Low-Level Radioactive Waste Management
Approaches Used by Foreign Countries May Provide Useful Lessons for Managing U.S. Radioactive Waste Gao ID: GAO-07-221 March 21, 2007GAO has reported on limitations in the management of U.S. low-level radioactive waste (LLRW). LLRW ranges from very low-activity to higher-activity waste. To identify potential approaches to overcome these limitations, GAO was asked to examine the extent to which other countries have (1) LLRW inventory databases, (2) timely removal of higher-activity LLRW from waste generator sites, (3) disposition options for all LLRW, and (4) requirements that LLRW generators have financial reserves to cover waste disposition costs, as well as any other approaches that might improve U.S. LLRW management. GAO primarily relied on a survey of 18 countries representing leading LLRW generators to identify their management approaches and to compare them with U.S. survey results and with approaches suggested by LLRW generators, disposal operators, and regulators in the United States.
Academic, industrial, medical, utility, and government entities in the United States, particularly the Department of Energy (DOE), disposed of at least 15 million cubic feet of LLRW in 2005. This waste includes debris, rubble, soils, paper, liquid, metals, and clothing that have been exposed to radioactivity or contaminated with radioactive material, and sealed radiological sources that are no longer useful for industrial or other applications (disused). Other countries that have nuclear reactor units and use radioactive materials in other ways manage the residual LLRW in some ways that are different than in the United States. Of the countries surveyed, GAO found that most countries indicated they have national radioactive waste inventory databases that include information on all waste generators, waste types, storage locations, and disused sealed radiological sources, and that they use them to forecast future disposal capacity needs. Most countries indicated they facilitate the timely removal of higher-activity LLRW, essentially disused sealed radiological sources, from generator sites to enhance safety and security, including requiring the return of a disused source to a source supplier. Most countries indicated they have disposal options for lower-activity LLRW, central storage options for higher-activity LLRW, and alternative disposal options for very low-level radioactive waste that in most cases does not require an exemption review by a nuclear regulatory authority. Half the countries indicated they impose financial assurance requirements on all waste generators to cover disposition costs, and most of these countries also use other approaches to reduce government costs to recover higher-activity LLRW, such as requiring a disposal fee at the time that a sealed radiological source is purchased. GAO also found that most countries surveyed use national radioactive waste plans to guide the management of their radioactive wastes. Many representatives from LLRW generators, disposal operators, regulators, and others told GAO that the application of similar approaches to those used by other countries might improve the management of U.S. radioactive waste.
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-07-221, Low-Level Radioactive Waste Management: Approaches Used by Foreign Countries May Provide Useful Lessons for Managing U.S. Radioactive Waste
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United States Government Accountability Office:
GAO:
Report to the Chairman and Ranking Minority Member, Committee on Energy
and Natural Resources, U.S. Senate:
March, 2007:
Low-Level Radioactive Waste Management:
Approaches Used by Foreign Countries May Provide Useful Lessons for
Managing U.S. Radioactive Waste:
GAO-07-221:
GAO Highlights:
Highlights of GAO-07-221, a report to the Chairman and Ranking Minority
Member, Committee on Energy and Natural Resources, U.S. Senate.
Why GAO Did This Study:
GAO has reported on limitations in the management of U.S. low-level
radioactive waste (LLRW). LLRW ranges from very low-activity to higher-
activity waste. To identify potential approaches to overcome these
limitations, GAO was asked to examine the extent to which other
countries have (1) LLRW inventory databases, (2) timely removal of
higher-activity LLRW from waste generator sites, (3) disposition
options for all LLRW, and (4) requirements that LLRW generators have
financial reserves to cover waste disposition costs, as well as any
other approaches that might improve U.S. LLRW management. GAO primarily
relied on a survey of 18 countries representing leading LLRW generators
to identify their management approaches and to compare them with U.S.
survey results and with approaches suggested by LLRW generators,
disposal operators, and regulators in the United States.
What GAO Found:
Academic, industrial, medical, utility, and government entities in the
United States, particularly the Department of Energy (DOE), disposed of
at least 15 million cubic feet of LLRW in 2005. This waste includes
debris, rubble, soils, paper, liquid, metals, and clothing that have
been exposed to radioactivity or contaminated with radioactive
material, and sealed radiological sources that are no longer useful for
industrial or other applications (disused). Other countries that have
nuclear reactor units and use radioactive materials in other ways
manage the residual LLRW in some ways that are different than in the
United States. Of the countries surveyed, GAO found that:
* Most countries indicated they have national radioactive waste
inventory databases that include information on all waste generators,
waste types, storage locations, and disused sealed radiological
sources, and that they use them to forecast future disposal capacity
needs.
* Most countries indicated they facilitate the timely removal of higher-
activity LLRW, essentially disused sealed radiological sources, from
generator sites to enhance safety and security, including requiring the
return of a disused source to a source supplier.
* Most countries indicated they have disposal options for lower-
activity LLRW, central storage options for higher-activity LLRW, and
alternative disposal options for very low-level radioactive waste that
in most cases does not require an exemption review by a nuclear
regulatory authority.
* Half the countries indicated they impose financial assurance
requirements on all waste generators to cover disposition costs, and
most of these countries also use other approaches to reduce government
costs to recover higher-activity LLRW, such as requiring a disposal fee
at the time that a sealed radiological source is purchased.
GAO also found that most countries surveyed use national radioactive
waste plans to guide the management of their radioactive wastes. Many
representatives from LLRW generators, disposal operators, regulators,
and others told GAO that the application of similar approaches to those
used by other countries might improve the management of U.S.
radioactive waste.
Photographs: An Interior and Exterior View of the LLRW Disposal
Facility in France:
Source: French National Radioactive Waste Management Agency (Agence
nationale pour la gestion des déchats radioactifs–Andra-FRL
Productions).
What GAO Recommends:
GAO recommends that the Nuclear Regulatory Commission (NRC) and DOE
evaluate and report on the usefulness of (1) adopting the identified
management approaches, and the steps and any authorities necessary to
implement them; and (2) developing a U.S. radioactive waste management
plan, and the costs, steps, and any authorities necessary to do so. NRC
and DOE generally agreed with these recommendations, but raised a
number of issues regarding their implementation.
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-221].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Gene Aloise at (202) 512-
3841 or aloisee@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Comprehensive National LLRW Inventory Databases Are Widely Used to
Track and Manage LLRW:
Methods for Promptly Removing Higher-Activity LLRW from Waste Generator
Sites Are Widely Used to Reduce Safety and Security Risks:
Central Storage and Alternative Disposal Options Are Widely Used to
Facilitate Management of LLRW:
Financial Assurance Requirements and Other Approaches Are Used by Most
Countries to Reduce Government LLRW Recovery Costs:
National Radioactive Waste Management Plans Are Considered Important
for Managing LLRW:
Conclusions:
Recommendations:
Agency Comments and Our Evaluation:
Appendix I: Recent GAO Findings and Agency Actions on LLRW Management:
Appendix II: Scope and Methodology:
Appendix III: Survey of LLRW Management Approaches Response from United
States:
Appendix IV: Volume and Location of LLRW in the United States:
Appendix V: Status of Class B and C Waste Disposal and Potential
Effects of Reduced Access to South Carolina Disposal Facility:
Appendix VI: Comments from the Nuclear Regulatory Commission and Our
Response:
Appendix VII: Comments from the Department of Energy and Our Response:
Appendix VIII: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Tables:
Table 1: IAEA Suggested Radioactive Waste Classification System:
Table 2: Listing of Domestic LLRW Stakeholder Group Respondents:
Table 3: Total LLRW Disposed at the Three Operating Commercial LLRW
Disposal Facilities as of 2005:
Table 4: Total Disposed LLRW at the Four Closed Commercial Disposal
Facilities:
Table 5: Total LLRW Disposed at the Three Commercial LLRW Disposal
Facilities during 2005:
Table 6: LLRW in Storage or Disposal at DOE Sites:
Table 7: Transuranic Waste Disposed of or in Storage Awaiting Disposal
at WIPP:
Table 8: Central Storage and Disposal of Disused Sealed Radiological
Sources Recovered by DOE‘s Off-Site Source Recovery Project:
Table 9: Class B and C Waste Type Groups:
Table 10: Total Class B and C Waste Disposed at Richland and Barnwell
by Waste Type Group, 2001-2005:
Table 11: Number of Generators That Disposed of Class B and C Waste at
Richland and Barnwell by Generator Type and Waste Type, 2001-2005:
Table 12: Range of Class B and C Waste Disposed Annually at Richland
and Barnwell by Generator Type, 2001-2005:
Table 13: Distribution of Class B and C Waste Disposed Annually at
Richland and Barnwell by Generator Type, 2001-2005:
Table 14: Distribution of Non-Utility Class B and C Waste Disposed
Annually at Richland and Barnwell by Generator Type, 2001-2005:
Table 15: Disposed Class B and C Waste at Richland and Barnwell by LLRW
Compact, 2001-2005:
Table 16: Class B and C Waste Disposed at Barnwell from Atlantic,
Northwest, and Rocky Mountain Generators, and Other Generators, 2001-
2005:
Table 17: Number of Waste Generators That Disposed of Sealed
Radiological Sources at Richland and Barnwell Ranked by Compact, 2001-
2005:
Figures:
Figure 1: Contents of National Radioactive Waste Inventory Databases:
Figure 2: Management Approaches for National Radioactive Waste
Inventory Databases:
Figure 3: Management Approaches for Tracking and Managing LLRW:
Figure 4: Methods to Facilitate Prompt Removal of LLRW from Generator
Sites:
Figure 5: LLRW Disposal Options and Management Responsibilities:
Figure 6: Central Storage Options for LLRW:
Figure 7: Disposal Options and Exemption Methods for Managing Very Low-
Level Radioactive Waste:
Figure 8: Financial Approaches to Reduce Government Costs to Recover
LLRW:
Figure 9: Number of Generators That Disposed of Class B and C Waste at
Richland and Barnwell by Generator Type and Waste Type, 2001-2005:
Abbreviations:
DOE: Department of Energy:
GTCC: greater-than-class C:
IAEA: International Atomic Energy Agency:
LLRW: low-level radioactive waste:
NEA: Nuclear Energy Agency:
NRC: Nuclear Regulatory Commission:
WIPP: Waste Isolation Pilot Plant:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
March 21, 2007:
The Honorable Jeff Bingaman:
Chairman:
The Honorable Pete V. Domenici:
Ranking Minority Member:
Committee on Energy and Natural Resources:
United States Senate:
Academic, industrial, medical, utility, and government entities in the
United States, particularly the Department of Energy (DOE)”commercially
disposed of at least 15-million cubic feet of low-level radioactive
waste (LLRW) in 2005.[Footnote 1] LLRW substantially includes debris,
rubble, and contaminated soils from facility decommissioning and site
cleanup, as well as items such as rags, paper, liquid, glass, metal
components, resins, filters, and protective clothing that have been
exposed to radioactivity or contaminated with radioactive material. In
addition, LLRW includes sealed radiological sources that are no longer
used (disused) for their authorized use in agriculture, education,
industry, medicine, and research applications. Sealed radiological
sources contain radioactive material encapsulated, or sealed in metal
to prevent its dispersal. At the present time, commercial disposal
options are available for almost all LLRW in the United States.
However, during the mid-1990s there was a period of time when a
disposal facility was not available for some LLRW, and most waste
generators are now facing the prospect of another disposal shortage in
2008 if the state of South Carolina restricts access as planned to a
key LLRW disposal facility. The Nuclear Regulatory Commission (NRC)
considers future disposal costs and availability to be uncertain. The
uncertainties surrounding disposal costs and availability and other
limitations in LLRW management are taking on even greater significance
as the United States embarks on developing new nuclear power plants,
which would eventually create even more LLRW. Moreover, according to
NRC, many non-utility generators of LLRW do not have the physical or
financial capability to effectively manage disposal shortages and may
have to curtail beneficial uses of radioactive material.
The principal federal legislation governing the disposal of LLRW is the
Low-Level Radioactive Waste Policy Act, as amended. The LLRW Policy
Act, among other things, assigns to the states and the federal
government responsibility for providing disposal availability for LLRW.
[Footnote 2] NRC has divided the radioactive waste covered by the act
into categories of increasing levels of hazard, beginning with class A,
followed by B, C, and greater-than-class C (GTCC) waste, although there
is no statutory upper limit or lower limit for the level of
radioactivity required to declare a material to be LLRW. In addition,
the act required DOE to provide technical assistance to the states,
establish a computerized database to assist the states and DOE in
monitoring the management of LLRW, and to report annually to the
Congress on the management of LLRW by the states. However, DOE no
longer receives specific appropriations to provide technical
assistance”except for some funding to maintain a database of LLRW
disposed at commercial facilities”and its reporting requirements
terminated effective May 2000. NRC”or when authorized an Agreement
State”is responsible for licensing LLRW disposal facilities. [Footnote
3] In addition, NRC is responsible for overseeing and regulating all
nuclear power plants, and for promulgating rules governing the safe and
secure use of nuclear materials. The Agreement States must adopt and
implement requirements that are compatible with NRC‘s standards.
The LLRW Policy Act promotes greater LLRW disposal capacity on a
regional basis and more equitably distributes responsibility for
managing this waste among the 50 states. As an incentive for states to
manage LLRW on a regional basis, the Congress consented to the
formation of interstate agreements, known as compacts, and granted
compact member states the authority to refuse to accept LLRW from other
compacts or unaffiliated states. There are currently three licensed
commercial LLRW disposal facilities, each operating under different
access and licensing restrictions, and none developed under the
regional compact structure as authorized in the LLRW Policy Act. One of
these disposal facilities is in Clive, Utah, and it accepts almost all
the nation‘s class A waste. Another commercial LLRW disposal facility
is in Barnwell, South Carolina, and it accepts almost all of the
nation‘s class B and C waste. The third commercial disposal facility is
in Richland, Washington, and it receives class A, B, and C waste from
the 11 states of the Rocky Mountain and Northwest LLRW Compacts. DOE is
currently studying the feasibility of disposal options for GTCC waste.
GAO has reported on limitations in the management of U.S. LLRW.
[Footnote 4] We have examined the contents of the LLRW commercial
disposal inventory and national source tracking system databases;
safety and security of stored class B, C, and GTCC waste; availability
of LLRW disposition options; and issues facing DOE‘s ability to recoup
costs for the recovery of disused sealed radiological sources. More
specifically, we reported in 2004 on the scope and reliability of U.S.
LLRW inventory information and found that DOE‘s commercial LLRW
disposal database (1) did not contain data on all disposed LLRW, (2)
did not capture information on LLRW that is produced and stored at
waste generator sites, and (3) had data inaccuracies. We also found
that the then proposed national source tracking system database would
not have captured almost all the disused commercial sources that DOE
had recovered from licensees. International authorities consider
disused sealed radiological sources held in local storage at user
premises waiting for disposal or return to manufacturer to be at
greatest risk of becoming an orphan source. [Footnote 5]
We also reported on the safety and security of storing class B, C, and
GTCC waste at non-utility waste generator sites, such as industrials,
medical and non-DOE governmental users of nuclear material. We found
that NRC does not place general time limits on local storage of any
LLRW nor does it require waste generators to return their disused
sealed radiological sources to a source supplier. However, NRC
explained that its existing licensing and inspection programs are
adequate to ensure the safety and security of stored LLRW.
Nevertheless, we also found that adding additional information on the
storage of disused sealed radiological sources to the then proposed
national source tracking system would assist DOE‘s ongoing source
recovery program to remove these sources from waste generator sites. We
also reported on the adequacy of LLRW disposition options and found
that greater federal oversight was needed to monitor LLRW storage and
disposal conditions in light of uncertainties surrounding future
disposal availability for class B and C waste. Finally, we commented on
the lack of financial mechanisms for DOE to recoup the costs of
recovering, storing, and disposing of thousands of disused sealed
radiological sources from their holders who in some cases do not have
capacity to store or dispose of them. We found that NRC did not require
all non-utility waste generators, particularly those possessing sealed
radiological sources, to ensure that funds are available to cover
future LLRW disposition costs.
NRC and DOE accepted many of the recommendations made in these GAO
reports and they have taken other actions to improve the management of
LLRW. Other actions include a current strategic assessment of NRC‘s
regulation of LLRW that is intended to identify and prioritize staff
activities. According to NRC officials, this assessment will consider
the recommendations made in GAO reports and other recent reports
including those from an NRC chaired task force on radiation source
protection and security, the NRC Advisory Committee on Nuclear Waste,
and the National Research Council. [Footnote 6] We were informed this
assessment currently lacks a systematic review of approaches taken by
other countries to manage their LLRW. DOE is also designing a complex-
wide strategy to optimize the disposition of its low-level waste and
mixed low-level waste. Appendix I contains a more detailed discussion
of GAO findings and agency actions on LLRW management.
Given our past reports on LLRW management and NRC and DOE responses to
our recommendations, you asked us to identify approaches taken by other
countries to manage their LLRW, and whether any of these approaches
might be applicable in the United States. Specifically, you asked us to
determine the extent to which other countries have: (1) comprehensive
national LLRW inventory databases, (2) timely removal of higher-
activity LLRW in storage at waste generator sites, (3) disposition
options for all LLRW, and (4) requirements to assure that non-utility
LLRW generators have adequate financial reserves to cover all waste
disposition costs. We also agreed to report on any other approaches
that we identified in the course of our work that might support
improvement in the management of LLRW in the United States.
To conduct our work, we primarily relied on the results of a survey of
20 foreign countries representing the leading generators of LLRW,
reviews of reports from the International Atomic Energy Agency (IAEA)
and the Nuclear Energy Agency (NEA), [Footnote 7] and interviews with
representatives from U.S. LLRW stakeholder groups. These countries,
along with the United States, account for 85 percent of the world‘s
installed nuclear power plant capacity. While countries generate
similar radioactive waste, there is variation in the way they classify
this waste. Our survey relied on the suggested IAEA waste
classification scheme that defines two categories of LLRW, short-lived
low- and intermediate-level radioactive waste (lower-activity LLRW) and
long-lived low- and intermediate-level radioactive waste (higher-
activity LLRW). The IAEA is also considering adding another class of
radioactive waste”very low-level radioactive waste”which some countries
already use in managing LLRW. Eighteen of the 20 foreign countries
responded to our survey to identify their use of management approaches
to address our four research objectives. [Footnote 8] NRC collaborated
with DOE and other LLRW stakeholder groups to complete a U.S. response
to our survey. In addition, we visited LLRW facilities and interviewed
officials in France, Japan, and Sweden. We chose these countries
because of their extensive experience with nuclear power generation and
with constructing and operating LLRW disposal facilities. We also
interviewed representatives of U.S. LLRW stakeholder groups regarding
their knowledge of approaches used in other countries and their
opinions on new approaches that might help improve LLRW management in
this country. For the most part, these representatives provided little
awareness of approaches used in other countries. Those interviewed
represented federal and state nuclear regulatory authorities,
commercial LLRW disposal operators, state LLRW compact commissions, and
other groups. As not all representatives provided a response to
questions about each LLRW management issue, our content analysis of the
interviews captures opinions from only those representatives that
responded to each issue. We also reviewed a variety of documents
provided to us by these representatives. We identified and assessed the
reliability of various waste inventory databases in an attempt to
describe the volume and location of LLRW in the United States. We
determined that these data were sufficiently reliable for the purposes
of our report. We conducted our review between September 2005 and
February 2007 in accordance with generally accepted government auditing
standards. A more detailed description of our scope and methodology is
provided in appendix II. Appendix III provides the response of the
United States to the survey of LLRW management approaches.
Results in Brief:
Most countries we surveyed use comprehensive national radioactive waste
inventory databases to assist in the management of LLRW. Thirteen
countries indicated that their inventory databases typically contained
information on all waste types”10 of which specifically inventoried
very low-level radioactive waste”the storage of waste at generator
sites, including disused sealed radiological sources, and all waste
generator types in their countries. In addition, 15 countries indicated
that they take steps to increase the reliability of the information
collected by ensuring its completeness, accuracy, and timeliness.
Almost all countries use these databases to track the location and
quantities of radioactive waste to forecast future disposal capacity
needs. Most of the U.S. LLRW stakeholder group representatives who
responded to this issue generally supported the usefulness of
developing comprehensive national LLRW inventory databases. The NRC
chaired task force also commented on the need to evaluate including
more source categories in the national source tracking system.
Fourteen of the 18 countries we surveyed use methods to promptly remove
higher-activity LLRW from generating sites in order to reduce safety
and security risks. These countries both encourage and enforce the
timely removal of disused sealed radiological sources to prevent the
uncontrolled exposure of workers and the public to radiation. Some of
these countries also place general time limits on the storage of these
sources at generator sites. To facilitate the removal of this higher-
activity LLRW, almost all countries surveyed require that sealed
radiological sources be returned to their suppliers or to central waste
storage when they are no longer in use. Most of these countries also
have established orphan source recovery programs to collect sealed
radiological sources that have been abandoned or lost. Some U.S.
stakeholder group representatives who responded to this issue and the
recent report from the NRC chaired task force generally supported the
need to evaluate methods that could be used to facilitate the removal
of higher-activity LLRW, essentially disused sealed radiological
sources, from non-utility waste generator sites.
Ten of the 18 countries we surveyed have disposal options for lower-
activity LLRW and 6 other countries have plans to build such
facilities. While only 3 countries indicated that they have a disposal
option for higher-activity LLRW, 14 countries reported that they have
central storage facilities for this waste. Moreover, 13 countries
indicated that they have clearance or unrestricted removal of very low-
level radioactive waste from regulatory control as LLRW, and 8
countries indicated that they have disposal options for this waste. The
U.S. LLRW stakeholder group representatives who responded to this issue
were split on the need for central storage options for higher-activity
LLRW when a disposal option is not available, but most of them
supported exempting very low-level radioactive waste from regulatory
control as LLRW. The NRC chaired task force and other reports have
commented on, among other related issues, the need to reexamine
disposal options for LLRW.
Half the countries we surveyed indicated that their nuclear regulatory
authorities require all non-utility LLRW generators to have sufficient
financial assurances to cover the removal of radioactive waste from
their sites. In addition, seven of the countries use other financial
assurance approaches to ensure that the government is reimbursed for
any sealed radiological sources that it may need to recover from non-
utility LLRW generators. More than half of the U.S. LLRW stakeholder
group representatives who responded to this issue and the recent report
from the NRC chaired task force commented on the need to improve the
financial assurance structure for some LLRW generators in the United
States. The task force report suggested that NRC evaluate some
approaches that are similar to those used in some other countries to
ensure that radioactive material users have financial reserves to cover
waste disposition costs.
We also found that 12 of the 18 countries surveyed rely on national
radioactive waste management plans to guide the management of their
radioactive wastes and that the United States lacks such a plan.
Several of these plans required the management of radioactive waste
from a national perspective and specified one administrative entity as
responsible for coordinating their development. In addition, there was
often a requirement in the plans for periodic public reporting of LLRW
conditions. While the usefulness of such a plan was not sought through
a question in the survey or specifically raised in interviews with U.S.
LLRW stakeholder group representatives, most of the representatives and
recent reports on LLRW management mentioned the need to evaluate
alternative ways to manage LLRW.
To improve the management of LLRW in the United States and address a
potential disposal shortage for higher-activity LLRW in 2008 and other
management concerns, we are recommending that the Chairman of NRC and
the Secretary of Energy evaluate and report back to the Congress within
1 year on the usefulness to the United States of (1) adopting the LLRW
management approaches used in the countries that are discussed in this
report, and the steps and any authorities necessary for their
implementation, if deemed appropriate; and (2) developing a U.S.
radioactive waste management plan, and the potential costs, steps, and
any authorities necessary to develop such a plan, if deemed
appropriate.
NRC and DOE generally agreed with the recommendations in a draft of our
report, but raised a number of issues regarding their implementation.
Specifically, they suggested other means through which they could
report the results of their evaluations to Congress and they questioned
the benefits of developing a national radioactive waste management
plan. We do not take issue with how NRC and DOE may choose to report to
the Congress; as long as the Congress gets the information it needs,
the reporting format is a secondary consideration. In addition, in
response to NRC and DOE suggestions, we revised our recommendation
regarding the development of a national radioactive waste management
plan to clarify that the agencies first evaluate and report on the
usefulness of such a plan, and then conduct other analysis if deemed
appropriate. However, based on the experience of other nations, we
continue to believe that a national radioactive waste management plan
has merit. We responded to specific comments from NRC and DOE in
appendix VI and VII, respectively, and incorporated technical changes
in this report where appropriate based on detailed comments provided by
the agencies. The State Department did not comment on our draft report.
Background:
The 30 countries in the world that generate electricity from 435
nuclear power reactor units face the need to manage the radioactive
wastes that are generated from these units as well as the waste
generated by non-utility users of nuclear materials. The United States
is a large generator of radioactive waste with its 104 nuclear power
reactors and thousands of radioactive material licensees. These
countries, including the United States, contribute to and are guided by
advice from international organizations on approaches to manage
radioactive materials. The principal international organizations are
IAEA and NEA. For example, countries may voluntarily use IAEA standards
to demonstrate implementation of the obligations set forth in the Joint
Convention on the Safety of Spent Fuel Management and on the Safety of
Radioactive Waste Management, which the United States has signed.
According to IAEA, the Joint Convention recognizes and reinforces the
internationally held view that radioactive waste management is an issue
of national concern, but that the development, implementation, and
maintenance of national programs for radioactive waste management must
be carried out with due regard to internationally-endorsed criteria and
standards. [Footnote 9] Moreover, for contracting parties to various
international safety conventions, IAEA standards provide a consistent,
reliable means of ensuring the effective fulfillment of their
obligations. One example of these criteria and standards is the IAEA
Code of Conduct for the Safety and Security of Radioactive Sources.
[Footnote 10] This code, which the United States has agreed to work
toward implementing, is intended to guide countries in developing and
harmonizing policies, laws, and regulations pertaining to sealed
radiological sources. The code states, among other things, that the
nuclear regulatory authority in each country should establish a
national registry of radioactive sources to track the possession of
these sources. At a minimum, the code recommends that the nuclear
regulatory authority in each country include sources in categories 1
and 2 of the five source categories defined by IAEA. These two
categories contain sources with the highest level of radioactivity.
However, the code suggests that the nuclear regulatory authorities also
give appropriate attention to sources in the other three categories, as
they would pose health and security risks when aggregated in harmful
quantities.
IAEA has also put forth suggested guidance on a general system for
classifying radioactive waste to facilitate communication and
information exchange among countries. In general, U.S. class A, B, and
most of class C waste would fall into IAEA‘s category of short-lived
low- and intermediate-level radioactive waste (lower-activity waste),
and the remaining 25 percent of class C waste and all of GTCC waste
would be within IAEA‘s long-lived low- and intermediate-level
radioactive waste category (higher-activity waste). IAEA acknowledges
that spent or disused sealed radiological sources are not considered
waste in certain countries, such as the United States, but considers
that the safe management of such sources is achieved by compliance with
the requirements for managing radioactive waste. Table 1 provides a
description of the suggested IAEA radioactive waste classification
scheme.
Table 1: IAEA Suggested Radioactive Waste Classification System:
Waste class: 1. Exempt waste;
Typical characteristics: Activity levels at or below clearance levels,
which are based on annual dose less than 0.01 mSv[a];
Disposal options: No radiological restrictions.
Waste class: 2. Low- and intermediate-level waste;
Typical characteristics: Activity levels above clearance levels and thermal
power below about 2 kW/m3[b];
Disposal options: [Empty].
Waste class: 2. Low- and intermediate-level waste, 2.1 Short-lived
waste;
Typical characteristics: Restricted long-lived radionuclide
concentrations;
Disposal options: Near-surface or geological disposal facility.
Waste class: 2. Low- and intermediate-level waste, 2.2 Long-lived
waste;
Typical characteristics: Long-lived radionuclide concentrations
exceeding restricted short-lived waste;
Disposal options: Geological disposal facility.
Waste class: 3. High-level waste;
Typical characteristics: Thermal power above about 2 kW/m3 and
long-lived radionuclide concentrations exceeding limitations for
short-lived waste;
Disposal options: Geological disposal facility.
Source: IAEA, Radioactive Waste Management: Status and Trends-Issue #2
(Vienna, Austria: Sept. 2002) 24.
[a] mSv (millisivert) is a unit of radiation dose measurement. Two and
a half millisieverts is the national average dose of background
radiation from all sources.
[b] kW/m3 is kilowatts per cubic meter of thermal power.
[End of table]
IAEA presently does not define a category for very low-level
radioactive waste, but such a category is under consideration. IAEA has
drafted for consideration by its member states a new waste
classification system that would add more waste categories,
particularly categories for low-activity radioactive waste. This
proposed system would have six categories: (1) exempt waste, (2) very
short-lived waste, (3) very low-level waste, (4) low-level waste, (5)
intermediate-level waste, and (6) high-level waste. The very low-level
waste category might be considered the lower spectrum of class A waste,
and include materials with very limited radioactivity, such as
contaminated soil and rubble from decommissioned power plants.
Finally, IAEA issued a Safety Standard guide in 2005 regarding the
management of waste from the use of radioactive material in medicine,
industry, agriculture, research and education. [Footnote 11] IAEA
stated that a national strategy for the management of radioactive waste
should be developed in accordance with the safety objectives and
principles. A strategy is necessary in order to define the
infrastructure and the means to be adopted for the management of
radioactive waste. IAEA stated that a key element in the strategy is
the extent to which national and regional waste management facilities
are developed rather than managing the waste at a number of locations
where it arises.
Comprehensive National LLRW Inventory Databases Are Widely Used to
Track and Manage LLRW:
Most countries we surveyed use comprehensive national radioactive waste
inventory databases to assist in the management of LLRW. Thirteen
countries indicated that their inventory databases typically contained
information on all waste types”10 of which specifically inventoried
very low-level radioactive waste”the storage of waste at generator
sites, including disused sealed radiological sources, and all waste
generator types in their countries. In addition, 15 countries indicated
that they take steps to increase the reliability of the information
collected by ensuring its completeness, accuracy, and timeliness.
Almost all countries use these databases to track the location and
quantities of radioactive waste to forecast future disposal capacity
needs. Most of the U.S. LLRW stakeholder group representatives who
responded to this issue generally supported the usefulness of
developing comprehensive national LLRW inventory databases. The NRC
chaired task force also commented on the need to evaluate including
more source categories in the national source tracking system.
Most Countries Have Comprehensive National Radioactive Waste Inventory
Databases:
Thirteen of the 18 countries are considered to have comprehensive
national radioactive waste inventory databases that typically contain
information on a wide range of waste types, locations of stored waste,
waste generators, and the possession of sealed radiological sources.
Almost all countries (17/18) indicated that their inventory databases
include short-lived low- and intermediate-level waste as well as long-
lived intermediate-level waste. In addition, 10 countries indicated
that their inventories also include very low-level radioactive waste,
13 include long-lived low-level waste, and 14 include high-level waste.
All 17 countries that have national radioactive waste inventory
databases indicated that they capture waste data from all generators in
their countries, which could include academic, government, industrial,
medical, and nuclear reactor sources of LLRW. In regard to tracking the
location of waste, 14 countries indicated that their radioactive waste
inventory databases capture waste in storage at generator sites. For
example, France indicated that its national radioactive waste inventory
database records the types of radioactive waste located at all waste
generator sites, central storage, and disposal sites.
The countries in our survey also maintain national registries of sealed
radiological sources, including those in use, storage or disuse. Most
countries indicated in their survey responses that their national
radiological source registries go beyond the minimum of category 1 and
2 suggested in the IAEA Code of Conduct on the Safety and Security of
Radioactive Sources. Fourteen of 18 countries indicated that their
national source registries include all category 1, 2, and 3 sources,
and nine of these countries also include category 4 and 5 sources. The
nine countries with comprehensive source registries were Denmark,
Finland, France, Hungary, Italy, Japan, Mexico, Slovak Republic, and
Switzerland. While the survey did not seek information on the number of
sources in a country, the countries with comprehensive source
registries include those that may have a relatively small number of
sources to track, such as Denmark, to those countries that have much
larger numbers to track, such as France and Japan. Figure 1 summarizes
the comprehensiveness of the national radioactive waste inventory
databases in the countries we surveyed.
Figure 1: Contents of National Radioactive Waste Inventory Databases:
LLRW management approach:
Maintains a national radioactive waste inventory database:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: No;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 17.
LLRW management approach:
Very low-level radioactive waste is included in the national
radioactive waste inventory database:
France: Yes;
Japan: Yes;
Germany: No;
Canada: Yes;
United Kingdom: No;
Sweden: No;
Spain: Yes;
Belgium: No;
Finland: No Response;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: No;
Italy: Yes;
Australia: Not Applicable;
Denmark: Yes;
Norway: No Response;
Total Yes Count: 10.
LLRW management approach:
Short-lived low- and intermediate-level waste, and long-lived
intermediate-level waste are included in the national radioactive waste
inventory database:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Not Applicable;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 17.
LLRW management approach:
Long-lived low-level waste (including naturally occurring radioactive
material) is included in the national radioactive waste inventory
database:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: Yes;
Italy: Yes;
Australia: Not Applicable;
Denmark: Yes;
Norway: No;
Total Yes Count: 14.
LLRW management approach:
High-level radioactive waste are included in the national radioactive
waste inventory database:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Not Applicable;
Denmark: Not Applicable;
Norway: No;
Total Yes Count: 14.
LLRW management approach:
All types of radioactive waste generators in the country are included
in the national radioactive waste inventory database:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Not Applicable;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 17.
LLRW management approach:
National radioactive waste inventory database captures waste stored at
generator sites:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Not Applicable;
Denmark: No;
Norway: No;
Total Yes Count: 14.
LLRW management approach:
Maintains a national source registry containing IAEA categories 1, 2,
and 3 radiological sources:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: No;
Sweden: No;
Spain: No Response;
Belgium: No;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Yes;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 14.
LLRW management approach:
Maintains a national source registry containing IAEA categories 1-5
radiological sources:
France: Yes;
Japan: Yes;
Germany: No;
Canada: No;
United Kingdom: No;
Sweden: No;
Spain: No Response;
Belgium: No;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: No;
Italy: Yes;
Australia: No;
Denmark: Yes;
Norway: No;
Total Yes Count: 9.
Source: GAO survey of foreign countries, 2006.
Note: Denmark responded to questions about the contents of its national
radioactive waste inventory database, although it will not be
established until 2007. Countries are ordered according to their
nuclear electricity generation at the beginning of 2006, as reported by
NEA. The last four countries in the table currently do not have nuclear
electricity generation, but Italy did in the past, and the other
countries have nuclear research reactors. The United States would be
the largest nuclear electricity generator if listed.
[End of figure]
Countries Take Steps to Ensure Reliability of Information in Their
Inventory Databases:
The countries in our survey try to increase the reliability of their
radioactive waste inventory databases by taking steps to ensure that
the information collected is complete, accurate, and timely. Almost all
countries (15/18) indicated that they have at least one control in
place to verify the completeness and accuracy of information in their
national radioactive waste inventories. These controls include periodic
inspections of the waste at generator sites, checking generator waste
inventory data submissions against past and projected waste from the
generator, and periodic audits of the waste inventory records
maintained by the generator. For example, in the United Kingdom, the
information provided by LLRW waste generators is reviewed and checked
for consistency with previous inventory information and against similar
types of waste. Moreover, independent assessments are undertaken to
provide upper-bound estimates of total radioactivity of the waste at
generator sites. The waste generators are also required to obtain a
letter of compliance to package their waste before final waste
processing. At the time the letter of compliance is issued, the waste
data is reviewed, and if found insufficient, the waste generator may be
subject to a further audit.
Although almost all countries (17/18) have a national authority or
waste management organization responsible for maintaining their
national radioactive waste inventory databases, countries varied in how
information is transmitted to the entity managing the inventory and the
frequency of information submission. Currently, only 2 of the 18
countries require the submission of waste data through a secure
website. The most common methods for data submission were use of e-
mail, standard mail, fax, and by phone. Most of the countries (12/18)
indicated that their national radioactive waste inventory databases
receive data from waste generators annually or more frequently. Survey
results indicated that inventory updates every 6 months or less are
obtained from waste generators in Denmark, Mexico, Norway, Slovak
Republic, Spain, and Switzerland. Figure 2 summarizes the approaches
used in the countries surveyed to manage their national radioactive
waste inventory databases.
Figure 2: Management Approaches for National Radioactive Waste
Inventory Databases:
LLRW management approach:
National nuclear regulatory authority or national waste management
organization is responsible for managing the national radioactive waste
inventory database:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: No Response;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 17.
LLRW management approach:
Manager of national radioactive waste inventory database uses at least
one control to verify the completeness and accuracy of information
submitted by waste generators:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: No Response;
Italy: Yes;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 15.
LLRW management approach:
Waste generators submit data to manager of national radioactive waste
inventory database through a secure website:
France: No Response;
Japan: No;
Germany: No;
Canada: No Response;
United Kingdom: Yes;
Sweden: Yes;
Spain: No;
Belgium: No;
Finland: No Response;
Switzerland: No;
Slovak Republic: No Response; Hungary: No;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 2.
LLRW management approach:
Waste generators are required to submit data to manager of national
radioactive waste inventory database once a year or more frequently:
France: No;
Japan: Yes;
Germany: Yes;
Canada: No;
United Kingdom: No;
Sweden: Yes;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: No;
Italy: Yes;
Australia: Not Applicable;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 12.
LLRW management approach:
Member of the European Union and has implemented Council Directive
2003/122EURATOM regarding the control of high-activity sealed
radioactive sources and orphan sources:
France: Yes;
Japan: Not Applicable;
Germany: Yes;
Canada: Not Applicable;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Not Applicable;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Not Applicable;
Netherlands: Yes;
Italy: No;
Australia: Not Applicable;
Denmark: No;
Norway: Not Applicable;
Total Yes Count: 10.
Source: GAO survey of foreign countries, 2006.
Note: Denmark responded to questions about the contents of its national
radioactive waste inventory database, although it will not be
established until 2007. Countries are ordered according to their
nuclear electricity generation at the beginning of 2006, as reported by
NEA. The last four countries in the table currently do not have nuclear
electricity generation, but Italy did in the past, and the other
countries have nuclear research reactors. The United States would be
the largest nuclear electricity generator if listed.
[End of figure]
Countries Use Inventory Databases to Track and Manage LLRW:
Sixteen of the 18 countries in our survey indicated that they use their
national radioactive waste inventory databases to forecast waste
volumes, plan for disposal capacity, and track the location of disused
sealed radiological sources. Thirteen countries indicated that they
publicize information from their national radioactive waste inventory
databases on what is stored and disposed of to gain community
acceptance for siting these facilities. Sixteen of the countries
indicated that they keep records of the location and status and use of
sources in their national source registries. Figure 3 shows the
responses for each country.
Figure 3: Management Approaches for Tracking and Managing LLRW:
LLRW management approach:
Regulator keeps a record of the locations and status of use of sources,
including disused sources:
France: Yes;
Japan: No;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: No Response;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 16.
LLRW management approach:
National radioactive waste inventory database is used to make
projections of future waste volumes for capacity planning of central
waste storage and disposal facilities:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: No;
Denmark: Yes;
Norway: No;
Total Yes Count: 16.
LLRW management approach:
Radioactive waste inventory information is publicized to help obtain
community acceptance of LLRW central storage and disposal facilities:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: No Response;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: No Response;
Italy: No;
Australia: Yes;
Denmark: No Response;
Norway: Yes;
Total Yes Count: 13.
Source: GAO survey of foreign countries, 2006.
Note: Denmark responded to questions about the contents of its national
radioactive waste inventory database, although it will not be
established until 2007. Countries are ordered according to their
nuclear electricity generation at the beginning of 2006, as reported by
NEA. The last four countries in the table currently do not have nuclear
electricity generation, but Italy did in the past, and the other
countries have nuclear research reactors. The United States would be
the largest nuclear electricity generator if listed.
[End of figure]
Domestic Experts Support Need for More Comprehensive LLRW Inventory
Databases:
Most representatives of domestic LLRW stakeholder groups who responded
in interviews to this issue (19/25) supported the need to establish a
more comprehensive national radioactive waste inventory database in the
United States. Over half of these representatives commented that such
an inventory would allow LLRW stakeholders to forecast waste volumes
and to plan for future disposal capacity requirements. However, some
representatives felt that a more comprehensive national radioactive
waste inventory database would not be necessary. For example, one
representative argued that the cost-effectiveness of adding more
reporting requirements to include the storage of class B and C waste
might not be justified given the small quantities of this waste that
are generated each year.
A recent report of the interagency Radiation Source Protection and
Security Task Force, chaired by NRC, addressed the scope of the current
national source tracking system, which currently tracks the possession
of category 1 and 2 sources. The task force suggested that NRC conduct
a comprehensive analysis of category 3 sources for possible inclusion
in the National Source Tracking System. The task force found that
category 3 and lower-activity sources comprise a major portion of those
sources voluntarily identified as surplus, excess, or unwanted in the
commercial sector. Moreover, the task force found that the U.S. metal
recycle industry claims that category 3 sources are those more commonly
misplaced or abandoned by industry, resulting in potential
contamination of the metal recycling process with operational and
financial impacts.
Methods for Promptly Removing Higher-Activity LLRW from Waste Generator
Sites Are Widely Used to Reduce Safety and Security Risks:
Fourteen of the 18 countries we surveyed use methods to promptly remove
higher-activity LLRW from generating sites in order to reduce safety
and security risks. These countries both encourage and enforce the
timely removal of disused sealed radiological sources to prevent the
uncontrolled exposure of workers and the public to radiation. Some of
these countries also place general time limits on the storage of these
sources at generator sites. To facilitate the removal of higher-
activity LLRW, almost all countries surveyed require that sealed
radiological sources be returned to their suppliers when they are no
longer in use. Most of these countries also have established orphan
source recovery programs to collect sealed radiological sources that
have been abandoned or lost. Some U.S. stakeholder group
representatives who responded to this issue and the recent report from
the NRC chaired task force generally supported the need to evaluate
methods that could be used to facilitate the removal of higher-activity
LLRW, essentially disused sealed radiological sources, from non-utility
waste generator sites.
Most Countries Encourage and Enforce the Prompt Removal of Higher-
Activity LLRW from Generator Sites:
Most countries we surveyed (14/18) indicated that their nuclear
regulatory authority encourages the removal of higher-activity LLRW,
essentially disused sealed radiological sources, from generator sites,
and half of the countries enforce the prompt removal of these sources.
Some of the countries that require the prompt removal of these sources
also place time limits on how long LLRW can remain in storage at waste
generator sites. Seven countries indicated that they limit the amount
of time that LLRW can remain in storage at non-utility waste generator
sites, and four other countries impose time limits only when waste
generators have a disposal option for the waste. For example, in
Sweden, depending on the facility, waste generators can only hold
disused sealed radiological sources for 6 months to a year and a half,
and any other LLRW intended for storage at a waste generator site for
more than 2 years must be registered with the national regulatory
authority.
Most Countries Use a Variety of Approaches to Facilitate the Removal of
Higher-Activity LLRW from Generator Sites:
Almost all countries we surveyed (15/18) indicated that they require
that sealed radiological sources be returned to their source supplier
or to a central storage facility when they are no longer in use. The
general support for this LLRW management approach might be attributable
to international guidance on managing sources. All countries in our
survey have agreed to follow the IAEA Code of Conduct on the Safety and
Security of Radioactive Sources, which recommends that nuclear
regulatory authorities attach clear and unambiguous conditions on the
use of sources, including, where applicable, agreements regarding the
return of disused sources to a supplier. In addition, the Council of
the European Union Directive 2003/122 states that all member countries
must establish requirements that a holder of a sealed radiological
source return the source to the supplier, place it in a recognized
installation, or transfer it to another authorized holder without undue
delay after termination of the use, unless otherwise agreed by the
nuclear regulatory authority. For example, in France, the supplier of
sealed radiological sources is responsible for the sources it sells.
Once the purchaser of a source ceases to use it, the holder must
immediately return it to the supplier who is responsible for accepting
it unconditionally. Until the source user can prove that the source has
been returned to a supplier, the user retains responsibility for it.
Only three countries, two of which are non-European Union member
countries, indicated that they do not currently impose this regulation
on source holders.
Most countries we surveyed (11/18) indicated that they have government
programs to recover higher-activity sources that are not under
regulatory control (orphan sources). Once again, there is international
guidance in this area. The IAEA Code of Conduct on the Safety and
Security of Radioactive Sources recommends that nuclear regulatory
authorities establish provisions to recover and restore appropriate
control over orphan sources. Moreover, the Council of the European
Union also recognized that despite the existence of an appropriate
regulatory framework to control these higher-activity sources, they
still may be abandoned or lost. Council Directive 2003/122 states that
all member countries shall ensure that their nuclear regulatory
authorities are prepared to or have assigned responsibilities for
recovering orphan sources. This directive also states that the nuclear
regulatory authorities in these countries shall be notified of any
changes in the situation of a higher-activity source, such as its
location and use, and to register these changes. Nine countries,
including three non-European Union countries, indicated that holders of
sealed radiological sources are required to notify the nuclear
regulatory authority when a source has become disused, and most
countries (14/18) indicated that their authority verifies this
information by periodically inspecting the storage of disused sources
at user sites. Eleven countries indicated that a government entity is
given responsibility for managing an orphan source recovery program; 3
countries give this responsibility to a non-governmental entity. For
example in Japan, the Japan Radioisotope Association is responsible for
recovering and storing sealed radiological sources and other
radioisotopes from users of these radioactive materials. The
association, regulated by the Ministry of Education, Culture, Sports,
Science and Technology”the Japanese ministry responsible for regulating
medical uses of radioisotopes”is funded through fees collected by users
of these materials. Figure 4 provides a summary of the methods used by
countries in our survey to facilitate the prompt removal LLRW,
particularly disused sealed radiological sources from waste generator
sites.
Figure 4: Methods to Facilitate Prompt Removal of LLRW from Generator
Sites:
LLRW management approach:
On-site storage time limits for LLRW are set for non-nuclear power
plant entities:
France: Yes;
Japan: No;
Germany: No;
Canada: No Response;
United Kingdom: Yes;
Sweden: Yes;
Spain: No;
Belgium: Yes;
Finland: No;
Switzerland: No;
Slovak Republic: Yes;
Hungary: No;
Mexico: No;
Netherlands: Yes;
Italy: Yes;
Australia: No;
Denmark: No;
Norway: No;
Total Yes Count: 7.
LLRW management approach:
On-site storage time limits for LLRW are set only when a disposal
option is available:
France: Yes;
Japan: No Response;
Germany: No Response;
Canada: No Response;
United Kingdom: Yes;
Sweden: Not Applicable;
Spain: No Response;
Belgium: Not Applicable;
Finland: No Response;
Switzerland: No Response;
Slovak Republic: Not Applicable;
Hungary: No Response;
Mexico: Yes;
Netherlands: Not Applicable;
Italy: Yes;
Australia: No Response;
Denmark: No Response;
Norway: No Response;
Total Yes Count: 4.
LLRW management approach:
Regulator encourages removal of disused radiological sources from user
sites:
France: No Response;
Japan: No;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: No Response;
Denmark: No Response;
Norway: Yes;
Total Yes Count: 14.
LLRW management approach:
Regulator enforces prompt removal of disused radiological sources from
user sites:
France: Yes;
Japan: No;
Germany: No;
Canada: Yes;
United Kingdom: No;
Sweden: No;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: No;
Slovak Republic: Yes;
Hungary: No;
Mexico: Yes;
Netherlands: No Response;
Italy: Yes;
Australia: No Response;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 9.
LLRW management approach:
Time limits are placed on length of time a radiological source can be
used:
France: Yes;
Japan: No;
Germany: No;
Canada: Yes;
United Kingdom: No;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No;
Switzerland: No;
Slovak Republic: No;
Hungary: Yes;
Mexico: Yes;
Netherlands: No;
Italy: No;
Australia: No;
Denmark: No;
Norway: No;
Total Yes Count: 4.
LLRW management approach:
Requirement that disused radiological sources be returned to a supplier
or central waste storage:
France: Yes;
Japan: No;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: No;
Australia: No;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 15.
LLRW management approach:
Maintains an orphan radiological source recovery program:
France: Yes;
Japan: Yes;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: No;
Slovak Republic: Yes;
Hungary: No;
Mexico: Yes;
Netherlands: Yes;
Italy: No;
Australia: No;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 10.
LLRW management approach:
Government entity is made responsible for orphan radiological source
recovery program:
France: Yes;
Japan: No;
Germany: No Response;
Canada: Yes;
United Kingdom: Yes;
Sweden: No Response;
Spain: Yes;
Belgium: No Response;
Finland: Yes;
Switzerland: No Response;
Slovak Republic: No;
Hungary: No Response;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Yes;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 11.
LLRW management approach:
An organization other than the government is responsible for recovering
orphan radiological sources:
France: No;
Japan: Yes;
Germany: No Response;
Canada: No;
United Kingdom: No;
Sweden: No Response;
Spain: No;
Belgium: No Response;
Finland: No;
Switzerland: No Response;
Slovak Republic: Yes;
Hungary: No Response;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No;
Denmark: No;
Norway: Yes;
Total Yes Count: 3.
LLRW management approach:
Users must inform regulators if holding disused sources:
France: No;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: No;
Finland: No Response;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: No Response;
Italy: Yes;
Australia: No Response;
Denmark: No;
Norway: No;
Total Yes Count: 9.
LLRW management approach:
Regulator periodically inspects the operational storage of disused
radiological sources:
France: Yes;
Japan: No;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: Yes;
Italy: Yes;
Australia: No Response;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 14.
Source: GAP survey of foreign countries, 2006.
Note: Countries are ordered according to their nuclear electricity
generation at the beginning of 2006, as reported by NEA. The last four
countries in the table currently do not have nuclear electricity
generation, but Italy did in the past, and the other countries have
nuclear research reactors. The United States would be the largest
nuclear electricity generator if listed.
[End of figure]
Domestic Experts Support Need to Evaluate Methods for Facilitating the
Removal of Higher-Activity LLRW from Waste Generator Sites:
The representatives from domestic LLRW stakeholder groups who responded
in interviews to this issue generally agreed that the United States
should consider exploring methods for promptly removing higher-activity
LLRW from waste generator sites. Eleven of 27 representatives supported
imposing time limits on storing higher-activity LLRW at non-utility
waste generator sites, but not for radioactive wastes that are allowed
to decay in storage within a reasonable amount of time. For example,
several representatives suggested that LLRW generators should be
treated the same as generators of hazardous waste. The generators of
large quantities of hazardous waste are required to remove waste from
their sites within 90 days, unless they receive authorization for long-
term storage of this waste. However, other representatives were not in
favor of establishing time limits for waste storage, for the most part
because of uncertainties surrounding disposal availability in the
United States. Some of the representatives noted that placing time
limits on the storage of higher-activity LLRW could only be justified
if it posed a safety and security risk. In this respect, almost all
representatives (25/26) suggested that having a requirement that
disused sealed radiological sources be returned to their source
supplier would be an effective way to promote more timely removal of
these sources from waste generator sites.
The NRC chaired task force reported that while existing measures to
ensure the safety and security of higher-activity sealed radiological
sources are adequate, the current disposal system is prompting some
users into long-term storage of their disused sources and otherwise
creating significant disincentives for properly disposing of these
sources. The report noted that the lack of a legal disposal pathway or
the high costs of disposal due to the lack of alternative disposal
options will perpetuate this situation until the disposal system
changes. The task force report suggested that the U.S. government
should encourage suppliers to provide arrangements for the return of
disused sources. The task force noted that holding a source in storage
longer than 24 months usually indicates the lack of a strategy to use
or dispose of the source. As a result, the task force suggested that
NRC consider a new requirement for licensees to review and document the
reasons for storing higher-activity sources for longer than 24 months.
Moreover, the task force suggested that once disposal options are
available for GTCC waste (equivalent to long-lived intermediate-level
waste), NRC should also consider requiring a maximum time limit on long-
term storage of disused sealed radiological sources that would be
considered GTCC waste when packaged for disposal.
Central Storage and Alternative Disposal Options Are Widely Used to
Facilitate Management of LLRW:
Ten of the 18 countries we surveyed have disposal options for lower-
activity LLRW and 6 have plans to build such facilities. While only 3
countries indicated that they have a disposal option for higher-
activity LLRW, 14 reported that they have central storage facilities
for this waste. Moreover, 13 countries indicated that they have
clearance or unrestricted removal of very low-level radioactive waste
from regulatory control as LLRW and eight countries indicated that they
have disposal options for this waste. The U.S. LLRW stakeholder group
representatives who responded to this issue were split on the need for
central storage options for higher-activity LLRW when a disposal option
is not available, but most of them supported exempting very low-level
radioactive waste from regulatory control as LLRW. The NRC chaired task
force and other reports have commented on the need to reexamine the
disposal options for LLRW.
About Half the Countries Make Disposal Options Available for Most Lower-
Activity LLRW:
About half of the countries in our survey indicated that they currently
have a disposal option for lower-activity LLRW, but few have a disposal
option for higher-activity LLRW. Ten of 18 countries indicated that
they have disposal options available for lower-activity LLRW, and 10
have reported plans to build new or additional disposal facilities for
lower-activity LLRW. While only 3 countries indicated that they
currently have a disposal option for higher-activity LLRW, 14 have
reported plans to develop a disposal facility for such waste.
Other countries have made a variety of organizations responsible for
providing and operating the existing or planned disposal facilities,
including national regulatory authorities, nuclear utility
organizations, and commercial waste management companies. In the 10
countries that have disposal facilities for lower-activity LLRW, only 2
indicated that a national organization is responsible for both
providing and operating this disposal facility. The other eight
countries indicated that these responsibilities were given to other
combinations that sometimes included nuclear utilities and commercial
waste management companies. In the 14 countries that are planning to
build disposal facilities for higher-activity LLRW, 6 indicated that a
national organization would be responsible for providing and operating
the future disposal facility and 3 indicated that it would be another
organization. The other countries indicated either a mix of
responsibilities or they did not respond to the question. For example,
the Netherlands has reported that it has decided to delay a final
decision on developing a disposal facility and instead construct an
engineered surface storage facility with sufficient capacity for all
radioactive waste generated in a period of at least 100 years. However,
if a disposal facility is ever constructed, this country indicated in
its survey that its nuclear regulatory authority would be responsible
for providing the facility and a national waste management organization
would be responsible for operating it. In regard to the cost of
disposal, half of the countries indicated that disposal fees are
currently or anticipated to be set nationally, based on waste type. Two
countries indicated that such fees are currently based on negotiations
with disposal operators according to waste type. Mexico indicated use
of both a national fee schedule and negotiated fees. Figure 5 provides
a summary of LLRW disposal availability and management responsibilities
across the countries in our survey.
Figure 5: LLRW Disposal Options and Management Responsibilities
LLRW management approach:
Disposal options are available for all LLRW:
France: No;
Japan: No;
Germany: No;
Canada: No;
United Kingdom: No;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No;
Switzerland: No;
Slovak Republic: No;
Hungary: No;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No;
Denmark: No;
Norway: No;
Total Yes Count: 0.
LLRW management approach:
Disposal options are available for short-lived low- and intermediate-
level radioactive waste:
France: Yes;
Japan: Yes;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: No;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: Yes;
Denmark: No;
Norway: Yes;
Total Yes Count: 10.
LLRW management approach:
There are plans to build a LLRW disposal facility for short-lived low-
and intermediate-level radioactive waste:
France: No;
Japan: No;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: Yes;
Slovak Republic: No;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: Yes;
Australia: Yes;
Denmark: Yes;
Norway: No;
Total Yes Count: 10.
LLRW management approach:
Disposal options are available for long-lived low-level radioactive
waste:
France: No;
Japan: No Response;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No Response;
Switzerland: No;
Slovak Republic: No;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No;
Denmark: No;
Norway: No;
Total Yes Count: 2.
LLRW management approach:
Disposal options are available for long-lived intermediate-level
radioactive waste:
France: No;
Japan: No Response;
Germany: No;
Canada: No;
United Kingdom: No;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No Response;
Switzerland: No;
Slovak Republic: No;
Hungary: No;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No Response;
Denmark: No;
Norway: Yes;
Total Yes Count: 1.
LLRW management approach:
There are plans to build a disposal facility for long-lived low- and
intermediate-level radioactive waste:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: Yes;
Australia: Yes;
Denmark: Yes;
Norway: No;
Total Yes Count: 14.
LLRW management approach:
A central organization (national nuclear regulatory authority or
national waste management organization) is responsible for providing a
waste disposal facility:
France: Yes;
Japan: No;
Germany: Yes;
Canada: No;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: No;
Slovak Republic: Yes;
Hungary: No;
Mexico: No;
Netherlands: Yes;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: Yes;
Total Yes Count: 8.
LLRW management approach:
A central organization (national nuclear regulatory authority or
national waste management organization) is responsible for operating a
waste disposal facility:
France: Yes;
Japan: No;
Germany: Yes;
Canada: Yes;
United Kingdom: No;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: Yes;
Slovak Republic: No;
Hungary: Yes;
Mexico: No;
Netherlands: Yes;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 8.
LLRW management approach:
A nuclear utility organization is responsible for providing a waste
disposal facility:
France: No Response;
Japan: Yes;
Germany: No;
Canada: Yes;
United Kingdom: No;
Sweden: No;
Spain: Yes;
Belgium: No;
Finland: No;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 6.
LLRW management approach:
A nuclear utility organization is responsible for operating a waste
disposal facility:
France: No;
Japan: No Response;
Germany: No;
Canada: Yes;
United Kingdom: No;
Sweden: Yes;
Spain: No;
Belgium: No;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: No;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: Yes;
Total Yes Count: 6.
LLRW management approach:
A commercial waste management company is responsible for operating a
waste disposal facility:
France: No;
Japan: Yes;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: Yes;
Spain: No Response;
Belgium: No;
Finland: No Response;
Switzerland: Yes;
Slovak Republic: No Response;
Hungary: No;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 4.
LLRW management approach:
Disposal fees are or planned to be determined by a national fee
schedule based on type of radioactive waste:
France: No;
Japan: No;
Germany: Yes;
Canada: Not Applicable;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: No;
Mexico: Yes;
Netherlands: Yes;
Italy: Not Applicable;
Australia: Not Applicable;
Denmark: Not Applicable;
Norway: Yes;
Total Yes Count: 9.
LLRW management approach:
Waste generators negotiate disposal fees based on type of radioactive
waste:
France: Yes;
Japan: Yes;
Germany: No;
Canada: No Response;
United Kingdom: No;
Sweden: No;
Spain: No Response;
Belgium: No;
Finland: No;
Switzerland: No;
Slovak Republic: No Response; Hungary: No;
Mexico: Yes;
Netherlands: No;
Italy: Not Applicable;
Australia: No Response;
Denmark: Not Applicable;
Norway: No;
Total Yes Count: 2.
Source: GAO survey of foreign countries, 2006, and reported information
on planned LLRW disposal facilities in IAEA and NEA country reports.
Note: Countries are ordered according to their nuclear electricity
generation at the beginning of 2006, as reported by NEA. The last four
countries in the table currently do not have nuclear electricity
generation, but Italy did in the past, and the other countries have
nuclear research reactors. The United States would be the largest
nuclear electricity generator if listed.
[End of figure]
Most Countries Have Central Storage for LLRW Lacking a Disposal Option:
Most countries we surveyed currently have interim or long-term central
storage options for some LLRW. Thirteen countries reported that they
have central storage options available for lower-activity LLRW. Six
countries reported that they have both disposal and some central
storage options for this waste. Fourteen countries reported that they
have central storage options for higher-activity LLRW, sometimes at
large waste production sites as in France. For the most part, these
countries do not have a disposal option for higher-activity LLRW,
although Norway indicated that it had disposal and interim storage
options for the long-lived, intermediate-level waste. Figure 6 provides
a summary of the central storage options available in the countries we
surveyed.
Figure 6: Central Storage Options for LLRW:
LLRW management approach:
Disposal options are available for short-lived low- and intermediate-
level waste:
France: Yes;
Japan: Yes;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: No;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: Yes;
Denmark: No;
Norway: Yes;
Total Yes Count: 10.
LLRW management approach:
Central storage options are available for short-lived low- and
intermediate-level waste:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: Yes;
Slovak Republic: No;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: No;
Australia: No;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 13.
LLRW management approach:
Disposal options are available for long-lived low-level waste:
France: No;
Japan: No Response;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No Response;
Switzerland: No;
Slovak Republic: No;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No;
Denmark: No;
Norway: No;
Total Yes Count: 2.
LLRW management approach:
Disposal options are available for long-lived intermediate-level waste:
France: No;
Japan: No Response;
Germany: No;
Canada: No;
United Kingdom: No;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No Response;
Switzerland: No;
Slovak Republic: No;
Hungary: No;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: No;
Denmark: No;
Norway: Yes;
Total Yes Count: 1.
LLRW management approach:
Central storage options are available for long-lived low-level waste
and long-lived intermediate-level waste:
France: Yes;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: No;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: No;
Mexico: Yes;
Netherlands: Yes;
Italy: No;
Australia: No;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 14.
Source: GAO survey of foreign countries, 2006, and reported information
on central storage options for LLRW in IAEA and NEA country reports.
Note: Countries are ordered according to their nuclear electricity
generation at the beginning of 2006, as reported by NEA. The last four
countries in the table currently do not have nuclear electricity
generation, but Italy did in the past, and the other countries have
nuclear research reactors. The United States would be the largest
nuclear electricity generator if listed.
[End of figure]
Most Countries Make Alternative Disposal Options Available for Very Low-
Level Radioactive Waste:
Most countries provide alternative disposal options for very low-level
radioactive waste either by removing such waste from regulatory control
as LLRW or providing special disposal arrangements. Almost all
countries (15/18) indicated that their nuclear regulatory authorities
exempt this waste from regulatory control as nuclear material, thus
allowing alternative disposal options for the waste. The countries use
various approaches to remove very low-level radioactive waste from
regulatory control as LLRW, including general exemption, case-by-case
exemption, and clearance. The most frequently cited approach used by
the countries was exemption (15/18), followed by clearance (13/18), and
then case-by-case exemption (11/18). For example, according to a May
2005 updated nuclear development report submitted by Japan to the NEA,
Japan followed IAEA guidance to amend its ’Law for the Regulations of
Nuclear Source Material, Nuclear Fuel Material and Rectors“ to
introduce a clearance system for materials, such as scrap metals and
concrete used in nuclear installations. Half the countries in our
survey indicated that they use all three management approaches.
Some countries in our survey indicated that they have alternative
disposal options for very low-level radioactive waste. These options
included disposal at municipal landfills, nuclear power plants, and in
special facilities for such waste. Eight countries indicated that they
have disposal options for very low-level radioactive waste. For
example, in Sweden, this radioactive material is cleared for
unrestricted use or disposal as conventional non-radioactive waste.
Sweden reported that, in 2004, approximately 660 tons of very low-level
radioactive waste was cleared for disposal at municipal landfills and
approximately 550 tons of melted scrap metal was cleared for recycling.
In contrast, France does not have a clearance threshold below which
radioactive waste is no longer considered a radioactive hazard.
Instead, France uses a case-by-case exemption process to allow for the
disposal of very low-level radioactive waste in a special repository
that was commissioned in 2003. The French government reported that this
facility represents another essential component of France‘s overall
system for radioactive waste management and that it will accommodate
most of the waste resulting from the decommissioning and dismantling of
facilities in which radioactive substances have been used. Figure 7
provides a summary of the disposal options and exemption methods used
by countries in our survey for managing very low-level radioactive
waste.
Figure 7: Disposal Options and Exemption Methods for Managing Very Low-
Level Radioactive Waste:
LLRW management approach:
Disposal options are available for very low-level radioactive waste:
France: Yes;
Japan: Yes;
Germany: No;
Canada: No;
United Kingdom: Yes;
Sweden: Yes;
Spain: No;
Belgium: No;
Finland: Yes;
Switzerland: No;
Slovak Republic: No;
Hungary: Yes;
Mexico: No;
Netherlands: No;
Italy: No;
Australia: Yes;
Denmark: No;
Norway: Yes;
Total Yes Count: 8.
LLRW management approach:
Exemption by the nuclear regulatory authority of a source or practice
that need not be subject to some or all aspects of regulatory control
on the basis that exposure is too small given the moderate quantities
of radioactive material:
France: No Response;
Japan: Yes;
Germany: Yes;
Canada: Yes;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: Yes;
Denmark: No Response;
Norway: No;
Total Yes Count: 15.
LLRW management approach:
Case-by-case exemption by the nuclear regulatory authority of large
quantities of radioactive material the still requires some regulatory
control:
France: Yes;
Japan: No;
Germany: Yes;
Canada: No;
United Kingdom: No;
Sweden: Yes;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: No;
Italy: Yes;
Australia: No Response;
Denmark: No Response;
Norway: Yes;
Total Yes Count: 11.
LLRW management approach:
Clearance or unrestricted removal of radioactive materials or
radioactive objects with authorized practices from any further
regulatory control by the nuclear regulatory authority:
France: No;
Japan: Yes;
Germany: Yes;
Canada: No;
United Kingdom: Yes;
Sweden: Yes;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: Yes;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: Yes;
Netherlands: Yes;
Italy: Yes;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 13.
Source: GAO survey of foreign countries, 2006.
Note: Countries are ordered according to their nuclear electricity
generation at the beginning of 2006, as reported by NEA. The last four
countries in the table currently do not have nuclear electricity
generation, but Italy did in the past, and the other countries have
nuclear research reactors. The United States would be the largest
nuclear electricity generator if listed.
[End of figure]
Domestic Experts Support Need to Examine Alternative Disposition
Options for Some LLRW:
The representatives of domestic LLRW stakeholder groups who responded
in interviews to this issue as well as findings reported by some groups
generally supported the need to evaluate alternative disposition
options for some LLRW. In regard to developing central storage options
for higher-activity LLRW when a disposal option is not available, the
representatives were split in their support. Those in favor (13/27)
noted that having a central storage option would encourage the
efficient and timely removal of higher-activity LLRW from waste
generator sites. For example, one representative commented that
facilities such as hospitals, academic institutions, and some
industries may have limited on-site storage space, restrictions placed
on waste storage time in their license, or possession limits for
radioactive material, which would need to account for the radioactivity
in the stored waste. Those opposed (14/27) to developing central
storage options for LLRW generally rejected this approach as an
unnecessary step prior to disposing of the waste”a step they also saw
as potentially increasing safety and security risks. For example, one
representative commented that developing central storage for LLRW that
does to have a disposal option would only detract from finding an
ultimate disposal solution.
The representatives from LLRW stakeholder groups were more supportive
of the need for NRC to adopt a clearance rule in lieu of the current
case-by-case exemption process for allowing very low-level radioactive
waste to be removed from regulation as LLRW. Most representatives
(19/25) who responded in interviews to this issue commented that a
clearance rule would promote more rapid removal of very low-level
radioactive waste from waste-generating sites or in some cases negate
the need for the on-site removal of this type of radioactive waste.
They also suggested that this action would expedite the cost-effective
disposal of this waste by reducing administrative burdens, lowering
disposal costs, and saving space in licensed LLRW disposal facilities
for higher-activity LLRW. For example, one representative commented
that knowing up front what type of radioactive waste would not require
nuclear regulatory authority review prior to disposition could reduce
the need to plan for storage space, shipment, and disposal of such
waste as LLRW. Another representative commented that a clearance rule
would provide a clear and consistent exemption for very low-level
radioactive waste across the Agreement States and non-Agreement States.
Several representatives supported the adoption of a clearance rule, but
cautioned that public resistance and other factors have impeded
previous NRC attempts to adopt this approach. Some representatives
contended that exempting very low-level radioactive waste from disposal
as LLRW might prompt LLRW disposal operators to increase the cost of
disposing of the other LLRW to compensate for the lost revenue from no
longer receiving large quantities of very low-level radioactive waste.
The NRC chaired task force report concluded that a number of challenges
are associated with disposing of all categories of commercial sealed
radiological sources because of the limited number of available
disposal facilities, the lack of options to dispose of all types of
radioactive waste, and the high cost of disposal. The task force found
that commercial LLRW disposal has evolved from an essentially free-
market system to a much more constrained and costly system today.
However, the task force did not identify any immediate security
concerns related to the higher-activity sources under review because
licensees are required to safely and securely store these sources, and
DOE has a program to recover sealed radiological sources that represent
a threat to public heath, safety, and security. Nevertheless, the task
force noted that because of uneven implementation of the LLRW Policy
Act, several issues affect the disposal of higher-activity sources,
such as the possible closure of the South Carolina LLRW disposal
facility to non-compact member states. The task force recommended that
the U.S. government evaluate the waste disposal options as outlined in
the 2004 and 2005 GAO reports addressing this issue. [Footnote 12]
The recent National Research Council report on Improving the Regulation
and Management of Low-Activity Radioactive Wastes also commented on
disposal options for low-activity waste (very low-level radioactive
waste). The report noted that the United States could benefit from
greater consideration of standards and practices developed
internationally to institute risk-based management of very low-level
radioactive waste. The report noted that European Commission and IAEA
standards already provide guidelines for wastes that pose insignificant
risks to be cleared or exempted from control as radioactive material.
The report recommended that the United States give greater
consideration to the international consensus standards surrounding
alternative disposition options for very low-level radioactive,
including disposal with other non-hazardous wastes, or disposal in
special facilities suitable for such waste. The report did not
conclude, however, that exemption or clearance should necessarily imply
the free release of this waste into general commerce.
Finally, NRC‘s Advisory Committee on Nuclear Waste similarly commented
on the need to examine alternative options for the disposition of some
LLRW. The committee‘s December 2005 white paper referred to previous
recommendations the committee made to NRC with respect to concerns
about the interim storage of LLRW at waste generator sites. The
committee found that no evidence exists that on-site storage of waste
can be safe and secure over the expected life of the waste and that the
proliferation of on-site storage at waste generator sites across the
country will only increase the probability of an adverse event. The
white paper also discusses past initiatives by NRC to examine
regulations governing future development of assured isolation
facilities (central storage facilities) for LLRW. The committee found
that only one Agreement State, Ohio, had such regulations as of the end
of 2005. The committee report noted that in January 2004, the
Commissioners directed NRC staff to defer action on the development of
an assured isolation rule, but to annually review the need for further
action in this area.
Financial Assurance Requirements and Other Approaches Are Used by Most
Countries to Reduce Government LLRW Recovery Costs:
Nine of the 18 countries we surveyed indicated that their nuclear
regulatory authorities require all non-utility LLRW generators to have
sufficient financial assurances to cover the removal of radioactive
waste from their sites. In addition, seven countries use other
financial assurance approaches to ensure that the government is
reimbursed for any sealed radiological sources that it may need to
recover from non-utility LLRW generators. More than half of the
representatives from U.S. LLRW stakeholder groups who responded to this
issue and statements in the recent report from the NRC chaired task
force indicated some need to improve the financial assurance structure
for some LLRW generators. The task force report suggested that NRC
evaluate some approaches that are similar to those used in some other
countries to ensure that radioactive material users have financial
reserves to cover waste disposition costs.
Half of the Countries Require All Non-Utility LLRW Generators to Meet
Financial Assurance Requirements:
Half of the countries we surveyed indicated that they require all non-
utility LLRW generators to set aside sufficient financial reserves to
cover waste disposition costs. These countries more often provide
disposal options for lower-activity LLRW and generally provide central
storage for higher-activity LLRW. In addition, three countries
indicated that they have plans to impose financial assurance
requirements on all non-utility LLRW generators. For example, Japan
indicated that it planned to develop these requirements, but could not
predict when they would be implemented.
Some Countries Use Other Financial Approaches to Reduce Government
Orphan Source Recovery Costs:
Some countries have taken approaches to reduce the potential government
costs of recovering orphan sealed radiological sources that are no
longer under regulatory control. The Council of the European Union
Directive 2003/122 states that all member countries must organize
campaigns to recover orphan sources left behind by past activities, and
suggests campaigns include financial participation by member countries
in the costs of recovering, managing, and disposing of these sources,
as well as in the review of records on the sealed radiological sources
being used at research institutes, material testing institutes, and
hospitals. This directive also requires that member countries ensure
establishment of a system of financial assurance requirements or other
equivalent means of reimbursing the government for its costs in
recovering orphan sources. As a means to reimburse the government for
orphan source recovery costs, 5 countries in our survey indicated that
users of sealed radiological sources have established common funds to
pay the LLRW disposition costs by source users. Moreover, 2 countries
indicated that sealed radiological source recovery funds have been
established by source suppliers to cover similar disposition costs for
these companies. For example, in France, the association of source
suppliers and manufacturers contribute to a common fund to reimburse
the government for recovering sealed radiological sources from any
supplier or manufacturer that is unable to disposition them. In cases
where the supplier cannot be identified, the government is reimbursed
by an insurance system implemented by the source manufacturers. In
addition, France indicated on its survey that under the new radiation
protection regulations consideration is being given to examining the
benefits of adding financial guarantees to this system. Nine countries
indicated that they either require a disposal fee at the time that a
source is purchased or are planning to impose such a fee to ensure that
funds are available to reimburse government for the costs of recovering
orphan sources. Figure 8 provides a summary of the financial approaches
used by the countries in our survey to reduce government costs of
recovering LLRW.
Figure 8: Financial Approaches to Reduce Government Costs to Recover
LLRW:
LLRW management approach:
Requirement that sufficient funds be set aside by non-nuclear power
plant entities to pay the cost of the central storage and/or disposal
of their LLRW:
France: No;
Japan: No;
Germany: No;
Canada: Yes;
United Kingdom: No Response;
Sweden: No;
Spain: Yes;
Belgium: Yes;
Finland: Yes;
Switzerland: No;
Slovak Republic: Yes;
Hungary: Yes;
Mexico: No;
Netherlands: Yes;
Italy: No;
Australia: No;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 9.
LLRW management approach:
Plan to implement a requirement that sufficient funds be set aside by
non-nuclear power plant entities to pay the cost of the central storage
and/or disposal of their LLRW:
France: No;
Japan: Yes;
Germany: No;
Canada: Not Applicable;
United Kingdom: No Response;
Sweden: No Response;
Spain: Not Applicable;
Belgium: Not Applicable;
Finland: Not Applicable;
Switzerland: No;
Slovak Republic: Not Applicable; Hungary: Not Applicable;
Mexico: Yes;
Netherlands: Not Applicable;
Italy: Yes;
Australia: No;
Denmark: Not Applicable;
Norway: Not Applicable;
Total Yes Count: 3.
LLRW management approach:
Orphan source recovery costs paid by a national organization:
France: Yes;
Japan: No;
Germany: Not Applicable;
Canada: Not Applicable;
United Kingdom: Yes;
Sweden: Not Applicable;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: Not Applicable;
Slovak Republic: Yes;
Hungary: Not Applicable;
Mexico: Yes;
Netherlands: Yes;
Italy: Not Applicable;
Australia: Not Applicable;
Denmark: Yes;
Norway: Yes;
Total Yes Count: 9.
LLRW management approach:
Orphan source recovery costs paid by disposition fund established by
source users:
France: No;
Japan: No;
Germany: No Response;
Canada: No Response;
United Kingdom: No Response;
Sweden: No;
Spain: No;
Belgium: Yes;
Finland: No Response;
Switzerland: No Response;
Slovak Republic: Yes;
Hungary: No;
Mexico: No;
Netherlands: Yes;
Italy: Yes;
Australia: No Response;
Denmark: No Response;
Norway: Yes;
Total Yes Count: 5.
LLRW management approach:
Orphan source recovery costs paid by disposition fund established by
source suppliers:
France: Yes;
Japan: No;
Germany: No Response;
Canada: No Response;
United Kingdom: No Response;
Sweden: No;
Spain: No;
Belgium: No;
Finland: No Response;
Switzerland: No Response;
Slovak Republic: No Response;
Hungary: Yes;
Mexico: No;
Netherlands: No Response;
Italy: No;
Australia: No Response;
Denmark: No Response;
Norway: No;
Total Yes Count: 2.
LLRW management approach:
Requirement that a disposal fee be assessed when a sealed radiological
source is purchased to pay the cost of future central storage and/or
disposal costs:
France: Yes;
Japan: No;
Germany: No;
Canada: No;
United Kingdom: No;
Sweden: Yes;
Spain: Yes;
Belgium: No;
Finland: Yes;
Switzerland: No;
Slovak Republic: Yes;
Hungary: No;
Mexico: No;
Netherlands: Yes;
Italy: No;
Australia: No;
Denmark: No Response;
Norway: No;
Total Yes Count: 6.
LLRW management approach:
Plan to establish a requirement that a disposal fee be assessed when a
sealed radiological source is purchased to pay the cost of future
central storage and/or disposal costs:
France: No Response;
Japan: No;
Germany: No;
Canada: No Response;
United Kingdom: No Response;
Sweden: Yes;
Spain: No Response;
Belgium: No;
Finland: No Response;
Switzerland: No;
Slovak Republic: No Response; Hungary: No;
Mexico: Yes;
Netherlands: No Response;
Italy: Yes;
Australia: No;
Denmark: No Response;
Norway: No;
Total Yes Count: 3.
Source: GAO survey of foreign countries, 2006.
Note: Countries are ordered according to their nuclear electricity
generation at the beginning of 2006, as reported by NEA. The last four
countries in the table currently do not have nuclear electricity
generation, but Italy did in the past, and the other countries have
nuclear research reactors. The United States would be the largest
nuclear electricity generator if listed.
[End of figure]
Domestic Experts Support the Need to Evaluate Financial Assurance
Approaches:
The potential usefulness of financial assurance approaches that were
identified through our survey was reflected in interviews with domestic
LLRW stakeholder group representatives. More than half of the
representatives (8/14) who responded to this issue in interviews
commented on the need to improve the financial assurance structure for
LLRW generators in the United States. These representatives suggested
approaches to improve financial assurances, such as new rulemaking by
NRC, periodic updating of the level of financial assurance requirements
for LLRW generators, and providing a mechanism for small businesses
that cannot self-guarantee financial assurance to otherwise provide
this assurance. In addition, some of the representatives (5/16)
supported the imposition of a disposal fee at the time of source
purchase to help promote a more cost-effective disposal system and more
predictable disposal costs for source users. For example, one
representative noted that imposing such a fee has merit, but obtaining
a commitment or obligation to pay the disposal fee would be an
important first step.
The NRC chaired task force found that sealed radiological source users
are moving disused sources into prolonged storage because they are not
required to have financial assurance to cover the disposal costs or
otherwise appropriately dispositioning their disused sources. The
report reiterated the concern that prolonged storage of disused sources
can lead to possible misuse, abandonment, loss, or theft. Further, the
task force found that the cost of source disposal can often be high,
prompting the holders of disused sources to delay disposal either by
choice or economic necessity. The task force identified three options
to improve financial assurance coverage that were in many ways similar
to approaches used to varying extents in other countries. The first
option is to broaden NRC financial assurance requirements to include
those entities that have lower thresholds of radioactive materials.
This option would ensure that adequate funds are set aside by these
entities to cover their waste disposition costs. However, the task
force found that this action alone would not cover government costs of
recovering orphan sources or sources for which there is no responsible
or financially capable party. Thus, two other options were proposed
that include (1) assessing a source-specific surcharge at the time of
source acquisition or throughout a source‘s service life to pay the
costs of disposal, and (2) assessing a universal disposal surcharge on
all licensees of radioactive material (not limited to sealed
radiological source holders) to cover waste disposition costs. The task
force recommended that NRC evaluate these alternative financial
assurance options and include the impacts on the regulated community,
implementation approaches, and the involvement of stakeholders.
National Radioactive Waste Management Plans Are Considered Important
for Managing LLRW:
We also found that 12 of the 18 countries surveyed rely on national
radioactive waste management plans to guide the management of their
radioactive wastes. Several of these plans required the management of
radioactive waste from a national perspective and specified one
administrative entity as responsible for coordinating their
development. In addition, there was often a requirement in the plans
for periodic public reporting of LLRW conditions. While the usefulness
of such a plan was not sought through a question in the survey or
specifically raised in interviews with U.S. LLRW stakeholder group
representatives, most of the representatives and recent reports on LLRW
management mentioned the need to evaluate alternative ways to manage
LLRW in the United States.
Many Countries Have Developed Radioactive Waste Management Plans That
Are National in Scope and Formulated by One Administrative Entity:
At least 12 of the 18 countries in our survey have national radioactive
waste management plans or draft plans to guide the management of this
material. The 12 countries included Belgium, Canada, France, Germany,
Italy, Japan, the Netherlands, Slovakia, Spain, Sweden, Switzerland,
and the United Kingdom. While the other countries may also have such
plans, we did not ask whether they had one in our survey. We identified
the 12 countries with management plans through a review of recent IAEA
and NEA country reports. The management plans from France, Germany, and
Spain contain strategies to address all radioactive waste types. They
are formulated by either a national level ministry or national waste
management organization, often through consultation with other
stakeholder groups. The management plans are approved by the
parliament, with in some cases requirements for periodic reporting of
waste management conditions back to the governing body.
France:
In 2003, the national nuclear regulatory authority of France formulated
a national plan for the management of radioactive waste and reusable
material. The development of this plan involved many stakeholders,
including the national waste management organization, waste producers,
elected representatives, and professional associations. According to
the 2006 Program Act on the Sustainable Management of Radioactive
Materials and Wastes, the national management plan will evaluate
existing management approaches for radioactive materials and waste,
identify foreseeable needs for storage or disposal facilities and the
time frame for storage as well as assess the management approaches for
radioactive wastes that do not yet have a path to disposal. The Program
Act also states that the national plan for managing radioactive
materials and wastes will be updated and reported to the parliament by
the nuclear regulatory authority every 3 years.
Germany:
According to a 2006 update report to NEA on the status of German
radioactive waste management, in late 2001 Germany amended its Atomic
Energy Act to request that the Federal Ministry for the Environment
prepare and submit a national waste management plan. At the same time
it amended this act, the parliament decided to phase out the use of
nuclear energy for commercial electricity generation. According to the
report, the draft plan, which is expected to be approved by parliament
in 2007, addresses the strategic management of all radioactive waste,
provides an inventory of existing radioactive waste, forecasts further
waste production, delineates waste management planning for the next few
years, and contains recommendations and required actions. The national
radioactive waste inventory, for the first time, captures all types of
radioactive waste, including high-level waste, waste from research,
medicine, and industry; decommissioning waste from nuclear power
plants; and uranium mine and mill tailing waste. Until a final disposal
site in a deep geologic formation is available for all radioactive
waste, the plan calls for the German federal states to construct and
operate regional interim storage facilities for all non-utility waste
generators, and requires nuclear power plants to provide interim on-
site waste storage.
Spain:
In 2006, Spain adopted its sixth general radioactive waste plan. This
plan replaces the previous plan enacted 7 years ago. As stated in the
plan, this document contemplates the strategies, the necessary actions,
and the technical solutions to be developed in the short-, medium-, and
long-term to ensure the adequate management of radioactive waste, the
dismantling and decommissioning of nuclear and radioactive facilities,
and related activities, including the economic and financial measures
required to carry them out. Further, this document states that this
plan is the basic reference document that clearly and concisely
addresses all the strategies and actions to be undertaken in Spain with
regard to the different fields of radioactive waste management and the
dismantling of facilities, along with a corresponding study of economic
and financial conditions. The plan, among other components, presents
the data related to radioactive waste generation, programs for removal,
the capacity of disposal facilities as well as costs and revenues.
Every 4 years or whenever requested by the cognizant ministry, the
national waste management organization develops a new radioactive waste
management plan, which is submitted to government and then reported to
the parliament. The national waste management organization, a state-
owned company established in 1984, has been given the responsibility
for radioactive waste management and decommissioning of nuclear
facilities. In addition to this action, the national waste management
organization must draw up an annual report describing the actions taken
during the previous financial year and any incremental revisions that
need to be made to the general radioactive waste plan.
Domestic Experts Support Need to Evaluate the U.S. LLRW Management
System:
There was general agreement among the representatives from the LLRW
stakeholder groups that the management of LLRW in the United States
needs improvement. Most of the representatives who responded to
questions associated with this issue (22/29) suggested that the time is
right to explore alternative approaches to make the LLRW disposal
system more predictable (reliable) and stable (cost-effective). Many of
the representatives cited the proposed closure of the South Carolina
disposal facility to non-compact waste generators as the reason to
explore these alternatives approaches. However, one representative
cautioned that while the present disposal system in the United States
is not what was envisioned in the LLRW Policy Act, it is an alternative
that has generally provided disposal availability to most waste
generators. As we did not directly ask the representatives about the
need for a national radioactive waste management plan at the time of
the interviews, we have no basis to tabulate their reaction to this
specific LLRW management approach.
The National Research Council of the National Academies recently
reported on improving the regulation and management of low-activity
waste in the context of the U.S. LLRW management system. The report
recommended that regulatory agencies develop integrated strategies to
implement risk-informed regulation for very low-level radioactive
waste. According to the report, such a strategy would require continued
integration and coordination among the regulatory agencies, including
NRC, DOE, the Environmental Protection Agency, Department of Defense,
and other federal and state agencies. Moreover, the report recommended
that government agencies continue to explore ways to improve their
efforts to gather knowledge and opinions of stakeholders, particularly
public stakeholders. While the report did not go so far as to recommend
the establishment of a national radioactive waste management plan, it
did find that the current patchwork of regulations is complex and
inconsistent”leading in some instances to inefficient management
practices and possibly to increased overall risk in the system.
Finally, in May 2006, the NRC Advisory Committee on Nuclear Waste
agreed to examine issues surrounding the shortcomings in the national
LLRW management system. The committee solicited industry and
stakeholder views regarding the future role of NRC in the area of
commercial LLRW management, noting that NRC staff is updating its LLRW
strategic plan following NRC-directed program reductions. In an August
2006 letter to the NRC Commissioners, the committee recommended that an
examination be undertaken of how NRC and the Agreement States are
preparing to regulate potential increases in the storage of class B and
C waste if and when the LLRW disposal facility in South Carolina closes
to waste generators in non-compact states and no alternative options
become available. While the committee did not call for developing a
national radioactive waste management plan, it seemed to suggest the
need for contingency planning in the context of a strategic approach to
NRC‘s involvement in LLRW management.
Conclusions:
The 18 countries surveyed rely on a wide variety of approaches to
manage their LLRW. However, the extent to which each country uses these
LLRW management approaches varied across the surveyed countries. Based
on previous GAO reports, other pertinent reports, and responses to
GAO‘s survey, it appears that the United States relies on these
approaches to a lesser degree or not at all. In some cases, NRC has
already evaluated the merits of implementing some of these approaches
and rejected them or is in the process of evaluating the usefulness of
a few other approaches. Comments from representatives of U.S. LLRW
stakeholders groups as well as statements and recommendations in recent
reports related to LLRW management indicate that the application of
approaches similar to those used in other countries may improve the
management of U.S. radioactive waste. The management approaches
identified in this report include methods to improve the:
1. Comprehensiveness and usefulness of national radioactive waste
inventory databases:
* inventory all types of radioactive waste by volume, location and
generator type;
* inventory the possession and status of use of sealed radiological
sources in more than category 1 and 2;
* designate a national authority to manage the radioactive waste
inventory databases;
* take steps to verify the completeness and accuracy of these
databases;
* require waste generators to submit waste inventory information to the
national authority at least once a year; and;
* use the radioactive waste inventory databases to forecast future
waste volumes, and to inform the public on volumes of waste at central
storage and disposal facilities.
2. Prompt removal of higher-activity LLRW, primarily disused sealed
radiological sources from waste generator sites:
* establish on-site storage time limits for non-utility waste
generators, at least when disposal options are available; and;
* implement other methods to facilitate the removal disused sealed
radiological sources, such as requiring time limits on the use of
sources, return of disused sources to a supplier, and users to notify
the nuclear regulatory authority when the source becomes disused.
3. Disposition options for all LLRW:
* provide disposal options for all LLRW or central storage options for
higher-activity LLRW produced by non-utility waste generators if a
disposal option is not available; and;
* provide alternative disposal options for very low-level radioactive
waste by either removing this waste from review by the nuclear
regulatory authority as LLRW, or providing special disposal options for
this waste.
4. Financial assurance requirements on all waste generators to reduce
government disposition costs:
* require that all non-utility LLRW generators have sufficient
financial reserves to disposition their radioactive waste; and;
* implement methods to ensure that funds are available to reimburse
government for any costs to recover and disposition radioactive
materials, including requiring the establishment of insurance funds for
entities that receive disused sources back from their users, and a
disposal fee upon purchase of any sealed radiological sources.
In addition to the survey results, we also identified another
management approach used in most countries”national radioactive waste
management plans”that also might provide lessons for managing U.S.
radioactive waste. IAEA guidance supports the development of a national
strategy to define the infrastructure and the means to be adopted for
the management of radioactive waste. Currently, the United States does
not have a national radioactive waste management plan and does not have
a single federal agency or other organization responsible for
coordinating LLRW stakeholder groups to develop such a plan. Such a
plan for the United State could integrate the various radioactive waste
management programs that reside at the federal and state levels into a
single source document. A national plan could assist those interested
in radioactive waste management to identify waste quantities and
locations, plan for future storage and disposal development, uncover
research and development opportunities, and assess the need for
regulatory or legislative actions. For example, there are no national
contingency plan, other than allowing LLRW storage at waste generator
sites, to address the impending closure of a key LLRW disposal
facility. The availability of a national plan and periodic reporting on
waste conditions might also provide the Congress and the public with a
more accessible means to monitor the management of radioactive waste
and provide a mechanism to build greater public trust in the management
of these wastes in the United States.
Recommendations:
In order to improve the management of LLRW in the United States and
address a potential shortfall of disposal availability for higher-
activity LLRW in 2008 and other management concerns, we recommend that
the Chairman of NRC and the Secretary of Energy evaluate and report
back to the Congress within 1 year on the usefulness to the United
States of:
* Adopting the LLRW management approaches used in the countries
discussed in this report, and the steps and any authorities necessary
for their implementation, if deemed appropriate.
* Developing a U.S. radioactive waste management plan, and the
potential costs, steps, and any authorities necessary to develop such a
plan, if deemed appropriate.
Agency Comments and Our Evaluation:
We provided a draft of our report to NRC, DOE, and the State Department
for their review and comment. The State Department did not comment on
the draft report. NRC and DOE generally agreed with the recommendations
in our draft report, but raised a number of issues regarding their
implementation. Specifically, they suggested other means through which
they could report the results of their evaluations to Congress and they
questioned the benefits of developing a national radioactive waste
management plan. While we recognize the long-standing experience and
international leadership of NRC and DOE in the field of radioactive
materials, the intent of our report is to discuss the approaches used
in other countries. Based on our findings, we are recommending that NRC
and DOE collaborate in reviewing, and in some cases perhaps
reconsidering, the management approaches identified on pages 36-37 of
this report for their potential usefulness in the United States. We
believe the Congress would benefit from a collaborative evaluation or
reevaluation of these approaches to ensure that the best management
approaches are used in the United States.
NRC stated that it has already evaluated many of the LLRW management
approaches and is in the process of evaluating some others as part of a
strategic assessment of its LLRW program to ensure that NRC‘s
regulatory framework will continue to ensure the safe management of
LLRW. Further, NRC stated that it prefers to evaluate LLRW management
approaches through ongoing efforts and to report on these evaluations
in its annual letter to the Congress that addresses progress in
completing actions in response to recommendations in multiple GAO
reports. NRC also raised some concerns about our recommendation to
evaluate and report on the development of a national radioactive waste
management plan in specific comments accompanying its letter. While NRC
did not disagree with this recommendation, it pointed out that the
costs to develop a U.S. radioactive waste management plan would be
significant and the benefits unclear, particularly given the complex
composition of the current U.S. system. NRC noted that legislative
changes would likely be needed before the development of a plan could
substantially improve the U.S. system.
DOE stated that it regards the report as a useful comparison of U.S.
LLRW programs with comparable international programs. DOE accepted the
recommendation to evaluate the international approaches summarized in
our report, but did not agree that a report to the Congress is
necessary at this time. DOE offered to brief the Congress on the status
of its radioactive waste management efforts if asked to do so.
Regarding the development of a national radioactive waste management
plan, DOE stated that a single document synthesizing the activities of
numerous agencies and entities involved in radioactive waste management
would facilitate understanding of these complex programs. However, DOE
commented that it is concerned that development of such a document
would provide limited utility to the actual implementation of these
strategies yet would require diversion of significant resources from
actual waste management efforts. Moreover, DOE suggested that the U.S.
Second National Report for the Joint Convention on the Safety of Spent
Fuel Management and on the Safety of Radioactive Waste Management
provides a summary of the existing national waste management
strategies, issues, and progress.
We recognized in our report that NRC has evaluated some of the LLRW
management approaches in the past and is currently evaluating some
others. We also found that many of the U.S. LLRW stakeholder
representatives that we interviewed and some recent U.S. LLRW
management reports generally supported the reevaluation, if not use of
many of the management approaches identified in our report. We believe
that the Congress would benefit from a consolidated report that
contains the evaluations of these LLRW management approaches as they
apply to the U.S. situation. In regard to reporting, we do not take
issue with how the agencies might collaborate together and with other
LLRW stakeholder groups on reporting back to the Congress on these
management approaches as long as the evaluations are comprehensive.
We acknowledge the concerns of NRC and DOE regarding our draft
recommendation to evaluate and report on the development of a national
radioactive waste management plan. We have revised this recommendation
to clarify that the agencies need to evaluate and report on the
usefulness of such a plan and conduct further analysis if deemed
appropriate. We still conclude that the use of a national radioactive
waste management plan in most other countries in our survey and our own
assessment of its potential benefits, as reflected on pages 37-38 of
this report, indicates to us that there is value in further evaluating
this management approach. In addition, in our view, the U.S. national
report to the Joint Convention provides useful information on
radioactive waste management, but the waste inventory information in
this report is not comprehensive and the document does not contain
strategies to guide the management of radioactive waste. The letters
from NRC and DOE, along with our responses to their specific comments
are contained in appendix VI and VII, respectively.
We will send copies of this report to the appropriate congressional
committees as well as to the Chairman of NRC and the Secretary of
Energy. We will make copies available to others upon request. In
addition, the report will be available at no charge on the GAO Web site
at [hyperlink, http://www.gao.gov].
If you or your staff has any questions about this report, please
contact me at (202) 512-3841 or at aloisee@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff members that made
contributions to this report are listed in appendix VIII.
Signed by:
Gene Aloise:
Director, Natural Resources and Environment:
[End of section]
Appendix I: Recent GAO Findings and Agency Actions on LLRW Management:
GAO reports have addressed various aspects of low-level radioactive
waste (LLRW) management in the United States. [Footnote 13] We reported
in 2004 on the scope and reliability of national LLRW inventory
information and found that the Department of Energy (DOE)‘s commercial
LLRW disposal database did not contain data on all disposed LLRW, did
not capture information on LLRW that is produced and stored at waste
generator sites, and had data inaccuracies. We recommended that DOE
take steps to correct internal control weaknesses and shortcomings in
the usefulness and reliability of this database, which DOE claims it
has for the most part accomplished. More recently, we reviewed the U.S.
report to the Joint Convention on the Safety of Spent Fuel Management
and on the Safety of Radioactive Waste Management, which commits the
United States to, among other things, report on its national inventory
of radioactive waste, but does not prescribe how this should be done or
the level of reporting detail regarding the location and quantities of
LLRW. The U.S. report includes the location and quantities of DOE‘s
radioactive waste in storage and disposal as well as the commercially-
generated LLRW that has been disposed of, but less comprehensive
coverage of the location and quantities of non-DOE LLRW in storage
around the country. The response of the United States to the GAO survey
highlighted some gaps in the U.S. radioactive waste inventory. The
United States is also committed through its signing of the Joint
Convention to take steps to ensure the safe possession, remanufacture,
or disposal of disused sealed radiological sources. One step in this
direction is the establishment of a national radioactive source
registry in support of the IAEA Code of Conduct for the Safety and
Security of Radioactive Sources. We recommended in our 2005 report that
the Nuclear Regulatory Commission (NRC) and DOE, in collaboration with
the Radiation Source Protection and Security Task Force, evaluate and
report on how its source registry (National Source Tracking System)
could be designed and implemented to improve DOE‘s ability to identify
and track sources that may need DOE recovery and disposal. [Footnote
14] We found that 98.5 percent of the disused sealed radiological
sources that DOE had recovered as of June 2005 would not have been
included in the National Source Tracking System. NRC‘s final rule on
this source tracking system stipulates the tracking of only category 1
and 2 sources, although NRC indicated that additional sources could be
added through subsequent rulemaking. [Footnote 15] NRC has no plans to
monitor the status of sealed radiological source use in this tracking
system. However, according to NRC officials, the online version of the
tracking system will allow licensees to voluntarily provide information
on whether a source has been put in storage and will no longer be used.
Appendix IV contains an assessment of what is known about the volume
and location of LLRW in the United States.
In regard to the safety and security of stored class B, C, and GTCC
waste, we reported in 2004 about the possible increase in the storage
of this higher-activity LLRW at generator sites because, among other
reasons, generators may decide to store their waste on-site because of
high disposal costs. While NRC does not place time limits on the
storage of LLRW, NRC claims that its licensing and inspection programs
for waste generators provide assurance that stored LLRW will remain
safe and secure. Moreover, NRC contends that with the exception of
disused sealed radiological sources, LLRW does not present an
attractive target for adversaries. In regard to the safety and security
of sealed radiological sources, NRC reported that it has conducted
vulnerability assessments, imposed new security measures on those
licensees that possess category 1 and 2 sources, and it is reviewing
the adequacy of its guidance for long-term LLRW storage as well as
possible updates to this guidance. NRC officials informed us that the
new security measures also apply to licensees who possess aggregations
of category 3 or lesser-activity source categories that would meet or
exceed the category 2 radioactivity threshold. In addition, they told
us that NRC requires the timely removal of radioactive material as part
of the decommissioning process. Nevertheless, the response of the
United States to the GAO survey indicated that NRC does not enforce the
removal of disused sealed radiological sources from licensees that
generate this waste or require them to return their disused sources to
the source supplier. As we reported in 2005, NRC works with DOE to
identify disused sealed radiological sources at user sites that should
be recovered because they pose a safety and security risk. The
Conference on Radiation Control Program Directors also provides a
clearinghouse service for users to disposition their disused sources.
We noted, however, that the lack of information to track the number and
status of sealed radiological sources that may require recovery and
disposal in the future limits DOE‘s ability to effectively plan and
budget for its recovery and disposal efforts and to monitor the
performance of its source recovery program.
We also reported on LLRW disposal options in the United States, which
are affected by federal and state nuclear regulatory authorities,
commercial LLRW disposal operators, and LLRW compact commissions. We
found in our 2004 report that there appears to be sufficient disposal
capacity for class A, B, C waste, but uncertain future access to a
disposal facility for class B and C waste. In our 2005 report, we found
that there was some central storage for GTCC waste, essentially for
disused sealed radiological sources recovered by DOE, but no disposal
availability. These reports and others have commented on the many
factors affecting the predictability of disposal availability and
disposal costs. For example, NRC and the Agreement State regulators are
involved in granting the approval of LLRW disposal facilities and the
classes of waste that can be accepted. They also have discretion, on a
case-by-case basis, to exempt very low-level radioactive waste from
regulation as LLRW, thus providing waste generators with more disposal
options for this waste. [Footnote 16] According to NRC officials,
approvals for waste generators in states under its jurisdiction have
been granted for small quantities of waste”averaging about 2 per year
over the past 6 years”however, no comparable information is available
on the 34 Agreement States. NRC officials also told us that the agency
has attempted to improve the transparency of this process for a number
of stated reasons, including the anticipation that there will be large
amounts of this waste from nuclear power plant decommissioning. NRC has
evaluated and decided to defer action on a rule that would exempt very
low-level radioactive waste from having to go through regulatory review
as LLRW. The LLRW compact commissions can also affect the
predictability of the disposal system because they have discretion to
restrict access to disposal facilities as well as to charge variable
disposal fees based not only on waste type but the type of generator.
Likewise, commercial disposal facility operators can affect the
predictability of the disposal system. For example, the operator of the
disposal facility that accepts almost all of the class A waste charges
variable disposal fees based on the generator of the waste. Waste
generators, such as DOE and nuclear power plants, which dispose of
large volumes of class A waste, can negotiate lower disposal fees per
volume of waste than generators that dispose of much smaller quantities
of this waste. Appendix V contains a discussion of the type of waste
and waste generators that would be affected by reduced access to the
South Carolina disposal facility. For example, of the 671 waste
generators that sent disused sealed radiological sources to the South
Carolina disposal facility between 2001 and 2005, only 70 would be
allowed to do so after mid-2008.
In our 2005 report we commented on the limitations on DOE‘s ability to
recoup its costs for recovering disused sealed radiological sources
from non-utility waste generators. The response of the United States to
the GAO survey indicated that not all non-utility waste generators,
particularly those possessing sealed radiological sources, are
currently required to ensure that funds are available to cover future
LLRW disposition costs. NRC officials told us that they are revising
the financial assurance regulations aimed at addressing sites that
permanently cease radiological operations without adequate funds to
complete decommissioning. The revised regulations are intended to
address problems with funding large, complex sites that may include
extensive soil and groundwater contamination. The disposal of disused
sealed radiological sources is not part of this rulemaking. For non-
Agreement States, NRC officials indicated that about 5 to 10 small
businesses possessing sealed radiological sources go bankrupt each
year. However, NRC officials informed us that they have no information
on the annual number of bankruptcies in the 34 Agreement States. In
cases where waste generators do not have the funds to cover the cost of
removing, centrally storing, or disposing of their higher-activity
disused sealed radiological sources, the U.S. government has covered
these costs. One of NRC‘s performance goals is to reduce the potential
for unnecessary federal government funding to clean up sites if
licensees go bankrupt and have insufficient financial reserve to cover
these costs. According to NRC officials, the potential expansion of the
financial assurance requirements for its licensees will ensure that
they can meet their responsibilities to cover the cost to disposition a
broad range of radioactive materials, including sealed radiological
sources. NRC officials note that this initiative may also help reduce
the cost of DOE‘s program to recover disused sealed radiological
sources. Nevertheless, DOE officials told us that the department has no
basis to charge waste generators to recover and store disused sealed
radiological sources that would generally constitute GTCC waste when
disposed of because there is presently no disposal option for this
waste and thus no basis to determine a service fee schedule. In our
2005 report, we recommended that NRC and DOE evaluate mechanisms to
reduce government costs of recovering, storing and disposing of higher-
activity LLRW. The response of the United States to the GAO survey
indicated that NRC does not require a disposal fee at the time of
purchase or require that source users and suppliers contribute to a
recovery fund.
Finally, in reviewing the U.S. report to the Joint Convention on the
Safety of Spent Fuel Management and on the Safety of Radioactive Waste
Management, prepared by DOE in cooperation with other federal agencies,
we noted that while the report describes existing national policies and
practices for managing radioactive waste, it does not constitute a
national radioactive waste management plan. However, the Joint
Convention does not mention the need for such a plan and there is no
requirement in U.S. legislation for a federal agency to prepare a plan.
While the LLRW Policy Act required DOE to report to the Congress
annually on national LLRW conditions, the provision, which terminated
effective May 2000, it did not require a national radioactive waste
management plan. DOE officials have, however, provided us with a draft
copy of the department‘s strategy to optimize the disposition of DOE
low-level and mixed low-level radioactive waste. Similarly, NRC
officials told us that their responsibilities to oversee the use,
storage and disposal of radioactive materials do not include
development of a national radioactive waste management plan. However,
NRC officials informed us that in light of new challenges, influences,
and issues facing LLRW management today, they are currently conducting
a strategic assessment that will identify and prioritize staff
activities to ensure a stable, reliable, and adaptable regulatory
framework for effective LLRW management.
[End of section]
Appendix II: Scope and Methodology:
In our review, we examined the extent to which foreign countries have
(1) comprehensive national LLRW inventory databases, (2) timely removal
of higher-activity LLRW in storage at waste generator sites, (3)
disposition options for all LLRW, and (4) requirements to assure that
LLRW generators have adequate financial reserves to cover all waste
disposition costs. We also examined another management area that
surfaced during our review pertaining to the use of national
radioactive waste management plans. Our examination primarily relied on
a survey of radioactive waste management officials in countries, along
with the United States that account for 85 percent of the world‘s
installed nuclear power plant capacity. To better understand the
context of managing LLRW in other countries, we also spoke with
radioactive waste management officials and visited disposal facilities
in France, Japan, and Sweden. To describe the status of LLRW management
in the United States, we obtained responses from NRC to the same
questionnaire sent to other countries, interviewed NRC and DOE
officials as well as representatives from a wide range of domestic LLRW
stakeholder groups, and reviewed past GAO reports and other pertinent
documents.
Specifically, we developed, pretested, and sent out questionnaires to
20 countries to identify foreign experiences in managing LLRW. The
countries included Australia, Belgium, Canada, Czech Republic, Denmark,
Finland, France, Germany, Hungary, Italy, Japan, Mexico, the
Netherlands, Norway, Slovak Republic, South Korea, Spain, Sweden,
Switzerland, and United Kingdom. These countries, along with the United
States, are represented on the NEA Radioactive Waste Management
Committee. [Footnote 17] The questionnaire contained 32 questions and
potential answers that were distributed across the four areas of LLRW
management under review. Respondents were also given an opportunity to
specify other responses not listed and to provide additional comments
on most of the questions. Appendix II provides the questionnaire and
the responses from the United States. To increase the potential
response rate to the survey, we attended a March 2006 meeting of the
NEA Radioactive Waste Management Committee in Paris, France, to discuss
our interests in surveying the representatives of foreign countries who
attended the meeting. While at this meeting, we also reviewed a draft
questionnaire with representatives from the NEA and IAEA. We further
reviewed the draft questionnaire with radioactive waste management
officials that we met with in France and Sweden. Several e-mail
messages were sent to all 20 countries prior to administering the
survey in order to confirm the appropriate country official to receive
the questionnaire and to encourage each of them to participate in the
survey. All but two countries, the Czech Republic and South Korea,
responded to our survey (a 90-percent survey response rate). For the
most part, we accepted the responses provided by each country; however,
in a few cases we contacted country officials to clarify their
responses to some questions, and we took other steps to ensure more
complete responses to all questions. We then tabulated frequencies for
each question across the countries.
We made site visits to France, Japan, and Sweden to speak directly with
representatives from the nuclear regulatory authority, waste management
organization, and waste generators about LLRW management in their
country. These countries were selected because they are large
generators of radioactive waste and they represent both European Union
and non-European Union member countries on the NEA Radioactive Waste
Management Committee. We sent out questions in advance of our meetings
with these representatives and we used our time with them to obtain a
better understanding of why different management approaches were taken
and the experiences of stakeholder groups with them.
We identified and examined foreign country and international documents
addressing the management of radioactive waste to supplement the
information we obtained from our survey. These documents included
radioactive waste management reports that countries are required to
submit to IAEA under international agreements, national radioactive
waste management reports and updates prepared for the NEA Radioactive
Waste Management Committee, and information that we obtained during our
visits to the three countries. For example, we used these documents to
describe the extent to which countries use central storage facilities
for LLRW, formulate radioactive waste management plans, and apply
specific management approaches. In some instances, we used these
documents to check the responses provided by countries on their
questionnaire.
We interviewed NRC and DOE officials and representatives from a diverse
group of domestic LLRW stakeholders to describe the current LLRW
management situation in the United States and to identify approaches
that might be applied to improve the management of LLRW corresponding
to our four research objectives. The interviewees represented nuclear
regulators at the federal and state levels; LLRW disposal operators;
advisory groups including the Conference on Radiation Control Program
Directors, Department of Defense‘s Low-Level Radioactive Waste
Executive Agent, National Research Council of the National Academies,
and NRC Advisory Committee on Nuclear Waste; pertinent associations,
including the Council on Radionuclides and Radiopharmaceuticals, the
Health Physics Society, the Low-Level Radioactive Waste Forum, and the
Nuclear Energy Institute; and private consultancies. The Health Physics
Society is a scientific and professional organization whose 6,000
members specialize in occupational and environmental radiation safety,
and the Nuclear Energy Institute represents all nuclear power plant
operators. We conducted a content analysis of 33 domestic interviews;
coding responses as either agreeing, not agreeing, or not responding to
a common set of questions addressed in each interview (respondents are
shown in table 2). These responses were then quantified for statistical
analysis. In addition to interviews based on a standard list of
questions, in the course of our review we also conducted informational
interviews with the Energy Policy Research Institute, Army Corps of
Engineers, Exelon Nuclear, and program officials at DOE. Moreover, we
reviewed several pertinent reports, including a report of the NRC
chaired Radioactive Source Protection and Security Task Force, a report
from National Research Council, and a report of the NRC Advisory
Committee on Nuclear Waste. [Footnote 18] The formation of the
interagency NRC chaired task force and periodic reporting requirements
were mandated in the Energy Policy Act of 2005.
Finally, we examined LLRW inventory data from several sources to
estimate the volumes, types, locations, and generators of LLRW in the
United States and what is now received at the LLRW disposal facility in
South Carolina from non-compact member states. For the most part, we
relied on data from DOE‘s Manifest Information Management System and
from the U.S. report to the Joint Convention on the Safety of Spent
Fuel Management and on the Safety of Radioactive Waste Management. We
determined that these data were sufficiently reliable for the purposes
of this report. Our assessment of what is known about the location and
volume of LLRW in the United States is covered in appendix III. The
status of class B and C waste disposal in the United States, as well as
the impact of closing the South Carolina disposal facility to non-
compact member states, slated for 2008, is contained in appendix V.
We conducted our review between September 2005 and February 2007 in
accordance with generally accepted government auditing standards.
Table 2: Listing of Domestic LLRW Stakeholder Group Respondents:
Number: 1;
Domestic LLRW Stakeholder Group Respondent: Nuclear Regulatory
Commission.
Number: 2;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-Alabama.
Number: 3;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-Arkansas.
Number: 4;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-Louisiana.
Number: 5;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-New York.
Number: 6;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-North Carolina.
Number: 7;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-Texas.
Number: 8;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-Washington.
Number: 9;
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement
State-Wisconsin.
Number: 10;
Domestic LLRW Stakeholder Group Respondent: State of South Carolina,
Bureau of Land and Waste Management.
Number: 11;
Domestic LLRW Stakeholder Group Respondent: State of South Carolina,
Bureau of Radiological Health.
Number: 12;
Domestic LLRW Stakeholder Group Respondent: State of South Carolina,
South Carolina Energy Office.
Number: 13;
Domestic LLRW Stakeholder Group Respondent: State of Texas, Department
of State Health Services.
Number: 14;
Domestic LLRW Stakeholder Group Respondent: State of Utah, Division of
Radiation Control.
Number: 15;
Domestic LLRW Stakeholder Group Respondent: American Ecology.
Number: 16;
Domestic LLRW Stakeholder Group Respondent: Duratek (now Energy
Solutions).
Number: 17;
Domestic LLRW Stakeholder Group Respondent: Envirocare (now Energy
Solutions).
Number: 18;
Domestic LLRW Stakeholder Group Respondent: Waste Control Specialists.
Number: 19;
Domestic LLRW Stakeholder Group Respondent: Conference of Radiation
Control Program Directors.
Number: 20;
Domestic LLRW Stakeholder Group Respondent: Department of Defense‘s Low-
Level Radioactive Waste Executive Agent.
Number: 21;
Domestic LLRW Stakeholder Group Respondent: National Research Council
of the National Academies.
Number: 22;
Domestic LLRW Stakeholder Group Respondent: NRC Advisory Committee on
Nuclear Waste.
Number: 23;
Domestic LLRW Stakeholder Group Respondent: Council on Radionuclides
and Radiopharmaceuticals.
Number: 24;
Domestic LLRW Stakeholder Group Respondent: Health Physics Society.
Number: 25;
Domestic LLRW Stakeholder Group Respondent: Low-Level Radioactive Waste
Forum-Director.
Number: 26;
Domestic LLRW Stakeholder Group Respondent: Michigan Low-Level
Radioactive Waste Authority.
Number: 27;
Domestic LLRW Stakeholder Group Respondent: Midwest Low-Level
Radioactive Waste Compact Commission.
Number: 28;
Domestic LLRW Stakeholder Group Respondent: Northwest Low-Level
Radioactive Waste Compact Commission.
Number: 29;
Domestic LLRW Stakeholder Group Respondent: Southeast Low-Level
Radioactive Waste Compact Commission.
Number: 30;
Domestic LLRW Stakeholder Group Respondent: Southwest Low-Level
Radioactive Waste Compact Commission.
Number: 31;
Domestic LLRW Stakeholder Group Respondent:
Number: 32;
Domestic LLRW Stakeholder Group Respondent:
Number: 33;
Domestic LLRW Stakeholder Group Respondent:
[End of table]
[End of section]
Appendix III: Survey of LLRW Management Approaches: Response from
United States:
United States Government Accountability Office:
Foreign Experiences in Managing Low- and Intermediate-Level Radioactive
Waste:
Background:
The U.S. Government Accountability Office (GAO) is a professional,
nonpartisan legislative branch agency that supports the Congress by
reviewing the performance of federal agencies, assessing federal
policies and programs, analyzing the financing of government
activities, and anticipating emerging issues. One such issue is the
management of low- and intermediate-level radioactive waste.
While the United States embarks on new nuclear power development, it
also confronts the need to dismantle and dispose of older reactors.
Both activities will result in increased generation of low-and
intermediate-level radioactive waste. The current lack of a reliable
and cost-effective radioactive waste disposal system in the United
States may prompt the need to revise federal legislation and the
policies of the nuclear regulatory authorities. The Congress is
particularly interested in identifying approaches to improve the
management of these wastes, particularly in four key areas. GAO has
been asked to determine the extent to which the United States and other
countries have established: (1) national waste inventory and source
tracking systems; (2) requirements for the timely removal of waste from
user sites; (3) reliable and cost-effective waste disposal options; and
(4) funding mechanisms to ensure that users can cover waste storage and
disposal costs.
In order to obtain information about management approaches used in
other countries, GAO is seeking the cooperation of countries
represented on the OECD Nuclear Energy Agency Radioactive Waste
Management Committee. These countries generate relative large volumes
of low- and intermediate-level radioactive waste. We have worked with
representatives of the Nuclear Energy Agency, International Atomic
Energy Agency, and the U.S. Nuclear Regulatory Commission to prepare a
questionnaire that will collect information useful to all countries.
While these organizations support the GAO survey, they are not sponsors
or in other ways associated with the results of this survey.
Directions for Completing the Questionnaire:
Most of the 32 questions in this survey can be answered easily by
checking boxes or filling in blanks, which are highlighted in yellow.
Unless otherwise noted, please mark only one response for each
question.
You will notice that many questions are followed by boxes that allow
you to provide additional comments. You should only use these boxes if
you feel that you have additional information that you need to convey
to clarify your response. The box will expand to accept your entire
response. If the check mark answers provided are sufficient, you do not
need to provide any additional comments in the boxes.
* Please use your mouse to navigate throughout the survey by clicking
on the field or check box you wish to answer.
* To select a check box, simply click on the center of the box.
* To change or deselect a response, simply click on the check box and
the "X" will disappear.
You will also notice that we ask about both low- and intermediate-
radioactive waste in the survey. The United States does not have a low-
and intermediate radioactive waste classification system, but rather it
relies on four classes of low-level radioactive waste--class A, B, C,
and greater-than-class C waste. The International Atomic Energy Agency
(IAEA) has estimated that all of U.S. class A and B waste, and 75
percent of the class C waste would fall into the international short-
lived low-and intermediate-level waste category, and the remaining 25
percent, as well as all of the greater-than-class C waste would fall
into the long-lived low and intermediate-level waste category. The U.S.
class A waste includes radioactive wastes that some other countries
classify as very low-level radioactive waste (
