! ! ! ! ! ! ! ! Memorandum
To: Vanessa Pierce, Executive Director, HEAL Utah From: Arjun Makhijani Subject: Savannah River Site Depleted Uranium Shipments to Utah Date: February 16, 2010
You have asked me to analyze whether the U.S. Department of Energy’s (DOE’s) past and proposed disposal of Depleted Uranium (DU) from the Savannah River Site (SRS) at EnergySolutions’ low level radioactive waste (LLRW) disposal facility in Clive, Utah, conform to the U.S. Nuclear Regulatory Commission’s (NRC’s) low-level radioactive waste (LLRW) disposal rule and to the Energy Solutions’ Waste Acceptance Criteria (WAC). These are shipments of “Recycled DU,” that is, DU that has been irradiated and therefore has traces of fission products as well as transuranic radionuclides such as various plutonium isotopes. 1
As summarized below, I have concluded that neither the quantity nor the isotopic composition of the Recycled DU from the SRS meets the regulatory requirements for disposal as LLRW at the EnergySolutions site. My conclusions are summarized below. The bases for my conclusions are discussed in Attachment A (which presents my analysis of the DU disposal issue) and Attachment B (which focuses on the technetium-99 (Tc-99) concentrations in the waste drums and was prepared by Dr. Harry Chmelynski, who is a statistician).
As discussed in more detail in Attachments A and B, I have concluded that:
1. The disposal of such large amounts of DU as the DOE proposes to dispose of at the EnergySolutions site is not authorized by the NRC regulations that form the basis for the State of Utah’s own regulatory program, nor has it been subjected to the required environmental analysis. Even a very expansive view of the history of the regulation would not allow concentrations of uranium-238 higher than 50 nanocuries per cubic centimeter (cc) or a total amount of uranium-238 in excess of 17 curies (about 51 metric tons). The total number of curies of uranium in the 33,000 DU drums at SRS is 300 times (or more) greater than the maximum amount arguably envisioned under the low-level waste rule. The concentration is more than an order of magnitude !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 1Recycled DU is distinct isotopically from “Virgin DU,” which is DU that has been generated by the enrichment of uranium ore that has not been irradiated. The isotopic composition of Virgin DU consists of natural uranium isotopes and the radionuclides in their decay chains, none of which are in Tables 1 or 2 of 10 CFR 61.55(a). Recycled DU generally contains radionuclides listed in Table 1 or Table 2 or both; this is the case with the SRS recycled DU under consideration here. The distinction is central to my conclusion in paragraph 2 below but immaterial for my conclusion in paragraphs 1 and 3. greater than 50 nanocuries per cc. As you know, the NRC acknowledges that large amounts of DU were not covered by the low-level waste rule and is currently engaged in a process of determining what kinds of restrictions are appropriate for large amounts of depleted uranium. This rulemaking, however, has not been completed.
2. Disposal of recycled DU in any amount as Class A waste is not permitted. This is because classification as Class A waste under 10 CFR 61.55(a)(6) requires that the waste not contain any of the radionuclides listed in Tables 1 or 2 of LLRW disposal rule. In fact, the recycled DU from SRS that is proposed to be disposed of as Class A waste at the Clive, Utah, site contains radionuclides from both Table 1 and Table 2, including plutonium isotopes, iodone-129, technetium-99, strontium-90, and cesium- 137.2 As a result, recycled DU from SRS does not meet the regulatory definition of Class A waste, and disposal of recycled DU as Class A waste in any amount at any concentration is not permitted under federal low-level waste regulations. Therefore, the proposed disposal of recycled DU at the EnergySolutions site violates the low- level waste rule, independent of arguments related to the quantity of uranium involved.
3. Quite apart from the uranium content of the SRS waste, it is virtually certain that the technitium-99 content of many of the drums exceeds the Class A limit of 0.3 curies per cubic meter. Since only 33 samples were taken from 33,000 drums of recycled DU and the drums are not segregated between those meeting the Class A limit for Tc- 99 and those above it, none of the drums can be disposed of as Class A waste for this reason alone. The DOE’s claim that Class A limits for Table 1 and 2 radionuclides are met is based on a misleading interpretation of even the few samples that were taken. A properly conducted statistical analysis shows that it is more than 99 percent likely that a large number of drums would violate the Class A limit of 0.3 curies per cubic meter for Tc-99. Such an analysis is presented in Attachment B.
In sum, there are three different ways in which the recycled DU from SRS is not permitted to be disposed of as Class A waste at the Clive, Utah site.
In view of the three findings above and the past disposal of recycled depleted uranium at the EnergySolutions site, I have also concluded that neither the Utah Division of Radiation Control nor the NRC has been exercising due oversight over the low-level waste disposal process. Finally, it should be noted that the analysis in this report shows that the DOE has also not respected federal low-level waste rules in the process of sending its wastes to a commercial site covered by NRC regulations. Finally, if recycled uranium, whether depleted or not, has been disposed of at the EnergySolutions facility in Utah in the past, this too would violate the low-
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 2 Profile Record 2009 (EnergySolutions, Radioactive Waste Profile Record, EPA ID# SC1890008989, Waste Stream ID-9021-33. Waste Stream Name SRS DUO, Rev. 0, 11/16/2008, Shipped on December 8, 2009) and an attachment to the Profile Record 2009: Parkinson 2002 (K.S. Parkinson, Depleted Uranium Oxide Sampling Results, Interoffice Memorandum, to S. A. Williams and D.L. McWhorter, (NMM-ETS-2002-00184, Revision 0, Tracking number: 100049, D/A: DOE/ADM 17-17.a), Westinghouse Savannah River Company, Savannah River Site, November 4, 2002). level waste regulation. This is a matter that should be carefully investigated by the State of Utah and by the NRC.
Attachment A ! Analysis of Low-level Waste Regulations and Disposal of Recycled Depleted Uranium3
Arjun Makhijani
The Nuclear Regulatory Commission’s low-level waste regulation is published in the Code of Federal Regulations at 10 CFR Part 61. Section 61.55 specifies the concentrations of a variety of radionuclides that constitute the system of classification of waste into Class A, B, C, and Greater than Class C. However, not all radionuclides and types of waste are listed in 10 CFR 61.55. Specifically, the rule does not cover large amounts of depleted uranium, such as those from enrichment plants. In addition, it does not cover waste, such as recycled DU, that consists of combinations of radionuclides that are listed in Tables 1 or 2 of 10 C.F.R. 61.55 and radionuclides that are not listed in either table..
1. Large Amounts of DU
Small amounts of DU have been allowed to be disposed of as Class A waste under 10 CFR 61.55(a)(6) which states that all low-level waste not explicitly mentioned in Tables 1 and 2 constitute Class A waste. However, in October 2005, the NRC explicitly recognized that DU in large amounts was not covered by the rule. This clarification was needed because large amounts of DU were not considered waste at the time that the final rule was promulgated in 1982.
The NRC has begun its rulemaking process with initial explorations of whether large amounts of DU could be classified as Class A waste, with the additional requirement of a site-specific analysis prior to disposal. The NRC staff prepared a paper presenting calculations for hypothetical wet and dry sites and held workshops in Bethesda, Maryland, and Salt Lake City, Utah, in September 2009, on this and related topics. The Department of Energy participated in these workshops.
The NRC’s presentations during these workshops explicitly recognized that only small amounts of DU at low concentrations were analyzed in developing the LLRW disposal rule and that disposal of higher concentrations and amounts were not covered by the low-level waste rule as it stands at present. Larry Camper of the NRC, who provided the overview, stated the context as follows:
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 3 The physical, chemical, and radiological properties determined from analyses of these samples are provided in the EnergySolutions Radioactive Waste Profile Record and a 2002 memorandum prepared by SRS: EnergySolutions, Radioactive Waste Profile Record, EPA ID# SC1890008989, Waste Stream ID-9021-33. Waste Stream Name SRS DUO, Rev. 0, 11/16/2008, Shipped on December 8, 2009. Hereafter Profile Record 2009. The form was filled out by the DOE and the information regarding the results of radionuclide sampling attached to it was provided in an attachment by the Savannah River Site. We note that the file signature page on this document [pdf p.5], is dated 11- 23-09, and labeled ID-9021-32. The attachment is K.S. Parkinson, Depleted Uranium Oxide Sampling Results, Interoffice Memorandum, to S. A. Williams and D.L. McWhorter, (NMM-ETS-2002-00184, Revision 0, Tracking number: 100049, D/A: DOE/ADM 17-17.a), Westinghouse Savannah River Company, Savannah River Site, November 4, 2002. Hereafter Parkinson 2002. The Commission realized the uranium enrichment landscape was drastically changing. So when during the hearings for the LES facilities, Interveners filed contentions regarding the impacts from DU disposal. The Commission directed staff to evaluate these impacts separate from the hearing process. The Commission stressed in their order to the NRC staff to consider the quantities of DU at issue and noted that these large quantities were outside the bounds of the evaluation conducted in the Part 61 rulemaking in the early 1980s.4
Mr. Camper’s statement makes it clear that the NRC has recognized that large amounts of DU are not covered by the low-level waste rule. That is one of the reasons that the NRC is pursuing a modification of 10 CFR 61.55(a).
The NRC staff also provided further detail on what was analyzed during the process of rule- making. This is important since it provides a guide for the amounts and types of uranium- containing waste that might reasonably be disposed of prior to a modification of the rule covering large amounts of such waste. According to Mr. Camper of the NRC staff:
Approximately six metric tons of DU were assumed to be Class A in the draft Environmental Impact Statement. A draft concentration limit of 0.05 microcuries per cubic centimeter was determined. This draft concentration limit was not adopted in the final Environmental Impact Statement based on the Part 61 FEIS conclusion that "the types of uranium bearing waste typically being disposed of by NRC licensees do not present a sufficient hazard to warrant limitation on the concentration of this naturally-occurring material."
However, the specific activity of depleted uranium is 0.5 microcuries per cubic centimeter and now the landscape for waste stream generation is changing. So clearly NRC is entering new territory not envisioned when Part 61 was initially developed.5
Slides presented at the workshop by Dr. David Esh, the principal NRC staff author of the technical paper, further stated:6
Depleted Uranium Disposal: Problem Context • Large quantities of uranium were not evaluated in the EIS for 10 CFR Part 61 –17 Ci of 238U (in 1 million m3 of waste) –3 Ci of 235U
Dr. Esh elaborated on this slide as follows:
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 4 Public Workshop on Unique Waste Streams: Depleted Uranium, Nuclear Regulatory Commission, Bethesda, Maryland, September 2, 2009, Official Transcript of Proceedings, on the Web at http://www.nrc.gov/about- nrc/regulatory/rulemaking/potential-rulemaking/uw-streams/workshop-1-transcripts-day1.pdf, p. 25. Hereafter NRC Transcript September 2, 2009, emphasis added. 5 NRC Transcript September 2, 2009, pp. 23-24. 6 David Esh, Site-Specific Performance Assessment and NRC Depleted Uranium Technical Analysis Overview, September 2009, Slide 14, on the Web at (in a file combined with other presentations) at http://www.nrc.gov/about- nrc/regulatory/rulemaking/potential-rulemaking/uw-streams/du-workshop-presentations.pdf. So the depleted uranium disposal, the problem context, large quantities of uranium were not evaluated in the EIS for the 10 CFR part 61. But uranium was evaluated. Basically they evaluated about 17 curies of uranium-238 and 3 curies of uranium-235. And that was in roughly one million cubic meters of waste. So that gives you an idea of quantity and concentration that they assessed.7
The above facts about the process of rulemaking for 10 CFR Part 61, as well as the final omission of uranium from the list of radionuclides in the rule, provide the context for the amounts and types of uranium-bearing waste that might be construed as being covered by the low-level waste rule. Even though uranium is not mentioned in 10 CFR 61.55 explicitly, the history of the rule provides a rationale for arguing that 17 curies of U-238 and 3 curies of U-235 could be disposed of under the rule if these amounts were below certain concentrations. Further, an average concentration of 17 picocuries per cc might be considered acceptable, since the draft considered 17 curies in a million cubic meters (which equals a trillion cubic centimeters). Since the Draft EIS of the low-level waste rule proposed a much higher limit on the concentration of DU, at 50,000 picocuries per cc (=50 nanocuries per cc = 0.05 microcuries per cc), this might be construed as a potential upper limit on the concentration of uranium in low-level waste that could arguably be disposed of under the present low-level waste rule.
No reading of recent NRC decisions or of the low-level waste rule as promulgated would lead to a conclusion that disposal of more than 17 curies of U-238, the dominant uranium isotope in DU, and 3 curies of U-235, is permitted. Since U-235 is only 0.2 percent to 0.3 percent of the mass of DU and its specific activity is about 7 times that of U-238, the 17 curies value for U-238 would automatically be the limiting amount if the uranium to be disposed of is depleted uranium.8
The amounts of DU involved violate the limits discussed above.!!Using the weighted average value of the DU concentration provided in the Profile Record (311 nCi/gram), and the lowest value of density of 2.5 grams/cc, each drum contains just over half a metric ton of DU, almost all of which would be U-238 (by mass). This amounts to about 0.16 curies of U-238 per 55-gallon drum. Hence the limit of 17 curies would be reached in about 105 drums. If we use a median value of density,9 the value of 17 curies would in about 78 drums.
Seen another way, the 33,000 drums can be expected to contain about 5,300 curies or more of U- 238. This is over 300 times more than the maximum amount covered by the draft EIS that was part of the process that created the existing rule.
The DOE shipment also violates the concentration limit by a large amount. At the lowest density, the typical DU concentration in a drum would be about 780 nanocuries per cc. A median concentration would be about 1,040 nanocuries per cc, corresponding to a density of 3.35 grams/cc.10 Both these values are tens of thousands of times greater than the concentration of 17 picocuries per cc (0.017 nanocuries per cc) analyzed in the EIS. They are also about 16 to 21 !!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! " NRC Transcript September 2, 2009, pp. 78-79.!! 8 Seventeen curies of U-238 would weigh about 51 metric tons. As DU this would contain 0.1 to 0.15 metric tons of U-235, amounting to 0.2 to 0.3 curies (rounded) of U-235. 9 Assumed here to be the geometric mean of the lowest and highest values provided. 10 This value is the geometric mean of 2.5 and 4.5 grams per cc, the range of densities provided by the DOE in the shipment manifest. times higher than the limit of 50 nanocuries per cc for U-238 proposed in the draft low-level waste EIS.
The NRC has formally and publicly stated that any amounts of DU containing U-238 in excess of 17 curies or concentrations greater than 50 nanocuries per cc were not covered by the environmental impact analysis done for the low-level waste rule. Utah’s authority to regulate disposal of LLRW derives from its status as an Agreement State under the Atomic Energy Act. As an Agreement State, Utah has an obligation to establish a regulatory program that is “adequate to protect public health and safety” and “compatible with the Commission’s program.”11 DU disposal was not even considered in the NRC’s Final EIS for the LLRW disposal rule and there is no existing NRC regulation that governs disposal of DU in the concentrations and quantities contemplated by the DOE in this case. The NRC has only just taken the first steps in its rulemaking for disposal of large quantities and high concentrations of DU. It has not prepared a formal draft environmental analysis under the National Environmental Policy Act (NEPA) for public comment. At this point, the State of Utah has no basis for establishing permit conditions for disposal of the DU that would be “compatible” with the NRC’s program. Compatibility is especially important here since the disposal of large amounts of DU or DU in high concentrations has significant implications beyond the boundaries of the State of Utah.
In sum, the disposal of large amounts of DU or DU concentrations greater than 50 nancocuies per cc as Class A waste is not authorized by the federal regulations that form the basis for the State of Utah’s own regulatory program; nor has the NRC subjected it to the environmental analysis required under the National Environmental Protection Act.
2. Recycled Uranium
Recycled uranium in any amount cannot be disposed of as Class A waste. Specifically, 10 CFR 61.55(a)(4)states:
Classification determined by short-lived radionuclides. If radioactive waste does not contain any of the radionuclides listed in Table 1, classification shall be determined based on the concentrations shown in Table 2. However, as specified in paragraph (a)(6) of this section, if radioactive waste does not contain any nuclides listed in either Table 1 or 2, it is Class A.
Further, 10 CFR 61.55(a)(6) states:
Classification of wastes with radionuclides other than those listed in Tables 1 and 2. If radioactive waste does not contain any nuclides listed in either Table 1 or 2, it is Class A.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 11 Statement of Principles and Policy for the Agreement State Program; Policy Statement on Adequacy and Compatibility of Agreement State Programs, Nuclear Regulatory Commission, September 3, 1997, one the web at http://www.nrc.gov/reading-rm/doc-collections/commission/policy/62fr46517.pdf. . When the nuclear industry as well as the NRC staff argued (incorrectly as the Commission’s decisions have shown) that pure DU even in large quantities could be disposed of as Class A waste under 10 CFR 61.55(a)(6), even they noted that the DU they were speaking about did not contain any radionuclides in Table 1 or Table 2 of 10 CFR 61.55(a). For instance, the NRC staff testimony stated:
Q.7. Is Envirocare authorized to accept the type of radioactive waste that will be generated by the NEF [National Enrichment Facility]?
A.7. (TJ, JP, DP) Yes. Envirocare, which is regulated by the State of Utah Department of Environmental Quality Division of Radiation Control, is licensed to accept Class A low-level radioactive waste. Staff Exhibit 36 at 2-32. The Commission, in its decision Louisiana Energy Services, L.P., CLI-05-5, 61 NRC 22 (2005), determined that depleted uranium is low-level waste. As explained in our FEIS, for regulatory purposes low level radioactive waste is categorized in three classifications: Class A, B or C based on the concentration of certain long- lived radionuclides which are set forth in Tables 1 and 2 of 10 C.F.R. § 61.55. The regulation further provides, in § 61 .55(a)(6), that if radioactive waste does not contain any of the nuclides listed in those Tables, it is Class A. Depleted uranium consists mostly of long-lived isotopes of uranium, with small quantities of thorium-234 and protactinium-234. None of those isotopes is listed in Table 1 or 2. Accordingly, pursuant to 10 C.F.R. § 61 .55(a)(6), depleted uranium is considered Class A low level radioactive waste.12
As we have seen the Commission has recognized and the NRC Staff has accepted that, contrary to the NRC Staff view just quoted, large amounts of DU were not covered by the low-level waste regulation. But there has been no assertion that DU containing contaminants listed in Table 1 or Table 2, much less both, would be Class A waste under 10 CFR 61.55(a)(6).
The DU that has been shipped from SRS to Clive, Utah, contains radionuclides from Table 1 (Tc-99, transuranic alpha-emitting radionuclides, plutonium-241 and iodine-129).13 In addition, some radionuclides listed in Table 1 were not even analyzed (carbon-14, niobium-94, and nickel- 59 in activated metal) because they were expected to be present in “trace quantities only.”14 The SRS DU also contains radionuclides listed in Table 2, including strontium-90 and cesium-137. Two of the radionuclides in Table 2, cobalt-60 and nickel-63, were not analyzed for similar reasons. In the plain language of the paragraphs of the LLRW disposal rule cited above, recycled DU cannot be considered as Class A waste.
This analysis shows that depleted uranium waste containing any amounts of radionuclides listed in Table 1 or Table 2 of 10 CFR 61.55(a) cannot be disposed of as Class A waste. The SRS waste in question contains at least some of these radionuclides. This is apart from the question of the Class A limit for Tc-99, which is discussed in Attachment B.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 12 In the Matter of Louisiana Energy Services, Closed Hearing, Publicly Available Version, Atomic Safety Licensing Board, Nuclear Regulatory Commission, October 27, 2007, (NRC ADAMS # ML053610160) pdf pp. 16- 17. Emphasis added. An industry view can be found in the same proceedings. See the testimony of the Louisiana Energy Services of October 26, 2005, Closed Hearing, Publicly Available Version, (NRC ADAMS # ML053610166) pdf pp. 294-295. 13 Parkinson 2002. See also Profile Record 2009. 14 Parkinson 2002, table showing radionuclides not analyzed and text that follows the table. No page numbers. What makes the shipments from SRS to EnergySolutions especially egregious is that the shipments are occurring as the Nuclear Regulatory Commission has acknowledged the need for, and is actively considering, restrictions on the disposal of large amounts DU as low-level waste.
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Estimating the Number of Drums Exceeding the Utah’s Class A limit for Technetium-99
Dr. Harry Chmelynski ! Summary
The Department of Energy provided measurements of radionuclides and other data regarding drums of depleted uranium waste recently shipped from the Savannah River Site (SRS) to the EnergySolutions Class A radioactive waste disposal facility. This report addresses whether any of the drums might exceed Utah’s Class A limit of 0.3 Ci/m3 for technetium-99 (Tc-99).15!
The DOE sampled only 33 drums of about 33,000 drums of depleted uranium oxide. The manifest declares that “all samples” meet the WAC, but this assurance is provided using a single, low point estimate for density of 2.66 grams/cc, without taking into account stated variation in density of 2.5 to 4.5 grams/cc. It is also misleading in that the uncertainty in the Tc-99 content of the drums is not addressed.
This statistical analysis shows that, based on the Tc-99 measurements and density data in the Profile Record, a large number of drums would exceed Utah’s Class A limit for Tc-99 of 0.3 Ci/m3, which is also the federal limit. Four different distributions of Tc-99 in the drums were analyzed. A triangular distribution for density, with the mode at the low value of 2.66 grams/cc, used by DOE, was used. This is rather conservative in the sense that other choices, such as a uniform distribution, would result in higher estimates of the number of drums that would violate the Tc-99 Class A limit.
The results of the statistical analysis of the number of drums exceeding the Class A limit are shown in Table S-1. This analysis shows a “consensus estimate” (in the statistical sense) 16 of the 99 percent confidence range for the number of drums exceeding the Tc-99 limit as 682 drums to 5,678 drums. The best estimate is 3,180 drums or almost 10 percent of the drums. The range of best estimates is 2,253 to 4,036 drums, depending on the distribution chosen for the Tc-99 measurements. All four distributions give a lower 99 percent confidence bound of more than 2,000 drums exceeding the Tc-99 Class A limit.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 15 10 CFR 61.55(a)(3)(i); Classification and Characteristics of Low-Level Radioactive Waste, R313-15-1008, http://www.rules.utah.gov/publicat/code/r313/r313-015.htm#T46; and Bulk Waste Disposal and Treatment Facilities Waste Acceptance Criteria: (Includes Class A LLRW, Mixed Waste, and 11e.(2) Disposal Embankments), revision 7, http://www.energysolutions.com/alpha/license/BWF_WAC.pdf 16 The consensus estimate is the arithmetic mean of the best estimates obtained from the four simulations of technetium-99 activity. Confidence intervals for the consensus estimate of the number of drums exceeding the Class A limit are derived using the t-distribution with three degrees of freedom.
Table S-1: Number of Drums Exceeding the Class A limit for Tc-99
Assumed Best 95% Confidence Interval 99% Confidence Interval Lower Upper Lower Upper Distribution Estimate Bound Bound Bound Bound Uniform 2,253 2,162 2,345 2,131 2,371 Normal 2,667 2,572 2,764 2,544 2,796 Gamma 3,763 3,650 3,877 3,614 3,914 Lognormal 4,036 3,922 4,154 3,882 4,186 Consensus 3,180 1,819 4,541 682 5,678 Estimate
1. Technical Approach
Information submitted by Savannah River Nuclear Solutions in the Radioactive Waste Profile Record for approximately 33,000 drums of depleted uranium trioxide (UO3) 17 is based on calculations that rely on the average and "maximum" specific activity values derived from a small sample of 33 drums (0.1 percent sample) multiplied by a rather low point estimate of a second uncertain quantity – the waste density. The uncertainty accompanying these calculations is not reported. This paper addresses the issue of uncertainty in the technetium-99 calculations through the use of Monte Carlo simulation models. The models simulate the activity in 33,000 drums containing waste with random specific activity from a variety of probability distributions and random density. A software add-in program for Microsoft Excel named Crystal Ball from Decisioneering, Inc., was used to perform the simulations.
Attachment 1 to Parkinson 2002 in the waste profile record submitted by Savannah River includes measurements of the specific activity of technetium-99 in 33 sampled drums shown in Table 1. The frequency distribution of the samples is shown in the histogram in Figure 1. The shape of this plot is subject to a variety of interpretations, with no clear pattern due to the relatively small sample size. Six types of probability distributions were selected as possible candidates for the sample values: uniform, triangular, normal, lognormal, gamma, and Pareto.
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 17 The data are from Parkinson 2002 and Profile Record 2009.
Table 1: Technetium-99 Specific Activity Measurements Reported by DOE
Sample ID Measurement Sample Measurement ID nCi/g nCi/g 1 44.2 18 64.7 2 57.5 19 16.1 3 21.2 20 14.9 4 33.3 21 27.2 5 15.7 22 8.1 6 19.1 23 15.7 7 18.5 24 9.0 8 24.5 25 93.8 9 90.2 26 92.7 10 79.7 27 32.5 11 89.8 28 55.3 12 79.7 29 53.8 13 37.5 30 88.5 14 75.3 31 93.7 15 34.2 32 54.3 16 74.2 33 73.0 17 41.4
9 8 7 6 5 4
Frequency 3 2 1 0 7.5 22.5 37.5 52.5 67.5 82.5 97.5 Tc-99 Activity (nCi/g)
Figure 1: Histogram Showing the Frequency Distribution of the 33 Technetium-99 Sample Measurements
Crystal Ball was used to select the best fitting probability distributions. The Batch Fit function in Crystal Ball was applied in a step-wise procedure to find the best-fitting distributions for the samples in Figure 1. Crystal Ball provides a choice of three statistical measures of fit – Chi Squared; Kolmogorov-Smirnov; and Anderson-Darling – for selecting the best-fitting distribution from the set of candidate distributions. The three criteria were applied in a step-wise procedure to select the best fitting distributions for the technetium-99 samples.
In stage 1 of the step-wise procedure, the Chi Squared criterion in Crystal Ball produced the ranked results shown in Table 2. According to the Chi Squared criterion, the best-fitting probability distribution is the lognormal distribution. The correlation of the lognormal distribution with the technetium-99 sample measurements is shown in a scatter plot in Figure 2. Deviations of the sample values from the dashed regression line are an indication that the data may not fit a lognormal distribution. However, the correlation (R) is relatively high at 0.96.
Table 2: First Stage of Model Selection Using the Chi Squared Criterion
Data Series: Technetium-99 Chi-squared p- 0.735758883 value: Best fit: Lognormal
1 Lognormal 0.735758883 2 Normal 0.658250763 3 Gamma 0.572406707 4 Uniform 0.513264961 5 Triangular 0.008261465 6 Pareto 7.28246E-06 ! !
R2 = 0.92
! Figure 2: Correlation of the Lognormal Distribution with Technetium-99 Sample Measurements
In the second stage of the step-wise procedure, the Kolmogorov-Smirnov criterion was applied to select the best-fitting of the remaining five probability distributions. The results of the second stage are shown in Table 3. The Kolmogorov-Smirnov selection criterion selects the uniform distribution as the best fitting distribution. The correlation of the uniform distribution with technetium-99 sample measurements is shown in Figure 3. The uniform distribution appears to fit the data better than the lognormal, and the correlation is higher at 0.99. However, the uniform distribution has a fixed upper bound that is likely to be violated in a large population of 33,000 drums. For example, in a simulation using the best-fitting normal distribution (reported below), the maximum activity in 33,000 drums was found to be 52% higher than the maximum of the 33 sample values reported by the DOE, with a 99 percent confidence interval ranging from 36% to 85%.
Table 3: Second Stage of Model Selection Using the Kolmogorov-Smirnov Criterion
Data Series: Technetium-99 Kolmogorov- 0.108194652 Smirnov: Best fit: Uniform
1 Uniform 0.108194652 2 Normal 0.123674853 3 Gamma 0.142254592 4 Triangular 0.200571689 5 Pareto 0.27120283 ! !
R2 = 0.98
! Figure 3: Correlation of the Uniform Distribution with Technetium-99 Sample Measurements
In the third stage of the step-wise selection procedure, the Anderson-Darling selection criterion was applied to select the best-fitting of the remaining four probability distributions. The results of the third stage are shown in Table 4. The Anderson-Darling criterion selects the gamma distribution as the best fitting distribution of the remaining four. The gamma distribution is similar to the lognormal distribution, with less weight in the upper tail. Since the normal distribution appears as the second best distribution in all three stages of the selection procedure, the normal distribution was also included in the simulation study as the wild card. The correlation of the normal distribution with technetium-99 sample measurements is shown in Figure 4. The plot is similar to the lognormal distribution plot in Figure 2, with approximately the same correlation.
Table 4: Third Stage of Model Selection Using the Anderson-Darling Criterion ! Data Series: Technetium-99 Anderson- 0.799840342 Darling: Best fit: Gamma
1 Gamma 0.799840342 2 Normal 0.942950967 3 Triangular 1.995038267 4 Pareto 4.342894632 ! !
R2 = 0.92
! Figure 4: Correlation of the Normal Distribution with Technetium-99 Sample Measurements
Crystal Ball was used to estimate the parameters for the each of the four probability distributions selected above. The parameter estimates are shown in Table 5. Figure 5 contains frequency plots showing 5,000 simulated values from each of the four probability distributions selected by Crystal Ball. The best-fitting uniform distribution at the bottom of the figure has no tail extending beyond 100 nCi/g, but the other three probability distributions have no fixed upper bound, with non-negligible upper tails extending well above this value.
Table 5: Parameter Estimates for the Four Probability Distributions Selected for Simulation of Technetium-99 Specific Activity ! Distribution Parameter Estimate Uniform Minimum 5.42 Maximum 96.48 Normal Mean 49.37 Standard Deviation 29.26 Gamma Location 7.24 Scale 30.99 Shape 1.36 Lognormal Geometric Mean 39.52 Geometric Standard 2.08 Deviation ! !
! Figure 5: Comparison of the Four Probability Distributions Selected for Simulation of Technetium-99 Specific Activity
Part B.1 of the waste profile record submitted by Savannah River states that the density of the waste material ranges from 2.5 to 4.5 grams per cubic centimeter (g/cc). In the accompanying interoffice memo (Parkinson 2002), DOE states that the average and maximum technetium-99 drum activities are 0.1313 and 0.2495 curies per cubic meter (Ci/m3), respectively. These values are consistent with an assumed density of 2.66 g/cc. However, it was stated that the density of the waste material may range from 2.5 to 4.5 g/cc. DOE has selected a density very near the lower end of this range. A triangular distribution was used to reflect the uncertainty in the density of the waste. The distribution selected for the waste density ranges from 2.5 to 4.5 g/cc with a most likely value (the mode) of 2.66 g/cc. The frequency distribution of a Crystal Ball sample of 5,000 values is shown in Figure 6. This is rather conservative in the sense that other choices, such as a uniform distribution, would result in higher estimates of the number of drums that would violate the Tc-99 Class A limit. !
! Figure 6: Triangular Distribution Selected for Simulation of Waste Density ! ! 2. Simulation Results
The DOE (in Parkinson’s memo) reports sampling only 33 drums of about 33,000 drums of depleted uranium oxide. The memo declares that “all samples” meet the Waste Acceptance Criteria (WAC), but this assurance is provided using a single, low point estimate for density of 2.66 grams/cc, without taking into account stated variation in density of 2.5 to 4.5 grams/cc. It is also misleading in that the uncertainty in the Tc-99 content is ignored. The DOE did not report the uncertainty accompanying these calculations. As a result, the DOE memo gives a misleading impression that the 33,000 drums are in compliance with the Tc-99 Class A low-level waste limit of 0.3 Ci/m3.
This paper addresses the issue of uncertainty in the technetium-99 calculations through the use of Monte Carlo simulation models. The waste activity and waste density probability distributions derived in the previous section were applied in Crystal Ball. One model was constructed for each of the four probability distributions selected as a model of the specific activity. Each model simulates the activity in 33,000 drums containing waste with random specific activity from the appropriate distribution multiplied by a random density selected from the triangular distribution described above. Results of the simulation are shown in Figure 7 for each of the four selected probability distributions. The vertical line in the figure shows the Envirocare (now known as EnergySolutions) Waste Acceptance Criterion limit for technetium-99, which is the same as Utah’s Class A limit for this radionuclide. For each type of distribution, the upper tail of the distribution of drum activities extends beyond Utah’s Class A limit for technetium-99.
!
! Figure 7: Four Simulated Distributions of Drum Activity Compared with Waste Acceptance Criterion (WAC)—i.e., the Class A limit—for Technetium-99
Each simulation results in an estimate of the count of the number of containers with activity exceeding the WAC of 0.3 Ci/m3. This count was recorded by Crystal Ball after each iteration of the model. The simulation of the 33,000 drums was repeated 5,000 times to determine uncertainty in the number of containers over the WAC. The results of the simulation are shown in Figure 8. The uncertainty in the number of drums exceeding the WAC is relatively small when compared with the much larger variability due to the type of probability distribution selected for the specific activity. A substantial number of drums exceed the WAC, independent of the choice of the distribution of Tc-99 concentrations. Hence, this is a robust result, given the measurements and data in the Profile Record.
!
! Figure 8: Simulated Number of Drums Exceeding Waste Acceptance Criterion (WAC) for Technetium- 99
Table 6 shows the best point estimate, the arithmetic mean of the 5,000 iterations, for the number of drums exceeding the WAC for technetium-99. The best estimates range from over 2,000 drums to 4,000 drums. The simulated 95% and 99% confidence intervals for the number of drums exceeding the WAC under each selected distribution are also shown in the table. Numerical values for the upper and lower bounds of the 95% and 99% confidence intervals for the number of drums over the WAC are shown in Table 7. The uncertainty ranges for each best estimate are only a small fraction of the estimate, ranging up to approximately ±6%.
Table 7 also contains a consensus estimate for the number of drums exceeding the WAC in the final row of the table. The consensus estimate was obtained as the simple arithmetic average of the four best estimates. The confidence intervals for the consensus estimate of the number of drums exceeding the WAC are derived using the t-distribution with three degrees of freedom. The 99% confidence interval for the consensus estimate ranges from approximately 700 to 5,700 drums. Based on the available data and the assumptions of the simulation, it is almost a certainty that hundreds, perhaps thousands, of the 33,000 drums will exceed Utah’s Class A limit for technetium-99.
Table 6: Best Estimates for the Number of Drums Exceeding the Waste Acceptance Criterion (Class A limit) for Technetium-99, with 95% and 99% Confidence Intervals ! Assumed Best 95% Confidence 99% Confidence Distribution Estimate Interval Interval Uniform 2,253 #! 92 #! 122 Normal 2,667 #! 97 #! 129 Gamma 3,763 #! 114 #! 151 Lognormal 4,036 #! 118 #! 154 ! ! ! Table 7: Range of Estimates for the Number of Drums Exceeding the Waste Acceptance Criterion (Class A limit) for Technetium-99 ! 95% Confidence 99% Confidence Assumed Best Interval Interval Lower Upper Lower Upper Distribution Estimate Bound Bound Bound Bound Uniform 2,253 2,162 2,345 2,131 2,371 Normal 2,667 2,572 2,764 2,544 2,796 Gamma 3,763 3,650 3,877 3,614 3,914 Lognormal 4,036 3,922 4,154 3,882 4,186 Consensus 3,180 1,819 4,541 682 5,678 Estimate18 ! ! !
!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!! 18 The consensus estimate is the arithmetic mean of the best estimates obtained from the four simulations of technetium-99 activity. Confidence intervals for the consensus estimate of the number of drums exceeding the WAC are derived using the t-distribution with three degrees of freedom.
\
Curriculum Vita of Arjun Makhijani Address and Phone: Institute for Energy and Environmental Research 6935 Laurel Ave., Suite 201 Takoma Park, MD 20912 Phone: 301-270-5500 e-mail: [email protected] Website: www.ieer.org
A recognized authority on energy issues, Dr. Makhijani is the author and co-author of numerous reports and books on energy and environment related issues, including two published by MIT Press. He was the principal author of the first study of the energy efficiency potential of the US economy published in 1971. He is the author of Carbon-Free and Nuclear-Free: A Roadmap for U.S. Energy Policy (2007).
In 2007, he was elected Fellow of the American Physical Society. He was named a Ploughshares Hero, by the Ploughshares Fund (2006); was awarded the Jane Bagley Lehman Award of the Tides Foundation in 2008 and the Josephine Butler Nuclear Free Future Award in 2001; and in 1989 he received The John Bartlow Martin Award for Public Interest Magazine Journalism of the Medill School of Journalism, Northwestern University, with Robert Alvarez. He has many published articles in journals and magazines as varied as The Bulletin of the Atomic Scientists, Environment, The Physics of Fluids, The Journal of the American Medical Association, and The Progressive, as well as in newspapers, including the Washington Post.
Dr. Makhijani has testified before Congress, and has appeared on ABC World News Tonight, the CBS Evening News, CBS 60 Minutes, NPR, CNN, and BBC, among others. He has served as a consultant on energy issues to utilities, including the Tennessee Valley Authority, the Edison Electric Institute, the Lawrence Berkeley Laboratory, and several agencies of the United Nations.
Education:
x Ph.D. University of California, Berkeley, 1972, from the Department of Electrical Engineering. Area of specialization: plasma physics as applied to controlled nuclear fusion. Dissertation topic: multiple mirror confinement of plasmas. Minor fields of doctoral study: statistics and physics. x M.S. (Electrical Engineering) Washington State University, Pullman, Washington, 1967. Thesis topic: electromagnetic wave propagation in the ionosphere. x Bachelor of Engineering (Electrical), University of Bombay, Bombay, India, 1965. Current Employment:
x 1987-present: President and Senior Engineer, Institute for Energy and Environmental Research, Takoma Park, Maryland. (part-time in 1987). x February 3, 2004-present, Associate, SC&A, Inc., one of the principal investigators in the audit of the reconstruction of worker radiation doses under the Energy Employees Occupational Illness Compensation Program Act under contract to the Centers for Disease Control and Prevention, U.S. Department of Health and Human Services.
Other Long-term Employment
x 1984-88: Associate Professor, Capitol College, Laurel, Maryland (part-time in 1988). x 1983-84: Assistant Professor, Capitol College, Laurel, Maryland. x 1977-79: Visiting Professor, National Institute of Bank Management, Bombay, India. Principal responsibility: evaluation of the Institute's extensive pilot rural development program. x 1975-87: Independent consultant (see page 2 for details) x 1972-74: Project Specialist, Ford Foundation Energy Policy Project. Responsibilities included research and writing on the technical and economic aspects of energy conservation and supply in the U.S.; analysis of Third World rural energy problems; preparation of requests for proposals; evaluation of proposals; and the management of grants made by the Project to other institutions. x 1969-70: Assistant Electrical Engineer, Kaiser Engineers, Oakland California. Responsibilities included the design and checking of the electrical aspects of mineral industries such as cement plants, and plants for processing mineral ores such as lead and uranium ores. Pioneered the use of the desk-top computer at Kaiser Engineers for performing electrical design calculations.
Professional Societies:
x Institute of Electrical and Electronics Engineers and its Power Engineering Society x American Physical Society (Fellow) x Health Physics Society x American Association for the Advancement of Science
Awards and Honors:
x The John Bartlow Martin Award for Public Interest Magazine Journalism of the Medill School of Journalism, Northwestern University, 1989, with Robert Alvarez x The Josephine Butler Nuclear Free Future Award, 2001 x Ploughshares Hero, Ploughshares Fund, 2006 x Elected a Fellow of the American Physical Society, 2007, “For his tireless efforts to provide the public with accurate and understandable information on energy and environmental issues” x Jane Bagley Lehman Award of the Tides Foundation, 2007/2008
2 Invited Faculty Member, Center for Health and the Global Environment, Harvard Medical School: Annual Congressional Course, Environmental Change: The Science and Human Health Impacts, April 18-19, 2006, Lecture Topic: An Update on Nuclear Power - Is it Safe?
Consulting Experience, 1975-1987 Consultant on a wide variety of issues relating to technical and economic analyses of alternative energy sources; electric utility rates and investment planning; energy conservation; analysis of energy use in agriculture; US energy policy; energy policy for the Third World; evaluations of portions of the nuclear fuel cycle.
Partial list of institutions to which I was a consultant in the 1975-87 period:
x Tennessee Valley Authority x Lower Colorado River Authority x Federation of Rocky Mountain States x Environmental Policy Institute x Lawrence Berkeley Laboratory x Food and Agriculture Organization of the United Nations x International Labour Office of the United Nations x United Nations Environment Programme x United Nations Center on Transnational Corporations x The Ford Foundation x Economic and Social Commission for Asia and the Pacific x United Nations Development Programme
Languages: English, French, Hindi, Sindhi, and Marathi.
Reports, Books, and Articles (Partial list)
(Newsletter, newspaper articles, excerpts from publications reprinted in books and magazines or adapted therein, and other similar publications are not listed below)
Hower, G.L., and A. Makhijani, "Further Comparison of Spread-F and Backscatter Sounder Measurements," Journal of Geophysical Research, 74, p. 3723, 1969.
Makhijani, A., and A.J. Lichtenberg, An Assessment of Energy and Materials Utilization in the U.S.A., University of California Electronics Research Laboratory, Berkeley, 1971.
Logan, B. G., A.J. Lichtenberg, M. Lieberman, and A. Makhijani, "Multiple-Mirror Confinement of Plasmas," Physical Review Letters, 28, 144, 1972.
Makhijani, A., and A.J. Lichtenberg, "Energy and Well-Being," Environment, 14, 10, June 1972.
Makhijani, A., A.J. Lichtenberg, M. Lieberman, and B. Logan, "Plasma Confinement in Multiple Mirror Systems. I. Theory," Physics of Fluids, 17, 1291, 1974.
3 A Time to Choose: America's Energy Future, final report of the Ford Foundation Energy Policy Project, Ballinger, Cambridge, 1974. One of many co-authors.
Makhijani, A., and A. Poole, Energy and Agriculture in the Third World, Ballinger, Cambridge, 1975.
Makhijani, A., Energy Policy for the Rural Third World, International Institute for Environment and Development, London, 1976.
Kahn, E., M. Davidson, A. Makhijani, P. Caeser, and S. Berman, Investment Planning in the Energy Sector, Lawrence Berkeley Laboratory, Berkeley, 1976.
Makhijani, A., "Solar Energy for the Rural Third World," Bulletin of the Atomic Scientists, May 1977.
Makhijani, A., "Energy Policy for Rural India," Economic and Political Weekly, 12, Bombay, 1977.
Makhijani, A., Some Questions of Method in the Tennessee Valley Authority Rate Study, Report to the Tennessee Valley Authority, Chattanooga, 1978.
Makhijani, A., The Economics and Sociology of Alternative Energy Sources, Economic and Social Commission for Asia and the Pacific, 1979.
Makhijani, A., Energy Use in the Post-Harvest Component of the Food Systems in Ivory Coast and Nicaragua, Food and Agriculture Organization of the United Nations, Rome, 1982.
Makhijani, A., Oil Prices and the Crises of Debt and Unemployment: Methodological and Structural Aspects, International Labour Office of the United Nations, Final Draft Report, Geneva, April 1983.
Makhijani, A., and D. Albright, The Irradiation of Personnel at Operation Crossroads, International Radiation Research and Training Institute, Washington, D.C., 1983.
Makhijani, A., K.M. Tucker, with Appendix by D. White, Heat, High Water, and Rock Instability at Hanford, Health and Energy Institute, Washington, D.C., 1985.
Makhijani, A., and J. Kelly, Target: Japan - The Decision to Bomb Hiroshima and Nagasaki, July 1985, a report published as a book in Japanese under the title, Why Japan?, Kyoikusha, Tokyo, 1985.
Makhijani, A., Experimental Irradiation of Air Force Personnel During Operation Redwing - 1956, Environmental Policy Institute, Washington, D.C., 1985.
Makhijani, A., and R.S. Browne, "Restructuring the International Monetary System," World Policy Journal, New York, Winter, 1985-86.
4 Makhijani, A., R. Alvarez, and B. Blackwelder, Deadly Crop in the Tank Farm: An Assessment of Management of High-Level Radioactive Wastes in the Savannah River Plant Tank Farm, Environmental Policy Institute, Washington, D.C., 1986.
Makhijani, A., "Relative Wages and Productivity in International Competition," College Industry Conference Proceedings, American Society for Engineering Education, Washington, D.C., 1987.
Makhijani, A., An Assessment of the Energy Recovery Aspect of the Proposed Mass Burn Facility at Preston, Connecticut, Institute for Energy and Environmental Research, Takoma Park, 1987.
Makhijani, A., R. Alvarez, and B. Blackwelder, Evading the Deadly Issues: Corporate Mismanagement of America's Nuclear Weapons Production, Environmental Policy Institute, Washington, D.C., 1987.
Franke, B. and A. Makhijani, Avoidable Death: A Review of the Selection and Characterization of a Radioactive Waste Repository in West Germany, Health & Energy Institute, Washington, DC; Institute for Energy and Environmental Research, Takoma Park, November 1987.
Makhijani, A., Release Estimates of Radioactive and Non-Radioactive Materials to the Environment by the Feed Materials Production Center, 1951-85, Institute for Energy and Environmental Research, Takoma Park, 1988.
Alvarez, R., and A. Makhijani, "The Hidden Nuclear Legacy," Technology Review, 91, 42,1988.
Makhijani, A., Annie Makhijani, and A. Bickel, Saving Our Skins: Technical Potential and Policies for the Elimination of Ozone-Depleting Chlorine Compounds, Environmental Policy Institute and Institute for Energy and Environmental Research, Takoma Park, 1988.
Makhijani, A., Annie Makhijani, and A. Bickel, Reducing Ozone-Depleting Chlorine and Bromine Accumulations in the Stratosphere: A Critique of the U.S. Environmental Protection Agency's Analysis and Recommendations, Institute for Energy and Environmental Research and Environmental Policy Institute/Friends of the Earth, Takoma Park, 1989.
Makhijani, A., and B. Franke, Addendum to Release Estimates of Radioactive and Non- Radioactive Materials to the Environment by the Feed Materials Production Center, 1951-85, Institute for Energy and Environmental Research, Takoma Park, 1989.
Makhijani, A., Global Warming and Ozone Depletion: An Action Program for States, Institute for Energy and Environmental Research, Takoma Park, 1989.
Makhijani, A., Managing Municipal Solid Wastes in Montgomery County, Prepared for the Sugarloaf Citizens Association, Institute for Energy and Environmental Research, Takoma Park, 1990.
Saleska, S., and A. Makhijani, To Reprocess or Not to Reprocess: The Purex Question - A Preliminary Assessment of Alternatives for the Management of N-Reactor Irradiated Fuel at the
5 U.S. Department of Energy's Hanford Nuclear Weapons Production Facility, Institute for Energy and Environmental Research, Takoma Park, 1990.
Makhijani, A., "Common Security is Far Off," Bulletin of the Atomic Scientists, May 1990.
Makhijani, A., Draft Power in South Asian Agriculture: Analysis of the Problem and Suggestions for Policy, prepared for the Office of Technology Assessment, Institute for Energy and Environmental Research, Takoma Park, 1990.
Mehta, P.S., S.J. Mehta, A.S. Mehta, and A. Makhijani, "Bhopal Tragedy's Health Effects: A Review of Methyl Isocyanate Toxicity," JAMA 264, 2781, December 1990.
Special Commission of International Physicians for the Prevention of Nuclear War and the Institute for Energy and Environmental Research, Radioactive Heaven and Earth: The Health and Environmental Effects of Nuclear Weapons Testing In, On, and Above the Earth, Apex Press, New York, 1991. One of many co-authors.
Makhijani, A., and S. Saleska, High Level Dollars Low-Level Sense: A Critique of Present Policy for the Management of Long-Lived Radioactive Waste and Discussion of an Alternative Approach, Apex Press, New York, 1992.
Makhijani, A., From Global Capitalism to Economic Justice: An Inquiry into the Elimination of Systemic Poverty, Violence and Environmental Destruction in the World Economy, Apex Press, New York, 1992.
Special Commission of International Physicians for the Prevention of Nuclear War and the Institute for Energy and Environmental Research, Plutonium: Deadly Gold of the Nuclear Age, International Physicians Press, Cambridge, MA, 1992. One of several co-authors.
Makhijani, A., "Energy Enters Guilty Plea," Bulletin of the Atomic Scientists, March/April 1994.
Makhijani, A., "Open the Files," Bulletin of the Atomic Scientists, Jan./Feb. 1995.
Makhijani, A., " 'Always' the Target?" Bulletin of the Atomic Scientists, May/June 1995.
Makhijani, A., and Annie Makhijani, Fissile Materials in a Glass, Darkly: Technical and Policy Aspects of the Disposition of Plutonium and Highly Enriched Uranium, IEER Press, Takoma Park, 1995.
Makhijani, A., and K. Gurney, Mending the Ozone Hole: Science, Technology, and Policy, MIT Press, Cambridge, MA, 1995.
Makhijani, A., H. Hu, K. Yih, eds., Nuclear Wastelands: A Global Guide to Nuclear Weapons Production and the Health and Environmental Effects, MIT Press, Cambridge, MA, 1995.
6 Zerriffi, H., and A. Makhijani, The Nuclear Safety Smokescreen: Warhead Safety and Reliability and the Science Based Stockpile Stewardship Program, Institute for Energy and Environmental Research, Takoma Park, May 1996.
Zerriffi, H., and A. Makhijani, "The Stewardship Smokescreen," Bulletin of the Atomic Scientists, September/October 1996.
Makhijani, A., Energy Efficiency Investments as a Source of Foreign Exchange, prepared for the International Energy Agency Conference in Chelyabinsk, Russia, 24-26 September 1996.
Makhijani, A., "India's Options," Bulletin of the Atomic Scientists, March/April 1997.
Ortmeyer, P. and A. Makhijani, "Worse than We Knew," Bulletin of the Atomic Scientists, November/December 1997.
Fioravanti, M., and A. Makhijani, Containing the Cold War Mess: Restructuring the Environmental Management of the U.S. Nuclear Weapons Complex, Institute for Energy and Environmental Research, Takoma Park, October 1997.
Principal author of three chapters in Schwartz, S., ed., Atomic Audit: The Costs and Consequences of U.S. Nuclear Weapons Since 1940, Brookings Institution, Washington, D.C., 1998.
Franke, B., and A. Makhijani, Radiation Exposures in the Vicinity of the Uranium Facility in Apollo, Pennsylvania, Institute for Energy and Environmental Research, Takoma Park, February 2, 1998.
Fioravanti, M., and A. Makhijani, Supplement to Containing the Cold War Mess - IEER's Response to the Department of Energy's Review, Institute for Energy and Environmental Research, Takoma Park, March 1998.
Makhijani, A., "A Legacy Lost," Bulletin of the Atomic Scientists, July/August 1998.
Makhijani, A., and Hisham Zerriffi, Dangerous Thermonuclear Quest: The Potential of Explosive Fusion Research for the Development of Pure Fusion Weapons, Institute for Energy and Environmental Research, Takoma Park, July 1998.
Makhijani, A., and Scott Saleska, The Nuclear Power Deception - U.S. Nuclear Mythology from Electricity "Too Cheap to Meter" to "Inherently Safe" Reactors, Apex Press, New York, 1999.
Makhijani, A., "Stepping Back from the Nuclear Cliff," The Progressive, vol. 63, no. 8, August 1999.
Makhijani, A., Bernd Franke, and Hisham Zerriffi, Preliminary Partial Dose Estimates from the Processing of Nuclear Materials at Three Plants during the 1940s and 1950s, Institute for Energy and Environmental Research, Takoma Park, September 2000. (Prepared under contract to the newspaper USA Today.)
7 Makhijani, A., and Bernd Franke, Final Report of the Institute for Energy and Environmental Research on the Second Clean Air Act Audit of Los Alamos National Laboratory by the Independent Technical Audit Team, Institute for Energy and Environmental Research, Takoma Park, December 13, 2000.
Makhijani, A., Plutonium End Game: Managing Global Stocks of Separated Weapons-Usable Commercial and Surplus Nuclear Weapons Plutonium, Institute for Energy and Environmental Research, Takoma Park, January 2001.
Makhijani, A., Hisham Zerriffi, and Annie Makhijani, "Magical Thinking: Another Go at Transmutation," Bulletin of the Atomic Scientists, March/April 2001.
Makhijani, A., Ecology and Genetics: An Essay on the Nature of Life and the Problem of Genetic Engineering. New York: Apex Press, 2001.
Makhijani, A., "Burden of Proof," Bulletin of the Atomic Scientists, July/August 2001.
Makhijani, A., "Reflections on September 11, 2001," in Kamla Bhasin, Smitu Kothari, and Bindia Thapar, eds., Voices of Sanity: Reaching Out for Peace, Lokayan, New Delhi, 2001, pp. 59-64.
Makhijani, A., and Michele Boyd, Poison in the Vadose Zone: An examination of the threats to the Snake River Plain aquifer from the Idaho National Engineering and Environmental Laboratory, Institute for Energy and Environmental Research, Takoma Park, October 2001.
Makhijani, A., Securing the Energy Future of the United States: Securing the Energy Future of the United States: Oil, Nuclear, and Electricity Vulnerabilities and a post-September 11, 2001 Roadmap for Action, Institute for Energy and Environmental Research, Takoma Park, November 2001.
Makhijani, A., and Sriram Gopal, Setting Cleanup Standards to Protect Future Generations: The Scientific Basis of Subsistence Farmer Scenario and Its Application to the Estimation of Radionuclide Soil Action Levels (RSALs) for Rocky Flats, Institute for Energy and Environmental Research, Takoma Park, December 2001.
Makhijani, A., "Some Factors in Assessing the Response to September 11, 2001," Medicine and Global Survival, International Physicians for the Prevention of Nuclear War, Cambridge, Mass., February 2002.
Makhijani, Annie, Linda Gunter, and A. Makhijani, Cogema: Above the Law?: Concerns about the French Parent Company of a U.S. Corporation Set to Process Plutonium in South Carolina. A report prepared by Institute for Energy and Environmental Research and Safe Energy Communication Council. Takoma Park, MD, May 7, 2002.
Deller, N., A. Makhijani, and J. Burroughs, eds., Rule of Power or Rule of Law? An Assessment of U.S. Policies and Actions Regarding Security-Related Treaties, Apex Press, New York, 2003.
8 Makhijani, A., "Nuclear targeting: The first 60 years," Bulletin of the Atomic Scientists, May/June 2003.
Makhijani, A., "Strontium," Chemical & Engineering News, September 8, 2003.
Makhijani, A., and Nicole Deller, NATO and Nuclear Disarmament: An Analysis of the Obligations of the NATO Allies of the United States under the Nuclear Non-Proliferation Treaty and the Comprehensive Test Ban Treaty, Institute for Energy and Environmental Research, Takoma Park, Maryland, October 2003.
Makhijani, A., Manifesto for Global Democracy: Two Essays on Imperialism and the Struggle for Freedom, Apex Press, New York, 2004.
Makhijani, A., "Atomic Myths, Radioactive Realities: Why nuclear power is a poor way to meet energy needs," Journal of Land, Resources, & Environmental Law, v. 24, no. 1, 2004, pp. 61-72. Adapted from an oral presentation given on April 18, 2003, at the Eighth Annual Wallace Stegner Center Symposium titled "Nuclear West: Legacy and Future," held at the University of Utah S.J. Quinney College of Law."
Makhijani, A., and Michele Boyd, Nuclear Dumps by the Riverside: Threats to the Savannah River from Radioactive Contamination at the Savannah River Site, Institute for Energy and Environmental Research, Takoma Park, Maryland, March 2004.
Makhijani, A., and Brice Smith, The Role of E.I. du Pont de Nemours and Company (Du Pont) and the General Electric Company in Plutonium Production and the Associated I-131 Emissions from the Hanford Works, Institute for Energy and Environmental Research, Takoma Park. Maryland, March 30, 2004.
Makhijani, A., Peter Bickel, Aiyou Chen, and Brice Smith, Cash Crop on the Wind Farm: A New Mexico Case Study of the Cost, Price, and Value of Wind-Generated Electricity, Institute for Energy and Environmental Research, Takoma Park, Maryland, April 2004.
Makhijani, A., Lois Chalmers, and Brice Smith, Uranium Enrichment: Just Plain Facts to Fuel an Informed Debate on Nuclear Proliferation and Nuclear Power, Institute for Energy and Environmental Research, Takoma Park, Maryland, October 15, 2004.
Makhijani, A., and Brice Smith, Costs and Risks of Management and Disposal of Depleted Uranium from the National Enrichment Facility Proposed to be Built in Lea County New Mexico by LES, Institute for Energy and Environmental Research, Takoma Park, Maryland, November 24, 2004.
Makhijani, A., project director, Examen critique du programme de recherche de l'ANDRA pour déterminer l'aptitude du site de Bure au confinement géologique des déchets à haute activité et à vie longue: Rapport final, prepared for le Comité ocal d'Information et de Suivi; coordinator: Annie Makhijani; authors: Detlef Appel, Jaak Daemen, George Danko,Yuri Dublyansky, Rod Ewing, Gerhard Jentzsch, Horst Letz, Arjun Makhijani, Institute for Energy and Environmental Research, Takoma Park, Maryland, December 2004
9 Institute for Energy and Environmental Research, Lower Bound for Cesium-137 Releases from the Sodium Burn Pit at the Santa Susana Field Laboratory, IEER, Takoma Park, Maryland, January 13, 2005. (Authored by A. Makhijani and Brice Smith.)
Institute for Energy and Environmental Research, Iodine-131 Releases from the July 1959 Accident at the Atomics International Sodium Reactor Experiment, IEER, Takoma Park, Maryland, January 13, 2005. (Authored by A. Makhijani and Brice Smith.)
Makhijani, A., and Brice Smith. Update to Costs and Risks of Management and Disposal of Depleted Uranium from the National Enrichment Facility Proposed to be Built in Lea County New Mexico by LES. Institute for Energy and Environmental Research, Takoma Park, Maryland, July 5, 2005.
Makhijani, A., "A Readiness to Harm: The Health Effects of Nuclear Weapons Complexes," Arms Control Today, 35, July/August 2005.
Makhijani, A., Bad to the Bone: Analysis of the Federal Maximum Contaminant Levels for Plutonium-239 and Other Alpha-Emitting Transuranic Radionuclides in Drinking Water, Institute for Energy and Environmental Research, Takoma Park, Maryland, August 2005.
Makhijani, A., and Brice Smith, Dangerous Discrepancies: Missing Weapons Plutonium in Los Alamos National Laboratory Waste Accounts, Institute for Energy and Environmental Research, Takoma Park, Maryland, April 21, 2006.
Makhijani, Annie, and A. Makhijani, Low-Carbon Diet without Nukes in France: An Energy Technology and Policy Case Study on Simultaneous Reduction of Climate Change and Proliferation Risks, Institute for Energy and Environmental Research, Takoma Park, Maryland, May 4, 2006.
Makhijani, Annie, and A. Makhijani. Shifting Radioactivity Risks: A Case Study of the K-65 Silos and Silo 3 Remediation and Waste Management at the Fernald Nuclear Weapons Site, Institute for Energy and Environmental Research, Takoma Park, Maryland, August 2006.
Smith, Brice, and A. Makhijani, "Nuclear is Not the Way," Wilson Quarterly, v.30, p. 64, Autumn 2006.
Makhijani, A., Brice Smith, and Michael C. Thorne, Science for the Vulnerable: Setting Radiation and Multiple Exposure Environmental Health Standards to Protect Those Most at Risk, Institute for Energy and Environmental Research, Takoma Park, Maryland, October 19, 2006.
Makhijani, A., Carbon-Free and Nuclear Free: A Roadmap for U.S. Energy Policy, IEER Press, Takoma Park, Maryland; RDR Books, Muskegon, Michigan, 2007.
Makhijani, A., Assessing Nuclear Plant Capital Costs for the Two Proposed NRG Reactors at the South Texas Project Site, Institute for Energy and Environmental Research, Takoma Park, Maryland, March 24, 2008.
10 Makhijani, A., Energy Efficiency Potential: San Antonio's Bright Energy Future, Institute for Energy and Environmental Research, Takoma Park, Maryland, October 9, 2008.
Makhijani, A., The Use of Reference Man in Radiation Protection Standards and Guidance with Recommendations for Change, Institute for Energy and Environmental Research, Takoma Park, Maryland, December 2008.
Makhijani, A., Comments of the Institute for Energy and Environmental Research on the U.S. Nuclear Regulatory Commission’s Proposed Waste Confidence Rule Update and Proposed Rule Regarding Environmental Impacts of Temporary Spent Fuel Storage, Institute for Energy and Environmental Research, Takoma Park, Maryland, February 6, 2009.
Makhijani, A., Technical and Economic Feasibility of a Carbon-Free and Nuclear-Free Energy System in the United States, Institute for Energy and Environmental Research, Takoma Park, Maryland, March 4, 2009.
Fundación Ideas para el Progreso, A New Energy Model For Spain: Recommendations for a Sustainable Future (originally: Un nuevo modelo energético para España: Recomendaciones para un futuro sostenible), by the Working Group of Foundation Ideas for Progress on Energy and Climate Change, Fundación Ideas , Madrid, May 20, 2009. Arjun Makhijani contributed Section 2.2. The cost of nuclear energy and the problem of waste.
Makhijani, A., IEER Comments on the Nuclear Regulatory Commission’s Rulemaking Regarding the “Safe Disposal of Unique Waste Streams Including Significant Quantities of Depleted Uranium,” Institute for Energy and Environmental Research, Takoma Park, Maryland, October 30, 2009.
CV updated January 15, 2010
11 HARRY J. CHMELYNSKI, PhD
CONSULTING STATISTICIAN
Education
Ph.D.Statistics, Carnegie-Mellon University, 1982 M.S.Statistics, Carnegie-Mellon University, 1978 M.S.Physics, University of California at Berkeley, 1972 B.A.Physics/Chemistry, Rensselaer Polytechnic Institute, 1967
Professional Background
2000-present Consulting on the application of statistical methods to technical problems that arise in the areas of energy, radiation, economics and the environment.
1990-2000 SC&A, INC.: Project Director and Senior Statistician. Project Manager of in-house statistical projects and extensive subcontract activities under a recent multi-year prime contract with EPA's Office of Radiation Programs, including a large number of projects for the Radon Division. Project Manager for the National Residential Radon Survey, the National School Radon Survey and the EPA/State Residential Radon Survey.
1987-1990 THE WASHINGTON CONSULTING GROUP: Project Manager and Senior Statistician for environmental and energy projects. Responsible for initiating new tasks, developing the technical approach, directing the analysis, and quality control for project deliverables.
1979-1987 JACK FAUCETT ASSOCIATES: Senior Statistician and Project Director for this economics consulting firm which services a variety of government clients.
1973-1979 CARNEGIE-MELLON UNIVERSITY: Director of the Actuarial Science Program and instructor for the Departments of Mathematics and Physics while in the graduate statistics program.
1967-1970 U.S. MARINE CORPS: Infantry platoon leader, Vietnam. Company commander for enlisted personnel, Marine Corps Research and Development Center. Final rank, Captain.
Professional Experience
1. Technical Support
Currently providing support to NIOSH to evaluate and develop statistical methods for preparing accurate dose reconstructions for past workers at DOE atomic energy sites who have claims under the Energy Employees Occupational 1 HARRY J. CHMELYNSKI, PhD
Illness Compensation Program Act of 2000. Analyzed mathematical and statistical procedures for calculating individual dose estimates based on uncertain historical monitoring data at each site.
Provided support to the Nuclear Regulatory Commission to quantify the risks and uncertainties of recycling clean metal and concrete waste materials from decommissioned nuclear reactor sites using simulation models.
Supported the Nuclear Claims Tribunal in their negotiations with the U.S. government concerning the Pacific nuclear test sites. Applied regression methods to determine the rate of environmental degradation of surface radioactivity on islands near the test site considered for repopulation.
Project Manager for EPA's National School Radon Survey. Responsible for all implementation activities in this large-scale survey involving several firms. Short-term radon tests were conducted in over 30,000 schoolrooms within the allotted two-month winter testing period.
Project Manager for Year 5 and Year 6 of the EPA/State Residential Radon Survey. Responsible for coordination of all subcontract and supplier activities in this multi-firm, multi-year project--for EPA's Office of Radiation Programs.
Supervised data analysis for the School Radon Protocol Development Study. Measurements of schoolroom radon levels were made using seven types of radon detectors, under a variety of heating and ventilation conditions, in different seasons of the year, to support development of EPA's Guidance on Radon in Schools--for the EPA Office of Radiation Programs.
Analysis of required sample sizes for a proposed case-control epidemiological study to measure the relationship of household radon levels to lung cancer risk in non- smokers. Performed power calculations using a linear relative risk model and the National Residential Radon Survey distribution of radon levels--for EPA's Office of Radiation Programs.
Provided technical support to the ORIA in a pilot study on radon in office buildings. Combined Census Building permit data with DOE commercial building survey to develop estimates of the number and type of office buildings in high 2radon areas.
Analysis of U.S. worker radiation exposure data for 1960-1985 to determine trends in the dose distribution, particularly in the upper tails. Estimation of parametric models using the hybrid log-normal distribution provides excellent fit in modeling the extreme tails of these distributions.
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Applied analysis of variance techniques to assess the variability of safety-related characteristics of waste containment tanks at the Hanford facility -- for the Defense Nuclear Facility Safety Board.
2. Program Support/Implementation
Developed estimates of the state-wide economic impacts of the California SGIP program providing support to encourage more self-generation of electricity. Extracted output, value added, employment, and compensation coefficients from IMPLAN to determine the impacts of a variety of program options.
Designed a survey to determine compliance with NESHAPs, and developed information for subsequent OMB approval.
Statistical support to develop numerical criteria defining a reasonable degree of compliance of the proposed Waste Isolation Pilot Project WIPP with nuclear waste disposal site standards contained in 40 CFR Part 191. Conducted sensitivity and uncertainty analyses for the WIPP performance assessment model.
Cost-effectiveness analysis of proposed Lower Level Waste disposal regulations governing facility closure plans under consideration by the Nuclear Regulatory Commission.
Analyzed the costs and benefits of proposed radon emission standards for uranium mill tailings impoundments and elemental phosphorus plants. Prepared parts of the Regulatory Impact Analysis for proposed Clean Air Act standards for radionuclides, applying present-value techniques to compare the levelized costs and benefits of alternative proposed emission control technologies--for EPA's Office of Radiation Programs.
Conducted analysis to determine the current risk threshold for regulatory activity in Federal programs designed to reduce low-level risks. The results indicate no evidence for the existence of a de minimis threshold within the range of risks assessed in this study, which extends down to a lifetime risk level of one in 10 million-- for EPA's Office of Radiation Programs.
Provided litigation support in negotiations for clean-up of PCB contamination at a major energy facility with multiple sites. Negotiations resulted in a clean-up verification sampling plan that was costly, yet satisfactory to all parties--for the Office of Toxic Substances at EPA.
Project Manager for the development of a Radon and Indoor Air Public Opinion Survey for EPA Region 6. Coordinated subcontractor activities for developing 3 HARRY J. CHMELYNSKI, PhD
questionnaires, instructions, and procedures for implementation by the individual states in Region 6--for EPA's Office of Radiation Programs.
Applied statistical decision theory methods to evaluate the expected performance of alternative short-term radon testing procedures proposed for use in real estate transactions. Quantitative estimates for spatial and temporal variations and measurement errors were developed to determine expected misclassification rates. A multivariate form of the model was also developed to address sequential short-term radon tests in a recent revision of the Citizen's Guide to Radon--for EPA's Office of Radiation Programs.
Project Manager for developing a detailed map of radon potential in Alachua County, Florida to be used for efficient implementation of proposed radon-resistant building codes. Coordinated the activities of several sub-contractors, the USGS, the Florida Geological Survey, and the University of Florida--for the Florida Radon Research Program.
Provide technical support to ORIA in the development of statistical cleanup criteria for the release of remediated Federal lands for eventual public use. Cleanup activities on Federal lands require confirmatory soil testing to demonstrate compliance with proposed cleanup criteria. Reviewed nonparametric statistical approaches to determining compliance.
3. Other Managerial and Technical Experience
Analyzed the program effectiveness of the EPA Automobile Recall Program in meeting its goals of pollution reduction and deterrence. Evaluated the effectiveness of proposed alternative mileage-at-first-test strategies using a probabilistic simulation model based on historical recall experience--for EPA's Manufacturer's Operations Division.
Evaluated the potential macroeconomic impacts of future petroleum supply interruptions using an input-output model methodology--for the Assistant Secretary for Policy and Evaluation, Department of Energy.
Developed a program evaluation system to measure the economic impacts of environmental regulations on foreign and domestic automobile manufacturers. This study analyzed the cost-effectiveness of recent changes in emission standards for light-duty vehicles--for EPA's Office of Mobile Sources.
Estimated the potential energy and economic impacts of proposed emergency energy allocation plans developed for the Illinois Institute of Natural Resources.
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Software Experience: HTML, JavaScript, JAVA, SAS, SPSS, Excel, Crystal Ball, GoldSim, IMPLAN, C, MS-DOS, UNIX, RATS, APL, TPL, FORTRAN, OS/MVS/JCL, WYLBUR, TSO, BMDP
Hardware Experience: IBM Mainframes and PC's, DEC, CDC, UNIVAC
Selected Publications
“Guidance for Comparing Background and Chemical Concentrations in Soil for CERCLA Sites", OSWER 9285.7 41, September 2002 (EPA 540-R-01-003).
“Statistical Methods for Hanford Vadose Zone Investigations", SC&A contractor report, February, 2001.
“Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM)", contributing author, NUREG-1575 (EPA 401-R-97-016), December, 1997.
“Background Information Document for Proposed 40 CFR Part 194: Criteria for the Certification of Compliance with Environmental Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes", contributing author, EPA contractor report, December, 1993.
“National Radon Database Documentation, Vol 1-6," EPA contractor report, December, 1992.
“Background Information Document to Support NESHAPS Rulemaking on NRC and Agreement State Licensees other then Power Reactors," contributing author, EPA contractor report, May 1992.
“Power for Proposed Case-Control Study Sample Sizes," EPA contractor report, October 1991.
“School Radon Protocol Development Study," EPA contractor report, February 1991, with J.T. MacWaters, F. Moumen, T. Inge, and B. Hopkins.
“An Evaluation of the Performance of Alternative Short-term Radon Testing Procedures in Homes with Pending Real Estate Transactions," EPA contractor report, November 1990.
“Seasonal Variation in Short-Term and Long-Term Radon Measurements in Schools," published in Proceedings of the 1991 International Symposium on Radon and Radon Reduction Technology, Philadelphia, PA, with A. Schmidt and J.T. MacWaters.
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“Radon Measurements in 130 Schools: Results and Implications," published in Proceedings of the 1990 Symposium on Radon and Radon Reduction Technology, EPA 600/9-90/005, Atlanta, GA, with R.T. Peake, A. Schmidt, and J. MacWaters.
“EPA's School Protocol Development Study--Phase II," published in Proceedings of the 1990 Symposium on Radon and Radon Reduction Technology, EPA 600/9-90/005, Atlanta, GA, with A. Schmidt, R.T. Peake and J. MacWaters. “Screening Schools for Radon Using a Sample-Based Tolerance Test," EPA contractor report, January 1989.
“Radon and Radon Progeny Measurements in Five Schools," published in Proceedings of the 1988 Symposium on Radon and Radon Reduction Technology, EPA 600/9-89-006A, Vol. 1, Denver, CO, with R.T. Peake and J. MacWaters.
“Background Information Document for Proposed 40 CFR Part 194: Criteria for the Certification of Compliance with Environmental Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes," contributing author, EPA contractor report, December, 1993.
“Final Rule for Radon-222 Emissions from Licensed Uranium Mill Tailings: Economic Analysis," EPA 520/1-86-010, August 1986, with M.F. Lawrence and J. Skolnik.
“Changes in Worldwide Demand for Metals," Bureau of Mines Open File Report 92-86, August 1986, with J.G. Faucett.
“Comparison of AIRDOS-EPA Predictions of Ground-level Airborne Radionuclide Concentrations to Measured Values," EPA contractor report, 1986, with S.K. Beale, S.C. Cohen, B. Parks, and J. Hardin.
“Regulatory Impact Analysis of Emission Standards for Elemental Phosphorus Plants," EPA 520/1-84-025, October 1984, with M.F. Lawrence and J.T. Jablonski.
“Textile Dye Weighing Monitoring Study: Appendix D, Statistical Methodology," EPA 560/5-90-009, April 1990, with A. Greenland.
“State Energy Price Projections for the Residential Sector," EIA Service Reports dated 1987, 1988, 1989, and 1990, with K. Elwell and F. Moumen.
“The Short-term Liner Trade Forecasting System," sponsored by the U.S. Maritime Administration, December 1980, with M.F. Lawrence and J.T. Jablonski.
“A New Multivariate Error Structure for Multiple Regression Based on a Bayesian Analysis of the Gamma Process," Ph.D. Thesis, Carnegie-Mellon University, 1982. 6