Martin Letourneau, Jay Rhoderick
U.S. DOE

Carol Crockett
SAIC

DOE and in particular the Office of Environmental Management (EM) currently has an unprecedented quality and breath of data concerning its LLW and MLLW volumes and types, facility capacities, management costs, and impacts of alternative management schemes. Through the LLW Disposal Capacity Report, EM learned that the existing and future capacities for LLW and MLLW disposal in the public and private sectors may offer sufficient capacity to manage all current and projected DOE LLW and MLLW. Through the WM PEIS, DOE learned what sites have the best conditions to support regionalized and consolidated disposal options. Through its recently completed cost study, EM learned what sites offer the lowest cost management alternatives and the volume of waste that is necessary to capitalize on the economies of scale inherent to disposal operations to bring unit costs down to a level that is competitive with the commercial sector for LLW and MLLW disposal. This paper explores the relationship of these dynamics and sets forth (1) a strategy for right-sizing the DOE LLW and MLLW disposal complex, (2) an appropriate mix of public and private services, given waste types, their associated hazards, and management needs, and (3) establishes the potential cost savings associated with implementation of such an approach to using LLW and MLLW disposal services.

One of the goals of the Waste Management Program at the Department of Energy (DOE) is to make life-cycle decisions concerning its complex-wide configuration of facilities for disposal of low-level waste (LLW) and mixed low-level waste (MLLW) in a manner that is protective of the public, worker health and safety, and the environment. In addition, DOE's LLW and MLLW disposal configuration must: maintain compliance with applicable laws and regulations; promote competition, when appropriate, to increase flexibility and reduce costs; ensure utilization of the correct mix of resources, including both Federal and commercial waste disposal services; aid in reducing DOE's mortgage; and support meeting the goals of the 2006 Plan. DOE's decision making must also reflect the concerns of stakeholders and citizens and balance cross-site issues such as risk, economic impact, and equity.

Numerous studies and analyses of LLW/MLLW generation, treatment, and disposal have been conducted by DOE in recent years. DOE truly has an unprecedented breadth and quality of data right now concerning its LLW and MLLW volumes and types, facility capacities, management costs, and needs. Based on this information, DOE can make an optimization decision about its complex-wide disposal configuration. However, the data and knowledge gained from these studies must be synthesized in order to identify both an optimum waste disposal strategy that meets the Department's goals and the barriers that may exist for implementing that strategy.

The Records of Decision (RODs) that will be issued over the next year for LLW and MLLW disposal decisions under the Waste Management Programmatic Environmental Impact Statement (WM PEIS) will document the ultimate configuration decisions. Between now and the issuance of the RODs, DOE will engage in analysis and discussions about how these factors and considerations should be balanced in the decision making process. The issues discussed in this paper focus primarily on the economics and analytics of optimizing the LLW and MLLW disposal configuration. Such optimization is an ideal goal, but one that may not be achievable when other factors and equity issues are factored in. The conclusions presented here address the strategies that can be applied to optimize the configuration, the appropriate mix of DOE facilities, the potential role of commercial facilities, and the potential cost savings from an optimized configuration.

It has been DOE's policy to dispose of its LLW at DOE sites since 1979. Prior to 1979, DOE routinely used commercial LLW disposal facilities to dispose of some of its low activity LLW, initially to help support the development of commercial facilities and for waste from some DOE sites which did not have on-site disposal capability. Between 1975 and 1978, three of the existing commercial low-level waste disposal facilities in the U.S. experienced operational problems and were required to shut down. State governments began to pay more attention to the three remaining sites in Beatty, Nevada; Barnwell, South Carolina; and Richland, Washington. Following the Three Mile Island accident in March 1979, a series of incidents involving improperly managed waste and other operational concerns resulted in the Governors of the States hosting these facilities ordering shut downs of the facilities and imposing restrictions to ensure that their states would not become the de facto radioactive waste dumps for the nation.

In 1979, DOE adopted the policy of disposing its LLW primarily at DOE sites to ensure capacity would exist as to not disrupt its defense production mission and to limit liability. Subsequently, DOE ensured continued development of LLW disposal facilities at six DOE sites: Hanford, Idaho National Engineering and Environmental Laboratory (INEEL), Los Alamos National Laboratory (LANL), Nevada Test Site (NTS), Oak Ridge Reservation (ORR), and Savannah River Site (SRS). In the 1980's, DOE developed plans to also locate MLLW disposal facilities at these sites. To date, however, only two MLLW disposal facilities have been developed, at Hanford and NTS, and neither is currently operating for disposal of MLLW from other sites within the complex.

Only recently has DOE began using commercial facilities again for disposal of LLW and MLLW. Recent use of commercial facilities has been primarily limited to high-volume, low-activity LLW generated by the Environmental Restoration program and MLLW for which there has been limited disposal capacity at DOE sites.

As noted above, DOE's policy (per DOE Order 5820.2A) is to dispose of DOE LLW and MLLW at the site where it is generated, if practical, or if on-site disposal is not available, at another DOE site. However, the Order allows exemptions from this requirement. Subsequent DOE policy (Alm, 1996) establishes that the use of a non-DOE disposal facility shall be evaluated on a case-by-case basis and establishes criteria that must be met for exemptions to the Order. DOE's policy continues to be a preference for disposing of DOE waste at DOE sites; however, the policy also recognizes that use of non-DOE disposal capability may under certain circumstances provide a cost-effective disposal option that is in the best interest of DOE and its stakeholders.

As discussed above, DOE Policy has been to use DOE capacity for disposal of its LLW and MLLW. To date, the six DOE disposal facilities at Hanford, INEEL, LANL, NTS, ORR, and SRS have provided the primary DOE disposal capacity. However, as noted, non-DOE (commercial) facilities have played an increasing role. Additionally, the shift in emphasis to clean up and decommissioning has created greater emphasis on development of on-site restoration disposal as an alternative to transporting very large volumes of relatively low-activity wastes.

Cumulatively, DOE has disposed of 3 million cubic meters of LLW from DOE operations in disposal facilities at DOE sites and has sent approximately 200,000 cubic meters of LLW to commercial facilities. In 1997, DOE disposed of approximately 40,000 cubic meters of LLW from DOE operations at its six operating disposal facilities in the following proportions: Hanford, 28 percent; INEEL, 12 percent; LANL, 17 percent; NTS, 15 percent; ORR, 1 percent; and SRS, 27 percent.

Although the Department currently generates LLW at more than 36 sites, six sites or programs account for approximately 90 percent of the LLW generated by DOE sites. These sites include Hanford, Idaho, Los Alamos, the Naval Reactors Program, Oak Ridge, and Savannah River. The majority of DOE sites which do not possess disposal facilities transport their LLW to either Hanford (non-defense waste) or NTS (defense waste) for disposal.

To date, DOE has disposed of approximately 40,000 cubic meters of MLLW from DOE operations, primarily at commercial facilities. As noted, while DOE planned to develop MLLW disposal facilities at each of the six sites currently disposing of LLW, only two MLLW disposal facilities have been developed. The two MLLW disposal facilities, at Hanford and NTS, are not currently operating for disposal of MLLW from other sites within the complex. Until MLLW disposal decisions are made through the WM PEIS RODs, most DOE MLLW will continue to be treated and then stored on-site until disposal capacity is available.

DOE currently generates, stores, or expects to generate approximately 200,000 cubic meters (life-cycle) of MLLW at 39 sites in 19 states. Greater than 90 percent of this inventory of MLLW is stored at 7 sites: Hanford, INEEL, ORR, Portsmouth, Rocky Flats, and SRS.

Through DOE's Environmental Restoration Program, over 1.2 million cubic meters of LLW and MLLW have been disposed at various sites. Approximately 500,000 cubic meters of this waste has been transferred to the Waste Management Program for disposal in one of the six operations disposal facilities. Approximately 250,000 cubic meters, primarily high-volume low-activity wastes such as contaminated soils, have been disposed at commercial facilities. The remainder, primarily contaminated soils and rubble, has been disposed at restoration sites either through the cleanup process or in restoration disposal cells.

Under the Environmental Restoration Program, two restoration disposal cells have been constructed to date, at Hanford and Fernald, solely for disposal of wastes from clean up activities at those sites. These facilities are designed and sited under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and are designed to accept the full volume of environmental restoration LLW from on-site clean up activities. Waste generated by these projects that exceed the on-site disposal facility radiological parameters is shipped to other facilities for disposal. Plans for additional restoration disposal cells are also being discussed at other DOE sites.

Beginning early in the 1990's, DOE's defense production activities steadily decreased while the focus on cleanup increased. Consequently, the sources and types of waste now being generated have shifted from waste management supporting operations to environmental restoration and decommissioning. While the precise volumes and types of waste to be generated from environmental restoration activities is difficult to predict, the overall needs of the LLW and MLLW disposal are much clearer now due to recent emphasis on planning and projections.

In response to Defense Nuclear Facilities Safety Board (DNFSB) Recommendation 94-2, DOE has implemented an ongoing process for systematically evaluating projected waste volumes against existing and planned disposal capacity. DOE's Current and Planned Low-Level Waste Disposal Capacity Report (DOE[b], 1997) evaluates the adequacy of the Department's LLW disposal capacity. The analysis compares projected LLW volumes from waste management and environmental restoration activities at each site against DOE's existing and planned LLW disposal facilities through 2030. In addition to volume, the projected or known radiological content of the waste is compared to the waste acceptance and source term limits of the facilities to determine an overall radiological capacity, which could be less than the volumetric capacity (Waters, 1996).

Based on this analysis, it is expected that approximately 12 million cubic meters LLW and approximately 810,000 cubic meters MLLW will be generated from the Waste Management and Environmental Restoration programs that will require disposal. Including restoration disposal cells, existing and planned DOE capacity for disposal at DOE sites is expected to be over 12 million cubic meters for LLW and over 1 million cubic meters for MLLW. As a result, DOE has concluded that sufficient capacity will exist at DOE sites to dispose of all LLW and MLLW projected to be generated.

As discussed above, DOE projects that over their lifetime cleanup activities and ongoing missions will generate approximately 12 million cubic meters of LLW and 810,000 cubic meters of MLLW. Of this total, stabilization and deactivation activities performed by the Nuclear Materials and Facility Stabilization program will generate approximately 100,000 cubic meters of LLW and 32,000 cubic meters of MLLW. Remediation and decommissioning activities performed by the Environmental Restoration program are expected to generate approximately 9.8 million cubic meters of LLW and 460,000 cubic meters of MLLW. Other DOE missions (e.g., Defense Programs, Energy Research, Nuclear Energy, and the Naval Nuclear Propulsion Program) as well as the Waste Management Program will generate approximately 1.8 million cubic meters of LLW and 220,000 cubic meters of MLLW. The Waste Management program is also responsible for the final disposition of approximately 170,000 cubic meters of legacy LLW and 100,000 cubic meters of legacy MLLW in storage.

Treatment, storage, and disposal of MLLW and LLW is examined in the Final Waste Management Environmental Impact Statement for Managing, Treatment, Storage, and Disposal of Radioactive and Hazardous Waste (DOE[a], 1997). The WM PEIS considers alternatives within four broad categories: no action, decentralized, regionalized, and centralized. The decentralized alternative considers disposal at a number of major sites where LLW is located or could be generated in the future. The centralized alternative considers consolidating LLW disposal at one major site. The regionalized alternative considers consolidating LLW disposal at a number of facilities fewer than the decentralized alternative but greater than the centralized alternative.

The impacts of LLW and MLLW disposal were evaluated across all the LLW alternatives to identify trends and ultimately a preferred alternative. The regionalized alternative is identified in the WM PEIS as the preferred alternative for LLW and MLLW disposal, meaning that two or three sites may be selected from the following six: Hanford, INEEL LANL, NTS, ORR, and SRS.

The conclusions of the PEIS analysis were of a general nature, but illustrative of the decisions to be made by DOE regarding LLW and MLLW disposal configurations. First, at a national level, costs, risks, and impacts would be greater for a policy of volume reducing waste prior to disposal than a policy of applying treatment only as needed. Transportation costs are substantially lower than facility costs, making shipment to other sites generally less expensive than building new on-site facilities. The greatest risk posed by the management of LLW is to workers involved in management and transportation activities, primarily as a result of physical hazards. Centralized disposal would result in transportation of large amounts of waste with commensurately greater risk, and may not be flexible enough to support program needs. Costs decrease as the number of disposal sites decreases, and rail transport also has lower overall risks and impacts that truck transport; of the six existing disposal sites only Hanford, INEEL, and SRS have rail access. Finally, some sites may not be able to dispose of all kinds of waste due to radiological limits.

The Performance Evaluation of the Technical Capabilities of DOE Sites for Disposal of Mixed Low-Level Waste was used in both the capacity report and cost study. The purpose of the analysis was to quantify and compare the potential disposal capabilities of 15 DOE sites. The study analyzed the groundwater, air, and inadvertent human intrusion pathways for 15 DOE sites to estimate the permissible concentration limits for each site.

The Performance Evaluation study concluded that all 15 DOE sites have the technical capability to dispose of some radioactive materials, however, the technical capabilities of each differ. For most radionuclides, inadvertent human intrusion and the resulting estimated concentration limits were more important than other pathways and limits (groundwater, air), particularly for arid sites. For humid sites, the estimated concentration limits were driven by the groundwater pathway. For short-lived radionuclides, however, the groundwater pathway was often not important because the travel time to the compliance boundary was greater by an order of magnitude than the half-life of the radionuclide. Additionally, engineered barriers were found to provide no significant long-term advantages for the disposal of wastes containing longer-lived radionuclides, but did for shorter-lived radionuclides. Comparing the estimates of maximum permissible waste concentrations derived from the Performance Evaluation study with the estimates of concentrations of radionuclides in LLW and MLLW indicates that 90 percent of the LLW and MLLW could be disposed of at arid sites and approximately 50 percent could be disposed at humid sites.

In considering potential configuration decisions and implementation of the 2006 Plan, DOE commissioned studies to look at the drivers behind disposal costs and to better understand how configuration decisions may affect overall costs. As discussed below, these reports have provided additional insights into how DOE can optimize its LLW and MLLW disposal configuration.

The objective of the Low-Level Waste Disposal Cost Comparison Report (DOE, 1997) was to estimate and compare the costs to DOE sites of LLW disposal, including the costs of operating disposal facilities and costs borne by generators to prepare waste for disposal.

The study concluded that generator costs for preparing and certifying waste for disposal at DOE facilities is often higher than the unit cost charged by the disposal facility for disposal. A large portion of the total cost of disposal, possibly as much as 60 percent is associated with generator packaging, certification, and acceptance costs. Of the costs associated with the disposal facilities alone, fixed costs represent approximately 71 percent of the total DOE disposal program costs projected for FY 1998, with the remaining 29 percent representing variable operations and maintenance costs.

In general, the unit cost per volume disposed was lowest at facilities with the largest volumes of LLW disposed, demonstrating the economies of scale. The type of disposal facility (trench vs. engineered vault) was also a driver of unit cost, which is closely linked with site geology, climate, and other site-specific factors. Special waste characteristics (activity/shielding, remote handling) also affected unit cost. The unit costs at environmental restoration disposal facilities are generally lower than operations waste facilities because: (1) higher disposal volumes at which result in lower unit costs; and (2) larger percentages of bulk wastes, reducing packaging and handling costs.

The second cost study, the LLW Disposal Configuration Cost Analysis (DOE, 1997), evaluated on a complex-wide basis the total cost to DOE of LLW and MLLW disposal for the current configuration of six operations disposal facilities (Hanford, INEEL, LANL, NTS, ORR, SRS) and two environmental restoration disposal facilities (Hanford and Fernald). The analysis estimated the complex-wide total cost to DOE for the current disposal configuration and compared that cost to alternative disposal configurations. The scenarios evaluated consisted of: continued operation of all six operations disposal facilities; consolidation of disposal at fewer sites; and consolidation at one site, encompassing the range of alternatives analyzed in the WM PEIS.

The results of the study indicated that while some sites are costly to operate, (e.g., humid sites, engineered facilities, small volumes disposed annually), the largest portion of cost for most sites has already been invested in the siting, design, and construction of the facilities. Therefore, it may make sense to exhaust existing capacity at these sites, but not expand them once existing capacity is used. Additionally, while a smaller number of sites overall would have a lower operating cost, most sites reported significant costs associated with suspending use of their existing facilities and/or bearing the additional costs of certification, packaging, and transportation to another site, which reduce the potential savings from an optimized disposal configuration.

Based on the study, cost savings may be as little as $100 million over the lifetime of a $1.2 billion complex-wide disposal program, or as high as $500 million. Whether cost savings are at the high or low end of this range depends greatly upon DOE's ability reduce costs of closing on-site facilities and costs of switching to off-site facilities.

Key to optimizing any market, industry, or provision of a good or service is the economics of the particular activity. As discussed below, the economics of waste disposal are unique and must be carefully considered before configuration decisions can be accurately made.

Economies of scale exist wherever the marginal cost of providing a good or service is very low beyond the initial investment, or the initial investment is very high relative to the subsequent operational costs. In the long run, the price charged for a good or service must recover all of these costs in order to break even. In such cases, the total cost of the service, much of which is fixed cost, is spread over the total number of units of the good or service expected to be sold during the lifetime of the enterprise. If the resulting price that would be charged is higher than the market will bear or higher than what competitors are charging, then either cost must be further reduced or the number of units of the good or service sold must be increased. As noted, however, where economies of scale exist, the largest portions of cost are fixed and largely already invested when provision of the good or service actually begins. Such economies of scale are traditionally associated with capital and infrastructure intensive enterprises, such as railroads, electricity, and local telephone service.

Disposal of LLW and MLLW exhibits economies of scale both within the DOE complex and in the commercial sector. In both cases, siting, design, construction, and authorization (licensing) of disposal facilities may cost $100 million or more. To achieve a unit cost of $10 per cubic foot, such a facility would need to be guaranteed of disposing of 10 million cubic feet of waste over its lifetime just to break even. As such, an economically sensible configuration of DOE LLW and MLLW disposal sites should not have a total disposal capacity, for which significant fixed costs have already been paid, in excess of the total volume of waste expected to be generated. Likewise, siting and construction of new facilities in excess of expected volumes would not be economically sound.

Competition is often cited as the ultimate weapon for reducing cost; an increase in supply of a good or service drives the cost down and purchasers of the good or service will be able to buy disposal more cheaply. This classic law of supply and demand and the introduction of competition works well under textbook conditions, but not always so in the real world. In order for competition and an increase in supply to work as the economic theory suggests, certain conditions must exist. If those conditions are not evident, then the laws of supply and demand and the introduction of competition may not be able achieve the optimal or lower costs described.

Among the most important conditions of competition are: (1) the presence of enough suppliers and demanders that no one buyer/seller's actions can affect the overall price; (2) barriers to entry in the market are small or non-existent and mobility in and out of the market is easy; (3) significant economies of scale do not operate in the market; (4) transaction costs are minimal; and (5) all participants in the market have access to adequate information about market factors.

As evidenced elsewhere in this paper, many of these conditions do not exist. There are few suppliers of disposal capacity and a few large generators account for large percentages of the total volumes of waste to be disposed. The action of any one generator to ship waste to another facility reduces the unit cost of all waste sent to that facility. Barriers to entry in the market are high, including ownership of adequate acreage of acceptable conditions for a disposal facility, authorization and licensing, design, and construction activities totaling as much as $100 million. Significant economies of scale do exist. Transaction costs do exist for meeting the waste acceptance criteria of a different disposal facility. Information, particularly about what actual future volumes of waste will be or when disposal capacity will be needed is generally not adequate. Therefore, the classic role of supply and demand and introduction of competition cannot be expected to work well with regards to disposal of LLW and MLLW.

However, there is still a role for competition in the market for LLW and MLLW disposal services, including within DOE. As long as the total supply of capacity and expected volumes of waste requiring disposal are close to equilibrium, then competition between existing disposal service providers, whether commercial, DOE, or both, can provide the impetus for continued, aggressive, and innovative cost control. While most costs are fixed and already committed, the generator borne costs associated with preparing waste for shipment, packaging, certification, and transportation can be kept in check through competition. If several facilities are operating at roughly the same investment and operating cost levels, and receive similar volumes of waste, then a reduction in effort required to ship waste or cost associated with preparing waste for shipment to one facility can be the discriminator that drives decision making. Therefore, such competition can drive cost control efforts, particularly within DOE. However, if the market is in equilibrium, the addition of new facilities and capacities could result in excess capacity relative to projected volumes requiring disposal. Because of economies of scale, higher unit costs would result by reducing the volume of waste going to each facility.

The final economic factor to be considered in optimizing LLW and MLLW disposal is that of market definition. While a market may appear to be very large, it may in fact be composed of market segments that do not compete with each other.

One of the best illustrations of market definition is the sale and purchase of automobiles. The purchaser of a Mercedes is not likely to be in the same "market" as the purchaser of a Yugo. While both are purchasing cars, the Yugo buyer may not be able financially to consider the Mercedes. The Mercedes buyer is also not likely to consider the Yugo to be a reasonable alternative. Likewise, the seller of the Mercedes is not concerned that his product is over priced relative to the Yugo.

It is necessary therefore to explore whether the configuration we seek to optimize operates within a single market or whether there may be separate market segments. Is disposal of LLW and MLLW from DOE operations in the same market as disposal of environmental restoration waste? Are commercial and DOE disposal facilities part of the same market for disposal of these wastes?

Unique attributes often clarify whether two seemingly similar activities occur within the same market or not. For example, DOE disposes of approximately 40,000 cubic meters of LLW from operations activities annually, while the volume of waste generated by a single environmental restoration activity may be greater than 100,000 cubic meters. Waste generated from DOE operations tends to include a range of radionuclides exhibiting a range of characteristics at medium to high concentrations, while waste from environmental restoration activities often consists of soil or rubble contaminated with very low concentrations of long-lived radionuclides. While volumes of waste to be generated by DOE missions can be predicted with relative precision, given ongoing and expected missions, the actual amount or type of waste to be generated by environmental restoration activities cannot usually be predicted accurately until the precise form and extent of contamination is known and remedial actions to address it have been selected. Can one "market" or configuration of disposal facilities serve equally well the needs of both operations waste generators and environmental restoration waste generators? Maybe not. Could a single LLW and MLLW disposal system be created that is optimally configured and that can expand or contract as needed to meet both needs? Probably not.

Having presented and considered each of the sources of information and studies discussed above, a number of messages are evident. While not themselves optimization strategies, these findings move us closer to an overall strategy for optimization of the DOE LLW and MLLW disposal configuration.

Historically, DOE used commercial facilities for LLW and MLLW disposal, but currently only uses regional (non-compact) commercial facilities by exception for small volumes of waste or unique situations such as some environmental restoration wastes. DOE has LLW and MLLW disposal sites with a total disposal capacity greater than the total volume of wastes expected to be generated. Including limited use of commercial facilities and development of additional environmental restoration cells, LLW and MLLW disposal capacity is clearly adequate, and development of new capacity is not needed. Some of the existing facilities, however, operate at a much higher cost and should either be closed or not expanded once existing capacity is used. Waste would then be shipped to a smaller number of sites that have better cost and performance attributes and lower costs, and further reduce costs through economies of scale. To the extent possible, shipments using rail transport would reduce costs and risks. In order to further reduce costs, DOE must find ways to reduce generator costs associated with preparing waste for disposal, and competition amongst existing DOE and commercial disposal operators may provide the impetus for cost control. However, addition of new capacity through competition does not appear to be needed, and could result in excess capacity and higher costs.

These findings are not, however, without caveats. As noted earlier, a configuration based on these concepts may be an optimal ideal, but may not be achievable when other equity and stakeholder concerns are considered. Certainly if such optimization efforts are to be successful, then stakeholder and equity concerns must be considered. Changes in regulations may also impact such efforts in either a positive or negative manner. Differences between requested and appropriated budget allocation may require modifications.

Having set forth the themes and findings of our analysis, the answers to the following questions summarize our recommended strategy for "right-sizing" the DOE LLW and MLLW disposal configuration, the appropriate role of commercial capacity, and the expected overall cost savings.

First, DOE needs to ensure that disposal capacity is indeed in equilibrium with projected needs. Assuming it is, DOE should examine all its existing capacity and facilities and determine whether it is cost effective to close any facilities immediately. Next, DOE should determine which facilities should not be expanded once existing capacities are used, and focus on the lower cost facilities with the best performance capabilities to be regional disposal sites. Commercial facilities should still be available for unique situations, but DOE should emphasize use of its own facilities to an even greater extent. Better forecasting, flow control, and commitments from generator facilities will allow disposal facilities to provide much lower prices due to greater volumes and reduced uncertainties. Likewise, efforts by disposal facilities to help reduce the costs imposed on generators to prepare waste for disposal will make such facilities more attractive to DOE generators, including environmental restoration. While DOE LLW and MLLW disposal capacities cannot and probably should not try to expand to meet the demand of all environmental restoration activities, it does appear that adequate capacity exists for environmental restoration waste that is shipped off site for disposal. Development of on-site environmental restoration cells for disposal of the remaining large volumes of lower activity environmental restoration wastes is appropriate.

There will always be a role for commercial facilities in disposing of DOE LLW and MLLW. However, that role should be a small one. Will there be DOE waste that makes sense from an economics, risk, and equity perspective to send to commercial disposal? Yes. However, given an optimized DOE disposal configuration, such circumstances should be rare. Additionally, DOE has always kept control of higher activity wastes at DOE sites, and should probably continue to do so in the future. For situations where commercial disposal is more appropriate and economical, it is expected that low-activity wastes such as those generated by the Environmental Restoration program may be involved.

Frankly, it is hard to say without more information, but based on DOE studies, the overall cost savings may be as little as $100 million over the lifetime of a $1.2 billion program, if generator costs remain high and there are back-end costs associated with closures. Alternatively, the costs savings could be as much as $500 million if DOE is successful in taking the actions that will reduce costs to generators.

1. U.S. DOE, "Radioactive Waste Management," DOE Order 5820.2A (September 1988).
2. A. ALM, Memorandum to Operations Managers, "Delegation of Authority to Grant Exemptions to Department of Energy Order 5820.2A to Allow the Use of Commercial facilities for Disposal of Department of Energy Low-Level Waste" (October 24, 1996).
3. U.S. DOE, "Final Waste Management Programmatic Environmental Impact Statement for Managing Treatment, Storage, and Disposal of Radioactive and Hazardous Waste," DOE/EIS-0200-F, Office of Waste Management (May 1997).
4. WATERS, GRUEBEL, ET AL, "Performance Evaluation of the Technical Capabilities of DOE Sites for Disposal of Mixed Low-Level Waste," DOE/ID-10521/1, SAND96-0721/1-UC-2020 (March 1996).
5. U.S. DOE, "The Current and Planned Low-Level Waste Disposal Capacity Report," Draft, Revision 1, Office of Waste Management (September 1997).
6. U.S. DOE, "Low-Level Waste Disposal Cost Comparison Report," Office of Waste Management (July 1997).
7. D. F. KETTL, "Sharing Power: Public Governance and Private Markets," (1993).
8. U.S OMB, "Enhancing Governmental Productivity through Competition: A New Way of Doing Business within the Government to Provide Quality Government at Least Cost," (August 1988).

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