Nuclear Nonproliferation
DOE Action Needed to Ensure Continued Recovery of Unwanted Sealed Radioactive Sources Gao ID: GAO-03-483 April 15, 2003Potentially dangerous sealed sources containing greater-than-Class-C radioactive material pose a threat to national security because terrorists could use them to make "dirty bombs." Public Law 99-240 requires the Department of Energy (DOE) provide a facility for disposing of unwanted sources. Because DOE has no disposal facility for these sources, its Off-Site Source Recovery Project is recovering and temporarily storing them at Los Alamos, New Mexico. GAO was asked to determine (1) the number of unwanted sealed sources that DOE plans to recover through 2010 and the estimated cost, (2) the status of recovery efforts and any problems that DOE may face, and (3) the status of DOE's efforts to provide a disposal facility for these sealed sources
The exact number of unwanted greater-than-Class-C sealed sources in the United States is unknown, but DOE estimates it will recover about 14,300 such sources by the end of fiscal year 2010, at a total cost of about $69 million. DOE's estimate of the number of sealed sources it will recover was based on three assumptions--that a permanent disposal facility would be available by fiscal year 2007; that the Off-Site Source Recovery Project's recovery operations would be phased out from fiscal years 2007 through 2010; and that, after fiscal year 2010, all sealed sources would be sent directly to a disposal facility and the project would cease operations. Through February 2003, DOE's Off-Site Source Recovery Project had recovered more than 5,000 greater-than-Class-C sealed sources from about 160 sites across the United States; however, the project faces three problems that could hinder future recovery efforts. First, the project is not a priority with DOE's Office of Environmental Management, because, according to office officials, the project does not conform with the mission of the office. The project did not receive full funding, even after September 11, 2001, because of the Office of Environmental Management's other higher priority projects, and the office's current budget specifies future annual funding levels that, according to project officials, would be insufficient to enable the project to recover additional sealed sources. Second, DOE cannot recover any additional sealed sources containing plutonium-239 because the project has already run out of space at the Los Alamos National Laboratory that meets DOE's higher security standards for storing these sources. Third, DOE has not approved a means for storing sealed sources containing strontium-90 and cesium-137 until a permanent disposal facility is available. As of February 2003, more than 17 years after the enactment of Public Law 99-240, DOE had not made progress toward providing for the permanent disposal of greater-than-Class-C radioactive sealed sources, as required by the act. Specifically, DOE had not assigned responsibility to an office within DOE to begin developing such a facility. Also, according to DOE officials, DOE lacks a plan for ensuring the continued recovery of sealed sources in the likely event that the disposal facility is delayed beyond fiscal year 2007.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-483, Nuclear Nonproliferation: DOE Action Needed to Ensure Continued Recovery of Unwanted Sealed Radioactive Sources
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Report to the Ranking Minority Member, Subcommittee on Financial
Management, the Budget, and International Security, Committee on
Governmental Affairs, U.S. Senate:
United States General Accounting Office:
GAO:
April 2003:
NUCLEAR NONPROLIFERATION:
DOE Action Needed to Ensure Continued Recovery of Unwanted Sealed
Radioactive Sources:
GAO-03-483:
GAO Highlights:
Highlights of GAO-03-483, a report to the Ranking Minority Member,
Subcommittee on Financial Management, the Budget, and International
Security, Committee on Governmental Affairs, United States Senate
Why GAO Did This Study:
Potentially dangerous sealed sources containing greater-than-Class-C
radioactive material pose a threat to national security because
terrorists could use them to make ’dirty bombs.“ Public Law 99-240
requires the Department of Energy (DOE) provide a facility for
disposing of unwanted sources. Because DOE has no disposal facility
for these sources, its Off-Site Source Recovery Project is recovering
and temporarily storing them at Los Alamos, New Mexico. GAO was asked
to determine (1) the number of unwanted sealed sources that DOE plans
to recover through 2010 and the estimated cost, (2) the status of
recovery efforts and any problems that DOE may face, and (3) the
status of DOE‘s efforts to provide a disposal facility for these
sealed sources.
What GAO Recommends:
GAO recommends that the Secretary of Energy (1) determine whether the
priority given to the project is commensurate with the threat these
sources pose; (2) ensure adequate resources are devoted to the
project; (3) take immediate action to provide space to store sealed
sources containing plutonium-239, strontium-90, and cesium-137; (4)
initiate the process to develop a permanent disposal facility for
greater-than-Class-C radioactive waste; and (5) develop a plan to
ensure the continued recovery of greater-than-Class-C waste until a
disposal facility is available. DOE did not comment on our
recommendations.
what GAO Found:
The exact number of unwanted greater-than-Class-C sealed sources in
the United States is unknown, but DOE estimates it will recover about
14,300 such sources by the end of fiscal year 2010, at a total cost of
about $69 million. DOE‘s estimate of the number of sealed sources it
will recover was based on three assumptions”that a permanent disposal
facility would be available by fiscal year 2007; that the Off-Site
Source Recovery Project‘s recovery operations would be phased out from
fiscal years 2007 through 2010; and that, after fiscal year 2010, all
sealed sources would be sent directly to a disposal facility and the
project would cease operations.
Through February 2003, DOE‘s Off-Site Source Recovery Project had
recovered more than 5,000 greater-than-Class-C sealed sources from
about 160 sites across the United States; however, the project faces
three problems that could hinder future recovery efforts. First, the
project is not a priority with DOE‘s Office of Environmental
Management, because, according to office officials, the project does
not conform with the mission of the office. The project did not
receive full funding, even after September 11, 2001, because of the
Office of Environmental Management‘s other higher priority projects,
and the office‘s current budget specifies future annual funding levels
that, according to project officials, would be insufficient to enable
the project to recover additional sealed sources. Second, DOE cannot
recover any additional sealed sources containing plutonium-239 because
the project has already run out of space at the Los Alamos National
Laboratory that meets DOE‘s higher security standards for storing
these sources. Third, DOE has not approved a means for storing sealed
sources containing strontium-90 and cesium-137 until a permanent
disposal facility is available.
As of February 2003, more than 17 years after the enactment of Public
Law 99-240, DOE had not made progress toward providing for the
permanent disposal of greater-than-Class-C radioactive sealed sources,
as required by the act. Specifically, DOE had not assigned
responsibility to an office within DOE to begin developing such a
facility. Also, according to DOE officials, DOE lacks a plan for
ensuring the continued recovery of sealed sources in the likely event
that the disposal facility is delayed beyond fiscal year 2007.
www.gao.gov/cgi-bin/getrpt?GAO-03-483.
To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Gene Aloise, 202-512-3841,
aloisee@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
The Exact Number of Unwanted Greater-Than-Class-C Sealed Sources Is
Unknown, but DOE Plans to Recover About 14,000 Sealed Sources by the
End of Fiscal Year 2010 at an Estimated Cost of About $69 Million:
DOE Has Recovered a Large Number of Sources, but Unresolved Problems
Could Hinder Future Recovery Efforts:
DOE Has Not Made Progress toward Providing a Permanent Disposal
Facility:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Scope and Methodology:
Appendix I: Sections 1, 2, and 3 of the Low-Level Radioactive
Waste Policy Amendments Act of 1985, Public Law
99-240:
Appendix II: Comments from the Department of Energy:
Tables:
Table 1: Estimated Number of Greater-Than-Class-C Sealed Sources DOE
Plans to Recover Annually, Fiscal Years 1999 through 2010:
Table 2: Number of Each Type of Greater-Than-Class-C Sealed Source that
DOE Plans to Recover by the End of Fiscal Year 2010:
Table 3: Estimated Annual Cost to Complete the Recovery of 14,309
Greater-Than-Class-C Sealed Sources, Fiscal Years 2002 through 2011:
Table 4: Estimated Total Cost to Complete Remaining Recovery and
Closeout Activities, as of Fiscal Year 2002:
Table 5: Number of Each Type of Greater-Than-Class-C Sealed Source
Recovered and Associated Grams and Curies of Radioactive Material, as
of February 2003:
Table 6: Number of Each Type of Greater-Than-Class-C Sealed Source
Awaiting Recovery and Associated Number of Holders and Grams and Curies
of Radioactive Material, as of February 2003:
Figures:
Figure 1: The Off-Site Source Recovery Project's Process for Recovering
Greater-Than-Class-C Sealed Sources:
Figure 2: Photograph of a Structure at the Los Alamos National
Laboratory in Which Greater-Than-Class-C Sealed Sources Recovered by
the Off-Site Source Recovery Project Are Stored as Waste:
Figure 3: Greater-Than-Class-C Sealed Sources Recovered by State, as of
February 2003:
Figure 4: Greater-Than-Class-C Sealed Sources in Need of Recovery by
State, as of February 2003:
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Abbreviations:
DOE: Department of Energy
NEPA: National Environmental Policy Act of 1969
NRC: Nuclear Regulatory Commission:
United States General Accounting Office:
Washington, DC 20548:
:
April 15, 2003:
The Honorable Daniel K. Akaka
Ranking Minority Member
Subcommittee on Financial Management,
the Budget, and International Security
Committee on Governmental Affairs
United States Senate:
Dear Senator Akaka:
Since the terrorist attacks of September 11, 2001, there has been a
great deal of concern about the control of sealed sources containing
radioactive material used in medicine, agriculture, research, and
industry throughout the United States. The radioactive material in
these sealed sources is encapsulated, or sealed, in metal--such as
stainless steel, titanium, or platinum--to prevent its dispersal. The
small size and portability of the sealed sources make them susceptible
to misuse, improper disposal, and theft. If these sealed sources fell
into the hands of terrorists, they could be used as simple and crude
but potentially dangerous radiological weapons, commonly called dirty
bombs. In general, a dirty bomb is produced by packaging explosives,
such as dynamite, with radioactive material, which would be dispersed
when the bomb went off. The radioactive material dispersed--depending
on the type, form (e.g., solid or powder), amount, and concentration--
could cause radiation sickness for people nearby as well as the serious
economic costs and social disruption associated with the evacuation and
subsequent cleanup of the contaminated area.
Certain sealed sources are considered particularly attractive for
potential use in producing dirty bombs because, among other things,
they contain more concentrated amounts of nuclear material known as
"greater-than-Class-C material"--typically americium-241, cesium-137,
plutonium-238, plutonium-239, and strontium-90.[Footnote 1]
Applications of greater-than-Class-C sealed sources include portable
and fixed gauges used in commercial manufacturing processes, gauges
used by the construction industry for testing the moisture content of
soil, medical pacemakers, medical diagnostics and treatments, gauges
used for petroleum exploration, and government and private research and
development.
The Low-Level Radioactive Waste Policy Amendments Act of 1985, Public
Law 99-240, requires the Department of Energy (DOE) to provide a
facility for disposing of all greater-than-Class-C radioactive waste,
including greater-than-Class-C sealed sources that are no longer wanted
by their owners, but DOE has not yet developed a disposal facility (see
app. I). Until a disposal facility is available, DOE created the Off-
Site Source Recovery Project, which, since fiscal year 1999, has been
recovering unwanted greater-than-Class-C sealed sources from their
owners and temporarily storing them at the Los Alamos National
Laboratory in Los Alamos, New Mexico. Currently, owners of unwanted
greater-than-Class-C sealed sources must continue to store and secure
their sources on their premises until either DOE recovers and
temporarily stores them or a disposal facility becomes available. Once
a permanent disposal facility becomes available, source holders will be
able to send their sources directly to the facility, and the sources
that DOE is storing at Los Alamos will be transferred to the facility
for permanent disposal.
To assess DOE's progress toward improving its control of greater-than-
Class-C sealed sources, you asked us to determine (1) the number of
greater-than-Class-C sealed sources that are unwanted, the number that
DOE plans to recover and dispose of through 2010, and the estimated
cost and schedule to recover and temporarily store these sources until
a permanent disposal facility is available; (2) the status of recovery
efforts to date and any problems that DOE may face in recovering and
temporarily storing greater-than-Class-C sealed sources; and (3) the
status of DOE's efforts to meet the requirements of Public Law 99-240
to provide long-term disposal for greater-than-Class-C radioactive
waste. To address these objectives, we, among other things, visited the
Off-Site Source Recovery Project office at the Los Alamos National
Laboratory to observe the storage facilities and interview project
officials, reviewed studies estimating the number of greater-than-
Class-C sealed sources and DOE's budget documents, and analyzed data on
the progress of recovery efforts. This report is the first of three we
are preparing at your request to examine efforts to control sealed
radiological sources. Forthcoming reports will review domestic and
international efforts to control these sources beyond those of the Off-
Site Source Recovery Project.
Results in Brief:
The exact number of unwanted greater-than-Class-C sealed sources is
unknown but DOE's Off-Site Source Recovery Project officials estimate
they will recover about 14,300 unwanted greater-than-Class-C sealed
sources by the end of fiscal year 2010, at an estimated total cost of
about $69 million. These officials told us that the number of unwanted
greater-than-Class-C sealed sources that would be recovered is a rough
estimate, which was derived by reviewing, among other information,
studies completed by the Nuclear Regulatory Commission and DOE's Idaho
National Engineering Laboratory and information provided by sealed
source manufacturers. Although the Idaho National Engineering
Laboratory study estimated that there currently could be about 250,000
to 500,000 greater-than-Class-C sealed sources in the United States,
the actual number of greater-than-Class-C sealed sources that are no
longer wanted is not known because no one kept track of this
information. The estimate of the number of greater-than-Class-C sealed
sources that DOE's project will recover is based on three assumptions-
-that a permanent disposal facility for greater-than-Class-C sealed
sources will be available by fiscal year 2007; that the Off-Site Source
Recovery Project will continue to recover sources from certain holders
of sources during a transition period from fiscal year 2007 through
fiscal year 2010; and that, after fiscal year 2010, all greater-than-
Class-C sealed sources will be sent directly to the disposal facility
and the Off-Site Source Recovery Project will cease operations.
As of February 2003, DOE's Off-Site Source Recovery Project had
recovered more than 5,000 greater-than-Class-C sealed sources from
about 160 sites across the United States; however, the project faces
three problems that could hinder future recovery efforts. These
problems include the questionable long-term commitment of DOE's Office
of Environmental Management to the project, inadequate storage capacity
that meets the higher security needs of sealed sources containing
plutonium-239, and the lack of a means for temporarily storing sealed
sources containing strontium-90 and cesium-137. With regard to the
first problem, officials from DOE's Office of Environmental Management,
which is responsible for the Off-Site Source Recovery Project, told us
that they would like the responsibility for the project to be placed in
another DOE office because the mission of the project is inconsistent
with the mission of the Office of Environmental Management. They also
told us that the project did not receive full funding, even after
September 11, 2001, because of other higher priority projects, and
current Office of Environmental Management budget documents specify
future annual funding levels that, according to project officials,
would limit the project's ability to recover additional greater-than-
Class-C sealed sources. Without funding available to the Off-Site
Source Recovery Project to recover additional sources, owners of
unwanted greater-than-Class-C sealed sources will be forced to store
and secure their sources on their premises until a disposal facility is
available.
Further, the Off-Site Source Recovery Project cannot recover any
additional greater-than-Class-C sealed sources containing plutonium-
239 because there is no more space at the Los Alamos National
Laboratory that meets DOE's security standards for storing these
sources. As a result, about 150 holders of unwanted sources containing
plutonium-239, most of which are universities, must retain them and
keep them properly secured until space becomes available. Although this
nuclear material requires special security measures because of its
potential for use in a crude nuclear bomb, two holders of these sources
have told us of instances in which doors to the rooms containing
unwanted greater-than-Class-C sealed sources were left unlocked and
open, and most holders expressed their desire to dispose of the sources
as quickly as possible. In addition, DOE has not approved a means for
temporarily storing strontium-90 and cesium-137 at a DOE facility until
a permanent disposal facility is developed as DOE has done for the
other types of radioactive materials contained in the sealed sources it
needs to recover. According to DOE, it recognizes these problems and is
developing options to resolve them. Our report recommends that DOE
determine whether the priority that it is giving the project is
commensurate with the risks these sealed sources pose, ensure adequate
resources are devoted to the project, and provide, as soon as possible,
storage space for sealed sources containing plutonium-239, strontium-
90, and cesium-137 with the appropriate level of security.
As of February 2003, DOE's Office of Environmental Management had not
made progress toward providing for the permanent disposal of greater-
than-Class-C radioactive waste, and it is unlikely to provide such a
facility by fiscal year 2007, as previously assumed, because it is not
a priority with the office. Specifically, the office had not begun the
first step in developing a disposal facility--completing an appropriate
analysis as required by the National Environmental Policy Act of 1969
and implementing regulations, which would likely be an Environmental
Impact Statement. Officials from DOE's Office of Environmental
Management told us that the office had provided funding for fiscal
years 2002 and 2003 to develop such an analysis, but that after the
office reviewed the budget in February 2002, it reallocated these funds
to other priorities. These officials also told us that DOE is
considering moving the responsibility for developing the analysis to
another office within DOE, and they anticipate that this decision will
be made some time in fiscal year 2003. In an Environmental Impact
Statement, which Office of Environmental Management officials say could
take 2 years to develop, DOE could propose that either a new disposal
facility be built or an existing facility be used. If a new facility
were decided upon, developing it could take at least 7 years, according
to DOE's estimates. If an existing facility were selected, disposal
services could be provided sooner, depending upon the availability of
the facility. For example, DOE has been exploring the possibility of
sending greater-than-Class-C sealed sources containing plutonium-239
to an existing facility, its Waste Isolation Pilot Plant located in
Carlsbad, New Mexico, but it remains uncertain when or if this will be
possible. Finally, according to Office of Environmental Management
officials, DOE does not have a plan for recovering greater-than-Class-
C sealed sources in the event that the disposal facility is delayed.
Our report recommends that DOE initiate the process to provide a
permanent disposal facility for greater-than-Class-C waste, develop a
plan to help manage this process, and develop a plan to ensure the
continued recovery and storage of greater-than-Class-C sealed sources
in the likely event that availability of the disposal facility is
delayed beyond fiscal year 2007.
Background:
The Nuclear Regulatory Commission (NRC) regulates medical, industrial,
and research uses of radioactive materials through a combination of
activities, including regulatory requirements; licensing; and safety
oversight, including inspection and enforcement. NRC issues licenses
for the ownership of radioactive material and for the possession and
use of this material in certain items, such as sealed sources. NRC
licensees include medical, industrial, and academic organizations. In
addition, NRC has delegated its licensing authority to 32 states,
called "agreement states." These agreement states administer 76 percent
of the licensees while NRC administers the remainder of the licensees.
In the 1970s, DOE began to recover unwanted greater-than-Class-C sealed
sources containing plutonium-239. Through 1998, DOE recovered more than
1,300 such sealed sources, mainly from universities, and destroyed them
by chemical processing. During this time, the Congress also enacted the
Low-Level Radioactive Waste Policy Amendments Act of 1985, Public
Law 99-240, which requires the Department of Energy (DOE) to provide a
facility for disposing of all greater-than-Class-C radioactive waste,
including all greater-than-Class-C sealed sources that are no longer
wanted by their owners. However, DOE has not yet developed such a
facility. Although DOE had no formal program to accept unwanted
greater-than-Class-C sealed sources from their owners, in 1992, the
agency established a working agreement with NRC to address greater-
than-Class-C sealed sources that might cause potential health and
safety problems. Between 1993 and 1999, DOE recovered over 40 greater-
than-Class-C sealed sources at the request of NRC. By 1999, however,
DOE determined that chemically processing greater-than-Class-C sealed
sources was expensive, exposed laboratory workers involved in the
chemical processing to unacceptable doses of radioactivity, and created
problematic waste that needed disposal. In addition, DOE lacked
sufficient capacity to process the growing numbers of greater-than-
Class-C sealed sources that were being reported as unwanted. As a
result, DOE determined in 1999 that chemical processing should be
discontinued. That same year, DOE's Office of Environmental Management,
whose main mission is to clean up DOE's contaminated weapons
development facilities that DOE plans to close, created the Off-Site
Source Recovery Project to recover and temporarily store unwanted
greater-than-Class-C sealed sources until a disposal facility was
available. The Office of Environmental Management funds and provides
oversight and direction to the project; DOE's National Nuclear Security
Administration Service Center in Albuquerque, New Mexico, provides
project oversight and direction for the Los Alamos National Laboratory;
and the University of California conducts planning and recovery
operations for DOE at Los Alamos.
The greater-than-Class-C sealed source recovery process begins when a
holder of a source notifies the project that it has no further use for
its source or when NRC or state regulators notify the project that a
source needs to be recovered because it might cause a potential health
or safety problem (see fig. 1).
Figure 1: The Off-Site Source Recovery Project's Process for Recovering
Greater-Than-Class-C Sealed Sources:
[See PDF for image]
Source: DOE.
[End of figure]
Project officials obtain extensive descriptive information about the
source, maintain the information in a database, and work with NRC to
use the information to prioritize recoveries. Once a decision has been
made to recover a greater-than-Class-C sealed source, the recovery
effort can occur in one of three ways: (1) the source holder packages
and ships the source to the Los Alamos National Laboratory; (2) project
staff travel to the source's location to characterize, package, and
ship the source to Los Alamos; or (3) project subcontractors accomplish
the required work for the project. In any of these cases, the sources
may be shipped directly to the Los Alamos National Laboratory for
receipt and storage, or they may first be shipped to a subcontractor
facility where they are consolidated and stored until a larger shipment
to Los Alamos is prepared. Greater-than-Class-C sealed sources sent to
the Los Alamos National Laboratory are either stored as nuclear
material under appropriate security or, if security requirements are
waived, may be stored as waste in some of the same structures as other
radioactive waste stored by the laboratory (see fig. 2).
Figure 2: Photograph of a Structure at the Los Alamos National
Laboratory in Which Greater-Than-Class-C Sealed Sources Recovered by
the Off-Site Source Recovery Project Are Stored as Waste:
[See PDF for image]
[End of figure]
At the request of the Secretary of Energy and NRC Chairman in June
2002, the DOE/NRC Interagency Working Group on Radiological Dispersal
Devices was convened to identify any concerns with the nation's ability
to adequately protect nuclear materials, including radiological
sources, that can be used in a radiological dispersal device, or dirty
bomb. The working group was tasked to provide a report to the Secretary
of Energy and NRC Chairman detailing recommendations for protecting
radioactive materials of concern. The objectives of the working group
were to identify those radioactive materials of concern for use as a
radiological dispersal device, examine the options for tracking these
materials in a national database system, assess potential technologies
for tagging these materials for tracking purposes, and identify actions
needed to ensure that sources are secure and that storage and disposal
is available for unsecured, excess, and unwanted sources. The report
provides recommendations that DOE and NRC can pursue to enhance control
of materials that could be used in radiological dispersal devices.
These include coordination with the Department of Homeland Security and
other federal agencies to establish national policies for defining
threats and radiological dispersal device protection levels,
implementing a national source tracking system, and developing national
strategies for recovering and disposing of unsecured sources. As of
February 2003, the report was still in draft.
The Exact Number of Unwanted Greater-Than-Class-C Sealed Sources Is
Unknown, but DOE Plans to Recover About 14,000 Sealed Sources by the
End of Fiscal Year 2010 at an Estimated Cost of About
$69 Million:
Neither DOE nor any other government agency has kept track of the
number of greater-than-Class-C sealed sources that are no longer
wanted; therefore, this number is not known with certainty. Also, DOE
created the Off-Site Source Recovery Project to enable DOE to comply
with Public Law 99-240 until a disposal facility became available;
hence, the project was never envisioned as a permanent solution. As a
result, before DOE could estimate the number of greater-than-Class-C
sealed sources that the project would recover, it had to estimate how
long the project would be in operation. In fiscal year 2002, DOE
estimated that the Off-Site Source Recovery Project would operate from
fiscal years 1999 through 2010 and, during that time frame, the project
would recover and temporarily store 14,309 unwanted greater-than-Class-
C sealed sources.[Footnote 2] DOE also estimated the total cost to
complete the planned recovery effort at $69.3 million.
DOE's Estimate of How Long the Off-Site Source Recovery Project Will
Operate and How Many Sealed Sources DOE Plans to Recover:
To develop its estimate of the number of unwanted greater-than-Class-C
sealed sources it planned to recover, DOE first determined how long the
Off-Site Source Recovery Project would operate. Prior to 1999, DOE's
activity was limited to recovering and destroying unwanted greater-
than-Class-C sealed sources. At the time, DOE was processing and
destroying up to 100 sealed sources per year. According to a project
official, the rate at which DOE estimated it could process and destroy
sealed sources played a key role in determining the time frame for Off-
Site Source Recovery Project operations. According to this official,
prior to 1999, DOE planned to increase its processing capability to
about 400 sealed sources annually, and in 1999, DOE estimated that a
backlog of about 4,000 to 5,000 unwanted greater-than-Class-C sealed
sources existed. As a result, DOE set the time frame for the Off-Site
Source Recovery Project at
12 years (fiscal year 1999 through fiscal year 2010), which was
approximately the amount of time DOE estimated it would take to manage
the existing backlog. Although DOE plans to store the sources it
recovers instead of destroying them, the time frame for the project has
remained the same.
DOE then estimated the number of greater-than-Class-C sealed sources
that would become unwanted from fiscal year 1999 through fiscal year
2010. To do this, DOE officials reviewed, among other information, its
preliminary database of about 3,000 unwanted greater-than-Class-C
sealed sources, discussions with representatives from the sealed source
industry, and past studies by NRC and DOE's Idaho National Engineering
Laboratory, which included surveys of source holders and manufacturers
conducted by NRC and state regulatory agencies.[Footnote 3] The study
by the Idaho National Engineering Laboratory, completed in 1994 at the
request of DOE, estimated that there could be about 250,000 to 500,000
greater-than-Class-C sealed sources currently in the United States and
as many as 24,000 new greater-than-Class-C sealed sources are being
produced each year. According to a project official, the estimate of
how many of these sealed sources will become unwanted during the time
period that the Off-Site Source Recovery Project is in operation
represents a best guess based on all of the information available.
As such, DOE officials estimated that about 18,000 greater-than-Class-
C sealed sources would become unwanted from fiscal years 1999 through
2010. DOE initially developed a plan detailing how many of the 18,000
unwanted greater-than-Class-C sealed sources it planned to recover each
fiscal year. However, DOE later modified the plan to recover 14,309
unwanted greater-than-Class-C sealed sources on the basis of three key
assumptions: (1) that a permanent disposal facility for the sources
would be available by fiscal year 2007; (2) that the Off-Site Source
Recovery Project would continue to recover sources from certain holders
of sources during a transition period from fiscal year 2007 through
fiscal year 2010;[Footnote 4] and (3) that after fiscal year 2010, all
greater-than-Class-C sealed sources would be shipped by their owners to
the disposal facility and the Off-Site Source Recovery Project would
cease operations.[Footnote 5] Table 1 shows DOE's plan for recovering
14,309 unwanted greater-than-Class-C sealed sources through the end of
fiscal year 2010.
Table 1: Estimated Number of Greater-Than-Class-C Sealed Sources DOE
Plans to Recover Annually, Fiscal Years 1999 through 2010:
Fiscal year 1999: 53; Fiscal year 2000: 39; Fiscal year 2001: 2,915;
Fiscal year 2002: 1,325; Fiscal year 2003: 2,130; Fiscal year 2004:
2,470; Fiscal year 2005: 2,332; Fiscal year 2006: 1,680; Fiscal year
2007: 675; Fiscal year 2008: 412; Fiscal year 2009: 203; Fiscal year
2010: 75; Total number of sources: 14,309.
Source: DOE.
Note: GAO's presentation of DOE's data.
[End of table]
According to DOE's estimates, about 85 percent of the 14,309 greater-
than-Class-C sealed sources that the project plans to recover would
contain americium-241, with the remainder containing plutonium-238,
plutonium-239, and various other radioactive materials (see table 2).
DOE did not specify the number of sealed sources containing cesium-137
or strontium-90 that it planned to recover.
Table 2: Number of Each Type of Greater-Than-Class-C Sealed Source that
DOE Plans to Recover by the End of Fiscal Year 2010:
Type of greater-than-
Class-C sealed source: Americium-241; Number of sources
DOE plans to recover: 12,176.
Type of greater-than-
Class-C sealed source: Plutonium-238; Number of sources
DOE plans to recover: 1,722.
Type of greater-than-
Class-C sealed source: Plutonium-239; Number of sources
DOE plans to recover: 364.
Type of greater-than-
Class-C sealed source: Other; Number of sources
DOE plans to recover: 47.
Type of greater-than-
Class-C sealed source: Total; Number of sources
DOE plans to recover: 14,309.
Source: DOE.
Note: GAO's analysis of DOE's data.
[End of table]
DOE Estimates the Total Cost to Recover 14,309 Sealed Sources at
$69.3 Million:
In fiscal year 2002, DOE estimated that it would cost about $56.5
million to complete the recovery of 14,309 greater-than-Class-C sealed
sources from fiscal years 2002 through 2011 (see table 3).[Footnote 6]
In addition, since DOE had already spent about $12.7 million on
recovery activities from fiscal years 1999 through 2001, DOE estimated
the total cost to recover the 14,309 sealed sources at about $69.3
million.[Footnote 7]
Table 3: Estimated Annual Cost to Complete the Recovery of 14,309
Greater-Than-Class-C Sealed Sources, Fiscal Years 2002 through 2011:
(Dollars in millions).
Fiscal year 2002: $5.1; Fiscal year 2003: $7.1;
Fiscal year 2004: $6.7; Fiscal year
2005: $8.7; Fiscal year 2006: $8.0;
Fiscal year 2007: $6.7; Fiscal year
2008: $4.9; Fiscal year 2009: $4.4;
Fiscal year 2010: $4.5; Fiscal year
2011[A]: $0.4; Total cost to complete
activities: $56.5.
Source: DOE.
Note: GAO's presentation of DOE's data.
[A] The $400,000 cost estimated for fiscal year 2011 is for project
closeout activities.
[End of table]
Table 4 shows how DOE plans to spend the $56.5 million the agency
estimates it will need to complete remaining project activities.
Table 4: Estimated Total Cost to Complete Remaining Recovery and
Closeout Activities, as of Fiscal Year 2002:
(Dollars in millions).
Activity: Recovering, inspecting, and storing
greater-than-Class-C sealed sources, including planning recoveries,
maintaining contracts with subcontractors, and preparing waste for
future permanent disposal; Estimated cost:
$24.2.
Activity: Upgrading equipment at Los Alamos and
designing, testing, and acquiring tools and containers for packaging,
transporting, and storing greater-than-Class-C sealed sources;
Estimated cost: 9.0.
Activity: Conducting other activities supporting
project operations, including overseeing and controlling the quality of
project performance, complying with applicable regulations and
requirements, maintaining project data, training staff, disseminating
information, and paying the project's share of the costs associated
with the Los Alamos National Laboratory's management and support staff;
Estimated cost: 11.2.
Activity: Conducting activities related to
planning a disposal facility and transitioning project operations to
this facility, including facilitating the recovery of nuclear material
leased to federal agencies and universities, characterizing and
certifying greater-than-Class-C waste stored at Los Alamos,
transferring the waste to a disposal facility, and closing out project
operations; Estimated cost: 12.1.
Activity: Total estimated cost to complete
remaining recovery and closeout activities;
Estimated cost: $56.5.
Source: DOE.
Note: GAO's analysis of DOE's data.
[End of table]
DOE Has Recovered a Large Number of Sources, but Unresolved Problems
Could Hinder Future Recovery Efforts:
As of February 2003, DOE's Off-Site Source Recovery Project had
recovered 5,294 unwanted greater-than-Class-C sealed sources, but the
project faces three problems that could hinder future recovery efforts.
These problems include the questionable long-term commitment of DOE's
Office of Environmental Management to the project, the lack of storage
capacity needed to allow the recovery of sealed sources containing
plutonium-239, and the lack of an approved means for temporarily
storing sealed sources containing strontium-90 and cesium-137.
The Off-Site Source Recovery Project Has Recovered a Large Number of
Unwanted Greater-Than-Class-C Sealed Sources:
As of February 2003, the Off-Site Source Recovery Project had
identified and recovered 5,294 unwanted greater-than-Class-C sealed
sources, and owners of an additional 4,380 greater-than-Class-C sealed
sources had reported to DOE that they no longer wanted their sources,
but DOE had not yet recovered them. According to DOE's estimates, these
4,380 sealed sources and another 4,635 greater-than-Class-C sealed
sources that DOE estimates are either currently in use or not yet
reported as unwanted will need to be recovered by the end of fiscal
year 2010.
About 65 percent of the 5,294 unwanted greater-than-Class-C sealed
sources that DOE had recovered contained the radioactive material
americium-241, either alone or in combination with cesium-137, and
about 35 percent of the sources recovered contained plutonium-238 (see
table 5). As table 5 shows, DOE had recovered 15 of the 364 sealed
sources containing plutonium-239 it planned to recover before running
out of storage capacity and had recovered no sealed sources containing
strontium-90. All together, the project has secured almost 2 kilograms
of unwanted radioactive material.
Table 5: Number of Each Type of Greater-Than-Class-C Sealed Source
Recovered and Associated Grams and Curies of Radioactive Material, as
of February 2003:
Type of greater-than-Class-C sealed source: Americium-241; Number of
sources recovered: 3,004; Number of grams of radioactive material
recovered: 730; Number of curies of radioactive material recovered:
2,513.
Type of greater-than-Class-C sealed source: Americium-241 and Cesium-
137; Number of sources recovered: 411; Number of grams of radioactive
material recovered: 5; Number of curies of radioactive material
recovered: 24.
Type of greater-than-Class-C sealed source: Curium-244; Number of
sources recovered: 2; Number of grams of radioactive material
recovered: Less than 1; Number of curies of radioactive material
recovered: Less than 1.
Type of greater-than-Class-C sealed source: Plutonium-238; Number of
sources recovered: 1,862; Number of grams of radioactive material
recovered: 489; Number of curies of radioactive material recovered:
7,235.
Type of greater-than-Class-C sealed source: Plutonium-239; Number of
sources recovered: 15; Number of grams of radioactive material
recovered: 696; Number of curies of radioactive material recovered: 44.
Type of greater-than-Class-C sealed source: Total; Number of sources
recovered: 5,294[A]; Number of grams of radioactive material recovered:
1,920; Number of curies of radioactive material recovered: 9,816.
Source: DOE.
Note: GAO's analysis of DOE's data.
[A] Total includes 16 greater-than-Class-C sealed sources that DOE
recovered before Off-Site Source Recovery Project operations began.
[End of table]
These greater-than-Class-C sealed sources were recovered from 157 sites
nationwide. Figure 3 shows the number of unwanted greater-than-Class-C
sealed sources that DOE recovered from each state. These recoveries
include sealed sources contained in:
* 1,632 gauges that had been used by the construction industry for
testing the moisture content of soil from a manufacturer in North
Carolina who is consolidating these sources for shipment to Los Alamos
and another 231 gauges from a manufacturer in California;
* 1,500 gauges used for petroleum exploration from a DOE subcontractor
that is consolidating sources for shipment to Los Alamos and various
companies in Texas; and:
* 588 medical pacemakers from a manufacturer in Minnesota, 483 from a
manufacturer in Pennsylvania, 233 from a manufacturer in Florida, and
219 from DOE's Oak Ridge research facility in Tennessee.
Figure 3: Greater-Than-Class-C Sealed Sources Recovered by State, as of
February 2003:
[See PDF for image]
Note: GAO's presentation of DOE's data. In addition, the project
recovered one source from a site in Puerto Rico.
[End of figure]
The 4,380 unwanted greater-than-Class-C sealed sources that awaited
recovery as of February 2003, were estimated to contain about
80.3 kilograms of radioactive material (see table 6). About 80 percent
of these unwanted greater-than-Class-C sealed sources (3,495 out of
4,380) contained the radioactive material americium-241, either alone
or in combination with cesium-137. Table 6 also shows that the Off-Site
Source Recovery Project has identified 85 more sealed sources
containing plutonium-239 that need to be recovered than it initially
estimated (currently totaling 449 as compared to the 364 initially
estimated). In addition, the project has identified 46 unwanted
strontium-90 sealed sources that need to be recovered, which contain
about 78 percent (about 62.8 kilograms) of the total amount of
radioactive material that needs to be recovered.
Table 6: Number of Each Type of Greater-Than-Class-C Sealed Source
Awaiting Recovery and Associated Number of Holders and Grams and Curies
of Radioactive Material, as of February 2003:
Type of source: Americium-241; Number of holders: 193; Number of
sources: 3,343; Curies: 11,904; Grams: 3,542.
Type of source: Americium-241 and Cesium-137; Number of holders: 19;
Number of sources: 152; Curies: 23; Grams: 3.
Type of source: Californium-252[A]; Number of holders: 3; Number of
sources: 15; Curies: 22; Grams: Less than 1.
Type of source: Cesium-137[B]; Number of holders: 9; Number of sources:
21; Curies: 3,435; Grams: 57.
Type of source: Cobalt-60[B]; Number of holders: 1; Number of sources:
8; Curies: 363; Grams: 2.
Type of source: Curium-244; Number of holders: 6; Number of sources:
59; Curies: Less than 1; Grams: Less than 1.
Type of source: Plutonium-238; Number of holders: 47; Number of
sources: 282; Curies: 11,925; Grams: 881.
Type of source: Plutonium-239; Number of holders: 149; Number of
sources: 449; Curies: 812; Grams: 13,034.
Type of source: Radium-226[C]; Number of holders: 5; Number of sources:
5; Curies: 2; Grams: 2.
Type of source: Strontium-90; Number of holders: 8; Number of sources:
46; Curies: 3,971,315; Grams: 62,786.
Type of source: Total; Number of holders: 440[D]; Number of sources:
4,380; Curies: 3,999,801; Grams: 80,308[E].
Source: DOE.
Note: GAO's analysis of DOE's data.
[A] According to an Off-Site Source Recovery Project official, because
californium-252 is expensive to make, all greater-than-Class-C sealed
sources containing californium-252 are recycled.
[B] According to an Off-Site Source Recovery Project official, owners
of 29 sealed sources containing cesium-137 or cobalt-60 have reported
to the project that their sources are no longer wanted. Although most
of these sources are not greater than Class C and could be sent to an
existing commercial disposal facility, the owners for various reasons
have been unable to dispose of them.
[C] According to an Off-Site Source Recovery Project official, because
radium-226 is a naturally occurring radioactive material, the Atomic
Energy Act of 1954 places naturally occurring radioactive material
outside of federal jurisdiction. However, this official told us that
although such sources are the responsibility of the states, few states
currently have the ability to recover these sources.
[D] Some holders of sources have more than one type of source.
[E] Total does not add to 80,308 because of rounding.
[End of table]
The 4,380 unwanted greater-than-Class-C sealed sources that awaited
recovery were held by 328 different owners located across the United
States.[Footnote 8] As figure 4 shows, about 59 percent of these
unwanted sealed sources are located in the state of Texas in gauges
that had been used for petroleum exploration.
Figure 4: Greater-Than-Class-C Sealed Sources in Need of Recovery by
State, as of February 2003:
[See PDF for image]
Note: GAO's presentation of DOE's data.
[End of figure]
The Off-Site Source Recovery Project Is Not a Priority of DOE's Office
of Environmental Management:
The Office of Environmental Management's most recent budget plan, which
was completed in fiscal year 2001, showed DOE providing about
$3 million annually to the Off-Site Source Recovery Project from fiscal
year 2002 through fiscal year 2030.[Footnote 9] Consequently, the
amount of funding that the Office of Environmental Management
authorized for the Off-Site Source Recovery Project in fiscal year 2002
was about $2.2 million less than the $5.1 million that the project
estimated it needed.
In February 2002, the Office of Environmental Management conducted a
review of its priorities with the goal of improving program
performance. The review recommended that the office realign its
priorities in a manner more consistent with its main mission to
accelerate the cleanup and closure of contaminated DOE weapons
development facilities. Office of Environmental Management officials
told us that they questioned whether it is appropriate that the Off-
Site Source Recovery Project be assigned to their office and they are
looking into the possibility of moving responsibility for managing the
project to another office in DOE. These officials told us that the
Office of Environmental Management planned to allocate more funding to
cleaning up and closing contaminated DOE nuclear weapons production
facilities, which the office considered a higher priority, and only
provide the project funding to store sealed sources that already had
been recovered. Consequently, DOE's Office of Environmental Management
reduced its request for funding for the project for fiscal years 2003
and 2004 to $2.2 million and $2 million, respectively. However, a DOE
official told us that the office plans to reduce future requests
further to $1 million annually beginning in fiscal year 2005, a funding
level that, according to this official, would be insufficient to keep
current project staff assigned to the project.
In August 2002, the Congress appropriated an additional $10 million for
DOE's Off-Site Source Recovery Project, as part of the 2002
Supplemental Appropriations Act for Further Recovery from and Response
to Terrorist Attacks on the United States, Public Law 107-206.
According to a DOE official, the Congress may have appropriated these
funds, in part, as a result of a January 2002 letter from the NRC
Chairman to the Secretary of Energy requesting an acceleration of
efforts to recover greater-than-
Class-C sealed sources. In the letter, the NRC Chairman noted that NRC
had completed an evaluation that concluded that--in light of the events
of September 11, 2001--the possession or storage of unwanted
radioactive sealed sources with no disposal outlet presents a potential
vulnerability to terrorist threats. The letter urged DOE to recover,
within 18 months, all greater-than-Class-C sealed sources currently
known to be unwanted.
Rather than accelerating DOE's recovery efforts, however, these funds
will be needed to keep DOE's recovery efforts on track through fiscal
year 2004. The Off-Site Source Recovery Project had planned recovery
activities for fiscal years 2003 and 2004 with a total cost of $13.8
million, but DOE's Office of Environmental Management had requested
from the Congress a total of $4.2 million for these years, leaving a
funding shortfall of $9.6 million. Prior to fiscal year 2003, the Off-
Site Source Recovery Project was able to make up for funding shortfalls
by carrying over unspent funds from prior fiscal years. However, by the
end of fiscal year 2002, the size of the shortfall far exceeded the
amount of funding available to carry forward. Therefore, almost all of
the supplemental funding appropriated by the Congress will go toward
helping the Off-Site Source Recovery Project make up the funding
shortfall and continue recovering greater-than-Class-C sealed sources
as planned through the end of fiscal year 2004. Beyond fiscal year
2004, however, it remains unclear whether the Off-Site Source Recovery
Project will receive the funding it needs to continue its planned
recovery activities. The Secretary of Energy publicly stated in
November 2002 that securing and reducing radiological materials that
could be fabricated into dirty bombs is DOE's highest priority and an
urgent problem. However, without funding available to the Off-Site
Source Recovery Project to recover additional sources, owners of
unwanted greater-than-Class-C sealed sources will be forced to store
and secure their sources on their premises until a disposal facility is
available.
DOE Lacks Storage Capacity Meeting the Security Requirements for
Storing Additional Sealed Sources Containing Plutonium-239:
The Off-Site Source Recovery Project has not been able to recover
additional greater-than-Class-C sealed sources containing plutonium-
239 since mid-2002 because DOE lacks storage capacity at the Los Alamos
National Laboratory that meets the security requirements for this
material. Because plutonium-239 can be used to make a crude nuclear
bomb, as well as a dirty bomb, DOE regulations require that any DOE
facility storing
6 kilograms or more of this material must meet DOE's most stringent
security requirements. Meeting these requirements means that, among
other things, the sources containing plutonium-239 must be stored in a
vault-like room in a facility protected by two layers of physical
barriers (e.g., an outer and an inner fence) providing access controls
and intrusion detection; armed guards who are capable of responding to
an intrusion; inspections of personnel, vehicles, and hand-carried
items entering and exiting the facility; and exits that are alarmed or
controlled at all times. As of February 2003, the greater-than-Class-C
sealed sources in storage at the Los Alamos National Laboratory contain
a total of less than 1 kilogram of plutonium-239. DOE's security
requirements for this smaller amount of material are less stringent and
have already been met in the locations at the Los Alamos National
Laboratory where it is being stored. However, according to a DOE
official, these storage locations have also been used to store
radioactive material associated with other programs operating at Los
Alamos. As a result, by mid-2002, the Off-Site Source Recovery Project
had reached the limits of its capacity to store additional plutonium-
239 at Los Alamos without needing to meet DOE's most stringent security
requirements. As of February 2003, the project had identified an
additional 449 unwanted greater-than-Class-C sealed sources containing
about
13 kilograms of plutonium-239 that it will not be able to recover until
storage space meeting DOE's most stringent security requirements is
made available.[Footnote 10]
DOE is currently pursuing two parallel efforts to allow the Off-Site
Source Recovery Project to recover and store additional greater-than-
Class-C sealed sources containing plutonium-239. First, DOE is
evaluating two options for physically increasing the amount of storage
space available that meets the stringent security requirements for the
additional plutonium-239 that the project plans to recover. These
options include packaging and placing the sources in a secure trailer
at the Los Alamos National Laboratory in such a way that they are
stored at least as securely as if they were in a vault and creating
secured storage space at the Nevada Test Site in Nye County, Nevada.
DOE is developing these options but is not yet able to provide us with
a time frame for how long it will take to select and implement an
alternative. An official from the Off-Site Source Recovery Project told
us that the project budgeted $1.5 million to cover the initial cost of
creating additional secure storage space for
plutonium-239 but was unable to provide a plan for ensuring that the
project received the additional funding that would be needed to
continue to maintain this storage space for as long as it was needed.
Concurrent with efforts to increase physical storage capacity, DOE is
also exploring whether all of the sealed sources containing plutonium-
239 that the Off-Site Source Recovery Project plans to recover meet the
legal and regulatory requirements for disposal at the Waste Isolation
Pilot Plant. Currently, by law, only radioactive waste resulting from
the development of nuclear weapons, referred to as defense waste, can
be disposed of at the Waste Isolation Pilot Plant. Any greater-than-
Class-C sealed sources containing plutonium-239 that were used in this
manner can be disposed of at this facility; however, most of the
plutonium-239 sources that the Off-Site Recovery Project plans to
recover were not directly used for defense purposes. DOE is exploring
whether a case can be made that, although these sources were used for
research and other purposes, the
plutonium-239 that they contain was originally manufactured for use in
weapons development and thus can be disposed of at the Waste Isolation
Pilot Plant. In this way, DOE could potentially bypass the plutonium-
239 storage problem entirely by establishing a permanent disposal
facility. However, DOE regulations specify that no amount of plutonium-
239 requiring secured storage can be discarded, whether or not the
material is defense-related, without special approval to terminate the
security requirements. In March 2003, DOE approved the termination of
the security requirements for less than 2 kilograms of plutonium-239 so
that the Off-Site Source Recovery Project can dispose of the defense-
related plutonium-239 it is storing at the Los Alamos National
Laboratory, but it has not yet approved such a termination for non-
defense-related plutonium-239 in storage at Los Alamos.
Until DOE is able to increase its capacity to store greater-than-Class-
C sealed sources containing plutonium-239, 149 holders of unwanted
sources containing this radioactive material must continue to store and
secure their sources on their premises. About 77 percent of the holders
of unwanted plutonium-239 sources are universities. Six of the
universities we contacted told us that they received the sources during
the 1950s and 1960s as part of a national effort to promote research
related to nuclear physics and they have not used these sources for
many years. As a result, these universities each told us that they are
storing and securing from 1 to 10 sealed sources of plutonium-239 that
they no longer want. In general, the sources are stored in rooms or
closets, typically without windows, and access to the rooms can only be
gained by passing through one or more locked doors. Access to the keys
to the doors is controlled, and doors are checked periodically by
campus safety personnel to ensure that they are locked. In addition,
NRC or state regulatory agencies review how the universities are
securing their sealed sources as part of the agencies' reviews of the
universities' nuclear safety programs. However, representatives from
two universities told us of instances in which the doors to the sources
had been found unlocked or open, and representatives from six of the
universities told us that they wanted the Off-Site Source Recovery
Project to recover their sources immediately.[Footnote 11] We also
talked to officials from a Department of Defense facility, a DOE
facility, and a decommissioned nuclear power plant about their
plutonium-239 sources, one of which had as many as 60 plutonium-239
sealed sources on-site. Officials at these facilities told us that
their sources were secure, and no instances of concern were mentioned.
The official at the nuclear power plant told us that the facility would
like the Off-Site Source Recovery Project to recover its sources as
soon as possible because it was in the process of shutting down
operations.
DOE Lacks an Approved Means for Temporarily Storing Sealed Sources
Containing Strontium-90 and Cesium-137:
The Off-Site Source Recovery Project cannot recover unwanted greater-
than-Class-C sealed sources containing strontium-90 and cesium-137,
because DOE has not approved a means for temporarily storing these
types of sealed sources at a DOE facility until a permanent disposal
facility is developed as it has done for the other types of sealed
sources it needs to recover.[Footnote 12] In deciding how and where
sealed sources containing strontium-90 and cesium-137 will be stored,
DOE must do an appropriate analysis as required by the National
Environmental Policy Act of 1969 (NEPA) and implementing regulations.
Once DOE completes and approves the NEPA analysis process for each type
of source, it could begin to implement a storage alternative. DOE
prepared its NEPA analysis for strontium-90 in December 2001, which
offered nine alternatives for storing sealed sources containing this
radioactive material until a disposal facility is available. As of
February 2003, the Office of Environmental Management had not approved
its analysis for strontium-90 and had not begun its analysis for
cesium-137, and DOE was unable to provide us with an estimate of how
long it might take. According to Off-Site Source Recovery Project data,
almost all of the greater-than-Class-C sealed sources containing
strontium-90 that need to be recovered are currently being stored at
facilities operated by the Department of Defense and DOE. Also, while,
according to a project official, most unwanted sealed sources
containing cesium-137 that have been reported to the project do not
contain a greater-than-
Class-C amount of radioactive material, this official told us that
there are about 100 medical devices currently in use for treating blood
that contain cesium-137 sealed sources and that some of these sources
may contain a greater-than-Class-C amount of the radioactive material.
The owners of these medical devices have told project officials that
they would like to replace the devices with new technology.
DOE Has Not Made Progress toward Providing a Permanent Disposal
Facility:
As of February 2003, DOE had not made progress toward providing a
permanent disposal facility for greater-than-Class-C radioactive
waste, as required by Public Law 99-240. Specifically, DOE had not
decided which office within the agency would begin the first step in
developing such a facility, completing the appropriate NEPA analysis,
which would likely be an Environmental Impact Statement. According to
DOE officials, it is unlikely that DOE will be able to provide a
permanent disposal facility by fiscal year 2007 unless the agency makes
it a priority. Furthermore, the agency lacks a plan for recovering and
storing unwanted greater-than-Class-C sealed sources in the event that
the disposal facility is delayed.
DOE Is Unlikely to Provide a Disposal Facility by Fiscal Year 2007:
According to officials from the Off-Site Source Recovery Project, DOE
is unlikely to be able to provide a disposal facility by fiscal year
2007, as it had assumed, unless the agency makes it a priority. As of
February 2003, DOE had not decided which DOE office would be assigned
the responsibility for beginning the first step in providing a disposal
facility for greater-than-Class-C radioactive waste--completing the
appropriate NEPA analysis. Public Law 99-240 gave DOE responsibility
for providing for the disposal of greater-than-Class-C radioactive
waste. In developing a disposal facility, DOE must determine, as
required by NEPA and implementing regulations, whether an Environmental
Impact Statement is necessary. If an Environmental Impact Statement is
necessary, DOE would have to propose a number of disposal alternatives,
and the public would have an opportunity to comment. Following
completion of the Environmental Impact Statement and a mandatory 30-day
waiting period, DOE would initiate a Record of Decision, in which the
agency would select the alternative to be implemented. After the Record
of Decision is completed, approved, and made public, DOE may begin to
implement the decision. Whether the alternative selected is to
construct a new facility or modify an existing facility, funding would
need to be identified, and after the facility was built, it would need
to be licensed by NRC. All together, developing a new disposal facility
could take at least 7 years, not including the time to physically build
the facility.
Also, DOE had neither provided funding nor produced a timeline for
completing the NEPA analysis. Officials in DOE's Office of
Environmental Management told us that the office had identified funding
for completing the Environmental Impact Statement for fiscal years 2002
and 2003; however, after office management reviewed the budget in
February 2002, the office redirected the funding to other higher
priority projects. They also told us that they anticipated that DOE
would decide which DOE office would be responsible for the NEPA
analysis some time in fiscal year 2003, and the Office of Environmental
Management's most recent budget plan for the Off-Site Source Recovery
Project mentioned the office's intention to defer the development of
the facility.
DOE officials told us that it typically takes about 2 years to complete
an Environmental Impact Statement and as long as 3 years or more to
complete a Record of Decision. If the Record of Decision indicates that
a new facility is needed, funding would need to be secured, and
construction activities completed. The officials told us that there was
not enough information available at this time to estimate how long
construction activities would take. However, they told us that the NRC
licensing process that would follow could take at least 2 years. In a
1987 report to the Congress, DOE estimated that providing a new
facility, including construction, could require at least 7 to 9 years
to complete.[Footnote 13]
In the 1987 report, DOE also stated that if an existing facility could
be used for disposal of greater-than-Class-C sealed sources, disposal
services could be provided sooner, depending upon the availability of
the facility. However, it remains uncertain when or if this will be
possible. DOE has been exploring whether the acceptance criteria for
the Waste Isolation Pilot Plant in Carlsbad, New Mexico, can be
broadened to include more of the sealed sources that the project is
recovering. Currently, the Waste Isolation Pilot Plant can only accept
certain types of radioactive waste resulting from DOE's defense-related
activities, which would preclude it from taking the majority of the
sources recovered by the project. Furthermore, although the
Environmental Protection Agency has certified the Waste Isolation Pilot
Plant, the facility did not require an NRC license because the waste
sent there did not result from NRC-licensed activities. However, Public
Law 99-240 requires DOE to dispose of any greater-than-Class-C
radioactive waste that resulted from NRC-licensed activities, which
includes most of the sealed sources that the Off-Site Source Recovery
Project is recovering, at a facility licensed by NRC. These legal
matters would need to be resolved before the Waste Isolation Pilot
Plant could be considered a viable option.
Another possibility being explored is the potential for disposing of
greater-than-Class-C sealed sources at DOE's planned repository for
waste resulting from the nuclear power industry. For example, the
Environmental Impact Statement for building a disposal facility at
Yucca Mountain discussed the potential for disposing of greater-than-
Class-C radioactive waste at this facility. The purpose of such a
repository is to enable DOE to meet the requirements of the Nuclear
Waste Policy Act, which establishes DOE's responsibility for providing
for the permanent disposal of high-level radioactive waste. However,
the Nuclear Waste Policy Act limits the amount of high-level waste that
can be disposed of at a facility built to satisfy the requirements of
the Act and does not explicitly state whether greater-than-Class-C
waste could also be disposed of at the same facility. As with the Waste
Isolation Pilot Plant, these legal matters would need to be resolved
before sending unwanted greater-than-Class-C sealed sources to DOE's
planned repository could be considered a viable option.
DOE Lacks a Plan for Recovering Sealed Sources if the Disposal Facility
Is Delayed:
As of February 2003, DOE's Office of Environmental Management did not
have a plan for continuing the recovery of greater-than-Class-C sealed
sources in the event that the disposal facility is delayed. The Off-
Site Source Recovery Project was originally envisioned as providing DOE
with the means of recovering and temporarily storing unwanted greater-
than-Class-C sealed sources until a permanent disposal facility was
available. However, DOE still plans to begin phasing out the Off-Site
Source Recovery Project's operations in fiscal year 2007 and cease
operations altogether in fiscal year 2010 as originally assumed. As a
result, under the current plan, any delays in providing a disposal
facility could begin to hinder DOE's efforts to ensure unwanted
greater-than-Class-C sealed sources are properly secured as early as
fiscal year 2007.
Conclusions:
Since September 11, 2001, recovering and disposing of greater-than-
Class-C radioactive sealed sources has taken on added significance
because doing so would secure nuclear materials that have the potential
for being misused and that pose a threat to national security. The
Secretary of Energy publicly stated in November 2002 that securing and
reducing radiological materials that could be fabricated into dirty
bombs is DOE's highest priority and an urgent problem. We believe that
continuing the recovery efforts of the Off-Site Source Recovery Project
and providing a permanent disposal facility for greater-than-Class-C
radioactive sealed sources should be key elements in any DOE strategy
to address this problem. However, responsibility for these efforts is
currently located in an office within DOE where they are not a
priority. As a result, the Off-Site Source Recovery Project has not
received adequate funding; key decisions about how and where to
temporarily store and ultimately dispose of greater-than-Class-C sealed
sources have not been made; and future progress toward permanently
securing unwanted sealed sources is likely to be limited.
The Off-Site Source Recovery Project has made progress recovering
greater-than-Class-C sealed sources, but future progress will depend on
whether DOE gives the project the priority that is commensurate with
the risks that these sealed sources pose to the public; ensures
adequate resources are devoted to the project; and provides, as soon as
possible, sufficient space to store, at an appropriate level of
security, any sealed sources that it needs to recover. Ultimately,
however, all unwanted greater-than-Class-C sealed sources will need to
be placed in a permanent disposal facility. Since already more than 17
years have passed since the enactment of Public Law 99-240, we believe
it is time that DOE initiate the process to provide such a facility.
DOE will have difficulty ensuring the success of this effort, however,
without a plan that would, at a minimum, assign responsibility for
developing the facility; establish milestones by which progress could
be measured; evaluate potential disposal options; estimate costs and
schedules; and address legislative, regulatory, and licensing
considerations. Also, because it is unlikely that such a facility will
be operational by fiscal year 2007 when the Off-Site Source Recovery
Project is scheduled to begin phasing out operations, a plan to ensure
the continued recovery and storage of greater-than-Class-C sealed
sources until a disposal facility is available would help DOE prevent
any gaps in its ability to secure unwanted greater-than-Class-C sealed
sources.
As sealed sources currently in use wear out or become obsolete, the
proliferation of unwanted greater-than-Class-C sealed sources of all
types across the United States will continue to increase. Unless action
is taken, DOE's efforts to recover, temporarily store, and ultimately
dispose of unwanted greater-than-Class-C sealed sources will be
severely impeded, ultimately forcing owners of these dangerous
materials to continue storing and securing them on their premises where
they will remain susceptible to misuse, improper disposal, and theft.
Recommendations for Executive Action:
Because of the risk that unwanted greater-than-Class-C sealed sources
could be used as weapons of terror, we recommend that the Secretary of
Energy determine whether the priority given to the Off-Site Source
Recovery Project is commensurate with the threat posed by these sealed
sources. Once this determination has been made, the Secretary should
ensure that adequate resources are devoted to the project to cover the
costs of recovering and storing these sealed sources as quickly as
possible. To ensure that unwanted greater-than-Class-C sealed sources
containing plutonium-239, strontium-90, and cesium-137 are properly
secured to prevent their use in dirty bombs or, in the case of sources
containing plutonium-239, nuclear weapons, we further recommend that
the Secretary of Energy take immediate action to provide storage space
for these sources at a secure DOE facility and establish milestones by
which progress can be measured to ensure that the storage space is
provided as soon as possible.
In addition, we recommend that the Secretary of Energy initiate the
process to develop a permanent disposal facility for greater-than-
Class-C radioactive waste to carry out the requirements of Public Law
99-240. To help manage the process, the Secretary should develop a plan
that would, at a minimum, assign responsibility for developing the
facility; establish milestones by which progress can be measured;
evaluate potential disposal options; estimate costs and schedules; and
address legislative, regulatory, and licensing considerations. Because
it is unlikely that a permanent disposal facility for such waste will
be operational by fiscal year 2007 when the Off-Site Source Recovery
Project is scheduled to begin phasing out operations, we recommend that
the Secretary of Energy develop a plan to ensure the continued recovery
and storage of greater-than-Class-C sealed sources until a disposal
facility is available.
Agency Comments:
During a discussion of our report with DOE officials, including the
Associate Deputy Assistant Secretary for Integration and Disposition,
agency officials expressed general agreement with our findings,
conclusions, and recommendations. In a subsequent March 31, 2003,
letter, which is reproduced in appendix II, DOE provided written
comments on our report and raised three issues. Specifically, DOE
asserted that (1) our report did not mention a joint DOE and NRC
working group that was chartered to address the issue of unwanted
sealed sources and their potential use in radiological dispersal
devices; (2) the project baseline we reviewed had not been revised to
incorporate the results of the working group's draft report and the
need to change the recovery effort from a general health-and-safety-
driven program to a national-security-and-nuclear-nonproliferation-
driven program; and (3) we did not interview any policy executives
within DOE in preparing our report.
Regarding the first issue, we have added to the report a discussion of
the purpose and objectives of this working group and its preliminary
recommendations to DOE and NRC. Although the efforts of this working
group are broader than the scope of the Off-Site Source Recovery
Project, in our view, the working group's preliminary findings,
conclusions, and recommendations generally support the conclusions and
recommendations in our report. Regarding the second issue, our report
states that the greater-than-Class-C sealed sources that are being
recovered by the project are a national security concern because they
are particularly attractive for potential use in producing dirty bombs.
In addition, DOE has been required to provide a facility for disposing
of these sources for more than 17 years. Finally, regarding the third
issue, it is unclear to us why this point is being raised. During the
course of our review, we met with the Director and then the Acting
Director for Technical Program Integration, and on February 20, 2003,
we met with the Associate Deputy Assistant Secretary for Integration
and Disposition to obtain her comments on our written findings and
discuss our preliminary conclusions and potential recommendations.
Furthermore, on March 26, 2003, at her request, we met with the
Assistant Secretary for Environmental Management. During the meeting,
we offered to accept any additional information she wanted to provide
and make appropriate changes to the draft as needed. During this
meeting, no changes were suggested to our findings, conclusions, or
recommendations.
Scope and Methodology:
We performed our review at the Off-Site Source Recovery Project office
at the Los Alamos National Laboratory in Los Alamos, New Mexico; DOE's
Albuquerque Operations Office in Albuquerque, New Mexico; and DOE's and
NRC's headquarters in Washington, D.C. We reviewed statutes,
regulations, and appropriate guidance as well as interviewed agency
officials to determine the relevant statutory framework. We reviewed
cost and schedule estimates from DOE and interviewed appropriate
officials to determine how much DOE had spent to date recovering and
storing unwanted greater-than-Class-C sealed sources and how DOE
estimated the number of sealed sources it planned to recover from
fiscal years 1999 through 2010 and the cost to complete the remaining
project activities. We also obtained and reviewed the studies and other
information on which DOE based its estimates. We reviewed data from the
Off-Site Source Recovery Project on the number of greater-than-Class-C
sealed sources recovered to date and the number still awaiting
recovery. In addition, we visited the Los Alamos National Laboratory to
see how sealed sources that the project had recovered were being
stored. We reviewed budget data and interviewed headquarters officials
from DOE's Office of Environmental Management to assess the level of
the office's commitment to the Off-Site Source Recovery Project. We
also interviewed appropriate officials to determine what efforts DOE
was undertaking to provide safe and secure storage capacity for
greater-than-Class-C sealed sources containing plutonium-239,
strontium-90, and cesium-137. To understand how owners of unwanted
sources containing plutonium-239 were managing their sources until they
were recovered, we spoke with representatives from eight universities,
a Department of Defense facility, a DOE facility, and a decommissioned
nuclear power plant, which were located throughout the United States
and listed on the project's database as having unwanted sources
awaiting recovery. Finally, we interviewed headquarters officials from
DOE's Office of Environmental Management to determine the progress DOE
had made toward providing a permanent disposal facility.
We conducted our work from June 2002 through April 2003 in accordance
with generally accepted government auditing standards.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution of it until 30
days from the date of this letter. We will then send copies to the
Secretary of Energy, the Acting Administrator, National Nuclear
Security Administration, the Director, Office of Management and Budget,
and interested congressional committees and other interested parties.
We will also make copies available to others who request them. In
addition, the report will be available at no charge at GAO's web site
at http:www.gao.gov.
If you or your staff have any questions about this report, I can be
reached at (202) 512-3841. Major contributors to this report include
Gene Aloise, Stephen Cleary, and Ilene Pollack.
Sincerely yours,
Robert A. Robinson
Managing Director, Natural Resources and Environment:
Signed by Robert A. Robinson:
[End of section]
Appendix I: Sections 1, 2, and 3 of the Low-Level Radioactive Waste
Policy Amendments Act of 1985, Public Law 99-240:
[See PDF for image]
[End of figure]
[End of section]
Appendix II: Comments from the Department of Energy:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
Department of Energy Washington, DC 20585:
March 31, 2003:
Mr. Robert A. Robinson:
Managing Director, Natural Resources and Environment:
United States General Accounting Office Washington, D.C. 20548:
Dear Mr. Robinson:
We have reviewed your draft report entitled Nuclear Nonproliferation:
Department of Energy (DOE) Action Needed to Ensure Continued Recovery
of Unwanted Sealed Radioactive Sources (GAO-03-483). The Office of
Environmental Management (EM) believes your draft report does not
adequately consider a number of issues that the DOE is addressing
concerning nonproliferation of sealed sources.
The DOE takes seriously the new national security aspects of this
source recovery program. In June 2002 the Secretary of Energy and the
Chairman of the U.S. Nuclear Regulatory Commission (NRC) chartered a
working group to address the issue of unwanted sealed sources and their
potential use in radiological dispersal devices (a copy of that group's
charter is enclosed). The working group has drafted a report, currently
undergoing internal agency review, that makes a number of
recommendations which, when implemented, will make considerable
improvements in how the DOE and NRC are addressing the issue of
unwanted sealed sources. One major focus of this effort is to ensure
DOE's resources are spent wisely, to focus recovery efforts on those
sealed sources which pose the greatest concern.
The project baseline that your team reviewed was approved in April
2002. That baseline was prepared to reflect the work necessary to
address unwanted sources from a general health and safety perspective.
The baseline has not been revised to incorporate the results of the
working group report and the need to change the recovery effort from a
general health and safety driven program to a national security and
nuclear nonproliferation driven program. The baseline proposes a budget
for fiscal year (FY) 2005 that will be considered, along with the
working group report, during DOE's FY 2005 budget request preparation,
which is ongoing. EM further believes the results of this effort
provide the DOE with a technical context within which to conduct proper
analysis under the National Environmental Policy Act for disposal of
the necessary range of sources.
I appreciate the opportunity to comment on this report. However, the
report should focus on DOE's policy approach to addressing this
initiative. Furthermore, the General Accounting Office (GAO) failed to
interview any policy executives within DOE in preparing this report,
and the draft report reflects this fact.
if you have any questions, please call me at (202) 586-7709 or Ms.
Patrice M. Bubar, Associate Deputy Assistant Secretary, Office of
Integration and Disposition, at (202) 586-5151.
Sincerely,
Jessie Hill Roberson Assistant Secretary for Environmental Management:
Signed by Jessie Hill Roberson:
Enclosure:
See comment 2.
See comment 1.
See comment 1.
See comment 3.
The following are GAO's comments on the Department of Energy's (DOE)
letter dated March 31, 2003.
GAO Comments:
DOE commented that our draft report does not adequately consider a
number of issues that DOE is addressing concerning nonproliferation of
sealed sources. Specifically, DOE mentions a joint DOE and Nuclear
Regulatory Commission (NRC) working group that was chartered to address
the issue of unwanted sealed sources and their potential use in
radiological dispersal devices. A discussion of the working group and
its draft report will be addressed in our forthcoming report on the
control of domestic radiological sources. However, we have added, in
the background section of this report, a discussion of the purpose of
the working group, the objectives it was addressing, and its
preliminary recommendations to DOE and NRC regarding the disposal of
radiological sources. The efforts of this working group are broader
than the scope of the Off-Site Source Recovery Project in that they
include a discussion of all radiological materials not just greater-
than-Class-C sealed sources. In our view, the working group's
preliminary findings, conclusions, and recommendations generally
support our conclusions and recommendations regarding the need for DOE
to (1) provide sufficient resources to ensure the continued operations
of the Off-Site Source Recovery Project; (2) provide secure storage
space for greater-than-Class-C sealed sources that DOE needs to
recover; (3) initiate the process to provide a permanent disposal
facility for greater-than-
Class-C waste; and (4) develop a plan to ensure continued recovery of
these sources in the likely event that a permanent facility is delayed.
DOE also makes the point that one major focus of this DOE and NRC
working group's effort is to ensure DOE's resources are spent wisely
and to focus recovery efforts on those sealed sources that pose the
greatest concern. However, greater-than-Class-C sealed sources have
already been identified as particularly attractive for potential use in
producing dirty bombs. Among other things, they contain concentrated
amounts of high-risk nuclear materials, such as americium-241, cesium-
137, plutonium-238, plutonium-239, and strontium-90. Furthermore,
Public Law 99-240 specifically requires that DOE provide for the
permanent disposal of greater-than-Class-C sealed sources, a task even
more important now, following the events of September 11, 2001, than
when the law was enacted.
DOE commented that the project's baseline that we reviewed had not yet
been revised to incorporate the results of the working group's draft
report and the need to change the recovery effort from a general
health-and-safety-driven program to a national-security-and-nuclear-
nonproliferation-driven program. In addition, the project's baseline
proposes a budget for fiscal year 2005 that will be considered, along
with the working group's report, during DOE's fiscal year 2005 request
preparation, which is ongoing. Regarding DOE's comment that the
project's baseline will be revised to focus on national security and
nonproliferation, greater-than-Class-C sealed sources are a concern
because they are particularly attractive for potential use in producing
dirty bombs. Furthermore, for more than 17 years, DOE has been required
by Public Law 99-240 to provide a facility for disposing of all
greater-than-Class-C waste, including greater-than-Class-C sealed
sources that are no longer wanted by their owners. To date, however,
DOE has not developed such a facility. Regarding DOE's point about the
budget, DOE's comments indicate that the project's future estimated
budget needs will be considered along with the recommendations of the
working group. However, there is still no indication that the Off-Site
Source Recovery Project will get the funding it needs to recover
greater-than-Class-C sealed sources beyond fiscal year 2004. As stated
in our report, DOE's Office of Environmental Management reduced its
request for funding for the Off-Site Source Recovery Project for fiscal
years 2003 and 2004 to
$2.2 million and $2 million, respectively, to provide the funds
necessary to store sealed sources that had already been recovered. In
addition, a DOE official told us that the office plans to reduce future
requests further to $1 million annually beginning in fiscal year 2005,
a funding level that, according to this official, would be insufficient
to keep current project staff assigned to the project.
DOE commented that we failed to interview any policy executives within
DOE in preparing this report and that the draft report reflects this
fact. It is unclear to us why this point is being raised. During the
course of our review, in addition to meeting with a variety of project
managers, we met with the Director and then the Acting Director for
Technical Program Integration. These officials are directly responsible
for the management of the Off-Site Source Recovery Project. On February
19, 2003, we provided DOE with our written findings, prior to sending
the draft to DOE for agency comment, to confirm that the critical facts
and key information used to formulate our analyses and findings were
current, correct, and complete. On February 20, 2003, we met with a
variety of program officials, including the Associate Deputy Assistant
Secretary for Integration and Disposition to discuss our findings,
preliminary conclusions, and potential recommendations that flowed from
the factual information we collected. These officials agreed with our
findings and preliminary conclusions and recommendations. They did
provide us technical changes, which we made to the draft report as
appropriate. In addition, on March 26, 2003, at her request, we met
with the Assistant Secretary for Environmental Management. At this
meeting, we said that we were willing to accept any information
regarding the findings, conclusions, and recommendations in our draft
report that the Assistant Secretary may have. In addition, we said that
we were willing to make appropriate changes to the draft. The Assistant
Secretary did not dispute the findings, conclusions, or recommendations
in our draft report but said that our draft did not mention the working
group and its resulting draft report dated February 2003. As stated
above, we included a discussion of the working group's efforts in the
background section of this report.
FOOTNOTES
[1] The Nuclear Regulatory Commission classifies low-level radioactive
waste (i.e., waste not specifically classified as high-level waste,
such as used fuel rods from nuclear power plants) as A, B, or C for the
purpose of disposal. Radioactive waste is classified by type of
radionuclide (e.g., americium-241) and concentration of radioactivity
(often measured in curies per gram). Class A, B, and C radioactive
wastes must meet progressively more stringent requirements for
disposal. Class A, B, and C wastes (e.g., exit signs containing tritium
and contaminated soil or lab equipment) generally can be disposed of at
existing commercial disposal facilities. Wastes that exceed the Nuclear
Regulatory Commission's criteria for Class C, known as greater-than-
Class-C wastes, generally cannot be disposed of at existing facilities.
[2] As of February 2003, DOE had not modified these estimates.
[3] Nuclear Regulatory Commission, Above Class C Source/Device
Inventory Survey (Washington, D.C.: Nov. 1989) and Idaho National
Engineering Laboratory, Characterization of Greater-Than-Class-C
Sealed Sources, Volumes 1, 2, and 3, DOE/LLW-163 (Idaho Falls, Idaho:
Sept. 1994).
[4] According to a project official, DOE assumed that, based on past
experience, owners of small numbers of unwanted greater-than-Class-C
sealed sources initially might have difficulty shipping their sources
directly to a disposal facility without the assistance of the Off-
Source Recovery Project. DOE assumed that by the end of the transition
period these difficulties would be resolved.
[5] At 14,309, the number of greater-than-Class-C sealed sources that
DOE plans to recover appears more precise than it is because DOE
reduced the number of sealed sources it initially planned to recover
during the transition years, fiscal years 2007 through 2010, by a
certain percentage each year.
[6] Although DOE planned to cease project operations by the end of
fiscal year 2010, DOE planned project closeout activities for fiscal
year 2011. As of February 2003, DOE had not changed its estimate of the
cost to complete the planned recovery activities.
[7] DOE's $56.5 million estimate of the cost to complete the recovery
of 14,309 greater-than-Class-C sealed sources and the $12.7 million
that DOE had spent from fiscal years 1999 through 2001 do not add to
$69.3 million because of rounding.
[8] The number of different holders of unwanted greater-than-Class-C
sealed sources that awaited recovery is lower than the number in table
6 because some holders of sources have more than one type of source.
[9] The Office of Environmental Management's budget plan was completed
before DOE finalized the time frame for the Off-Site Source Recovery
Project, which, as currently planned, will cease operations by the end
of fiscal year 2010.
[10] The Off-Site Source Recovery Project also identified greater-than-
Class-C sealed sources containing another 15 kilograms of plutonium-239
that are currently in use. According to an official from the Off-Site
Source Recovery Project, DOE will eventually need to recover these
sources as well. Consequently, DOE could need to provide the capacity
to securely store a total of an additional 28 kilograms of this
material, if a disposal facility were not made available beforehand.
[11] Representatives from two universities told us that they wanted to
keep their sealed sources even though these sources were listed as
unwanted on the project's database.
[12] Strontium-90 and cesium-137 are nuclear materials that remain
radioactive for a long period of time, can contaminate property, and
require an extensive clean-up. These nuclear materials can also be
absorbed in the food chain and are potential cancer causing risks.
According to an Off-Site Recovery Project official, the project is able
to store the unwanted greater-than-Class-C sealed sources that contain
both americium-241 and cesium-137 because the americium-241 in the
sources determines how the sources must be stored.
[13] Public Law 99-240 also requires DOE to submit a report to the
Congress setting forth the agency's recommendations for ensuring the
safe disposal of greater-than-Class-C radioactive waste, which the
agency completed in February 1987. See U.S. Department of Energy,
Recommendations for Management of Greater-Than-Class-C Low-Level
Radioactive Waste, Report to Congress in Response to Public Law 99-240
(Washington, D.C.: Feb. 1987).
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