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4 Pathways and Estimated Costs for Disposition of Slightly Radioactive Material For this discussion, the study committee has assumed that the following three possibilities are available for disposition of the inventories of suspected low-activity radioactive and/or slightly radioactive solid material (SRSM) arising from operating and decommissioning nuclear facilities: No release (i.e., disposal to a licensed low-level radioactive waste [LLRW] disposal facility); Conditional clearance (release for controlled reuse or disposal in a mu- nicipal or hazardous waste landfill); and Clearance (unrestricted reuse, recycle, or disposal). Figure 4-1 illustrates the general decision pathway for disposition under these three possibilities. Under a no-release scenario, all of the materials are sent directly to LLRW disposal. All other disposition scenarios begin with an initial sorting of materials into two streams: cleared materials and materials needing further scrutiny. The materials not cleared are then divided into streams to un- dergo treatment or not. The uncleared-not treated stream is sorted into a stream for LLRW disposal and a stream of conditionally cleared materials. The post- treatment stream is sorted into three streams: LLRW disposal, conditionally cleared material, and cleared material. Conditionally cleared material may be released for controlled reuse or dis- posal in a Resource Conservation and Recovery Act (RCRA) Subtitle D (or, less 72

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PATHWAYS FOR DISPOSITION OF SLIGHTLY RADIOACTIVE MATERIAL No-release scenario 73 ('=: ~CIeared decontaminate ~ Sort ~ 1 - LLRW _ Disposal ~ Facility LLF tW _4 Volume ~ Reductions' nditional Clearance ~ rJ Yes 1 /T-~,l~4 _ ~Second\ ~ No ~~ ) ~ ~ ow | Material | | Inventory | Prompt | f~ Delayed FIGURE 4-1 Decision points and disposition pathways. \ Not \ Cleared t~ - Conditional Clearance (controlled reuse or landfill disposal) Clearance (unrestricted reuse, recycle or disposal) frequently, Subtitle C) landfill.1 Material cleared for disposal should be managed according to its nonradiological properties. In the remainder of this chapter, the committee discusses these pathways and the various decision points in the dispo- sition system represented by Figure 4-1. The discussion includes estimates of the costs for disposing of metallic and concrete SRSM from the population of li- censed power reactors in the United States via these three possibilities. Decon- tamination, segmentation, and transport costs are not included in the costs esti- mated in this report for disposition. DISPOSITION SYSTEM DECISIONS Many nuclear facilities today use waste brokers (firms licensed to receive, process, package, and transport suspected radioactive materials) to handle se- lected materials arising from their facility operations or decommissioning activi- ties. Thus, an initial decision the waste generator makes is whether to handle its tin addition to municipal solid waste landfills (MSWLF), which must meet minimum national criteria set forth by EPA at 40 CFR Part 258, two other types of Subtitle D landfills are commonly used: construction and demolition landfills, and industrial solid waste landfills. The latter two types of landfills are subject to state regulation with respect to liners, leachate collection, etc., require- ments which can vary state to state; there were approximately 3,000 such facilities in the United States in the mid-199Os. There is frequent overlap between the types of waste received at the differ- ent types of facilities, e.g., regulations allow MSWLFs to receive industrial nonhazardous waste, and in some states construction and demolition waste are disposed of in MSWLFs.

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74 THE DISPOSITION DILEMMA waste disposal activities in-house or to contract with a waste broker. In either case, the decision points and pathways shown in Figure 4-1 remain the same. The next decision is whether the SRSM could be stored for a sufficient time prior to disposal to allow decay of radionuclides to levels that might meet adopted clearance standards. For this purpose, materials could be stored at either the waste generator's site, a licensed storage facility, or a waste broker's site. Many factors can influence this decision, including the following: . Will the radioactive isotopes present decay rapidly enough that a reason- ably short storage period is possible? Is suitable storage capability available either on-site or at a licensed waste broker's site? Does the waste owner have the long-term financial stability to ensure safe and proper storage of the radioactive materials and future disposition of the residual material at the end of the storage period? Are the avoided immediate disposal costs and the projected future dis- posal costs and disposal capacities sufficiently well known to justify the risks of a longer-term financial commitment? Are the surrounding communities amenable to the long-term storage of these materials? Some waste generators (particularly hospitals) already use a storage ap- proach for wastes that contain short-lived radionuclides, such as those used in nuclear medicine for treatment or diagnosis. Generally, storage for less than a year is sufficient to permit disposal of these types of wastes subject only to other characteristics that might dictate disposal at hazardous waste (Subtitle C) or municipal waste (Subtitle D) landfills under existing guidance (i.e., Regulatory Guide 1.86~. In these circumstances, storage is less costly than the expenses associated with packaging, transport, and disposal at an LLRW facility. In some locations, access to an LLRW disposal facility may be restricted by the compacts and the Low-Level Radioactive Waste Policy Amendments Act of 1985 (LLWPAA). Storage for decay may be the only choice. Generators of SRSM containing radioactive species with half-lives in the range of one year or less may find the storage approach appealing. However, if the radioactive species have half-lives longer than a few years, the SRSM genera- tor cannot solve the disposal problem with a storage approach. In the conceptual framework, the next activity is to sort the waste stream into materials that presently can be cleared subject to the appropriate standards and those that cannot. The cleared material is then released for unrestricted use. The next decision is whether treatment is available and will be used prior to disposition. The SRSM is sorted into two streams, one amenable to treatment and one for which treatment would not be beneficial. Materials to be treated are decontaminated using various chemical or mechanical methods to remove radio-

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PATHWAYS FOR DISPOSITION OF SLIGHTLY RADIOACTIVE MATERIAL 75 active contaminants from their surfaces. The SRSM that has been subject to treatment is then sorted into cleared, conditionally cleared, and LLRW streams (i.e., no release). The untreated materials are sorted into conditionally cleared and LLRW streams. The two streams of conditionally cleared materials can then be released for controlled reuse or for disposal in a Subtitle C or Subtitle D landfill. The LLRW materials may be reduced in volume before being delivered to an LLRW disposal facility. A secondary radioactive waste stream generated from the chemical or mechanical decontamination activities will also require disposal at an LLRW disposal facility. RELATIVE COSTS FOR DISPOSITION ALTERNATIVES Determining the costs for the pathways in this disposition system can be difficult, but some useful data are available. Components of disposal prices at Barnwell and U.S. Ecology are part of the public record. The disposal costs for special items such as reactor pressure vessels or steam generators are often nego- tiated privately between the waste owner and the disposal facility. In addition, many waste generators now use waste brokers to process and dispose of their wastes. These costs are based on negotiated contracts, which are generally not public record and are therefore not readily available. Many factors affect costs, and the committee was not able to make a detailed analysis of all these factors nor did it find that the U.S. Nuclear Regulatory Commission (USNRC) had prepared a detailed economic analysis. Factors affecting costs include volume, physical and chemical characteristics of the material, taxes and fees imposed by the vari- ous regulatory entities, and past relationship of the generator and disposal facil- ity. The disposal cost for LLRW from decommissioning can constitute a major share of the total cost of decommissioning a nuclear power plant (Konzek et al. 1995; Smith et al. 1996~. The USNRC must ensure that utility owners deposit adequate monies into the decommissioning funds to cover the cost of decommis- sioning their nuclear power plants. Therefore, for the past decade the USNRC has issued a periodic report on LLRW disposal costs, Report on Waste Burial Charges, NUREG-1307. The latest revision of NUREG-1307 (USNRC, 2000b) lists the published year-2000 charge rates for LLRW disposal at licensed com- mercial disposal sites in Richland, Washington ("US Ecology"), and Barnwell, South Carolina ("Barnwell"~. It also contains information on the escalation of LLRW disposal costs over recent years and a set of generic rates typically being charged by waste brokers for disposition of contaminated concrete rubble and contaminated metals. These generic rates come from a survey of licensed waste brokers. Thus, some data are available for use in estimating the disposition costs for contaminated materials. NUREG-1307 does not include data for Envirocare of Utah, which is not subject to the limitations of the LLWPAA and was designed specifically to receive high-volume, low-activity waste.

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76 THE DISPOSITION DILEMMA Disposal of commercially generated LLRW and SRSM, as defined in this report, is geographically controlled by the provisions of the LLWPAA. The LLWPAA established the framework for the creation of interstate compacts and granted the compacts the authority to exclude the importation of wastes from outside each compact. At the present time, three disposal facilities are operating in the United States and additional facilities are not likely to be developed in the near future. The US Ecology disposal facility on the Hanford Reservation in Washington takes LLRW and some technologically enhanced naturally occurring radioactive material (TENORM) from states in the Northwest Interstate Compact region (Washington, Oregon, Idaho, Utah, Montana, Wyoming, Alaska, and Ha- waii) and, by agreement, the Rocky Mountain Compact region (Colorado, Ne- vada, and New Mexico). The Envirocare facility, located in Clive, Utah, takes some LLRW and SRSM from all over the country but, out of deference to the Northwest Compact, takes limited wastes from that region. The Chem Nuclear facility in Barnwell, South Carolina, currently takes LLRW from all other states, except North Carolina, although waste receipts at Barnwell will be further limited in the future. The South Carolina state Budget and Control Board has reported, "As you are probably aware, a South Carolina state law passed last year limits the annual volume of waste that can be accepted at the Barnwell site through our fiscal year 2008, which ends June 30, 2008. After that date, the site can only accept waste generated within the Atlantic Compact region. For the current fiscal year, July 1, 2001, through June 30, 2002, the site can accept 80,000 cubic feet, which is a 35 percent reduction from the volume received last fiscal year" (Newberry, 2001~. The following discussion of the estimated costs of disposal is provided for illustrative purposes and does not purport to represent the actual costs that any particular waste generator may incur. The projected dates for reactor decommis- sioning are too uncertain, as are the interest and discount rates appropriate to those dates, to permit any meaningful present value analyses. In addition, the cost of disposal of nuclear waste will in the future be subject to factors the committee is not able to foresee or take into account in these estimates. For example, the closing of Barnwell to receipt of waste from outside the Atlantic Compact after June 30, 2008, could have an effect on the prices charged by Envirocare of Utah and US Ecology for disposal services. However, the possibility cannot be ruled out that other compacts may open competing LLRW disposal facilities pursuant to the LLWPAA of 1985. Such facilities could accept SRSM generated within compact and, at their discretion, from other compacts. Historically, high disposal costs and lack of access to disposal sites have caused licensees to employ volume reduction (e.g., compaction) and other waste management strategies. This was observed, for example, during the closure of Barnwell to certain states during the 1990s (NRC, 2001~. Finally, while the committee has considered the probable future market prices for disposal of waste in developing estimates for the costs of various disposition options, other input variables such as the costs of transporta-

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PATHWAYS FOR DISPOSITION OF SLIGHTLY RADIOACTIVE MATERIAL TABLE 4-1 Approximate Costs for Disposal of Solid Material as Low-Level Radioactive Waste (dollars) 77 Average Price Average Price Site per Cubic Meter per Kilogram Chem-Nuclear Barnwell S.C. 16,800 (metal or concrete) 13.86 US Ecology Hanford, Wash. 3,120 (metal or concrete) 2.64 Envirocare of Utah Clive, Utaha 388 (concrete) 0.33 NOTES: The table does not include the cost of decontamination, waste processing, transportation, and handling. Taxes and government charges are included. Nominal waste density is 1,200 kg/m3. aEnvirocare does not publish its rates. The committee was able to verify one set of rates for one customer for 1 l(e)(2) materials only and cannot state whether this rate is representative for disposal of SRSM in general. lion, treatment, fees and tariffs, and so forth, have not been included in these estimates. The committee recognizes that the costs of treatment, transportation and handling fees can be substantial; however, since these costs are expected to be case dependent, it was decided not to include them in developing generic cost estimates for disposal. To estimate the costs of LLRW disposal of metal at the US Ecology and Barnwell disposal facilities, the study committee applied the average costs for disposal at those sites to the inventory of net metallic SRSM (excluding concrete) for the population of U.S. power reactors, as shown in Table 3-1. The average cost for disposal of LLRW materials at the US Ecology disposal facility, adjusted to year-2000 dollars, was about $3,120 per cubic meter. The analogous cost for the Barnwell facility was $16,800 per cubic meter. Table 4-1 lists nominal rates for disposal of solid material used in this discussion. Not all licensees are autho- rized to dispose of materials at all LLRW facilities, due to the regulatory com- plexities of the waste compact provisions of the LLWPAA. Envirocare of Utah can accept certain types of high-volume low-activity Class A waste under 10 CFR Part 61, naturally occurring radioactive material (NORM), and ll~e)~2) wastes.2 With respect to bulk scrap metals that would be generated by power reactor decommissioning, Envirocare's waste acceptance guidelines state that the facility can accept "bulk oversized debris in the form of large pieces of metal, boulders, equipment, etc." (Envirocare, 2001, p. 20~. However, Envirocare does not publish prices for disposal of wastes, including large pieces of metal, at its facility. The committee has thus not made estimates of disposal of metals at Envirocare. The cost for disposal as LLRW wastes of net metallic SRSM from 2Charles Judd, President, Envirocare of Utah, presentation to the committee, March 26, 2001.

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78 THE DISPOSITION DILEMMA the total population of power reactors could range from about $1.6 billion for US Ecology disposal to about $8.8 billion for Barnwell disposal. The committee estimated the costs for disposal of the same net metallic SRSM at a landfill. The unit costs range from about $30 per metric ton at a municipal waste (Subtitle D) landfill to about $110 per metric ton at a hazardous waste (Subtitle C) landfill. Based on the estimate in Table 3-2 for the weight of metallic SRSM from the population of power reactors, the cost for disposal as conditionally cleared metals would be about $22 million in a Subtitle D landfill or about $81 million in a Subtitle C landfill. The possible income (or cost) associated with clearance of the net metallic SRSM could range from an income of about $22 million (assuming a scrap recycle value of about $30 per ton) to a cost of about $22 million (assuming Subtitle D landfill disposal). Similar cost estimates arise from consideration of disposition of the concrete SRSM from the population of U.S. power reactors. Envirocare can accept con- crete debris for disposal, provided it is Class A waste under 10 CFR Part 61 (Envirocare, 2001, p. 19; see also footnote 2~. Envirocare does not publically advertise disposal rates and negotiates disposal rates on a case-by-case basis (see p. 484, Envirocare of Utah, Inc. v. U.S., 44 Fed.Cl. 474 (Fed.Cl., Jun 11, 1999) (NO.99-76C)~. In the absence of direct information, the committee has therefore estimated costs for disposing of concrete from power reactors by using the pub- licly available contract rate for debris (including concrete) used under contract with the U.S. Army Corps of Engineers (USAGE) for disposal of l l (e)~2) wastes at Envirocare of $296.8 per cubic yard ($388 per cubic meter) (USAGE, 1998~. (The previous year, the contract rate for debris, which includes concrete debris, for the USACE was $427.5 per cubic yard $559 per cubic meter illustrating the case-by-case variability in the price of disposing of such wastes at Envirocare.) Disposal of all concrete rubble from U.S. power reactors at Envirocare would cost approximately $2.9 billion. Using the US Ecology and Barnwell disposal charge rates given previously, disposal costs for this concrete as LLRW would range from about $2.9 billion (Envirocare), as noted, to $23 billion (US Ecology), to $123 billion (Barnwell), if all of the concrete is disposed in one site. The text and Table 4-1 show a large difference in disposal costs at the three operating sites. Barnwell and US Ecology are regional disposal facilities under the LLWPAA and, as such, are subject to regional and state surcharges, taxes, and some rate regulation. Envirocare is not a regional disposal facility and is not similarly regulated. The committee cannot explain the differences in rates, nor does the committee know whether the quoted rate for ll~e)~2) disposal at Envirocare is representative of rates for other materials, volumes, or generators. Detailed analysis of the components of disposal costs (e.g., surcharges) is beyond the scope of the committee's task. Disposal costs for this concrete as conditionally cleared material in a Subtitle D or Subtitle C landfill would range from $265 million to $975 million, depend- ing on the type of landfill utilized. Clearance of this concrete for use in roadway

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PATHWAYS FOR DISPOSITION OF SLIGHTLY RADIOACTIVE MATERIAL TABLE 4-2 Estimated Costs for Alternative Dispositions of Slightly Radioactive Solid Materiala (billion dollars) 79 Disposal Location SRSM Metals SRSM Concrete U.S. Ecology Richland, Wash. 1.6 23 Chem-Nuclear Barnwell, S.C. 8.8 123 Envirocare of Utah Clive, Utah Not calculated 2.9 Subtitle C landfill (generic) 0.081 0.98 Subtitle D landfill (generic) 0.022 0.27 aValues represent disposal of all material at a given disposal site, and do not reflect any credits that might arise from recycle or reuse of this material. foundations or other similar unrestricted applications would reduce that portion of the disposition costs associated with disposal to nearly zero. Costs for these and other disposal options for concrete and metal are summarized in Table 4-2. FINDING Finding 4.1. Disposal of all slightly radioactive solid materials arising from decommissioning the population of U.S. power reactors into low-level radioac- tive waste disposal sites would be expensive (about $4.5 billion to $11.7 billion) at current disposal charge rates. Disposal in Subtitle D or Subtitle C landfills would be cheaper ($0.3 billion to $1 billion, respectively). Clearance of all of this material could reduce disposal costs to nearly zero (assumes 100 percent reuse or recycle) or might even result in some income (~$20 million) arising from the sale of scrap materials for recycle or reuse. Decontamination, segmentation, and trans- port costs are not included in the costs estimated in this report for disposition.