SPENT NUCLEAR 

FUEL

Accumulating 

Quantities at 

Commercial Reactors 

Present Storage and 

Other Challenges

Report to Congressional Requesters

August 2012

GAO-12-797

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-797, a report to 

congressional requesters 

August 2012 

SPENT NUCLEAR FUEL

Accumulating Quantities at Commercial Reactors 

Present Storage and Other Challenges

Why GAO Did This Study

Spent nuclear fuel, the used fuel 

removed from nuclear reactors, is one 

of the most hazardous substances 

created by humans. Commercial spent 

fuel is stored at reactor sites; about 

74 percent of it is stored in pools of 

water, and 26 percent has been 

transferred to dry storage casks. The 

United States has no permanent 

disposal site for the nearly 

70,000 metric tons of spent fuel 

currently stored in 33 states.

GAO was asked to examine (1) the 

amount of spent fuel expected to 

accumulate before it can be moved 

from commercial nuclear reactor sites, 

(2) the key risks posed by stored spent 

fuel and actions to help mitigate these 

risks, and (3) key benefits and 

challenges of moving spent nuclear 

fuel out of wet storage and ultimately 

away from commercial nuclear 

reactors. GAO reviewed NRC

documents and studies on spent fuel’s 

safety and security risks and industry 

data, interviewed federal and state 

government officials and 

representatives from industry and other

groups, and visited reactor sites.

What GAO Recommends

To help facilitate decisions on storing 

and disposing of spent nuclear fuel 

over the coming decades, GAO 

recommends that NRC develop a 

mechanism for locating all classified 

studies. NRC generally agreed with the 

findings and the recommendation in 

the report.

The amount of spent fuel stored on-site at commercial nuclear reactors will 

continue to accumulate—increasing by about 2,000 metric tons per year and 

likely more than doubling to about 140,000 metric tons—before it can be moved 

off-site, because storage or disposal facilities may take decades to develop. In 

examining centralized storage or permanent disposal options, GAO found that 

new facilities may take from 15 to 40 years before they are ready to begin 

accepting spent fuel. Once an off-site facility is available, it will take several more 

decades to ship spent fuel to that facility. This situation will be challenging 

because by about 2040 most currently operating reactors will have ceased 

operations, and options for managing spent fuel, if needed to meet 

transportation, storage, or disposal requirements, may be limited. 

Studies show that the key risk posed by spent nuclear fuel involves a release of 

radiation that could harm human health or the environment. The highestconsequence event posing such a risk would be a self-sustaining fire in a drained 

or partially drained spent fuel pool, resulting in a severe widespread release of 

radiation. The Nuclear Regulatory Commission (NRC), which regulates the 

nation’s spent nuclear fuel, considers the probability of such an event to be low. 

According to studies GAO reviewed, the probability of such a fire is difficult to 

quantify because of the variables affecting whether a fire starts and spreads. 

Studies show that this low-probability scenario could have high consequences, 

however, depending on the severity of the radiation release. These 

consequences include widespread contamination, a significant increase in the 

probability of fatal cancer in the affected population, and the possibility of early 

fatalities. According to studies and NRC officials, mitigating procedures, such as 

replacement water to respond to a loss of pool water from an accident or attack, 

could help prevent a fire. Because a decision on a permanent means of 

disposing of spent fuel may not be made for years, NRC officials and others may 

need to make interim decisions, which could be informed by past studies on 

stored spent fuel. In response to GAO requests, however, NRC could not easily 

identify, locate, or access studies it had conducted or commissioned because it 

does not have an agencywide mechanism to ensure that it can identify and 

locate such classified studies. As a result, GAO had to take a number of steps to 

identify pertinent studies, including interviewing numerous officials.

Transferring spent fuel from wet to dry storage offers several key benefits, 

including safely storing spent fuel for decades after nuclear reactors retire—until 

a permanent solution can be found—and reducing the potential consequences of 

a pool fire. Regarding challenges, transferring spent fuel from wet to dry storage 

is generally safe, but there are risks to moving it, and accelerating the transfer of 

spent fuel could increase those risks. In addition, operating activities, such as 

refueling, inspections, and maintenance, may limit the time frames available for 

transferring spent fuel from wet to dry storage. Once spent fuel is in dry storage, 

there are additional challenges, such as costs for repackaging should it be 

needed. Some industry representatives told GAO that they question whether the 

cost of overcoming the challenges of accelerating the transfer from wet to dry 

storage is worth the benefit, particularly considering the low probability of a 

catastrophic release of radiation. NRC stated that spent fuel is safe in both wet 

and dry storage and that accelerating transfer is not necessary given the small 

increase in safety that could be achieved.

View GAO-12-797. For more information, 

contact Gene Aloise at (202) 512-3841 or 

aloisee@gao.gov. 
Page i GAO-12-797 Accumulation of Spent Nuclear Fuel

Letter 1 

Background 5

Large Quantities of Spent Nuclear Fuel Are Expected to Remain at 

Commercial Reactor Sites for Decades 19

The Key Risk of Stored Spent Fuel Is Difficult to Quantify, but 

Some Mitigating Actions Have Been Taken 27

Transfer of Spent Fuel from Wet Storage Offers Benefits but Also 

Presents Challenges 37

Conclusions 47

Recommendation for Executive Action 47

Agency Comments 47

Appendix I Scope and Methodology 50

Appendix II Selected Other Countries’ Spent Fuel Management Programs 53

Appendix III Accumulation of Commercial Spent Fuel by State over Time 57

Appendix IV Comments from the Nuclear Regulatory Commission 59

Appendix V GAO Contact and Staff Acknowledgments 61

Tables

Table 1: Typical Reactor Characteristics and Storage Capacity 22

Table2: Summary of Commercial Nuclear Programs and Spent Fuel 

Management Programs for Selected Countries 53

Table 3: Cumulative Quantities of Spent Fuel, by State, for 2012, 

2027, 2032, 2052, and 2067 57

Figures

Figure 1: Commercial Spent Nuclear Fuel Storage Sites 6

Contents
Page ii GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 2: Fuel Pellet and Fuel Rod Assembly for a Commercial 

Nuclear Power Reactor 8

Figure 3: Location of a Spent Nuclear Fuel Pool in a Boiling Water 

Reactor 10

Figure 4: Spent Nuclear Fuel Pool 11

Figure 5: Canister in a Transfer Cask in a Spent Nuclear Fuel Pool 15

Figure 6: Spent Fuel in Dry Storage 16

Figure 7: Trends in Accumulation of Spent Nuclear Fuel Overall 

and in Wet and Dry Storage 21

Figure 8: Accumulation of Commercial Spent Fuel by State over 

Time 24

Figure 9: Growth Trend of Total Spent Fuel Compared with Spent 

Fuel from Decommissioned Reactors 27

Abbreviations

DOE Department of Energy

EPRI Electric Power Research Institute

NRC Nuclear Regulatory Commission

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

United States. The published product may be reproduced and distributed in its entirety 

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

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-12-797 Accumulation of Spent Nuclear Fuel

United States Government Accountability Office 

Washington, DC 20548

August 15, 2012

Congressional Requesters

Nuclear fuel that has been used and removed from the reactor core of a 

nuclear power plant—known as spent nuclear fuel—is one of the most 

hazardous substances created by humans.1

Two federal agencies—the Nuclear Regulatory Commission (NRC) and the 

Department of Energy (DOE)—are primarily responsible for the regulation 

and disposal of the nation’s spent nuclear fuel. NRC regulates the 

construction and operation of commercial nuclear power plants and spent 

fuel repositories, as well as the storage and transportation of spent fuel. 

DOE is charged with investigating sites for a federal geologic repository to 

dispose of spent nuclear fuel and high-level nuclear waste from commercial 

nuclear power plants and some defense activities under the Nuclear Waste 

Policy Act of 1982, as amended.

If not properly contained or 

shielded, the intense radioactivity of spent fuel can cause immediate 

deaths and environmental contamination and, in lower doses, cause longterm health hazards, such as cancer. Some radioactive components of 

spent fuel remain hazardous for tens of thousands of years. In the United 

States, the national inventory of commercial spent nuclear fuel amounts 

to nearly 70,000 metric tons. Concerns were heightened about the 

vulnerabilities at nuclear power plants to releases of large doses of 

radiation into surrounding communities after the terrorist attacks of 

September 11, 2001, and the earthquake and tsunami that struck the 

Fukushima Daiichi nuclear power plant complex in Japan in March 2011.

2

 

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 as fuel again in a reactor. Reprocessing, however, still 

results in nuclear waste that requires disposal. The United States does not reprocess its 

spent nuclear fuel, and this fuel, when it is accepted for disposal, is considered to be highlevel waste as defined by the Nuclear Regulatory Commission.

In 1987, however, Congress amended 

2

This report does not address the about 13,000 metric tons of spent nuclear fuel and highlevel waste DOE manages, which was primarily generated by the nation’s nuclear 

weapons program. For example, DOE manages some former commercial spent fuel, such 

as spent fuel at a reactor at Fort St. Vrain in Colorado. We reported separately on this 

issue. See GAO, DOE Nuclear Waste: Better Information Needed on Waste Storage at 

DOE Sites as a Result of the Yucca Mountain Shutdown, GAO-11-230 (Washington, D.C.: 

Mar. 23, 2011).

 
 

Page 2 GAO-12-797 Accumulation of Spent Nuclear Fuel

the act to direct DOE to focus its efforts only on Yucca Mountain, Nevada. 

In addition, the act authorized DOE to contract with commercial nuclear 

reactor operators to take custody of their spent nuclear fuel for disposal at 

the repository beginning in January 1998, but because of a series of delays 

due to, among other reasons, state and local opposition to the construction 

of a permanent nuclear waste repository in Nevada and technical 

complexities, DOE was unable to begin receiving waste by that time.3

Currently, the status of the proposed repository at Yucca Mountain is 

uncertain. DOE and NRC separately suspended their efforts to license this 

repository in 2010 and 2011, respectively, and several parties have filed a 

petition in federal court seeking to force NRC to resume the licensing 

proceeding.4 In April 2011, we reported on the proposed termination of the 

Yucca Mountain repository and recommended actions to assist future 

waste management efforts.5 In that report, we suggested that Congress 

might consider a more predictable funding mechanism and an independent 

organization, outside DOE, for siting and developing a permanent 

repository. NRC concurred with the facts in a draft of that report, and DOE 

strongly disagreed with key facts in the draft and our recommendations. No 

action has been taken to implement our recommendations. Because it did 

not take custody of the spent fuel starting in 1998, DOE reports that as of 

September 2011, 76 lawsuits have been filed against it by utilities to 

recover claimed damages resulting from the delay. These lawsuits have 

resulted in a cost to taxpayers of about $1.6 billion from the U.S. Treasury’s 

judgment fund. DOE estimates that future liabilities will total about an 

additional $19.1 billion through 2020 and that they may cost about $500 

million each year after that.6

Spent nuclear fuel consists of thumbnail-sized pellets of uranium dioxide 

fitted into 12- to 15-foot hollow metal rods, which are bundled together 

 

3

Some technical complexities, such as DOE’s assessment of how heat from the spent 

nuclear fuel might affect the performance of the repository, became the focus of years of 

scientific inquiry.

4

NRC responded to the parties’ petition by stating that it does not have sufficient 

appropriated funds to complete action on the license application. On August 3, 2012, the 

federal court reviewing the parties’ petition issued an order holding the case in abeyance 

pending updates by the parties on the status of fiscal year 2013 appropriations with 

respect to the issues presented in the case.

5

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).

6

These costs are in constant 2011 dollars.
 

Page 3 GAO-12-797 Accumulation of Spent Nuclear Fuel

into assemblies. Operators of commercial nuclear power reactors use two 

methods to store spent nuclear fuel: wet storage in pools of water or dry 

storage in steel and concrete casks. When reactor operators first remove 

spent fuel from a reactor, it is thermally hot and intensely radioactive and 

must be immersed in deep pools of water, which cools the spent fuel and 

shields the environment from the spent fuel. As the inventory of spent fuel 

has grown, reactor operators have increased the number of assemblies 

stored in the pools—generally 40 feet deep—by replacing existing 

storage racks with newer racks holding denser arrangements of 

assemblies. Despite the denser arrangements, which can sometimes hold 

thousands of assemblies, spent fuel pools have limited capacity. 

Beginning in the 1980s, reactor operators began to transfer spent fuel to 

dry cask storage systems to free space in the pools for fuel removed from 

the reactor. Spent fuel can be transferred to dry storage once it has aged 

sufficiently to be cooled by passive air ventilation—generally after about 5 

years. Dry cask storage typically consists of a stainless steel canister 

placed inside a larger stainless steel or concrete cask, which isolates it 

from the environment. Dozens of community action and environmental 

groups have advocated that reactor operators accelerate the transfer of 

spent fuel from pools to dry storage cask systems, believing the risks of 

dry storage are lower than that of wet storage. NRC maintains that spent 

fuel is safe and secure in both wet and dry storage systems.

In light of concerns over the nation’s growing quantities of stored spent 

nuclear fuel, ongoing security threats, and safety concerns raised by events 

in Japan, you asked us to review the safety and security of spent fuel. 

Specifically, our objectives were to examine (1) the amount of spent fuel 

that is expected to accumulate before it can be moved from commercial 

nuclear reactor sites, (2) the key safety and security risks posed by spent 

fuel stored at reactor sites and actions to help mitigate these risks, and 

(3) key benefits and near- and long-term challenges of transferring spent 

nuclear fuel out of wet storage and ultimately away from reactor sites.

To answer these objectives, we reviewed pertinent NRC documents; 

analyzed studies on the safety and security of spent fuel; interviewed 

officials from federal and state regional organizations and representatives 

from industry, academia, and various community action and environmental 
 

Page 4 GAO-12-797 Accumulation of Spent Nuclear Fuel

groups; and visited selected decommissioned and operating reactor sites.7

Specifically, to determine the amount of spent fuel projected to accumulate 

before it can be moved from individual reactor sites, we obtained a 

database on spent fuel projections from the Nuclear Energy Institute, an 

industry advocacy organization. We based our estimates for when 

centralized storage and permanent disposal facilities might become 

available on assumptions from our November 2009 report and on 

additional analysis based on reports from various sources, including DOE 

and the Electric Power Research Institute (EPRI, a nonprofit research 

entity) on centralized storage and permanent disposal.8 To determine key 

safety and security risks of spent fuel and potential mitigation actions, we 

reviewed studies from NRC and other groups, including Sandia National 

Laboratories, the National Academy of Sciences, and community action 

groups. We also reviewed NRC requirements addressing the safety and 

security of spent fuel and directives from the nuclear power industry. We 

interviewed officials from NRC and DOE and representatives from industry, 

academia, and various community groups. We visited the Haddam Neck 

decommissioned reactor site and the Millstone reactor in Connecticut, the 

Hope Creek and Salem reactors in New Jersey, and the Susquehanna 

reactor in Pennsylvania, and we spoke with NRC officials and industry 

representatives about spent fuel storage issues at these sites. To 

determine the benefits and challenges of transferring spent fuel from wet to 

dry storage, we reviewed documents from NRC, DOE, industry, and 

community groups. We also interviewed officials from NRC, DOE, and 

state regional organizations, and representatives of industry, academia, the 

Blue Ribbon Commission on America’s Nuclear Future,9

 

7

Our selection of sites was a judgmental sample based on reactor sites that met specific 

criteria, including the type of operating reactor, the type of dry storage systems used, and 

whether the reactor was operating or decommissioned. We found a group of reactors in 

the Northeast meeting these criteria, enabling us to visit sites in a single 1-week trip. 

Although our observations on the methods and risks of spent fuel storage are similar at all 

reactor sites, each site is sufficiently different that our specific observations at one site 

cannot be generalized to all reactor sites.

and community 

groups. Appendix I presents our scope and methodology in more detail.

8

GAO, 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).

9

In 2010, the administration directed DOE to establish this Blue Ribbon Commission of 

recognized experts to study nuclear waste management alternatives. The commission 

issued a report in January 2012.
 

Page 5 GAO-12-797 Accumulation of Spent Nuclear Fuel

We conducted this performance audit from June 2011 to August 2012, 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.

In the United States, the national inventory of commercial spent nuclear 

fuel amounts to nearly 70,000 metric tons, which is stored at 75 sites in 

33 states (see fig. 1).

Background
 

Page 6 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 1: Commercial Spent Nuclear Fuel Storage Sites

Note: Of the 75 sites, 65 have currently operating reactors, 7 have decommissioned reactors, 2 have 

reactors being decommissioned, and 1 site was constructed as a storage pool for spent fuel awaiting 

reprocessing. 
 

Page 7 GAO-12-797 Accumulation of Spent Nuclear Fuel

Fuel for commercial nuclear power reactors is typically made from lowenriched uranium fashioned into thumbnail-size ceramic pellets of 

uranium dioxide.10 These pellets are fitted into 12- to 15-foot hollow rods, 

referred to as cladding, made of a zirconium alloy.11

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

which most of the fuel it contains is spent, and the uranium dioxide is no 

longer cost-efficient at producing energy. Reactor operators typically 

discharge about one-third of the fuel assemblies every 18 months to 2

years and place this spent fuel in a pool to cool. Water circulates in the 

pool to remove the enormous heat generated from the radioactive decay 

of some of the radioisotopes. As long as circulating water continues to 

remove this heat, pool water temperature is maintained well below 

boiling, typically below 120 degrees Fahrenheit. If exposed to air, 

however, recently discharged spent fuel could rise in temperature by 

hundreds or thousands degrees Fahrenheit. A pool is needed to ensure 

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 a sustainable chain reaction that creates an 

enormous amount of heat and radioactivity. The heat is used to generate 

steam for a turbine, which generates electricity. The fragments created 

when fission splits atoms, or when bombarding neutrons bond with 

atoms, include hundreds of radioisotopes, or radioactive substances, 

such as krypton-90, cesium-137, and strontium-90. Furthermore, the 

neutron bombardment of uranium can also create heavier radioisotopes, 

such as plutonium-239. 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 fuel.

 

10Uranium is found naturally in the ground, consisting of about 99.3 percent of the 

nonfissile uranium-238, with only 0.7 percent fissile uranium-235. In its natural state, 

uranium is only slightly radioactive and can be handled without shielding. To make fuel for 

a commercial power reactor, the proportion of uranium-235—which is responsible for a 

sustainable nuclear chain reaction—must be enriched to 3 to 5 percent, but even this 

enrichment requires little shielding from heat or radioactivity. It is not until after the 

uranium is irradiated in a reactor and is bombarded with neutrons that it becomes 

hazardous because of production of other radioisotopes.

11A zirconium alloy is used because of its resistance to corrosion and low absorption of 

neutrons, meaning it does not interfere with the nuclear chain reaction.

Commercial Nuclear 

Reactor Operations and 

Storage of Spent Fuel
 

Page 8 GAO-12-797 Accumulation of Spent Nuclear Fuel

that heat generated from the decay of radioisotopes, particularly 

immediately after discharge from a reactor, does not damage fuel rods 

and release radioactive material. Figure 2 shows a fuel pellet for a 

commercial nuclear reactor and a fuel rod in an assembly.

Figure 2: Fuel Pellet and Fuel Rod Assembly for a Commercial Nuclear Power Reactor

The pools of water are typically about 40 feet deep, with at least 20 feet of 

water covering the spent fuel, and the water is cooled and circulated to 

keep the assemblies from overheating. These pools are constructed 

according to NRC’s requirements, typically 4- to 6-feet thick with steelreinforced concrete and a steel liner. The pools must be located inside 

what is known as the vital area of a nuclear power reactor, protected by 

armed guards, physical barriers, and limited access. Within the vital area, 
 

Page 9 GAO-12-797 Accumulation of Spent Nuclear Fuel

pools may be in one of two locations, depending on the type of reactor. In 

a pressurized water reactor, spent fuel is stored in a pool at or below 

ground level,12 but in a typical boiling water reactor, spent fuel is stored in 

a pool well above ground level, near the reactor vessel, as high as three 

stories above ground.13

 

12In addition, a pressurized water reactor has two independent loops: one to carry heat to 

a steam generator and one to carry nonradioactive steam to a turbine to generate 

electricity. In a boiling water reactor, steam generated by the reactor goes directly to a 

turbine, and after leaving the turbine, the slightly radioactive steam is condensed into 

water and recycled back to the reactor.

Figure 3 shows the location of a spent fuel pool 

for a boiling water reactor, and figure 4 shows a typical spent fuel pool.

13The reactors damaged at the Fukushima Daiichi nuclear power plant complex in Japan 

were boiling water reactors. The Japanese had difficulty accessing one of the reactor’s 

spent fuel pools because of its height above ground. According to NRC, all but 4 of the 35 

boiling water reactors in the United States have similar designs. The spent fuel pools at 

these 4 boiling water reactors are situated in a separate fuel storage building at or near 

ground level.
 

Page 10 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 3: Location of a Spent Nuclear Fuel Pool in a Boiling Water Reactor
 

Page 11 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 4: Spent Nuclear Fuel Pool

As part of the construction permit and operating license application process 

for nuclear reactors, NRC requires companies licensed to operate these 

reactors to assess natural hazards, such as earthquakes, floods, 

hurricanes, and tidal waves that their reactors might face. Reactor 

operators must also show that their proposed pool designs would survive 

the most severe natural hazards, or combinations of less severe hazards, 

expected for that particular area.14

 

14See GAO, Nuclear Regulatory Commission: Natural Hazard Assessments Could Be 

More Risk-Informed, 

Since the Fukushima Daiichi disaster, 

NRC has required reactor operators to reevaluate their original design 

criteria against more recent seismic information that has been developed 

since many of the nuclear power plants were first licensed. According to 

NRC documents, NRC developed its requirements with a concept of 

“defense-in-depth,” which is a way of designing and operating nuclear 

GAO-12-465 (Washington, D.C.: Apr. 26, 2012).
 

Page 12 GAO-12-797 Accumulation of Spent Nuclear Fuel

power reactors that focuses on creating multiple independent and 

redundant layers of defense to compensate for potential human and 

mechanical failures so that no single layer, no matter how robust, is 

exclusively relied upon.15

To remove a spent fuel assembly from the reactor, an operator must stop 

the nuclear chain reaction, then allow the water in the reactor to 

depressurize and cool before accessing the fuel assemblies, a process 

that typically takes several days. Once spent fuel is discharged from a 

reactor and placed in a pool, the spent fuel continues to decay into other 

substances and continues to generate enormous amounts of heat.16

 

15According to NRC, the defense-in-depth concept is not defined in NRC regulations, and 

no single, agency-accepted description of the concept exists. Nevertheless, the term 

includes the use of access controls, physical barriers, redundant and diverse key safety 

functions, and emergency response measures.

For 

example, plutonium-239—one of the components of spent fuel—decays 

into various radioactive substances, such as thorium and radium, and 

eventually decays into a stable, nonradioactive form of lead, although the 

entire process may take millions of years. As a general rule, the older the 

spent fuel, the cooler and less hazardous it is, but the spent fuel still has 

enough long-lived components to make it dangerous to humans and the

environment for tens of thousands of years. When in an intact assembly, 

these components are dangerous only to nearby persons if the assembly 

is not adequately shielded and is only dangerous to the public and 

environment if its components are aerosolized and dispersed. Different 

components of the spent fuel decay at different rates, but many of the 

more hazardous components decay quickly. For example, iodine-131 has 

a half-life of 8.04 days and will be virtually gone within 3 months. 

(Radioactive iodine can congregate in the thyroid and cause thyroid 

cancer. For this reason, some populations living near nuclear power 

plants have been given iodine tablets to take if advised to do so during an 

event to reduce the likelihood of developing cancer in the event of a 

16All radioactive substances—referred to as radioisotopes—are unstable and 

spontaneously transform themselves into more stable isotopes by capturing or emitting 

atomic particles or by fission. The time it takes a radioisotope to decay into more stable 

substances is measured by a half-life. A half-life is the length of time it takes for one-half 

of a particular radioisotope to decay into a new isotope. After two half-lives, one-quarter of 

the original radioisotope will be left, but three-quarters will have changed to the new 

isotope. After 10 half-lives, only 1/1,000 of the original radioisotope is left.
 

Page 13 GAO-12-797 Accumulation of Spent Nuclear Fuel

nuclear emergency.17

Typically, according to NRC officials, spent fuel must remain in a pool for at 

least 5 years to decay enough to remain within the heat limits of currently 

licensed dry cask storage systems. Spent fuel cools very rapidly for the first 

5 years, after which the rate of cooling slows significantly. Spent fuel can 

be sufficiently cool to load into dry casks earlier than 5 years, but doing so 

is generally not practical. Some casks may not accommodate a full load of 

spent fuel because of the greater heat load. That is, the total decay heat in 

these casks needs to be limited to prevent the fuel cladding from becoming 

brittle and failing, which could affect the alternatives available to manage 

spent fuel in the future, such as retrieval. In recent years, reactor operators 

have moved to a slightly more enriched fuel, which can burn longer in the 

reactor. Referred to as high-burn-up fuel, this spent fuel may be hotter and 

more radioactive coming out of a reactor than conventional fuel and may 

have to remain in a pool for as long as 7 years to cool sufficiently.

) In contrast, cesium-137 has a half-life of 30.2 

years and will take over 300 years to decay to negligible amounts. 

Cesium-137 contributes to the decay heat in a spent fuel pool and is a 

significant land contaminant if released.

In the original designs submitted for spent fuel pools, fuel assemblies 

were packed in relatively low densities, but operators have replaced these 

low-density racks with higher-density racks to store more spent fuel.

According to NRC officials, NRC accepts high-density storage of spent 

fuel if certain conditions are met, such as adequate cooling, the 

maintenance of structural integrity, and the prevention of a critical chain 

reaction. Neutron-absorbing materials can be used to keep closely 

packed assemblies from starting a chain reaction.18

 

17Taking potassium iodine tablets floods the thyroid with nonradioactive iodine so the 

thyroid cannot absorb radioactive iodine-131. Children are particularly susceptible to 

cancer from iodine-131.

As pools began to fill 

in the 1980s, NRC conducted several safety studies on the impact of 

increasing the density of spent fuel in pools and determined that the risk 

of a potential release from overheating or igniting, or even of a critical 

chain reaction from the dense geometric configuration, was small, 

particularly if certain steps were taken to reduce the risk. Even with re18Neutron-absorbing material typically contains boron, which absorbs neutrons and will 

help prevent a nuclear chain reaction. NRC has identified some issues with degradation of 

the boron plates in boiling water and pressurized water reactors and asked operators to 

monitor their condition.
 

Page 14 GAO-12-797 Accumulation of Spent Nuclear Fuel

racking to a dense configuration, however, spent nuclear fuel pools are 

reaching their capacities and may contain several thousand assemblies 

each.

As reactor operators have run out of space in their spent fuel pools, more 

operators have turned to dry cask storage systems. These systems consist 

of a steel canister protected by an outer cask made of steel or steel and 

concrete to provide shielding from the heat and radiation of spent fuel. 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 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 lid is welded onto the canister, and the water drained. 

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

canister is maneuvered into the storage cask. The storage casks, in either 

vertical or horizontal designs, are usually situated on a large concrete pad 

surrounded by safety systems and a security infrastructure, such as 

radiation detection devices and intrusion detection systems. The transfer 

process has become routine at some power plants (see fig. 5).
 

Page 15 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 5: Canister in a Transfer Cask in a Spent Nuclear Fuel Pool

In addition to regulating the construction and operation of commercial 

nuclear power plants, NRC also regulates spent fuel in dry storage. NRC 

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

offer protection from significant amounts of radiation. NRC evaluates the 

design of passively air-cooled dry storage systems for resistance to 

certain natural disasters, such as floods, earthquakes, tornado missiles, 

and temperature extremes. NRC may require physical tests of the 

systems, or it may accept information derived from scaled physical tests 

and computer modeling. For example, dry storage systems must be able 

to withstand, among other things, being dropped from the height to which 

it would be lifted during operations; being tipped over by seismic activity, 

weather, or other forces or accidents; fires; and floods. NRC has also 

analyzed the performance of dry storage systems in different terrorist 

attack scenarios. Once a dry storage system is approved, NRC issues a 

certificate of compliance for a cask design. Currently, NRC may issue a 
 

Page 16 GAO-12-797 Accumulation of Spent Nuclear Fuel

cask certificate for a term not to exceed 40 years.19 Similarly, NRC may 

renew a cask certificate for a term not to exceed 40 years (see fig. 6).20

Figure 6: Spent Fuel in Dry Storage

The length of time that spent fuel can safely be stored in dry casks is 

uncertain. We earlier reported that experts agree that spent fuel can be 

safely stored for up to about 100 years, assuming regular monitoring and 

maintenance.21

 

19Cask certificates issued before May 17, 2011, expire 20 years from the date of issuance 

and may be renewed for an additional 20 years. In February 2011, NRC amended part 72 

to change the 20-year term and renewal period to a term not to exceed 40 years. 76 Fed. 

Reg. 8872, 8875-76. (Feb. 16, 2011). 10 C.F.R. § 72.238 (2012).

In December 2010, NRC issued a determination and 

associated rule stating that spent fuel can be safely stored for up to 60 

2010 C.F.R § 72.240(a) (2012).

21GAO-10-48. 
 

Page 17 GAO-12-797 Accumulation of Spent Nuclear Fuel

years beyond the licensed life of the reactor in a combination of wet and 

dry storage.22 Four states, an Indian community, and environmental 

groups petitioned for review of NRC’s rule, however, arguing in part that 

NRC violated the National Environmental Policy Act by failing to prepare 

an environmental impact statement in connection with the 

determination.23 On June 8, 2012, the U.S. Court of Appeals for the 

District of Columbia Circuit held that the rulemaking did require 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 has not yet indicated what actions it will 

take in response to the court’s action. On August 7, 2012, the 

commissioners voted not to issue final licenses dependent on the 

determination and rule until it addresses the court’s remand, however, the 

commission is currently preparing an environmental impact statement on 

the effects of storing spent fuel for 200 years. In addition, NRC, DOE, and 

industry are conducting a series of studies to evaluate the regulatory 

actions or additional engineering measures needed for long-term storage 

of spent fuel to account for possible degradation of the canisters or the 

spent fuel in the canisters.

Since the 1950s, even before operation of the first commercially licensed 

nuclear power reactor in the United States, the federal government 

recognized the need to manage the back end of the fuel cycle—spent 

nuclear fuel removed from a reactor. A 1957 National Academy of 

Sciences report endorsed deep geological formations to isolate high-level 

radioactive waste, which includes spent nuclear fuel, but during the 1950s 

and 1960s, nuclear waste management received relatively little attention 

 

22NRC first issued the determination and rule in 1984 and updated them in 1990. Because 

the licensed life of a reactor may include the term of a revised or renewed license, which 

together may extend to 60 years, NRC’s determination extends to 120 years. The 

determination and rule also state that NRC believes that sufficient mined geologic 

repository capacity will be available when necessary. 75 Fed. Reg. 81037 (Dec. 23, 2010); 

10 C.F.R. § 51.23 (2012). NRC has stated that, as a matter of policy, it will not license 

reactors if it does not have reasonable confidence that the spent fuel can be disposed of 

safely and that spent fuel, if properly stored and monitored, can be kept safe and secure 

on site for decades.

23The National Environmental Policy Act requires federal agencies to evaluate the likely 

environmental effects of a proposed project using an environmental assessment or, if the 

project is likely to significantly affect the environment, a more detailed environmental 

impact statement evaluating the proposed project and alternatives. 42 U.S.C. §§ 4321-

4347 (2006).

Federal Efforts to Identify 

and Develop a Site for a 

Spent Fuel Repository
 

Page 18 GAO-12-797 Accumulation of Spent Nuclear Fuel

from policymakers. The early regulators and developers of nuclear power 

viewed waste disposal primarily as a technical problem that could be 

solved when necessary by applying existing technology. Attempts were 

made to reprocess the spent nuclear fuel—that is, to reuse some useful 

elements remaining in a spent fuel assembly after it is discharged from a 

reactor, such as unfissioned uranium-235—but this process was not 

pursued because of economic issues and concerns that reprocessed 

nuclear materials raise proliferation risks.24

As noted above, the Nuclear Waste Policy Act of 1982 charged DOE with 

investigating sites for a federal geologic repository and authorized DOE to 

contract with reactor operators to take custody of spent fuel for disposal 

at the repository beginning in 1998. In 1987, Congress amended the 

Nuclear Waste Policy Act to direct DOE to focus its efforts only on Yucca 

Mountain for a repository. DOE did not submit a license application for 

Yucca Mountain until 2008, however—10 years after it was supposed to 

start taking custody of spent fuel. In 2009, DOE announced that it 

planned to terminate its work related to the Yucca Mountain repository, 

and in 2010 it filed a motion to withdraw the license application. NRC’s 

licensing board denied the motion, but DOE continued to take steps to 

dismantle the repository project. In September 2011, the NRC 

commissioners considered whether to overturn or uphold the licensing 

board’s decision, but they were evenly divided and unable to take final 

action on the matter. Instead, the NRC commissioners directed the 

licensing board to suspend work by September 30, 2011. NRC’s failure to 

consider the application, among other things, is being contested in federal 

court. Several parties have filed a petition against NRC asking the federal 

court to, among other things, compel NRC to provide a proposed 

schedule with milestones and a date for approving or disapproving the 

license application. Currently, it remains uncertain whether NRC will have 

to resume its license review efforts and whether a repository at Yucca 

Mountain will be built. In the interim, in 2010, the administration directed 

DOE to establish a Blue Ribbon Commission of experts to study an array 

of nuclear waste management alternatives. DOE established the 

 

24Over 95 percent of spent fuel consists of uranium and plutonium that can be 

reprocessed and reused as fuel in a commercial power reactor. Concerns have been 

raised, however, that separating plutonium from other components of spent fuel raises 

proliferation risks, since plutonium can be used to make nuclear weapons. See GAO, 

Nuclear Fuel Cycle Options: DOE Needs to Enhance Planning for Technology 

Assessment and Collaboration with Industry and Other Countries, GAO-12-70 

(Washington, D.C.: Oct. 17, 2011).
 

Page 19 GAO-12-797 Accumulation of Spent Nuclear Fuel

commission, which studied alternatives including options for interim 

storage of spent fuel and permanent disposal. In its January 2012 report, 

the commission recommended that the nation adopt centralized storage 

of some spent fuel as an interim measure but, at the same time, develop 

a process to find and license a site for a permanent repository. With 

nowhere to send the spent fuel, operators must keep it on-site at 

decommissioned and operating commercial reactors until some option to 

move it off-site becomes available.

Countries other than the United States also produce electricity from 

nuclear power reactors and have programs to manage their spent nuclear 

fuel. Some countries, such as France, store their spent fuel in pools until 

it can be reprocessed, and other countries, such as Canada, use both wet 

and dry storage systems. Following the accident at Fukushima, Japan 

temporarily shut down its nuclear reactors, but it has restarted one and 

may restart others. Several countries have programs to develop 

permanent disposal facilities. See appendix II for more information on 

other countries’ programs.

The amount of spent fuel accumulating at commercial reactor sites is 

expected to increase by about 2,000 metric tons each year until it can 

begin to be shipped off-site and, even then, shipping it off-site will be a 

decades-long process. By then, currently operating reactors will begin to 

retire, dismantling their spent fuel pools and leaving the spent fuel 

stranded in dry storage canisters with limited options for repackaging 

them, should repackaging be required to replace degraded canisters, or 

to meet transportation or disposal requirements.

The amount of spent fuel is expected to more than double to about 

140,000 metric tons by 2055, when the last of currently operating reactors 

is expected to retire, according to the Nuclear Energy Institute, but it may 

take at least that long to ship the spent fuel off-site. This amount is based 

on the assumption that the nation’s current reactors continue to produce 

spent nuclear fuel at the same rate—about 2,000 additional metric tons 

annually; that no new reactors are brought online; and that some decline 

in the generation of spent fuel takes place as reactors are retired. At the 

end of 2012, over 69,000 metric tons is expected to accumulate at 75 

Large Quantities of 

Spent Nuclear Fuel 

Are Expected to 

Remain at 

Commercial Reactor 

Sites for Decades

Spent Nuclear Fuel Could 

Nearly Double before 

Being Transported to a 

Storage or Disposal 

Facility
 

Page 20 GAO-12-797 Accumulation of Spent Nuclear Fuel

sites in 33 states, enough to fill a football field about 17 meters deep.25

Current industry practice has been to store the spent fuel in the pools, 

with an industry expectation that, at some point, DOE would begin to take 

custody of it. In 2011, about 74 percent of commercial spent fuel was 

stored in pools, and the remaining 26 percent was in dry storage, but 

these proportions will slowly change as more pools fill and the spent fuel 

is transferred to dry storage. According to the Nuclear Energy Institute, by 

2025, assuming no new reactors, the proportion of spent fuel in wet 

storage and dry storage should be roughly equal, about 50,000 metric 

tons in each. Shortly after 2055, when the last currently operating 

reactors’ licenses are expected to expire, and the reactors are expected 

to retire, virtually all the spent fuel arising from the current fleet will have 

been moved to dry storage. Figure 7 shows the trend of accumulated 

spent fuel and the rate of spent fuel transferred from wet storage to dry 

storage through 2067, according to our analysis of Nuclear Energy 

Institute data.

Without central storage options or an available permanent disposal 

facility, spent fuel continues to accumulate at the sites where it was 

generated.

 

25The expected accumulation of about 140,000 metric tons of spent fuel by about 2055 

does not include spent fuel from new reactors. By 2016, NRC projects it will have received 

23 applications to construct 37 new nuclear power reactors. For example, 2 new reactors 

are currently under construction in Georgia.
 

Page 21 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 7: Trends in Accumulation of Spent Nuclear Fuel Overall and in Wet and Dry Storage

When it became evident that DOE was likely decades behind its deadline 

to pick up spent fuel, nuclear power plant operators began transferring 

spent fuel to dry storage to retain enough space in their pools to safely 

discharge fuel from their reactors. The rate of transfer differs by the 

operating and spent fuel characteristics of the reactor—that is, reactor 

type and size—as well as the size of the spent fuel pool. In general, 

reactor operators must transfer an average of three to six canisters each 

year to keep pace with the discharge of spent fuel from their reactors. 

Table 1 provides data on reactors and spent fuel and the rate of transfer 

anticipated to dry storage.
 

Page 22 GAO-12-797 Accumulation of Spent Nuclear Fuel

Table 1: Typical Reactor Characteristics and 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 reactor 193 assemblies

(87 metric tons)

72 to 84 assemblies 

every 18 months

(32 to 38 metric tons)

32 assemblies

(14.4 metric tons)

3-6 canisters annually

Boiling water reactor 560 assemblies

(101 metric tons)

224 assemblies every 

24 months

(40 metric tons)

61 assemblies

(11 metric tons)

4 canisters biennially

Sources: GAO analysis of data from the Electric Power Research Institute and the Nuclear Energy Institute.

Note: Estimates were developed by the Electric Power Research Institute and the Nuclear Energy 

Institute to represent typical systems. 

Reactor operators continue to fill their spent fuel pools until capacity is 

reached, in part because the transfer of spent fuel to dry storage is costly 

and time-consuming. Specifically, operators must take extensive steps to 

ensure that safety precautions to protect workers and the public are met. 

Before an operator can transfer a single fuel assembly to dry storage, the 

operator must train personnel and practice the procedure. According to 

industry representatives, these efforts involve several weeks of mobilization 

and demobilization of equipment before and after the transfer. The transfer 

of spent fuel to a single canister typically takes at least 1 week.

The amount of spent fuel that accumulates and is stored on-site will also 

be affected by the timing of an off-site central storage or permanent 

disposal facility, if and when one becomes available. To estimate the 

amount of accumulation at commercial nuclear power plants before an 

off-site facility becomes available, we considered three scenarios: 

(1) Yucca Mountain as a permanent disposal facility, (2) two federally 

funded centralized storage facilities, and (3) an alternative permanent 

disposal facility. For purposes of our analysis, we assumed that each 

storage facility would be licensed by NRC and funded by Congress. 

Furthermore, for each scenario, we recognized that multiple factors could 

affect the projected time frame. These factors include the siting, licensing, 

and construction, and the start of operations of the storage or disposal 

facility, as well as the time needed to ship spent fuel to the off-site facility 

and reduce the backlog of already-accumulated spent fuel. For each 

scenario, we made certain assumptions and incorporated them into our 

analyses. We estimated the earliest likely dates that Yucca Mountain, two 

federal centralized storage facilities, or a permanent repository could be 

opened. Our analysis was based on information from our prior work in 
 

Page 23 GAO-12-797 Accumulation of Spent Nuclear Fuel

analyzing alternatives to a repository at Yucca Mountain, including expert 

input to develop assumptions to model the time frames for different 

scenarios for spent fuel management.26

Our analysis showed that regardless of which storage or disposal scenario 

was considered, it would take at least 15 years to open an off-site location 

and decades to ship the spent fuel once the central storage or disposal 

facility became available. The time needed for shipment depends on the 

amount of fuel accumulated and assumes a shipment rate of 3,000 metric 

tons per year—the rate that DOE developed as part of its plans for Yucca 

Mountain. Experts we consulted in our prior work agreed this rate was 

reasonable. A faster or slower shipping rate could affect the rate of 

continued accumulation or drawdown of the backlog. When we conducted 

our analysis in 2009, we reported that Yucca Mountain—the first 

scenario—was likely to offer the earliest option for off-site disposal, in 2020. 

Since then, the process for licensing Yucca Mountain has stopped, and it is 

unclear whether the licensing process will be resumed; in addition, many 

key workers who worked on Yucca Mountain have left DOE for other 

employment or retirement. If the licensing process for Yucca Mountain 

were resumed in 2012, we estimate that DOE would require roughly at 

least 15 more years to open the site as a repository, or sometime around 

2027. We estimate that the second scenario—for the federal government to 

site, license, construct, and open two centralized storage facilities—might 

take about 20 years, with completion in 2032, because of the complexities 

in siting, licensing, and constructing such facilities. We estimate that the 

third scenario—for a potential permanent disposal facility as an alternative 

to the Yucca Mountain repository—would take the longest to be realized, 

about 40 years, or 2052, because of the additional scientific analysis 

required to ascertain the safety of a permanent disposal facility. Figure 8 

shows the amount of spent fuel that is expected to accumulate in each 

state for the years 2012; 2027 (the earliest likely opening date if the Yucca 

Mountain repository were to be licensed and constructed); 2032 (the 

earliest a centralized storage facility could be expected to open); 2052 (the 

earliest a permanent disposal facility other than Yucca Mountain could be 

expected to open); and 2067, when all currently operating commercial 

nuclear power reactors are expected to have retired and transferred their 

spent fuel to dry storage.

See appendix I for more details 

on our methodology for this analysis.

 

26GAO-10-48. 
Page 24 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 8: Accumulation of Commercial Spent Fuel by State Over Time Interactive Graphic

	 Instructions: Online, hover over the state names in the graphic for more information.

For print version, see appendix III, page 57.

Resolving the issue of what to do with commercial spent nuclear fuel will 

likely be a decades-long, costly, and complex endeavor. Planning ahead 

to allow reactor operators and local communities to make better-informed 

and forward-looking decisions is important in such a complex 

undertaking. For example, DOE had earlier created designs for a specific 

type of canister for disposal at the Yucca Mountain repository, and had 

informed reactor operators that all spent fuel destined for Yucca Mountain 

needed to be packaged in this specific canister, called a transportation, 

aging, and disposal canister. Although the canister had not gone into
 

Page 25 GAO-12-797 Accumulation of Spent Nuclear Fuel

commercial production, its design specifications had at least informed 

reactor operators. Now that both DOE and NRC have suspended their 

licensing efforts for the Yucca Mountain repository, a great deal of 

uncertainty exists about future spent fuel management. Given this 

uncertainty, it may be difficult for reactor operators to make decisions 

about issues such as the rate of transferring spent fuel to dry storage and 

the type of canister to be used for disposal.

During the decades it will take to open a storage or disposal facility, many 

reactors will be retiring from service, “stranding” their accumulated spent 

fuel in a variety of different dry storage systems, with no easy way of 

repackaging them should repackaging be required to meet storage or 

disposal requirements. Most U.S. reactors were built during the 1960s 

and 1970s and, after a 40-year licensing period with a possible 20-year 

extension, will begin retiring in large numbers by about 2030 and 

emptying their pools by about 2040. NRC regulations require radioactive 

contamination to be reduced at a reactor to a level that allows NRC to 

terminate the reactor license and release the property for other use after 

a reactor shuts down permanently. This cleanup process—known as 

decommissioning—costs hundreds of millions of dollars per reactor, and 

NRC is responsible for ensuring that operators provide reasonable 

assurance that they will have adequate funds to decommission their 

reactors.27

 

27See GAO, Nuclear Regulation: NRC’s Oversight of Nuclear Power Reactors’ 

Decommissioning Funds Could Be Further Strengthened,

Once a spent fuel pool is removed, reactor operators will have 

limited options for managing spent fuel. For example, if reactor operators 

need to repackage their spent fuel because a canister has degraded or 

because other transportation or disposal requirements must be met, they 

will have to build a new spent fuel pool or some other dry transfer facility, 

or they will need to ship their spent fuel to another site with a wet or dry 

transfer facility.

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 fuel cools and 

decays over a longer period. In these scenarios, we assumed that operators will 

immediately decommission their reactors, placing their spent fuel in dry storage and 

disposing of the rest of their radioactive waste, including the reactor and the spent fuel 

pool, as either low-level waste or as slightly more radioactive waste called greater-thanclass-C waste.

As Many Nuclear Reactors 

Begin Closing in 2040, 

Growing Quantities of 

Spent Fuel May Be 

Stranded in Place
 

Page 26 GAO-12-797 Accumulation of Spent Nuclear Fuel

As of January 2012, the United States had nine decommissioned 

commercial nuclear power plant sites. Seven of these plants have 

completely removed spent fuel from their pools—a total of 1,748 metric 

tons—as well as all infrastructure except that needed to safeguard the 

spent fuel.28

Assuming that no centralized storage or permanent disposal facility 

becomes available, our analysis indicates that by 2040, the amount of 

stranded spent fuel in closed commercial nuclear power plants will total 

an estimated 3,894 metric tons; by 2045, that amount could increase to 

28,751 metric tons; and by 2050, the amount could be 62,237 metric tons. 

By 2067, nearly all of the 140,000 metric tons of spent fuel could be 

stranded in dry storage. Figure 9 shows the expected pattern of growth 

for total accumulated spent fuel compared with that of spent fuel from 

decommissioned reactors, or stranded spent fuel.

The other two sites, which have a total of 5,103 metric tons 

of spent fuel in both wet and dry storage, are in the process of emptying 

their pools and transferring all their spent fuel to dry storage.

 

28These sites include Big Rock Point in Michigan, Haddam Neck in Connecticut, Humboldt 

Bay and Rancho Seco in California, Maine Yankee in Maine, Trojan in Oregon, and 

Yankee Rowe in Massachusetts. In addition to these decommissioned sites, an additional 

spent fuel pool is located in Morris, Illinois. This pool was built and filled with spent fuel in 

anticipation of reprocessing into usable nuclear fuel, but when reprocessing was 

suspended, the spent fuel remained in the pool, essentially stranded.
 

Page 27 GAO-12-797 Accumulation of Spent Nuclear Fuel

Figure 9: Growth Trend of Total Spent Fuel Compared with Spent Fuel from Decommissioned Reactors

Note: The data assume that additional spent fuel will not be generated by new reactors or extension 

of reactor licenses beyond 60 years. 

According to several studies on spent fuel storage, the key risk of storing 

spent fuel at reactor sites is radiation exposure from spent fuel that has 

caught fire when it is stored in a pool, but it is difficult to quantify the 

probability of such an event. Nuclear reactor operators have put into 

place several efforts to mitigate the effects of such a fire, although 

disagreement exists on the mitigation needed. In contrast to pool storage, 

spent fuel in dry storage is less susceptible to severe radiological 

releases. Furthermore, NRC has no centralized database to help identify, 

locate, and access classified studies on spent fuel.

The Key Risk of 

Stored Spent Fuel Is 

Difficult to Quantify, 

but Some Mitigating 

Actions Have Been 

Taken
 

Page 28 GAO-12-797 Accumulation of Spent Nuclear Fuel

Radiation exposure—from a minor dose resulting from a work-related 

accident to a severe, widespread release of radiation from a spent fuel 

fire—is the key concern about the hazard of storing spent nuclear fuel. 

According to studies we reviewed and NRC officials and representatives 

of other groups we spoke with, the worst-case scenario for spent fuel at 

reactor sites is the possibility of a self-sustaining fire in a spent fuel pool, 

which could engulf all assemblies in the pool, with significant 

consequences. According to the analysis in a February 2001 NRC study, 

assuming a high release of radiation, the release of spent fuel fission 

products resulting from a pool fire could result in nearly 200 early 

fatalities, thousands of subsequent cancer fatalities, and widespread land 

contamination. These early fatalities could be reduced or eliminated, 

according to the study, if the radiation release was less severe and if 

there were an early evacuation of the affected population. NRC officials 

told us that the assumptions used in that study were very conservative 

and that they believed that a lower release of radiation and an early 

evacuation are more representative of potential scenarios involving 

operating nuclear power reactors. A 2006 National Academy of Sciences 

study also found that a spent fuel fire could release large quantities of 

radioactive materials into the environment and cause widespread 

contamination.

NRC officials, as well as studies by Sandia National Laboratories 

(commissioned by NRC) and the National Academy of Sciences (2006), 

informed us about the conditions that could lead to a fire. Such a fire 

could occur only if enough water in the spent fuel pool were lost, such as 

through drainage or boiling away, exposing roughly the top half of the fuel 

assemblies.29

 

29As reported by the 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. Nevertheless, the water level at Fukushima 

did not drop to levels at which a fire could start.

Without sufficient water to keep spent fuel covered and 

cool, it is possible that some of the hotter assemblies—those most 

recently discharged from a reactor—could ignite. Furthermore, once 

started, a fire in a spent fuel pool would be very difficult to extinguish 

because, in such a case, the zirconium alloy making up the metal 

cladding surrounding the assemblies would react with oxygen and, when 

Radiological Release from 

a Pool Fire Is the Key Risk 

Posed by Spent Fuel 

Storage, but Quantifying 

This Probability Is Difficult
 

Page 29 GAO-12-797 Accumulation of Spent Nuclear Fuel

a certain temperature was reached, would begin a chemical reaction that 

releases energy and raises the temperature. Essentially, the fire becomes 

hotter and self-sustaining and, depending upon the density of spent fuel 

in the pool, could spread to other assemblies. On the basis of studies 

cited by NRC officials and a Sandia National Laboratories study, a fire in 

a fully drained pool can start at about 1,830 degrees Fahrenheit (about 

1,000 degrees Celsius). A zirconium fire does not involve flames; rather, it 

burns like a welding torch.

A zirconium fire can start only if a complex series of conditions occurs. 

NRC and other studies indicate that such a fire is not likely. Furthermore, 

the physical protection features and mitigation measures at nuclear power 

reactors make the probability of a fire in a spent fuel pool very low. First, 

there must be an initiating event,30

Whether a self-sustaining fire starts and spreads depends on additional 

variables, according to Sandia National Laboratories studies 

commissioned by NRC from 2003 through 2006 to assess the effects of 

some of these variables for pool fires. Two important variables are:

such as an earthquake more severe 

than the pool was designed to withstand, an accidental drop of a cask 

during dry cask loading operations, or a terrorist attack. Second, the 

initiating event must result in a critical loss of water, such as through a 

breach in the pool wall or floor that would allow water to drain out. Third, 

the reactor operator must be unable to respond adequately to a water 

loss, such as being unable to replenish lost pool water sufficiently to cool 

the assemblies.

• The age and the heat of the spent fuel. Spent fuel is hottest when first 

discharged from a reactor but cools relatively quickly. The risk of a 

zirconium fire is much greater with recently discharged fuel than with 

older fuel.

• The size of a hole in the pool and subsequent rate of water drainage. 

A Sandia National Laboratories study analyzed the effects of 

differently sized holes for various fuel assembly configurations, fuel 

ages, ventilation assumptions, and replacement water scenarios, and 

this analysis showed that larger holes and drainage rates, all other 

 

30In this report, we use the term “event” to generally describe a situation involving an 

accident or attack on a spent fuel pool. We also use the term “initiating event” to specifically 

describe the first action that takes place to trigger severe damage to a spent fuel pool.
 

Page 30 GAO-12-797 Accumulation of Spent Nuclear Fuel

factors being equal, resulted in higher temperatures of the fuel 

assemblies.

NRC officials told us that, from a regulatory perspective, the risks of an 

event causing a large release of radiation that endangers public safety 

from spent fuel in either wet or dry storage are low enough to be within 

acceptable limits of risk. NRC officials also said the agency considers risk 

to be the probability of an event occurring multiplied by the consequences 

of that event and has determined that a spent fuel fire is a low-probability, 

high-consequence event. In 2001, an NRC study estimated the frequency 

of having spent fuel pool assemblies uncovered and exposed to the air to 

be, on average, an event that occurs once every 420,000 years.31

Independent studies we reviewed indicate the difficulty of quantifying the 

level of risk of stored spent fuel. Examples of these studies follow:

NRC 

officials told us the agency did not update its quantitative likelihood 

estimates after the September 11, 2001, terrorist attacks. Since

Fukushima Daiichi, NRC has been engaged in ongoing initiatives related 

to items such as addressing a loss of off-site electricity and seismic 

hazard reevaluation. It has been conducting a study on the consequences 

of accident scenarios affecting spent fuel pools and is undertaking a 

probabilistic risk assessment to quantify spent fuel risk for a selected 

reactor site of interest.

• The Institute for Resource and Security Studies, a Massachusettsbased technical and policy research group, reported in 2009 that the 

methodology needed to estimate the probability of nuclear accidents 

is complex, requiring consideration of internal and external initiating 

events, analyses involving uncertainty, peer review, and estimates of 

radiological consequences.

• The National Academy of Sciences stated in a 2006 study that the 

probability of a terrorist attack on spent fuel storage cannot be 

assessed quantitatively or comparatively and that it is not possible to 

predict the behavior and motivations of terrorists. This study noted, 

and a National Academy of Sciences official expressed concern, that 

in the NRC-sponsored studies available when the National Academy 

 

31Nuclear Regulatory Commission, Technical Study of Spent Fuel Pool Accident Risk at 

Decommissioning Nuclear Power Plants, NUREG-1738 (Washington, D.C.: 

February 2001).
 

Page 31 GAO-12-797 Accumulation of Spent Nuclear Fuel

of Sciences was performing its work, NRC did not examine some lowprobability scenarios that could result in severe consequences and 

that, although unlikely, should be protected against.

Efforts to mitigate safety and security risks could reduce the effects of key 

factors in the dynamics of a potential fire in a spent fuel pool, according to 

our analysis of Sandia National Laboratories studies on pool fire 

scenarios. Still, disagreement exists—largely between community action 

groups and NRC—as to the appropriate density of assemblies in a spent 

fuel pool.

Storage configurations that disperse the hottest spent fuel assemblies are 

among the most important mitigation efforts that Sandia National 

Laboratories has identified. NRC and community action groups differ, 

however, on the extent to which these efforts should be employed. In 

2011, Sandia National Laboratories reported on its study of the safety and 

security benefits presented by five different fuel configurations in a 

storage pool. According to this study, it is preferable to employ 

configurations that place the more recently discharged, hotter assemblies 

away from each other—the farther the better—and intersperse them with 

older, cooler assemblies or, preferably, with empty adjacent cells. NRC 

has provided regulatory guidance to reactor sites to take advantage of 

these safer configurations.

Representatives from community action groups we interviewed said that 

even with NRC’s mitigation efforts, spent fuel pools remain too densely 

packed and that the total amount of spent fuel in the pools should be 

reduced by accelerating the transfer of spent fuel into dry storage. In 

addition, a 2003 study led by a scholar at a community action group 

proposed open rack storage for spent fuel pools. Under this proposal, 20 

percent of the pool assemblies would be transferred to dry storage, which 

would then allow an open channel on each side of the pool. This 

configuration would help promote air convection between the assemblies 

and, in turn, reduce the probability of an ignition and subsequent spread 

to other assemblies. The fewer assemblies that catch fire, the smaller the 

amount of potential radiation that could be released into the 

Mitigation Efforts Could 

Reduce the Likelihood of 

Severe Consequences, but 

Disagreement Exists on 

the Mitigation Needed

Fuel Assembly Configurations 

and Density in Pools
 

Page 32 GAO-12-797 Accumulation of Spent Nuclear Fuel

atmosphere.32

NRC requires nuclear reactor sites to develop and implement strategies 

to maintain or restore cooling of reactor cores, containment, and cooling 

capabilities for spent fuel pools under circumstances due to explosions or 

fire—a requirement that includes providing sufficient, portable, and on-site 

cooling equipment. A Sandia National Laboratories study determined that 

when holes in pool structure cause significant water drainage, reactor 

operators would generally have from a few hours to a few days to replace 

lost water or cool spent fuel with sprays in an effort to prevent a fire. If no 

water drained, such as in a loss-of-power event that caused a loss of 

cooling and allowed the pool water to boil, reactor operators might have 

days or weeks. NRC officials said that as spent fuel is uncovered, sprays 

are efficient and effective in cooling fuel assemblies. They also told us 

that trade-offs exist between installed and portable spray systems. 

Installed spray systems can be operated remotely but are susceptible to 

damage during an event. Portable systems provide adequate spray and 

are stored at least 100 yards away from the pool in secure places, but in 

case of an event, reactor operators may not always have access to the 

pool area to use them because of radiation hazard or physical 

obstruction. According to a member of a community action group we 

interviewed, replacement water and sprays may be effective in cooling 

spent fuel, but replacement water may not contain boron, which is needed 

to absorb neutrons and prevent a critical chain reaction. This member told 

us that there is no requirement for reactor operators to keep a supply of 

Furthermore, in 2006, over 150 community action and 

environmental groups collaborated to develop a set of principles for 

safeguarding spent fuel. They advocated spent fuel storage policies, 

including an open-frame, low-density layout for spent fuel pools and 

transfer of this fuel to dry storage within 5 years after its removal from a 

reactor. According to NRC, a state regional organization, and 

representatives from industry and community action groups, there are 

trade-offs between the benefits versus the costs and risks of moving 

spent fuel. Nonetheless, no clear agreement exists—according to Sandia 

National Laboratories’ analysis and input from community action groups—

on the extent to which the density of spent fuel in pools should be 

reduced.

 

32NRC issued a 2002 order that, according to NRC officials, accomplished a functionally 

similar action to the open rack proposal. The order, which took several years to 

implement, required the reactor operator to establish contiguous open areas in the pool for 

natural air circulation and active heat removal using sprays, if water were lost.

Replacement Water and Sprays 
 

Page 33 GAO-12-797 Accumulation of Spent Nuclear Fuel

boron to add to replacement water. According to NRC officials, only 

operators of pressurized water reactors have the option of adding boron 

to the water to prevent a critical chain reaction, but operators of these 

reactors must also show that the assemblies will remain sub-critical 

without the boron. The NRC officials stated that all reactors are required 

to have a 5-percent margin of safety to prevent a critical chain reaction. In 

addition to boron in the water, prevention of a critical chain reaction can 

also be achieved by boron in plates in the racks, spacing among the 

assemblies, and other storage configurations.

After the Fukushima Daiichi nuclear power reactor accident, NRC in 

March 2012 supplemented existing requirements by issuing an order 

instructing nuclear power operators to install monitoring equipment to 

remotely measure a wider range of water levels in spent fuel pools. NRC 

issued a second order, also in March 2012, that required reactor 

operators to ensure the effectiveness of water mitigation measures. It is 

more difficult to provide sprays and replacement water to boiling water 

reactor pools because they are typically several stories above ground and 

located close to the reactor,33

As we stated in our 2003 report, air ventilation can mitigate the likelihood 

of a pool fire in the event of water drainage. Logically, this mitigation 

potential depends upon where the ventilation occurs and how much 

ventilation can be created. A Sandia National Laboratories study found 

that space between assemblies and the pool wall can help promote 

ventilation, as can doors and vents in the room where the pool is located. 

Space under the assemblies can be created at the foot of racks 

supporting fuel assemblies, which allows circulating air to flow up 

between the assemblies and carry heat away with it in the event of 

whereas spent fuel pools for pressurized 

water reactors are at ground level or partially embedded in the ground. At 

Fukushima Daiichi, cooling flow to the spent fuel pool was lost during the 

loss of off-site power and was not immediately restored with the use of 

emergency diesel generators. Emergency operators did not have remote 

monitoring equipment to determine whether pool water levels had 

dropped enough to expose the spent fuel. Subsequent inspections, 

however, determined that water levels did not drop below the top of the 

fuel assemblies in the pool.

 

33Mark I and Mark II boiling water reactors are elevated, but Mark III reactors are not, 

because of a different design.

Ventilation
 

Page 34 GAO-12-797 Accumulation of Spent Nuclear Fuel

complete drainage of water from the pool. However, according to a study 

led by a scholar at a community action group, with assemblies packed in 

dense configurations in racks at most nuclear reactor pools and boron 

plates lining the racks of assemblies, ventilation may be reduced.

Spent nuclear fuel in dry storage is less susceptible to a radiological 

release of the magnitude of a zirconium fire in a spent fuel pool, 

according to documents we reviewed and interviews we conducted with 

officials from NRC, the National Academy of Sciences, and the Nuclear 

Waste Technical Review Board; officials from industry; and 

representatives of community action groups. Such a release is less likely 

for the following reasons:

• Spent fuel cools rapidly, and spent fuel in dry storage—typically at 

least 5 years old—has cooled sufficiently so that ignition is less likely. 

In addition, passive air cooling in dry cask storage systems is not 

affected by the loss of off-site power, and active monitoring—other 

than ensuring that air vents are not clogged—is not necessary to 

prevent overheating and possible ignition.

• The amount of radioactive material in a dry storage canister is a 

fraction of the amount of radiation in a spent fuel pool. According to 

the National Academy of Sciences’ 2006 study, each dry storage 

canister contains 32 to 68 fuel assemblies—whereas thousands of 

assemblies are typically stored in pools—and therefore each canister 

has less radioactive material that can be released than the radiation 

from a pool. Logically, breaching dozens of spent fuel canisters 

simultaneously could result in more severe consequences than a 

single breached canister, but breaching dozens of canisters 

simultaneously is difficult.

• To trigger any severe off-site radiological release from spent fuel 

stored in a canister, the fuel would have to undergo aerosolization, 

which would entail breaching the outer and inner shielding units. 

Furthermore, any holes would have to be sufficiently large enough to 

allow release of the aerosolized spent fuel. It would be difficult to 

aerosolize radioactive material in dry storage and difficult to have 

some mechanism to transport the radioactive material away from the 

reactor site. Such mechanisms would require energy, such as a fire.

• Dry storage is not as susceptible to the buildup of hydrogen as are 

spent fuel pools. If an accident or attack involving a spent fuel pool 

Spent Fuel in Dry Storage 

Is Less Susceptible to a 

Significant Radiological 

Release Than Is Spent Fuel 

Stored in Pools
 

Page 35 GAO-12-797 Accumulation of Spent Nuclear Fuel

causes a loss of water, the fuel assemblies can heat up and produce 

steam. This steam can react with the hot zirconium cladding 

surrounding the fuel assemblies, producing hydrogen that, when 

mixed with oxygen, could cause an explosion and structural damage 

to the reactor building.

As we reported in our 2003 study, NRC had concluded before September 

11, 2001, that spent fuel in dry cask storage systems was considered 

safe and secure.34

This study helped inform NRC’s technical evaluation—first discussed 

internally at NRC in 2007, according to NRC officials, and published for 

solicitation of public comments in 2009.

A Sandia National Laboratories study conducted from 

2003 through 2005, supplemented by NRC analyses, evaluated several 

representative types of dry cask storage designs against airplane and 

ground attacks to determine if any other security measures were needed, 

in addition to those already issued by order. This work did not find that 

any further mitigating or security procedures were needed for nearly all 

the scenarios, but it did identify some potential scenarios in which some 

radiation could be released.

35

 

34GAO, Spent Nuclear Fuel: Options Exist to Further Enhance Security, 

This evaluation included a 

proposal to establish a security-based dose limit that would require 

owners of spent fuel in dry storage systems to develop site security 

strategies to protect against a potential radiological release that exceeds 

NRC’s acceptable dose limits at a site boundary. NRC issued this 

evaluation for public comment for a proposed rule to revise security 

requirements for storing spent fuel away from a reactor. During the public 

comment period, NRC received general comments showing a preference 

for guarding against a specific threat rather than the dose-based 

approach proposed in the technical evaluation. For example, under the 

dose-based approach, some owners told NRC that they might have to 

increase their security forces to prevent potential radiological releases, 

and they raised concerns about the cost of such efforts compared with 

the benefit. As a result, according to NRC officials, the agency has 

delayed the proposed rule in order to gather more information regarding 

the public comments. NRC officials told us the agency plans to 

GAO-03-426 

(Washington, D.C.: Jul. 15, 2003).

35See Draft Technical Basis for Rulemaking Revising Security Requirements for Facilities 

Storing SNF and HLW; Notice of Availability and Solicitation of Public Comments, 74 Fed. 

Reg. 66589 (Dec. 16, 2009).
 

Page 36 GAO-12-797 Accumulation of Spent Nuclear Fuel

commission additional studies to help assess the situation and determine 

the appropriate security strategy.

In conducting our work, we found that NRC does not have a mechanism 

to ensure that it can easily identify and locate all classified studies 

conducted over the years. When we requested classified and other 

studies from NRC officials, it was difficult for them to provide us with the 

information we requested in a timely manner. Specifically, nearly 5 

months elapsed from our initial request for classified studies of wet 

storage until NRC provided these documents. A National Academy of 

Sciences official told us that the academy had also experienced difficulty 

in obtaining some of NRC’s classified studies while performing its 2004 

study.

36

Managing spent fuel until permanently disposed of may take many 

decades, and NRC and DOE managers and staff and operators with 

appropriate clearances may need to review an extensive number of 

classified studies conducted for NRC on the safety and security of spent 

fuel. Several studies conducted after September 11, 2001, by NRC and 

other groups referred to NRC studies conducted before that date—some 

conducted as early as 1979. We also found decades-old NRC studies to 

still be useful in our review. The nature and characteristics of spent fuel 

discharged from a reactor likely will not change, and therefore the 

underlying principles and knowledge of spent fuel safety and security are 

likely to remain applicable and informative to future scientists and others. 

Although preserving key scientific and technical studies is important, 

preservation of information alone is not enough if others may not be 

aware of a study’s existence or location. Scientists and others rely on 

mechanisms that allow them to easily identify, locate, and access 

To identify studies, we interviewed numerous NRC and other 

officials and identified studies through references in other studies we 

reviewed. NRC officials said the classified studies are stored in the safes 

of NRC officials. We also contacted officials from Sandia National 

Laboratories and requested a list of all their studies on spent fuel safety 

and security. NRC officials told us that developing and maintaining a 

classified database covering the most important topics involving spent 

fuel, as designated by agency management, would not be burdensome.

 

36The 2004 National Academy of Sciences study is the classified version of its 2006 study, 

which is unclassified.

NRC Has No Centralized 

Mechanism to Help 

Identify, Locate, and 

Access Classified Studies 

on Spent Fuel
 

Page 37 GAO-12-797 Accumulation of Spent Nuclear Fuel

pertinent information, as well as to prevent unnecessary duplication of 

research.

Transferring spent fuel from wet to dry storage is generally safe and 

offers several key benefits, but any movement of spent fuel entails some 

level of risk. Accelerating the transfer of spent fuel from wet to dry storage 

to reduce the inventory of spent fuel in a pool could increase those risks. 

Additional operational and other challenges to accelerating the transfer of 

spent fuel to dry storage may limit the degree of acceleration that may 

ultimately be achieved. Once spent fuel is in dry storage, additional 

challenges may arise, such as costs for repackaging should it be needed.

The transfer of spent fuel from wet to dry storage and long-term storage 

at reactor sites, although not originally part of the plan for managing spent 

fuel, has offered some benefits, according to our analysis of documents 

and interviews with NRC officials, representatives from industry, and 

community action and environmental groups. For example, without a 

permanent means of disposing of spent nuclear fuel for at least several 

decades, the transfer of spent fuel from pools to dry storage has provided 

the nation with time to develop a more permanent solution. We previously 

reported—on the basis of input from experts—that dry storage is 

considered safe for at least 100 years and is easily retrievable.37

• Reducing the potential consequences of pool fires. An accelerated 

transfer of spent fuel to dry storage may return the pools to a lowdensity, open-frame configuration that could reduce potential 

consequences should an unintended release of radiation occur from a 

pool fire. Accelerated transfer has been advocated by more than 150 

community action and environmental groups.

Moreover, because most spent fuel pools are nearly at capacity, reactor 

operators must transfer as much spent fuel to dry storage as is 

discharged from the reactor. According to our analysis of input from these 

officials and representatives, accelerating the transfer of spent fuel from 

wet to dry storage may offer the following additional benefits:

 

37GAO-10-48. 

Transfer of Spent Fuel 

from Wet Storage 

Offers Benefits but 

Also Presents 

Challenges

Transferring Spent Fuel 

from Wet to Dry Storage 

Offers Benefits
 

Page 38 GAO-12-797 Accumulation of Spent Nuclear Fuel

• Potentially increasing the volume of transportation-ready spent fuel. 

Accelerating the transfer of spent fuel to dry storage could increase 

the volume of readily transportable spent fuel for ease of removal to 

an off-site facility for storage, reprocessing, or disposal, with the 

caveat that reactor operators take steps to ensure that canisters and 

their contents meet transportation requirements.

In addition, we note that once a reactor is decommissioned, spent fuel is 

less expensive to safeguard in dry storage than in wet storage. 

Specifically, we previously reported that the cost of operating a spent fuel 

pool at a decommissioned reactor could range from about $8 million to 

nearly $13 million a year but that the cost of operating a dry storage 

facility might amount to about $3 million to nearly $7 million per year.38

Nine reactor sites nationwide are currently shut down and partly 

decommissioned and have already transferred all their spent fuel to dry 

storage or are in the process of doing so, with plans to remove their spent 

fuel pools. A tenth site never had an operating reactor but was built as an 

interim storage pool in anticipation of reprocessing.39 The operators of 

this site have not announced any plans to transfer spent fuel to dry 

storage.

Accelerating the transfer of spent fuel from wet to dry storage entails 

some operational challenges, and some industry representatives told us 

that they have questioned whether the cost of overcoming these 

challenges is worth the benefit, particularly considering the low probability 

of a catastrophic release of radiation. Furthermore, in a 2003 response to 

a recommendation by the Institute of Policy Analysis to accelerate the 

transfer of spent fuel from wet to dry storage to reduce the likelihood and 

potential consequences of a pool fire, NRC reported that accelerating the 

transfer of spent fuel is not justified, particularly given the billions of 

dollars it will cost, with no appreciable increase in safety. In commenting 

on a draft of this report, NRC reiterated this position, stating that it does 

not require the accelerated transfer of spent fuel to dry storage, 

particularly considering the small increase in safety that could be 

 

38In constant 2012 dollars. GAO-10-48. 

39General Electric originally built the pool to store spent fuel intended for reprocessing, but 

when reprocessing was suspended in the United States—and never resumed—the spent 

fuel became stranded. In 2007, General Electric transferred ownership of the spent fuel 

pool to GE-Hitachi Nuclear Energy Americas LLC.

Accelerating Transfer of 

Spent Fuel from Wet to 

Dry Storage Presents 

Challenges and Some Risk
 

Page 39 GAO-12-797 Accumulation of Spent Nuclear Fuel

achieved, because it considers both wet and dry storage to be safe under 

current regulations. 

The studies that NRC provided to us on the safety and security of spent 

fuel did not include any comprehensive analysis of the advantages and 

disadvantages of accelerating the transfer of spent fuel from wet to dry 

storage. However, NRC officials stated that the commission is currently 

evaluating accelerated transfer of spent fuel to dry storage as part of a 

larger review of lessons learned from the Fukushima event. The officials 

stated that the evaluation will allow NRC to determine whether regulatory 

action is needed to require accelerated transfer of spent fuel. NRC 

officials have stated that they believe they can complete their planned 

evaluation within about 5 years. Some of the challenges from accelerating 

the transfer of spent fuel include the following:

• Increasing the need for skilled workers and potential radiation doses 

to those workers. Workers at reactors face radiation exposure during 

routine transfer of spent fuel from wet to dry storage, particularly 

during loading operations, but this risk could increase if transfer were 

accelerated, according to a 2010 analysis by EPRI. The institute 

estimated worker exposure rates, assuming transfer of spent fuel in 

generic reactors both at the rate of current practice and at an 

accelerated rate. At the rate of current practice, EPRI reported, 

workers would collectively receive a dose of 15,836 rem over a nearly 

90-year period associated with transferring the expected inventory of 

about 140,000 metric tons from wet to dry storage,40

 

40The rem (roentgen equivalent man) is a unit that measures absorbed dose of radiation 

to a human and helps estimate the effects of a given absorbed dose on a human body. To 

determine this radiation dosage, an equation is used that multiplies the absorbed dose by 

a qualifying factor, which is based on factors such as the rate of exposure and the type of 

radiation. For instance, the annual effective dose to the general population in the United 

States is about 620 millirem, about half of which comes from natural sources, such as 

radon, a naturally occurring radioactive gas produced from the natural radioactive decay 

of uranium, that is found in rocks and soil. The remainder comes from medical, 

commercial, and industrial activities, such as dental X-rays.

performing 

annual maintenance and inspection of the dry storage systems, and 

constructing additional dry storage systems if additional dry storage 

capacity is needed. Assuming an accelerated rate of transfer after 5 

years of cooling, EPRI calculated that worker dose would increase by 

507 rem, or 3 percent, as a result of the transfer, maintenance and 

inspection, and construction duties performed over the same 90-year 

period. Assuming worker exposure rates would remain roughly the 
 

Page 40 GAO-12-797 Accumulation of Spent Nuclear Fuel

same, the additional 507 rem under an accelerated transfer scenario 

would represent the equivalent of an estimated 1,500 workers.41

• Increasing the potential for accidents. Accelerating the transfer 

process would result in more movements of equipment and, therefore, 

potentially more accidents. Additionally, an industry representative 

said that workers might have to be rotated to reduce worker exposure 

to radiation, increasing the number of workers moving spent fuel, 

including those with less experience. Under normal conditions, 

operators risk accidents every time spent fuel is moved. NRC has not 

reported any accidents with severe consequences during efforts to 

transfer spent nuclear fuel from wet to dry storage, but human and 

mechanical errors sometimes occur. For example, from 1969 to 2002, 

NRC reported 57 events involving load drops at reactor sites.

Furthermore, EPRI has reported that industry is moving to high-burnup fuel for greater efficiency. But this high-burn-up fuel is hotter and 

more radioactive than conventional fuel and requires cooling for about 

7 years before it can be safely transferred to dry storage. If transfer is 

accelerated, this high-burn-up fuel could potentially increase worker 

dose.

42

 

41GAO performed this analysis using EPRI’s data to provide a basis for comparing current 

worker exposure rates with future exposure rates, assuming an accelerated transfer rate. 

Actual worker exposure rates can be higher or lower depending on work performed. For 

example, EPRI assumes a worker dose of 400 millirem during a typical loading campaign, 

but it is possible that as high-burn-up spent fuel is transferred to dry storage, worker dose 

may be higher. Specifically, EPRI estimated that worker dose would rise by 284 rem for 

transferring spent fuel to dry storage, a 7.5 percent increase representing an estimated 

increase of 710 workers; a 102 rem increase for performing annual maintenance and 

inspection duties, a 1 percent increase representing an estimated increase of 63 workers; 

and a 121 rem increase for duties associated with constructing additional dry storage 

systems and moving additional loaded dry storage casks to the storage pad, a 7.6 percent 

increase representing an estimated increase of 712 workers. In addition, NRC limits 

annual radiation exposure for workers. The limits vary depending on the affected part of 

the body, but the total annual effective dose equivalent is 5 rem. 10 C.F.R. § 

20.1201(a)(1) (2012).

According to the Nuclear Energy Institute, none of these events 

involved a spent fuel cask or canister, but in 25 instances, one or 

more fuel assemblies were dropped. Accidents are of concern 

because, for example, if a cask is dropped, it can damage other 

42NRC, A Survey of Crane Operating Experience at U.S. Nuclear Power Plants from 1968 

through 2002, NUREG-1774 (Washington, D.C.: July 2003).
 

Page 41 GAO-12-797 Accumulation of Spent Nuclear Fuel

assemblies or the pool liner, potentially leading to water drainage.43 A 

single fuel assembly from a boiling water reactor weighs about 700 

pounds, and a single fuel assembly from a pressurized water reactor 

weighs about 1,500 pounds; dry storage casks, once fully loaded, can 

weigh from 100 to 180 tons or more. NRC has provided guidance to 

industry to take steps to minimize damage from such a drop, such as 

using overhead cranes with special added safety features so that a 

single failure will not result in dropping a damaging load or developing 

handling routes designed to avoid lifting heavy loads over vulnerable 

equipment.44,45

• Working within time constraints. Timing preferences and operational 

limitations could constrain how much spent fuel is transferred in a 

given year and may present an obstacle to accelerated transfer from 

wet to dry storage. Industry representatives told us that under current 

practice, reactor operators prefer to transfer spent fuel to dry storage 

during periods of time that do not interfere with refueling, receiving 

new fuel, required inspections, and maintenance or other activities 

vital to plant operations. These activities typically consume about 8 to 

9 months of each year’s calendar. A routine dry storage loading 

operation may take 2 months or more, according to industry 

representatives. For example, one industry representative told us that 

it can take about 2 weeks to mobilize workers and equipment before 

the operation and about 2 more weeks to demobilize after the 

operation. Additionally, according to industry representatives at one 

operating reactor site we visited, each canister takes about 1 week to 

load, dry, seal, and move to a storage pad, which limits the number of 

canisters that can be loaded in a given year. In addition, spatial 

limitations—such as space for drying or welding lids onto multiple 

canisters, limited heavy lifting capabilities, and lack of free space in 

spent fuel pools to accommodate more than one cask at a time—may 

make simultaneous loading of canisters difficult. Some industry 

representatives we spoke with told us that there are limits on how 

much acceleration can be achieved in a single year.

 

43NRC, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear 

Power Plants, NUREG-1738 (Washington, D.C: February 2001).

44NRC, Single-Failure-Proof Cranes for Nuclear Power Plants, NUREG-0554 

(Washington, D.C.: May 1979).

45NRC, Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical 

Activity A-36, NUREG-0612 (Washington, D.C.: July 1980).
 

Page 42 GAO-12-797 Accumulation of Spent Nuclear Fuel

• Increasing costs. The transfer of spent fuel from wet to dry storage is 

costly in several ways. We estimated in a November 2009 report that 

the transfer cost for about five canisters is about $5.1 million to 

$8.8 million.46 One industry representative told us that if the transfer of 

spent fuel to dry storage were accelerated, the associated high upfront costs could strain some nuclear power plants’ budgets. These 

up-front costs, which would be incurred over a longer period without 

acceleration, include the construction of a storage pad with 

accompanying safety and security features, which, we reported, could 

cost about $19 million to $44 million.47 These costs are initially borne 

by ratepayers or plant owners but may be passed on to taxpayers as 

a result of industry lawsuits against DOE for failure to take custody of 

the spent fuel. Moreover, EPRI reported that as older, cooler spent 

fuel is loaded into canisters, reactor operators eventually will be left 

with younger, hotter spent fuel to transfer from wet to dry storage. 

Spent fuel stored in canisters generally should not exceed about 

752 degrees Fahrenheit (400 degrees Celsius), and, as we reported 

earlier, spent fuel being discharged from reactors today may have to 

cool at least 7 years before it can be placed in dry storage. Given the 

heat load requirements for storing spent fuel, EPRI noted that it may 

not be possible to fill some canisters to capacity. Specifically, a 

canister with a capacity for 60 boiling water reactor assemblies that 

would store 60 older, cooler assemblies may be able to contain only 

38 younger, hotter assemblies.

Reactor operators had never intended to leave spent fuel on their sites for 

extended periods, but even if the United States began to develop an offsite centralized storage or disposal facility today, spent fuel—which has 

already been stored on-site for several decades—would be stored on-site 

for several decades more. As a result, the following challenges could 

affect decisions on managing spent fuel.

Repackaging stranded spent fuel. Once reactors are decommissioned, 

reactor operators have limited options for managing the stored spent fuel. 

 

46In constant 2012 dollars. GAO-10-48. 

47In constant 2012 dollars. These costs are not intended to be all-inclusive and represent 

a generic case for comparative purposes. A storage pad could be used to store multiple 

vertical or horizontal dry storage systems. For example, at Haddam Neck in Connecticut, 

43 vertical casks are stored on a single pad. GAO-10-48. 

Managing Spent Fuel after 

Transfer from Wet to Dry 

Storage at Reactor Sites 

Presents Additional 

Challenges
 

Page 43 GAO-12-797 Accumulation of Spent Nuclear Fuel

Specifically, once they package the spent fuel in canisters and dry casks, 

they are unlikely to have any means of repackaging if the canisters 

degrade over the long term, or if the operators have to meet different 

storage or disposal requirements. As we previously reported, experts told 

us that canisters are likely safe for at least 100 years, but by then the 

spent fuel may have to be repackaged because of degradation.48

Reducing community opposition. As reactors begin to be closed down 

and decommissioned, reactor operators will leave spent fuel on sites that 

will serve no other purpose than storing that fuel. Continued on-site 

storage would likely face increasing community opposition, which could 

make it difficult for operators to obtain NRC recertification for storage 

By the 

time such repackaging might be needed, reactor operators may no longer 

have pools or the necessary infrastructure to undertake the repackaging, 

as was the case at the Haddam Neck site we visited. Specifically, the 

Haddam Neck site had already decommissioned the reactor, transferred 

all its spent fuel from wet to dry storage, and dismantled its spent fuel 

pool. If the spent fuel at the site needed to be repackaged, a special 

transfer facility would need to be built, or the spent fuel would need to be 

shipped to a site that had a transfer facility. In addition, to reduce costs, 

reactor operators are selecting a variety of dry storage systems that 

maximize storage capacity. These varied systems do not raise safety 

issues, but they may complicate a transfer to a centralized storage facility 

or a permanent disposal facility because different systems require 

different handling requirements, such as the type of grappling hook and 

the size of the transport cask required. These differences may present 

more complex engineering challenges and cost issues as time passes, 

and the volume of spent fuel in various systems increases. In addition, 

over time, it is possible that handling equipment would not be maintained 

and personnel would not continue to be trained. Maximizing storage 

capacity may raise additional engineering challenges and cost issues, 

particularly since larger canisters may meet storage requirements but not 

transportation requirements. The Nuclear Energy Institute has reported 

that of all the spent fuel currently in dry storage, only about 30 percent is 

directly transportable. It also reported that the remaining spent fuel could 

need as much as 10 more years of cooling to meet NRC’s transportation 

heat-load requirements to ensure that assemblies can withstand the force 

of a potential accident.

 

48GAO-10-48. 
 

Page 44 GAO-12-797 Accumulation of Spent Nuclear Fuel

sites at reactors, approval for licenses to extend the operating life of other 

reactors, or licenses for new reactors. According to officials from a state 

regional organization we spoke with, the longer the federal government 

defers a permanent disposition pathway for spent fuel, the less likely the 

public would be to accept interim solutions, for fear such solutions would 

become de facto permanent solutions. Also, in our prior work, experts 

noted that many commercial reactor sites are not suitable for long-term 

storage and that none have had an environmental review to assess the 

impacts of storing spent fuel beyond the period for which the sites are 

currently licensed.49

Managing costs. Continued storage of spent fuel may be costly. Because 

owners of spent fuel would have to safeguard it beyond the life of 

currently operating reactors, decommissioned reactor sites would not be 

available to local communities and states for alternative development. 

The Blue Ribbon Commission recommended that the nation open one or 

more centralized storage facilities and put a high priority on transferring 

the so-called stranded spent fuel to free decommissioned reactor sites for 

other uses. We previously reported the cost of developing two federal 

centralized storage facilities to be about $16 billion to $30 billion, although 

this estimate does not include final disposal costs, which could cost tens 

of billions of dollars more.

As discussed above, in June 2012, a federal 

appellate court remanded NRC’s waste confidence determination and 

rule for the preparation of an environmental impact statement or finding of 

no significant environmental impact.

50 In addition, we also previously reported that if 

spent fuel needs to be repackaged because of degradation, repackaging 

could cost from $180 million to nearly $500 million,51

 

49

with costs 

GAO-10-48. 

50In constant 2012 dollars. Centralized storage poses additional challenges as well. 

Provisions in the Nuclear Waste Policy Act of 1982, as amended, that allowed DOE to 

arrange for centralized storage have either expired or are unusable because they were 

tied to milestones in repository development that have not been met. DOE acknowledged 

that it might have authority to arrange for centralized storage of spent fuel through the 

Atomic Energy Act of 1954, as amended, but only under certain circumstances, such as 

emergencies involving spent fuel that threaten public health. Transportation risks, too, are 

associated with centralized storage, since the spent fuel would have to be transported 

twice, once to the interim storage site and once to a disposal site.

51In constant 2012 dollars.
 

Page 45 GAO-12-797 Accumulation of Spent Nuclear Fuel

depending on the number of canisters to be repackaged and whether a 

site has a transfer facility, such as a storage pool.52

Planning transportation to an off-site facility. The transportation of large 

amounts of spent fuel is inherently complex and may take decades to 

accomplish, depending on a number of variables including distance, 

quantity of material, mode of transport, rate of shipment, level of security, 

and coordination with state and local authorities. For example, according 

to officials from a state regional organization we talked to and the Blue 

Ribbon Commission report, transportation planning could take about 10 

years, in part because routes have to be agreed upon, first responders 

have to be trained, and critical elements of infrastructure and equipment 

need to be designed and deployed. In addition, according to the Nuclear 

Energy Institute, some spent fuel in canisters that serve a dual purpose—

both storage and transportation—might not be readily transportable 

because NRC’s transportation requirements for heat and radioactivity 

may require additional time for cooling and decay. To transport spent fuel 

before it is sufficiently cooled, reactor operators might have to repackage 

it or place it in more robust transportation casks. Uncertainties also 

surround the transportation of high-burn-up fuel. The Blue Ribbon 

Commission noted that NRC has not yet certified a shipping cask for the 

transport of high-burn-up fuels,53

 

52

which are now commonly being 

discharged from reactors. Spent fuel that has been stored for extended 

periods may become degraded and require additional handling before it 

can be transported. NRC has reported that the zirconium cladding of 

high-burn-up fuel is known to become more brittle after long cooling 

periods. Once sealed in a canister, the spent fuel cannot easily be 

inspected for degradation. If the cladding degrades, there is no assurance 

the spent fuel would remain in a safe configuration, potentially leading to 

a nuclear reaction if conditions were right. NRC officials told us that if they 

determined that a safe geometry could not be maintained during 

transportation because of cladding degradation, they would require the 

owner of the spent fuel to demonstrate that an uncontrolled critical chain 

reaction would not occur and would not issue an approval for 

transportation until they could assure a safe geometric configuration. In 

addition, NRC expressed concerns about the safe handling of spent fuel 

GAO-11-229. 

53A license is required for delivery of licensed material to a carrier for transport or for the

transport of licensed material. 10 C.F.R. § 71.3 (2012). 
 

Page 46 GAO-12-797 Accumulation of Spent Nuclear Fuel

after transportation because of uncertainties over the condition of large 

amounts of high-burn-up fuel that might have to be repackaged for 

disposal. As a result, NRC stated that until further guidance is developed, 

the transportation of high-burn-up fuel will be handled on a case-by-case 

basis using the criteria given in current regulations.54

Maintaining security over the long term. Future security requirements for 

the extended storage of spent fuel are uncertain and could pose 

additional challenges. Specifically, before the September 11, 2001, 

terrorist attacks, spent nuclear fuel was largely considered to be selfprotecting for several decades because its very high radiation would 

prevent a person from handling the material without incurring health or 

life-threatening injury in a very short time, although incapacitating health 

impacts may sometimes not occur for up to 16 hours.

Without a 

standardized cask design for storage, transportation, and disposal, it may 

be difficult to design the type of large-scale transportation program 

needed to transfer high-burn-up fuel away from reactor sites.

55

Continuing taxpayer liabilities. The continued on-site storage of spent fuel 

will not alleviate industry’s lawsuits against DOE for failure to take 

custody of the spent fuel in 1998 as required by contracts authorized 

under the Nuclear Waste Policy Act of 1982, as amended. DOE estimates 

that the federal government’s liabilities resulting from the lawsuits will be 

about $21 billion through 2020 and about $500 million each year after 

that. These costs are paid for by the taxpayer through the Department of 

the Treasury’s Judgment Fund.

In addition, as 

spent fuel decays over time, it produces less decay heat. A spent fuel 

assembly can lose nearly 80 percent of its heat 5 years after it has been 

removed from a reactor and 95 percent of its heat after 100 years. Given 

the willingness of terrorists in recent years to sacrifice their lives as part of 

an attack, the national and international communities have begun to 

rethink just how long spent fuel really might be self-protecting. As spent 

fuel ages and becomes less self-protecting, additional security

precautions may be required.

 

54These regulations include 10 C.F.R. §§ 71.55, .43(f), and .51.

55The International Atomic Energy Agency, DOE, and NRC have considered spent fuel to 

be self-protecting with a radiation level exceeding 100 rad—or, radiation absorbed dose, a 

unit of measurement—per hour at 1 meter unshielded. After short-term exposure to 250 to 

500 rad, about 50 percent of the people coming in contact with the spent fuel would be 

expected to die within 60 days.
 

Page 47 GAO-12-797 Accumulation of Spent Nuclear Fuel

The decades-old problem of where to permanently store commercial 

spent nuclear fuel remains unsolved even as the quantities of spent 

fuel—in either wet or dry storage—continue to accumulate at reactor sites 

across the country. It is not yet clear where a repository will be sited, but it 

is clear that it may take decades more to site, license, construct, and 

ultimately open a disposal site. In the interim, some scientists, 

environmentalists, community groups, and others have expressed 

growing concerns about the spent nuclear fuel that is densely packed in 

spent fuel pools, especially after the water in the pools at the Fukushima 

Daiichi nuclear power plant complex in Japan were at risk of being 

depleted, increasing the risk of widespread radioactive contamination. 

The chances of a radiation release are extremely low in either wet or dry 

storage, but the event with the most serious consequences—a selfsustaining fire in a spent fuel pool—could result in widespread radioactive 

contamination. NRC has studied the likelihood of such an event and has 

taken a number of steps to prevent a fire, including a number of mitigating 

measures, though some community action groups have raised questions 

if those steps are enough, given the severity of consequences.

Moreover, because storage or disposal facilities may take decades to 

develop, in managing spent fuel, NRC and DOE officials and others with 

appropriate clearances and a need to know may need to review classified 

studies conducted by and for NRC on the safety and security of spent 

fuel. These studies are likely to be relevant for decades and, therefore, 

continue to contribute to institutional knowledge and the ultimate 

decisions made concerning the handling and storage of spent nuclear 

fuel. Nevertheless, NRC does not have a mechanism that allows for easy 

identification and location of classified studies conducted over the years. 

Without such a mechanism, it may be difficult and time-consuming to 

access the necessary studies.

To help facilitate decisions on storing and disposing of spent nuclear fuel 

over the coming decades, we recommend that the Chairman of the 

Nuclear Regulatory Commission direct agency staff to develop a 

mechanism that allows individuals with appropriate clearances and the 

need to know to easily identify and access classified studies so as to help 

ensure that institutional knowledge is not lost.

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

written comments, which are reproduced in appendix IV, NRC generally 

agreed with the findings and the recommendation in our report. NRC did 

Conclusions

Recommendation for 

Executive Action

Agency Comments
 

Page 48 GAO-12-797 Accumulation of Spent Nuclear Fuel

note, however, that our characterization of NRC’s position to not require 

accelerated transfer of spent fuel to dry storage was factually incorrect. 

Specifically, NRC stated that we characterized its position on accelerated 

transfer as being solely a cost-benefit decision. NRC stated that it does 

not require accelerated transfer because it considers both wet and dry 

storage to provide a safe means of storing spent fuel that is in full 

conformance with agency regulations. We clarified the report language to 

more clearly state NRC’s position. Regarding the recommendation, NRC 

stated that it planned to review its internal procedures to determine if any 

measures need to be taken to ensure the classified information is readily 

available to future decision makers. NRC also provided technical 

comments, which we have 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 Chairman of the 

Nuclear Regulatory Commission, the Secretary of Energy, appropriate 

congressional committees, and other interested parties. In addition, the 

report will be available at no charge on the GAO website at 

http://www.gao.gov. 

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

contact me at (202) 512-3841 or aloisee@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 V.

Gene Aloise

Director

Natural Resources and Environment
 

Page 49 GAO-12-797 Accumulation of Spent Nuclear Fuel

List of Requesters

Fred Upton

Chairman

Joe Barton

Chairman Emeritus

Committee on Energy and Commerce

House of Representatives

Cliff Stearns

Chairman

Subcommittee on Oversight and Investigations

Committee on Energy and Commerce

House of Representatives

Ed Whitfield

Chairman

Subcommittee on Energy and Power

Committee on Energy and Commerce

House of Representatives

John Shimkus

Chairman

Subcommittee on Environment and the Economy

Committee on Energy and Commerce

House of Representatives
Appendix I: Scope and Methodology

Page 50 GAO-12-797 Accumulation of Spent Nuclear Fuel

To determine the amount of spent fuel projected to accumulate before it 

can be moved from individual reactor sites, we obtained data from the 

Nuclear Energy Institute, an industry advocacy organization, on current 

inventories of commercial spent nuclear fuel in wet and dry storage and a 

database on year-to-year projections of on-site spent fuel accumulation in 

wet and dry storage. We developed the projections of this amount on the 

basis of several assumptions, including that all 104 reactors would renew 

their licenses for 20 years, with the early shutdown of Oyster Creek, in 

New Jersey, 10 years before its license expires; that no new reactors are 

brought online; that the nation’s current reactors continue to produce 

spent fuel at the same rate; and that all spent fuel remaining in wet 

storage would be moved to dry storage 12 years after a reactor’s final 

shutdown. As part of our analysis, we obtained information in reports and 

from interviews from the Nuclear Regulatory Commission (NRC); the 

Department of Energy (DOE); the Electric Power Research Institute, a 

nonprofit research entity; and representatives from industry, academia, 

and community action and environmental groups. To assess the reliability 

of existing data, we reviewed available documentation and conducted 

interviews with individuals knowledgeable about the data. On the basis of 

this information, we found these data to be sufficiently reliable for the 

purposes of our report.

To determine the most likely options for moving spent fuel off-site, we used 

prior work that had analyzed the Yucca Mountain program and its most 

likely alternatives to help us assess three scenarios: (1) Yucca Mountain, 

(2) two federally funded central storage facilities, and (3) a new permanent 

disposal facility.1

 

1

We used assumptions from our prior work, including 

updating dates from our assumptions, and we supplemented these 

assumptions by reviewing documents and interviewing officials from federal 

and state regional organizations and representatives from industry, 

independent groups, and community action and environmental groups. 

Specifically, for the Yucca Mountain option, we asked DOE how long it 

would take for a repository at Yucca Mountain to open if licensing were to 

resume in 2012, assuming the license and funding were both approved. 

DOE told us that the best way to develop a new estimate would be to take 

the estimates that existed before the program was shut down and add the 

time elapsed between when DOE stopped work on licensing and when it 

may resume licensing, which is 10 years. We previously reported, however, 

GAO-10-48. 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 51 GAO-12-797 Accumulation of Spent Nuclear Fuel

that DOE’s original estimate for licensing was likely too optimistic. 

Furthermore, because all of DOE’s former Yucca Mountain program staff 

have been assigned to other offices, left the agency, or retired, some 

delays are likely in reassembling a licensing team—as much as 2 years, 

according to one former DOE official familiar with the Yucca Mountain 

program.2 Given these challenges, we added 5 additional years to DOE’s 

original 10-year estimate of completing Yucca Mountain. If licensing for the 

Yucca Mountain program were to resume in 2012, the earliest possible 

opening date is roughly 2027. For the two federal centralized storage 

facilities, we updated dates we developed for a prior report, in which we 

projected when the centralized storage facilities might be built, which was 

19 years.3

To determine key safety and security risks of spent fuel, as well as 

potential mitigation actions, we reviewed NRC-commissioned studies 

performed by Sandia National Laboratories and studies by NRC, the 

National Academy of Sciences, community action groups, and industry. 

Our primary period of focus was post-September 11, 2001, which 

included studies from 2002 to 2009, but we also reviewed pre-September 

11, 2001, studies dating back to 1979. We identified relevant studies for 

review by asking officials from NRC, DOE, and Sandia National 

Laboratories, as well as knowledgeable persons whom we interviewed, 

and by reviewing the citations in these studies to identify still other 

relevant studies. We reviewed studies of spent fuel pools and dry casks 

at the classified, NRC safeguards, official use only, and unclassified 

levels. In addition, we toured the Haddam Neck decommissioned reactor 

site and the Millstone reactor in Connecticut, the Hope Creek and Salem 

Since these are rough estimates, we rounded the time frame to 

20 years, meaning that if the process were started in 2012, the earliest that 

two federal centralized storage sites could open would be 2032. For a new 

repository, we analyzed DOE’s actual and projected time frames for 

licensing and opening the Yucca Mountain repository and DOE’s report to 

Congress on the time frames necessary to open a second repository. We 

also analyzed the time frames necessary to open the nation’s only highlevel radioactive disposal facility, the Waste Isolation Pilot Plant in New 

Mexico. On the basis of our analysis, we determined that if a process were 

started in 2012 to open a new repository, it could open in about 40 years, 

or 2052.

 

2

GAO-10-48 and GAO-11-229. 

3

GAO-10-48. 
Appendix I: Scope and Methodology

Page 52 GAO-12-797 Accumulation of Spent Nuclear Fuel

reactors in New Jersey, and the Susquehanna reactor in Pennsylvania, 

and we spoke with NRC officials and industry representatives about wet 

and dry spent fuel storage issues, including potential mitigation actions, at 

these sites. Our site visits included decommissioned and operating 

reactor sites, sites with both pressurized water reactors and boiling water 

reactors, sites having both wet and dry storage, and sites using both 

vertical and horizontal dry storage systems. We also reviewed NRC 

requirements addressing the safety and security of spent fuel, as well as 

directives from the nuclear power industry.

To determine the benefits and challenges of transferring spent fuel from 

wet to dry storage, including transferring this fuel at an accelerated rate, 

we reviewed prior GAO reports and documents from NRC, DOE, the 

Nuclear Waste Technical Review Board, the National Academy of 

Sciences, the Blue Ribbon Commission on America’s Nuclear Future, 

academia, industry, and community action and environmental groups. We 

also interviewed officials from NRC, DOE, and state regional 

organizations, and representatives of industry, academia, the Blue 

Ribbon Commission on America’s Nuclear Future, and community action 

and environmental groups. We spoke with industry representatives and 

NRC inspectors at the decommissioned and operating reactor sites we 

visited. In our interviews, we asked for their views on the benefits and 

challenges of transferring spent fuel from wet to dry storage and the 

benefits and challenges of accelerating that transfer. To further determine 

the cost considerations for transferring spent fuel from wet to dry storage, 

we updated cost component estimates developed for our 2009 report to 

constant 2012 dollars. In that report, we obtained information from a small 

group of experts to develop initial assumptions, which we then provided to 

a larger set of nearly 150 experts for comment.4

We conducted this performance audit from June 2011 to August 2012, in 

accordance with generally accepted government auditing standards. 

These 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.

 

4

For further information on the scope and methodology used, please see appendixes I, II, 

and III in GAO-10-48. 
Appendix II: Selected Other Countries’ Spent 

Fuel Management Programs

Page 53 GAO-12-797 Accumulation of Spent Nuclear Fuel

Like the United States, other countries produce electricity from nuclear 

power reactors and have programs to manage their spent nuclear fuel. 

Table 2 provides a brief description of the programs in selected countries.

Table2: Summary of Commercial Nuclear Programs and Spent Fuel Management Programs for Selected Countries

Country

Began 

commercial 

nuclear operations

Number of 

operating 

reactors

Spent fuel Inventory 

at end of 2007 (tons 

of heavy metal) Spent fuel management program

Canada 1968 18 38,400 • Does not reprocess spent nuclear fuel.

• Stores spent nuclear fuel at nuclear power reactor sites 

in both wet and dry storage.

• Does not have an independent centralized interim 

storage facility.

• Plans to develop an independent centralized interim 

storage facility in rock formations suitable for shallow 

underground storage.

• A group that includes Canadian utilities and the 

Canadian government has recommended a geological 

repository, but no specific site has been selected.

Japan 1966 50a 19,000 • Reprocesses spent nuclear fuel. Historically, Japan has 

shipped its spent nuclear fuel to France and the United 

Kingdom.

• Stores spent nuclear fuel in pools at reactor sites with 

two reactor sites that also store spent fuel in dry storage.

• Constructed its own reprocessing plant at Rokkasho, 

Japan. (Uncertainty surrounds the future of Rokkasho as 

the Japanese government reviews its nuclear policy after 

the disaster at the Fukushima Daiichi nuclear power 

plant. No date for operation has been set.)

• Rokkasho contains an interim wet storage pool for spent 

nuclear fuel. The pool is currently full, awaiting start of 

reprocessing operations.

• An interim dry storage facility is under construction at 

Mutsu near the Rokkasho reprocessing plant. The plan 

is to store spent fuel there until transfer for reprocessing. 

(Construction at Mutsu has been put on hold following 

the Fukushima disaster in March 2011.)

• Plans to construct a geological repository but has not 

selected any sites.

Russia 1963 33 17,895 • Reprocesses some spent nuclear fuel as well as spent 

fuel from other countries.

• Pools are used to store spent nuclear fuel at reactor 

sites. 

• In 2011, construction was completed on the world’s 

largest dry storage facility at Zheleznogorsk, Siberia. 

Zheleznogorsk also houses wet storage pools as part of 

Russia’s centralized interim storage facilities.

• No formalized plans for a geological repository.

Appendix II: Selected Other Countries’ Spent 

Fuel Management Programs 
Appendix II: Selected Other Countries’ Spent 

Fuel Management Programs

Page 54 GAO-12-797 Accumulation of Spent Nuclear Fuel

Country

Began 

commercial 

nuclear operations

Number of 

operating 

reactors

Spent fuel Inventory 

at end of 2007 (tons 

of heavy metal) Spent fuel management program

France 1964 58 13,500 • Reprocesses its own spent nuclear fuel as well spent 

fuel from other countries; virtually all of the spent fuel 

reprocessed today is domestic.

• Uses only wet storage for spent nuclear fuel.

• Spent nuclear fuel from French reactors is cooled in 

pools for several years at reactor sites and then 

transported to the reprocessing plant at La Hague, 

France. The spent fuel is then stored for several more 

years in massive pools before reprocessing.

• No independent centralized storage facility. La Hague 

serves as a quasi-centralized storage facility while spent 

fuel awaits reprocessing.

• Plans to develop a geological repository. A tentative site 

has been selected at Bure, France, but no final plan has 

been approved.

South 

Korea

1978 23 10,900 • Does not reprocess spent nuclear fuel.

• Stores spent nuclear fuel at nuclear power reactor sites 

in both wet and dry storage systems.

• A centralized storage facility for spent nuclear fuel is 

pending construction by 2016.

• Envisions a geological repository but has not selected a 

site.

Germany 1969 9 5,850 • Shipped most of its spent nuclear fuel to France and the 

United Kingdom for reprocessing, until 2005.

• Stores the majority of spent nuclear fuel in interim dry 

storage facilities at reactor sites.

• Stores some spent nuclear fuel at sites away from 

reactors in interim dry storage.

• Plans to develop a geological repository for spent 

nuclear fuel. A site that was tentatively selected has 

become controversial, and no final decision on a site has 

been made.

United 

Kingdom

1956 18 5,850 • Reprocesses its own spent nuclear fuel as well spent 

fuel from other countries.

• Uses only wet storage for spent nuclear fuel.

• Does not have an independent centralized interim 

storage facility.

• Plans to develop a geological repository for spent 

nuclear fuel but has not selected a site.

Sweden 1972 10 5,400 • Does not reprocess spent nuclear fuel.

• Stores spent nuclear fuel at reactor sites in pools before 

transfer to a central interim underground wet storage 

facility at the Oskarshamn nuclear power plant.

• Finalized plans for a geological repository for spent 

nuclear fuel at the Forsmark nuclear power plant in 

Sweden. Full construction at the site is scheduled to 

begin in 2015 and operation in approximately 2023. 
Appendix II: Selected Other Countries’ Spent 

Fuel Management Programs

Page 55 GAO-12-797 Accumulation of Spent Nuclear Fuel

Country

Began 

commercial 

nuclear operations

Number of 

operating 

reactors

Spent fuel Inventory 

at end of 2007 (tons 

of heavy metal) Spent fuel management program

Finland 1977 4 1,600 • Does not reprocess spent nuclear fuel. After collapse of 

Soviet Union, discontinued sending some of its nuclear 

fuel to the Soviet Union for reprocessing.

• Stores spent nuclear fuel in pools at nuclear power 

plants until transfer to a deep geological repository.

• Finalized plans for a geological repository sited next to 

its Olkiluoto nuclear power plant. Acceptance of spent 

nuclear fuel is scheduled to start in approximately 2020.

Sources: For the spent nuclear fuel inventory amounts at the end of 2007, International Panel on Fissile Materials, Managing Spent 

Fuel from Nuclear Power Reactors: Experience and Lessons from Around the World (Princeton, NJ: September 2011). The amounts 

reflect fuel stored in cooling pools and dry storage. In addition, we used the following sources for the countries listed:

For Canada: International Panel on Fissile Materials, Managing Spent Fuel from Nuclear Power 

Reactors; World Nuclear Association, “Country Briefings: Nuclear Power in Canada,” accessed May 

2012, http://www.world-nuclear.org; Nuclear Energy Institute, “Global Nuclear Power Development: 

Major Expansion Continues” (Washington, D.C.: May 2012); U.S. Nuclear Waste Technical Review 

Board, Survey of National Programs for Managing High-Level Radioactive Waste and Spent Nuclear 

Fuel: A Report to Congress and the Secretary of Energy (Arlington, VA: October 2009), and 

Experience Gained from Programs to Manage High-Level Radioactive Waste and Spent Nuclear Fuel 

in the United States and Other Countries: A Report to Congress and the Secretary of Energy

(Arlington, VA: April 2011). 

For Japan: World Nuclear Association, “Country Briefings: Nuclear Power in Japan,” accessed May 

2012, http://www.world-nuclear.org; Japan Atomic Industrial Forum, “Moves Afoot to Restart Nuclear 

Power Plant Operation and Its Related Issues in Japan,” (Tokyo: May 31,2012), accessed May 31, 

2012, http://www.jaif.or.jp/english/activities_new.html#purpose; International Panel on Fissile 

Materials, Managing Spent Fuel from Nuclear Power Reactors.

For Russia: World Nuclear Association, “Country Briefings: Nuclear Power in Russia,” accessed May 

2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing Spent Fuel 

from Nuclear Power Reactors; World Nuclear Association, “Radioactive Waste Management,” 

Nuclear Fuel Cycle: Nuclear Wastes, accessed April 2012, http://www.world-nuclear.org; International 

Panel on Fissile Materials, “Spent Fuel from Nuclear Power Reactors: Overview of a New Study.” 

Presentation by Frank von Hippel, hosted by the American Association for the Advancement of 

Science, Washington, D.C., June 3, 2011; World Nuclear Association, “Country Briefings: Russia’s 

Nuclear Fuel Cycle,” accessed March 2012, http://www.world-nuclear.org. 

For France: Embassy of France in Washington, D.C. “Nuclear Energy in France,” accessed March 

2008, http://ambafrance-us.org/spip.php?article637; World Nuclear Association, “Country Briefings: 

Nuclear Power in France,” accessed February 2012, http://www.world-nuclear.org; International 

Panel on Fissile Materials, Managing Spent Fuel from Nuclear Power Reactors and “Spent Fuel from 

Nuclear Power Reactors”; World Nuclear Association, “Radioactive Waste Management,” accessed 

April 2012, http://www.world-nuclear.org. 

For South Korea: World Nuclear Association, “Country Briefings: Nuclear Power in South Korea,” 

accessed April 2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing 

Spent Fuel from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors.” 

For Germany: International Panel on Fissile Materials, Managing Spent Fuel from Nuclear Power 

Reactors; EnBW, Uranium Is Energy: The Nuclear Power Plants of EnBW (Karlsruhe: Energy BadenWurttemberg, June 2007); International Panel on Fissile Materials, “Spent Fuel from Nuclear Power 

Reactors,”; World Nuclear Association, “Country Briefings: Nuclear Power in Germany,” accessed 

April 2012, http://www.world-nuclear.org; U.S. Nuclear Waste Technical Review Board, Survey of 

National Programs for Managing High-Level Radioactive Waste. 
Appendix II: Selected Other Countries’ Spent 

Fuel Management Programs

Page 56 GAO-12-797 Accumulation of Spent Nuclear Fuel

For the United Kingdom: World Nuclear Association, “Country Briefings: Nuclear Development in the 

United Kingdom,” accessed March 2012, http://www.world-nuclear.org; Nuclear Energy Institute 

“Global Nuclear Power Development”; International Panel on Fissile Materials, Managing Spent Fuel 

from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors”;World Nuclear 

Association, “Radioactive Waste Management”; U.S. Nuclear Waste Technical Review Board, Survey 

of National Programs for Managing High-Level Radioactive Waste; World Nuclear Association, 

“Country Briefings: Nuclear Power in the United Kingdom”, accessed May 2012, 

http://www.world-nuclear.org. 

For Sweden: World Nuclear Association, “Country Briefings: Nuclear Power in Sweden,” accessed 

April 2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing Spent 

Fuel from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors”; World Nuclear 

Association, “Radioactive Waste Management,” app. 3, “National Policies,” accessed April 2012, 

http://www.world-nuclear.org. 

For Finland: World Nuclear Association, “Country Briefings: Nuclear Power in Finland,” accessed 

April 2012, http://www.world-nuclear.org; International Panel on Fissile Materials, Managing Spent 

Fuel from Nuclear Power Reactors and “Spent Fuel from Nuclear Power Reactors”; U.S. Nuclear 

Waste Technical Review Board, Experience Gained from Programs to Manage High-Level 

Radioactive Waste and Spent Nuclear Fuel in the United States and Other Countries. 

a

On May 5, 2012, Japan’s lone operating nuclear power plant ceased operation. All of Japan’s 

nuclear power plants were to remain shut down pending the Japanese government’s safety 

inspections and support of local Japanese governments to restart nuclear operations. Since May 5, 

2012, Japan has restarted one nuclear power plant to full power and may determine restart dates for 

other reactors. The disaster at the Tokyo Electric Power Company’s Fukushima Daiichi nuclear power 

plant, triggered by the earthquake and tsunami of March 11, 2011, had a debilitating effect on the 

operation of Japan’s nuclear power plants. On June 16, 2012, the Japanese government announced 

plans to restart two reactors at the Ohi nuclear power plant in July 2012, but the future of the 

Japanese nuclear energy program is uncertain, and not all of the 50 reactors listed are expected to 

restart. 
Appendix III: Accumulation of Commercial 

Spent Fuel by State over Time

Page 57 GAO-12-797 Accumulation of Spent Nuclear Fuel

Our report identified three scenarios in which spent fuel could be moved 

to an off-site location. Briefly, the earliest likely opening date if the Yucca 

Mountain repository were to be licensed and constructed is about 2027, 

the earliest a centralized storage facility could be expected to open is 

about 2032, and the earliest a permanent disposal facility that was an 

alternative to Yucca Mountain could be expected to open is about 2052. 

Table 3 summarizes the amount of spent fuel that is expected to 

accumulate in each state for these dates, as well as 2012—the current 

spent fuel accumulation—and 2067, when all currently operating 

commercial nuclear power reactors are expected to have retired and 

transferred their spent fuel to dry storage. The table also shows the rank 

for each state in terms of the amount of its accumulated spent fuel in 

comparison with the other states.

Table 3: Cumulative Quantities of Spent Fuel, by State, for 2012, 2027, 2032, 2052, and 2067

Metric tons

State 

2012 2027 2032 2052 2067

Total 

volume Rank

Total 

volume Rank

Total 

volume Rank

Total 

volume Rank

Total 

volume Rank

Alabama 3,341 5 5,300 5 6,004 5 6,899 4 6,899 4 

Arizona 2,041 15 3,331 14 3,761 14 5,108 13 5,108 13

Arkansas 1,377 18 2,117 17 2,369 17 2,659 19 2,659 19

California 3,059 6 4,565 6 5,039 6 6,351 6 6,351 6 

Connecticut 2,079 14 2,729 16 2,962 16 3,477 16 3,477 16

Florida 3,035 7 4,319 7 4,847 7 5,467 9 5,467 9 

Georgia 2,691 10 4,101 9 4,584 9 5,815 8 5,815 8 

Illinois 8,995 1 12,978 1 14,639 1 17,354 1 17,354 1 

Iowa 476 32 692 31 746 31 838 31 838 31

Kansas 685 25 1,075 25 1,192 26 1,593 25 1,593 25

Louisiana 1,288 20 2,062 18 2,275 18 3,035 17 3,035 17

Maine 542 31 542 32 542 32 542 32 542 32

Maryland 1,379 17 1,979 19 2,179 19 2,451 20 2,451 20

Massachusetts 664 27 888 29 1,046 29 1,046 29 1,046 29

Michigan 2,692 9 4,012 11 4,468 10 5,193 12 5,193 12

Minnesota 1,235 21 1,767 22 1,973 22 2,077 22 2,077 22

Mississippi 805 24 1,215 24 1,379 24 1,805 23 1,805 23

Missouri 679 26 1,059 26 1,211 25 1,553 26 1,553 26

Nebraska 904 23 1,309 23 1,462 23 1,608 24 1,608 24

Appendix III: Accumulation of Commercial 

Spent Fuel by State over Time
Appendix III: Accumulation of Commercial 

Spent Fuel by State over Time

Page 58 GAO-12-797 Accumulation of Spent Nuclear Fuel

State 

2012 2027 2032 2052 2067

Total 

volume Rank

Total 

volume Rank

Total 

volume Rank

Total 

volume Rank

Total 

volume Rank

New 

Hampshire

586 30 966 28 1,080 28 1,517 27 1,517 27

New Jersey 2,667 11 4,031 10 4,419 11 5,390 10 5,390 10

New York 3,726 4 5,423 4 6,045 4 6,771 5 6,771 5 

North Carolina 4,984 3 7,484 3 8,294 3 10,384 3 10,384 3 

Ohio 1,154 22 1,829 21 2,044 20 2,699 18 2,699 18

Oregon 345 33 345 33 345 33 345 33 345 33

Pennsylvania 6,272 2 9,408 2 10,410 2 13,082 2 13,082 2 

South Carolina 2,898 8 4,308 8 4,807 8 5,324 11 5,324 11

Tennessee 1,672 16 2,742 15 3,063 15 4,056 15 4,215 15

Texas 2,199 13 3,759 12 4,305 12 6,264 7 6,343 7 

Vermont 624 29 854 30 989 30 989 30 989 30

Virginia 2,527 12 3,607 13 4,031 13 4,471 14 4,471 14

Washington 656 28 1,032 27 1,126 27 1,500 28 1,500 28

Wisconsin 1,367 19 1,847 20 2,024 21 2,119 21 2,119 21

Source: GAO analysis of Nuclear Energy Institute data.

Note: The data from this table constitute the underlying data in figure 8. 
Appendix IV: Comments from the Nuclear 

Regulatory Commission

Page 59 GAO-12-797 Accumulation of Spent Nuclear Fuel

Appendix IV: Comments from the Nuclear 

Regulatory Commission
Appendix IV: Comments from the Nuclear 

Regulatory Commission

Page 60 GAO-12-797 Accumulation of Spent Nuclear Fuel
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 61 GAO-12-797 Accumulation of Spent Nuclear Fuel

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

In addition to the individual named above, Janet E. Frisch (Assistant 

Director), Antoinette Capaccio, Virginia Chanley, Ellen W. Chu, Randall 

Cole, R. Scott Fletcher, Cristian Ion, Mehrzad Nadji, Kevin Remondini, 

Robert Sánchez, Carol Shulman, Kiki Theodoropoulos, and Franklyn Yao 

made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(361313)
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