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entitled 'Low-Level Radioactive Waste Management: Approaches Used by 
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Radioactive Waste' which was released on March 22, 2007.

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United States Government Accountability Office: 
GAO:

Report to the Chairman and Ranking Minority Member, Committee on Energy 
and Natural Resources, U.S. Senate: 

March, 2007: 

Low-Level Radioactive Waste Management: 

Approaches Used by Foreign Countries May Provide Useful Lessons for 
Managing U.S. Radioactive Waste: 

GAO-07-221: 

GAO Highlights:

Highlights of GAO-07-221, a report to the Chairman and Ranking Minority 
Member, Committee on Energy and Natural Resources, U.S. Senate. 

Why GAO Did This Study: 

GAO has reported on limitations in the management of U.S. low-level 
radioactive waste (LLRW). LLRW ranges from very low-activity to higher-
activity waste. To identify potential approaches to overcome these 
limitations, GAO was asked to examine the extent to which other 
countries have (1) LLRW inventory databases, (2) timely removal of 
higher-activity LLRW from waste generator sites, (3) disposition 
options for all LLRW, and (4) requirements that LLRW generators have 
financial reserves to cover waste disposition costs, as well as any 
other approaches that might improve U.S. LLRW management. GAO primarily 
relied on a survey of 18 countries representing leading LLRW generators 
to identify their management approaches and to compare them with U.S. 
survey results and with approaches suggested by LLRW generators, 
disposal operators, and regulators in the United States. 

What GAO Found: 

Academic, industrial, medical, utility, and government entities in the 
United States, particularly the Department of Energy (DOE), disposed of 
at least 15 million cubic feet of LLRW in 2005. This waste includes 
debris, rubble, soils, paper, liquid, metals, and clothing that have 
been exposed to radioactivity or contaminated with radioactive 
material, and sealed radiological sources that are no longer useful for 
industrial or other applications (disused). Other countries that have 
nuclear reactor units and use radioactive materials in other ways 
manage the residual LLRW in some ways that are different than in the 
United States. Of the countries surveyed, GAO found that: 

* Most countries indicated they have national radioactive waste 
inventory databases that include information on all waste generators, 
waste types, storage locations, and disused sealed radiological 
sources, and that they use them to forecast future disposal capacity 
needs. 

* Most countries indicated they facilitate the timely removal of higher-
activity LLRW, essentially disused sealed radiological sources, from 
generator sites to enhance safety and security, including requiring the 
return of a disused source to a source supplier. 

* Most countries indicated they have disposal options for lower-
activity LLRW, central storage options for higher-activity LLRW, and 
alternative disposal options for very low-level radioactive waste that 
in most cases does not require an exemption review by a nuclear 
regulatory authority. 

* Half the countries indicated they impose financial assurance 
requirements on all waste generators to cover disposition costs, and 
most of these countries also use other approaches to reduce government 
costs to recover higher-activity LLRW, such as requiring a disposal fee 
at the time that a sealed radiological source is purchased. 

GAO also found that most countries surveyed use national radioactive 
waste plans to guide the management of their radioactive wastes. Many 
representatives from LLRW generators, disposal operators, regulators, 
and others told GAO that the application of similar approaches to those 
used by other countries might improve the management of U.S. 
radioactive waste. 

Photographs: An Interior and Exterior View of the LLRW Disposal 
Facility in France: 

Source: French National Radioactive Waste Management Agency (Agence 
nationale pour la gestion des déchats radioactifs–Andra-FRL 
Productions). 

What GAO Recommends: 

GAO recommends that the Nuclear Regulatory Commission (NRC) and DOE 
evaluate and report on the usefulness of (1) adopting the identified 
management approaches, and the steps and any authorities necessary to 
implement them; and (2) developing a U.S. radioactive waste management 
plan, and the costs, steps, and any authorities necessary to do so. NRC 
and DOE generally agreed with these recommendations, but raised a 
number of issues regarding their implementation. 

[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-221]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Gene Aloise at (202) 512-
3841 or aloisee@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Comprehensive National LLRW Inventory Databases Are Widely Used to 
Track and Manage LLRW: 

Methods for Promptly Removing Higher-Activity LLRW from Waste Generator 
Sites Are Widely Used to Reduce Safety and Security Risks: 

Central Storage and Alternative Disposal Options Are Widely Used to 
Facilitate Management of LLRW: 

Financial Assurance Requirements and Other Approaches Are Used by Most 
Countries to Reduce Government LLRW Recovery Costs: 

National Radioactive Waste Management Plans Are Considered Important 
for Managing LLRW: 

Conclusions: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendix I: Recent GAO Findings and Agency Actions on LLRW Management: 

Appendix II: Scope and Methodology: 

Appendix III: Survey of LLRW Management Approaches Response from United 
States: 

Appendix IV: Volume and Location of LLRW in the United States: 

Appendix V: Status of Class B and C Waste Disposal and Potential 
Effects of Reduced Access to South Carolina Disposal Facility: 

Appendix VI: Comments from the Nuclear Regulatory Commission and Our 
Response: 

Appendix VII: Comments from the Department of Energy and Our Response: 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: IAEA Suggested Radioactive Waste Classification System: 

Table 2: Listing of Domestic LLRW Stakeholder Group Respondents: 

Table 3: Total LLRW Disposed at the Three Operating Commercial LLRW 
Disposal Facilities as of 2005: 

Table 4: Total Disposed LLRW at the Four Closed Commercial Disposal 
Facilities: 

Table 5: Total LLRW Disposed at the Three Commercial LLRW Disposal 
Facilities during 2005: 

Table 6: LLRW in Storage or Disposal at DOE Sites: 

Table 7: Transuranic Waste Disposed of or in Storage Awaiting Disposal 
at WIPP: 

Table 8: Central Storage and Disposal of Disused Sealed Radiological 
Sources Recovered by DOE’s Off-Site Source Recovery Project: 

Table 9: Class B and C Waste Type Groups: 

Table 10: Total Class B and C Waste Disposed at Richland and Barnwell 
by Waste Type Group, 2001-2005: 

Table 11: Number of Generators That Disposed of Class B and C Waste at 
Richland and Barnwell by Generator Type and Waste Type, 2001-2005: 

Table 12: Range of Class B and C Waste Disposed Annually at Richland 
and Barnwell by Generator Type, 2001-2005: 

Table 13: Distribution of Class B and C Waste Disposed Annually at 
Richland and Barnwell by Generator Type, 2001-2005: 

Table 14: Distribution of Non-Utility Class B and C Waste Disposed 
Annually at Richland and Barnwell by Generator Type, 2001-2005: 

Table 15: Disposed Class B and C Waste at Richland and Barnwell by LLRW 
Compact, 2001-2005: 

Table 16: Class B and C Waste Disposed at Barnwell from Atlantic, 
Northwest, and Rocky Mountain Generators, and Other Generators, 2001-
2005: 

Table 17: Number of Waste Generators That Disposed of Sealed 
Radiological Sources at Richland and Barnwell Ranked by Compact, 2001-
2005: 

Figures: 

Figure 1: Contents of National Radioactive Waste Inventory Databases: 

Figure 2: Management Approaches for National Radioactive Waste 
Inventory Databases: 

Figure 3: Management Approaches for Tracking and Managing LLRW: 

Figure 4: Methods to Facilitate Prompt Removal of LLRW from Generator 
Sites: 

Figure 5: LLRW Disposal Options and Management Responsibilities: 

Figure 6: Central Storage Options for LLRW: 

Figure 7: Disposal Options and Exemption Methods for Managing Very Low-
Level Radioactive Waste: 

Figure 8: Financial Approaches to Reduce Government Costs to Recover 
LLRW: 

Figure 9: Number of Generators That Disposed of Class B and C Waste at 
Richland and Barnwell by Generator Type and Waste Type, 2001-2005: 

Abbreviations: 

DOE: Department of Energy: 

GTCC: greater-than-class C: 

IAEA: International Atomic Energy Agency:

LLRW: low-level radioactive waste: 

NEA: Nuclear Energy Agency: 

NRC: Nuclear Regulatory Commission: 

WIPP: Waste Isolation Pilot Plant: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

March 21, 2007: 

The Honorable Jeff Bingaman: 
Chairman: 
The Honorable Pete V. Domenici: 
Ranking Minority Member: 
Committee on Energy and Natural Resources: 
United States Senate: 

Academic, industrial, medical, utility, and government entities in the 
United States, particularly the Department of Energy (DOE)—commercially 
disposed of at least 15-million cubic feet of low-level radioactive 
waste (LLRW) in 2005.[Footnote 1] LLRW substantially includes debris, 
rubble, and contaminated soils from facility decommissioning and site 
cleanup, as well as items such as rags, paper, liquid, glass, metal 
components, resins, filters, and protective clothing that have been 
exposed to radioactivity or contaminated with radioactive material. In 
addition, LLRW includes sealed radiological sources that are no longer 
used (disused) for their authorized use in agriculture, education, 
industry, medicine, and research applications. Sealed radiological 
sources contain radioactive material encapsulated, or sealed in metal 
to prevent its dispersal. At the present time, commercial disposal 
options are available for almost all LLRW in the United States. 
However, during the mid-1990s there was a period of time when a 
disposal facility was not available for some LLRW, and most waste 
generators are now facing the prospect of another disposal shortage in 
2008 if the state of South Carolina restricts access as planned to a 
key LLRW disposal facility. The Nuclear Regulatory Commission (NRC) 
considers future disposal costs and availability to be uncertain. The 
uncertainties surrounding disposal costs and availability and other 
limitations in LLRW management are taking on even greater significance 
as the United States embarks on developing new nuclear power plants, 
which would eventually create even more LLRW. Moreover, according to 
NRC, many non-utility generators of LLRW do not have the physical or 
financial capability to effectively manage disposal shortages and may 
have to curtail beneficial uses of radioactive material. 

The principal federal legislation governing the disposal of LLRW is the 
Low-Level Radioactive Waste Policy Act, as amended. The LLRW Policy 
Act, among other things, assigns to the states and the federal 
government responsibility for providing disposal availability for LLRW. 
[Footnote 2] NRC has divided the radioactive waste covered by the act 
into categories of increasing levels of hazard, beginning with class A, 
followed by B, C, and greater-than-class C (GTCC) waste, although there 
is no statutory upper limit or lower limit for the level of 
radioactivity required to declare a material to be LLRW. In addition, 
the act required DOE to provide technical assistance to the states, 
establish a computerized database to assist the states and DOE in 
monitoring the management of LLRW, and to report annually to the 
Congress on the management of LLRW by the states. However, DOE no 
longer receives specific appropriations to provide technical 
assistance—except for some funding to maintain a database of LLRW 
disposed at commercial facilities—and its reporting requirements 
terminated effective May 2000. NRC—or when authorized an Agreement 
State—is responsible for licensing LLRW disposal facilities. [Footnote 
3] In addition, NRC is responsible for overseeing and regulating all 
nuclear power plants, and for promulgating rules governing the safe and 
secure use of nuclear materials. The Agreement States must adopt and 
implement requirements that are compatible with NRC’s standards. 

The LLRW Policy Act promotes greater LLRW disposal capacity on a 
regional basis and more equitably distributes responsibility for 
managing this waste among the 50 states. As an incentive for states to 
manage LLRW on a regional basis, the Congress consented to the 
formation of interstate agreements, known as compacts, and granted 
compact member states the authority to refuse to accept LLRW from other 
compacts or unaffiliated states. There are currently three licensed 
commercial LLRW disposal facilities, each operating under different 
access and licensing restrictions, and none developed under the 
regional compact structure as authorized in the LLRW Policy Act. One of 
these disposal facilities is in Clive, Utah, and it accepts almost all 
the nation’s class A waste. Another commercial LLRW disposal facility 
is in Barnwell, South Carolina, and it accepts almost all of the 
nation’s class B and C waste. The third commercial disposal facility is 
in Richland, Washington, and it receives class A, B, and C waste from 
the 11 states of the Rocky Mountain and Northwest LLRW Compacts. DOE is 
currently studying the feasibility of disposal options for GTCC waste. 

GAO has reported on limitations in the management of U.S. LLRW. 
[Footnote 4] We have examined the contents of the LLRW commercial 
disposal inventory and national source tracking system databases; 
safety and security of stored class B, C, and GTCC waste; availability 
of LLRW disposition options; and issues facing DOE’s ability to recoup 
costs for the recovery of disused sealed radiological sources. More 
specifically, we reported in 2004 on the scope and reliability of U.S. 
LLRW inventory information and found that DOE’s commercial LLRW 
disposal database (1) did not contain data on all disposed LLRW, (2) 
did not capture information on LLRW that is produced and stored at 
waste generator sites, and (3) had data inaccuracies. We also found 
that the then proposed national source tracking system database would 
not have captured almost all the disused commercial sources that DOE 
had recovered from licensees. International authorities consider 
disused sealed radiological sources held in local storage at user 
premises waiting for disposal or return to manufacturer to be at 
greatest risk of becoming an orphan source. [Footnote 5] 

We also reported on the safety and security of storing class B, C, and 
GTCC waste at non-utility waste generator sites, such as industrials, 
medical and non-DOE governmental users of nuclear material. We found 
that NRC does not place general time limits on local storage of any 
LLRW nor does it require waste generators to return their disused 
sealed radiological sources to a source supplier. However, NRC 
explained that its existing licensing and inspection programs are 
adequate to ensure the safety and security of stored LLRW. 
Nevertheless, we also found that adding additional information on the 
storage of disused sealed radiological sources to the then proposed 
national source tracking system would assist DOE’s ongoing source 
recovery program to remove these sources from waste generator sites. We 
also reported on the adequacy of LLRW disposition options and found 
that greater federal oversight was needed to monitor LLRW storage and 
disposal conditions in light of uncertainties surrounding future 
disposal availability for class B and C waste. Finally, we commented on 
the lack of financial mechanisms for DOE to recoup the costs of 
recovering, storing, and disposing of thousands of disused sealed 
radiological sources from their holders who in some cases do not have 
capacity to store or dispose of them. We found that NRC did not require 
all non-utility waste generators, particularly those possessing sealed 
radiological sources, to ensure that funds are available to cover 
future LLRW disposition costs. 

NRC and DOE accepted many of the recommendations made in these GAO 
reports and they have taken other actions to improve the management of 
LLRW. Other actions include a current strategic assessment of NRC’s 
regulation of LLRW that is intended to identify and prioritize staff 
activities. According to NRC officials, this assessment will consider 
the recommendations made in GAO reports and other recent reports 
including those from an NRC chaired task force on radiation source 
protection and security, the NRC Advisory Committee on Nuclear Waste, 
and the National Research Council. [Footnote 6] We were informed this 
assessment currently lacks a systematic review of approaches taken by 
other countries to manage their LLRW. DOE is also designing a complex-
wide strategy to optimize the disposition of its low-level waste and 
mixed low-level waste. Appendix I contains a more detailed discussion 
of GAO findings and agency actions on LLRW management.

Given our past reports on LLRW management and NRC and DOE responses to 
our recommendations, you asked us to identify approaches taken by other 
countries to manage their LLRW, and whether any of these approaches 
might be applicable in the United States. Specifically, you asked us to 
determine the extent to which other countries have: (1) comprehensive 
national LLRW inventory databases, (2) timely removal of higher-
activity LLRW in storage at waste generator sites, (3) disposition 
options for all LLRW, and (4) requirements to assure that non-utility 
LLRW generators have adequate financial reserves to cover all waste 
disposition costs. We also agreed to report on any other approaches 
that we identified in the course of our work that might support 
improvement in the management of LLRW in the United States. 

To conduct our work, we primarily relied on the results of a survey of 
20 foreign countries representing the leading generators of LLRW, 
reviews of reports from the International Atomic Energy Agency (IAEA) 
and the Nuclear Energy Agency (NEA), [Footnote 7] and interviews with 
representatives from U.S. LLRW stakeholder groups. These countries, 
along with the United States, account for 85 percent of the world’s 
installed nuclear power plant capacity. While countries generate 
similar radioactive waste, there is variation in the way they classify 
this waste. Our survey relied on the suggested IAEA waste 
classification scheme that defines two categories of LLRW, short-lived 
low- and intermediate-level radioactive waste (lower-activity LLRW) and 
long-lived low- and intermediate-level radioactive waste (higher-
activity LLRW). The IAEA is also considering adding another class of 
radioactive waste—very low-level radioactive waste—which some countries 
already use in managing LLRW. Eighteen of the 20 foreign countries 
responded to our survey to identify their use of management approaches 
to address our four research objectives. [Footnote 8] NRC collaborated 
with DOE and other LLRW stakeholder groups to complete a U.S. response 
to our survey. In addition, we visited LLRW facilities and interviewed 
officials in France, Japan, and Sweden. We chose these countries 
because of their extensive experience with nuclear power generation and 
with constructing and operating LLRW disposal facilities. We also 
interviewed representatives of U.S. LLRW stakeholder groups regarding 
their knowledge of approaches used in other countries and their 
opinions on new approaches that might help improve LLRW management in 
this country. For the most part, these representatives provided little 
awareness of approaches used in other countries. Those interviewed 
represented federal and state nuclear regulatory authorities, 
commercial LLRW disposal operators, state LLRW compact commissions, and 
other groups. As not all representatives provided a response to 
questions about each LLRW management issue, our content analysis of the 
interviews captures opinions from only those representatives that 
responded to each issue. We also reviewed a variety of documents 
provided to us by these representatives. We identified and assessed the 
reliability of various waste inventory databases in an attempt to 
describe the volume and location of LLRW in the United States. We 
determined that these data were sufficiently reliable for the purposes 
of our report. We conducted our review between September 2005 and 
February 2007 in accordance with generally accepted government auditing 
standards. A more detailed description of our scope and methodology is 
provided in appendix II. Appendix III provides the response of the 
United States to the survey of LLRW management approaches. 

Results in Brief: 

Most countries we surveyed use comprehensive national radioactive waste 
inventory databases to assist in the management of LLRW. Thirteen 
countries indicated that their inventory databases typically contained 
information on all waste types—10 of which specifically inventoried 
very low-level radioactive waste—the storage of waste at generator 
sites, including disused sealed radiological sources, and all waste 
generator types in their countries. In addition, 15 countries indicated 
that they take steps to increase the reliability of the information 
collected by ensuring its completeness, accuracy, and timeliness. 
Almost all countries use these databases to track the location and 
quantities of radioactive waste to forecast future disposal capacity 
needs. Most of the U.S. LLRW stakeholder group representatives who 
responded to this issue generally supported the usefulness of 
developing comprehensive national LLRW inventory databases. The NRC 
chaired task force also commented on the need to evaluate including 
more source categories in the national source tracking system. 

Fourteen of the 18 countries we surveyed use methods to promptly remove 
higher-activity LLRW from generating sites in order to reduce safety 
and security risks. These countries both encourage and enforce the 
timely removal of disused sealed radiological sources to prevent the 
uncontrolled exposure of workers and the public to radiation. Some of 
these countries also place general time limits on the storage of these 
sources at generator sites. To facilitate the removal of this higher-
activity LLRW, almost all countries surveyed require that sealed 
radiological sources be returned to their suppliers or to central waste 
storage when they are no longer in use. Most of these countries also 
have established orphan source recovery programs to collect sealed 
radiological sources that have been abandoned or lost. Some U.S. 
stakeholder group representatives who responded to this issue and the 
recent report from the NRC chaired task force generally supported the 
need to evaluate methods that could be used to facilitate the removal 
of higher-activity LLRW, essentially disused sealed radiological 
sources, from non-utility waste generator sites. 

Ten of the 18 countries we surveyed have disposal options for lower-
activity LLRW and 6 other countries have plans to build such 
facilities. While only 3 countries indicated that they have a disposal 
option for higher-activity LLRW, 14 countries reported that they have 
central storage facilities for this waste. Moreover, 13 countries 
indicated that they have clearance or unrestricted removal of very low-
level radioactive waste from regulatory control as LLRW, and 8 
countries indicated that they have disposal options for this waste. The 
U.S. LLRW stakeholder group representatives who responded to this issue 
were split on the need for central storage options for higher-activity 
LLRW when a disposal option is not available, but most of them 
supported exempting very low-level radioactive waste from regulatory 
control as LLRW. The NRC chaired task force and other reports have 
commented on, among other related issues, the need to reexamine 
disposal options for LLRW. 

Half the countries we surveyed indicated that their nuclear regulatory 
authorities require all non-utility LLRW generators to have sufficient 
financial assurances to cover the removal of radioactive waste from 
their sites. In addition, seven of the countries use other financial 
assurance approaches to ensure that the government is reimbursed for 
any sealed radiological sources that it may need to recover from non-
utility LLRW generators. More than half of the U.S. LLRW stakeholder 
group representatives who responded to this issue and the recent report 
from the NRC chaired task force commented on the need to improve the 
financial assurance structure for some LLRW generators in the United 
States. The task force report suggested that NRC evaluate some 
approaches that are similar to those used in some other countries to 
ensure that radioactive material users have financial reserves to cover 
waste disposition costs. 

We also found that 12 of the 18 countries surveyed rely on national 
radioactive waste management plans to guide the management of their 
radioactive wastes and that the United States lacks such a plan. 
Several of these plans required the management of radioactive waste 
from a national perspective and specified one administrative entity as 
responsible for coordinating their development. In addition, there was 
often a requirement in the plans for periodic public reporting of LLRW 
conditions. While the usefulness of such a plan was not sought through 
a question in the survey or specifically raised in interviews with U.S. 
LLRW stakeholder group representatives, most of the representatives and 
recent reports on LLRW management mentioned the need to evaluate 
alternative ways to manage LLRW. 

To improve the management of LLRW in the United States and address a 
potential disposal shortage for higher-activity LLRW in 2008 and other 
management concerns, we are recommending that the Chairman of NRC and 
the Secretary of Energy evaluate and report back to the Congress within 
1 year on the usefulness to the United States of (1) adopting the LLRW 
management approaches used in the countries that are discussed in this 
report, and the steps and any authorities necessary for their 
implementation, if deemed appropriate; and (2) developing a U.S. 
radioactive waste management plan, and the potential costs, steps, and 
any authorities necessary to develop such a plan, if deemed 
appropriate. 

NRC and DOE generally agreed with the recommendations in a draft of our 
report, but raised a number of issues regarding their implementation. 
Specifically, they suggested other means through which they could 
report the results of their evaluations to Congress and they questioned 
the benefits of developing a national radioactive waste management 
plan. We do not take issue with how NRC and DOE may choose to report to 
the Congress; as long as the Congress gets the information it needs, 
the reporting format is a secondary consideration. In addition, in 
response to NRC and DOE suggestions, we revised our recommendation 
regarding the development of a national radioactive waste management 
plan to clarify that the agencies first evaluate and report on the 
usefulness of such a plan, and then conduct other analysis if deemed 
appropriate. However, based on the experience of other nations, we 
continue to believe that a national radioactive waste management plan 
has merit. We responded to specific comments from NRC and DOE in 
appendix VI and VII, respectively, and incorporated technical changes 
in this report where appropriate based on detailed comments provided by 
the agencies. The State Department did not comment on our draft report. 

Background: 

The 30 countries in the world that generate electricity from 435 
nuclear power reactor units face the need to manage the radioactive 
wastes that are generated from these units as well as the waste 
generated by non-utility users of nuclear materials. The United States 
is a large generator of radioactive waste with its 104 nuclear power 
reactors and thousands of radioactive material licensees. These 
countries, including the United States, contribute to and are guided by 
advice from international organizations on approaches to manage 
radioactive materials. The principal international organizations are 
IAEA and NEA. For example, countries may voluntarily use IAEA standards 
to demonstrate implementation of the obligations set forth in the Joint 
Convention on the Safety of Spent Fuel Management and on the Safety of 
Radioactive Waste Management, which the United States has signed. 
According to IAEA, the Joint Convention recognizes and reinforces the 
internationally held view that radioactive waste management is an issue 
of national concern, but that the development, implementation, and 
maintenance of national programs for radioactive waste management must 
be carried out with due regard to internationally-endorsed criteria and 
standards. [Footnote 9] Moreover, for contracting parties to various 
international safety conventions, IAEA standards provide a consistent, 
reliable means of ensuring the effective fulfillment of their 
obligations. One example of these criteria and standards is the IAEA 
Code of Conduct for the Safety and Security of Radioactive Sources. 
[Footnote 10] This code, which the United States has agreed to work 
toward implementing, is intended to guide countries in developing and 
harmonizing policies, laws, and regulations pertaining to sealed 
radiological sources. The code states, among other things, that the 
nuclear regulatory authority in each country should establish a 
national registry of radioactive sources to track the possession of 
these sources. At a minimum, the code recommends that the nuclear 
regulatory authority in each country include sources in categories 1 
and 2 of the five source categories defined by IAEA. These two 
categories contain sources with the highest level of radioactivity. 
However, the code suggests that the nuclear regulatory authorities also 
give appropriate attention to sources in the other three categories, as 
they would pose health and security risks when aggregated in harmful 
quantities. 

IAEA has also put forth suggested guidance on a general system for 
classifying radioactive waste to facilitate communication and 
information exchange among countries. In general, U.S. class A, B, and 
most of class C waste would fall into IAEA’s category of short-lived 
low- and intermediate-level radioactive waste (lower-activity waste), 
and the remaining 25 percent of class C waste and all of GTCC waste 
would be within IAEA’s long-lived low- and intermediate-level 
radioactive waste category (higher-activity waste). IAEA acknowledges 
that spent or disused sealed radiological sources are not considered 
waste in certain countries, such as the United States, but considers 
that the safe management of such sources is achieved by compliance with 
the requirements for managing radioactive waste. Table 1 provides a 
description of the suggested IAEA radioactive waste classification 
scheme. 

Table 1: IAEA Suggested Radioactive Waste Classification System: 

Waste class: 1. Exempt waste;
Typical characteristics: Activity levels at or below clearance levels, 
which are based on annual dose less than 0.01 mSv[a]; 
Disposal options: No radiological restrictions. 

Waste class: 2. Low- and intermediate-level waste; 
Typical characteristics: Activity levels above clearance levels and thermal 
power below about 2 kW/m3[b]; 
Disposal options: [Empty]. 

Waste class: 2. Low- and intermediate-level waste, 2.1 Short-lived 
waste; 
Typical characteristics: Restricted long-lived radionuclide 
concentrations; 
Disposal options: Near-surface or geological disposal facility. 

Waste class: 2. Low- and intermediate-level waste, 2.2 Long-lived 
waste; 
Typical characteristics: Long-lived radionuclide concentrations 
exceeding restricted short-lived waste; 
Disposal options: Geological disposal facility. 

Waste class: 3. High-level waste; 
Typical characteristics: Thermal power above about 2 kW/m3 and 
long-lived radionuclide concentrations exceeding limitations for 
short-lived waste; 
Disposal options: Geological disposal facility. 

Source: IAEA, Radioactive Waste Management: Status and Trends-Issue #2 
(Vienna, Austria: Sept. 2002) 24. 

[a] mSv (millisivert) is a unit of radiation dose measurement. Two and 
a half millisieverts is the national average dose of background 
radiation from all sources. 

[b] kW/m3 is kilowatts per cubic meter of thermal power.

[End of table] 

IAEA presently does not define a category for very low-level 
radioactive waste, but such a category is under consideration. IAEA has 
drafted for consideration by its member states a new waste 
classification system that would add more waste categories, 
particularly categories for low-activity radioactive waste. This 
proposed system would have six categories: (1) exempt waste, (2) very 
short-lived waste, (3) very low-level waste, (4) low-level waste, (5) 
intermediate-level waste, and (6) high-level waste. The very low-level 
waste category might be considered the lower spectrum of class A waste, 
and include materials with very limited radioactivity, such as 
contaminated soil and rubble from decommissioned power plants. 

Finally, IAEA issued a Safety Standard guide in 2005 regarding the 
management of waste from the use of radioactive material in medicine, 
industry, agriculture, research and education. [Footnote 11] IAEA 
stated that a national strategy for the management of radioactive waste 
should be developed in accordance with the safety objectives and 
principles. A strategy is necessary in order to define the 
infrastructure and the means to be adopted for the management of 
radioactive waste. IAEA stated that a key element in the strategy is 
the extent to which national and regional waste management facilities 
are developed rather than managing the waste at a number of locations 
where it arises. 

Comprehensive National LLRW Inventory Databases Are Widely Used to 
Track and Manage LLRW: 

Most countries we surveyed use comprehensive national radioactive waste 
inventory databases to assist in the management of LLRW. Thirteen 
countries indicated that their inventory databases typically contained 
information on all waste types—10 of which specifically inventoried 
very low-level radioactive waste—the storage of waste at generator 
sites, including disused sealed radiological sources, and all waste 
generator types in their countries. In addition, 15 countries indicated 
that they take steps to increase the reliability of the information 
collected by ensuring its completeness, accuracy, and timeliness. 
Almost all countries use these databases to track the location and 
quantities of radioactive waste to forecast future disposal capacity 
needs. Most of the U.S. LLRW stakeholder group representatives who 
responded to this issue generally supported the usefulness of 
developing comprehensive national LLRW inventory databases. The NRC 
chaired task force also commented on the need to evaluate including 
more source categories in the national source tracking system. 

Most Countries Have Comprehensive National Radioactive Waste Inventory 
Databases: 

Thirteen of the 18 countries are considered to have comprehensive 
national radioactive waste inventory databases that typically contain 
information on a wide range of waste types, locations of stored waste, 
waste generators, and the possession of sealed radiological sources. 
Almost all countries (17/18) indicated that their inventory databases 
include short-lived low- and intermediate-level waste as well as long-
lived intermediate-level waste. In addition, 10 countries indicated 
that their inventories also include very low-level radioactive waste, 
13 include long-lived low-level waste, and 14 include high-level waste. 
All 17 countries that have national radioactive waste inventory 
databases indicated that they capture waste data from all generators in 
their countries, which could include academic, government, industrial, 
medical, and nuclear reactor sources of LLRW. In regard to tracking the 
location of waste, 14 countries indicated that their radioactive waste 
inventory databases capture waste in storage at generator sites. For 
example, France indicated that its national radioactive waste inventory 
database records the types of radioactive waste located at all waste 
generator sites, central storage, and disposal sites. 

The countries in our survey also maintain national registries of sealed 
radiological sources, including those in use, storage or disuse. Most 
countries indicated in their survey responses that their national 
radiological source registries go beyond the minimum of category 1 and 
2 suggested in the IAEA Code of Conduct on the Safety and Security of 
Radioactive Sources. Fourteen of 18 countries indicated that their 
national source registries include all category 1, 2, and 3 sources, 
and nine of these countries also include category 4 and 5 sources. The 
nine countries with comprehensive source registries were Denmark, 
Finland, France, Hungary, Italy, Japan, Mexico, Slovak Republic, and 
Switzerland. While the survey did not seek information on the number of 
sources in a country, the countries with comprehensive source 
registries include those that may have a relatively small number of 
sources to track, such as Denmark, to those countries that have much 
larger numbers to track, such as France and Japan. Figure 1 summarizes 
the comprehensiveness of the national radioactive waste inventory 
databases in the countries we surveyed. 

Figure 1: Contents of National Radioactive Waste Inventory Databases: 

LLRW management approach: 
Maintains a national radioactive waste inventory database: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 17. 

LLRW management approach: 
Very low-level radioactive waste is included in the national 
radioactive waste inventory database: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: Yes; 
United Kingdom: No; 
Sweden: No; 
Spain: Yes; 
Belgium: No; 
Finland: No Response; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: No; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: Yes; 
Norway: No Response; 
Total Yes Count: 10. 

LLRW management approach: 
Short-lived low- and intermediate-level waste, and long-lived 
intermediate-level waste are included in the national radioactive waste 
inventory database: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 17. 

LLRW management approach: 
Long-lived low-level waste (including naturally occurring radioactive 
material) is included in the national radioactive waste inventory 
database: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: Yes; 
Norway: No; 
Total Yes Count: 14. 

LLRW management approach: 
High-level radioactive waste are included in the national radioactive 
waste inventory database: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: Not Applicable; 
Norway: No; 
Total Yes Count: 14. 

LLRW management approach: 
All types of radioactive waste generators in the country are included 
in the national radioactive waste inventory database: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 17. 

LLRW management approach: 
National radioactive waste inventory database captures waste stored at 
generator sites: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: No; 
Norway: No; 
Total Yes Count: 14. 

LLRW management approach: 
Maintains a national source registry containing IAEA categories 1, 2, 
and 3 radiological sources: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: No; 
Sweden: No; 
Spain: No Response; 
Belgium: No; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Yes; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 14. 

LLRW management approach: 
Maintains a national source registry containing IAEA categories 1-5 
radiological sources: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: No; 
United Kingdom: No; 
Sweden: No; 
Spain: No Response; 
Belgium: No; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: No; 
Italy: Yes; 
Australia: No; 
Denmark: Yes; 
Norway: No; 
Total Yes Count: 9. 

Source: GAO survey of foreign countries, 2006. 

Note: Denmark responded to questions about the contents of its national 
radioactive waste inventory database, although it will not be 
established until 2007. Countries are ordered according to their 
nuclear electricity generation at the beginning of 2006, as reported by 
NEA. The last four countries in the table currently do not have nuclear 
electricity generation, but Italy did in the past, and the other 
countries have nuclear research reactors. The United States would be 
the largest nuclear electricity generator if listed. 

[End of figure] 

Countries Take Steps to Ensure Reliability of Information in Their 
Inventory Databases: 

The countries in our survey try to increase the reliability of their 
radioactive waste inventory databases by taking steps to ensure that 
the information collected is complete, accurate, and timely. Almost all 
countries (15/18) indicated that they have at least one control in 
place to verify the completeness and accuracy of information in their 
national radioactive waste inventories. These controls include periodic 
inspections of the waste at generator sites, checking generator waste 
inventory data submissions against past and projected waste from the 
generator, and periodic audits of the waste inventory records 
maintained by the generator. For example, in the United Kingdom, the 
information provided by LLRW waste generators is reviewed and checked 
for consistency with previous inventory information and against similar 
types of waste. Moreover, independent assessments are undertaken to 
provide upper-bound estimates of total radioactivity of the waste at 
generator sites. The waste generators are also required to obtain a 
letter of compliance to package their waste before final waste 
processing. At the time the letter of compliance is issued, the waste 
data is reviewed, and if found insufficient, the waste generator may be 
subject to a further audit. 

Although almost all countries (17/18) have a national authority or 
waste management organization responsible for maintaining their 
national radioactive waste inventory databases, countries varied in how 
information is transmitted to the entity managing the inventory and the 
frequency of information submission. Currently, only 2 of the 18 
countries require the submission of waste data through a secure 
website. The most common methods for data submission were use of e-
mail, standard mail, fax, and by phone. Most of the countries (12/18) 
indicated that their national radioactive waste inventory databases 
receive data from waste generators annually or more frequently. Survey 
results indicated that inventory updates every 6 months or less are 
obtained from waste generators in Denmark, Mexico, Norway, Slovak 
Republic, Spain, and Switzerland. Figure 2 summarizes the approaches 
used in the countries surveyed to manage their national radioactive 
waste inventory databases. 

Figure 2: Management Approaches for National Radioactive Waste 
Inventory Databases: 

LLRW management approach: 
National nuclear regulatory authority or national waste management 
organization is responsible for managing the national radioactive waste 
inventory database: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No Response; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 17. 

LLRW management approach: 
Manager of national radioactive waste inventory database uses at least 
one control to verify the completeness and accuracy of information 
submitted by waste generators: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: No Response; 
Italy: Yes; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 15. 

LLRW management approach: 
Waste generators submit data to manager of national radioactive waste 
inventory database through a secure website: 
France: No Response; 
Japan: No; 
Germany: No; 
Canada: No Response; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: No; 
Belgium: No; 
Finland: No Response; 
Switzerland: No; 
Slovak Republic: No Response; Hungary: No; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 2. 

LLRW management approach: 
Waste generators are required to submit data to manager of national 
radioactive waste inventory database once a year or more frequently: 
France: No; 
Japan: Yes; 
Germany: Yes; 
Canada: No; 
United Kingdom: No; 
Sweden: Yes; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: No; 
Italy: Yes; 
Australia: Not Applicable; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 12. 

LLRW management approach: 
Member of the European Union and has implemented Council Directive 
2003/122EURATOM regarding the control of high-activity sealed 
radioactive sources and orphan sources: 
France: Yes; 
Japan: Not Applicable; 
Germany: Yes; 
Canada: Not Applicable; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Not Applicable; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Not Applicable; 
Netherlands: Yes; 
Italy: No; 
Australia: Not Applicable; 
Denmark: No; 
Norway: Not Applicable; 
Total Yes Count: 10. 

Source: GAO survey of foreign countries, 2006. 

Note: Denmark responded to questions about the contents of its national 
radioactive waste inventory database, although it will not be 
established until 2007. Countries are ordered according to their 
nuclear electricity generation at the beginning of 2006, as reported by 
NEA. The last four countries in the table currently do not have nuclear 
electricity generation, but Italy did in the past, and the other 
countries have nuclear research reactors. The United States would be 
the largest nuclear electricity generator if listed. 

[End of figure] 

Countries Use Inventory Databases to Track and Manage LLRW: 

Sixteen of the 18 countries in our survey indicated that they use their 
national radioactive waste inventory databases to forecast waste 
volumes, plan for disposal capacity, and track the location of disused 
sealed radiological sources. Thirteen countries indicated that they 
publicize information from their national radioactive waste inventory 
databases on what is stored and disposed of to gain community 
acceptance for siting these facilities. Sixteen of the countries 
indicated that they keep records of the location and status and use of 
sources in their national source registries. Figure 3 shows the 
responses for each country. 

Figure 3: Management Approaches for Tracking and Managing LLRW: 

LLRW management approach: 
Regulator keeps a record of the locations and status of use of sources, 
including disused sources: 
France: Yes; 
Japan: No; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No Response; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 16. 

LLRW management approach: 
National radioactive waste inventory database is used to make 
projections of future waste volumes for capacity planning of central 
waste storage and disposal facilities: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No; 
Denmark: Yes; 
Norway: No; 
Total Yes Count: 16. 

LLRW management approach: 
Radioactive waste inventory information is publicized to help obtain 
community acceptance of LLRW central storage and disposal facilities: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: No Response; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No Response; 
Italy: No; 
Australia: Yes; 
Denmark: No Response; 
Norway: Yes; 
Total Yes Count: 13. 

Source: GAO survey of foreign countries, 2006. 

Note: Denmark responded to questions about the contents of its national 
radioactive waste inventory database, although it will not be 
established until 2007. Countries are ordered according to their 
nuclear electricity generation at the beginning of 2006, as reported by 
NEA. The last four countries in the table currently do not have nuclear 
electricity generation, but Italy did in the past, and the other 
countries have nuclear research reactors. The United States would be 
the largest nuclear electricity generator if listed. 

[End of figure] 

Domestic Experts Support Need for More Comprehensive LLRW Inventory 
Databases: 

Most representatives of domestic LLRW stakeholder groups who responded 
in interviews to this issue (19/25) supported the need to establish a 
more comprehensive national radioactive waste inventory database in the 
United States. Over half of these representatives commented that such 
an inventory would allow LLRW stakeholders to forecast waste volumes 
and to plan for future disposal capacity requirements. However, some 
representatives felt that a more comprehensive national radioactive 
waste inventory database would not be necessary. For example, one 
representative argued that the cost-effectiveness of adding more 
reporting requirements to include the storage of class B and C waste 
might not be justified given the small quantities of this waste that 
are generated each year. 

A recent report of the interagency Radiation Source Protection and 
Security Task Force, chaired by NRC, addressed the scope of the current 
national source tracking system, which currently tracks the possession 
of category 1 and 2 sources. The task force suggested that NRC conduct 
a comprehensive analysis of category 3 sources for possible inclusion 
in the National Source Tracking System. The task force found that 
category 3 and lower-activity sources comprise a major portion of those 
sources voluntarily identified as surplus, excess, or unwanted in the 
commercial sector. Moreover, the task force found that the U.S. metal 
recycle industry claims that category 3 sources are those more commonly 
misplaced or abandoned by industry, resulting in potential 
contamination of the metal recycling process with operational and 
financial impacts. 

Methods for Promptly Removing Higher-Activity LLRW from Waste Generator 
Sites Are Widely Used to Reduce Safety and Security Risks: 

Fourteen of the 18 countries we surveyed use methods to promptly remove 
higher-activity LLRW from generating sites in order to reduce safety 
and security risks. These countries both encourage and enforce the 
timely removal of disused sealed radiological sources to prevent the 
uncontrolled exposure of workers and the public to radiation. Some of 
these countries also place general time limits on the storage of these 
sources at generator sites. To facilitate the removal of higher-
activity LLRW, almost all countries surveyed require that sealed 
radiological sources be returned to their suppliers when they are no 
longer in use. Most of these countries also have established orphan 
source recovery programs to collect sealed radiological sources that 
have been abandoned or lost. Some U.S. stakeholder group 
representatives who responded to this issue and the recent report from 
the NRC chaired task force generally supported the need to evaluate 
methods that could be used to facilitate the removal of higher-activity 
LLRW, essentially disused sealed radiological sources, from non-utility 
waste generator sites. 

Most Countries Encourage and Enforce the Prompt Removal of Higher-
Activity LLRW from Generator Sites: 

Most countries we surveyed (14/18) indicated that their nuclear 
regulatory authority encourages the removal of higher-activity LLRW, 
essentially disused sealed radiological sources, from generator sites, 
and half of the countries enforce the prompt removal of these sources. 
Some of the countries that require the prompt removal of these sources 
also place time limits on how long LLRW can remain in storage at waste 
generator sites. Seven countries indicated that they limit the amount 
of time that LLRW can remain in storage at non-utility waste generator 
sites, and four other countries impose time limits only when waste 
generators have a disposal option for the waste. For example, in 
Sweden, depending on the facility, waste generators can only hold 
disused sealed radiological sources for 6 months to a year and a half, 
and any other LLRW intended for storage at a waste generator site for 
more than 2 years must be registered with the national regulatory 
authority. 

Most Countries Use a Variety of Approaches to Facilitate the Removal of 
Higher-Activity LLRW from Generator Sites: 

Almost all countries we surveyed (15/18) indicated that they require 
that sealed radiological sources be returned to their source supplier 
or to a central storage facility when they are no longer in use. The 
general support for this LLRW management approach might be attributable 
to international guidance on managing sources. All countries in our 
survey have agreed to follow the IAEA Code of Conduct on the Safety and 
Security of Radioactive Sources, which recommends that nuclear 
regulatory authorities attach clear and unambiguous conditions on the 
use of sources, including, where applicable, agreements regarding the 
return of disused sources to a supplier. In addition, the Council of 
the European Union Directive 2003/122 states that all member countries 
must establish requirements that a holder of a sealed radiological 
source return the source to the supplier, place it in a recognized 
installation, or transfer it to another authorized holder without undue 
delay after termination of the use, unless otherwise agreed by the 
nuclear regulatory authority. For example, in France, the supplier of 
sealed radiological sources is responsible for the sources it sells. 
Once the purchaser of a source ceases to use it, the holder must 
immediately return it to the supplier who is responsible for accepting 
it unconditionally. Until the source user can prove that the source has 
been returned to a supplier, the user retains responsibility for it. 
Only three countries, two of which are non-European Union member 
countries, indicated that they do not currently impose this regulation 
on source holders. 

Most countries we surveyed (11/18) indicated that they have government 
programs to recover higher-activity sources that are not under 
regulatory control (orphan sources). Once again, there is international 
guidance in this area. The IAEA Code of Conduct on the Safety and 
Security of Radioactive Sources recommends that nuclear regulatory 
authorities establish provisions to recover and restore appropriate 
control over orphan sources. Moreover, the Council of the European 
Union also recognized that despite the existence of an appropriate 
regulatory framework to control these higher-activity sources, they 
still may be abandoned or lost. Council Directive 2003/122 states that 
all member countries shall ensure that their nuclear regulatory 
authorities are prepared to or have assigned responsibilities for 
recovering orphan sources. This directive also states that the nuclear 
regulatory authorities in these countries shall be notified of any 
changes in the situation of a higher-activity source, such as its 
location and use, and to register these changes. Nine countries, 
including three non-European Union countries, indicated that holders of 
sealed radiological sources are required to notify the nuclear 
regulatory authority when a source has become disused, and most 
countries (14/18) indicated that their authority verifies this 
information by periodically inspecting the storage of disused sources 
at user sites. Eleven countries indicated that a government entity is 
given responsibility for managing an orphan source recovery program; 3 
countries give this responsibility to a non-governmental entity. For 
example in Japan, the Japan Radioisotope Association is responsible for 
recovering and storing sealed radiological sources and other 
radioisotopes from users of these radioactive materials. The 
association, regulated by the Ministry of Education, Culture, Sports, 
Science and Technology—the Japanese ministry responsible for regulating 
medical uses of radioisotopes—is funded through fees collected by users 
of these materials. Figure 4 provides a summary of the methods used by 
countries in our survey to facilitate the prompt removal LLRW, 
particularly disused sealed radiological sources from waste generator 
sites. 

Figure 4: Methods to Facilitate Prompt Removal of LLRW from Generator 
Sites: 

LLRW management approach: 
On-site storage time limits for LLRW are set for non-nuclear power 
plant entities: 
France: Yes; 
Japan: No; 
Germany: No; 
Canada: No Response; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: No; 
Belgium: Yes; 
Finland: No; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: No; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No; 
Denmark: No; 
Norway: No; 
Total Yes Count: 7. 

LLRW management approach: 
On-site storage time limits for LLRW are set only when a disposal 
option is available: 
France: Yes; 
Japan: No Response; 
Germany: No Response; 
Canada: No Response; 
United Kingdom: Yes; 
Sweden: Not Applicable; 
Spain: No Response; 
Belgium: Not Applicable; 
Finland: No Response; 
Switzerland: No Response; 
Slovak Republic: Not Applicable; 
Hungary: No Response; 
Mexico: Yes; 
Netherlands: Not Applicable; 
Italy: Yes; 
Australia: No Response; 
Denmark: No Response; 
Norway: No Response; 
Total Yes Count: 4. 

LLRW management approach: 
Regulator encourages removal of disused radiological sources from user 
sites: 
France: No Response; 
Japan: No; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No Response; 
Denmark: No Response; 
Norway: Yes; 
Total Yes Count: 14. 

LLRW management approach: 
Regulator enforces prompt removal of disused radiological sources from 
user sites: 
France: Yes; 
Japan: No; 
Germany: No; 
Canada: Yes; 
United Kingdom: No; 
Sweden: No; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: Yes; 
Netherlands: No Response; 
Italy: Yes; 
Australia: No Response; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 9. 

LLRW management approach: 
Time limits are placed on length of time a radiological source can be 
used: 
France: Yes; 
Japan: No; 
Germany: No; 
Canada: Yes; 
United Kingdom: No; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: No; 
Italy: No; 
Australia: No; 
Denmark: No; 
Norway: No; 
Total Yes Count: 4. 

LLRW management approach: 
Requirement that disused radiological sources be returned to a supplier 
or central waste storage: 
France: Yes; 
Japan: No; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: No; 
Australia: No; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 15. 

LLRW management approach: 
Maintains an orphan radiological source recovery program: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: No; 
Australia: No; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 10. 

LLRW management approach: 
Government entity is made responsible for orphan radiological source 
recovery program: 
France: Yes; 
Japan: No; 
Germany: No Response; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No Response; 
Spain: Yes; 
Belgium: No Response; 
Finland: Yes; 
Switzerland: No Response; 
Slovak Republic: No; 
Hungary: No Response; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Yes; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 11. 

LLRW management approach: 
An organization other than the government is responsible for recovering 
orphan radiological sources: 
France: No; 
Japan: Yes; 
Germany: No Response; 
Canada: No; 
United Kingdom: No; 
Sweden: No Response; 
Spain: No; 
Belgium: No Response; 
Finland: No; 
Switzerland: No Response; 
Slovak Republic: Yes; 
Hungary: No Response; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No; 
Denmark: No; 
Norway: Yes; 
Total Yes Count: 3. 

LLRW management approach: 
Users must inform regulators if holding disused sources: 
France: No; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: No; 
Finland: No Response; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No Response; 
Italy: Yes; 
Australia: No Response; 
Denmark: No; 
Norway: No; 
Total Yes Count: 9. 

LLRW management approach: 
Regulator periodically inspects the operational storage of disused 
radiological sources: 
France: Yes; 
Japan: No; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No Response; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 14. 

Source: GAP survey of foreign countries, 2006. 

Note: Countries are ordered according to their nuclear electricity 
generation at the beginning of 2006, as reported by NEA. The last four 
countries in the table currently do not have nuclear electricity 
generation, but Italy did in the past, and the other countries have 
nuclear research reactors. The United States would be the largest 
nuclear electricity generator if listed. 

[End of figure] 

Domestic Experts Support Need to Evaluate Methods for Facilitating the 
Removal of Higher-Activity LLRW from Waste Generator Sites: 

The representatives from domestic LLRW stakeholder groups who responded 
in interviews to this issue generally agreed that the United States 
should consider exploring methods for promptly removing higher-activity 
LLRW from waste generator sites. Eleven of 27 representatives supported 
imposing time limits on storing higher-activity LLRW at non-utility 
waste generator sites, but not for radioactive wastes that are allowed 
to decay in storage within a reasonable amount of time. For example, 
several representatives suggested that LLRW generators should be 
treated the same as generators of hazardous waste. The generators of 
large quantities of hazardous waste are required to remove waste from 
their sites within 90 days, unless they receive authorization for long-
term storage of this waste. However, other representatives were not in 
favor of establishing time limits for waste storage, for the most part 
because of uncertainties surrounding disposal availability in the 
United States. Some of the representatives noted that placing time 
limits on the storage of higher-activity LLRW could only be justified 
if it posed a safety and security risk. In this respect, almost all 
representatives (25/26) suggested that having a requirement that 
disused sealed radiological sources be returned to their source 
supplier would be an effective way to promote more timely removal of 
these sources from waste generator sites. 

The NRC chaired task force reported that while existing measures to 
ensure the safety and security of higher-activity sealed radiological 
sources are adequate, the current disposal system is prompting some 
users into long-term storage of their disused sources and otherwise 
creating significant disincentives for properly disposing of these 
sources. The report noted that the lack of a legal disposal pathway or 
the high costs of disposal due to the lack of alternative disposal 
options will perpetuate this situation until the disposal system 
changes. The task force report suggested that the U.S. government 
should encourage suppliers to provide arrangements for the return of 
disused sources. The task force noted that holding a source in storage 
longer than 24 months usually indicates the lack of a strategy to use 
or dispose of the source. As a result, the task force suggested that 
NRC consider a new requirement for licensees to review and document the 
reasons for storing higher-activity sources for longer than 24 months. 
Moreover, the task force suggested that once disposal options are 
available for GTCC waste (equivalent to long-lived intermediate-level 
waste), NRC should also consider requiring a maximum time limit on long-
term storage of disused sealed radiological sources that would be 
considered GTCC waste when packaged for disposal. 

Central Storage and Alternative Disposal Options Are Widely Used to 
Facilitate Management of LLRW: 

Ten of the 18 countries we surveyed have disposal options for lower-
activity LLRW and 6 have plans to build such facilities. While only 3 
countries indicated that they have a disposal option for higher-
activity LLRW, 14 reported that they have central storage facilities 
for this waste. Moreover, 13 countries indicated that they have 
clearance or unrestricted removal of very low-level radioactive waste 
from regulatory control as LLRW and eight countries indicated that they 
have disposal options for this waste. The U.S. LLRW stakeholder group 
representatives who responded to this issue were split on the need for 
central storage options for higher-activity LLRW when a disposal option 
is not available, but most of them supported exempting very low-level 
radioactive waste from regulatory control as LLRW. The NRC chaired task 
force and other reports have commented on the need to reexamine the 
disposal options for LLRW. 

About Half the Countries Make Disposal Options Available for Most Lower-
Activity LLRW: 

About half of the countries in our survey indicated that they currently 
have a disposal option for lower-activity LLRW, but few have a disposal 
option for higher-activity LLRW. Ten of 18 countries indicated that 
they have disposal options available for lower-activity LLRW, and 10 
have reported plans to build new or additional disposal facilities for 
lower-activity LLRW. While only 3 countries indicated that they 
currently have a disposal option for higher-activity LLRW, 14 have 
reported plans to develop a disposal facility for such waste. 

Other countries have made a variety of organizations responsible for 
providing and operating the existing or planned disposal facilities, 
including national regulatory authorities, nuclear utility 
organizations, and commercial waste management companies. In the 10 
countries that have disposal facilities for lower-activity LLRW, only 2 
indicated that a national organization is responsible for both 
providing and operating this disposal facility. The other eight 
countries indicated that these responsibilities were given to other 
combinations that sometimes included nuclear utilities and commercial 
waste management companies. In the 14 countries that are planning to 
build disposal facilities for higher-activity LLRW, 6 indicated that a 
national organization would be responsible for providing and operating 
the future disposal facility and 3 indicated that it would be another 
organization. The other countries indicated either a mix of 
responsibilities or they did not respond to the question. For example, 
the Netherlands has reported that it has decided to delay a final 
decision on developing a disposal facility and instead construct an 
engineered surface storage facility with sufficient capacity for all 
radioactive waste generated in a period of at least 100 years. However, 
if a disposal facility is ever constructed, this country indicated in 
its survey that its nuclear regulatory authority would be responsible 
for providing the facility and a national waste management organization 
would be responsible for operating it. In regard to the cost of 
disposal, half of the countries indicated that disposal fees are 
currently or anticipated to be set nationally, based on waste type. Two 
countries indicated that such fees are currently based on negotiations 
with disposal operators according to waste type. Mexico indicated use 
of both a national fee schedule and negotiated fees. Figure 5 provides 
a summary of LLRW disposal availability and management responsibilities 
across the countries in our survey. 

Figure 5: LLRW Disposal Options and Management Responsibilities

LLRW management approach: 
Disposal options are available for all LLRW: 
France: No; 
Japan: No; 
Germany: No; 
Canada: No; 
United Kingdom: No; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: No; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No; 
Denmark: No; 
Norway: No; 
Total Yes Count: 0. 

LLRW management approach: 
Disposal options are available for short-lived low- and intermediate-
level radioactive waste: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: Yes; 
Denmark: No; 
Norway: Yes; 
Total Yes Count: 10. 

LLRW management approach: 
There are plans to build a LLRW disposal facility for short-lived low- 
and intermediate-level radioactive waste: 
France: No; 
Japan: No; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: Yes; 
Australia: Yes; 
Denmark: Yes; 
Norway: No; 
Total Yes Count: 10. 

LLRW management approach: 
Disposal options are available for long-lived low-level radioactive 
waste: 
France: No; 
Japan: No Response; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No Response; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No; 
Denmark: No; 
Norway: No; 
Total Yes Count: 2. 

LLRW management approach: 
Disposal options are available for long-lived intermediate-level 
radioactive waste: 
France: No; 
Japan: No Response; 
Germany: No; 
Canada: No; 
United Kingdom: No; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No Response; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: No; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No Response; 
Denmark: No; 
Norway: Yes; 
Total Yes Count: 1. 

LLRW management approach: 
There are plans to build a disposal facility for long-lived low- and 
intermediate-level radioactive waste: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: Yes; 
Australia: Yes; 
Denmark: Yes; 
Norway: No; 
Total Yes Count: 14. 

LLRW management approach: 
A central organization (national nuclear regulatory authority or 
national waste management organization) is responsible for providing a 
waste disposal facility: 
France: Yes; 
Japan: No; 
Germany: Yes; 
Canada: No; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: No; 
Netherlands: Yes; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: Yes; 
Total Yes Count: 8. 

LLRW management approach: 
A central organization (national nuclear regulatory authority or 
national waste management organization) is responsible for operating a 
waste disposal facility: 
France: Yes; 
Japan: No; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: No; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: No; 
Netherlands: Yes; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 8. 

LLRW management approach: 
A nuclear utility organization is responsible for providing a waste 
disposal facility: 
France: No Response; 
Japan: Yes; 
Germany: No; 
Canada: Yes; 
United Kingdom: No; 
Sweden: No; 
Spain: Yes; 
Belgium: No; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 6. 

LLRW management approach: 
A nuclear utility organization is responsible for operating a waste 
disposal facility: 
France: No; 
Japan: No Response; 
Germany: No; 
Canada: Yes; 
United Kingdom: No; 
Sweden: Yes; 
Spain: No; 
Belgium: No; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: Yes; 
Total Yes Count: 6. 

LLRW management approach: 
A commercial waste management company is responsible for operating a 
waste disposal facility: 
France: No; 
Japan: Yes; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: No Response; 
Belgium: No; 
Finland: No Response; 
Switzerland: Yes; 
Slovak Republic: No Response; 
Hungary: No;  
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 4. 

LLRW management approach: 
Disposal fees are or planned to be determined by a national fee 
schedule based on type of radioactive waste: 
France: No; 
Japan: No; 
Germany: Yes; 
Canada: Not Applicable; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Not Applicable; 
Australia: Not Applicable; 
Denmark: Not Applicable; 
Norway: Yes; 
Total Yes Count: 9. 

LLRW management approach: 
Waste generators negotiate disposal fees based on type of radioactive 
waste: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: No Response; 
United Kingdom: No; 
Sweden: No; 
Spain: No Response; 
Belgium: No; 
Finland: No; 
Switzerland: No; 
Slovak Republic: No Response; Hungary: No; 
Mexico: Yes; 
Netherlands: No; 
Italy: Not Applicable; 
Australia: No Response; 
Denmark: Not Applicable; 
Norway: No; 
Total Yes Count: 2. 

Source: GAO survey of foreign countries, 2006, and reported information 
on planned LLRW disposal facilities in IAEA and NEA country reports.

Note: Countries are ordered according to their nuclear electricity 
generation at the beginning of 2006, as reported by NEA. The last four 
countries in the table currently do not have nuclear electricity 
generation, but Italy did in the past, and the other countries have 
nuclear research reactors. The United States would be the largest 
nuclear electricity generator if listed. 

[End of figure] 

Most Countries Have Central Storage for LLRW Lacking a Disposal Option: 

Most countries we surveyed currently have interim or long-term central 
storage options for some LLRW. Thirteen countries reported that they 
have central storage options available for lower-activity LLRW. Six 
countries reported that they have both disposal and some central 
storage options for this waste. Fourteen countries reported that they 
have central storage options for higher-activity LLRW, sometimes at 
large waste production sites as in France. For the most part, these 
countries do not have a disposal option for higher-activity LLRW, 
although Norway indicated that it had disposal and interim storage 
options for the long-lived, intermediate-level waste. Figure 6 provides 
a summary of the central storage options available in the countries we 
surveyed. 

Figure 6: Central Storage Options for LLRW: 

LLRW management approach: 
Disposal options are available for short-lived low- and intermediate-
level waste: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: Yes; 
Denmark: No; 
Norway: Yes; 
Total Yes Count: 10. 

LLRW management approach: 
Central storage options are available for short-lived low- and 
intermediate-level waste: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: No; 
Australia: No; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 13. 

LLRW management approach: 
Disposal options are available for long-lived low-level waste: 
France: No; 
Japan: No Response; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No Response; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No; 
Denmark: No; 
Norway: No; 
Total Yes Count: 2. 

LLRW management approach: 
Disposal options are available for long-lived intermediate-level waste: 
France: No; 
Japan: No Response; 
Germany: No; 
Canada: No; 
United Kingdom: No; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No Response; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: No; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: No; 
Denmark: No; 
Norway: Yes; 
Total Yes Count: 1. 

LLRW management approach: 
Central storage options are available for long-lived low-level waste 
and long-lived intermediate-level waste: 
France: Yes; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: No; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: No; 
Australia: No; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 14. 

Source: GAO survey of foreign countries, 2006, and reported information 
on central storage options for LLRW in IAEA and NEA country reports. 

Note: Countries are ordered according to their nuclear electricity 
generation at the beginning of 2006, as reported by NEA. The last four 
countries in the table currently do not have nuclear electricity 
generation, but Italy did in the past, and the other countries have 
nuclear research reactors. The United States would be the largest 
nuclear electricity generator if listed. 

[End of figure] 

Most Countries Make Alternative Disposal Options Available for Very Low-
Level Radioactive Waste: 

Most countries provide alternative disposal options for very low-level 
radioactive waste either by removing such waste from regulatory control 
as LLRW or providing special disposal arrangements. Almost all 
countries (15/18) indicated that their nuclear regulatory authorities 
exempt this waste from regulatory control as nuclear material, thus 
allowing alternative disposal options for the waste. The countries use 
various approaches to remove very low-level radioactive waste from 
regulatory control as LLRW, including general exemption, case-by-case 
exemption, and clearance. The most frequently cited approach used by 
the countries was exemption (15/18), followed by clearance (13/18), and 
then case-by-case exemption (11/18). For example, according to a May 
2005 updated nuclear development report submitted by Japan to the NEA, 
Japan followed IAEA guidance to amend its “Law for the Regulations of 
Nuclear Source Material, Nuclear Fuel Material and Rectors” to 
introduce a clearance system for materials, such as scrap metals and 
concrete used in nuclear installations. Half the countries in our 
survey indicated that they use all three management approaches.

Some countries in our survey indicated that they have alternative 
disposal options for very low-level radioactive waste. These options 
included disposal at municipal landfills, nuclear power plants, and in 
special facilities for such waste. Eight countries indicated that they 
have disposal options for very low-level radioactive waste. For 
example, in Sweden, this radioactive material is cleared for 
unrestricted use or disposal as conventional non-radioactive waste. 
Sweden reported that, in 2004, approximately 660 tons of very low-level 
radioactive waste was cleared for disposal at municipal landfills and 
approximately 550 tons of melted scrap metal was cleared for recycling. 
In contrast, France does not have a clearance threshold below which 
radioactive waste is no longer considered a radioactive hazard. 
Instead, France uses a case-by-case exemption process to allow for the 
disposal of very low-level radioactive waste in a special repository 
that was commissioned in 2003. The French government reported that this 
facility represents another essential component of France’s overall 
system for radioactive waste management and that it will accommodate 
most of the waste resulting from the decommissioning and dismantling of 
facilities in which radioactive substances have been used. Figure 7 
provides a summary of the disposal options and exemption methods used 
by countries in our survey for managing very low-level radioactive 
waste. 

Figure 7: Disposal Options and Exemption Methods for Managing Very Low- 
Level Radioactive Waste: 

LLRW management approach: 
Disposal options are available for very low-level radioactive waste: 
France: Yes; 
Japan: Yes; 
Germany: No; 
Canada: No; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: No; 
Belgium: No; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: No; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No; 
Italy: No; 
Australia: Yes; 
Denmark: No; 
Norway: Yes; 
Total Yes Count: 8. 

LLRW management approach: 
Exemption by the nuclear regulatory authority of a source or practice 
that need not be subject to some or all aspects of regulatory control 
on the basis that exposure is too small given the moderate quantities 
of radioactive material: 
France: No Response; 
Japan: Yes; 
Germany: Yes; 
Canada: Yes; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: Yes; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 15. 

LLRW management approach: 
Case-by-case exemption by the nuclear regulatory authority of large 
quantities of radioactive material the still requires some regulatory 
control: 
France: Yes; 
Japan: No; 
Germany: Yes; 
Canada: No; 
United Kingdom: No; 
Sweden: Yes; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: No; 
Italy: Yes; 
Australia: No Response; 
Denmark: No Response; 
Norway: Yes; 
Total Yes Count: 11. 

LLRW management approach: 
Clearance or unrestricted removal of radioactive materials or 
radioactive objects with authorized practices from any further 
regulatory control by the nuclear regulatory authority: 
France: No; 
Japan: Yes; 
Germany: Yes; 
Canada: No; 
United Kingdom: Yes; 
Sweden: Yes; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: Yes; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 13. 

Source: GAO survey of foreign countries, 2006. 

Note: Countries are ordered according to their nuclear electricity 
generation at the beginning of 2006, as reported by NEA. The last four 
countries in the table currently do not have nuclear electricity 
generation, but Italy did in the past, and the other countries have 
nuclear research reactors. The United States would be the largest 
nuclear electricity generator if listed. 

[End of figure] 

Domestic Experts Support Need to Examine Alternative Disposition 
Options for Some LLRW: 

The representatives of domestic LLRW stakeholder groups who responded 
in interviews to this issue as well as findings reported by some groups 
generally supported the need to evaluate alternative disposition 
options for some LLRW. In regard to developing central storage options 
for higher-activity LLRW when a disposal option is not available, the 
representatives were split in their support. Those in favor (13/27) 
noted that having a central storage option would encourage the 
efficient and timely removal of higher-activity LLRW from waste 
generator sites. For example, one representative commented that 
facilities such as hospitals, academic institutions, and some 
industries may have limited on-site storage space, restrictions placed 
on waste storage time in their license, or possession limits for 
radioactive material, which would need to account for the radioactivity 
in the stored waste. Those opposed (14/27) to developing central 
storage options for LLRW generally rejected this approach as an 
unnecessary step prior to disposing of the waste—a step they also saw 
as potentially increasing safety and security risks. For example, one 
representative commented that developing central storage for LLRW that 
does to have a disposal option would only detract from finding an 
ultimate disposal solution. 

The representatives from LLRW stakeholder groups were more supportive 
of the need for NRC to adopt a clearance rule in lieu of the current 
case-by-case exemption process for allowing very low-level radioactive 
waste to be removed from regulation as LLRW. Most representatives 
(19/25) who responded in interviews to this issue commented that a 
clearance rule would promote more rapid removal of very low-level 
radioactive waste from waste-generating sites or in some cases negate 
the need for the on-site removal of this type of radioactive waste. 
They also suggested that this action would expedite the cost-effective 
disposal of this waste by reducing administrative burdens, lowering 
disposal costs, and saving space in licensed LLRW disposal facilities 
for higher-activity LLRW. For example, one representative commented 
that knowing up front what type of radioactive waste would not require 
nuclear regulatory authority review prior to disposition could reduce 
the need to plan for storage space, shipment, and disposal of such 
waste as LLRW. Another representative commented that a clearance rule 
would provide a clear and consistent exemption for very low-level 
radioactive waste across the Agreement States and non-Agreement States. 
Several representatives supported the adoption of a clearance rule, but 
cautioned that public resistance and other factors have impeded 
previous NRC attempts to adopt this approach. Some representatives 
contended that exempting very low-level radioactive waste from disposal 
as LLRW might prompt LLRW disposal operators to increase the cost of 
disposing of the other LLRW to compensate for the lost revenue from no 
longer receiving large quantities of very low-level radioactive waste. 

The NRC chaired task force report concluded that a number of challenges 
are associated with disposing of all categories of commercial sealed 
radiological sources because of the limited number of available 
disposal facilities, the lack of options to dispose of all types of 
radioactive waste, and the high cost of disposal. The task force found 
that commercial LLRW disposal has evolved from an essentially free-
market system to a much more constrained and costly system today. 
However, the task force did not identify any immediate security 
concerns related to the higher-activity sources under review because 
licensees are required to safely and securely store these sources, and 
DOE has a program to recover sealed radiological sources that represent 
a threat to public heath, safety, and security. Nevertheless, the task 
force noted that because of uneven implementation of the LLRW Policy 
Act, several issues affect the disposal of higher-activity sources, 
such as the possible closure of the South Carolina LLRW disposal 
facility to non-compact member states. The task force recommended that 
the U.S. government evaluate the waste disposal options as outlined in 
the 2004 and 2005 GAO reports addressing this issue. [Footnote 12] 

The recent National Research Council report on Improving the Regulation 
and Management of Low-Activity Radioactive Wastes also commented on 
disposal options for low-activity waste (very low-level radioactive 
waste). The report noted that the United States could benefit from 
greater consideration of standards and practices developed 
internationally to institute risk-based management of very low-level 
radioactive waste. The report noted that European Commission and IAEA 
standards already provide guidelines for wastes that pose insignificant 
risks to be cleared or exempted from control as radioactive material. 
The report recommended that the United States give greater 
consideration to the international consensus standards surrounding 
alternative disposition options for very low-level radioactive, 
including disposal with other non-hazardous wastes, or disposal in 
special facilities suitable for such waste. The report did not 
conclude, however, that exemption or clearance should necessarily imply 
the free release of this waste into general commerce. 

Finally, NRC’s Advisory Committee on Nuclear Waste similarly commented 
on the need to examine alternative options for the disposition of some 
LLRW. The committee’s December 2005 white paper referred to previous 
recommendations the committee made to NRC with respect to concerns 
about the interim storage of LLRW at waste generator sites. The 
committee found that no evidence exists that on-site storage of waste 
can be safe and secure over the expected life of the waste and that the 
proliferation of on-site storage at waste generator sites across the 
country will only increase the probability of an adverse event. The 
white paper also discusses past initiatives by NRC to examine 
regulations governing future development of assured isolation 
facilities (central storage facilities) for LLRW. The committee found 
that only one Agreement State, Ohio, had such regulations as of the end 
of 2005. The committee report noted that in January 2004, the 
Commissioners directed NRC staff to defer action on the development of 
an assured isolation rule, but to annually review the need for further 
action in this area. 

Financial Assurance Requirements and Other Approaches Are Used by Most 
Countries to Reduce Government LLRW Recovery Costs: 

Nine of the 18 countries we surveyed indicated that their nuclear 
regulatory authorities require all non-utility LLRW generators to have 
sufficient financial assurances to cover the removal of radioactive 
waste from their sites. In addition, seven countries use other 
financial assurance approaches to ensure that the government is 
reimbursed for any sealed radiological sources that it may need to 
recover from non-utility LLRW generators. More than half of the 
representatives from U.S. LLRW stakeholder groups who responded to this 
issue and statements in the recent report from the NRC chaired task 
force indicated some need to improve the financial assurance structure 
for some LLRW generators. The task force report suggested that NRC 
evaluate some approaches that are similar to those used in some other 
countries to ensure that radioactive material users have financial 
reserves to cover waste disposition costs. 

Half of the Countries Require All Non-Utility LLRW Generators to Meet 
Financial Assurance Requirements: 

Half of the countries we surveyed indicated that they require all non-
utility LLRW generators to set aside sufficient financial reserves to 
cover waste disposition costs. These countries more often provide 
disposal options for lower-activity LLRW and generally provide central 
storage for higher-activity LLRW. In addition, three countries 
indicated that they have plans to impose financial assurance 
requirements on all non-utility LLRW generators. For example, Japan 
indicated that it planned to develop these requirements, but could not 
predict when they would be implemented. 

Some Countries Use Other Financial Approaches to Reduce Government 
Orphan Source Recovery Costs: 

Some countries have taken approaches to reduce the potential government 
costs of recovering orphan sealed radiological sources that are no 
longer under regulatory control. The Council of the European Union 
Directive 2003/122 states that all member countries must organize 
campaigns to recover orphan sources left behind by past activities, and 
suggests campaigns include financial participation by member countries 
in the costs of recovering, managing, and disposing of these sources, 
as well as in the review of records on the sealed radiological sources 
being used at research institutes, material testing institutes, and 
hospitals. This directive also requires that member countries ensure 
establishment of a system of financial assurance requirements or other 
equivalent means of reimbursing the government for its costs in 
recovering orphan sources. As a means to reimburse the government for 
orphan source recovery costs, 5 countries in our survey indicated that 
users of sealed radiological sources have established common funds to 
pay the LLRW disposition costs by source users. Moreover, 2 countries 
indicated that sealed radiological source recovery funds have been 
established by source suppliers to cover similar disposition costs for 
these companies. For example, in France, the association of source 
suppliers and manufacturers contribute to a common fund to reimburse 
the government for recovering sealed radiological sources from any 
supplier or manufacturer that is unable to disposition them. In cases 
where the supplier cannot be identified, the government is reimbursed 
by an insurance system implemented by the source manufacturers. In 
addition, France indicated on its survey that under the new radiation 
protection regulations consideration is being given to examining the 
benefits of adding financial guarantees to this system. Nine countries 
indicated that they either require a disposal fee at the time that a 
source is purchased or are planning to impose such a fee to ensure that 
funds are available to reimburse government for the costs of recovering 
orphan sources. Figure 8 provides a summary of the financial approaches 
used by the countries in our survey to reduce government costs of 
recovering LLRW. 

Figure 8: Financial Approaches to Reduce Government Costs to Recover 
LLRW: 

LLRW management approach: 
Requirement that sufficient funds be set aside by non-nuclear power 
plant entities to pay the cost of the central storage and/or disposal 
of their LLRW: 
France: No; 
Japan: No; 
Germany: No; 
Canada: Yes; 
United Kingdom: No Response; 
Sweden: No; 
Spain: Yes; 
Belgium: Yes; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: Yes; 
Mexico: No; 
Netherlands: Yes; 
Italy: No; 
Australia: No; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 9. 

LLRW management approach: 
Plan to implement a requirement that sufficient funds be set aside by 
non-nuclear power plant entities to pay the cost of the central storage 
and/or disposal of their LLRW: 
France: No; 
Japan: Yes; 
Germany: No; 
Canada: Not Applicable; 
United Kingdom: No Response; 
Sweden: No Response; 
Spain: Not Applicable; 
Belgium: Not Applicable; 
Finland: Not Applicable; 
Switzerland: No; 
Slovak Republic: Not Applicable; Hungary: Not Applicable; 
Mexico: Yes; 
Netherlands: Not Applicable; 
Italy: Yes; 
Australia: No; 
Denmark: Not Applicable; 
Norway: Not Applicable; 
Total Yes Count: 3. 

LLRW management approach: 
Orphan source recovery costs paid by a national organization: 
France: Yes; 
Japan: No; 
Germany: Not Applicable; 
Canada: Not Applicable; 
United Kingdom: Yes; 
Sweden: Not Applicable; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: Not Applicable; 
Slovak Republic: Yes; 
Hungary: Not Applicable; 
Mexico: Yes; 
Netherlands: Yes; 
Italy: Not Applicable; 
Australia: Not Applicable; 
Denmark: Yes; 
Norway: Yes; 
Total Yes Count: 9. 

LLRW management approach: 
Orphan source recovery costs paid by disposition fund established by 
source users: 
France: No; 
Japan: No; 
Germany: No Response; 
Canada: No Response; 
United Kingdom: No Response; 
Sweden: No; 
Spain: No; 
Belgium: Yes; 
Finland: No Response; 
Switzerland: No Response; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: No; 
Netherlands: Yes; 
Italy: Yes; 
Australia: No Response; 
Denmark: No Response; 
Norway: Yes; 
Total Yes Count: 5. 

LLRW management approach: 
Orphan source recovery costs paid by disposition fund established by 
source suppliers: 
France: Yes; 
Japan: No; 
Germany: No Response; 
Canada: No Response; 
United Kingdom: No Response; 
Sweden: No; 
Spain: No; 
Belgium: No; 
Finland: No Response; 
Switzerland: No Response; 
Slovak Republic: No Response; 
Hungary: Yes; 
Mexico: No; 
Netherlands: No Response; 
Italy: No; 
Australia: No Response; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 2. 

LLRW management approach: 
Requirement that a disposal fee be assessed when a sealed radiological 
source is purchased to pay the cost of future central storage and/or 
disposal costs: 
France: Yes; 
Japan: No; 
Germany: No; 
Canada: No; 
United Kingdom: No; 
Sweden: Yes; 
Spain: Yes; 
Belgium: No; 
Finland: Yes; 
Switzerland: No; 
Slovak Republic: Yes; 
Hungary: No; 
Mexico: No; 
Netherlands: Yes; 
Italy: No; 
Australia: No; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 6. 

LLRW management approach: 
Plan to establish a requirement that a disposal fee be assessed when a 
sealed radiological source is purchased to pay the cost of future 
central storage and/or disposal costs: 
France: No Response; 
Japan: No; 
Germany: No; 
Canada: No Response; 
United Kingdom: No Response; 
Sweden: Yes; 
Spain: No Response; 
Belgium: No; 
Finland: No Response; 
Switzerland: No; 
Slovak Republic: No Response; Hungary: No; 
Mexico: Yes; 
Netherlands: No Response; 
Italy: Yes; 
Australia: No; 
Denmark: No Response; 
Norway: No; 
Total Yes Count: 3. 

Source: GAO survey of foreign countries, 2006. 

Note: Countries are ordered according to their nuclear electricity 
generation at the beginning of 2006, as reported by NEA. The last four 
countries in the table currently do not have nuclear electricity 
generation, but Italy did in the past, and the other countries have 
nuclear research reactors. The United States would be the largest 
nuclear electricity generator if listed. 

[End of figure] 

Domestic Experts Support the Need to Evaluate Financial Assurance 
Approaches: 

The potential usefulness of financial assurance approaches that were 
identified through our survey was reflected in interviews with domestic 
LLRW stakeholder group representatives. More than half of the 
representatives (8/14) who responded to this issue in interviews 
commented on the need to improve the financial assurance structure for 
LLRW generators in the United States. These representatives suggested 
approaches to improve financial assurances, such as new rulemaking by 
NRC, periodic updating of the level of financial assurance requirements 
for LLRW generators, and providing a mechanism for small businesses 
that cannot self-guarantee financial assurance to otherwise provide 
this assurance. In addition, some of the representatives (5/16) 
supported the imposition of a disposal fee at the time of source 
purchase to help promote a more cost-effective disposal system and more 
predictable disposal costs for source users. For example, one 
representative noted that imposing such a fee has merit, but obtaining 
a commitment or obligation to pay the disposal fee would be an 
important first step. 

The NRC chaired task force found that sealed radiological source users 
are moving disused sources into prolonged storage because they are not 
required to have financial assurance to cover the disposal costs or 
otherwise appropriately dispositioning their disused sources. The 
report reiterated the concern that prolonged storage of disused sources 
can lead to possible misuse, abandonment, loss, or theft. Further, the 
task force found that the cost of source disposal can often be high, 
prompting the holders of disused sources to delay disposal either by 
choice or economic necessity. The task force identified three options 
to improve financial assurance coverage that were in many ways similar 
to approaches used to varying extents in other countries. The first 
option is to broaden NRC financial assurance requirements to include 
those entities that have lower thresholds of radioactive materials. 
This option would ensure that adequate funds are set aside by these 
entities to cover their waste disposition costs. However, the task 
force found that this action alone would not cover government costs of 
recovering orphan sources or sources for which there is no responsible 
or financially capable party. Thus, two other options were proposed 
that include (1) assessing a source-specific surcharge at the time of 
source acquisition or throughout a source’s service life to pay the 
costs of disposal, and (2) assessing a universal disposal surcharge on 
all licensees of radioactive material (not limited to sealed 
radiological source holders) to cover waste disposition costs. The task 
force recommended that NRC evaluate these alternative financial 
assurance options and include the impacts on the regulated community, 
implementation approaches, and the involvement of stakeholders. 

National Radioactive Waste Management Plans Are Considered Important 
for Managing LLRW: 

We also found that 12 of the 18 countries surveyed rely on national 
radioactive waste management plans to guide the management of their 
radioactive wastes. Several of these plans required the management of 
radioactive waste from a national perspective and specified one 
administrative entity as responsible for coordinating their 
development. In addition, there was often a requirement in the plans 
for periodic public reporting of LLRW conditions. While the usefulness 
of such a plan was not sought through a question in the survey or 
specifically raised in interviews with U.S. LLRW stakeholder group 
representatives, most of the representatives and recent reports on LLRW 
management mentioned the need to evaluate alternative ways to manage 
LLRW in the United States. 

Many Countries Have Developed Radioactive Waste Management Plans That 
Are National in Scope and Formulated by One Administrative Entity: 

At least 12 of the 18 countries in our survey have national radioactive 
waste management plans or draft plans to guide the management of this 
material. The 12 countries included Belgium, Canada, France, Germany, 
Italy, Japan, the Netherlands, Slovakia, Spain, Sweden, Switzerland, 
and the United Kingdom. While the other countries may also have such 
plans, we did not ask whether they had one in our survey. We identified 
the 12 countries with management plans through a review of recent IAEA 
and NEA country reports. The management plans from France, Germany, and 
Spain contain strategies to address all radioactive waste types. They 
are formulated by either a national level ministry or national waste 
management organization, often through consultation with other 
stakeholder groups. The management plans are approved by the 
parliament, with in some cases requirements for periodic reporting of 
waste management conditions back to the governing body. 

France: 

In 2003, the national nuclear regulatory authority of France formulated 
a national plan for the management of radioactive waste and reusable 
material. The development of this plan involved many stakeholders, 
including the national waste management organization, waste producers, 
elected representatives, and professional associations. According to 
the 2006 Program Act on the Sustainable Management of Radioactive 
Materials and Wastes, the national management plan will evaluate 
existing management approaches for radioactive materials and waste, 
identify foreseeable needs for storage or disposal facilities and the 
time frame for storage as well as assess the management approaches for 
radioactive wastes that do not yet have a path to disposal. The Program 
Act also states that the national plan for managing radioactive 
materials and wastes will be updated and reported to the parliament by 
the nuclear regulatory authority every 3 years.

Germany: 

According to a 2006 update report to NEA on the status of German 
radioactive waste management, in late 2001 Germany amended its Atomic 
Energy Act to request that the Federal Ministry for the Environment 
prepare and submit a national waste management plan. At the same time 
it amended this act, the parliament decided to phase out the use of 
nuclear energy for commercial electricity generation. According to the 
report, the draft plan, which is expected to be approved by parliament 
in 2007, addresses the strategic management of all radioactive waste, 
provides an inventory of existing radioactive waste, forecasts further 
waste production, delineates waste management planning for the next few 
years, and contains recommendations and required actions. The national 
radioactive waste inventory, for the first time, captures all types of 
radioactive waste, including high-level waste, waste from research, 
medicine, and industry; decommissioning waste from nuclear power 
plants; and uranium mine and mill tailing waste. Until a final disposal 
site in a deep geologic formation is available for all radioactive 
waste, the plan calls for the German federal states to construct and 
operate regional interim storage facilities for all non-utility waste 
generators, and requires nuclear power plants to provide interim on-
site waste storage. 

Spain: 

In 2006, Spain adopted its sixth general radioactive waste plan. This 
plan replaces the previous plan enacted 7 years ago. As stated in the 
plan, this document contemplates the strategies, the necessary actions, 
and the technical solutions to be developed in the short-, medium-, and 
long-term to ensure the adequate management of radioactive waste, the 
dismantling and decommissioning of nuclear and radioactive facilities, 
and related activities, including the economic and financial measures 
required to carry them out. Further, this document states that this 
plan is the basic reference document that clearly and concisely 
addresses all the strategies and actions to be undertaken in Spain with 
regard to the different fields of radioactive waste management and the 
dismantling of facilities, along with a corresponding study of economic 
and financial conditions. The plan, among other components, presents 
the data related to radioactive waste generation, programs for removal, 
the capacity of disposal facilities as well as costs and revenues. 
Every 4 years or whenever requested by the cognizant ministry, the 
national waste management organization develops a new radioactive waste 
management plan, which is submitted to government and then reported to 
the parliament. The national waste management organization, a state-
owned company established in 1984, has been given the responsibility 
for radioactive waste management and decommissioning of nuclear 
facilities. In addition to this action, the national waste management 
organization must draw up an annual report describing the actions taken 
during the previous financial year and any incremental revisions that 
need to be made to the general radioactive waste plan. 

Domestic Experts Support Need to Evaluate the U.S. LLRW Management 
System: 

There was general agreement among the representatives from the LLRW 
stakeholder groups that the management of LLRW in the United States 
needs improvement. Most of the representatives who responded to 
questions associated with this issue (22/29) suggested that the time is 
right to explore alternative approaches to make the LLRW disposal 
system more predictable (reliable) and stable (cost-effective). Many of 
the representatives cited the proposed closure of the South Carolina 
disposal facility to non-compact waste generators as the reason to 
explore these alternatives approaches. However, one representative 
cautioned that while the present disposal system in the United States 
is not what was envisioned in the LLRW Policy Act, it is an alternative 
that has generally provided disposal availability to most waste 
generators. As we did not directly ask the representatives about the 
need for a national radioactive waste management plan at the time of 
the interviews, we have no basis to tabulate their reaction to this 
specific LLRW management approach. 

The National Research Council of the National Academies recently 
reported on improving the regulation and management of low-activity 
waste in the context of the U.S. LLRW management system. The report 
recommended that regulatory agencies develop integrated strategies to 
implement risk-informed regulation for very low-level radioactive 
waste. According to the report, such a strategy would require continued 
integration and coordination among the regulatory agencies, including 
NRC, DOE, the Environmental Protection Agency, Department of Defense, 
and other federal and state agencies. Moreover, the report recommended 
that government agencies continue to explore ways to improve their 
efforts to gather knowledge and opinions of stakeholders, particularly 
public stakeholders. While the report did not go so far as to recommend 
the establishment of a national radioactive waste management plan, it 
did find that the current patchwork of regulations is complex and 
inconsistent—leading in some instances to inefficient management 
practices and possibly to increased overall risk in the system. 

Finally, in May 2006, the NRC Advisory Committee on Nuclear Waste 
agreed to examine issues surrounding the shortcomings in the national 
LLRW management system. The committee solicited industry and 
stakeholder views regarding the future role of NRC in the area of 
commercial LLRW management, noting that NRC staff is updating its LLRW 
strategic plan following NRC-directed program reductions. In an August 
2006 letter to the NRC Commissioners, the committee recommended that an 
examination be undertaken of how NRC and the Agreement States are 
preparing to regulate potential increases in the storage of class B and 
C waste if and when the LLRW disposal facility in South Carolina closes 
to waste generators in non-compact states and no alternative options 
become available. While the committee did not call for developing a 
national radioactive waste management plan, it seemed to suggest the 
need for contingency planning in the context of a strategic approach to 
NRC’s involvement in LLRW management. 

Conclusions: 

The 18 countries surveyed rely on a wide variety of approaches to 
manage their LLRW. However, the extent to which each country uses these 
LLRW management approaches varied across the surveyed countries. Based 
on previous GAO reports, other pertinent reports, and responses to 
GAO’s survey, it appears that the United States relies on these 
approaches to a lesser degree or not at all. In some cases, NRC has 
already evaluated the merits of implementing some of these approaches 
and rejected them or is in the process of evaluating the usefulness of 
a few other approaches. Comments from representatives of U.S. LLRW 
stakeholders groups as well as statements and recommendations in recent 
reports related to LLRW management indicate that the application of 
approaches similar to those used in other countries may improve the 
management of U.S. radioactive waste. The management approaches 
identified in this report include methods to improve the: 

1. Comprehensiveness and usefulness of national radioactive waste 
inventory databases: 
* inventory all types of radioactive waste by volume, location and 
generator type; 
* inventory the possession and status of use of sealed radiological 
sources in more than category 1 and 2; 
* designate a national authority to manage the radioactive waste 
inventory databases; 
* take steps to verify the completeness and accuracy of these 
databases; 
* require waste generators to submit waste inventory information to the 
national authority at least once a year; and; 
* use the radioactive waste inventory databases to forecast future 
waste volumes, and to inform the public on volumes of waste at central 
storage and disposal facilities. 

2. Prompt removal of higher-activity LLRW, primarily disused sealed 
radiological sources from waste generator sites: 
* establish on-site storage time limits for non-utility waste 
generators, at least when disposal options are available; and; 
* implement other methods to facilitate the removal disused sealed 
radiological sources, such as requiring time limits on the use of 
sources, return of disused sources to a supplier, and users to notify 
the nuclear regulatory authority when the source becomes disused. 

3. Disposition options for all LLRW: 

* provide disposal options for all LLRW or central storage options for 
higher-activity LLRW produced by non-utility waste generators if a 
disposal option is not available; and; 
* provide alternative disposal options for very low-level radioactive 
waste by either removing this waste from review by the nuclear 
regulatory authority as LLRW, or providing special disposal options for 
this waste. 

4. Financial assurance requirements on all waste generators to reduce 
government disposition costs: 
* require that all non-utility LLRW generators have sufficient 
financial reserves to disposition their radioactive waste; and; 
* implement methods to ensure that funds are available to reimburse 
government for any costs to recover and disposition radioactive 
materials, including requiring the establishment of insurance funds for 
entities that receive disused sources back from their users, and a 
disposal fee upon purchase of any sealed radiological sources. 

In addition to the survey results, we also identified another 
management approach used in most countries—national radioactive waste 
management plans—that also might provide lessons for managing U.S. 
radioactive waste. IAEA guidance supports the development of a national 
strategy to define the infrastructure and the means to be adopted for 
the management of radioactive waste. Currently, the United States does 
not have a national radioactive waste management plan and does not have 
a single federal agency or other organization responsible for 
coordinating LLRW stakeholder groups to develop such a plan. Such a 
plan for the United State could integrate the various radioactive waste 
management programs that reside at the federal and state levels into a 
single source document. A national plan could assist those interested 
in radioactive waste management to identify waste quantities and 
locations, plan for future storage and disposal development, uncover 
research and development opportunities, and assess the need for 
regulatory or legislative actions. For example, there are no national 
contingency plan, other than allowing LLRW storage at waste generator 
sites, to address the impending closure of a key LLRW disposal 
facility. The availability of a national plan and periodic reporting on 
waste conditions might also provide the Congress and the public with a 
more accessible means to monitor the management of radioactive waste 
and provide a mechanism to build greater public trust in the management 
of these wastes in the United States. 

Recommendations: 

In order to improve the management of LLRW in the United States and 
address a potential shortfall of disposal availability for higher-
activity LLRW in 2008 and other management concerns, we recommend that 
the Chairman of NRC and the Secretary of Energy evaluate and report 
back to the Congress within 1 year on the usefulness to the United 
States of: 

* Adopting the LLRW management approaches used in the countries 
discussed in this report, and the steps and any authorities necessary 
for their implementation, if deemed appropriate. 

* Developing a U.S. radioactive waste management plan, and the 
potential costs, steps, and any authorities necessary to develop such a 
plan, if deemed appropriate. 

Agency Comments and Our Evaluation: 

We provided a draft of our report to NRC, DOE, and the State Department 
for their review and comment. The State Department did not comment on 
the draft report. NRC and DOE generally agreed with the recommendations 
in our draft report, but raised a number of issues regarding their 
implementation. Specifically, they suggested other means through which 
they could report the results of their evaluations to Congress and they 
questioned the benefits of developing a national radioactive waste 
management plan. While we recognize the long-standing experience and 
international leadership of NRC and DOE in the field of radioactive 
materials, the intent of our report is to discuss the approaches used 
in other countries. Based on our findings, we are recommending that NRC 
and DOE collaborate in reviewing, and in some cases perhaps 
reconsidering, the management approaches identified on pages 36-37 of 
this report for their potential usefulness in the United States. We 
believe the Congress would benefit from a collaborative evaluation or 
reevaluation of these approaches to ensure that the best management 
approaches are used in the United States. 

NRC stated that it has already evaluated many of the LLRW management 
approaches and is in the process of evaluating some others as part of a 
strategic assessment of its LLRW program to ensure that NRC’s 
regulatory framework will continue to ensure the safe management of 
LLRW. Further, NRC stated that it prefers to evaluate LLRW management 
approaches through ongoing efforts and to report on these evaluations 
in its annual letter to the Congress that addresses progress in 
completing actions in response to recommendations in multiple GAO 
reports. NRC also raised some concerns about our recommendation to 
evaluate and report on the development of a national radioactive waste 
management plan in specific comments accompanying its letter. While NRC 
did not disagree with this recommendation, it pointed out that the 
costs to develop a U.S. radioactive waste management plan would be 
significant and the benefits unclear, particularly given the complex 
composition of the current U.S. system. NRC noted that legislative 
changes would likely be needed before the development of a plan could 
substantially improve the U.S. system. 

DOE stated that it regards the report as a useful comparison of U.S. 
LLRW programs with comparable international programs. DOE accepted the 
recommendation to evaluate the international approaches summarized in 
our report, but did not agree that a report to the Congress is 
necessary at this time. DOE offered to brief the Congress on the status 
of its radioactive waste management efforts if asked to do so. 
Regarding the development of a national radioactive waste management 
plan, DOE stated that a single document synthesizing the activities of 
numerous agencies and entities involved in radioactive waste management 
would facilitate understanding of these complex programs. However, DOE 
commented that it is concerned that development of such a document 
would provide limited utility to the actual implementation of these 
strategies yet would require diversion of significant resources from 
actual waste management efforts. Moreover, DOE suggested that the U.S. 
Second National Report for the Joint Convention on the Safety of Spent 
Fuel Management and on the Safety of Radioactive Waste Management 
provides a summary of the existing national waste management 
strategies, issues, and progress. 

We recognized in our report that NRC has evaluated some of the LLRW 
management approaches in the past and is currently evaluating some 
others. We also found that many of the U.S. LLRW stakeholder 
representatives that we interviewed and some recent U.S. LLRW 
management reports generally supported the reevaluation, if not use of 
many of the management approaches identified in our report. We believe 
that the Congress would benefit from a consolidated report that 
contains the evaluations of these LLRW management approaches as they 
apply to the U.S. situation. In regard to reporting, we do not take 
issue with how the agencies might collaborate together and with other 
LLRW stakeholder groups on reporting back to the Congress on these 
management approaches as long as the evaluations are comprehensive. 

We acknowledge the concerns of NRC and DOE regarding our draft 
recommendation to evaluate and report on the development of a national 
radioactive waste management plan. We have revised this recommendation 
to clarify that the agencies need to evaluate and report on the 
usefulness of such a plan and conduct further analysis if deemed 
appropriate. We still conclude that the use of a national radioactive 
waste management plan in most other countries in our survey and our own 
assessment of its potential benefits, as reflected on pages 37-38 of 
this report, indicates to us that there is value in further evaluating 
this management approach. In addition, in our view, the U.S. national 
report to the Joint Convention provides useful information on 
radioactive waste management, but the waste inventory information in 
this report is not comprehensive and the document does not contain 
strategies to guide the management of radioactive waste. The letters 
from NRC and DOE, along with our responses to their specific comments 
are contained in appendix VI and VII, respectively. 

We will send copies of this report to the appropriate congressional 
committees as well as to the Chairman of NRC and the Secretary of 
Energy. We will make copies available to others upon request. In 
addition, the report will be available at no charge on the GAO Web site 
at [hyperlink, http://www.gao.gov]. 

If you or your staff has any questions about this report, please 
contact me at (202) 512-3841 or at aloisee@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff members that made 
contributions to this report are listed in appendix VIII. 

Signed by: 

Gene Aloise: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Recent GAO Findings and Agency Actions on LLRW Management: 

GAO reports have addressed various aspects of low-level radioactive 
waste (LLRW) management in the United States. [Footnote 13] We reported 
in 2004 on the scope and reliability of national LLRW inventory 
information and found that the Department of Energy (DOE)’s commercial 
LLRW disposal database did not contain data on all disposed LLRW, did 
not capture information on LLRW that is produced and stored at waste 
generator sites, and had data inaccuracies. We recommended that DOE 
take steps to correct internal control weaknesses and shortcomings in 
the usefulness and reliability of this database, which DOE claims it 
has for the most part accomplished. More recently, we reviewed the U.S. 
report to the Joint Convention on the Safety of Spent Fuel Management 
and on the Safety of Radioactive Waste Management, which commits the 
United States to, among other things, report on its national inventory 
of radioactive waste, but does not prescribe how this should be done or 
the level of reporting detail regarding the location and quantities of 
LLRW. The U.S. report includes the location and quantities of DOE’s 
radioactive waste in storage and disposal as well as the commercially-
generated LLRW that has been disposed of, but less comprehensive 
coverage of the location and quantities of non-DOE LLRW in storage 
around the country. The response of the United States to the GAO survey 
highlighted some gaps in the U.S. radioactive waste inventory. The 
United States is also committed through its signing of the Joint 
Convention to take steps to ensure the safe possession, remanufacture, 
or disposal of disused sealed radiological sources. One step in this 
direction is the establishment of a national radioactive source 
registry in support of the IAEA Code of Conduct for the Safety and 
Security of Radioactive Sources. We recommended in our 2005 report that 
the Nuclear Regulatory Commission (NRC) and DOE, in collaboration with 
the Radiation Source Protection and Security Task Force, evaluate and 
report on how its source registry (National Source Tracking System) 
could be designed and implemented to improve DOE’s ability to identify 
and track sources that may need DOE recovery and disposal. [Footnote 
14] We found that 98.5 percent of the disused sealed radiological 
sources that DOE had recovered as of June 2005 would not have been 
included in the National Source Tracking System. NRC’s final rule on 
this source tracking system stipulates the tracking of only category 1 
and 2 sources, although NRC indicated that additional sources could be 
added through subsequent rulemaking. [Footnote 15] NRC has no plans to 
monitor the status of sealed radiological source use in this tracking 
system. However, according to NRC officials, the online version of the 
tracking system will allow licensees to voluntarily provide information 
on whether a source has been put in storage and will no longer be used. 
Appendix IV contains an assessment of what is known about the volume 
and location of LLRW in the United States. 

In regard to the safety and security of stored class B, C, and GTCC 
waste, we reported in 2004 about the possible increase in the storage 
of this higher-activity LLRW at generator sites because, among other 
reasons, generators may decide to store their waste on-site because of 
high disposal costs. While NRC does not place time limits on the 
storage of LLRW, NRC claims that its licensing and inspection programs 
for waste generators provide assurance that stored LLRW will remain 
safe and secure. Moreover, NRC contends that with the exception of 
disused sealed radiological sources, LLRW does not present an 
attractive target for adversaries. In regard to the safety and security 
of sealed radiological sources, NRC reported that it has conducted 
vulnerability assessments, imposed new security measures on those 
licensees that possess category 1 and 2 sources, and it is reviewing 
the adequacy of its guidance for long-term LLRW storage as well as 
possible updates to this guidance. NRC officials informed us that the 
new security measures also apply to licensees who possess aggregations 
of category 3 or lesser-activity source categories that would meet or 
exceed the category 2 radioactivity threshold. In addition, they told 
us that NRC requires the timely removal of radioactive material as part 
of the decommissioning process. Nevertheless, the response of the 
United States to the GAO survey indicated that NRC does not enforce the 
removal of disused sealed radiological sources from licensees that 
generate this waste or require them to return their disused sources to 
the source supplier. As we reported in 2005, NRC works with DOE to 
identify disused sealed radiological sources at user sites that should 
be recovered because they pose a safety and security risk. The 
Conference on Radiation Control Program Directors also provides a 
clearinghouse service for users to disposition their disused sources. 
We noted, however, that the lack of information to track the number and 
status of sealed radiological sources that may require recovery and 
disposal in the future limits DOE’s ability to effectively plan and 
budget for its recovery and disposal efforts and to monitor the 
performance of its source recovery program. 

We also reported on LLRW disposal options in the United States, which 
are affected by federal and state nuclear regulatory authorities, 
commercial LLRW disposal operators, and LLRW compact commissions. We 
found in our 2004 report that there appears to be sufficient disposal 
capacity for class A, B, C waste, but uncertain future access to a 
disposal facility for class B and C waste. In our 2005 report, we found 
that there was some central storage for GTCC waste, essentially for 
disused sealed radiological sources recovered by DOE, but no disposal 
availability. These reports and others have commented on the many 
factors affecting the predictability of disposal availability and 
disposal costs. For example, NRC and the Agreement State regulators are 
involved in granting the approval of LLRW disposal facilities and the 
classes of waste that can be accepted. They also have discretion, on a 
case-by-case basis, to exempt very low-level radioactive waste from 
regulation as LLRW, thus providing waste generators with more disposal 
options for this waste. [Footnote 16] According to NRC officials, 
approvals for waste generators in states under its jurisdiction have 
been granted for small quantities of waste—averaging about 2 per year 
over the past 6 years—however, no comparable information is available 
on the 34 Agreement States. NRC officials also told us that the agency 
has attempted to improve the transparency of this process for a number 
of stated reasons, including the anticipation that there will be large 
amounts of this waste from nuclear power plant decommissioning. NRC has 
evaluated and decided to defer action on a rule that would exempt very 
low-level radioactive waste from having to go through regulatory review 
as LLRW. The LLRW compact commissions can also affect the 
predictability of the disposal system because they have discretion to 
restrict access to disposal facilities as well as to charge variable 
disposal fees based not only on waste type but the type of generator. 
Likewise, commercial disposal facility operators can affect the 
predictability of the disposal system. For example, the operator of the 
disposal facility that accepts almost all of the class A waste charges 
variable disposal fees based on the generator of the waste. Waste 
generators, such as DOE and nuclear power plants, which dispose of 
large volumes of class A waste, can negotiate lower disposal fees per 
volume of waste than generators that dispose of much smaller quantities 
of this waste. Appendix V contains a discussion of the type of waste 
and waste generators that would be affected by reduced access to the 
South Carolina disposal facility. For example, of the 671 waste 
generators that sent disused sealed radiological sources to the South 
Carolina disposal facility between 2001 and 2005, only 70 would be 
allowed to do so after mid-2008. 

In our 2005 report we commented on the limitations on DOE’s ability to 
recoup its costs for recovering disused sealed radiological sources 
from non-utility waste generators. The response of the United States to 
the GAO survey indicated that not all non-utility waste generators, 
particularly those possessing sealed radiological sources, are 
currently required to ensure that funds are available to cover future 
LLRW disposition costs. NRC officials told us that they are revising 
the financial assurance regulations aimed at addressing sites that 
permanently cease radiological operations without adequate funds to 
complete decommissioning. The revised regulations are intended to 
address problems with funding large, complex sites that may include 
extensive soil and groundwater contamination. The disposal of disused 
sealed radiological sources is not part of this rulemaking. For non-
Agreement States, NRC officials indicated that about 5 to 10 small 
businesses possessing sealed radiological sources go bankrupt each 
year. However, NRC officials informed us that they have no information 
on the annual number of bankruptcies in the 34 Agreement States. In 
cases where waste generators do not have the funds to cover the cost of 
removing, centrally storing, or disposing of their higher-activity 
disused sealed radiological sources, the U.S. government has covered 
these costs. One of NRC’s performance goals is to reduce the potential 
for unnecessary federal government funding to clean up sites if 
licensees go bankrupt and have insufficient financial reserve to cover 
these costs. According to NRC officials, the potential expansion of the 
financial assurance requirements for its licensees will ensure that 
they can meet their responsibilities to cover the cost to disposition a 
broad range of radioactive materials, including sealed radiological 
sources. NRC officials note that this initiative may also help reduce 
the cost of DOE’s program to recover disused sealed radiological 
sources. Nevertheless, DOE officials told us that the department has no 
basis to charge waste generators to recover and store disused sealed 
radiological sources that would generally constitute GTCC waste when 
disposed of because there is presently no disposal option for this 
waste and thus no basis to determine a service fee schedule. In our 
2005 report, we recommended that NRC and DOE evaluate mechanisms to 
reduce government costs of recovering, storing and disposing of higher-
activity LLRW. The response of the United States to the GAO survey 
indicated that NRC does not require a disposal fee at the time of 
purchase or require that source users and suppliers contribute to a 
recovery fund. 

Finally, in reviewing the U.S. report to the Joint Convention on the 
Safety of Spent Fuel Management and on the Safety of Radioactive Waste 
Management, prepared by DOE in cooperation with other federal agencies, 
we noted that while the report describes existing national policies and 
practices for managing radioactive waste, it does not constitute a 
national radioactive waste management plan. However, the Joint 
Convention does not mention the need for such a plan and there is no 
requirement in U.S. legislation for a federal agency to prepare a plan. 
While the LLRW Policy Act required DOE to report to the Congress 
annually on national LLRW conditions, the provision, which terminated 
effective May 2000, it did not require a national radioactive waste 
management plan. DOE officials have, however, provided us with a draft 
copy of the department’s strategy to optimize the disposition of DOE 
low-level and mixed low-level radioactive waste. Similarly, NRC 
officials told us that their responsibilities to oversee the use, 
storage and disposal of radioactive materials do not include 
development of a national radioactive waste management plan. However, 
NRC officials informed us that in light of new challenges, influences, 
and issues facing LLRW management today, they are currently conducting 
a strategic assessment that will identify and prioritize staff 
activities to ensure a stable, reliable, and adaptable regulatory 
framework for effective LLRW management. 

[End of section] 

Appendix II: Scope and Methodology: 

In our review, we examined the extent to which foreign countries have 
(1) comprehensive national LLRW inventory databases, (2) timely removal 
of higher-activity LLRW in storage at waste generator sites, (3) 
disposition options for all LLRW, and (4) requirements to assure that 
LLRW generators have adequate financial reserves to cover all waste 
disposition costs. We also examined another management area that 
surfaced during our review pertaining to the use of national 
radioactive waste management plans. Our examination primarily relied on 
a survey of radioactive waste management officials in countries, along 
with the United States that account for 85 percent of the world’s 
installed nuclear power plant capacity. To better understand the 
context of managing LLRW in other countries, we also spoke with 
radioactive waste management officials and visited disposal facilities 
in France, Japan, and Sweden. To describe the status of LLRW management 
in the United States, we obtained responses from NRC to the same 
questionnaire sent to other countries, interviewed NRC and DOE 
officials as well as representatives from a wide range of domestic LLRW 
stakeholder groups, and reviewed past GAO reports and other pertinent 
documents. 

Specifically, we developed, pretested, and sent out questionnaires to 
20 countries to identify foreign experiences in managing LLRW. The 
countries included Australia, Belgium, Canada, Czech Republic, Denmark, 
Finland, France, Germany, Hungary, Italy, Japan, Mexico, the 
Netherlands, Norway, Slovak Republic, South Korea, Spain, Sweden, 
Switzerland, and United Kingdom. These countries, along with the United 
States, are represented on the NEA Radioactive Waste Management 
Committee. [Footnote 17] The questionnaire contained 32 questions and 
potential answers that were distributed across the four areas of LLRW 
management under review. Respondents were also given an opportunity to 
specify other responses not listed and to provide additional comments 
on most of the questions. Appendix II provides the questionnaire and 
the responses from the United States. To increase the potential 
response rate to the survey, we attended a March 2006 meeting of the 
NEA Radioactive Waste Management Committee in Paris, France, to discuss 
our interests in surveying the representatives of foreign countries who 
attended the meeting. While at this meeting, we also reviewed a draft 
questionnaire with representatives from the NEA and IAEA. We further 
reviewed the draft questionnaire with radioactive waste management 
officials that we met with in France and Sweden. Several e-mail 
messages were sent to all 20 countries prior to administering the 
survey in order to confirm the appropriate country official to receive 
the questionnaire and to encourage each of them to participate in the 
survey. All but two countries, the Czech Republic and South Korea, 
responded to our survey (a 90-percent survey response rate). For the 
most part, we accepted the responses provided by each country; however, 
in a few cases we contacted country officials to clarify their 
responses to some questions, and we took other steps to ensure more 
complete responses to all questions. We then tabulated frequencies for 
each question across the countries. 

We made site visits to France, Japan, and Sweden to speak directly with 
representatives from the nuclear regulatory authority, waste management 
organization, and waste generators about LLRW management in their 
country. These countries were selected because they are large 
generators of radioactive waste and they represent both European Union 
and non-European Union member countries on the NEA Radioactive Waste 
Management Committee. We sent out questions in advance of our meetings 
with these representatives and we used our time with them to obtain a 
better understanding of why different management approaches were taken 
and the experiences of stakeholder groups with them. 

We identified and examined foreign country and international documents 
addressing the management of radioactive waste to supplement the 
information we obtained from our survey. These documents included 
radioactive waste management reports that countries are required to 
submit to IAEA under international agreements, national radioactive 
waste management reports and updates prepared for the NEA Radioactive 
Waste Management Committee, and information that we obtained during our 
visits to the three countries. For example, we used these documents to 
describe the extent to which countries use central storage facilities 
for LLRW, formulate radioactive waste management plans, and apply 
specific management approaches. In some instances, we used these 
documents to check the responses provided by countries on their 
questionnaire. 

We interviewed NRC and DOE officials and representatives from a diverse 
group of domestic LLRW stakeholders to describe the current LLRW 
management situation in the United States and to identify approaches 
that might be applied to improve the management of LLRW corresponding 
to our four research objectives. The interviewees represented nuclear 
regulators at the federal and state levels; LLRW disposal operators; 
advisory groups including the Conference on Radiation Control Program 
Directors, Department of Defense’s Low-Level Radioactive Waste 
Executive Agent, National Research Council of the National Academies, 
and NRC Advisory Committee on Nuclear Waste; pertinent associations, 
including the Council on Radionuclides and Radiopharmaceuticals, the 
Health Physics Society, the Low-Level Radioactive Waste Forum, and the 
Nuclear Energy Institute; and private consultancies. The Health Physics 
Society is a scientific and professional organization whose 6,000 
members specialize in occupational and environmental radiation safety, 
and the Nuclear Energy Institute represents all nuclear power plant 
operators. We conducted a content analysis of 33 domestic interviews; 
coding responses as either agreeing, not agreeing, or not responding to 
a common set of questions addressed in each interview (respondents are 
shown in table 2). These responses were then quantified for statistical 
analysis. In addition to interviews based on a standard list of 
questions, in the course of our review we also conducted informational 
interviews with the Energy Policy Research Institute, Army Corps of 
Engineers, Exelon Nuclear, and program officials at DOE. Moreover, we 
reviewed several pertinent reports, including a report of the NRC 
chaired Radioactive Source Protection and Security Task Force, a report 
from National Research Council, and a report of the NRC Advisory 
Committee on Nuclear Waste. [Footnote 18] The formation of the 
interagency NRC chaired task force and periodic reporting requirements 
were mandated in the Energy Policy Act of 2005. 

Finally, we examined LLRW inventory data from several sources to 
estimate the volumes, types, locations, and generators of LLRW in the 
United States and what is now received at the LLRW disposal facility in 
South Carolina from non-compact member states. For the most part, we 
relied on data from DOE’s Manifest Information Management System and 
from the U.S. report to the Joint Convention on the Safety of Spent 
Fuel Management and on the Safety of Radioactive Waste Management. We 
determined that these data were sufficiently reliable for the purposes 
of this report. Our assessment of what is known about the location and 
volume of LLRW in the United States is covered in appendix III. The 
status of class B and C waste disposal in the United States, as well as 
the impact of closing the South Carolina disposal facility to non-
compact member states, slated for 2008, is contained in appendix V. 

We conducted our review between September 2005 and February 2007 in 
accordance with generally accepted government auditing standards. 

Table 2: Listing of Domestic LLRW Stakeholder Group Respondents:

Number: 1; 
Domestic LLRW Stakeholder Group Respondent: Nuclear Regulatory 
Commission.

Number: 2; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-Alabama. 

Number: 3; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-Arkansas. 

Number: 4; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-Louisiana. 

Number: 5; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-New York. 

Number: 6; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-North Carolina. 

Number: 7; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-Texas. 

Number: 8; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-Washington. 

Number: 9; 
Domestic LLRW Stakeholder Group Respondent: Organization of Agreement 
State-Wisconsin. 

Number: 10; 
Domestic LLRW Stakeholder Group Respondent: State of South Carolina, 
Bureau of Land and Waste Management. 

Number: 11; 
Domestic LLRW Stakeholder Group Respondent: State of South Carolina, 
Bureau of Radiological Health. 

Number: 12; 
Domestic LLRW Stakeholder Group Respondent: State of South Carolina, 
South Carolina Energy Office. 

Number: 13; 
Domestic LLRW Stakeholder Group Respondent: State of Texas, Department 
of State Health Services. 

Number: 14; 
Domestic LLRW Stakeholder Group Respondent: State of Utah, Division of 
Radiation Control. 

Number: 15; 
Domestic LLRW Stakeholder Group Respondent: American Ecology. 

Number: 16; 
Domestic LLRW Stakeholder Group Respondent: Duratek (now Energy 
Solutions). 

Number: 17; 
Domestic LLRW Stakeholder Group Respondent: Envirocare (now Energy 
Solutions). 

Number: 18; 
Domestic LLRW Stakeholder Group Respondent: Waste Control Specialists. 

Number: 19; 
Domestic LLRW Stakeholder Group Respondent: Conference of Radiation 
Control Program Directors. 

Number: 20; 
Domestic LLRW Stakeholder Group Respondent: Department of Defense’s Low-
Level Radioactive Waste Executive Agent. 

Number: 21; 
Domestic LLRW Stakeholder Group Respondent: National Research Council 
of the National Academies. 

Number: 22; 
Domestic LLRW Stakeholder Group Respondent: NRC Advisory Committee on 
Nuclear Waste. 

Number: 23; 
Domestic LLRW Stakeholder Group Respondent: Council on Radionuclides 
and Radiopharmaceuticals. 

Number: 24; 
Domestic LLRW Stakeholder Group Respondent: Health Physics Society. 

Number: 25; 
Domestic LLRW Stakeholder Group Respondent: Low-Level Radioactive Waste 
Forum-Director. 

Number: 26; 
Domestic LLRW Stakeholder Group Respondent: Michigan Low-Level 
Radioactive Waste Authority. 

Number: 27; 
Domestic LLRW Stakeholder Group Respondent: Midwest Low-Level 
Radioactive Waste Compact Commission. 

Number: 28; 
Domestic LLRW Stakeholder Group Respondent: Northwest Low-Level 
Radioactive Waste Compact Commission. 

Number: 29; 
Domestic LLRW Stakeholder Group Respondent: Southeast Low-Level 
Radioactive Waste Compact Commission. 

Number: 30; 
Domestic LLRW Stakeholder Group Respondent: Southwest Low-Level 
Radioactive Waste Compact Commission. 

Number: 31;
Domestic LLRW Stakeholder Group Respondent: 

Number: 32; 
Domestic LLRW Stakeholder Group Respondent: 

Number: 33; 
Domestic LLRW Stakeholder Group Respondent: 

[End of table] 

[End of section] 

Appendix III: Survey of LLRW Management Approaches: Response from 
United States: 

United States Government Accountability Office: 

Foreign Experiences in Managing Low- and Intermediate-Level Radioactive 
Waste: 

Background: 

The U.S. Government Accountability Office (GAO) is a professional, 
nonpartisan legislative branch agency that supports the Congress by 
reviewing the performance of federal agencies, assessing federal 
policies and programs, analyzing the financing of government 
activities, and anticipating emerging issues. One such issue is the 
management of low- and intermediate-level radioactive waste.

While the United States embarks on new nuclear power development, it 
also confronts the need to dismantle and dispose of older reactors. 
Both activities will result in increased generation of low-and 
intermediate-level radioactive waste. The current lack of a reliable 
and cost-effective radioactive waste disposal system in the United 
States may prompt the need to revise federal legislation and the 
policies of the nuclear regulatory authorities. The Congress is 
particularly interested in identifying approaches to improve the 
management of these wastes, particularly in four key areas. GAO has 
been asked to determine the extent to which the United States and other 
countries have established: (1) national waste inventory and source 
tracking systems; (2) requirements for the timely removal of waste from 
user sites; (3) reliable and cost-effective waste disposal options; and 
(4) funding mechanisms to ensure that users can cover waste storage and 
disposal costs.

In order to obtain information about management approaches used in 
other countries, GAO is seeking the cooperation of countries 
represented on the OECD Nuclear Energy Agency Radioactive Waste 
Management Committee. These countries generate relative large volumes 
of low- and intermediate-level radioactive waste. We have worked with 
representatives of the Nuclear Energy Agency, International Atomic 
Energy Agency, and the U.S. Nuclear Regulatory Commission to prepare a 
questionnaire that will collect information useful to all countries. 
While these organizations support the GAO survey, they are not sponsors 
or in other ways associated with the results of this survey. 

Directions for Completing the Questionnaire: 

Most of the 32 questions in this survey can be answered easily by 
checking boxes or filling in blanks, which are highlighted in yellow. 
Unless otherwise noted, please mark only one response for each 
question. 

You will notice that many questions are followed by boxes that allow 
you to provide additional comments. You should only use these boxes if 
you feel that you have additional information that you need to convey 
to clarify your response. The box will expand to accept your entire 
response. If the check mark answers provided are sufficient, you do not 
need to provide any additional comments in the boxes. 

* Please use your mouse to navigate throughout the survey by clicking 
on the field or check box you wish to answer. 

* To select a check box, simply click on the center of the box. 

* To change or deselect a response, simply click on the check box and 
the "X" will disappear. 

You will also notice that we ask about both low- and intermediate-
radioactive waste in the survey. The United States does not have a low- 
and intermediate radioactive waste classification system, but rather it 
relies on four classes of low-level radioactive waste--class A, B, C, 
and greater-than-class C waste. The International Atomic Energy Agency 
(IAEA) has estimated that all of U.S. class A and B waste, and 75 
percent of the class C waste would fall into the international short-
lived low-and intermediate-level waste category, and the remaining 25 
percent, as well as all of the greater-than-class C waste would fall 
into the long-lived low and intermediate-level waste category. The U.S. 
class A waste includes radioactive wastes that some other countries 
classify as very low-level radioactive waste (<10Bq/g, with a half-life 
on the order of decades).

Please complete this questionnaire and return it via e-mail within 3 
weeks of receipt. If you have any questions, please contact:

Stated GAO Official: 

If you prefer to return the survey via post, the return address is:

U.S. Government Accountability Office: Denver Field Office: 
1244 Speer Boulevard, Suite 800: Denver, Colorado 80204: 
USA: 

Although this questionnaire may require input from various individuals, 
GAO asks that one person assume responsibility for coordinating its 
completion. Please list the person's name below in case we have 
questions or need follow-up. Thank you. 

Name: NRC Official: 
Title: 
Telephone Number:    
E-mail: 
Country: USA: 
Agency or Organization: NRC: 

Definition of Radioactive Waste Generators: The U.S. radioactive waste 
disposal inventory database for low-level radioactive waste captures 
six waste generator categories—academic, government (including defense, 
but excluding the Department of Energy), industry, medical, utility 
(nuclear power plant), and other. Data is not collected on the 
generation of radioactive waste on the front and back end of the fuel 
cycle, as well as operators that treat and condition the waste. 

Radioactive Waste Inventory Database: 

1. Does your country currently have a national radioactive waste 
inventory database?

Yes; [Skip to question 3].

2. Do you plan to develop a national radioactive waste inventory 
database? Yes; 
[Please specify the date the database is scheduled to be operational.]
No; Skip to question 13. 

3. What types of radioactive wastes are in the national radioactive 
waste inventory database?

* Very low-level radioactive waste: No; 
* Short-lived low- and intermediate-level waste: Yes; 
* Long-lived low-level waste (including naturally occurring radioactive 
material): No; 
* Long-lived intermediate-level waste: No; 
* High-level radioactive waste No; 
* Other: [Empty]; 
* please specify: [Empty]. 

Additional comments: 

National waste inventory "database" is defined here as the U.S. 
National Report for the Joint Convention, which contains quantities and 
types of most of the nuclear fuel cycle wastes in the U.S. The U.S. 
also has a computerized database for non- DOE waste that's been 
disposed of (the Manifest Information Management System (MIMS)). MIMS 
covers only LLW disposed of in commercial LLW facilities. For Long-
Lived LLW in the above list, there is an inventory of fuel cycle 
wastes, but none for naturally occurring material. 

4. What categories of radioactive waste generator are included in the 
national radioactive waste inventory database?

* Academic: Yes;    
* Government (including defense): Yes;     
* Industrial: Yes;   
* Medical: Yes;     
* Nuclear power plants: Yes;  
* Front end of fuel cycle: No; 
* Back end of fuel cycle: Yes; 
* Waste Treatment: No; 
* Other: [Empty]; 
* please specify: [Empty]. 

Additional comments: 

See U.S. National Report and MIMS for details. 

5. What locations of radioactive waste does the national radioactive 
waste inventory database capture?

* Disposed at national facilities: Yes;     
* Disposed at regional facilities: Yes;     
* Disposed at waste generator sites: No; 
* Stored at national facilities: Yes; 
* Stored at regional facilities: No; 
* Stored at the waste generator sites; No; 
* Other: No. 
* please specify: [Empty]. 

Additional comments: 

Note--National facilities are defined as the DOE LLW disposal sites. 
Inventory in MIMS includes waste disposed at commercial (non-DOE) 
facilities. The locations of the above facilities are in the National 
Report. See, for example, Annexes D-1 and D-2. At least partial 
inventory information is also included and may be available from other 
sources (e.g., WIPP disposal inventory is readily available). Data on 
waste stored at DOE sites is contained in the National Report. Similar 
data on waste in storage at commercial sites not reported. 

6. Who is responsible for maintaining the national radioactive waste 
inventory database? 

National nuclear regulatory authority: Yes; 
National waste management organization: [Empty]; 
Regional nuclear regulatory authority: [Empty]; 
Nuclear utility organization: [Empty]; 
Commercial waste management company: [Empty]; 
Other: Yes; 
* please specify: [Empty]. 

Additional comments: 

DOE maintains the MIMS. DOE also is the lead Federal agency for the 
preparation of the U.S. National Report for the Joint Convention and 
receives assistance from NRC and EPA. DOE is a national organization 
and has regulatory authority for its own internal activities, so we 
have checked that block. This may not be the sense that GAO uses the 
term "national nuclear regulatory authority," however. 

7. How does the national radioactive waste inventory database receive 
data from the waste generators?

* Secure website reporting form: Yes; 
* E-mail attachments: Yes; 
* Mail or faxed paper documents; Yes; 
* Phone: [Empty]; 
* Other: Yes; 
* please specify: [Empty]. 

Additional comments: 

MIMS, DOE receives e-mail attachments of disposal data from all 
facility operators. Generators furnish waste manifests either 
technically or in paper to disposal facility operators. 

8. How frequently does the national radioactive waste inventory 
database receive data from waste generators?

* Once a month: [Empty]; 
* Twice a year: [Empty]; 
* Once a year: [Empty]; 
* Other: Yes. 
* please specify: Updates are typically received quarterly. 

Additional comments: [Empty] 

9. Which of the following activities, if any, are used by the 
organization responsible for maintaining the national radioactive waste 
inventory database to verify the completeness and accuracy of the data?

* Periodic inspections of waste generators to verify the accuracy of 
the reported waste data: [Empty]; 
* Check generator submissions against past and projected waste from the 
generator: [Empty];
* Periodic audits of waste generator records: [Empty]; 
* Other: Yes;  
* please specify: DOE, who manages MIMS, has some data routines that 
verify format and consistency of the data. 
* None of the above: Yes.    

Additional comments: [Empty]. 

10. Is the national radioactive waste inventory database used to make 
projections of future waste volumes that are used for capacity planning 
of central waste storage and waste disposal facilities? 

* Yes: [Empty]; 
* No: Yes. 

11. If your country is a member of the European Union, has it 
implemented Council Directive 2003/122/EURATOM, regarding the control 
of high-activity sealed radioactive sources and orphan sources?

* Yes: [Empty]; 
* No: [Empty]; 
* Not a European Union country: [Check]. 

12. As a country that has made a political commitment to the IAEA Code 
of Conduct on the Safety and Security of Radiological Sources, which of 
the following source categories, if any, are or will be included in the 
national source registry?

* IAEA category 1 sources: Yes; 
* IAEA category 2 sources: Yes; 
* IAEA category 3 sources: No; 
* IAEA category 4 sources: No; 
* IAEA category 5 sources: No. 

Additional comments: 

The Commission has directed NRC staff to conduct a survey of Category 
3.5 sources (0.1 of Cat 3) and to prepare a proposed rule that would 
include Category 3 data in the tracking system. See [hyperlink, 
http://www.nrc.gov/reading-rm/doc-collections/commission/srm/2006/2006-
0094srm.html] for details. 

Removal of Radioactive Waste from User Sites: 

13. What limits, if any, are placed on the time that radioactive waste 
can be stored at the waste generator's site? 

* Radioactive waste generator: Nuclear power plants: No limits;     
* Radioactive waste generator: Non-nuclear power plant entities: No 
limits. 

* please specify: [Empty]. 

14. Does your country place any limit on the time that a sealed 
radioactive source can be used? 

* Yes: [Empty]; 
* No: [Check]. 

Additional comments: [Empty]. 

15. Has your country implemented requirements that a disused 
radioactive source be returned either to the manufacturer of the source 
or to central waste storage? 

* Yes: [empty]; 
* No: [check]. 

Additional comments: [Empty]. 

16. Does your country have an orphan source recovery program to collect 
disused radioactive sources from entities that cannot afford to send 
them to an off-site central waste storage or a waste disposal facility? 

* Yes: [check]; 
* No: [empty]; Skip to question 18. 

Additional comments: 

The US has two programs (DOE's Offsite Source Recovery Program, and a 
Conference of Radiation Control Program Directors (CRCPD) program) that 
may collect disused sources from entities that cannot afford to get rid 
of them, under certain specific circumstances (e.g., a lack of disposal 
alternative for GTCC waste, or a case involving a safety/security 
concern). 

17. Which organization is responsible for recovering orphan radioactive 
sources? 

* National nuclear regulatory authority: [Empty}; 
* National waste management organization: [Empty}; 
* Regional nuclear regulatory authority: [Empty}; 
* Nuclear utility organization: [Empty}; 
* Commercial waste management company: [Empty};
* Other: Yes. 
* please specify: [empty]. 

Additional comments: 

DOE, CRCPD. The U.S. Army also has a source recovery program for its 
sources, and EPA could recover sources in certain emergency situations. 

18. What additional actions, if any, has the national nuclear 
regulatory authority taken to reduce the potential number of orphan 
radioactive sources? 

* Users must inform regulators if holding disused sources: No; 
* Regulators keep records of the location and status of use of sources, 
including disused sources: Yes; 
* Regulators periodically inspect the operational storage of disused 
sources at user sites: Yes; 
* Regulators encourage users to send disused sources to central storage 
or disposal, if available: Yes; 
* Regulators enforce the prompt removal of disused sources from user 
sites: No; 
* Other: Yes; 
* please specify: Multiple US agencies fund CRCPD's Orphan Radiological 
Material Disposition Program (a non-profit program to facilitate 
information exchange and provide limited assistance in source 
disposition, including disused and orphan sources). 

Additional comments: 

For item 2, records are kept for certain subsets of sources (i.e., high 
risk sources). There are increased controls on certain subsets of 
sources to reduce the likelihood of loss or theft. DOE funds OSRP. 

Reliable and Cost Effective Storage and Disposal Options: 

19. Which approaches does your country have to clear low- and 
intermediate-level radioactive waste from regulatory control or to 
reduce the level of control for very low-activity radioactive waste?

* Exemption, defined as the determination by a regulatory body that a 
source or practice need not be subject to some or all aspects of 
regulatory control on the basis that exposure is too small given the 
moderate quantities of radioactive material: No; 
* Case by Case Exemption for larger quantities of radioactive material 
that still require some regulatory control: Yes;    
* Clearance defined as the unrestricted removal of radioactive 
materials or radioactive objects within authorized practices from any 
further regulatory control by a regulatory body: No; 
* Do not clear bulk radioactive materials from regulatory control but 
establish a new regulated disposal facility for very low-activity 
radioactive waste: No; 
* Other: Yes; 
* please specify: [empty]. 

Additional comments: 

US has a number of exemptions, such as smoke detectors, in regulations 
but they are not for "waste" specifically. These materials often become 
waste when their use has ended. US has no rule for clearance, but NRC 
has issued guidance for releasing materials that is used by licensees. 
DOE also has its own clearance process. 

20. Are disposal options available for the following low- and 
intermediate-level radioactive waste? 

* Very low-level radioactive waste: [empty]; 
* Short-lived low- and intermediate-level waste: Yes; 
* Long-lived low-level waste (including naturally occurring radioactive 
material): Yes; 
* Long-lived intermediate-level waste: Yes; No;     
* Other: [empty]; 
* please specify: Some long-lived commercial LLW (GTCC) does not have a 
disposal option at this time. 

Additional comments: 

On July 1, 2008, LLW generators in 34 States are expected to lose 
access to their Class B/C disposal option at the Barnwell facility. The 
facility is scheduled to close to out-of-compact waste on that date. 

21. Which entity in your country is primarily responsible for providing 
disposal facilities for low- and intermediate-level radioactive waste? 
If more than one entity is responsible for different types of waste, 
please clarify each entity's responsibility in the Additional Comments 
box. 

* National nuclear regulatory authority: No; 
* National waste management organization: No; 
* Regional nuclear regulatory authority: Yes; 
* Nuclear utility organization: No; 
* Commercial waste management company: No; 
* Other: [empty]; 
* please specify: States and LLW Compacts are responsible under law for 
providing for disposal capacity for commercial (non-DOE) LLW. DOE is 
responsible for providing for disposal of GTCC waste (which is also 
commercial waste). In one case, a private company, EnergySolutions, has 
developed a facility on its own initiative for commercial waste. DOE 
disposes of its own LLW and TRU waste.

Additional comments: [empty]. 

22. Which entity in your country is primarily responsible for operating 
disposal facilities for low- and intermediate-level radioactive waste? 
If more than one entity is responsible for different types of waste, 
please clarify each entity's responsibility in the Additional Comments 
box. 

* National nuclear regulatory authority: No; 
* National waste management organization: No; 
* Regional nuclear regulatory authority: No; 
* Nuclear utility organization: No; 
* Commercial waste management company: Yes; 
* Other: No; 
* please specify: [empty]. 

Additional comments: 

For disposal facilities accepting commercial waste, all three are 
operated by private companies. DOE operates its own disposal 
facilities for LLW and TRU waste. It should be noted that DOE regulates 
its own activities, including the disposal facilities it operates. It 
is generally not thought of as a "national nuclear regulatory 
authority" however, given its much broader responsibilities. 

23. What were the factors that were persuasive in your country's 
decision to grant responsibilities to the entity(s) charged with 
managing the disposal of low- and intermediate-level radioactive waste? 

Comments: 

States' wanted the responsibility for providing for commercial LLW 
disposal. For DOE waste, DOE and its predecessor organizations have 
always managed waste in conjunction with their other extensive nuclear 
activities. 

24. How are disposal fees for radioactive waste determined?

* National disposal fee schedule based on the type of radioactive 
waste: No; 
* Waste generators negotiate disposal fees based on the type of 
radioactive waste: Yes; No; 
* Waste generators pay for disposal space through a tax not related to 
the type of radioactive waste: No; 
* Other: [empty];    
* please specify: [empty]. 

Additional comments: 

If Texas facility goes into operation, Texas Compact Commission will 
set rates for Compact waste. Rates for DOE waste disposal at the Texas 
site will be negotiated. For most sites, there is negotiation of rates, 
but certain taxes, surcharges, etc. are established by State and are 
not negotiable. 

25. What disposal facility costs are covered by the disposal fees? If 
there are different approaches used for more than one disposal 
facility, please clarify in the Additional Comments box. 

* Facility development costs: Yes; No; 
* Operating costs: Yes; 
* Estimated closure costs: Yes; 
* Estimated long-term monitoring costs: Yes; 
* Financial surety costs: Yes; No; 
* Community economic development surcharges: Yes; No; 
* Profit margin if a commercial facility: Yes; No; 
* Other costs: [empty]; 
* please specify: [empty]. 

Additional comments: 

Answers vary depending upon the particular facility in U.S. WRT "profit 
margin," the "no" answer is for the Richland site where the State 
stipulates a revenue requirement to be met by the operator.

26. Which of the following approaches, if any, does your country use to 
obtain community acceptance for hosting a low- and intermediate-level 
radioactive waste central storage or disposal facility? 

* Allow local communities a veto power in the site selection decision 
making process: Yes; No; 
* Provide economic development funding to communities that will host a 
disposal facility: Yes; No; 
* Promote the indirect economic benefit of hosting a disposal facility 
based no added value: Yes; No; 
* Establish a selection committee comprised of experts, regulators, and 
community members: Yes; No; 
* Encourage public access to inspect health and safety conditions at 
the disposal facility: Yes; No; 
* Publicize information on the activities of the disposal facility: 
Yes; No; 
* Other: [empty]; 
* please specify: [empty]. 

Additional comments: 

US has four commercial disposal sites, three in operation, one under 
license review. The particulars vary for each facility, so both "yes" 
and "no" apply above. We can provide details upon request. 

[End of section] 

Appendix IV: Volume and Location of LLRW in the United States: 

The United States is required under international agreement to prepare 
a national report on the safety of spent fuel and radioactive waste 
management that includes an inventory of radioactive waste in the 
country. [Footnote 19] Even though the DOE has taken lead 
responsibility for preparing this inventory, there is no designated 
agency responsible for managing a national LLRW inventory database. The 
reported information includes data from DOE’s own radioactive waste 
inventory, as well as publicly available information that is compiled 
from a variety of sources, including DOE’s Manifest Information 
Management System containing information from the three LLRW disposal 
operators, EIA spent fuel database, Broker and Processor database, and 
other sources. While DOE can report on the radioactive waste it has in 
storage or has disposed of, there is limited information on the storage 
of waste at non-DOE sites. DOE has reported some LLRW storage at waste 
brokers and processor sites, and the GTCC waste stored at commercial 
nuclear power plants. NRC and Agreement State radioactive materials 
licensees are supposed to maintain records of the nuclear material that 
they possess, but information on the status of use of these materials, 
particularly disused sealed radiological sources, is not centrally 
collected. The Electric Power and Research Institute collects 
proprietary data from nuclear power plant operators on the annual 
generation of LLRW, but not on the storage of all LLRW, which is 
constantly changing. The institute estimates that an average plant 
generates about 12,000 cubic feet of LLRW each year. 

The following tables provide some information on non-DOE and DOE 
radioactive waste volumes and locations. DOE classifies its radioactive 
waste somewhat differently than waste generated by NRC and Agreement 
State licensees. DOE reports four classes of radioactive waste, not 
including mixed waste, that include high-level waste, transuranic 
waste, low-level waste, and 11(e)(2) byproduct material. [Footnote 20] 
DOE’s low-level waste category and transuranic waste would clearly fall 
within the NRC waste classification scheme. Low-level waste would be 
generally categorized as class A, B, or C waste, and transuranic waste 
would be categorized as greater-than-class C waste. DOE’s 11(e)(2) 
byproduct material is a special category of radioactive waste. 

According to NRC officials, 11(e)(2) byproduct materials and other 
types of radioactive waste exists in the United States but are not 
considered LLRW under NRC regulations. The National Research Council of 
the National Academies has reported that the principal origin of 
uranium and thorium ore processing waste comes from the recovery of 
this material for DOE or civilian nuclear applications. Typical 
examples include mining and mill tailings, process residues, soils and 
contaminated equipment. Similar waste comes from naturally occurring 
and technologically enhanced naturally occurring radioactive materials. 
The principal origins of these materials are from the recovery and 
processing of mineral resources not related to nuclear applications, 
and municipal water treatment. Examples of these materials include 
commercial ore mining residues, phosphate mining and fertilizers, scale 
and sludge from oil and gas production, water treatment filters, 
resins, and other sludge. There are large volumes of these wastes, but 
limited information on the actual quantities that remain at sites 
around the United States. 

Table 3: Total LLRW Disposed at the Three Operating Commercial LLRW 
Disposal Facilities as of 2005: 

Disposal Facility: Barnwell; 
Location: Barnwell, South Carolina; 
Class A waste volume (cubic feet): 24,815,969; 
Class B waste volume (cubic feet): 1,643,933; 
Class C waste volume (cubic feet): 825,833; 
Total volume (cubic feet): 
27,285,735. 

Disposal Facility: Envirocare; 
Location: Clive, Utah; 
Class A waste volume (cubic feet): 66,295,270; 
Class B waste volume (cubic feet): 0; 
Class C waste volume (cubic feet): 0; 
Total volume (cubic feet): 66,295,270. 

Disposal Facility: Richland; 
Location: Richland, Washington; 
Class A waste volume (cubic feet): 13,450,191; 
Class B waste volume (cubic feet): 137,056; 
Class C waste volume (cubic feet): 137,233; 
Total volume (cubic feet): 13,724,480. 

Source: Manifest Information Management System data and United States 
of America Second National Report for the Joint Convention on the 
Safety of Spent Fuel Management and on the Safety of Radioactive Waste 
Management, October 2005. 

[End of table] 

Table 4: Total Disposed LLRW at the Four Closed Commercial Disposal 
Facilities: 

Closed commercial disposal facilities: Beatty; 
State: Nevada; 
Total volume (cubic feet): 4,854,178. 

Closed commercial disposal facilities: West Valley; 
State: New York; 
Total volume (cubic feet): 2,721,843. 

Closed commercial disposal facilities: Maxey Flats; 
State: Kentucky; 
Total volume (cubic feet): 4,777,368. 

Closed commercial disposal facilities: Sheffield; 
State: Illinois; 
Total volume (cubic feet): 3,119,486. 

Closed commercial disposal facilities: Total; 
State: [Empty]; 
Total volume (cubic feet): 15,472,875. 

Source: DOE Integrated Database Report 1997, all four facilities were 
closed prior to 1993. 

[End of table] 

Table 5: Total LLRW Disposed at the Three Commercial LLRW Disposal 
Facilities during 2005: 

Disposal Facility: Barnwell; 
Location: Barnwell, South Carolina; 
Class A waste volume (cubic feet): 25,111; 
Class B waste volume (cubic feet): 9,367; 
Class C waste volume (cubic feet): 8,535; 
Total volume (cubic feet): 43,013. 

Disposal Facility: Envirocare; 
Location: Clive, Utah; 
Class A waste volume (cubic feet): 15,471,876; 
Class B waste volume (cubic feet): 0; 
Class C waste volume (cubic feet): 0; 
Total volume (cubic feet): 15,471,876. 

Disposal Facility: Richland; 
Location: Richland, Washington; 
Class A waste volume (cubic feet): 19,906; 
Class B waste volume (cubic feet): 7; 
Class C waste volume (cubic feet): 191; 
Total volume (cubic feet): 20,104. 

Disposal Facility: Total; 
Location: [Empty]; 
Class A waste volume (cubic feet): 15,516,893; 
Class B waste volume (cubic feet): 9,374; 
Class C waste volume (cubic feet): 8,726; 
Total volume (cubic feet): 15,534,993. 

Source: Manifest Information Management System data and information 
provided by DOE on waste disposed in 2005. 

Note: The total waste disposed at Envirocare (now Energy Solutions) in 
2005 includes class A waste from the Department of Energy. 

[End of table] 

Table 6 provides information on LLRW that is currently on DOE sites, 
either in storage or in disposal. The information in this table comes 
from the waste inventories of each DOE site that has LLRW, as reported 
in the 2005 U.S. National Report for the Joint Convention on the Safety 
of Spent Fuel Management and on the Safety of Radioactive Waste 
Management. 

Table 6: LLRW in Storage or Disposal at DOE Sites: 

State: Idaho; 
Installation: Idaho National Laboratory; 
Total volume (cubic feet): 2,509,390. 

State: Kentucky; 
Installation: Paducah Gaseous Diffusion Plant; 
Total volume (cubic feet): 335,489. 

State: Nevada; 
Installation: Nevada Test Site; 
Total volume (cubic feet): 27,259,391; 

State: New Mexico; 
Installation: Los Alamos National Laboratory; 
Total volume (cubic feet): 7,592,653. 

State: New York; 
Installation: West Valley Demonstration Project; 
Total volume (cubic feet): 575,276. 

State: New York; 
Installation: Brookhaven National Laboratory; 
Total volume (cubic feet): 2,048. 

State: Ohio;
Installation: Ashtabula Environmental Management Project; 
Total volume (cubic feet): 108,204. 

State: Ohio; 
Installation: Fernald Environmental Management Project; 
Total volume (cubic feet): 59,962,962. 

State: Ohio; 
Installation: Portsmouth Gaseous Diffusion Plant; 
Total volume (cubic feet): 536,783. 

State: South Carolina; 
Installation: Savannah River Site; 
Total volume (cubic feet): 27,168,738. 

State: Tennessee; 
Installation: Oak Ridge Site; 
Total volume (cubic feet): 22,054,009. 

State: Washington; 
Installation: Hanford Site; 
Total volume (cubic feet): 81,641,859. 

State: Multiple states; 
Installation: small facilities; 
Total volume (cubic feet): 353. 

State: Total; 
Installation: [Empty]; 
Total volume (cubic feet): 229,747,155. 

Source: United States of America Second National Report for the Joint 
Convention on the Safety of Spent Fuel Management and on the Safety of 
Radioactive Waste Management, October 2005. 

[End of table] 

Table 7 provides information on transuranic waste disposed at the Waste 
Isolation Pilot Plant (WIPP) located in southeastern New Mexico. This 
facility can only accept defense-related transuranic waste. 

Table 7: Transuranic Waste Disposed of or in Storage Awaiting Disposal 
at WIPP: 

DOE site: Hanford Site; 
State: Washington; 
Volume disposed of at WIPP (cubic feet): 52,972; 
Volume in storage awaiting disposal at WIPP(cubic feet): 1,539,719. 

DOE site: Idaho National Laboratory; 
State: Idaho; 
Volume disposed of at WIPP (cubic feet): 204,825; 
Volume in storage awaiting disposal at WIPP(cubic feet): 2,171,852. 

DOE site: Lawrence Livermore National Laboratory; 
State: California; 
Volume disposed of at WIPP (cubic feet): [Empty]; 
Volume in storage awaiting disposal at WIPP(cubic feet): 12,431. 

DOE site: Los Alamos National Laboratory; 
State: New Mexico; 
Volume disposed of at WIPP (cubic feet): 24,720; 
Volume in storage awaiting disposal at WIPP(cubic feet): 441,433. 

DOE site: Nevada Test Site; 
State: Nevada; 
Volume disposed of at WIPP (cubic feet): [Empty]; 
Volume in storage awaiting disposal at WIPP(cubic feet): 28,781. 

DOE site: Oak Ridge Site; 
State: Tennessee; [Empty]; 
Volume disposed of at WIPP (cubic feet): 
Volume in storage awaiting disposal at WIPP(cubic feet): 86,097. 

DOE site: Rocky Flats Site; 
State: Colorado; 
Volume disposed of at WIPP (cubic feet): 529,720; 
Volume in storage awaiting disposal at WIPP(cubic feet): [Empty]. 

DOE site: Savannah River Site; 
State: South Carolina; 
Volume disposed of at WIPP (cubic feet): 250,734; 
Volume in storage awaiting disposal at WIPP(cubic feet): 459,091. 

DOE site: Small Quantity Sites; 
State: [Empty]; 
Volume disposed of at WIPP (cubic feet): 20,836; 
Volume in storage awaiting disposal at WIPP(cubic feet): 21,754. 

DOE site: West Valley Demonstration Project; 
State: New York; 
Volume disposed of at WIPP (cubic feet): [Empty]; 
Volume in storage awaiting disposal at WIPP(cubic feet): 30,017. 

DOE site: Total; 
State: [Empty]; 
Volume disposed of at WIPP (cubic feet): 1,083,807; 
Volume in storage awaiting disposal at WIPP(cubic feet): 4,791,175. 

Source: 2004 Sandia National Laboratories WIPP Compliance 
Recertification Application Performance Assessment Baseline 
Calculation, and the United States of America Second National Report 
for the Joint Convention on the Safety of Spent Fuel Management and on 
the Safety of Radioactive Waste Management, October 2005. 

[End of table] 

Table 8 shows the number of disused sealed radiological sources that 
have been collected and sent to disposal by the former DOE Off-Site 
Source Recovery Project, which is now under the DOE’s Global Threat 
Reduction Initiative. 

Table 8: Central Storage and Disposal of Disused Sealed Radiological 
Sources Recovered by DOE’s Off-Site Source Recovery Project: 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in storage: Los Alamos National 
Laboratory;  State: New Mexico; 
Total number of sources: 9,920. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in storage: Los Alamos National 
Laboratory (for Pu 239 sources); 
State: New Mexico; 
Total number of sources: 1. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in storage: National Naval 
Medical Center; 
State: Maryland; 
Total number of sources: 22. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in storage: Nevada Test Site - Pu 
239 Storage; 
State: Nevada; 
Total number of sources: 39. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in storage: NSSI Sources and 
Services Inc.; 
State: Texas; 
Total number of sources: 484. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in storage: Southwest Research 
Institute; 
State: Texas; 
Total number of sources: 135. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in disposal: Barnwell; 
State: South Carolina; 
Total number of sources: 474. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in disposal: Nevada Test Site;  
State: Nevada; 
Total number of sources: 345. 

Location of collected sealed radiological sources in storage or 
disposed: Sealed radiological sources in disposal: Waste Isolation 
Pilot Plant; 
State: New Mexico; 
Total number of sources: 2,397. 

Location of collected sealed radiological sources in storage or 
disposed: Total; 
State: [Empty]; 
Total number of sources: 13,817. 

Source: DOE’s Off-Site Source Recovery Project, June 28, 2006. 

Note: The disused sealed radiological sources in storage are not 
considered to be waste until they are packed for disposal. 

[End of table] 

[End of section] 

Appendix V: Status of Class B and C Waste Disposal and Potential 
Effects of Reduced Access to South Carolina Disposal Facility: 

Limiting waste generator access to the LLRW disposal facility in South 
Carolina to only the three compact member states by mid-2008 will 
require waste generators to store their class B and C waste until 
another disposal option becomes available. We reported in June 2004 
that 99 percent of the class B and C waste disposed in this country 
went to the Barnwell, South Carolina, disposal facility, the only 
option available to waste generators in 39 states. Generators in the 11 
other states have access to the LLRW disposal facility in Richland, 
Washington. In total the class B and C waste that is disposed at both 
of these facilities amounts to slightly less than 0.5 percent of all 
LLRW that was disposed of commercially in the United States between 
1999 and 2003. 

We conducted a further analysis of data in the DOE managed Manifest 
Information Management System for 2001 to 2005 for the waste generators 
that use the two disposal facilities that can accept class B and C 
waste (Barnwell, South Carolina, and Richland, Washington), and the 
types and quantities of waste disposed at these facilities during this 
time period. In order to compare the waste types disposed as these two 
facilities, we had to come up with a categorization scheme that 
captured the different types of class B and C waste. For the purpose of 
our analysis, we consolidated these waste types into groups as shown in 
the table 9. 

Table 9: Class B and C Waste Type Groups: 

Waste type group: Dry active waste (DAW); 
Waste type: Charcoal, Incinerator ash, Soil, Demolition rubble, 
Glassware or labware, Compactable trash, Non-compactable trash. 

Waste type group: Oil, gas, EPA or state hazardous, paint or plating 
(OGEP); 
Waste type: Paint or plating. 

Waste type group: Liquids and sludge; 
Waste type: Aqueous liquid, Evaporator bottoms/sludge/concentrates, 
Solidified liquids. 

Waste type group: Filters, filter media & resins; 
Waste type: Filter media, Mechanical filter, Cation ion-exchange 
media, Mixed bed ion-exchange media, Non-cartridge filter media. 

Waste type group: Equipment and material; 
Waste type: Contaminated equipment, Activated material, Activated 
reactor hardware. 

Waste type group: Sealed radiological sources; 
Waste type: Sealed source/device, Sealed sources. 

Waste type group: Biological materials; 
Waste type: Animal carcass. 

Waste type group: Other; 
Waste type: Other, Dry solid, Non-compacted dry active waste, 
Solidified chelates, Combination. 

Source: GAO determination from analysis of Manifest Information 
Management System records. 

[End of table] 

Table 10 shows the volume and activity of the class B and C waste that 
was disposed between 2001 and 2005 by waste type group. Filters, filter 
media, and resins contributed the greatest volume of waste (44 percent 
of total disposed volume), but only about 3 percent of total disposed 
activity. Equipment and materials, by contrast, contributed only about 
28 percent of the total disposed volume but accounted for 86 percent of 
the disposed activity. According to a nuclear industry official, 
contaminated equipment and material is highly radioactive and will need 
to be stored on-site similar to spent fuel rods, if there is no 
disposal option for this type of waste. 

Table 10: Total Class B and C Waste Disposed at Richland and Barnwell 
by Waste Type Group, 2001-2005: 

Waste type group: Dry active waste; 
Volume (in cubic feet), Total: 7,849; 
Volume (in cubic feet), Percent: 5; 
Activity (in curies), Total: 34,490; 
Activity (in curies), Percent: 2. 

Waste type group: Oil, gas, EPA or state hazardous, paint or plating; 
Volume (in cubic feet), Total: 1; 
Volume (in cubic feet), Percent: 0; 
Activity (in curies), Total: 0; 
Activity (in curies), Percent: 0. 

Waste type group: Liquids and sludge; 
Volume (in cubic feet), Total: 2,222; 
Volume (in cubic feet), Percent: 2; 
Activity (in curies), Total: 7,729; 
Activity (in curies), Percent: 0. 

Waste type group: Filters, filter media and resins; 
Volume (in cubic feet), Total: 63,814; 
Volume (in cubic feet), Percent: 44; 
Activity (in curies), Total: 63,825; 
Activity (in curies), Percent: 3. 

Waste type group: Equipment and material; 
Volume (in cubic feet), Total: 39,856; 
Volume (in cubic feet), Percent: 28; 
Activity (in curies), Total: 1,797,562; 
Activity (in curies), Percent: 86. 

Waste type group: Sealed radiological sources; 
Volume (in cubic feet), Total: 4,995; 
Volume (in cubic feet), Percent: 3; 
Activity (in curies), Total: 92,287; 
Activity (in curies), Percent: 4. 

Waste type group: Biological materials; 
Volume (in cubic feet), Total: 18; 
Volume (in cubic feet), Percent: 0; 
Activity (in curies), Total: 86; 
Activity (in curies), Percent: 0. 

Waste type group: Other; 
Volume (in cubic feet), Total: 25,335; 
Volume (in cubic feet), Percent: 18; 
Activity (in curies), Total: 83,044; 
Activity (in curies), Percent: 4. 

Waste type group: Total[a]; 
Volume (in cubic feet), Total: 144,090; 
Volume (in cubic feet), Percent: 100; 
Activity (in curies), Total: 2,079,023; 
Activity (in curies), Percent: 100. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Column percentages may not add up to 100 percent due to rounding. 

[End of table] 

Table 11 shows the number of generators of a particular waste type 
distributed across the generator types. No total is provided for the 
number of different generator types because in some cases one generator 
may be disposing of different types of waste. Providing a total by 
generator type would result in an over count of the total number of 
generators. 

Table 11: Number of Generators That Disposed of Class B and C Waste at 
Richland and Barnwell by Generator Type and Waste Type, 2001-2005: 

Waste type Group: Dry active waste; Academic: 19; 
Government: 20; 
Industry: 60; 
Medical: 3; 
Utility: 45; 
Total: 147. 

Waste type Group: Oil, gas, EPA or state hazardous, paint or plating; 
Academic: 0; 
Government: 0; 
Industry: 0; 
Medical: 0; 
Utility: 1; 
Total: 1. 

Waste type Group: Liquids and sludge; 
Academic: 1; 
Government: 1; 
Industry: 7; 
Medical: 0; 
Utility: 8; 
Total: 17. 

Waste type Group: Filters, filter media and resins; 
Academic: 0; 
Government: 6; 
Industry: 6; 
Medical: 0; 
Utility: 65; 
Total: 77. 

Waste type Group: Equipment and material; 
Academic: 1; 
Government: 4; 
Industry: 7; 
Medical: 0; 
Utility: 31; 
Total: 43. 

Waste type Group: Sealed radiological sources; 
Academic: 158; 
Government: 125; 
Industry: 286; 
Medical: 100; 
Utility: 29; 
Total: 698. 

Waste type Group: Biological materials; 
Academic: 1; 
Government: 0; 
Industry: 1; 
Medical: 0; 
Utility: 0; 
Total: 2. 

Waste type Group: Other; 
Academic: 8; 
Government: 60; 
Industry: 29; 
Medical: 2; 
Utility: 58; 
Total: 157. 

Source: Manifest Information Management System records for 2001-2005. 

[a] “Sealed Sources” and “Other” Includes one U.S. Army waste generator 
outside of the United States. 

[End of table] 

Figure 9: Number of Generators That Disposed of Class B and C Waste at 
Richland and Barnwell by Generator Type and Waste Type, 2001-2005: 

This figure is a stacked bar graph. The vertical axis of the graph 
represents number of generators from 0 to 800. The horizontal axis of 
the graph represents eight generator types, with types of waste stacked 
into each bar. The types of waste depicted in the stacked bars are: 
Utility; Medical; Industry; Government; and Academic. The approximate 
number of generators depicted by generator type are as follows:

DAW: approximately 150;
OGEP: approximately 10; 
Liquids and Solids: approximately 20; 
Filters, Filer Media and Resins: approximately 50; 
Equipment and Material: approximately 30; 
Sealed Sources: approximately 700; 
Biological Materials: approximately 10; 
Other: approximately 160. 

Source: GAO based on Manifest Information Management System records for 
2001-2005. 

Note: The amounts across the chart above do not add to 854 because some 
generators disposed of more than one type of waste. 

[End of figure] 

Table 12 shows that the volume of class B and C waste ranges from year 
to year across the waste generator types. The average volume of class B 
and C waste between 2001 and 2005 was about 28,800 cubic feet. 

Table 12: Range of Class B and C Waste Disposed Annually at Richland 
and Barnwell by Generator Type, 2001-2005: 

Generator: Academic; 
Volume (in cubic feet), Average: 113; 
Volume (in cubic feet), Minimum: 51; 
Volume (in cubic feet), Maximum: 263; 
Volume (in cubic feet), Total: 564; 
Activity (in curies), Average: 139; 
Activity (in curies), Minimum: 10; 
Activity (in curies), Maximum: 337; 
Activity (in curies), Total: 694. 

Generator: Government; 
Volume (in cubic feet), Average: 916; 
Volume (in cubic feet), Minimum: 220; 
Volume (in cubic feet), Maximum: 1,643; 
Volume (in cubic feet), Total: 4,581; 
Activity (in curies), Average: 20,135; 
Activity (in curies), Minimum: 111; 
Activity (in curies), Maximum: 88,159; 
Activity (in curies), Total: 100,673. 

Generator: Industry; 
Volume (in cubic feet), Average: 1,308; 
Volume (in cubic feet), Minimum: 712; 
Volume (in cubic feet), Maximum: 2,285; 
Volume (in cubic feet), Total: 6,542; 
Activity (in curies), Average: 15,888; 
Activity (in curies), Minimum: 7,906; 
Activity (in curies), Maximum: 30,213; 
Activity (in curies), Total: 79,442. 

Generator: Medical; 
Volume (in cubic feet), Average: 36; 
Volume (in cubic feet), Minimum: 23; 
Volume (in cubic feet), Maximum: 61; 
Volume (in cubic feet), Total: 178; 
Activity (in curies), Average: 7; 
Activity (in curies), Minimum: 2; 
Activity (in curies), Maximum: 16; 
Activity (in curies), Total: 33. 

Generator: Utility; 
Volume (in cubic feet), Average: 26,445; 
Volume (in cubic feet), Minimum: 17,054; 
Volume (in cubic feet), Maximum: 33,698; 
Volume (in cubic feet), Total: 132,225; 
Activity (in curies), Average: 379,636; 
Activity (in curies), Minimum: 122,851; 
Activity (in curies), Maximum: 499,854; 
Activity (in curies), Total: 1,898,182. 

Generator: Total[a]; 
Volume (in cubic feet), Average: 28,818; 
Volume (in cubic feet), Minimum: 18,060; 
Volume (in cubic feet), Maximum: 37,950; 
Volume (in cubic feet), Total: 144,090; 
Activity (in curies), Average: 415,805; 
Activity (in curies), Minimum: 130,880; 
Activity (in curies), Maximum: 618,579; 
Activity (in curies), Total: 2,079,024. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Column percentages may not add up to 100 percent due to rounding. 

Note: DOE recognizes that as the industry category includes brokers and 
processors that collect waste from other generator categories, the 
contribution of waste disposed by industry generators is overestimated; 
however, DOE has not done the analysis to determine the extent of this 
overestimation. 

[End of table] 

The next two tables provide a distribution of class B and C waste (both 
volume and activity) disposed at Richland and Barnwell from 2001 to 
2005 by waste generator type. Table 13 shows that utilities contributed 
the about 92 percent of the volume and 91 percent of the activity of 
class B and C waste disposed at Richland and Barnwell from 2001 to 
2005. Table 14 shows the distribution of class B and C waste across 
generator types excluding utility generators. In this table, industry 
disposed of about 55 percent of class B and C waste, which amounted to 
about 44 percent of the total activity. Government, on the other hand, 
contributed about 39 percent of the volume, but about 56 percent of the 
activity. 

Table 13: Distribution of Class B and C Waste Disposed Annually at 
Richland and Barnwell by Generator Type, 2001-2005: 

Generator: Academic; 
Percent of Volume (in cubic feet), Richland: 0.5; 
Percent of Volume (in cubic feet), Barnwell: 0.4; 
Percent of Volume (in cubic feet), Total: 0.4; 
Percent of Activity (in curies), Richland: 0.0; 
Percent of Activity (in curies), Barnwell: 0.0; 
Percent of Activity (in curies), Total: 0.0. 

Generator: Government; 
Percent of Volume (in cubic feet), Richland: 18.8; 
Percent of Volume (in cubic feet), Barnwell: 3.0; 
Percent of Volume (in cubic feet), Total: 3.2; 
Percent of Activity (in curies), Richland: 1.1; 
Percent of Activity (in curies), Barnwell: 4.9; 
Percent of Activity (in curies), Total: 4.8. 

Generator: Industry; 
Percent of Volume (in cubic feet), Richland: 37.7; 
Percent of Volume (in cubic feet), Barnwell: 4.2; 
Percent of Volume (in cubic feet), Total: 4.5; 
Percent of Activity (in curies), Richland: 96.4; 
Percent of Activity (in curies), Barnwell: 2.9; 
Percent of Activity (in curies), Total: 3.8. 

Generator: Medical; 
Percent of Volume (in cubic feet), Richland: 0.1; 
Percent of Volume (in cubic feet), Barnwell: 0.1; 
Percent of Volume (in cubic feet), Total: 0.1; 
Percent of Activity (in curies), Richland: 0.0; 
Percent of Activity (in curies), Barnwell: 0.0; 
Percent of Activity (in curies), Total: 0.0. 

Generator: Utility; 
Percent of Volume (in cubic feet), Richland: 42.9; 
Percent of Volume (in cubic feet), Barnwell: 92.2; 
Percent of Volume (in cubic feet), Total: 91.8; 
Percent of Activity (in curies), Richland: 2.5; 
Percent of Activity (in curies), Barnwell: 92.2; 
Percent of Activity (in curies), Total: 91.3. 

Generator: Total[a]; 
Percent of Volume (in cubic feet), Richland: 100; 
Percent of Volume (in cubic feet), Barnwell: 100; 
Percent of Volume (in cubic feet), Total: 100; 
Percent of Activity (in curies), Richland: 100; 
Percent of Activity (in curies), Barnwell: 100; 
Percent of Activity (in curies), Total: 100. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Column percentages may not add up to 100 percent due to rounding. 

Note: DOE recognizes that as the industry category includes brokers and 
processors that collect waste from other generator categories, the 
contribution of waste disposed by industry generators is overestimated; 
however, DOE has not done the analysis to determine the extent of this 
overestimation. 

[End of table] 

Table 14: Distribution of Non-Utility Class B and C Waste Disposed 
Annually at Richland and Barnwell by Generator Type, 2001-2005: 

Generator: Academic; 
Percent of Volume (in cubic feet), Richland: 0.8; 
Percent of Volume (in cubic feet), Barnwell: 5.1; 
Percent of Volume (in cubic feet), Total: 4.8; 
Percent of Activity (in curies), Richland: 0.0; 
Percent of Activity (in curies), Barnwell: 0.4; 
Percent of Activity (in curies), Total: 0.4. 

Generator: Government; 
Percent of Volume (in cubic feet), Richland: 32.9; 
Percent of Volume (in cubic feet), Barnwell: 39.1; 
Percent of Volume (in cubic feet), Total: 38.6; 
Percent of Activity (in curies), Richland: 1.1; 
Percent of Activity (in curies), Barnwell: 62.5; 
Percent of Activity (in curies), Total: 55.7. 

Generator: Industry; 
Percent of Volume (in cubic feet), Richland: 66.1; 
Percent of Volume (in cubic feet), Barnwell: 54.3; 
Percent of Volume (in cubic feet), Total: 55.1; 
Percent of Activity (in curies), Richland: 98.9; 
Percent of Activity (in curies), Barnwell: 37.0; 
Percent of Activity (in curies), Total: 43.9. 

Generator: Medical; 
Percent of Volume (in cubic feet), Richland: 0.1; 
Percent of Volume (in cubic feet), Barnwell: 1.6; 
Percent of Volume (in cubic feet), Total: 1.5; 
Percent of Activity (in curies), Richland: 0.0; 
Percent of Activity (in curies), Barnwell: 0.0; 
Percent of Activity (in curies), Total: 0.0. 

Generator: Total[a]; 
Percent of Volume (in cubic feet), Richland: 100; 
Percent of Volume (in cubic feet), Barnwell: 100; 
Percent of Volume (in cubic feet), Total: 100; 
Percent of Activity (in curies), Richland: 100; 
Percent of Activity (in curies), Barnwell: 100; 
Percent of Activity (in curies), Total: 100. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Column percentages may not add up to 100 percent due to rounding. 

Note: DOE recognizes that as the industry category includes brokers and 
processors that collect waste from other generator categories, the 
contribution of waste disposed by industry generators is overestimated; 
however, DOE has not done the analysis to determine the extent of this 
overestimation. 

[End of table] 

Table 15 shows the total volume and activity of class B and C waste, by 
compact, that was disposed of at both Richland and Barnwell from 2001 
to 2005. The last two columns show the percent contribution that each 
compact made to total volume and activity of disposed class B and C 
waste at Richland and Barnwell from 2001 to 2005. If Barnwell closed to 
non-compact states and the current pattern of disposal remained the 
same, waste generators in these states would accumulate over 100,000 
cubic feet of class B and C waste over a 5-year period. 

Table 15: Disposed Class B and C Waste at Richland and Barnwell by LLRW 
Compact, 2001-2005: 

Compact: Appalachian; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 10,417; 
Barnwell, Activity: 499,433; 
Total, Volume: 10,417; 
Total, Activity: 499,433; 
Percent, Volume: 7.2; 
Percent, Activity: 24.0. 

Compact: Atlantic; 
Richland, Volume: 0;  
Richland, Activity: 0; 
Barnwell, Volume: 38,196; 
Barnwell, Activity: 215,884; 
Total, Volume: 38,196; 
Total, Activity: 215,884; 
Percent, Volume: 26.5; 
Percent, Activity: 10.4. 

Compact: Central; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 4,306; 
Barnwell, Activity: 13,286; 
Total, Volume: 4,306; 
Total, Activity: 13,286; 
Percent, Volume: 3.0; 
Percent, Activity: 0.6. 

Compact: Central Midwest; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 15,520; 
Barnwell, Activity: 480,153; 
Total, Volume: 15,520; 
Total, Activity: 480,153; 
Percent, Volume: 10.8; 
Percent, Activity: 23.1. 

Compact: Midwest; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 6,235; 
Barnwell, Activity: 74,168; 
Total, Volume: 6,235; 
Total, Activity: 74,168; 
Percent, Volume: 4.3; 
Percent, Activity: 3.6. 

Compact: Northwest; 
Richland, Volume: 1,448; 
Richland, Activity: 19,257; 
Barnwell, Volume: 280; 
Barnwell, Activity: 161; 
Total, Volume: 1,728; 
Total, Activity: 19,418; 
Percent, Volume: 1.2; 
Percent, Activity: 0.9. 

Compact: Rocky Mountain; 
Richland, Volume: 69; 
Richland, Activity: 1,402; 
Barnwell, Volume: 5; 
Barnwell, Activity: 0.1; 
Total, Volume: 74; 
Total, Activity: 1,402; 
Percent, Volume: 0.1; 
Percent, Activity: 0.1. 

Compact: Southeast; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 21,991; 
Barnwell, Activity: 329,245; 
Total, Volume: 21,991; 
Total, Activity: 329,245; 
Percent, Volume: 15.2; 
Percent, Activity: 15.8. 

Compact: Southwestern; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 6,490; 
Barnwell, Activity: 7,774; 
Total, Volume: 6,490; 
Total, Activity: 7,774; 
Percent, Volume: 4.5; 
Percent, Activity: 0.4. 

Compact: Texas; 
Richland, Volume: 0;  
Richland, Activity: 0; 
Barnwell, Volume: 5,345; 
Barnwell, Activity: 6,680; 
Total, Volume: 5,345; 
Total, Activity: 6,680; 
Percent, Volume: 3.7; 
Percent, Activity: 0.3. 

Compact: Unaffiliated; 
Richland, Volume: 0; 
Richland, Activity: 0; 
Barnwell, Volume: 33,787; 
Barnwell, Activity: 431,582; 
Total, Volume: 33,787; 
Total, Activity: 431,582;
Percent, Volume: 23.5; 
Percent, Activity: 20.8. 

Compact: Total[b]; 
Richland, Volume: 1,517; 
Richland, Activity: 20,659; 
Barnwell, Volume: 142,572; 
Barnwell, Activity: 2,058,366; Total, Volume: 144,089; 
Total, Activity: 2,079,025; 
Percent, Volume: 100; 
Percent, Activity: 100. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Includes one U.S. Army waste generator outside of the United States 
that accounted for 16.34 cubic feet of waste that contained 27.4 curies 
of activity. 

[b] Column percentages may not add up to 100 percent due to rounding. 

[End of table] 

Table 16 summarizes one way to show the affects of eliminating access 
to waste generators in 36 states that will not have disposal access for 
class B and C waste in 2008 because they are not affiliated with the 
Atlantic, Northwest or Rocky Mountain Compacts. Using the past 5 years 
of disposal data as an indicator, the closing of Barnwell to these 
generators would affect 73 percent of the disposed volume and about 90 
percent of the disposed activity. Almost all of the remaining volume 
going to Barnwell would come from the Atlantic LLRW Compact. 

Table 16: Class B and C Waste Disposed at Barnwell from Atlantic, 
Northwest, and Rocky Mountain Generators, and Other Generators, 2001-
2005: 

Compact: Atlantic, Northwest, and Rocky Mountain; 
Barnwell, Volume: 38,482; 
Barnwell, Activity: 216,046; 
Percent of Barnwell, Volume: 27.0; 
Percent of Barnwell, Activity: 10.5. 

Compact: Other; 
Barnwell, Volume: 104,091; 
Barnwell, Activity: 1,842,320; 
Percent of Barnwell, Volume: 73.0; 
Percent of Barnwell, Activity: 89.5. 

Compact: Total; 
Barnwell, Volume: 142,573; 
Barnwell, Activity: 2,058,366; 
Percent of Barnwell, Volume: 100; 
Percent of Barnwell, Activity: 100. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Column percentages may not add up to 100 percent due to rounding. 

[End of table] 

Another way to illustrate the affects of eliminating access to the 
Barnwell disposal facility is the number of waste generators that would 
no longer have a place to dispose of their disused, sealed radiological 
sources and would thus have to store these sources on-site. Table 17 
shows the compacts where these generators are located.

Table 17: Number of Waste Generators That Disposed of Sealed 
Radiological Sources at Richland and Barnwell Ranked by Compact, 2001-
2005: 

Compact: Unaffiliated; 
Total generators: 138; 
Percent of total: 20; 
Impacted by Barnwell closure: 138. 

Compact: Southeast; 
Total generators: 98; 
Percent of total: 14; 
Impacted by Barnwell closure: 98. 

Compact: Southwestern; 
Total generators: 92; 
Percent of total: 13; 
Impacted by Barnwell closure: 92. 

Compact: Appalachian; 
Total generators: 82; 
Percent of total: 12; 
Impacted by Barnwell closure: 82. 

Compact: Midwest; 
Total generators: 82; 
Percent of total: 12; 
Impacted by Barnwell closure: 82. 

Compact: Atlantic; 
Total generators: 70; 
Percent of total: 10; 
Impacted by Barnwell closure: [Empty]. 

Compact: Texas; 
Total generators: 45; 
Percent of total: 6; 
Impacted by Barnwell closure: 45. 

Compact: Central Midwest; 
Total generators: 43; 
Percent of total: 6; 
Impacted by Barnwell closure: 43. 

Compact: Central; 
Total generators: 21; 
Percent of total: 3; 
Impacted by Barnwell closure: 21. 

Compact: Northwest; 
Total generators: 17; 
Percent of total: 2; 
Impacted by Barnwell closure: o. 

Compact: Rocky Mountain; 
Total generators: 9; 
Percent of total: 1; 
Impacted by Barnwell closure: 0. 

Compact: Total[a]; 
Total generators: 697; 
Percent of total: 100; 
Impacted by Barnwell closure: 601. 

Source: Manifest Information Management System records for 2001-2005. 

[a] Excludes one U.S. Army waste generator outside of the United States.

[End of table] 

[End of section] 

Appendix VI: Comments from the Nuclear Regulatory Commission and Our 
Response: 

Note: GAO comments supplementing those in the report text appear at the 
end of the appendix. 

United States Nuclear Regulatory Commission: Washington DC 20555-0001: 

February 21, 2007: 

Mr. Gene 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 
January 2007 draft of the U.S. Government Accountability Office's 
(GAO's) report entitled "Low-Level Radioactive Waste Management: 
Approaches Used by Foreign Countries Would Provide Useful Lessons for 
Managing U.S. Radioactive Waste" (GAO-07-221). The U.S. Nuclear 
Regulatory Commission (NRC) appreciates the time and effort that you 
and your staff have taken to prepare this report. 

In the report, GAO identifies a number of low-level radioactive waste 
(LLRW) management approaches used in other countries. The GAO 
recommends that the NRC and the U.S. Department of Energy (DOE) 
evaluate and report back to Congress within one year on the usefulness 
to the U.S. of adopting certain LLRW management approaches discussed in 
the report and the potential costs to develop a U.S. national 
radioactive waste management plan. 

For the reasons discussed below and in the Enclosure, NRC believes a 
stand-alone study may not be the most effective means to evaluate the 
usefulness of adopting many of the LLRW management approaches discussed 
in the report. We believe it would be more effective to consider the 
LLRW management approaches through ongoing efforts being conducted in 
the U.S., such as NRC's assessment to identify needed improvements to 
the LLRW regulatory program, and through organizations with broad 
representation of U.S. stakeholders, such as the Interagency Steering 
Committee on Radiation Standards. The results of such efforts could be 
reported in our annual letter to Congress that addresses progress in 
completing actions in response to recommendations in multiple GAO 
reports. 

It is important to note that systems for LLRW management in various 
countries have evolved differently than in the U.S., due to many 
factors such as culture and public sentiment, systems of government, 
public policy, and geography. Such differences have precluded adoption 
in the U.S. of some of the approaches used in other countries. It is 
important to consider these factors in comparing systems for LLRW 
management and assessing the transferability of best practices among 
countries. 

As noted in the GAO report, NRC is currently conducting a strategic 
assessment of its LLRW program to ensure that NRC's regulatory 
framework will continue to ensure the safe management of LLRW. Many of 
the waste management practices noted by GAO are being evaluated in the 
strategic assessment. Further, NRC and other U.S. stakeholders have 
previously considered and evaluated several of the approaches discussed 
in the GAO draft report, and either determined that the approaches were 
not practical or not necessary to ensure safety and security of LLRW. 
The report could be better informed by acknowledging these past and 
ongoing U.S. efforts to consider approaches used to manage LLRW in 
other countries, especially in cases where the approaches ultimately 
were not implemented.

Additional information on the above general comments and our detailed 
comments, along with those of the Chairman of the NRC's Advisory 
Committee on Nuclear Waste, are enclosed. If you have any questions on 
our comments or would like to discuss these issues further, please 
contact Ms. Melinda Malloy of my staff at (301) 415-1785.

Sincerely,

Signed by: 

Luis A. Reyes: 
Executive Direct for Operations: 

Enclosure: Comments on Draft Report: 

(See section entitled "Agency Comments and Our Evaluation" for GAO's 
response to this letter) 

[End of letter] 

General Comments: 

NRC Staff: 

1. The U.S. Government Accountability Office (GAO) report states that 
the U.S. is lacking an integrated national radioactive waste management 
plan. However, GAO does not identify the national problem that it 
believes could be solved by the implementation of such a plan. The 
report did not acknowledge that, in large measure, the Low-Level 
Radioactive Waste Policy Amendments Act (LLRWPAA) was an attempt to 
formulate and encourage States to implement such a plan, nor did the 
report refer to efforts of various States in forming low-level 
radioactive waste (LLRW) compacts with the purpose of developing 
regional disposal facilities. It is considered by many that the LLRWPAA 
did not achieve its desired outcome. Legislative changes would likely 
be needed before the development of a national radioactive waste 
management plan could substantively improve the U.S. system. The U.S. 
Nuclear Regulatory Commission (NRC) notes that the costs to develop a 
U.S. radioactive waste management plan would be significant, and that 
the benefits of such a plan are unclear, particularly given the complex 
composition of the current U.S. system. {See comment 1)

2. It is important to note that systems for LLRW management in various 
countries have evolved differently than in the U.S., due to many 
factors such as culture and public sentiment, systems of government, 
public policy, and geography. The U.S. system relies on a broad 
spectrum of private and public entities to manage radioactive wastes, 
while most European Union (EU) countries rely on national (government) 
disposal solutions. The U.S. program is highly complex, involving 
numerous governmental and commercial organizations that generate, 
process, dispose of LLRW, and regulate these activities, under 
different legislative authorities and a patchwork of laws that speak to 
the various forms and origins of radioactive waste. Within the EU, most 
national authorities have primacy over the LLRW management program, and 
there are no provisions to relinquish regulatory authority to the 
individual provinces in Europe. Developing a waste management plan for 
the U.S. would be much more difficult and complex, owing to the nature 
of the program, than for many countries that have programs with a 
limited number of organizations and waste generation rates. It is 
important to consider these factors in comparing systems for LLRW 
management and assessing the transferability of best practices among 
countries. (See comment 2)

3. While most of the U.S. LLRW stakeholder group representatives 
interviewed by GAO for this study suggested the need to evaluate 
alternative ways to manage LLRW in the U.S., they did not cite the 
development of a national waste management plan as a means for 
accomplishing this. The GAO report states that, in the absence of a 
national radioactive waste management plan, interested parties in the 
U.S. lack a means to identify radioactive waste quantities and 
locations, forecast future storage and disposal needs, assess research 
and development opportunities, determine appropriate safety and 
security requirements, and prepare contingency plans. While the current 
U.S. radioactive waste management system is complex and diffuse, these 
issues are addressed in large part by the current system. For example, 
safety and security requirements are specified by Federal agencies and 
Agreement State authorities, while LLRW storage and disposal needs and 
research opportunities are forecasted by a combination of public and 
private sector entities. Contingency planning is performed by the 
respective groups that comprise the system according to their roles. 
(See comment 3)

4. It is important to note that the national radioactive waste 
management plans for France, Germany, and Spain, which are cited as 
examples in the report, were formulated by either a national-level 
ministry or national waste management organization that does not exist 
in the U.S. system. The NRC agrees that in some instances, an 
integrated approach by Federal and State authorities is needed to make 
progress toward improvements in the U.S. system. However, NRC believes 
that groups such as the Interagency Steering Committee on Radiation 
Standards (ISCORS) constitute a more appropriate and efficient 
mechanism for achieving this coordination. Both State and Federal 
officials (including the U.S. Department of Energy (DOE)) participate 
in ISCORS. (See comment 4) 

5. Before finalizing the current report, it is suggested that the GAO 
contributors conduct a thorough examination of the wealth of 
information and data provided, analyzed and peer-reviewed in the 
international Joint Convention on the Safety of Spent Fuel Management 
and on the Safety of Radioactive Waste Management (the Joint 
Convention). The basis for lessons to the U.S. LLRW program would be 
more completely informed by reviewing the National Reports required by 
the Joint Convention. All but one of the 20 surveyed countries (Mexico 
is not a Contracting Party to the Joint Convention) were subject to 
detailed review of their LLRW management program, including inventories 
of waste stored and disposed. Furthermore, questions and comments were 
provided to all of the Contracting Parties on details of their waste 
management programs, after thorough review by all of the other 
Contracting Parties. There are now 44 Contracting Parties, including 
the U.S., the Peoples Republic of China, and Russia. (See comment 5) 

6. The NRC and DOE have mature, robust programs for international 
information exchange and are actively engaged in learning about 
successful radioactive waste management practices used in other 
countries as well as sharing best practices from the U.S. This learning 
and exchange occurs through mechanisms such as participation in the 
Joint Convention, in International Atomic Energy Agency (IAEA) meetings 
and the development of IAEA safety standards and guides, in the Nuclear 
Energy Agency (NEA) Radioactive Waste Management Committee, and via a 
number of other formal and informal interactions. In carrying out these 
activities, the U.S. is looked to as a world leader in safely managing 
radioactive waste and plays a leadership role in developing 
international regulatory practices. The NRC will continue its efforts 
to share best practices with its international and domestic 
counterparts and to incorporate those practices that can be implemented 
within the U.S. regulatory system. (See comment 6) 

7. The NRC is focused on the continuous improvement of its programs, 
including its LLRW regulatory program. As noted in the report, NRC is 
currently conducting a strategic assessment of its LLRW program to 
ensure that NRC's regulatory framework will continue to ensure the safe 
management of LLRW and will promote regulatory stability, reliability, 
and efficiency. Many of the waste management practices noted in the GAO 
report are being evaluated in the strategic assessment. Further, NRC 
has previously considered and commented on several of these practices. 
For example, in our response to GAO's 2004 report on LLRW disposal 
availability (GAO-04-604), we commented on the utility of a national 
LLRW tracking system and noted that the regulatory costs of 
implementing such a system are not balanced by the negligible benefits. 
Disposal capacity needs have been and will continue to be accurately 
forecasted absent a national radioactive waste inventory database 
through a combination of public and private sector efforts by DOE, 
waste generators, disposal site operators, and other industry groups. 
The NRC continues to believe that implementation of a national database 
is not needed to ensure safe LLRW management and would impose an 
unnecessary burden on Agreement States, NRC, and U.S. licensees. NRC 
also believes that agency resources can best be used to continue 
efforts that have already been identified as needed improvements to the 
LLRW regulatory program. (See comment 7) 

8. Because the U.S. is one of the countries considered in the survey 
process, it would be informative and instructive for the comparison 
tables throughout the report to include the U.S. in one of the columns. 
This would help provide a better insight into which countries may have 
approaches which could result in improvements to the U.S. program. (See 
comment 8) 

9. The GAO report notes that other countries make extensive use of 
landfills for disposal of low-activity radioactive waste, and that 
several countries allow materials with small amounts of residual 
radioactivity to be exempted from regulatory control. The NRC currently 
has a case-by-case exemption process to allow for the alternate 
disposal of some low-activity radioactive waste in landfills or 
hazardous waste facilities. The NRC and the U.S. Environmental 
Protection Agency have explored options for a general exemption or 
clearance provision for low activity waste, but have faced significant 
opposition to these proposals. In the 1992 Energy Policy Act, Congress 
gave States the authority to regulate the disposal of LLRW exempted 
from regulation by NRC in response to State concerns regarding NRC 
plans at that time to exempt certain low activity materials. Then in 
2002, NRC initiated a rulemaking to facilitate the disposition of 
certain solid materials with no, or very small amounts of, residual 
radioactivity resulting from licensed operations, but deferred action 
on this rulemaking in 2005. The reasons for deferring action were that 
NRC was faced with several high priority and complex tasks, that the 
current approach to review specific cases on an individual basis is 
fully protective of public health and safety, and that the immediate 
need for this rule had changed due to the shift in timing for reactor 
decommissioning. (See comment 9) 

10. The NRC has financial assurance requirements for many aspects of 
LLRW management, including provisions that apply to many non-utility 
LLRW generators. The NRC continues to evaluate this very important 
aspect of regulation, and is currently pursuing a rulemaking associated 
with financial assurance for "legacy" decommissioning sites. As noted 
in the GAO report, a recent report from the Interagency Radiation 
Source Protection and Security Task Force, which was chaired by NRC, 
recommended an additional evaluation of financial assurance 
requirements associated with licensees that possess Category 1 and 
Category 2 radioactive sources. (See comment 10) 

11. A careful examination of terminology is necessary to fully 
appreciate how different Nations employ terms such as "practices," 
"waste," "clearance," "background," and others. For example, the "Front 
End of the Nuclear Fuel Cycle" means different things in the 
international arena. For regulatory purposes, the front end of the U.S. 
nuclear fuel cycle is the uranium processing of ore, sometimes referred 
to as milling. For other countries the term would include conventional 
mining of uranium or thorium ore and the associated mine spoil, which 
is at radioactivity levels typical of mine spoils from other industrial 
resource development. (See comment 11) 

12. There appears to be an interchangeable use of terms such as LLRW 
and orphaned sources. Although high-activity sources are generally 
LLRW, albeit greater than Class C (GTCC), not all LLRW forms are 
composed of disused sealed sources. (See comment 12)  

13. Throughout the report the Radiation Source Protection and Security 
Task Force (Task Force) is referred to as the U.S. Nuclear Regulatory 
Commission (NRC) Task Force. This is misleading. The Task Force was 
chaired by NRC, as directed by the Energy Policy Act, but it was an 
interagency task force and should be referred to as such. (See comment 
13)  

14. The authors may need to view and evaluate the U.S. LLRW management 
program through integration of the functions and activities of Federal 
and State authorities and the private sector. In addition, the authors 
should recognize the safe management of LLRW in the U.S. over the past 
decades considering actual data for: (a) volume of waste disposed; (b) 
workers exposure records; (c) public exposure records; and (d) 
environmental impacts. (See comment 14)  

Comments from the Chairman, Advisory Committee on Nuclear Waste (ACNW): 

Observation: The GAO report specifically addresses GTCC wastes (higher 
activity yet short-lived) and low activity wastes. GAO observed that 
much can be done to improve the management of these wastes. They 
examined how the Europeans manage these wastes and also sought advice 
from stakeholders in the regulated and regulator communities. 

1. The GAO report makes two recommendations for Congress to consider: 
(1) that the NRC Chairman and the U.S. Department of Energy (DOE) 
Secretary evaluate the usefulness of adopting European LLRW management 
practices described in their report; and (2) that the NRC Chairman and 
the DOE Secretary identify the steps, authorities, and potential costs 
associated with developing a (comprehensive) radioactive waste 
management plan. Note: The report is silent on the role of the U.S. 
Environmental Protection Agency (EPA) in setting generally applicable 
standards for radioactive waste management. While currently shared 
among several Federal agencies and State agencies through the Agreement 
States program, the U.S. does have a comprehensive radioactive waste 
management program. It is just not centralized in one agency and has 
developed over time. (See comment 1)  

2. The GAO report would be strengthened by including the detailed 
information that is included in the ACNW's final report on LLRW 
regulation in the U.S. (NUREG-1853). Some of the issues that the GAO 
report addresses have been addressed in the ACNW's letter of August 16, 
2006, that accompanied the NUREG-1853 report. The NUREG report and the 
ACNW letter may provide some additional insights to GAO and would be a 
useful foundation for any further discussions. (See comment 2)  

3. The focus of the GAO report is primarily on the management of 
commercial LLRW at high concentration and low concentration ends of the 
LLRW classification system. One key difference is that the U.S. 
radioactive waste management system relies on a mix of private and 
government initiatives to manage radioactive wastes. Most European 
countries rely on national government disposal solutions. (See comment 
3)  

4. The GAO report makes reference to radioactive waste management 
practices focused on the Organization for Economic Cooperation and 
Development (OECD)/Nuclear Energy Agency (NEA) Member States. However, 
there is no detail for each country's programs. Such information is 
available in the OECD/NEA publication, "Radioactive Waste Management 
Programmes in OECD/NEA Member Countries," Issy-les-Moulineaux, NEA 
Radioactive Waste Management Committee, 2005. It is a compendium report 
covering radioactive waste management practices in 20 OECD/NEA Member 
Countries. (See comment 4)  

5. GAO makes reference to the need to exempt certain radioactive wastes 
from regulation. However, the GAO report does not acknowledge in their 
report past NRC experience with de minimis wastes and Below Regulatory 
Concern policy, on which Congress later pre-empted Commission action. 
This is discussed in NUREG-1853. (See comment 5)  

6. The first GAO recommendation would be clearer if a new table to the 
report that correlates European and U.S. management practices used as 
the basis for the recommendation. It would be helpful if the GAO report 
recommended specific practices that should be considered for adoption 
in the U.S. (See comment 6)  

[End of general comments] 

NRC provided 14 specific comments about our report accompanying its 
letter. Our response to each comment follows.  

1. We acknowledge that our past reports have not found the lack of a 
national radioactive waste management plan as a limitation in the 
management of LLRW in the United Sates. Nevertheless, in the course of 
conducting our study, we found that most countries in our survey use 
national radioactive waste management plans to guide the management of 
these wastes. Our report discussed the LLRW Policy Act, but not to 
extent that we have in previous GAO reports, and we agree with NRC that 
the act has not achieved its desired outcome of establishing regional 
disposal facilities for LLRW. NRC’s suggestion that legislative changes 
would likely be needed before the development of a national radioactive 
waste management plan could substantially improve the U.S. system is in 
line with our recommendation to evaluate the steps involved in 
developing such a plan. Finally, we considered NRC’s concerns about the 
potential costs and unclear benefits of developing a national 
radioactive waste management plan and observe that an evaluation of 
these concerns would be better placed in the report we recommended that 
NRC and DOE prepare for the Congress.  

2. We believe that the complexity of the U.S. LLRW management system 
should provide a further rationale for evaluating the usefulness of 
developing a national radioactive waste management plan that could 
integrate the various radioactive waste management programs that reside 
at the federal and state levels into a single source document.  

3. While the LLRW stakeholder group representatives that we interviewed 
did not identify a need to develop a national radioactive waste 
management plan, we believe that their support for the need to evaluate 
alternative ways to manage LLRW in the United States is consistent with 
our recommendation to evaluate the usefulness of developing such a 
plan. We acknowledge that much of the information on radioactive waste 
management is already available from a variety of sources. We concluded 
on pages 37-38 of our report that a national radioactive waste 
management plan could help integrate these activities into a single 
source document.  

4. We concur with NRC that in some instances an integrated approach by 
federal and state authorities is needed to make progress toward 
improvement in the U.S. system. In our view, one way to bring 
stakeholders together to discuss ways to improve radioactive waste 
management would be in the context of developing a national radioactive 
waste management plan. NRC and DOE can decide the most appropriate 
means to evaluate the usefulness of developing such a plan and who 
should participate in the process.  

5. As our report notes, we reviewed the national reports to the Joint 
Convention of the countries surveyed and other international reports 
addressing each country. For the most part, our survey was designed to 
collect information that was not available in these existing reports.  

6. We commented in our report on the agencies’ engagements in 
international information exchanges regarding radioactive waste 
management practices. We also observe that NRC and DOE encouraged us to 
collect information on the LLRW management approaches used in other 
countries, as this information was not readily available from other 
sources.  

7. In our view, the LLRW management approaches identified in this 
report should help direct NRC’s strategic assessment of its LLRW 
program. Moreover, NRC should include in its report to Congress the 
results of any previous and ongoing evaluations of the LLRW approaches 
that we cited in our report.  

8. We provided the response of the United States to the survey in 
appendix III of our report.  

9. We commented on NRC’s evaluation of and decision on a rule to 
facilitate the disposition of certain solid materials with no, or very 
small amounts of residual radioactivity (very low-level radioactive 
waste) in appendix I of our report. We observe that NRC’s current 
position on this issue contrasts with the management practices of most 
other countries and differs from the opinions we obtained from most 
LLRW stakeholder representatives.  

10. We identified some of the current gaps in financial assurance 
requirements for those licensed to use radioactive materials in the 
United States in appendix I of our report. We also pointed out in our 
report that there is no national database on those licensees that move 
into bankruptcy and cannot afford to disposition their sealed 
radiological sources. Our report identified approaches used in some 
other countries to reduce the government cost to recover and 
disposition these disused sources.  

11. Interpretation of terms is always an issue with questionnaires. We 
pretested the questionnaire in two other countries and with 
international experts to identify problematic terms. We attempted to 
use terms that are generally understood internationally by referring to 
NEA and IAEA technical guidance, and reports from other countries.  

12. We revised our report to clarify this point.  

13. We revised our report to clarify this point.  

14. The purpose of our report was to determine the extent to which 
other countries use LLRW management approaches in areas that GAO has 
identified as needing some improvement. We did not attempt to identify 
approaches other countries use to increase the safe use of radioactive 
materials.  

The Chairman, Advisory Committee on Nuclear Waste, provided 6 specific 
comments about our report with the NRC letter. Our response to each 
comment follows.  

1. While the totality of the various federal and state programs 
addressing LLRW management may be comprehensive when aggregated, we 
view this collection of programs as not representing a national 
radioactive waste management plan. We identified some potential 
benefits of such a plan on pages 37-38 of this report.  

2. We referred to the Advisory Committee’s 2006 letter in our report, 
but the final report of the advisory committee was not available when 
we sent the draft copy of our report to the NRC. We have added a 
reference to the final version of the advisory committee report in our 
report.  

3. We point out that a third of the countries in our survey are not 
members of the European Union. Our survey found that most countries 
take a national perspective to the management of LLRW; however, those 
entities that are responsible for providing and operating LLRW disposal 
and storage facilities are not always government agencies. For example, 
the LLRW system in Japan relies primarily on nuclear utility companies, 
operating under stringent government regulation, to construct and 
operate radioactive waste treatment, storage, and disposal facilities.  

4. We reviewed country reports, including those provided to NEA, IAEA, 
and the Joint Convention, as a check on and supplement to the 
information that we obtained directly from the 18 countries in our 
survey.  

5. We did not recommend in our report that the United States needs to 
exempt certain radioactive wastes from regulation. Our report 
identifies LLRW management practices in other countries, and the level 
of support for these approaches among representatives from LLRW 
stakeholder groups and in some recent LLRW management reports. We 
commented on NRC’s evaluation of a rule to exempt very level 
radioactive waste from regulation as LLRW in appendix I.  

6. We provided the response of the United States to the survey in 
appendix III of our report.  

[End of GAO comments]  

[End of section]  

Appendix VII: Comments from the Department of Energy and Our Response:  

Note: GAO comments supplementing those in the report text appear at the 
end of the appendix.  

Department of Energy: 
Washington, DC 20585:  

March 7, 2007:  

Mr. Gene Aloise: 
Director: 
Natural Resources and Environment Team: United States Government 
Accountability Office: Washington, D.C. 20548:  

Dear Mr. Aloise: 

My office has reviewed the draft report entitled Low-Level Radioactive 
Waste Management: Approaches Used by Foreign Countries Would Provide 
Useful Lessons for Managing U.S. Radioactive Waste (GAO-07-221). This 
letter provides the Department of Energy's (DOE) consolidated comments 
on the report; it has been coordinated with the National Nuclear 
Security Administration. 

The report provides information on other countries' experiences in 
radioactive waste management. It also provides observations on the 
United States (U.S.) low-level radioactive waste (LLRW) management 
programs and continuing efforts to manage disused radioactive sealed 
sources. The report summarizes previous Government Accountability 
Office studies on the U.S., and specifically DOE LLRW efforts, as well 
as recent efforts by the Federal Government to analyze and address 
programmatic vulnerabilities, such as the Interagency "Radiation Source 
Protection and Security Task Force Report." For these reasons, DOE 
regards this draft report as a useful comparison of the U.S. LLRW 
programs to comparable international programs. I am happy to note that 
the draft report does not identify any new programmatic vulnerabilities 
or challenges within our domestic LLRW programs. 

We do not believe there are significant vulnerabilities in the DOE's 
LLW management programs or the commercial LLW program of which Congress 
has not yet been informed. Also, DOE is very aware of international 
waste management practices through our participation in numerous 
international forums, including International Atomic Energy Agency 
activities and the Joint Convention on the Safety of Spent Fuel 
Management and on the Safety of Radioactive Waste Management. Due to 
the extent and quality of our programs, the U.S. is respected as a 
world leader in radioactive waste management. We will continue to 
actively monitor international policies and practices, as well as 
domestic commercial waste management programs. 

The draft report recommends that DOE and the Nuclear Regulatory 
Commission (NRC) evaluate and report to Congress within one year on the 
usefulness of adopting the LLRW approaches used in other countries and 
the steps and authorities necessary for their implementation. DOE 
accepts the recommendation for continued evaluation of these 
approaches, but does not agree that a report to Congress is necessary 
at this time. 

The draft report also recommends DOE and NRC report on the potential 
cost to develop a national radioactive waste management plan containing 
strategies for the interim storage and disposal of all types of 
radioactive waste and the steps and authority necessary to develop such 
a plan. We are concerned with this recommendation, as it goes beyond 
the scope and focus of this LLRW-related study. Further, the survey on 
which the report findings are based only addressed LLRW streams, not 
transuranic and high-level waste streams. DOE strongly believes that 
the current U.S. statutory framework adequately defines the strategies 
for management of the nation's radioactive waste streams. It is correct 
that the regulatory authorities and responsibilities for the nation's 
various radioactive waste streams involve numerous agencies and 
entities. We acknowledge that a single document synthesizing these 
efforts would facilitate understanding of these complex programs. 
However, we are concerned that development of such a document would 
provide limited utility to the actual implementation of these 
strategies, yet would require diversion of significant resources from 
actual waste management efforts. We note that the U.S. Second National 
Report to the Joint Convention, which was developed in 2005, provides a 
summary of the existing national waste management strategies, issues 
and progress. 

As we continue to evaluate the international approaches summarized in 
this draft report, we remain ready to brief Congress on the status of 
our radioactive waste management efforts if such a briefing is 
requested. 

The enclosure provides our specific comments on the draft report. If 
you have any questions, please contact Mr. Frank Marcinowski, Deputy 
Assistant Secretary for Regulatory Compliance, at (202) 586-0370. 

Sincerely,  

Signed by:  

James A. Rispoli: 
Assistant Secretary for Environmental Management:  

Enclosure:  

(See section entitled "Agency Comments and Our Evaluation" for GAO's 
response to this letter)  

[End of letter]  

Enclosure:  

Department of Energy Comments on Draft GAO Report (GAO-07-221) Low-
Level Radioactive Waste Management: Approaches Used by Foreign 
Countries Would Provide Useful Lessons for Managing U.S. Radioactive 
Waste:  

These specific comments are additions to those general reactions 
provided in the response memorandum from James Rispoli, Assistant 
Secretary for Environmental Management 

Title: The report concludes, without evidence, that foreign approaches 
would be useful to the United States (U.S.), as noted in the title of 
the document. This is inconsistent with the recommendation that the 
agencies evaluate and report on whether the approaches would be useful. 
We recommend the title be revised to "Approaches Used by Foreign 
Countries May Provide Useful Lessons for Managing U.S. Radioactive 
Waste." (See comment 1)  

General: The report implies that just because nations have different 
waste management practices that these practices would be beneficial to 
the U.S. In fact, many of the approaches cited in this report, as well 
as other international practices, have been considered previously by 
the Department. The report does not acknowledge these previous – even 
recent – evaluations, nor the reasons why these approaches were not 
implemented. (See comment 2)  

General: The report does not provide justification for the conclusion 
that a national waste management plan is needed for all waste types. 
The report also fails to recognize the existing legal framework that 
defines the nation's strategies for the various waste management 
streams. The report simply cites potential disposal shortage for higher-
activity LLRW in 2008 and other items related to LLRW as evidence that 
a national strategy is needed. There is no basis for the extrapolation 
from commercial LLRW to all radioactive waste streams. Further, the 
scope of the review and survey was limited to LLRW. (See comment 3)  

General: In one instance, the report acknowledges that a national 
management plan would provide improved information access to those 
interested in radioactive waste (page 40). This benefit differs 
significantly from the report conclusions that a national management 
plan is needed to define strategy for management of the wastes. (See 
comment 4)  

General: The report would benefit from additional context on the U.S.'s 
nuclear programs relative to those of the international respondents. 
There is no attempt to identify or explain the differences between the 
U.S. and other nations. Most of the respondents have small nuclear 
programs. For example, the U.S. has 104 of the 435 nuclear power 
reactors cited on page 11, while the other 30 countries share 331. Some 
of the countries surveyed do not have nuclear power plants at all. 
Thousands of licensees exist in the U.S. under dozens of regulatory 
agencies, most of which are state and not federal, e.g., all the 
commercial U.S. LLRW disposal facilities are licensed by states. (See 
comment 5)  

General: The draft report does not take into account that the Low-Level 
Radioactive Waste Policy Act provides the national strategy for 
commercial LLW disposal. The authority and responsibility falls on the 
States and regional compacts. Development of a national LLRW management 
plan by a federal agency does not appear reasonable while 
implementation of the strategy is the responsibility of the states and 
regional compacts. (See comment 6)  

General: Also, the report fails to explain that the disposition of 
commercial LLRW is provided within a market driven industry, consistent 
with existing laws. This market influence contributes to the way waste 
streams are managed, and it would be directly impacted by adoption of 
some of the recommended approaches. The report fails to acknowledge 
this or the fact that the market factors of the U.S. commercial LLRW 
program differ vastly from most of the international respondents. (See 
comment 7)  

General: In several instances the report appears to incorrectly 
extrapolate conclusions that apply to disused sealed sources to all 
LLRW. There are instances where "higher-activity LLRW" appears to be 
equated with disused sealed sources, e.g., titles of sections versus 
text discussion on page 19. Further, it is imprecise to assume that all 
disused sealed sources are, by definition, managed as wastes. It is 
possible a disused source could be redeployed to beneficial reuse. (See 
comment 8)  

General: The report references the recent Interagency "Radiation Source 
Protection and Security Task Force Report." In several cases, the 
findings and recommendation of that report are taken out of context. 
Also, this draft GAO report fails to explain that the Task Force Report 
was required by the Energy Policy Act of 2005 and has been provided to 
Congress for their review. It also fails to explain that subsequent 
Task Force Report updates are required by the Energy Policy Act of 
2005, and that an interagency implementation plan has already been 
developed. (see comment 9)  

General: The report discusses storage of LLRW in many instances, yet 
several important contextual facts are not provided. It should be noted 
that not all storage, even at generator sites, is unsafe. It should be 
noted that, commercial generators are responsible for storage of 
greater than class C wastes that cannot yet be disposed. Finally, the 
commercial market has provided for off-site storage at commercial 
facilities, for example Waste Control Specialists. (See comment 10) 

[End of enclosure]  

DOE provided 10 specific comments about our report in accompanying its 
draft letter. Our response to each comment follows.  

1. We have revised the title of our report.  

2. Our report discussed previous actions by the agencies to respond to 
our recommendations and to evaluate some of the LLRW management 
approaches that are similar to those identified as in use in other 
countries. This discussion is in appendix I of our report. In our view, 
the fact that some of these LLRW management approaches have already 
been evaluated by NRC and DOE does not lessen the need for their 
inclusion in a report to the Congress.  

3. We revised the draft recommendation to more clearly reflect the need 
to evaluate and report on the usefulness of developing a national 
radioactive waste management plan and to conduct further analysis if 
deemed appropriate. Our views on the potential usefulness of such a 
plan are provided on pages 37-38 of this report.  

4. We revised our second recommendation to clarify this point.  

5. The purpose of our report was to identify the extent to which other 
countries use approaches to address four areas of U.S. LLRW management 
that we identified in previous reports as having some limitations. We 
did not recommend adopting any of the approaches identified as in use 
on other countries, only to evaluate and report to the Congress on 
their usefulness to improve management of this waste in the United 
States.  

6. In our view, assigning responsibility for waste disposal in the LLRW 
Policy Act is not synonymous with establishing a national radioactive 
waste management plan. We revised our recommendation to clarify that 
NRC and DOE need to evaluate and report on the usefulness of developing 
such a plan. We did not suggest how the agencies should conduct this 
evaluation or which entities should participate in the evaluation 
process.  

7. We did not attempt to provide a detailed discussion of how market 
forces operate in the United States in the disposition of commercial 
LLRW in our report. This level of discussion was not an objective of 
our report. Our previous reports have described the conditions 
surrounding the management of LLRW in the United States.  

8. Our report associates disused sealed sources with higher-activity 
LLRW, as this is, for the most part, international practice. Our report 
further states that a holder of a disused source can return it to a 
supplier, place it in a recognized installation (central storage or 
disposal facility), or transfer it to another authorized holder when it 
is no longer wanted.  

9. We cannot comment on this DOE observation, as the department 
provided no specific information to substantiate this claim. We believe 
that our characterization of the findings and recommendations of the 
task force report are accurate. Moreover, we referenced a previous 2005 
GAO report that provides more information on the origin and purpose of 
the radiation source protection and security task force. Our intent in 
referring to the task force and other recent reports was to point out 
that these reports suggested and recommended approaches that were 
similar to what other countries indicated in our survey that they use.  

10. We agree with DOE that not all storage of radioactive waste is 
unsafe. Our report referred to international experts that claim that 
the storage of disused sealed radiological sources at user sites poses 
a greater risk of being lost from regulatory control.  

[End of GAO comments]  

[End of section]  

Appendix VIII: GAO Contact and Staff Acknowledgments:  

GAO Contact:  

Gene Aloise (202) 512-3841 or at aloisee@gao.gov.  

Staff Acknowledgments:  

In addition to the person named above, Daniel Feehan, Assistant 
Director, and Kevin Bray, John Delicath, Doreen Feldman, Bart Fischer, 
Peter Grana, Susan Iott, Erin Lanier, Thomas Laetz, and Amanda Miller 
made key contributions to this report.  

[End of section]  

Related GAO Products:  

Management of LLRW:  

Low-Level Radioactive Waste: Future Waste Volumes and Disposal Options 
Are Uncertain. GAO-04-1097T. Washington, D.C.: September 30, 2004.  

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 10, 2004.  

Low-Level Radioactive Wastes: States Are Not Developing Disposal 
Facilities. GAO/RCED-99-238. Washington, D.C.: September 17, 1999.  

Nuclear Regulation: Better Oversight Needed to Ensure Accumulation of 
Funds to Decommission Nuclear Power Plants. GAO/RCED-99-75. Washington, 
D.C.: May 3, 1999.  

Radioactive Waste: Answers to Questions Related to the Proposed Ward 
Valley Low-Level Radioactive Waste Disposal Facility. GAO/RCED-98-40R. 
Washington, D.C.: May 22, 1998.  

Radioactive Waste: Interior’s Continuing Review of the Proposed 
Transfer of the Ward Valley Waste Site. GAO/RCED-97-184. Washington, 
D.C.: July 15, 1997.  

Radioactive Waste: Status of Commercial Low-Level Waste Facilities. 
GAO/RCED-95-67. Washington, D.C.: May 5, 1995.  

Radioactive Waste: EPA Standards Delayed by Low Priority and 
Coordination Problems. GAO/RCED-93-126. Washington, D.C.: June 3, 1993.  

Nuclear Waste: Connecticut’s First Site Selection Process for a 
Disposal Facility. GAO/RCED-93-81. Washington, D.C.: April 5, 1993.  

Nebraska Low-Level Waste. GAO/RCED-93-47R. Washington, D.C.: October 
14, 1992.  

Nuclear Waste: New York’s Adherence to Site Selection Procedures Is 
Unclear. GAO/RCED-92-172. Washington, D.C.: August 11, 1992.  

Connecticut Low-Level Waste. GAO/RCED-92-137R. Washington, D.C.: March 
17, 1992.  

Nuclear Waste: Slow Progress Developing Low-Level Radioactive Waste 
Disposal Facilities. GAO/RCED-92-61. Washington, D.C.: January 10, 
1992.  

Nuclear Waste: Extensive Process to Site Low-Level Waste Disposal 
Facility in Nebraska. GAO/RCED-91-149. Washington, D.C.: July 5, 1991.  

Regional Low-Level Radioactive Waste Disposal Sites—Progress Being 
Made, But New Sites Will Probably Not Be Ready by 1986. GAO/RCED-83-48. 
Washington, D.C.: April 11, 1983.  

Hazards of Past Low-Level Radioactive Waste Ocean Dumping Have Been 
Overemphasized. GAO/EMD-82-9. Washington, D.C.: October 21, 1981.  

Existing Nuclear Sites Can Be Used for New Powerplants and Nuclear 
Waste Storage. GAO/EMD-80-67. Washington, D.C.: April 1, 1980.  

The Problem of Disposing of Nuclear Low-Level Waste: Where Do We Go 
From Here? GAO/EMD-80-68. Washington, D.C.: March 31, 1980.  

Legal Authority of a State Governor to Impose Limitations on the Use of 
a Licensed, Privately Owned, Low-Level Nuclear Waste Burial Facility. 
GAO-B-194786. Washington, D.C.: June 21, 1979.  

The Nation’s Nuclear Waste—Proposals for Organization and Siting. 
GAO/EMD-79-77. Washington, D.C.: June 21, 1979.  

Need for Greater Regulatory Oversight of Commercial Low-Level 
Radioactive Waste. GAO/EMD-78-101, Washington, D.C.: August 16, 1978.  

Major Unresolved Issues Preventing a Timely Resolution to Radioactive 
Waste Disposal. GAO/EMD-78-94. Washington, D.C.: July 13, 1978.  

Nuclear Energy’s Dilemma: Disposing of Hazardous Radioactive Waste 
Safely. GAO-103414. Washington, D.C.: September 12, 1977.  

Nuclear Energy’s Dilemma: Disposing of Hazardous Radioactive Waste 
Safely. GAO/EMD-77-41. Washington, D.C.: September 9, 1977.  

Institutional and Jurisdictional Issues in Nuclear Waste Management. 
GAO-102168. Washington, D.C.: May 20, 1977. 

Improvements Needed in the Land Disposal of Radioactive Wastes—A 
Problem of Centuries. GAO/RED-76-54. Washington, D.C.: January 12, 
1976.  

Management of Sealed Radiological Sources:  

Border Security: Investigations Successfully Transported Radioactive 
Sources Across Our Nation’s Borders at Selected Locations. GAO-06-545R. 
Washington, D.C.: March 28, 2006.  

Nuclear Security: DOE Needs Better Information to Guide Its Expanded 
Recovery of Sealed Radiological Sources. GAO-05-967. Washington, D.C.: 
September 22, 2005.  

Nuclear Security: Federal and State Action Needed to Improve Security 
of Sealed Radioactive Sources. GAO-03-804. Washington, D.C.: August 6, 
2003.  

Nuclear Nonproliferation: U.S. and International Assistance Efforts to 
Control Sealed Radioactive Sources Need Strengthening. GAO-03-638. 
Washington, D.C.: May 16, 2003.  

Nuclear Nonproliferation: DOE Actions Needed to Ensure Continued 
Recovery of Unwanted Sealed Radioactive Sources. GAO-03-483. 
Washington, D.C.: April 15, 2003.  

[End of section]  

Footnotes:  

[1] LLRW is defined by exclusion; that is, LLRW is defined in statute 
as radioactive waste that is not high-level radioactive waste, spent 
nuclear fuel, or certain byproduct materials, such as tailings or waste 
produced by the extraction or concentration of uranium or thorium from 
any ore processed primarily for its source material content 42 U.S.C. § 
2021b(9).  

[2] The states are responsible for providing near surface disposal of 
class A, B and C wastes as defined in 10 C.F.R. § 61.55, with the 
exception of three types of federal waste—DOE waste, Navy waste from 
decommissioning, and waste from nuclear weapons program research, 
development, testing, and production. DOE is responsible for providing 
disposal for a fourth category of LLRW, known as greater-than-class C 
waste, and the disposal of waste that it owns and generates.  

[3] NRC provides assistance to states expressing interest in 
establishing programs to assume NRC regulatory authority under the 
Atomic Energy Act of 1954, as amended. Section 274 of the act provides 
a statutory basis under which NRC relinquishes to Agreement States 
portions of its regulatory authority to license and regulate byproduct 
materials (radioisotopes); source materials (uranium and thorium); and 
certain quantities of special nuclear materials. The mechanism for the 
transfer of NRC authority to a state is an agreement signed by the 
governor of the state and the NRC chairman, in accordance with section 
274(b) of the act. There are presently 34 Agreement States.  

[4] GAO, Nuclear Security: Federal and State Action Needed to Improve 
Security of Sealed Radiological Sources, GAO-03-804 (Washington, D.C.: 
Aug. 6, 2003); 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); GAO, Nuclear 
Security: DOE Needs Better Information to Guide Its Expanded Recovery 
of Sealed Radiological Sources, GAO-05-976 (Washington, D.C.: Sept. 22, 
2005); and GAO, Low-Level Radioactive Waste: Future Waste Volumes and 
Disposal Options Are Uncertain, GAO-04-1097T (Washington, D.C.: Sept. 
30, 2004).  

[5] An orphan source is a source that is not under regulatory control, 
either because it has never been under regulatory control, or because 
it has been abandoned, lost, misplaced, stolen, or transferred without 
proper authorization.  

[6] Radiation Source Protection and Security Task Force, The Radiation 
Source Protection and Security Task Force Report (Washington, D.C.: 
Aug. 15, 2006); Advisory Committee on Nuclear Waste, ACNW White Paper: 
History and Framework of Commercial Low-Level Radioactive Waste 
Management in the U.S. (Washington, D.C.: Dec. 30, 2005); and National 
Research Council, Improving the Regulation and Management of Low-
Activity Radioactive Wastes (Washington, D.C.: 2006). The current 
version of the advisory committee’s report is on the NRC’s Web sites 
under NUREG-1853.  

[7] IAEA was established within the United Nations to promote safe, 
secure, and peaceful nuclear technologies. NEA is a specialized agency 
within the Organization of Economic Cooperation and Development, an 
intergovernmental organization of industrialized countries.  

[8] The 18 countries that responded to the survey included Australia, 
Belgium, Canada, Denmark, Finland, France, Germany, Hungary, Italy, 
Japan, Mexico, Netherlands, Norway, Slovak Republic, Spain, Sweden, 
Switzerland, and United Kingdom. The two countries not responding to 
the survey were the Czech Republic and South Korea.  

[9] IAEA, Radioactive Waste Management: Status and Trends-Issue#2 
(Vienna, Austria: Sept. 2002) 11.  

[10] IAEA, Code of Conduct on the Safety and Security of Radioactive 
Sources (Vienna, Austria: Jan. 2004).  

[11] IAEA, Management of Waste from the Use of Radioactive Material in 
Medicine, Industry, Agriculture, Research and Education, Safety Guide 
No. WS-G-2.7 (Vienna, Austria: 2005).  

[12] 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); and GAO, 
Nuclear Security: DOE Needs Better Information to Guide Its Expanded 
Recovery of Sealed Radiological Sources, GAO-05-967 (Washington, D.C.: 
Sept. 22, 2005).  

[13] GAO, Nuclear Security: Federal and State Action Needed to Improve 
Security of Sealed Radiological Sources, GAO-03-804 (Washington, D.C.: 
Aug. 6, 2003); 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); GAO, Nuclear 
Security: DOE Needs Better Information to Guide Its Expanded Recovery 
of Sealed Radiological Sources, GAO-05-976 (Washington, D.C.: Sept. 22, 
2005); and GAO, Low-Level Radioactive Waste: Future Waste Volumes and 
Disposal Options Are Uncertain, GAO-04-1097T (Washington, D.C.: Sept. 
30, 2004).  

[14] The Energy Policy Act of 2005 established an interagency task 
force under the leadership of NRC to evaluate and provide 
recommendations to the President and Congress relating to the security 
of radiation sources in the United States from terrorist threats, 
including acts of sabotage, theft, or use of a radiation sources in a 
radiological dispersal device.  

[15] National Source Tracking of Sealed Sources: Final Rule, 71 Fed. 
Reg. 65,686 (Nov. 8, 2006).  

[16] NRC notes that other measures for controlling the hazard from 
these materials could be implemented at the disposal facilities, for 
example at disposal sites under the regulatory control of the 
Environmental Protection Agency that can accept hazardous materials.  

[17] The Radioactive Waste Management Committee is an international 
committee made up of senior representatives from regulatory 
authorities, radioactive waste management agencies policy-making 
bodies, and research and development institutions. The committee is 
under the NEA, which is a specialized agency within the Organization 
for Economic Cooperation and Development, an intergovernmental 
organization of industrialized countries.  

[18] Radiation Source Protection and Security Task Force, The Radiation 
Source Protection and Security Task Force Report (Washington, D.C.: 
Aug. 15, 2006); National Research Council, Improving the Regulation and 
Management of Low-Activity Radioactive Wastes (Washington, D.C.: 2006); 
and Advisory Committee on Nuclear Waste, ACNW White Paper: History and 
Framework of Commercial Low-Level Radioactive Waste Management in the 
U.S. (Washington, D.C.: Dec. 30, 2005).  

[19] As a contracting member of the International Atomic Energy Agency 
Joint Convention, the United States is required to submit a national 
report that must include the following: radioactive waste that is being 
held in storage at radioactive waste management and nuclear fuel cycle 
facilities, radioactive waste that has been disposed of, and 
radioactive waste that has resulted from past practices.  

[20] “11(e)(2)” refers to “tailings or wastes produced by the 
extraction or concentration of uranium or thorium from any ore 
processed primarily for its source material content,” as described in 
section 11(e)(2) of the Atomic Energy Act of 1954 that defines 
“byproduct” wastes. 42 U.S.C. § 2014(e)(2). These wastes arise in the 
recovery of uranium and thorium from nuclear energy applications.  

[End of section]  

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