Dr. E. J. Bentz, Jr., C. B. Bentz, and T. D. O'Hora
E. J. Bentz & Associates, Inc.
Alexandria, Virginia

This paper provides interim findings developed by E. J. Bentz & Associates as a member of the Nevada Risk Assessment/Management Program (NRAMP) regarding the volumes of low-level radioactive waste (LLW) and mixed low-level radioactive waste (MLLW) which have been projected for disposal at the Nevada Test Site (NTS) by recent DOE reports. This analysis was undertaken in response to a request from the Community Advisory Board for Nevada Test Site Programs relevant to risk-related waste disposal issues among DOE Weapons Complex sites. Additional finding are being developed regarding the characterization of such wastes.

Recent DOE Reports. The primary sources of data for LLW and MLLW volumes projected for disposal at the NTS are six recent DOE reports. Each of these reports was developed to address a different programmatic requirement or issue relevant to DOE’s Environmental Management (EM) program. Hence, each report utilizes its own unique set of programmatic and technical assumptions, depending upon its particular purpose. All of the reports were published during the years 1996 and 1997. The following are brief descriptions of these reports and their respective purposes:

The 1996 Baseline Environmental Management Report (BEMR), June, 1996¹, is a report mandated by Federal law (the 1994 and 1995 Defense Authorization Acts), which provides a total life-cycle cost estimate and anticipated schedule for the projects and activities necessary to carry out the DOE EM program's missions. The 1996 BEMR "Base Case" represents a long-range projection of activities, schedules, and associated costs that fully describe the EM program as of October, 1995, from its then-current state to anticipated completion in 2070, based on compliance with pertinent laws, regulations, and agreements. The 1996 BEMR waste volume data represent the estimated waste either currently in inventory or anticipated to be generated while performing projected activities. Waste volumes are estimated on an annual basis from 1996 through 2070.

The Current and Planned Low-Level Waste Disposal Capacity Report (LLWDCR), Revision 0, July, 1996², was prepared as DOE's first step toward establishing a uniform program for forecasting LLW disposal needs in response to the Defense Nuclear Facilities Safety Board's (DNFSB) Recommendation 94-2 regarding DOE's low-level waste disposal practices. The report provides life cycle volumetric projections of DOE LLW by originating site and program (Waste Management, Environmental Restoration, and Nuclear Material and Facility Stabilization), provides anticipated disposal sites, and provides comparisons of its projected volumes with estimates of the current and planned capacities at anticipated DOE disposal facilities. In addition, the report provides life cycle volumetric projections of DOE MLLW, but provides no site-specific breakdown for Waste Management program MLLW generation, and no information on anticipated MLLW disposal sites and capacities.

The Final Waste Management Programmatic Environmental Impact Statement (WM PEIS), May, 1997³, is a nationwide study which examines the environmental impacts of DOE's management of more than two million cubic meters of radioactive and hazardous wastes from past and anticipated DOE activities (anticipated over 20 years). The WM PEIS identifies and analyzes several waste management and disposal alternatives for each waste type, including LLW and MLLW. The WM PEIS analyzes 14 alternatives for the disposal of LLW within the four broad categories: No Action, Decentralized, Regionalized, and Centralized. Six of the alternatives (No Action; Regionalized 3, 4, 5, and 7; and Centralized 2) anticipate the shipment of some LLW from off-site to the NTS for disposal. Seven alternatives are analyzed for the disposal of MLLW within the four broad categories: No Action, Decentralized, Regionalized, and Centralized. Three of these alternatives would result in the shipment of some MLLW from off-site to the NTS for disposal.

The Final Environmental Impact Statement for the Nevada Test Site and Off-Site Locations in the State of Nevada (NTS EIS), August, 1996⁴, is a site-wide programmatic EIS that analyzes the existing and potential environmental impacts that have resulted, or could result from, current and future DOE operations in Nevada during the 10-year period beginning in 1996. The EIS analyzes four alternatives relative to future radioactive waste management activities at the NTS: No Action, Expanded Use, Closure, and Alternate Use of the Withdrawn Land. Under the No Action Alternative, the NTS would continue to accept LLW from 15 currentlyapproved, off-site generators. Under the Expanded Use Alternative, waste shipments would be accepted from approximately 28 off-site waste generators. Under the other alternatives, the NTS would not accept shipments of off-site waste for disposal.

The Draft Accelerated Plans, February, 1997, are site-specific plans to implement a current, DOE-wide strategy to improve productivity and accelerate site clean-up, with a particular focus on completing clean-up at as many sites as possible by 2006. The Draft Accelerated Plans provide site-specific projected volumes of LLW and MLLW to be generated as well as volumes to be transferred to other specified sites for treatment or disposal under the accelerated strategy.

A Contractor Report to the Department of Energy on Environmental Management Baseline Programs and Integration Opportunities (Discussion Draft) (Contractor Report), May, 1997⁵, is the result of a DOE-chartered effort by a complex-wide Integration Team of EM program site contractors to develop technically defensible opportunities for additional acceleration of clean-up and cost savings beyond those provided by the Draft Accelerated Plans. The study was limited to eleven major DOE sites. The "enhanced baseline" data in the report was based on the Draft Accelerated Plans scenarios, adjusted to reconcile data gaps and inconsistencies among sites. Graphical depictions of proposed plans by site and by waste type are provided from current state to final waste disposition. The flow diagrams generally provide data on current, projected, and total initial volumes by waste stream description and identification number; proposed treatment and treatment site (if any); disposal volumes; and anticipated disposal sites.

Databases Underlying the DOE Reports. Several additional sources of data regarding DOE LLW and MLLW inventories and volume projections are identified and referenced in the DOE reports described above, including the 1995 Integrated Data Base (IDB) Report, the 1996 Baseline Environmental Management Report (BEMR) Data Set, the EM-40 Core Database, the 1995 Mixed Waste Inventory Report (MWIR) Database, and the Site Treatment Plans (STP) Database. These databases provide the most current and detailed data available regarding DOE LLW and MLLW inventories and projections. Various vintages of these databases provided some or all of the source data for the reports described above. Figure 1 depicts the general relationship of these databases to DOE reports projecting LLW and MLLW disposal at the NTS; following are brief descriptions of the databases.

The 1995 Integrated Data Base (IDB) Report (as of December 31, 1995)⁶ contains data that has been assembled as part of the Integrated Data Base Program at DOE's Oak Ridge National Laboratory. The IDB data for non-Environmental Restoration (ER) program LLW inventories and projections was derived from information supplied in response to site-specific questionnaires. Annual LLW projection rates for the 1995 IDB are provided for three time periods: 1996, 1997-2001, and 2002-2030. Volume and total gross activity data are currently provided for each site by waste physical form. No further characterization of LLW is provided. The most current data available from the other databases discussed below is integrated into the IDB as inventory and projected data for non-ER program MLLW and for ER program LLW and MLLW. Thus, the IDB is a composite database drawing from other DOE databases (discussed below).

The 1996 BEMR Data Set (as of October, 1995)⁷ was developed to support the data collection and review process required for the 1996 BEMR; it contains the information that forms the basis for the BEMR "Base Case" estimate. Volume data represent the estimated waste either currently in inventory or anticipated to be generated while performing projected activities. LLW and MLLW volumes are estimated on an annual basis from 1996 through 2070. No characteristics of the waste streams are provided.

The EM-40 Core Database (Phase I: as of October, 1995)⁸, which is maintained by DOE's Office of Environmental Restoration, was developed to provide a centralized repository for key programmatic data. The Database serves as the primary source of information on waste streams and waste stream characteristics for volumes projected to be generated from ER program activities. The initial data call for the EM-40 Core Database began in August, 1995, and concentrated on the acquisition of data required by the 1996 BEMR. The Database includes waste volume totals reported at the installation level by the same waste classes as the BEMR (e.g. LLW, MLLW), grouped by medium category (environmental media, stored waste, or structures/equipment). In addition, data is available regarding the concentrations of contaminants associated with a specific waste stream. The EM-40 Core Database provides this information for both ER LLW and MLLW inventories and projections.

The 1995 National Mixed Waste Inventory Report (MWIR) Database (as of December 31, 1994)⁹, which is maintained by Lockheed Idaho Technologies Company for DOE's Office of Waste Management, contains a site-specific compilation of information on DOE mixed waste streams and treatment systems. The MWIR Database includes MLLW volumes currently in storage at EM-30 and EM-40 sites; and streams anticipated to be generated within the next 5 years from sources other than ER and D&D activities. The MLLW is characterized by the 152 Treatability Group Matrix Parameter Categories found in the DOE Waste Treatability Group Guidance¹⁰.

The Site Treatment Plans (STP) Database (as of June, 1996)¹¹, which is maintained by MACTEC for DOE's Office of Waste Management, is a site-specific compilation of DOE MLLW volumes, waste stream characteristics, and waste management plans developed and maintained in response to the requirements of RCRA, as amended by the Federal Facility Compliance Act. The STP Database includes volume data by waste type for inventories and projected 5-year generation of MLLW for each site, according to the 152 Treatability Group Matrix Parameter Categories found in the DOE Waste Treatability Group Guidance. The MWIR Database described above contains more detailed characterization information (e.g. radiological parameters and regulatory contaminant classifications) on DOE MLLW waste streams than does the STP Database. However, due to its role in the development of the STPs, the STP Database contains more detail on the planned management of MLLW by each site. This information does not include disposal site designation. Neither of the databases (STP or MWIR) contains data on key radionuclide isotope or curie content.

Due to funding constraints, neither the MWIR Database nor the STP Database has undergone any overall revision since 1995. However, DOE sites have continued to provide updates to the STP Database as part of ongoing efforts to finalize site STPs, per the requirements of the Federal Facility Compliance Act. The currentness of the data in the STP Database for the various DOE sites ranges from January, 1995 to June, 1996.

This analysis of LLW and MLLW volume projections focuses on the DOE reports described above rather than on the underlying databases. The reports provide specific projections of LLW and/or MLLW which may be shipped to the NTS for disposal, based on report-specific technical and programmatic assumptions and scenarios; as depicted on Figure 1, the underlying databases do not provide disposal site destinations.

A review of the projections reveals that there are significant differences among the reports in both site-specific and total projections of LLW and MLLW destined for disposal at the NTS. Maximum forecasts of off-site LLW destined for disposal at the NTS have ranged from 192,824 cubic meters to 2,386,004 cubic meters (see Figure 2). Forecasts of off-site MLLW destined for disposal at the NTS have ranged from zero to 414,114 cubic meters. These differences are at least partly attributable to several factors relevant to the development of projections by each report, including those summarized below.

Different Programmatic Assumptions. Reflecting emerging policy, the reports utilize significantly different programmatic assumptions on the extent and pace of originating-site clean-up. For example, the WM PEIS, BEMR, LLWDCR, and NTS EIS forecast site clean-up operations through the year 2070. The Draft Accelerated Plans and the Contractor Report assume accelerated site clean-up and, in many cases, different project end-states than those envisioned by the previous environmental management program baselines.

Different Technical Assumptions. The reports vary with respect to technical assumptions regarding pre-treatment of waste and waste volume reduction. The Contractor Report, which provides volumes by waste stream descriptions and identification numbers, also provides projected treatments for the wastes and resulting, after-treatment disposal volumes. The materials inflows and outflows (for treatment and disposal) provided in the Draft Accelerated Plans also generally account for the effects of treatment on LLW and MLLW disposal volumes. However, none of the other identified reports address the potential effects of treatment on projected disposal volumes. (The WM PEIS generically considers LLW and MLLW treatment in its environmental impacts analysis; no adjustment is made in volume projections to account for the effects of treatment).

Different Underlying Databases. The reports utilize different data sources and different vintages of source data:

The 1997 WM PEIS uses the 1992 IDB as the primary source of LLW projections; updated LLW projections derived from the more current, 1994 IDB are used for five sites. The 1994 MWIR is the source of data for WM program MLLW projections, except for Colonie, ETEC, and RFETS, which use late-1994 site estimates; and except for ANL-East and the NTS, which use data from the 1995 MWIR. Projections of ER program LLW and MLLW are derived from the EM-40 Core Database.

The 1996 BEMR Data Set was developed from a document-specific data call.

The 1996 LLWDCR uses the 1994 IDB as the source of data for the WM LLW inventory and projections to 2030, and the 1996 BEMR as the source for LLW projections for the period 2031-2070. The 1995 MWIR is the source of data for WM MLLW projections through 2000, and the 1996 BEMR serves as the source of WM MLLW projections for the period 2000-2070. Projections of ER program volumes of LLW and MLLW are derived from the EM-40 Core Database.

The Draft Accelerated Plans volumes data was developed by each site during the 1996-97 time period specifically to support development of the National Discussion Draft Accelerated Plan¹².

The 1997 Contractor Report LLW and MLLW volumes data (for the enhanced baseline scenario) is based on the above data submitted to support development of the National Discussion Draft Accelerated Plan. However, that data has been adjusted to reconcile data gaps and inconsistencies among DOE sites.

The 1996 NTS EIS uses LLW and MLLW data from the 1994 IDB, the 1995 BEMR, and the Draft WM PEIS (1991 data). It is not clear how these sources are specifically utilized.

Different Forecast Periods. The waste generation forecast periods considered by the reports also vary, generally as a function of the purpose of the report. Due to its scope, the NTS EIS considers only NTS site operations occurring over a 10-year period. The WM PEIS considers only waste management operations projected to occur over the 20 years covered by its own analysis. The BEMR and the LLWDCR both project LLW and MLLW volumes from activities at all DOE sites through the year 2070. While the Draft Accelerated Plans and the Contractor Report are based on accelerated clean-up assumptions (over 10 years), the projections in these reports include additional LLW and MLLW generated by DOE sites through the year 2070 (under the Draft Accelerated Plan, some sites will continue to generate LLW and MLLW after ten years).

Different Numbers of Projected Generator Sites. Some significant differences in projections among the reports are attributable to currently-unapproved generator sites being included or not included. The reports vary from considering six generators currently approved for disposal of LLW at the NTS (the Contractor Report) to as many as 31 generators (the WM PEIS Centralized 2 Alternative). Figure 3 provides a summary of the number of originating sites assumed by each report (currently approved, additional sites, and total).

Under certain alternatives, such as the NTS EIS Preferred Alternative and the WM PEIS Centralized 2 Alternative, additional sites (not currently approved) such as Savannah River, INEEL, and Hanford are among the largest volume generators projected for NTS disposal. Table I provides a summary of the relative ranking of important generator sites according to their LLW disposal volumes projected by each of the identified reports.

* Denotes a generator site not currently approved for LLW disposal at the NTS.
SOURCE: E. J. Bentz & Associates from the referenced reports

Defense Nuclear Facilities Safety Board (DNFSB) Recommendation 94-2. Problems associated with historic DOE projections of LLW generation were officially recognized on September 8, 1994 by the Defense Nuclear Facilities Safety Board's (DNFSB) Recommendation 94-2, Conformance with Safety Standards at Department of Energy (DOE) Low-Level Nuclear Waste and Disposal Sites¹³. Recommendation 94-2 concluded that the DOE LLW management program had not kept pace with the evolution of commercial practices. Among the DOE LLW management deficiencies noted by the Board's summary findings was the inadequacy of historic, long-range LLW disposal projections. The Board specifically noted that:

The Board recommended that DOE conduct a complex-wide review to establish the dimensions of LLW management vulnerabilities and to identify necessary corrective actions to assure safe disposition of past, present, and future volumes of LLW. The Board specifically recommended that DOE develop a program to improve projections of LLW volumes anticipated to be generated by DOE activities.

DOE's complex-wide review resulted in the issuance of the Final Report Complex-Wide Review of DOE's Low-Level Waste Management ES&H Vulnerabilities¹⁴. This report identified inadequate forecasting of LLW generation, inadequate disposal capacity planning, and inadequacies in LLW characterization as primary, complex-wide vulnerabilities.

The DOE Low-Level Waste Projection Program. DOE's Implementation Plan¹⁵ for responding to Recommendation 94-2 has resulted in the development of the DOE Low-Level Waste Projection Program Guide¹⁶, which provides a standardized approach and methodology for developing low-level waste projections and for the improvement of projected data, beginning with a data call in FY97 for the years 1996-2006 and 2007-2030. The data developed for the FY97 data call will be included in the 1996 IDB and utilized in the development of Revision 1 of the Current and Planned Low-Level Waste Capacity Report, which at the time of this writing were expected to be released in January, 1998.

The above Guide requires each DOE field element responsible for low-level waste to implement a Low-Level Waste Projection Program in FY97. Projections must provide annual totals for years 1 through 10 and a single total for years 11 though 30. Projections may be assigned relative certainty levels by including maximum and minimum expected volumes with a baseline volume. A period of three projection cycles "may be allowed to fully meet data quality objectives" (to be developed with DOE Headquarters). It is expected that the quality of the data "for the first three years of the forecast period" should be reasonably high, and that the uncertainty of data will increase for more distant time periods.

The Guide specifies that the projections should include key isotopic and curie content information, and the physical/chemical form (matrix) of the LLW, using the 152 RCRA Treatability Group Matrix Parameter Categories defined in the DOE Waste Treatability Group Guidance. Radionuclide information may be limited to the controlling key radionuclides that present the highest potential for radiation exposure during handling, or that may present long-term risks to public health and safety or to the environment.

A Technical Directives Manual, to be developed in concert with the DOE's revision of Radioactive Waste Management, proposed DOE Order 435.1, will include LLW Projection Program requirements based upon key elements from the Guide. Drafts of the Manual and the Order are currently expected to be released for public comment in March, 1998.

There are significant differences in recent (1996-97) DOE reports in both the site-specific and the total projections of off-site LLW and MLLW destined for disposal at the NTS. Forecasts of total off-site LLW destined for disposal at the NTS have ranged from 192,824 cubic meters to 2,386,004 cubic meters. Forecasts of total off-site MLLW destined for disposal at the NTS have ranged from zero to 414,114 cubic meters.

Differences among the projections reflect differences among the reports which include:

• Significantly different programmatic assumptions on the extent and pace of originating-site clean-up, reflecting emerging policy;
• Significantly different technical assumptions concerning pre-treatment of waste and volume reduction; and
• Use of significantly different data sources, vintages of source data, and periods of forecast.

Differences among the projections are also attributable to the inclusion or non-inclusion of sites that are not currently approved to dispose of LLW/MLLW at the NTS; the reports vary from considering six currently-approved generators to considering as many as 31 waste generators.

The historic DOE LLW and MLLW forecasts have been undertaken with no uniform, DOE-wide guidance or methodology, and are beset with such uncertainties so as to provide little confidence in the currently-available data. Very little waste characterization data is currently available.

DOE's recently developed Low-Level Waste Projection Program Guide provides a new standardized approach and methodology for improving and developing LLW projections. Implementation of the new program should result in more uniform, accurate, and detailed projections (i.e., which include pertinent waste characteristics).

1. U.S. DOE, The 1996 Baseline Environmental Management Report, DOE/EM-0290, Office of Environmental Management (June 1996).
2. U.S. DOE, The Current and Planned Low-Level Waste Disposal Capacity Report, Revision 0 (July 1996).
3. U.S. DOE, Final Waste Management Programmatic Environmental Impact Statement, DOE/EIS 0200-F, Office of Environmental Management (May 1996).
4. U.S. DOE, Final Environmental Impact Statement for the Nevada Test Site and Off-Site Locations in the State of Nevada, DOE/EIS 0243, Nevada Operations Office (August 1996).
5. COMPLEX-WIDE EM INTEGRATION TEAM, A Contractor Report to the Department of Energy on Opportunities for Integration of Environmental Management Activities Across the Complex, INEL/EXT-97-00493 (May 1997).
6. U.S. DOE, Integrated Data Base Report - 1995: U.S. Spent Fuel and Radioactive Waste Inventories, Projections, and Characteristics, Revision 12, DOE/RW-006, Oak Ridge National Laboratory (December 1996).
7. U.S. DOE, The 1996 BEMR Data Distribution Software, Version 1, Office of Environmental Management (1996).
8. U.S. DOE, EM-40 Core Database, Phase I Approved Data, Office of Environmental Restoration, Office of Waste Management (May 1996).
9. U.S. DOE, National 1995 Mixed Waste Inventory Report Database, Office of Environmental Management (November 1995).
10. U.S. DOE, DOE Waste Treatability Group Guidance, Revision 0, DOE/LLW-217, Idaho National Engineering Laboratory (January 1995).
11. U.S. DOE, Site Treatment Plan Data Base, Office of Environmental Restoration, Office of Waste Management (updated through December 1996).
12. U.S. DOE, Accelerating Cleanup: Focus on 2006, Discussion Draft, Office of Environmental Management (June 1997).
13. DEFENSE NUCLEAR FACILITIES SAFETY BOARD, Recommendation 94-2, Conformance with Safety Standards at Department of Energy (DOE) Low-Level Nuclear Waste and Disposal Sites (September 1994).
14. U.S. DOE, Final Report Complex-Wide Review of DOE's Low-Level Waste Management ES&H Vulnerabilities, DOE/EM-0280, Office of Environmental Management (May 1996).
15. U.S. DOE, Implementation Plan, Defense Nuclear Facilities Safety Board Recommendation 94-2, Revision 1 (April 1996).
16. U.S. DOE, Low-Level Waste Projection Program Guide (December 1996).

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