FEBRUARY 2000

DOE/IG-0462

AUDIT

REPORT

NATIONAL LOW-LEVEL WASTE 

MANAGEMENT PROGRAM 

U.S. DEPARTMENT OF ENERGY

OFFICE OF INSPECTOR GENERAL

OFFICE OF AUDIT SERVICES
February 24, 2000

MEMORANDUM FOR THE SECRETARY

FROM: Gregory H. Friedman (Signed)

 Inspector General

SUBJECT: INFORMATION: Audit Report on "National Low-Level Waste Management 

Program"

BACKGROUND

Under the Low-Level Radioactive Waste Policy Act of 1980 (Act), States were responsible for 

providing for disposal of commercial low-level radioactive waste. They were encouraged to 

enter into compacts to facilitate the development of new disposal sites. The Department of 

Energy (Department) was required to provide technical assistance to support States and compact 

regions in developing such facilities. In 1990, the Department was also directed by the Congress 

to provide assistance in establishing an independent, self-directed association through which

States and compact regions could accomplish low-level waste disposal objectives.

Since 1982, the Department has spent over $80 million to provide technical assistance to States 

and compact regions. The Department has provided $5.4 million, since 1990, to fund the LowLevel Radioactive Waste Forum, an independent association for information exchange between 

State and compact officials. 

Pursuant to a request from an official in the National Low-Level Waste Management Program, 

the Office of Inspector General reviewed the program to determine whether the assistance 

provided to States and compact regions supports the development of low-level waste disposal 

facilities.

RESULTS OF AUDIT

The Low-Level Waste Program, as envisioned by the Congress in 1980, has not come to fruition: 

• No permanent disposal site has been developed by the States and compact regions,

• As traditional disposal efforts have stalled in every State and compact region, there has been a 

growing interest in pursuing alternative waste management techniques, and

• The Department provided assistance to States that was not fully consistent with the Act's 

objectives, in an attempt to adapt to the circumstances facing the National Low-Level Waste 

Management Program.
In response to State requests, the Department shifted the emphasis of its technical 

assistance from developing permanent disposal facilities to assured isolation of low-level 

waste. In assured isolation, the waste is stored in temporary aboveground facilities and is 

easily retrievable. The Nuclear Regulatory Commission has stated that assured isolation, 

by its nature, can only be considered temporary storage. This is in contrast to the 

permanent disposal objectives of the Act. As such, there is some question as to whether 

the technical assistance provided by the Department is consistent with congressional 

intent.

The audit further disclosed that the Department has provided assistance to the 

Radioactive Waste Forum beyond the duration envisioned by the Congress. The 

Department’s role was limited to providing initial funding for Forum activities until the 

States and compacts could develop independent means of financing. Yet, the States and 

compacts have not provided any funds for Forum activities despite annual financial 

sponsorship by the Department. This indicates that the States and compacts do not 

consider the Waste Forum a priority. Continued Federal funding of the Forum at current 

rates through Fiscal Year 2006 is expected to cost $4.6 million.

In conducting this audit, the Office of Inspector General recognizes that issues associated 

with the storage and disposal of commercial low-level waste are complex. We also 

understand the Department’s sensitivity to the interests of its stakeholders, including the 

States. Recognizing these issues in the context of our concern that Federal taxpayer 

funds be appropriately expended, we recommended that the Assistant Secretary for 

Environmental Management clarify the intent of the Congress regarding the expenditure 

of funds in developing storage sites. We also recommended that the Department 

discontinue funding for the Forum and technical assistance until clarification is obtained. 

We noted that Congress did not provide funding for Forum activities or for the technical 

assistance program in Fiscal Year 2000. We were informed that Environmental 

Management, as a consequence, is considering using available Fiscal Year 2000 funding 

for these activities.

MANAGEMENT REACTION

The Assistant Secretary for Environmental Management disagreed with the audit 

conclusions and recommendations, indicating that most of the substantive issues arose 

from differing interpretations of the Department and States' duties under the Act. 

Management also questioned the conclusion in the report regarding assured isolation. 

Management believes that it is appropriate and legally defensible for the Department to 

provide technical assistance to States and compact regions on assured isolation, as well 

as support to States through the grant process for the Low-Level Waste Forum. A more 

detailed summary of management's comments and our response are included in the 

Management Reaction and Auditor Comments sections of this report.

cc: Deputy Secretary

 Under Secretary

2
Overview

Introduction And Objective ...................................................................1

Conclusions And Observations .............................................................2

Departmental Support For Waste Disposal Facilities

Details Of Finding .................................................................................4

Recommendation And Comments ........................................................7

Funding Of The Low-Level Radioactive Waste Forum

Details Of Finding .................................................................................9

Recommendation And Comments ......................................................11

Appendices

1. Scope And Methodology...............................................................12

2. Related Audit Reports ...................................................................13

3. Nuclear Regulatory Commission Position Letter..........................14

The U.S. Department Of Energy's National Low-Level Waste 

Management Program

TABLE OF 

CONTENTS
Page 1

The Low-Level Radioactive Waste Policy Act of 1980 (Act), as 

amended, declared that States were responsible for providing for the 

disposal of commercial low-level radioactive waste and encouraged 

States to enter into compacts (interstate agreements) to fulfill this 

responsibility. Ten compact regions consisting of 44 States were 

formed and approved by the Congress. The six other States remained 

unaffiliated with any compact.

Under the Act, the Department was required to provide States and 

compact regions with technical assistance to support them in fulfilling 

their responsibilities to develop new low-level waste disposal facilities. 

To carry out its responsibility, the Department's Office of 

Environmental Management assigned this effort to the National LowLevel Waste Management Program (National Program) at the Idaho 

National Engineering and Environmental Laboratory. The National 

Program provided technical assistance by holding workshops, fulfilling 

State requests for specific assistance, developing technical documents, 

distributing general information on low-level waste, and providing 

technical coordination for organization conferences. Since 1982, the 

Department has spent over $80 million to provide States and compact 

regions various types of technical assistance.

In 1990, the Department was also directed by the Congress to provide 

organizational assistance in establishing an independent, self-directed 

association through which States and compacts could accomplish their 

site disposal objectives. The Department was to initially fund an 

association until the States could develop a means for independent 

funding. A 3-year grant was used to provide this funding for the LowLevel Radioactive Waste Forum (Forum). The Forum consists of State 

and compact officials appointed to exchange information related to the 

development of new waste sites. As of December 1999, the Forum has 

received $5.4 million from the Department with no funds provided by 

the States or compact regions. 

Pursuant to a request from an official of the National Program, the 

Office of Inspector General reviewed the program to determine whether 

the assistance provided to States and compact regions supported the 

development of low-level waste disposal facilities.

Overview

INTRODUCTION AND 

OBJECTIVE

Introduction And Objective
Page 2

CONCLUSIONS AND 

OBSERVATIONS

The assistance provided by the Department to States and compact 

regions did not fully support the development of low-level waste

disposal facilities. Specifically, the Department funded assistance to 

States and compact regions for alternative waste management 

methods, such as storing low-level waste, which were not covered by 

the Act. In addition, the Department continued to finance Forum 

activities beyond the initial funding responsibilities envisioned by 

Congress.

Although traditional disposal efforts have stalled in every State and 

compact region, there has been a growing interest from several States 

in pursuing alternative management techniques to traditional disposal. 

Initial efforts by States and compact regions to build disposal facilities 

incurred numerous barriers that hindered progress, including public 

and legislative opposition. Also, because existing disposal capacity 

was available, there was little incentive for States or compact regions 

to establish new waste disposal facilities. By the beginning of 1997, 

all unaffiliated States had stopped their waste disposal siting efforts. 

In early 1999, all compact States had stopped further progress on their 

disposal siting efforts. As of October 1999, no disposal facilities for 

commercial low-level radioactive waste had been developed or built.

Starting in 1996, the Department shifted its technical assistance from 

developing low-level waste disposal facilities to providing assistance 

to States and compact regions on assured isolation as a low-level 

radioactive waste management technique. In assured isolation, the 

waste remains available for inspection and easily retrievable in 

temporary aboveground storage facilities. However, the assured 

isolation concept does not meet the purpose and intent of the Act, 

which required waste to be placed in permanent isolation. The Nuclear 

Regulatory Commission (NRC) has stated that assured isolation, by its 

very nature, could only be considered a temporary facility. 

Despite the position of the NRC, the Department's National Program 

Office has provided funding for assured isolation. Specifically, it has 

published five reports for various States on the cost and use of this 

alternative to permanent disposal. In total, the Department has spent 

$9.1 million since 1997 on this program, including funding for studies 

on assured isolation. Additionally, the National Program's life-cycle 

cost plan estimated that approximately $22 million would be spent 

through Fiscal Year 2006 to provide assistance to States, including 

assured isolation technical assistance.

Conclusions And Observations
Page 3

The Department has also provided organizational assistance to the 

States beyond its responsibilities stipulated by the Congress. The 

Department was only to provide initial funding for Forum activities 

until the States and compacts could develop an independent means of 

financing. However, the Forum has relied on the Department for 100 

percent of its funding. Grant funding has grown from about $395,000 

in 1990 to about $657,000 in 1999. The State and compact membership 

has not provided funds for any of the Forum's initiatives. This indicates 

to us that the Forum is not a State nor compact priority.

The Congress did not provide funding in Fiscal Year 2000 for the 

technical assistance program or Forum activities, except for funds to 

maintain Federal databases on waste disposal information. The 

Assistant Secretary for Environmental Management should clarify with 

appropriate congressional committees the intent of the Congress 

regarding the expenditure of funds in developing storage sites prior to 

authorizing additional work in this area. Furthermore, the Assistant 

Secretary should discontinue funding for technical assistance not 

related to permanent disposal until clarification is obtained.

Management should consider the issues discussed in this report when 

preparing the yearend assurance memorandum on internal controls.

 (Signed) 

 Office of Inspector General

Conclusions And Observations
Page 4

The Department's responsibilities to provide technical assistance to 

States and compact regions were established in the Low-Level 

Radioactive Waste Policy Act, as amended. The Act stated that the 

Department shall provide technical assistance including, but not limited 

to, the following:

1) technical guidelines for site selection;

2) alternative technologies for low-level radioactive waste 

disposal;

3) volume reduction options;

4) management techniques to reduce low-level waste 

generation;

5) transportation practices for shipment of low-level wastes;

6) health and safety considerations in the storage, shipment, 

and disposal of low-level radioactive wastes; and

7) establishment of a computerized database to monitor the 

management of low-level radioactive waste.

The Senate Energy Committee report accompanying this Act described 

the types of activities for which the Department was responsible. It 

stated that these responsibilities included continued technical assistance 

to States and compact regions for the development of new low-level 

radioactive waste disposal facilities (emphasis added). Disposal was 

defined as the "permanent isolation" of low-level waste.

Despite the Act's requirement, the Department provided technical 

assistance to States and compact regions for alternative methods of 

storing low-level waste that were not considered permanent disposal 

technologies. Since 1996 the Department has provided technical 

assistance for a new concept to manage low-level waste termed 

"assured isolation."

The Department's National Program described assured isolation as an 

alternative approach to safe, long-term management of low-level waste. 

Assured isolation offers an alternative to permanent underground 

disposal whereby the facility can be physically inspected, monitored, 

and maintained for many years. The Idaho Operations Office reported 

that as many as eight States have participated in requests for technical 

assistance on assured isolation including the issuance of reports and 

studies from 1995 through 1999.

Departmental Support For Waste Disposal Facilities

Technical Assistance 

Requirements

Technical Assistance For 

Temporary Storage

Details Of Finding
Page 5

In August 1999, the Department issued its latest report comparing lowlevel waste disposal to assured isolation. The report acknowledged that 

despite State and compact region endeavors to develop new low-level 

radioactive waste disposal facilities, no such facility has been licensed 

and actually constructed. This report also indicated that assured 

isolation facility costs were estimated to be 50 to 75 percent higher than 

those of a disposal facility. In addition, the report recognized that 

assured isolation did not function like a disposal facility. 

Even as States have continued to receive technical assistance from the 

Department, they were concerned whether the definition and licensing 

criteria for assured isolation would meet the intent and legal 

requirements of their compact obligations to build a disposal facility. 

For example, in August 1999, a State Radiation Advisory Board 

recommended that a definition be developed so the concept of assured 

isolation satisfied the States' intent to isolate waste materials, even 

though this concept is different from underground disposal. The Board 

stated that it was important that assured isolation was not ruled 

unacceptable due to a definition of disposal that does not consider 

aboveground storage options.

To clarify the regulatory requirements for an assured isolation facility, 

we discussed this issue with NRC personnel. A NRC senior project 

manager stated that NRC had not established a license requirement for 

an assured isolation facility. Also, the NRC concluded that assured 

isolation was temporary storage, not disposal. This position was 

articulated in a March 1999 letter to a Texas State Representative (See 

Appendix 3). The Chairman of the NRC stated that "We do not 

consider assured storage to be the equivalent of permanent disposal of 

LLW (Low-Level Waste). By its very nature, assured storage is 

considered a temporary facility."

To understand management's rationale for providing technical 

assistance for assured isolation, we discussed this issue with 

Environmental Management officials. A representative from the Office 

of Waste Management stated that the Office of Environmental 

Management supports the States in the concept of assured isolation, and 

if the States pursue this concept the Department would support them 

from a national perspective. The National Program Manager stated that 

the Department was chartered under the Act to come up with alternative 

approaches for the disposal of low-level waste. The Program Manager 

Details Of Finding

Program Management
Page 6

further indicated that while the Act listed certain types of technical 

assistance that were to be provided by the Department, assistance was 

not limited to the listed items. Based on this interpretation, the 

contractor developed and promoted the assured isolation concept, even 

though it was not permanent disposal.

The Department's shift in technical assistance emphasis was a reaction 

to the States' inability to overcome barriers to disposal site selection. 

In a recent program funding profile, the Department recognized that 

States and compacts had suspended their efforts to site and construct 

new disposal sites because of these conditions. The National Program 

Office adapted to these changes by increasing support to State 

regulatory agencies for radioactive waste related issues and reducing 

assistance for new site development activities. Also the National 

Program increased assistance to State policy makers to aid them in 

evaluating policy options.

With this reduction in site development activities, we asked the 

National Program Manager why the program should continue if no 

State is attempting to establish a new facility. The manager said that 

even though States had stopped their site development efforts, program 

staff continued to respond to requests for other types of technical 

assistance. For example, they received many requests for additional 

information on licensing and regulatory issues. They also received 

increased requests for technical assistance in the areas of tracking 

waste, providing personnel support for a State task force working on 

options to waste disposal, and storing waste by those who generate it. 

However, assistance for waste generators was obtained through the 

compacts since the Program cannot provide assistance directly to them.

The Program Manager added that personnel anticipated additional 

requests to provide workshops on waste storage issues such as costs if 

States store their waste, financial liabilities to States, and continuing 

requests for help with licensing and data management functions. In 

addition, the Program maintains information management systems that 

keep data for all the disposal operators and prepares the Department's 

annual report to the Congress required by the Act.

Continued Departmental funding of the program for Fiscal Years 2000 

through 2006, including assistance for assured isolation, is expected to 

cost approximately $22 million. Beginning in Fiscal Year 2000, the 

Details Of Finding

Need For Continued 

Funding
Page 7

Department planned to start downsizing the National Program. 

However, Congress did not provide any funding in Fiscal Year 2000 for 

the technical assistance program except for $595,000 to fund Federal 

database maintenance. The Assistant Secretary for Environmental 

Management chose to use $1.7 million of projected carryover money to 

continue funding National Program activities, including assured 

isolation, in Fiscal Year 2000. We believe further expenditure of 

Departmental funds for assistance on temporary storage projects is 

inconsistent with the intent of Congress.

Because no State or compact region is developing a permanent disposal 

facility, we recommend that the Assistant Secretary for Environmental 

Management clarify with appropriate congressional committees the 

intent of Congress regarding the expenditure of funds in developing 

storage sites prior to authorizing additional work in this area. 

Furthermore, the Assistant Secretary should discontinue funding for 

technical assistance not related to permanent disposal until clarification 

is obtained.

The Assistant Secretary for Environmental Management indicated that 

management disagreed with the audit conclusions and recommendations. 

Management also stated that its interpretation of the Act permitted the 

Department to fund a range of technical assistance activities related to 

the management of low-level radioactive waste. Ba sed on this 

interpretation and belief that Congress did not intend for the Department 

to return for further guidance every time circumstances changed, 

management did not see any need to seek clarification from the 

authorizing committee. Management further indicated that the Nuclear 

Regulatory Commission had not issued a formal policy on assured 

isolation.

Management also provided additional comments during the exit 

conference. They pointed out that the assured isolation concept is an 

evolving issue among the States. However, carryover funds will not be 

used to conduct any additional studies on assured isolation. They stated 

that the Office of Environmental Management was using the carryover 

amounts in Fiscal Year 2000 to fund the Forum and National Program 

closeout activities.

Recommendation And Comments

RECOMMENDATION

MANAGEMENT

REACTION
Page 8

We disagree that alternative storage technologies, such as assured 

isolation, are consistent with congressional intent to promote the 

development of low-level radioactive waste disposal sites. With 

passage of the Act, Congress clearly intended for the Department to 

provide States and compact regions the technical assistance they needed 

to provide for the disposal of waste. Disposal is defined as the 

permanent isolation of radioactive waste, not the safe storage of waste. 

We recognize that the Act gave the Secretary the latitude to determine 

which States and compact regions require technical assistance, but such 

assistance is limited to waste disposal projects.

Beyond this disagreement, management's response to the draft audit 

report did not recognize that after nearly 20 years of technical 

assistance to States and compact regions, no State or compact region 

has established a low-level waste disposal facility. The inability to 

establish disposal sites raises a concern about the effectiveness and 

desirability of providing additional technical assistance, even as States 

and compact regions persist with requests for the Department to spend 

additional resources.

Furthermore, for Fiscal Year 2000, Congress chose not to directly 

appropriate any additional funds for the National Low-Level 

Radioactive Waste Management Program, except for funding of Federal 

database management. The House Appropriations Committee, in 

choosing not to provide additional funds, stated that "Over $80,000,000 

has been provided for the low-level waste program over the past two 

decades, and State expertise is now mature enough that Federal funding 

is no longer required."

With reference to the Nuclear Regulatory Commission statement, the 

audit report does not present the NRC statement as policy. It clearly 

identifies the source of the statement on assured isolation as a letter 

from the NRC Chairman to a Texas State representative. We consider 

the Chairman an authoritative source in describing the NRC position on 

assured isolation.

Recommendation And Comments

AUDITOR

COMMENTS
Page 9

Departmental responsibility to initially fund the Low-Level Waste 

Forum was established by Congress. In a committee report attached to 

the 1990 Energy and Water Development Appropriations Bill, Congress 

recognized the need to establish an independent State forum that would 

promote an effective and efficient system for management and disposal 

of low-level waste. It also recognized that disposal was a State 

responsibility (emphasis added) with the Department providing initial 

assistance to the States. 

To support this effort, the Committee recommended the following:

"...that during the fiscal year 1990, the Department of 

Energy assist the states and compacts in organizing an 

independent, self-directed association through which the 

States and compacts may accomplish these objectives. 

The DOE should provide organizational assistance to the 

extent requested by the States and compacts, in 

establishing such an association, and should provide 

initial funding (emphasis added) for the association 

until the States and compacts can develop a means for 

independent funding."

The Department continued to fund the Low-Level Radioactive Waste 

Forum beyond requirements intended by Congress. Although the 

Congress directed the Department to provide only initial funding, the 

Forum has relied upon the Department for 100 percent of its finances 

since 1990. This funding has been provided through grant awards 

totaling $5.4 million. Since 1990, annual funding has increased from 

$395,387 to $656,780 in 1999 as shown in the table below.

Details Of Finding

Funding Of The Low-Level Radioactive Waste Forum

State And Federal 

Funding Responsibilities

Continued Federal 

Funding 

0

200

400

600

800

Dollars

(000)

1990199119921993199419951996199719981999

Government Funding of the Forum 
Page 10

During the same period (1990-1999), the frequency of Forum meetings 

decreased. Originally, the Forum held four meetings a year. As State 

efforts to site low-level disposal facilities diminished, the number of 

meetings held in 1997 and 1998 dropped to three per year with only 

two meetings held in 1999. Despite this change, there was not a 

proportional decrease in Government funding.

The Department had not formally evaluated the effectiveness of 

continued funding for Forum activities and the accuracy of information 

supporting Forum funding.

In its initial evaluation of the grant award, the Department stated that it 

expected Federal support for State and compact low-level waste 

activities to be significantly reduced after 1992. The evaluation report 

indicated that it would be prudent for the States and compacts to 

establish an organization entity that could foster interstate cooperation 

and was capable of managing funds. The report pointed out that the 

Department had notified State and compact officials that its role in 

assisting them was transitional.

Personnel in the National Program office stated that little, if any, 

attempt had been made by States and compact commissions to provide 

funding for Forum activities. The only financial support provided by 

States was for travel expenses. At its February 1998 meeting, the 

executive committee of the Forum notified the Department that it was 

unable to incorporate and become self-funded. As a result, the Forum 

would continue to seek Departmental funding through the grant 

process. 

State organizations have recently requested the Department to continue 

funding the grant based upon the Forum's contribution to the States' 

"...progress toward finding permanent disposal locations for low-level 

radioactive waste." Despite this assertion, no State was actively 

attempting to site a facility for disposal of its low-level waste. 

Departmental funds for the Low-Level Waste Forum represent about 

20 percent of the total program expenditures over the last 2 years. This 

represents a significant continuing reduction in the funds available to 

perform National Program operations. If the Department continues to 

fund the Forum at 1999 levels, an additional $4.6 million will be spent 

through the remaining life of the program. The Congress did not 

Details Of Finding

Evaluation Of Funding 

Requests

Future Funding 

Requests
Page 11

provide funding in Fiscal Year 2000 for Forum activities. However, the 

Assistant Secretary for Environmental Management is considering 

using available carryover funds in Fiscal Year 2000 for Forum 

activities.

Given the States' unwillingness to fund the Low-Level Radioactive 

Waste Forum, we recommend that the Assistant Secretary for 

Environmental Management discontinue funding this activity.

The Assistant Secretary for Environmental Management did not 

provide specific comments on the audit recommendation concerning 

funding for the Low-Level Waste Forum. Management stated in its 

general response to the draft report that "...states have routinely 

identified the Low-Level Waste Forum as being the highest priority for 

DOE support to the states." During the exit conference, management 

noted that the Department's decision to fund the Forum in Fiscal Year 

2000 was consistent with past budget requests for Forum funding.

States have not viewed the Low-Level Waste Forum to be enough of a 

priority to provide any funding for its activities since it was established. 

In this regard, the Forum's executive committee informed the 

Department in February 1998 that it was unable to become self-funded 

and would continue to seek Departmental money through the grant 

process. The unwillingness of the States to fund the Forum raises 

serious questions about whether the Forum is the highest State priority 

for Departmental support as suggested in management's response. In 

addition, continued funding of the Forum is inconsistent with 

congressional and Departmental positions that the Department's role in 

supporting the Forum was transitional.

Recommendation And Comments

RECOMMENDATION

MANAGEMENT 

REACTION

AUDITOR

COMMENTS
Page 12

The audit was performed from July through November 1999 at 

Department Headquarters in Washington, DC, and Germantown, MD, 

and the Idaho Operations Office in Idaho Falls, Idaho.

To accomplish the audit objective, we:

• Reviewed Federal and Departmental regulations and operating 

policies and procedures relating to the management of the 

Department's Low-Level Radioactive Waste Management Program; 

• Reviewed applicable laws and regulations, including the Low-Level 

Radioactive Waste Policy Act of 1980, as amended, and the Energy 

and Water Development Bill of 1990;

• Held discussions with personnel from the Office of Waste 

Management responsible for directing the Program;

• Interviewed Department and contractor personne l responsible for 

managing the Program at the Idaho Operations Office;

• Reviewed and evaluated contractor files used to support the 

Program;

• In accordance with the requirements of the Government 

Performance and Results Act reviewed performance measures; and

• Held a discussion with personnel from the Nuclear Regulatory 

Commission to determine licensing procedures for low-level waste 

disposal facilities. 

The audit was performed in accordance with generally accepted 

Government auditing standards for performance audits and included 

tests of internal controls and compliance with laws and regulations to 

the extent necessary to satisfy the audit objective. Because our review 

was limited, it would not necessarily have disclosed all internal control 

deficiencies that may have existed at the time of our audit. We did not 

rely on computer-processed data to accomplish our audit objective. 

We held an exit conference with officials from the Office of the Deputy 

Assistant Secretary for Waste Management on February 11, 2000.

Scope And Methodology

Appendix 1

SCOPE

METHODOLOGY
Page 13 Related Audit Reports

Appendix 2

AUDIT REPORTS RELATING TO LOW-LEVEL RADIOACTIVE WASTE MANAGEMENT

• Disposal of Low-Level and Low-Level Mixed Waste, (DOE/IG-0426, September 3, 1998). The 

Department generally did not dispose of low-level and mixed waste as cost-effectively as possible. 

Most Department facilities stored large quantities of waste on-site, and when disposals of low-level 

waste were made, they were often not cost effective.

• Low-Level Radioactive Waste: States Are Not Developing Disposal Facilities, General Accounting 

Office (GAO/RCED-99-238, September 17, 1999). States, acting alone or within compacts of two or 

more States, have collectively spent almost $600 million over the last 18 years attempting to find and 

develop about 10 sites for disposing of commercially generated low-level radioactive waste. None of 

the States or compacts has successfully developed a new disposal facility.
Page 14

Appendix 3

Nuclear Regulatory Commission

Position Letter
Page 15 Nuclear Regulatory Commission

Position Letter
 IG Report No. DOE/IG-0462

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