United States Government Accountability Office

GAO Report to the Chairman and Ranking 

Minority Member, Committee on 

Energy and Natural Resources, U.S. 

Senate 

LOW-LEVEL 

RADIOACTIVE 

WASTE 

MANAGEMENT 

Approaches Used by 

Foreign Countries 

May Provide Useful 

Lessons for Managing 

U.S. Radioactive 

Waste 

March 2007 

 

GAO-07-221 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 2007

LOW-LEVEL RADIOACTIVE WASTE 

MANAGEMENT 

Approaches Used by Foreign Countries 

May Provide Useful Lessons for 

Managing U.S. Radioactive Waste 

Highlights of GAO-07-221, a report to the 

Chairman and Ranking Minority Member, 

Committee on Energy and Natural 

Resources, U.S. Senate 

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 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. 

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 higheractivity 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. 

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).

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. 
Contents 

Letter 1

Results in Brief 6

Background 9

Comprehensive National LLRW Inventory Databases Are Widely

Used to Track and Manage LLRW 11 

Methods for Promptly Removing Higher-Activity LLRW from Waste 

Generator Sites Are Widely Used to Reduce Safety and Security 

Risks 17

Central Storage and Alternative Disposal Options Are Widely Used 

to Facilitate Management of LLRW 22 

Financial Assurance Requirements and Other Approaches Are 

Used by Most Countries to Reduce Government LLRW Recovery 

Costs 30

National Radioactive Waste Management Plans Are Considered 

Important for Managing LLRW 33 

Conclusions 36

Recommendations 38

Agency Comments and Our Evaluation 38 

Appendix I Recent GAO Findings and Agency Actions on 

LLRW Management 42 

Appendix II Scope and Methodology 47 

Appendix III Survey of LLRW Management Approaches

Response from United States 52 

Appendix IV Volume and Location of LLRW in the United States 68 

Appendix V Status of Class B and C Waste Disposal and 

Potential Effects of Reduced Access to South 

Carolina Disposal Facility 74 

Page i GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI Comments from the Nuclear Regulatory 

Commission and Our Response 83 

Appendix VII Comments from the Department of Energy 

and Our Response 94 

Appendix VIII GAO Contact and Staff Acknowledgments 100 

Related GAO Products 101 

Tables 

Table 1: IAEA Suggested Radioactive Waste Classification System 10 

Table 2: Listing of Domestic LLRW Stakeholder Group 

Respondents 50

Table 3: Total LLRW Disposed at the Three Operating Commercial 

LLRW Disposal Facilities as of 2005 69 

Table 4: Total Disposed LLRW at the Four Closed Commercial 

Disposal Facilities 70 

Table 5: Total LLRW Disposed at the Three Commercial LLRW 

Disposal Facilities during 2005 70 

Table 6: LLRW in Storage or Disposal at DOE Sites 71 

Table 7: Transuranic Waste Disposed of or in Storage Awaiting

Disposal at WIPP 72 

Table 8: Central Storage and Disposal of Disused Sealed 

Radiological Sources Recovered by DOE’s Off-Site Source 

Recovery Project 73 

Table 9: Class B and C Waste Type Groups 75 

Table 10: Total Class B and C Waste Disposed at Richland and 

Barnwell by Waste Type Group, 2001-2005 76 

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 77 

Table 12: Range of Class B and C Waste Disposed Annually at 

Richland and Barnwell by Generator Type, 2001-2005 79 

Page ii GAO-07-221 Foreign Radwaste Management Experiences
Table 13: Distribution of Class B and C Waste Disposed Annually at 

Richland and Barnwell by Generator Type, 2001-2005 80 

Table 14: Distribution of Non-Utility Class B and C Waste Disposed 

Annually at Richland and Barnwell by Generator Type, 

2001-2005 80

Table 15: Disposed Class B and C Waste at Richland and Barnwell 

by LLRW Compact, 2001-2005 81 

Table 16: Class B and C Waste Disposed at Barnwell from Atlantic, 

Northwest, and Rocky Mountain Generators, and Other 

Generators, 2001-2005 82 

Table 17: Number of Waste Generators That Disposed of Sealed

Radiological Sources at Richland and Barnwell Ranked by 

Compact, 2001-2005 82 

Figures 

Figure 1: Contents of National Radioactive Waste Inventory 

Databases 13

Figure 2: Management Approaches for National Radioactive Waste 

Inventory Databases 15 

Figure 3: Management Approaches for Tracking and Managing 

LLRW 16

Figure 4: Methods to Facilitate Prompt Removal of LLRW from 

Generator Sites 20 

Figure 5: LLRW Disposal Options and Management Responsibilities 24 

Figure 6: Central Storage Options for LLRW 25 

Figure 7: Disposal Options and Exemption Methods for Managing 

Very Low-Level Radioactive Waste 27 

Figure 8: Financial Approaches to Reduce Government Costs to 

Recover LLRW 31 

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 78 

Page iii GAO-07-221 Foreign Radwaste Management Experiences
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 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 

Page iv GAO-07-221 Foreign Radwaste Management Experiences
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 2005.1

 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.

 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). 

Page 1 GAO-07-221 Foreign Radwaste Management Experiences
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.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.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 

 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. 

Page 2 GAO-07-221 Foreign Radwaste Management Experiences
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.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.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 

 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. 

Page 3 GAO-07-221 Foreign Radwaste Management Experiences
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.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.

 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. 

Page 4 GAO-07-221 Foreign Radwaste Management Experiences
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),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 (loweractivity 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.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 

 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. 

Page 5 GAO-07-221 Foreign Radwaste Management Experiences
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. 

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. 

Results in Brief 

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

Page 6 GAO-07-221 Foreign Radwaste Management Experiences
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 loweractivity 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. 

Page 7 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Page 8 GAO-07-221 Foreign Radwaste Management Experiences
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 nonutility 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.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.

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. 

Background 

 9

IAEA, Radioactive Waste Management: Status and Trends-Issue#2 (Vienna, Austria:

Sept. 2002) 11. 

10IAEA, Code of Conduct on the Safety and Security of Radioactive Sources (Vienna, 

Austria: Jan. 2004). 

Page 9 GAO-07-221 Foreign Radwaste Management Experiences
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 intermediatelevel 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 (higheractivity 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 Typical characteristics Disposal options

1. Exempt waste Activity levels at or below 

clearance levels, which are 

based on annual dose less 

than 0.01 mSva

No radiological restrictions 

2. Low- and intermediatelevel waste 

Activity levels above 

clearance levels and thermal 

power below about 2 kW/m3b

 2.1 Short-lived waste Restricted long-lived 

radionuclide concentrations 

Near-surface or geological 

disposal facility

 2.2 Long-lived waste Long-lived radionuclide

concentrations exceeding 

restricted short-lived waste 

Geological disposal facility 

3. High-level waste Thermal power above about 

2 kW/m3

 and long-lived 

radionuclide concentrations 

exceeding limitations for 

short-lived waste 

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. 

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) 

Page 10 GAO-07-221 Foreign Radwaste Management Experiences
exempt waste, (2) very short-lived waste, (3) very low-level waste, (4) lowlevel 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.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. 

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. 

Comprehensive 

National LLRW 

Inventory Databases 

Are Widely Used to 

Track and Manage 

LLRW 

 11IAEA, 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). 

Page 11 GAO-07-221 Foreign Radwaste Management Experiences
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 longlived 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. 

Most Countries Have 

Comprehensive National 

Radioactive Waste 

Inventory Databases 

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. 

Page 12 GAO-07-221 Foreign Radwaste Management Experiences
Figure 1: Contents of National Radioactive Waste Inventory Databases 

NR

NA

NA

NA

17

14

14

NA

NR

NA 14

NA

14

9

NR

17

NR 10

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

Hungary

Australia

France

NA 17

Maintains a national radioactive waste inventory database

Very low-level radioactive waste is included in the national radioactive 

waste inventory database

Short-lived low- and intermediate-level waste, and long-lived 

intermediate-level waste are included in the national radioactive waste 

inventory database

Long-lived low-level waste (including naturally occurring radioactive 

material) is included in the national radioactive waste inventory 

database

National radioactive waste inventory database captures waste stored at 

generator sites

Maintains a national source registry containing IAEA categories 1, 2, 

and 3 radiological sources

Maintains a national source registry containing IAEA categories 1-5 

radiological sources

High-level radioactive waste are included in the national radioactive 

waste inventory database

All types of radioactive waste generators in the country are included in 

the national radioactive waste inventory database

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Source: GAO survey of foreign countries, 2006.

Legend: ● – Yes, o – No; NR – No response; NA – Not applicable 

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.

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 

Page 13 GAO-07-221 Foreign Radwaste Management Experiences
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 upperbound 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. 

Page 14 GAO-07-221 Foreign Radwaste Management Experiences
Figure 2: Management Approaches for National Radioactive Waste Inventory Databases 

NR

NR

NR NR NR NR NR NR

NR NR

NR

2

12

15

NA

17

15

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

Belgium

Spain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

Italy

DenmarkNorway

Slovak Republic

Hungary

Australia

France

NA NA NA NA NA NA 10

National nuclear regulatory authority or national waste management 

organization is responsible for managing the national radioactive waste 

inventory database

Manager of national radioactive waste inventory database uses at least 

one control to verify the completeness and accuracy of information 

submitted by waste generators

Waste generators submit data to manager of national radioactive waste 

inventory database through a secure website

Waste generators submit data to manager of national radioactive waste 

inventory database through e-mail, mail, fax, or by phone

Waste generators are required to submit data to manager of national 

radioactive waste inventory database once a year or more frequently

Member of the European Union and has implemented Council Directive 

2003/122EURATOM regarding the control of high-activity sealed 

radioactive sources and orphan sources

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Source: GAO survey of foreign countries, 2006.

Legend: ● – Yes, o – No; NR – No response; NA – Not applicable 

Note: Denmark responded to questions about the management 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. 

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. 

Page 15 GAO-07-221 Foreign Radwaste Management Experiences
Figure 3: Management Approaches for Tracking and Managing LLRW

13

16

16

NR

NR NR NR

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

Hungary

Australia

France

Regulator keeps a record of the locations and status of use of sources, 

including disused sources

National radioactive waste inventory database is used to make 

projections of future waste volumes for capacity planning of central 

waste storage and disposal facilities

Radioactive waste inventory information is publicized to help obtain 

community acceptance of LLRW central storage and disposal facilities

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Source: GAO survey of foreign countries, 2006.

Legend: ● – Yes, o – No; NR – No response 

Note: Denmark responded to questions about the management 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. 

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 costeffectiveness 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 

Page 16 GAO-07-221 Foreign Radwaste Management Experiences
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. 

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 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. 

Methods for Promptly 

Removing HigherActivity LLRW from 

Waste Generator Sites 

Are Widely Used to 

Reduce Safety and 

Security Risks 

Most Countries Encourage 

and Enforce the Prompt 

Removal of Higher-Activity 

LLRW from Generator 

Sites 

Page 17 GAO-07-221 Foreign Radwaste Management Experiences
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 Use a 

Variety of Approaches to 

Facilitate the Removal of 

Higher-Activity LLRW from 

Generator Sites 

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 higheractivity 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 

Page 18 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Page 19 GAO-07-221 Foreign Radwaste Management Experiences
Figure 4: Methods to Facilitate Prompt Removal of LLRW from Generator Sites 

NR NR NR

NR

NR

NR

NR

14

4

9

10

11

3

NR

NR

NR

NR

NR NR NR

NR

NR

NR NR

NR

NR

NR

7

NR NR NR NR NA NA 4

NR

NR NR NA NA NR

NR

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

HungaryAustraliaFrance

15

On-site storage time limits for LLRW are set for non-nuclear power plant 

entities

On-site storage time limits for LLRW are set only when a disposal option 

is available

Regulator encourages removal of disused radiological sources from 

user sites

Regulator enforces prompt removal of disused radiological sources from 

user sites

Maintains an orphan radiological source recovery program

Government entity is made responsible for orphan radiological source 

recovery program

An organization other than the government is responsible for recovering 

orphan radiological sources

Users must inform regulators if holding disused sources 9

14 Regulator periodically inspects the operational storage of disused 

radiological sources

Time limits are placed on length of time a radiological source can be 

used

Requirement that disused radiological sources be returned to a supplier 

or central waste storage

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Source: GAO survey of foreign countries, 2006.

Legend: ● – Yes, o – No; NR – No response; NA – Not applicable

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. 

Page 20 GAO-07-221 Foreign Radwaste Management Experiences
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 higheractivity LLRW from waste generator sites. Eleven of 27 representatives 

supported imposing time limits on storing higher-activity LLRW at nonutility 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. 

Domestic Experts Support 

Need to Evaluate Methods 

for Facilitating the 

Removal of Higher-Activity 

LLRW 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. 

Page 21 GAO-07-221 Foreign Radwaste Management Experiences
Ten of the 18 countries we surveyed have disposal options for loweractivity 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 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. 

Central Storage and 

Alternative Disposal 

Options Are Widely

Used to Facilitate 

Management of LLRW 

About Half the Countries 

Make Disposal Options 

Available for Most LowerActivity LLRW

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 

Page 22 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Page 23 GAO-07-221 Foreign Radwaste Management Experiences
Figure 5: LLRW Disposal Options and Management Responsibilities

NR

NR

NR

NR

10

1

2

NR

9

8

6

NR NR

NR NR

NR NR

NR NR

NR NR NR

NR

0

10

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

Hungary

Australia

France

14

Disposal options are available for all LLRW

Disposal options are available for short-lived low- and intermediate-level 

radioactive waste

There are plans to build a LLRW disposal facility for short-lived low- and 

intermediate-level radioactive waste

Disposal options are available for long-lived low-level radioactive waste

A central organization (national nuclear regulatory authority or national 

waste management organization) is responsible for providing a waste 

disposal facility

A central organization (national nuclear regulatory authority or national 

waste management organization) is responsible for operating a waste 

disposal facility

A nuclear utility organization is responsible for providing a waste 

disposal facility

6 A nuclear utility organization is responsible for operating a waste 

disposal facility

4 A commercial waste management company is responsible for operating 

a waste disposal facility NR NR NR

NA NA

NR NR NR

NA NA

NA NA NR

9 Disposal fees are or planned to be determined by a national fee 

schedule based on type of radioactive waste

3 Waste generators negotiate disposal fees based on type of radioactive 

waste

Disposal options are available for long-lived intermediate-level 

radioactive waste

There are plans to build a disposal facility for long-lived low- and 

intermediate-level radioactive waste

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

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

country reports.

Legend: ● – Yes, o – No; NR – No response; NA – Not applicable 

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. 

Page 24 GAO-07-221 Foreign Radwaste Management Experiences
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 longlived, intermediate-level waste. Figure 6 provides a summary of the central

storage options available in the countries we surveyed. 

Most Countries Have 

Central Storage for LLRW 

Lacking a Disposal Option 

Figure 6: Central Storage Options for LLRW

NR

NR

NR

NR

2

14

1

10

13

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

HungaryAustraliaFrance

Disposal options are available for short-lived low- and intermediate-level 

waste

Central storage options are availabe for short-lived low- and 

intermediate-level waste

Disposal options are available for long-lived low-level waste

Disposal options are available for long-lived intermediate-level waste

Central storage options are available for long-lived low-level waste and 

long-lived intermediate-level waste

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

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

country reports.

Legend: ● – Yes, o – No; NR – No response 

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. 

Page 25 GAO-07-221 Foreign Radwaste Management Experiences
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-bycase 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. 

Most Countries Make 

Alternative Disposal 

Options Available for Very 

Low-Level Radioactive 

Waste

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. 

Page 26 GAO-07-221 Foreign Radwaste Management Experiences
Figure 7: Disposal Options and Exemption Methods for Managing Very Low-Level Radioactive Waste 

NR

NR NR

NR NR

NR

11

13

8

15

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

HungaryAustralia

France

Disposal options are available for very low-level radioactive waste

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

Case-by-case exemption by the nuclear regulatory authority of large 

quantities of radioactive material the still requires some regulatory 

control

Clearance or unrestricted removal of radioactive materials or radioactive 

objects with authorized practices from any further regulatory control by 

the nuclear regulatory authority

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Source: GAO survey of foreign countries, 2006.

Legend: ● – Yes, ○ – No; NR – No response 

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. 

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 higheractivity 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 

Page 27 GAO-07-221 Foreign Radwaste Management Experiences
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 caseby-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 onsite 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 

Page 28 GAO-07-221 Foreign Radwaste Management Experiences
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.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 nonhazardous 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. 

 12GAO, 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). 

Page 29 GAO-07-221 Foreign Radwaste Management Experiences
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 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 higheractivity 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 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 

Financial Assurance 

Requirements and 

Other Approaches Are 

Used by Most 

Countries to Reduce 

Government LLRW

Recovery Costs 

Half of the Countries 

Require All Non-Utility 

LLRW Generators to Meet 

Financial Assurance 

Requirements 

Some Countries Use Other 

Financial Approaches to 

Reduce Government 

Orphan Source Recovery 

Costs 

Page 30 GAO-07-221 Foreign Radwaste Management Experiences
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

NA NA

NA

NR NR

9

2

5

NR NR NR NR NR NR

NR NR NR NR NR NR NR NR

NR NR

3

NR

NR

9

NA NA NA NA NA 3

NA NA

NR NR NR NR NR

NA NA NA NA

NR NR NA NA

NR

LLRW management approach Japan

Germany

SwedenCanada

Switzerland

BelgiumSpain

United KingdomTotal Yes Count

Finland

MexicoNetherlands

ItalyDenmarkNorway

Slovak Republic

HungaryAustralia

France

6

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 

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

Orphan source recovery costs paid by a national organization

Orphan source recovery costs paid by disposition fund established by 

source users

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

Orphan source recovery costs paid by disposition fund established by 

source suppliers

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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18

Source: GAO survey of foreign countries, 2006.

Legend: ● – Yes, o – No; NR – No response; NA – Not applicable 

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. 

Page 31 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Domestic Experts Support 

the Need to Evaluate 

Financial Assurance 

Approaches 

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. 

Page 32 GAO-07-221 Foreign Radwaste Management Experiences
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. 

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. 

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. 

National Radioactive 

Waste Management 

Plans Are Considered 

Important for 

Managing LLRW 

Many Countries Have 

Developed Radioactive 

Waste Management Plans 

That Are National in Scope 

and Formulated by One 

Administrative Entity 

France 

Page 33 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Germany

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 

Spain 

Page 34 GAO-07-221 Foreign Radwaste Management Experiences
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 

Page 35 GAO-07-221 Foreign Radwaste Management Experiences
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. 

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: 

Conclusions 

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 

Page 36 GAO-07-221 Foreign Radwaste Management Experiences
• 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 

Page 37 GAO-07-221 Foreign Radwaste Management Experiences
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. 

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. 

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 longstanding experience and international leadership of NRC and DOE in the 

Recommendations 

Agency Comments 

and Our Evaluation 

Page 38 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Page 39 GAO-07-221 Foreign Radwaste Management Experiences
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 

http://www.gao.gov. 

Page 40 GAO-07-221 Foreign Radwaste Management Experiences
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. 

Gene Aloise 

Director, Natural Resources 

 and Environment 

Page 41 GAO-07-221 Foreign Radwaste Management Experiences
Appendix I: Recent GAO Findings and Agency

Appendix I: Recent GAO Findings and Actions on LLRW Management

Agency Actions on LLRW Management 

GAO reports have addressed various aspects of low-level radioactive

waste (LLRW) management in the United States.

1

 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 

 1

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). 

Page 42 GAO-07-221 Foreign Radwaste Management Experiences
Appendix I: Recent GAO Findings and Agency

Actions on LLRW Management

disposal.2 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.3

 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 longterm 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 

 2

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. 

3

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

Page 43 GAO-07-221 Foreign Radwaste Management Experiences
Appendix I: Recent GAO Findings and Agency

Actions on LLRW Management

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 lowlevel radioactive waste from regulation as LLRW, thus providing waste 

generators with more disposal options for this waste.4

 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 

 4

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. 

Page 44 GAO-07-221 Foreign Radwaste Management Experiences
Appendix I: Recent GAO Findings and Agency

Actions on LLRW Management

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 

Page 45 GAO-07-221 Foreign Radwaste Management Experiences
Appendix I: Recent GAO Findings and Agency

Actions on LLRW Management

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. 

Page 46 GAO-07-221 Foreign Radwaste Management Experiences
Appendix II: Scope and Methodology 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.1

 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 

 1

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. 

Page 47 GAO-07-221 Foreign Radwaste Management Experiences
Appendix II: Scope and Methodology 

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 nonEuropean 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; 

Page 48 GAO-07-221 Foreign Radwaste Management Experiences
Appendix II: Scope and Methodology 

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.2

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 

 2

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). 

Page 49 GAO-07-221 Foreign Radwaste Management Experiences
Appendix II: Scope and Methodology 

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 Domestic LLRW Stakeholder Group Respondent 

1 Nuclear Regulatory Commission 

2 Organization of Agreement State-Alabama 

3 Organization of Agreement State-Arkansas 

4 Organization of Agreement State-Louisiana 

5 Organization of Agreement State-New York 

6 Organization of Agreement State-North Carolina 

7 Organization of Agreement State-Texas 

8 Organization of Agreement State-Washington

9 Organization of Agreement State-Wisconsin

10 State of South Carolina, Bureau of Land and Waste Management 

11 State of South Carolina, Bureau of Radiological Health 

12 State of South Carolina, South Carolina Energy Office 

13 State of Texas, Department of State Health Services 

14 State of Utah, Division of Radiation Control 

15 American Ecology

16 Duratek (now Energy Solutions) 

17 Envirocare (now Energy Solutions) 

18 Waste Control Specialists

19 Conference of Radiation Control Program Directors 

20 Department of Defense’s Low-Level Radioactive Waste Executive Agent 

21 National Research Council of the National Academies 

22 NRC Advisory Committee on Nuclear Waste 

23 Council on Radionuclides and Radiopharmaceuticals 

24 Health Physics Society 

25 Low-Level Radioactive Waste Forum-Director

26 Michigan Low-Level Radioactive Waste Authority 

27 Midwest Low-Level Radioactive Waste Compact Commission 

28 Northwest Low-Level Radioactive Waste Compact Commission 

29 Southeast Low-Level Radioactive Waste Compact Commission 

30 Southwest Low-Level Radioactive Waste Compact Commission 

Page 50 GAO-07-221 Foreign Radwaste Management Experiences
Appendix II: Scope and Methodology 

Number Domestic LLRW Stakeholder Group Respondent 

31 Nuclear Energy Institute 

32 JTG Consulting, Inc. 

33 MRT, Inc.

Source: GAO interviews with representatives from LLRW stakeholder groups. 

Page 51 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management Appendix III: Survey of LLR Approaches: Response from United States W Management 

Approaches: Response from United States 

Page 52 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 53 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 54 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 55 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 56 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 57 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 58 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 59 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 60 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 61 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 62 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 63 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 64 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 65 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 66 GAO-07-221 Foreign Radwaste Management Experiences
Appendix III: Survey of LLRW Management 

Approaches: Response from United States 

Page 67 GAO-07-221 Foreign Radwaste Management Experiences
Appendix IV: Volume and Location of LLRW in Appendix IV the United States : 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.1

 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.2

 DOE’s low-level waste 

category and transuranic waste would clearly fall within the NRC waste 

 1

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. 

2

“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. 

Page 68 GAO-07-221 Foreign Radwaste Management Experiences
Appendix IV: Volume and Location of LLRW in 

the United States 

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 Location 

Class A waste

volume 

(cubic feet)

Class B waste

volume 

(cubic feet)

Class C waste

volume 

(cubic feet)

Total volume

 (cubic feet)

Barnwell Barnwell, South Carolina 24,815,969 1,643,933 825,833 27,285,735

Envirocare Clive, Utah 66,295,270 0 0 66,295,270

Richland Richland, Washington 13,450,191 137,056 137,233 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. 

Page 69 GAO-07-221 Foreign Radwaste Management Experiences
Appendix IV: Volume and Location of LLRW in 

the United States 

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

Closed commercial disposal 

facilities State 

Total volume 

(cubic feet)

Beatty Nevada 4,854,178 

West Valley New York 2,721,843 

Maxey Flats Kentucky 4,777,368 

Sheffield Illinois 3,119,486 

Total 15,472,875

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

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

Disposal facility Location 

Class A waste

volume 

(cubic feet)

Class B waste

volume 

(cubic feet)

Class C waste

volume

(cubic feet)

Total volume 

(cubic feet)

Barnwell Barnwell, South Carolina 25,111 9,367 8,535 43,013

Envirocare Clive, Utah 15,471,876 0 0 15,471,876

Richland Richland, Washington 19,906 7 191 20,104

Total 15,516,893 9,374 8,726 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. 

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. 

Page 70 GAO-07-221 Foreign Radwaste Management Experiences
Appendix IV: Volume and Location of LLRW in 

the United States 

Table 6: LLRW in Storage or Disposal at DOE Sites 

State Installation

Total volume

 (cubic feet)

Idaho Idaho National Laboratory 2,509,390

Kentucky Paducah Gaseous Diffusion Plant 335,489 

Nevada Nevada Test Site 27,259,391 

New Mexico Los Alamos National Laboratory 7,592,653 

New York West Valley Demonstration Project 575,276 

 New York Brookhaven National Laboratory 2,048

Ohio Ashtabula Environmental Management 

Project 108,204 

 Ohio Fernald Environmental Management Project 59,962,962 

 Ohio Portsmouth Gaseous Diffusion Plant 536,783 

South Carolina Savannah River Site 27,168,738

Tennessee Oak Ridge Site 22,054,009 

Washington Hanford Site 81,641,859 

Multiple states Small facilities 353 

Total 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. 

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. 

Page 71 GAO-07-221 Foreign Radwaste Management Experiences
Appendix IV: Volume and Location of LLRW in 

the United States 

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

DOE site State 

Volume disposed of at 

WIPP (cubic feet)

Volume in storage awaiting

 disposal at WIPP

(cubic feet)

Hanford Site Washington 52,972 1,539,719

Idaho National Laboratory Idaho 204,825 2,171,852

Lawrence Livermore National Laboratory California - 12,431

Los Alamos National Laboratory New Mexico 24,720 441,433

Nevada Test Site Nevada - 28,781

Oak Ridge Site Tennessee - 86,097

Rocky Flats Site Colorado 529,720 -

Savannah River Site South Carolina 250,734 459,091

Small Quantity Sites - 20,836 21,754

West Valley Demonstration Project New York - 30,017

Total 1,083,807 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. 

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. 

Page 72 GAO-07-221 Foreign Radwaste Management Experiences
Appendix IV: Volume and Location of LLRW in 

the United States 

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 State 

Total number 

of sources 

Sealed radiological sources in storage 

Los Alamos National Laboratory New Mexico 9,920

Los Alamos National Laboratory (for Pu 239 sources) New Mexico 1

National Naval Medical Center Maryland 22

Nevada Test Site - Pu 239 Storage Nevada 39

NSSI Sources and Services Inc. Texas 484

Southwest Research Institute Texas 135

Sealed radiological sources in disposal 

Barnwell South Carolina 474

Nevada Test Site Nevada 345

Waste Isolation Pilot Plant New Mexico 2,397

Total 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. 

Page 73 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced Appendix V Access to South Carolina Disposal Facility

: 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. 

Page 74 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

Table 9: Class B and C Waste Type Groups

Waste type group Waste type

Dry active waste (DAW) Charcoal 

Incinerator ash

Soil

Demolition rubble

Glassware or labware

Compactable trash

Non-compactable trash

Oil, gas, EPA or state hazardous, paint or 

plating (OGEP) 

Paint or plating

Liquids and sludge Aqueous liquid

Evaporator

bottoms/sludge/concentrates 

Solidified liquids

Filters, filter media & resins Filter media 

Mechanical filter

Cation ion-exchange media 

Mixed bed ion-exchange media 

Non-cartridge filter media 

Equipment and material Contaminated equipment 

Activated material

Activated reactor hardware 

Sealed radiological sources Sealed source/device 

Sealed sources

Biological materials Animal carcass

Other Other

Dry solid

Non-compacted dry active waste 

Solidified chelates

Combination

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

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 

Page 75 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

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 

Volume (in cubic feet) Activity (in curies) 

Waste type group Total Percent Total Percent

Dry active waste 7,849 5 34,490 2

Oil, gas, EPA or state hazardous, paint or 

plating 1 0 0 0

Liquids and sludge 2,222 2 7,729 0

Filters, filter media and resins 63,814 44 63,825 3

Equipment and material 39,856 28 1,797,562 86

Sealed radiological sources 4,995 3 92,287 4

Biological materials 18 0 86 0

Other 25,335 18 83,044 4

Total

a

144,090 100 2,079,023 100

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

a

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

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. 

Page 76 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

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 Academic Government Industry Medical Utility Total

Dry active waste 19 20 60 3 45 147

Oil, gas, EPA or state hazardous, paint or plating 0 0 0 0 1 1

Liquids and sludge 1 1 7 0 8 17

Filters, filter media and resins 0 6 6 0 65 77

Equipment and material 1 4 7 0 31 43

Sealed radiological sources 158 125 286 100 29 698

Biological materials 1 0 1 0 0 2

Other 8 60 29 2 58 157

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. 

Page 77 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

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 

0

100

200

300

400

500

600

700

800

Number of generators

Type of waste

DAW

OGEP

Liquids 

& Sludges

Filters, Filter 

Media & Resins

Equipment 

& Material

Sealed 

Sources

Biological 

Materials

Other

Utility

Medical

Industry

Government

Academic

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. 

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.

Page 78 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

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

Volume (in cubic feet) Activity (in curies) 

Generator Average Min Max Total Average Min Max Total

Academic 113 51 263 564 139 10 337 694

Government 916 220 1,643 4,581 20,135 111 88,159 100,673

Industry 1,308 712 2,285 6,542 15,888 7,906 30,213 79,442

Medical 36 23 61 178 7 2 16 33

Utility 26,445 17,054 33,698 132,225 379,636 122,851 499,854 1,898,182

Total

a

28,818 18,060 37,950 144,090 415,805 130,880 618,579 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. 

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. 

Page 79 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

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

Percent of Volume (in cubic feet) Percent of Activity (in curies) 

Generator Richland Barnwell Total Richland Barnwell Total

Academic 0.5 0.4 0.4 0.0 0.0 0.0

Government 18.8 3.0 3.2 1.1 4.9 4.8

Industry 37.7 4.2 4.5 96.4 2.9 3.8

Medical 0.1 0.1 0.1 0.0 0.0 0.0

Utility 42.9 92.2 91.8 2.5 92.2 91.3

Total

a

100 100 100 100 100 100

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. 

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

2001-2005 

Percent of Volume (in cubic feet) Percent of Activity (in curies) 

Generator Richland Barnwell Total Richland Barnwell Total

Academic 0.8 5.1 4.8 0.0 0.4 0.4

Government 32.9 39.1 38.6 1.1 62.5 55.7

Industry 66.1 54.3 55.1 98.9 37.0 43.9

Medical 0.1 1.6 1.5 0.0 0.0 0.0

Total

a

100 100 100 100 100 100

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. 

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, 

Page 80 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

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 

Richland Barnwell Total Percent 

Compact Volume Activity Volume Activity Volume Activity Volume Activity

Appalachian 0 0 10,417 499,433 10,417 499,433 7.2 24.0

Atlantic 0 0 38,196 215,884 38,196 215,884 26.5 10.4

Central 0 0 4,306 13,286 4,306 13,286 3.0 0.6

Central 

Midwest 0 0 15,520 480,153 15,520 480,153 10.8 23.1

Midwest 0 0 6,235 74,168 6,235 74,168 4.3 3.6

Northwest 1,448 19,257 280 161 1,728 19,418 1.2 0.9

Rocky 

Mountain 69 1,402 5 0.1 74 1,402 0.1 0.1

Southeast 0 0 21,991 329,245 21,991 329,245 15.2 15.8

Southwestern 0 0 6,490 7,774 6,490 7,774 4.5 0.4

Texas 0 0 5,345 6,680 5,345 6,680 3.7 0.3

Unaffiliated 0 0 33,787 431,582 33,787 431,582 23.5 20.8

Total

b

1,517 20,659 142,572 2,058,366 144,089 2,079,025 100 100

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. 

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. 

Page 81 GAO-07-221 Foreign Radwaste Management Experiences
Appendix V: Status of Class B and C Waste 

Disposal and Potential Effects of Reduced 

Access to South Carolina Disposal Facility

Table 16: Class B and C Waste Disposed at Barnwell from Atlantic, Northwest, and

Rocky Mountain Generators, and Other Generators, 2001-2005 

Barnwell Percent of Barnwell 

Compact Volume Activity Volume Activity

Atlantic, Northwest, and Rocky 

Mountain 38,482 216,046 27.0 10.5

Other 104,091 1,842,320 73.0 89.5

Total 142,573 2,058,366 100 100

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

a

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

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 Total generators Percent of total 

Impacted by

Barnwell closure

Unaffiliated 138 20 138

Southeast 98 14 98

Southwestern 92 13 92

Appalachian 82 12 82

Midwest 82 12 82

Atlantic 70 10

Texas 45 6 45

Central Midwest 43 6 43

Central 21 3 21

Northwest 17 2 0

Rocky Mountain 9 1 0

Total

a

697 100 601

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

a

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

Page 82 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear Appendix VI: Comments from the Nuclear Regulatory Commission and Our Response 

Regulatory Commission and Our Response 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of the appendix. 

See pages 38-40 for 

GAO’s response to this

letter. 

Page 83 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

Page 84 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

See comment 1. 

See comment 2. 

See comment 3. 

Page 85 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

See comment 4. 

See comment 5. 

See comment 6. 

See comment 7. 

Page 86 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

See comment 8. 

See comment 9. 

See comment 10. 

See comment 11. 

See comment 12. 

Page 87 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

See comment 13. 

See comment 14. 

See comment 1. 

See comment 2. 

See comment 3. 

See comment 4. 

Page 88 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

See comment 5. 

See comment 6. 

Page 89 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

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 

Page 90 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

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 

Page 91 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

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. 

Page 92 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VI: Comments from the Nuclear 

Regulatory Commission and Our Response 

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. 

Page 93 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VII: Comments from the Appendix VII: Comments from the Department of Energy and Our Response 

Department of Energy and Our Response 

Note: GAO comments 

supplementing those in 

the report text appear at 

the end of the appendix. 

See pages 38-40 for 

GAO’s response to this

letter. 

Page 94 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VII: Comments from the 

Department of Energy and Our Response 

Page 95 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VII: Comments from the 

Department of Energy and Our Response 

See comment 1. 

See comment 2. 

See comment 3. 

See comment 4. 

See comment. 5 

Page 96 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VII: Comments from the 

Department of Energy and Our Response 

See comment 6. 

See comment 7. 

See comment 8. 

See comment 9. 

See comment 10. 

Page 97 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VII: Comments from the 

Department of Energy and Our Response 

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. 

Page 98 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VII: Comments from the 

Department of Energy and Our Response 

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. 

Page 99 GAO-07-221 Foreign Radwaste Management Experiences
Appendix VIII: 

A

GAO Contact and Staff 

cknowledgments 

Page 100 GAO-07-221

Appendix VIII: GAO Contact and Staff 

Acknowledgments 

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

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. 

GAO Contact 

Staff 

Acknowledgments 

Foreign Radwaste Management Experiences
Related GAO Products 

Page 101 GAO-07-221

Related GAO Products 

Low-Level Radioactive Waste: Future Waste Volumes and Disposal 

Options Are Uncertain. GAO-04-1097T. Washington, D.C.: September 30, 

2004. 

Management of LLRW 

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/RCED98-40R. 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. 

Foreign Radwaste Management Experiences
Related GAO Products 

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. 

Page 102 GAO-07-221 Foreign Radwaste Management Experiences
Related GAO Products 

Improvements Needed in the Land Disposal of Radioactive Wastes—A 

Problem of Centuries. GAO/RED-76-54. Washington, D.C.: January 12, 

1976. 

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. 

Page 103 GAO-07-221 Foreign Radwaste Management Experiences

Management of Sealed 

Radiological Sources 

(360632) 
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER