The Department of Energy’s Office of Civilian Radioactive Waste Management prepared this document to report plans for the Civilian Radioactive Waste Management Program, whose mission is to manage and dispose of the nation’s spent fuel and high-level radioactive waste in a manner that protects the health and safety of the public and of workers and the quality of the environment. The Congress established this program through the Nuclear Waste Policy Act of 1982 (see Appendix A), though efforts to solve the waste-disposal problem go back several decades.

There has been a resurgence of interest in the possibility of processing the US spent nuclear fuel, instead of burying it in a geologic repository. Accordingly, key topical findings from three relevant EPRI evaluations made in the 1990-1995 timeframe are recapped and updated to accommodate a few developments over the subsequent ten years. Views recently expressed by other US entities are discussed.

In June 2008, the U.S. Department of Energy (DOE) submitted a license application to the U.S. Nuclear Regulatory Commission (NRC) for the construction of a geologic repository at Yucca Mountain, Nevada, for the disposal of spent nuclear fuel and high-level radioactive waste. The license application was accepted for formal NRC review in September 2008. Throughout the more than 20-year history of the Yucca Mountain project, EPRI has performed independent assessments of key technical and scientific issues to facilitate an understanding of overall repository performance.

EPRI has discovered several aspects of the U.S Department of Energy (DOE) proposed design and operation of the Yucca Mountain repository that—if implemented as described in the license application (LA)—could result in unnecessary occupational health and safety risk to workers involved with repository-related activities. This report identifies key DOE conservatisms and focuses on the occupational risk consequences of the DOE's approach to the repository design, performance assessment, and operation.

U.S. efforts to site and construct a deep geologic repository for used fuel and high level
radioactive waste (HLW) proceeded in fits and starts over a three decade period from the late
1950s until 1982, when the U.S. Congress enacted the Nuclear Waste Policy Act (NWPA). This
legislation codified a national approach for developing a deep geologic repository. Amendment
of the NWPA in 1987 resulted in a number of dramatic changes in direction for the U.S.
program, most notably the selection of Yucca Mountain as the only site of the three remaining

U.S. efforts to site and construct a deep geologic repository for used fuel and high level radioactive waste (HLW) proceeded in fits and starts over a three decade period from the late 1950s until 1982, when the U.S. Congress enacted the Nuclear Waste Policy Act (NWPA). This legislation codified a national approach for developing a deep geologic repository. Amendment of the NWPA in 1987 resulted in a number of dramatic changes in direction for the U.S. program, most notably the selection of Yucca Mountain as the only site of the three remaining candidates for continued investigation.

The effective termination of the Yucca Mountain program by the U.S. Administration in 2009
has left the U.S. program for management of used fuel and high level radioactive waste (HLW)
in a state of uncertainty. In concert with this major policy reset and in response to the resulting
policy vacuum, the President directed the Energy Secretary to establish the Blue Ribbon
Commission on America’s Nuclear Future (BRC) “…to conduct a comprehensive review of
policies for managing the back end of the nuclear fuel cycle and to provide recommendations for

Since 1989, EPRI has been conducting independent assessments of the proposed deep geologic repository for the disposal of spent nuclear fuel and high level radioactive waste at Yucca Mountain, Nevada. EPRI pioneered application of the total system performance assessment (TSPA) approach for evaluating performance of geologic repository systems on a probabilistic basis. Along the way, EPRI developed the Integrated Multiple Assumptions and Release Code (IMARC) as its primary analytical tool for TSPA-based evaluations.

Over the decade since NWPA, the disposal
program's strategy, based on its interpretation of the
legislative mandate and regulatory requirements, has
sought:
• in a single large step and under a tight
schedule, to achieve the first-of-a-kind licensing
of a first-of-a-kind repository for isolating
wastes from the human environment for many
thousands of years.
• in a single large step and as rapidly as possible,
to build a full-scale repository and begin
disposing of the bulk of the nation's inventory