other component 

activities of the two 

alternatives would be 

essentially the same.
5-25

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

AIR QUALITY: 

Non-radiological

(Cont.) 

(blending) process 

equipment would be minor 

because the blending 

process is conducted at 

ambient temperatures, and 

any emissions must 

comply with NAAQS, 

NESHAPs, and other 

permit or license 

requirements, with 

emissions controls 

employed as necessary. 

Note also that these 

emissions would be 

expected to be less than 

those from the thermal 

processing alternatives 

(1B, 4A, and 4B) that 

involve heating of the 

spent IERs and resulting 

increased volatilization.

Best management 

practices (BMPs) would be 

employed to minimize 

fugitive dust generation 

during spent IER disposal 

operations at the LLRW 

disposal facility.

employed at the 

thermal processing 

facility to control air 

emissions, and 

stack emissions 

must comply with 

NAAQS, NESHAPs, 

and other permit or 

license 

requirements.

NESHAPs, OSHA, and 

other permit or license 

requirements. Emissions 

controls and other 

measures would be 

employed to minimize air 

emissions from the 

equipment. BMPs would be 

used to minimize fugitive 

dust generation. Any 

impacts would be 

temporary and intermittent 

in nature over the short 

duration of construction of 

the small storage facilities. 

Also, construction activities 

would comply with 

applicable license and 

permit requirements. For 

the most part, since the 65 

NPPs are located in 

separate regions of 

influence (ROIs) for air 

emissions, construction of 

the storage facilities 

generally would not result 

in cumulative air quality 

impacts due to construction 

of multiple storage facilities 

in the same air quality ROI.

comply with NAAQS, 

NESHAPs, OSHA, and 

other permit or license 

requirements. Emissions 

controls and other 

measures would be 

employed to minimize air 

emissions from the 

equipment. BMPs would 

be used to minimize 

fugitive dust generation. 

Any impacts would be 

temporary and intermittent 

in nature over the relatively 

short duration of 

construction of the spent 

IER storage area. Also, 

construction activities 

would comply with 

applicable license and 

permit requirements. Since 

it is likely that this waste 

storage facility would be 

constructed in increments 

(stages) rather than all at 

once, air quality impacts at 

each stage would be 

smaller than those for 

construction of the entire 

storage facility at one time. 
5-26

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

AIR QUALITY: 

Non-radiological

(Cont.) 

Maintenance and

monitoring of the long-term 

spent IER storage facilities, 

when in use at the 65 

NPPs, would serve to 

minimize any nonradiological air emissions.

Maintenance and 

monitoring of the long-term 

spent IER storage facility, 

when in use at the waste 

disposal site, and the 

stabilized nature of the 

waste form, would serve to 

minimize any nonradiological air emissions. 

ECOLOGICAL 

RESOURCES

SMALL. The existing NPPs 

and mechanical mixing 

(blending) and disposal 

facilities would operate 

within existing facility 

footprints. There would be 

little or no additional 

ground disturbance or 

other activities during 

spent IER handling and 

processing and none 

during spent IER transport. 

Thus, impacts on wildlife 

and plants from these 

operations would be 

minimal.

Any air emissions and 

wastewater discharges 

would be within regulatory 

limits, and noise mitigation 

measures would keep 

SMALL. Impacts to 

ecological 

resources from 

spent IER handling, 

thermal processing 

(blending), 

transport, and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. Impacts to 

ecological resources 

from spent IER 

handling, transport, 

and disposal 

activities would be 

similar to those 

described for 

Alternative 1A.

SMALL. Impacts to 

ecological resources from 

spent IER handling, 

transport, and disposal 

activities would be similar 

to those described for 

Alternative 1A.

Construction of the small, 

onsite spent IER storage 

facilities would occur within 

existing, operating NPP 

footprints and boundaries. 

These storage facilities 

would occupy very small 

areas in comparison to 

current NPP site footprints 

(i.e., about 0.04-0.07% of 

total NPP site areas, on 

average; see Section 

4.2.4), and thus would 

affect only very small areas 

SMALL. Impacts to 

ecological resources from 

spent IER handling, 

thermal processing 

(volume reduction), 

transport, and disposal 

activities would be similar 

to those described for 

Alternative 1A. 

Construction of a long-term 

spent IER storage facility 

would occur at an existing, 

operating waste disposal 

site. This storage facility 

would occupy a relatively 

small area in comparison 

to the waste disposal 

facility footprint (i.e., less 

than 1% of total waste 

disposal facility site areas 

see Section 4.2.5), and 

SMALL. Impacts to 

ecological resources 

from spent IER 

handling, thermal 

processing (volume 

reduction), transport, 

and disposal activities 

would be similar to 

those described for 

Alternative 1A.
5-27

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

ECOLOGICAL 

RESOURCES

(Cont.)

noise levels and any 

associated ecological 

impacts to a minimum.

of land. Impacts to 

ecological resources, if any, 

would be minimized 

through threatened and 

endangered (T&E) species 

surveys, consultation with 

the U.S. Fish and Wildlife 

Service (USFWS) and 

corresponding State 

agencies, and avoidance or 

mitigation, where possible. 

Impacts, if any, might be 

greater than for Alternatives 

1A, 1B, 2, and 4B, in which 

no such construction would 

occur. 

No additional ecological 

impacts would be expected 

during operation of the 

long-term spent IER 

storage facilities at the 

NPPs.

thus would affect only a 

very small area of land. 

Impacts to ecological 

resources, if any, would be 

minimized through T&E 

species surveys, 

consultation with the 

USFWS and 

corresponding State 

agencies, and avoidance 

or mitigation, where 

possible. Impacts, if any, 

might be greater than for 

Alternatives 1A, 1B, 2, and 

4B, in which no such 

construction would occur. 

No additional ecological 

impacts would be expected 

during operation of the 

long-term spent IER 

storage facility.

HISTORIC AND 

CULTURAL 

RESOURCES

SMALL. The existing NPPs 

and mechanical mixing 

(blending) and disposal 

facilities would be 

operating within existing 

facility footprints. There 

would be minimal or no 

additional ground 

SMALL. Impacts to 

historic and cultural 

resources from 

spent IER handling, 

thermal processing 

(blending), 

transport, and 

disposal activities 

SMALL. Impacts to 

historic and cultural 

resources from 

spent IER handling, 

transport, and 

disposal activities 

would be similar to 

those described for 

SMALL. Impacts to historic 

and cultural resources from 

spent IER handling, 

transport, and disposal 

activities would be similar 

to those described for 

Alternative 1A.

SMALL. Impacts to historic 

and cultural resources from 

spent IER handling, 

thermal processing 

(volume reduction), 

transport, and disposal 

activities would be similar 

to those described for 

SMALL. Impacts to 

historic and cultural 

resources from spent 

IER handling, thermal 

processing (volume 

reduction), transport, 

and disposal activities 

would be similar to 
5-28

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

HISTORIC AND 

CULTURAL 

RESOURCES

(Cont.) 

disturbance during spent 

IER handling and 

processing and none 

during spent IER transport. 

Therefore, no destruction 

of, or other adverse effects 

on, historic or cultural 

resources would be 

expected as a result of 

these activities. 

would be similar to 

those described for 

Alternative 1A.

Alternative 1A. SMALL to MODERATE. 

Construction of the small, 

onsite spent IER storage 

facilities would occur within 

existing NPP sites. Historic 

and cultural resources 

eligible for listing on the 

National Register of 

Historic Places (NRHP), if 

any, would be identified 

through cultural resource 

inventories and surveys 

and subsequently avoided, 

minimized, or mitigated 

according to requirements 

of the National Historic 

Preservation Act (NHPA) 

Section 106 regulations 

and through consultations 

with State Historic 

Preservation Officers 

(SHPOs) and Tribal Historic 

Preservation Officers 

(THPOs), as appropriate. 

However, due to the small 

sizes of these new storage 

facilities (see Section 

4.2.4), impacts could likely 

be avoided. No additional 

impacts to historic and 

cultural resources would be 

Alternative 1A.

SMALL to MODERATE. 

Construction of a relatively 

small long-term spent IER 

storage facility would occur 

at an existing waste 

disposal site. Historic and 

cultural resources eligible 

for listing on the NRHP 

would be identified through 

cultural resource 

inventories and surveys 

and subsequently avoided, 

minimized, or mitigated 

according to requirements 

of the NHPA Section 106 

regulations and through 

consultations with the 

SHPO and THPO, as

appropriate. However, due 

to the small size of the new 

storage facility (see 

Section 4.2.5), impacts 

could likely be avoided. No 

additional impacts to 

historic and cultural 

resources would be 

expected during operation 

of the long-term spent IER 

storage facility.

those described for 

Alternative 1A.
5-29

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

HISTORIC AND 

CULTURAL 

RESOURCES

(Cont.) 

expected during operation 

of the long-term spent IER 

storage facilities.

NOISE

(NOTE: Noise 

impacts 

associated with

the transport of 

spent IERs are 

addressed later in 

this table, under 

Transportation: 

Local and National 

Traffic.) 

SMALL. Noise resulting 

from spent IER handling, 

mechanical mixing 

(blending), and disposal 

would occur at existing, 

licensed facilities in 

compliance with applicable 

noise regulations, and 

noise mitigation measures

would typically be 

employed where 

necessary.

SMALL. Impacts 

from noise 

generated by spent 

IER handling, 

thermal processing 

(blending), and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. Impacts 

from noise 

generated by spent 

IER handling, and 

disposal activities 

would be similar to 

those described for 

Alternative 1A. This 

alternative involves 

no waste processing 

and associated 

noise impacts.

SMALL. Impacts from noise 

generated by spent IER 

handling, and disposal 

activities would be similar 

to those described for 

Alternative 1A. This 

alternative involves no 

waste processing and 

associated noise impacts. 

Construction of the small 

onsite waste storage 

facilities at the NPPs would 

result in temporary and 

intermittent construction 

noise impacts. In populated 

areas, construction 

activities may be scheduled 

to minimize potential noise 

impacts and avoid 

disturbing the public. 

Minimal or no additional 

noise impacts would be 

expected during operation 

of the long-term spent IER 

storage facilities.

SMALL. Impacts from 

noise generated by spent 

IER handling, thermal 

processing (volume 

reduction), and disposal 

activities would be similar 

to those described for 

Alternative 1A.

Construction of a relatively 

small, long-term spent IER 

storage facility at the waste 

disposal site would result 

in temporary and 

intermittent construction 

noise impacts. If in a 

populated area, 

construction activities may 

be scheduled to minimize 

potential noise impacts and 

avoid disturbing the public. 

Minimal or no additional 

noise impacts would be 

expected during operation 

of the long-term spent IER 

storage facility.

SMALL. Impacts from 

noise generated by 

spent IER handling, 

thermal processing 

(volume reduction), and 

disposal activities would 

be similar to those 

described for Alternative 

1A. 
5-30

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Occupational 

Health –

Radiological

SMALL. Workers 

performing spent IER 

handling, transport, 

mechanical mixing 

(blending), and disposal 

activities operate within an 

environment subject to 

OSHA regulations in 29 

CFR 1910, the U.S. 

Nuclear Regulatory 

Commission (NRC) 

Standards for Protection 

Against Radiation (10 CFR 

Part 20), Agreement State 

requirements (where 

applicable), radiological 

practices and procedures 

to achieve and maintain 

radiological exposure to 

levels that are as low as 

reasonably achievable 

(ALARA), and safety 

standard operating 

procedures (SOPs) 

developed for specific 

tasks. Worker radiological 

dose rates may increase 

minimally; however, illness 

rates would not be 

expected to increase from 

the above activities when 

SMALL. 

Radiological 

impacts to workers 

performing spent 

IER handling, 

transport, thermal 

processing 

(blending), and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. 

Radiological 

impacts to workers 

performing spent 

IER handling, 

transport, and 

disposal activities in 

this alternative could 

be less than those 

described for 

Alternatives 1A, 1B, 

4A, and 4B because 

no radioactive waste 

processing (i.e., 

blending or volume 

reduction) step 

would be involved. 

These impacts 

could also be less 

than those for 

Alternatives 3 and 

4A because no 

worker exposure 

during long-term 

storage of spent 

IERs would occur.

SMALL. Radiological 

impacts to workers 

performing spent IER 

handling, transport, and 

disposal activities, would be 

similar to those described 

for Alternative 1A. Although 

there could be less worker 

exposure in this alternative, 

as compared to that for 

Alternatives 1A, 1B, 4A, 

and 4B, because no radioactive waste processing 

would be involved, this 

could be offset to some 

degree by worker exposure 

during the long-term 

storage of spent IERs at 

the NPPs (although this 

exposure would still be 

minimal due to OSHA and 

other safety requirements). 

There would be no radiological impacts to workers 

resulting from construction 

of the long-term spent IER 

storage facilities at the 

NPPs because no radioactive materials would be 

used during construction.

SMALL. Radiological 

impacts to workers 

performing spent IER 

handling, transport, 

thermal processing 

(volume reduction), longterm storage, and disposal 

activities could be higher 

than those described for 

Alternatives 1A, 1B, and 

4B because this alternative

involves the additional 

activity of long-term 

storage of spent IERs at 

the waste disposal site 

(although this exposure 

would still be minimal due 

to OSHA and other safety 

requirements). 

There would be no 

radiological impacts to 

workers resulting from 

construction of the longterm spent IER storage 

facility because no 

radioactive materials would 

be used during 

construction.

SMALL. Radiological 

impacts to workers 

performing spent IER 

handling, transport, 

thermal processing 

(volume reduction), and 

disposal activities, 

would be similar to 

those described for 

Alternative 1A..
5-31

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Occupational 

Health –

Radiological

(Cont.)

in adherence to the above 

stated requirements, 

practices, and procedures.

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Occupational 

Health – 

Non-radiological

SMALL. Workers 

performing spent IER 

handling, transport, 

mechanical mixing 

(blending), and disposal 

activities operate within an 

environment subject to 

OSHA and other Federal 

regulations, as well as 

safety SOPs developed for 

specific tasks. As a result, 

worker injury and illness 

rates would not be 

expected to increase from 

these activities. 

SMALL. Nonradiological impacts 

to workers 

performing spent 

IER handling, 

transport, thermal 

processing 

(blending), and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. Nonradiological impacts 

to workers 

performing spent 

IER handling, 

transport, and 

disposal activities in 

this alternative could 

be less than those 

described for 

Alternatives 1A, 1B, 

4A, and 4B because 

no waste processing 

(i.e., blending or 

volume reduction) 

step would be 

involved.

SMALL. Non-radiological 

impacts to workers 

performing spent IER 

handling, transport, and 

disposal activities, would be 

similar to those described 

for Alternative 1A.

Workers involved in the 

construction of long-term 

waste storage facilities at 

the NPPs would be 

exposed to typical risks 

associated with 

construction activities. 

However, these activities 

would be subject to OSHA 

and other applicable safety 

requirements and SOPs. 

Non-radiological impacts to 

workers during 

maintenance and 

monitoring of the long-term 

SMALL. Non-radiological 

impacts to workers 

performing spent IER 

handling, transport, 

thermal processing 

(volume reduction), longterm storage, and disposal 

activities would be similar 

to those described for 

Alternative 1A.

Workers involved in the 

construction of the longterm waste storage facility 

at the waste disposal site 

would be exposed to 

typical risks associated 

with construction activities. 

However, these activities 

would be subject to OSHA 

and other applicable safety 

requirements and SOPs. 

Non-radiological impacts to 

SMALL. Nonradiological impacts to 

workers performing 

spent IER handling, 

transport, thermal 

processing (volume 

reduction), and disposal 

activities would be 

similar to those 

described for Alternative 

1A. 
5-32

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Occupational 

Health – 

Non-radiological

(Cont.) 

spent IER storage facilities 

would be expected to be 

minimal.

workers during 

maintenance and 

monitoring of the long-term 

spent IER storage facility 

would be expected to be 

minimal.

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Public Health – 

Radiological

(NOTE: 

Radiological 

impacts to public 

health from 

incident-free 

transportation and 

transportation 

accidents are 

described later in 

this table under 

Transportation.)

SMALL. Minimal or no 

exposure of the public to 

radiological constituents 

would be expected to 

occur from the spent IER 

handling, mechanical 

mixing (blending), and 

disposal activities due to 

safety-related procedures 

and regulatory controls 

implemented during these 

operations and the 

physical separation of the 

public (due to access 

limitations and distance) 

from these operations. In 

addition, the blending and 

waste disposal facilities 

would maintain compliance 

with applicable Federal, 

State, and local regulations 

for the protection of air 

quality and water quality 

SMALL. 

Radiological 

impacts to public 

health from spent 

IER handling, 

thermal processing 

(blending), and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. Minimal or 

no exposure of the 

public to radiological 

constituents would 

be expected to 

occur from the spent 

IER handling and 

disposal activities 

due to safetyrelated procedures 

and regulatory 

controls 

implemented during 

these operations. 

This alternative 

involves no waste 

processing and 

associated public 

health impacts.

SMALL. Minimal or no 

exposure of the public to 

radiological constituents 

would be expected to occur 

from the spent IER 

handling and disposal 

activities due to safetyrelated procedures and 

regulatory controls 

implemented during these 

operations. This alternative 

involves no waste 

processing and associated 

public health impacts. 

There would be no 

radiological impacts to the 

public resulting from 

construction of the longterm spent IER storage 

facilities at the NPPs 

because no radioactive 

SMALL. Impacts to public 

health from spent IER 

handling, thermal 

processing (volume 

reduction), and disposal 

activities would be similar 

to those described for 

Alternative 1A.

There would be no 

radiological impacts to the 

public resulting from 

construction of the longterm spent IER storage 

facility at the waste 

disposal site because no 

radioactive materials would 

be used during 

construction. Long-term 

waste storage is not 

anticipated to result in 

public health impacts due 

SMALL. Impacts to 

public health from spent 

IER handling, thermal 

processing (volume 

reduction), and disposal 

activities would be 

similar to those 

described for Alternative 

1A. 
5-33

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Public Health – 

Radiological

(Cont.) 

and for waste 

management, thus 

minimizing potential 

impacts to the public (see 

under Air Quality 

(Radiological), Waste 

Management, and Water 

Resources (Water Quality) 

in this table).

materials would be used 

during construction. Longterm storage of spent IERs 

is not anticipated to result 

in public health impacts due 

to the implementation of 

maintenance and 

monitoring programs.

to the implementation of 

maintenance and 

monitoring programs.

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Public Health – 

Non-radiological

(NOTE: Nonradiological 

impacts to public 

health from 

transportation 

accidents are 

described later in 

this table under 

Transportation.)

SMALL. Minimal or no 

exposure of the public to 

non-radiological 

constituents would be 

expected to occur from the 

spent IER handling, 

mechanical mixing 

(blending), and disposal 

activities due to safetyrelated procedures and 

regulatory controls 

implemented during these 

operations and the physical 

separation of the public 

(due to access limitations 

and distance) from these 

operations. In addition, the 

mechanical mixing 

(blending) facility would 

maintain compliance with 

applicable Federal, State, 

SMALL. Nonradiological impacts 

to public health 

from spent IER 

handling, thermal 

processing 

(blending), and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. Nonradiological impacts 

to public health from 

spent IER handling 

and disposal 

activities would be 

similar to those 

described for 

Alternative 1A. This 

alternative involves 

no waste processing 

and associated 

public health 

impacts.

SMALL. Non-radiological 

impacts to public health 

from waste handling and 

disposal activities would be 

similar to those described 

for Alternative 1A. This 

alternative involves no 

waste processing and 

associated public health 

impacts.

Non-radiological impacts to 

public health from 

construction of the small 

onsite waste storage 

facilities at the NPPs are 

addressed in this table 

under Air Quality (Nonradiological), Noise, and 

Water Resources (Water 

Quality). Long-term storage 

SMALL. Non-radiological 

impacts to public health 

from waste handling, 

thermal processing 

(volume reduction), and 

disposal activities would be 

similar to those described 

for Alternative 1A.

Non-radiological impacts to 

public health from 

construction of the small 

onsite waste storage 

facilities at the NPPs are 

addressed in this table 

under Air Quality (Nonradiological), Noise, and 

Water Resources (Water 

Quality). Long-term 

storage of spent IERs at 

the waste disposal site is 

SMALL. Nonradiological impacts to 

public health from spent 

IER handling, thermal 

processing (volume 

reduction), and disposal 

activities would be 

similar to those 

described for Alternative 

1A. 
5-34

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

PUBLIC AND 

OCCUPATIONAL 

HEALTH: 

Public Health – 

Non-radiological

(Cont.) 

and local regulations for air 

quality, noise, and water 

quality protection and for 

waste management, thus 

minimizing potential 

impacts to the public (see 

under Air Quality (Nonradiological), Noise, Waste 

Management, and Water 

Resources (Water Quality)

in this table).

Criteria emissions (e.g., 

particulate matter) from 

disposal activities, with 

commensurate public 

health impacts, would be 

minimized through the 

implementation of BMPs 

(e.g., pollution controls on 

equipment, dust 

suppression techniques), 

and distance to public 

receptors. 

of spent IERs at the NPPs 

is not anticipated to result 

in public health impacts due 

to the implementation of 

maintenance and 

monitoring programs.

not anticipated to result in 

public health impacts due 

to the implementation of 

maintenance and 

monitoring programs.

SOIL SMALL. No activities would 

take place during spent 

IER handling, transport, 

and mechanical mixing 

(blending) that would result 

in soil disturbance or 

contamination, other than 

SMALL. Soil 

impacts as a result 

of spent IER 

handling, transport, 

thermal processing 

(blending), and 

disposal activities 

SMALL. Soil 

impacts as a result 

of spent IER 

handling, transport, 

and disposal 

activities would be 

similar to those 

SMALL. Soil impacts as a 

result of spent IER 

handling, transport, and 

disposal activities under 

this alternative would be 

similar to those described 

for Alternative 1A. This 

SMALL. Soil impacts as a 

result of spent IER 

handling, transport, 

thermal processing 

(volume reduction), and 

disposal activities would be 

similar to those described 

SMALL. Soil impacts as 

a result of spent IER 

handling, transport, 

thermal processing 

(volume reduction), and 

disposal activities would 

be similar to those 
5-35

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

SOIL

(Cont.)

minor accidental spills that 

would be immediately 

addressed in accordance 

with spill prevention, 

control, and countermeasures (SPCC) plans.

Waste disposal activities 

would include application 

of BMPs (e.g., earth 

berms, dikes, sediment 

fences) to reduce soil 

erosion and 

implementation of SPCC 

plans for cleanup of 

accidental spills. 

would be similar to 

those described for 

Alternative 1A.

described for 

Alternative 1A. This 

alternative involves 

no waste processing 

and associated soil 

impacts, if any.

alternative involves no 

waste processing and 

associated soil impacts.

Construction of the small, 

onsite spent IER storage 

facilities at the NPPs would 

involve soil disturbance. 

Application of BMPs (e.g., 

earth berms, dikes,

sediment fences) would 

reduce soil erosion. 

Implementation of SPCC 

plans would reduce 

potential impacts from 

chemical spills or releases 

during both construction 

and operation of the 

storage facilities. 

for Alternative 1A.

Construction of the longterm spent IER storage 

facility at the waste 

disposal site would involve 

soil disturbance. 

Application of BMPs (e.g., 

earth berms, dikes, 

sediment fences) would 

reduce soil erosion. 

Implementation of an 

SPCC Plan would reduce 

potential impacts from 

chemical spills or releases 

during both construction 

and operation of the 

storage facility.

described for Alternative 

1A. 

TRANSPORTATION: 

Local and 

National Trafficc 

SMALL. On the local level, 

there would be about 1 

spent IER truck per 

operating hour and about 1 

truck per every 2 operating 

hours on average, near the 

waste processing 

(blending) facility and 

waste disposal facility, 

respectively. These 

numbers of trucks would 

represent very small 

SMALL. 

Alternatives 1B and 

1A differ only in the 

method of blending 

employed, and the 

numbers of annual 

truck trips to and 

from the waste 

processing and 

waste disposal 

facilities in these 

two alternatives 

SMALL. On the 

local level, there 

would be about 1 

spent IER truck 

every 2 operating 

hours, on average, 

near the waste 

disposal facility. 

This would 

represent a very 

small addition to 

local traffic in the 

SMALL. On the local level, 

in Years 1-20, there would 

be about 1 truck every 2.5 

operating hours, on 

average, near the waste 

disposal facility. These 

numbers of trucks would 

represent very small 

additions to local traffic 

near a waste disposal site.

On the national level, in 

SMALL. On the local level, 

there would be about 1 

truck per 8-hour operating 

day and 1 truck every 2 

operating hours, on 

average, near the waste 

processing (volume 

reduction) facility and 

waste disposal facility, 

respectively. These 

numbers of trucks would 

represent very small 

SMALL. Impacts on 

local and national traffic 

would be similar to 

those described for 

Alternative 4A.
5-36

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Local and 

National Traffic

(Cont.) 

additions to local traffic 

near industrial and waste 

disposal sites.

On the national level, total 

annual spent IER 

shipments (full and empty 

casks) would constitute 

approximately 0.0005% of 

total tractor-trailer truck 

freight weight on U.S. 

roads each year and, 

therefore, an even smaller 

(negligible) percentage of 

the total annual national 

vehicle traffic. 

Corresponding to the small 

local and national traffic 

impacts described above, 

there would be small 

impacts on associated 

traffic congestion, air 

quality, noise levels, and 

road surface wear. Nonradiological air emissions 

(e.g., from vehicle exhaust) 

from trucks transporting 

spent IERs and empty 

casks would be minimal 

due to the small scale and 

would be the same. 

Therefore, impacts 

on local and 

national traffic 

would be similar to 

those described for 

Alternative 1A. 

vicinity of a waste 

disposal site.

On the national 

level, total annual 

spent IER 

shipments (full and 

empty casks) would 

constitute 

approximately 

0.0003% of total 

tractor-trailer truck 

freight weight on 

U.S. roads each 

year and, therefore, 

an even smaller 

(negligible) 

percentage of the 

total annual national 

vehicle traffic. 

Corresponding 

small local and 

national impacts on 

traffic congestion, 

air quality, noise 

levels, and road 

surface wear would 

be as described 

under Alternative 

1A.

Years 1-20, total annual 

spent IER shipments (full 

and empty casks) would 

constitute approximately 

0.0002% of total tractortrailer truck freight weight 

on U.S. roads each year 

and, therefore, an even 

smaller (negligible) 

percentage of the total 

annual national vehicle 

traffic. Impacts on local and 

national traffic after Year 21 

would be similar to those of 

Alternative 2, as both of 

these alternatives involve 

direct disposal of all Class 

A, B, and C spent IERs. 

Corresponding small local 

and national impacts on 

traffic congestion, air 

quality, noise levels, and 

road surface wear would be 

as described under 

Alternative 1A.

additions to local traffic 

near industrial and waste 

disposal sites.

On the national level, total 

annual spent IER 

shipments (full and empty 

casks) would constitute 

approximately 0.0003% of 

total tractor-trailer truck 

freight weight on U.S. 

roads each year and, 

therefore, an even smaller 

(negligible) percentage of 

the total annual national 

vehicle traffic. 

Corresponding small local 

and national impacts on 

traffic congestion, air 

quality, noise levels, and 

road surface wear would 

be as described under 

Alternative 1A.
5-37

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Local and 

National Traffic

(Cont.)

intermittent nature of these 

operations, which would be 

dispersed over wide 

geographic areas. 

TRANSPORTATION: 

Routine 

(Incident-free) - 

Radiological

(Individuals and 

Populations)c

(NOTE: In 

actuality, all of the 

radiation doses 

and LCFs would 

be lower than 

estimated here 

because people 

would not be at 

the same locations 

for an entire year. 

Also, not all trucks 

carrying spent 

IERs would stop at 

the same rest and 

refueling stops.)

SMALL. For individuals, 

the maximally exposed 

individual (MEI) dose from 

moving trucks carrying all 

spent IER shipments 

annually would be 

approximately 0.08% of the 

average annual U.S. 

background radiation dose, 

and the corresponding LCF 

would be negligible at 3 x 

10-11% of 2010 total 

estimated U.S. cancer 

fatalities. 

For an average resident 

near a truck stop, the dose 

from trucks carrying all 

spent IER shipments 

annually would be 

approximately 0.14% of the 

background dose, and the 

corresponding LCF would 

be 5 x 10-11% of 2010 

estimated cancer fatalities. 

Radiation doses and LCFs 

to all other individual 

SMALL. 

Radiological 

impacts of routine 

transportation on 

individuals and 

populations would 

be similar to those 

described for 

Alternative 1A.

SMALL. For 

individuals, the MEI 

dose from moving 

trucks carrying all 

spent IER 

shipments annually 

would be 

approximately 

0.04% of the 

average annual 

U.S. background 

radiation dose, and 

the corresponding 

LCF would be 

negligible at 

1 x 10-11% of 2010 

total estimated U.S. 

cancer fatalities. 

For an average 

resident near a truck 

stop, the dose from 

trucks carrying all 

spent IER 

shipments annually 

would be 

approximately 

SMALL. For individuals, in 

Years 1-20, the MEI dose 

from moving trucks carrying 

all spent IER shipments 

annually would be 

approximately 0.03% of the 

average annual U.S. 

background radiation dose, 

and the corresponding LCF 

would be negligible at 1 x 

10-11% of 2010 total 

estimated U.S. cancer 

fatalities. 

For an average resident 

near a truck stop, the dose 

from trucks carrying all 

spent IER shipments 

annually would be 

approximately 0.058% of 

the background dose, and 

the corresponding LCF 

would be 2 x 10-11% of 

2010 estimated cancer 

fatalities. Radiation doses 

and LCFs to all other 

individual receptors would 

SMALL. For individuals, 

the MEI dose from moving 

trucks carrying all spent 

IER shipments annually 

would be approximately 

0.04% of the average 

annual U.S. background 

radiation dose, and the 

corresponding LCF would 

be negligible at 1 x 10-11% 

of 2010 total estimated 

U.S. cancer fatalities. 

For an average resident 

near a truck stop, the dose 

from trucks carrying all 

spent IER shipments 

annually would be 

approximately 0.077% of 

the background dose, and 

the corresponding LCF 

would be 3 x 10-11% of 

2010 estimated cancer 

fatalities. Radiation doses 

and LCFs to all other 

individual receptors would 

be orders of magnitude 

SMALL. Radiological 

impacts of routine 

transportation on 

individuals and 

populations would be 

similar to those 

described for Alternative 

4A. 
5-38

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Routine 

(Incident-free) - 

Radiological

(Individuals and 

Populations)

(Cont.) 

receptors would be orders 

of magnitude lower. 

For populations along the 

representative 

transportation routes, the 

maximum annual collective 

population dose and LCF 

from moving trucks, from 

all annual spent IER 

shipments, would be about 

5 x 10-5% of the U.S. 

average annual 

background radiation dose 

and 3 x 10-9% of 2010 total 

estimated U.S. cancer 

fatalities, respectively. 

For residents near rural 

and suburban truck rest 

and refueling stops, the 

maximum annual collective 

population doses, from all 

annual spent IER 

shipments, would each be 

about 0.2% of the U.S. 

average annual 

background dose, for the 

time these populations are 

exposed; and the 

maximum LCFs as 

0.074% of the 

background dose, 

and the 

corresponding LCF 

would be 

2 x 10-11% of 2010 

estimated cancer 

fatalities. Radiation 

doses and LCFs to 

all other individual 

receptors would be 

orders of magnitude 

lower. 

For populations 

along the 

representative 

transportation 

routes, the 

maximum annual 

collective population 

dose and LCF from 

moving trucks, from 

all annual spent IER 

shipments, would be 

about 10-4% of the 

U.S. average 

annual background 

radiation dose and 

2 x 10-9% of 2010 

total estimated U.S. 

be orders of magnitude 

lower. 

For populations along the 

representative 

transportation routes, in 

Years 1-20, the maximum 

annual collective population 

dose and LCF from moving 

trucks, from all annual 

spent IER shipments, 

would be about 8 x 10-5% 

of the U.S. average annual 

background radiation dose 

and 1 x 10-9% of 2010 total 

estimated U.S. cancer 

fatalities, respectively. 

For residents near rural and 

suburban truck rest and 

refueling stops, in Years 1-

20, the maximum annual 

collective population doses, 

from all annual spent IER 

shipments, would each be 

about 0.1% of the U.S. 

average annual 

background dose, for the 

time these populations are 

exposed; and the maximum 

LCFs as percentages of 

lower. 

For populations along the 

representative 

transportation routes, the 

maximum annual collective 

population dose and LCF 

from moving trucks, from 

all annual spent IER 

shipments, would be about 

8 x 10-5% of the U.S. 

average annual 

background radiation dose 

and 4 x 10-10% of 2010 

total estimated U.S. cancer 

fatalities, respectively. 

For residents near rural 

and suburban truck rest 

and refueling stops, the 

maximum annual collective 

population doses, from all 

annual spent IER 

shipments, would each be 

about 0.1% of the U.S. 

average annual 

background dose, for the 

time these populations are 

exposed; and the 

maximum LCFs as 

percentages of 2010 total 
5-39

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Routine

(Incident-free) - 

Radiological

(Individuals and 

Populations)

(Cont.)

percentages of 2010 total 

estimated U.S. cancer 

fatalities would be 

negligible at about 

2 x 10-9% and 4 x 10-8%, 

respectively.

cancer fatalities, 

respectively. 

For residents near 

rural and suburban 

truck rest and 

refueling stops, the 

maximum annual 

collective population 

doses, from all 

annual spent IER 

shipments, would 

each be about 0.1% 

of the U.S. average 

annual background 

dose, for the time 

these populations 

are exposed; and 

the maximum LCFs 

as percentages of 

2010 total estimated 

U.S. cancer 

fatalities would be 

negligible at about 8 

x 10-10% and 2 x 

10-8%, respectively.

2010 total estimated U.S. 

cancer fatalities would be 

negligible at about 7 x 

10-10% and

2 x 10-8%, respectively. 

Radiological impacts of 

routine transportation on 

individuals and populations 

after Year 21 would be 

similar to those described 

for Alternative 2. 

estimated U.S. cancer 

fatalities would be 

negligible at about

9 x 10-10% and 2 x 10-8%, 

respectively.

TRANSPORTATION: 

Accidents – 

Non-radiological 

and Radiologicalc 

SMALL. Regarding nonradiological impacts of 

transportation accidents, in 

the most conservative case 

evaluated, there would be 

SMALL. Nonradiological and 

radiological impacts 

from transportation 

accidents would be 

SMALL. Regarding 

non-radiological 

impacts of 

transportation 

accidents, in the 

SMALL. Regarding nonradiological impacts of 

transportation accidents, in 

Years 1-20, in the most 

conservative case 

SMALL. Regarding nonradiological impacts of 

transportation accidents, in 

the most conservative case 

evaluated, there would be 

SMALL. Nonradiological and 

radiological impacts 

from transportation 

accidents would be 
5-40

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Accidents – 

Non-radiological 

and Radiological

(Cont..)

about 2.6 accidents per 

year involving trucks 

carrying spent IERs or 

empty casks, which is 

0.0007% of the 2009 U.S. 

annual tractor-trailer truck 

accident rate. From these 

accidents, there would be 

about 0.02 fatality per year, 

which is equivalent to 1 

fatal accident every 50 

years and represents 

0.004% of 2009 U.S. 

tractor-trailer truck 

fatalities.

Regarding radiological 

impacts of transportation 

accidents in which no 

radioactive materials are 

released, in the most 

conservative case 

evaluated, the collective 

population dose as a 

percentage of U.S. 

average annual 

background dose would be 

0.01%, and the 

corresponding LCF as a 

percentage of estimated 

annual traffic fatalities 

similar to those 

described for 

Alternative 1A.

most conservative 

case evaluated, 

there would be 

about 2 accidents 

per year involving 

trucks carrying 

spent IERs or empty 

casks, which is 

0.0004% of the 

2009 U.S. annual 

tractor-trailer truck 

accident rate. From 

these accidents, 

there would be 

about 0.01 fatality 

per year, which is 

equivalent to 1 fatal 

accident every 100 

years and 

represents 0.002% 

of 2009 U.S. tractortrailer truck 

fatalities.

Regarding 

radiological impacts 

of transportation 

accidents in which 

no radioactive 

materials are 

released, in the 

evaluated, there would be 

about 1.3 accidents per 

year involving trucks 

carrying spent IERs or 

empty casks, which is 

0.0003% of the 2009 U.S. 

annual tractor-trailer truck 

accident rate. From these 

accidents, there would be 

about 0.01 fatality per year, 

which is equivalent to 1 

fatal accident every 100 

years and represents 

0.002% of 2009 U.S. 

tractor-trailer truck fatalities.

Regarding radiological 

impacts of transportation 

accidents in which no 

radioactive materials are 

released, in Years 1-20, in 

the most conservative case 

evaluated, the collective 

population dose as a 

percentage of U.S. average 

annual background dose 

would be 0.005%, and the 

corresponding LCF as a 

percentage of estimated 

annual traffic fatalities 

involving spent IER 

about 1 accident per year 

involving trucks carrying 

spent IERs or empty 

casks, which is 0.0001% of 

the 2009 U.S. annual 

tractor-trailer truck accident 

rate. From these accidents, 

there would be about 0.01 

fatalities per year, which is 

equivalent to 1 fatal 

accident every 100 years 

and represents 0.002% of 

2009 U.S. tractor-trailer 

truck fatalities.

Regarding radiological 

impacts of transportation 

accidents in which no 

radioactive materials are 

released, in the most 

conservative case 

evaluated, the collective 

population dose as a 

percentage of U.S. 

average annual 

background dose would be 

0.006%, and the 

corresponding LCF as a 

percentage of estimated 

annual traffic fatalities 

involving spent IER 

similar to those 

described for Alternative 

4A. 
5-41

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Accidents – 

Non-radiological 

and Radiological

(Cont.) 

involving spent IER 

shipments and of 2010 

estimated U.S. cancer 

fatalities would be 0.136% 

and 2.5 x 10-9%, 

respectively. For the 

nearest member of the 

public, the MEI, the dose 

and LCF are 0.013% of 

background and 

2.3 x 10-8% of 2010 total 

estimated U.S. cancer 

fatalities, respectively. 

Regarding radiological 

impacts of transportation 

accidents in which 

radioactive materials could 

be released from Type A 

and Type B casks, 

accident consequences 

were calculated separately 

for accidents involving 

spent IERs from BWRs 

and PWRs and for a single 

accident scenario for each 

cask type (i.e., not for each 

of the six alternatives). For 

the Type A cask accident 

scenario, the MEI dose 

and LCF as percentages of 

most conservative 

case evaluated, the 

collective population 

dose as a 

percentage of U.S. 

average annual 

background dose 

would be 0.006%, 

and the 

corresponding LCF 

as a percentage of 

estimated annual 

traffic fatalities 

involving spent IER 

shipments and of 

2010 estimated U.S. 

cancer fatalities 

would be 0.099% 

and 7.7 x 10-9%, 

respectively. The 

potential 

radiological impact 

to the MEI would be 

the same as 

described under 

Alternative 1A. 

Regarding 

radiological impacts 

of transportation 

accidents in which 

shipments and of 2010 

estimated U.S. cancer 

fatalities would be 0.078% 

and 1.2 x 10-9%, 

respectively. The potential 

radiological impact to the 

MEI would be the same as 

described under Alternative 

1A. 

Regarding radiological 

impacts of transportation 

accidents in which 

radioactive materials could 

be released from Type A 

and Type B casks, see 

discussion under 

Alternative 1A.

Non-radiological and 

radiological impacts from 

transportation accidents 

after Year 21 would be 

similar to those described 

for Alternative 2. 

shipments and of 2010 

estimated U.S. cancer 

fatalities would be 0.078% 

and 1.2 x 10-9%, 

respectively. The potential 

radiological impact to the 

MEI would be the same as 

described under 

Alternative 1A. 

Regarding radiological 

impacts of transportation 

accidents in which 

radioactive materials could 

be released from Type A 

and Type B casks, see 

discussion under 

Alternative 1A.
5-42

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

TRANSPORTATION: 

Accidents – 

Non-radiological 

and Radiological

(Cont.) 

U.S. average annual 

background and 2010 U.S. 

total estimated cancer 

fatalities would be 36% 

and 1 x 10-8%, 

respectively, for either 

reactor type. For the Type 

B cask accident scenario, 

at most (for BWRs), the 

MEI dose and LCF as 

percentages of background 

and 2010 estimated cancer 

fatalities would be 19% 

and 6 x 10-9%, 

respectively; and the 

corresponding collective 

dose and LCF percentages 

would be 0.25% and 

2 x 10-7%, respectively.

radioactive 

materials could be 

released from Type 

A and Type B 

casks, see 

discussion under 

Alternative 1A.

WASTE 

MANAGEMENT

SMALL. Spent IER 

handling, transport, 

mechanical mixing 

(blending), and disposal 

activities would not result 

in substantial generation of 

incidental radioactive, 

hazardous, mixed, or nonhazardous solid waste or 

liquid effluent, based on 

the nature of these 

activities. Thus, there 

SMALL. Waste 

management 

impacts resulting 

from spent IER 

handling, transport, 

and disposal 

activities would be 

similar to those 

described for 

Alternative 1A. 

Small quantities of 

LLRW and 

SMALL. Waste 

management 

impacts resulting 

from spent IER 

handling, transport, 

and disposal 

activities would be 

similar to those 

described for 

Alternative 1A. No 

solid wastes or 

liquid effluents 

SMALL. Waste 

management impacts 

resulting from spent IER 

handling, transport, and 

disposal activities would be 

similar to those described 

for Alternative 1A. No solid 

wastes or liquid effluents 

incidental to spent IER 

processing would be 

generated under this 

alternative.

SMALL. Waste 

management impacts 

resulting from spent IER 

handling, transport, 

thermal processing 

(volume reduction), and 

disposal activities would be 

similar to those described 

for Alternative 1B as these 

alternatives use similar 

thermal processing 

technologies, and all other 

SMALL. Waste 

management impacts 

resulting from waste 

handling, transport, 

thermal processing 

(volume reduction), and 

disposal activities would 

be similar to those 

described for Alternative 

1B as these alternatives 

use similar thermal 

processing 
5-43

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

WASTE 

MANAGEMENT

(Cont.) 

would be minimal resulting 

impacts on safety, waste 

disposal capacity, or other 

resources. Liquid effluents 

(including stormwater) 

would be managed in 

accordance with Federal 

and State regulations, 

including discharging 

within permitted limits (e.g., 

under NPDES 

requirements and 10 CFR 

20.1301 dose-based 

requirements). 

hazardous waste 

would be generated 

as a result of the 

process, which 

would be managed 

in accordance with 

Federal and State 

regulations. Thus, 

there would be 

minimal resulting 

impacts on safety, 

waste disposal 

capacity, or other 

resources. Liquid 

effluents (including 

stormwater) would 

be managed in 

accordance with 

Federal and State 

regulations, 

including 

discharging within 

permitted limits 

(e.g., under NPDES 

requirements and 

10 CFR 20.1301 

dose-based 

requirements). 

incidental to spent 

IER processing 

would be generated 

under this 

alternative.

Construction of the small 

onsite spent IER storage 

facilities at the NPPs could

generate small quantities of 

hazardous and nonhazardous solid wastes, 

which would be managed in 

accordance with applicable 

Federal, State, and local 

requirements to avoid or 

minimize environmental 

impacts. Stormwater would 

be managed in accordance 

with NPDES requirements. 

Long-term spent IER 

storage at the NPPs would 

result in minimal 

generation, if any, of 

radioactive, hazardous, 

mixed, or non-hazardous 

solid waste, or liquid 

effluent. Liquid effluent 

would be managed in 

accordance with applicable 

regulations, including 

discharging within 

permitted limits (e.g., under 

NPDES requirements and 

10 CFR 20.1301 dosecomponent activities of the 

two alternatives would be 

essentially the same.

Construction of a long-term 

spent IER storage facility 

at the waste disposal site 

could generate small 

quantities of hazardous 

and non-hazardous solid 

wastes, which would be 

managed in accordance 

with applicable Federal, 

State, and local 

requirements to avoid or 

minimize environmental 

impacts. Stormwater would 

be managed in accordance 

with NPDES requirements. 

Long-term spent IER 

storage would result in 

minimal generation, if any, 

of radioactive, hazardous, 

mixed, or non-hazardous 

solid waste, or liquid 

effluent. Liquid effluent 

would be managed in 

accordance with applicable 

regulations, including 

discharging within 

technologies, and all 

other component 

activities of the two 

alternatives would be 

essentially the same.
5-44

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

WASTE 

MANAGEMENT

(Cont.) 

based requirements). permitted limits (e.g., under 

NPDES requirements and 

10 CFR 20.1301 dosebased requirements). 

WATER 

RESOURCES: 

Water Quality

SMALL. Little or no effluent 

discharges are anticipated 

from spent IER handling, 

transport, and disposal 

activities. Stormwater 

runoff would be managed 

in accordance with permit 

limits.

Only permitted discharges 

of effluents would be 

allowed at the mechanical 

mixing (blending) facility. 

Discharges would be 

monitored in accordance 

Federal and State (e.g., 

NPDES and 10 CFR 

20.1301 dose-based 

requirements) 

requirements that are 

protective of human health 

and the environment, 

thereby limiting any 

impacts to surface water 

and groundwater.

Accidental spills would be 

addressed in accordance 

SMALL. Water 

quality impacts 

resulting from spent 

IER handling, 

thermal processing 

(blending), 

transport, and 

disposal activities 

would be similar to 

those described for 

Alternative 1A.

SMALL. Water 

quality impacts 

resulting from spent 

IER handling, 

transport, and 

disposal activities 

would be similar to 

those described for 

Alternative 1A. No 

liquid effluents 

incidental to waste 

processing (i.e., 

blending or volume 

reduction) would be 

generated under 

this alternative.

SMALL. Water quality 

impacts resulting from 

spent IER handling, 

transport, and disposal 

activities would be similar 

to those described for 

Alternative 1A. No liquid 

effluents incidental to waste 

processing (i.e., blending or 

volume reduction) would be 

generated under this 

alternative.

Effects of sediment 

discharge on water quality 

during construction of the 

small onsite spent IER 

storage facilities at the 

NPPs would be minimized 

through application of 

BMPs (e.g., earth berms, 

dikes, sediment fences).

Accidental spills would be 

immediately addressed in 

accordance with SPCC 

plans. Little or no liquid 

effluent discharge is 

SMALL. Water quality 

impacts resulting from 

spent IER handling, 

transport, thermal 

processing (volume 

reduction), and disposal 

activities would be similar 

to those described for 

Alternative 1A.

Effects of sediment 

discharge on water quality 

during construction of the 

relatively small long-term 

storage facility at the waste 

disposal site would be 

minimized through 

application of BMPs (e.g., 

earth berms, dikes, 

sediment fences). 

Accidental spills would be 

immediately addressed in 

accordance with an SPCC 

Plan. Little or no liquid 

effluent discharge is 

anticipated from long-term 

spent IER storage.

SMALL. Water quality 

impacts resulting from 

spent IER handling, 

transport, thermal 

processing (volume 

reduction), and disposal 

activities would be 

similar to those 

described for Alternative 

1A. 
5-45

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

WATER 

RESOURCES: 

Water Quality

(Cont.)

with SPCC plans. anticipated from long-term 

spent IER storage. 

WATER 

RESOURCES: 

Water Supply

SMALL. There would be 

minimal water use 

associated with spent IER 

handling and transport.

Small quantities of water 

would be used at the 

mechanical mixing 

(blending) facility and for 

dust suppression and other 

activities (e.g., equipment 

washing) at the waste 

disposal facility associated 

with the disposal of the 

relatively small quantities 

of spent IERs. Quantities 

of water used would result 

in minimal impacts to water 

supply.

SMALL. Water use 

impacts associated 

with spent IER 

handling, transport, 

and disposal would 

be similar to those 

described for 

Alternative 1A. 

Anticipated water 

use at the thermal 

processing 

(blending) facility 

would be low. 

Quantities of water 

used would result in 

minimal impacts to 

water supply.

SMALL. Water use 

impacts associated 

with spent IER 

handling, transport, 

and disposal would 

be similar to those 

described for 

Alternative 1A. 

There would be no 

water use 

associated with 

spent IER 

processing (i.e., 

blending or volume 

reduction) in this 

alternative.

SMALL. Water use impacts 

associated with spent IER 

handling, transport, and 

disposal would be similar to 

those described for 

Alternative 1A. There would 

be no water use associated 

with spent IER processing 

(i.e., blending or volume 

reduction) in this 

alternative.

Construction of the small 

onsite spent IER storage 

facilities at the NPPs would 

require water for dust 

suppression and other 

construction activities (e.g., 

equipment washing), but 

the small quantities of 

water needed for these 

purposes would not be 

expected to result in 

impacts to water supply. 

There would be minimal 

water use associated with 

SMALL. Water use impacts 

associated with spent IER 

handling, thermal 

processing (volume 

reduction), transport, and 

disposal would be similar 

to those described for 

Alternative 1B as these 

alternatives employ similar 

thermal processing 

technologies, and all other 

component activities of the 

two alternatives would be 

essentially the same.

Construction of the 

relatively small, long-term 

spent IER storage facility 

at the waste disposal site 

would require water for 

dust suppression and other 

construction activities (e.g., 

equipment washing), but 

the small quantities of 

water needed for these 

purposes would not be 

SMALL. Water use 

impacts associated with 

spent IER handling, 

thermal processing 

(volume reduction), 

transport, and disposal 

would be similar to 

those described for 

Alternative 1B as these 

alternatives employ 

similar thermal 

processing 

technologies, and all 

other component 

activities of the two 

alternatives would be 

essentially the same.
5-46

Table 5 Comparison of Potential Environmental Impacts of the Six Alternatives for Handling LLRW Spent Ion Exchange Resins (Cont.)

RESOURCE OR 

IMPACT AREA

POTENTIAL ENVIRONMENTAL IMPACTS BY ALTERNATIVEa

ALTERNATIVE 1A 

DISPOSAL OF BLENDED 

CLASS A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING FACILITY 

(USING MECHANICAL 

MIXING)

ALTERNATIVE 1B

DISPOSAL OF 

BLENDED CLASS 

A, B, AND C 

SPENT IER LLRW 

FROM A CENTRAL 

PROCESSING 

FACILITY 

(USING THERMAL 

PROCESSING) 

ALTERNATIVE 2

DIRECT DISPOSAL 

OF 

CLASS A, B, AND C 

SPENT IER LLRW

ALTERNATIVE 3

LONG-TERM ONSITE 

STORAGE OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs, 

THEN DISPOSALb

ALTERNATIVE 4A

VOLUME REDUCTION OF 

CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING FACILITY, 

LONG-TERM STORAGE, 

THEN DISPOSALb

ALTERNATIVE 4B

VOLUME REDUCTION 

OF CLASS B AND C 

CONCENTRATION 

SPENT IERs AT A 

PROCESSING 

FACILITY, 

THEN DISPOSALb

WATER 

RESOURCES: 

Water Supply

(Cont.) 

the long-term storage of 

spent IERs.

expected to result in 

impacts to water supply. 

There would be minimal 

water use associated with 

the long-term storage of 

spent IERs. a Note that the six alternatives are assumed to be implemented at existing NPPs, waste processing facilities, and waste disposal facilities, and within the existing site boundaries and 

licensed envelopes of operation at those facilities.

b Alternative 3 includes immediate disposal of Class A LLRW spent IERs.

c See Appendix A for the basis of the quantitative results reported here.
5-47

5.2 Summary and Discussion of Comparative Environmental Evaluation

As shown in Table 5, the potential environmental impacts of all six alternatives in all resource 

and impact areas evaluated would be SMALL, with the exception of potential impacts on historic 

and cultural resources from construction of long-term spent IER storage facilities in Alternatives 

3 and 4A, which could be SMALL to MODERATE. Note also that although implementation of 

Alternative 3 would require construction (expansion) of long-term spent IER storage areas at 

65 NPP locations, these storage facilities would have small footprints, within existing NPP 

operational areas and under current license conditions, and at widely dispersed geographic 

locations; thus the impacts of these construction activities would not be cumulative in relation to 

each other. Furthermore, for reasons discussed earlier, conservative, often bounding 

assumptions were used in this comparative environmental evaluation of generic, non-locationspecific alternatives in several cases, such that the actual impacts of the alternatives, if 

implemented, would be even smaller. 

As summarized below, there are several reasons why the potential environmental impacts of all 

six alternatives would be mostly SMALL. 

5.2.1 Air Quality 

Nearly all of the radiological and non-radiological air emissions would come from the blending 

(mechanical mixing, thermal processing) and volume reduction facilities in Alternatives 1A, 1B, 

4A, and 4B. Note that among Alternatives 1A, 1B, 4A, and 4B, air emissions from the ambient 

temperature mechanical mixing (blending) process in Alternative 1A would have the potential to 

be less than those from Alternative 1B (blending using thermal processing) and Alternatives 4A 

and 4B (volume reduction by thermal processing), which would involve treatment of spent IERs 

at elevated temperatures (800 ̊C) with resulting increased volatilization of constituents. 

However, emission controls (e.g., off-gas filtration equipment in the case of the thermal 

processing options) would be employed at these facilities as necessary to maintain compliance 

with applicable air quality regulations and keep emissions within regulatory limits under 

NESHAPs and NAAQS. Non-radiological air emissions from equipment usage and fugitive dust 

generation during spent IER handling and disposal, and during construction of relatively small, 

long-term spent IER storage facilities in Alternatives 3 and 4A, would be temporary and 

intermittent in nature and also subject to air quality regulations; and would be minimized and 

controlled using emissions controls, best management practices (BMPs), and other mitigation 

measures as necessary. Non-radiological air quality impacts associated with the transport of 

spent IERs are addressed below under Transportation—Local and National Traffic.

5.2.2 Ecological Resources 

The existing NPPs and spent IER processing and disposal facilities would be operating within 

existing facility footprints. There would be minimal or no additional ground disturbance or other 

activities during spent IER handling and processing activities, and none during spent IER 

transport. Therefore, any impacts on wildlife and plants from these operations would be 

minimal. Any air emissions and wastewater discharges would be within regulatory limits and 

noise mitigation measures would keep noise levels and any associated ecological impacts to a 
5-48

minimum. Potential impacts from construction of long-term spent IER storage facilities in 

Alternatives 3 and 4A would be SMALL due to the very small sizes of these facilities; and would 

be avoided, minimized, or mitigated where possible, based on threatened and endangered 

species surveys and consultations with the USFWS and corresponding State agencies. No 

additional ecological impacts would be expected during operation of the long-term spent IER 

storage facilities.

5.2.3 Historic and Cultural Resources 

The existing NPPs and waste processing and disposal facilities would be operating within 

existing facility footprints. There would be minimal or no additional ground disturbance during 

spent IER handling, processing, and disposal, and none during spent IER transport. Therefore, 

no destruction of, or other adverse effects on, historic or cultural resources would be expected 

as a result of these activities. Construction of long-term spent IER storage facilities in 

Alternatives 3 and 4A could possibly encounter and destroy, or otherwise adversely affect, 

resources determined eligible for listing in the NRHP (i.e., historic properties). However, the 

footprints of these storage facilities would be relatively small (see Sections 4.2.4 and 4.2.5), and 

conduct of cultural resource inventories and surveys, consultation with SHPOs and THPOs, and 

implementation of appropriate impact avoidance, minimization, or mitigation measures would 

keep the impacts to such resources at SMALL to MODERATE levels. No additional impacts to 

historic and cultural resources would be expected during operation of the long-term spent IER 

storage facilities.

5.2.4 Noise 

Noise resulting from spent IER handling, processing, storage, and disposal would occur at 

existing, licensed facilities in compliance with applicable noise regulations and with noise 

mitigation measures typically employed as necessary. Noise impacts during construction of 

long-term spent IER storage facilities in Alternatives 3 and 4A would be temporary and 

intermittent in nature, and could be minimized in populated areas, if necessary, through suitable 

scheduling of construction activities and other measures. Minimal or no additional noise 

impacts would be expected during operation of the long-term spent IER storage facilities. Noise

impacts associated with the transport of spent IERs are addressed below under 

Transportation—Local and National Traffic.

5.2.5 Public and Occupational Health 

Worker activities for handling, processing, storage, and disposal of spent IERs must comply with 

NRC, Agreement State, OSHA, as low as reasonably achievable (ALARA), and other worker 

protection requirements and SOPs, as applicable, thus limiting any radiological and 

non-radiological occupational exposures to acceptable levels. The nature of facility operations, 

facility access limitations, applicable air quality, noise, water quality, and waste management 

regulatory requirements (e.g., air quality standards under NESHAPs and NAAQS, water quality 

requirements under NPDES, dose-based requirements under 10 CFR 20.1301), and emissions

control and mitigation measures at the NPPs and waste processing and disposal facilities, and 

implementation of maintenance and monitoring programs at long-term spent IER storage 
5-49

facilities would result in minimal or no exposure of members of the public to radiological and 

non-radiological constituents.

5.2.6 Soil 

Except for construction of long-term spent IER storage facilities at the NPPs in Alternative 3 and 

at the waste disposal site in Alternative 4A, essentially no activities would take place during 

spent IER handling and processing at the existing facilities, and during spent IER transport, that 

would result in soil disturbance or contamination, other than accidental spills, which would be 

immediately addressed in accordance with spill prevention, control, and countermeasures 

(SPCC) plans. Construction of long-term spent IER storage facilities at the NPPs and the waste 

disposal site in Alternatives 3 and 4A, respectively, and waste disposal activities, would involve 

application of BMPs (e.g., earth berms, dikes, sediment fences) to reduce soil erosion and 

implementation of SPCC plans for cleanup of accidental spills.

5.2.7 Transportation 

As discussed below, for the three categories of potential transportation impacts assessed in this 

evaluation, the quantitatively estimated, potential non-radiological and radiological impacts to 

members of the public from the shipment of spent IERs and empty casks would be small to 

negligible in magnitude. 

5.2.7.1 Local and National Traffic Impacts 

On a local level, the numbers of trucks transporting spent IERs or empty casks on local roads 

near the waste processing or disposal facilities were estimated to range from about one truck 

per 8-hour operating day near the spent IER processing (volume reduction) facilities in 

Alternatives 4A and 4B, to about one truck per operating hour near the spent IER processing 

(blending) facilities in Alternatives 1A and 1B. This range in the numbers of trucks traveling on 

local roads represents very small additions to local traffic in the vicinities of industrial sites. On 

a national level, total annual spent IER freight shipments (full and empty casks) would constitute 

approximately 0.0002 to 0.0005 percent (depending on the alternative) of the total annual U.S. 

freight weight carried by tractor-trailer trucks. These percentages would be even smaller 

(negligible) as compared to total annual national vehicle traffic (tractor-trailer trucks plus all 

other vehicles). Corresponding to these small local and national traffic impacts, there would be 

small impacts on associated traffic congestion, air quality, noise levels, and road surface wear.

5.2.7.2 Radiological Impacts of Routine Transportation 

For individuals, the highest estimated doses and corresponding LCFs would be to the MEI and 

to residents near truck stops, although these would all be low. However, the radiological 

impacts of the alternatives would be similar to each other. The MEI dose from moving trucks 

carrying all spent IER shipments annually would range from approximately 0.03 to 0.08 percent 

of the average annual U.S. background radiation dose; and the corresponding LCFs would be 

negligible, ranging from about 1 x 10-11 to 3 x 10-11 percent of 2010 total estimated U.S. cancer 

fatalities. For an average resident near a truck stop, the dose from trucks carrying all spent IER
5-50

shipments annually would range from approximately 0.058 to 0.14 percent of the background 

dose, and the corresponding LCFs would range from 2 x 10-11 to 5 x 10-11 percent of 2010 

estimated cancer fatalities. Radiation doses and LCFs to all other individual receptors would be 

orders of magnitude lower. 

For populations along the representative transportation routes and near truck rest and refueling 

stops, the maximum annual collective population doses and LCFs from moving and stationary 

trucks, respectively, from all annual spent IER shipments for each of the six alternatives, would 

also be similar. Collective population doses from moving trucks would range from about 5 × 10--

5 to 10-4 percent of the U.S. average annual background radiation dose; and corresponding 

LCFs would be negligible, ranging from about 1 × 10-10 to 3 × 10-9 percent of 2010 total 

estimated U.S. cancer fatalities, respectively. For trucks at rural and suburban rest and 

refueling stops, maximum annual collective population doses from stationary trucks would range 

from about 0.1 to 0.2 percent of background; and corresponding LCFs would be negligible, 

ranging from about 1 × 10-8 to 4 × 10-8 percent of 2010 estimated cancer fatalities, respectively. 

Any differences between the collective doses to residents near rural and suburban truck stops 

depend only on the difference in population (with the populations near suburban trucks stops 

typically being higher). The radiation source and its strength are the same in both cases. 

Note that in actual practice, impacts to both individuals and populations would be lower than 

estimated because not all residents would be at the same locations for an entire year and not all 

trucks carrying spent IERs would stop at the same rest and refueling stops. 

5.2.7.3 Non-radiological and Radiological Impacts of Transportation Accidents

Regarding non-radiological impacts of transportation accidents, in the most conservative case 

evaluated in the transportation analysis, there would be about 2.6 accidents per year involving 

trucks carrying spent IERs or empty casks, which is 0.0007 percent of the 2009 U.S. annual 

tractor-trailer truck accident rate. From these accidents, there would be about 0.02 traffic fatality 

per year, which is equivalent to 1 fatal accident every 50 years and represents 0.004 percent of 

2009 U.S. tractor-trailer truck accident fatalities. There is little variation between these results 

for the various alternatives and representative transportation routes evaluated. 

Regarding radiological impacts of transportation accidents in which no radioactive materials are 

released, for the most conservative cases evaluated in the analysis, the collective population 

dose as a percentage of U.S. average annual background dose would be 0.01 percent, and the 

corresponding collective LCF as a percentage of estimated annual traffic fatalities involving 

spent IER shipments and of 2010 estimated U.S. cancer fatalities would be 0.136 percent and 

7.7 × 10-9 percent, respectively. Again, there is little variation between these results for the 

various alternatives and representative transportation routes. 

Regarding radiological impacts of transportation accidents in which radioactive materials could 

be released from Type A and Type B casks (a) For the Type A cask accident scenario, the MEI 

dose and LCF as percentages of U.S. average annual background and 2010 U.S. total 

estimated cancer fatalities would be 36 percent and 1 × 10-8 percent, respectively, for BWRs 
5-51

and PWRs; (b) For the Type B cask accident scenario, at most (for BWRs), the MEI dose and 

LCF as percentages of background and 2010 estimated cancer fatalities would be 19 percent 

and 6 × 10-9 percent, respectively; and the corresponding collective dose and LCF percentages 

would be 0.25 percent and 2 × 10-7 percent, respectively. 

5.2.8 Waste Management 

Spent IER handling, transport, processing, and disposal, and construction of relatively small 

long-term spent IER storage facilities, would not result in substantial generation of radioactive, 

hazardous, mixed, or non-hazardous solid waste that would adversely affect safety, waste 

disposal capacity, or other resources. Liquid effluents (including stormwater) from facility 

operations and construction activities would be managed in accordance with applicable Federal 

and State regulations, including discharging within permitted limits (e.g., NPDES requirements

and dose-based requirements under 10 CFR 20.1301).

5.2.9 Water Resources 

With regard to water quality, only permitted liquid effluent discharges, within regulatory limits, 

would be allowed at all facilities, as applicable. Sediment discharges during construction of the 

relatively small long-term spent IER storage facilities in Alternatives 3 and 4A would be 

controlled through implementation of BMPs (e.g., earth berms, dikes, sediment fences). 

Accidental spills would be immediately addressed in accordance with SPCC plans. With regard 

to potential impacts on water supply, the small quantities of water that would be used at the 

spent IER processing facilities, and for dust suppression and other activities (e.g., equipment 

washing) at the waste disposal facilities and during construction of the relatively small long-term 

spent IER storage facilities in Alternatives 3 and 4A, would be expected to result in minimal 

impacts to water supply. There would be minimal water use associated with spent IER 

handling, transport, and long-term storage.
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6-1 

6 REFERENCES

(American Cancer Society, 2010) “Cancer Facts and Figures 2010”, American Cancer Society, 

Atlanta, GA.

(Anderson, 2009) Anderson, Sarah. “Companies Press NRC to Provide Clarity on Blending.” 

RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. Vol. 2, No. 27. pp. 2-

4. December 28. 

(Anderson, 2011) Anderson, Sarah. “EnergySolutions Outlines Blended Waste Disposal 

Proposal to Utah.” RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. 

Vol. 4, No. 12. pp. 7-8. March 11. 

(DOE, 1993) U.S. Department of Energy. Fundamentals Handbook Chemistry (Volume 2), U.S. 

Department of Energy, DOE-HDBK-1015/2-93. January.

(DOE, 2002) U.S. Department of Energy. “Environmental Impact Statement for a Geologic 

Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca 

Mountain, Nye County, Nevada.” DOE/EIS-0250F. Summary, Volumes I and II. Office of Civilian 

Radioactive Waste Management, Washington, D.C.

(DOE, 2011) U.S. Department of Energy. Manifest Information System, Volume and Activity 

Summary, January 1, 2010 through December 31, 2010. ADAMS Accession No. ML113130162. 

(DOE, 2012) U.S. Department of Energy. “Waste Isolation Pilot Plant (WIPP) Photo Gallery.” 

June 5. ADAMS Accession No. ML12158A090.

(DTS, 2011) Diversified Technologies Services Inc. “Company Brochure: HVVTM Dewatering.” 

2680 Westcott Boulevard, Knoxville, TN 37931-3111. < http://www.dts9000.com/hvv.pdf> 

Accessed June 27, 2012. 

(EnergySolutions, 2009) EnergySolutions. Magette, T.E. “Blending of Low-Level Radioactive 

Waste, Presentation to U.S. Nuclear Regulatory Commission.” December 15. ADAMS 

Accession No. ML093620105.

(EPRI, 2007) Electric Power Research Institute. “An Evaluation of Alternative Classification 

Methods for Routine Low Level Waste from the Nuclear Power Industry.” Palo Alto, CA.

(Fischer et al., 1987) Fischer, L.E., Chou, C.K., Gerhard, M.A., Kimura, C.Y., Martin, R.W., 

Mensing, R.W., Mount, M.E., and M.C. Witte. “Shipping Container Response to Severe Highway 

and Railway Accident Conditions.” NUREG/CR-4829, UCID-20733. Prepared by Lawrence 

Livermore National Laboratory for the U.S. Nuclear Regulatory Commission, Division of Reactor 

System Safety, Office of Nuclear Regulatory Research.
6-2 

(Gonveau, 2005) Gonveau, Joseph. “Key Areas and Buildings at the Nuclear Power Plant Site,” 

The Virtual Nuclear Tourist. December 8. <http://www.nucleartourist.com/areas/areas.htm> 

Accessed June 25, 2012. 

(Grove, 2005) Grove Software, Inc. MicroShield User’s Manual Version 7. Lynchburg, VA.

(Herness, 2012a) Herness, Sarah. “WCS Becomes First New Disposal Site to Open in 

Decades.” RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. Vol. 5, No. 

18. pp. 2-3. April 27.

(Herness, 2012b) Herness, Sarah. “Texas Compact Approves Import Shipments to WCS.” 

RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. Vol. 5, No. 28. pp. 2-

3. July 6.

(Herness, 2013) Herness, Sarah. “Texas Law Gives WCS Window for Additional Import 

Disposal.” RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. Vol. 6, No. 

26. June 21.

(IAEA, 2002a) International Atomic Energy Agency, Technical Report. ”Application of Ion 

Exchange Processes for the Treatment of Radioactive Waste and Management of Spent Ion 

Exchangers.” Series No. 408. Vienna, Austria.

(IAEA, 2002b) International Atomic Energy Agency. “Advisory Material for the IAEA Regulations 

for the Safe Transport of Radioactive Materials.” IAEA Safety Standards Series TS-G-1.1. 

Vienna, Austria.

(ISCORS, 2002) Interagency Steering Committee on Radiation Standards. “Final Report: A 

Method for Estimating Radiation Risk from Total Effective Dose Equivalent (TEDE).” ISCORS 

Technical Report No. 1. US DOE Office of Environmental Policy and Guidance, Washington, 

DC.

(Johnson and Michelhaugh, 2003) Johnson, P.E. and R.D. Michelhaugh. “Transportation 

Routing Analysis Geographic Information System (TRAGIS) User Manual.” ORNL/NTRC-2006, 

Oak Ridge National Laboratory.

(Johnson, 2011) Email from P.E. Johnson to Ruth Weiner dated November 1, 2011. “Subject: 

TRAGIS Statement.” ADAMS Accession No. ML113130173.

(Lowman, 2011) Memo from Donald Lowman, NRC, to file. September 14. ADAMS Accession 

No. ML112430157.

(Mason et al., 1999) Mason, J.B., Oliver, T.W., Carson, M.P., and Hill, M.H. “Studsvik 

Processing Facility Pyrolysis/Steam Reforming Technology for Volume and Weight Reduction 

and Stabilization of LLRW and Mixed Wastes.” Tucson, Arizona: Waste Management ’99 

Conference Proceedings. February 28-March 4.
6-3 

(NCRP, 2009) National Council on Radiation Protection & Measurements. “Ionizing Radiation 

Exposure of the Population of the United States.” Report No. 160, Bethesda, MD. 

(NRC, 1977) U.S. Nuclear Regulatory Commission. “Final Environmental Statement on the 

Transportation of Radioactive Material by Air and Other Modes,” Volumes I and II. NUREG0170. December. ADAMS Accession Nos. ML022590355 (Volume1) and ML022590511 

(Volume 2).

(NRC, 1985) U.S. Nuclear Regulatory Commission. Siskind, B., Dougherty D.R., and 

MacKenzie, D.R. “Extended Storage of Low-Level Radioactive Waste: Potential Problem 

Areas.” NUREG/CR-4062. December. ADAMS Accession No. ML080710258.

(NRC, 1989a) U.S. Nuclear Regulatory Commission. NRC Information Notice No. 89-27, 

“Limitations on the Use of Waste Forms and High Integrity Containers for the Disposal of LowLevel Radioactive Waste.” March 8. ADAMS Accession No. ML031180600.

(NRC, 1989b) U.S. Nuclear Regulatory Commission. Soo, P., Anderson, C.I., and Clinton, J.H. 

“A Study of the Use of Crosslinked High-Density Polyethylene for Low-Level Radioactive Waste 

Containers.” NUREG/CR-5363, BNL-NUREG-52196. June 1. ADAMS Accession No. 

ML12178A228.

(NRC, 1995) U.S. Nuclear Regulatory Commission. “Branch Technical Position on 

Concentration Averaging and Encapsulation,” January 23, 1995, Federal Register, (60 FR 

4451).

(NRC, 2003) U.S. Nuclear Regulatory Commission. “Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs.” NUREG-1748. August. ADAMS Accession 

No. ML032450279. 

(NRC, 2007) U.S. Nuclear Regulatory Commission. Ryan, M., Lee, M.P., and Larson, H.J. 

“History and Framework of Commercial Low-level Radioactive Waste Management in the United 

States.” NUREG-1853. January. ADAMS Accession No. ML070600684.

(NRC, 2010a) U.S. Nuclear Regulatory Commission. “Blending of Low-Level Radioactive 

Waste.” NRC Commission Paper, SECY-10-0043. April 7. ADAMS Accession No. 

ML090410246. 

(NRC, 2010b) U.S. Nuclear Regulatory Commission. “Blending of Low-Level Radioactive 

Waste.” NRC Commission Staff Requirements Memorandum, SRM-SECY-10-0043. October 

13. ADAMS Accession No. ML102861764.

(NRC, 2010c) U.S. Nuclear Regulatory Commission. Official Transcript of Proceedings. “Public 

Meeting on Low-Level Radioactive Waste, Rockville, Maryland.” January 14. ADAMS Accession 

No. ML100220019. 
6-4 

(NRC, 2012) U.S. Nuclear Regulatory Commission. “Draft Comparative Environmental 

Evaluation of Alternatives for Handling Low-Level Radioactive Waste Spent Ion Exchange 

Resins from Commercial Nuclear Power Plants.” Draft Report for Comment. September. 

ADAMS Accession No. ML12256A965.

(Nuclear Power Daily, 2010) Nuclear Power Daily. “Utah Radioactive Waste Facility Under 

Interstate Compact Authority.” November 22. 

<http://www.nuclearpowerdaily.com/reports/Utah_Radioactive_Waste_Facility_Under_Interstate

_Compact_Authority_999.html> Accessed June 25, 2012.

(Purolite®, 2011) The Purolite Company. “Nuclear Grade Ion Exchange Resins for Power 

Generation.” Purolite® Product NRW Bulletin 19012010. 150 Monument Road, Bala Cynwyd, 

PA 19004.

(SC DHEC, 2007), South Carolina Department of Health and Environmental Control (SC 

DHEC). Commercial Low-Level Radioactive Waste Disposal in South Carolina, Columbia, SC, 

CR-000907, March. 

(Shleien et al., 1998) Shleien, B., Slaback, L.S., Birky, B.K. 1998. Handbook of Health Physics 

and Radiological Health, Third Edition. Williams and Wilkins, Baltimore, MD. 

(Sprung et al., 2000) Sprung, J.L., Ammerman, D.J., Breivik, N.L., Dukart, R.J., Kanipe, F.L., 

Koski, J.A., Mills, G.S., Neuhauser, K.S., Radloff, H.D., Weiner, R.F., and H.R. Yoshimura. 

“Reexamination of Spent Fuel Shipment Risk Estimates, Volumes 1 and 2.” NUREG/CR-6672, 

SAND2000-0234. Prepared by Sandia National Laboratories for the U.S. Nuclear Regulatory 

Commission, Spent Fuel Project Office, Office of Nuclear Material Safety and Safeguards. 

(Steinman et al., 2002) Steinman, R.L., R.F. Weiner, and K. Kearfott. “Comparison of Transient 

Dose Model Predictions and Experimental Measurements.” Health Physic., Vol. 83. p. 504, et 

seq.

(Studsvik, 2009) Studsvik, Inc., Rockville, MD. “Comments on Blending of Low-Level 

Radioactive Waste (NRC-2009-0520).” December 14. ADAMS Accession No. ML093620111. 

(Studsvik, 2012) Studsvik, Inc. “Studsvik Company Brochure: Processing of Organic and Wet 

LLW/ILW (Processing of Radioactive Waste): THORsm – Studsvik’s Thermal Volume Reduction 

Technology.” 5605 Glenridge Drive, Suite 705, Atlanta, Georgia 30342.

(THORsm, 2006) THOR Treatment Technologies, LLC. “THORsm Steam Reforming Process for 

Hazardous and Radioactive Wastes, Technology Report, TR-SR02-1, Rev. 1.” Richland, WA. 

ADAMS Accession No. ML120730124. 

(Tran and James, 2008) Tran, P. and James, D. “EPRI Takes on Low-Level Waste Disposal 

Issues.” Electric Power Research Institute, Radwaste Solutions, A Publication of the American 

Nuclear Society, Volume 18, Number 3, pp. 14-21. May/June.
6-5 

(URS, 2009) URS Washington Division. “LaSalle Dewatered Resin Flammable Gas Generation 

Assessment.” Technical Report Supporting Engineering Change, Project No. 29487-NC0097, 

EC No. 375636. Rev. 0, Appendix B. September 28.

(USDOT, 2010) U.S. Department of Transportation. “State Transportation Statistics 2010.” 

Bureau of Transportation Statistics, Washington, DC.

(USDOT, 2011) U.S. Department of Transportation, Bureau of Transportation Statistics. 

“National Transportation Statistics, 2011.” U.S. Department of Transportation, Washington, DC.

(Waste Control Specialists, 2009) Waste Control Specialists LLC. “Press Release. WCS, 

Andrews County to Provide Texas Solution for Disposal of Low-Level Radioactive Waste.” 5430 

LBJ Freeway, Suite 1700, Dallas, Texas 75240. September 10. 

(Waste Control Specialists, 2011) Waste Control Specialists LLC. “Company Brochure: Meeting 

the Needs for Cost-Effective Waste Management Services.” 5430 LBJ Freeway, Suite 1700, 

Dallas, TX 75240. <http://www.wcstexas.com/index.shtml> Accessed August 5, 2013. 

(Waste Control Specialists, 2012) Waste Control Specialists LLC. “Press Release: WCS 

Commences Low-Level Radioactive Waste Disposal Operations.” 5430 LBJ Freeway, Suite 

1700, Dallas, TX 75240. April 27.

(Weiner et al., 2009) Weiner, R.F., Dennis, M.L., Hinojosa, D., Heames, T.J., Penisten, J.J., 

Marincel, M.K., and Osborn, D.M. RADCAT 3.0 User Guide. 2009. SAND2009-5129P, Sandia 

National Laboratories, Albuquerque, NM.

(Wikipedia, 2012) “Ion Exchange Resins>” Wikipedia. The Free Encyclopedia. 

<http://en.wkkipedia.org/wiki/Ion_exchange_resins> Accessed June 25, 2012. 
6-6 

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A-1 

APPENDIX A 

TRANSPORTATION ANALYSIS: 

METHODOLOGY, ASSUMPTIONS, AND POTENTIAL IMPACTS 

 
A-2 

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A-3 

A.1 Introduction 

A.1.1 Overview 

This appendix presents a detailed technical analysis of potential transportation impacts of the 

six alternatives identified by the U.S. Nuclear Regulatory Commission (NRC) staff for handling 

low-level radioactive waste (LLRW) spent ion exchange resins (IERs) from commercial nuclear 

power plants (NPPs). Sections 3.1 and 4 of the main report present descriptions of the six 

alternatives. This analysis was prepared with assistance from the Risk and Reliability Analysis 

Department and Environmental Safety and Testing Department of Sandia National Laboratories 

(SNL), Albuquerque, New Mexico. 

For reasons discussed in Section 3.1, the six alternatives evaluated in this report are generic 

and not location-specific. The transportation analysis is based on conservative, often bounding 

assumptions that are consistent with the alternatives. Note also that the transportation impact 

evaluation used quantitative information such as estimated numbers of shipments of full and 

empty spent IER shipping casks, quantities of waste transported in shipments, and trip lengths 

and population densities based on representative transportation routes. Results are 

correspondingly expressed quantitatively, although they are limited by the generic, non-locationspecific nature of the six alternatives and, therefore, are also assessed qualitatively in this 

appendix and in the main report. 

Additionally, this analysis focuses entirely on the potential impacts of transportation of the spent 

IERs, primarily because the bulk of potential transportation impacts of the six alternatives would 

result from the shipment of these wastes. It is recognized that there would also be impacts 

resulting from transportation of operational workforces, raw materials, supplies, and incidental 

process wastes to and from the waste processing and disposal facilities. Transportation 

impacts related to the operations of the NPPs are not addressed because these impacts have 

already been assessed by the NRC in the environmental impact statements (EIS’s) prepared in 

association with the licensing of these facilities. 

As discussed in Section 4.1.2.1, when transported on public roadways, the spent IERs are 

shipped in shielded shipping containers, or casks, on large, legal weight or overweight trucks 

(usually 18-wheel, semi-detached flatbed trailer trucks). In the six alternatives considered in this 

evaluation, spent IER truck shipments of full and returned empty shipping casks may occur 

between NPPs and centralized waste processing facilities (for spent IER blending or volume 

reduction), between NPPs and LLRW disposal facilities, and between waste processing facilities 

and LLRW disposal facilities. The potential effects of routine transportation1

 of untreated and 

treated (processed) spent IERs and empty casks in the various alternatives on traffic volumes 

and patterns (e.g., traffic congestion) nationally and in areas local to the waste processing and 

waste disposal facilities are considered in the analysis. Routine transportation of radioactive 

materials could also affect air quality, noise, and road surface wear. 

 

1

 Routine transportation takes place without incident. A transportation incident is any event that interferes with 

transportation between origin and destination. A transportation accident is an event that results in death, injury, or 

enough damage to an involved vehicle that the vehicle cannot move under its own power. All accidents are incidents. 
A-4 

In addition, transporting radioactive materials under any conditions could pose inherent risks 

and impacts to members of the public due to possible radiation exposure during routine 

transportation or because of transportation accidents. Facilities and transporters that handle 

radioactive materials must comply with regulatory requirements and have standard operating 

procedures (SOPs) in place to minimize these risks and protect worker and public health and 

safety. Note that exposures of “radiation workers” (e.g., truck crews, package handlers, 

inspectors, and emergency responders) are not considered in this analysis because these 

workers are specially trained in, and knowledgeable of, necessary hazardous materials and 

radiation safety requirements and procedures, and are monitored and have radiation exposure 

limits stipulated by NRC regulation in 10 CFR 20.1201. 

Three categories of transportation impacts listed below are assessed in this evaluation. These 

categories capture the range of reasonable potential impacts to the public from the 

transportation of spent IERs (full and empty casks). 

 Impacts of spent IER shipments on local traffic near centralized waste processing 

facilities and LLRW disposal facilities, and on total traffic in the U.S. Vehicle traffic on 

public roadways, including large trucks that carry spent IERs and empty shipping 

containers, affects air quality (e.g., due to vehicle exhaust emissions), noise levels, 

traffic accident likelihood, and roadway congestion. The potential impacts on local traffic 

near centralized spent IER processing facilities (for blending or volume reduction) and 

LLRW disposal facilities are analyzed. The analysis assumes that spent IER processing 

facilities would most likely be located in industrial areas with already existing large truck 

traffic and other vehicular traffic associated with the operations of the various industrial 

and commercial facilities in these areas. LLRW disposal facilities are typically located 

far from populated areas. The potential impact that the trucks would have on national 

traffic is also analyzed. In both cases (local and national), the associated transportation 

impacts would be like those from any other large tractor-trailer trucks carrying cargo on 

public roadways. 

 Radiological impacts to members of the public from routine, incident-free transport of 

spent IERs. Radiation doses2 to members of the public (individuals and populations) 

during routine spent IER shipments (full containers) are estimated using the RADTRAN 

6 computer code (Neuhauser et al., 2000; Weiner et al., 2009). Such radiation doses 

could result from external radiation emanating from the shipping casks. RADTRAN 6 is 

the nationally accepted, standard computer program for calculating the risks of 

transporting radioactive materials. 

 Non-radiological and radiological impacts to members of the public from transportation 

accidents involving spent IER shipments. Accidents during transport of spent IERs (full 

casks) could have both non-radiological and radiological impacts on members of the 

public. Non-radiological impacts of transportation accidents are assessed in terms of the 

 

2

 Radiation dose, or simply dose, is a measure of the biological damage to an individual from ionizing radiation. 

Millisieverts (mSv) are the unit of measure of the effect ionizing radiation has on people. As a point of reference, the 

average annual background dose from natural sources of radiation received by a person in the U.S. is about 3.11 

mSv (311 mrem) (NCRP, 2009). 
A-5 

estimated numbers of traffic accident and traffic accident fatalities from implementation 

of each alternative. RADTRAN 6 is used to estimate the potential radiological impacts 

for cases in which radioactive materials (i.e., spent IERs) are not released and are 

released to the environmental as a result of transportation accidents. 

A.1.2 Key General Assumptions Used in This Transportation Analysis 

A number of assumptions form the basis of this analysis of transportation impacts. Section 3 of 

the main report presents assumptions that apply to the entire evaluation. General assumptions 

that are specific to this transportation analysis are discussed below. Additional assumptions 

that are specific to the three analysis categories described above are discussed in the 

corresponding parts of Section A.3 of this appendix. 

In this analysis, it is assumed that all transportation of untreated and treated (processed) spent 

IERs on public roadways would be by truck, because this is likely to be the most common mode 

of transport of spent IERs. It is further assumed that all shipping casks are full when carrying 

spent IERs from an origin to a destination, and then always returned empty to the origin. Based 

on this assumption, the transportation analysis considered that the shipping casks used to 

transport the spent IERs from the NPPs to the waste processing facilities or waste disposal 

facilities and from the waste processing facilities to the waste disposal facilities, would all be 

returned empty to the NPPs or waste processing facilities from which they originated. The 

analysis also considered that separate shipping casks would be used to ship processed 

(blended or volume-reduced) spent IERs between the waste processing facilities and waste 

disposal sites. 

Note, however, that in actual practice, trucks transporting shipping casks full of spent IERs from 

NPP origins to spent IER processing facility destinations could then transport the processed 

resins directly to the LLRW disposal sites rather than returning to the NPPs. In Alternatives 1A, 

1B, 4A, and 4B, which involve spent IER processing (blending or volume reduction), this would 

reduce the total number of trips and the total number of miles driven. There is a direct relation 

between transportation impacts and numbers of shipments (trips) and miles driven (i.e., more 

trips or miles driven results in more impacts). Thus, since this transportation analysis makes the 

conservative assumption that full shipping casks are always transported from an origin to a 

destination and then return empty to the origin, the analysis overestimates the number of trips 

and corresponding miles driven and correspondingly conservatively estimates potential 

transportation impacts of the four waste processing alternatives.3

 

 

3

 It was also considered that LLRW processing and disposal companies frequently are the owners of the shielded 

shipping casks that would be used to transport the spent IERs, and would try to use these casks as efficiently as 

possible. As such, these companies would most likely seek to optimize the use of their shipping casks and, therefore, 

would likely keep them on the move throughout the U.S. and would minimize the miles driven carrying empty casks. 

Thus, the NRC staff believes that the assumption in this analysis that full containers of spent IERs are always 

returned empty to their origins, which essentially doubles the numbers of shipments (trips) and miles driven, still 

results in very conservative estimates of actual transportation impacts. 
A-6 

A.1.3 Organization of the Remainder of this Appendix 

The remainder of this appendix is organized as follows: 

 The estimated number of annual truck shipments of spent IERs and returned empty 

containers for each of the six alternatives is developed and presented in Section A.2. 

 Potential transportation impacts of the six alternatives, in each of the three impact 

categories identified earlier, are discussed in Section A.3. 

 References cited in this appendix are listed in Section A.4. 

A.2 Estimated Annual Number of Truck Shipments by Alternative 

The transportation analysis in this appendix is based largely on the annual number of truck 

shipments for each of the six alternatives. This section provides estimates of these numbers of 

truck shipments, as well as the methods and assumptions used to derive these estimates. The 

annual number of truck shipments depends on factors such as the total volume of spent IERs to 

be transported per year by waste classification, sizes of containers used for transport, and the 

number of containers that can be carried on each truck. 

A.2.1 Volume and Classification of Spent IERs Generated Annually 

The estimated average annual volumes of spent IERs generated by the 65 operating U.S. 

commercial NPPs, by waste classification, are shown in Table 2 in Section 2.1.3 of the main 

report. From this table, the projected average total annual volume of spent IERs generated is 

2568 cubic meters (m3

) (90,620 cubic feet (ft3)), of which 2215 m3 (78,182 ft3) are Class A 

concentration, 319 m3

 (11,258 ft3) are Class B concentration, and 34 m3 (1180 ft3) are Class C 

concentration. 

A.2.2 Spent IER Shipping Requirements 

As discussed in Section 2.1.2, prior to shipping, spent IERs are placed in High Integrity 

Containers (HICs) or liners at the NPPs. As discussed in Section 4.1.2.1, the spent IERs are 

generally sufficiently radioactive that they must be transported in special transportation 

containers when shipped on public roads. The HICs or liners are placed in these special 

transportation containers for offsite shipment. The type of shipping container that is used 

depends on a number of factors, including the mix of radionuclides in the material, the specific 

activity mix of radionuclides, and the unshielded dose rate from the HIC or liner. 

“Low specific activity” spent IERs may be shipped as NRC-defined Low Specific Activity (LSA) 

material4

 in industrial packages (shipping containers) that are not certified by the NRC 

 

4 Low Specific Activity (LSA) material means radioactive material with limited specific activity which is nonfissile or is 

excepted under 10 CFR 71.15, and which satisfies the descriptions and limits for LSA-I, LSA-II, and LSA-III materials 

set forth in 10 CFR 71.4. Shielding materials surrounding the LSA material may not be considered in determining the 

estimated average specific activity of the package contents. (10 CFR 71.4)
A-7 

(i.e., packages that are exempt from NRC certification), if the specific activity (the activity per 

unit mass) of the spent IERs is low enough and other requirements are met. The following three 

criteria must be met for shipping spent IERs as LSA material (specifically LSA-II): 

 Average specific activity does not exceed one-ten thousandth of the A2 value5

 per gram 

of material (10 CFR 71.4)6

; 

 External radiation from the shipping package must not exceed 0.1 millisievert (mSv)/hour 

(10 millirem (mrem)/hour) at 2 meters (m) (6.6 feet (ft)) (10 CFR 71.47(b)(3)); and 

 The material must have an external radiation dose less than or equal to 10 mSv/hour 

(1 rem/hour) at a distance of 3 m (10 ft) from the unshielded material (10 CFR 

71.14(b)(3)(i)). 

Spent IERs that cannot be shipped as LSA material would be shipped in either a Type A or 

Type B shielded and certified shipping cask, depending on the A2 value of the contents of the 

shipping container (10 CFR Part 71, Appendix A). If the radioactivity of the spent IERs in the 

HIC or liner does not exceed the A2 value, the spent IERs can be shipped in Type A shipping 

casks. If the radioactivity of the spent IERs in the HIC or liner exceeds the A2 value, the spent 

IERs are shipped in Type B casks. (See Table A-18 in Section A.3.3.2.2 later in this appendix 

for the calculation of the A2 value for typical spent IER shipments.) 

Note that there could be special cases resulting from the NRC regulations discussed above for 

shipments of materials (e.g., spent IERs) that meet the definition of LSA, two such cases are 

listed below: 

 A package of spent IERs that meets the LSA criteria, and can be shipped as LSA, could 

contain more than the A2 value as long as the LSA criteria of 10 CFR Part 71 are met. 

 Low specific activity material (i.e., material that has a specific activity less than or equal 

to one-ten thousandth of the A2 value per gram) would be shipped in a Type A cask if the 

external dose rate from the package is too high and the package requires the shielding 

that the Type A cask provides. 

Although some spent IERs may be shipped as LSA in industrial packages, this evaluation 

assumes that all the spent IERs are shipped in Type A and Type B casks. The Type A and 

Type B casks that are typically used for shipping spent IERs from commercial NPPs are the 

Chem-Nuclear Systems (CNS) 14-215 and the CNS 8-120B, respectively. Table A-1 

summarizes the specifications (capacities, dimensions, and loaded weights) of these two 

 

5

 The A2 value is the maximum amount of radioactive material (measured in curies or becquerels), other than special 

form, Low Specific Activity (LSA), and Surface Contaminated Object (SCO) materials, permitted in a Type A package. 

This value is either listed in 10 CFR Part 71, Appendix A, Table A-1, or may be derived in accordance with the 

procedures prescribed in 10 CFR Part 71, Appendix A . (10 CFR 71.4) (See complete definitions of LSA and SCO 

materials in 10 CFR 71.4.)

6

 For LSA-II material. 
A-8 

shipping cask types. A number of different sizes of HICs or liners will fit inside each type of 

shipping cask (EnergySolutions 2010a; 2010b); however, this evaluation is based on the largest 

liner that will fit in each type of shipping cask because industry typically maximizes the volume 

of spent IERs shipped in each cask. 

Table A-1 Specifications of Type A and Type B Shipping Casks 

DIMENSIONS TYPE A CASKa

(CNS 14-215) 

TYPE B CASKb

(CNS 8-120B) 

Capacity of the liner that fits inside the cask 

(L14-195 liner for Type A and L8-120 liner for 

Type Bc

) (m3 (ft3)) 

5.29 (187) 3.17 (112) 

Total Length of Cask (m (ft))d 2.16 (7.09) 2.24 (7.33)

Outer Diameter of Cask (m (ft)) 2.06 (6.76) 1.88 (6.17)

Maximum Loaded Weight (metric tons (tons)) 26.5 (29) 29 (32)

 a Source: EnergySolutions, 2010b. 

 b Source: EnergySolutions, 2010a. 

 c The model L14-195 and L8-120 liners are used for illustrative purposes in the evaluation. Other 

 liner types are available for use for containing spent IERs. 

 d m = meters; ft = feet. 

The assumption that all the spent IERs are shipped in Type A or Type B casks results in a more 

conservative analysis than assuming that some spent IERs are shipped as LSA in industrial 

packages. This assertion is directly tied to four primary factors detailed in this appendix upon 

which potential environmental impacts of transporting spent IERs are based: (1) the total 

number of shipments (affects local and national traffic); (2) the radiation dose rate from the 

shipping container (affects radiation doses to members of the public from routine, incident-free 

transport); (3) the number of miles driven (affects the potential number of transportation 

accidents); and (4) the dose rate from unshielded material (affects the potential impacts from an 

accident in which the radioactive contents of a shipping container are released). Each factor is 

discussed below, to establish why the assumed use of only Type A and Type B casks for spent 

IER shipments is more conservative than using industrial packages for some shipments: 

1. Total number of shipments: Because Type A and Type B packages incorporate heavy 

shielding and Type B packages also have impact load limiters, the weight of Type A and 

B casks is higher than for industrial packages; and while more than one industrial 

package would be transported per truck shipment to optimize shipping, only one Type A 

or Type B cask can be transported per truck. Thus assuming the use of only Type A and 

B packages for spent IER transport results in the estimation of more shipments and, 

therefore, greater potential impacts on local and national traffic, than would be estimated 

when using smaller, lighter industrial packages for some shipments. 

2. Dose rate from the shipping container: By regulation, the maximum allowable dose rate 

on the outside of the shipping container is the same for LSA, Type A, and Type B 

packages (i.e. 0.1 mSv/hour (10 mrem/hour) at 2 m (10 CFR 71.47(b)(3))). Because the 
A-9 

external package dose limit is the same for all three package types (i.e., LSA = Type A = 

Type B), and there will be more shipments if using only Type A and Type B casks (see 

above), the estimated population dose is increased by the assumption that all shipments 

are in Type A and Type B casks. 

3. Number of miles driven: Since assuming the use of only Type A and B packages results 

in the estimation of more shipments and, therefore, more miles driven than would be 

estimated when using industrial packages for some shipments, it follows that the more 

miles that are driven, the more potential transportation accidents could occur. 

4. Dose rate from unshielded material: In Section A.3.3.2.2, the dose to the maximally 

exposed member of the public is calculated, based on an accident that releases the 

entire A2 quantity of spent IERs from a Type A cask. In this accident scenario, the 

estimated dose to the member of the public of 1.11 mSv (111 mrem) is based on a 10 

hour exposure, at 30 m, to an unshielded A2 quantity of spent IERs (see Table A-19). If 

instead of a Type A cask with an A2 quantity, the contents of an industrial package, 

carrying spent IERs as LSA-II were released, the dose to a member of the public would 

be lower, at 1 mSv (100 mrem).7

 

Truck shipments of spent IERs in Type A and Type B casks are generally transported on 

interstate highways, and on other primary U.S. highways where interstate highways are not 

available. Both Type A and Type B shipping casks are usually transported using tractor-trailer 

trucks with semi-detached flatbed trailers. Only one Type A or one Type B cask can be carried 

per truck shipment because the total weight of two or more casks, plus the weight of the tractortrailer, would exceed the U.S. interstate system weight limit of 36 metric tons (40 tons) 

established by the U.S. Department of Transportation (USDOT, 1995). Although tractors pulling 

more than one trailer are allowed on some interstate highways (USDOT, 1995), this evaluation 

conservatively assumes one trailer per tractor. Therefore, for this evaluation, it is assumed that 

a tractor-trailer truck would carry one Type A or one Type B shipping cask, either of which would 

hold one HIC or liner of spent IERs. 

A.2.3 Annual Numbers of Truck Shipments 

The annual number of truck shipments for each alternative is estimated using information from 

Sections A.2.1 and A.2.2 above. For this estimate, it is assumed that the total annual volume of 

spent IERs (2568 m3

 (90,620 ft3)) would be managed under each alternative, and there would 

be no mix of alternatives (see Section 3.1). 

For the generic, non-location-specific alternatives considered in this evaluation, the A2 value of 

each HIC or liner volume to be transported is not known; therefore, information on past shipping 

 

7

 This dose to a member of the public is based on the following: The regulatory maximum dose rate for unshielded 

LSA is 10 mSv/hour @ 3 m (10 CFR 71.14(b)(3)(i)). Thus 10 hours of exposure at 3 m gives a dose of 100 mSv at 3 

m. Then to calculate what this dose of 100 mSv at 3 m would be at 30 m, since dose is inversely proportional to the 

square of the distance from the source, 100 mSv is multiplied by the ratio of squares of the distances (3 m and 30 m). 

The dose for 10 hours of exposure @ 30 m = [(3 x 3) / (30 x 30)] x 100 mSv = 1 mSv. 
A-10 

practices is used to project the fractions of future spent IER shipments made in Type A and 

Type B casks. Information from EnergySolutions on actual LLRW spent IER shipments 

received at the Barnwell, South Carolina, LLRW disposal facility during a recent 10-year period 

indicates that approximately 78.5 percent of the shipments were in Type A casks and 

21.5 percent were in Type B casks (Magette, 2011). As discussed in Section A.2.2, lower 

activity LLRW would be shipped in Type A casks and higher activity LLRW would be shipped in 

Type B casks. As illustrated in the discussion of Table 2 in Section 2.1.3, approximately 86 

percent of the spent IERs generated annually contain Class A concentrations of radionuclides, 

and 14 percent contain Class B or C concentrations. These percentages correlate fairly well 

with the numbers reported by Magette for Type A and Type B cask shipments to the Barnwell 

LLRW disposal site. Thus, for the purposes of this analysis, it is reasonably assumed that all of 

the lower activity Class A concentration spent IERs would be shipped in Type A casks and all of 

the higher activity Class B and C concentration spent IERs would be shipped in Type B casks. 

It is also assumed that Class B and Class C concentration spent IERs could be shipped 

together in the same cask. 

Based on the assumption that only one Type A or one Type B cask would be carried per truck 

shipment, the annual number of truck shipments with full casks would be the same as the 

annual number of cask volumes, or casks that would need to be shipped. Thus, the annual 

number of casks that would be shipped in each of the six alternatives is estimated based on the 

total annual volumes of spent IERs, by waste classification, that would need to be transported in 

each shipment step8

 of each alternative divided by the volume of the appropriate HIC or liner for 

each cask type (shown in Table A-1). 

However, the following base calculations were first done to estimate the total number of 

shipping casks volumes of each type that could be filled annually by the 65 NPPs. These 

numbers of cask volumes would be the same as the numbers of shipping casks of each type 

that could be filled and potentially shipped from the NPPs. Estimated annual spent IER 

volumes from Section A.2.1 and liner volumes by cask type from Table A-1 were used in these 

calculations, as follows (with results are rounded to the nearest whole number): 

 To estimate the annual number of Type A cask volumes that could be filled by the NPPs, 

the total annual volume of Class A concentration spent IERs is divided by the capacity of 

the liner that fits in the Type A cask, i.e., 2215 m3

/year (Class A) ÷ 5.29 m3 (Type A cask) 

≈ 419 Type A cask volumes/year. 

 To estimate the annual number of Type B cask volumes that could be filled by the NPPs, 

the total annual volume of Class B and C concentration spent IERs is divided by the 

capacity of the liner that fits in the Type B cask, i.e., [319 m3

/year + 34 m3/year (Class B 

and C)] ÷ 3.17 m3

 (Type B cask) ≈ 111 Type B cask volumes/year. 

 

8

 Examples of “shipment steps” in the various alternatives include shipment of spent IERs from the NPPs to a waste 

processing facility and shipment of spent IERs from a waste processing facility to a waste disposal facility. 
A-11 

Based on these foundation calculations and on applicable assumptions stated above and in the 

main report, the number of spent IER shipments annually for each alternative is estimated as 

follows: 

 Alternative 1A—Disposal of Blended Class A, B, and C Spent IER LLRW from a Central 

Processing Facility (using Mechanical Mixing): There would be 530 spent IER 

shipments from the NPPs to the central processing (blending) facility (419 Type A and 

111 Type B cask shipments) and 530 casks returning empty to the NPPs, for a total of 

1060 shipments annually. After processing, since the blended Class A, B, and C 

concentration spent IERs would have Class A status, all shipments from the blending 

facility to the disposal facility could be in Type A casks. Also, since the blending process 

in this alternative uses a mechanical mixing process that does not appreciably affect the 

waste volume (see Section 4.2.1), the volume of the processed spent IERs coming out 

of the blending facility would be approximately the same as the volume of untreated 

spent IERs coming into the blending facility from the NPPs (i.e., 2568 m3

). Therefore, 

485 Class A LLRW spent IER shipments (2568 m3 ÷ 5.29 m3 per Type A cask shipment) 

would travel from the processing facility to the disposal facility, and 485 would return 

empty to the blending facility, for a total of 970 shipments annually. Thus, there would 

be a total of 2030 shipments annually in this alternative (1060 shipments + 970 

shipments). 

 Alternative 1B—Disposal of Blended Class A, B, and C Spent IER LLRW from a Central 

Processing Facility (using Thermal Processing): The blending process in this alternative 

uses a thermal treatment process that would not reduce or otherwise appreciably 

change the volume of the spent IERs (see Section 4.2.2). Therefore, since Alternatives 

1A and 1B are essentially the same except for the blending process used, the number of 

annual shipments and cask types used for Alternative 1B would be the same as for 

Alternative 1A (i.e., 2030 shipments annually). 

 Alternative 2—Direct Disposal of Class A, B, and C Spent IER LLRW: There would be 

530 shipments from the NPPs directly to the disposal facility (419 Type A and 111 Type 

B cask shipments) and 530 casks returning empty to the NPPs, for a total of 1060 

shipments annually. 

 Alternative 3—Long-term Onsite Storage of Class B and C Concentration Spent IERs, 

then Disposal: As discussed in Section 4.2.4, Alternative 3 is divided into three separate 

and distinct stages over time—(1) “Years 1-20”, (2) “Year 21”, and (3) ”After Year 21”. 

o Years 1-20--As discussed in Section 4.2.4, all Class A concentration spent IERs 

would have a disposal pathway and would be shipped for direct disposal. The 

Class B and C concentration spent IERs would be placed in long-term storage at 

the NPP sites for 20 years awaiting disposal. Thus, there would be 419 

“immediate”, direct annual shipments of Class A LLRW spent IERs from the 

NPPs to the Class A disposal facility in Type A casks and 419 returning empty, 

for a total of 838 shipments annually over the 20-year period of storage of the 
A-12 

Class B and C concentration resins. With regard to the Class B and C 

concentration spent IERs, there would be 111 cask volumes of these resins 

generated annually. Therefore, 2220 cask volumes of this waste would 

accumulate in storage over the entire 20-year storage period. 

o Year 21--At the conclusion of the 20 years of accumulation, it is assumed for this 

evaluation that all 2220 cask volumes of stored Class B and C concentration 

spent IERs would be shipped to a disposal facility in the twenty-first year. Also in 

that twenty-first year, there would be an additional 111 cask volumes of Class B 

and C concentration spent IERs generated. Those plus the 2220 cask volumes 

in storage, for a total of 2331 cask volumes of Class B and C concentration spent 

IERs, would be shipped to the disposal facility in Type B casks, and 2331 casks 

would return empty, for a total of 4664 shipments in the twenty-first year. There 

would also be 419 shipments of Class A LLRW spent IERs in Type A casks to 

the disposal facility and 419 returning empty, for a total of 838 shipments. Thus, 

there would be an overall total of 5500 shipments to/from the disposal facility 

(4662 (Type B) + 838 (Type A)) in the twenty-first year. 

(NOTE: The assumption that there would be 5500 total shipments in the twentyfirst year, with 4662 of these in Type B casks (2331 full and 2331 empty), is likely 

a considerable overestimation of what would happen in actual practice, due 

largely to the limited number of Type B shipping casks that would be expected to 

be available at the time. This premise is based on there currently (early 2012) 

being only four Type B casks available in the U.S. for shipping the majority of 

Class B and C LLRW (i.e., the majority of all Class B and C LLRW, not only the 

spent IERs that comprise a small fraction of the total U.S. LLRW annually (see 

Section 2.1.3)) (Herness, 2012a). Assuming 250 workdays per year (based on 

50 work weeks/year x 5 workdays/week = 250 workdays), there would need to be 

an average of 9 to 10 shipments per day (2331 cask volumes/year ÷ 250 

workdays/year) every workday for a year to ship all 2331 cask volumes of Class 

B and C LLRW spent IERs in Type B casks in the twenty-first year. However, 

with the four Type B casks currently available, there presently could be at most 

only four spent IER shipments per day if the available Type B casks were used 

solely for Class B and C LLRW spent IER shipments. Again, however, these 

Type B casks would also be needed to ship other types of Class B and C LLRW 

generated annually in the U.S. Further, even if industry were to double the 

number of Type B casks as is currently planned (Herness, 2012a), and even if 

shipments were made 365 days a year, it would still not be possible to ship the 

entire 2331 cask volumes of Class B and C LLRW spent IERs in a single year. 

Instead, it would reasonably be expected to take several years to accomplish. 

Nevertheless, for simplicity, the analysis in this appendix very conservatively 

assumes there would be 4662 Type B cask shipments, and 5500 Type A and 

Type B cask shipments, in the twenty-first year of Alternative 3. This assumption 

is necessary and justifiable because there is no way to predict, or speculate on, 
A-13 

how many Type B casks would actually be available for Class B and C LLRW 

spent IER shipments following the 20-year storage period or how many years it 

would actually take to ship all of the stored Class B and C wastes from the NPPs 

for disposal. Thus, again, the assumption that all of the Class B and C 

concentration spent IERs would be shipped for disposal in twenty-first year 

clearly results is a substantial overestimate of the transportation impacts in Year 

21 of Alternative 3; and in reality, the impacts would most likely be significantly 

less than are estimated in this appendix. This makes the Alternative 3 in Year 21 

scenario a special case, or outlier, in relation to all of the other transportation 

scenarios evaluated in this report for the six alternatives.) 

o After Year 21--Starting in the twenty-first year and thereafter, the NPPs would be 

able to ship all of their B and C LLRW spent IERs for direct disposal, in addition 

to their Class A LLRW resins. Therefore, the period after Year 21 of Alternative 3 

would be identical to and would have the same annual numbers of Type A and 

Type B casks shipments as Alternative 2. Again, this assumes that all of the 

stored Class B and C concentration spent IERs are shipped for disposal from the 

65 NPPs in the twenty-first year. However, note that the potential transportation 

impacts of Alternative 3 after Year 21 are not separately estimated herein 

because those impacts would be identical to those of Alternative 2. 

 Alternative 4A—Volume Reduction of Class B and C Concentration Spent IERs at a 

Processing Facility, Long-term Storage, then Disposal: There would be 419 “immediate” 

annual Class A concentration spent IER shipments in Type A casks from the NPPs to 

the disposal facility and 419 returning empty, for a total of 838 shipments annually. Also, 

there would be 111 Class B and C concentration spent IER shipments in Type B casks 

annually to the processing (volume reduction) facility and 111 returning empty to the 

NPPs, for a total of 222 Class B and C shipments annually. As discussed in 

Section 4.2.5, the volume reduction process would decrease the volume of the spent 

IERs by a factor of approximately five. Thus, for every 111 Type B casks of Class B and 

C concentration spent IERs shipped to the processing facility, about 23 Type B casks of 

processed (volume-reduced) spent IERs would result (i.e., 111 ÷ 5 ≈ 23). Therefore, 

under the scenario in which the volume-reduced Class B and C concentration wastes 

are shipped to the waste disposal site and stored there for 20 years prior to disposal, 

there would be 23 shipments annually from the processing facility to the long-term 

storage site and 23 shipments returning empty to the processing facility, for a total of 46 

annual shipments. Thus, the total number of annual shipments under this alternative 

would be 1106 (838 + 222 + 46). 

 Alternative 4B—Volume Reduction of Class B and C Concentration Spent IERs at a 

Processing Facility, then Disposal: For this alternative, the total number of annual 

shipments would be the same as under Alternative 4A (i.e., 1106). The only difference 

between the two alternatives is the volume-reduced waste long-term storage step at the 

waste disposal site in Alternative 4A prior to waste disposal. Thus, the number of 

shipments between the NPPs and the disposal facility for Class A LLRW spent IERs 
A-14 

(828), and between the NPPs and processing (volume reduction) facilities for Class B 

and C concentration spent IERs (222), would be the same. In addition, since the volume 

reduction process used would be the same as in Alternative 4A, there would also be 46 

Type B cask shipments annually to and from the waste disposal site (though for direct 

disposal rather than long-term storage of the wastes). 

Table A-2 presents a summary of the annual number of truck trips estimated above. 

Table A-2 Annual Number of Truck Shipments by Alternative 

ALTERNATIVE 

ANNUAL NUMBER OF TRUCK SHIPMENTS 

NPPs to/from 

Processing 

Facility 

Processing 

Facility to/from 

Disposal Facility 

NPPs to/from 

Disposal Facility Total Trips 

1A 1060 970 N/Aa

 2030 

1B 1060 970 N/A 2030 

2 N/A N/A 1060 1060 

3 

(Years 1-20)b N/A N/A 838 838 

3 

(Year 21)b N/A N/A 5500 5500 

3 

(After 

Year 21)b,c

N/A N/A 1060 1060 

4A 222 46 838 1106 

4B 222 46 838 1106 

 a N/A = not applicable. 

 b See text above for explanation of the three stages of Alternative 3. 

 c Potential transportation impacts of Alternative 3 after Year 21 are not separately estimated in this report because 

 those impacts would be identical to those of Alternative 2 (see text). 

A.3 Potential Transportation Impacts 

The three categories of potential transportation impacts identified earlier are evaluated in this 

section. The section includes a discussion of assessment methodologies, assumptions, and 

results. The three transportation impact categories are: 

 Impacts on local and national traffic (Section A.3.1); 

 Radiological impacts of routine transportation (Section A.3.2); and 

 Non-radiological and radiological impacts of transportation accidents (Section A.3.3). 
A-15 

Although quantitative estimates of potential transportation impacts are calculated, impacts are 

also assessed qualitatively, using the significance levels of SMALL, MODERATE, or LARGE 

discussed in Section 3.2 of the main report. 

It is important to note that for the Alternative 3 in “Year 21” spent IER transportation scenario 

(described in Section 4.2.4 of the main report), potential transportation impacts are estimated 

and reported in this section for the sake of completeness only. Those potential impacts are 

neither discussed at any length in the text of this appendix nor mentioned at all in the 

corresponding discussions of potential transportation impacts in the main report. This is 

because, for the justifiable reasons detailed in the NOTE in Section A.2.3, the potential 

transportation impacts of the Alternative 3 in Year 21 scenario are substantially overestimated in 

this report; therefore, this scenario is fundamentally a special case, or outlier, in relation to all of 

the other transportation scenarios evaluated for the six alternatives. Thus, elaboration on 

potential transportation impacts for this scenario, or comparison of those impacts with those of 

the other alternatives, would not be representative of actual practice. 

A.3.1 Impacts on Local and National Traffic 

In this section, potential impacts on local and national traffic from the transportation of the spent 

IERs (full and empty casks) are evaluated, as discussed in Sections A.3.1.1 and A.3.1.2, 

respectively. 

A.3.1.1 Impacts on Local Traffic 

The impacts on local traffic near spent IER processing facilities (for blending or volume 

reduction) and LLRW disposal facilities, from trucks carrying spent IERs and empty shipping 

casks, are evaluated using the estimated numbers of annual truck shipments shown in 

Table A-2 in Section A.2.3 for each alternative. Trucks would enter and leave these facilities 

only during their normal working hours. Thus, for this analysis, the annual numbers of 

shipments (trips) for each of the alternatives are divided by the number of operating hours per 

year for a waste processing or disposal facility (assumed 2000 hours per year, based on fifty 

40-hour workweeks). This gives an average number of trucks per hour on local roads entering 

and leaving these facilities. 

The numbers of trucks per hour on local roads, for each of the six alternatives, is estimated as 

described below: 

 Alternatives 1A and 1B: As shown in Section A.2.3, the numbers of trips between the 

various origins and destinations in these two alternatives would all be the same. In each 

of these alternatives, there would be a total of 2030 truck shipments per year going to, 

and returning from, the central processing (blending) facility (1060 truck shipments 

between the NPPs and the processing facility plus 970 shipments between the 

processing facility and waste disposal facility). From this, for the 2000 hours per year 

during which each type of facility is assumed to be operating, there would be an average 

of about one additional truck per operating hour on local roads near the processing 

facility (i.e., 2030 trucks/year ÷ 2000 hours/year = 1.02 trucks/hour). In addition, there 
A-16 

would be 970 truck shipments per year going to, and returning from, the disposal facility. 

Thus, there would be an average of about one truck every two operating hours traveling 

locally near the waste disposal site (i.e., 970 trucks/year ÷ 2000 hours/year = 

0.49 truck/hour). One additional truck per operating hour on local roads near the 

processing facility, and one additional truck every two hours on local roads near the 

disposal facility, would represent very small additions to local truck traffic volumes and 

even smaller additions to overall traffic volumes and, therefore, SMALL impacts on local 

traffic near these facilities. 

 Alternative 2: There would be 1060 truck shipments per year going to, and returning 

from, the waste disposal facility. This equates to an average of about one truck every 

two operating hours (1060 trucks/year ÷ 2000 hours/year = 0.53 trucks/hour) traveling on 

local roads near the disposal facility. One additional truck per two operating hours would 

represent a SMALL impact on local traffic near the waste disposal site. 

 Alternative 3: For Years 1-20, there would be 838 truck shipments per year going to, 

and returning from, the waste disposal facility. This would result in an average of about 

one additional truck every 2.5 operating hours (838 trucks/year ÷ 2000 hours/year = 0.42 

trucks/hour) traveling on local roads near the waste disposal facility and a 

correspondingly SMALL impact on local traffic. In Year 21, there would be a total of 

5500 truck shipments going to, and returning from, the disposal facility, or an average of 

about three additional trucks per hour (5500 trucks/year ÷ 2000 hours/year = 

2.75 trucks/hour) traveling locally. Although as discussed in Section A.2.3, 5500 truck 

trips in Year 21 represents a substantial overestimate, even three additional trucks per 

hour would represent a SMALL impact when compared to the average of 75 trucks per 

hour at an LLRW disposal facility discussed above. As discussed in Section A.2.3, the 

potential impact after Year 21 would be the same as that estimated for Alternative 2. 

 Alternatives 4A and 4B: As shown in Section A.2.3, the numbers of trips between the 

various origins and destinations in these two alternatives would all be the same. Thus, 

in both of these alternatives, there would be a total of 268 truck shipments per year 

going to, and returning from, the thermal processing (volume reduction) facility (i.e., 222 

trips between the NPPs and the processing facility and 46 between the processing 

facility and the waste disposal site). This would result in an average of a little more than 

about one truck per 8-hour operating day traveling on local roads near the waste 

processing facility (i.e., 268 trucks/year ÷ 2000 hours/year = 0.14 trucks/hour). In 

addition, there would be 884 trucks per year traveling to and from the waste disposal site 

(838 trips between the NPPs and the waste disposal site and 46 trips between the 

processing facility and the disposal site). This would result in an average of a little less 

than one truck every two operating hours traveling locally near the disposal site (i.e., 884 

trucks/year ÷ 2000 hours/year = 0.44 trucks/hour). Less than one additional truck per 

8-hour operating day traveling locally near the waste processing facility and less than 

one additional truck every two operating hours near the waste disposal site would 

represent SMALL impacts on local traffic near these facilities. 
A-17 

Table A-3 presents a summary of the average numbers of additional trucks on local roads near 

spent IER processing and waste disposal facilities estimated above. The results demonstrate 

that spent IER shipments (full and empty casks) would add little to existing local traffic near the 

waste processing and disposal facilities in all six alternatives. Therefore, transportation of spent 

IERs in all six alternatives would have SMALL impacts on local traffic near these facilities, and 

correspondingly SMALL impacts on local traffic congestion, air quality, noise levels, and road 

surface wear. 

Table A-3 Estimated Additional Numbers of Trucks on Local Roads near 

Spent IER Processing and Disposal Facilities by Alternative 

ALTERNATIVE 

ADDITIONAL TRUCKS NEAR 

WASTE PROCESSING 

FACILITYa

ADDITIONAL TRUCKS NEAR 

WASTE DISPOSAL SITEa

1A 1

per operating hour

1

every 2 operating hours

1B 1

per operating hour

1

every 2 operating hours 

2 and 

3 (After Year 21) N/Ab 1

every 2 operating hours 

3 

(Years 1-20) N/A 1

every 2.5 operating hours 

3 

(Year 21) N/A 3

per operating hour 

4A 1

per 8-hour operating day

1

every 2 operating hours 

4B 1

per 8-hour operating day

1

every 2 operating hours

 a Based on an 8-hour operating day. 

 b N/A = not applicable. 

A.3.1.2 Impacts on National Traffic 

Potential traffic impacts on a national level, from truck shipments of spent IERs and empty 

casks, are evaluated by comparing the total annual weight of these shipments in each 

alternative to the total annual weight of all U.S. freight transported by tractor-trailer trucks. The 

annual number of tractor-trailer truck trips per year in the U.S., or of total trips per year for 

vehicles of all types, is not recorded. Therefore, it is not possible to compare the number of 

spent IER and empty cask truck shipments from Table A-2 to the annual total number of tractortrailer trips or total number of vehicle trips. 

The Bureau of Transportation Statistics of the USDOT provides data on the total annual weight 

of U.S. freight transported by tractor-trailer trucks in the U.S., 1.13 × 1010 metric tons per year 

(1.25 × 1010 tons per year) (USDOT, 2011; Table 3-1). From Table A-1 in Section A.2.2, the 

Type A cask (CNS 14-215) and Type B cask (CNS 8-120B) have maximum loaded weights of 

26.5 metric tons (29 tons) and 29 metric tons (32 tons), respectively. For the purposes of this 
A-18 

specific evaluation, the full and empty casks are conservatively assumed to have the same 

maximum loaded weights, as shown above, which results in a conservative estimate of the 

potential impact the spent IER shipments would have on national traffic. This assumption is 

necessary because the weights of the HICs or liners containing spent IERs that are within the 

Type A and Type B shipping casks can be highly variable and, therefore, cannot be estimated 

with certainty. 

Table A-4 presents the estimated annual shipment weights for each of the six alternatives and 

their percentages of the total annual U.S. tractor-trailer shipment weight. The numbers of 

shipments by shipping cask type in this table are calculated using the information developed in 

Section A.2.3. As shown in Table A-4, the spent IER shipments would account for a very small 

percentage of the annual national (freight) traffic on U.S. highways, ranging from 0.0002 percent 

for Alternative 3 (Years 1-20) to 0.0005 percent for Alternatives 1A and 1B. Note that these 

percentages would be even smaller (negligible) if all other vehicular traffic (e.g., cars, vans, 

buses, light trucks, etc.) were considered in the calculations. Thus, the effect of spent IER 

shipments under any of the alternatives on national traffic and on associated traffic congestion, 

air quality, noise levels, and road surface wear would be SMALL. 

Table A-4 Annual Spent IER Truck Shipments as Percentages of 

Total U.S. Tractor-Trailer Truck Shipments, Based on Freight Weights 

ALTERNATIVE 

SPENT IER TRUCK SHIPMENTS 

PER YEAR 

BY SHIPPING CASK TYPEa ANNUAL SPENT 

IER SHIPMENT 

WEIGHT 

(TONS)b

SPENT IER 

SHIPMENT WEIGHT 

AS % OF TOTAL 

TRACTOR-TRAILER 

FREIGHT WEIGHTc Type A Casks 

(CNS 14-215) 

Type B Casks 

(CNS 8-120B) 

1A 1808 222 59,536 0.0005%

1B 1808 222 59,536 0.0005%

2 and 3 

(After Year 21) 838 222 31,406 0.0003%

3 (Years 1-20) 838 0 24,302 0.0002%

3 

(Year 21) 838 4664 173,486 0.001%

4A 838 268 32,878 0.0003%

4B 838 268 32,878 0.0003%

a For shipments of both full and empty casks. 

b

 Calculated by multiplying the numbers of CNS 14-215 (Type A) cask shipments by 29 tons and of CNS 8-120B 

(Type B) cask shipments by 32 tons (from Table A-1). 

 c Calculated by dividing the annual spent IER shipment weights in tons by the total annual U.S. tractor-trailer 

shipment weight of 1.25 x 1010 tons (USDOT, 2010). 
A-19 

A.3.2 Radiological Impacts of Routine Transportation 

Potential radiological impacts from routine, incident-free transportation of spent IERs in Type A 

and Type B shipping casks are evaluated for individual receptors and for populations in 

Sections A.3.2.1 and A.3.2.2, respectively. Potential impacts are assessed for various 

scenarios involving moving and stationary trucks. Individual receptors are persons at various 

locations along transportation routes traveled by trucks carrying radioactive materials 

(e.g., spent IERs from NPPs). Populations are groups of residents along the transportation 

routes. 

During routine transportation, external radiation from the shipping containers used to transport 

radioactive materials, such as the spent IERS from NPPs, is the source of the radiation dose to 

the various potential receptors. In this evaluation, potential radiological impacts due to possible 

exposures of various individual human receptors to this external radiation, in terms of doses of 

radiation in mSv (or mrem), are estimated using the RADTRAN 6 model (Weiner et al., 2009) 

(hereafter called the “RADTRAN model” or “RADTRAN”). For a radiation dose to a population, 

RADTRAN calculates the “collective dose” (expressed in units of person-mSv9

) by integrating 

the average radiation dose over the area occupied by the population. RADTRAN is the 

nationally accepted, standard computer program for calculating the risks of transporting 

radioactive materials. RADTRAN has been used to calculate radiological risks of transporting 

radioactive materials in U.S. environmental assessments and EIS's since 1977 and 

internationally since the mid-1980s. RADTRAN includes modules for use in modeling 

radiological impacts of routine transportation and of transportation accidents. The former is 

used in evaluating potential impacts in this section, and the latter is used in Section A.3.3. The 

RADTRAN model has been validated using field measurements (Steinman et al., 2002). 

In modeling radiological impacts from routine transportation, RADTRAN models the external 

radiation dose rate from the shipping cask as if the radiation were emitted from a point source 

located where the center of the cask would be (radiation dose rate, or dose rate, is the radiation 

dose per unit time, expressed as mSv per hour (or mrem per hour)). RADTRAN sets the 

intensity of this point source equal to the Transport Index (TI) of the cask, which is defined as 

the dose rate measured at a distance of 1 m (3.3 ft) from the lateral surface of the cask.10 To a 

receptor located far from the cask, the radiation dose received from such a point source would 

be indistinguishable from that received from the actual cask. It has been shown that the dose 

calculated by the RADTRAN approximation overestimates the measured dose by a few percent 

(Steinman et al., 2002). 

 

9

 Person-mSv is a unit of dose that represents an individual dose integrated over an area that is occupied by a 

population. It can be thought of as an average individual dose multiplied by the number of people over which it is 

averaged. 

10 Transport Index (TI) is defined as the dose rate at 1 meter from a vertical plane perpendicular to the side of the 

trailer carrying the cask (NRC, 2012). RADTRAN does not account for the offset between the cask and trailer. 
A-20 

Furthermore, when the actual external radiation dose rate from the shipping cask is not 

specifically known, as is the case for the Type A and Type B shipping casks containing spent 

IERs in this evaluation, the maximum external dose rate for a shipping container allowed by 

NRC regulation is used in RADTRAN to assess radiation doses to individuals and populations. 

NRC regulations allow shipping containers, or casks, that hold radioactive materials to emit 

minor amounts of ionizing radiation from the external cask surfaces. The Type A and Type B 

casks used to transport spent IERs, as all containers certified for use to transport radioactive 

materials, must meet the NRC standard for external radiation during normal transport. In the 

case of flat-bed style trucks (such as those used to transport casks of spent IERs), 

10 CFR 71.47(b)(3) states that the dose rate from this external radiation must not exceed 0.1 

mSv per hour (10 mrem per hour) at 2 m (6.6 ft) from the vertical planes projected by the outer 

edges of the trailer carrying the cask. Compliance with this regulation is guaranteed by 

appropriate cask shielding design, package content limitations, and inspections. Basing the 

RADTRAN modeling on this maximum, legally allowable dose rate is conservative because 

actual dose rates from shipping casks would generally be much lower than the allowable limit. 

In the sections that follow, potential radiological impacts to individual receptors and populations 

are estimated, expressed as radiation doses in mSv. The radiation doses from the various 

alternatives are estimated based on annual numbers of spent IER shipments; therefore, these 

estimated doses are the doses from exposures over a period of one year. Thus, to put the 

annual doses to individuals in perspective, they are compared with the average annual U.S. 

background dose, from natural sources, of 3.11 mSv/year (311 mrem/year) (NCRP, 2009), as a 

percentage of this background dose. For populations, the annual collective dose is compared to 

3.11 mSv (311 mrem) multiplied by the affected population, since each member of the 

population sustains this annual average background dose. The use of the annual U.S. 

background radiation level allows for the assumption that the background level would be the 

same for all receptors. In addition, from the estimated radiation doses, the corresponding 

probabilities of fatal cancers resulting from exposure to these radiation doses, or latent cancer 

fatalities (LCFs), are derived. Specifically, LCFs are the expected number of additional cancer 

fatalities that may occur during the lifetime of individuals, because of (or latent to) an exposure 

to ionizing radiation. LCF risk values are derived by multiplying the dose by a conversion factor, 

6 × 10-5 LCF per mSv (ISCORS, 2002). The calculated LCFs are also expressed as a fraction 

(percentage) of 2010 total estimated cancer fatalities in the U.S. of 569,495 (American Cancer 

Society, 2010; p. 4).11 

A.3.2.1 Impacts on Individual Receptors 

Potential radiological impacts are calculated using RADTRAN for the following types of 

individual receptors: 

 

11 2010 total estimated cancer fatalities in the U.S. derived by the American Cancer Society from U.S. mortality data, 

1969-2007. 
A-21 

 Individual maximally exposed to a moving truck (maximally exposed individual, or MEI) 

 Average person along the transportation route: rural–suburban 

 Average person along the transportation route: urban 

 Average resident near a truck stop: rural–suburban 

The MEI shown above is the individual receiving the maximum exposure to a moving truck 

carrying a radioactive cargo. The MEI is modeled as a person standing as close as possible 

(30 m from the center of the highway) to the moving truck, when the truck is moving slowly 

(about 24 kilometers per hour (kph) (15 miles per hour (mph)), past the MEI. This slow speed is 

possibly from a traffic jam, road construction, or bad weather. 

Truck stops would be for rest and refueling. Truck stops are not modeled in urban areas 

because stops used by trucks carrying radioactive materials would generally be away from 

heavily populated areas. 

Tables A-5 and A-6 identify (and define) the input parameters, by cask type, used in the 

RADTRAN model for the evaluation of the potential radiological impacts of routine (incidentfree) transportation on individuals.12 These parameters are the same for all six alternatives. The 

parameters in Table A-6 are specifically used to evaluate the potential radiological impacts to 

individuals living near truck stops. 

Potential radiological impacts to individuals (in terms of radiation doses) calculated using 

RADTRAN are first estimated for one routine shipment of spent IERs of each cask type (full 

casks). The results of those calculations are then used to estimate the potential radiological 

impacts to individuals from all routine shipments per year for each of the six alternatives. 

Return trips are not modeled because there would be negligible or no radiological impacts from 

routine shipments of empty casks. 

 

12 Note that the RADTRAN user interface also lists a number of default parameter values (e.g., breathing rate). 
A-22 

Table A-5 RADTRAN Input Parameters for Calculating Radiation Doses to 

Individual Receptors from Routine Transportation 

INPUT PARAMETERS Type A Cask 

(CNS 14-215) 

Type B Cask 

(CNS 8-120B) 

Cask/vehicle longest dimension (m (ft)): shipping cask and 

vehicle (the trailer of a tractor-trailer truck) are modeled to have 

the same longest external dimensionsa

2.16 (7.09) 2.24 (7.35) 

Cask/vehicle dose rate at 1 meter from the cask (mSv/hour 

(mrem/hour)): calculated from the NRC regulatory maximum of 

0.1 mSv/hour (10 mrem/hour) at 2 meters from the cask (10 CFR 

71.47(b)(3))

0.146 (14.6) 0.142 (14.2) 

Gamma fraction: fraction of external radiation from the cask that 

is gamma radiation 1 1 

Neutron fraction: fraction of external radiation from the cask that 

is neutron radiation 0 0 

Rural and suburban vehicle speed (kph (mph)) 108 (67) 108 (67) 

Urban vehicle speed (kph (mph)) 102 (63) 102 (63) 

Maximally exposed individual (MEI) distance from vehicle (m 

(ft)) 30 (98) 30 (98) 

Vehicle speed past MEI (kph (mph)) 24 (15) 24 (15) 

Minimum distance to nearest resident (m (ft))b 30 (98) 30 (98) 

Maximum distance to nearest resident (m (mile))c 800 (0.50) 800 (0.50) 

Rural shielding factord 1 1 

Suburban shielding factord 0.87 0.87 

Urban shielding factord 0.018 0.018 

a

 In order to accommodate the RADTRAN spherical model, the longest cask dimension and the vehicle length are 

assumed to be the same. This assumption is valid because any additional trailer length beyond the cask does not 

change the radiation dose to the public, because the affected public is in a direction perpendicular to the radiating 

cask and not behind it. 

b The distance from the center of a six-lane interstate highway to the outer edge of the shoulder is at least 22 m 

(FHWA, 2012). The nearest residence is usually 10 m further from the highway. c The dose to a resident along the route is proportional to 1/r

2

. The dose at 1600 m (1 mile) is not significantly 

different from the dose at 800 m; therefore, 800 m is the default value in RADTRAN. d The shielding factor is the inverse of the fraction of energy transmitted; i.e., a shielding factor of 1 means that all 

energy from the source is transmitted and there is no shielding. The rural, suburban, and urban shielding factors are 

based on the following assumptions: rural residents spend a great deal of time out of doors, with no shielding; 

suburban residents live in wood or stucco houses and have a small amount of shielding; and urban residents live in 

brick or concrete block buildings and are heavily shielded (Neuhauser et al., 2000). 
A-23 

Table A-6 Additional RADTRAN Input Parameters for Calculating Radiation Doses to 

Individual Receptors near Truck Stops 

INPUT PARAMETERS Type A Cask 

(CNS 14-215) 

Type B Cask 

 (CNS 8-120B) 

Average time at stop (hours) 0.33 0.33 

Minimum distance of a nearby resident from the truck at 

the stop (m (ft)) 30 (98) 30 (98) 

Maximum distance of a nearby resident from the truck 

at the stop (m (mile)) 800 (0.50) 800 (0.50) 

Stop due to a truck accident (hours): only in which there 

is no release of radioactive material 10 10

A.3.2.1.1 Impacts to Individuals from One Routine Shipment 

Table A-7 shows the estimated radiological impacts to the various types of individual receptors 

from one routine shipment of spent IERs, for both the Type A and the Type B cask (full casks), 

including estimated doses and LCFs (calculated as described earlier). For completeness, 

comparisons with U.S. annual average background dose and 2010 total estimated U.S. cancer 

fatalities are shown; however, these results are not discussed, as the purpose of Table A-7 is to 

provide data for use in later calculations in this appendix. Note that the results for the average 

resident near the rural and suburban truck stops are the equivalent. 

A Note about Exponential Notations Used in This Appendix 

Numbers in this appendix with exponential notations are shown in two 

different ways, in one way in text and in an equivalent (though different 

looking) way in certain tables. For example, the number 0.000053 can be 

expressed exponentially in either one of the two ways—as the more familiar 

5.3 x 10-5 (as shown in the text) or as 5.3E-05 (as shown in tables). The 

reason for this is that Microsoft Excel® is used to generate many of the 

results tables in this appendix, and that software uses the “E” notation. 

A.3.2.1.2 Impacts to Individuals from All Routine Shipments by Alternative 

The total annual doses and corresponding LCFs from all spent IER shipments (full casks) by 

alternative, to the various types of individual receptors by cask type, are shown in Table A-8. 

The total annual doses in this table are calculated by multiplying the dose from a single 

shipment (from Table A-7) by the annual number of shipments carrying spent IERs for each 

cask type (full casks), which is half of the number of shipments shown in Table A-4. The total 

annual doses by cask type are then added to show the collective doses for all spent IER 

shipments by alternative. This approach is based on the conservative assumptions that 

(1) each individual receptor is exposed to every spent IER shipment for a given alternative13, 

 

13 In actual practice, this would not occur since not all individuals would be located in the same place at the same 

time over a period of one year. 
A-24 

and (2) the doses from exposures to multiple shipments are additive.14 Thus, actual exposures 

would be lower than are estimated in this evaluation. Table A-8 also shows the collective dose 

results as percentages of U.S. average annual background doses. In addition, Table A-8 shows 

the corresponding LCFs (calculated as discussed earlier), and compares them, as a 

percentage, to the American Cancer Society 2010 estimated U.S. cancer fatalities data. 

Table A-7 Estimated Radiological Impacts to Individual Receptors from a 

Single Routine Spent IER Shipment 

RECEPTOR CASK

TYPE

DOSE 

(mSv) 

DOSE AS 

% U.S. ANNUAL 

BACKGROUNDa

LCF 

LCF AS 

% 2010 

ESTIMATED 

U.S. CANCER 

FATALITIESb

Maximally exposed individual 

(MEI) 

A 2.4E-06 1E-05% 1.5E-10 3E-14% 

B 2.4E-06 1E-05% 1.5E-10 3E-14% 

Average person along the 

route: rural 

A 1.2E-09 4E-8% 7.3E-14 1E-17% 

B 1.2E-09 4E-8% 7.4E-14 1E-17% 

Average person along the 

route: suburban 

A 1.1E-09 4E-8% 6.7E-14 1E-17% 

B 1.1E-09 4E-8% 6.8E-14 1E-17% 

Average person along the 

route: urban

A 2.3E-11 7E-10% 1.4E-15 3E-19% 

B 2.3E-11 7E-10% 1.4E-15 3E-19% 

Average resident near truck 

stop: rural 

A 4.3E-06 1E-04% 2.6E-10 5E-14% 

B 4.3E-06 1E-04% 2.6E-10 5E-14% 

Average resident near truck 

stop: suburban 

A 4.3E-06 1E-04% 2.6E-10 5E-14% 

B 4.3E-06 1E-04% 2.6E-10 5E-14% 

 a Average annual U.S. background dose = 3.11 mSv/year (NCRP, 2009). 

 b Based on 2010 total estimated U.S. cancer fatalities of 569,495 (American Cancer Society, 2010). 

As shown in Table A-8, the MEI would receive the highest radiation doses from moving trucks 

and residents near truck stops would receive the highest doses overall. However, the 

radiological impacts of the alternatives would be similar to each other. Radiation doses and 

LCFs to all individuals from all of the shipments of spent IERs for each of the alternatives would 

generally be small to negligible percentages of the average annual background dose sustained 

by the individual receptor and of the 2010 total estimated U.S. cancer fatalities, respectively. 

The doses range from approximately 8 × 10-7 to 1.4 × 10-1 percent of annual background, and 

would thus be representative of SMALL impacts to individual receptors. This conclusion is 

supported by the negligible LCFs associated with these doses, which range from about 1 × 10-16

to 5 × 10-11 percent of the total estimated fatal cancer fatalities in the United States in 2010. 

 

14 In reality, multiple radiation doses over time are not additive. For example, in calculating medical therapeutic and 

diagnostic doses, the patient’s prior history of radiation exposure is not usually considered or summed (Shleien et al., 

1998; Chapter 10). 
A-25 

Table A-8 Estimated Radiological Impacts to Individual Receptors from All Routine Spent IER Shipments for Each Alternative 

RECEPTOR CASK TYPE 

TOTAL ANNUAL DOSE (mSv) FROM ALL SPENT IER 

(FULL CASK) SHIPMENTS BY ALTERNATIVE 

TOTAL ANNUAL LCF FROM ALL SPENT IER 

(FULL CASK) SHIPMENTS BY ALTERNATIVE 

1A and 1B 

2 and 3 

(After Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4B 1A and 1B 

2 and 3 

(After Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4B 

Maximally 

exposed 

individual 

(MEI) 

A 2.2E-03 1.0E-03 1.0E-03 1.0E-03 1.0E-03 A 1.3E-07 6.1E-08 6.1E-08 6.1E-08 6.1E-08 

B 2.7E-04 2.7E-04 N/A 6.7E-03 3.3E-04 B 1.6E-08 1.6E-08 N/A 4.0E-07 2.0E-08 

A + B 2.5E-03 1.3E-03 1.0E-03 7.7E-03 1.3E-03 A + B 1.5E-07 7.7E-08 6.1E-08 4.6E-07 8.1E-08 

A+B % U.S. Annual 

Background 8E-02% 4E-02% 3E-02% 2E-01% 4E-02% 

A+B % 2010 

Estimated U.S. Cancer 

Fatalities 

3E-11% 1E-11% 1E-11% 8E-11% 1E-11% 

Average 

person along 

route: rural

A 1.1E-06 5.1E-07 5.1E-07 5.1E-07 5.1E-07 A 6.6E-11 3.1E-11 3.1E-11 3.1E-11 3.1E-11 

B 1.4E-07 1.4E-07 N/A 3.4E-06 1.7E-07 B 8.2E-12 8.2E-12 N/A 2.0E-10 9.9E-12 

A + B 1.2E-06 6.5E-07 5.1E-07 3.9E-06 6.8E-07 A + B 7.4E-11 3.9E-11 3.1E-11 2.3E-10 4.1E-11 

A+B % U.S. Annual 

Background 4E-05% 2E-05% 2E-05% 1E-04% 2E-05% 

A+B % 2010 

Estimated U.S. Cancer 

Fatalities 

1E-14% 7E-15% 5E-15% 4E-14% 7E-15% 

Average 

person along 

route: 

suburban 

A 1.0E-06 4.7E-07 4.7E-07 4.7E-07 4.7E-07 A 6.1E-11 2.8E-11 2.8E-11 2.8E-11 2.8E-11 

B 1.3E-07 1.3E-07 N/A 3.1E-06 1.5E-07 B 7.5E-12 7.5E-12 N/A 1.9E-10 9.1E-12 

A + B 1.1E-06 6.0E-07 4.7E-07 3.6E-06 6.2E-07 A + B 6.9E-11 3.6E-11 2.8E-11 2.2E-10 3.7E-11 

A+B % U.S. Annual 

Background 4E-05% 2E-05% 2E-05% 1E-04% 2E-05% 

A+B % 2010 

Estimated U.S. Cancer 

Fatalities 

1E-14% 6E-15% 5E-15% 4E-14% 6E-15% 

Average 

person along 

route: urban 

A 2.1E-08 9.7E-09 9.7E-09 9.7E-09 9.7E-09 A 1.3E-12 5.8E-13 5.8E-13 5.8E-13 5.8E-13 

B 2.6E-09 2.6E-09 N/A 6.4E-08 3.1E-09 B 1.6E-13 1.6E-13 N/A 3.9E-12 1.9E-13

A + B 2.4E-08 1.2E-08 9.7E-09 7.4E-08 1.3E-A-808 A + B 1.5E-12 7.4E-13 5.8E-13 4.5E-12 7.7E-13 

A+B % U.S. Annual 

Background 8E-07% 4E-07% 3E-07% 2E-06% 4E-07% 

A+B % 2010 

Estimated U.S. Cancer 

Fatalities 

3E-16% 1E-16% 1E-16% 8E-16% 1E-16% 

Average 

resident near 

truck stop: 

rural or 

suburban 

A 3.9E-03 1.8E-03 1.8E-03 1.8E-03 1.8E-03 A 2.3E-07 1.1E-07 1.1E-07 1.1E-07 1.1E-07

B 4.8E-04 4.8E-04 N/A 1.2E-02 5.8E-04 B 2.9E-08 2.9E-08 N/A 7.2E-07 3.5E-08

A+B 4.4E-03 2.3E-03 1.8E-03 1.4E-02 2.4E-03 A+B 2.6E-07 1.4E-07 1.1E-07 8.3E-07 1.5E-07

A+B % U.S. Annual 

Background 1.4E-01% 7.4E-02% 5.8E-02% 4.5E-01% 7.7E-02% 

A+B % 2010 

Estimated U.S. Cancer 

Fatalities 

5E-11% 2E-11% 2E-11% 1E-10% 3.E-11% 

 a Average annual U.S. background dose = 3.11 mSv/year (NCRP, 2009). 

 b Based on 2010 total estimated U.S. cancer fatalities of 569,495 (American Cancer Society, 2010). 

CASK TYPE
A-26 

A.3.2.2 Impacts on Populations 

This section discusses potential radiological impacts, in terms of population doses, from routine 

spent IER shipments (full casks) on populations. Potential impacts are estimated for 

populations residing along transportation routes (from moving trucks) and near truck stops (from 

stationary trucks). For the six alternatives considered in this evaluation, the transportation 

routes would be between NPPs and waste processing facilities (for blending or volume 

reduction), between NPPs and LLRW disposal facilities, and between waste processing facilities 

and LLRW disposal facilities. 

The calculation of population dose is based on the concept of “collective dose”, which is defined 

as a radiation dose to a population (expressed in units of person-mSv) calculated by integrating 

the average radiation dose over the area occupied by the population. For example, if an 

average person receives a dose of 1.2 × 10-9 mSv from one moving truck of spent IERs and 

there are 10,000 people in the population along the transportation route of that truck, the 

collective dose to that population from one shipment is 1.2 × 10-5 person-mSv (1.2 × 10-9 mSv x 

10,000 persons = 1.2 × 10-5 person-mSv). 

The RADTRAN calculation of collective dose requires the identification of specific transportation 

origins and destinations, and estimates of the populations along the transportation routes 

between these origins and destinations. For this analysis, a number of “representative” origins 

and destinations have been identified for use in the modeling. These were selected to be 

representative of origins of untreated or treated (processed) spent IERs (i.e., NPPs or waste 

processing facility locations, respectively) and destinations for spent IER processing or disposal. 

The representative origins and destinations selected, although generally based on actual, 

existing facility locations, are used in this evaluation for illustrative purposes only for calculating 

potential radiological impacts on populations. They are not meant to designate actual spent IER 

shipment origins and destinations for the six alternatives because actual routes cannot be 

identified for generic, non-location-specific alternatives such as those considered in this 

evaluation. 

TRAGIS (TRAnsportation Geographic Information System), the routing code maintained by Oak 

Ridge National Laboratory (Johnson and Michelhaugh, 2003), is typically used to provide 

transportation route parameters for use in RADTRAN. However, for this evaluation, the choice 

of representative origins and destinations and corresponding transportation routes between 

them was severely constrained because, at the time the evaluation was originally conducted, 

TRAGIS was shut down and unavailable for an undetermined time period (Johnson, 2011). 

TRAGIS, when available, provides the most recent census data of population densities along 

routes, a listing of every road and every intersection by highway route number, and the rural, 

suburban, and urban fractions of the total routes through each state. 

Since TRAGIS was not available, the representative transportation origins and destinations and 

corresponding transportation routing data were constructed from, and limited by, the availability 

of relevant information on transportation routes in the library of TRAGIS routings maintained by 

SNL. Within these constraints, the following transportation origins and destinations were 
A-27 

selected to allow for the analysis of potential radiological impacts to populations along a range 

of transportation routes spanning the U.S.: 

 As the origins of untreated spent IERs in all six alternatives, actual existing, operating 

NPP locations were used, including the following four NPPs locations geographically 

spanning the U.S.: 

o Northeastern U.S. - Indian Point Energy Center (Indian Point) in New York State 

(NY) 

o Midwestern U.S. - Dresden Generating Station (Dresden) in Illinois (IL) 

o Western/Southwestern U.S. - Palo Verde Nuclear Generating Station (Palo 

Verde) in Arizona (AZ) 

o Southeastern U.S. - Alvin W. Vogtle Electric Generating Plant (Vogtle) in Georgia 

(GA). 

 For the spent IER central processing (blending or volume reduction) facility in 

Alternatives 1A, 1B, 4A, and 4B, a location in Tennessee (TN) was selected. This is 

because Tennessee is a somewhat centralized location in relation to U.S. NPPs, which 

are located mostly east of the Mississippi River, and because the SNL library of TRAGIS 

routings includes data for a location in Oak Ridge, Tennessee. This central processing 

facility location would be the destination for untreated spent IERs to be processed and 

the origin of processed resins destined for disposal (in alternatives 1A, 1B, and 4B) or 

long-term storage (in Alternative 4A). 

 For the LLRW disposal facility, the existing disposal site location selected for purposes 

of this evaluation is near Andrews, Texas (TX). 

A.3.2.3 Potential Impacts from Routine Transportation 

In the subsections that follow, potential radiological impacts on populations from routine 

transportation are separately estimated and discussed for moving trucks and for trucks at rest 

and refueling stops. 

A.3.2.3.1 Impacts from Moving Trucks 

This section discusses the radiological impacts to populations, in terms of collective doses, from 

routine, incident-free movement of spent IER shipments along transportation routes defined by 

the origins and destinations identified above. The collective dose from a spent IER shipment 

(full cask) for each representative transportation route is the sum of the collective doses for the 

rural, suburban, and urban route segments in all of the states traversed on the route. This 

summed result is then multiplied by the number of spent IER shipments (full casks) per 

alternative to obtain the total collective doses for each of the six alternatives. 
A-28 

The area occupied by a receptor population, over which the collective dose is calculated using 

RADTRAN for each route segment, is a band 800 m (0.5 mile) wide on both sides of the 

highway multiplied by the length of the route segment. The receptor population in each route 

segment is the product of this area and the average population density obtained from SNL’s 

library of TRAGIS routings for the particular route segment. Results for rural, suburban, and 

urban route segments are combined for each route. The rural, suburban, and urban route 

lengths, average population densities, and average individual doses (from Table A-7) are 

multiplied appropriately to give the rural, suburban, and urban collective dose for each route. 

Table A-9 shows the rural, suburban, and urban route lengths, and average population densities 

for each representative origin-destination combination (or transportation route) considered in 

this analysis, as obtained from SNL’s library of TRAGIS routings. 

Using the approach described above with the representative transportation route data in 

Table A-9 and the average individual doses from Table A-7, the collective (population) doses to 

populations for one routine shipment of spent IERs (full casks) for each shipping cask type are 

estimated for each of the representative origin–destination combinations. The results are 

shown in Table A-10. 

Total annual collective (population) doses for all shipments of spent IERs for each alternative, 

for each representative transportation route, are then calculated as follows: 

1. Half the total annual number of Type A and of Type B cask shipments (from Table A-4) 

for each alternative (i.e., full casks) is multiplied by the collective dose for one routine 

shipment of spent IERs for each cask type for each route (from Table A-10). This gives 

the annual collective dose for each route by cask type for each alternative. 

2. The results for the two cask types from step 1 above are then added to give the total 

collective dose for all of the route segments of each alternative. Using Alternative 1A as 

an example, these collective doses were added for the transportation routes from the 

NPPs to the waste processing facility and from the waste processing facility to the waste 

disposal facility. 

Table A-11 presents the results of the collective dose calculations using the above steps, and 

shows the collective doses as percentages of U.S. average annual background doses. In 

addition, Table A-11 shows the corresponding LCFs calculated as discussed earlier, and 

compares them, as a percentage, to the American Cancer Society 2010 total estimated U.S. 

cancer fatalities data. 

As Table A-11 shows, the percentages of U.S. annual average background of the estimated 

total annual collective doses for all six alternatives are all very low and of similar magnitude, 

ranging from 10-5 to 10-4 percent. Thus, since the total collective doses from annual routine 

shipments of spent IERs in each alternative are all considerably less than the average annual 

background dose that populations receive, the resulting radiological impacts to populations 

would be SMALL. Correspondingly, the percentages of 2010 estimated cancer fatalities that the 

LCF risks shown in Table A-11 are also all very low (the highest being about 1 x 10-8 percent), 

similarly representative of SMALL impacts. 
A-29 

Table A-9 Rural, Suburban, and Urban Route Lengths and Population Densities for the 

Representative Transportation Routes 

DESTINATIONSa

STATES 

ON THE 

ROUTE 

RURAL SUBURBAN URBAN 

Route 

Length 

(km)b

Population 

Density 

(people/ 

km2

)

c 

Route 

Length

(km) 

Population 

Density 

(people/ 

km2

) 

Route 

Length 

(km) 

Population 

Density 

(people/ 

km2

) 

Indian Point (NY) NPP to Waste Processing and Disposal Facilities 

Processing (TN)

MD 5.7 18.8 12.3 380 1.4 1765 

NJ 40.2 19.7 67.6 478.5 14.2 2338 

NY 11.7 13.2 28.1 583.4 16.4 2569 

PA 134.5 22.6 120.4 335.4 11 2257 

TN 110.8 21.9 109.6 314.5 6.1 1849 

VA 282 18 230 280 9.7 2192 

WV 12.6 29.5 28.8 342.6 0.7 1979 

Disposal (TX) 

AR 317.4 14.4 130 273.4 8.4 2060 

MD 5.7 18.8 12.3 380 1.4 1765 

NJ 40.2 19.7 67.6 478.5 14.2 2338 

NY 11.7 13.2 28.1 583.4 16.4 2569 

OK 428.4 11.9 98.2 311.5 8.4 2339 

PA 134.5 22.6 120.4 335.4 11 2257 

TN 496.4 18.1 241.4 314.3 31.3 2172 

TX 220 5.2 18.8 400 7.2 2148 

VA 282 18 230 280 9.7 2192 

WV 12.6 29.5 28.8 342.6 0.7 1979 

Dresden (IL) NPP to Waste Processing and Disposal Facilities 

Processing (TN) 

IL 27.7 24.6 133.9 482.4 29 2456 

IN 249.1 16.9 139.5 313.7 16.9 2285 

KY 171.8 22.5 138.9 282.1 11.5 2145 

OH 10.8 18 9.3 337.5 1.1 19.0 

TN 71.3 15.7 57.4 384.9 7.1 1908 

Disposal (TX) 

IL 308.9 16.1 203.1 289.2 10.3 2261 

MO 291.5 19.8 158.1 324 8.7 2077 

OK 640.3 4.3 12.6 283 1.1 1765 

TX 341.3 4.8 18.9 399.1 7.2 2148 
A-30 

Table A-9 Rural, Suburban, and Urban Route Lengths and Population Densities for the 

Representative Transportation Routes (Cont.) 

DESTINATIONSa

STATES 

ON THE 

ROUTE 

RURAL SUBURBAN URBAN 

Route 

Length 

(km)b

Population 

Density 

(people/ 

km2

)

c 

Route 

Length

(km) 

Population 

Density 

(people/ 

km2

) 

Route 

Length 

(km) 

Population 

Density 

(people/ 

km2

) 

Palo Verde (AZ) NPP to Waste Processing and Disposal Facilities 

Processing (TN) 

AR 317.2 14.4 130 276.5 8.5 2052

AZ 533.2 7 37.9 369.9 3.6 2312 

NM 519.7 7.7 63.5 308.9 13.8 2387 

OK 425.7 11.9 100 308.8 4.3 2098 

TN 12.1 17.6 11.7 430 5.1 2521 

TX 256.9 4.8 18.9 399.1 7.2 2148 

Disposal (TX) 

AZ 533.2 7 37.9 369.9 3.6 2312 

NM 220 7.7 18.9 308.9 6.8 2387 

TX 36.9 4.8 0 0 0 0 

Vogtle (GA) NPP to Waste Processing and Disposal Facilities 

Processing (TN) 

GA 189.3 18 145.3 359.7 24.2 2210 

SC 14.4 16 6 295.3 0.4 2045 

TN 12.1 17.6 11.7 430 5.1 2521 

Disposal (TX) 

AL 225.2 17.5 111.3 278 6.3 2034 

GA 274.6 18 145.3 359.7 24.2 2210 

LA 206.8 12.5 96.4 282.2 5.2 1950 

MS 172.8 16.5 71.2 306.4 3.9 2010 

NM 196.8 4.2 6.7 412.6 1.0 2044 

SC 14.4 16 8 295.3 1.4 2045 

TX 804.6 11.6 211.8 322.2 23.7 2248 

Waste Processing Facility (TN) to Waste Disposal Facility (TX) 

Disposal (TX) 

AR 317.4 14.4 130 273.4 8.4 2060 

OK 428.4 11.9 98.2 311.5 8.4 2339 

TN 496.4 18.1 281.4 314.3 31.3 2172 

TX 220.1 5.2 18.8 400 7.2 2148 

a Since TRAGIS was not available, the representative transportation origins and destinations and corresponding 

transportation routing data were constructed from, and limited by, the availability of relevant information on 

transportation routes in the library of TRAGIS routings maintained by SNL (see text). 

b

 km = kilometers. 

c

 km2 = square kilometers. 
A-31 

Table A-10 Collective (Population) Doses by Cask Type for One Routine Shipment of 

Spent IERs for Representative Transportation Routes (Moving Trucks) 

TRANSPORTATION ROUTES COLLECTIVE DOSE (PERSON-mSv) 

Origin Destination Rural Suburban Urban Total 

Type A Cask (CNS 14-215)

Indian Point, NY 

Processing (TN) 1.5E-05 2.5E-04 2.9E-06 2.6E-04 

Disposal (TX) 3.6E-05 3.0E-04 3.9E-07 3.4E-04 

Dresden, IL 

Processing (TN) 1.2E-05 2.1E-04 3.1E-06 2.3E-04 

Disposal (TX) 1.8E-05 1.5E-04 1.2E-06 1.7E-04 

Palo Verde, AZ 

Processing (TN) 2.3E-05 1.4E-04 6.3E-07 1.6E-04 

Disposal (TX) 6.1E-06 2.6E-05 5.0E-07 3.3E-05 

Vogtle, GA 

Processing (TN) 4.7E-06 6.6E-05 1.4E-06 7.3E-05 

Disposal (TX) 3.0E-05 2.5E-04 2.9E-06 2.8E-04 

Processing (TN) Disposal (TX) 2.4E-05 2.0E-04 2.5E-06 2.2E-04 

Type B Cask (CNS 8-120B)

Indian Point, NY 

Processing (TN) 1.4E-05 2.4E-04 2.9E-06 2.5E-04 

Disposal (TX) 3.6E-05 3.0E-04 5.2E-06 3.4E-04 

Dresden, IL 

Processing (TN) 1.2E-05 2.1E-04 3.2E-06 2.3E-04 

Disposal (TX) 1.9E-05 1.5E-04 1.2E-06 1.7E-04 

Palo Verde, AZ 

Processing (TN) 2.3E-05 1.4E-04 2.0E-06 1.6E-04 

Disposal (TX) 6.1E-06 2.7E-05 5.0E-07 3.3E-05 

Vogtle, GA 

Processing (TN) 5.5E-07 9.1E-06 2.9E-07 9.9E-06 

Disposal (TX) 2.6E-05 2.1E-04 3.0E-06 2.4E-04 

Processing (TN) Disposal (TX) 1.9E-05 1.6E-04 2.2E-06 1.8E-04 

A.3.2.3.2 Impacts from Trucks at Rest and Refueling Stops 

This section discusses collective radiation doses and associated potential radiological impacts 

to receptors from tractor-trailer trucks carrying spent IERs (full casks) that have stopped at truck 

stops for rest and refueling. External radiation from the shipping casks on these trucks would 

result in a collective dose to members of the public who live near the truck stops. 

Tractor-trailer trucks tend to stop for rest and refueling when the two fuel tanks that they carry 

are approximately half empty (DOE, 2002; Appendix J). The average fuel mileage for a loaded 

18-wheel tractor-trailer is 6.5 miles/gallon (mi/gal) and these trucks generally have two 80-gal 
A-32 

Table A-11 Annual Radiological Impacts on Populations from Routine Transportation of 

All Spent IER Shipments for Each Alternative by Representative Transportation Route 

(Moving Trucks) 

ORIGIN NPP 

LOCATION 

MEASURES OF 

POTENTIAL 

RADIOLOGICAL 

IMPACTS 

ANNUAL COLLECTIVE DOSE AND LCF 

BY ALTERNATIVEa 

1A and 1Bb

2 and 

3 

(after Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4Bb 

Indian Point, NY 

Annual Collective Dose 

(Person-mSv) 0.25 0.18 0.14 0.94 0.17 

Annual Collective Dose 

as % U.S. Annual 

Backgroundc

2E-05% 1E-05% 1E-05% 5E-05% 1E-05% 

Collective LCF 1.5E-05 1.1E-05 8.5E-06 5.7E-05 1.0E-05 

LCF as % 2010 

Estimated U.S. 

Cancer Fatalitiesd

3E-09% 2E-09% 1E-09% 1E-08% 2E-09% 

Dresden, IL 

Annual Collective Dose 

(Person-mSv) 0.23 0.089 0.070 0.46 0.10 

Annual Collective Dose 

as % U.S. Annual 

Background 

1E-05% 1E-05% 1E-05% 8E-05% 8E-05% 

Collective LCF 1.4E-05 5.3E-06 4.2E-06 2.8E-05 6.0E-06 

LCF as % 2010 

Estimated U.S. 

Cancer Fatalities 

2E-09% 9E-10% 7E-10% 5E-09% 1E-09% 

Palo Verde, AZ 

Annual Collective Dose 

(Person-mSv) 0.19 0.017 0.014 0.091 0.036 

Annual Collective Dose 

as % of U.S. Annual 

Background 

5E-05% 1E-05% 1E-05% 6E-05% 2E-05% 

Collective LCF 1.2E-05 1.0E-06 8.3E-07 5.5E-06 2.2E-06 

LCF as % 2010 

Estimated U.S. 

Cancer Fatalities 

2E-09% 2E-10% 1E-10% 1E-09% 4E-10% 

Vogtle, GA 

Annual Collective Dose 

(Person-mSv) 0.14 0.15 0.12 0.69 0.12 

Annual Collective Dose 

as % of U.S. Annual 

Background 

1E-05% 1E-04% 8E-05% 5E-05% 8E-05% 

Collective LCF 8.4E-06 8.8E-06 7.1E-06 4.1E-05 7.5E-06 

LCF as % 2010 

Estimated U.S. 

Cancer Fatalities 

1E-09% 2E-09% 1E-09% 7E-09% 1E-09% 

a Because of the uncertainties inherent in this type of analysis (Weiner et al, 2009), percentages are reported to one 

significant figure and radiation doses and LCFs to two significant figures. 

b The collective doses for Alternatives 1A and 1B and Alternatives 4A and 4B are the sum of the collective doses from 

the NPP to the processing facility and from the processing facility to disposal. 

c The annual collective dose as % of U.S. average annual background dose was calculated by dividing the annual 

collective dose by the total number of persons exposed along the shipment route and then dividing by the annual 

background dose of 3.11 mSv/year (NCRP, 2009), and then multiplying by 100 to obtain a percentage. 

d

 LCF as % of 2010 total estimated U.S. cancer fatalities was calculated by dividing the LCF by the U.S. estimated 

number of annual cancer fatalities for 2010, which was 569,495 (American Cancer Society, 2010) and then 

multiplying by 100 to obtain a percentage. 
A-33 

fuel tanks. Thus, these trucks would stop to refuel about every 520 miles, on average (80 gal × 

6.5 mi/gal = 520 miles). Truck crewmembers try to combine activities at a stop; typically, one

crew member fills the tank while the other uses the facilities, buys food, etc. (Griego et al., 

1996). As shown in Table A-6, the average time spent at a truck stop is about 0.33 hour. 

Truck stops that would serve the 18-wheel tractor-trailer trucks that carry Type A or Type B 

casks containing spent IERs would mostly be located in rural or suburban areas near freeway 

access ramps. Each truck stop is surrounded by a different resident population. This analysis 

conservatively assumes that the resident population at each truck stop would be exposed to all 

of the shipments in each alternative. Tables A-12 through A-14 show the intermediate and final 

results of the analysis to determine impacts to populations near truck rest and refueling stops. 

Table A-12 provides estimates of the average numbers of truck stops on each of the 

representative transportation routes identified in Section A.3.2.3.1. The number of stops is 

determined by dividing the total route length by 520, the approximate number of miles between 

refueling stops (see above). Table A-13 provides the average rural and suburban population 

densities (derived from information in Table A-9; see Table A-13, footnote a). Table A-13 also 

shows the populations near truck stops for each representative transportation route, which are 

estimated by multiplying the population densities by the annular area between 30 and 800 

meters around the truck stop—i.e., 2.0 square kilometers (km2

) (0.77 square mile (mi2)).15 

As shown in Table A-7, the average individual external dose to a resident near a rural or 

suburban truck stop from either cask type is about 4.3 × 10-6 mSv. Multiplying this average 

individual external dose by the rural or suburban population numbers in Table A-13 yields the 

collective dose for one routine spent IER shipment for each population zone (rural or suburban) 

and representative origin-destination combination. Then, multiplying this collective dose per 

shipment by the number of spent IER shipments (full casks) yields the collective dose for each 

alternative. These results are shown for rural and suburban truck stops in Table A-14. 

As shown in Table A-14, the estimated total annual collective doses are all a small fraction of 

background, ranging from 0.1 to 0.5 percent of background at rural and suburban truck stops. 

Thus, since the total collective doses from annual routine shipments of spent IERs in each 

alternative are all lower than the average annual background dose that populations receive, the 

resulting radiological impacts to populations would be SMALL. Any differences between the 

collective doses to residents near rural and suburban truck stops depend only on the difference 

in population (with the populations near suburban trucks stops typically being higher). The 

radiation source and its strength are the same in both cases. Further, the LCFs as percentages 

of 2010 U.S. total estimated cancer fatalities shown in Table A-14 are also all negligible, the 

highest being about 4 x 10-8 percent, representing similarly SMALL impacts. Note that in actual 

practice, impacts would be lower than estimated because not all trucks carrying spent IERs 

would stop at the same rest stops and not all residents would be at the same locations for an 

entire year. 

 

15 RADTRAN assumes that potentially affected populations near truck stops reside no closer than a minimum radius 

of 30 m (0.03 km), and no farther than a maximum radius of 800 m (0.8 km), from the stop (see Table A-6). Thus, the 

area (in km2

) in which these populations reside can be calculated as follows: Area = π x [(0.8 km)2 - (0.03 km)2] = 2.0 

km2

. 
A-34 

Table A-12 Average Number of Truck Stops for 

Each Representative Transportation Route 

(Trucks Carrying Full Casks of Spent IERs) 

ORIGIN DESTINATION ONE-WAY ROUTE 

MILESa

TRUCK 

REFUELING 

STOPSb

Indian Point, NY 

Processing (TN) 779 1 

Processing (TN) + Disposal (TX) 2283 4 

Direct Disposal (TX) 1911 4 

Dresden, IL 

Processing(TN) 668 1 

Processing (TN) + Disposal (TX) 2171 2 

Direct Disposal (TX) 1244 5 

Palo Verde, AZ 

Processing (TN) 1534 3 

Processing (TN) + Disposal (TX) 3037 6 

Direct Disposal (TX) 533 1 

Vogtle, GA 

Processing (TN) 255 1c

Processing (TN) + Disposal (TX) 1758 4 

Direct Disposal (TX) 1622 3 

Processing (TN) Disposal (TX) 1503 3 

 a Summation of rural, suburban, and urban route distances from Table A-9. 

b Calculated by dividing the one-way route miles by the approximate number of miles between refueling stops 

(i.e., 520 miles, as calculated in the text above) and rounded. 

 c Actually, 255/520 = 0.5, so the truck might not have to stop at all. Listing 1 stop is conservative. 

In comparing the collective doses as percent of background in Table A-11 (for moving trucks) 

with those in Table A-14 (for stopped trucks), it is evident that the percentages in the former 

case are notably lower than those in the latter. This is because the collective dose percent of 

background dose is directly related to the time during which a population is exposed to the 

spent IER shipments. RADTRAN assumes that each resident near a truck stop is exposed to 

the radiation from the shipping cask on a stopped (stationary) truck for 0.33 hour (about 20 

minutes) (see above and Table A-6). However, a resident along a transportation route is 

exposed to radiation from a moving truck for only a few tenths of a second at most (based on 

108 kph truck speed (from Table A-5) = 30 m/sec = 3 m/0.1 second). This difference is also 

reflected in Table A-7: where the dose to the average individual near a truck stop is larger than 

the dose to the average individual along the route. Nevertheless, as indicated above and in 

Section A.3.2.3.1, radiological impacts due to radiation exposures to populations from stationary 

trucks near truck stops and from moving trucks along transportation routes, respectively, would 

both be SMALL. 
A-35 

Table A-13 Average Rural and Suburban Population Densities and Populations near 

Truck Stops for Each Representative Transportation Route 

ORIGIN DESTINATION 

AVERAGE POPULATION 

DENSITY (People/km2

)

a,b POPULATIONa,c 

RURAL SUBURBAN RURAL SUBURBAN

Indian Point, NY 

Processing (TN) 21 388 41 778 

Disposal (TX) 17 370 34 743 

Dresden, IL 

Processing (TN) 20 360 39 723 

Disposal (TX) 11 324 23 650 

Palo Verde, AZ 

Processing (TN) 11 349 21 700 

Disposal (TX) 6 385 12 772 

Vogtle, GA 

Processing (TN) 17 363 28 647

Disposal (TX) 14 322 34 728 

Processing (TN) Disposal (TX) 12 270 35 542 

a

 All numbers in these columns are rounded numbers from calculations. 

b

 The data in the two columns below represent the averages of the state rural and suburban population densities 

listed in Table A-9 for each origin-destination combination. 

c This would be the resident population in an annulus defined by radii of between 30 to 800 meters from the stopped 

truck (see text). 

A.3.3 Non-radiological and Radiological Impacts of Transportation Accidents 

Trucks carrying spent IERs or empty casks are as likely to be involved in traffic accidents as any 

other similar heavy trucks. Potential non-radiological and radiological impacts of transportation 

accidents as a result of traffic collisions involving trucks carrying spent IER shipments are 

evaluated in this section. Section A.3.3.1 assesses potential non-radiological impacts of 

transportation accidents, measured in terms of the number of traffic accidents and the number 

of traffic accident fatalities from the transport of both full and empty casks. Section A.3.3.2 

evaluates the radiological impacts of traffic accidents involving trucks carrying full shipping 

casks of spent IERs, under scenarios in which radioactive materials are and are not released. 

A.3.3.1 Non-Radiological Impacts of Transportation Accidents 

In this evaluation, non-radiological impacts of transportation accidents are assessed in terms of 

the number of traffic accidents and the number of traffic accident fatalities from implementation 

of each alternative. These potential non-radiological impacts are estimated using tractor-trailer 
A-36 

Table A-14 Annual Radiological Impacts to Populations near Truck Stops from Routine Spent IER Shipments for Each Alternative 

ORIGIN 

NPP 

LOCATION 

TOTAL ANNUAL COLLECTIVE DOSE (mSv) FROM SPENT IER SHIPMENTS 

TO RESIDENTS NEAR A TRUCK STOP, BY ALTERNATIVEa, b

TOTAL ANNUAL LCF FROM SPENT IER SHIPMENTS 

TO RESIDENTS NEAR A TRUCK STOP, BY ALTERNATIVEa

1A and 1Bc

2 and 

3 (After Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4Bc 1A and 1Bc

2 and 

3 (After Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4Bc

Indian Point, NY 

Rural Stop 0.16 0.078 0.062 0.41 0.084 Rural Stop 9.4E-06 4.7E-06 3.7E-06 2.4E-05 5.0E-06 

% U.S. Annual 

Backgroundd 0.1% 0.1% 0.1% 0.4% 0.1% % U.S. 2010 Estimated Cancer Fatalitiese 2E-09% 8E-10% 7E-10% 4E-09% 9E-10% 

Suburban Stop 3.6 1.3 1.3 8.8 1.8 Suburban Stop 2.2E-04 7.8E-05 8.0E-05 5.3E-04 0.00011 

% U.S. Annual 

Background 0.1% 0.1% 0.1% 0.4% 0.1% % U.S. 2010 Estimated Cancer Fatalities 4E-08% 1E-08% 1E-08% 9E-08% 2E-08% 

Dresden, IL 

Rural Stop 0.15 0.051 0.041 0.27 0.062 Rural Stop 9.2E-06 3.1E-06 2.4E-06 1.6E-05 3.7E-06 

% U.S. Annual 

Background 0.2% 0.1% 0.1% 0.3% 0.1% % U.S. 2010 Estimated Cancer Fatalities 2E-09% 5E-10% 4E-10% 3E-09% 7E-10% 

Suburban Stop 3.5 1.5 1.2 8.6 1.6 Suburban Stop 2.1E-04 9.1E-05 7.0E-05 5.2E-04 9.5E-05 

% U.S. Annual 

Background 0.2% 0.1% 0.1% 0.5% 0.1% % U.S. 2010 Estimated Cancer Fatalities 4E-08% 2E-08% 1E-08% 9E-08% 2E-08% 

Palo Verde, AZ 

Rural Stop 0.11 0.027 0.021 0.14 0.034 Rural Stop 6.7E-06 1.6E-06 1.3E-06 8.4E-06 2.0E-06 

% U.S. Annual 

Background 0.2% 0.05% 0.03% 0.2% 0.05% % U.S. 2010 Estimated Cancer Fatalities 1E-09% 3E-10% 3E-10% 2E-09% 4E-10% 

Suburban Stop 3.4 1.7 1.4 7.9 1.8 Suburban Stop 2.1E-04 1.0E-04 8.3E-05 4.7E-04 1.1E-04 

% U.S. Annual 

Background 0.1% 0.1% 0.1% 0.4% 0.1% % U.S. 2010 Estimated Cancer Fatalities 4E-08% 2E-08% 2E-08% 8E-08% 2E-08% 

Vogtle, GA 

Rural Stop 0.14 0.063 0.050 0.33 0.065 Rural Stop 8.4E-06 3.8E-06 3.0E-06 2.0E-05 8.4E-06 

% U.S. Annual 

Background 0.1% 0.1% 0.1% 0.4% 0.1% % U.S. 2010 Estimated Cancer Fatalities 2E-09% 7E-10% 5E-10% 3E-09% 7E-10% 

Suburban Stop 3.5 1.5 1.2 8.9 1.5 Suburban Stop 2.1E-04 9.2E-05 7.0E-05 5.5E-04 9.3E-05 

% U.S. Annual 

Background 0.2% 0.1% 0.1% 0.5% 0.1% % U.S. 2010 Estimated Cancer Fatalities 4E-08% 2E-08% 1E-08% 9E-09% 2E-08% 

 a Because of the uncertainties inherent in this type of analysis (Weiner, et al, 2009), percentages are reported to one significant figure and radiation doses and LCFs to two significant figures.  b The annual collective dose for a rural or suburban truck stop is equal to the average individual external dose to a resident near the truck stop (from Table A-7) multiplied by the population 

 and half of the total annual shipments of Type A and Type B casks ( from Table A-4) for each shipment route. 

 c The collective doses for Alternatives 1A and 1B and Alternatives 4A and 4B are the sum of the collective dose s from the NPP to the waste processing facility and from the waste processing 

 facility to disposal. 

 d The annual collective dose as a percentage of annual background was calculated by dividing the annual collective dose by the rural population along the shipment route and then dividing by 

 the annual background dose of 3.11 mSv/year (NCRP, 2009), and multiplying by 100 to obtain a percentage. 

 e The LCF risk as % of 2010 U.S. estimated cancer fatalities was calculated by dividing the LCF risk by U.S. estimated annual cancer fatalities for 2010, which was 569.495 (American Cancer 

 Society, 2010) and multiplying by 100 to obtain a percentage. 
A-37 

truck traffic accident and accident fatality rate information coupled with the total distances driven 

under each alternative with full and empty casks. 

Tractor-trailer truck accident rates by state are first estimated. Table A-15 shows these accident 

rates as the number of truck accidents per kilometer driven (tractor-trailer-truck-km), for the 

contiguous 48 states and the District of Columbia (information is not provided in Table A-15 for 

Alaska and Hawaii as there are no NPPs in those states and no spent IERs would be 

transported through those states). Since the USDOT does not specifically provide this 

information, the numbers of accidents per truck-km in Table A-15 are calculated using other 

USDOT traffic fatality data from the year 2009, the most recent data available. 

Table A-15 Estimated Tractor-Trailer Truck Accident Rates in the 

Contiguous States and District of Columbia 

STATE 

ACCIDENTS PER 

TRACTOR-TRAILER 

TRUCK-KM 

STATE 

ACCIDENTS PER 

TRACTOR-TRAILER 

TRUCK-KM 

Alabama 4.95E-07 Nebraska 6.70E-07 

Arizona 4.05E-07 Nevada 3.40E-07 

Arkansas 8.24E-07 New Hampshire 1.85E-07 

California 2.76E-07 New Jersey 2.87E-07 

Colorado 2.79E-07 New Mexico 4.73E-07 

Connecticut 1.61E-07 New York 2.68E-07 

Delaware 2.61E-07 North Dakota 3.78E-07 

District of Columbia 9.86E-08 North Carolina 1.30E-06 

Florida 3.17E-07 Ohio 3.19E-07 

Georgia 4.11E-07 Oklahoma 6.28E-07 

Idaho 4.56E-07 Oregon 3.08E-07 

Illinois 2.78E-07 Pennsylvania 4.23E-07 

Indiana 4.56E-07 Rhode Island 2.29E-07 

Iowa 6.86E-07 South Carolina 5.62E-07 

Kansas 6.19E-07 South Dakota 5.08E-07 

Kentucky 7.44E-07 Tennessee 4.29E-07 

Louisiana 5.99E-07 Texas 4.30E-07 

Maine 4.44E-07 Utah 3.17E-07 

Maryland 2.97E-07 Vermont 2.73E-07 

Massachusetts 1.33E-07 Virginia 3.32E-07 

Michigan 2.21E-07 Washington 1.94E-07 

Minnesota 3.03E-07 West Virginia 5.28E-07 

Mississippi 5.04E-07 Wisconsin 2.98E-07 

Missouri 4.22E-07 Wyoming 5.60E-07 

Montana 7.02E-07 

Source: Derived from USDOT 2009 state and national transportation statistics data as discussed in the text. 
A-38 

Table 2-1 in the USDOT’s “State Transportation Statistics 2010” (USDOT, 2010) provides, for 

each state, the vehicle fatalities per 100,000 people, the number of people driving vehicles in 

the state, and the vehicle-miles traveled in that state. From that information, vehicle fatalities 

per vehicle mile are calculated as follows: 

State vehicle fatalities per vehicle-mile = 

[(vehicle fatalities/100,000 people) x (number of people driving)] ÷ (vehicle-miles driven) 

Table 2-3 of the same USDOT (2010) publication gives the fraction of vehicle fatalities for each 

state that are tractor-trailer truck fatalities. From that information, tractor-trailer truck fatalities 

per tractor trailer-truck-mile are calculated as follows: 

State tractor-trailer truck fatalities per tractor-trailer-truck-mile = 

(vehicle fatalities per vehicle-mile) x (fraction of fatalities for tractor-trailer trucks) 

Table 2-1 in the USDOT’s “National Transportation Statistics 2011” (USDOT, 2011) gives 2009 

total U.S. tractor-trailer truck fatalities and Table 2-3 in that publication gives 2009 total U.S. 

tractor-trailer truck accidents. Assuming that traffic fatalities in each state are proportional to 

national traffic accidents, then the tractor-trailer truck accidents per tractor-trailer-truck-mile for 

each state are calculated as follows: 

State tractor-trailer truck accidents per tractor-trailer truck-mile = 

(tractor-trailer truck fatalities/tractor-trailer-truck-mile) x (tractor-trailer accidents ÷ tractortrailer fatalities) 

Tractor-trailer truck accidents per tractor-trailer-truck-mile were then converted to tractor-trailer 

truck accidents per tractor-trailer-truck-km by multiplying by 0.62137, to obtain the figures 

shown in Table A-15. 

Projected annual numbers of spent IER tractor-trailer truck traffic accidents and traffic accidentrelated fatalities (full and empty casks) were then calculated for each alternative for each 

representative transportation origin-destination combination identified in Section A.3.2.3. The 

results are shown in Table A-16. In this table, the estimated annual number of spent IER truck 

accidents are compared with annual U.S. tractor-trailer truck accidents as percentages (based 

on 367,920 annual tractor-trailer truck accidents in 2009 (USDOT, 2011; Table 2-3)). In 

addition, estimated annual fatalities involving spent IER tractor-trailer trucks are similarly 

compared with annual U.S. fatalities involving all tractor-trailer trucks (based on 503 annual 

tractor trailer accident fatalities in 2009 (USDOT, 2011; Table 2-1)). 

The information in Table A-16 is based on traffic accident and fatality rates for tractor-trailer 

trucks, the distance driven for each route (from the one-way route kilometers from Table A-9, 

and the annual number of shipments by alternative (including full and empty casks), from 

Table A-2). A sample calculation is presented below, showing how the results in Table A-16 

were derived. This sample calculation is for Alternative 3 (Years 1-20) and the transportation 

route originating from Indian Point, NY. The sample calculation computes the total potential 

accidents along the route by multiplying the following: the total kilometers traveled per state 

(rural + suburban + urban), the state-specific tractor-trailer truck accident rate for the distance 

traveled in that state, and the annual number of shipments traversing that route. 
A-39 

Table A-16 Estimated Annual Tractor-Trailer Accidents and Fatalities for 

Representative Transportation Routes to Disposal by Alternative 

(Full and Empty Casks) 

ORIGIN NPP 

LOCATION 

MEASURES OF POTENTIAL 

NON-RADIOLOGICAL 

IMPACTS 

ANNUAL SPENT IER TRUCK ACCIDENTS AND FATALITIES 

BY ALTERNATIVE

1A and 1Ba 

2 and 

3 (After Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4Ba

Indian Point, NY 

Annual No. of Spent IER 

Truck Accidents 1.6 2 1.3 8 1 

% of Annual U.S. TractorTrailer Truck Accidentsb 0.0004% 0.0004% 0.0003% 0.002% 0.0001% 

Projected Annual Fatalities 

Involving Spent IER 

Shipments 

0.01 0.01 0.01 0.06 0.01 

% of Annual U.S. Fatalities 

Involving All 

Tractor-Trailer Trucksc

0.002% 0.002% 0.002% 0.012% 0.002% 

Dresden, IL 

Annual No. of Spent IER 

Truck Accidents 1.7 1 0.7 4 1 

% of Annual U.S. TractorTrailer Truck Accidents 0.0005% 0.0002% 0.0002% 0.001% 0.0001% 

Projected Annual Fatalities 

Involving Spent IER 

Shipments 

0.01 0.01 0.005 0.03 0.005 

% of Annual U.S. Fatalities 

Involving All 

Tractor-Trailer Trucks 

0.002% 0.002% 0.001% 0.006% 0.001% 

Palo Verde, AZ 

Annual No. of Spent IER 

Truck Accidents 2.6 0.4 0.3 2 0.3 

% of Annual U.S. TractorTrailer Truck Accidents 0.0007% 0.0001% 0.0001% 0.0005% 0.0.0001% 

Projected Annual Fatalities 

Involving Spent IER 

Shipments 

0.02 0.002 0.002 0.01 0.002 

% of Annual U.S. Fatalities 

Involving All 

Tractor-Trailer Trucks 

0.004% 0.0004% 0.0004% 0.002% 0.0005% 

Vogtle, GA 

Annual No. of Spent IER 

Truck Accidents 1.2 1 0.3 4 1 

% of Annual U.S. TractorTrailer Truck Accidents 0.0003% 0.0001% 0.0001% 0.0009% 0.0001% 

Projected Annual Fatalities 

Involving Spent IER 

Shipments 

0.01 0.01 0.002 0.03 0.005 

% of Annual U.S. Fatalities 

Involving All 

Tractor-Trailer Trucks 

0.002% 0.002% 0.0004% 0.006% 0.001% 

a The accidents and fatalities for Alternatives 1A and 1B and Alternatives 4A, and 4B are the sum of the accidents 

and fatalities from the NPP to the waste processing facility and from the processing facility to disposal. 

 b Based on 367,920 annual tractor-trailer truck accidents in 2009 (USDOT, 2011). 

 c Based on 503 annual U.S. fatalities involving all tractor-trailer trucks in 2009 (USDOT, 2011). 
A-40 

Sample Calculation Showing How Data Presented in Table A-16 Are Derived: 

Indian Point, NY, to Disposal, for Alternative 3 (Years 1-20) with 838 Annual Shipments 

A. Total Truck Kilometers Traveled (Rural + Suburban + Urban) (from Table A-9): 

In AR: 317.4 km + 130 km + 8.4 km = 455.8 km 

In MD: 5.7 km + 12.3 km + 1.4 km = 19.4 km 

In NJ: 40.2 km + 67.6 km + 14.2 km = 122.0 km 

In NY: 11.7 km + 28.1 km + 16.4 km = 56 .2 km 

In OK: 428.2 km + 98.2 km + 8.4 km = 535 km 

In PA: 134.5 km + 120.4 km + 11 km = 265.9 km 

In TN: 496.4 km + 241.4 km + 31.3 km = 769.1 km 

In TX: 220 km + 18.8 km + 7.2 km = 246 km 

In VA: 282 km + 230 km + 9.7 km = 521.7 km 

In WV: 12.6 km + 28.8 km + 0.7 km = 42.1 km 

B. State Tractor-Trailer Truck Accident Rates per km (from Table A-15): 

AR: 8.24 x 10-7 PA: 4.23 x 10-7

MD: 2.97 x 10-7 TN: 4.29 x 10-7

TX: 4.30 x 10-7 TX: 4.30 x 10-7

NY: 2.68 x 10-7 VA: 3.32 x 10-7

OK: 6.28 x 10-7 WV: 5.28 x 10-7

C. Annual State Tractor-Trailer Truck Accidents: A x B X 838 shipments/year 

No. of accidents in AR: 0.315 accident/year 

No. of accidents in MD: 0.00483 accident/year 

No. of accidents in NJ: 0.0293 accident/year 

No. of accidents in NY: 0.0126 accident/year 

No. of accidents in OK: 0.282 accident/year 

No. of accidents in PA: 0.0943 accident/year 

No. of accidents in TN: 0.277 accident/year 

No. of accidents in TX: 0.0886 accident/year 

No. of accidents in VA: 0.145 accident/year 

No. of accidents in WV: 0.0197 accident/year 

D. Total Potential Annual Accidents from Indian Point, NY to Disposal: 

0.315 + 0.00483 + 0.0293 + 0.0126 + 0.282 + 0.0941 + 0.277 + 0.0886 + 0.145 + 0.0197 

≈ 1.3 accidents/year 

U.S. tractor-trailer truck traffic fatalities in 2009, used in Table A-16, were calculated from 

national statistics in Tables 2-1 and 2-3 of USDOT (2011), as shown below. 2009 data are the 

most recent available. 
A-41 

2009 U.S. tractor-trailer truck accidents (from Table 2-3) = 367,920 

2009 U.S. tractor-trailer truck fatalities (from Table 2-1) = 503 

Fatalities per accident = 503 ÷ 367,920 = 0.00137 

As shown in Table A-16, the largest estimated annual number of potential traffic accidents 

involving spent IER shipments (full and empty casks) is 2.6 accidents for the transportation 

route originating in Palo Verde, AZ, for Alternatives 1A and 1B. This number of accidents is 

0.0007 percent of the annual number of tractor-trailer truck accidents in the U.S. Also from 

Table A-16, the largest number of potential traffic fatalities is 0.02 per year for the same Palo 

Verde origin for Alternatives 1A and 1B. This is equivalent to one fatal traffic accident every 50 

years, and is 0.004 percent of the total annual U.S. truck fatalities. Thus, the non-radiological 

impacts represented by the projected numbers of tractor-trailer truck accidents and associated 

number of traffic accident fatalities would be SMALL. 

A.3.3.2 Radiological Impacts of Transportation Accidents 

The potential radiological impacts of accidents involving the transport of untreated and treated 

(processed) spent IERs in Type A and Type B shipping casks (full casks) are evaluated in this 

section. Two types of transportation accidents are considered involving trucks transporting 

radioactive materials that could have radiological impacts: 

 Accidents in which there is no impact on the cask and, therefore, no release of 

radioactive material; and 

 Accidents in which there is an impact on the cask, and radioactive material could be 

released. 

Sections A.3.3.2.1 and A.3.3.2.2 evaluate the consequences of these two accident scenarios, 

respectively. The distinction between the two types of accidents is made because more than 91 

percent of all accidents involving trucks carrying radioactive material and more than 99 percent 

of accidents involving Type B casks do not result in any damage to the cargo; therefore, these 

accidents would not involve a release of radioactive material (NRC, 1977; Table 5-3; Sprung et 

al., 2000: Chapter 7, pp. 7-73 to 7-76). 

A.3.3.2.1 Accidents with No Release of Radioactive Materials 

This section evaluates potential radiological impacts to members of the public from 

transportation accidents in which the spent IER cargo in full Type A or Type B casks on tractortrailer trucks is not impacted (i.e., no radioactive materials are released from the shipping 

casks), but in which the tractor-trailers would be disabled and stationary and require assistance. 

Since no radioactive materials would be released, exposure would be from the external 

radiation from the casks; and the analysis is conservatively based on the legally-defined 

maximum external dose rates from the Type A and Type B casks. For each representative 

route in each of the six alternatives, the consequence of an accident is represented by the 

collective (population) dose to residents near the location of the accident. The dose to the 

nearest member of the public, the MEI, is also calculated. 
A-42 

The doses to individuals and populations near the accident sites are calculated using 

RADTRAN in a similar fashion as individual and collective doses are calculated near routine 

transportation stops (i.e., truck rest and refueling stops; see Section A.3.2.3.2), except that 

RADTRAN models the duration of the stop as a result of an accident as 10 hours rather than the 

0.33 hour for the routine stop (see Table A-6) and multiplies the resulting dose by the accident 

probability16 along the route where the stop occurs. An accident, even a minor accident, would 

generally require the removal of the cask, either by transferring it by crane to another vehicle or 

by removing the truck and cask from the accident scene. Considering the size and weight of the 

full casks (see Table A-1), it could take several hours to deploy appropriate equipment for this 

purpose at the accident location; and 10 hours is assumed for the RADTRAN assessment. 

Additionally, the RADTRAN modeling to calculate collective (population) doses in this evaluation 

is conducted based on an average population near a suburban truck stop because that is more 

conservative than modeling for an average population near a rural truck stop (i.e., suburban 

populations are larger than rural populations). Thus, the accident is assumed to take place on a 

suburban highway, the distance to the nearest member of the public would be 30 m (98 ft) (from 

Table A-6), and the affected population would be the population between 30 and 800 meters 

from the accident (from Table A-6). 

Table A-17 presents the RADTRAN-calculated collective doses to residents near the accident 

and associated collective LCFs for each alternative, for the representative transportation routes 

identified in Section A.3.2.2. The collective doses are calculated in the following manner: 

Collective dose (person-mSv) = 

[average suburban population (from Table A-13)] x [average individual dose near truck 

stop for either a Type A or Type B cask (from Table A-717)] x [number of full cask 

shipments (one half of Table A-4 values)] x [accident probability] 

In Table A-17, the calculated collective doses are compared to average annual background 

dose. In addition, estimated annual fatalities for traffic accidents involving spent IER tractortrailer trucks (from Table A-16) are included to compare potential cancer fatalities from radiation 

exposure to spent IER shipments during a traffic accident (i.e.collective LCFs) to potential truck 

traffic accident fatalities from causes other than radiological exposure. For further comparison 

purposes in the table, collective LCFs are calculated as percentages of 2010 total estimated 

U.S. cancer fatalities. 

 

16 The accident probability (risk) on any route is the sum of the accident probabilities for the route through each state 

transited. These state accident probabilities are calculated by multiplying the route kilometers in each state (from 

Table A-9) by the accidents per km for that state (from Table A-15). 

17 The analysis is based on either cask type because both have the same legally-defined maximum external dose 

rate (0.1 mSv/hour (10 mrem/hour) at two meters (6.6 feet) from the cask (10 CFR 71.47(b)(3)) to which it is 

conservatively assumed that members of the public would be exposed. Therefore, exposure to either cask type in the 

type of accident evaluated in this section results in essentially the same radiological impact to individual receptors, as 

illustrated in Table A-7. In actual practice, the external dose rates from these casks would probably be lower than the 

legally-defined maximum. 
A-43 

Table A-17 Estimated Collective Population Doses and LCFs for an Accident with an 

Undamaged Cask for Representative Transportation Routes to Disposal by Alternative 

ORIGIN NPP 

LOCATION 

MEASURES OF POTENTIAL 

RADIOLOGICAL IMPACTS 

RESULTS BY ALTERNATIVE 

1A and 1Ba 

2 and 

3 (After Year 

21) 

3 

(Years 1-20) 

3 

(Year 21) 4A and 4Ba

Indian Point, 

NY 

Collective Dose (person-mSv) 0.143 0.143 0.113 0.740 0.113 

Collective Dose as % of Collective 

Average Annual Backgroundb 0.007% 0.006% 0.005% 0.032% 0.006% 

Collective LCF 8.6E-06 8.6E-06 6.8E-06 4.4E-05 6.8E-06 

Estimated Annual Traffic Fatalities 

Involving Spent IER Shipmentsc 0.01 0.01 0.01 0.06 0.01 

Collective LCF as % of Projected 

Annual Traffic Fatalities Involving 

Spent IER Shipments 

0.086% 0.086% 0.068% 0.074% 0.068% 

Collective LCF as % of 2010 

Estimated U.S. Cancer Fatalitiesd 1.5E-09% 1.5E-09% 1.2E-09% 7.7E-09% 1.2E-09% 

Dresden, IL 

Collective Dose (person-mSv) 0.150 0.0752 0.0594 0.390 0.0594 

Collective Dose as % of Collective 

Average Annual Background 0.008% 0.003% 0.003% 0.020% 0.003% 

Collective LCF 9.0E-06 4.5E-06 3.6E-06 2.3E-05 3.6E-06 

Estimated Annual Traffic Fatalities 

Involving Spent IER Shipments 0.01 0.01 0.005 0.03 0.005 

Collective LCF as % of Projected 

Annual Traffic Fatalities Involving 

Spent IER Shipments 

0.090% 0.045% 0.071% 0.078% 0.071% 

Collective LCF as % of 2010 

Estimated U.S. Cancer Fatalities 1.6E-09% 7.9E-10% 6.3E-10% 4.0E-09% 6.3E-10% 

Palo Verde, 

AZ 

Collective Dose (person-mSv) 0.228 0.0330 0.0261 0.172 0.0261 

Collective Dose as % of Collective 

Average Annual Background 0.01% 0.001% 0.001% 0.007% 0.001% 

Collective LCF 1.4E-05 2.0E-06 1.6E-06 1.0E-05 1.6E-06 

Estimated Annual Traffic Fatalities 

Involving Spent IER Shipments 0.02 0.002 0.002 0.01 0.002 

Collective LCF as % of Projected 

Annual Traffic Fatalities Involving 

Spent IER Shipments 

0.069% 0.099% 0.078% 0.103% 0.078% 

Collective LCF as % of 2010 

Estimated U.S. Cancer Fatalities 2.5E-09% 3.5E-10% 2.8E-10% 1.8E-09% 2.8E-10% 

Vogtle, GA 

Collective Dose (person-mSv) 0.226 0.0729 0.0261 0.378 0.0576 

Collective Dose as % of Collective 

Average Annual Background 

0.01% 0.003% 0.001% 0.016% 0.003% 

Collective LCF 1.4E-05 4.4E-05 1.6E-06 2.3E-05 3.5E-06 

Estimated Annual Traffic Fatalities 

Involving Spent IER Shipments 0.01 0.01 0.002 0.03 0.005 

Collective LCF as % of Projected 

Annual Traffic Fatalities Involving 

Spent IER Shipments 

0.136% 0.044% 0.078% 0.076% 0.069% 

Collective LCF as % of 2010 

Estimated U.S. Cancer Fatalities 2.5E-09% 7.7E-09% 2.8E-10% 4.0E-09% 6.1E-10% 

a The collective doses for Alternatives 1A and 1B and Alternatives 4A and 4B are the sums of the collective dose from the NPP to 

the waste processing facility and from the processing facility to disposal. 

b The collective dose as a percentage of collective average annual background was calculated by dividing the annual collective dose 

by the annual collective background dose to the suburban population from Table A-13 times 3.11 person-mSv/year (NCRP, 2009), 

and multiplying by 100 to obtain a percentage.

 c From Table A-16. 

 d Based on 569,495 estimated cancer fatalities in the United States in 2010 (American Cancer Society, 2010). 
A-44 

Table A-17 shows that even assuming a stop as long as 10 hours, the estimated collective 

doses are small fractions of the U.S. average annual background dose and the corresponding 

LCFs are very low and several orders of magnitude lower than the estimated number of traffic 

fatalities from spent IER shipments and 2010 estimated U.S. cancer fatalities. There is little 

variation between these results for the various alternatives and representative transportation 

routes. The dose to, and corresponding LCF for, the nearest member of the public, the MEI, for 

this type of accident are 1.3 × 10-4 mSv and 7.8 × 10-9, respectively, and are the same 

regardless of transportation route, accident location, or alternative. This dose and LCF are 

0.015 percent of background and 2.3 × 10-8 percent of 2010 total estimated U.S. cancer 

fatalities, respectively. Thus, the potential radiological impacts to individuals and populations 

from this type of accident would be SMALL. 

A.3.3.2.2 Accidents in Which Radioactive Material Could Be Released 

This section separately examines the consequences of accidents involving Type A and Type B 

casks in which radioactive material could be released. Due to design differences between these 

two types of shipping casks and the different classes of waste they would carry, the 

consequences of such accidents involving these two cask types would be different. Type A 

casks are the less robust in design of the two and, therefore, more likely to be damaged in an 

accident, but would carry the lower activity Class A spent IERs. Type B casks, which would 

carry the higher activity Class B and C IERs, are very robust and designed to withstand severe 

accidents. Note also that accident consequences for each cask type are evaluated for a single 

accident of each kind and not for each of the six alternatives. This is because, as illustrated in 

Table A-15, the numbers of tractor-trailer truck accidents that occur is extremely low and the 

likelihood of even one such accident occurring is very small. 

Accidents in Which a Type A Cask Would be Impacted 

This section examines the potential impact on members of the public if a Type A cask is in an 

accident that is severe enough to damage the cask and expose the public to the entire spent 

IER contents of the cask. The test series required for Type A casks (such as the CNS 14-215) 

in 10 CFR 71.71 ensures that these casks can withstand the stresses and strains of routine 

transportation, but not necessarily survive severe accidents. Consequently, the radionuclide 

inventory18 that can be carried in a Type A cask is limited by regulation; specifically, the 

radionuclide inventory than can be transported in a Type A cask cannot not exceed the A2 value 

defined in 10 CFR 71, Appendix A, Table A-1. 

The A2 values were calculated using the “Q system” defined by the International Atomic Energy 

Agency (IAEA, 2002; Appendix I, Section I.11, pp. 216 et seq.), which is based on a set of 

exposure scenarios called the “Q series”. The “Q” in the term Q system stands for “quantity”. 

The Q system defines the quantity limits of radionuclides (e.g., in terms of A2 values) that are 

 

18 Radionuclide inventory is the list of radionuclides in a particular material and the radioactivity of each. In this 

document, the radionuclide inventory is expressed in curies. 
A-45 

allowed in a Type A package. As discussed below, the analysis in this section uses the Q 

system to define the basis for exposure to a release of spent IERs from a Type A cask severely 

damaged in a transportation accident. Spent IERs are contaminated with radionuclides 

throughout their volume, and the amount that can be carried in a Type A cask is defined by the 

A2 values. 

There are five IAEA Q series exposure scenarios: 

 QA - exposure to external gamma radiation; 

 QB - exposure to external beta radiation; 

 QC - exposure to radioactive material by inhalation, resulting in an internal dose; 

 QD - skin contamination by, and ingestion doses from, radioactive material; and 

 QE - exposure by submersion in a cloud of radioactive material. 

The IAEA Q series scenarios are based on a person exposed to an A2 quantity of radioactive 

material in any one of the Q series scenarios receiving a radiation dose no greater than 50 mSv 

(5000 mrem) if that person is located one meter from the A2 quantity for 30 minutes. Thus, if a 

Type A cask carrying an A2 quantity of material is in an accident so severe that a person 

standing one meter from the cask is exposed to the entire contents of the cask for 30 minutes, 

he or she would receive a dose of ionizing radiation that is at most 50 mSv. Under these 

conditions, a dose of 50 mSv is considered acceptable by the IAEA. The A2 values from the 

Q series, which limit the types and amount of radionuclides that can be transported in a Type A 

package, are based on these criteria. Although it is acknowledged that 50 mSv is a sizeable 

dose of radiation, IAEA considers this dose to be acceptable based on the assumption that no 

one would remain as close as a meter to an A2 amount of radioactive material. 

The above information and considerations may be used to calculate the dose to a receptor at 

any distance from a source (e.g., the A2 amount potentially released from a damaged Type A 

cask in an accident) for any period of time. The radiological risks and consequences of 

accidental releases of radioactive material depend on the radionuclide inventory in the shipping 

cask. Radiation dose is inversely proportional to the square of the distance of the receptor from 

the radiation source and directly proportional to the amount of time the receptor spends at that 

distance. The dose to a receptor is also directly proportional to the total radioactivity to which 

the receptor is exposed. This scheme is used in this analysis to calculate the radiation dose to 

a receptor if a Type A package carrying its maximum A2 quantity of spent IERs (the maximum 

quantity allowed) is severely damaged in an accident and the receptor is exposed to the entire 

contents of the cask. 

It is further assumed that spent IERs transported in a Type A cask would not be dispersed in the 

air if the cask were severely damaged and, therefore, the public would only be externally 

exposed to the spent IERs (i.e., the IERs would not be inhaled or ingested). Physical 
A-46 

characteristics of spent IERs are such that atmospheric dispersion is highly unlikely. A typical 

IER, Purolite® NRW3240, has a density of 705 to 740 grams per liter and a particle size range 

of 425 to 1200 micrometers (μm) (Purolite, 2012). Although the densities of many aerosolizable 

materials are similar (e.g., the density of water is 1000 grams per liter), typical aerosolizable 

particle size is less than 50 μm, much smaller than typical IER particle size. Thus, the spent 

IERs from a damaged Type A cask released to the environment would most likely remain on the 

ground at the site of the accident rather than being dispersed because of their larger particle 

size. Thus, the QA scenario, external gamma dose to a receptor, is the most likely exposure 

scenario for this damaged Type A cask accident case, and the dose from a damaged Type A 

cask carrying spent IERs to a member of the public is calculated in the present analysis based 

on the QA scenario for external radiation exposure. The progression of this analysis is detailed 

below. 

Table A-18 provides basic data and intermediate calculations for the accident analysis, which 

are the projected annual average radionuclide inventories of spent IERs per boiling water 

reactor (BWR) unit and per pressurized water reactor (PWR) unit and the calculated A2 values 

of the mixtures.19

The numbered columns in the table are as follows:

Column 1: Radionuclides that could be released in an accident involving the Type A 

cask. 

Column 2: A2 value for each radionuclide. 

Column 3: Average annual radionuclide Ci content of spent IERs per BWR unit. 

Column 4: Average annual radionuclide Ci content of spent IERs per PWR unit. 

Column 5: Fraction of total BWR Ci represented by the activity of each radionuclide. 

Column 6: Fraction of total PWR Ci represented by the activity of each radionuclide. 

Column 7: Ratio of each BWR radionuclide fraction to its A2 value. 

Column 8: Ratio of each PWR radionuclide fraction to its A2 value. 

 

 

19 It is important to distinguish between spent IERs from boiling water reactors (BWRs) and those from pressurized 

water reactors (PWRs) in this analysis because the radionuclide inventories from these two sources would be 

different and the public would be exposed to the actual radionuclide inventory. In general, the curie content 

(i.e., amount of radioactivity) of BWR spent IERs is slightly higher than that of PWR spent IERs. 
A-47 

Table A-18 Radionuclide Inventories of BWR and PWR Spent IERs and 

Calculation of the A2 Values of the Mixtures 

1 2 3 4 5 6 7 8 

RADIONUCLIDEA2(i) 

VALUE 

BWRa

(Ci) 

PWRb

(Ci) 

BWR 

Fraction

PWR 

Fraction 

BWR 

f(i)/A2(i) 

PWR 

f(i)/A2(i) 

H-3c 0.54 0.54 0.8 1.29E-03 5.94E-03 2.40E-03 1.10E-02

C-14 81 0.72 0.55 1.73E-03 4.08E-03 2.13E-05 5.04E-05

Cr-51 810 2.8 0.043 6.71E-03 3.19E-04 8.28E-06 3.94E-07

Mn-54 27 25 3.4 5.99E-02 2.52E-02 2.22E-03 9.35E-04

Fe-55 1100 240 22 5.75E-01 1.63E-01 5.23E-04 1.48E-04

Fe-59 24 0.42 0.018 1.01E-03 1.34E-04 4.19E-05 5.57E-06

Co-57 270 0.0072 0.37 1.73E-05 2.75E-03 6.39E-08 1.02E-05

Co-58 27 2.4 18 5.75E-03 1.34E-01 2.13E-04 4.95E-03

Co-60 11 110 12 2.64E-01 8.91E-02 2.40E-02 8.10E-03

Ni-59 --d

 0.24 0.07 5.75E-04 5.20E-04 -- -- 

Ni-63 810 4.3 43 1.03E-02 3.19E-01 1.27E-05 3.94E-04

Zn-65 54 16 0.016 3.83E-02 1.19E-04 7.10E-04 2.20E-06

Sr-90 8.1 0.18 0.094 4.31E-04 6.98E-04 5.32E-05 8.62E-05

Zr-95 22 0.027 0.036 6.47E-05 2.67E-04 2.94E-06 1.21E-05

Nb-94 19 0.00 5.40E-07 0.00 4.01E-09 0.00 2.11E-10

Tc-99 24 0.00002 0.00017 4.79E-08 1.26E-06 2.00E-09 5.26E-08

Ag-110m 11 0.063 0.034 1.51E-04 2.52E-04 1.37E-05 2.29E-05

Sb-125 27 0.34 0.034 8.15E-04 2.52E-04 3.02E-05 9.35E-06

Cs-134 19 0.027 0.93 6.47E-05 6.90E-03 3.40E-06 3.63E-04

Cs-137 16 1.3 13 3.11E-03 9.65E-02 1.95E-04 6.03E-03

Ce-144 5.4 12 20 2.88E-02 1.48E-01 5.32E-03 2.75E-02

Pu-238 0.027 0.9 0.29 2.16E-03 2.15E-03 7.99E-02 7.97E-02

Pu-239/240 0.027 0.002 0.00073 4.79E-06 5.42E-06 1.77E-04 2.01E-04

Pu-241 0.027 0.00033 0.00026 7.91E-07 1.93E-06 2.93E-05 7.15E-05

Am-241 0.027 0.077 0.0034 1.84E-04 2.52E-05 6.83E-03 9.35E-04

Cm-242 0.27 0.00029 0.00045 6.95E-07 3.34E-06 2.57E-06 1.24E-05

Cm-243 0.027 0.0014 0.00035 3.35E-06 2.60E-06 1.24E-04 9.62E-05

Cm-244 0.054 0.0011 0.00059 2.64E-06 4.38E-06 4.88E-05 8.11E-05

Total Ci Content 417 135 Total f(i)/A2(i) 0.116/Ci 0.140/Ci 

܍ܚܝܜܠܑܕ ܚܗ܎ ૛ۯ

ൌ ૚

∑ ܎ሺܑሻ

ࡵ ሻܑሺ૛ۯ

8.61 Ci 7.15 Ci 

Sources: (EPRI, 2007; Table 6-13) and 10 CFR 71 Appendix A (see text). 

a BWR = boiling water reactor 

b

 PWR = pressurized water reactor. 

c

 A2 value for this radionuclide is from 10 CFR 71, Appendix A, Table A-3. 

d

 There is no useable A2 value for this radionuclide. 
A-48 

The radionuclide inventory and curie (Ci) content data is from EPRI (EPRI, 2007; Table 6-12), 

and the A2 values of the radionuclides are from Table A-1 of 10 CFR Part 71, Appendix A. The 

information in Table A-18 does not distinguish between Class A, B, and C concentration spent 

IERs because there are no radionuclide inventory data available for the individual classes of the 

spent IERs. 

In Table A-18, the following formula from 10 CFR 71, Appendix A, is used to calculate the A2

values of the mixtures of BWR and PWR spent IER radionuclides: 

ൌ ݁ݎݑݐݔ݉݅	ݎ݋݂	ଶܣ

1

∑ ݂ሺ݅ሻ

ܣଶሺ݅ሻ ூ

In this equation, f(i) is the fraction of activity of radionuclide i in the cask and A2(i) is the A2 value 

of the radionuclide i. The results of the calculations using this equation are shown at the bottom 

of the table. These are the maximum A2 values of the spent IER mixtures allowed to be carried 

in a Type A cask. 

As discussed earlier, the A2 value for a Type A cask shipment is based on a dose of 50 mSv to 

a person one meter from the damaged cask for 30 minutes. From this, the dose to a person 

located at a different distance from an actual damaged cask for a different period of time can be 

calculated. The representative dose, D(r, t), to a receptor located closest to the site of an 

accident involving a single Type A spent IER shipment in which the cask is damaged and all of 

its contents are released, is calculated using the following equation: 

ൌ ሻݐ ,ݎሺܦ

ܥ

ଶܣ

ݐܭ

ଶݎ

In this equation, C is the curies per shipment; t is the exposure time; A2 is the A2 value of the 

spent IER mixture in the cask; and r is the distance of the receptor from the cask. K is a 

constant based on the IAEA QA exposure scenario of a 50-mSv dose to a person one meter 

from the damaged cask for 30 minutes (0.5 hour (hr)), and is given by: 

ܭ ൌ 50	݉ܵݒሺ1݉ሻଶ

100 ൌ ݎ݄	0.5

ଶ݉ ∙ ݒ݉ܵ

ݎ݄

For this analysis, the calculations are based on the following additional parameters and 

assumptions, similar to those used in RADTRAN calculations of radiological impacts to 

individual receptors near truck stops: 

 The accident occurs on an interstate highway, and is outside with no shielding. 

 The closest member of the public to the accident (the MEI) would be 30 meters away 

(from Table A-6). 

 The exposure lasts for 10 hours (hr) (from Table A-6). 
A-49 

For this analysis, the maximum curie content per Type A spent IER shipment is assumed be the 

A2 value derived in Table A-18 (i.e., 8.61 Ci for BWR shipments and 7.15 Ci for PWR 

shipments). With this conservative assumption that the Type A casks carrying the A2 values are 

involved in an accident, and using the information in the three bullets above for accident 

conditions, exposure time, and distance, the estimated dose received by the nearest receptor to 

a damaged Type A cask carrying BWR spent IERs, DBWR, is: 

݅ܥ	8.61 ൌ ௐோ஻ܦ

	ݔ	 ݅ܥ	8.61

ଶ݉ ∙ ݒ݉ܵ 100

ݎ݄	10	ݔ	 ݎ݄

ሺ30	݉ሻଶ ൌ 1.11	݉ܵݒ	ሺ111	݉ݎ݁݉ሻ

The dose for a cask containing PWR spent IERs is similarly calculated and produces the same 

result, since the PWR IER cask is also carrying A2 curies. LCFs are calculated from the doses 

as discussed earlier in this appendix. Dose and LCF results are summarized in Table A-19, 

compared with average annual background and 2010 total estimated U.S. cancer fatalities, 

respectively. 

As shown in Table A-19, the MEI dose and LCF as percentages of U.S. average annual 

background and 2010 U.S. total estimated cancer fatalities are 36 percent and 1 × 10-8 percent, 

respectively, for either reactor type. These results indicate that potential radiological impacts to 

an individual exposed to spent IERs released from a damaged Type A cask in a truck accident 

would be SMALL. Collective doses were not calculated because the IAEA Q series is based on 

individual dose, not collective dose. 

Table A-19 Estimated Doses and LCFs to an Individual Receptor for 

an Accident Involving a Damaged Type A Cask by NPP Reactor Type 

MEASURES OF POTENTIAL RADIOLOGICAL IMPACTS

REACTOR TYPE 

BWR PWR 

MEI Dose (mSv) 1.11 1.11 

MEI Dose as % U.S. Annual Backgrounda 36% 36% 

MEI LCF 6.7E-05 6.7E-05 

MEI LCF as % 2010 Estimated U.S. Cancer Fatalitiesb 1E-08% 1E-08% 

 a Based on average annual U.S. background dose of 3.11 mSv/year (NCRP, 2009). 

 b Based on 2010 total estimated cancer fatalities in the U.S. of 569,495 (American Cancer Society, 2010).

Accidents in Which a Type B Cask May Be Impacted 

Spent IERs that exceed the A2 limit must be carried in Type B casks. For this evaluation, it is 

assumed that the Class B and C resins would be shipped in these casks. Type B casks are 

designed to be sufficiently robust that they are not likely to be damaged in a traffic accident. 
A-50 

The degree of robustness is ensured by the NRC regulations in 10 CFR Part 71. The test 

series in 10 CFR 71.73 and 71.51(a)(2) required for Type B casks subjects these casks to 

conditions generally more severe than a very bad traffic accident (Sprung et al., 2000), thus 

ensuring that the cask can withstand the stress of a traffic accident. Therefore, release of 

radioactive material from a Type B cask could occur only in accidents considerably worse than 

almost all traffic accidents. Such accidents would involve extremely severe impacts of casks 

onto hard targets, or a very long-lasting, very hot fire, or both. Even such extreme conditions 

would not damage the body of the cask (although the cask’s lead shielding might be slightly 

damaged); and releases of radioactive material, if any, could occur only through the cask seals 

and then only in very small quantities (Sprung et al., 2000; Chapters 7 and 8). Thus, the only 

way in which spent IER material released from a Type B cask could result in a radiation dose to 

a member of the public is if the material could be dispersed from damaged cask seals as very 

small, aerosol-sized particles. Larger particles would be too large to escape through the seals. 

From among the six alternatives, the only spent IERs that could potentially be released through 

damaged Type B cask seals as aerosolized particles could be those that are thermally 

processed (blended or volume-reduced) and transported to a waste disposal site in Alternatives 

1B, 4A, and 4B. In Alternative 1B, the processed (blended) resins would be Class A LLRW 

when shipped for disposal, thus not shipped in a Type B cask; however, in Alternatives 4A and 

4B, the volume-reduced resins would be Class B or C waste. These thermally processed resins 

would be the only materials to be transported that would be dry (water free) form. As noted in 

Section 4.2.2, this final, thermally processed waste form appears to be granular to powdery. 

Prior to thermal processing in Alternatives 1A, 4A and 4B, in all other stages of these three 

alternatives, and in all stages of Alternatives 1A, 2 and 3, the spent IERs in transport would not 

be in aerosolizable form. Although excess water will have been removed to varying degrees 

from the spent IERs (see Section 4.1.1), it is reasonably assumed that these resins, which had 

not been thermally processed, would not readily aerosolize and, therefore, would not be 

released through the seals because they would not be sufficiently dry and, more importantly, 

they would be in relatively large, bead-like form (see Section 2.1.1). 

Note, however, that information on the physical properties of the final, thermally processed 

spent IERs in Alternatives 1B, 4A, and 4B is not available. Therefore, for this evaluation, it is 

conservatively assumed that there might be sufficiently fine material present in this final waste 

form that could aerosolize through damaged Type B cask seals. However, if thermally 

processed spent IERs do not contain any sufficiently fine, powdery material, then this evaluation 

overestimates actual impacts. 

There is no published model for the accidental release of spent IERs, or similar LLRW, in 

aerosolized form from damaged seals of a Type B cask. The only current published model of 

such releases of radioactive material from a Type B cask is that of potential release of NPP 

spent nuclear fuel (SNF) particles and of corrosion products that are on the outer surface of 

SNF elements (Sprung, et al, 2000; Chapter 7) (hereafter call the “SNF model”). This model is 

adapted for this analysis and used in association with the RADTRAN accident model to assess 

potential radiological impacts of spent IER releases. 
A-51 

It is very important to note that the radioactivity levels of the Class A, B, and C LLRW spent 

IERs are orders of magnitude lower than that of SNF materials. For example, Cesium-137 

(Cs-137) is present in SNF in concentrations on the order of 105

 Ci per fuel assembly (DOE, 

2002; Appendix A, Tables A-8 and A-9). However, the Ci content of Cs-137 in a spent IER 

shipment in a Type B cask would be about one curie or less, and the total curie content in a 

Type B cask carrying BWR Class B and C resins would be about 12 Ci or less (see Table A-21 

later in this section). 

In modeling spent IER releases using the SNF model, it is necessary to consider the following 

additional, noteworthy differences between the SNF model and the nature and behavior of 

thermally processed spent IERs, and differences in the Type B casks used for SNF and spent 

IER transport, which lead to the development of assumptions in the spent IER modeling: 

 Pressure differentials: Sealed Type B casks used for SNF transport have a naturally 

slightly higher internal pressure than ambient atmospheric pressure (due to the elevated 

temperatures of SNF over ambient temperatures), so that if breached, particles would be 

driven out of the casks by the pressure differential. However, in the case of the spent 

IERs, the internal pressures in the Type B transportation casks are expected to be about 

the same as the ambient atmospheric pressure, so that there would be no internal force 

within the casks that would drive out the resin particles. Thus, smaller amounts of spent 

IERs would be released through damaged cask seals. 

 Particle sizes: Studies of SNF have established a range of particle sizes for spent fuel 

and for the particulate corrosion products that are on the surface of spent fuel rods 

(Einziger, 2007; Einziger and Beyer, 2007; Hanson et al., 2008). These particles can be 

released through a breach in the seals with only a small pressure differential (Einziger, 

2007). However, the particle size range for thermally processed spent IERs is not 

available. It is assumed for this analysis that the particle sizes of these IERs are similar 

to those of SNF and associated corrosion products. 

 Gaps in cask seals: Sprung et al. (2000) studied the gaps in SNF cask seals that result 

from very severe accidents. However, no such documentation exists for the CNS8-120B 

Type B casks used for Class B and C spent IER transport. It is assumed for this 

analysis that the behavior of the cask seals in a CNS8-120B is similar to that of SNF 

casks. 

 Gaseous radionuclides: While radionuclides in the gas phase are present in SNF, in the 

process spent IER material they would have been released during high temperature 

thermal processing and, therefore, would not be present in the shipping casks. 

Accidents differ in the amount of stress on the cask and in the amount of material that could be 

released. Following the practice first used by the NRC in NUREG-0170, “Final Environmental 

Impact Statement for the Transportation of Radioactive Material by Air and Other Modes” (NRC, 

1977), and used subsequently in other environmental impact assessments and studies of this 

type (Fischer et al., 1987; Sprung et al., 2000; DOE, 2002, Appendix J), six different types of 
A-52 

accidents, of varying severity and a range of release fractions, are postulated in this analysis. 

The release fractions (i.e., the fraction of total radioactivity in the cask released for that 

particular accident scenario) associated with these accident scenarios are intended to include 

most of the extremely severe transportation-related accidents possible (DOE, 2002; 

Appendix J). Table A-20 lists these accident scenarios and their associated conditional 

probabilities (i.e., the probabilities of particular accident scenarios in the event of an accident) 

and release fractions for the SNF corrosion products and spent fuel particles. Note that all of 

the release fractions are very low, indicating that extremely small of amounts of the cask 

contents would be released to the environment. 

Table A-20 The Six Accident Scenarios and 

Associated Conditional Probabilities and Release Fractions 

SCENARIO DESCRIPTION SCENARIO 

INDEX 

APPROXIMATE 

CONDITIONAL 

PROBABILITYa

FRACTION OF 

Ci INVENTORY RELEASED 

Corrosion 

Product Particles

Spent Fuel 

Particles c 

No releaseb 1 0.9999 0.00 0.00 

Low-speed impact (less than 90 

mph) into hard target 2 6.1E-05 1.36E-03 1.02E-07 

High-speed impact (greater than 90 

mph) into hard target 3 5.9E-06 2.52E-03 6.71E-08 

Truck fire exposing the cask 4 5E-07 1.83E-03 3.37E-07 

Truck fire exposing the cask with 

low-speed impact into hard target 5 7.5E-08 3.16E-03 3.77E-06 

Truck fire exposing the cask with 

high-speed impact into hard target 6 3E-10 3.17E-03 5.01E-06 

 Source: Sprung, 2007; Chapter 7. 

 a The conditional probability is the probability of the particular accident scenario in the event of an accident. 

 b This scenario, which is analyzed in Section A.3.3.2.1 above, is included to provide a complete accident scenario 

picture, and to show the most likely accident scenario in relation to the other accident scenarios. It also reinforces that 

in 99.99% of Type B cask accidents, no radioactive inventory is released. 

 c The release fractions for spent fuel particles are not included in the analysis because they are three or more orders 

of magnitude less than the release fractions for corrosion product particles, and therefore would not affect the 

analysis results. 

In this evaluation, the RADTRAN accident analysis is conducted only for the most severe 

accident scenario—Scenario Index 6: “Truck fire exposing the cask with high-speed impact into 

hard target”—because that is the scenario with the highest release fraction of the six 

(3.17 × 10-3) and, therefore, would yield the most conservative impact analysis results. The 

data in Table A-20 are some of the user defined input parameters to the RADTRAN accident 

analysis. Other input parameters to RADTRAN for radiation dose calculation from a 

transportation accident involving a Type B (CNS8-120B) cask, which are usually defined by the 
A-53 

analyst, are identified and discussed below. These input parameters are based on some 

assumptions because the radionuclide inventory of each individual cask of thermally processed 

spent IERs is not precisely known, the behavior of the processed spent IER material under 

accident conditions has not been studied, and a specific location of the modeled accident is not 

defined for the present generic, non-location specific evaluation. 

Note also that the accident is not specifically analyzed for each of the alternatives because the 

only difference between the alternatives is the number of shipments. In fact, the severe 

accidents listed in Table A-20 are unlikely to occur at all because the probabilities of their 

occurrence are extremely low (less than one in a million in most cases). Thus, such accidents 

are highly unlikely to occur more than once for any alternative. Further, for reasons discussed 

above, the Type B cask accident scenario analyzed would apply only to Alternatives 1B, 4A, 

and 4B. However, the release is analyzed in this appendix only for the processed resins from 

Alternatives 4A and 4B because only these alternatives include higher activity Class B or C 

spent IERs that would be in a dry (water free), aerosolizable form as a result of thermal 

processing and could be released through the cask seals and dispersed in a severe accident. 

The RADTRAN model input for this analysis is derived from the RADCAT 3.0 User Guide 

(Weiner et al., 2009) and other sources (Sprung et al., 2000 (Chapter 7); DOE, 2002 (Chapter 6 

and Appendix J)). The input parameter values are for the release of particulate corrosion 

products from an SNF Type B cask. The additional RADTRAN inputs specific to this calculation 

are:

 Release of material at ground level 

 U.S. average meteorology (from which to calculate dispersion): Pasquill stability D, 4.7 

meters/second (m/sec) wind speed 

 Accident location in urban area (with population density 2500 persons/km2

)

20 

 Distance of maximally exposed individual (MEI) from truck: 30 m (from Table A-5) 

 Aerosol fraction: 1 (i.e., all particles released into the environment are aerosolized) 

 Respirable fraction21 of aerosolized particles: 0.0522

 Particle deposition velocity: 0.01 m/sec.23

 

20These parameters are conservative because the largest impacts from the postulated accidents would occur in 

urban areas where population densities are the greatest. Also, the selected population density is near the top of the 

range of the urban population densities along the representative transportation routes discussed in Section A.3.2.2 

(see Table A-7). In addition, the population density is assumed to exist under the entire plume, from the location of 

the accident out to 120 km (about 75 miles). 

21 Respirable fraction is the fraction of the aerosol that receptors would inhale all the way into their lungs, on average. 

22 Based on RADTRAN model constraint. 

23 Based on RADTRAN model constraint. 
A-54 

In an average year, 17,760 curies of spent IERS are generated from BWRs and 9,256 curies of 

spent IERs are generated from PWRs (from EPRI, 2007, Table 6-12). Because no data are 

available to determine what fraction of these curies would be shipped in a Type A or Type B 

cask, it was conservatively assumed for the analysis in this section that all of these curies are 

shipped in Type B packages. This is conservative because some fraction of these curies is 

lower activity and could be shipped in Type A casks. 

In the calculation, the number of annual BWR or PWR Type B shipments is first determined by 

dividing the volume of Class B plus Class C spent IERs (from Table 2 of Section 2.3.1) by the 

volume of one Type B cask. The curies per Type B shipment for PWRs and BWRs is then 

determined by dividing the annual curies of spent IERs (17,760 curies from BWRs and 9,256 

curies from PWRs) by the calculated number of annual BWR or PWR Type B shipments. 

The number of BWR or PWR Type B shipments and curies per shipment is calculated as 

follows: 

# of BWR Type B Shipments: ଵଵହ	௠య஼௟௔௦௦	஻	ூாோ௦ା଻	௠య஼௟௔௦௦	஼	ூாோ௦

ݏݐ݉݁݊݌݄ܵ݅	ܤ	݁݌ݕܶ	ܹܴܤ	38 ൎ ௞௦௣௘	஻	஼௔௬்௣௘௥	య଻௠ଵ.ଷ

# of PWR Type B Shipments: ଶ଴ସ	௠య஼௟௔௦௦	஻	ூாோ௦ାଶ଻	௠య஼௟௔௦௦	஼	ூாோ௦

ଷ.ଵ଻௠య௣௘௥	்௬௣௘	஻	஼௔௦௞ ൎ 73	ܹܴܲ	ܶ݌ݕ݁	ܤ	݄ܵ݅݌݉݁݊ݏݐ

BWR Type B Curie Content per Shipment: 

ݏݎ݋ݐܴ݁ܽܿ	ܹܴܤ	݈݈ܽ	ݎ݋݂	ݎ݁ܽݕ	ݎ݁݌	ݏ݅݁ݎݑܿ	݈ܽݐ݋ܶ	17,600

ݐ݉݁݊݌݄ܵ݅	ܤ	݁݌ݕܶ	ܹܴܤ	ݎ݁݌	݅ܥ	467.4	 ൌ ݏݐ݉݁݊݌݄ܵ݅	ܤ	݁݌ݕܶ	ܹܴܤ	38

PWR Type B Curie Content per Shipment: 

ݏݎ݋ݐܴ݁ܽܿ	ܹܴܲ	݈݈ܽ	ݎ݋݂	ݎ݁ܽݕ	ݎ݁݌	ݏ݅݁ݎݑܿ	݈ܽݐ݋ܶ	9,256

ݐ݉݁݊݌݄ܵ݅	ܤ	݁݌ݕܶ	ܹܴܲ	ݎ݁݌	݅ܥ	127	 ൌ ݏݐ݉݁݊݌݄ܵ݅	ܤ	݁݌ݕܶ	ܹܴܲ	73

The fractions of total curies represented by each radionuclide (from Table A-18, columns “BWR 

Fraction” and “PWR Fraction”) are multiplied by the BWR and PWR curies per shipment, then 

corrected for the absence of tritium (H-3) and C-14 in the shipments.24 The total BWR and PWR 

curies per Type B shipment are then 466 Ci and 126 Ci, respectively. The curie inventories are 

shown in Table A-21. These curie amounts are used in the accident analysis. 

 

24 Tritium and C-14 would have been driven off as gases during thermal processing in Alternatives 4A and 4B. 
A-55 

Table A-21 Calculated Curie Inventories of a 

Single BWR and Single PWR Type B (CNS 8-210B) Cask Shipment 

RADIONUCLIDEa BWR CURIES PWR CURIES 

Cr-51 3.50 0.0401 

Mn-54 32.4 3.19 

Fe-55 284 20.5 

Co-57 7.50E-03 0.349 

Co-58 2.66 17.0 

Fe-59 0.521 0.0162 

Ni-59 0.212 0.159 

Co-60 111 11.6 

Ni-63 4.29 40.8 

Zn-65 14.3 .0149 

Sr-90 0.163 0.0877 

Zr-95 0.0989 0.0378 

Nb-94 1.70E-05 1.79E-04 

Tc-99 0.0576 0.0321 

Ag-110m 0 0 

Sb-125 0.30 0.0368 

Cs-134 0.18 0.892 

Cs-137 1.11 11.7 

Ce-144 10.2 18.8 

Pu-238 0.813 0.274 

Pu-239/240 0 1.71E-06 

Pu-241 1.82E-03 7.08E-04 

Am-241 3.0E-03 2.55E-04 

Cm-242 0.0803 0.0327 

Cm-243 2.60E-03 4.23E-04 

Cm-244 1.23E-03 3.66E-04 

Total 466 126 a H-3 and C-14 would be present in the spent IER mixture as water and 

CO2 and would therefore not be present in the processed material. 

The results (consequences) of the analysis of the modeled release for the “Truck fire exposing 

the cask with high-speed impact into hard target” accident scenario are shown in Table A-22. 

As is evident from the low MEI and collective (population) dose and LCF percentages of 

background and 2010 estimated U.S. cancer fatalities, respectively, a release and subsequent 

dispersion of spent IER material as a result of a transportation accident involving a Type B cask 

would result in a SMALL impact. 

 
A-56 

Table A-22 Consequences of Dispersion of Spent IERs from Accidental Release from a 

Type B Cask for Accident Scenario Index 6 from Table A-20 

MEASURES OF POTENTIAL RADIOLOGICAL IMPACTS 

REACTOR TYPE 

BWR PWR 

MEI Dose (mSv) 0.60 0.20 

MEI Dose as % of U.S. Annual Background 19% 6.4% 

MEI LCF 3.5E-05 1.2E-05

MEI LCF as % of 2010 Estimated U.S. Cancer Fatalities 6E-09% 2E-09% 

Collective (Population) Dose (person-mSv) 19.9 6.16 

Collective Dose as % of U.S. Annual Background 0.25% 0.079% 

Collective LCF 1.2E-03 3.6E-04 

Collective LCF as % of 2010 Estimated U.S. Cancer Fatalities 2E-07% 7E-09% 

A.4 References 

(American Cancer Society, 2010) “Cancer Facts and Figures 2010”, American Cancer Society, 

Atlanta, GA. (Data used in this report was taken from table titled, “Estimated Deaths for 

Selected Cancer Sites by State, U.S., 2010.) 

(DOE, 2002) U.S. Department of Energy. “Environmental Impact Statement for a Geologic 

Repository for the Disposal of Spent Nuclear Fuel and High-Level Radioactive Waste at Yucca 

Mountain, Nye County, Nevada.” DOE/EIS-0250F. Summary, Volumes I and II. Office of Civilian 

Radioactive Waste Management, Washington, DC. 

(Einziger, 2007) Einziger, R.E. “Source Terms for Spent fuel Transportation and Storage Cask 

Evaluation.” Proceedings of the 15th International Symposium on the Packaging and 

Transportation of Radioactive Materials. PATRAM 2007, Miami, FL. 

(Einziger and Beyer, 2007) Einziger, R.E. and C. Beyer. “Effect of High-Burnup Fuel on Source 

Term in Cask Accidents.” Nuclear Technology 199: 134-140. Washington, DC. 

(EnergySolutions, 2010a) “Cask Book for Model 8-120B USA/9168/B(U)” Rev. 33. Energy 

Solutions, Columbia, SC. 

(EnergySolutions, 2010b) “Cask Book for Model 14/210 & 14-215 USA/9168/B(U)” Rev. 18. 

Energy Solutions, Columbia, SC. 
A-57 

(EPRI, 2007) Electric Power Research Institute. “An Evaluation of Alternative Classification 

Methods for Routine Low-Level Waste from the Nuclear Power Industry.” EPRI Report 1016120. 

Charlotte, NC. 

(FHWA, 2012) “Highway Statistics 2010”, Federal Highway Administration, Washington, DC. 

(Fischer et al., 1987) Fischer, L.E., Chou, C.K., Gerhard, M.A., Kimura, C.Y., Martin, R.W., 

Mensing, R.W., Mount, M.E., and M.C. Witte. “Shipping Container Response to Severe Highway 

and Railway Accident Conditions.” NUREG/CR-4829, UCID-20733. Prepared by Lawrence 

Livermore National Laboratory for the U.S. Nuclear Regulatory Commission, Division of Reactor 

System Safety, Office of Nuclear Regulatory Research. ADAMS Accession Nos. ML070810403 

(Volume 1) and ML070810404 (Volume 2). 

(Griego et al., 1996) Griego, N.R., Smith, J.D., and K.S Neuhauser. “Investigation of RADTRAN 

Stop Model Input Parameters for Truck Stops.” SAND96-0714C. Sandia National Laboratories, 

Albuquerque, NM. 

(Hanson, et al, 2008) Hanson, B.D., Daniel, R.C., Casella, A.M., Wittman, R.S., Wu, W., 

MacFarlan, P.J., and P.J. Shimskey. “Fuel-In-Air FY07 Summary Report Rev. 1.” PNNL-17275. 

Pacific Northwest National Laboratory, Richland, WA. 

(Herness, 2012a) Herness, Sarah. “NRC Decision on New Class B C Casks Delayed Until 

March.” RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. Vol.5, No. 5. 

p.4. February 3. 

(IAEA, 2002) International Atomic Energy Agency. “Advisory Material for the IAEA Regulations 

for the Safe Transport of Radioactive Materials.” IAEA Safety Standards Series TS-G-1.1. 

Vienna, Austria. 

(ISCORS, 2002) Interagency Steering Committee on Radiation Standards. “Final Report: A 

Method for Estimating Radiation Risk from Total Effective Dose Equivalent (TEDE).” ISCORS 

Technical Report No. 1. US DOE Office of Environmental Policy and Guidance, Washington, 

DC. 

(Johnson and Michelhaugh, 2003) Johnson, P.E. and R.D. Michelhaugh. “Transportation 

Routing Analysis Geographic Information System (TRAGIS) User Manual.” ORNL/NTRC-2006, 

Oak Ridge National Laboratory, Processing. 

(Johnson, 2011) Email from P.E. Johnson to Ruth Weiner dated November 1, 2011. “Subject: 

TRAGIS Statement.” ADAMS Accession No. ML113130173. 

(Magette, 2011) Email from Thomas Magette to James Kennedy (NRC) dated October 11, 

2011. “Subject: Barnwell Resins.” ADAMS Accession No. ML112850813. 
A-58 

(NCRP, 2009) National Council on Radiation Protection and Measurement “Ionizing Radiation 

Exposure of the Population of the United States.” Report No. 160, NCRP Publications, 

Bethesda, MD. 

(Neuhauser et al., 2000) Neuhauser, K.S., Kanipe, F.L., and R.F. Weiner. “RADTRAN 5 

Technical Manual.” SAND2000-1256. Sandia National Laboratories, Albuquerque, NM. 

(NRC, 1977) U.S. Nuclear Regulatory Commission. “Final Environmental Impact Statement for 

the Transportation of Radioactive Material by Air and Other Modes, Volumes I and II.” NUREG0170. December. ADAMS Accession Nos. ML022590265, ML022590348, ML022590370, 

ML022590467, and ML022590506. 

(NRC, 2012) U.S. Nuclear Regulatory Commission. “Spent Fuel Transportation Risk 

Assessment.” NUREG-2125. Draft Report. May. ADAMS Accession No. ML12125A218. 

(Purolite®, 2011) The Purolite Company. “Nuclear Grade Ion Exchange Resins for Power 

Generation.” Purolite® Product NRW Bulletin 19012010. 150 Monument Road, Bala Cynwyd, 

Pennsylvania 19004. 

(Shleien et al., 1998) Shleien, B., Slaback, L.S., and B.K. Birky. “Handbook of Health Physics 

and Radiological Health, Third Edition.” Williams and Wilkins, Baltimore, MD. 

(Sprung et al., 2000) Sprung, J.L., Ammerman, D.J., Breivik, N.L., Dukart, R.J., Kanipe, F.L., 

Koski, J.A., Mills, G.S., Neuhauser, K.S., Radloff, H.D., Weiner, R.F., and H.R. Yoshimura. 

“Reexamination of Spent Fuel Shipment Risk Estimates, Volumes 1 and 2.” NUREG/CR-6672, 

SAND2000-0234. Prepared by Sandia National Laboratories for the U.S. Nuclear Regulatory 

Commission, Spent Fuel Project Office, Office of Nuclear Material Safety and Safeguards. 

(Steinman et al., 2002) Steinman, R.L., R.F. Weiner, and K. Kearfott. “Comparison of Transient 

Dose Model Predictions and Experimental Measurements.” Health Physics, Vol. 83, p. 504, et 

seq. 

(USDOT, 1995). U.S. Department of Transportation. “Comprehensive Truck Size and Weight 

Study.” Research and Innovative Technology Administration (RITA). 

(USDOT, 2010) U.S. Department of Transportation. “State Transportation Statistics 2010.” 

Bureau of Transportation Statistics, Washington, DC. 

(USDOT, 2011) U.S. Department of Transportation. “National Transportation Statistics 2011.” 

Bureau of Transportation Statistics. Washington, DC. 

(Weiner et al., 2009) Weiner, R.F., Dennis, M.L., Hinojosa, D., Heames, T.J., Penisten, J.J., 

Marincel, M.K., and D.M. Osborn. “RADCAT 3.0 User Guide.” SAND2009-5129P. Sandia 

National Laboratories, Albuquerque, NM. 
B-1 

APPENDIX B 

NRC RESPONSE TO PUBLIC COMMENTS ON THE 

DRAFT COMPARATIVE ENVIRONMENTAL EVALUATION OF ALTERNATIVES FOR 

HANDLING LOW-LEVEL RADIOACTIVE WASTE SPENT ION EXCHANGE RESINS 

FROM COMMERCIAL NUCLEAR POWER PLANTS 
B-2 

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B-3 

B.1 Introduction 

On September 20, 2012, the U.S. Nuclear Regulatory Commission (NRC) staff published a 

notice in the Federal Register (77 FR 58416) requesting public comments on the “Draft 

Comparative Environmental Evaluation of Alternatives for Handling Low-Level Radioactive 

Waste Spent Ion Exchange Resins from Commercial Nuclear Power Plants” (Draft Report) 

(NRC, 2012a). The public comment period was 120 days, ending on January 18, 2013. The 

NRC received comments from six commenters in response to the notice, including one 

governmental agency, four nongovernmental organizations, and one member of the general 

public, for a total of approximately 65 individual comments. This appendix presents all of the 

comments received and the staff’s response to each of those comments. The Final Report has 

been prepared in consideration of all the comments received, and includes revisions to the Draft 

Report based on some of these comments. Where applicable, report revisions are identified in 

the comment responses. 

Table B-1 lists all of the commenters on the Draft Report in order of NRC-assigned Commenter 

Number, their name, their affiliation, and the Accession Number of the document in the NRC’s 

Agencywide Documents Access and Management System (ADAMS) in which their comments 

appear. The NRC staff also assigned a unique comment number to each individual comment. 

The comment numbers consist of two parts. The first part identifies the commenter (i.e., the 

Commenter Number in Table B-1). The second part identifies each individual comment to 

which the staff provides a response in Section B.2 below. For example, the first comment of 

Commenter Number 5 is Comment 5-01; the second comment is Comment 5-02; etc. 

Table B-1 Draft Report Commenter Identification 

COMMENTER 

NUMBER 

COMMENTER NAME AFFILIATION 

COMMENT 

DOCUMENT 

ADAMS ACCESSION 

NUMBER 

1 Kenneth Gunther Member of the Public ML12324A274 

2 J. Scott Kirk Waste Control Specialists LLC ML13017A406 

3 Rusty Lundberg Utah Department of Environmental 

Quality, Division of Radiation Control ML13025A354 

4 Joseph DiCamillo Studsvik, Inc. ML13025A355 

5 Thomas Magette EnergySolutions ML13025A356 

6 Michael Dooley Phoenix Energy of Nevada, LLC ML13092A456 

B.2 Public Comments on the Draft Report and NRC Responses 

The following are all of the comments received by the NRC on the Draft Report and the NRC 

staff’s responses to those comments. All of the comments are addressed in individual 

subsections below, in order of Commenter Number in Table B-1.
B-4 

B.2.1 Commenter 1—Kenneth Gunter (Member of the Public) 

Comment 1-01: Nuclear waste disposal is no longer manageable. We must bring this 

expensive and disastrous industry to a rapid close. 

NRC Response: The NRC staff acknowledges this comment and appreciates the public 

participation. However, this comment is outside the scope of the Draft Report because it does 

not directly pertain to the comparative environmental evaluation of the six alternatives identified 

in the report for handling low-level radioactive waste (LLRW) spent ion exchange resins (IERs) 

from commercial nuclear power plants (NPPs). Because this comment is out of scope, no 

revisions are being incorporated into the report as a result of this comment. 

B.2.2 Commenter 2—J. Scott Kirk (Waste Control Specialists LLC (WCS)) 

Summary Comments 

Comment 2-01: There are significant differences in the environmental impacts presented by 

the various alternatives (for example, a doubling of risk associated with transportation). The 

distinction between impacts is too broad to support a useful comparison of alternatives if wide 

ranges of risk and impacts are all considered to be small, even if the entire range is considered 

to be acceptable. 

NRC Response: As discussed in Section 3.2 of the Draft Report, the environmental analysis is 

largely qualitative, which the staff believes is necessary and appropriate for the comparative 

environmental evaluation of the six generic, non-location-specific alternatives. This is because, 

for the most part, a reasonable set of quantitative evaluation factors could not feasibly be 

established for such broad, generalized alternatives. The staff considers this to be an 

acceptable limitation to the evaluation. Therefore, in Table 5 and Section 5.2 of the Draft 

Report, the staff endeavored to compare the alternatives to the extent possible within the 

constraints of this qualitative analysis. An exception is that the assessment of potential 

transportation impacts was initially conducted quantitatively, because quantifiable factors such 

as estimated numbers of shipments of full and empty shipping casks and representative 

transportation routes on which to base this analysis could be realistically projected. Thus, in the 

case of potential transportation impacts, a quantitative comparison of impacts of the alternatives 

was possible and therefore conducted. 

Further, the staff assessed potential environmental impacts using its established standard of 

significance that is based on the standards of the Council on Environmental Quality’s (CEQ’s) 

regulations in Title 40 of the Code of Federal Regulations (40 CFR) 1508.27. Using this 

approach, each environmental impact was assigned a significance level of SMALL, 

MODERATE, or LARGE (NRC, 2003). These significance levels are defined in Section 3.2 of 

the report and repeated below: 

 SMALL. The environmental effects are not detectable or are so minor that they would 

neither destabilize nor noticeably alter any important attribute of the resource. 
B-5 

 MODERATE. The environmental effects are sufficient to noticeably alter, but not 

destabilize important attributes of the resource. 

 LARGE. The environmental effects are clearly noticeable and are sufficient to destabilize 

important attributes of the resource. 

As the commenter correctly notes, there are differences in the environmental impacts presented 

by the various alternatives. For example, the total miles spent IERs are transported under one 

alternative might be double the total miles spent IERs are transported under another alternative, 

thus resulting in a doubling of the magnitude of certain potential environmental impacts. 

However, if the environmental effects of such differences were determined by the staff to not be 

detectable or so minor that they would neither destabilize nor noticeably alter any important 

attribute of the resource, as was the case for nearly all the qualitative and quantitative impacts 

assessed in the evaluation, then the impacts were appropriately assigned a significance level of 

SMALL. Under these circumstances, the differences between the impacts of the various 

alternatives were considered small. Accordingly, no revisions were made to the report as a 

result of this comment. 

Comment 2-02: The evaluation assumes that the current volume of resin shipments from 

nuclear power plants comprise the entire universe of shipments in downblending/processing 

alternatives. In fact, significantly larger numbers of shipments of Class A material are likely to 

be required from non-power plant facilities to provide sufficient low-activity feedstock to 

accomplish the downblending. The impacts of the additional shipments of these materials to a 

central processing facility are not addressed in the evaluation. 

NRC Response: The scope of the evaluation was established in Option 2 in the NRC staff’s 

paper for the Commission, SECY-10-0043, “Blending of Low-Level Radioactive Waste,” April 7, 

2010 (NRC, 2010a). Option 2 stated, “As part of the NEPA analysis for this rulemaking,1

disposal of blended ion exchange resins from a central processing facility would be compared 

to direct disposal of the resins, onsite storage of certain wastes when disposal is not possible 

and further volume reduction of the Class B and C concentration resins (emphasis added).” 

Option 2 was approved by the Commission on October 13, 2010, in Staff Requirements 

Memorandum SRM-SECY-10-0043, “Staff Requirements – SECY-10-0043 - Blending of LowLevel Radioactive Waste” (NRC, 2010b). As such, the Commission directed the staff to conduct 

a comparative environmental evaluation of a specified set of alternatives for managing spent 

IERs. Furthermore, the staff’s intent in SECY-10-0043, Option 2, was that the comparative 

environmental evaluation would be conducted for alternatives for managing spent IERs from 

NPPs, including blending. As discussed in the Background section of SECY-10-0043 and the 

Enclosure to SECY-10-0043 (NRC, 2010c), this type of waste was being considered for 

blending because it can be blended into a relatively uniform mixture; these resins account for 

                                                            

1

 NRC Staff Note: The rulemaking referenced here is the 10 CFR Part 61 rulemaking that the Commission directed 

the staff to conduct in its March 18, 2009, Staff Requirements Memorandum SRM-SECY-08-0147, “Staff 

Requirements – SECY-08-0147 – Response to Commission Order CLI-05-20 Regarding Depleted Uranium” (NRC, 

2009). 
B-6 

about half of the volume of Class B and C waste generated each year; and these resins were 

the focus of a waste processor’s expanded LLRW blending at its facility in the State of 

Tennessee. Additionally, the Commission did not direct the staff to study the technical or 

economic feasibility of implementing any of the alternatives. Thus, specific to the comment, the 

evaluation did not include a determination of whether significantly larger numbers of shipments 

of Class A material from non-power plant facilities would be required to accomplish the blending 

of spent IERs from NPPs. For the above reasons, the impacts of additional shipments of 

materials other than spent IERs from commercial NPPs are not addressed in the evaluation and 

no revision to the report was made as a result of this comment. 

Comment 2-03: The evaluation equates alternatives with inherently low risk with more complex 

alternatives with significantly greater risk of environmental impact, presuming that the impacts 

are mitigated by administrative and engineering controls. There is no apparent consideration for 

the impact of a failure in the administrative or engineering controls in complex radioactive waste 

treatment systems. This seems both inadequate and incongruous with the treatment of failures 

of administrative and engineering controls during transportation, which the evaluation does 

attempt to address.

NRC Response: Taking credit for the mitigation of potential environmental impacts, by such 

factors as administrative and engineering controls, is a standard and accepted practice in 

environmental evaluations performed by the NRC and other Federal agencies. These 

evaluations reasonably assume that if any mitigation measures were to fail, appropriate 

corrective measures would be taken to avoid or minimize adverse environmental impacts. 

Further, as discussed in Section 3.3 of the report, the evaluation did not consider accidents and 

other off-normal conditions, which could include the potential failure of administrative and 

engineering controls, because it is not feasible to develop accident and off-normal event 

scenarios for generic, non-location-specific alternatives. Instead, the evaluation assumed that 

analyses of credible accident scenarios and other off-normal credible events would have 

already been conducted and reviewed by Federal and State regulatory agencies for licensed 

and permitted facilities, and that appropriate controls and mitigation measures (e.g., fire and 

radiation protection systems) would have been considered when evaluating the consequences 

associated with these events. On the other hand, the evaluation did address the potential 

impacts of transportation accidents because they are not unique to any location or alternative, 

and could be addressed generically using factors such as estimated numbers of shipments and 

hypothetical transportation routes. Accordingly, no revisions were made as a result of this 

comment. 

Comment 2-04: Similarly, the report does not consider the additional significant worker doses 

that would occur due to the double handling and treatment of the waste in the processing 

alternatives when compared to direct disposal. Additional occupational dose, controlled by the 

processing licensee to acceptable limits, is additional dose nonetheless. This additional worker 

dose does not comply with ALARA2

 principles and should be considered in the impact 

                                                            

2

 NRC Staff Note: ALARA = as low as reasonably achievable. 
B-7 

assessment, even if the expectation is that the dose to any given individual will be within 

regulatory limits. 

NRC Response: In Section 5.1.2.5, Table 5, and Section 5.2.5, the report considered that 

worker activities for handling, processing, storage, and disposal of spent IERs in all six 

alternatives must comply with NRC, Agreement State, Occupational Safety and Health 

Administration, ALARA, and other worker protection requirements and standard operating 

procedures, as applicable, thus limiting any radiological occupational exposures to acceptable 

levels for all the alternatives evaluated. The NRC staff recognizes that there would be 

differences in occupational doses between the various alternatives; however, the fact that the 

doses would be within acceptable levels resulted in the staff’s finding that the potential 

occupational health impacts would be SMALL in all cases. 

Furthermore, the staff does not agree with the commenter’s assertion that ALARA principles are 

violated because some alternatives have higher worker doses than other alternatives. According 

to the NRC’s definition in 10 CFR 20.1003, “ALARA...means making every reasonable effort to 

maintain exposures to radiation as far below the dose limits...as is practical consistent with the 

purpose for which the licensed activity is undertaken, taking into account the state of 

technology, the economics of improvements in relation to state of technology, the economics of 

improvements in relation to benefits to the public health and safety, and other societal and 

socioeconomic considerations, and in relation to utilization of nuclear energy and licensed 

materials in the public interest (emphasis added).” Accordingly, the staff believes that ALARA 

principles apply individually to licensed activities and would not appropriately be used to 

compare the worker doses among different licensed activities. No revisions were made to the 

report as a result of this comment. 

Comment 2-05: The evaluation understates transportation impacts with an assertion that Class 

A resin shipments will occur in Type A casks. In fact, significant amounts of Class A resin 

(particularly the low activity feedstock from non-power facilities) are unlikely to require the use of 

an NRC approved package. 

NRC Response: The commenter provided a more detailed comment about the shipping of 

Class A resins in non-NRC approved packages in Comment 2-19A below; and the NRC 

response to that aspect of Comment 2-05 is provided there. Low activity feedstock from 

non-power facilities is not addressed in the NRC’s comparative environmental evaluation for 

reasons discussed in the response to Comment 2-02 above. 

Comment 2-06: Downblending and thermal processing represent a strategy in which the 

requirements for packaging and disposal applicable to a given curie of waste are dramatically 

reduced. This reduction of standards seems certain to reduce the level of public and 

environmental protection against exposure to the radioactivity in these materials. The current 

evaluation does not address the impact of the reduced environmental protection measures. In 

order to meet its stated objectives, the evaluation must address the environmental impacts of 

diversion of thousands of curies of radioactivity from engineered disposal in robust facilities to 

alternatives featuring conventional disposal in standard Class A landfills with their 

correspondingly lower level of environmental protection. 
B-8 

NRC Response: The staff disagrees that the level of environmental protection at Class A 

landfills would be less that at Class B and C landfills. In the licensing requirements for disposal 

of radioactive waste, found in 10 CFR Part 61, the level of protection is defined by the dose 

limits, which are 25 millirem (mrem)/year for an offsite member of the public and 500 mrem/year 

for an inadvertent intruder into the disposal facility.3

 Even though some waste could be reduced 

from Class B and C concentrations to Class A concentrations as a result of blending, the level of 

protection that must be met in 10 CFR Part 61 remains the same, because the dose limits are 

the same for Class A, B and C disposal facilities. In all three cases, the environmental and 

public health impacts are SMALL (i.e., they are not more than the dose limits cited above). The 

commenter has defined “level of protection” by the controls that are used to manage the hazard 

of the waste, and the controls are commensurate with the hazard, so that the same required 

level of protection is achieved. Thus, because the Class B and C wastes have higher 

concentrations than the Class A wastes, the Class B and C wastes have more controls for 

managing risk than Class A wastes. The NRC has developed standards and guidance for 

managing Class A waste, including blended waste, to achieve the required level of protection. 

No change to the report was made as a result of this comment. 

Detailed Comments 

Comment 2-07: Executive Summary, Introduction and Purpose 

Evaluation Content: The Staff Requirements, SECY-10-0043 accepted the Option 2 

recommendation that disposal of blended ion exchange resins from a central processing facility 

would be compared to direct disposal of the resins as part of the NEPA analysis for this 

rulemaking. 

Comment: The draft Branch Technical Position (BTP) on Blending of Low Level Radioactive 

Waste provides for the blending of many waste streams in addition to ion exchange resins. The 

environmental impacts of blending a variety of waste streams may not be adequately addressed 

by consideration of ion exchange resins alone. The environmental evaluation of alternatives 

should include other waste streams, or, include a determination that the evaluation of resin 

processing and disposal effectively addresses the environmental impacts of processing other 

waste streams considered by the BTP. As an alternative, the BTP should state that blending 

only applies to resins. 

NRC Response: As discussed in the response to Comment 2-02 above, the scope of the 

evaluation was defined in Option 2 of the NRC staff’s paper for the Commission, SECY-10-0043 

(NRC, 2010a), and approved by the Commission in SRM-SECY-10-0043 (NRC, 2010b); and 

that scope is specific to blending “ion exchange resins.” Although the NRC is not legally 

obligated to prepare an environmental impact evaluation, the Commission directed the NRC 

staff to prepare an analysis of the environmental impacts of resin blending. The Commission, 

however, did not direct the staff to evaluate the possible environmental impacts of blending 

other materials. 

                                                            

3 NRC Staff Note: 500 millirem/year is not contained in the regulation, but is the basis for the waste classification 

tables in 10 CFR 61.55. 
B-9 

The commenter is correct in stating that the 1995 BTP is being revised, and that this BTP, as 

well as earlier versions, allow blending of other physically similar wastes that are amenable to 

mixing to achieve relatively uniform radionuclide concentrations. However, as measured in 

terms of volume, and as measured in terms of activity, the staff believes that the blending of 

spent IERs from commercial NPPs is the most significant blending operation that could occur in 

the U.S. No change was made as a result of this comment.

Comment 2-08: Page viii, 3rd full paragraph (and page 103, 1st full paragraph, page 2-4 last 

paragraph) 

Evaluation Content: [WCS] recently received approval to accept LLRW from individual 

generators in additional states, but only on a case-by-case basis and subject to annual activity 

and volume limits. As a result, all U.S. commercial NPPs (which currently include 104 operating 

nuclear reactors at 65 NPP locations) can dispose of their Class A LLRW spent IERs, but more 

than 40 of the 65 operating NPPs have no access, or only limited access, to a disposal facility 

for their Class B and C spent IERs.

Comment: The evaluation presents the straightforward compact import petition process as 

unduly restrictive. In particular, it is not correct to state that any of the US NPPs have "no 

access" to Class B and C disposal. No petition to import Class B and C resin to WCS has ever 

been denied, so the term "limited access" also seems a misnomer. Finally, the curie and 

volume limits on waste imports stated in the report were initially established by the Texas 

legislation before the WCS facility opened and began accepting waste. Based on the results of 

the ongoing TCEQ4

 updated capacity report, these limits may be increased. We do not agree 

with the characterization of our license limits as restricting the availability of direct Class B and 

C resin disposal at the pace at which it is likely to occur. 

NRC Response: The NRC acknowledges that the WCS LLRW disposal facility can accept outof-compact Class A, B, and C LLRW (Herness, 2013). Accordingly, the text in the Executive 

Summary and Sections 1 and 2.2 has been revised to recognize that WCS can accept out-ofcompact Class A, B, and C LLRW for disposal (subject to annual limits and case-by-case import 

petition approval by the Texas Compact), and that all NPPs potentially have access to a 

disposal facility for their Class B and C spent IERs at this time. However, as also discussed in 

the revised text of the report, the scope of the evaluation was defined at a time when, in fact, the 

majority of NPPs had no access, or limited access, to Class B and C disposal. Therefore, the 

Final Report will continue to address all six alternatives in the same manner as in the Draft 

Report. 

Comment 2-09: Page ix, footnote 1 (and page 1-3, 1st partial paragraph) 

Evaluation Content: Throughout this report, spent IERs that are not yet being shipped for 

disposal are referred to as Class A, B, or C concentration spent IERs, rather than as Class A, B, 

or C waste. The Class A, B, and C designations are related to the hazards that the waste 

presents to an inadvertent human intruder after closure of a LLRW disposal facility, and are not 

                                                            

4

 NRC Staff Note: TCEQ = Texas Commission on Environmental Quality. 
B-10 

related to the hazards at intermediate points in handling. NRC regulations in 10 CFR 20 

Appendix G do not require LLRW to be classified until it is shipped for disposal.

Comment: The distinction between waste concentration and waste class seems unnecessary. It 

is clear, even in the Draft Evaluation's descriptions of the Alternatives 1A and 1B, that "Class A, 

B, and C spent IER LLRW” will be blended intentionally "to produce Class A waste." Admittedly, 

10 CFR Appendix G, Section Ill A, does not require that waste classification be performed prior 

to shipment to a centralized waste blending or thermal treatment facility. Nonetheless, it is 

transparent to the most casual observer that spent materials with no further use are waste. 

Further, the classification of the waste could readily be determined based on the 

characterization performed to support shipment, and it is obvious that the intent of the blending 

is to reduce the waste classification of Class B and C wastes by combination with large volumes 

of waste materials of a lesser classification. 

NRC Response: The comment is noted. However, as stated in the report, the regulations do 

not require waste to be characterized until shipped for disposal, so the characterization of spent 

IERs that are not yet being shipped for disposal as Class A, B or C concentration spent IERs is 

correct. Based on current information, the report will remain unchanged in this regard. 

Comments 2-10A, B, and C: General Content 

Evaluation Content: Radiological impacts associated with direct disposal are generally 

described as "somewhat less" than Alternatives involving long term storage or thermal 

treatment. 

Comment 2-10A: The safety and radiological impacts of direct disposal are considerably less 

than for alternatives involving blending and thermal treatment. For example, the number of 

shipments required for processing necessarily doubles (since an extra shipment to a central 

processing facility is required). Indeed, trucks on the road vary two and a half times (0.0002-

0.0005% of freight traffic, pg xiv), and public dose from truck varies by two and one third times 

(0.03 to 0.07% of US average background). The dose to workers in the alternatives involving 

thermal treatment and/or storage can be expected to be significantly higher than that for 

workers at a disposal facility where waste packages are not opened and exposure is minimal. 

The distinction between small, moderate, and large impacts is perhaps too broad to support a 

comparison of Alternatives if a demonstrated doubling of transportation risk and obvious 

occupations exposure risk remains "small''. 

NRC Response: The response to Comment 2-01 above provides the basis and justification for 

the NRC’s comparative environmental impact evaluation approach, and for the determinations 

of potential impacts to be SMALL. That response also discusses why the differences between 

the impacts of the various alternatives were considered small. However, the staff has 

considered that the characterization of certain potential environmental impacts in the evaluation 

as being “somewhat less” or “somewhat greater” than others may not be meaningful, given the 

qualitative nature of the evaluation. Therefore, the word “somewhat” has been removed 

wherever it appears in the report as a part of a descriptor of the magnitude of potential 

environmental impacts. 
B-11 

Comment 2-10B: Similarly, while a licensee would be expected to assure the safety of workers 

during the extra offloading, thermal treatment, and plant maintenance procedures that are 

required for thermal processing, the exposure to workers in a direct disposal scenario is 

significantly less. The additional occupational dose to workers in the processing alternatives is 

not considered as an additional impact, because the occupational dose is assumed to be 

controlled by the licensee. This assumption may be correct, but failure to consider the additional 

dose associated with processing does not meet ALARA principals and may not support an 

accurate comparison of the alternatives under evaluation. 

NRC Response: See response to Comment 2-04 above concerning the evaluation of worker 

doses and ALARA principles. 

Comment 2-10C: In addition, the report appears to equate alternatives with inherently low risk 

with more complex alternatives with significantly greater risks because they can be mitigated by 

administrative and engineering controls. However, the risks (particularly air quality and public 

and occupational health) associated with the bulk blending and thermal treatment of high activity 

resins present an apparent "unique risk" that should be considered as described in 40 CFR 

1508.27(b)(5). There are numerous risks inherent in the bulk processing of resins that are 

unique to that process and do not present themselves at all in a direct disposal option where 

resins are never removed from their packaging/liner. Indeed, it appears the draft report only 

addresses "significance" as defined in 40 CFR 1508.27, and does not attempt to address risk as 

it is included in the definition of "intensity" (except for transportation risk). There is no apparent 

consideration for the impact of a failure in the administrative or engineering controls in complex 

radioactive waste treatment systems. Also, the cumulative risk (40 CFR 1508.7) of repeated 

transportation events and complex and technology-intensive waste treatment do not appear to 

have been considered in the evaluation. Again, the distinction between impacts is too broad to 

support a useful comparison of alternatives if wide ranges of risk and impacts are all considered 

to be small; even if the entire range is ultimately considered to be acceptable. 

The risks of long term storage are perhaps less severe, but there are risks unique to alternatives 

featuring storage, i.e. container/liner failure in storage, exposure to workers during extended 

storage, and accidental or malevolent intrusion. These risks, however well-controlled, are still 

additional risks that are not present in less complex alternatives (e.g. direct disposal). 

NRC Response: The NRC staff’s consideration of mitigation of potential impacts using 

administrative or engineering controls and the impacts of failure of such controls is discussed in 

the response to Comment 2-03 above. The staff acknowledges that all aspects of all of the 

alternatives, including transportation, blending, thermal treatment, long-term storage, and 

disposal, have several associated inherent “unique risks.” In the report, the staff assessed these 

potential risks, or impacts, within the limitations of a qualitative evaluation of generic, nonlocation-specific alternatives, and using the NRC’s established standard of significance that is 

based on the standards of the CEQ’s regulations in 40 CFR 1508.27, as discussed in the 

response to Comment 2-01 above. As discussed in Section 3.2 of the report, this evaluation 

was conducted under the reasonable assumption that all blending, thermal treatment, long-term 

storage, and disposal activities would be conducted at licensed facilities and in compliance with 
B-12 

all applicable Federal, State, and local legal and regulatory requirements. Finally, the staff also 

acknowledges that the environmental impacts of all the alternatives could include potential 

cumulative effects. However, as also discussed in Section 3.2, cumulative impacts (as defined 

in the CEQ’s regulations in 40 CFR 1508.7) were not assessed in the evaluation because there 

is no basis here for determining the past, present, and reasonably foreseeable future actions on 

which such an analysis could be based for generic, non-location specific alternatives. 

Comment 2-11: Page 3-3, Description of Alternative 3 

Comment: Alternative 3 includes the long term, 20-year storage of IERs as being necessary 

until a Class B and C disposal facility becomes available, and states that "commercial NPPs 

could eventually have a disposal pathway for their Class B and C resins." The draft language 

should be adjusted since WCS provides this alternative today. Similarly, the description of 

Alternative 4A, and footnote #9 do not properly recognize the current availability of WCS as a 

Class B and C disposal option for commercial NPPs. 

NRC Response: As discussed in the response to Comment 2-08 above, the text in the 

Executive Summary and Sections 1 and 2.2 has been revised to recognize that WCS can 

accept out-of compact Class A, B, and C LLRW for disposal (subject to annual limits and caseby-case import petition approval by the Texas Compact), and that all NPPs potentially have 

access to a disposal facility for their Class B and C spent IERs at this time. However, as 

indicated in the response to Comment 2-02 above, “onsite storage of certain wastes when 

disposal is not possible,” as described in Alternative 3, is one of the alternatives specified for 

evaluation in Option 2 of SECY-10-0043 (NRC, 2010a). Therefore, the description of 

Alternative 3 in the report will remain unchanged. As for Alternative 4A, this report is an 

environmental evaluation of generic, non-location-specific alternatives for handling low-level 

radioactive waste spent ion exchange resins and staff believes that Alternative 4A is a valid 

generic scenario for evaluation. Accordingly, Alternative 4A has been retained for consideration 

in the evaluation, and the description of Alternative 4A and the text of footnote #9 referenced in 

the comment (footnote 13 in the Final Report) have not been changed as a result of this 

comment. 

Comment 2-12: Page 4-4, Section 4.2.1, Description of alternative 1A, Mechanical Mixing 

Comment: The NRC presumption is that compacted IERs require either hydraulic or 

mechanical agitation before they can be removed from the HICs5 or liners. Hydraulic agitation is 

the technique generally used to loosen and sluice resin materials. However, the NRC goes on 

to say that the mechanical blending of differing Class concentrations of resins would produce 

little ancillary waste because it would use small quantities of water. However, the assumption 

that mechanical blending does not use significant quantities of water does not accurately reflect 

the process. Indeed, mechanical mixing alone may not add much water, but the hydraulic 

agitation and sluicing required to remove compacted resins from their HICs/liners does generate 

large amounts of water that should not be overlooked in the environmental evaluation of 

                                                            

5

 NRC Staff Note: HIC = High Integrity Container. 
B-13 

alternative. The fact that mechanical blending has never been used on a commercial scale is 

acknowledged, making the extent of environmental impact difficult to assess. But other proven 

options, like direct disposal, introduce no water at all, and this fact should be considered 

favorably in the evaluation of alternatives. 

NRC Response: The NRC staff agrees that mechanical blending has never been used on a 

commercial scale. If mechanical blending is used on a commercial scale, the staff believes that 

facility operators would optimize their processes to minimize the generation of ancillary liquid 

wastes, and would handle any waste liquids generated in accordance with applicable regulatory 

requirements. The commenter does not provide sufficient justification to alter the description of 

Alternative 1A or the assessment of the potential impacts of this alternative in the report. 

The staff further notes that in a proven option like direct disposal, water enters or infiltrates into 

disposal cells during precipitation events, and water may also be introduced as a result of other 

natural processes or intentional dust control. However, as with all the other alternatives, the staff 

has reasonably assumed that any impacts would be minimized through appropriate mitigation 

measures. No changes were made to the report as a result of this comment. 

Comment 2-13: Page 4-6, Section 4.2.2, Description of alternative 1B, Blending with Thermal 

Processing 

Comment: The description of the ion exchange resin 'destructive distillation' process notes that 

1 million gallons of water will be needed each year to support the thermal destruction of blended 

resins. This is described as not being unusual for a small industrial facility. However, the use of 

1 million gallons of water per year to decompose highly radioactive resins seems to be 

summarily dismissed in the environmental evaluation, and seems to have no weight at all in 

comparing this complex and resource-intensive thermal destruction process to simpler 

processes which introduce no water and produce no additional wastes whatsoever (e.g. direct 

disposal). 

NRC Response: The comment highlights an important point; an individual reading the report 

may not understand the relative significance of the 1 million gallon figure. Without context, the 

use of 1 million gallons of water per year may seem to the reader like a significant impact. To 

place this in perspective, the U.S. Environmental Protection Agency (EPA) reports that, on 

average, a family of four in the U.S. can use 400 gallons of water every day (EPA, 2008). This 

means that a mere seven households of four persons each would use about 1 million gallons of 

water per year (7 four-person households x 400 gallons per day per household x 365 days per 

year ≈ 1 million gallons per year). Thus, the use of this quantity of water would, indeed, 

represent a SMALL impact. 

Regarding the commenter’s statement that direct disposal introduces no water, the introduction 

of water in the direct disposal alternative is discussed in the response to Comment 2-12 above. 
B-14 

Comments 2-14A and B: General Comment on Blending/Processing 

Comment 2-14A: The discussion of resin blending and processing presumes that HICs/liners 

containing resins do not contain other waste materials (e.g. filters and other contaminated 

objects). While some plants control and limit HIC/Iiner contents to resins alone, many view the 

HIC/Iiner as a waste container and seek to fill the volume to the extent practical with wastes that 

can be similarly characterized or profiled. The environmental evaluation fails to address two 

consequences of this likely inclusion: (1) Since these included materials cannot reasonably be 

considered feedstock for resin blending, it may not be compliant practice to ship these materials 

to a processor without designating the shipment as "waste", and, (2) The discussion of resin 

processing as a smooth running process operating on like materials of similar physical process 

seems to fail to evaluate the complications and possible environmental and dose impacts of 

encountering these materials. These complications include process interventions required to 

address the likely presence of non-resin waste items, and variation in the properties of the 

resins themselves. 

NRC Response: The comment would be accurate for wastes shipped for direct disposal. 

However, the NRC staff believes it is reasonable to assume that blending and thermal 

processing facilities would take steps to ensure that only acceptable materials are included in 

material shipments. For example, ensuring that only acceptable materials are included in 

shipments would serve to promote smooth operation of the processing facilities and prevent 

returns of unacceptable shipments. Such steps could include waste acceptance criteria (WAC) 

prohibiting non-spent IER materials and penalties for violations of the waste processor’s WAC. 

No changes were made to the report as a result of this comment. 

Comment 2-14B: Dilution with clean materials is clearly prohibited in waste management 

practice. However, blending and thermal processing generally include the addition of clean 

materials for use as stabilizing media. The environmental evaluation and other requirements or 

guidance should be clear on the limits to which stabilization with arguably diluting media is an 

acceptable practice.

NRC Response: The NRC’s revised BTP will address the blending process, and will 

recommend against the introduction of clean materials for the sole purpose of dilution. NRC 

regulations do not prohibit dilution, but NRC proposed guidance recommends constraints on it. 

For example, in Table C of the May 2012 draft revised BTP (NRC, 2012b), the NRC states that 

clean (i.e., non-radioactive) materials added to a mixture “should have a purpose other than 

reducing the waste class, such as waste stabilization or process control. Consistent with other 

provisions in this BTP, extreme measures to lower the waste classification should be avoided.” 

No changes were made to the report as a result of this comment. 

Comment 2-15: General Comment on Tariffs 

Comment: In recent years, some states (notably Iowa and Indiana) have established tariffs to 

shipments of radioactive wastes being transported through their states. These tariffs are 

generally established to fund emergency and environmental response to accidents involving 

radioactive waste, and are levied in part, based on the identification of the shipment as a waste 
B-15 

shipment (e.g. the presence of an NRC 541/542 form). The establishment of a centralized resin 

processing facility in one state may burden neighboring states with the responsibility for 

responding to the accidents involving the shipments of non-waste resin feedstock. However, 

without the revenues associated with the shipment of waste, states may not be able to mount 

the appropriate response to an environmental release. The existence of a centralized 

processing facility essentially doubles the number of radioactive materials shipments, even as 

the artificial non-waste designation thwarts states' efforts to collect revenues for transportation 

accident emergency response. 

NRC Response: The comment is noted. However, Option 2 of SECY-10-0043 (NRC, 2010a) 

included “disposal of blended ion exchange resins from a central processing facility (emphasis 

added)” as an alternative to be included in the scope of the comparative environmental 

evaluation (see response to Comment 2-02 above). It is too fine of a detail for a generic, nonlocation-specific evaluation to consider a small number of isolated, State-imposed tariffs and 

their impact on emergency responses to accidents involving environmental releases. It is 

assumed that the commenter’s reference to the “artificial non-waste designation” relates to the 

issue the commenter raised in Comment 2-09 above, in which the commenter questioned the 

need for the distinction between waste concentration and waste class. Setting aside the tariff 

issue, the NRC staff believes it is reasonable to assume for this evaluation that releases of 

radioactive materials during transportation would be appropriately handled regardless of 

whether or not the materials have been classified as waste. No changes were made to the 

report as a result of this comment. 

Comment 2-16: Section 5.1.2. Resource and Impact Area-Specific Methodologies and 

Assumptions 

Comment: The environmental evaluation is devoid of any discussion of the differing levels of 

environmental protection provided the end-state disposal options. There is no distinction made 

between the level of environmental protection provided for safe disposal of smaller quantities of 

Class B and C wastes in a robust facility specifically designed to accept those materials, and the 

relative risk of disposal in standard landfills accepting much larger quantities of Class A wastes. 

Downblending and thermal processing dramatically increases the curie content that may be 

disposed in Class A facilities with minimal protection for the environment. In contrast, Class B 

and C facilities are specifically designed with robust protections that directly address the 

disposal risks presented by the huge number of curies in these waste materials. 

Downblending and thermal processing represent a strategy in which the requirements for 

packaging and disposal applicable to a given curie of waste are effectively reduced. This 

reduction of standards seems certain to reduce the level of public and environmental protection 

against exposure. In order to meet its stated objectives, the evaluation must address the 

environmental impacts of diversion of thousands of curies of radioactivity from engineered 

disposal in robust facilities to conventional disposal in standard Class A landfills. 

NRC Response: Regarding the differing levels of protection afforded by the disposal of Class B 

and C LLRW as compared to disposal of Class A LLRW, see response to Comment 2-06 

above. In response to the general comment that “downblending” represents a strategy in which 
B-16 

the requirements for packaging applicable to a given curie of waste are effectively reduced, the 

classification of the final waste product dictates the packaging requirements that must be met 

and the NRC staff believes that compliance with the NRC radioactive materials packaging and 

transportation regulations in 10 CFR Part 71 ensures the safe transport of spent IERs of all 

classes, pre- or post-blending.

Comment 2-17: Section 5.1.2.7 Transportation Impacts 

Comment: The section states that the exposures of radiation workers (e.g. truck crews, package 

handlers, and inspectors) are not considered in the analysis because these are trained radiation 

workers. Failure to consider the additional person-rem exposure of additional personnel 

resulting from the increased number of transportation events necessary to ship to an 

intermediate processing facility seems inappropriate. Controlled or not, the involvement and 

exposure of additional personnel in roughly double the number of transportation events should 

be considered in the evaluation of alternatives as an additional impact. 

NRC Response: The complete discussion in Section 5.1.2.7 of the report states, “Note that 

exposures of ‘radiation workers’ (e.g., truck crews, package handlers, and inspectors) are not 

considered in the analysis because these workers are specially trained in, and knowledgeable 

of, necessary radiation safety requirements and procedures, and are monitored and have 

radiation exposure limits stipulated by NRC regulation in 10 CFR 20.1201.” Had potential 

radiation doses to these workers been considered, the staff would have concluded that the 

doses would be within regulatory limits, an impact that would have been assigned a significance 

level of SMALL. See also the response to Comment 2-04 above regarding occupational health 

impacts. Accordingly, no change to the report was made in response to this comment. 

Comments 2-18A and B: General Treatment of Risk: 

Comment 2-18A: The transportation analysis appropriately considers the risk of accidents. Yet 

this is the only aspect of the environmental evaluation that appears to consider risk. The 

evaluation recognizes that transportation risks exist even though transportation is regulated, 

controlled, and executed by trained personnel. However, the evaluation presumes that risk is 

eliminated (or already satisfactorily addressed) for many other activities because these other 

activities are subject to similar controls. For example, there is no discussion of the 

environmental risk associated with the potential failure of environmental controls at a processing 

facility. This dismissive treatment of other environmental risks in the evaluation seems 

inappropriate, and fails to address the increased risk of public and environmental exposure 

associated with blending and processing tasks of increasing complexity. This is particularly 

obvious in omission of any assessment of disposal risk. 

NRC Response: See response to Comment 2-03 above. 

Comment 2-18B: In the evaluation, disposal of downblended material at Class A facilities is 

presumed to be in accordance with the Class A disposal license, and therefore, environmentally 

acceptable. But the diversion of thousands of curies of waste from robust disposal facilities 

specifically designed to protect the environment, to disposal in facilities that do not provide 
B-17 

equivalent environmental protection from these curies, is not discussed. This focus of the 

evaluation is too narrow, and it fails to consider the broad systematic effects of downblending on 

the environment. In this way, the evaluation fails to meet its stated objective to compare the 

environmental impacts of disposal of downblended materials in a conventional Class A landfill 

with the engineered disposal of Class B and C resins in a facility specifically designed for that 

purpose. 

NRC Response: See response to Comment 2-06 above. 

Comments 2-19A and B: 5.1.2.7.3 Radiological Impacts (of Transportation Accidents) 

Comment 2-19A: The evaluation considers transportation events involving only Type A and 

Type B casks, with the underlying assumption that shipments of Class A resins will benefit from 

the protections afforded by an approved cask design. This overstates the level of protection 

provided for most Class A shipments, and may result in an unduly low misrepresentation of the 

calculated risk of public exposure from an accident involving Class A material. 

First, the evaluation's assertion that Type A casks can carry no more than an A2 value is 

incorrect. It quite common for Type A casks to be used for their shielding properties for 

materials meeting LSA-II6

 shipping criteria. The Department of Transportation (DOT) does not 

limit to the activity that may be transported on a conveyance loaded with LSA-II noncombustible solids. An 8-120A cask, loaded to its 20,000 lb.7

 capacity with LSA-II material, 

could contain up to 900 A2 values; and a 21-300 cask could contain over 1,200 A2 values (based 

on the cask capacity and the 10-4 A2/g8

 LSA-II concentration limit). 

Second, very large quantities of low-level Class A resin will likely be needed to effectively 

downblend the more highly contaminated Class B and C resins. The vast majority of Class A 

waste (which includes this resin population when it is not being used for downblending) is 

currently shipped in IP-1 or IP-II packages9

 that are deemed compliant by the shipper; and do 

not benefit from the design requirements or NRC approval requirements of Type A or B casks. 

The presumed use of Type A casks for large quantities of low-activity feedstock is an 

overstatement of the protection afforded by the packaging of these materials, and may 

under-represent the transportation risks associated with downblending and processing 

alternatives. 

NRC Response: Although the commenter is correct that the evaluation considers 

transportation events involving only Type A and Type B shipping casks, the commenter is not 

correct that there is an underlying assumption that shipments of Class A resins will benefit from 

the protections afforded by an approved cask design. No such assumption has been made in 

conducting the evaluation. The commenter is also correct that some Class A spent IERs are 

shipped in industrial packages as LSA material, and that the total curies in a single industrial 

package of LSA could exceed the A2 value. The report text has been modified as indicated 

                                                            

6

 NRC Staff Note: LSA = low specific activity. 

7

 NRC Staff Note: lb. = pound. 

8

 NRC Staff Note: g = gram. 

9

 NRC Staff Note: IP = Industrial Package. 
B-18 

below to account for these factors. However, for reasons discussed below, the NRC staff 

disagrees with the commenter’s assertions that the assumed use of Type A casks overstates 

the protection afforded these materials during transport and misrepresents the calculated risk of 

public exposure from an accident involving Class A material as unduly low. On the contrary, the 

assumption that all Class A spent IER shipments would be in Type A shipping casks results in a 

more conservative estimation of potential environmental impacts than if industrial packages 

would be used for some shipments. Justification for basing the analysis on shipment of spent 

IERs solely in Type A and Type B shipping casks is provided, and the analysis in the report 

remains unchanged. Finally, the commenter’s contention that very large quantities of low-level 

Class A resin will likely be needed to effectively “downblend” the more highly contaminated 

Class B and C resins is addressed in the response to Comment 2-02 above. 

The text in Section 2.1.2 of the report has been modified to state that the type of container used 

to ship the spent IERs depends on a number of factors, including the mix of radionuclides in the 

material to be transported and the specific activity of the material. Additional information is also 

provided in Section 4.1.2.1, where it is noted that low specific activity spent IERs can be 

shipped as LSA material when certain criteria are met. 

Also, the text in Section A.2.2 in Appendix A has been modified to further describe the different 

types of shipping containers and the factors that influence the choice of a specific type of 

container. Specific to the comment, the modified text presents the following three criteria that 

must be met for shipping spent IERs as LSA material: 

 Average specific activity does not exceed one-ten thousandth of the A2 value per gram of 

material (10 CFR 71.4)10; 

 External radiation from the shipping package must not exceed 0.1 millisieverts 

(mSv)/hour (10 mrem/hour) at 2 meters (m) (6.6 feet (ft)) (10 CFR 71.47(b)(3)); and 

 The material must have and external radiation dose less than or equal to 10 mSv/hour 

(1 rem/hour) at a distance of 3 m (10 ft) from the unshielded material (10 CFR 

71.14(b)(3)(i)). 

These three criteria, taken together, demonstrate a “safety equivalency,” where the external 

dose rate from a shipping package and the dose rate from the unshielded contents in the 

package are regulated to the same equivalent standards, regardless of whether the package is 

an industrial package or a Type A or Type B cask. 

The revised text in Section A.2.2 also notes that, in some cases, a package of spent IERs that 

meets the LSA criteria, and can be shipped as LSA, can contain more than the A2 value. 

However, an industrial package carrying more than the A2 value must meet the 10 CFR Part 71 

criteria for LSA cited above with regard to the external dose rates of the shipping container and 

unshielded material. 

                                                            

10 NRC Staff Note: For LSA-II material. 
B-19 

In response to the comment, the staff agrees that, technically, an 8-120A cask and a 21-300 

cask, each loaded to capacity with LSA material, could potentially contain up to 900 A2 values 

and over 1,200 A2 values, respectively. However, without additional information, the NRC 

cannot determine if such packages could actually be shipped as LSA, because the contents 

may fail to meet the regulatory criteria identified above for the dose rate limits for the loaded 

shipping containers or their unshielded contents. 

The text in Section A.2.2 has also been modified to include justification for the assumption that 

all the spent IERs are shipped in Type A or Type B casks results in a more conservative 

analysis than assuming that some spent IERs are shipped as LSA in industrial packages. This 

assertion is directly tied to four primary factors detailed in Appendix A upon which potential 

environmental impacts of transporting spent IERs are based: (1) the total number of shipments 

(affects local and national traffic); (2) the radiation dose rate from the shipping container (affects 

radiation doses to members of the public from routine, incident-free transport); (3) the number of 

miles driven (affects the potential number of transportation accidents); and (4) the dose rate 

from unshielded material (affects the potential impacts from accidents in which the radioactive 

contents of shipping containers are released). Each factor is discussed below, to establish why 

the assumed use of only Type A and Type B casks for spent IER shipments is more 

conservative than using industrial packages for some shipments: 

1. Total number of shipments: Because Type A and Type B packages incorporate heavy 

shielding and Type B packages also have impact load limiters, the weight of Type A and 

B casks is higher than for industrial packages; and while more than one industrial 

package would be transported per truck shipment to optimize shipping, only one Type A 

or Type B cask can be transported per truck. Thus assuming the use of only Type A and 

B packages for spent IER transport results in the estimation of more shipments and, 

therefore, greater potential impacts on local and national traffic, than would be estimated 

when using smaller, lighter industrial packages for some shipments. 

2. Dose rate from the shipping container: By regulation, the maximum allowable dose rate 

on the outside of the shipping container is the same for LSA, Type A, and Type B 

packages, i.e., 0.1 mSv/hour (10 mrem/hour) at 2 m (10 CFR 71.47(b)(3)). Because the 

external package dose limit is the same for all three package types (i.e., LSA = Type A = 

Type B), and there will be more shipments if using only Type A and Type B casks (see 

above), the estimated population dose is increased by the assumption that all shipments 

are in Type A and Type B casks. 

3. Number of miles driven: Since assuming the use of only Type A and B packages results 

in the estimation of more shipments and, therefore, more miles driven than would be 

estimated when using industrial packages for some shipments, it follows that the more 

miles that are driven, the more potential transportation accidents could occur. 

4. Dose rate from unshielded material: In Section A.3.3.2.2, the dose to the maximally 

exposed member of the public is calculated, based on a transportation accident that 

releases the entire A2 quantity of spent IERs from a Type A cask. In this accident 

scenario, the estimated dose to the member of the public of 1.11 mSv (111 mrem) is 
B-20 

based on a 10-hour exposure, at 30 m, to an unshielded A2 quantity of spent IERs (see 

Table A-19). If instead of a Type A cask with an A2 quantity, the contents of an industrial 

package carrying spent IERs as LSA were released, the dose to a member of the public 

would be lower, at 1 mSv (100 mrem).11 

Comment 2-19B: Third, the evaluation fails to consider that the vast majority of the curies 

shipped in Class B and C wastes currently benefit from the protections afforded by shipment in 

Type B casks, which are designed to withstand accident conditions. In a downblending 

scenario, a significant amount of radioactivity will be dispersed into a large number of shipments 

that do not benefit from the protections afforded by robust Type B packaging. It should also be 

expected that market forces will drive the average curie content of the myriad Class A 

shipments to the very limits of radioactivity of that waste class, and to the limits of Type A cask 

capacity. Well-blended materials may not even require casks at all, but might be transported as 

LSA-II in shipper self-certified IP-2 packages as described above. In a disposal alternative, this 

huge curie inventory benefits from the additional transportation protections provided by Type B 

casks. In the processing alternatives, the risk is diluted and spread over myriad shipments, and 

the level of protection provided to any given curie in transportation is effectively reduced. 

NRC Response: Compliance with the NRC radioactive materials packaging and transportation 

regulations in 10 CFR Part 71 ensures that transport of spent IERs, pre- or post-blending, is 

equally safe if shipped as LSA in industrial packages or shipped as non-LSA material in Type A 

or Type B casks. The NRC cannot predict market forces or their effects on the average curie 

content of the Class A spent IER shipments or on Type A cask availability for these shipments. 

The NRC disagrees with the commenter’s characterization of the numbers of shipments in the 

processing alternatives as “myriad,” in comparison to the numbers of shipments in the other 

alternatives. No change was made in response to this comment. 

Comments 2-20A and B: Annual Number of Truck Shipments 

Comment 2-20A: The evaluation apparently assumes that the net total resin shipments will 

reflect only the current volume of Class A, B, and C resin shipments from nuclear power plants, 

and that the plants themselves will provide sufficient Class A resin material to support effective 

downblending. The basis of this assumption is not evident, and the industry generally presumes 

that Class A resins from other sources (e.g. public water treatment facilities) will be needed as 

'feedstock' to affect downblending to Class A. If this is the case, many more Class A shipments 

of Class A feedstock will be required to support downblending. Since these materials are 

currently direct-disposed as wastes, their shipment to a central processing facility necessarily 

doubles the required transportation and associated risk, not considered in the current 

evaluation. 

                                                            

11 NRC Staff Note: This dose to a member of the public is based on the following: The regulatory maximum dose rate 

for unshielded LSA is 10 mSv/hour @ 3 m (10 CFR 71.14(b)(3)(i)). Thus, 10 hours of exposure at 3 m gives a dose 

of 100 mSv at 3 m. Then, to calculate what this dose of 100 mSv at 3 m would be at 30 m, since dose is inversely 

proportional to the square of the distance from the source, 100 mSv is multiplied by the ratio of squares of the 

distances (3 m and 30 m). The dose for 10 hours of exposure @ 30 m = [(3 x 3) / (30 x 30)] x 100 mSv = 1 mSv. 
B-21 

NRC Response: For reasons discussed in the response to Comment 2-02 above, the NRC 

staff’s intent in Option 2 of SECY-10-0043 (NRC, 2010a) was that the comparative 

environmental evaluation would be conducted for alternatives for managing spent IERs from 

NPPs, including blending. As also discussed, Option 2 did not specify that the staff should 

study the technical or economic feasibility of implementing any of the alternatives. Thus, the 

evaluation was not required to, and therefore did not include a determination of whether 

additional shipments of Class A spent IERs would be required from non-NPP facilities to provide 

sufficient low-activity feedstock to accomplish the blending. Therefore, the impacts of additional 

shipments of Class A spent IERs from sources other than NPPs were not considered in the 

evaluation and no changes were made as a result of this comment. 

Comment 2-20B: WCS also notes that the evaluation does not consider the finite availability of 

Type A and Type B shipping casks. Alternatives featuring treatment increase the number of 

transport evolutions, and correspondingly increase the demand for cask use (approximately 

doubling the number of required shipments). Limited cask availability therefore seems likely to 

force resin processing facilities to store treated resins on site for extended periods. Extended 

storage of waste by generators is contrary to the longstanding official position of the NRC. The 

evaluation should consider the public dose and environmental impacts of extended storage at 

the processing facilities made necessary by the limited availability of shipping casks. In 

addition, the limited cask availability owing to increased demand from extra trips to the 

processing may result in an inadvertent extension of resin storage at the nuclear power plants 

(a delay that does not occur in direct disposal alternatives). It should also be noted that the 

companies that benefit most from the downblending process own and control most of these 

casks, which could cause further disruption of their availability for the preferred direct disposal 

option. 

NRC Response: Although not specifically stated in the Draft Report, the evaluation was based 

on an underlying assumption that there would be sufficient numbers of Type A and Type B 

shipping casks to implement each of the alternatives in accordance with their descriptions. This 

assumption and its effect on the evaluation have now been added to the discussion in Section 

3.1.2 of the report. If in actual practice there was, in fact, a shortage of Type A and Type B 

casks, some of this shortage could offset by using industrial packages for shipments that could 

be classified as LSA, which as indicated by the commenter in Comment 2-19A above and 

agreed by the NRC staff, are already in use for shipping some Class A resins. 

The assumption that sufficient numbers of shipping casks would be available is reasonable for 

the generic, non-location-specific evaluation, because it would be too complex to evaluate the 

potential impacts of several additional possible actions within each of the alternatives, such as 

extended storage—for different periods of time—of untreated spent IERs at the NPPS, of 

untreated or treated spent IERs at the processing facility, and of treated spent IERs at the 

disposal facility. Also, this assumption results in conservative estimates of potential 

environmental impacts, considering that if alternatives were instead assumed to be 

implemented over extended periods of time due to cask shortages, the annual numbers of truck 

shipments and associated potential transportation impacts on an annual basis would be 

reduced. Finally, in a generic evaluation, the staff can make no assumptions or conclusions 

regarding which companies control the shipping casks, how these casks may be used in actual 

practice, and the ability of other companies to fabricate or purchase additional casks. 
B-22 

B.2.3 Commenter 3—Rusty Lundberg (Utah Department of Environmental Quality, 

Division of Radiation Control (DRC))12

Comments 3-01A and B: Disposal Need—the document may understate the need for shallow 

land disposal of SIER13 in the U.S. for at least 2 reasons. 

Comment 3-01A: Number of Nuclear Reactors Without Class B/C Disposal Access—the NRC 

document (p. viii) states that 40 of 65 operating NPP in the U.S. have no disposal access for 

Class B and C low-level radioactive waste (LLRW); indicating 61.5% of the industry lacks 

disposal access. However, when considering many domestic NPP stations have more than 

1 reactor at their site, the problem is actually larger. Prior to July, 201214, 85 of the 104 

operating U.S. nuclear reactors (or ~82%) did not have Class B-C disposal access, see 

Attachment 115. [NRC Staff Note: Attachment 1 has not been reproduced in this appendix, but is 

available in ADAMS in the commenter’s original comment transmittal, under ADAMS Accession 

Number ML13025A354.] 

NRC Response: The comment is noted. However, when preparing the Draft Report, the NRC 

staff intentionally chose to express the problem in terms of number of NPPs rather than number 

of nuclear reactors, because staff believes that the general public would be more familiar with 

the concept of numbers of power plants than numbers of reactors. In that context, it was correct 

that, as stated in the Draft Report, more than 40 of the 65 operating NPPs in the U.S. had no 

disposal access for their Class B and C spent IERs. This approach did not result in an 

understatement in the report of the need for shallow land disposal of spent IERs in the U.S. 

Therefore, no change has been made to the report as a result of this comment. However, as 

discussed in the response to Comment 2-08 above, the report has been revised to recognize 

that WCS can accept out-of compact Class A, B, and C LLRW for disposal (subject to annual 

limits and case-by-case import petition approval by the Texas Compact), and that all NPPs 

potentially have access to a disposal facility for their Class B and C spent IERs at this time. 

Comment 3-01B: Relative Resin Volume and Activity in NPP LLRW—recent research 

conducted by the Electric Power Research Institute (EPRI) of LLRW manifests records, taken 

from the DOE MIMS16 database, for 4 years (2003–2006), of LLRW waste shipments from 41 

NPP sites (or 65 reactors), found that SIER waste constituted about 9% (~257,000 ft3

) of the 

national LLRW volume generated, yet represented about 79% (~63,240 Ci17)

18 of the annual 

                                                            

12 NRC Staff Note: A list of references provided by the commenter has not been reproduced in this appendix, but is 

available in ADAMS on page 6 of 6 of the commenter’s original comment transmittal, under ADAMS Accession 

Number ML13025A354. 

13 NRC Staff Note: SIER = spent ion exchange resins. 

14 NRC Staff Note: This footnote appears as footnote 2 in the comment: In July, 2012 the Texas LLRW Compact 

began approving import petitions for disposal of waste. 

15 NRC Staff Note: This footnote appears as footnote 3 in the comment: Attachment 1 is based on a November 6, 

2012 presentation by Dr. Allison M. McFarlane, NRC Chairman (Slide 2) after comparison with current LLRW 

Compact membership. This membership map is available at: http://www.nrc.gov/waste/llwdisposal/licensing/compacts.html. (accessed 11/30/12). 

16 NRC Staff Note: DOE = U.S. Department of Energy; MIMS = Manifest Information Management System. 

17 NRC Staff Note: Ci = curie(s). 
B-23 

activity. Further, the EPRI study projected the industry-wide SIER generation, for 100 domestic 

reactors and estimated that national SIER annual output would be 90,620 ft3

/yr19 (volume) with a 

total activity of 43,800 Ci/yr20, see Table 1 below. Please note that these recent EPRI 

predictions of industry SIER output is only about 35% of those SIER quantities suggested in the 

1981 NRC Draft Environmental Impact Statement for LLRW.21

Table 1. EPRI Projected Annual NPP Industry SIER Output22

National Annual 

Reactor Type / Design Volume 

ft3

/yr23

Activity 

Ci/yr24

Boiling Water Reactors 53,600 30,600 

Pressurized Water Reactors 37,020 13,100 

Total: 90,620 43,80025

NRC Response: As discussed in Section 2.1.3 of the report, the NRC staff used the EPRI 

study referenced by the commenter as the source of average annual NPP spent IERs volumes 

used in the evaluation. The projected annual NPP industry spent IER output of 90,620 ft3

 quoted 

by the commenter matches the quantity reported in Section 2.1.3. The staff would like to clarify 

that using data from DOE’s MIMS database (as cited in Section 2.1.3 of the report), this 90,620-

ft3

/yr volume represents approximately 4 percent of the total volume of LLRW from all 

commercial generators in 2010 (2,146,000 ft3

), including the NPPs. The report correctly 

characterizes the need for shallow land disposal of spent IERs in the U.S. The remainder of the 

information presented in the comment is noted, but is not directly relevant to the evaluation. As 

such, no change to the report was made because of this comment. 

                                                                                                                                                                                               

18 NRC Staff Note: This footnote appears as footnote 4 in the comment: See Attachment 2. Resin percentages were 

calculated by DRC staff from information provided in the November, 2007, EPRI Report, Tables 6-4 and 6-5. [NRC 

Staff Note: The commenter’s Attachment 2 has not been reproduced in this appendix, but is available in ADAMS in 

the commenter’s original comment transmittal, under ADAMS Accession Number ML13025A354.] 

19 NRC Staff Note: ft3

/yr = cubic feet/year. 

20 NRC Staff Note: Ci/yr = curies/year. 

21 NRC Staff Note: This footnote appears as footnote 5 in the comment: See 1981 NRC DEIS, Vol. 2, Table 3.4, 

specifically the sum of the 3 waste streams: P=IXRESIN; B=IXRESIN; and L=DECONRS. 

22 NRC Staff Note: This footnote appears as footnote 6 in the comment: November, 2007 EPRI report. This table is 

similar to Table 2 found in the 9/12 NRC SIER Evaluation Report. 

23 NRC Staff Note: This footnote appears as footnote 7 in the comment: Based on DRC addition of EPRI projected 

industry-wide resin volume data for Class A, B, and C LLRW, see November 2007 EPRI Report, Table 6-10. 

24 NRC Staff Note: This footnote appears as footnote 8 in the comment: See November, 2007 EPRI Report, Table 6-

12. 

25 NRC Staff Note: This footnote appears as footnote 9 in the comment: Direct quote of industry-wide projection of 

total activity, see November, 2007 EPRI Report, Table 6-12. 
B-24 

Comment 3-02: NRC Dependence on EPA Programs for Environmental Protection 

(p. xvi, etc.)—the NRC evaluation states (p. xvi26) that SIER handling, transport, processing, 

and disposal would not pose a threat to the environment, because of regulatory authority / 

permitting of the EPA National Pollutant Discharge Elimination System (NPDES) program. 

While at first glance, it would appear that EPA and/or its Primacy States would be able to use 

surface water quality regulations (i.e., NPDES rules) to protect public health and the 

environment, the document does not consider several key issues, namely: 

A. Purpose of the Atomic Energy Act (AEA)—from its onset, the purpose of the AEA was to 

place the responsibility for oversight of nuclear energy and protection of public health 

and the environment with the agency that is now known as the NRC. The document 

does not explain why the NRC should rely on, share, or defer its responsibility to the 

EPA (or Primacy States) to permit and inspect facilities that store, treat or dispose of 

SIER. In order to fulfill the intent of the AEA, it appears that NRC should develop all 

needed regulations, issue appropriate licenses, and fulfill inspections and compliance 

activities for SIER treatment, storage, and disposal facilities. 

B. Limitations in EPA Defined Water Quality Criteria for Alpha Emitters—EPA has 

promulgated only three (3) concentration-based surface water quality criteria (or 

standards) for protection of human health, namely: gross alpha, Ra-226+228, and 

Uranium27. These three are taken from EPA Drinking Water standards, discussed 

below. Of these three, radium isotopes should not be found in NPP SIER, having been 

eliminated from nuclear fuel during enrichment / fabrication. However, many alpha 

emitting nuclides, including U-235 have been identified by the Electric Power Research 

Institute (EPRI) as important or principle nuclides in LLRW and SIER, see Table 2, 

below. This research was based on EPRI review of the DOE MIMS database LLRW 

manifest forms for 4 years (2003 - 2006) from 41 NPP in the U.S (i.e., 65 different 

reactors). 

Other information was also available for NPP SIER from NRC sources28, and has also 

been added to Table 2. Table 2 illustrates that 12 alpha emitting nuclides are known to 

exist in SIER, however, the EPA NPDES program would only have one surface water 

quality standard, gross alpha, to monitor for these. Hence, it is unclear if the NPDES 

program could effectively protect public health and the environment at SIER treatment, 

storage, or disposal facilities. 

                                                            

26 NRC Staff Note: This footnote appears as footnote 10 in the comment: This claim is made in many other locations 

in the document, e.g., pp.5-5, 5-53, 5-51, etc. 

27 NRC Staff Note: This footnote appears as footnote 11 in the comment: See EPA Water Quality Standards 

Handbook, 2nd Edition, March 2012, “Chapter 3 Water Quality Criteria (40 CFR 131.11)”, available on internet at: 

http://water.epa.gov/scitech/swguidance/standards/handbook/index.cfm (accessed November 23, 2012). 

28 NRC Staff Note: This footnote appears as footnote 12 in the comment: September, 2012 NRC SIER Evaluation, p. 

2-2; and 1981 NRC Draft Environmental Impact Statement, Vol. 2, Table 3.3. 
B-25 
B-26 

C. Complication in EPA Dose Standards for Human Health: Beta-Gamma Emitters—as 

seen in Table 2, 24 of the known NPP SIER nuclides are beta-gamma emitters. For 

these isotopes, the EPA NPDES program does set discrete water quality criteria 

(standards) for beta and photon emitting radionuclides. Instead, EPA sets an annual 

dose limit of 4 mR/yr29. In order to convert the EPA dose standard to an activity 

equivalent, isotope-specific dose conversion factors are required. The EPA NPDES 

rules do not dictate a specific methodology to guide the regulator in the selection of dose 

conversion factors that would determine compliance standards in surface water under a 

NPDES permit. In summary, the NPDES program relies on the EPA Safe Drinking 

Water Act and its rules to establish in-direct drinking water standards (DWS) and 

determine conversion factors for individual nuclides, to protect human health. 

Closer review of the Safe Drinking Water (SDW) rules shows that only two of the SIER 

beta-gamma emitters have promulgated DWS activity limits, H-3 and Sr-9030. For the 

remaining 24 beta-gamma emitters, the 4 mR/yr dose standard applies. As for dose 

conversion factors, the EPA SDW rules rely on severely antiquated dose conversion 

factors be used to calculate equivalent water quality activity standards; namely the 

National Bureau of Standards Handbook 69, published in August, 196331. These dose 

conversion factors are even older than those used by the NRC to establish the current 

occupational and effluent limits set in 10 CFR 20 rules [ICRP Publications 26 (1977) 

and 30 (1978)]32. These NRC limits are aimed at protection of NPP workers and the 

environment, and are not directly focused on direct human consumption (drinking water). 

Further, even more modern dose conversion factors have been published, based on 

more recent scientific research, see ICRP Publications 60 (1991) and 103 (2007)33. 

NRC should consider updating its 10 CFR 20 rules to reflect these modern 

advancements in dose conversion factors, and establish limits for direct human 

consumption. 

Table 2 Sidenote: It is important to note in Table 2, that 15 of the 36 known SIER 

nuclides are long-lived. Of these 15 nuclides, 14 have half-lives in excess of 5,700 

years. These very long-lived nuclides can pose significant challenges for long term 

waste management and LLRW disposal embankment performance. Many of these 

long-lived nuclides were identified as SIER components in the original NRC EIS that 

launched the US LLRW program34. 

                                                            

29 NRC Staff Note: This footnote appears as footnote 13 in the comment: Annual dose limit found in: 1) EPA Water 

Quality Standards Handbook, 2nd Edition, March, 2012, “Chapter 3 Water Quality criteria (40 CFR 131.11)”, at: 

http://water.epa.gov/scitech/swguidance/standards/handbook/index.cfm, and 2) 

http://water.epa.gov/drink/contaminants/index.cfm. 

30 NRC Staff Note: This footnote appears as footnote 14 in the comment: See 40 CFR 141.66, Table A; where EPA 

DWS for H-3 (20,000 pCi/l) and Sr-90 (8 pCi/l) are set. 

31 NRC Staff Note: This footnote appears as footnote 15 in the comment: See 40 CFR 141.66(d)(2). 32 NRC Staff Note: This footnote appears as footnote 16 in the comment: Federal Register Notice, Vol. 71, No. 13, 

January 20, 2006, p. 3343. 

33 NRC Staff Note: This footnote appears as footnote 17 in the comment: See ICRP Publication 103, p. 11 Extract 

available at: http://www.icrp.org/page.asp?id=111. (accessed 12/3/12). 34 NRC Staff Note: This footnote appears as footnote 18 in the comment: September, 1981 NRC NUREG-0782, 

Volume 2, Table 3.3, waste streams P-IXRESIN and B-IXRESIN. 
B-27 

NRC Response: In the Draft Report, the NPDES program was cited as an example of a 

Federal/State requirement that would serve to limit potential environmental impacts. For 

example, in Table 5, under Water Resources (Water Quality), NPDES requirements are cited as 

an example of a regulation that would limit discharges of liquid effluents. This does not mean 

that the NRC relies on, shares, or defers its responsibility under the AEA to the EPA (or Primacy 

States) to permit and inspect facilities that store, treat, or dispose of spent IERs. On the 

contrary, the NRC has developed all needed regulations, issues appropriate licenses, and fulfills 

inspections and compliance activities for spent IER treatment, storage, and disposal facilities 

(except where licensing, inspection, and compliance activities are appropriately delegated to 

Agreement States). However, where NPDES requirements were referenced as an example, the 

Draft Report did not include references to the NRC’s regulation in 10 CFR 20.1301, which 

requires NRC licensees to meet all-pathways dose limits to protect individual members of the 

public. Agreement-state licensees are subject to identical requirements imposed by the 

responsible Agreement State agency. In addition, both the NRC and Agreement State 

regulations specify that licensees subject to the provisions of EPA's generally applicable 

environmental radiation standards in 40 CFR Part 190 shall comply with those standards. 

The report has been modified to include the reference to 10 CFR 20.1301 where appropriate. 

This addition has been made in Table 5 under “Waste Management” and “Water Resources: 

Water Quality;” in Sections 5.1.2.6, 5.2.5, and 5.2.8; and under Public and Occupational Health 

and Waste Management in the Summary of Comparative Environmental Evaluation section of 

the Executive Summary. As discussed above, the existing references to NPDES are appropriate 

and have therefore been retained. The remainder of the detailed information presented in the 

comment is noted, but is not directly relevant to the generic evaluation. 

Comment 3-03: Long-term Storage Under Alternatives 3 and 4A (pp. 3-3 to 3-4)—both of 

these NRC alternatives call for a 20-year storage of Class B-C waste, after SIER treatment, and 

before any permanent land disposal.

A. Utah Storage Prohibition—under NRC Alternative 4A, the NRC SIER evaluation makes 

mention of the possibility of long-term storage of Class B-C SIER at an existing LLRW 

landfill, that might be working on or awaiting issuance of a Class B-C license. Please 

note that commercial storage of Class B-C LLRW is currently prohibited in Utah by state 

statute35. 

B. Storage on Speculation—both options call for some type of 20-year "temporary" storage, 

be it at each NPP (Alternate 3), or at a central national location (Alternate 4A). However, 

both alternates depend on speculation that sometime in the future sufficient national 

Class B-C disposal capacity will be available, after NRC (or Agreement State) 

authorization of new landfills. It is unlikely that 20 years of storage will suffice. This is 

reinforced by the history of the US LLRW program, in that 30 years transpired since 

                                                            

35 NRC Staff Note: This footnote appears as footnote 19 in the comment: See Utah Code Annotated (UCA) 19-3-

103.7. 
B-28 

issuance of the 1982 NRC Final EIS36, before any single Class B-C landfill was sited, 

licensed, and opened for operation (WCS facility in Texas). Consequently, NRC should 

possibly consider evaluating longer periods of time in its analysis. 

NRC Response: First, regarding the introductory statement made in this comment, the NRC 

staff would like to clarify that of Alternatives 3 and 4A, only Alternative 4A involves long-term 

storage of Class B and C concentration spent IERs after treatment (by volume reduction). In 

Alternative 3, the untreated Class B and C concentration spent IERs are stored at the NPPs for 

20 years, and then shipped for disposal at the end of the long-term storage period. 

Second, the staff notes the information on the Utah storage prohibition. However, this has no 

bearing on the generic, non-location-specific evaluation of the alternatives. 

Third, in developing the evaluation, the staff considered a range of long-term storage periods 

(including periods shorter and longer than 20 years). The staff has considered evaluating longer 

periods of time (e.g., 30 years) in the analysis, but believes that the findings would not be 

significantly different for Alternatives 3 and 4A, and that the additional analysis would add little 

or no value. No change was made to the report as a result of this comment. 

Comment 3-04: HIC Headspace Requirements for Long-Term Storage: Utah's Need to Revisit 

CWF Design Basis (p. 4-8)—the NRC Evaluation states that empty head space is required in 

the High Integrity Containers (HIC), during long-term storage, to accommodate swelling of the 

SIER due to the absorption of water. Previous DRC engineering design review of SIER 

disposal at the Clive, Utah site is based on the stability of the waste form. Further, the approved 

engineering design basis for the Containerized Waste Facility (CWF), where this waste is 

disposed, requires each HIC have no more than a 15% internal headspace at the time of 

disposal. The NRC should consider providing references to technical literature where this 

swelling phenomenon has been documented. 

NRC Response: The reference in the report for information on spent IER swelling is (IAEA, 

2002a), which was cited in Section 4.2.4 and included in the reference list (Section 6) of the 

Draft Report. A citation of this reference has been added in Section 4.2.4 where IER swelling 

due to water absorption is first mentioned. 

Comment 3-05: Control of Soil Impacts by EPA NPDES Program (p. 5-5, Table 5, etc.)—the 

NRC SIER Evaluation makes a statement in Section 5.1.2.6 that the NPDES program can be 

relied on to protect soil contamination near SIER storage / treatment facilities. This statement 

appears to over-estimate the authority of the NPDES regulations, which are designed to protect 

"waters of the United States", or in other words navigable or interstate waters37. While EPA or 

Primacy State permits may govern construction and operation of facilities that potentially 

discharge pollutants, the program's mission is to protect water resources, and not soils or 

                                                            

36 NRC Staff Note: This footnote appears as footnote 20 in the comment: NRC NUREG-0945, published in 

November, 1982. 

37 NRC Staff Note: This footnote appears as footnote 21 in the comment: See EPA rules in 40 CFR 122.1(b) and 

122.2. 
B-29 

groundwater. Groundwater protection has its regulatory foundation in state law and regulation. 

This comment also applies to NRC Table 5 (pp. 5-34 to 35). 

NRC Response: NPDES requirements would also be protective of soil by limiting soil 

contamination from stormwater discharges over land. This has been clarified in Section 5.1.2.6 

(Soil Impacts), where it is now indicated that it is the NPDES stormwater requirements that 

would help reduce, control, or avoid soil impacts. NPDES requirements were not mentioned 

under Soil in Table 5 in the Draft Report, and no change has been made in this regard in the 

Final Report. In addition, NRC regulations in 10 CFR, 20.1301 would apply, as discussed in the 

response to Comment 3-02 above. 

Comment 3-06: Pollution Prevention via Application of EPA NPDES to SIER Treatment, 

Storage and Disposal Facilities (p. 5-51)—reference is made that liquid effluents would not pose 

a hazard to human health or the environment due to the application of the EPA NPDES 

regulations, which would be done thru permit issuance and compliance activities conducted by 

EPA or Primacy States. We believe this claim may overstate the ability and regulatory authority 

of the EPA or Primacy States to oversee SIER related facilities and operations. Please refer to 

Comment 2, above [NRC Staff Note: this is Comment 3-02 above]. EPA regulation of SIER 

facilities may not involve design / construction review, nor compliance monitoring as it relates to 

most of the nuclides known to be present in SIER materials, because AEA-regulated facilities 

are essentially exempt from regulation under the Clean Water Act. 

NRC Response: See response to Comment 3-02 above. 

B.2.4 Commenter 4—Joseph DiCamillo (Studsvik, Inc.) 

Comment 4-01: Studsvik supports the conclusions reached in the Comparative Environmental 

Evaluation. Studsvik suggests that an additional case be added to the evaluation to reflect 

current industry practices. Namely, volume reduction of Class A, B, and C Concentration spent 

IERs at a Processing Facility, then Disposal. Perhaps this case could be Alternative 4C. While 

Studsvik does not believe that this case will in any way alter the conclusions of the report, 

Studsvik believes that the report should identify, discuss and analyze all scenarios. 

NRC Response: The NRC staff notes this comment and has considered the commenter’s 

suggestion to add an additional alternative to the evaluation to reflect “current industry 

practices.” However, the additional alternative suggested by the commenter cannot be included 

in the report because it is not consistent with the alternatives specified in Option 2 of SECY-10-

0043 (NRC, 2010a), which defined the scope of the evaluation (see response to Comment 2-02 

above). No change was made to the report as a result of this comment. 

B.2.5 Commenter 5—Thomas Magette (EnergySolutions, Inc.)

Comment 5-01: In general we agree with NRC staff's conclusion that there are no significant 

impacts from the management of spent ion exchange resins, including those that involve 

blending. We further agree that impacts from all alternatives considered are in almost all cases 

low. We appreciate the staff s efforts to thoroughly address concerns that have been raised 
B-30 

regarding the potential environmental issues associated with blending ion exchange resins. As 

staff has demonstrated with its conservative, bounding analysis, the environmental impacts 

associated with this waste management strategy are inconsequential. 

NRC Response: The NRC staff notes the comment. No change was made to the report as a 

result of the comment. 

Comment 5-02: Attached are several detailed comments for your consideration. While we 

believe that these comments merit consideration and may result in minor editorial revisions, 

none are sufficiently significant to challenge the conclusions staff has reached. We do not 

believe that any additional analyses or significant revisions to the report are necessary. 

NRC Response: The commenter’s detailed comments and NRC’s responses to these 

comments are presented below.

Comment 5-03: page viii - IERs are "bead-like materials." A significant portion is powdered 

material (pressure-precoat systems). There is also no mention of the frequent addition of 

activated charcoal to resin beds. 

NRC Response: The NRC staff agrees with this comment. The Introduction and Purpose 

section of the Executive Summary and Sections 1 and 2.1.1 of the report have been modified as 

appropriate to reflect the additional descriptive information provided in the comment. 

Comment 5-04: page viii - last paragraph refers to one licensed disposal facility as being 

authorized to accept Class A waste from all 50 States. This appears to be a reference to Clive, 

which while strictly speaking is true, does not correctly portray the situation. The Rocky 

Mountain and Northwest Compacts have a site that they are required to use. The Northwest 

Compact can authorize waste from that compact to go to Clive, but that is not the norm. 

NRC Response: The report has been modified to clarify that the Clive facility could accept 

LLRW from all 50 states, but the Rocky Mountain and Northwest Compacts require their 

generators to send Class A LLRW to the licensed LLRW disposal facility in the Northwest 

Compact. This clarification has been made in footnote 1 in the Introduction and Purpose section 

of the Executive Summary, footnote 7 in Section 1, and Section 2.2. This clarification does not 

change a key point in the report, that NPPs in all 50 states have access to an LLRW disposal 

facility for their Class A spent IERs. 

Comment 5-05: page xi - Thermal processing options will result in increased air emissions of 

radionuclides which are not normally removed from stack flow by mechanical filtration 

(e.g.,14CO2 and tritium). These emissions can be controlled within established limits, but 

arguably present higher radionuclide releases than mechanical blending.

NRC Response: The NRC staff appreciates the clarification. However, the report has not been 

modified because only very general information is presented in the report on how air emissions 

may be controlled, and the staff believes the current description is sufficient to support the 

evaluation.
B-31 

Comment 5-06A, B, and C: page xiii – Transportation 

Comment 5-06A: The Transportation summary states that all resins are assumed to be 

transported over-the-road in Type A or Type B shipping casks. Note that resins meeting the 

definition of LSA material may be shipped in Industrial Packaging (see 49 CFR 173.427, Table 

6). Current practices include disposition of significant quantities of very low activity Class A 

resins shipped by truck in 100 ft3

 metal boxes and sometimes metal drums. Less than half of the 

resins shipped to Bear Creek arrive in Type A or B casks. 

NRC Response: See response to Comment 2-19A above. 

Comment 5-06B: In addition, final disposition of these very low activity resins can include nonClass 7 shipments to local industrial landfills, rather than subsequent transfer to one of the four 

licensed disposal sites. 

NRC Response: The NRC staff appreciates the clarification. The general information in the 

comment has been added to the discussions of LLRW disposal facilities in footnote 6 in Section 

1 and footnote 12 in Section 2.2 of the report. The analysis of transportation impacts in the 

report assumes that, in each alternative, all spent IERs are ultimately transported along 

representative routes to a single Class A or a single Class B and C disposal facility (see 

assumption in Section 3.1.2). Therefore, the identification of industrial landfills as a disposal 

option for very low activity spent IERs does not change the analysis. 

Comment 5-06C: It is also important to note that rail transport of wastes has displaced 

significant fraction of the over-the-road transport (particularly from Oak Ridge, TN, to Clive, UT). 

NRC Response: The NRC staff appreciates the clarification, and the text in Section 3.1.2 has 

been modified to indicate that transport of some portion of the untreated and treated spent IERs 

and of returned empty casks could be by rail. 

Comment 5-07: page 1-2 - Next to last paragraph states that resins must be replaced when 

their ion exchange capability is expended. Many of these resins can be regenerated, and some 

existing nuclear power plants (NPPs) were built with the capability to do so. In most NPPs, the 

practice has been found to be economically inefficient, with resulting waste problematic for 

disposal. This is, however, an additional processing option for generators, but one that is not 

addressed to any significant extent in this document. 

NRC Response: The NRC staff appreciates the additional information. Regeneration of IERs is 

discussed in Section 2.1.1 of the report. However, this process is not further discussed in the 

report because it is not one of the alternatives specified in Option 2 of SECY-10-0043 (NRC, 

2010a) for consideration in the comparative environmental evaluation (see response to 

Comment 2-02 above). 

Comment 5-08: page 1-3 - As on page vii, the second paragraph on this page states that one 

licensed disposal facility is authorized to accept Class A waste from all 50 States. This appears 

to be an incorrect reference to Clive, which is not authorized to accept waste from the Rocky 

Mountain or Northwest Compacts. 
B-32 

NRC Response: See response to Comment 5-04 above. 

Comment 5-09: page 2-1, section 2.1.1, Ion Exchange Resin Composition and Use. This section 

introduces IERs as "typically bead-like...", and should also note the widespread use of powdered 

resins (e.g., Graver Powdex systems). 

NRC Response: See response to Comment 5-03 above. 

Comment 5-10: page 2-1, section 2.1.2, Spent IER Generation and Management. This section 

states that spent IERs are sluiced to HICs or appropriate liners, which ignores the intermediate 

use of a spent resin storage tank. These tanks may be sized to accommodate resins from 

multiple resin beds, and can effectively result in commingling at the NPP sites. This has the 

same net effect as blending by an offsite processor.

NRC Response: The NRC staff appreciates the additional information. A footnote has been 

added in Section 2.1.2 of the report, which indicates that some NPP sites have a tank for 

holding spent IERs, and that spent IERs of differing concentrations may be mixed in such tanks 

as part of normal operations. However, the staff does not believe that this comingling of spent 

IERs has the same net effect as blending by an offsite processor. The offsite mechanical and 

thermal blending processes described in Alternatives 1A and 1B, respectively, would use 

equipment and procedures designed to effectively blend Class A, B, and C concentration spent 

IERs to create final homogeneous waste forms that would meet Class A concentration 

requirements. The NPP spent IER storage tanks were not designed to create uniform resin 

mixtures. No changes were made to the report as a result of this comment. 

Comment 5-11: page 2-4, last paragraph. Another reference to Clive accepting Class A waste 

from all 50 States that needs to be corrected. 

NRC Response: See response to Comment 5-04 above. 

Comment 5-12: page 2-5, 1st paragraph states that processors may "take title" to B and C 

wastes, then thermally process the wastes for long term storage at another location pending 

availability of disposal. This statement oversimplifies the waste attribution considerations 

applicable to processors. These considerations are Compact-driven, and generally require 

explicit treatment in the licensing process. 

NRC Response: The statement in Section 2.2 of the report regarding a LLRW processing 

company “taking title” to the Class B and C concentration spent IERs has been removed from 

the report. 

Comment 5-13: page 3-3, Alternative 2. This direct disposal option assumes that NPPs perform 

handling (including dewatering), final packaging, and shipment to the LLRW disposal site. It 

should be noted that the NPP will need appropriate shielded process areas, dewatering 

equipment, and (most importantly) a process control plan to ensure the final IER package meets 

the water content limits. This can be addressed in detail in Section 4. 
B-33 

NRC Response: The comment is noted. However, the additional information will not be added 

to Section 4 of the report because the NRC staff believes the descriptions of spent IER 

handling, packaging, and offsite shipment in Section 4.1 are sufficient to support the evaluation. 

Further, as discussed in Section 3.2, the evaluation assumes that no new spent IER storage, 

handling, processing, and disposal facilities will be constructed (with the exception of the longterm spent IER storage facilities considered in Alternatives 3 and 4A) and that all existing 

facilities operate under licenses from the NRC or Agreement States, which means the 

evaluation assumes that required infrastructure--such as appropriate shielded areas, 

equipment, and process control plans--would already be in place for each of the alternatives. 

Comment 5-14: page 3-3, last paragraph. For Alternative 4A (thermal volume reduction of B&C 

concentrations IERs by a processor, long-term storage, then disposal). Using the stated VR38

factor of 5, spent IERs should be limited to those with concentrations < 20 % of the Class C limit 

(volume concentration based limits, Ci/m3

)

39 to avoid generating > Class C waste. Similar 

constraints are needed for alpha-emitting TRU40 nuclides (with half-life >5 years), 241Pu, and 

242Cm subject to specific activity limits (nCi/g41). Details are appropriate for Section 4, but the 

limitation should be mentioned here. In addition, a VR of 5 may shift materials from Class B to 

Class C, with associated disposal restrictions and increased disposal cost. 

NRC Response: The NRC staff appreciates the additional information. The descriptions of 

Alternative 4A in Sections 3.1.1 and 4.2.5 of the report have been modified to indicate that an 

average volume reduction factor of 5 to 1 is assumed, and the volume reduction facility would 

control the process to ensure that the final waste forms do not exceed Class C limits. 

Comment 5-15: page 3-3, 2nd paragraph. The same considerations noted in #12 [NRC Staff 

Note: this is Comment 5-14 above], above, concerning volume reduction apply to Alternative 

4B, as well. 

NRC Response: Since the descriptions of Alternative 4B in Sections 3.1.1 and 4.2.6 of the 

report state that Alternative 4B is similar to Alternative 4A, and since no discussion of the 

volume reduction factor is included in those descriptions, no changes have been made to the 

report in response to this comment. 

Comment 5-16: page 4-1, paragraph 4.1.1, Dewatering of Spent IERs. Many NPPs lack 

available space, equipment and validated process control plans (frequently held as processor 

proprietary information) to conduct final dewatering for disposal. In addition, some resins require 

additional pre-treatment to reduce gas generation resulting from biological contamination of the 

IER. This treatment requires additional processing equipment and time. It should also be noted 

the IERs with significant iron oxide content become very difficult and time consuming to 

dewater. We do not propose that the analysis be revised to accommodate these exceptions, 

but they should be noted as limitations on the applicability of on-site final dewatering by NPPs. 

                                                            

38 NRC Staff Note: VR = volume reduction. 

39 NRC Staff Note: Ci/m3

 = curies/cubic meter. 

40 NRC Staff Note: TRU = transuranic. 

41 NRC Staff Note: nCi/g = nanocuries/gram. 
B-34 

NRC Response: The comment is noted. However, the additional information will not be added 

to Section 4.1.1 of the report because the NRC staff believes the description of spent IER 

dewatering in this section is sufficient to support the evaluation. Further, as discussed in Section 

3.2, the evaluation assumes that no new spent IER storage, handling, processing, and disposal 

facilities will be constructed (with the exception of the long-term spent IER storage facilities 

considered in Alternatives 3 and 4A) and that all existing facilities operate under licenses from 

the NRC or Agreement States, which means the evaluation assumes that required 

infrastructure—such as that identified in the comment—would already be in place for each of 

the alternatives. 

Comment 5-17: page 4-3, paragraph 4.1.3, Disposal of Untreated and Treated Spent IERs. 

This section states that all untreated and treated spent IERs will ultimately be disposed at 

licensed LLRW facilities. A significant quantity of very low activity resins is disposed at 

unlicensed industrial landfills. This could be classified as an additional disposal alternative. 

NRC Response: See response to Comment 5-06B above. 

Comment 5-18: page 4-4, last paragraph. This section should note that a process option for 

liquid from the dewatering step is necessary. Although gross dewatering may occur at NPP site 

prior to shipment to a processor, additional contaminated water is removed to prepare the IERs 

for disposal. This is in addition to the recycled water associated with routine sluicing operations. 

NRC Response: The NRC staff appreciates the additional information. Section 4.1.1 of the 

report identifies the 10 CFR 61.56(b)(2) requirements to dewater the spent IERs prior to 

disposal. The staff believes that the current description of spent IER dewatering in the report is 

sufficient to support the evaluation. No change was made to the report as a result of this 

comment. 

Comment 5-19: page 4-6, 3rd paragraph. This section states that thermal processing produces 

essentially no secondary solid wastes. As noted in the process description, ceramic filters are 

used in two stages of processing, along with HEPA filtration of the final offgas. In addition, 

contaminated waste salts are produced from acid gas neutralization and dewatering filters (used 

by NPPs to conduct the initial gross dewatering) and must be properly disposed, along with any 

shipping containers not reused for burial shipment. In summary, the thermal process does 

produce substantial secondary waste.

NRC Response: The NRC staff appreciates the additional information. The generation of 

incidental wastes had already been noted in the description of Alternative 1B in Section 4.2.2 of 

the Draft Report. However, Section 4.2.2 has been modified to indicate that these incidental 

wastes, which include ceramic filters, HEPA filters, and contaminated salt wastes, and are 

relatively small in volume when compared to the volume of materials processed. Also, as was 

noted in the Draft Report and again in the Final Report, these incidental wastes contain less 

than one-half of one percent of the incoming radioactivity. (Mason et al., 1999; THORsm, 2006) 

For these reasons, the staff does not find these wastes to be “substantial,” as indicated in the 

comment. 
B-35 

Comment 5-20: page 4-6, Alternative 2, Direct Disposal of Class A, B, and C Spent IER LLRW. 

This very brief entry for this Alternative should acknowledge considerations described above in 

comment #14 [NRC Staff Note: this is Comment 5-16 above]. 

NRC Response: The additional information on dewatering of spent IERs at NPPs described in 

the commenter’s referenced comment is not appropriate for inclusion in Section 4.2.3 of the 

report, which describes Alternative 2, as dewatering is already appropriately addressed in 

Section 4.1.1. See also the response to Comment 5-16 above regarding including additional 

information on dewatering in Section 4.1.1. 

Comment 5-21: page 4-8, paragraph 4.2.5, Alternative 4A. We do not find this alternative to be 

credible or realistic. Storage of processed waste at disposal and processor sites is strictly 

controlled and long-term storage of waste is prohibited by license. Although it was recently 

done at the Texas Compact site, regulators in Texas have objected to its becoming a common 

practice and it is not likely to be repeated. Rather than investing effort to remove or reanalyze 

this alternative, we propose that its practical limitations simply be noted. 

NRC Response: The comment is noted. While some license restrictions may apply for a 

licensee, the analysis in this report is not tailored to specific license conditions. This report is a 

generic environmental evaluation of alternatives for handling low-level radioactive waste spent 

ion exchange resins and staff believes that Alternative 4A is a valid scenario for evaluation. 

Accordingly, Alternative 4A has been retained for consideration in the evaluation and no change 

was made to the report as a result of this comment.

Comment 5-22: page 5-9, 1st paragraph. For reference and comparative risk evaluations, an 

outdated baseline "U.S background dose" is cited as 360 mrem/y,42 using data from the 1998 3rd

edition of Handbook of Health Physics and Radiological Health, Schleien, et al. That data is 

based upon information from the NCRP Report #93,43 Ionizing Radiation Exposure of the 

Population of the United States, published in 1987. The data set has been updated in NCRP 

Report #160, Ionizing Radiation Exposure of the Population of the United States, published in 

2009. The reference value has been revised upward to 620 mrem/y, mostly attributable to 

increased use of CT44 scans as a diagnostic tool. Note that the use of the term "U.S. 

background dose" may be somewhat misleading, as the values in both reports are the average 

exposures to the U.S. population from all sources. The effect of the nominal 70% increase in 

average exposure is the commensurate reduction in relative risk when transportation-related 

doses are compared to the average annual dose from all sources. 

NRC Response: This comment has given the NRC staff reason to reconsider the U.S. average 

annual background dose used for comparison purposes in the evaluation. The reported 

“background dose” has changed over time. U.S. background dose was assessed by the NCRP 

in 1987 as 3.6 mSv per year, of which 83 percent (3.0 mSv per year) was categorized as 

“natural” and included doses internal to the human body, and the remainder was from “artificial” 

                                                            

42 NRC Staff Note: y = year. 

43 NRC Staff Note: NCRP = National Council on Radiation Protection & Measurements. 

44 NRC Staff Note: CT = computed tomography. 
B-36 

sources including medical procedures, consumer products, and other sources (NCRP, 1987). 

Although the NCRP was careful to identify natural background radiation and distinguish it from 

other sources, after 1987 the U.S. average annual background dose was usually cited (e.g., in 

NRC reports) as 3.6 mSv per year, the sum of the natural and artificial components. In 2009, the 

NCRP re-evaluated the annual U.S. background dose and concluded that, while average annual 

U.S. background radiation from natural sources had increased only slightly, from 3.0 to 3.11 

mSv, the average annual exposure to other sources (primarily medical procedures) had 

increased approximately five-fold, from 0.6 mSv per year to 3.1 mSv per year (NCRP, 2009), for 

a total of 6.2 mSV per year (620 mrem per year) as noted by the commenter. The increase in 

the artificial contribution to “background” has resulted in different interpretations by different 

analysts of what background is, i.e., whether or not it should include the artificial component. 

For this evaluation, the staff has decided to use the average background dose of 3.11 mSv per 

year (311 mrem per year) from natural sources only (NCRP, 2009) for comparison with 

estimated doses in the report, because this is more conservative than using higher background 

values that include artificial contributions and because doses to members of the public from 

artificial sources of radiation are highly variable. Consequently, revised discussions regarding 

background dose are presented in the Final Report in Sections A.1.1 (footnote 2), A.3.2, 

5.1.2.1.1 (footnote 22), and 5.1.2.7.2, and under Transportation in the Summary of Comparative 

Environmental Evaluation section of the Executive Summary (footnote 6). In addition, 

comparisons with background where they appear in tables and corresponding text in Appendix 

A have been re-calculated by substituting the U.S. average annual natural background value of 

3.11 mSv per year for the traditionally cited value of 3.6 mSv per year used in the Draft Report. 

The comparisons of radiation dose from the spent IER shipments with U.S. average annual 

background radiation shown in Tables A-7, A-8, A-11, A-14, A-17, A-19, and A-22 remained the 

same in most cases, because they were appropriately cited to only one or two significant figures 

and are very small numbers. The changes that did occur were very small to negligible in 

magnitude. The changes in the tables resulted in minor changes to the text describing the 

comparisons with background in the tables, in Sections A.3.2.1.2, A.3.2.3.1, A.3.2.3.2, 

A.3.3.2.1, and A.3.3.2.2. These changes are also reflected where appropriate in the main report, 

under “Transportation: Routine (Incident-free) – Radiological (Individuals and Populations)” and 

“Transportation: Accidents – Non-radiological and Radiological” in Table 5 and in Sections 

5.2.7.2 and 5.2.7.3 and the corresponding sections in the Executive Summary. 

Comment 5-23: page 5-13, Accidents in Which a Type A Cask Would Be Impacted. As noted in 

Comment #4, above [NRC Staff Note: this is Comment 5-06A above], resins meeting LSA-2 

criteria may be shipped in IP-2 packages, rather than Type A or Type B casks. Shielded 

overpack containers may be used to meet restrictions on radiation levels.

NRC Response: See response to Comment 2-19A above. 

Comment 5-24: page 5-28, Table 5, Comparison of Potential Environmental Impacts of the Six 

Alternatives..... Assessing the potential impacts of Alternatives 3 and 4A (both long-term 

storage scenarios) on Historic and Cultural Resources as "small to moderate" appears unduly 

conservative. Given the acknowledged small footprint required for storage and the thorough 
B-37 

environment siting process for NPPs and disposal sites, it is highly unlikely that there would be 

any impacts from these alternatives that could not be easily avoided or fully mitigated. We 

recommend the potential impacts of alternatives 3 and 4A be revised downward to "small." 

NRC Response: In this evaluation, the NRC staff’s findings for Alternatives 3 and 4A were 

based on known cases in actual practice in which impacts to historic and cultural resources that 

could perhaps have been avoided were instead mitigated. However, the text in Table 5 does 

acknowledge that due to the small sizes of the new storage facilities (as described in Sections 

4.2.4 and 4.2.5, respectively), impacts could likely be avoided. NRC staff elected to include the 

more conservative assumption that mitigation of adverse effects might be employed, in which 

case the impact could be MODERATE. No changes have been made to the report in response 

to this comment. 

Comments 5-25A and B: page 5-49, paragraph 5.2.7.2 

Comment 5-25A: dose should be updated to reflect currently available information. The result 

will be reductions in the already extremely low relative risk data presented. 

NRC Response: See response to Comment 5-22 above. 

Comment 5-25B: Analyses do not consider use of Industrial Packagings in addition to Type A 

and B casks. 

NRC Response: See response to Comment 2-19A above. 

B.2.6 Commenter 6—Michael Dooley (Phoenix Energy of Nevada, LLC and Kurion, Inc.) 

[NRC Staff Note: A portion of the comment package from Commenter 6 is reproduced below. 

The entire 48-page comment package is available in ADAMS, under ADAMS Accession 

Number ML13092A456. The package presents descriptive and design information for the 

Phoenix Energy of Nevada, LLC and Kurion Inc. “Skid Mounted Transportable Nuclear Power 

Plant On-Site Spent Ion Exchange Resins Class B/C Driver Radioactive Isotopes Stripping and 

Transfer and induction Heat Melt Volume reduction Modular Vitrification System Low Level 

Radioactive Waste Processing and Storage Systems Facility.”] 

Comment 6-01: Phoenix Energy of Nevada, LLC (PENV), a power and energy engineering, 

design and construction Company, and Kurion, Inc., a nuclear and hazardous waste handling, 

processing, mitigation and management Company (in partnership and working jointly), in a 

combined response to offer recommendations and provide potential resolutions on the issues 

and problems identified in this subject report; present the following solution. A fully independent 

& Design Engineered, compact and portable, secure, self-enclosed, and skid mounted 

Processing and Storage Systems Facility. A system capable of being fully transportable for 

Nuclear Power Plant On-Site transfer of spent Ion Exchange Resins and Class B/C Driver 

Radioactive Isotopes into an induction heat melting, volume reduction MVS (modular vitrification 

system) processed, Low Level Radioactive Waste (LLRW) facility. This aforementioned “MVSLLRW Processing Systems Facility” separately, individually, collectively, and concurrently 
B-38 

mitigates and resolves each and every one of the six (6) NRC Staff identified, potential, and 

environmental impacts. (As identified alternatives for managing low-level radioactive waste 

(LLRW) and spent ion exchange resins (IER’s) being generated at commercial nuclear power 

plants (CNPP’s), and as discussed in this subject report). 

After reading this subject “NRC September 2012 Draft Comparative Report”, the joint PENVKurion Commercial Nuclear Power Plant Projects Management and Engineering Team has 

decided to launch the development of their newly designed system. Readily accepting the 

engineering, design, and development challenges for a unique closed loop, independent, selfcontained, and securely portable/transportable facility. A skid mounted, nuclear environment 

ready, low-level radioactive waste facility for the transfer, processing and storage of spent ion 

exchange resins and class B/C driver radioactive isotopes by MVS technology; reliant upon this 

NRC September 2012 Draft Comparative Report as the upper tier specification document for 

controlling the engineering, design, technical/operations input, specifications and requirements 

final document. 

NRC Response: The NRC staff notes this comment and thanks the commenter for the 

information. No changes were made to the report as a result of this comment. 

B.3 References 

(EPA, 2008) U.S. Environmental Protection Agency. “Indoor Water Use in the United States.” 

EPA WaterSense. June. ADAMS Accession No. ML13149A298. 

(Herness, 2013) Herness, Sarah. “Texas Law Gives WCS Window for Additional Import 

Disposal.” RadWaste Monitor. ExchangeMonitor Publications, Inc., Washington, DC. Vol. 6, No. 

26. June 21. 

(Mason et al., 1999) Mason, J.B., Oliver, T.W., Carson, M.P., and Hill, M.H. “Studsvik 

Processing Facility Pyrolysis/Steam Reforming Technology for Volume and Weight Reduction 

and Stabilization of LLRW and Mixed Wastes.” Tucson, Arizona: Waste Management ’99 

Conference Proceedings. February 28-March 4. 

(NCRP, 1987) National Council on Radiation Protection & Measurements. “Ionizing Radiation 

Exposure of the Population of the United States.” Report No. 93, Washington, DC. 

(NCRP, 2009) National Council on Radiation Protection & Measurements. “Ionizing Radiation 

Exposure of the Population of the United States.” Report No. 160, Bethesda, MD. 

(NRC, 2003) U.S. Nuclear Regulatory Commission. “Environmental Review Guidance for 

Licensing Actions Associated with NMSS Programs.” NUREG-1748. August. ADAMS Accession 

No. ML032450279. 

(NRC, 2009) U.S. Nuclear Regulatory Commission. “Response to Commission Order CLI-05-20 

Regarding Depleted Uranium.” NRC Commission Staff Requirements Memorandum, SRMSECY-08-0147. March 18. ADAMS Accession Number ML090770988. 
B-39 

(NRC, 2010a) U.S. Nuclear Regulatory Commission. “Blending of Low-Level Radioactive 

Waste.” NRC Commission Paper, SECY-10-0043. April 7. ADAMS Accession No. 

ML090410246. 

(NRC, 2010b) U.S. Nuclear Regulatory Commission. “Blending of Low-Level Radioactive 

Waste.” NRC Commission Staff Requirements Memorandum, SRM-SECY-10-0043. October 

13. ADAMS Accession No. ML102861764. 

(NRC, 2010c) U.S. Nuclear Regulatory Commission. “Analysis of Blending of Low-Level 

Radioactive Waste.” Enclosure to Commission Paper, SECY-10-0043. April 7. ADAMS 

Accession No. ML090410260. 

(NRC, 2012a) U.S. Nuclear Regulatory Commission. “Draft Comparative Environmental 

Evaluation of Alternatives for Handling Low-Level Radioactive Waste Spent Ion Exchange 

Resins from Commercial Nuclear Power Plants.” Draft Report for Comment. September. 

ADAMS Accession ML12256A965. 

(NRC, 2012b) U.S. Nuclear Regulatory Commission. “Draft Branch Technical Position on 

Concentration Averaging and Encapsulation, Revision 1.” May. ADAMS Accession No. 

ML121170418. 

(THORsm, 2006) THOR Treatment Technologies, LLC. “THORsm Steam Reforming Process for 

Hazardous and Radioactive Wastes, Technology Report, TR-SR02-1, Rev. 1.” Richland, WA. 

ADAMS Accession No. ML120730124. 
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