Nuclear Security
DOE Needs Better Information to Guide Its Expanded Recovery of Sealed Radiological Sources Gao ID: GAO-05-967 September 22, 2005Concerns remain over the control of sealed radiological sources, widely used in many industrial and medical devices and applications. The Nuclear Regulatory Commission (NRC), the Department of Energy (DOE), and states have responsibilities for ensuring the safe and secure use and eventual disposal of these sources as low-level radioactive wastes. DOE must ensure disposal availability for greater-than-class C (GTCC) waste; states must do so for non-GTCC waste, that is, classes A, B, and C waste. NRC and DOE also collaborate to identify and recover unwanted sources that are not safe or secure. GAO examined DOE's (1) efforts to recover unwanted sources and develop a GTCC waste disposal option, (2) actions to recover and dispose of non-GTCC source waste, and (3) ability to identify sources for recovery and disposal.
DOE has increased emphasis on its source recovery project and begun the process of identifying disposal options for GTCC waste. DOE transferred project responsibilities to another office that has given the project higher priority and accelerated DOE's recovery efforts. DOE exceeded an earlier goal for recovering sources and has now collected over 10,800 of them. This recovery has been facilitated by additional project funding support and DOE's resolving a shortage of storage space for certain sources. In May 2005, DOE issued a notice of intent to prepare an environmental impact statement to assess GTCC waste disposal options; however, DOE has not yet determined when a disposal site might be made available. DOE has expanded the scope of its recovery effort to include non-GTCC waste from sealed radiological sources, a change that could increase DOE expenditures. DOE recovered and commercially disposed of 443 of these sources from a bankrupt firm, at a cost to DOE of about $581,000. Given that unwanted sources in storage present higher vulnerabilities, DOE might need to recover more of them in the future if the commercial disposal site that currently accepts this non-GTCC waste from most states ceases to do so as planned in 2008. Lacking a commercial disposal option, DOE anticipates storing this waste, rather than disposing of it at DOE sites, because, among other reasons, it does not want to undermine the responsibility the Congress gave the states to provide disposal availability for non-GTCC waste. DOE lacks information that would assist its efforts to identify and recover unwanted sealed radiological sources that may pose a safety and security risk. DOE has useful information on the sources in its possession, including recovered sources. However, DOE does not know how many sources might need recovery and how much disposal capacity is needed for GTCC waste. NRC is developing a national source tracking system that would not be useful for DOE's source recovery efforts because it is only designed to track individual sources with high radioactivity. According to DOE, nearly all of the sites where it has recovered sources contained individual sources with lesser radioactivity than would be tracked by NRC, but their combined radioactivity posed enough of a risk to warrant their recovery by DOE.
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-05-967, Nuclear Security: DOE Needs Better Information to Guide Its Expanded Recovery of Sealed Radiological Sources
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Report to the Chairman, Committee on Energy and Natural Resources, U.S.
Senate:
September 2005:
Nuclear Security:
DOE Needs Better Information to Guide Its Expanded Recovery of Sealed
Radiological Sources:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-967]
GAO Highlights:
Highlights of GAO-05-967, a report to the Chairman, Committee on Energy
and Natural Resources, U.S. Senate:
Why GAO Did This Study:
Concerns remain over the control of sealed radiological sources, widely
used in many industrial and medical devices and applications. The
Nuclear Regulatory Commission (NRC), the Department of Energy (DOE),
and states have responsibilities for ensuring the safe and secure use
and eventual disposal of these sources as low-level radioactive wastes.
DOE must ensure disposal availability for greater-than-class C (GTCC)
waste; states must do so for non-GTCC waste, that is, classes A, B, and
C waste. NRC and DOE also collaborate to identify and recover unwanted
sources that are not safe or secure. GAO examined DOE‘s (1) efforts to
recover unwanted sources and develop a GTCC waste disposal option, (2)
actions to recover and dispose of non-GTCC source waste, and (3)
ability to identify sources for recovery and disposal.
What GAO Found:
DOE has increased emphasis on its source recovery project and begun the
process of identifying disposal options for GTCC waste. DOE transferred
project responsibilities to another office that has given the project
higher priority and accelerated DOE‘s recovery efforts. DOE exceeded an
earlier goal for recovering sources and has now collected over 10,800
of them. This recovery has been facilitated by additional project
funding support and DOE‘s resolving a shortage of storage space for
certain sources. In May 2005, DOE issued a notice of intent to prepare
an environmental impact statement to assess GTCC waste disposal
options; however, DOE has not yet determined when a disposal site might
be made available.
DOE has expanded the scope of its recovery effort to include non-GTCC
waste from sealed radiological sources, a change that could increase
DOE expenditures. DOE recovered and commercially disposed of 443 of
these sources from a bankrupt firm, at a cost to DOE of about $581,000.
Given that unwanted sources in storage present higher vulnerabilities,
DOE might need to recover more of them in the future if the commercial
disposal site that currently accepts this non-GTCC waste from most
states ceases to do so as planned in 2008. Lacking a commercial
disposal option, DOE anticipates storing this waste, rather than
disposing of it at DOE sites, because, among other reasons, it does not
want to undermine the responsibility the Congress gave the states to
provide disposal availability for non-GTCC waste.
DOE lacks information that would assist its efforts to identify and
recover unwanted sealed radiological sources that may pose a safety and
security risk. DOE has useful information on the sources in its
possession, including recovered sources. However, DOE does not know how
many sources might need recovery and how much disposal capacity is
needed for GTCC waste. NRC is developing a national source tracking
system that would not be useful for DOE‘s source recovery efforts
because it is only designed to track individual sources with high
radioactivity. According to DOE, nearly all of the sites where it has
recovered sources contained individual sources with lesser
radioactivity than would be tracked by NRC, but their combined
radioactivity posed enough of a risk to warrant their recovery by DOE.
DOE Personnel Packaging a Sealed Radiological Source in a Disposal
Drum:
[See PDF for image]
[End of image]
What GAO Recommends:
GAO recommends that DOE and NRC evaluate and report on the cost
implications of DOE‘s recovery and disposal of non-GTCC waste, options
to recoup these DOE costs from licensees, the feasibility of using DOE
disposal sites, and how a national source tracking system can be
designed and implemented to improve DOE‘s recovery and disposal
efforts. DOE generally supported GAO‘s recommendations. NRC found the
report well written and balanced, but did not agree or disagree with
GAO‘s recommendations.
www.gao.gov/cgi-bin/getrpt?GAO-05-967.
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:
DOE Has Increased Emphasis on Its Source Recovery Project and Begun
Assessing Options for Disposing of GTCC Waste:
DOE Expanded the Scope of Its Source Recovery Project to Include Non-
GTCC Waste, Which Could Increase Project Expenditures:
DOE Lacks Information to Better Identify Unwanted Sealed Radiological
Sources That May Need Recovery:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Scope and Methodology:
Appendix II: Selected Sealed Radiological Source Devices and Their
Potential Waste Classes:
Appendix III: Comments from the Department of Energy:
Appendix IV: Comments from the Nuclear Regulatory Commission:
Appendix V: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: IAEA High-risk Categories of Sealed Radiological Sources:
Table 2: Summary of DOE-Recovered Sealed Radiological Sources, by
Radionuclide, as of June 7, 2005:
Table 3: DOE-Recovered Sealed Radiological Sources, by Their IAEA
Source Category, as of June 7, 2005:
Table 4: Selected Sealed Radiological Source Devices and Their
Potential Waste Classes:
Figures:
Figure 1: Loss of Control of Sealed Radiological Sources:
Figure 2: Source Recovery Project Personnel Remove a Sealed
Radiological Source and Repackage It into a WIPP-Acceptable Disposal
Drum:
Figure 3: Relative Size of a Sealed Radiological Source and Typical
Disposal Drums:
Figure 4: A Cross Section of a Nuclear Gauge, and Leveling Gauges
Returned to a Manufacturer:
Figure 5: Interior Views of Two 55-Gallon Disposal Drums, One with a
Large Opening for an Entire Disused Device and the Other with a Narrow
Pipe Opening for Only Sources:
Abbreviations:
CRCPD: Conference of Radiation Control Program Directors:
DOE: Department of Energy:
EIS: environmental impact statement:
GTCC: greater-than-class C:
IAEA: International Atomic Energy Agency:
NNSA: National Nuclear Security Administration:
NRC: Nuclear Regulatory Commission:
WIPP: Waste Isolation Pilot Plant:
Letter September 22, 2005:
The Honorable Pete V. Domenici:
Chairman, Committee on Energy and Natural Resources:
United States Senate:
Dear Mr. Chairman:
The regulatory control and tracking of sealed radiological sources in
the possession of academic, government, industrial, medical, and
utility entities that are licensed to use them in devices and
applications continues to evolve. These sources contain radioactive
material encapsulated, or sealed, in metal to prevent its dispersal.
The small size and portability of sealed radiological sources, however,
make them susceptible to misuse, improper disposal, and theft. If some
types of sealed radiological sources fell into the hands of terrorists,
they could be used in fabricating crude but potentially dangerous
radiological weapons, commonly called dirty bombs. In general, a dirty
bomb is produced by packaging explosives, such as dynamite, with
radioactive material, which would be dispersed when the bomb was
activated.
There are an estimated 2 million devices containing sealed radiological
sources in use throughout the United States,[Footnote 1] and as many as
one-quarter of them, or up to 500 thousand, may no longer be needed.
However, only some of these sources are considered particularly
attractive for producing dirty bombs because, among other things, they
contain more concentrated amounts of certain nuclear material, such as
americium-241, cesium-137, plutonium-238, and strontium-90. Depending
on the type, form (e.g., solid or powder), amount, and concentration of
the radioactive material dispersed in a malevolent act, the released
material could cause radiation sickness for people nearby as well as
significant economic costs and serious social disruption associated
with the evacuation and subsequent cleanup of the contaminated area.
Even without an intentional act, the inadvertent loss of a sealed
radiological source can also lead to radiation exposure, high
decontamination costs, and public panic. For example, in a 1983
incident, a Texas company sold a cancer treatment machine containing a
sealed radioactive source to a clinic in Mexico. The device was
subsequently stolen, and the source was accidentally melted with other
metals to form steel reinforcing rods that were imported into the
United States and eventually used to build 37 homes and businesses. The
steel rods were encased in concrete and thus were naturally shielded,
but the incident caused public concern, costly decontamination, and
increased regulatory inspections.
The Nuclear Regulatory Commission (NRC) and the Agreement
States[Footnote 2] are responsible for regulating the use of sealed
radiological sources and other radioactive materials, from creation to
disposal, in a way that ensures the public health and safety. They do
so through a combination of regulatory requirements, licensing,
inspection, and enforcement. Under the Atomic Energy Act of 1954, NRC
also is responsible for issuing rules, regulations, or orders to
promote the common defense and security. As we reported in August 2003,
NRC and the Agreement States disagreed about the appropriate state role
in the regulation of sealed radiological source security.[Footnote 3]
According to NRC, it and the Agreement States are currently working
together to implement increased regulatory requirements on licensees
that possess sealed radiological sources that are of security concern.
After a licensee determines that a sealed radiological source is no
longer useful, the source can be returned to the manufacturer or
supplier, transferred to another licensee, stored to allow for a
natural decrease in radioactivity, or sent to a commercial waste
disposal facility. Once the source is packaged for disposal, the
disposal container is put into a waste class. NRC defines the four
types of low-level radioactive waste (i.e., waste not classified as
high-level waste, such as spent fuel from nuclear power plants) as
classes A, B, C, and greater-than-class C (GTCC).[Footnote 4] The type
of radionuclide (e.g., americium-241) and the concentration of
radioactivity (often measured in curies per gram),[Footnote 5] are
considered in determining the waste class of the radioactive material,
which carries progressively more stringent requirements for disposal
from class A to GTCC waste. Non-GTCC waste, including classes A, B, and
C waste (e.g., contaminated soil, laboratory equipment, exit signs
containing tritium, and some sealed radiological sources) generally can
be disposed of by shallow burial at existing commercial low-level
radioactive waste disposal sites. However, GTCC waste (e.g., activated
metals,[Footnote 6] sealed radiological sources, and other highly
radioactive waste) will generally require a different type of disposal.
Under the Low- Level Radioactive Waste Policy Act of 1980, as
amended,[Footnote 7] the states and federal government were given
separate responsibilities for providing disposal availability for these
wastes. States were made responsible for providing disposal
availability for non-GTCC waste, and the Department of Energy (DOE) was
given the responsibility of providing disposal for GTCC waste. Non-GTCC
waste must be disposed of in a facility licensed by either NRC or an
Agreement State, but only NRC can license a facility for GTCC waste. As
an incentive for states to manage waste on a regional basis, the
Congress consented to the formation of interstate agreements, known as
compacts, and granted compact member states the authority to exclude
low-level radioactive waste from other compacts and unaffiliated
states.[Footnote 8]
Even though states have not developed any new disposal sites for low-
level radioactive waste since passage of the act, we reported in June
2004,[Footnote 9] that disposal availability for non-GTCC waste was
adequate in the short term, but that federal oversight was needed to
identify any future shortfalls. There are currently three commercial
disposal sites that collectively serve the nation's non-GTCC waste
disposal needs.[Footnote 10] A shortfall in disposal availability for
the higher radioactive non-GTCC waste (classes B and C waste), however,
could occur by mid-2008, if South Carolina follows through with plans
to restrict access to its Barnwell disposal site to only the 3 member
states of the Atlantic Compact. This restriction would mean that
licensees in the 36 states that are currently allowed to use this
disposal site would be denied access to it, and under current
conditions, they would have no alternative option to dispose of their
higher radioactive non-GTCC waste. Regarding GTCC waste disposal, we
reported in April 2003[Footnote 11] that DOE had not made progress
toward providing for the permanent disposal of GTCC waste because doing
so was not a priority at the time.
Given the lack of disposal options for GTCC waste and the public
health, safety, and national security concerns about unwanted sealed
radiological sources at licensee sites around the country, DOE, in
collaboration with NRC, has been recovering, taking title of, and
storing sources--primarily at its Los Alamos National Laboratory. DOE
has been taking these actions through its Off-Site Source Recovery
Project, which has been operated by Los Alamos National Laboratory
personnel since the late-1990s. In June 1999, NRC and DOE entered into
a memorandum of understanding describing their respective roles and
responsibilities for addressing the problem of unwanted and
uncontrolled sealed radiological sources, often referred to as "orphan
sources." This memorandum formalized agreements reached between these
agencies in 1992 to have DOE begin recovering and storing unwanted
sealed radiological sources because DOE had yet to develop a disposal
site for GTCC waste. Since then, DOE has routinely recovered, from
licensees that request such a collection, sealed radiological sources
that when packaged for disposal would be classified as GTCC waste. Many
of these unwanted sources, such as plutonium-239, were originally
derived from defense programs and loaned to colleges and universities
that no longer want them. DOE, at the request of NRC, also recovers
sources that are in the possession of licensees that are no longer able
to ensure their safety and security. In our April 2003 report, we found
that while DOE's source recovery project had collected more than 5,000
sources, the project faced the following three problems that could
hinder future recovery efforts: questionable long-term commitment to
the program of DOE's Office of Environmental Management, inadequate
storage capacity that meets the higher security requirements for sealed
radiological sources containing plutonium-239, and DOE's inability to
store sealed radiological sources containing strontium-90 and cesium-
137.
In this context, we examined (1) the status of DOE's efforts to recover
unwanted sealed radiological sources and to develop a disposal option
for GTCC waste, (2) DOE actions taken to recover and dispose of non-
GTCC waste from sealed radiological sources, and (3) the extent to
which DOE can identify unwanted sealed radiological sources for
recovery and disposal.
To conduct our work, we reviewed pertinent information in existing
databases and published reports and interviewed officials from federal
and state agencies, professional organizations, and representatives
from entities that are licensed to possess sealed radiological sources.
More specifically, we examined DOE's efforts to recover unwanted sealed
radiological sources and the databases maintained by DOE and NRC to
inventory some of these materials. We assessed the reliability of these
data and determined that they were sufficiently reliable for the
purposes of this report. We also used structured interviews of
licensees and commercial waste brokers that possess unwanted sealed
radiological sources and reviewed their waste forms to obtain an
understanding of how these materials are classified, and what
challenges might be faced if there is no disposal option availability
for them in the future. We excluded some radioactive wastes from our
review because the radioactive materials are already under higher
security, such as at nuclear power plants and DOE facilities, or
because they present a lower security risk, such as class A waste. We
conducted our review between June 2004 and September 2005 in accordance
with generally accepted government auditing standards. A more detailed
description of our methodology is provided in appendix I.
Results in Brief:
DOE has increased emphasis on its source recovery project and begun the
process of identifying disposal options for GTCC waste. Specifically,
DOE transferred responsibilities for source recovery from its Office of
Environmental Management to its National Nuclear Security
Administration (NNSA) to better respond to both domestic and
international threats posed by unwanted sealed radiological sources.
DOE was able to recover 5,529 of these sources within 18 months,
exceeding a recovery goal established in October 2002 and more than
doubling the number of sources recovered since 1996. As of June 7,
2005, DOE had collected a total of 10,806 sealed radiological sources
and plans to continue recovering sources at least until there is a
permanent disposal option for GTCC waste. DOE's accelerated recovery
efforts have been supported through continued annual and supplemental
appropriations. The recovery of these unwanted sealed radiological
sources was also facilitated by DOE's resolution of some problems with
storage availability for certain types of sources. For example, DOE was
able to recover and provide storage for over 260 plutonium-239 sources
that licensees had registered for collection; however, some new issues
have arisen that are preventing DOE from recovering the more than 100
of these sources that still remain at licensee sites. Finally, DOE has
begun identifying disposal options for GTCC waste. In May 2005, DOE
issued a notice of its intent to prepare an environmental impact
statement assessing various disposal options for GTCC waste. In
preparing this document, DOE plans to gather information on the amount
of GTCC waste that might be generated over the next 30 to 50 years;
however, making useful projections will be difficult because, among
other things, no national database tracks the volume of GTCC materials
or waste. Further, DOE has not yet determined when a permanent GTCC
waste disposal site might be available because of uncertainties
surrounding what alternatives will be available to DOE after it
completes the assessment of the various disposal options for this
waste.
DOE has expanded the scope of its source recovery project to include
non-GTCC waste from unwanted sealed radiological sources--a change that
could increase recovery project expenditures if DOE needs to recover
and dispose of more of this waste in the future. DOE has already
recovered and commercially disposed of non-GTCC waste from some
licensees that could no longer ensure the safety and security of their
unwanted sealed radiological sources. For example, in fiscal year 2004,
at the request of NRC, DOE recovered from a bankrupt firm and
commercially disposed of 443 mostly cesium-137, sealed radiological
sources at a cost of approximately $581,000. Moreover, DOE may need to
begin recovering greater quantities of non-GTCC waste from unwanted
sealed radiological sources if licensees in most states have no access
to commercially dispose of it in the future. Domestic and international
experts contend that the lack of disposal availability for unwanted
sealed radiological sources makes them more vulnerable to abandonment,
misplacement, and theft that would pose a safety and security risk. If
DOE needs to recover more of these types of sources, source recovery
project expenditures may increase unless DOE can recoup some of its
costs from licensees that could otherwise pay for disposal if a
commercial disposal option were available. In the absence of any
commercial disposal option for the non-GTCC waste that DOE collects,
the department anticipates indefinitely storing this waste. DOE's
current policy is to not use its own sites for disposing of this waste
because, among other reasons, it does not want to undermine the
responsibility that the Congress gave to the states for providing
disposal availability for non-GTCC waste. We are recommending that DOE
and NRC collaborate in evaluating and reporting on the potential cost
implications of expanding DOE's recovery and disposal of non-GTCC waste
from sealed radiological sources, options to recoup DOE costs from
licensees that may have no disposal option, and the feasibility of
disposing of this waste at DOE sites.
DOE's ability to identify unwanted sealed radiological sources that may
pose a safety or security risk is limited by a lack of information
needed to guide its recovery and disposal efforts. DOE has useful
inventory data only on the sealed radiological sources in its
possession, including those recovered from licensees. This inventory
captures, among other things, information on the status of each source,
including whether it is in active use, is inaccessible, is in storage
for potential future use, or is packaged for disposal. However, DOE
does not have comparable information on the sealed radiological sources
in the possession of licensees that might need recovery in the future
because NRC and the Agreement States do not centrally collect this
information from them. NRC has recently issued a proposed rule that
will allow it to establish a national system to track the possession
and movement of some individual sealed radiological sources that
present a potential risk to individuals, society, and the environment
because of their high levels of radioactivity. This proposed rule is
consistent with the recently enacted Energy Policy Act of
2005,[Footnote 12] which, among other things, requires NRC to establish
a tracking system and a task force to evaluate and report on radiation
source protection and security concerns. However, as presently
designed, this system would only track individual sources with high
radioactivity concentrations and would not include essentially all of
the sources of lesser radioactivity that DOE has recovered. According
to DOE, over 90 percent of the licensee sites where sources were
recovered contained individual sources of lesser radioactivity than
would be individually tracked by NRC, yet their combined radioactivity
concentration posed enough of a safety and security risk to warrant
their recovery by DOE. As a result, this proposed national source
tracking system would be of little use to DOE in its efforts to plan
and budget for the recovery and disposal of unwanted sealed
radiological sources. We are recommending that DOE and NRC collaborate
on evaluating and reporting on how a national source tracking system
can be designed and implemented to improve DOE's ability to identify
unwanted sealed radiological sources that may need DOE recovery and
disposal.
DOE and NRC provided comments on a draft of this report. DOE stated
that it generally supports all of our recommendations. Moreover, DOE
commented that we had correctly reported the department's position with
regard to issues discussed in this report. In addition, DOE affirmed
the need to improve the national source tracking system to assist the
department in identifying and recovering unwanted sources from outside
the department that pose a potential safety and security risk. NRC
stated that overall our report was well written and balanced. NRC did
not specifically agree or disagree with our recommendations. However,
NRC expressed concerns that any changes to the design of its national
source tracking system at this time could be extremely burdensome on
licensees and the agency and would yield little, if any, practical
benefit. Nevertheless, NRC stated that it will continue to seek
comments on the inclusion of sources of lower radioactivity in its
national source tracking system because licensees possessing large
quantities of these sources could present a security concern.
Background:
The loss of control of sealed radiological sources can arise from their
abandonment, misplacement, or theft. In such cases, there is a risk of
either the inadvertent or intentional malevolent human exposure to
radioactive materials in these sources. Figure 1 shows a graphic
representation of the ways in which the loss of control of sealed
radiological sources can occur.
Figure 1: Loss of Control of Sealed Radiological Sources:
[See PDF for image]
[End of figure]
Since September 11, 2001, international and U.S. agencies have taken
additional steps to increase the safety and security of radioactive
materials, particularly sealed radiological sources. Between 2002 and
2003, the International Atomic Energy Agency (IAEA)[Footnote 13] held
various meetings and conferences to discuss how the agency's Code of
Conduct on the Safety and Security of Radioactive Sources might be
revised in light of new security concerns. One result of these
gatherings was the development of a categorization scheme for sealed
radiological sources in terms of the potential risks associated with
their malevolent uses.[Footnote 14] The first three of the five source
categories identified by IAEA, which are considered to pose the most
significant risk to individuals, society, and the environment, are
listed in an annex to the Code of Conduct. The Code of Conduct
recommends that IAEA member states establish a national registry that
tracks, at a minimum, the first two source categories. Table 1 contains
a listing of the radionuclides and their curie levels that are
presented in the IAEA Code of Conduct.
Table 1: IAEA High-risk Categories of Sealed Radiological Sources:
Radionuclide: Americium-241;
Category 1 (curies)[A]: 2,000;
Category 2 (curies)[A]: 20;
Category 3 (curies)[A]: 2.
Radionuclide: Americium-241/Beryllium;
Category 1 (curies)[A]: 2,000;
Category 2 (curies)[A]: 20;
Category 3 (curies)[A]: 2.
Radionuclide: Californium-252;
Category 1 (curies)[A]: 500;
Category 2 (curies)[A]: 5;
Category 3 (curies)[A]: 0.5.
Radionuclide: Cesium-137;
Category 1 (curies)[A]: 3,000;
Category 2 (curies)[A]: 30;
Category 3 (curies)[A]: 3.
Radionuclide: Cobalt-60;
Category 1 (curies)[A]: 800;
Category 2 (curies)[A]: 8;
Category 3 (curies)[A]: 0.8.
Radionuclide: Curium-244;
Category 1 (curies)[A]: 1,000;
Category 2 (curies)[A]: 10;
Category 3 (curies)[A]: 1.
Radionuclide: Gadolinium-153;
Category 1 (curies)[A]: 30,000;
Category 2 (curies)[A]: 300;
Category 3 (curies)[A]: 30.
Radionuclide: Iridium-192;
Category 1 (curies)[A]: 2,000;
Category 2 (curies)[A]: 20;
Category 3 (curies)[A]: 2.
Radionuclide: Plutonium-238;
Category 1 (curies)[A]: 2,000;
Category 2 (curies)[A]: 20;
Category 3 (curies)[A]: 2.
Radionuclide: Plutonium-239/Beryllium;
Category 1 (curies)[A]: 2,000;
Category 2 (curies)[A]: 20;
Category 3 (curies)[A]: 2.
Radionuclide: Promethium-147;
Category 1 (curies)[A]: 1,000,000;
Category 2 (curies)[A]: 10,000;
Category 3 (curies)[A]: 1,000.
Radionuclide: Radium-226;
Category 1 (curies)[A]: 1,000;
Category 2 (curies)[A]: 10;
Category 3 (curies)[A]: 1.
Radionuclide: Scandium-75;
Category 1 (curies)[A]: 5,000;
Category 2 (curies)[A]: 50;
Category 3 (curies)[A]: 5.
Radionuclide: Selenium-75;
Category 1 (curies)[A]: 5,000;
Category 2 (curies)[A]: 50;
Category 3 (curies)[A]: 5.
Radionuclide: Strontium-90;
Category 1 (curies)[A]: 30,000;
Category 2 (curies)[A]: 300;
Category 3 (curies)[A]: 30.
Radionuclide: Thulium-170;
Category 1 (curies)[A]: 500,000;
Category 2 (curies)[A]: 5,000;
Category 3 (curies)[A]: 500.
Radionuclide: Ytterbium-169;
Category 1 (curies)[A]: 8,000;
Category 2 (curies)[A]: 80;
Category 3 (curies)[A]: 8.
Source: IAEA, Code of Conduct on the Safety and Security of Radioactive
Source (Vienna Austria: January 2004) Annex I, Table 1, p. 16.
[A] A curie is a measure of the rate of radioactive decay; it is
equivalent to the radioactivity of 1 gram of radium or 37 billion
disintegrations per second.
[End of table]
In May 2003, a DOE/NRC interagency working group--which was formed to
address security concerns over the radioactive materials that could be
used in a radiological dispersal device--issued a report that, among
other things, recommended that actions be taken to develop a national
threat policy based on vulnerability assessments, a national source
tracking system, and an integrated national strategy for disposing of
unsecured sealed radiological sources.[Footnote 15] Following this
DOE/NRC report, NRC adopted the nonlegally binding IAEA Code of Conduct
as a basis for (1) determining which licensees may need additional
protective measures for the sealed radiological sources in their
possession and (2) defining the scope of a national source tracking
system. NRC found that the curie thresholds for radionuclides in the
sources identified by the DOE/NRC interagency working group were
similar enough to the Code of Conduct categories to warrant adoption of
the IAEA source categorization scheme to better align domestic and
international efforts to increase the safety and security of sealed
radiological sources.
NRC and DOE have since engaged in separate efforts to (1) assess the
vulnerability of facilities that contain sealed radiological sources
within their jurisdictions, (2) promulgate new security measures, and
(3) begin systematically tracking some of these sources. According to
NRC officials, NRC has been working with the Agreement States since
January 2002, and with licensees since September 2002, using a risk
informed approach to enhance the regulatory requirements applicable to
high-risk radioactive material. In June 2003 and January 2004, NRC
issued its first set of protective measures to large irradiators and
device manufacturers and distributors, respectively. In January 2004,
NRC and the Agreement States began to consider the need for additional
protective measures for other licensees. This process has involved
several iterations of vulnerability assessments of licensee sites that
have devices or use applications containing IAEA categories 1 and 2
sources, such as teletherapy, gamma knife, well-logging devices, and
self-shielded irradiators. On September 6, 2005, NRC announced that
over approximately the next 90 days, affected licensees will receive
orders from the agency spelling out increased controls for certain
radioactive materials. Over the same period, individual Agreement
States will issue their licensees legally binding requirements
essentially identical to NRC's orders. Materials covered by these
requirements will be consistent with the IAEA Code of Conduct.
Regarding source tracking, in November 2003, NRC, with the assistance
of the Agreement States, identified and initially surveyed
approximately 2,600 entities licensed to possess IAEA categories 1 and
2 sources. The resulting interim inventory will supplement other
information NRC intends to use in developing a national source tracking
system. Regarding DOE efforts, DOE officials told us that various
department offices have been involved in developing, reviewing, and
issuing domestic and international guidance related to the security of
sealed radiological sources. Moreover, DOE has established its own
source tracking system--that is, the Radioactive Source Registry and
Tracking System--which, among other things, includes the unwanted
sealed radiological sources that DOE has recovered from licensees.
In addition to securing and tracking sealed radiological sources, IAEA
and NRC support the disposal of unwanted sources and other radioactive
waste. IAEA contends that although waste may be safely stored for
decades, as long as institutional controls are maintained, progress
must be made toward permanent disposal. According to the Director
General for Energy and Transport, European Commission, "the sources at
greatest risk of being lost from regulatory control are disused
(unwanted) sources held in local storage at the user's premises waiting
for final disposal or return to manufacturer."[Footnote 16] In response
to an international joint convention addressing spent nuclear fuel and
radioactive waste management,[Footnote 17] IAEA set forth the elements
of an effective national legal and organizational structure that would
provide for the safe and secure management of radioactive waste by
appropriate national authorities. One of the key indicators of such a
structure is that "the amount of waste in storage awaiting disposal
should depend only upon operational considerations—and should not
include a backlog due to an inability (technical, financial,
organizational, etc.) to reduce the backlog."[Footnote 18] NRC also
supports the disposal of low-level radioactive waste but has placed no
time limits on storage, as long as the radioactive material is safe and
secure. NRC contends that it is acceptable to allow some licensees to
store a backlog of sources in instances where a disposal option for
this waste is not available to them.
In August 2005, the President signed into law the Energy Policy Act of
2005, which, among other things, addressed the safe disposal of GTCC
waste and nuclear facility and materials security. The act requires DOE
to prepare plans for the continued recovery of sealed radiological
sources and to report on its efforts to develop a GTCC waste disposal
site. Other provisions call for NRC to issue regulations establishing a
mandatory tracking system for radiation sources in the United States
and to chair a task force on radiation source protection and security.
The task force, comprised of NRC, DOE and other federal agencies, in
consultation with other groups, is to evaluate and provide
recommendations relating to the security of radiation sources in the
United States from potential terrorist threats, including acts of
sabotage or theft or the use of radiation sources in a radiological
dispersal device.
DOE Has Increased Emphasis on Its Source Recovery Project and Begun
Assessing Options for Disposing of GTCC Waste:
DOE has placed increased emphasis on its source recovery project and
has begun to assess disposal options for GTCC waste. DOE has realigned
its source recovery project within NNSA to more effectively respond to
both domestic and international threats posed by unwanted sealed
radiological sources. Further, DOE has accelerated its recovery
efforts, surpassing an earlier source recovery goal, and has made
progress in resolving a storage space shortage at its facilities that
has slowed the recovery of certain unwanted sealed radiological
sources. Finally, DOE has begun preparing an environmental impact
statement to assess possible disposal options for GTCC waste. However,
difficulties in estimating current GTCC waste storage and future waste
volumes, especially from sealed radiological sources, will complicate
this effort. Further, DOE has not yet determined when a permanent GTCC
waste disposal facility will be available.
DOE Transferred Responsibility for the Source Recovery Project to NNSA:
To better respond to the security threats posed by unwanted sealed
radiological sources both within the United States and abroad, in
October 2003, DOE realigned management responsibilities for its source
recovery project from the Office of Environmental Management to
NNSA.[Footnote 19] This realignment was, in part, a response to a
recommendation to the Secretary of Energy that we made in our April
2003 report that the priority given to its Off-Site Source Recovery
Project be commensurate with the threat posed by some unwanted sealed
radiological sources. Subsequently, NNSA established the Nuclear and
Radiological Threat Reduction Task Force, under the Office of Defense
Nuclear Nonproliferation, to unite all of the department's radiological
threat reduction efforts. One of the principal missions of this task
force is to identify; secure; and store, on an interim basis,
radioactive materials that could be used as a radiological weapon. In
May 2004, DOE announced the creation of the Global Threat Reduction
Initiative, which further elevated the importance of the task force and
DOE's recovery of sealed radiological sources. This initiative was
later institutionalized in the Office of Global Radiological Threat
Reduction, with a domestic component, the U.S. Radiological Threat
Reduction Program, and an international component, the International
Radiological Threat Reduction Program. The Off-Site Source Recovery
Project was subsumed under the U.S. Radiological Threat Reduction
Program, but the program retained Los Alamos National Laboratory
personnel to continue the source recovery effort.
DOE Accelerated Its Efforts to Recover Unwanted Sealed Radiological
Sources:
DOE accelerated the recovery of unwanted sealed radiological sources
beginning in late 2002. As we reported in April 2003, DOE's ability to
meet planned recovery activities was largely facilitated by
supplemental congressional funding and by the urging of NRC to
accelerate recovery efforts in light of the events of September 11,
2001. In August 2002, the Congress provided an additional $10 million
to DOE's Off-Site Source Recovery Project to recover 5,000 unwanted
sealed radiological sources over the following 18 months.[Footnote 20]
Between October 1, 2002, and March 31, 2004, DOE recovered 5,529 of
these sources, exceeding its recovery goal and more than doubling the
number of sources previously recovered since 1996. As of June 7, 2005,
DOE had recovered 10,806 of these sources. According to the source
recovery project leader, the bulk of the remaining excess and unwanted
sealed radiological sources in the United States should be recovered in
the next 2 years. Table 2 contains a summary of DOE-recovered sealed
radiological sources, by radionuclide, as of June 7, 2005.
Table 2: Summary of DOE-Recovered Sealed Radiological Sources, by
Radionuclide, as of June 7, 2005:
Radionuclide: Americium-241/Beryllium;
Number of sources: 5,222;
Percentage of total sources: 48.33%;
Curies[A]: 11,657.48;
Percentage of total curies[A]: 7.77%.
Radionuclide: Plutonium-238;
Number of sources: 1,907;
Percentage of total sources: 17.65%;
Curies[A]: 7,040.66;
Percentage of total curies[A]: 4.70%.
Radionuclide: Americium-241;
Number of sources: 1,900;
Percentage of total sources: 17.58%;
Curies[A]: 464.07;
Percentage of total curies[A]: 0.31%.
Radionuclide: Americium-241/Berylllium/Cesium-137;
Number of sources: 552;
Percentage of total sources: 5.11%;
Curies[A]: 26.48;
Percentage of total curies[A]: 0.02%.
Radionuclide: Cesium-137Cs;
Number of sources: 363;
Percentage of total sources: 3.36%;
Curies[A]: 1,621.65;
Percentage of total curies[A]: 1.08%.
Radionuclide: Plutonium-239Pu/Beryllium;
Number of sources: 255;
Percentage of total sources: 2.36%;
Curies[A]: 543.42;
Percentage of total curies[A]: 0.36%.
Radionuclide: Colbalt-60;
Number of sources: 197;
Percentage of total sources: 1.82%;
Curies[A]: 42,602.21;
Percentage of total curies[A]: 28.41%.
Radionuclide: Plutonium-238/Beryllium;
Number of sources: 169;
Percentage of total sources: 1.56%;
Curies[A]: 2,186.87;
Percentage of total curies[A]: 1.46%.
Radionuclide: Plutonium-239;
Number of sources: 99;
Percentage of total sources: 0.92%;
Curies[A]: 5.48;
Percentage of total curies[A]: 0.00%.
Radionuclide: Neptunium-237;
Number of sources: 25;
Percentage of total sources: 0.23%;
Curies[A]: 0.01;
Percentage of total curies[A]: 0.00%.
Radionuclide: Americium-241/Cerium;
Number of sources: 24;
Percentage of total sources: 0.22%;
Curies[A]: 51.00;
Percentage of total curies[A]: 0.03%.
Radionuclide: Americium-241/Lithium;
Number of sources: 22;
Percentage of total sources: 0.20%;
Curies[A]: 437.00;
Percentage of total curies[A]: 0.29%.
Radionuclide: Curium-244;
Number of sources: 18;
Percentage of total sources: 0.17%;
Curies[A]: 7.51;
Percentage of total curies[A]: 0.01%.
Radionuclide: Radium-226;
Number of sources: 17;
Percentage of total sources: 0.16%;
Curies[A]: 0.05;
Percentage of total curies[A]: 0.00%.
Radionuclide: Plutonium-238/Lithium;
Number of sources: 16;
Percentage of total sources: 0.15%;
Curies[A]: 255.50;
Percentage of total curies[A]: 0.17%.
Radionuclide: Strontium-90;
Number of sources: 10;
Percentage of total sources: 0.09%;
Curies[A]: 82,958.85;
Percentage of total curies[A]: 55.33%.
Radionuclide: Plutonium-238/Lithium/Cesium-137;
Number of sources: 7;
Percentage of total sources: 0.06%;
Curies[A]: 66.10;
Percentage of total curies[A]: 0.05%.
Radionuclide: Uranium-235;
Number of sources: 2;
Percentage of total sources: 0.02%;
Curies[A]: 0.00;
Percentage of total curies[A]: 0.00%.
Radionuclide: Americium-241/Boron;
Number of sources: 1;
Percentage of total sources: 0.01%;
Curies[A]: 15.00;
Percentage of total curies[A]: 0.01%.
Radionuclide: Total;
Number of sources: 10,806;
Percentage of total sources: 100.00%;
Curies[A]: 149,939.34;
Percentage of total curies[A]: 100.00%.
Source: DOE source recovery project inventory database.
[A] A curie is a measure of the rate of radioactive decay; it is
equivalent to the radioactivity of 1 gram of radium or 37 billion
disintegrations per second.
[End of table]
DOE has maintained its source recovery project efforts through annual
and supplemental appropriations. In our April 2003 report, we
recommended that the Secretary of Energy ensure that adequate resources
be devoted to covering the costs of recovering and storing unwanted
sealed radiological sources as quickly as possible. In a September 2004
congressional hearing, the director of DOE's Office of Global
Radiological Threat Reduction testified that the department had
increased funding for the source recovery project and had committed
funds for continuing these efforts.[Footnote 21] The director stated
that the fiscal year 2004 program budget was $1.96 million, not
including about $3.49 million that was added to the budget to respond
in part to unexpected requests from NRC to recover sources of security
concern.[Footnote 22] In fiscal year 2005, the source recovery project
budget was increased to $5.6 million; for fiscal year 2006, DOE has
requested $12.8 million, in part, to better fund the expanded scope of
the U.S. Radiological Threat Reduction Program. The source recovery
project leader has estimated an average recovery cost of $3,000 per
source, on the basis of the initial 10,000 sources recovered, not
including commercial disposal costs for certain sources.
DOE plans to continue recovering unwanted sealed radiological sources,
at least until a GTCC waste disposal site is available. In our April
2003 report, we recommended that the Secretary of Energy develop a plan
to ensure the continued recovery and storage of unwanted sealed
radiological sources until a GTCC waste disposal site is available. We
reported that DOE used several sources of information and made three
key assumptions when projecting the anticipated need to recover 14,309
sources between fiscal years 1999 and 2010. The assumptions were that
(1) a permanent disposal site for the sources would be available by
fiscal year 2007; (2) the Off-Site Source Recovery Project would
continue to recover sources from certain holders of sources during a
transition period from fiscal years 2007 through 2010; and (3) after
fiscal year 2010, all unwanted sealed radiological sources would be
shipped by their owners to a disposal site, and the Off-Site Source
Recovery Project would cease operations. However, according to the
manager of DOE's U.S. Radiological Threat Reduction Program, these
assumptions are no longer used by the department because the lack of a
firm date for when a GTCC waste disposal site will be available means
that DOE cannot determine when it will cease recovering unwanted sealed
radiological sources from licensees. The Energy Policy Act of 2005
requires DOE to submit a plan to the Congress that ensures the
continued recovery and storage of unwanted sealed radiological sources
that pose a security threat until a permanent GTCC waste disposal
facility is available. Further, this DOE manager told us that source
recovery project personnel may still be needed to help some licensees
to meet the packaging requirements of any future GTCC waste disposal
facility.
DOE Has Made Progress in Resolving a Storage Space Shortage That Has
Slowed Recovery of Some Sealed Radiological Sources:
DOE has taken actions to address the storage space shortage that has
prevented the recovery of certain types of unwanted sealed radiological
sources. We reported in April 2003 that DOE had inadequate storage
capacity to meet the higher security needs for recovered sealed
radiological sources containing plutonium-239, and lacked a means for
temporarily storing sources containing strontium-90 and cesium-137. We
recommended, among other things, that the Secretary of Energy take
immediate action to provide storage space for these sources at a secure
DOE facility. According to the director of DOE's Office of Global
Radiological Threat Reduction, as of September 2004, DOE had developed
sufficient storage space at the Los Alamos National Laboratory and the
Nevada Test Site to recover more than 260 plutonium-239 sealed
radiological sources registered by licensees for collection. According
to the source recovery project team leader, DOE's plan has been to
recover over 100 remaining plutonium-239 registered sources,
representing approximately 60 drums of waste;[Footnote 23] ship them to
the Nevada Test Site; and then incrementally transfer them to the Los
Alamos National Laboratory as space is made available from the shipment
of the existing stored plutonium-239 sources to the Waste Isolation
Pilot Plant (WIPP) in New Mexico.[Footnote 24] WIPP will only accept
sources that are shipped from Los Alamos. Implementation of this plan,
however, has been delayed pending final approvals to ship these sources
between locations.
Additional progress has been made in addressing the storage issues that
relate to unwanted strontium-90, cesium-137, and some cobalt-60 sealed
radiological sources. According to the source recovery project team
leader, DOE has recovered a strontium-90 radioisotopic thermoelectric
generator that was owned by the department and used as a remote power
supply and disposed of the generator at the Nevada Test Site. DOE also
has recovered six of these devices that were commercially owned and is
storing them at the Los Alamos National Laboratory, pending approval
for disposal as waste. Regarding the cesium-137 sealed radiological
sources, the source recovery project has recycled 5 large cesium-137
irradiators to commercial firms. DOE has also contracted to recover the
remaining 14 registered irradiators by the end of fiscal year 2005.
Moreover, the team leader told us that the source recovery project
plans to collect 221 cobalt-60 sources from a university this summer
and to dispose of them at the Nevada Test Site as DOE-owned nuclear
material.
DOE Is Preparing an Environmental Impact Statement for GTCC Waste
Disposal Options, but Estimating Storage and Future Waste Volumes Will
Be Difficult:
DOE has begun to take action to identify a suitable location for the
disposal of GTCC waste, but producing useful estimates of the current
storage and future generation of this waste will be difficult. We
reported in April 2003 that DOE had not made progress toward providing
for a permanent disposal facility for the nation's GTCC waste, and that
it was unlikely to provide such a facility by fiscal year 2007 because
developing a disposal site for this waste was considered a low priority
within the department. We recommended that the Secretary of Energy
initiate a process to develop a permanent disposal facility for GTCC
waste, including empowering an office to take on this responsibility.
In September 2004, DOE took a first step in this direction by
transferring responsibility for assessing disposal options for GTCC
waste from its Office of Environment, Safety, and Health to its Office
of Environmental Management. With this authority and the heightened
need to take action, on May 11, 2005, the Office of Environmental
Management published an advance notice in the Federal Register of its
intent to prepare an environmental impact statement (EIS) for GTCC
waste disposal.[Footnote 25] DOE now anticipates that the actual notice
of intent to prepare the EIS will be issued in the fall of 2005,
followed by public meetings to further define the scope of the EIS and
to identify significant issues to be addressed. The DOE document
manager for the EIS told us that after the notice of intent is issued,
the process of preparing the EIS could take 2 years. The Energy Policy
Act of 2005 requires that, within 1 year, DOE report to the Congress on
the estimated costs and a proposed schedule to complete both the EIS
and a record of decision for a permanent disposal facility for GTCC
waste. Moreover, before DOE makes a final decision on the long-term
disposal alternative or alternatives to be implemented, this act
requires DOE to prepare a report to the Congress describing all
alternatives under consideration, including recommendations for
ensuring the safe disposal of GTCC waste, and then to await action by
the Congress. Therefore, it is not possible for DOE to determine when a
permanent disposal facility will be available for GTCC waste.
In his September 2004 congressional testimony, the director of DOE's
Office of Global Radiological Threat Reduction, stated that the EIS for
GTCC waste disposal will include an analysis of waste inventories, long-
term disposition alternatives, and resource requirements--as well as an
assessment of legislative, regulatory, and licensing requirements.
According to the director, the broad scope of the EIS should enable DOE
to consider any new or existing site, facility, and disposal method for
GTCC waste. Possible locations and disposal options include commercial,
DOE, or other governmental facilities and private land. The disposal
methods examined will range from deep geologic disposal to enhanced
near-surface disposal, depending on the type of GTCC waste.
In completing the EIS, DOE plans to inventory the GTCC waste in storage
at licensee and DOE facilities as well as estimate the waste expected
to be generated in the future. According to the DOE document manager
for the EIS, the department will obtain information on nuclear utility
and DOE GTCC waste that is currently in storage and will estimate
future volumes over the next 30 to 50 years on the basis of a
representative sample of some nuclear power plants that are being
decommissioned, and from existing DOE databases. For nonutility
licensees, the information on the storage and projected generation of
GTCC waste will be more speculative. This official said that DOE has
selected a contractor to update the estimates made in a 1994 DOE report
that the department now considers outdated.[Footnote 26] DOE asked the
contractor to begin with the methodology used in the 1994 report to
estimate current GTCC waste storage and to project future generation of
these wastes by nonutility licensees, rather than attempt to survey all
NRC and Agreement State licensees that might possess these radioactive
materials.
Attempting to obtain information on nonutility licensee storage of GTCC
waste that can be used to estimate future generation of GTCC waste from
sealed radiological sources will be especially difficult. Of the three
types of GTCC waste, the second largest volume behind activated metals
is from sealed radiological sources. Uncertainties surround producing
these estimates, such as (1) how to determine the quantities of
unwanted sealed radiological sources in storage and (2) how much waste
and what class of waste might be generated once these sources are
packaged for disposal. One estimating problem is that there is
currently no standard process by which licensees declare their sealed
radiological sources as disused (unwanted). According to an NRC
official, sealed radiological sources would not be considered waste,
even if they are stored unused by a licensee, until the licensee has
determined that they are no longer useful. In addition, sealed
radiological sources that are no longer useful may be returned to the
source manufacturer or allowed to decrease in radioactivity
concentration while in storage so that they can be disposed as a lower
level waste class. Because licensees typically do not declare their
disused (unwanted) sources as waste until they are packaged and ready
for shipment to a waste broker or disposal site, it will be difficult
for DOE to project when this type of waste might need disposal in a
GTCC waste disposal facility.
Another uncertainty in estimating the future quantities of GTCC waste
is that the volume of waste generated by a small sealed radiological
source is determined by the size of its disposal container and not by
the size of the source or number of sources in the container. Disused
sources are typically placed in 30-gallon or 55-gallon disposal drums.
The number of sources put into one drum and the packing materials used
are affected by the acceptance criteria of the disposal site. Figure 2
shows a sequence of photographs depicting source recovery project
personnel removing a 5-curie, plutonium-239/beryllium source and
repackaging it into a 55-gallon drum especially designed to meet the
acceptance criteria at WIPP. Source recovery project personnel told us
that these drums cost between $5,000 and $6,000 each. The sealed
radiological source held in pliers in the first photograph is clearly a
fraction of the size of the 55-gallon disposal drum.
Figure 2: Source Recovery Project Personnel Remove a Sealed
Radiological Source and Repackage It into a WIPP-Acceptable Disposal
Drum:
[See PDF for image]
[End of figure]
Figures 3 through 5 show photographs that illustrate the scale of
sealed radiological sources relative to their devices as well as how
the sources or their devices are packaged into more traditional
disposal drums.
Figure 3: Relative Size of a Sealed Radiological Source and Typical
Disposal Drums:
[See PDF for image]
[End of figure]
Figure 4: A Cross Section of a Nuclear Gauge, and Leveling Gauges
Returned to a Manufacturer:
[See PDF for image]
[End of figure]
Figure 5: Interior Views of Two 55-Gallon Disposal Drums, One with a
Large Opening for an Entire Disused Device and the Other with a Narrow
Pipe Opening for Only Sources:
[See PDF for image]
[End of figure]
Yet another uncertainty in projecting the future volume of GTCC waste
from sealed radiological sources is that different types of
radionuclides can comprise the sources used in a device, and, depending
on the radionuclide used, the age of the source, and how the source is
packaged for disposal, the device can fall into different classes of
waste. For example, as shown in table 4 in appendix II, six different
radionuclides can be used as the source in an industrial radiography
device. Further, the sources that can be used in this industrial
radiography device can produce non-GTCC and GTCC waste, depending in
part on how much radioactivity remains in the source when it is
disposed of and how the source is packaged. For example, a 5-curie,
cesium-137 sealed radiological source that is used in a device might
fall into a GTCC waste class when packaged if little of the source is
depleted; but once it becomes unwanted and then packaged in a 55-gallon
disposal drum with nonradioactive filler material, it might fall into
the non-GTCC waste class because its radioactivity, as averaged over
the entire volume of the drum, would be lower.
DOE Expanded the Scope of Its Source Recovery Project to Include Non-
GTCC Waste, Which Could Increase Project Expenditures:
DOE has expanded its source recovery efforts to include all sealed
radiological sources that could present a threat, a change that could
increase project expenditures. DOE's source recovery project now
includes, among other activities, the recovery and commercial disposal
of non-GTCC waste from unwanted sealed radiological sources that pose a
health, safety, security, or environmental threat. The recovery and
commercial disposal of more of these types of sealed radiological
sources from licensees that cannot afford to dispose of them today, in
addition to the recovery of higher radioactive sources, is likely to
increase DOE project expenditures. Further, DOE may need to recover
even more non-GTCC waste from unwanted sealed radiological sources in
the future if licensees in many states lose access to the only
commercial low-level radioactive waste disposal site where they can
currently dispose of higher radioactive non-GTCC waste (classes B and C
waste). This increased recovery of non-GTCC waste from sealed
radiological sources will place greater demands on source recovery
project expenditures because of impediments to DOE's recouping recovery
costs from licensees that could otherwise cover their source disposal
costs if there were disposal availability. In the absence of access to
commercial disposal, DOE anticipates the need to indefinitely store the
recovered non-GTCC waste until a commercial disposal option becomes
available. DOE's current policy does not include using DOE sites to
permanently dispose of this waste because, among other reasons, it does
not want to undermine the authority the Congress gave to the states to
provide disposal availability for non-GTCC waste.
DOE Has Recovered and Commercially Disposed of Some Non-GTCC Waste:
The expanded scope of the source recovery project now includes, among
other activities, the collection and commercial disposal of non-GTCC
waste from unwanted sealed radiological sources that pose a health,
safety, security, or environmental threat.[Footnote 27] Responsibility
for the safe management and disposal of these radioactive materials is
normally held by those entities that NRC or the Agreement States
license to possess and use these materials. However, in some cases,
licensees are unable to (1) ensure the safe and secure use of these
materials or (2) cover the disposal costs of their unwanted sealed
radiological sources. For example, according to the source recovery
project leader, at the request of NRC, DOE commercially disposed of its
first significant quantities of non-GTCC waste during fiscal year 2004.
Source recovery project personnel collected 443 unwanted sealed
radiological sources (containing cesium-137, cobalt-60, or radium-226)
from a bankrupt firm in Pennsylvania and commercially disposed of most
of them at the Barnwell, South Carolina, disposal site. In commenting
on a draft of this report, DOE provided examples of other non-GTCC
waste from sealed radiological sources that it had recovered.
Under the expanded scope of the source recovery project, DOE has
developed a priority scheme for deciding which sources to recover and
when to do so. According to the director of DOE's Office of Global
Radiological Threat Reduction, DOE has been working with the Department
of Homeland Security and other agencies, in addition to NRC, to
determine the sources that should receive the highest priority for
recovery, including those that when disposed of would not be considered
GTCC waste. In addition, the manager of DOE's U.S. Radiological Threat
Reduction Program told us that DOE and NRC are also in the process of
revising the 1999 memorandum of understanding that defined the
responsibilities of each agency with respect to the problem of unwanted
and uncontrolled sealed radiological sources to better reflect current
DOE recovery practices. The source recovery project leader provided us
with an initial priority ranking scheme for recovering sources that is
used by DOE, as well as some other factors that DOE considers. The
initial ranking involves combining three factors into an overall risk
ranking for each licensee site that contains sealed radiological
sources. These factors include the level of security over the source at
a licensee site, the total quantity of radioactive material present,
and the quantity of radioactive material in any single sealed
radiological source to a licensee site. Other factors that DOE
considers when prioritizing sources at recover include the opportunity
of recovering additional unwanted sealed radiological sources that
source recovery personnel may discover during their visit at a licensee
site. For example, the source recovery project leader told us that if
team members come across vulnerable sealed radiological sources of
lesser radioactivity at a location where they are recovering higher
radioactive sources, they will collect them as well.
Recovery of More Non-GTCC Waste from Sealed Radiological Sources Could
Increase Project Expenditures Because DOE Cannot Recoup Recovery Costs:
DOE has already incurred additional expenses to recover and
commercially dispose of non-GTCC waste from unwanted sealed
radiological sources. It cost DOE approximately $581,000 to recover
hundreds of these sources that had accumulated at a bankrupt firm in
Pennsylvania and to commercially dispose of them. The Barnwell disposal
site received 15 of the 16, 55-gallon and 30-gallon drums of this non-
GTCC waste and charged DOE a $1,650 per-cubic-foot disposal fee. For
example, the disposal fee and container cost for just 1, 55-gallon
disposal drum holding 130 of the recovered cesium-137 sealed
radiological sources cost DOE about $21,000, not including labor,
transport, and other costs. Additional DOE recovery of non-GTCC waste
from licensees that currently need to store their sources and other
waste because they do not want to or cannot pay these high disposal
fees may be necessary in the future. According to the deputy director
of DOE's Office of Global Radiological Threat Reduction, because of the
cost involved, encouraging those licensees that have sealed
radiological sources to dispose of them properly has proven difficult,
particularly with entities that only have a few sources. NRC can impose
fines as high as three times the cost of commercial disposal on a
licensee that fails to properly dispose of radioactive
material.[Footnote 28] However, a senior NRC official has publicly
acknowledged the difficulty that licensees with only a few unwanted
sources have in finding a cost-effective means for disposing of them.
DOE is currently impeded from recouping more of its recovery and
storage costs for GTCC waste as well as any non-GTCC wastes that it may
need to recover. Regarding GTCC waste, since DOE issued its 1987 report
on how it planned to address its responsibilities under the Low-Level
Radioactive Waste Policy Act of 1980, as amended, no specific action
has been taken to identify a different method of funding the source
recovery project, other than through the appropriations process.
According to the manager of DOE's U.S. Radiological Threat Reduction
Program, DOE has been unable to establish a standard fee for recovering
unwanted sealed radiological sources from licensees because existing
cost recovery mechanisms require the department to know both the number
of years that these sources will be stored and the cost of their
disposal before setting a fee, which is not currently possible.
Regarding non-GTCC waste, the sources recovered to date were primarily
from a commercial firm that had gone bankrupt and did not have the
necessary funds to cover the cost of disposing of its sources. DOE had
to cover the recovery and commercial disposal costs because there was
no other source of funding. One of the reporting requirements for the
task force on radiation source protection and security, required under
the Energy Policy Act of 2005, is to provide recommendations for
appropriate regulatory and legislative changes for the establishment
of, or modification to, a national system (including user fees and
other methods) to provide for the proper disposal of sealed
radiological sources under the act.
DOE May Need to Recover and Dispose of More Non-GTCC Waste If Licensees
Have No Disposal Option, Further Increasing Demands on Project
Expenditures:
In the future, DOE may have to recover more non-GTCC waste from sealed
radiological sources if licensees that are forced to store their
unwanted sources because they have no access to a disposal site. As we
reported in June 2004, if South Carolina follows through with plans to
restrict access to the Barnwell disposal site to only the three member
states of the Atlantic Compact by mid-2008, and if no disposal
alternative for the more highly radioactive non-GTCC waste (classes B
and C waste) is developed, licensees in 36 states that are presently
allowed to use this site will need to store more of their unwanted
radioactive materials. Although NRC does not place time limits on the
storage of radioactive materials as long as they are safe and secure,
greater quantities and longer periods of storage, particularly of
unwanted sealed radiological sources, will likely increase safety and
security risks. In January 2002, NRC sent a letter to DOE requesting
that the source recovery project take actions to recover registered
unwanted sealed radiological sources because the possession and storage
of these sources with no GTCC waste disposal outlet represented a
potential health and safety threat. Regarding non-GTCC waste from
unwanted sealed radiological sources, the manager of DOE's U.S.
Radiological Threat Reduction Program told us that DOE will likely need
to increase the recovery of these sources if licensees have no
commercial disposal option for this waste. Domestic and international
experts contend that the lack of disposal availability for unwanted
sealed radiological sources can increase their risk of abandonment,
misplacement, and theft. For example, the Health Physics
Society[Footnote 29] stated that the lack of a GTCC and non-GTCC waste
disposal option for unwanted sealed radiological sources that pose
security and public health concerns will continue to increase the
number of orphan sources. Further, IAEA has reported that disused
(unwanted) sources represent the largest pool of vulnerable and
potential orphan sources.[Footnote 30] If DOE were to begin recovering
more non-GTCC waste from unwanted sealed radiological sources, even
greater demands will be placed on DOE recovery project resources if DOE
cannot recoup some of its recovery costs from licensees. While DOE is
justified in covering the recovery and commercially disposal cost of
the non-GTCC waste it has collected from licensees that could not
afford to dispose of it themselves, the department may be able to
recoup some of its costs in the future from licensees that could afford
the cost of disposal if it were commercially available.
It is difficult to estimate the budgetary impact on DOE if there were a
need to increase the recovery of unwanted sealed radiological sources
from licensees that have no access to a commercial disposal site for
their higher radioactive non-GTCC waste. One reason for this situation
is the lack of information on the number of sources in storage that
might need DOE recovery. As we reported August 2003, there is no
national database on the quantities of sealed radiological sources in
storage. Moreover, there is no national database that tracks the
storage of any low-level radioactive waste. Given the lack of national
data on how much waste is generated annually, the disposal data from
low-level radioactive waste disposal operators can only provide an
indication of the quantity of disused or unwanted sealed radiological
sources and other waste that might need storage each year in the
absence of disposal availability. Nevertheless, we found that between
2001 and 2004, the Barnwell disposal site disposed of, on average,
31,150 cubic feet of the higher radioactive non-GTCC waste (classes B
and C waste), of which about 588 cubic feet, or about 2 percent of the
total, was derived from disused sealed radiological sources.[Footnote
31] Approximately one-half of the sealed radiological source waste
(about 56 percent) came from private industry, followed by government
agencies (about 25 percent), colleges and universities (about 11
percent), and medical waste (about 4 percent). If DOE recovered, took
title of, and commercially disposed of all non-GTCC waste from sealed
radiological sources that are sent to the Barnwell disposal site
annually, it might cost DOE approximately $1 million a year just to
cover the disposal cost at the current $1,700 cubic foot disposal fee
rate. However, until DOE has better information on the number of
sources that may need to be recovered and future disposal costs,
including recovery, packaging, transport, and other costs, it will be
difficult to accurately estimate future costs of recovering non-GTCC
waste.
Lack of Commercial Disposal Availability Could Heighten Interest in
Using DOE Sites for Disposal:
If licensees lose access to commercial disposal sites for their higher
radioactive non-GTCC waste in the future, DOE will likely have to
recover more of this waste from unwanted sealed radiological sources,
which could heighten interest in using DOE sites for disposal of these
wastes. The manager of DOE's U.S. Radiological Threat Reduction Program
told us that although DOE is not legally prohibited from permanently
disposing of, at DOE sites, the recovered non-GTCC waste for which it
has taken title, it would not want to do so. This DOE manager said that
on the basis of current policy, DOE would indefinitely store any
recovered non-GTCC waste from unwanted sealed radiological sources at
its sites until commercial disposal is available or DOE receives other
congressional guidance. The DOE manager provided three reasons to
justify this current policy. First, DOE does not want to undermine the
responsibility given by the Congress to the states to provide disposal
availability for non-GTCC waste under the Low-Level Radioactive Waste
Policy Act of 1980, as amended. Second, DOE is not allowed to compete
with commercial waste companies for the disposal of non-GTCC waste.
Finally, DOE does not want to dispose of the relatively small quantity
of recovered non-GTCC waste at its sites because this might set a
precedent for disposing of all non-GTCC waste that does not have a
commercial disposal pathway. However, in lieu of storing this non-GTCC
waste, this DOE manager suggested that DOE could, under emergency
access provisions, approach the regulatory bodies that have
jurisdiction over commercial disposal sites to obtain disposal access.
Despite DOE's current policy regarding what it would do in the future
with recovered non-GTCC waste if there were no commercial disposal
availability, there have been calls to consider using DOE sites for the
disposal of this waste. Our June 2004 report[Footnote 32] discussed
some issues that would need to be resolved to use DOE sites for this
waste, including the feasibility of DOE's accepting all non-GTCC waste,
the responsibility for paying for the disposal of this waste, and the
licensing and regulatory responsibilities covering its disposal.
DOE Lacks Information to Better Identify Unwanted Sealed Radiological
Sources That May Need Recovery:
DOE lacks information that would assist in its efforts to identify and
recover unwanted sealed radiological sources that pose a safety or
security risk. Although DOE maintains an inventory of recovered sealed
radiological sources and sources registered for future recovery,
neither DOE nor any other government agency has centrally tracked the
number of sources in the United States or the number of unwanted
sources in storage at licensee sites across the country. Under the
current regulatory structure, NRC and Agreement states only know the
authorized uses and maximum quantities allowed for each licensee, not
what they actually possess. As a result, DOE has no means of
determining the actual number of sealed radiological sources that may
require recovery in the future. NRC is currently developing a national
source tracking system to, among other things, identify the possession
and movement of some high-risk sealed radiological sources. However, as
presently designed, this tracking system lacks information that DOE
might find useful in planning and budgeting for the recovery of
unwanted sealed radiological sources and their eventual disposal.
DOE Has Information on Sealed Radiological Sources Already Recovered
and Limited Information on Those to Be Recovered:
The source recovery project maintains its own inventory of sealed
radiological sources that have been recovered and are in storage, and
those that licensees or NRC have asked DOE to recover. According to the
source recovery project team leader, the accuracy of the information on
a sealed radiological source in this inventory improves from when a
licensee initially registers the source; to when source recovery
personnel have follow-up conversations with the licensee to clarify the
recovery request for the source; to when the source recovery project
team actually visits the site to physically inspect the source, record
its serial number, and package it for disposal. The source recovery
project team leader told us that the information on sources initially
registered is less accurate because the licensee may not know anything
about their source, or a licensee might inadvertently provide incorrect
information about the source, such as its radionuclide and
radioactivity concentration. Once recovered, the information in the
source recovery project inventory includes the type of radionuclide,
serial number, size, radioactivity concentration, and method of
packaging for storage or disposal. The source recovery project team
leader told us that this inventory is designed to assist in
administrative planning, scheduling and prioritizing recoveries,
tracking shipments, and documenting storage or disposal locations.
Information on the recovered sealed radiological sources in DOE's
possession is then integrated into DOE's Radiological Source Registry
and Tracking System. This departmentwide inventory system was
established in November 2003, in response to a recommendation of the
DOE/NRC Interagency Working Group on Radiological Dispersal Devices.
The tracking system is managed by DOE's Office of Plutonium, Uranium,
and Special Materials Inventory and maintained at Sandia National
Laboratories. DOE designed its system to help (1) monitor the safety
and security of all DOE-owned sealed radiological sources that meet a
certain threshold size and radioactivity concentration and (2) provide
information on the potential threat they pose. In addition to
descriptive information on the type of sealed radioactive source and
its location within the DOE complex, this tracking system also records
data on the source's status--such as whether the source is in active
use; is inaccessible and, thus, not being used; is in storage for
potential future use; or is packaged and awaiting final disposal.
DOE Cannot Determine How Many Unwanted Sealed Sources May Need
Recovery:
Because neither DOE nor any other government agency has centrally
tracked the number of sealed radiological sources in the United States
at any given time or the number of unwanted sources held by NRC and
Agreement States licensees, DOE has few available means of estimating
the quantities of sources that may need recovery in the future. Under
the current regulatory structure, NRC and the Agreement States only
have information on the authorized uses and maximum quantities of
radioactive materials licensees are allowed to possess, although each
licensee is responsible for maintaining inventories of its individual
sources. Further, the source recovery project inventory contains only
information that licensees have voluntarily provided to DOE on their
unwanted sealed radiological sources and more limited voluntary
registration of sources that may require recovery in the future. The
information on sealed radiological sources that NRC provides to DOE for
scheduling recovery only captures those sources that NRC or Agreement
States are aware of that need recovery and does not include sources
that licensees may possess that are unwanted. Consequently, neither of
these methods for obtaining information provides the kind of data that
DOE can use to estimate future quantities of sealed radiological
sources that may need recovery. According to the manager of DOE's U.S.
Radiological Threat Reduction Program, because the source recovery
project has no information on the number of sources in current use or
in storage, DOE is limited in its ability to provide useful estimates
of the quantities of sealed radiological sources that DOE might need to
recover in the future.
The Proposed National Source Tracking System Is Not Designed to Collect
Some Information That Could Be Useful to DOE:
NRC plans to develop a national source tracking system that will
register certain sealed radiological sources possessed by licensees
and/or DOE. In November 2003, NRC, in cooperation with the Agreement
States, contacted 2,600 entities licensed to possess IAEA categories 1
and 2 sources in an effort to capture for the first time national data
on the actual type, quantities, and current ownership of these sources.
Over 99 percent of these licensees voluntarily reported information
back to NRC, but only about one-half of them reported that they
possessed these sources. NRC has already conducted a follow-up survey
of a portion of these licensees, and other surveys are planned leading
up to an implementation of the national source tracking system in 2007.
Although licensees are requested to volunteer information for these
interim surveys, NRC issued a proposed rule in July 2005[Footnote 33]
that would, among other things, require licensees to provide an
inventory of their sealed radiological sources; annually verify and
reconcile their actual inventory with the information registered in the
system; and report certain transactions, such as the date of
manufacture, transfer, or disposal of their sealed radiological
sources. The Energy Policy Act of 2005 requires that NRC issue
regulations, within 1 year, establishing this mandatory tracking system
that shall be coordinated with systems established by the Department of
Transportation to track the shipment of radiation sources. Such a
tracking system must, among other things, provide for the reporting of
required information through a secure Internet connection.
As presently designed, NRC's national source tracking system will
inventory and monitor primarily IAEA categories 1 and 2 sources--the
minimum required under the 2004 IAEA Code of Conduct--despite support
from IAEA and DOE for tracking additional source categories and other
information.[Footnote 34] In its July 2003 technical document detailing
the methodology behind the IAEA source categorization scheme, IAEA
suggested that member states consider the combined radioactivity of
aggregated sealed radiological sources in one location for the purpose
of categorizing these sources on the basis of their potential to cause
harm to human health.[Footnote 35] Using this methodology, the
accumulation of enough individual IAEA category 3 sources in close
proximity to one another would yield concentrations of radioactive
material equivalent to a single IAEA category 2 source. For example,
storing 15 well-logging devices in close proximity (each well-logging
device typically contains a 2-curie, cesium-137 source, which is an
IAEA category 3 source) would be equivalent to having a 30-curie,
cesium-137 source in this location, which is an IAEA category 2 source.
Almost all of the unwanted sealed radiological sources recovered by DOE
would fall into categories below IAEA categories 1 and 2 and,
therefore, would not have been registered in the national source
tracking system as presently designed. According to the manager of
DOE's U.S. Radiological Threat Reduction Program, over 90 percent of
the sites where DOE has recovered sealed radiological sources had
quantities of lesser radioactive sources that when aggregated were
equivalent to an individual IAEA category 2 source and, thus, posed
enough of a safety and security risk to warrant their recovery. This
recovery has been justified despite the fact that the total curie level
of all the recovered IAEA category 3 sources was only about 15 percent
of the curie level of the relatively few recovered categories 1 and 2
sources, and without regard to whether the sources might or might not
have been located in close proximity at each of the licensee sites. In
a 2004 technical document, IAEA suggested that it would be beneficial
from both a safety and security viewpoint for all disused or unwanted
sealed radiological sources to be identified and to undergo proper
disposition.[Footnote 36] According to IAEA, the quality of a country's
national registry of radioactive sources will be a prime indicator of
the probability of there being vulnerable and orphan sources. History
has shown that many accidents involving orphan sources come about
because sources that are no longer in use are eventually forgotten,
with subsequent loss of control years later. Table 3 shows a breakdown
of the sealed radiological sources that DOE has recovered, by their
IAEA source category, as of June 7, 2005. As shown in the table, about
98.5 percent of these sources fall below category 2 and, therefore,
would not have been tracked in the proposed national source tracking
system.
Table 3: DOE-Recovered Sealed Radiological Sources, by Their IAEA
Source Category, as of June 7, 2005:
IAEA source category: Category 1;
Number of sources: 37;
Percentage of total sources: 0.34%;
Curies[A]: 78,984.07;
Percentage of total curies[A]: 52.68%.
IAEA source category: Category 2;
Number of sources: 129;
Percentage of total sources: 1.19%;
Curies[A]: 50,181.55;
Percentage of total curies[A]: 33.47%.
IAEA source category: Category 3;
Number of sources: 4,941;
Percentage of total sources: 45.73%;
Curies[A]: 19,540.26;
Percentage of total curies[A]: 13.03%.
IAEA source category: Categories 4 and 5;
Number of sources: 5,672;
Percentage of total sources: 52.49%;
Curies[A]: 1,233.43;
Percentage of total curies[A]: 0.82%.
IAEA source category: Uncategorized[B];
Number of sources: 27;
Percentage of total sources: 0.25%;
Curies[A]: 0.01;
Percentage of total curies[A]: 0.00%.
IAEA source category: Total;
Number of sources: 10,806;
Percentage of total sources: 100.00%;
Curies[A]: 149,939.32;
Percentage of total curies[A]: 100.00%.
Source: DOE source recovery project inventory database.
[A] A curie is a measure of the rate of radioactive decay; it is
equivalent to the radioactivity of 1 gram of radium or 37 billion
disintegrations per second.
[B] Uncategorized sources contain radionuclides that are not covered by
an IAEA source category.
[End of table]
In the proposed rule to implement a national source tracking system,
NRC states that it does not plan to include IAEA category 3 sources in
the registry at this time, but that it may consider doing so in the
future because licensees possessing a large quantity of IAEA category 3
sources could present a security concern. Although NRC contends that
reliable tracking of the accumulation of IAEA category 3 sources will
be difficult and might pose a potential burden on licensees, NRC is
seeking comments on the inclusion of these sources in its tracking
system. NRC stated in its notice of intent that one way to address the
accumulation of sources of concern would be to lower the threshold for
source tracking to include all IAEA category 3 sources, since a source
level tracking system cannot include aggregation of sources because the
sources may move in and out of the tracking system with the change of
ownership. However, in commenting on a draft of this report, NRC stated
that in lieu of the inclusion of category 3 sources in the proposed
national source tracking system at this time, its new security orders
for licensees possessing IAEA categories 1 and 2 sources do, where
appropriate, address aggregation of any sources below these two
categories, such that the net result could reach the category 2
threshold in a given physical location. Nevertheless, it does not
appear that these new security orders would apply to licensees that do
not possess IAEA categories 1 and 2 sources but still have large
accumulations of IAEA category 3 or lesser source categories.
The national source tracking system, as designed, also would not
collect other information that DOE might find useful in budgeting and
planning for source recovery and future disposal needs for GTCC waste.
Recent IAEA technical guidance states that it is important to capture
information on the frequency of use of the source in a national
registry of sealed radiological sources--for example, whether the
source is actually being used or whether it is being stored
securely.[Footnote 37] DOE already inventories such information on
sources in its possession in its Radioactive Source Registry and
Tracking System. DOE initially requested that NRC collect information
on licensees' disposal plans in its interim survey, including whether
the licensees were planning to have DOE recover their sources. NRC
included this question in its first survey of licensees but has decided
to drop it in subsequent surveys and in the design of the tracking
system, because of the low response rate to this question and because
its security regulations currently do not require licensees to report
this information. However, NRC is contemplating adding a feature to the
design of its anticipated national source tracking system that would
capture information on the long-term storage of some sealed
radiological sources, although it would be voluntary for licensees to
provide this information.
The Energy Policy Act of 2005 requires NRC to chair an interagency task
force on radiation source protection and security. Within 1 year of its
creation, the task is to prepare a report to the Congress and the
President providing recommendations for a list of additional radiation
sources that should be required to be secured as well as any necessary
modifications to the national source tracking system. In addition, the
task force is also charged with making recommendations in this report
regarding the creation of, or modification to, procedures for
improving, among other things, the security of stored sources,
including periodic audits or investigations by NRC to ensure that these
sources are properly secured and can be fully accounted for.
Conclusions:
DOE and NRC have important roles and responsibilities in ensuring the
safety and security of radiological sealed sources. The recently
enacted Energy Policy Act of 2005, among other things, adds new
requirements for both agencies, including the creation of a task force
on radiation source protection and security, chaired by NRC, and
continued recovery by DOE of unwanted sources until it provides a
disposal site for GTCC waste. The responsibilities for DOE may expand
further if licensees in most states lose access to the only disposal
site for their higher radioactive non-GTCC waste by mid-2008.
Specifically:
* Loss of access would increase the quantities of non-GTCC waste in
storage that could necessitate more recovery of this waste by DOE.
This, in turn, might lead to increased costs for DOE's source recovery
efforts. However, how much additional funding will be necessary for
this effort would be difficult to ascertain for several reasons,
including uncertainties regarding the quantity of non-GTCC waste that
might need collection.
* These increased recovery and disposal costs will be incurred by DOE
unless other mechanisms are adopted to recoup these costs, especially
from those licensees that would be able to cover them if commercial
disposal were available.
* The increasing quantities of non-GTCC waste that will not have a
commercial disposal pathway could heighten interest in using DOE sites
for the disposal of this waste.
* 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 project.
Recommendations for Executive Action:
We recommend that the Secretary of Energy and the Chairman of the
Nuclear Regulatory Commission, in collaboration with the Task Force on
Radiation Source Protection and Security, evaluate and report on:
* the cost implications of a potential expansion of DOE's recovery and
disposal of non-GTCC waste from sealed radiological sources,
* options for DOE to recoup these costs from licensees that may have no
commercial waste disposal options,
* the feasibility of disposing of this waste at DOE sites, and:
* how a national source tracking system can be designed and implemented
to improve DOE's ability to identify and track sealed radiological
sources that may need DOE recovery and disposal.
Agency Comments and Our Evaluation:
We provided a draft of this report to DOE and NRC for their review and
comment. DOE's written comments are reproduced in appendix III. DOE
stated that it generally supports the recommendations contained in this
report. More specifically, DOE commented that we had correctly reported
the department's position with respect to recouping recovery and
disposal costs; however, the department expressed some concern that
charging fees or recouping costs from licensees may inhibit them from
registering sources, leaving these excess sources at risk. We
acknowledge in the report that DOE should cover the recovery, storage,
and disposal costs of unwanted sealed radiological sources that were
previously owned by DOE. We also acknowledge the need for DOE to cover
these costs in cases where sources posing a health, safety, security,
or environmental threat are recovered from licensees that do not have
the financial means to ensure their proper disposal. Nevertheless,
given the possibility that, in most states, there may not be a
commercial disposal option available to licensees for their higher
radioactive non-GTCC waste after mid-2008, we continue to believe that
DOE and NRC should evaluate approaches to recoup recovery and disposal
costs from licensees that could otherwise afford to cover these costs
if a commercial disposal option were available. DOE also stated that,
in addition to the non-GTCC sealed source waste that we stated it
recovered and disposed, it had also recovered other sources that fall
into this waste class. We added a reference to these other sources in
the report. Regarding using DOE sites for non-GTCC waste disposal, the
department commented that we appropriately noted its current policy and
statutory responsibilities that prohibit the use of department
facilities for this purpose. DOE stated that it would continue to
identify potential commercial treatments or disposal options for any
additional non-GTCC waste that is recovered. Finally, DOE concurred
with our assessment that the proposed national source tracking system
should be improved to assist the department in identifying and
recovering unwanted sources from outside the department that pose a
potential safety and security risk. DOE stated that its Office of
Security is working with other elements of the department and NRC in
developing requirements to ensure that these unwanted sources are
adequately tracked.
NRC also provided written comments to a draft of this report, which are
reproduced in appendix IV. NRC stated that overall our report was well
written and balanced. While NRC did not specifically agree or disagree
with our four recommendations, its letter raised seven issues regarding
the proposed national source tracking system.
1. NRC stated that its tracking system would provide some information
useful to DOE. We agree that the national source tracking system might
provide some information useful to DOE in its recovery of IAEA
categories 1 and 2 sources. However, since we found that only 1.5
percent of the sources recovered by DOE as of June 7, 2005, were in
these two categories, it appears that the national source tracking
system would yield little, if any, practical benefits to DOE.
2. NRC stated that requiring the reporting of certain information that
our report asserts DOE would find useful, such as frequency of source
use, could be extremely burdensome on licensees and NRC and would yield
little, if any, practical benefits. NRC provided no support for this
contention or for why it cannot overcome these burdens as it has done
in justifying the reporting requirements proposed for licensees
possessing IAEA categories 1 and 2 sources. In addition, NRC stated in
its notice of proposed rulemaking for the national source tracking
system that most licensees already have systems in which information on
sources is maintained, and that NRC's tracking system is designed to
ease the reporting burden for these licensees. As to the comment on the
practical benefit of tracking the use of high-risk radioactive
materials, our report notes that the most vulnerable sources to
abandonment, misplacement, and theft are those that are unwanted and in
storage. Therefore, it seems reasonable to attempt to collect some
information on frequency of source use, particularly if the storage of
sources were to increase in the future in the absence of a commercial
disposal option for the higher radioactive non-GTCC waste.
3. NRC commented that our report did not accurately characterize some
issues involving IAEA category 3 sources, mainly regarding our claim
that IAEA-TECDOC-1388 suggested that category 3 sources be tracked. NRC
claimed that the IAEA document did not make this suggestion and
provided some passages from the document to support its position. We
believe that NRC's comments in this regard reflect a narrow view of the
guidance provided by IAEA. For example, in IAEA's discussion of disused
(unwanted) sources in this technical document, it clearly suggests a
need to identify these sources and to gather information on their
frequency of use.
"Disused sources represent the largest pool of vulnerable and potential
orphan sources. History has shown that many accidents involving orphan
sources come about because sources that are no longer in use are
eventually forgotten, with subsequent loss of control years later. To
this end, it is beneficial from both a safety and security viewpoint
for all disused sources to be identified [emphasis added] and to
undergo proper disposition—. Licensees are discouraged from proper
disposal of disused sources by the cost involved, by the bureaucracy of
doing so, or by the lack of an available disposal option—. It is clear
that information needs to be gathered by those developing a national
strategy regarding the status of at least all [emphasis added] Category
1, 2 and 3 sources on the licensee's inventory or national registry so
that appropriate decisions can be made regarding them. Generally, this
will involve asking the licensee or owner of the source about its
frequency of use [emphasis added]."
4. In support of its decision not to track IAEA category 3 sources at
this time, NRC drew attention to its other regulatory efforts,
especially its new security orders for some licensees that possess IAEA
categories 1 and 2 sources. NRC stated that, where appropriate, these
security orders address aggregation of any sources (IAEA category 3
sources and below) such that the net result could reach the category 2
source threshold in a given physical location. Despite these security
orders, NRC's source tracking system would not include IAEA category 3
sources and below. However, NRC stated in its notice of proposed
rulemaking for the national source tracking system, that it is seeking
comments on the inclusion of IAEA category 3 sources in the registry
because licensees possessing large quantities of these sources could
present a security concern.
5. NRC pointed out that, as we reported, the actions it is taking to
track IAEA categories 1 and 2 sources are consistent with the IAEA Code
of Conduct and the Energy Policy Act of 2005. However, NRC failed to
mention, as we do in our report, that this legislation also directs NRC
to chair an interagency task force to provide a report, within 1 year,
to the Congress and the President with recommendations for, among other
things, additional radiation sources that should be required to be
secured as well as any modifications necessary to the national source
tracking system. We believe that our report provides ample support for
areas where NRC, in collaboration with DOE and other federal agencies,
might consider modifying the design of the national source tracking
system to better assist DOE in planning and budgeting for the recovery
and disposal of unwanted sealed radiological sources.
6. NRC commented that it does not matter that almost all of the sources
that DOE has recovered are below IAEA categories 1 and 2 sources
because, according to NRC, the greatest risk from a source is its
radioactivity level. The radioactivity of an individual source is
clearly one measure of its potential safety and security risk. However,
as our report notes, DOE's recovery efforts, often at the request of
NRC, are not solely dictated by the radioactivity of an individual
source, but more broadly the health, safety, security, or environmental
threat posed by the aggregated radioactivity of many unwanted sources
that are typically in storage at licensee sites around the country. Our
report also notes that unwanted sources in storage tend to be the most
vulnerable to abandonment, misplacement, and theft despite requirements
that licensees keep track of the radioactive materials they possess.
Some of the lesser radioactive sources are frequently found by DOE to
be kept in quantities where their aggregated radioactivity would be
equivalent to an IAEA category 2 source that would present a security
concern. These lesser radioactive sources also may be more susceptible
to inadvertent loss, which has already led in some cases to radiation
exposure, high decontamination costs, and public panic. IAEA
acknowledged in its Code of Conduct that its categorization of high-
risk radiological sources is based on health effects and does not fully
take into account the range of impacts that could result from accidents
or malicious acts involving radioactive sources.
7. NRC stressed in its comments that DOE, through its representatives
on NRC working groups and committees developing the national source
tracking system, has had the opportunity to provide input on the design
of the system and the potential usefulness of the system to assist its
source recovery efforts. Regardless of DOE's opportunities to provide
input to NRC, DOE officials raised concerns to us during the course of
our work about the usefulness of NRC's source tracking system.
Furthermore, in commenting on our draft report, DOE stated that there
is a need for a more rigorous national-level tracking capability to
assist the department in identifying and recovering unwanted sources.
We incorporated technical changes in this report, where appropriate, on
the basis of detailed comments provided by both agencies.
We will send copies of this report to the appropriate congressional
committees. 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 have 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 who made major contributions
to this report are listed in appendix V.
Sincerely yours,
Signed by:
Gene Aloise, Director:
Natural Resources and Environment:
[End of section]
Appendixes:
Appendix I: Scope and Methodology:
In our review, we examined (1) the status of the Department of Energy's
(DOE) efforts to recover unwanted sealed radiological sources and
develop a disposal option for greater-than-class C (GTCC) waste, (2)
DOE actions taken to recover and dispose of unwanted non-GTCC waste
from sealed radiological sources, and (3) the extent to which DOE can
identify and track unwanted sealed radiological sources for recovery
and disposal. To better understand these issues, we met with officials
at DOE, the National Nuclear Security Administration, and the Nuclear
Regulatory Commission (NRC), and we visited the office of DOE's source
recovery project at Los Alamos National Laboratory and observed
laboratory personnel recovering unwanted sealed radiological sources
from a university. We also interviewed officials at nonfederal
organizations, including the Health Physics Society, the Organization
of Agreement States, and the Conference on Radiation Control Program
Directors (CRCPD), as well as some recognized experts in the field. We
also met with representatives from commercial entities that are
licensed to possess high-risk radioactive sources and state regulatory
officials in California and Ohio.
More specifically, to examine the status of DOE efforts to recover
unwanted sealed radiological sources and develop a disposal option for
GTCC waste, we interviewed DOE officials from the U.S. Radiological
Threat Reduction Program, Office of Environmental Management, and
Office of Security. We reviewed applicable statutes, regulations, and
agency guidance as well as relevant DOE and NRC studies, reports,
documents, and agency plans. We obtained information from the source
recovery project inventory database to determine the number and type of
sources recovered as of June 7, 2005. To determine the reliability of
these data, we first asked officials a series of data reliability
questions that addressed areas such as data entry, data access, quality
control procedures, and data accuracy and completeness. We also
inspected data records, reviewed manuals and documents relating to DOE
data collection and verification methods, and interviewed DOE
officials. We asked follow-up questions as necessary. In consultation
with a GAO expert in research methodology, we analyzed the officials'
responses for relevant weaknesses in data reliability that would make
their data unusable for our analysis and reporting purposes. On the
basis of these efforts, we determined that these data were sufficiently
reliable for summarizing volumes of recovered sealed radiological
sources.
We also sought a better understanding of how sealed radiological
sources are classified as waste. We developed a structured interview
guide to collect information from commercial waste brokers that possess
GTCC and non-GTCC waste from sealed radiological sources. This
interview guide asked questions on areas such as the wastes these
brokers often collect and the potential waste classes of common types
of sealed radiological source devices. Because the practical
difficulties of developing and administering a structured interview
guide may introduce errors--resulting from how a particular question is
interpreted, for example, or from differences in the sources of
information available to respondents in answering a question--we
included steps in the development and administration of the structured
interview guide for the purpose of minimizing such errors. We pretested
the instrument with three commercial waste brokers by telephone and
modified it as appropriate to reflect questions and comments received
during the pretests.
To determine which commercial waste brokers to interview, we first used
a list of commercial waste brokers compiled by CRCPD's National Orphan
Radioactive Material Disposition Program. This list contained 18 waste
brokers that met the CRCPD criteria of being in good standing with
CRCPD and serving more than 1 million customers, serving non-DOE
customers, or serving more than one state. However, because this list
is not comprehensive and there is no single source listing of
commercial waste brokers, we also asked each broker we interviewed for
the names of additional brokers who could provide useful information or
insights into these issues. We continued this expert referral technique
until the references we received became repetitive. In all, we used our
structured interview guide to interview a nonprobablility sample of 12
commercial waste brokers in various geographical locations.[Footnote
38] We then used the results of these structured interviews to create a
table summarizing common sealed radiological sources devices and their
potential waste class (see app. II). We shared preliminary drafts of
this table with experts at DOE and NRC and with leading scientists in
the field of sealed radiological source security from nonfederal
organizations, such as the Monterrey Institute of International Studies
and the Low-Level Waste Forum. We received and incorporated their
comments as appropriate on the structure and contents of the table. On
the basis of this process, we determined that these data were
sufficiently reliable for the purposes of this report.
To examine the actions DOE has taken to recover and dispose of unwanted
sealed radiological sources, we interviewed source recovery project
personnel and officials from the U.S. Radiological Threat Reduction
Program. We also conducted interviews with representatives from
nonfederal entities, including the Monterrey Institute of International
Studies, the Health Physics Society, CRCPD, the National Research
Council, and the Council on Foreign Relations. We discussed with these
agency officials and representatives the likelihood of DOE's needing to
recover more non-GTCC waste from unwanted sealed radiological sources
in the future if the Barnwell, South Carolina, disposal site restricts
access for licensees in 36 states by mid-2008 as planned. To obtain a
better understanding of how much non-GTCC waste might be stored if
licensees in these states are denied disposal access for this waste, we
gathered information on the quantity of non-GTCC waste disposed at the
two commercial disposal sites that can accept classes B and C waste in
Richland, Washington, and Barnwell, South Carolina, between 2001 and
2004. To determine the reliability of these data, we first asked
disposal operators a series of data reliability questions that
addressed specific areas, such as data entry, data access, quality
control procedures, and data accuracy and completeness. We added follow-
up questions as necessary. In consultation with a GAO expert in
research methodology, we analyzed their responses for relevant
weaknesses in data reliability that would make their data unusable for
our analysis and reporting purposes. On the basis of these efforts, we
determined that these data were sufficiently reliable for summarizing
volumes of disposed waste at these disposal sites.
To determine the extent to which DOE can identify and track unwanted
sealed radiological sources for recovery and disposal, we interviewed
DOE and NRC officials regarding the scope, capabilities, and
limitations of their existing databases for tracking these sources. We
reviewed past estimates of the number of sealed radiological sources in
the United States, including the scope and methodologies used to create
these estimates. To examine NRC efforts to develop a national source
tracking system for certain sealed radiological sources, we interviewed
NRC and DOE officials who participated in the system's initial
formulation. We reviewed planning and management documents, including
related NRC submissions to the Office of Management and Budget, NRC's
business case analyses, and the proposed rule for implementing a
national source tracking system. We also reviewed the survey instrument
NRC used to populate the interim database. Finally, we interviewed
state officials from Illinois, New York, Ohio, and Oregon to determine
whether any states currently track sealed radiological sources and
gathered these officials' views on the need for a national source
tracking system.
We conducted our review between June 2004 and September 2005 in
accordance with generally accepted government auditing standards.
[End of section]
Appendix II: Selected Sealed Radiological Source Devices and Their
Potential Waste Classes:
Table 4 presents selected common devices that utilize sealed
radioactive sources and the NRC waste classes in which sources from
these devices might be disposed. This table shows the variability in
the possible sources used in devices, their relative risks according to
the International Atomic Energy Agency (IAEA) categorization scheme,
and the range of waste classes associated with the sources that could
be used in these devices. The radionuclides and the ranges of
radioactivity listed next to each device are presented for illustrative
purposes--each device might use one of these radionuclides in one or
more sources. The IAEA source category corresponds to each radionuclide
and radioactivity range, based on an IAEA technical document, as noted.
The potential waste classes are associated with each device and not
with the specific radionuclides that might be in these devices. In
other words, not all radionuclides that could be used in a source
within a device produce the range of waste classes associated with the
device.
Table 4: Selected Sealed Radiological Source Devices and Their
Potential Waste Classes:
Device: Radioisotopic thermoelectric generators:
Radionuclide: Strontium-90;
Approximate initial curie[A] range of radioactivity per device or
application: 9,000 - 680,000;
IAEA source category[B]: 1,2;
Potential NRC waste class[B] when disposed: B/C, GTCC.
Device: Radioisotopic thermoelectric generators:
Radionuclide: Plutonium-238;
Approximate initial curie[A] range of radioactivity per device or
application: 28 - 280;
IAEA source category[B]: 2.
Device: Panoramic irradiators[C]:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 500,000 - 5,000,000;
IAEA source category[B]: 1;
Potential NRC waste class[B] when disposed: A, B/C.
Device: Self-shielded irradiators[C]:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 2,500 - 42,000;
IAEA source category[B]: 1,2;
Potential NRC waste class[B] when disposed: B/C, GTCC.
Device: Self-shielded irradiators[C]:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 1,500 - 50,000;
IAEA source category[B]: 1.
Device: Blood-tissue irradiators[C]:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 1,000 - 12,000;
IAEA source category[B]: 1,2;
Potential NRC waste class[B] when disposed: B/C, GTCC.
Device: Blood-tissue irradiators[C]:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 1,500 - 3,000;
IAEA source category[B]: 1.
Device: Gamma knife (fixed, multibeam teletherapy)[C]:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 4,000 - 10,000;
IAEA source category[B]: 1;
Potential NRC waste class[B] when disposed: B/C.
Device: Teletherapy:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 1,000 - 15,000;
IAEA source category[B]: 1;
Potential NRC waste class[B] when disposed: B/C.
Device: Teletherapy:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 500 - 1,500;
IAEA source category[B]: 2.
Device: Calibration sources:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: .55
- 16,000;
IAEA source category[B]: 1,2,3,4;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Calibration sources:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 1.5 - 14,000;
IAEA source category[B]: 1,2,3,4.
Device: Calibration sources:
Radionuclide: Americium-241;
Approximate initial curie[A] range of radioactivity per device or
application: 1 - 25;
IAEA source category[B]: 2,3,4.
Device: Calibration sources:
Radionuclide: Plutonium-239/Beryllium;
Approximate initial curie[A] range of radioactivity per device or
application: 2 - 25;
IAEA source category[B]: 2,3.
Device: Calibration sources:
Radionuclide: Strontium-90;
Approximate initial curie[A] range of radioactivity per device or
application: 0.05 - 2;
IAEA source category[B]: 4.
Device: Industrial radiography:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 11 - 330;
IAEA source category[B]: 2;
Potential NRC waste class[B] when disposed: A, B/C, GTCC[D].
Device: Industrial radiography:
Radionuclide: Iridium-192;
Approximate initial curie[A] range of radioactivity per device or
application: 5 - 290;
IAEA source category[B]: 2,3.
Device: Industrial radiography:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 5 - 12;
IAEA source category[B]: 3.
Device: Industrial radiography:
Radionuclide: Selenium-75;
Approximate initial curie[A] range of radioactivity per device or
application: 80;
IAEA source category[B]: 2.
Device: Industrial radiography:
Radionuclide: Ytterbium-169;
Approximate initial curie[A] range of radioactivity per device or
application: 2.5 - 20;
IAEA source category[B]: 3,4.
Device: Industrial radiography:
Radionuclide: Thulium-170;
Approximate initial curie[A] range of radioactivity per device or
application: 20 - 200;
IAEA source category[B]: 4.
Device: Fixed industrial gauges (level, dredger, conveyor, blast
furnace, and spinning pipe):
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 0.1
- 40;
IAEA source category[B]: 2,3,4;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Fixed industrial gauges (level, dredger, conveyor, blast
furnace, and spinning pipe):
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 0.1 - 20;
IAEA source category[B]: 2,3,4.
Device: Fixed industrial gauges (level, dredger, conveyor, blast
furnace, and spinning pipe):
Radionuclide: Californium-252;
Approximate initial curie[A] range of radioactivity per device or
application: 0.037;
IAEA source category[B]: 4.
Device: Well-logging sources:
Radionuclide: Americium-241/Beryllium;
Approximate initial curie[A] range of radioactivity per device or
application: 0.5 - 70;
IAEA source category[B]: 2,3,4;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Well-logging sources:
Radionuclide: Radium-226;
Approximate initial curie[A] range of radioactivity per device or
application: 20;
IAEA source category[B]: 2.
Device: Well-logging sources:
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 0.2 -10;
IAEA source category[B]: 2, 3.
Device: Well-logging sources:
Radionuclide: Plutonium-238/Beryllium;
Approximate initial curie[A] range of radioactivity per device or
application: 5 - 70;
IAEA source category[B]: 2, 3.
Device: Well-logging sources:
Radionuclide: Tritium;
Approximate initial curie[A] range of radioactivity per device or
application: 1 - 20;
IAEA source category[B]: 5.
Device: Well-logging sources:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 0.5 - 20;
IAEA source category[B]: 3,4.
Device: Well-logging sources:
Radionuclide: Californium-252;
Approximate initial curie[A] range of radioactivity per device or
application: 0.027 - 1.61;
IAEA source category[B]: 3,4.
Device: Brachytherapy (high/medium and low dose rate):
Radionuclide: Cobalt-60;
Approximate initial curie[A] range of radioactivity per device or
application: 1 - 20;
IAEA source category[B]: 2,3;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Brachytherapy (high/medium and low dose rate):
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 0.01 - 8;
IAEA source category[B]: 3,4,5.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Iridium-192;
Approximate initial curie[A] range of radioactivity per device or
application: 0.02 - 15;
IAEA source category[B]: 3,4,5.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Radium-226;
Approximate initial curie[A] range of radioactivity per device or
application: 0.005 - 0.05;
IAEA source category[B]: 4,5.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Iodine-125;
Approximate initial curie[A] range of radioactivity per device or
application: 0.005 - 1.3;
IAEA source category[B]: 4,5.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Gold-198;
Approximate initial curie[A] range of radioactivity per device or
application: 0.08;
IAEA source category[B]: 4.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Californium-252;
Approximate initial curie[A] range of radioactivity per device or
application: 0.083 - 0.54;
IAEA source category[B]: 3,4.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Strontium-90;
Approximate initial curie[A] range of radioactivity per device or
application: 0.02 - 0.12;
IAEA source category[B]: 4,5.
Radionuclide: Ruthenium/Rhodium-106;
Approximate initial curie[A] range of radioactivity per device or
application: 0.00022 - 0.0006;
IAEA source category[B]: 5.
Device: Brachytherapy (high/medium and low dose rate): Radionuclide:
Palladium-103;
Approximate initial curie[A] range of radioactivity per device or
application: 0.03 - 0.056;
IAEA source category[B]: 5.
Device: Pacemakers:
Radionuclide: Plutonium-238;
Approximate initial curie[A] range of radioactivity per device or
application: 2.9 - 8;
IAEA source category[B]: 3;
Potential NRC waste class[B] when disposed: B/C, GTCC.
Device: Research reactor startup source:
Radionuclide: Americium-241/Beryllium;
Approximate initial curie[A] range of radioactivity per device or
application: 2 - 5;
IAEA source category[B]: 3;
Potential NRC waste class[B] when disposed: B/C, GTCC.
Device: Portable gauges (moisture detectors, density and
moisture/density)[C]:
Radionuclide: Americium-241/Beryllium;
Approximate initial curie[A] range of radioactivity per device or
application: 0.01 - 3;
IAEA source category[B]: 3,4,5;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Portable gauges (moisture detectors, density and
moisture/density)[C]:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 0.008 - 0.011;
IAEA source category[B]: 5.
Device: Portable gauges (moisture detectors, density and
moisture/density)[C]:
Radionuclide: Radium-226;
Approximate initial curie[A] range of radioactivity per device or
application: 0.002 - 0.005;
IAEA source category[B]: 5.
Device: Portable gauges (moisture detectors, density and
moisture/density)[C]:
Radionuclide: Californium-252;
Approximate initial curie[A] range of radioactivity per device or
application: 0.00003 - 0.00007;
IAEA source category[B]: 5.
Device: Static eliminators:
Radionuclide: Americium-241;
Approximate initial curie[A] range of radioactivity per device or
application: 0.03 - 0.11;
IAEA source category[B]: 4;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Static eliminators:
Radionuclide: Polonium-210;
Approximate initial curie[A] range of radioactivity per device or
application: 0.03 - 0.11;
IAEA source category[B]: 4.
Device: Thickness/fill-level gauges:
Radionuclide: Krypton-85;
Approximate initial curie[A] range of radioactivity per device or
application: 0.05 - 1;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Thickness/fill-level gauges:
Radionuclide: Strontium-90;
Approximate initial curie[A] range of radioactivity per device or
application: 0.01 - 0.2;
IAEA source category[B]: 5.
Device: Thickness/fill-level gauges:
Radionuclide: Americium-241;
Approximate initial curie[A] range of radioactivity per device or
application: 0.012 - 0.6;
IAEA source category[B]: 4,5.
Device: Thickness/fill-level gauges:
Radionuclide: Cesium-137;
Approximate initial curie[A] range of radioactivity per device or
application: 0.05 - 0.065;
IAEA source category[B]: 4.
Device: Thickness/fill-level gauges:
Radionuclide: Promethium-147;
Approximate initial curie[A] range of radioactivity per device or
application: 0.05;
IAEA source category[B]: 5.
Device: Thickness/fill-level gauges:
Radionuclide: Curium-244;
Approximate initial curie[A] range of radioactivity per device or
application: 0.2 - 1;
IAEA source category[B]: 4.
Device: Bone densitometry:
Radionuclide: Cadmium-109;
Approximate initial curie[A] range of radioactivity per device or
application: 0.02;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: B/C, GTCC.
Device: Bone densitometry:
Radionuclide: Gadolinium-153;
Approximate initial curie[A] range of radioactivity per device or
application: 0.02 - 1.5;
IAEA source category[B]: 4,5.
Device: Bone densitometry:
Radionuclide: Iodine-125;
Approximate initial curie[A] range of radioactivity per device or
application: 0.04 - 0.8;
IAEA source category[B]: 4,5.
Device: Bone densitometry:
Radionuclide: Americium-241;
Approximate initial curie[A] range of radioactivity per device or
application: 0.027 - 0.27;
IAEA source category[B]: 4.
Device: X-ray fluorescence analyzers:
Radionuclide: Iron-55;
Approximate initial curie[A] range of radioactivity per device or
application: 0.003 - 0.14;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: X-ray fluorescence analyzers:
Radionuclide: Americium-241;
Approximate initial curie[A] range of radioactivity per device or
application: 0.004 - 0.20;
IAEA source category[B]: 4,5.
Device: X-ray fluorescence analyzers:
Radionuclide: Cadmium-109;
Approximate initial curie[A] range of radioactivity per device or
application: 0.005 - 0.15;
IAEA source category[B]: 5.
Device: X-ray fluorescence analyzers:
Radionuclide: Cobalt-57;
Approximate initial curie[A] range of radioactivity per device or
application: 0.005 - 0.04;
IAEA source category[B]: 5.
Device: Electron capture detectors:
Radionuclide: Nickel-63;
Approximate initial curie[A] range of radioactivity per device or
application: 0.005 - 0.50;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: A, B/C.
Device: Electron capture detectors:
Radionuclide: Tritium;
Approximate initial curie[A] range of radioactivity per device or
application: 0.05 - 1.0;
IAEA source category[B]: 5.
Device: Lightning preventers:
Radionuclide: Americium-241;
Approximate initial curie[A] range of radioactivity per device or
application: 0.0013 - 0.013;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: A, B/C, GTCC.
Device: Lightning preventers:
Radionuclide: Radium-226;
Approximate initial curie[A] range of radioactivity per device or
application: 0.000007 - 0.00008;
IAEA source category[B]: 5.
Device: Lightning preventers:
Radionuclide: Tritium;
Approximate initial curie[A] range of radioactivity per device or
application: 0.2;
IAEA source category[B]: 5.
Device: PET checking:
Radionuclide: Germanium-68;
Approximate initial curie[A] range of radioactivity per device or
application: 0.001 - 0.01;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: A, B/C.
Device: Mossbauer spectrometry:
Radionuclide: Cobalt-57;
Approximate initial curie[A] range of radioactivity per device or
application: 0.005 - 0.1;
IAEA source category[B]: 5;
Potential NRC waste class[B] when disposed: A, B/C.
Sources: See the note below.
Note: The primary source for the first four columns is IAEA,
Categorization of Radioactive Sources, TECDOC-1344 (Vienna, Austria:
July 2003). The primary sources for the waste classification column are
interviews we conducted with commercial low-level radioactive waste
brokers. We received comments and suggestions on drafts of this table
from nine scientists and regulators in the field and accepted revisions
as appropriate. These revisions affected roughly 30 percent of the
fields in the table, primarily those in the range of radioactivity and
waste classification columns.
[A] A curie is a measure of the rate of radioactive decay; it is
equivalent to the radioactivity of 1 gram of radium or 37 billion
disintegrations per second:
[B] See 10 C.F.R. part 61 for the NRC waste classification system.
[C] A device may utilize multiple sealed radiological sources. The
range of radioactivity per use for these devices reflects the aggregate
activity.
[D] There was unresolved disagreement between the waste brokers and
some of the regulators regarding whether industrial radiography sources
could be GTCC.
[End of table]
[End of section]
Appendix III: Comments from the Department of Energy:
Department of Energy:
National Nuclear Security Administration:
Washington, DC 20585:
SEP 01 2005:
Mr. Gene Aloise:
Director:
Natural Resources and Environment:
Government Accountability Office:
Washington, DC:
Dear Mr, Aloise:
The National Nuclear Security Administration (NNSA) appreciated the
opportunity to have reviewed the Government Accountability Office's
(GAO) draft report, GAO-05-967, "NUCLEAR SECURITY: DOE Needs Better
Infonnation to Guide Its Expanded Recovery of Sealed Radiological
Sources." We understand that the Chairman, Senate Committee on Energy
and Natural Resources requested you to examine (1) our efforts to
recover Greater-Than-Class-C (GTCC) sources and develop a disposal
option; (2) actions to recover and dispose of non-GTCC sources; and (3)
ability to identify sources for recovery and disposal.
Recovery of excess and unwanted radioactive sources is accomplished
through the Office of Defense Nuclear Nonproliferation's Office of
Global Threat Reduction. Their mission is to reduce the threat
domestically posed by a dirty bomb, or Radiological Dispersal Devices
(RDD). As the draft notes, this program has recovered over 11,000
sealed sources since 1997, including recovering 5,529 sources in 18
months from October 2002 to March 2004, as directed by Congress.
Additionally, as GAO stated, the Office of Environmental Management
(EM) has initiated actions to prepare an environmental impact statement
to assess disposal options for GTCC sealed sources and other GTCC
waste.
GAO is recommending that the Nuclear Regulatory Commission (NRC) and
the Department evaluate and report on cost implications of DOE's
recovery and disposal of non-Greater Than Class C (GTCC) sources,
options to recoup these DOE costs, feasibility of using DOE disposal
sites, and how a national source tracking system can be designed and
implemented to improve DOE's recovery and disposal efforts. NNSA
generally supports the recommendations contained in the draft report.
Addressing each in turn:
* The NRC and DOE evaluate and report on cost implications of DOE's
recovery and disposal of non-GTCC sources, options to recoup these DOE
costs, feasibility of using DOE disposal sites.
NNSA collects, stores, and disposes unwanted non-GTCC sealed sources
when warranted. However, NNSA believes that charging fees or recouping
costs from licensees may inhibit licensees from registering their
sources leaving these excess sources at risk.
NNSA has experience in recovering non-GTCC sources and has been able to
plan for these activities. In addition to the recovery of sources
mentioned in the draft report, the NNSA program that recovers excess,
unwanted sealed sources - the Office of Global Threat Reduction's U.S.
Radiological Threat Reduction Program (USRTR) - has recovered over
1,100 curies of cobalt-60, a non-GTCC radionuclide, from a university
irradiator. These sources were originally loaned to the university by
the DOE and are the property of DOE. The sources were recovered and
shipped to DOE low-level waste disposal. USRTR has also performed a
number of recoveries of non-GTCC sources where these sources were sent
to commercial disposal. In addition, in 2004, NNSA began aggressively
removing excess and unwanted gamma irradiators from 19 institutions,
including high schools and colleges, throughout the United States. This
work will be completed this summer.
With respect to charging a fee to recoup costs for non-GTCC sources,
the draft report correctly states that the Department is prohibited
from charging fees for services it cannot define or provide -
specifically a fee cannot be charged for an undetermined length of
storage time, nor can a fee be charged for disposal if such disposal is
not available to determine a cost, without specific legislation
establishing such a fee mechanism, which does not exist for the
program. USRTR was transferred from the Office of Environmental
Management to the National Nuclear Security Administration in 2003, and
a result is that the USRTR is approaching the recovery of sealed
sources as a national security issue. The USRTR ensures that excess and
unwanted sources that are of sufficient type and quantity to be a
threat for use in a dirty bomb are securely stored or disposed. USRTR
depends on licensees to voluntarily register their sources with the
program for recovery. As far as the disposal of non-GTCC sources at a
Departmental site, the draft report appropriately notes that the
current policy and statutory responsibilities do not provide for the
permanent disposal of such waste at a Department facility. However,
NNSA and EM, as appropriate will continue to work with the commercial
industry to identify potential commercial treatment or disposal options
for non-GTCC scaled sources recovered by the Department.
* How a national source tracking system can be designed and implemented
to improve DOE's recovery and disposal efforts.
USRTR has a secure web-based system for licensees to register their
excess and unwanted sources and provide detailed information about the
sources. The USRTR has successfully used this system for several years,
and licensees use it. This system is an integrated tool used for many
aspects of the program.
Additionally, Department's Office of Security (the departmental office
with responsibility for the National Source Tracking Database)
recognizes the need for a more rigorous national-level tracking
capability to assist in identifying and recovering unwanted sources
from outside the Department that pose a potential safety and security
risk. They are working with other elements of the Department and NRC in
developing requirements to ensure that these unwanted sources are
adequately tracked.
Should you have any questions related to this response, please contact
Richard Speidel, Director, Policy and Internal Controls Management. He
may be contacted at 202-586-5009.
Sincerely,
Signed by:
Michael C. Kane:
Associate Administrator for Management and Administration:
cc: Assistant Secretary for Environmental Management;
Deputy Administrator for Defense Nuclear Nonproliferation;
Senior Procurement Executive;
Director, Service Center.
[End of section]
Appendix IV: Comments from the Nuclear Regulatory Commission:
UNITED STATES:
NUCLEAR REGULATORY COMMISSION:
WASHINGTON, D.C. 20555-0001:
September 6, 2005:
Mr. Eugene E. Aloise:
Director, Natural Resources and Environment:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, D.C. 20548:
Dear Mr. Aloise:
Thank you for the opportunity to review and submit comments on the U.S.
Government Accountability Office (GAO) draft report, "Nuclear Security:
DOE Needs Better Information to Guide Its Expanded Recovery of Sealed
Radiological Sources" (GAO-05-967). The U.S. Nuclear Regulatory
Commission (NRC) appreciates the time and effort you and your staff
have taken to review this important topic.
Overall, the NRC believes the report to be well written and balanced.
One general point I would like to make is that the proposed National
Source Tracking System (NSTS) will provide information on sealed
sources which the draft report notes is currently lacking (e.g., on
page 32 of the draft report, the number of covered sources manufactured
and actually possessed by licensees, the distribution of the sources,
and their disposal). Knowing this information could permit the U.S.
Department of Energy (DOE) to at least approximate the number of
sources that DOE potentially may need to recover. On the other hand,
requiring the reporting of certain information which the draft report
asserts DOE would find useful (e.g., frequency of source use) could be
extremely burdensome on licensees and the NRC, and would yield little,
if any, practical benefit.
As written, the report does not accurately characterize a number of
issues involving category 3 sources. For example, on page 34 of the
draft report, the first paragraph states, "In a subsequent 2004
technical document, IAEA suggested that category 3 sources be included
in a national registry of sealed radiological sources" and references
"IAEA, Strengthening Control Over Radioactive Sources in Authorized Use
and Regaining Control Over Orphan Sources: National Strategies, IAEA-
TECDOC-1388 (Vienna, Austria: Feb. 2004, p. 5)." This reference does
not suggest that category 3 sources must be tracked by a national
system. Instead, the reference states that category 3 sources should be
part of the national strategy for improving control over sources. The
Code of Conduct recommends a minimum of category 1 and 2 sources to be
included in a national source registry. On page 5, IAEA-TECDOC-1388
states:
The objective of this report is to provide practical guidance to States
on the development of a national strategy for improving control over
radioactive sources, particularly dangerous sources (categories 1-3).
Part of this process involves the determination of the magnitude of the
potential problem with orphan and vulnerable sources and indeed,
whether or not a national strategy is needed.
The ultimate objective is that States will use this report to develop
and then implement a plan of action that will result in all significant
sources being managed in a safe and secure manner.
The NRC regulatory framework addressed all sources regulated by the NRC
before the adoption of the International Atomic Energy Agency (IAEA)
Code of Conduct, and it continues to do so today. The national strategy
being implemented by the NRC is a risk-informed approach that also
includes an evaluation of the adequacy of existing regulations to
provide appropriate control of sources. Based on this risk-informed
approach and regulatory review, the NRC issued orders requiring
additional security measures, particularly for the higher risk sources
in categories 1 and 2. Where appropriate, these security orders did
address aggregation of any sources (category 3 and below) such that the
net result could reach the category 2 threshold in a given physical
location.
On page 34 of the draft GAO report, it states that the NSTS will only
address the IAEA Code of Conduct category 1 and 2 sealed sources.
Although this action is consistent with the IAEA Code of Conduct and
the Energy Policy Act of 2005, limiting the NSTS to category 1 and 2
sources raises concerns by some individuals who believe that at least
category 3 sources should be included as well. For the initial NSTS
program, NRC decided not to include category 3 sources, at this time,
based on (1) an assessment that category 3 sources represent a limited
hazard as a radiological dispersal or exposure device and (2) a
potential disproportionate burden of including category 3 sources on
both the regulatory bodies and licensees. It is also important to note
that, although the NSTS will provide a national tracking system for
some sealed sources, licensees are responsible for appropriate tracking
of all sources in their possession under their licenses. However, the
notice of proposed rulemaking for the NSTS published on July 28, 2005
(70 FR 43646) acknowledged that the aggregation of category 3 sources
could present a security concern. For this reason, the notice of
proposed rulemaking specifically invites comments on including category
3 sources in the NSTS in the future. The public comment period is still
open for this proposed rule. The Commission will evaluate the public
comments received on this rulemaking, and will factor in comments from
other Federal agencies and our international contacts, before deciding
what additional action, if any, may be warranted for category 3 sources
and below.
GAO is also concerned because category 3 and below sources account for
over 98.5 percent of the total number of sources recovered to date by
DOE but would not be covered by the NSTS. The DOE source recovery
program includes orphaned sources determined to represent a risk to
public health and safety. Focusing solely on the number of sources
recovered is not a risk informed approach. The activity level of the
sources provides a measure of the greatest risk. The category 1 and 2
sources recovered by the DOE program to date account for approximately
86 percent of the total activity recovered.
I would also like to stress that DOE, through its representatives on
NRC working groups and committees developing the proposed NSTS, has had
the opportunity to provide input on the design of the system and the
potential usefulness of the system to assist it in its source recovery
program. DOE and other stakeholders will have an additional opportunity
to comment on these and other issues raised in the notice of proposed
rulemaking published July 28, 2005 (70 FR 43646).
As you are aware, the NRC and GAO staffs have had multiple exchanges
regarding the report's contents and context. These exchanges have been
very beneficial. The enclosure provides specific comments on the draft
report in addition to the matters discussed above. Should you have
questions about these additional comments or the issues raised in this
letter, please contact Ms. Melinda Malloy at (301) 415-1785, or Mr.
Lance Rakovan at (301) 415-2589.
Sincerely,
Signed by:
Luis A. Reyes:
Executive Director for Operations:
Enclosure: Additional NRC Comments on Draft GAO-05-967:
[End of section]
Appendix V: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gene Aloise (202) 512-3841:
Staff Acknowledgments:
In addition to the person named above, Casey Brown, Ryan Coles, John
Delicath, Daniel Feehan, Doreen Feldman, Susan Iott, Thomas Laetz,
Cynthia Norris, Anthony Padilla, Judy Pagano, Leslie Pollock, and
Barbara Timmerman made key contributions to this report.
(360486):
FOOTNOTES
[1] This estimate was first in J.O. Lubenau and J.G. Yusko,
"Radioactive materials in recycled metals--an update," Health Physics,
Volume 74, No. 3 (March 1998) p. 297.
[2] The Agreement States system was formed by section 274 of the Atomic
Energy Act of 1954, as amended (42 U.S.C. § 2021). This section of the
act allows NRC to relinquish certain parts of its authority to
Agreement States, of which there are 33, to license and regulate
certain radioactive materials. NRC retains regulatory responsibility
over licensees in the other 17 states, and over other activities, such
as regulation of all nuclear power plants.
[3] GAO, Nuclear Security: Federal and State Action Needed to Improve
Security of Sealed Radiological Sources, GAO-03-804 (Washington, D.C.:
Aug. 6, 2003).
[4] 10 C.F.R. § 61.55.
[5] A curie is a measure of the rate of radioactive decay; it is
equivalent to the radioactivity of 1 gram of radium or 37 billion
disintegrations per second.
[6] As a result of reactor operations, portions of the reactor barrel
and other stainless steel components near the fuel assembly become
highly radioactive. The majority of this waste is generated when
nuclear power plants are decommissioned, although some waste may result
from maintenance activities performed before decommissioning. There are
presently 103 active and 24 decommissioned nuclear power plants in the
United States.
[7] Pub. L. No. 96-573, as amended by Pub. L. No. 99-240, codified at
42 U.S.C. §§ 2021b-2021j.
[8] There are 10 compacts comprised of 43 states and 7 unaffiliated
states as well as the District of Columbia and Puerto Rico.
[9] GAO, Low-Level Radioactive Waste: Disposal Availability Adequate in
the Short Term, but Oversight Needed to Identify Any Future Shortfalls,
GAO-04-604 (Washington, D.C.: June 9, 2004).
[10] The commercial disposal site in Barnwell, South Carolina, is
available to the 3 member states of the Atlantic Compact and 36 other
states that are currently allowed to use this site for all non-GTCC
waste. The commercial disposal site in Richland, Washington, serves
only the 8 member states of the Northwest Compact and the 3 member
states of the Rocky Mountain Compact for all non-GTCC waste. A third
commercial disposal site in Utah is available to all states, except the
Northwest Compact member states, for the disposal of only class A
waste.
[11] GAO, Nuclear Nonproliferation: DOE Action Needed to Ensure
Continued Recovery of Unwanted Sealed Radioactive Sources, GAO-03-438
(Washington, D.C.: Apr. 15, 2003).
[12] Pub. L. No. 109-58, 119 Stat. 594 (2005).
[13] IAEA was established within the United Nations in 1957. IAEA works
with its member states; 138 countries, including the United States; and
multiple other partners to promote safe, secure, and peaceful nuclear
technologies.
[14] IAEA, Categorization of Radioactive Sources, TECDOC-1344 (Vienna,
Austria: July 2003). IAEA defined five categories of radioactive
sources in this 2003 document. The agency based its categorization
framework on the health effects of exposure to the radioactive
materials in the sources and did not fully take into account the range
of impacts that could result from accidents or malicious acts involving
radioactive sources.
[15] DOE/NRC Interagency Working Group on Radiological Dispersal
Devices, Radiological Dispersal Devices: An Initial Study to Identify
Materials of Greatest Concern and Approaches to Their Tracking, Tagging
and Disposal (May 2003).
[16] IAEA, Proceedings of an international conference on security of
radioactive sources, held March 10-13, (Vienna, Austria: 2003).
[17] A Joint Convention on the Safety of Spent Fuel Management and on
the Safety of Radioactive Waste Management, signed by Member States of
the IAEA, entered into force on June 18, 2001.
[18] IAEA, Radioactive Waste Management: Status and Trends--Issue No. 2
(Vienna, Austria: September 2002) p. 16.
[19] This realignment did not include transferring responsibilities for
the long-term storage and disposal of the recovered sources.
[20] H.R. Rep. No. 107-593, at 142 (2002), conference report
accompanying Pub. L. No. 107-206, Making Supplemental Appropriations
for Further Recovery From and Response to Terrorist Attacks on the
United States for the Fiscal Year Ending September 30, 2002, and for
Other Purposes.
[21] Statement of Edward G. McGinnis, Director, Office of Global
Radiological Threat Reduction, National Nuclear Security
Administration, Department of Energy, before the United States Senate,
Energy and Natural Resources Committee, September 30, 2004.
[22] According to NRC, funding to support its request represented about
$500,000 of the additional $3.49 supplemental funding for the source
recovery project in fiscal year 2004.
[23] As a comparison, according to the source recovery project team
leader, the Los Alamos National Laboratory is currently storing 21,000
55-gallon drums of DOE-or defense-related nuclear waste destined for
disposal at WIPP.
[24] WIPP, operated by DOE and licensed by the Environmental Protection
Agency, is an underground repository for defense-generated transuranic
waste. Transuranic waste refers to man-made radioactive wastes that
have particles whose atoms are heavier than uranium; are alpha particle-
emitting, with a half-life longer than 20 years; and have a
concentration greater than 100 nano-curies per gram of waste. These
wastes include radionuclides, such as americium-241, plutonium-238, and
plutonium-239, that are generated by nuclear weapons production and the
reprocessing of spent nuclear fuels.
[25] 70 Fed. Reg. 24775 (May 11, 2005).
[26] Idaho National Engineering Laboratory, Greater-Than-Class C Low
Level Radioactive Waste Characterization: Estimated Volumes,
Radionuclides and Other Characteristics, DOE/LLW-114, Revision 1 (Idaho
Falls, ID: September 1994).
[27] The other activities of the source recovery project include
recovering from other countries sealed radiological sources that were
previously owned by the U.S. government, cooperating with IAEA, and
working with the Department of Homeland Security.
[28] NRC policy establishes base civil penalties for loss, abandonment,
or improper transfer or disposal of sealed radiological sources and
devices that, according to NRC, have been imposed on many occasions.
[29] The Health Physics Society is a nonprofit, scientific professional
organization whose mission is to promote the practice of radiation
safety. The society has approximately 6,000 scientists, physicians,
engineers, lawyers, and other professionals representing academia,
industry, government, national laboratories, the Department of Defense,
and other organizations.
[30] IAEA, Strengthening Control Over Radioactive Sources in Authorized
Use and Regaining Control Over Orphan Sources: National Strategies,
IAEA-TECDOC-1388 (Vienna, Austria: February 2004) p. 54.
[31] Between 2001 and 2004, the other low-level radioactive waste
disposal site in Washington only received an average of 155 cubic feet
of classes B and C waste comprised of sealed radiological sources.
[32] GAO-04-604.
[33] 70 Fed. Reg. 43646 (July 28, 2005).
[34] NRC has added seven radionuclides not recommended for tracking by
the IAEA Code of Conduct, including actinium-227, polonium-210,
plutonium-236, plutonium-239, plutonium-240, thorium-228, and thorium-
239. Although these radionuclides are not prevalently used by
licensees, they are used at DOE facilities.
[35] IAEA, Categorization of Radioactive Sources, p. 9.
[36] IAEA, Strengthening Control Over Radioactive Sources, pp. 39, 54.
[37] IAEA, Strengthening Control Over Radioactive Sources, p. 55.
[38] Results from nonprobability samples cannot be used to make
inferences about a population because in a nonprobability sample, some
elements of the population being studied have no chance or an unknown
chance of being selected as part of the sample.
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