Nuclear Security: DOE Needs Better Information to Guide Its Expanded Recovery of Sealed Radiological Sources

We recommended that DOE and NRC, in collaboration with a participating task force, evalute and report on the cost implications of a potential expansion of DOE's recovery and disposal of non-GTCC waste from sealed radiological sources. In a December 20, 2005 correspondence to us, DOE indicated its concurrence with this recommendation and that it had completed actions to respond to it. DOE indicated that NNSA had evaluated the cost implications of expanding its radiological threat reduction activities to recover and dispose of unwanted non-GTCC sealed sources. As a result, NNSA expanded its collection activities to address these sources because they posed a risk if used in a radiological dispersal device. In addition, NNSA indicated that it's budget allows for implementation of this activity. In a May 12, 2009 correspondence to us, NNSA stated that it's budget for collection of disused sealed sources had increased substantially since the 2005 GAO report, ranging from about $8 million in FY 2005 to about $16 million in FY 2009. During this time, NNSA's efforts to recover unwanted GTCC sealed sources expanded alongside efforts to recover the non-GTCC sealed sources. NNSA also determined that the GTCC waste threshold (DOE is responsible for providind disposal for all GTCC waste) should not be a constraining factor for determining what sealed sources to recover. However, NNSA informed us that because recovery contracts and task orders do not distinguish between GTCC and non-GTCC sealed sources for recovery purposes, it would be difficult for NNSA to engage in a cost analysis that would distinguish dollars spent on GTCC source recovery from those spent on non-GTCC source recovery. Nevertheless, NNSA estimated that the cost of collecting unwanted non-GTCC sealed sources has been $400,000 per year since FY 2007. We therefore conclude that DOE has evaluated and reported on the cost implications of a potential expansion of its recovery and disposal of non-GTCC waste from unwanted sealed sources.

We recommended that DOE and NRC, in collaboration with a participating task force, evaluate and report on the cost implications of a potential expansion of DOE's recovery and disposal of unwanted non-GTCC sealed sources. DOE concurred with the recommendation in a December 20, 2005 correspondence to us and completed actions to close this recommendation. No action was needed by NRC.

We recommended that DOE and NRC, in collaboration with a participating task force, evaluate and report on options for DOE to recoup recovery and disposal costs from licensees that may have no commercial waste disposal option. In a December 20, 2005 correspondence to us, DOE stated that it did not concur with this recommendation because charging fees or recouping costs from licensees might inhibit them from registering their sources, leaving these sources at risk. However, in a May 12, 2009 correspondence to us, NNSA stated that it was working to minimize costs. For example, NNSA stated that it was working with manufacturers who charge licensees a fee ($500-$1,000) for receipt and disassembly of devices. According to NNSA, this effort saves the agency substantial costs by greatly minimizing the number of sites to which it must travel and labor for device dissembly. NNSA is also working on making packaging commercially available so that these items can be purchased by larger licensees. Finally, NNSA is working with the Conference of Radiation Control Program Directors to identify cost-sharing arrangements with licensees whose sources are recovered under the Source Collection and Threat Reduction project in states with commercial disposal. However, 36 states presently do not have such access to disposal for these unwanted sealed sources. We therefore consider that the actions taken by DOE to evaluate this issue and to reduce costs meet the intent of this recommendation.

We recommended that DOE and NRC, in collaboration with a participating task force, evaluate and report on options for DOE to recoup the costs of collecting and disposing of unwanted sealed sources from licensees that may have no commercial waste disposal options. The NRC-led task force evaluated financial assurance requirements for Category 1 and 2 radioactive sources to assure that funding is available for final disposition of the sources. NRC has also formed a Task Force Working Group to provide recommendations on sufficiency of financial assurance. Currently, NRC regulations require funds be set aside for decommissioning. The working group is looking into whether these funds could be assessed for recovery efforts not associated with decommissioning. The group is also considering broadening existing financial assurance thresholds, assessing source-specific surcharges for disposal, and assessing universal disposal surcharges on all licensees. We therefore conclude that NRC has evaluated and reported on this issue to meet the intent of the recommendation.

We recommended that DOE and NRC, in collaboration with a participating task force, evaluate and report on the feasibility of disposing of non-GTCC waste at DOE sites. In August 2006, the NRC-led task force evaluated and reported on a number of options to address the lack of disposal capability for unwanted non-GTCC sealed sources. These options included the use of DOE facilities. The task force report did not advocate a particular option or options, but recommended that the issue be evaluated further. The Department of Homeland Security has formed a Disused Source Focus Group, including NRC and DOE, to further evaluate this issue. The focus group is to investigate and recommend immediate and long-term options for both GTCC and non-GTCC sealed sources. We therefore conclude that NRC has evaluated and reported on this issue to satisfy the intent of the recommendation.

We recommended that DOE and NRC, in collaboration with a participating task force, evaluate and report on the feasibility of disposing of unwanted sealed sources at DOE sites. In a December 20, 2005 correspondence to us, DOE concurred with this recommendation and indicated that it had completed actions to respond to it. According to DOE, while current policy and statutory responsibilities do not provide for the permanent disposal of this waste at DOE sites, when warranted, NNSA collects, stores, and disposes of unwanted non-GTCC sealed sources. The NNSA program has also performed a number of recoveries of non-GTCC sources where these sources were sent to commercial disposal. If commercial disposal is not available to meet long-term program needs, DOE stated that it would revisit policy and statutory issues regarding permanent disposal at its facilities. In a May 12, 2009 correspondence to us, NNSA indicated that the NRC-led task force had reported on a number of options to address the lack of disposal capability for unwanted non-GTCC sealed sources, including options to use DOE facilities and efforts to promote access to the two existing commercial facilities. The task force report did not advocate a particular option or options, but recommended that the issue be evaluated further. This further evaluation has been taken up by the Department of Homeland Security's Disused Source Focus Group, comprised of DOE, NRC, other federal agencies, state agencies, and the private sector. This Focus Group is charged with promoting disposal solutions for unwanted sealed sources. We therefore conclude that DOE has sufficiently evaluated and reported on this issue.

We recommended that DOE and NRC, in collaboration with a participating task force, evaluate and report on how a national source tracking system could be designed and implemented to improve DOE's ability to identify and track sealed sources that may need DOE recovery and disposal. In a December 20, 2005 correspondence to us, DOE stated that it concurred with this recommendation and that actions were taken to respond to it. DOE informed us that the NRC-led task force had evaluated ways to track and dispose of disused sealed sources. In addition, DOE informed us that it has a secure web-based system for licensees to register their excess and unwanted sealed sources and to provide detailed information about these sources. DOE wrote that this system has been used successfully for several years and is an integrated tool used for many aspects of the program. In a May 12, 2009 correspondence to us, DOE reported that NRC had developed and implemented a National Source Tracking System for certain sealed sources. Moreover, in April 2008, NRC published a proposed rule to expand the sources in this tracking system. DOE cooperated in this discussion. We therefore conclude that DOE has sufficiently evaluated and reported on this issue to meet our recommendation.