SPENT NUCLEAR 

FUEL MANAGEMENT

Outreach Needed to 

Help Gain Public 

Acceptance for 

Federal Activities That 

Address Liability

Report to Congressional Requesters

October 2014

GAO-15-141

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-141, a report to 

congressional requesters

D 

October 2014

SPENT NUCLEAR FUEL MANAGEMENT

Outreach Needed to Help Gain Public Acceptance for 

Federal Activities That Address Liability

Why GAO Did This Study

DOE is responsible for disposing of 

commercial spent nuclear fuel. DOE 

entered into contracts with owners and 

generators of spent nuclear fuel to 

begin disposing of it beginning in 1998, 

with plans for disposal in a national 

repository. DOE, however, was unable 

to meet the 1998 date and, as a result 

of lawsuits, the federal government has 

paid out about $3.7 billion for storage 

costs. DOE proposed a new strategy in 

January 2013 to build consolidated

interim storage facilities—starting 

operations in 2021 and 2025. 

GAO was asked to review issues 

related to DOE’s strategy for managing 

spent nuclear fuel. This report (1) 

describes the expected rate of spent 

nuclear fuel accumulation in wet and 

dry storage, (2) identifies the basis of 

federal liability for spent nuclear fuel 

management to date and of DOE’s 

estimate of future liabilities, and (3) 

assesses challenges, if any, that 

experts and stakeholders have 

identified to the federal government’s 

ability to meet DOE’s time frames for 

managing spent nuclear fuel at 

consolidated interim storage facilities 

and potential ways for DOE to mitigate 

the challenges. GAO reviewed 

documents from DOE and other

agencies, and interviewed experts and 

stakeholders from industry, federal and 

state governments, interest groups, 

and independent entities. 

What GAO Recommends

DOE should implement a coordinated

outreach strategy to better inform the 

public about federal spent nuclear fuel 

management issues. DOE generally 

agreed with the findings and 

recommendation in the report.

What GAO Found

Spent nuclear fuel—the used fuel removed from nuclear power reactors—is 

expected to accumulate at an average rate of about 2,200 metric tons per year in 

the United States. This spent nuclear fuel is mostly stored wet, submerged in 

pools of water. However, since pools have been reaching their capacities,

owners and generators of spent nuclear fuel (typically utilities and reactor 

operators) have been transferring it to canisters that are placed in casks on 

concrete pads for dry storage—which is an expensive and time-consuming 

process. When operating reactors’ licenses begin to expire in the 2030s, the rate 

of spent nuclear fuel accumulation is expected to decrease, but the amount in dry 

storage will increase as the pools are closed and all spent nuclear fuel is 

transferred to dry storage. By 2067, the currently operating reactors are expected 

to have generated about 139,000 metric tons of spent nuclear fuel, nearly all of 

which is expected to be transferred to dry storage.

Federal liability for managing spent nuclear fuel has been based on costs that 

owners and generators of this fuel have paid because the Department of Energy 

(DOE) has not met its contractual obligation to dispose of spent nuclear fuel. 

DOE’s estimate of future federal liability is based on how long DOE expects the 

federal government to continue to pay the costs for managing spent nuclear fuel

to plant owners and generators. Generally, the damages paid—mostly for the 

costs of transferring spent nuclear fuel from wet to dry storage—have been for 

costs that owners and generators would not have incurred if DOE had begun 

disposing of the spent nuclear fuel. DOE’s most recent estimate of future 

liability—$21.4 billion through 2071—assumes that DOE will begin taking title to 

and possession of spent nuclear fuel in 2021 and complete the process in 2071, 

thereby ending the federal liability. DOE has extended the expected date that the 

last of the spent nuclear fuel will be picked up several times, and each extension 

has added to the future federal liability. 

Spent nuclear fuel management experts and stakeholders GAO spoke with 

identified several legislative, regulatory, technical, and societal challenges to 

meeting DOE’s time frames for managing spent nuclear fuel at interim storage 

facilities. Although DOE has begun to take actions to address some of these 

challenges, officials noted that the department’s strategy cannot be fully 

implemented until Congress provides direction on a new path forward. However, 

experts and stakeholders believe that one key challenge—building and 

sustaining public acceptance of how to manage spent nuclear fuel—will need to 

be addressed irrespective of which path Congress agrees to take. In this context, 

they suggested the need for a coordinated public outreach strategy regarding 

spent nuclear fuel management issues, including perceived risks and benefits, 

which would be consistent with the Administration’s directive to be more 

transparent and collaborative. DOE officials stated they currently do not have 

such a strategy. Without a better understanding of spent nuclear fuel 

management issues, the public may be unlikely to support any policy decisions 

about managing spent nuclear fuel.

View GAO-15-141. For more information, 

contact Frank Rusco at (202) 512-3841 or 

ruscof@gao.gov. 
Page i GAO-15-141 Spent Nuclear Fuel Liability

Letter 1 

Background 4

About 2,200 Metric Tons of Spent Nuclear Fuel Is Expected to 

Accumulate Annually, Mostly in Wet Storage, but This Pace Is 

Expected to Change as Reactors Shut Down 11

Federal Liability for Spent Nuclear Fuel Management Is Based on 

Costs Incurred Because DOE Has Not Met Contract Obligations 16

Experts and Stakeholders Identified Challenges to and 

Suggestions for Managing Spent Nuclear Fuel at Interim 

Storage Facilities within DOE’s Time Frames 19

Conclusions 36

Recommendation for Executive Action 37

Agency Comments 37

Appendix I Objectives, Scope, and Methodology 39

Appendix II Spent Nuclear Fuel Experts and Stakeholders We Interviewed 43

Appendix III Commercial Spent Nuclear Fuel Stored in Wet, Dry, and Shutdown 

Storage Sites (Text for Interactive Figure 5) 46

Appendix IV Additional Information on the Spent Nuclear Fuel Settlement Agreements

49

Appendix V Process and Costs of Transferring Spent Nuclear Fuel from Wet to

Dry Storage (Text for Interactive Figure 7) 52

Appendix VI Comments from the Department of Energy 53

Appendix VII GAO Contact and Staff Acknowledgments 55

Contents
Page ii GAO-15-141 Spent Nuclear Fuel Liability

Tables

Table 1: Typical Reactor Characteristics, Canister Storage 

Capacity 17

Table 2: Typical Costs Associated with Transferring Spent Nuclear 

Fuel in Canisters from Wet to Dry Storage 17

Figures

Figure 1: Nuclear Fuel Pellet and Fuel Rod Assembly for a 

Commercial Nuclear Power Reactor 6

Figure 2: Spent Nuclear Fuel in Wet Pool Storage 7

Figure 3: Dry Cask Storage System for Spent Nuclear Fuel 9

Figure 4: Spent Nuclear Fuel in Dry Storage 10

Figure 5: Commercial Spent Nuclear Fuel Stored in Wet, Dry, and 

Shutdown Storage Sites 13

Figure 6: Estimated Amount of Accumulation of Spent Nuclear 

Fuel in Wet and Dry Storage through 2067 15

Figure 7: Process and Costs of Transferring Spent Nuclear Fuel 

from Wet to Dry Storage 18

Figure 8: Four Major Types of Challenges Identified By Experts 

and Stakeholders on Federal Efforts to Manage Spent 

Nuclear Fuel at Consolidated Interim Storage Facilities 20

Abbreviations

DOE Department of Energy

NRC Nuclear Regulatory Commission

NWPA Nuclear Waste Policy Act of 1982

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

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-15-141 Spent Nuclear Fuel Liability

441 G St. N.W.

Washington, DC 20548

October 9, 2014

The Honorable Fred Upton

Chairman

Committee on Energy and Commerce

House of Representatives

The Honorable John Shimkus

Chairman

Subcommittee on Environment and the Economy

Committee on Energy and Commerce

House of Representatives

Spent nuclear fuel—used nuclear fuel that has been removed from the 

reactor core of a nuclear power plant1

To address the growing inventory, Congress made disposal of spent 

nuclear fuel a federal responsibility with the passage of the Nuclear 

—is an extremely harmful 

substance if not managed properly. Without protective shielding, its 

intense radioactivity can kill a person who is directly exposed to it or 

cause long-term health hazards, such as cancer. In addition, if not 

managed properly, or if it were released by a natural disaster or an act of 

terrorism, it could contaminate the environment with radiation. The 

nation’s inventory of spent nuclear fuel from commercial nuclear power 

reactors is stored at 75 sites in 33 states, generally where it was 

generated. The spent nuclear fuel is stored either wet in pools of water or 

dry in storage systems that typically consist of stainless steel canisters 

within protective casks. Over the past several decades, the inventory of 

commercial spent nuclear fuel in storage in the United States has grown 

to about 72,000 metric tons.

 

1

Spent (or used) nuclear fuel can no longer efficiently generate power in a nuclear reactor. 

However, it is potentially a resource because it can be reprocessed to separate out 

uranium and plutonium to be used again as fuel in a reactor. Reprocessing, however, still 

results in high-level radioactive waste that requires disposal, and the United States does 

not currently reprocess spent nuclear fuel from commercial nuclear power reactors. The 

federal government generates spent nuclear fuel from power, research, and navy 

shipboard reactors. The U.S. Nuclear Regulatory Commission considers spent nuclear 

fuel that is accepted for disposal to be high-level radioactive waste. High-level radioactive 

waste also includes byproducts of weapons production and other defense-related 

activities generated from reprocessing spent nuclear fuel. The scope of this review only 

includes commercial spent nuclear fuel.
 

Page 2 GAO-15-141 Spent Nuclear Fuel Liability

Waste Policy Act of 1982 (NWPA), which directed the Department of 

Energy (DOE) to investigate sites for a permanent repository.2 The act 

also authorized DOE to enter into contracts with owners and generators 

of commercial spent nuclear fuel—typically utilities and reactor 

operators—to begin taking title to (legal ownership) spent nuclear fuel 

following commencement of a repository and disposing of spent nuclear 

fuel beginning no later than January 31, 1998. In 1987, Congress 

amended the act to direct DOE to focus its efforts only on a site at Yucca 

Mountain, Nevada, about 100 miles northwest of Las Vegas. DOE did not 

begin disposing of spent nuclear fuel by 1998 because of state and local 

opposition to a repository in Nevada, technical complexities, and funding 

uncertainties, among other reasons.3

Since 1998, owners and generators of spent nuclear fuel have sued DOE 

primarily in the U.S. Court of Federal Claims for failing to meet its 

obligations under the contracts that DOE had entered into with them. The 

Department of Justice reported that as of March 2014, 90 such lawsuits 

had been filed. As of the end of fiscal year 2013, the federal government 

had reimbursed owners and generators about $3.7 billion in connection 

with such lawsuits.4 The reimbursements come from the U.S. Department 

of Treasury’s judgment fund,5

In 2008, DOE submitted a license application for a repository at Yucca 

Mountain to the Nuclear Regulatory Commission (NRC), which is 

which is financed by U.S. taxpayers. DOE 

estimates that future federal liability for litigation related to storing spent 

nuclear fuel will amount to $21.4 billion through 2071.

 

2

Pub. L. 97-425 §§ 112. 113. NWPA also addressed disposal of high-level radioactive 

waste other than spent nuclear fuel.

3

See GAO, Commercial Nuclear Waste: Effects of a Termination of the Yucca Mountain 

Repository Program and Lessons Learned, GAO-11-229 (Washington, D.C.: Apr. 8, 

2011).

4

In addition to the $3.7 billion reimbursed to owners and generators through fiscal year 

2013, the Department of Justice, which defends DOE in the lawsuits, has expended 

approximately $219.5 million in defense-related costs, as of December 31, 2013. Industry 

officials said that, for proprietary reasons, they could not provide a total for their litigation 

costs but that they are also incurring similar expenses. While the courts have not ordered 

the federal government to reimburse utilities for attorneys’ fees, the Court of Federal 

Claims generally has awarded court costs to utility plaintiffs.

5

The fund is a permanent, indefinite appropriation for the payment of judgments against 

the United States.
 

Page 3 GAO-15-141 Spent Nuclear Fuel Liability

responsible for regulating storage, transportation, and disposal of spent 

nuclear fuel from commercial nuclear power reactors. Then, in a change 

of policy in 2009, the Secretary of Energy said that a repository at Yucca 

Mountain was not a workable option, and in 2010, DOE terminated its 

efforts to license a repository there. In 2010, DOE chartered the Blue 

Ribbon Commission on America’s Nuclear Future to recommend a plan 

for management and disposal of spent nuclear fuel. In January 2012, the 

Blue Ribbon Commission recommended that Congress create and fund a 

new organization dedicated solely to managing spent nuclear fuel.6 The 

commission also recommended development of a consent-based 

approach to locating or establishing (or “siting”) future spent nuclear fuel 

management facilities, among other things. In January 2013, DOE issued 

a strategy for managing spent nuclear fuel in response to the 

commission’s recommendations.7

In light of the billions of dollars in liabilities being paid by taxpayers 

because the federal government has not begun disposing of spent 

nuclear fuel as it agreed to do, you asked us to review issues related to 

DOE’s spent nuclear fuel strategy and the federal government’s liabilities. 

This report (1) describes the expected rate of spent nuclear fuel 

accumulation in wet and dry storage, (2) identifies the basis of federal 

liability for spent nuclear fuel management to date and of DOE’s estimate 

The strategy calls for the federal 

government to begin accepting spent nuclear fuel for management at a 

pilot interim storage facility by 2021 and at a larger consolidated interim 

storage facility by 2025, among other things. According to the strategy, it 

represents “an initial basis for discussions among the Administration, 

Congress and other stakeholders on a sustainable path forward for 

disposal” of spent nuclear fuel and other types of high-level radioactive 

waste. According to DOE’s strategy, beginning operations at the pilot and 

larger interim storage facilities in 2021 and 2025, respectively, will allow 

the federal government to accept enough spent nuclear fuel to limit 

expected federal liabilities to DOE’s fiscal year 2013 liability estimate of 

$21.4 billion. Delays in meeting the strategy’s milestones for interim 

storage might result in additional liabilities.

 

6

Blue Ribbon Commission on America’s Nuclear Future, Report to the Secretary of 

Energy, (Washington, D.C.: Jan. 26, 2012). The Blue Ribbon Commission’s 

recommended plan was to cover spent nuclear fuel and other high-level waste.

7

DOE, Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level 

Radioactive Waste, (Washington, D.C.: January 2013).
 

Page 4 GAO-15-141 Spent Nuclear Fuel Liability

of future liabilities, and (3) assesses challenges, if any, that experts and 

stakeholders have identified to the federal government’s ability to meet 

DOE’s time frames for managing spent nuclear fuel at consolidated 

interim storage facilities and potential ways for DOE to mitigate the 

challenges.

To answer these objectives, we reviewed documents and interviewed 

officials from DOE and NRC regarding their regulatory roles related to 

spent nuclear fuel management. We also consulted with Department of 

Justice officials regarding their role in defending the government in the 

owners’ and generators’ lawsuits. In addition, we obtained input from 

experts and stakeholders in spent nuclear fuel management. Specifically, 

to describe the expected rate of spent nuclear fuel accumulation in wet 

and dry storage, we obtained data from the Nuclear Energy Institute, an 

industry policy umbrella organization. This information contains the 

amounts of spent nuclear fuel currently in wet and dry storage, and 

projected amounts of spent nuclear fuel to be added to the current wet 

and dry storage inventory as spent nuclear fuel is removed from reactors 

until they shut down. To identify the basis of federal liability for spent 

nuclear fuel management to date and of DOE’s estimate of future 

liabilities, we reviewed DOE documents and interviewed DOE officials. To 

assess the challenges, if any, that experts and stakeholders have 

identified to the federal government’s ability to meet DOE’s time frames 

for managing spent nuclear fuel at consolidated interim storage facilities 

and potential ways for DOE to mitigate these challenges, we identified 

individuals with spent nuclear fuel management experience and 

expertise. We obtained input from these experts and stakeholders by 

interviewing them and reviewing documents prepared by the 

organizations with which they are affiliated. Appendix I presents our 

scope and methodology in more detail and appendix II lists the experts 

and stakeholders with whom we consulted.

We conducted this performance audit from November 2013 to October

2014, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

Fuel for commercial nuclear power reactors is typically made from low 

enriched uranium fashioned into thumbnail-size ceramic pellets of Background
 

Page 5 GAO-15-141 Spent Nuclear Fuel Liability

uranium dioxide. These pellets are fitted into 12- to 15-foot hollow rods, 

referred to as cladding, made of a zirconium alloy. The rods are then 

bound together into a larger assembly. A typical reactor holds about 100 

metric tons of fuel when operating—generally from 200 to 800 fuel 

assemblies. The uranium in the assemblies undergoes fission—a process 

of splitting atoms into fragments and neutrons that then bombard other 

atoms—resulting in additional fission reactions and a sustainable chain 

reaction that creates an enormous amount of heat and radioactivity in the 

form of radioisotopes, or radioactive substances. The heat is used to 

generate steam to turn a turbine, which generates electricity. The 

radioisotopes produced in a reactor can remain hazardous from a few 

days to many thousands of years; these radioisotopes remain in the fuel 

assemblies and as components of the resulting spent nuclear fuel. Figure 

1 shows what a fuel pellet for a commercial nuclear reactor and a fuel rod 

in an assembly look like.
 

Page 6 GAO-15-141 Spent Nuclear Fuel Liability

Figure 1: Nuclear Fuel Pellet and Fuel Rod Assembly for a Commercial Nuclear Power Reactor

Each fuel assembly is typically used in the reactor from 4 to 6 years, after 

which most of the uranium dioxide is no longer cost-efficient at producing 

energy. Reactor operators typically discharge about one-third of the fuel 

assemblies from a reactor every 18 months to 2 years and place the 

spent nuclear fuel in a pool to cool. Most commercial spent nuclear fuel is 

stored immersed in pools of water designed to cool and isolate it from the 

environment. Water circulates in the pool to remove the heat generated 

from the radioactive decay of some of the radioisotopes. In recent years, 

reactor operators have used fuel that is burned longer in the reactor 
 

Page 7 GAO-15-141 Spent Nuclear Fuel Liability

under the same operating conditions, resulting in higher “burn-up” and 

higher decay heat in comparison to the lower burn-up fuel that had been 

in use.8

Figure 2: Spent Nuclear Fuel in Wet Pool Storage

The pools of water for cooling spent nuclear fuel are typically 

about 40 feet deep, with at least 20 feet of water covering the spent fuel. 

Figure 2 shows a typical spent nuclear fuel pool.

Industry practice has been to store the spent nuclear fuel in the pools for 

at least 5 years, with an industry expectation that, at some point, DOE 

would begin to accept it. Spent nuclear fuel typically must remain in a 

pool for at least 5 years to decay enough to remain within the heat limits 

currently allowed for dry cask storage systems. Spent nuclear fuel can be 

 

8

Reactor fuel “burn-up” is a measure of the energy that has been produced by the fuel. 

High burn-up fuel generally has been in a reactor longer than low burn-up fuel and is 

defined as having a burn-up higher than 45,000 megawatt days per metric ton.
 

Page 8 GAO-15-141 Spent Nuclear Fuel Liability

sufficiently cool to load into dry storage systems earlier than 5 years, but 

doing so is generally not practical. Some dry storage systems, depending 

on the rated heat load, may not accommodate a full load of spent nuclear 

fuel. High burn-up fuel may have to remain in a pool longer than low burnup fuel to cool sufficiently.

The pools at commercial nuclear power reactors have largely reached 

their maximum capacities, however. When spent nuclear fuel is 

discharged from a reactor at a plant where the spent nuclear fuel pool is 

at maximum capacity, spent nuclear fuel equal to the amount of spent 

nuclear fuel discharged from the reactor must be transferred to dry 

storage. The dry storage systems typically consist of either a thick-walled, 

bolted steel vertical cask, or a welded steel canister inside a vertical or 

horizontal steel-reinforced concrete cask. Dry storage systems are 

designed with thick steel and concrete walls to provide radiation shielding 

and passive pathways for removal of spent nuclear fuel decay heat, such 

as air vents in the casks. In one typical process of transferring spent fuel 

to dry storage, reactor operators place a steel canister inside a larger 

steel transfer cask and lower both into a pool. Spent nuclear fuel is 

loaded into the canister, a lid is placed on the canister, and then both the 

canister and transfer cask are removed from the pool. The transfer cask 

shields nearby workers from the radiation produced by the spent nuclear 

fuel in the canister. The water is drained and a lid is welded onto the 

canister. Then the canister and transfer cask are aligned with a storage 

cask and the canister is maneuvered into the storage cask. The transfer 

cask can be re-used. The storage casks, in either vertical or horizontal 

designs (see fig. 3), are usually situated on a large concrete pad with 

safety and security measures, such as radiation detection devices and 

intrusion detection systems. 
 

Page 9 GAO-15-141 Spent Nuclear Fuel Liability

Figure 3: Dry Cask Storage System for Spent Nuclear Fuel
 

Page 10 GAO-15-141 Spent Nuclear Fuel Liability

NRC requires that spent fuel in dry storage be stored in approved 

systems that offer protection from significant amounts of radiation. NRC 

requires storage systems to demonstrate compliance with its regulations, 

including through physical tests of the systems, scaled physical tests, and 

computer modeling. Once a dry storage system is approved, NRC issues 

a certificate of compliance for a cask design or a specific license. Figure 4 

shows spent nuclear fuel on a concrete pad in dry storage.

Figure 4: Spent Nuclear Fuel in Dry Storage

Most U.S. reactors were built during the 1960s and 1970s and, after a 40-

year licensing period have received a 20-year license extension, and 

some may apply for subsequent extensions. Nevertheless, these reactors 

may begin permanently shutting down in large numbers by about 2030 

and emptying their pools by about 2040 absent additional license 

renewals. In the absence of a repository, the reactors’ accumulated spent 

nuclear fuel will be “stranded” in a variety of different dry storage systems, 

with no easy way of repackaging the spent fuel should repackaging be 

required to meet future storage or disposal requirements. NRC 
 

Page 11 GAO-15-141 Spent Nuclear Fuel Liability

regulations require radioactive contamination to be reduced at a reactor 

to a level that allows NRC to terminate the reactor’s license and release 

the property for other use after a reactor shuts down permanently. This 

cleanup process is known as decommissioning.9

Spent nuclear fuel is expected to accumulate at an average rate of about 

2,200 metric tons per year in the United States, mostly in wet storage, but 

this rate and the amount in wet storage are expected to decrease as 

more reactors, as projected, begin to shut down in the 2030s. More 

specifically, according to data provided by the Nuclear Energy Institute, 

the rate of accumulation will be about 2,100 metric tons in 2031, 

decreasing to about 1,200 metric tons in 2040, about 200 metric tons in 

2050, and less than 100 metric tons per year from 2051 through 2055, 

when the last one of the currently operating nuclear power reactors is 

expected to shut down. These rates assume that except for the few 

reactors that have announced early permanent shutdown dates, the 

nation’s current reactors continue to operate through a 20-year extended 

license period without any further license extensions and continue to 

produce spent nuclear fuel at the same rate, and that no new reactors are 

brought online.10

 

9

See GAO, Nuclear Regulation: NRC’s Oversight of Nuclear Power Reactors’ 

Decommissioning Funds Could Be Further Strengthened, GAO-12-258 (Washington, 

D.C.: Apr. 5, 2012). Decommissioning must generally be completed within 60 years of 

cessation of reactor operations. Reactor operators may either immediately decontaminate 

and dismantle their reactor sites or monitor and maintain them as the spent nuclear fuel 

cools and decays over a longer period.

10NRC has issued licenses for the construction of four new reactors in South Carolina and 

Georgia. The Nuclear Energy Institute data did not include spent nuclear fuel that is 

expected to be generated from these reactors. The Nuclear Energy Institute data also did 

not include spent nuclear fuel that might be generated from a second license extension of 

existing nuclear power reactors. The Nuclear Energy Institute stated that some operators 

of reactors are considering a second license renewal.

About 2,200 Metric 

Tons of Spent 

Nuclear Fuel Is 

Expected to 

Accumulate Annually, 

Mostly in Wet 

Storage, but This 

Pace Is Expected to 

Change as Reactors 

Shut Down
 

Page 12 GAO-15-141 Spent Nuclear Fuel Liability

By the end of fiscal year 2013, DOE reported that it had signed contracts 

with owners and generators of spent nuclear fuel involving 118 reactors. 

The spent nuclear fuel from these 118 reactors is stored at 75 sites in 

both wet and dry storage systems. Several reactors share the same site. 

For example, the Palo Verde site in Arizona has 3 operating reactors.

In 2013, about 70 percent of accumulated spent nuclear fuel—about 

50,000 metric tons—was stored in pools, with the remaining 30 percent—

about 22,000 metric tons—in dry storage. Figure 5 shows the 75 spent 

nuclear fuel wet and dry storage sites, including shut-down sites, in the 

United States.

Shutdown of Nuclear Reactors in the 

United States

Of the 118 nuclear reactors in the United 

States, 18 reactors have permanently shut 

down. Three of these reactors are located on 

a site that also has an operating reactor. The 

remaining 15 reactors are located on 12 sites 

where the reactors have been or will be 

dismantled and decontaminated. After this 

decommissioning, the site can be used for 

other purposes and the only relic remaining at 

the site will be the spent nuclear fuel storage 

facility and the associated safety and security 

infrastructure.

Source: DOE. | GAO-15-141
Page 1 GAO-15-715 Spent Nuclear Fuel Liability

Figure 5: Commercial Spent Nuclear Fuel Stored in Wet, Dry, and Shutdown Storage Sites Interactive Graphic

Instructions: Online, hover over the symbols in the key for more information.

 To print a version containing text, see appendix III, page 46

a

In addition, there are three permanently shutdown reactors at sites that continue to have operating 

reactors. The sites that have both shutdown and operating reactors include the Dresden, Indian Point, 

and Millstone sites. Of the 12 shutdown reactor sites, the Zion site has two permanently shutdown 

reactors and the San Onofre site has three permanently shutdown reactors.
 

Page 14 GAO-15-141 Spent Nuclear Fuel Liability

In the future, more spent nuclear fuel is expected to be put into dry 

storage for two reasons. First, since most spent nuclear fuel pools have 

reached their maximum capacities, reactor operators must transfer fuel 

from the pools to dry storage to make room for newer spent nuclear fuel, 

a time-consuming and costly process. Second, the amount of spent

nuclear fuel transferred to dry storage is expected to increase as reactors 

shut down and their pools are closed. According to data from the Nuclear 

Energy Institute, by 2024, the proportion of spent fuel in wet storage and 

dry storage from currently existing reactors should be roughly equal—

about 48,000 metric tons each. By 2040, about 70 percent of the spent 

fuel is expected to be in dry storage, or about 89,000 metric tons, 

compared to about 39,000 metric tons in wet storage. By 2067—after the 

last of the currently operating reactors have shut down—nearly all the 

139,000 metric tons of spent fuel expected to be generated by currently 

operating reactors is expected to be in dry storage. Figure 6 shows the 

estimated amounts of spent nuclear fuel accumulation and transfer from 

wet storage to dry storage through 2067.
 

Page 15 GAO-15-141 Spent Nuclear Fuel Liability

Figure 6: Estimated Amount of Accumulation of Spent Nuclear Fuel in Wet and Dry Storage through 2067

Note: The rates in the figure assume that except for the few reactors that have announced early 

permanent shutdown dates, the nation’s current reactors continue to operate through a 20-year 

extended-license period without any further license extensions and continue to produce spent nuclear 

fuel at the same rate that no new reactors are brought online, and that generation of spent nuclear 

fuel declines as reactors shut down.
 

Page 16 GAO-15-141 Spent Nuclear Fuel Liability

Federal liability for managing spent nuclear fuel has been based on costs 

that owners and generators of this fuel have paid because DOE has not 

met its contractual obligations to begin disposing of this fuel, and DOE’s 

estimate of future liability—$21.4 billion through 2071—is based on how 

long the federal government is expected to pay these costs. This estimate 

is based on DOE’s strategy to begin accepting spent nuclear fuel in 2021 

and assumes no delays in their schedule.

Generally, the U.S. Court of Federal Claims has held that the federal 

government’s liability covers the cost of managing the spent nuclear fuel 

that DOE was obligated to begin disposing of in 1998. The Department of 

Justice has also agreed to pay such costs as a result of settlement 

agreements.11

Some of the costs for which the federal government has been liable have 

related to expanding wet storage of spent nuclear fuel. For example, the 

federal government has compensated owners and generators for 

replacing lower-density storage racks with higher-density storage racks in 

pools to increase the capacity of the pools. The capacity of nearly all the 

spent nuclear fuel pools in the country has been expanded to the extent 

practical, and according to NRC, most pools have been filled to their 

maximum prudent capacities.

(See app. IV for additional information on the settlement 

agreements.) Under the standard contract, DOE was obligated to take 

title to and dispose of a certain quantity of spent nuclear fuel beginning in 

1998. The order in which spent nuclear fuel was to be picked up is based 

on the order in which it was removed from reactors—or the oldest fuel 

first. The owner or generator was expected to pay continued storage 

costs for the spent nuclear fuel that DOE was not obligated to pick up.

The majority of the types of costs for which the federal government has 

been liable have pertained to dry storage costs of spent nuclear fuel. 

Some have been one-time costs, such as the cost of constructing a 

concrete pad for storing spent nuclear fuel once it has been transferred 

from the pools to dry canisters or casks. Constructing a concrete storage 

pad typically costs from about $5.5 million to $6.5 million, but can range 

higher if additional equipment or special design requirements are needed. 

 

11According to a Department of Justice official, the department has settled as many of the 

cases brought by owners and generators of spent nuclear fuel as possible out of court to 

reduce the time and expense of litigation and to achieve some consistency in what the 

government should expect to pay in potential future claims. 

Federal Liability for 

Spent Nuclear Fuel 

Management Is 

Based on Costs 

Incurred Because 

DOE Has Not Met 

Contract Obligations
 

Page 17 GAO-15-141 Spent Nuclear Fuel Liability

Other dry storage costs are recurring; for example, the cost of the 

canisters themselves, which depends on the size of the canister and type 

of spent nuclear fuel stored in it. Table 1 shows the differences in sizes of 

canisters, which typically cost from $700,000 to $1.5 million, and how the 

numbers of canisters for which the federal government may have to pay 

can vary from site to site.

Table 1: Typical Reactor Characteristics, Canister Storage Capacity

Type of reactor Typical core size Typical discharge

Typical capacity of 

dry storage canister

Typical number of 

canisters to be 

loaded to keep pace 

with discharge

Pressurized water reactora 193 assemblies

(87 metric tons)

72 to 84 assemblies (32 

to 38 metric tons)

32 assemblies

(14.4 metric tons)

3-6 canisters annually

Boiling water reactora 650 assemblies 

(101 metric tons)

224 assemblies every 24 

months (40 metric tons)

61 assemblies 

(11 metric tons)

4 canisters biennially

Source: GAO analysis of Electric Power Research Institute and Nuclear Energy Institute data. | GAO-15-141

a

Fuel for nuclear reactors differs according to the type of reactor. In the United States, about twothirds of the 100 operating reactors are pressurized water reactors, with the remainder being boiling 

water reactors. Fuel assemblies for both types of reactors are typically 14 feet tall, but such 

assemblies for pressurized water reactors are about 8.5 inches square compared with about 6 inches 

square for boiling water reactors.

Another recurring cost is the cost of transferring spent nuclear fuel in the 

canisters from the pools to dry storage. Table 2 reflects typical costs 

associated with the transfer of spent nuclear fuel from wet to dry storage 

that may contribute to federal liabilities.

Table 2: Typical Costs Associated with Transferring Spent Nuclear Fuel in Canisters from Wet to Dry Storage

Component Typical Costs

Labor costs to transfer spent nuclear fuel from pool to dry storagea $150,000 to $550,000

Transfer cask $1.5 million to $3 million

Crawler-type transporter $1 million to $1.5 million

Vertical storage cask $250,000 to $350,000

Horizontal storage module $500,000 to $600,000

Design, licensing, and construction $5.5 million to $42 million

Annual operations $100,000 to $300,000 for operating reactor site

$2.5 million to $6.5 million for permanently shutdown reactor site

Source: GAO analysis of Nuclear Energy Institute data. | GAO-15-141

Note: Some items, such as a transfer cask and a transporter can be re-used and may reflect one-time 

costs. In addition, costs for the transfer cask and transporter reflect purchase costs, but this 

equipment could be leased, rather than purchased. The costs for canisters, ranging from $700,000 to 

$1.5 million, are not included in this table.
Page 18 GAO-15-715 Spent Nuclear Fuel Liability 

Figure 7: Process and Costs of Transferring Spent Nuclear Fuel from Wet to Dry Storage Interactive Graphic

Instructions: Online, hover over the number in the figure for more information.

 To print a version containing text, see appendix V, page 52

Note: Since each dry storage facility is unique in terms of proximity to the reactor, size, and type of storage systems, this figure is only illustrative and does not show a typical dry storage facility. For example, 

vertical and horizontal storage systems are typically not found at the same site.
 

Page 19 GAO-15-141 Spent Nuclear Fuel Liability

DOE’s estimate of future liability is based on how long DOE expects the 

federal government to continue to pay for managing spent nuclear fuel 

that DOE was obligated to have begun disposing of if it had begun picking 

up the fuel in 1998. DOE’s most recent estimate of this liability is $21.4 

billion through 2071. This estimate assumes that DOE will begin 

accepting spent nuclear fuel in 2021 and complete the process in 2071, 

ending the federal government’s liability. However, DOE has previously 

extended the dates in its liability estimates several times. For example, in 

the fiscal year 2006 liability estimate, DOE estimated (1) that the federal 

liability was $6.9 billion, (2) that DOE would begin accepting spent 

nuclear fuel in 2017, and (3) it would complete the process by 2055. Each 

time extension adds to the federal government’s liability.

Experts and stakeholders in the area of spent nuclear fuel management, 

including DOE and other government officials, identified four major types 

of challenges to the federal government’s ability to meet DOE’s time 

frames for managing spent nuclear fuel at consolidated interim storage 

facilities. First, DOE does not have legislative authority to fully implement 

its strategy, although DOE officials said they are conducting some 

planning activities that are allowed by the NWPA. Second, the licensing 

process could take more time than DOE has allowed. Third, there are 

several technical challenges to transporting some spent nuclear fuel. 

Fourth, achieving sustainable public acceptance of transporting and 

storing spent nuclear fuel is a societal challenge that will need to be 

addressed irrespective of any policy that is implemented and that experts 

said DOE could mitigate with a coordinated outreach strategy. Figure 8 

summarizes the four major types of challenges identified by experts and 

stakeholders with whom we spoke.

Experts and 

Stakeholders 

Identified Challenges 

to and Suggestions 

for Managing Spent 

Nuclear Fuel at 

Interim Storage 

Facilities within 

DOE’s Time Frames
 

Page 20 GAO-15-141 Spent Nuclear Fuel Liability

Figure 8: Four Major Types of Challenges Identified By Experts and Stakeholders on Federal Efforts to Manage Spent Nuclear 

Fuel at Consolidated Interim Storage Facilities

In general, experts identified the legislative challenges as critical to 

implementing DOE’s strategy within the time frames proposed. In 

particular, the experts pointed out that new legislative authority is needed 

for developing interim storage that is not tied to Yucca Mountain, creating 

a new waste management organization, and providing predictable funding 

for carrying out spent nuclear fuel management. However, experts and 

stakeholders generally noted that because the Congress has not agreed 

on a new path forward for managing spent nuclear fuel since funding was 

suspended in 2010, nor have DOE officials proposed legislation 

requesting new authority, obtaining specific legislative authority in time to 

meet DOE’s proposed time frames might be challenging. 

DOE Does Not Have 

Legislative Authority

to Fully Implement

Its Strategy
 

Page 21 GAO-15-141 Spent Nuclear Fuel Liability

As we reported in November 2009 and August 2012,12

DOE’s strategy calls for a new waste management and disposal 

organization for managing spent nuclear fuel; however, Congress has not 

authorized such an organization. According to DOE, a new organization 

separate from DOE is needed to “provide stability, focus, and credibility to 

build public trust and confidence.” Industry representatives and 

presenters at a Bipartisan Policy Center Conference in 2014 agreed that 

DOE is not the right organization to implement its strategy because the 

public lacks confidence in the agency and its ability to move forward in 

managing spent nuclear fuel. In addition, an expert from industry said that 

a new organization designed to implement a consent-based process 

would be better suited to site a consolidated storage facility—a view that 

provisions in 

NWPA that authorize DOE to arrange for consolidated interim storage 

have either expired or are unusable because they are tied to milestones 

in the development of a repository at Yucca Mountain that have not been 

met. DOE officials and experts from industry agreed with this 

assessment, and they noted that the federal government’s ability to site, 

license, construct, and operate a consolidated interim storage facility is 

dependent upon new legislative authority. Some industry representatives 

we spoke with said that such authority would be needed by the end of 

2014 to meet DOE’s 2021 goal to begin operations at a pilot interim 

storage facility. DOE officials noted that their strategy is available to 

Congress and is intended to initiate discussions on developing a future 

path forward or future policy to be implemented. However, experts and 

stakeholders generally noted that there is not agreement between the 

House and Senate on a path forward, and therefore obtaining such 

authority in 2014 is unlikely. Pending such agreement, the agency has 

been planning what it can do, and the agency has undertaken some 

activities allowed under current authority to inform the development of an 

interim storage facility. For example, the agency is reviewing reports 

submitted by contractors in 2013 on design concept alternatives for a 

consolidated interim storage facility. DOE officials said, however, that the 

agency’s strategy could not be fully implemented until Congress provides 

direction on a path forward.

 

12GAO, Spent Nuclear Fuel: Accumulating Quantities at Commercial Reactors Present 

Storage and Other Challenges, GAO-12-797 (Washington, D.C.: Aug. 15, 2012) and 

Nuclear Waste Management: Key Attributes, Challenges, and Costs for the Yucca 

Mountain Repository and Two Potential Alternatives, GAO-10-48 (Washington, D.C.: Nov. 

4, 2009).

Siting, Licensing, Constructing, 

and Operating of Interim 

Storage Facilities Included

in DOE’s Strategy Have Not 

Been Authorized

Development of a New Waste 

Management and Disposal 

Organization Has Not

Been Authorized
 

Page 22 GAO-15-141 Spent Nuclear Fuel Liability

is generally consistent with one of our past matters for congressional 

consideration noting that an independent organization, outside DOE, 

could be more effective in siting and developing a permanent repository 

for the nation’s nuclear waste.13

However, experts from industry told us that even with congressional 

authorization, such an organization would take time to create, in part, 

according to an industry expert, because a new organization would need 

to acquire personnel, implement a quality assurance program, and 

develop an implementation plan. These could take from 2 to 5 years, 

according to the experts.

Similarly, the Blue Ribbon Commission 

on America’s Nuclear Future recommended establishing a new federal 

corporation or similar independent organization to implement, among 

other things, a consent-based siting process. Such an organization would 

be more effective because it would be less vulnerable to political 

interference, according to the commission.

In 2011, we reported that funding for DOE’s work related to Yucca 

Mountain was unpredictable, noting that DOE’s annual appropriations 

related to spent nuclear fuel management had varied by as much as 20 

percent from year to year;14 further, DOE’s average annual appropriations 

fell about $90 million short of the amount DOE requested each year.15 We 

reported that this unpredictability made long-term planning difficult, and 

we suggested that Congress may wish to consider whether a more 

predictable funding mechanism would enhance future spent nuclear fuel 

management efforts. According to experts from industry and community 

action groups we interviewed, having sufficient funds consistently 

available is essential for any spent nuclear fuel management effort. 

However, as noted earlier, there is not agreement on a path forward—

including developing a more predictable funding mechanism. DOE 

reported in 2001 that the budgetary requirements enacted by Congress,16

 

13GAO-11-229. 

14Established by the NWPA in 1983, DOE’s office responsible for spent nuclear fuel was 

in the Office of Civilian Radioactive Waste Management (OCRWM), which was dismantled 

when DOE terminated Yucca Mountain. Currently, DOE’s Office of Nuclear Energy is 

responsible for spent nuclear fuel related activities.

15GAO-11-229. 

16See Department of Energy, Office of Civilian Radioactive Waste Management, 

Alternative Means of Financing and Managing the Civilian Radioactive Waste 

Management Program, DOE/RW-0546 (Washington, D.C.: August 2001).

Funding for DOE’s Past

Work on Spent Nuclear

Fuel Management Was 

Unpredictable, and Experts 

Said More Predictability

Is Essential
 

Page 23 GAO-15-141 Spent Nuclear Fuel Liability

subsequent to the creation the Nuclear Waste Fund,17 reduced financial 

flexibility. These funding challenges were also echoed by the Blue Ribbon 

Commission, which recommended that a new, more predictable, funding 

mechanism be developed.18

Because the NRC licensing process is time consuming, it may be difficult 

for DOE or an alternative waste management and disposal organization 

to begin operations at a pilot interim storage facility in 2021 and a 

consolidated interim storage facility in 2025, as called for in DOE’s 

strategy. The NRC licensing process cannot begin until an interim storage 

site has been selected, which, as stated previously in this report, cannot 

happen under existing legislative authority. Some industry experts, as 

well as a scientist from a national laboratory, told us licensing an interim 

facility could be achieved within 5 to 7 years of site selection. Other 

industry experts and a community action group told us licensing will more 

likely be an 8- to 10-year process because of the potential for legal 

concerns raised by the public. Such concerns may originate with an 

environmental impact statement—such a statement is required before a 

license can be granted, and it allows for public input that may require 

adjudication. The NRC hearing process could also lengthen the licensing 

process. For example, in 2006, after a 9-year licensing process, a 

consortium of electric power companies called Private Fuel Storage 

obtained an NRC license for a private consolidated storage facility on an 

Indian reservation in Utah.19

 

17In return for the federal government’s taking responsibility for disposing of the spent 

nuclear fuel, the owners and operators agreed to make quarterly payments, beginning in 

1983, into a Nuclear Waste Fund statutorily established under NWPA. According to DOE, 

the current value of the fund is approximately $28.2 billion, which—until this year—

included annual deposits of approximately $750 million in fee collections and $1.5 billion in 

accrued interest.

As we previously reported, the delay in 

licensing Private Fuel Storage was due to state opposition and to 

challenges raised during the license review process.

18Blue Ribbon Commission on America’s Nuclear Future, Report to the Secretary of 

Energy (January 2012).

19Private Fuel Storage obtained a 20-year license from NRC with an option for an 

additional 20-year extension. The license allowed storage of up to 40,000 metric tons of 

commercial spent nuclear fuel. Though Private Fuel Storage was licensed in 2006, it 

never began operations, in part because of other land-use decisions restricting new 

construction.

Experts and Stakeholders 

Identified Regulatory 

Challenges Related to 

Licensing a Consolidated 

Interim Storage Facility
 

Page 24 GAO-15-141 Spent Nuclear Fuel Liability

Experts described technical challenges that could be resolved with 

sufficient time. In particular, there are uncertainties regarding 

transportation of spent nuclear fuel, including the uncertainties related to 

the safety of high burn-up fuel during transportation,20

According to some industry experts, more information is needed about 

how to safely store and transport high burn-up fuel. Before 2000, most 

fuel discharged from U.S. nuclear power reactors was considered low 

burn-up fuel, and consequently, the industry has had decades of 

experience in storing and transporting it. In addition, the first dry storage 

canisters were loaded in 1986. One of these, containing low burn-up fuel, 

was opened 15 years later and the spent nuclear fuel inspected. The 

spent nuclear fuel was found to be in good condition, giving NRC 

additional confidence in the safe storage and transport of spent nuclear 

fuel. According to NRC, there has been considerable analysis performed 

on high burn-up fuel, but because it has only been used for about the past 

10 years, there has been little testing performed on it. According to 

various reports from DOE, NRC, the Electric Power Research Institute, 

and the Nuclear Waste Technical Review Board, as well as experts we 

spoke with, uncertainties exist on how long high burn-up fuel can be 

stored and then still be safely transported. Once sealed in a canister, the 

spent fuel cannot easily be inspected for degradation.

 readiness of spent 

nuclear fuel to be transported under current guidelines, and sufficiency of 

the infrastructure to support transportation. In addition, there are 

uncertainties related to repackaging spent nuclear fuel for transportation. 

According to DOE officials, the agency is taking steps to begin addressing 

technical challenges, but not all of the challenges can be addressed until 

uncertainties regarding the path forward are resolved.

 

20Reactor fuel burn-up is a measure of the energy that has been produced by the fuel. 

High burn-up fuel generally has been in a reactor longer than low burn-up fuel and is 

defined as having a burn-up higher than 45,000-megawatt days per metric ton.

Experts and Stakeholders 

Identified Technical 

Challenges That Could Be 

Resolved over Time

High Burn-Up Fuel Has 

Uncertainties Related to

Long-term Storage and

Future Transportation
 

Page 25 GAO-15-141 Spent Nuclear Fuel Liability

Source: GAO analysis of data from the Electric Power Research Institute, NRC, the Nuclear Waste Technical Review Board, and 

Pacific Northwest National Laboratory. | GAO-15-141

As of August 2014, NRC officials told us that they had analyzed 

laboratory tests and models developed to predict the changes that occur 

during dry storage and the results indicate that high burn-up fuel will 

maintain its integrity over very long periods of storage and can eventually 

be safely transported. However, NRC officials said they continue to seek 

additional evidence to confirm their position that long-term storage and 

transportation of high burn-up spent nuclear fuel is safe. In an effort to 

obtain evidence confirming the test and modeling results, DOE and the 

Electric Power Research Institute have planned a joint development 

project to load a special dry cask storage system with high burn-up fuel in 

mid-2017 and, using instrumentation built into the cask, monitor the spent 

nuclear fuel over a period of about 10 years. At that point, DOE and the 

Electric Power Research Institute expect to transport the canister to an 

appropriate facility and open it to inspect the high burn-up fuel and its 

Description of Concerns Related to High Burn-Up Fuel

According to the Nuclear Regulatory Commission (NRC), burn up is 

considered as part of NRC’s reviews of spent nuclear fuel cask designs 

because each dry storage system has limits on temperature and radiation, 

both of which are higher for high burn-up fuel. While in the reactor, hydrogen 

gas is generated and is absorbed by the cladding. Then, during the transfer 

from wet to dry storage, the spent nuclear fuel is loaded into a storage cask, 

which is removed from the storage pool and drained of water to dry the fuel. 

During the drying process, the fuel heats up, dissolving the hydrogen in the 

cladding structure. While the spent nuclear fuel is still hot and the cladding is 

still supple, there is little uncertainty in storing or transporting it, as long as 

temperature and radiation limits are met. However, as the spent nuclear fuel 

cools over extended periods in dry storage, the dissolved hydrogen can 

change the characteristics of the cladding and, if certain conditions exist, can 

cause the cladding to become brittle over time. The extent of the changes in 

cladding depend on the burn-up of the fuel, the type of cladding, and the 

temperatures reached during the drying process, and need to be accounted 

for in the storage and transportation of high burn-up spent nuclear fuel. There 

is not the same level of concern about changes in the cladding causing 

brittleness with low burn-up fuel because not as much hydrogen becomes 

dissolved in the cladding. In addition, there is more data available on the 

performance of low burn-up fuel during storage, since low burn-up fuel has 

been stored for long periods.
 

Page 26 GAO-15-141 Spent Nuclear Fuel Liability

cladding, as well as the cask, for any indication of damage or 

degradation. According to DOE and the Electric Power Research 

Institute, the project’s execution has been planned through 2018 and 

many future elements of the project still need to be developed. Experts 

and stakeholders expressed various views regarding the level of 

uncertainty of the safe transportation of high burn-up fuel after long-term 

storage. But one theme conveyed during our discussions with them was 

that high burn-up fuel would continue to be stored in dry storage canisters 

without knowing how long the spent nuclear fuel would be stored or how 

safe future transportation would be. DOE officials stated that their 

strategy would not involve transportation of large amounts of high burn-up 

fuel until at least 2025 and that even then, there is likely going to be 

enough low burn-up fuel to ship for the first several years, giving more 

time for the development project to yield results.

Because the guidelines governing dry storage of spent nuclear fuel allow 

higher temperatures and external radiation levels than guidelines for 

transporting the fuel, some of the spent nuclear fuel in dry storage may 

not be ready to be moved to an interim storage facility in time to meet 

DOE’s time frames. For example, according to the Nuclear Energy 

Institute, as of 2012, only about 30 percent of spent nuclear fuel currently 

in dry storage is cool enough to be directly transportable. For safety 

reasons, transportation guidelines do not allow the surface of the 

transportation cask to exceed 185 degrees Fahrenheit (85 degrees 

Celsius) because the spent nuclear fuel is traveling through public areas 

using the nation’s public transportation infrastructure.21 NRC’s guidelines 

on spent nuclear fuel dry storage limit spent nuclear fuel temperature to

752 degrees Fahrenheit (400 degrees Celsius).22

 

21See NRC, Office of Nuclear Material Safety and Safeguards, Standard Review Plan for 

Transportation Packages for Spent Nuclear Fuel, NUREG-1617 (Washington, D.C.: March 

2000).

Reactor sites, where 

spent nuclear fuel dry storage systems are typically found, are usually in 

secluded areas with a buffer zone between the spent nuclear fuel and the 

public. Dry storage sites are also usually located so that workers and the 

public have minimal exposure to radiation from the spent nuclear fuel. 

According to experts from industry, spent nuclear fuel has typically been 

stored in large dry storage canisters to maximize storage capacity and 

22See NRC, Office of Nuclear Material Safety and Safeguards, Standard Review Plan for 

Spent Fuel Dry Storage Systems at a General License Facility, NUREG-1536 Rev.1 

(Washington, D.C.: July 2010).

Some Stored Spent 

Nuclear Fuel May Not Be 

Readily Transportable
 

Page 27 GAO-15-141 Spent Nuclear Fuel Liability

minimize costs. Spent nuclear fuel stored in the large canisters, however, 

may have temperatures that exceed the limits of transportation 

guidelines.

Scientists from the national laboratories and experts from industry 

suggested three options for dealing with the stored spent nuclear fuel so it 

can be transported safely: (1) the spent nuclear fuel may be left to cool 

and decay at reactor sites, (2) the spent nuclear fuel may be repackaged 

into smaller canisters that reduce the heat and radiation, or (3) a special 

transportation “overpack” may be developed to safely transport the spent 

nuclear fuel in the current large canisters. Since Congress has not agreed 

on a new path forward since funding was suspended in 2010, it may be 

difficult to assess the options.

In a 2013 report, DOE states that the preferred mode for transporting 

spent nuclear fuel to a consolidated interim storage facility would be rail.

23

 

23See DOE, Office of Fuel Cycle and Research Development, A Project Concept for 

Nuclear Fuels Storage and Transportation, FCRD-NFST-2013-000132 Rev. 1 (June 15, 

2013).

However, several experts from industry pointed out that not all of the 

spent nuclear fuel currently in dry storage is situated near rail lines; also, 

one of these experts said that procuring qualified rail cars capable of 

transporting spent nuclear fuel will be a lengthy process. Storage sites 

without access to a rail line may require upgrades to the transportation 

infrastructure or alternative modes of transportation to the nearest rail 

line. Constructing new rail lines or extending existing rail lines could be a 

time-consuming and costly endeavor. In addition, an industry official 

noted that if spent nuclear fuel were trucked to the nearest rail line, the 

federal government would have to develop a safe method of transferring 

the spent nuclear fuel from heavy haul trucks onto rail cars. In September 

2013, DOE completed a preliminary technical evaluation of options 

available and needed infrastructure for DOE or a new waste management 

and disposal organization to transport spent nuclear fuel from shut-down 

sites to a consolidated interim storage facility. According to DOE officials, 

currently there is no need to make a decision regarding how best to move 

forward with the study results because there is, at this time, no site and 

Current Transportation 

Infrastructure May Not

Be Adequate
 

Page 28 GAO-15-141 Spent Nuclear Fuel Liability

no authorization to site, license, construct, and operate a consolidated 

interim storage facility.24

Source: DOE. | GAO-15-141

A DOE official and experts from industry also told us that DOE needs to 

begin procuring qualified rail cars capable of transporting spent nuclear 

fuel. DOE officials stated that the agency is beginning to request 

information from the rail car industry on the rail car design, testing, and 

approval for the transportation of commercial spent nuclear fuel and 

anticipates getting responses from interested parties by July 2014. 

According to an industry representative, the Association of American 

Railroads established the S-2043 standard, which sets higher standards 

for transportation of spent nuclear fuel than for normal rail operations. S2043 requires, for example, on-board safety protection technology unique 

to spent nuclear fuel shipments and a high performance structural 

upgrades to accommodate the extra weight of spent nuclear fuel as well 

as the transportation cask, which according to the industry representative, 

can weigh up to 500,000 pounds. Industry experts said it may be 

 

24See DOE, Preliminary Evaluation of Removing Used Nuclear Fuel from Shutdown Sites, 

PNNL-22676 Rev.1 (Sep. 30, 2013)

DOE’s Preliminary Evaluation of Removing Spent Nuclear Fuel from 

Shutdown Sites

DOE’s “Preliminary Evaluation of Removing Used Nuclear Fuel from 

Shutdown Sites” looked at 12 permanently shutdown sites, which included 

Maine Yankee, Yankee Rowe, Connecticut Yankee, Humboldt Bay, Big Rock 

Point, Rancho Seco, Trojan, La Crosse, Zion, Crystal River, Kewaunee, and 

San Onofre. The evaluation found that some shut-down sites, because the 

facilities have been decommissioned and lack onsite infrastructure, required 

multiple transportation modes such as heavy-haul-truck to rail, barge to rail, 

and in the cases of Kewaunee and Humboldt Bay, potentially heavy-haultruck to barge to rail. For example, Trojan’s rail spur was removed during the 

decommissioning process and Big Rock Point will probably need to truck its 

spent nuclear fuel 52 miles to Gaylord, Michigan. Some of the sites evaluated 

have no rail spur, and heavy haul trucking will be required for anywhere from 

7.5 miles to potentially 260 miles, depending on the site.
 

Page 29 GAO-15-141 Spent Nuclear Fuel Liability

challenging to design and fabricate rail cars that meet the S-2043 

standard for transporting heavy, fully loaded spent nuclear fuel canisters 

within DOE’s time frames. According to industry experts, it will take, at a 

minimum, 2 years to design and fabricate a new rail car, in addition to an 

extensive quality control process to ensure the car meets the S-2043 

standard. For example, an industry representative estimated that the 

entire rail car procurement process may take up to 9 years and another 

agreed that it may be feasible to begin to move the spent fuel by 2025 if 

DOE initiates the necessary planning soon. Another option would be for 

DOE to use what the U.S. Navy has learned from its rail cars designs for 

its nuclear navy program, which also generates spent nuclear fuel. DOE 

officials told us they would consider this suggestion as they proceed.

According to experts, some spent nuclear fuel in dry storage may need to 

be repackaged before it can be transported, and the repackaging is likely 

to be costly and difficult to accomplish. More specifically, as noted earlier, 

some dry storage canisters may be too hot or radioactive to meet 

transportation regulations. If the decision were made to transport the 

spent nuclear fuel before it had a chance to cool sufficiently, the canisters 

may have to be repackaged into smaller canisters that meet the 

transportation regulations. In addition, an industry expert and an expert 

from a community action group told us repackaging may also be required 

if current storage canisters, or the spent nuclear fuel in them, has 

degraded. For example, we previously reported that canisters are likely to 

last about 100 years,25 after which the spent nuclear fuel may have to be 

repackaged because of canister degradation.26

 

25

By the time such 

repackaging might be needed, reactor operators may no longer have 

pools or the necessary infrastructure to undertake the repackaging.

GAO-10-48. 

26In 2010, NRC updated its waste confidence decision and accompanying interim storage 

rule supporting generic findings of the impacts of storing spent nuclear fuel beyond the 

licensed life for operation of a nuclear power plant. The 2010 determination found, among 

other things, that spent nuclear fuel can be stored safely and without significant 

environmental impacts for at least 60 years beyond the licensed life of a reactor. In 2012, 

the U.S. Court of Appeals for the District of Columbia Circuit held that the rulemaking 

required either an environmental impact statement or a finding of no significant 

environmental impact and remanded the determination and rule back to NRC for further 

analysis. NRC subsequently completed a generic environmental impact statement and 

published final revisions to the rule on September 19, 2014. 

Repackaging Requirements, 

If Any, Are Uncertain
 

Page 30 GAO-15-141 Spent Nuclear Fuel Liability

According to DOE, under provisions of the standard contract, the agency 

does not consider spent nuclear fuel in canisters to be an acceptable form 

for waste it will receive. This may require utilities to remove the spent 

nuclear fuel already packaged in dry storage canisters. Nuclear power 

reactors that have closed their spent nuclear fuel pools would likely have 

to transport their spent nuclear fuel to operating reactors with pools, build 

a new pool, or repackage it in a yet-to-be-developed dry transfer facility. 

Cutting open these canisters is likely to be an expensive process for 

utilities that would require using specialized equipment to open welded 

lids, placing the assemblies back into a wet pool, and then packaging the 

assemblies into a new cask that DOE would provide under the terms of 

the standard contract. Such a process would require personnel and 

equipment, increase worker radiation exposure, increase the potential for 

fuel damage, produce additional low level waste,27 and, may, according to 

an industry expert, hinder electricity generating activities. In addition, 

another industry expert also expressed concerns that re-wetting and redrying during the repackaging process may lead to cladding degradation 

issues. However, NRC officials stated that prior to NRC’s granting a 

storage license, each system is analyzed by the applicant and reviewed 

by the NRC to ensure it can be re-flooded safely with no damage to the 

spent fuel. Until decisions have been made regarding a new path 

forward—storage and disposal—repackaging requirements will remain 

uncertain. However, according to scientists from national laboratories, 

given a path forward, technical challenges, such as repackaging, can be 

overcome with time and sufficient funding.

 

27Low-level waste can range from just-above-natural background levels to much higher 

levels and generally consists of equipment used in day-to-day management of radioactive 

materials. Some examples include radioactively contaminated cleaning rags, mops, filters, 

protective shoe covers, and protective clothing.
 

Page 31 GAO-15-141 Spent Nuclear Fuel Liability

Experts and stakeholders with expertise in spent nuclear fuel 

management identified achieving sustainable public acceptance as a 

challenge that needs to be overcome to implement a spent nuclear fuel 

management program, and they stated that public acceptance cannot be 

achieved without a coordinated outreach strategy.

Reports spanning several decades cite societal and political opposition as 

key obstacles to siting and building a permanent repository for disposal of 

spent nuclear fuel. For example, in 1982, the congressional Office of 

Technology Assessment28 reported that public and political opposition 

were key factors to siting and building a repository.29 The National 

Research Council of the National Academies reiterated this conclusion in 

a 2001 report, stating that the most significant challenge to siting and 

commencing operations at a repository is societal.30

This lesson has been borne out in efforts to site, license, build, and 

commence operations at a consolidated interim storage facility. As we 

reported in 2011 and as experts and stakeholders reiterated, it may be 

possible to find a willing community to host a consolidated interim storage 

facility, but obtaining and sustaining state support may be more difficult 

because of broader state constituencies and state-federal relations. For 

example, the Office of the Nuclear Waste Negotiator, established by the 

Our analysis of 

stakeholder and expert comments indicates the societal and political 

factors opposing a repository are the same for a consolidated interim 

storage facility.

 

28The Office of Technology Assessment was an office of Congress from 1972 to 1995 that 

provided congressional members and committees with analysis of scientific and technical 

issues.

29Office of Technology Assessment, Managing Commercial High-level Radioactive Waste

(Washington, D.C.: 1982).

30National Research Council of the National Academies, Disposition of High-Level Waste 

and Spent Nuclear Fuel: The Continuing Societal and Technical Challenges (Washington, 

D.C.: 2001).

Experts and Stakeholders 

Said Developing Interim 

Storage Facilities 

Depends on Achieving 

Sustainable Public 

Acceptance, Which May 

Be Difficult without a 

Coordinated Outreach 

Strategy

Development of Interim 

Storage Facilities Depends 

on Achieving Sustainable 

Public Acceptance
 

Page 32 GAO-15-141 Spent Nuclear Fuel Liability

NWPA amendments in 1987, tried to broker an agreement for a 

community to host a repository or interim storage facility. Two negotiators 

worked with local communities and Native American tribes for several 

years, but neither was able to conclude a proposed agreement with a 

willing community by January 1995, when the office’s authority expired. In 

one siting effort, in 1992, a county in Wyoming sought to host a 

consolidated interim storage facility, but the Wyoming governor stopped 

that effort. The governor expressed concerns that despite the assurances 

of federal officials, even those with “personal integrity and sincerity,” he 

could not be sure that the federal government’s attitudes or policies would 

remain the same over the next 50 years or that the state would have any 

future say in the program. The experience of Private Fuel Storage is 

another example in which a consortium of owners and generators of 

spent nuclear fuel found a willing community to host a consolidated 

interim storage site on the Goshute Indian reservation in Utah. The state 

of Utah opposed the effort and although the Private Fuel Storage site 

received a license in 2006, operations never began there because of 

ongoing legal battles and land use issues. A spokesperson for the State 

of Utah stated that if the owners and generators renewed their efforts to 

begin operations at Private Fuel Storage, Utah would continue to fight the 

effort. Furthermore, in 2014, the Western Governors Association—an 

association representing 19 western states—passed a resolution stating 

that the Governor of a state must agree in writing if an interim storage site 

for spent nuclear fuel is to be considered in the state. Experts and 

stakeholders we spoke with reiterated this position, stating that states, 

and many local communities, are concerned that a consolidated interim 

storage site could become a de facto permanent storage site.

In 2011, we reported that no nation had ever succeeded in building a 

permanent repository for spent nuclear fuel, in part due to societal 

concerns, and that there was no model or set of lessons that would 

guarantee success in such a complex, decades-long endeavor.31

 

31

Based 

on our discussions with experts and stakeholders and a review of relevant 

documents on spent nuclear fuel management, those same societal 

concerns apply to building a consolidated interim storage facility. 

However, as we reported in 2011, efforts to site and commence 

operations at the Waste Isolation Pilot Plant in New Mexico succeeded 

largely because a contractor addressed public opposition to the facility. 

GAO-11-229. 
 

Page 33 GAO-15-141 Spent Nuclear Fuel Liability

Specifically, the contractor involved local communities situated along the 

transportation routes throughout the state, providing education and 

training programs and equipment related to the safe transportation of 

radioactive waste.32

In our discussions with experts and stakeholders, one common theme 

was apparent: public acceptance cannot be achieved without a 

coordinated outreach strategy, which would include components such as 

transparent transportation planning, and a defined consent-based 

process. According to these experts and stakeholders, a coordinated 

outreach strategy could include, among other things, sharing information 

with specific stakeholders and the general public about DOE’s ongoing 

activities related to managing spent nuclear fuel. The experts and 

stakeholders said that DOE has no coordinated outreach strategy, which 

DOE officials confirmed. A coordinated outreach strategy would be an 

important aspect of informing the public about spent nuclear fuel 

management plans and DOE’s current management efforts irrespective of 

which path Congress agrees upon.

The project might have ended because of state 

opposition if DOE had not conceded some oversight authority to the state.

DOE officials confirmed that they do not have a coordinated outreach 

strategy for communicating with specific stakeholders and the general 

public about their activities related to spent nuclear fuel management. 

Instead, DOE officials said they communicate regularly with certain 

stakeholders. For example, DOE officials told us that they actively obtain 

the input of state and tribal representatives on spent nuclear fuel 

transportation-planning issues. In addition, DOE officials told us they plan 

to continue to participate in meetings with technical experts and industry 

stakeholders and to post information online. For example, DOE officials 

made several presentations on issues related to storage, transportation, 

and disposal at the Nuclear Waste Technical Review Board’s meeting in 

November 2013. Some experts we spoke with were critical of DOE efforts 

to involve stakeholders. For example, experts who represent multi-state, 

regional organizations active in spent-nuclear-fuel transportation planning 

said DOE has not been transparent or effective in its communication with 

stakeholders. Furthermore, although DOE had issued fact sheets related 

to spent nuclear fuel management related to work on Yucca Mountain, 

DOE has not recently developed spent nuclear fuel information for the 

 

32GAO-11-229. 

Experts and Stakeholders

Said Coordinated Outreach 

May Help Achieve and

Sustain Public Acceptance
 

Page 34 GAO-15-141 Spent Nuclear Fuel Liability

general public, such as a fact sheet explaining issues related to 

transporting spent nuclear fuel, nor does DOE have plans to do so in the 

upcoming fiscal year. DOE officials said that recently they have stepped 

up their outreach efforts with stakeholders. For example, in April 2014, 

DOE completed a Draft National Transportation Plan for moving spent 

nuclear fuel.

In terms of DOE’s efforts to inform specific stakeholders and the general 

public about spent nuclear fuel issues by posting information online, DOE 

has two websites devoted to spent nuclear fuel issues. However, we 

found that the information on those sites either does not provide 

information about the agency’s ongoing activities or is not easily 

accessible.33 DOE also has an online library where it has posted selected 

technical studies;

34

According to experts from industry and an entity representing state 

regulatory agencies, DOE officials have not defined a consent-based 

process or engaged interested communities in discussions on hosting a 

consolidated interim storage facility. An expert from an entity representing 

however, the agency has done little to explain how it 

plans to use these studies. DOE officials acknowledged that they could 

better explain the studies posted. They indicated that it is premature to 

conduct more extensive public outreach until the timing and logistics of 

transporting spent nuclear fuel have been determined. Experts from multistate organizations disagree, stating that if DOE does not engage the 

public soon, then DOE could appear to be unilaterally making decisions 

without considering public input.

 

33One website is for DOE’s Nuclear Fuels Storage and Transportation Planning Project 

that among other things, plans for and implements the agency’s activities related to the 

transportation and storage aspects of its strategy and lists four documents: (1) the Blue 

Ribbon Commission on America’s Nuclear Future Report to the Secretary of Energy, (2) 

DOE’s Strategy for the Management and Disposal of Used Nuclear Fuel and High-Level 

Radioactive Waste, (3) DOE’s Preliminary Evaluation of Removing Used Nuclear Fuel 

From Shutdown Sites, and Public Preferences Related to Consent-Based Siting of 

Radioactive Waste Management Facilities for Storage and Disposal. The website is 

available at http://energy.gov/ne/fuel-cycle-technologies/nuclear-fuels-storagetransportation-planning-project. The other website—known as the Centralized Used Fuel 

Resource for Information Exchange website—was launched in March 2013 and shares 

documents and data about the storage, transportation, and disposal of spent nuclear fuel. 

However, as of July 2014, the website is not readily accessible from DOE’s website and 

must be found using public search engines, such as Google. This second website is 

available at http://curie.ornl.gov. 

34The library can be found at http://energy.gov/ne/listings/document-library. 
 

Page 35 GAO-15-141 Spent Nuclear Fuel Liability

state regulatory agencies said that in order to consent, potential host 

communities need to know what consent entails, both in the short and 

long term, including the perceived risks and benefits and the planned 

duration and proposed capacity of the facility before any decisions can be 

made. Furthermore, a few experts told us that they had heard of some 

community representatives who approached DOE to express their 

interest in hosting a storage facility, but DOE did not engage in 

substantive discussions with them. DOE has requested funding in its 

fiscal year 2014 and 2015 budget requests to plan for consent-based 

siting, but DOE officials said they had not developed a formal siting 

process for an interim storage facility.

A 2013 report by the University of Oklahoma, in collaboration with Sandia 

National Laboratory, documented the importance of social media,35 such 

as Twitter postings and Google searches, as public attention to both 

nuclear energy and nuclear waste management spiked immediately after 

the earthquake and tsunami struck the Fukushima Daiichi nuclear power 

plant complex in Japan on March 11, 2011, causing widespread concern 

of a potential release of radiation.36

 

35Prepared for DOE, Nuclear Fuel Storage and Transportation Planning Project, Public 

Preferences Related to Consent-Based Siting of Radioactive Waste Management 

Facilities for Storage and Disposal: Analyzing Variations over Time, Events, and Program 

Designs; (February 2013).

Furthermore, according to experts 

and stakeholders, social media have been used effectively to provide 

information to the public through coordinated outreach efforts by 

organizations with an interest in spent nuclear fuel policy. Some of these 

organizations oppose DOE’s strategy and the information they distribute 

reflects their position. In the absence of a coordinated outreach strategy 

by DOE, including social media, DOE does not effectively provide a forum 

to share information and offer greater transparency. DOE promotes the 

use of social media platforms to engage in open discussions about 

energy issues, but has posted only a few reports and descriptions of 

spent nuclear fuel management on its web page.

36As reported by the Institute of Nuclear Power Operations (Institute of Nuclear Power 

Operations, Special Report on the Nuclear Accident at the Fukushima Daiichi Nuclear 

Power Station (Atlanta, GA: November 2011), Tokyo Electric Power Company personnel 

determined that water levels in the spent fuel pool at Fukushima Daiichi did not drop 

below the top of the fuel. An NRC order noted that during the Fukushima event, there was 

concern that the spent fuel was overheating, and the concern persisted primarily because 

of a lack of readily available and reliable information on water levels in spent fuel pools. 
 

Page 36 GAO-15-141 Spent Nuclear Fuel Liability

Experts and stakeholders suggested that it would be beneficial for DOE to 

begin developing a plan and materials for communicating with the specific 

stakeholders and the general public about the benefits and concerns with 

issues related to moving and storing spent nuclear fuel. An expert from a 

multi-state organization added a particular focus should be on the

communities, including elected officials, living near shutdown sites. Such 

communication would be consistent with the Office of Management and 

Budget’s Open Government Directive, which directs agencies to create 

and institutionalize a culture of transparency, participation, and 

collaboration in order to create a more open government.37 Furthermore, 

as we reported previously in 2011 on lessons learned from spent nuclear 

fuel management,38 we found that transparency and cooperation are 

important in overcoming opposition to spent nuclear fuel storage. Without 

greater transparency and a coordinated outreach program, specific 

stakeholders and the general public may not have confidence in DOE’s 

efforts to manage spent nuclear fuel and may continue to distrust DOE.

DOE has made efforts to share information about its ongoing spent 

nuclear fuel management activities by presenting at technical meetings 

and posting information on its website. Sharing information is made more 

difficult for DOE by uncertainties about the future path of spent nuclear 

fuel management. DOE intends for its strategy to provide an initial basis 

for discussions on a sustainable path forward. Until the federal 

government proceeds with a new policy to meet its contractual 

obligations, the federal liability for litigation related to spent nuclear fuel 

management will continue to grow. Our analysis of expert and 

stakeholders comments indicates four types of challenges to 

implementing DOE’s January 2013 strategy to manage spent nuclear fuel 

within the time frames projected. DOE has begun to address aspects of 

these challenges, but the challenges cannot be fully addressed until 

uncertainties regarding a path forward are resolved. The societal 

challenge of building and sustaining public acceptance of the federal 

government’s spent nuclear fuel management activities, however, will 

need to be addressed irrespective of the path the federal government 

 

37Office of Management and Budget, Memorandum for the Heads of Executive 

Departments and Agencies, Open Government Directive (Washington, D.C.: Dec. 8, 

2009).

38GAO-11-229. 

Conclusions
 

Page 37 GAO-15-141 Spent Nuclear Fuel Liability

agrees upon. Unless and until there is a broad understanding of the 

issues associated with transporting spent nuclear fuel and managing it at 

consolidated facilities, specific stakeholders and the general public may 

be unlikely to support any spent nuclear fuel management program that is 

decided on in the future. According to experts and stakeholders,

organizations that oppose DOE’s strategy have reached the public by 

effectively using social media to promote their positions. In contrast, DOE 

currently has no coordinated outreach strategy. In the absence of a 

coordinated outreach strategy by DOE, specific stakeholders and the 

general public may not have complete and accurate information about the 

agency’s activities, making it more difficult for the federal government to 

move forward with any policy to manage spent nuclear fuel and address 

federal liability.

To help achieve and sustain public acceptance for future spent nuclearfuel management efforts, the Secretary of the Department of Energy 

should develop and implement a coordinated outreach strategy for 

providing information to specific stakeholders and the general public on 

federal activities related to managing spent nuclear fuel.

We provided DOE with a draft of this report for review and comment. In 

written comments, which are reproduced in appendix VI, DOE generally 

agreed with our findings and the recommendation in our report. DOE said 

that it plans to continue to engage states, tribes, and other stakeholders 

regarding planning for future transportation of spent nuclear fuel and that 

it would improve its outreach to the general public. DOE also said it would 

make an effort to provide the public with more complete information about 

its ongoing activities and the issues associated with spent fuel 

management. DOE also provided technical comments, which we 

incorporated as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the appropriate 

congressional committees, the Secretary of Energy, the Administrator of 

the Environmental Protection Agency, the Attorney General, the 

Chairman of the Nuclear Regulatory Commission, the Secretary of 

Transportation, and other interested parties. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov. 

Recommendation for 

Executive Action

Agency Comments
 

Page 38 GAO-15-141 Spent Nuclear Fuel Liability

If you or your staff members have any questions about this report, please 

contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. Key contributors to this report are listed in 

appendix VII.

Frank Rusco

Director

Natural Resources and Environment
Appendix I: Objectives, Scope, and 

Methodology

Page 39 GAO-15-141 Spent Nuclear Fuel Liability

To describe the expected rate of spent nuclear fuel accumulation in wet 

and dry storage, we obtained data from the Nuclear Energy Institute, an 

industry policy umbrella organization. These data included information on 

the amounts of spent nuclear fuel currently in wet and dry storage and 

projected amounts of spent nuclear fuel to be added to the current wet 

and dry storage inventory as it is removed from a reactor until it is 

permanently shut down. We updated the data as necessary to account 

for, among other things, reactors shutting down early. In describing the 

rate at which spent nuclear fuel accumulates, we assumed that except for

the few reactors that have announced early permanent shutdown dates, 

the nation’s current reactors continue to operate through a 20-year 

extended license period and continue to produce spent nuclear fuel at the 

same rate; that no new reactors are brought online, and that the 

generation of spent nuclear fuel declines as reactors shut down. To 

ensure the accuracy of our estimates, we provided selected sections of 

the draft report to representatives from the Nuclear Energy Institute for 

their review and comment. We incorporated their comments, as 

appropriate, in the final report.

To identify the basis of federal liability for spent nuclear fuel management 

to date and of DOE’s estimate of future liabilities, we reviewed documents 

from the Departments of Energy (DOE) and Justice. These documents 

included a generic Department of Justice settlement agreement, DOE’s 

annual memorandums that described the liability estimate, and DOE’s 

annual financial reports that include the figures on the cumulative 

amounts paid to settle with utilities for DOE’s inability to accept spent 

nuclear fuel for disposal and the estimated remaining liability. In addition, 

we interviewed officials from DOE and the Department of Justice. We 

also relied on our prior work (GAO-10-48) to provide information on the 

typical costs that may contribute to the federal government’s future 

liabilities. To ensure that we had complete and accurate information on 

these costs, we provided selected sections of the draft report to 

representatives from the Nuclear Energy Institute for their review and 

comment. We incorporated their comments, as appropriate, in the final 

report.

To assess the challenges, if any, that experts and stakeholders have 

identified to the federal government’s ability to meet DOE’s time frames 

for managing spent nuclear fuel at consolidated interim storage facilities 

and potential ways for DOE to mitigate the challenges, we identified 

individuals with spent nuclear fuel management experience and 

expertise. In our prior work (GAO-10-48), we had already identified 

experts in spent nuclear fuel management. Starting with this group and 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-15-141 Spent Nuclear Fuel Liability

using a snowballing technique, we asked experts about their own 

expertise and also asked each expert or stakeholder to recommend other 

individuals that we might consider including in our discussions. We 

determined that we had a sufficient sample of relevant experts and 

stakeholders when the names of experts and stakeholders recommended 

to us became repetitive and when we determined that we had a balanced 

set of viewpoints represented. In total, we interviewed over 90 individuals, 

including federal officials, who represented a wide range of viewpoints 

and expertise. However, our selection of experts is nongeneralizable, in 

that opinions cannot be generalized to other experts or tallied, either 

within or across types of expertise.

Once identified, we contacted the individuals and confirmed their 

familiarity with the issues. Before we began each interview, we asked the 

individual to provide information on his or her background, including 

education, employment history, and experiences related to spent nuclear 

fuel management to assess their level of expertise. In addition, we asked 

all interview participants to self-assess their expertise in various aspects 

of spent nuclear fuel management such as the political, technological, 

and regulatory issues related to spent nuclear fuel management. Using 

our professional judgment, we assessed the level of expertise for each 

individual in the different issues we considered in our analysis. Opinions 

of experts on a topic outside their own area of expertise are sometimes 

presented as the opinions of “stakeholders.” In some cases, the same 

individual might be considered an expert in one specific issue, but a 

stakeholder on another issue.

Generally, the experts and stakeholders represented their organization’s 

views. The experts and stakeholders we consulted included:

• DOE in headquarters, field offices, and scientists from several 

national laboratories, including Argonne National Laboratory, Oak 

Ridge National Laboratory, Pacific Northwest National Laboratory, 

and Sandia National Laboratories;

• officials from other federal agencies and organizations involved with 

spent nuclear fuel management activities, including the Department of 

Navy, the Nuclear Regulatory Commission, and the Nuclear Waste 

Technical Review Board;

• state, local, and regional governments or organizations, including the 

states of Nevada, Texas, and Utah; the State of Minnesota Public 

Utilities Commission; Eddy County, New Mexico; and Nye County, 

Nevada; Council of State Governments, Eastern Regional 
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-15-141 Spent Nuclear Fuel Liability

Conference; National Association of Regulatory Utility 

Commissioners; the National Conference of State Legislatures; 

Southern States Energy Board; The Council of State Governments, 

Midwestern Office; Western Governors’ Association; Western 

Interstate Energy Board;

• industry: including AHL Consulting; AREVA; Association of American 

Railroads; Chicago Bridge & Iron; Dairyland Power Cooperative; 

Dominion; Duke Energy; Energy Resources International, Inc.; Energy 

Solutions, Inc.; Exelon Corporation; Kouts Consulting; L. Barrett 

Consulting; Nuclear Energy Institute; Nuclear Waste Strategy 

Coalition; Pillsbury Winthrop Shaw Pittman LLP; PSEG Nuclear, LLC; 

Tennessee Valley Authority; The Brattle Group; Governmental 

Strategies, Inc.; The Yankee Nuclear Power Companies: Yankee 

Atomic, Connecticut Yankee, and Maine Yankee; Van Ness Feldman 

LLP; and Xcel Energy;

• representatives from a range of interest groups, including Beyond 

Nuclear, Institute for Energy and Environmental Research, Natural 

Resources Defense Council, Nuclear Information and Resource 

Service, Southwest Research and Information Center, Union of 

Concerned Scientists, U.S. Chamber of Commerce – Institute for 21st 

Century Energy; and

• independent entities, including Black Mountain Research; Carnegie 

Institution for Science; Kadak Associates; Leroy Law Office; National 

Research Council, National Academy of Sciences; TA Frazier LLC; 

and University of Oklahoma.

To ensure we asked consistent questions among all the indentified 

experts and stakeholders, we developed a data collection instrument that 

included broad questions related to the challenges, if any, to the federal 

government’s ability to meet DOE’s time frames for accepting spent 

nuclear fuel at consolidated interim storage facilities. We pre-tested the 

instrument with a few individual experts and stakeholders to ensure that 

our questions were clear and would provide us with the information that 

we needed. After each pretest, we refined the instrument, accordingly. 

We analyzed the interviews to identify consistent themes and issues that 

emerged. See appendix II for a list of the experts and stakeholders whom 

we interviewed and their affiliations.

In addition to the interviews, we reviewed relevant documents, such as 

DOE’s January 2013 strategy for the management and disposal of used 

nuclear fuel and high level waste and the January 2012 Blue Ribbon 

Commission on America’s Nuclear Future’s report to the Secretary of 
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-15-141 Spent Nuclear Fuel Liability

Energy. We also reviewed documents prepared by the organizations that 

we interviewed and attended conferences sponsored by relevant 

organizations, including

• the U.S. Nuclear Waste Technical Review Board’s Technical 

Workshop on the Impacts of Dry Storage Canister Designs on the 

Future Handling, Storage, Transportation, and Geologic Disposal of 

Spent Nuclear Fuel in the United States;

• the Nuclear Energy Institute’s Used Fuel Management Conference; 

and

• the Bipartisan Policy Center’s regional meeting of Identifying a Path 

Forward on America’s Nuclear Waste.

We also interviewed officials from the Department of Transportation and 

the Environmental Protection Agency. According to officials from these 

agencies, each agency has a specified role with respect to regulating 

transportation and interim storage of spent nuclear fuel. According to 

Department of Transportation officials, the agency coordinates and 

shares responsibility with the NRC on issues related to transporting spent 

nuclear fuel as stipulated in a memorandum of understanding between 

the two agencies. According to Environmental Protection Agency officials, 

the agency has a regulatory framework in place for storage of spent

nuclear fuel that will allow NRC to license interim storage facilities.

We conducted this performance audit from November 2013 to October

2014, in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Spent Nuclear Fuel Experts and 

Stakeholders We Interviewed

Page 43 GAO-15-141 Spent Nuclear Fuel Liability

Name Affiliation

1. Lake Barrett L. Barrett Consulting

2. Evaristo J. (Tito) Bonano Sandia National Laboratories

3. David Boyd State of Minnesota Public Utilities Commission

4. William Boyle Department of Energy

5. Tom Brookmire Dominion

6. John Butler Nuclear Energy Institute

7. Robert (Bob) Capstick The Yankee Nuclear Power Companies: Yankee Atomic, Connecticut Yankee, 

and Maine Yankee

8. Jack Clemmens Chicago Bridge & Iron

9. Pamela Cowan Exelon Corporation

10. Susan Crockett Eddy County, New Mexico

11. Martha Crosland Department of Energy

12. Kevin Crowley National Research Council, National Academy of Sciences

13. Matthew (Matt) Crozat Department of Energy

14. Kris Cummings Nuclear Energy Institute

15. Peter Davies Sandia National Laboratories

16. Alan Denko Department of Navy

17. Fred Dilger Black Mountain Research

18. Geoffrey (Geoff) Fettus Natural Resources Defense Council

19. Tim Frazier TA Frazier LLC

20. Derrick Freeman Nuclear Energy Institute

21. Bob Fronczak Association of American Railroads

22. James George Department of Energy

23. John Gercy Dominion

24. Mariko Geronimo The Brattle Group

25. Ellen Ginsberg Nuclear Energy Institute

26. Frank Graves The Brattle Group

27. Christopher Guith U.S. Chamber of Commerce – Institute for 21st Century Energy

28. Kuhika Gupta University of Oklahoma

29. Brian Gustems PSEG Nuclear, LLC

30. Robert Halstead State of Nevada

31. Don Hancock Southwest Research and Information Center

32. Brady Hanson Pacific Northwest National Laboratory

33. Christopher (Chris) Hanson Department of Energy

34. Scott Hendrick National Conference of State Legislatures

35. Nate Hickman State of Texas

36. Brian Holian Nuclear Regulatory Commission

Appendix II: Spent Nuclear Fuel Experts and 

Stakeholders We Interviewed
Appendix II: Spent Nuclear Fuel Experts and 

Stakeholders We Interviewed

Page 44 GAO-15-141 Spent Nuclear Fuel Liability

Name Affiliation

37. Rob Howard Oak Ridge National Laboratory

38. Lisa Janairo The Council of State Governments, Midwestern Office

39. Josh Jarrell Oak Ridge National Laboratory

40. Hank Jenkins-Smith University of Oklahoma

41. Bradley Jones Nuclear Regulatory Commission

42. Steve Jones Nuclear Regulatory Commission

43. Andrew Kadak Kadak Associates

44. Kevin Kamps Beyond Nuclear

45. Christopher Kouts Kouts Consulting

46. Darrell Lacy Nye County, Nevada

47. Doug Larson Western Interstate Energy Board

48. Ned Larson Department of Energy

49. David Leroy Leroy Law Office

50. Adam Levin AHL Consulting

51. Mark Lombard Nuclear Regulatory Commission

52. Edwin Lyman Union of Concerned Scientists

53. Arjun Makhijani Institute for Energy and Environmental Research

54. Zita Martin Tennessee Valley Authority

55. Ben McRae Department of Energy

56. Rodney (Rod) McCullum Nuclear Energy Institute

57. Katrina McMurrian Nuclear Waste Strategy Coalition

58. Richard Meserve Carnegie Institution for Science

59. Mike Morrissey State of Texas

60. Nigel Mote Nuclear Waste Technical Review Board

61. Paul Murray AREVA 

62. Connie Nakahara State of Utah

63. Steve Nesbit Duke Energy

64. Cyrus Nezhad Department of Energy

65. Robert Nordhaus Van Ness Feldman LLP

66. Mark Nutt Argonne National Laboratory

67. Brian O’Connella National Association of Regulatory Utility Commissioners

68. Mary Olson Nuclear Information and Resource Service

69. Rob Palmberg Dairyland Power Cooperative

70. Aaron Perea Department of Energy

71. Christopher (Chris) Phillips Energy Solutions, Inc.

72. Terry Pickens Xcel Energy

73. Lara Pierpoint Department of Energy
Appendix II: Spent Nuclear Fuel Experts and 

Stakeholders We Interviewed

Page 45 GAO-15-141 Spent Nuclear Fuel Liability

Name Affiliation

74. Everett Redmond Nuclear Energy Institute

75. James Rubenstone Nuclear Regulatory Commission

76. Chris Scolari Western Governors’ Association

77. Jay Silberg Pillsbury Winthrop Shaw Pittman LLP

78. Tim Smith Governmental Strategies, Inc.

79. Norman St. Amour Nuclear Regulatory Commission

80. Eileen Supko Energy Resources International, Inc.

81. Peter Swift Sandia National Laboratories

82. Sheiba Tafazzoli Nuclear Regulatory Commission

83. Jane Kelley Taylor Department of Energy

84. Leigh Trocine Nuclear Regulatory Commission

85. Uldis Vanags Council of State Governments, Eastern Regional Conference

86. Jack Volpato Eddy County, New Mexico

87. John Wagner Oak Ridge National Laboratory

88. Sandra Wastler Nuclear Regulatory Commission

89. Christopher Wells Southern States Energy Board

90. Jim Wiggins Nuclear Regulatory Commission

91. Jeffrey (Jeff) Williams Department of Energy

92. Jim Williams Western Interstate Energy Board

93. David (Dave) Zabransky Department of Energy

Source: GAO. | GAO-15-141

a

Brian O’Connell retired in 2013 as director of the Nuclear Waste Program.
Appendix III: Commercial Spent Nuclear Fuel 

Stored in Wet, Dry, and Shutdown Storage 

Sites (Text for Interactive Figure 5)

Page 46 GAO-15-141 Spent Nuclear Fuel Liability

Wet storage sites 1. Beaver Valley

2. Callaway

3. Clinton

4. Fermi 

5. Shearon Harris

6. Pilgrim 

7. South Texas Project

8. Virgil C. Summer

9. Three Mile Island

10. Watts Bar

11. Wolf Creek

12. GE Morris

Wet and dry storage sites 1. Arkansas Nuclear One

2. Braidwood

3. Browns Ferry

4. Brunswick 

5. Byron 

6. Calvert Cliffs

7. Catawba

8. Columbia Generating Station

9. Comanche Peak

10. Cooper

11. Davis-Besse

12. Diablo Canyon

13. Donald C. Cook

14. Dresden

15. Duane Arnold

16. Joseph M. Farley

17. James A. FitzPatrick

18. Fort Calhoun

19. R.E. Ginna

20. Grand Gulf

21. Edwin I. Hatch

22. Hope Creek

23. Indian Point

24. La Salle

25. Limerick

26. McGuire

27. Millstone

Appendix III: Commercial Spent Nuclear

Fuel Stored in Wet, Dry, and Shutdown 

Storage Sites (Text for Interactive Figure 5)
Appendix III: Commercial Spent Nuclear Fuel 

Stored in Wet, Dry, and Shutdown Storage 

Sites (Text for Interactive Figure 5)

Page 47 GAO-15-141 Spent Nuclear Fuel Liability

28. Monticello

29. Nine Mile Point

30. North Anna

31. Oconee

32. Oyster Creek

33. Palisades

34. Palo Verde

35. Peach Bottom

36. Perry 

37. Point Beach

38. Prairie Island

39. Quad Cities

40. River Bend

41. H. B. Robinson

42. St. Lucie

43. Salem

44. Seabrook

45. Sequoyah

46. Surry 

47. Susquehanna

48. Turkey Point

49. Vermont Yankee

50. Vogtle

51. Waterford

Shut-down storage sitesa 1. Big Rock Point

2. Maine Yankee

3. Yankee Rowe

4. Haddam Neck

5. Crystal River

6. Kewaunee

7. La Crosse

8. Zion

9. Trojan

10. Humboldt Bay

11. Rancho Seco

12. San Onofre

33 states with accumulated spent fuel 1. Alabama

2. Arizona 

3. Arkansas 
Appendix III: Commercial Spent Nuclear Fuel 

Stored in Wet, Dry, and Shutdown Storage 

Sites (Text for Interactive Figure 5)

Page 48 GAO-15-141 Spent Nuclear Fuel Liability

4. California

5. Connecticut

6. Florida

7. Georgia

8. Illinois

9. Iowa

10. Kansas

11. Louisiana

12. Maine

13. Maryland

14. Massachusetts

15. Michigan

16. Minnesota

17. Mississippi

18. Missouri

19. Nebraska

20. New Hampshire

21. New Jersey

22. New York

23. North Carolina

24. Ohio

25. Oregon

26. Pennsylvania

27. South Carolina

28. Tennessee

29. Texas

30. Vermont 

31. Virginia

32. Washington

33. Wisconsin

Source: GAO analysis of NRC and DOE data, as of July 2014. | GAO-15-141

a

In addition, there are three permanently shutdown reactors at sites that continue to have operating 

reactors. The sites that have both shutdown and operating reactors include the Dresden, Indian Point, 

and Millstone sites. Of the 12 shutdown reactor sites, the Zion site has two permanently shutdown 

reactors and the San Onofre site has three permanently shutdown reactors. Also, the operator at the 

Vermont Yankee site has announced that it plans to shut down the reactor at the end of 2014.
Appendix IV: Additional Information on the 

Spent Nuclear Fuel Settlement Agreements

Page 49 GAO-15-141 Spent Nuclear Fuel Liability

The settlement agreements between the Department of Justice and the 

owners or generators of spent nuclear fuel have not been identical and 

have changed over time. For example, from 2004 through 2009, the 

Department of Justice settled with six owners and generators 

representing 40 of the 118 reactors covered under the standard contract. 

Under the settlement agreements—known as the Exelon Settlement 

agreements—it was assumed that the Department of Energy (DOE) 

would have accepted spent nuclear fuel for disposal at a rate of 900 

metric tons per year from 1998 through 2014, and at a rate of 2,100 

metric tons per year thereafter. Under the Exelon Settlement agreements, 

DOE is liable for spent nuclear fuel storage costs that owners and 

generators would not have incurred if DOE had accepted and disposed of 

the fuel at this rate. Beginning in 2011, the Department of Justice began 

using a new settlement agreement—called the New Framework 

Settlement agreement. As of September 8, 2014, the Department of 

Justice reported that it has executed New Framework Settlement 

Agreements with 20 litigants representing 45 reactors covered under the 

standard contract. These settlement agreements do not supersede the 

Exelon agreements, which remain effective for the parties that settled 

through 2009. The New Framework Settlement agreements assumed a 

higher rate of acceptance of spent nuclear fuel, based on an appellate 

decision. Specifically, the new settlement agreements assumed that DOE 

would have accepted spent nuclear fuel for disposal at a rate of 1,200 

metric tons per year from 1998 through 2002; 2,000 metric tons in 2003; 

2,650 metric tons per year from 2004 through 2007; and 3,000 metric 

tons per year beginning in 2008. The result is that some types of spent 

nuclear fuel storage costs for which owners and generators were deemed 

responsible under the Exelon Settlement agreement are now a DOE 

liability under the new settlement agreements.1

According to a Department of Justice document used to discuss 

settlements for the owners and generators covered by the New 

Framework Settlement agreements, there are five categories of 

reimbursable costs:

 

1

The Department of Justice has also entered into four other settlement agreements with 

former owners of spent nuclear fuel who have since exited the industry. While there is no 

pending litigation concerning the settled claims, litigation continues with the new owners of 

the reactors in three of these cases.

Appendix IV: Additional Information on the 

Spent Nuclear Fuel Settlement Agreements
Appendix IV: Additional Information on the 

Spent Nuclear Fuel Settlement Agreements

Page 50 GAO-15-141 Spent Nuclear Fuel Liability

1. Additional Pool Storage: Costs to purchase, license, and install

new, additional, or replacement storage racks or to make available 

additional storage spaces to the extent, and only to the extent, 

necessary to provide additional capacity in the spent nuclear fuel pool 

at the site.

2. Dry Storage Costs: Costs to purchase canisters and casks, including 

canisters that may be licensed for transport and casks for transferring 

spent nuclear fuel to the dry storage facility;2

3. Modifications of the Existing Plant: Costs paid to modify cranes to 

the extent, and only to the extent, necessary to increase the rated 

lifting capacity of the crane(s) used in the loading of spent nuclear fuel 

from the fuel storage pool, provided that the utility can establish that 

these modifications would not have been necessary to meet the 

requirements of NUREG-0612 or load spent nuclear fuel in casks or 

costs to load spent 

nuclear fuel into and to transport canisters and casks to the dry 

storage facility; costs of ancillary equipment for casks and cask 

loading, such as crawler-type transporters, dollies, and vacuum-drying 

equipment; costs to conduct initial loading demonstrations required by 

the Nuclear Regulatory Commission (NRC); costs for training and 

development of procedures; costs for cask-loading campaign 

mobilization and demobilization; costs to study and to evaluate spent 

nuclear fuel storage options; costs for quality assurance inspections of 

cask vendors; costs for security improvements required by NRC for 

the dry storage facility; costs of maintaining and operating the dry 

storage facility; costs for security improvements or upgrades required 

to comply with utility’s security plan approved by the NRC; and costs 

to design, license and build the dry storage facility, including costs of 

building the portion of the facility that will be required for the dry 

storage of the utility’s spent nuclear fuel in addition to utility’s 

allocations, provided that the utility can demonstrate that it was more 

cost effective to incur the costs to design, license and build the dry 

storage facility during the claim period rather than after termination of 

the agreement. If the utility previously constructed a dry storage 

facility for reasons other than to store the utility’s allocations or needs 

to place, or places, items other than canisters or casks containing the 

utility’s allocations in dry storage, only the costs attributable to the 

portion of the dry storage facility needed to store the utility’s 

allocations will be allowable.

 

2

The dry storage facility is known as the independent spent fuel storage installation.
Appendix IV: Additional Information on the 

Spent Nuclear Fuel Settlement Agreements

Page 51 GAO-15-141 Spent Nuclear Fuel Liability

canisters provided by DOE had DOE begun performance in 1998; 

building modifications that the utility can establish would not have 

been necessary to load spent nuclear fuel into casks or canisters 

provided by DOE (e.g., seismic restraints for fuel pool or upgrades to 

floor of cask-loading area); and costs to improve the haul path from 

the fuel building to the dry storage facility, to the extent that the haul 

path is different from the path that the utility would have used to 

deliver fuel to DOE. If the utility incurs costs for site modifications or 

equipment purchases to store the utility’s allocations that otherwise 

benefit the operation of the plant, including crane modifications for 

purposes other than loading storage canisters or casks, the cost 

reimbursed will be proportional to the benefit to the operation of the 

plant.

4. Property Taxes: Costs paid as a result of any increase in assessed 

property tax resulting from and traceable to projects, as identified in 

the preceding three paragraphs, that were undertaken to provide 

additional storage for the utility’s allocations.

5. Labor and Overhead: The cost of labor charged directly by the 

utility’s employees to any project that is otherwise allowable shall be 

considered allowable, provided that the hours expended on such 

project are charged in accordance with utility’s standard time 

recordation system and are identified at the individual employee level. 

In addition, the following types of overhead charges will be deemed 

allowable provided that the charges are calculated in accordance with 

the utility’s established accounting practice and policy: (a) payroll 

overheads or “burdens” associated with labor hours charged to 

allowable projects and (b) non-payroll overheads allocated to 

allowable projects claimed up to a maximum of 5 percent of the 

portion of the utility’s claim which is otherwise allowable and to which 

such non-payroll overheads are allocated.
Appendix V: Process and Costs of 

Transferring Spent Nuclear Fuel from Wet to 

Dry Storage (Text for Interactive Figure 7)

Page 52 GAO-15-141 Spent Nuclear Fuel Liability

1. Nuclear power reactor and spent 

nuclear fuel pools

Nuclear power reactor and spent nuclear fuel pools—Spent nuclear fuel typically 

cools for at least 5 years in a pool before a canister ($700,000 to $1.5 million) is placed in 

the pool, filled with spent nuclear fuel, removed from the pool, and dried. A reusable steel 

transfer cask ($1.5 million to $3 million) provides shielding for nearby workers as the 

spent nuclear fuel is transferred from the pool and placed into either a vertical or 

horizontal dry storage system. The process of transferring spent nuclear fuel, excluding 

the canister, transfer cask, and storage system costs $150,000 to $550,000. Then the 

canister is placed into either a vertical or horizontal dry storage system.

2. Transporter Transporter— For vertical storage, a crawler-type transporter ($1 million to $1.5 million) 

carries the entire canister and storage cask in a vertical orientation to a storage pad. For 

horizontal storage, a tractor with a transfer trailer carries the canister in a reusable 

transfer cask in a horizontal orientation ($1.5 million to $3 million) to the horizontal 

module. 

3. Vertical storage cask/horizontal 

storage module

Vertical storage cask/horizontal storage module—Utilities typically choose either a 

vertical storage system ($250,000 to $350,000 per cask) or a horizontal storage system

($500,000 to $600,000 per module) for a particular site. 

4. Safety and security systems and 

annual operations

Safety and security systems and annual operations—Design, licensing, and 

construction of the dry storage facility and safety and security systems ($5.5 million to 

$42 million). Annual operations include costs of security, operations, and maintenance 

cost. Annual operations at an operating reactor site: $100,000 to $300,000 and at a 

shutdown reactor site: $2.5 million to $6.5 million.

Source: GAO analysis of Nuclear Energy Institute data. | GAO-15-141. 

Appendix V: Process and Costs of 

Transferring Spent Nuclear Fuel from Wet to 

Dry Storage (Text for Interactive Figure 7)
Appendix VI: Comments from the Department 

of Energy

Page 53 GAO-15-141 Spent Nuclear Fuel Liability

Appendix VI: Comments from the 

Department of Energy
Appendix VI: Comments from the Department 

of Energy

Page 54 GAO-15-141 Spent Nuclear Fuel Liability
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 55 GAO-15-141 Spent Nuclear Fuel Liability

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the individual named above, Karla Springer (Assistant 

Director), Arkelga Braxton, Kevin Bray, Ross Gauthier, Diana C. Goody, 

Armetha Liles, Wendell Matt, Mehrzad Nadji, Cynthia Norris, Katrina 

Pekar-Carpenter, Timothy Persons (Chief Scientist), Anne Rhodes-Kline, 

and Robert Sánchez made key contributions.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(361534)
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