Free Response to Motion - District Court of Federal Claims - federal

Case 1:98-cv-00126-JFM

Document 792-15

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nUCLEAR WASTE 'FUND FEE ADEQUACY I

AN ASSESSMEnT

July 1984

S. DEPARTMENT OF ENERG~

OFFICE orc IVIUAN RAIUOACTIVE WASTE
WASllmGTOI~, D. C.

MANAGEMEt'T

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n~TRODUCTIOIl Arm
'l'h1a is the sec' I re?Ort .!/ or an annIJal series that evaluates whetber the r?" .. Jes collecl:-d from the waste disposal fees

.eBtablishe. ..,

. 'Sp.ction 302 f the nuclear Waste Policy Act of 1982 (Public Law 97-425) Dre sufflcient to offset the Federal governraent ' 5 cos.ts for the t1isposalof commerchlly generated spent nuclear ruel (SNF) and high-level. radioactive waste. Nur.lear wastes produced from defense activities are not considered

in this report.
0 mill per
-0

The principal findintJs of this ye~r s analysis are noted below.

1tilowatt-hour (k.,hr) fee is The cu rrent 1. projected to produce revenues sufficient to offset total system H.fe cycle costs associatedwi. th the ca les ' specified l"tet" in the report, assumin() that the average annu-"l rate- of inflation does not exceed 2 to 3 percent.

Uigt.cr avc!l"Age annual rates

of inflation, or unanticipated real cost growth, would cause cumulative program costs to approach and then surpass cumulative revenues generated from the current 1. 0 mlll per kwhr fee.

Based on bn analysi8 of different inflAtion rates ~nd program cost growth projections discussed herein,. indexing of the . fee to correct for inflation would not need t obegin until 1985, at the earliest, ot"perhaps as

late (\$ the year 2000.

':hel" e . is substantial ,uncertainty about both the program cost and revenue projections. Ho~ever, more reliable data are expected to become available in the late 19808 ' as the prCXjt'aJI\ evolves froll its prGsent conceptual design

phase to . the engineering phase.
tha t

recommendation to raise the 1. 0 mill per kwhr fee before that time should be measured against the uncertainties

lienee, any.

attend the. present program.

BACJ(GROUND AltD l. eGAI. REOUIRE.1ENTS

The Act prescribed that the owners and Cje.. "rators

of commercially generated nuclear waste will pay the full costs of its disposal. The Act al~oesttlb1ished a Nuclear Waste Fund emiF) to ensure the full cost r~covery funding of a safe and environmentally acceptable program. This fund is composed of the revenue from an

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adju8table , tee .charged

quarterly for generated by commercial nucl~ar facilities be9innlng April 7, 1983, 8S well 8S a one-tirae fee, produce a total of $2. 3 billion, for nuclear waste produced prior ~o April 7, Revenues generated trom these two lources, 8. we.1l .a interest earnings accruing from the investment of Fund surpluses in U. S. '4'reasurysecurities, are deposited to the tMF, and disbursements are made as the program

aU electricity
1983.

uU..ted to

progresses.
ManagelHnt (OCRWH)

-8aaed on . the

resul'ts the adjusted, ifofnecessary.

The Act also created a new Office of Civilian Radioactive Waste under the u. s. Departnaent of Energy (DOC) to adainiater .. ~pUC' . oleprovisions of the legislation, including Section 302(aH that calls for an annual review of the adequacy of the wa8te disposal fees to' recover waste disposal program costs.
evaluation., the ongoing' fee

maybe

The analysis dlacu8sed' in this report examined both tho casts and

financing of the civilian n~clear waste management program described in noE s preliminary working draft Mission Plan 1983. However, the' H. ,slon Plan h as 81hce een revised ex'tenslvely in res ponse to nterna and PUbl ic commt: The. present= forlllal thf'. Hi,;slon Plan of Apt'! 1 1984

Dece~r

departs appreciably insevotal

draft of

ts.

tec

carrerated aspects

from the

'PaceMher version of the Plan i and the estimation of the costs associated with this revTiiCf progr:t:' hat' not been completed.

Thus, the findings offered in this repvrtshould be viewed as interim. Work is underway to publish a fee adequacy evaluation

report in January 1985 that will be consistent .with;
the

analysis reports.

inten

Mission Plan s to

that is to be aubraltted to the Congress. DOC ow the January publication date for all future fee

the versioJ\ of

HETHOOOLOGY AND ASSUMPTIONS

This evaluation of fee adequacy is based on the principle of -full-cost recovery- , which means that the Federal government should be reimbursed for all costs related to the waste disposal services it provides to the signatoties of DOE' s . Standard Contract for DhPD.i'tl of Spent Nuclear Fuel and/or lJi9h-Lev~1 Radioactive Waste. The principle of full-cost recovery underlies the basic analytic approaches used by DOR in 1978, 1980 and 1983 to evaluate financing Methods suited to it Federally administered civIlian nuclear waste management program.
The general 1I'Iethodology employed in this year s report projects Nuclear Waste P'und cash flows and resulting balances basf!d on program costs and revenues, inctuuing interest earnings and ~xpenses. A 2 percent real interest rate was assumed. If the projected final Fund balance is estiraated to be post tive, then ~~e

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projected f insl Fund

converse would be true.
Spent fuel cumulative discharge through ~he year 2020

fee is judged adequate to ensure full cost recovery. If the balance is estimated to be negative, then the

'1'he principal assumptions used in this report to oroduce the ~eference case estimates are noted below

uraniurn(M'l'U)
Two

l34, 000

metric tons

. reposl lodes

Number of geologi~

0'
0'

Repository design cap~city
Repository receipt rate3

70, 000 MTU each
800 M'l'U/yearly for

and then 3, 000
HTU/year; y

the first five years,

thereafter.

Minim~m cooling time sin~e

10 years

ischarge ' of SpOt ' fuel accepted f(\t' disposal

Operational stArt-up dates for the repositories

First one in 1998 and, the second one in 2003

Several 81 ternative program ceases (i. e. sensit lvity cases ) w! _ also studied to determine the sensitivity of the refere~ce ' C~8e

assumptions for t~ese alternative cases diverge from the as8u~ptlons ' noted above with res~ct to: 1) the inclusion of a five year repository schedule deJayandconstruction of ~nitored retrIevable storage facilities to accomodate the spent fuel flowJ 2) both ~igher and lower program construction and operations costs arising from either unanticipated . technical difficulUes or the use of more efficien~ designsJand 3) lower nuclear growth projections resulting in declining revenue and SNF discharge

cost estimates to different progra~matieassumptlons. The

lorecasts.

The revenue projections used in this analysis were derived from estimates of gross electricity generatlonprepared In September 1983 by the u. s. Energy Information Administration (CIA). Three

nuclear growth scenarios are depicted in this report

1) The "Firm-Base" case assumes all reactors currently undec construction but less than 30 percent complete are cancelled, andna orders for new reactors arepJ.aced. The net effect is that when the reactors now more than 30 ' percent complete begin operation by about 1990, the number of nuclear power plants is stable for about 10 years,

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and then declines to 4!ero in 2020 as plants are retired. 2) The -Low ' ca.e ~ake8 the same a88uRption~ about the completion of reacto~s now under constructi~n as in the " F1rm BaRe- case, but a180 aSBumcs a slow Increase in installed nul'.lear capacity through

c~Q'. clal nuclear .power ,grows

the yeftr 2020. ~. ) The " Hid" case aSsumes the Market share of

and 2020. EIA' s "H1gh- growth case ~as not included because , c.ho
the next two, decades appears highly unlikely-

aea moderate rate , resulting in an appr04. imate doubUnCJ of installed "uclear capacity between 1990

i_plied accelerated developmen".:

of comme,

rcial ' nuclearpawet'duting

The total system life cycle costs of the civilidu nuclear \faste management prOCjran analyzed in this rePvt't are organized into three major categories that retain the costing structure used in laet year s fee anaJ,ysis report. 'J'bese categories are: development and evaluation: 2) geologic repository construction, oper~tion., cl08ure and decommissioning I and 3)' transportation and

1)

systellls development. It' shouJd be noted, however,

that the cost 4stimates are based largely on conceptual designs, with definitive information still lacking in many areas. 'l'he estimat:.es \:111 be refined as new

lnformaUol becomes
sat t and tuf f) are being

available.

bedded salt, domed rocka for the first repository. For purposes of th:~ fee adequacy analvsis, granite 1s assumed to be the geologic meoium for the second repository.
ANALYSIS
This section of the repot" t discusse s both revenue and program cost per: projections and assesses the adequacy of the, current 1.

Four candidate geologic media (i.e. ,basalt, considered ,as host

kwhr fe~ to recover program costs.
7bl11ionl

0 mql

Cumulative revenues derived from the three EIA electricity generation cases discussed, in this report, based On the continuing application of the current fee, are as follows: 1) Firm-Dase case 2) Low-case - $26. 8 billion; and 3) Mid-case - $19.
$33. 3

dollars would also accrue to the Nuclear Waste Fund during those years when program revenues are expected to exceed program costs.

bill~on. Interest earnings amounting to several bi l1ion

LUe cycle costs a!\sociated with development and evaluation cover all the siting, testing, design development, re9ulatory and insti tutional activities relating to the two geologic repositories, monitored retrievable stora~e facilities, other facilities and the required transportation network. These CO&ts are estimated at $7. 6 billion, expressed in 1983 dollars.

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J: ~.,.. . " 3 '3,~IT\"S

.\jlJ

Mission Plan
for the

Civilian Radioactive ~Vaste

Management Program
Volume Part Part Overview /I Information Required Policy Act of and

Current Program Plans
by the

Nuclear Waste

1982

June

1985

S. Depdrtment of Energy
Ofiice of

Civiltan Radioactil' t'

Waste Management

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of high-level waste and spent fuel) and. ~ccotdinolv. ep~A!i~~ in the Treasury of the Uni tad States a special Nuclear Waste Fund to be composed of the payments made by those using the services (Section tors

3021.
Committing the Federal Government to study monitored retrievable storage in parallel wlth geologlc repositories (Section 1411.
Providing for a federally owned and operated system of interimstorage facilities for no more than 1900 MTU of spent fuel from civilian reactors whose owners cannot reasonably provide adequate storage capacity at the reactor site (Section 131) and creating an Interim Storage Fund to make certain that those using the services will pay the full costs (Section 1361.

Setting out an extensive system of checks and balances through public lnvolvement, along with written consultation-and-cooperation (C&CI agreements. to ensure Federal accountability to, and communication with, States and affected Indian tribes (Section 117).

1. 3

POLICY GOALS AND PROGRAM OBJECTIVES

Unprecedented technical and institutional challenges require resolution the Act are achieved. First, the public of must be convinced that the interests of the Nation are best served by consolidating the radioactive waste dispersed throughout the country in a limited number of geologic repositories designed for permanent disposal. The national interest must take precedence over parochial concerns. Next, the DOE must be able to achieve the tasks set forth in an unusually precise and complex schedule and to persuade the citizens of the country that the waste disposal program will be safe. efficient, and on schedule. Furthermore, the conflicting and competing interests that are mirrored by the tension between program schedule and technical certitude must be resolved. , Finally, the DOE must grapple with the contentious issues that often accompany a task as complex and enduring as its waste-management program while never wavering from its commitment to build and operate the required disposal facilities.
before the intent and the letter

The following policy goals guide the formulation and the implementation of the DOE' s program:
The protection of public health and safety and environmental acceptability are of paramount importance.

The program must be credible to the public by virtue of its integrity and technical excellence. The program must neither subsidize nor penalize nuclear power as an

energy source.
The program must be conducted in a cost-effective manner, with full cost recovery.

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Chapter 2 PROGRAM STRATEGY

INTRODUCTION

t i ves. several stand out:

The Nuclear Waste Policy Act of 1982 (the Act! put in place a comprehensive. complex set of activities for achieving the capability to dispose of the Nation s high-level radioactive waste. The strategy of the program is intended to provide maximum . assurance that the goals identified in Chapter 1. implementing the provisions of the Act. are met. Among these goals and objec-

The program must protect the health and safety of the public and the quality of the environment. The program must provide for the dissemination of the public and ensure opportunities for participation by the public and their representatives in order to achieve their confidence and

info~tion to

support.
The program must be conducted in a financially responsible. costeffective manner and on the basis of full cost recovery.
In accordance with the above goals. the program must vigorOUSly to begin accepting spent fuel and high-level waste for disposal no later than January 31. 1998. and to continue to dispose of the waste in a highly efficient manner consistent with the continued orderly operation of the Nation s nuclear

pursue the Act t s directive

power- generation plants.

The Act has provided a broad. flexible framework in which to conduct the necessary activities: it has authorized certain key facilities. set schedules and fees. articulated institutional interactions. provided the opportunity to analyze the desirability of enhancements to improve program perfo~nce. and recognized the need for flexibility and contingency planning in a large. complex. and controversial program that may span more than a century.

The strategy of the program is to ensure that the activities authorized by the Act are carried out in a vigorous manner: potentials for systemperformance improvements are analyzed and incorporated where useful. including requests for new Congressional authority as allowed by the Act; and contingency plans are identified and evaluated to provide maximum confidence that the program is prepared to adjust to meet the requirements of the Act notwithstanding uncertainties as to future Congressional authorization decisions and technical and institutional matters. The strategy can be described as a comprehensive system-development program through which any of three distinct plans can be successfully carried through to meet the requirements of the Act. In the discussions that follow in Sections 2. 2. 2. 3. and 2. 4. these plans are referred to as the " authorized plan. " the " improved-performance plan. " and contingency plans. Also discussed

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Table 2-:, Waste-Acceptante Sctledule--Autllorized S,.stCl4etric 'tons CUlUtat

0' urani~

(fCTU) per ,.ear)

, "N:t RellCl1:Uor"
S~t.Fu.1 ~.rationA
AMua 1

Se~ond ReDo~ I tory

Mi,tl-U"el '

Year

CU8llattve
Spent FUel

waste
SP*I1t fuel,

Total

'(&allathe
400 800
200'

C_lathe

Spent-Fuel Acceptance

SDen t-Fue1 8ac:lc1Ot

Pre 1998

"'8
400 400

Case 1:98-cv-00126-JFM

40, 100 41, 000 46, '00

4',
'00
900
liDO 3800
SOOO

12, 000 55, 000
400 400
400

SI, 61, 410
SlOO

400 400 400 900 1800 3400 3400

2900 3000 3000 3000 3000 3100 nOD 3400

IIO
:tOio
:tOOO

)400
3400 3400 3400
:1400

31.0
400
:1000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

aool 4.00
4000
3000

4100

47"
81. 100
SO..
sooo
300 3000 3000
:1000

4100

68, 72, 700
'400

900 700 500
:aOO

400 aoo 200 100 900 900 900 12, 900, 16, 000 21. 600 26. 400

31. 20i

40, 100, 42. 600 45, 200 47, 800 49, 900 51, 100 51, 200 51. 500 51, 900 51, 800 51, 100 51, 000 50. 700
ODD

%010

1011 2012 2013

"00
'8, 700
900

90. 400 94, 500
102, 900

100 900 300 10, 700 14, 100 17 , 500 20, 900 Z4, :IIO 27, 700 11, 100 500 )7, 900'

41, 400 47, 400 53, 400 59, 400

.0, 400

49, 000 47, 100 45. 300 43. 500
4' ,aDo

Document 792-15

'07. 200
3000 3000
3'400

0'\

3400 3400 3400 3400 3400 3400 1400

41, '00 44, 700 41, 100 51, 500

2014 2015 2016 2017 2018 2019
:1000

4200 4200 4300 4300 4500 4700 4700
3400
24110

10. 500 soo 16. 500 19. 500 22, 500 25, 500 28, 500 31. 500 34;500
37 . 500

20Z0
SODa

Zo:u.
1100

.900
3400
1100

111, 500 116. 000 120;700 125, 400 130, 100
3000

65, 400 71, 400 ' 77, 400 13, 400 19. 400 95, 400

40, 500

10; ,

400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400 400

58, '00 61. 700 65, 100 6*. '00 70, 000

4:1, 500
SOO

'os. soo
'OI,
3000 '
SOO
111 .500

40. 100, 38, 600 17, 300 36, 000 34. 900 28, 900 24, 800 21, 100
111'. aoo

900 1800 1800 1000 1800 2400 3000 3000 3000 3000 3000 3000 3000 3000 3000 3000 3000 '000' 3000
1000

49, 500 52, 500
)000

15', aoo

2022 2023 2024 2025 2026
1000

ZOZ7

114, 500 117, 500 120, 500

12, 800

ZOZI

In, SOo
3000 3000 3000 800

ZOZ9

2030

Filed 04/16/2004

203t

SS, 500 58, 500 61. S00 64, 500 67, 500 68. 300

126. 500 129. 500 130. 300
Stat.,~ and thO! World, OOUtIA 0438(14), lIovMber 1984.

800 800 800 aoo

diScha,...

"Ijata 'rOII

fr- _-'SSi~

".....reial .~I.ar p_r "84'
""' of def_-

PrClsoec:ts 'Dr t~ United

Includes

htgh-'tYel waste 'rllf/l the West defense acthltles and for hlth- 1.vel , waste ApprOxilll8te IilUte-.ec8lltance rates _tl~t~, ons , uranhll (Krlls) on a curie-equivalent basis. Direct Quantities halO. been . nonulhed. to,(, QIII,.W) and co.-rcial hlgh-,eyel waste (CHLW) resulted from .the reprocesSIng of Yaney Dell!nstra,tlon '",e1 waste with spent rlMl Is not ~",valent, Mc&YSe de,ense 1It",waste equals 800 canlst!lrs. ,Actual acceptance rates are to "'IIe,ollated between Defense Programs ex8111118. ..~

'roj~t.

'r- at_Ic _r,y

c_rc'a1

c~ar'son

spent IIMI, In 1M an4 the Office 0' CtvtHan Racltoacthe Waste

Page 9 of 11

..Jo.

first

Thefirst rellOs\toOl currentl,. is c..Slgned to ...,in operation In two phases. This ex"",'e shows the acceptance of OHLW and recltllt rate. pltase 1IIhen, tile sec~phase reaches its ..,.,iU20, . ' For , waste created after 2020. The Enerl,. Info...tton~lntstratton proJe'c:ts spent-fue1..oeneratlon only' throufh the year.

reactors; OOt.
_'aclttt

...".,-..tinthe

CitLW In the

nther the
by e..ten41O, the

CJ1

capacity 0' the First two repositories could be Increased b,. the year 2022, Additiona1 D"tW can be a~cOfmlDdated or additional repositorieS could bebultt. , an4 CHLW ...1&c'"

-10.

The IXIIIIiIIlt s/1OW$ a total 0' IDiO IfTU of DHLW IIHLW In tile secQnd operatIon of the first repository.

repository, or constMtlttt additional rep,osltorles.

as IndIcated In footnott 0

(") ...

.....
('"

"'.

",

"',

::0

Tntl 2-3.
Wastt-Acclptance Schedu1e--Improved-,erformance SyStem

(Metric tons of Iiran1la (1fTU)
per "ear)

Year

SoetIt I'_1 c.......tt~

Amwa 1

Cl8u1au..
Acceptance

HIS

I't"t ~DtI~Horv

Inventor,,
ItI$
Tota1

HIS
Sf fl"O8

Ktth-Llvet

Case 1:98-cv-00126-JFM

*-ste

C~tat1Ye

Se~/)ftd ~.DD~ttDry

C~'ath.

Tota'*-st.

Spent flll1 CIaI1attve

Ac:cept&ftCe

Spent-fuel Spent-fuel
Back1o.

're 1998

1"8
3000.
400,
900 400 400

2900

40, 100 41. 000
2200 3000

SOOO

SOlO

37. 900 37, aoo
:J7 . 800

SoOO

3000

000 49. 000 12, 000 5S, OOO
3000 3000 3000 3000 3000
SlOO

37 . 100

1999 2000 2001 2002 2003 2004

noo
68, &DO 72, 100
400 81, tOo

SlOO

ZOOS

S8, tOO 61, 400
800

37. 37. 800

400 800 200 100 900 300 10, 700 14. 100

2006 2001 2008 2009 2010
400

Document 792-15

410.
400
400

3410 3100 4100 4700 4500 4500 4000

400 400 400 400 400 400 400 400

1800 3400 3400 3400 3400 3400 3400 3400 3400

17, 5110 20, 900 24, 300 27. 700
31",

to , 400 94, 500
. 400

900 1800 1800 1800 1100

900 700 500 300

38, 200 18. 600 31. 500

:J7, 900

3000 3000 3000 3000 3000 3000 3000 3000
JOOO

2400 3000
' 3000

lOO

37 . 800 37 . 100 37 , 400

:J7. loa 21. 700
10, 500 13, 500 16, 500 19, 500
IOO

I',)

'000
3000 3000 2100

400 400 400 900 1800 3000 3000 3000 3000 3000 3000 3000 3000 3000 3000 1000 3000

200 200 200 11. 200 14, 200 11, 200 20. 200 23, 200 200 30. 100 34, 900 39, 700 44. 500 49, 300 54, 700 60. 700 66, 700

4200 4200 4100 4200 4100 4700 4700 4900

98, 700 102, 900 107 ,200 111, 500 116, 000 120, 125, 400

200 800 400 10, 000 12, too 13, )00 13, 300 13, 300 13, 300 13. 300 13 , 300 13, 300 13, 300 13, 300 13, 300" 13, 300 13, 300 13, 300 13, 300 13, 300 13, 100 10, 100

no, )to
100 100

1, too

34, 500 37, 900 41, 300 44, 700 48, 100 51, 500 ' 54, 900 58, 300

, 71. 700 84. 700

72, '00

3000 3000 3000 3000 3000 3000 1100

400 400 400 400 400 400 400 400 400

3400 3400 ' 3400 3400 3400 3400 1400 3400 3400 3400 3400 1500

'5,

700
100 500

93. 500
70, 000

'0, 500

32, 000 30. 200 28, 500 2'. 800 25. 500
2000 3000 3000 3000 3000 3000 3000 3000 3000 3000
:sODa

22, 500 25, 500 , 28, 500 31, 500 34, 500 37, 500 40, 500 43, 500
Soo

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 202* 2024 2025 8000

102, 500 105. 500 loe. soo
3000 3000 3000 3000
JOOO

99, 500

500

27. 200 2a, 900

30 , aDo 2? , 800

Filed 04/16/2004

202'

'00

24 , aDo 21. 100 114 500

18, 800 15, 100

49. 800 52, 500 55. 500 58, 500

12 , aoo

2027 2028 2029 2030

'1,
3000 100

500
64 .500

2031

61 ;500 300

117, 500 120i500 123, 500 12ft, 500 129, 500 130, 300
Uor1d , DO~/nA 0438(84), NOnwlber 1984.

800 800 100

loa

dec_1ss1one.1 ru.c:tors.

"oata fr."",.... II_... 1984

~-...,t.,

Pro"bP"h 'or tho. UnttPd SUt~~ .nd th.

Page 10 of 11

'ac1"t" 15 ' to "Iell a constant aceilitanee the f1rst rellosttor" as fast as , ~pent'ue1. The HIS 'ac111t" 101111 stOlliccept1nt,5j1eiit fuel , ioinen'rate ,and d1sc:har,e torn1 the ftrst the First reposItory can .c~ept 1ts 1nventor" wt11 See footnotes b and c in Table 2-2. rePOsttOl:1.

'The "-IS

ass~

.Includes disChar,e rrOlll

CJ1

;--I'

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both repositories, or , two
fense high- level

accept beginning in 1996 with the comthe Quantities of waste the , DOE pletion of an integral MRS facility is presented in Table 2-3. This sched~ ule assUllles that one HRS facility services the first repository. Other scenarios 'are possible. such as a large r MRS facility servicing part or:' all of
HRS, facilities

c~ld

servicing two repositories.

Included in Tables 2-2 and 2-3 are possible acceptance schedules for dewaste (DHLW) produced in national defense proq. rams and com, mercial high- level waste (CHLW) from the West Valley Demonstration Project. These schedules are based on the assumption that the DHLW and CHLW would be emplaced in phase 1 of the first repository after phase 2 begins operating and reaches its design capacity (see Section 3. 1 for a discussion of the first"; These schedules are for illustrative purposes only at. repository phases) this time. The amount of defense waste to be disposed of in the repository. and the actual acceptance rates, have not yet been determined 'by the DOE.

, tance of civilian

A comparison of the two acceptance schedules , shows the following advantages of the improved- performance plan over the authorized plan for the ac~ep-

spent fuel:

Spent- fuel

acceptance can begin as soon as the integral MRS facility begins operation, possibly 1 to 2 years ahead of the repository. '

and reach the ' design level sooner, thus easing the

System waste-acceptance rates with the integral MRSfacility ramp problem of spentfuel storage during the critical years around 1998. In the particular example depicted in Table 2-3. the spent-fuel ba~klog after 1998 never exceeds the cumulative spent- fuel inventory in words. with the exception of a few years just before the ' $tartup of the second repo~itory, the acceptance rate matches or exceeds the rate of spent-fuel generation after 1998.

1998. In other

The choice of the receipt rate for the integral MRS facility establishes the bounds by which the integrated waste-management' system would accept and package spent fuel during the critical years from 1998 to the startup of the second repository in 2006. The rate at which the integral MRS facility would accept spent fuel is based on two major considerations:

The need to relieve the utilities of onsite-fuel-storage pressures that could result in the disruption of orderly nuclear reactor operations after Ja~uary 31, 1998.

2. The need to operate the overall system in ' an orderly, c~st-effective
manner, which implies the handling of suitably aged nuclear fuel and the maintenance of fairly constant receipt and packaging rates over extended periods of time.

The representative waste-acceptance schedule, for the improved- performance system described in this chapter is designed to achieve the following DOE

objectives:

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