Impact assessment of draft DOE Order 5820.2B. Radioactive Waste Technical Support Program

The Department of Energy (DOE) has prepared a revision to DOE Order 5820.2A, entitled ''Radioactive Waste Management.'' DOE issued DOE Order 5820.2A in September 1988 and, as the title implies, it covered only radioactive waste forms. The proposed draft order, entitled ''Waste Management,'' addresses the management of both radioactive and nonradioactive waste forms. It also includes spent nuclear fuel, which DOE does not consider a waste. Waste forms covered include hazardous waste, high-level waste, transuranic (TRU) waste, low-level radioactive waste, uranium and thorium mill tailings, mixed waste, and sanitary waste. The Radioactive Waste Technical Support Program (TSP) of Leached Idaho Technologies Company (LITCO) is facilitating the revision of this order. The EM Regulatory Compliance Division (EM-331) has requested that TSP estimate the impacts and costs of compliance with the revised order. TSP requested Dames ampersand Moore to aid in this assessment by comparing requirements in Draft Order 5820.2B to ones in DOE Order 5820.2A and other DOE orders and Federal regulations. The assessment started with a draft version of 5820.2B dated January 14, 1994. DOE has released three updated versions of the draft order since then (dated May 20, 1994; August 26, 1994; and January 23, 1995). Each time DOE revised the order, Dames and Moore updated the assessment work to reflect the text changes. This report reflects the January 23, 1995 version of the draft order