United States Government Accountability Office

GAO Report to Congressional Requesters

NUCLEAR WASTE 

MANAGEMENT 

Key Attributes, 

Challenges, and Costs 

for the Yucca 

Mountain Repository 

and Two Potential 

Alternatives 

November 2009 

GAO-10-48 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

November 2009

NUCLEAR WASTE MANAGEMENT 

Key Attributes, Challenges, and Costs of the Yucca 

Mountain Repository and Two Potential Alternatives

Highlights of GAO-10-48, a report to 

congressional requesters 

High-level nuclear waste—one of 

the nation’s most hazardous 

substances—is accumulating at 80 

sites in 35 states. The United States 

has generated 70,000 metric tons of 

nuclear waste and is expected to 

generate 153,000 metric tons by 

2055. The Nuclear Waste Policy Act 

of 1982, as amended, requires the 

Department of Energy (DOE) to 

dispose of the waste in a geologic 

repository at Yucca Mountain, 

about 100 miles northwest of Las 

Vegas, Nevada. However, the 

repository is more than a decade 

behind schedule, and the nuclear 

waste generally remains at the 

commercial nuclear reactor sites 

and DOE sites where it was 

generated. 

This report examines the key 

attributes, challenges, and costs of 

the Yucca Mountain repository and 

the two principal alternatives to a 

repository that nuclear waste 

management experts identified: 

storing the nuclear waste at two 

centralized locations and 

continuing to store the waste on 

site where it was generated. GAO 

developed models of total cost 

ranges for each alternative using 

component cost estimates provided 

by the nuclear waste management 

experts. However, GAO did not 

compare these alternatives because 

of significant differences in their 

inherent characteristics that could 

not be quantified. 

What GAO Recommends

GAO is making no 

recommendations in this report. In 

written comments, DOE and NRC 

generally agreed with the report. 

The Yucca Mountain repository is designed to provide a permanent solution 

for managing nuclear waste, minimize the uncertainty of future waste safety, 

and enable DOE to begin fulfilling its legal obligation under the Nuclear Waste 

Policy Act to take custody of commercial waste, which began in 1998. 

However, project delays have led to utility lawsuits that DOE estimates are 

costing taxpayers about $12.3 billion in damages through 2020 and could cost 

$500 million per year after 2020, though the outcome of pending litigation may 

affect the government’s total liability. Also, the administration has announced 

plans to terminate Yucca Mountain and seek alternatives. Even if DOE 

continues the program, it must obtain a Nuclear Regulatory Commission 

construction and operations license, a process likely to be delayed by budget 

shortfalls. GAO’s analysis of DOE’s cost projections found that a repository to 

dispose of 153,000 metric tons would cost from $41 billion to $67 billion (in 

2009 present value) over a 143-year period until the repository is closed. 

Nuclear power rate payers would pay about 80 percent of these costs, and 

taxpayers would pay about 20 percent. 

Centralized storage at two locations provides an alternative that could be 

implemented within 10 to 30 years, allowing more time to consider final 

disposal options, nuclear waste to be removed from decommissioned reactor 

sites, and the government to take custody of commercial nuclear waste, 

saving billions of dollars in liabilities. However, DOE’s statutory authority to 

provide centralized storage is uncertain, and finding a state willing to host a 

facility could be extremely challenging. In addition, centralized storage does 

not provide for final waste disposal, so much of the waste would be 

transported twice to reach its final destination. Using cost data from experts, 

GAO estimated the 2009 present value cost of centralized storage of 153,000 

metric tons at the end of 100 years to range from $15 billion to $29 billion but 

increasing to between $23 billion and $81 billion with final geologic disposal. 

On-site storage would provide an alternative requiring little change from the 

status quo, but would face increasing challenges over time. It would also allow 

time for consideration of final disposal options. The additional time in on-site 

storage would make the waste safer to handle, reducing risks when waste is 

transported for final disposal. However, the government is unlikely to take 

custody of the waste, especially at operating nuclear reactor sites, which 

could result in significant financial liabilities that would increase over time. 

Not taking custody could also intensify public opposition to spent fuel storage 

site renewals and reactor license extensions, particularly with no plan in place 

for final waste disposition. In addition, extended on-site storage could 

introduce possible risks to the safety and security of the waste as the storage 

systems degrade and the waste decays, potentially requiring new maintenance 

and security measures. Using cost data from experts, GAO estimated the 2009 

present value cost of on-site storage of 153,000 metric tons at the end of 100 

years to range from $13 billion to $34 billion but increasing to between $20 

billion to $97 billion with final geologic disposal. 

View GAO-10-48 or key components.

For more information, contact Mark Gaffigan 

at 202-512-3841 or gaffiganm@gao.gov. 
Page i GAO-10-48 

Contents 

Letter 1

Background 5 

The Yucca Mountain Repository Would Provide a Permanent 

Solution for Nuclear Waste, but Its Implementation Faces 

Challenges and Significant Upfront Costs 13 

We Identified Two Nuclear Waste Management Alternatives and 

Developed Cost Models by Consulting with Experts 22 

Centralized Storage Would Provide a Near-Term Alternative, 

Allowing Other Options to Be Studied, but Faces 

Implementation Challenges 29 

On-Site Storage Would Provide an Intermediate Option with 

Minimal Effort but Poses Challenges that Could Increase Over 

Time 36 

Concluding Observations 40 

Agency Comments 41 

Appendix I Scope and Methodology 43 

Appendix II Our Methodology for Obtaining Comments from 

Nuclear Waste Management Experts 49 

Appendix III Nuclear Waste Management Experts We Interviewed 57 

Appendix IV Modeling Methodology, Assumptions, and Results 62 

Appendix V Comments from the Department of Energy 76 

Appendix VI Comments from the Nuclear Regulatory Commission 77 

Appendix VII GAO Contact and Staff Acknowledgments 78 

 Nuclear Waste Management 
Tables 

Table 1: Estimated Cost of the Yucca Mountain Scenarios 19 

Table 2: Key Assumptions Used to Define Alternatives 23 

Table 3: Models and Scenarios Used for Cost Ranges 27 

Table 4: Estimated Cost Range for Each Centralized Storage 

Scenario 34 

Table 5: Estimated Cost Range for Each On-site Storage Scenario 39 

Table 6: Our Data Collection Instrument for Nuclear Waste 

Management Experts 50 

Table 7: Initial Assumptions and Component Cost Estimates for 

Our Centralized Storage and On-site Storage Alternatives 

and Modifications Made Based on Experts’ Responses to 

Our Data Collection Instrument 52 

Table 8: Model Results for All Scenarios 71 

Figures 

Figure 1: Current Storage Sites and Proposed Repository for HighLevel Nuclear Waste 2 

Figure 2: Aerial View and Cut-Out of the Yucca Mountain 

Repository 6 

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

Figure 4: Cost Profile for the Yucca Mountain Repository, 

Assuming 70,000 Metric Tons 20 

Figure 5: Process Assumptions and Cost Components for 

Hypothetical Nuclear Waste Management Alternatives 25 

Figure 6: Scenario and Cost Time Frames for the Centralized 

153,000 Metric Ton Models 67 

Figure 7: Scenario and Cost Time Frames for the Centralized 70,000 

Metric Ton Model 68 

Figure 8: Scenarios and Cost Time Frames for the On-Site 153,000 

Metric Ton Models 69 

Figure 9: Scenario and Cost Time Frames for the On-Site 70,000 

Metric Ton Model 70 

Figure 10: Total Cost Ranges for Centralized Storage for 100 Years 

with Final Disposition 72 

Figure 11: Total Cost Ranges for On-site Storage for 100 years with 

Final Disposition 73 

Figure 12: Total Cost Ranges of On-Site Storage over 2,000 Years 74 

Page ii GAO-10-48 Nuclear Waste Management
Abbreviations 

DOE Department of Energy 

EPA Environmental Protection Agency 

NRC Nuclear Regulatory Commission 

NWPA Nuclear Waste Policy Act of 1982 

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

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

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necessary if you wish to reproduce this material separately. 

Page iii GAO-10-48 Nuclear Waste Management
Page 1 GAO-10-48 

United States Government Accountability Office

Washington, DC 20548 

 

November 4, 2009 

The Honorable Barbara Boxer 

Chairman 

Committee on Environment and Public Works 

United States Senate 

The Honorable Harry Reid 

United States Senate 

The Honorable John Ensign 

United States Senate 

High-level nuclear waste consists mostly of spent nuclear fuel removed 

from commercial power reactors and is considered one of the most 

hazardous substances on earth. The U.S. national inventory of 70,000 

metric tons of nuclear waste—enough to fill a football field more than 15 

feet deep—has been accumulating at 80 sites in 35 states since the mid1940s and is expected to more than double to 153,000 metric tons by 2055. 

The current national policy of constructing a federal repository to dispose 

of this waste at Yucca Mountain—which is about 100 miles northwest of 

Las Vegas, Nevada—has already been delayed more than a decade. As a 

result, nuclear waste generally remains at the sites where it was generated. 

Experts and regulators believe the nuclear waste, if properly stored and 

monitored, can be kept safe and secure on-site for decades; but 

communities across the country have raised concerns about the waste’s 

lethal nature and the possibility of natural disasters or terrorism, 

particularly at sites near urban centers or sources of drinking water. 

Industry has also raised concerns that local communities will not support 

the expansion of the nuclear energy industry without a final waste 

disposition pathway. Many experts and communities view nuclear energy 

as a potential means of meeting future energy demands while reducing 

reliance on fossil fuels and cutting carbon emissions, a key contributor to 

climate change. 

In addition to the spent nuclear fuel generated by commercial power 

reactors, the Department of Energy (DOE) owns and manages about 19 

percent of the nuclear waste—referred to as DOE-managed spent nuclear 

fuel and high-level waste—which consists of spent nuclear fuel from 

power, research, and navy shipboard reactors, and high-level nuclear 

waste from the nation’s nuclear weapons program. (See fig. 1 for the 

locations where nuclear waste is stored.) 

 Nuclear Waste Management 
 

Page 2 GAO-10-48 Nuclear Waste Management 

Figure 1: Current Storage Sites and Proposed Repository for High-Level Nuclear Waste 

Note: Locations are approximate. DOE has reported that it is responsible for managing nuclear waste 

at 121 sites in 39 states, but DOE officials told us that several sites have only research reactors that 

generate small amounts of waste that will be consolidated at the Idaho National Laboratory for 

packaging prior to disposal. 

Under the Nuclear Waste Policy Act of 1982 (NWPA), as amended, DOE 

was to evaluate one or more national geologic repositories that would be 

designated to permanently store commercial spent nuclear fuel and DOEmanaged spent nuclear fuel and high-level waste. NWPA was amended in 

1987 to direct DOE to evaluate only the Yucca Mountain site. In 2002, the 

president recommended and the Congress approved the Yucca Mountain 

site as the nation’s geologic repository. The repository is intended to 

Source: DOE.

Yucca

Mountian

San

Onofre

Palo Verde

Commercial sites

DOE sites

Proposed repository

Wolf Creek

Callaway

Fermi Perry

Diablo

Canyon

Humboldt

Bay

Fort St. 

Vrain 

Trojan

Hanford

Site

Idaho 

National

Laboratory

Savannah

River Site

West Valley

Demonstration

Project

Fort

Calhoun

Duane Arnold

Prairie

Island

Quad

Cities

Point

Beach

La Salle

Clinton

Grand

Gulf

Byron

Zion

Palisades

D.C. Cook

Monticello

Davis- Besse

Beaver Valley

Ginna

Three Mile Island

Calvert Cliffs

Catawba

St. Lucie

Crystal River

Edwin I.

Hatch

North

Anna

Shearon Harris

Brunswick

McGuire

Surry

Joseph M. Farley

Watts Bar 

Vogtle

Browns Ferry Turkey Point

Sequoyah

South Texas Project

River Bend

Waterford

Comanche

Peak

Summer

Oconee

H.B. Robinson

Peach Bottom

Salem & Hope Creek

Oyster Creek

Haddem Neck

Indian Point

Millstone

Pilgrim

Seabrook

Maine Yankee

Yankee Rowe

Vermont

Yankee 

Limerick

Big

Rock

Point

Nine Mile Point

& James A.

FitzPatrick

Susquehanna

Kewaunee

La Crosse

Cooper

Station

Columbia Generating Station

Rancho

Seco

Braidwood

Dresden

& Morris

Arkansas Nuclear One

MT

WY

ID OR

WA

CO

OK

KS

TX

UT

NV

CA

AZ

NM

NE

SD

ND

MN

IA

MO

AR

LA

MS

AL GA

FL

SC

TN

KY

IL

WI

MI

IN

OH

WV VA

NC

PA

NY VT

ME

NH

MA

CT

MD DE

NJ
 

isolate nuclear waste from humans and the environment for thousands of 

years, long enough for its radioactivity to decay to near natural 

background levels. NWPA set January 31, 1998, as the date for DOE to 

start accepting nuclear waste for disposal. To meet this goal, DOE has 

spent more than $14 billion for design, engineering, and testing activities.1

In June 2008, DOE submitted a license application to the Nuclear 

Regulatory Commission (NRC) for approval to construct the repository. In 

July 2008, DOE reported that its best achievable date for opening the 

repository, if it receives NRC approval, is in 2020. Delays in the Yucca 

Mountain repository have resulted in a need for continued storage of the 

waste onsite, leaving industry uncertain regarding the licensing of new 

nuclear power reactors and the nation uncertain regarding a final 

disposition of the waste. 

In March 2009, the Secretary of Energy testified that the administration 

planned to terminate the Yucca Mountain repository. Since then, the 

administration has announced plans to study alternatives to geologic 

disposal at Yucca Mountain before making a decision on a future nuclear 

waste management strategy, which the administration said could include 

reprocessing or other complementary strategies. 

In this context, you asked us to identify key aspects of DOE’s nuclear 

waste management program and other possible management approaches. 

Specifically, you asked us to examine (1) the key attributes, challenges, 

and costs of the Yucca Mountain repository; (2) and identify alternative 

nuclear waste management approaches; (3) the key attributes, challenges, 

and costs of storing the nuclear waste at two centralized sites; and (4) the 

key attributes, challenges, and costs of continuing to store the nuclear 

waste at its current locations. The centralized storage and onsite storage 

options—both with disposal scenarios—were the two most likely 

alternative approaches identified by the experts we interviewed. We are 

also providing information on what is known about sources of funding—

primarily taxpayers and nuclear power rate payers—for the Yucca 

Mountain repository and the two alternative approaches. 

To examine the key attributes, challenges, and costs of the Yucca 

Mountain repository, we obtained reports and supporting documentation 

 

1

In constant fiscal year 2009 dollars. Funding comes primarily from fees collected from 

electric power companies operating commercial reactors and appropriations for DOEmanaged spent nuclear fuel and high-level waste. 

Page 3 GAO-10-48 Nuclear Waste Management
 

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

Waste Technical Review Board. Specifically, we used DOE’s report on the 

Yucca Mountain repository’s total lifecycle cost to analyze the cost for 

disposing of either (1) 70,000 metric tons of nuclear waste, which is the 

statutory cap on the amount of waste that can be disposed of at Yucca 

Mountain, or (2) 153,000 metric tons, which is the estimated total amount 

of nuclear waste that has already been generated and will be generated if 

all currently operating commercial reactors operate for a 60-year lifespan.2

We then discounted these costs to 2009 present value. 

To identify alternative nuclear waste management approaches, we 

interviewed DOE officials, experts at the National Academy of Sciences 

and the Nuclear Waste Technical Review Board, and executives at the 

Nuclear Energy Institute, among others. Based on their comments, we 

identified two generic alternative approaches for managing this waste for 

at least a 100-year period before it is disposed in a repository: storing the 

nuclear waste at two centralized facilities—referred to as centralized 

storage—and continuing to store the nuclear waste on site at their current 

facilities—referred to as on-site storage. To examine the key attributes, 

challenges, and costs of each alternative, we asked nuclear waste 

management experts from federal agencies, industry, academic 

institutions, and concerned groups to comment on the attributes and 

challenges of each alternative, provide relevant cost data, and comment on 

the assumptions and cost components that we used to develop cost 

models for the alternatives. We then used the models to produce the total 

cost ranges for each alternative with and without final disposal in a 

geologic repository at the end of a 100-year specific time period. In 

addition, we analyzed onsite storage for longer periods than 100 years. We 

analyzed costs associated with storing 70,000 metric tons and 153,000 

metric tons and discounted the costs to 2009 present value. 

We did not compare the Yucca Mountain cost range to the ranges of other 

alternatives because of significant differences in inherent characteristics 

of these alternatives that our modeling work could not quantify. For 

example, the safety, health, and environmental risks for each are very 

different, which needs to be considered in the policy debate on nuclear 

waste management decisions. (See app. I for additional information about 

our scope and methodology, app. II for our methodology for soliciting 

 

2

DOE, Analysis of the Total System Lifecycle Cost of the Civilian Radioactive Waste 

Management Program, Fiscal Year 2007, DOE/RW-0591 (Washington, D.C., July 2008). 

Page 4 GAO-10-48 Nuclear Waste Management
 

comments from nuclear waste management experts, and app. III for a list 

of these experts.) 

We conducted this performance audit from April 2008 to October 2009 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. 

Nuclear waste is long-lived and very hazardous—without protective 

shielding, the intense radioactivity of the waste can kill a person within 

minutes or cause cancer months or even decades after exposure.3

 Thus, 

careful management is required to isolate it from humans and the 

environment. To accomplish this, the National Academy of Sciences first 

endorsed the concept of nuclear waste disposal in deep geologic 

formations in a 1957 report to the U.S. Atomic Energy Commission, which 

has since been articulated by experts as the safest and most secure 

method of permanent disposal.4

 However, progress toward developing a 

geologic repository was slow until NWPA was enacted in 1983. Citing the 

potential risks of the accumulating amounts of nuclear waste, NWPA 

required the federal government to take responsibility for the disposition 

of nuclear waste and required DOE to develop a permanent geologic 

repository to protect public health and safety and the environment for 

Background 

 

3

For the purposes of our report, nuclear waste includes both spent nuclear fuel—fuel that 

has been withdrawn from a nuclear reactor following irradiation—and high-level 

radioactive waste—generally the material resulting from the reprocessing of spent nuclear 

fuel. Nuclear waste—specifically spent nuclear fuel—is also very thermally hot. As the 

radioactive elements in spent nuclear fuel decay, they give off heat. However, according to 

DOE data, a spent nuclear fuel assembly can lose nearly 80 percent of its heat 5 years after 

it has been removed from a reactor and about 95 percent of its heat after 100 years. 

4

National Academy of Sciences, The Disposal of Radioactive Waste on Land, (Washington, 

D.C., September 1957). This report suggested several potential alternatives for disposal of 

nuclear waste, stressing that although there are many potential sites for geologic disposal 

of waste at various depths and in various geologic formations, further research was needed 

regarding specific waste forms and specific geologic formations, including disposal in deep 

underground formations. The report stated, “the hazard related to radioactive waste is so 

great that no element of doubt should be allowed to exist regarding safety.” Subsequent 

reports by the National Academy of Sciences and others have continued to endorse 

geologic isolation of nuclear waste and have suggested that engineered barriers, such as 

corrosion-resistant containers, can provide additional layers of isolation. 

Page 5 GAO-10-48 Nuclear Waste Management
 

current and future generations. Specifically, the act required DOE to study 

several locations around the country for possible repository sites and 

develop a contractual relationship with industry for disposal of the nuclear 

waste. The Congress amended NWPA in 1987 to restrict scientific study 

and characterization of a possible repository to only Yucca Mountain. (Fig. 

2 shows the north crest of Yucca Mountain and a cut-out of the proposed 

mined repository.) 

Figure 2: Aerial View and Cut-Out of the Yucca Mountain Repository 

Surface

1,000 ft.

(about 300 meters)

1,000 ft.

(about 300 meters)

Emplacement

Water table

Ventilation

shafts

North portal

Emplacement tunnels

Access portals

South portal

Aerial photo of Yucca Mountain

Source: DOE.

After the Congress approved Yucca Mountain as a suitable site for the 

development of a permanent nuclear waste repository in 2002, DOE began 

Page 6 GAO-10-48 Nuclear Waste Management
 

preparing a license application for submittal to NRC, which has regulatory 

authority over commercial nuclear waste management facilities. DOE 

submitted its license application to NRC in June 2008, and NRC accepted 

the license application for review in September 2008. NWPA requires NRC 

to complete its review of DOE’s license application for the Yucca 

Mountain repository in 3 years, although a fourth year is allowed if NRC 

deems it necessary and complies with certain reporting requirements. 

To pay the nuclear power industry’s share of the cost for the Yucca 

Mountain repository, NWPA established the Nuclear Waste Fund, which is 

funded by a fee of one mill (one-tenth of a cent) per kilowatt-hour of 

nuclear-generated electricity that the federal government collects from 

electric power companies. DOE reported that, at the end of fiscal year 

2008, the Nuclear Waste Fund contained $22 billion, with an additional 

$1.9 billion projected to be added in 2009. DOE receives money from the 

Nuclear Waste Fund through congressional appropriations. Additional 

funding for the repository comes from an appropriation which provides 

for the disposal cost of DOE-managed spent nuclear fuel and high-level 

waste. 

NWPA caps nuclear waste that can be disposed of at the Yucca Mountain 

repository at 70,000 metric tons until a second repository is available. 

However, the nation has already accumulated about 70,000 metric tons of 

nuclear waste at current reactor sites and DOE facilities. Without a change 

in the law to raise the cap or to allow the construction of a second 

repository, DOE can dispose of only the current nuclear waste inventory. 

The nation will have to develop a strategy for an additional 83,000 metric 

tons of waste expected to be generated if NRC issues 20-year license 

extensions to all of the currently operating nuclear reactors.5

 This amount 

does not include any nuclear waste generated by new reactors or future 

defense activities, or greater than class C nuclear waste.6

 According to 

 

5

NRC has already issued license extensions for 54 reactors, enabling them to operate for a 

total of 60 years. Extension requests for 21 units are currently under review and requests 

for as many as 25 more are anticipated through 2017. 

6

As of October 2009, NRC has received 18 applications for 29 new reactors. In addition to 

spent nuclear fuel and DOE-managed high-level waste, the nation also generates so-called 

greater than class C nuclear waste from the maintenance and decommissioning of nuclear 

power plants, from radioactive materials that were once used for food irradiation or for 

medical purposes, and from miscellaneous radioactive waste, such as contaminated 

equipment from industrial research and development. DOE, which is required to dispose of 

this nuclear waste, has not issued an environmental impact statement describing potential 

options, which could include disposal of the waste at the Yucca Mountain repository. 

Page 7 GAO-10-48 Nuclear Waste Management
 

DOE and industry studies, three to four times the 70,000 metric tons—and 

possibly more—could potentially be disposed safely in Yucca Mountain, 

which could address current and some future waste inventories, 

potentially delaying the need for a second repository for several 

generations. 

Nuclear waste has continued to accumulate at the nation’s commercial 

and DOE nuclear facilities over the past 60 years. Facility managers must 

actively manage the nuclear waste by continually isolating, confining, and 

monitoring it to keep humans and the environment safe. Most spent 

nuclear fuel is stored at reactor sites, immersed in pools of water designed 

to cool and isolate it from the environment. With nowhere to dispose of 

the spent nuclear fuel, the racks holding spent fuel in the pools have been 

rearranged to allow for more dense storage of assemblies. Even with this 

re-racking, spent nuclear fuel pools are reaching their capacities. Some 

critics have expressed concern about the remote possibility of an 

overcrowded spent nuclear fuel pool releasing large amounts of radiation 

if an accident or other event caused the pool to lose water, potentially 

leading to a fire that could disperse radioactive material. As reactor 

operators have run out of space in their spent nuclear fuel pools, they have 

turned in increasing number to dry cask storage systems that generally 

consist of stainless steel canisters placed inside larger stainless steel or 

concrete casks. (See fig. 3.) NRC requires protective shielding, routine 

inspections and monitoring, and security systems to isolate the nuclear 

waste to protect humans and the environment. 

Page 8 GAO-10-48 Nuclear Waste Management
 

Figure 3: Dry Cask Storage System for Spent Nuclear Fuel 

Source: NRC.

above

a

Page 9 GAO-10-48 Nuclear Waste Management
 

NRC has determined that these dry cask storage systems can safely store 

nuclear waste, but NRC considers them to be interim measures. In 1990, 

NRC issued a revised waste confidence rule, stating that it had co

that the waste generated by a reactor can be safely stored in either wet or 

dry storage for 30 years beyond a reactor’s life, including license 

extensions. NRC further determined that it had reasonable assurance that

safe geologic disposal was feasible and that a geologic repository would b

operational by about 2025. More recently, NRC has published a notice of 

proposed rulemaking to revise that rule, proposing that waste generated 

by a reactor can be safely stored for 60 years beyond the life of a reac

and that geologic disposal would be available in 50 to 60 years beyond a 

reactor’s life.

nfidence 

e 

tor 

ve 

lities 

s of June 2009, and the number of reactor 

sites storing spent nuclear fuel is likely to continue to grow until an 

e 

 for 

’s 

ions 

gton in 

tal 

review would include limitations on certain nuclear waste shipments to 

Hanford until the process of immobilizing tank waste in glass begins, 

 

7

 NRC is currently considering whether to republish its 

proposed rule to seek additional public input on certain issues. Forty-fi

reactor sites or former reactor sites in 30 states have dry storage faci

for their spent nuclear fuel a

alternative is implemented. 

Implementing a permanent, safe, and secure disposal solution for the 

nuclear waste is of concern to the nation, particularly state governments

and local communities, because many of the 80 sites where nuclear wast

is currently stored are near large populations or major water sources or 

consist of shutdown reactor sites that tie up land that could be used

other purposes. In addition, states that have DOE facilities with nuclear 

waste storage are concerned because of possible contamination to 

aquifers, rivers, and other natural resources. DOE’s Hanford Reservation, 

located near Richland, Washington, was a major component of the nation

nuclear weapons defense program from 1943 until 1989, when operat

ceased. In the settlement of a lawsuit filed by the state of Washin

2003, DOE agreed not to ship certain nuclear waste to Hanford until 

environmental reviews were complete. In August 2009, the U.S. 

government stated that the preferred alternative in DOE’s environmen

7

See 73 Fed. Reg. 59551-59570 (Oct. 9, 2008). 

Page 10 GAO-10-48 Nuclear Waste Management
 

expected in 2019.8 Moreover, some commercial and DOE sites where the 

nuclear waste is stored may not be able to accommodate much additional 

waste safely because of limited storage space or community objections. 

These sites will require a more immediate solution. 

The nation has considered proposals to build centralized storage facilities 

where waste from reactor sites could be consolidated. The 1987 

amendment to NWPA established the Office of the Nuclear Waste 

Negotiator to try to broker an agreement for a community to host a 

repository or interim storage facility. Two negotiators worked with local 

communities and Native American tribes for several years, but neither was 

able to conclude a proposed agreement with a willing community by 

January 1995, when the office’s authority expired. Subsequently, in 2006 

after a 9-year licensing process, a consortium of electric power companies 

called Private Fuel Storage obtained a NRC license for a private 

centralized storage facility on the reservation of the Skull Valley Band of 

the Goshute Indians in Utah. NRC’s 20-year license—with an option for an 

additional 20 years—allows storage of up to 40,000 metric tons of 

commercial spent nuclear fuel. However, construction of the Private Fuel 

Storage facility has been delayed by Department of the Interior decisions 

not to approve the lease of tribal lands to Private Fuel Storage and 

declining to issue the necessary rights-of-way to transport nuclear waste to 

the facility through Bureau of Land Management land. Private Fuel Storage 

and the Skull Valley Band of Goshutes filed a federal lawsuit in 2007 to 

overturn Interior’s decisions. 

Reprocessing nuclear waste could potentially reduce, but not eliminate, 

the amount of waste for disposal. In reprocessing, usable uranium and 

plutonium are recovered from spent nuclear fuel and are used to make 

new fuel rods. However, current reprocessing technologies separate 

weapons usable plutonium and other fissionable materials from the spent 

nuclear fuel, raising concerns about nuclear proliferation by terrorists or 

 

8

The U.S. government made this statement in a letter related to a tentative settlement 

agreement in the lawsuit of State of Washington v. Chu, No. CV-08-5085-FVS (E.D. 

Washington, filed Nov. 26, 2008). In 2008, the state of Washington filed suit claiming DOE 

had violated the Tri-Party Agreement among DOE, the state, and the Environmental 

Protection Agency by failing to meet enforceable cleanup milestones in the agreement. On 

August 10, 2009, DOE and the state announced they had reached a tentative settlement, 

including new cleanup milestones and a 2047 completion date for certain key cleanup 

activities. We have questioned DOE’s ability to meet this date. See GAO, Nuclear Waste: 

Uncertainties and Questions about Costs and Risks Persist with DOE’s Tank Waste 

Cleanup Strategy at Hanford, GAO-09-913 (Washington, D.C.: Sept. 30, 2009). 

Page 11 GAO-10-48 Nuclear Waste Management
 

enemy states. Although the United States pioneered the reprocessing 

technologies used by other countries, such as France and Russia, 

presidents Gerald Ford and Jimmy Carter ended government support for 

commercial reprocessing in the United States in 1976 and 1977, 

respectively, primarily due to proliferation concerns. Although President 

Ronald Reagan lifted the ban on government support in 1981, the nation 

has not embarked on any reprocessing program due to proliferation and 

cost concerns—the Congressional Budget Office recently reported that 

current reprocessing technologies are more expensive than direct disposal 

of the waste in a geologic repository.9

 DOE’s Fuel Cycle Research and 

Development program is currently performing research in reprocessing 

technologies that would not separate out weapons usable plutonium, but it 

is not certain whether these technologies will become cost-effective.10

The general consensus of the international scientific community is that 

geologic disposal is the preferred long-term nuclear waste management 

alternative. Finland, Sweden, Canada, France, and Switzerland have 

decided to construct geologic disposal facilities, but none have yet 

completed any such facility, although DOE reports that Finland and 

Sweden have announced plans to begin emplacement operations in 2020 

and 2023, respectively. Moreover, some countries employ a mix of 

complementary storage alternatives in their national waste management 

strategies, including on-site storage, consolidated interim storage, 

reprocessing, and geologic disposal. For example, Sweden plans to rely on 

on-site storage until the waste cools enough to move it to a centralized 

storage facility, where the waste will continue to cool and decay for an 

additional 30 years. This waste will then be placed in a geologic repository 

for disposal. France reprocesses the spent nuclear fuel, recycling usable 

portions as new fuel and storing the remainder for eventual disposal. 

 

9

Congressional Budget Office, Costs of Reprocessing Versus Directly Disposing of Spent 

Nuclear Fuel; Testimony before the Committee on Energy and Natural Resources 

(Washington, D.C.: Nov. 14, 2007). 

10DOE changed the name of this program from the Advanced Fuel Cycle Initiative to the 

Fuel Cycle Research and Development program in its fiscal year 2010 budget submission. 

Page 12 GAO-10-48 Nuclear Waste Management
 

The Yucca Mountain repository—mandated by NWPA, as amended—

would provide a permanent nuclear waste management solution for the 

nation’s current inventory of about 70,000 metric tons of waste. According 

to DOE and industry studies, the repository potentially could be a disposal 

site for three to four times that amount of waste. However, the repository 

lacks the support of the administration and the state of Nevada, and faces 

regulatory and other challenges. Our analysis of DOE’s cost projections 

found that the Yucca Mountain repository would cost from $41 billion to 

$67 billion (in 2009 present value) for disposing of 153,000 metric tons of 

nuclear waste.11 Most of these costs are up-front capital costs. However, 

once the Yucca Mountain repository is closed—in 2151 for our 153,000-

metric-ton model—it is not expected to incur any significant additional 

costs, according to DOE. 

The Yucca Mountain 

Repository Would 

Provide a Permanent 

Solution for Nuclear 

Waste, but Its 

Implementation Faces 

Challenges and 

Significant Upfront 

Costs 

As Designed, the Yucca 

Mountain Repository 

Would Be a Permanent 

Solution and Would 

Reduce the Uncertainty 

Associated with Future 

Nuclear Waste Safety 

The Yucca Mountain repository is designed to isolate nuclear waste in a 

safe and secure environment long enough for the waste to degrade into a 

form that is less harmful to humans and the environment. As nuclear 

waste ages, it cools and decays, becoming less radiologically dangerous. In 

October 2008, after years of legal challenges, the Environmental 

Protection Agency (EPA) promulgated standards that require DOE to 

ensure that radioactive releases from the nuclear waste disposed of at 

Yucca Mountain do not harm the public for 1 million years.12 This is 

because some waste components, such as plutonium 239, take hundreds of 

thousands of years to decay into less harmful materials. To meet EPA’s 

standards and keep the waste safely isolated, DOE’s license application 

proposes the use of both natural and engineered barriers. Key natural 

barriers of Yucca Mountain include its dry climate, the depth and isolation 

 

11Our cost range for a permanent repository differs from DOE’s most recent estimate of $96 

billion for the following reasons: First, our cost range is in 2009 present value, while DOE 

uses 2007 constant dollars, which are not discounted. Our present value analysis reflects 

the time value of money—costs incurred in the future are worth less today—so that 

streams of future costs become smaller. Second, our cost range does not include about $14 

billion in previously incurred costs. Third, our cost range is for 153,000 metric tons of 

nuclear waste while DOE’s estimated cost is for 122,100 metric tons. Finally, we use a 

range while DOE provides a point estimate. 

12The Energy Policy Act of 1992 directed EPA to base its health standards on a National 

Academy of Sciences study of the health issues related to radioactive releases. NRC has 

promulgated rules based on EPA’s October 2008 standards that require the Yucca Mountain 

repository to limit the annual radiation dose of the public to at most 15 millirem for the first 

10,000 years after disposal and at most 100 millirem from 10,001 years to 1 million years 

after disposal. In contrast, the average American is exposed to about 360 millirem of 

radiation annually, mainly from natural background sources. 

Page 13 GAO-10-48 Nuclear Waste Management
 

of the Death Valley aquifer in which the mountain resides, its natural 

physical shape, and the layers of thick rock above and below the 

repository that lie 1,000 feet below the surface of the mountain and 1,000 

feet above the water table. Key engineered barriers include the solid 

nature of the nuclear waste; the double-shelled transportation, aging, and 

disposal canisters that encapsulate the waste and prevent radiation 

leakage; and drip shields that are composed of corrosion-resistant 

titanium to ward off any dripping water inside the repository for many 

thousands of years. 

The construction of a geologic repository at Yucca Mountain would 

provide a permanent solution for nuclear waste that could allow the 

government to begin taking possession of the nuclear waste in the near 

term—about 10 to 30 years. The nuclear power industry sees this as an 

important consideration in obtaining the public support necessary to build 

new nuclear power reactors. The industry is interested in constructing 

new nuclear power reactors because, among other reasons, of the growing 

demand for electricity and pressure from federal and state governments to 

reduce reliance on fossil fuels and curtail carbon emissions. Some electric 

power companies see nuclear energy as an important option for 

noncarbon emitting power generation. According to NRC, 18 electric 

power companies have filed license applications to construct 29 new 

nuclear reactors.13 Nuclear industry representatives, however, have 

expressed concerns that investors and the public will not support the 

construction of new nuclear power reactors without a final safe and 

secure disposition pathway for the nuclear waste, particularly if that waste 

is generated and stored near major waterways or urban centers. Moreover, 

having a permanent disposal option may allow reactor operators to thinout spent nuclear fuel assemblies from densely packed spent fuel pools, 

potentially reducing the risk of harm to humans or the environment in the 

event of an accident, natural disaster, or terrorist event. 

In addition, disposal is the only alternative for some DOE and commercial 

nuclear waste—even if the United States decided to reprocess the waste—

because it contains nuclear waste residues that cannot be used as nuclear 

reactor fuel. This nuclear waste has no safe, long-term alternative other 

than disposal, and the Yucca Mountain repository would provide a nearterm, permanent disposal pathway for it. Moreover, DOE has agreed to 

 

13As of October 2, 2009, NRC had suspended or deferred five applications to build and 

operate six reactors at the request of the applicants. 

Page 14 GAO-10-48 Nuclear Waste Management
 

remove spent nuclear fuel from at least two states by certain dates or face 

penalties. Specifically, DOE has an agreement with Colorado stating that if 

the spent nuclear fuel at Fort St. Vrain is not removed by January 1, 2035, 

the government will, subject to certain conditions, pay the state $15,000 

per day until the waste is removed. In addition, the state of Idaho sued 

DOE to remove inventories of spent nuclear fuel stored at DOE’s Idaho 

National Laboratory. Under the resulting settlement DOE agreed to (1) 

remove the spent nuclear fuel by January 1, 2035, or incur penalties of 

$60,000 per day and (2) curtail or suspend future shipments of spent 

nuclear fuel to Idaho.14 Some of the spent nuclear fuel stored at the Idaho 

National Laboratory comes from refueling the U.S. Navy’s submarines and 

aircraft carriers, all of which are nuclear powered. Special facilities are 

maintained at the Idaho National Laboratory to examine naval spent 

nuclear fuel to obtain information for improving future fuel performance 

and to package the spent nuclear fuel following examination to make it 

ready for rail shipment to its ultimate destination. According to Navy 

officials, refueling these warships, which necessitates shipment of naval 

spent nuclear fuel from the shipyards conducting the refuelings to the 

Idaho National Laboratory, is part of the Navy’s national security mission. 

Consequently, curtailing or suspending shipments of spent nuclear fuel to 

Idaho raises national security concerns for the Navy. 

The Yucca Mountain repository would help the government fulfill its 

obligation under NWPA to electric power companies and ratepayers to 

take custody of the commercial spent nuclear fuel and provide a 

permanent repository using the Nuclear Waste Fund. When DOE missed 

its 1998 deadline to begin taking custody of the waste, owners of spent fuel 

with contracts for disposal services filed lawsuits asking the courts to 

require DOE to fulfill its statutory and contractual obligations by taking 

custody of the waste. Though a court decided that it would not order DOE 

to begin taking custody of the waste, the courts have, in subsequent cases, 

ordered the government to compensate the utilities for the cost of storing 

the waste. DOE projected that, based on a 2020 date for beginning 

operations at Yucca Mountain, the government’s liabilities from the 71 

lawsuits filed by electric power companies could sum to about $12.3 

billion, though the outcome of pending and future litigation could 

 

14The penalties in the settlement agreement specifically apply to spent nuclear fuel and not 

to other high-level waste. However, the agreement specifies that DOE must have the other 

high-level waste treated and ready for shipment out of Idaho for disposal by 2035. DOE 

officials acknowledged that Idaho could take further court action if its milestones toward 

meeting these goals are not being met. 

Page 15 GAO-10-48 Nuclear Waste Management
 

substantially affect the ultimate total liability.15 DOE estimates that the 

federal government’s future liabilities will average up to $500 million per 

year. Furthermore, continued delays in DOE’s ability to take custody of 

the waste could result in additional liabilities. Some experts noted that 

without immediate plans for a permanent repository, reactor operators 

and ratepayers may demand that the Nuclear Waste Fund be refunded.16

Finally, disposing of the nuclear waste now in a repository facility would 

reduce the uncertainty about the willingness or the ability of future 

generations to monitor and maintain multiple surface waste storage 

facilities and would eliminate the need for any future handling of the 

waste. As a 2001 report of the National Academies noted, continued 

storage of nuclear waste is technically feasible only if those responsible 

for it are willing and able to devote adequate resources and attention to 

maintaining and expanding the storage facilities, as required to keep the 

waste safe and secure.17 DOE officials noted that the waste packages at 

Yucca Mountain are designed to be retrievable for more than 100 years 

after emplacement, at which time DOE would begin to close the 

repository, allowing future generations to consider retrieving spent 

nuclear fuel for reprocessing or other uses. However, the risks and costs 

of retrieving the nuclear waste from Yucca Mountain are uncertain 

because planning efforts for retrieval are preliminary. Once closed, Yucca 

Mountain will require minimal monitoring and little or no maintenance, 

and all future controls will be passive.18 Some experts stated that the 

current generation has a moral obligation to not pass on to future 

 

15As of July 2009, of the 71 lawsuits filed by electric power companies, 51 cases were 

pending either in the Court of Federal Claims or in the Court of Appeals for the Federal 

Circuit, 10 had been settled, 6 were voluntarily withdrawn, and 4 had been litigated through 

final unappealable judgment. 

16DOE estimated the Nuclear Waste Fund at about $23 billion in June 2009, some of which 

is interest that has accrued. DOE is required to invest the Nuclear Waste Fund in U.S. 

Treasury securities, resulting in the government paying about $11.2 billion interest to the 

fund. Both the principal and the interest might be returned, if the fund is returned to the 

electric power companies. 

17National Research Council of the National Academies, Disposition of High-Level Waste 

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

D.C., 2001). 

18Section 801 (c) of the Energy Policy Act of 1992 requires DOE to provide indefinite 

oversight to prevent any activity at the site that poses an unreasonable risk of (1) breaching 

the repository’s engineered or geologic barriers or (2) increasing the exposure of the public 

to radiation beyond allowable limits. Pub. L. No. 102-486, 106 Stat. 2776, 2921-2922. 

Page 16 GAO-10-48 Nuclear Waste Management
 

generations the extensive technical and financial responsibilities for 

managing nuclear waste in surface storage. 

Yucca Mountain Faces 

Many Challenges, 

Including a Lack of Key 

Support and License 

Approval 

There are many challenges to licensing and constructing the Yucca 

Mountain repository, some of which could delay or potentially terminate 

the program. First, in March 2009, the Secretary of Energy stated that the 

administration planned to terminate the Yucca Mountain repository and to 

form a panel of experts to review alternatives. During the testimony, the 

Secretary stated that Yucca Mountain would not be considered as one of 

the alternatives. The administration’s fiscal year 2010 budget request for 

Yucca Mountain was $197 million, which is $296 million less than what 

DOE stated it needs to stay on its schedule and open Yucca Mountain by 

2020. 

In July 2009 letters to DOE, the Nuclear Energy Institute and the National 

Association of Regulatory Utility Commissioners raised concerns that, 

despite the announced termination of Yucca Mountain, DOE still intended 

on collecting fees for the Nuclear Waste Fund.19 The letters requested that 

DOE suspend collection of payments to the Nuclear Waste Fund. Some 

states have raised similar concerns and legislators have introduced 

legislation that could hold payments to the Nuclear Waste Fund until DOE 

begins operating a federal repository.20

Nevertheless, NWPA still requires DOE to pursue geologic disposal at 

Yucca Mountain. If the administration continues the licensing process for 

Yucca Mountain, DOE would face a variety of other challenges in licensing 

and constructing the repository. Many of these challenges—though unique 

to Yucca Mountain—might also apply in similar form to other future 

repositories, should they be considered. 

One of the most significant challenges facing DOE is to satisfy NRC that 

Yucca Mountain meets licensing requirements, including ensuring the 

repository meets EPA’s radiation standards over the required 1 million 

year time frame, as implemented by NRC regulation. For example, NRC’s 

 

19The Nuclear Energy Institute represents the nuclear power industry and the National 

Association of Regulatory Utility Commissioners represents state public utility 

commissions that regulate the electric power industry. 

20Minnesota House File No. 894, introduced February 16, 2009, and Michigan Senate 

Concurrent Resolution No. 8, introduced March 25, 2009. 

Page 17 GAO-10-48 Nuclear Waste Management
 

regulations require that DOE model its natural and engineered barriers in a 

performance assessment, including how the barriers will interact with 

each other over time and how the repository will meet the standards even 

if one or more barriers do not perform as expected. NRC has stated that 

there are uncertainties inherent in the understanding of the performance 

of the natural and engineered barriers and that demonstrating a 

reasonable expectation of compliance requires the use of complex 

predictive models supported by field data, laboratory tests, site-specific 

monitoring, and natural analog studies. The Nuclear Waste Technical 

Review Board has also stated that the performance assessment may be 

“the most complex and ambitious probabilistic risk assessment ever 

undertaken” and the Board, as well as other groups or individuals, have 

raised technical concerns about key aspects of the engineered or natural 

barriers in the repository design. 

DOE and NRC officials also stated that budget constraints raise additional 

challenges. DOE officials told us that past budget shortfalls and projected 

future low budgets for the Yucca Mountain repository create significant 

challenges in DOE’s ability to meet milestones for licensing and for 

responding to NRC’s requests for additional information related to the 

license application. In addition, NRC officials told us budget shortfalls 

have constrained their resources. Staff members they originally hired to 

review DOE’s license application have moved to other divisions within 

NRC or have left NRC entirely. NRC officials stated that the pace of the 

license review is commensurate with funding levels. Some experts have 

questioned whether NRC can meet the maximum 4-year time requirement 

stipulated in NWPA for license review and have pointed out that the longer 

the delays in licensing Yucca Mountain, the more costly and politically 

vulnerable the effort becomes. 

In addition, the state of Nevada and other groups that oppose the Yucca 

Mountain repository have raised technical points, site-specific concerns, 

and equity issues and have taken steps to delay or terminate the 

repository. For example, Nevada’s Agency for Nuclear Projects questioned 

DOE’s reliance on engineered barriers in its performance assessment, 

indicating that too many uncertainties exist for DOE to claim human-made 

systems will perform as expected over the time frames required. In 

addition, the agency reported that Yucca Mountain’s location near seismic 

and volcanic zones creates additional uncertainty about DOE’s ability to 

predict a recurrence of seismic or volcanic events and to assess the 

performance of its waste isolation barriers should those events occur 

some time during the 1-million-year time frame. The agency also has 

questioned whether Yucca Mountain is the best site compared with other 

Page 18 GAO-10-48 Nuclear Waste Management
 

locations and has raised issues of equity, since Nevada is being asked to 

accept nuclear waste generated in other states. In addition to the Agency 

for Nuclear Projects’ issues, Nevada has taken other steps to delay or 

terminate the project. For example, Nevada has denied the water rights 

DOE needs for construction of a rail spur and facility structures at Yucca 

Mountain. DOE officials told us that constructing the rail line or the 

facilities at Yucca Mountain without those water rights will be difficult. 

Based on DOE’s Cost 

Estimates, Yucca Mountain 

Will Likely Cost from $41 

Billion to $67 Billion for 

153,000 Metric Tons of 

Nuclear Waste, but Costs 

Could Increase 

Our analysis of DOE’s cost estimates found that (1) a 70,000 metric ton 

repository is projected to cost from $27 to $39 billion in 2009 present value 

over 108 years and (2) a 153,000 metric ton repository is projected to cost 

from $41 to $67 billion and take 35 more years to complete. These 

estimated costs include the licensing, construction, operation, and closure 

of Yucca Mountain for a period commensurate with the amount of waste. 

Table 1 shows each scenario with its estimated cost range over time. 

Table 1: Estimated Cost of the Yucca Mountain Scenarios 

Dollars in billions 

Amount of nuclear waste 

disposed 

Time period 

covereda

Present value

 estimate rangea

70,000 metric tons 2009 to 2116 

(108 years) 

$27 to $39

153,000 metric tons 2009 to 2151 

(143 years) 

$41 to $67

Source: GAO analysis based on DOE data. 

a

These costs are in 2009 present value and thus different than the values presented by DOE which 

are in constant 2007 dollars. Also, these costs do not include more than $14 billion, in constant fiscal 

year 2009 dollars, that DOE spent from 1983 through 2008 for the Yucca Mountain repository. In 

addition, we did not include potential schedule delays and costs associated with licensing. DOE 

reported that each year of delay could cost DOE about $373 million in constant 2009 dollars. 

As shown in figure 4, the Yucca Mountain repository costs are expected to 

be high during construction, followed by reduced, but consistent costs 

during operations, substantially reduced costs for monitoring, then a 

period of increased costs for installation of the drip shields, and finally 

costs tapering off for closure. Once the drip shields are installed, by 

design, the waste packages will no longer be retrievable. After closure, 

Yucca Mountain is not expected to incur any significant additional costs. 

Page 19 GAO-10-48 Nuclear Waste Management
 

Page 20 GAO-10-48 Nuclear Waste Management 

Figure 4: Cost Profile for the Yucca Mountain Repository, Assuming 70,000 Metric 

Tons 

Costs for the construction of a repository, regardless of location, could 

increase based on a number of different scenarios, including delays in 

license application, funding shortfalls, and legal or technical issues that 

cause delays or changes in plans. For example, we asked DOE to assess 

the cost of a year’s delay in license application approval from the current 3 

years to 4 years, the maximum allowed by NWPA. DOE officials told us 

that each year of delay would cost DOE about $373 million in constant 

2009 dollars. Although the experts with whom we consulted did not agree 

on how long the licensing process for Yucca Mountain might take, several 

experts told us that the 9 years it took Private Fuel Storage to obtain its 

license was not unreasonable. This licensing time frame may not directly 

apply to the Yucca Mountain repository because the repository has a 

significantly different licensing process and regulatory scheme, including 

extensive pre-licensing interactions, a federal funding stream, and an 

extended compliance period and, because of the uncertainties, could take 

shorter or longer than the Private Fuel Storage experience. A nine-year 

licensing process for construction authorization would add an estimated 

$2.2 billion to the cost of the repository, mostly in costs to maintain 

current systems, such as project support, safeguards and security, and its 

licensing support network. In addition to consideration of the issuance of 

a construction authorization, NRC’s repository licensing process involves 

two additional licensing actions necessary to operate and close a 

repository, each of which allows for public input and could potentially 

adversely affect the schedule and cost of the repository. The second action 

is the consideration of an updated DOE application for a license to receive 

and possess high-level radioactive waste. The third action is the 

Cost

Construction

Operations

2009 2020 2056 2095 2106 2116

Monitoring Closure

Drip shield

installation

Source: GAO analysis of DOE data.
 

consideration of a DOE application for a license amendment to 

permanently close the repository. Costs could also increase if unforeseen 

technical issues developed. For example, some experts told us that the 

robotic emplacement of waste packages could be difficult because of the 

heat and radiation output from the nuclear waste, which could impact the 

electronics on the machinery. DOE officials acknowledged the challenges 

and told us the machines would have to be shielded for protection. They 

noted, however, that industry has experience with remote handling of 

shielded robotic machinery and DOE should be able to use that experience 

in developing its own machinery. 

The responsibility for Yucca Mountain’s costs would come from the 

Nuclear Waste Fund and taxpayers through annual appropriations. NWPA 

created the Nuclear Waste Fund as a mechanism for the nuclear power 

industry to pay for its share of the cost for building and operating a 

permanent repository to dispose of nuclear waste. NWPA also required the 

federal taxpayers to pay for the portion of permanent repository costs for 

DOE-managed spent nuclear fuel and high-level waste. DOE has 

responsibility for determining on an annual basis whether fees charged to 

industry to finance the Nuclear Waste Fund are sufficient to meet 

industry’s share of costs. As part of that process, DOE developed a 

methodology in 1989 that uses the total system life cycle cost estimate as 

input for determining the shares of industry and the federal government by 

matching projected costs against projected assets. The most recent 

published assessment, published in July 2008, showed that 80.4 percent of 

the disposal costs would come from the Nuclear Waste Fund and 19.6 

percent would come from appropriations for the DOE-managed spent 

nuclear fuel and high-level waste. 

In addition, the Department of the Treasury’s judgment fund will pay the 

government’s liabilities for not taking custody of the nuclear waste in 1998, 

as required by DOE’s contract with industry. Based on existing judgments 

and settlements, DOE has estimated these costs at $12.3 billion through 

2020 and up to $500 million per year after that, though the outcome of 

pending litigation could substantially affect the government’s ultimate 

liability. The Department of Justice has also spent about $150 million to 

defend DOE in the litigation. 

Page 21 GAO-10-48 Nuclear Waste Management
 

We Identified Two 

Nuclear Waste 

Management 

Alternatives and 

Developed Cost 

Models by Consulting 

with Experts 

We used input from experts to identify two nuclear waste management 

alternatives that could be implemented if the nation does not pursue 

disposal at Yucca Mountain—centralized storage and continued on-site 

storage, both of which could be implemented with final disposal, 

according to experts. To understand the implications and likely 

assumptions of each alternative, as well as the associated costs for the 

component parts, we systematically solicited facts, advice, and opinions 

from experts in nuclear waste management. Finally, we used the data and 

assumptions that the experts provided to develop large-scale cost models 

that estimate ranges of likely total costs for each alternative. 

We Consulted with Experts 

to Identify and Develop 

Assumptions for Two 

Generic Alternatives to 

Analysis 

To identify waste management alternatives that could be implemented if 

the waste is not disposed of at Yucca Mountain, we solicited facts, advice, 

and opinions from nuclear waste management experts. Specifically, we 

interviewed dozens of experts from DOE, NRC, the Nuclear Energy 

Institute, the National Association of Regulatory Utility Commissioners, 

the National Conference of State Legislatures, and the State of Nevada 

Agency for Nuclear Projects. We also reviewed documents they provided 

or referred us to. 

Based on this information, we chose to analyze (1) centralized interim dry 

storage and (2) on-site dry storage (both interim and long-term). 

Centralized storage has been attempted to varying degrees in the United 

States, and on-site storage has become the country’s status quo. 

Consequently, the experts believe these two alternatives are currently 

among the most likely for this country in the near-term, in conjunction 

with final disposal in the long-term. The experts also told us that current 

nuclear waste reprocessing technologies raise proliferation concerns and 

are not considered commercially feasible, but they noted that reprocessing 

has future potential as a part of the nation’s nuclear waste management 

strategy. Because nuclear waste is not reprocessed in this country, we 

found a lack of sufficient and reliable data to provide meaningful analysis 

for this alternative. Experts have largely dismissed other alternatives that 

have been identified, such as disposal of waste in deep boreholes, because 

of cost or technical constraints. 

We developed a set of key assumptions to establish the scope of our 

alternatives by initially consulting with a small group of nuclear waste 

management experts. For example, we asked the experts about how many 

storage sites should be used and whether waste would have to be 

repackaged. These discussions occurred in an iterative manner—we 

followed up with experts with specific expertise to refine our assumptions 

Page 22 GAO-10-48 Nuclear Waste Management
 

as we learned more. Based on this input, we formulated several key 

assumptions and defined the alternatives in a generic manner by taking 

into account some, but not all, of the complexities involved with nuclear 

waste management (see table 2). We made this choice because experts 

advised us that trying to consider all of the variability among reactor sites 

would result in unmanageable models since each location where nuclear 

waste is currently stored has a unique set of environmental, management, 

and regulatory considerations that affect the logistics and costs of waste 

management. For example, reactor sites use different dry cask storage 

systems with varying costs that require different operating logistics to load 

the casks. 

Table 2: Key Assumptions Used to Define Alternatives 

Centralized storage 

Type of storage Conventional dry cask storage (for commercial spent nuclear fuel). 

Number of sites Two centralized interim storage sites, located in different geographic regions of the country. 

Reactor operations All currently operating reactors receive a 20-year license extension and continue operating until 

the extensions expire. 

Reactors will be decommissioned when operations cease, and only spent nuclear fuel dry storage 

will remain on site. 

Transportation Transportation to the centralized site will be via rail using dedicated trains. 

Repackaging Waste will not be repackaged at the centralized facilities. 

Final dispositionaAfter 100 years, the waste will be disposed of in a geologic repository. 

On-site storage 

Type of storage Conventional dry cask storage (for commercial spent nuclear fuel). 

Number of sites Commercial spent nuclear fuel will be stored on independent spent fuel storage installations at 75 

reactor sites, which includes operating reactor sites, decommissioned reactor sites, and the Morris 

facility.b

DOE high-level waste and spent nuclear fuel will remain at five current sites.c

DOE spent nuclear fuel will be moved to dry storage. DOE high-level waste will be vitrified and 

stored in facilities like the Glass Waste Storage Building at the Savannah River Site. 

Reactor operations All currently operating reactors receive a 20-year license extension and continue operating until 

the extensions expire. 

Reactors will be decommissioned when operations cease, and only spent nuclear fuel dry storage 

will remain on site. 

Transportation Waste will not be transported between reactor sites. 

Repackaging Dry cask storage systems will need to be replaced after 100 years, requiring repackaging into new 

inner canisters and outer casks. Only our 500-year on-site storage model assumes repackaging. 

Final disposition or long-term 

managementc

We analyzed two final disposition scenarios: The waste will be disposed of in a geologic repository 

after 100 years or the waste will remain on site for 500 years and be repackaged every 100 years. 

Source: GAO analysis based on expert-provided data. 

a

We analyzed some scenarios associated with these alternatives that did not include final disposition 

of the waste. 

Page 23 GAO-10-48 Nuclear Waste Management
 

b

The Morris facility is an independent spent nuclear fuel storage installation located in Illinois that is 

operated by General Electric Corporation, which originally intended to operate a fuel reprocessing 

plant at the site. The Morris facility is the only spent nuclear fuel pool licensed by NRC that is not at a 

reactor site. 

c

Hanford Reservation, Washington; Idaho National Laboratory, Idaho; Fort St. Vrain, Colorado; West 

Valley, New York; and Savannah River Site, South Carolina. 

In addition, there were some instances in which we made assumptions 

that, while not entirely realistic, were necessary to keep our alternatives 

generic and distinct from one another. For example, some electric power 

companies would likely consolidate nuclear waste from different locations 

by transporting it between reactor sites, but to keep the on-site storage 

alternative generic and distinct from the centralized storage alternative, 

we assumed that there would be no consolidation of waste. These 

simplifying assumptions make our alternatives hypothetical and not 

entirely representative of their real-world implementation. 

We also consulted with experts to formulate more specific assumptions 

about processes that reflect the sequence of activities that would occur 

within each alternative (see fig. 5). In addition, we identified the 

components of these processes that have associated costs. For example, 

one of the processes associated with both alternatives is packaging the 

nuclear waste in dry storage canisters from the pools of water where they 

are stored. The component costs associated with this process include the 

dry storage canisters and operations to load the spent nuclear fuel into the 

canisters. 

Page 24 GAO-10-48 Nuclear Waste Management
 

Figure 5: Process Assumptions and Cost Components for Hypothetical Nuclear Waste Management Alternatives 

Pool storage

• Storage 

 installation 

 construction

• Operations, 

 maintenance, 

and security

• Centralized 

 facility 

 construction

• Operations, 

 maintenance, 

 and security

• Transportation 

 casks

• Loading for

 transportation

• Transportation 

 infrastructure

• Transportation

 operations

• Transportation 

 casks

• Transportation 

 infrastructure

• Operations, 

 maintenance, 

 and security

• Repository 

 construction, 

 operation, 

 monitoring,

 and closure

• Repository 

 construction, 

 operation, 

 monitoring,

 and closure

Dry storage

Centralized 

storage

Geologic 

repository 

disposal

Transportation 

to centralized 

storage

• Cask storage

 systems

• Loading 

 operations

Packaged in

dry storage 

systems

Transportation 

to geologic 

repository

• Transportation 

 casks

• Transportation 

 infrastructure

• Operations, 

 maintenance, 

 and security

Geologic 

repository 

disposal

Transportation 

to geologic 

repository

Cost 

components:

Pool storage

• Storage 

 installation 

 construction

• Operations, 

 maintenance, 

 and security

Dry storage

• Cask storage

 systems

• Loading 

 operations

Packaged in

dry storage 

systems

Cost 

components:

Centralized Storage

On-Site Storage

OR

100 years

Source: GAO analysis based on expert-provided data.

• Repackaging facility construction

• Repackaging operations

• Storage pad replacement

• Repository construction, 

 operation, 

 monitoring,

 and closure

Waste repackaged

We then began to gather data on specific processes and component costs, 

such as the kind of cask systems we would use in our model and their 

cost. We gathered initial data from a core group of experts with 

specialized knowledge in different aspects of nuclear waste management, 

such as cask systems, waste loading operations, and transportation. We 

then solicited comments on the initial data from a broader group of 

experts using a data collection instrument that asked specific questions 

about how reasonable the data were. We received almost 70 sets of 

comments and used them to refine or modify our assumptions and 

component costs and develop the input data that we would use to estimate 

Page 25 GAO-10-48 Nuclear Waste Management
 

the overall costs of the alternatives. (See app. I for additional inform

about our scope and methodology, app. II for our methodology for 

soliciting comments

ation 

 from nuclear waste management experts, and app. III 

for these experts.) 

etric 

ic 

f 

ith 

el 

repository to represent cost for a hypothetical permanent repository.22

 

To generate cost ranges for the centralized storage and on-site storage 

alternatives, we developed four large-scale cost models that analyzed the 

costs for each alternative of storing 70,000 metric tons and 153,000 m

tons of nuclear waste and created scenarios within these models to 

analyze different storage durations and final dispositions. (See table 3.) We

generated cost ranges for each alternative for storing 153,000 metric tons

of waste for 100 years followed by disposal in a geologic repository. We 

also generated cost ranges for each alternative of storing 70,000 metr

tons and 153,000 metric tons of nuclear waste for 100 years, and for 

storing 153,000 metric tons of waste on site for 500 years without including 

the cost of subsequent disposal in a geologic repository. For each of the 

models, which rely upon data and assumptions provided by nuclear waste

management experts, the cost range was based on the annual volume o

commercial spent nuclear fuel that became ready to be packaged and 

stored in each year.21 In general, each model started in 2009 by annually 

tracking costs of initial packaging and related costs for the first 100 years

and for every 100 years thereafter if the waste was to remain on site and 

be repackaged. Since our models analyzed only the costs associated with 

storing commercial nuclear waste management, we augmented them w

DOE’s cost data for (1) managing its spent nuclear fuel and high-lev

waste and (2) constructing and operating a permanent repository. 

Specifically, we used DOE’s estimated costs for the Yucca Mountain 

Nuclear Waste Management

g 

 Models 

Discounted Future Costs 

We Developed Cost Ranges 

for Each Alternative Usin

Large-scale Cost

that Addressed 

Uncertainties and 

21NWPA caps the amount of nuclear waste that can be disposed of at Yucca Mountain at 

70,000 metric tons. The estimated amount of current waste plus additional commercial 

spent nuclear fuel that would be generated if all currently operating commercial reactors 

received license extensions is 153,000 metric tons. Our analysis did not consider new 

reactors because of the uncertainty if or when new reactors would be built, how many 

would be built, and their impact on waste streams. 

22We excluded historical costs for the Yucca Mountain repository because these costs 

represent challenges unique to Yucca Mountain and may not be applicable to a future 

repository. However, the bulk of future cost for construction, operation, and closure may 

be representative of a new repository. 

Page 26 GAO-10-48 
 

Table 3: Models and Scenarios Used for Cost Ranges 

Model Scenario 

Nuclear waste 

management 

alternative 

Waste 

volume 

(metric tons)

Storage 

duration 

(years) 

Final disposition or 

long-term 

management 

On-site storage 153,000 100 None 

100 Permanent repository 

500 Waste repackaged every 

100 years 

On-site storage 70,000 100 None 

Centralized 

storage 

153,000 100 None 

100 Permanent repository 

Centralized 

storage 

70,000 100 None 

Source: GAO analysis. 

One of the inherent difficulties of analyzing the cost of any nuclear waste 

management alternative is the large number of uncertainties that need to 

be addressed. In addition to general uncertainty about the future, there is 

uncertainty because of the lack of knowledge about the waste 

management technologies required, the type of waste and waste 

management systems that individual reactors will eventually employ, and 

cost components that are key inputs to the models and could occur over 

hundreds or thousands of years. Given these numerous uncertainties, it is 

not possible to precisely determine the total costs of each alternative. 

However, much of the uncertainty that we could not easily capture within 

our models can be addressed through the use of several alternative models 

and scenarios. As shown in table 3, we developed two models for each 

alternative to address the uncertainty regarding the total volume of waste 

for disposal. We then developed different scenarios within each model to 

address different time frames and disposal paths. Furthermore, we used a 

risk analysis modeling technique that recognized and addressed 

uncertainties in our data and assumptions. Given the different possible 

scenarios and uncertainties, we generated ranges, rather than point 

estimates, for analyzing the cost of each alternative. 

One of the most important uncertainties in our analysis was uncertainty 

over component costs. To address this, we used a commercially available 

risk analysis software program that enabled us to model specific 

Page 27 GAO-10-48 Nuclear Waste Management
 

uncertainties associated with a large number of cost inputs and 

assumptions. Using a Monte Carlo simulation process,23 the program 

explores a wide range of values, instead of one single value, for each cost 

input and estimates the total cost. By repeating the calculations thousands 

of times with a different set of randomly chosen input values, the process 

produces a range of total costs for each alternative and scenario. The 

process also specifies the likelihood associated with values in the 

estimated range. 

Another inherent difficulty in estimating the cost of nuclear waste 

management alternatives is the fact that the costs are spread over 

hundreds or thousands of years. The economic concept of discounting is 

central to such long-term analysis because it allows us to convert costs 

that occur in the distant future to present value—equivalent values in 

today’s dollars. Although the concept of discounting is an accepted and 

standard methodology in economics, the concept of discounting values 

over a very distant future—known as “intergenerational discounting”—is 

still subject to considerable debate. Furthermore, no consensus exists 

among economists regarding the exact value of the discount rate that 

should be used to discount values that are spread over many hundreds or 

thousands of years. 

To develop an appropriate discounting methodology and to choose the 

discount rates for our analysis, we reviewed a number of economic studies 

published in peer-reviewed journals that addressed intergenerational 

discounting. Based on our review, we designed a discounting methodology 

for use in our models. Because our review did not find a consensus on 

discount rates, we used a range of values for discount rates that we 

developed based on the economic studies we reviewed, rather than using 

one single rate. Consequently, because we used ranges for the discount 

rate along with the Monte Carlo simulation process, the present value of 

estimated costs does not depend on one single discount rate, but rather 

reflect a range of discount rate values taken from peer-reviewed studies. 

(See app. IV for details of our modeling and discounting methodologies, 

assumptions, and results.) 

 

23We used a commercially available risk analysis program called Crystal Ball for our Monte 

Carlo simulation. Crystal Ball is a commonly used spreadsheet-based software for 

predictive modeling and forecasting. 

Page 28 GAO-10-48 Nuclear Waste Management
 

Centralized Storage 

Would Provide a NearTerm Alternative, 

Allowing Other 

Options to Be 

Studied, but Faces 

Implementation 

Challenges 

Centralized storage would provide a near-term alternative for managing 

nuclear waste, allowing the government to begin taking possession of the 

waste within approximately the next 30 years, and giving additional time 

for the nation to consider long-term waste management options. However, 

centralized storage does not preclude the need for final disposal of the 

waste. In addition, centralized storage faces several implementation 

challenges including that DOE (1) lacks statutory authority to provide 

centralized storage under NWPA, (2) is expected to have difficulty finding 

a location willing to host a centralized storage facility, and (3) faces 

potential transportation risks. The estimated cost of implementing 

centralized storage for 100 years ranges from $15 billion to $29 billion for 

153,000 metric tons of nuclear waste, and the total cost ranges from $23 

billion to $81 billion if the nuclear waste is centrally stored and then 

disposed in a geologic repository. 

Centralized Storage Would 

Provide a Near-Term 

Alternative to Managing 

Nuclear Waste but Does 

Not Eliminate the Need for 

Final Disposal 

As the administration re-examines the Yucca Mountain repository and 

national nuclear waste policy, centralized dry cask storage could provide a 

near-term alternative for managing the waste that has accumulated and 

will continue to accumulate. This would provide additional time—NRC 

has stated that spent nuclear fuel storage is safe and environmentally 

acceptable for a period on the order of 100 years—to consider other longterm options that may involve alternative policies and new technologies 

and allow some flexibility for their implementation. For example, 

centralized storage would maintain nuclear waste in interim dry storage 

configurations so that it could be easily accessible for reprocessing in case 

the nation decided to pursue reprocessing as a waste management option 

and developed technologies that address current proliferation and cost 

concerns. In fact, reprocessing facilities could be built near or adjacent to 

centralized facilities to maximize efficiencies. However, even with 

reprocessing, some of the spent nuclear fuel and high-level waste in 

current inventories would require final disposal. 

Centralized storage would consolidate the nation’s nuclear waste after 

reactors are decommissioned, thereby decreasing the complexity of 

securing and overseeing the waste and increasing the efficiency of waste 

storage operations. This alternative would remove nuclear waste from all 

DOE sites and nine shutdown reactor sites that have no operations other 

than nuclear waste storage, allowing these sites to be closed. Some of 

these storage sites occupy land that potentially could be used for other 

purposes, imposing an opportunity cost on states and communities that no 

longer receive the benefits of electricity generation from the reactors. To 

compensate for this loss, industry officials noted that at least two states 

Page 29 GAO-10-48 Nuclear Waste Management
 

where decommissioned sites are located have tried to raise property taxes 

on the sites, and at one site, the state collects a per cask fee for storage. In 

addition, the continued storage of nuclear waste at decommissioned sites 

can cost the power companies between about $4 million and $8 million per 

year, according to several experts. 

Centralized storage could allow reactor operators to thin-out spent nuclear 

fuel assemblies from densely packed spent fuel pools and may also 

prevent operating reactors from having to build the additional dry storage 

capacity they would need if the nuclear waste remained on site. According 

to an industry official, 28 reactor sites could have to add dry storage 

facilities over the next 10 years in order to maintain a desired capacity in 

their storage pools. These dry storage facilities could cost about $30 

million each, but this cost would vary widely by site. In addition, some 

current reactor sites use older waste storage systems and are near large 

cities or large bodies of fresh water used for drinking or irrigation. 

Although NRC’s licensing and inspection process is designed to ensure 

that these existing facilities appropriately protect public health and safety, 

new centralized facilities could use state-of-the-art design technology and 

be located in remote areas with fewer environmental hazards, in order to 

protect public health and enhance safety. 

Finally, if DOE uses centralized facilities to store commercial spent 

nuclear fuel, this alternative could allow DOE to fulfill its obligation to 

take custody of the commercial spent nuclear fuel until a long-term 

strategy is implemented. As a result, DOE could curtail its liabilities to the 

electric power companies, potentially saving the government up to $500 

million per year after 2020, as estimated by DOE. The actual impact of 

centralized storage on the amount of the liabilities would depend on 

several factors, including when centralized storage is available, whether 

reactor sites had already built on-site dry storage facilities for which the 

government may be liable for a portion of the costs, how soon waste could 

be transported to a centralized site, and the outcome of pending litigation 

that may affect the government’s total liability. DOE estimates that if 

various complex statutory, regulatory, siting, construction, and financial 

issues were expeditiously resolved, a centralized facility to accept nuclear 

waste could begin operations as early as 6 years after its development 

began. However, a centralized storage expert estimated that the process 

from site selection until a centralized facility opens could take between 17 

and 33 years. 

Although centralized storage has a number of positive attributes, it 

provides only an interim alternative and does not eliminate the need for 

Page 30 GAO-10-48 Nuclear Waste Management
 

final disposal of the nuclear waste. To keep the waste safe and secure, a 

centralized storage facility relies on active institutional controls, such as 

monitoring, maintenance, and security. Over time, the storage systems 

may degrade and institutional controls may be disrupted, which could 

result in increased risk of radioactive exposure to humans or the 

environment. For example, according to several experts on dry cask 

systems, the vents on the casks—which allow for passive cooling—must 

be periodically inspected to ensure no debris clogs them, particularly 

during the first several decades when the spent nuclear fuel is thermally 

hot. If the vents become clogged, the temperature in the canister could 

rise, which could impact the life of the dry cask storage system. Over a 

longer time frame, concrete on the exterior casks could degrade, requiring 

more active maintenance. Although some experts stated that the risk of 

radiation being released into the environment may be low, such risks can 

be avoided by permanently isolating the waste in a manner that does not 

require indefinite, active institutional controls, such as disposal in a 

geologic repository. 

Legal and Community 

Challenges Contribute to 

the Complexity of 

Implementing Centralized 

Storage 

A key challenge confronting the centralized storage alternative is the lack 

of authority under NWPA for DOE to provide such storage. Provisions in 

NWPA that allow DOE to arrange for centralized storage have either 

expired or are unusable because they are tied to milestones in repository 

development that have not been met. For example, NWPA authorized DOE 

to provide temporary storage for a limited amount of spent nuclear fuel 

until a repository was available, but this authority expired in 1990. Some 

industry representatives have stated that DOE still has the authority to 

accept and store spent nuclear fuel under the Atomic Energy Act of 1954, 

as amended, but DOE asserts that NWPA limits its authority under the 

Atomic Energy Act.24 In addition, NWPA provided authority for DOE to 

site, construct, and operate a centralized storage facility, but such a facility 

could not be constructed until NRC authorized construction of the Yucca 

Mountain repository, and the facility could only store up to 10,000 metric 

 

24DOE acknowledged that the Atomic Energy Act of 1954, as amended, does provide the 

authority for DOE to accept and store spent nuclear fuel under certain circumstances, 

which DOE has used in the past to accept and store spent nuclear fuel. For example, 

pursuant to the Atomic Energy Act authority, DOE has accepted and stored U.S.-supplied 

spent nuclear fuel from foreign reactors, as well as damaged spent nuclear fuel from the 

Three Mile Island reactor site. However, DOE asserts that the NWPA’s detailed statutory 

scheme limits its authority to accept spent nuclear fuel under Atomic Energy Act authority 

except in compelling circumstances, such as an emergency involving spent nuclear fuel 

threatening public health. 

Page 31 GAO-10-48 Nuclear Waste Management
 

tons of nuclear waste until the repository started accepting spent nuclear 

fuel. Therefore, unless provisions in NWPA were amended, centralized 

storage would have to be funded, owned, and operated privately. A 

privately operated centralized storage facility alternative, such as the 

proposed Private Fuel Storage Facility in Utah, would not likely resolve 

DOE’s liabilities with the nuclear power companies.25

A second, equally important, challenge to centralized storage is the 

likelihood of opposition during site selection for a facility. Experts noted 

that affected states and communities would raise concerns about safety, 

security, and the likelihood that an interim centralized storage facility 

could become a de facto permanent storage site if progress is not being 

made on a permanent repository. Even if a local community supports a 

centralized storage facility, the state may not. For example, the Private 

Fuel Storage facility was generally supported by the Skull Valley Band of 

the Goshute Indians, on whose reservation the facility was to be located, 

but the state of Utah and some tribal members opposed its licensing and 

construction. Other states have indicated their opposition to involuntarily 

hosting a centralized facility through means such as the Western 

Governors’ Association, which issued a resolution stating that “no such 

facility, whether publicly or privately owned, shall be located within the 

geographic boundaries of a Western state without the written consent of 

the governor.”26 Some experts noted that a state or community may be 

willing to serve as a host if substantial economic incentives were offered 

and if the party building the site undertook a time-consuming and 

expensive process of site characterization and safety assessment. 

However, DOE officials stated that in their previous experience—such as 

with the Nuclear Waste Negotiator about 15 to 20 years ago—they have 

found no incentive package that has successfully encouraged a state to 

voluntarily host a site. 

A third challenge to centralized storage is that nuclear waste would likely 

have to be transported twice—once to the centralized site and once to a 

permanent repository—if a centralized site were not colocated with a 

 

25In addition, lawsuits filed against the government by nuclear reactor owners have 

included claims to recover the cost of the Private Fuel Storage facility. At least one utility 

has recovered these costs from the government, while a court did not allow another utility 

to recover these costs. 

26Western Governors’ Association Policy Resolution 09-5: Interim Storage and 

Transportation of Commercial Spent Nuclear Fuel. 

Page 32 GAO-10-48 Nuclear Waste Management
 

repository.27 Therefore, the total distance over which nuclear waste is 

transported is likely to be greater than with other alternatives, an 

important factor because, according to one expert, transportation risk is 

directly tied to this distance. However, according to DOE, nuclear waste 

has been safely transported in the United States since the 1960s and 

National Academy of Sciences, NRC, and DOE-sponsored reports have 

found that the associated risks are well understood and generally low. Yet, 

there are also perceived risks associated with nuclear waste 

transportation that can result in lower property values along 

transportation routes, reductions in tourism, and increased anxiety that 

create community opposition to nuclear waste transportation. According 

to experts, transportation risks could be mitigated through such means as 

shipping the least radioactive fuel first, using trains that only transport 

nuclear waste, and identifying routes that minimize possible impacts on 

highly populated areas. In addition, the hazards associated with 

transportation from a centralized facility to a repository would decline as 

the waste decayed and became less radioactive at the centralized facility. 

Cost Ranges for 

Centralized Storage Will 

Vary Depending on Waste 

Volume and Final 

Disposition 

As shown in table 4, our models generated cost ranges from $23 billion to 

$81 billion for the centralized storage of 153,000 metric tons of spent 

nuclear fuel and high-level waste for 100 years followed by geologic 

disposal. For centralized storage without disposal, costs would range from 

$12 billion to $20 billion for 70,000 metric tons of waste and from $15 

billion to $29 billion for 153,000 metric tons of waste. These centralized 

model scenarios include the cost of on-site operations required to package 

and prepare the waste for transportation, such as storing the waste in drycask storage until it is transported off site, developing and operating a 

system to transport the waste to centralized storage, and constructing and 

operating two centralized storage facilities. (See app. IV for information 

about our modeling methodology, assumptions, and results.) 

 

27NWPA prohibits development of a centralized storage facility in any state where a site is 

being characterized for development of a repository. 

Page 33 GAO-10-48 Nuclear Waste Management
 

Table 4: Estimated Cost Range for Each Centralized Storage Scenario 

Dollars in billions 

Centralized storage scenario 

Time period 

covereda

2009 present value

 estimate range 

Storage of 70,000 metric tons 2009 to 2108 

(100 years) 

$12 to $20

Storage of 153,000 metric tons 2009 to 2108 

(100 years) 

$15 to $29

Storage of 153,000 metric tons, 

with disposal in a permanent 

repository after 100 years 

2009 to 2240 

(232 yearsb

) 

$23 to $81

Source: GAO analysis of data provided by nuclear waste management experts and DOE. 

a

See appendix IV for an explanation of the periods covered by the scenarios. 

b

This period was chosen to capture costs of the hypothetical geologic repository through closure. 

Actual centralized storage costs may be more or less than these cost 

ranges if a different centralized storage scenario is implemented. For 

example, our models assume that there would be two centralized facilities, 

but licensing, construction, and operations and maintenance costs would 

be greater if there were more than two facilities and lower if there was 

only one facility. Some experts told us that centralized storage would 

likely be implemented with only one facility because it would be too 

difficult to site two. But other experts noted that having more sites could 

reduce the number of miles traveled by the waste and provide a greater 

degree of geographic equity. The length of time the nuclear waste is stored 

could also impact the cost ranges, particularly if the nuclear waste were 

stored for less than or more than the time period assumed in our model. 

For periods longer than 100 years, experts told us that the dry storage cask 

systems may be subject to degradation and require repackaging, 

substantially raising the costs, as well as the level of uncertainty in those 

costs. Transportation is another area where costs could vary if, for 

example, transportation was not by rail or if the transportation system 

differed significantly from what is assumed in our models. 

Furthermore, costs could be outside our ranges if the final disposition of 

the waste is different. Our scenario that includes geologic disposal is 

based on the current cost projections for Yucca Mountain, but these costs 

could be significantly different for another repository site or if much of the 

nuclear waste is reprocessed. A different geologic repository would have 

unique site characterization costs, may use an entirely different design 

than Yucca Mountain, and may be more or less difficult to build. Also, 

reprocessing could contribute significantly to the cost of an alternative. 

Page 34 GAO-10-48 Nuclear Waste Management
 

For example, we previously reported that construction of a reprocessing 

plant with an annual production throughput of 3,000 metric tons of spent 

nuclear fuel could cost about $44 billion.28 Studies analyzed by the 

Congressional Budget Office estimate that once a reprocessing plant is 

constructed, spent nuclear fuel could be reprocessed at between $610,000 

and $1.4 million per-metric-ton, when adjusted to 2009 constant dollars.29

This would result in an annual cost of about $2 billion to $4 billion, 

assuming a throughput of 3,000 metric tons per year. 

Finally, the actual cost of implementing one of our centralized storage 

scenarios would likely be higher than our estimated ranges indicate 

because our models omit several location-specific costs. These costs could 

not be quantified in our generic models because we did not make an 

assumption about the specific location of the centralized facilities. For 

example, a few experts noted that incentives may be given a state or 

locality as a basis for allowing a centralized facility to be built, but the 

incentive amount may vary from location to location based on what 

agreement is reached. Also, several experts said that rail construction may 

be required for some locations, which could add significant cost 

depending on the distance of new rail line required at a specific location. 

Experts could not provide data for these location-dependent costs to any 

degree of certainty, so we did not use them in our models. Also, the 

funding source for government-run centralized storage is unclear. The 

Nuclear Waste Fund, which electric power companies pay into, was 

established by NWPA to fund a permanent repository and cannot be used 

to pay for centralized storage without amending the act. Without such a 

change, the cost for the federal government to implement this alternative 

would likely have to be borne by the taxpayers. 

 

28GAO, Global Nuclear Energy Partnership: DOE Should Reassess Its Approach to 

Designing and Building Spent Nuclear Fuel Recycling Facilities, GAO-08-483 (Washington, 

D.C.: April 2008). 

29The studies used in the Congressional Budget Office’s analysis were: Boston Consulting 

Group, Economic Assessment of Used Nuclear Fuel Management in the United States 

(study prepared for AREVA Inc., July 2006); and Matthew Bunn and others, The Economics 

of Reprocessing vs. Direct Disposal of Spent Nuclear Fuel, Belfer Center for Science and 

International Affairs, John F. Kennedy School of Government, Harvard University, 

(Cambridge, Massachusetts, December 2003). 

Page 35 GAO-10-48 Nuclear Waste Management
 

On-Site Storage 

Would Provide an 

Intermediate Option 

with Minimal Effort 

but Poses Challenges 

that Could Increase 

Over Time 

On-site storage of nuclear waste provides an intermediate option to 

manage the waste until the government can take possession of it, requiring 

minimal effort to change from what the nation is currently doing to 

manage its waste. In the meantime, other longer term policies and 

strategies could be considered. Such strategies would eventually be 

required because the on-site storage alternative would not eliminate the 

need for final disposal of the waste. Some experts believe that legal, 

community, and technical challenges associated with on-site storage will 

intensify as the waste remains on site without plans for final disposition 

because, for example, communities are more likely to oppose 

recertification of on-site storage. The estimated cost to continue storing 

153,000 metric tons of nuclear waste on site for 100 years range from $13 

billion to $34 billion, and total costs would range from $20 billion to $97 

billion if the nuclear waste is stored on site for 100 years and then 

disposed in a geologic repository. 

On-Site Storage Would 

Require Minimal NearTerm Logistics and Provide 

Time to Decide on LongTerm Waste Management 

Strategies 

Because of delays in the Yucca Mountain repository, on-site storage has 

continued as the nation’s strategy for managing nuclear waste, thus its 

continuation would require minimal near-term effort and allow time for 

the nation to consider alternative long-term nuclear waste management 

options. This alternative maintains the waste in a configuration where it is 

readily retrievable for reprocessing or other disposition, according to an 

expert. However, like centralized storage, on-site storage is an interim 

strategy that relies on active institutional controls, such as monitoring, 

maintenance, and security. To permanently isolate the waste from humans 

and the environment without the need for active institutional controls 

some form of final disposal would be required, even if some of the waste 

were reprocessed. 

The additional time in on-site storage may also make the waste safer to 

handle because older spent nuclear fuel and high-level waste has had a 

chance to cool and become less radioactive. As a result, on-site storage 

could reduce transportation risks, particularly in the near-term, since the 

nuclear waste would be cooler and less radioactive when it is finally 

transported to a repository. In addition, some experts state that older, 

cooler waste may provide more predictability in repository performance 

and be some degree safer than younger, hotter waste. However, NRC 

cautioned that the ability to handle the waste more safely in the future also 

depends on other factors, including how the waste or waste packages 

might degrade over time. In particular, NRC stated that there are many 

uncertainties with the behavior of spent nuclear fuel as it ages, such as 

potential fracturing of the structural assemblies, possibly increasing the 

Page 36 GAO-10-48 Nuclear Waste Management
 

risks of release. If the waste has to be repackaged, for example, the 

process may require additional safety measures. Some experts noted that 

continuing to store nuclear waste on site would be more equitable than 

consolidating it in one or a few areas. As a result, the waste, along with its 

associated risks, would be kept in the location where the electrical power 

was generated, leaving the responsibility and risks of the waste in the 

communities that benefited from its generation. 

On-Site Storage Poses 

Legal, Community, and 

Technical Challenges that 

Are Likely to Intensify over 

Time 

With on-site storage of DOE-managed spent nuclear fuel and high-level 

waste, DOE would have difficulty meeting enforceable agreements with 

states, which could result in significant costs being incurred the longer 

spent nuclear fuel remains on site. In addition to Idaho’s agreement to 

impose a penalty of $60,000 per day if spent nuclear fuel is not removed 

from the state by 2035, DOE has an agreement with Colorado stating that if 

the spent fuel at Fort St. Vrain is not removed by January 1, 2035, the 

government will, subject to certain conditions, pay the state $15,000 per 

day until it is removed. Other states where DOE spent nuclear fuel and 

high-level waste are currently stored may seek similar penalties if the 

spent fuel and waste remain on-site with no progress toward a permanent 

repository or centralized storage facility. 

A second challenge is the cost due to the government’s possible legal 

liabilities to commercial reactor operators. Leaving waste on site under 

the responsibility of the electric power companies does not relieve the 

government of its obligation to take custody of the waste, thus the liability 

debt could continue to mount. For every year after 2020 that DOE fails to 

take custody of the waste in accordance with its contracts with the reactor 

operators, DOE estimates that the government will continue to accumulate 

up to $500 million per year beyond the estimated $12 billion in liabilities 

that will have accrued up to that point; however, the outcome of pending 

litigation could substantially affect the government’s total liability.30 The 

government will no longer incur these costs if DOE takes custody of the 

waste. Some representatives from industry have stated that it is not 

practical for DOE to take custody of the waste at commercial reactor sites. 

Moreover, some electric power company executives have stated that their 

ratepayers are paying for DOE to provide a geologic repository through 

 

30Legislative action by the Congress could also affect the amount of compensation the 

government ultimately pays to the reactor operators. For example, the Congress could 

amend NWPA to change contract provisions that would be applicable to newly constructed 

reactors. 

Page 37 GAO-10-48 Nuclear Waste Management
 

their contributions to the Nuclear Waste Fund, and the executives believe 

that simply taking custody of the waste is not sufficient. A DOE official 

stated that if DOE were to take custody of the waste on site, it would be a 

complex undertaking due to considerations such as liability for accidents. 

Third, continued use of on-site storage would likely also face community 

opposition. Some experts noted that without progress on a centralized 

storage facility or repository site to which waste will be moved, some state 

and local opposition to reactor storage site recertification will increase, 

and so will challenges to nuclear power companies’ applications for 

reactor license extensions and combined licenses to construct and operate 

new reactors. Also, experts noted that many commercial reactor sites are 

not suitable for long-term storage, and none has had an environmental 

review to assess the impacts of storing nuclear waste at the site beyond 

the period for which it is currently licensed. One expert noted that if onsite storage were to become a waste management policy, the long-term 

health, safety, and environmental risks at each site would have to be 

evaluated. Because waste storage would extend beyond the life of nuclear 

power reactors, decommissioned reactor sites would not be available for 

other purposes, and the former reactor operators may have to stay in 

business for the sole purpose of storing nuclear waste. 

Finally, although dry cask storage is considered reliable in the short term, 

the longer-term costs, maintenance requirements, and security 

requirements are not well understood. Many experts said waste packages 

will likely retain their integrity for at least 100 years, but eventually dry 

storage systems may begin to degrade and the waste in those systems 

would have to be repackaged. However, commercial dry storage systems 

have only been in existence since 1986, so nuclear utilities have little 

experience with long-term system degradation and requirements for 

repackaging. Some experts suggested that only the outer protective cask 

would require replacement, but the inner canister would not have to be 

replaced. Yet, other experts said that, over time, the inner canister would 

also be exposed to environmental conditions by vents in the outer cask, 

which could cause corrosion and require a total system replacement. In 

addition, experts disagreed on the relative safety risks and costs 

associated with using spent fuel pools to transfer the waste during 

repackaging compared to using a dry transfer system, which industry 

representatives said had not been used on a commercial scale. Finally, 

future security requirements for extended storage are uncertain because 

as spent nuclear waste ages and becomes cooler and less radioactive, it 

becomes less lethal to anyone attempting to handle it without protective 

shielding. For example, a spent nuclear fuel assembly can lose nearly 80 

Page 38 GAO-10-48 Nuclear Waste Management
 

percent of its heat 5 years after it has been removed from a reactor, 

thereby reducing one of the inherent deterrents to thieves and terrorists 

attempting to steal or sabotage the spent nuclear fuel and potentially 

creating a need for costly new security measures. 

Cost Ranges for On-Site 

Storage Will Vary 

Depending on Waste 

Volume, Final Disposition, 

and Duration of Storage 

As shown in table 5, our models generated cost ranges from $20 billion to 

$97 billion for the on-site storage of 153,000 metric tons of spent nuclear 

fuel and high-level waste for 100 years followed by geologic disposal. For 

only on-site storage for 100 years without disposal, costs would range from 

$10 billion to $26 billion for 70,000 metric tons of waste and from $13 

billion to $34 billion for 153,000 metric tons of waste. On-site storage costs 

would increase significantly if the waste were stored for longer periods—

storing 153,000 metric tons on site for 500 years would cost from $34 

billion to $225 billion—because it would have to be repackaged every 100 

years for safety. The on-site storage model scenarios include the costs of 

on-site operations required to package the waste into dry canister storage, 

build additional dry storage at the reactor sites, prepare the waste for 

transportation, and operate and maintain the on-site storage facilities. 

Most of the costs for the first 100 years would result from the initial 

loading of materials into dry storage systems. (See app. IV for information 

on our modeling methodology, assumptions, and results.) 

Table 5: Estimated Cost Range for Each On-site Storage Scenario 

Dollars in billions 

On-site storage scenario 

Period 

 covereda

2009 present value

 estimate range 

Storage of 70,000 metric tons 2009 to 2108 

(100 years) 

$10 to $26

Storage of 153,000 metric tons 2009 to 2108 

(100 years) 

$13 to $34

Storage of 153,000 metric tons, with 

disposal in a permanent repository 

after 100 years 

2009 to 2240 

(232 yearsb

) 

$20 to $97

Storage of 153,000 metric tons with 

repackaging every 100 years 

2009 to 2508 

(500 years ) 

$34 to $225

Source: GAO analysis of data provided by nuclear waste management experts and DOE. 

a

See appendix IV for an explanation of the periods covered by the scenarios. 

b

This period was chosen to capture costs of the hypothetical geologic repository through closure. 

Actual on-site storage costs may be more or less than these cost ranges if a 

different on-site storage scenario is implemented. For example, to keep it 

distinct from the centralized storage models, our on-site storage models 

Page 39 GAO-10-48 Nuclear Waste Management
 

assume that there would be no transportation or consolidation of waste 

between the reactor sites. However, several experts noted that in an actual 

on-site storage scenario, reactor operators would likely consolidate their 

waste to make operations more efficient and reduce costs. Also, as with 

the centralized storage alternative, costs for the on-site storage scenario 

that includes geologic disposal could differ for a repository site other than 

Yucca Mountain or for additional waste management technologies. 

Finally, our models did not include certain costs that were either locationspecific or could not be predicted sufficiently to be quantified for our 

purposes, which would make the actual costs of on-site storage higher 

than our cost ranges. For example, the taxes and fees associated with onsite storage could vary significantly by state and over time. Also, 

repackaging operations in our 500-year on-site storage scenario would 

generate low-level waste that would require disposal. However, the 

amount of waste generated and the associated disposal costs could vary 

depending on the techniques used for repackaging. Finally, the total 

amount of the government’s liability for failure to begin taking spent 

nuclear fuel for disposal in 1998 will depend on the outcome of pending 

and future litigation. 

Like the centralized storage alternative, the funding source for the on-site 

storage alternative is uncertain. Currently, the reactor operators have been 

paying for the cost to store the waste, but have filed lawsuits to be 

compensated for storage costs of waste that the federal government was 

required to take title to under standard contracts. Payments resulting from 

these lawsuits have come from the Department of the Treasury’s judgment 

fund, which is funded by the taxpayer, because a court determined that 

the Nuclear Waste Fund could not be used to compensate electric power 

companies for their storage costs. Without legislative or contractual 

changes—such as allowing the Nuclear Waste Fund to be used for on-site 

storage—taxpayers would likely bear the ultimate costs for on-site 

storage. 

Developing a long-term national strategy for safely and securely managing 

the nation’s high-level nuclear waste is a complex undertaking that must 

balance health, social, environmental, security, and financial factors. In 

addition, virtually any strategy considered will face many political, legal, 

and regulatory challenges in its implementation. Any strategy selected will 

need to have geologic disposal as a final disposition pathway. In the case 

of the Yucca Mountain repository, these challenges have left the nation 

with nearly three decades of experience. In moving forward, whether the 

Concluding 

Observations 

Page 40 GAO-10-48 Nuclear Waste Management
 

nation commits to the same or a different waste management strategy, 

federal agencies, industry, and policy makers at all levels of government 

can benefit from the lessons of Yucca Mountain. In particular, 

stakeholders can better understand the need for a sustainable national 

focus and community commitment. Federal agencies, industry, and 

policymakers may also want to consider a strategy of complementary and 

parallel interim and long-term disposal options—similar to those being 

pursued by some other nations—which might provide the federal 

government with maximum flexibility, since it would allow time to work 

with local communities and to pursue research and development efforts in 

key areas, such as reprocessing. 

We provided DOE and NRC with a draft of this report for their review and 

comment. In their written comments, DOE and NRC generally agreed with 

the report. (See apps. V and VI.) In addition, both DOE and NRC provided 

comments to improve the draft report’s technical accuracy, which we have 

incorporated as appropriate. 

Agency Comments 

We also discussed the draft report with representatives of the Nuclear 

Waste Technical Review Board, the Nuclear Energy Institute, and the State 

of Nevada Agency for Nuclear Projects. These representatives provided 

comments to clarify information in the draft report, 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 of this report to other 

appropriate congressional committees, the Secretary of Energy, the 

Chairman of NRC, the Director of the Office of Management and Budget, 

and other interested parties. The report also will be available at no charge 

on the GAO Web site at http://www.gao.gov. 

Page 41 GAO-10-48 Nuclear Waste Management
 

If you or your staffs have any questions about this report, please contact 

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

of Congressional Relations and Public Affairs can be found on the last 

page of this report. GAO staff who made major contributions to this report 

Mark E. Gaffigan 

are listed in appendix VII. 

Director, Natural Resources 

 and Environment 

Page 42 GAO-10-48 Nuclear Waste Management
Appendix I: Scope and Methodology 

Page 43 GAO-10-48 

Appendix I: Scope and Methodology 

For this report we examined (1) the key attributes, challenges, and costs 

of the Yucca Mountain repository; (2) alternative nuclear waste 

management approaches; (3) the key attributes, challenges, and costs of 

storing the nuclear waste at two centralized sites; and (4) the key 

attributes, challenges, and costs of continuing to store the nuclear waste at 

its current locations. 

Developing Information on 

Key Attributes, Challenges, 

and Costs of Yucca 

Mountain 

To provide information on the key attributes and challenges of the Yucca 

Mountain repository, we reviewed documents and interviewed officials 

from the Department of Energy’s (DOE) Office of Civilian Radioactive 

Waste Management and Office of Environmental Management; the Nuclear 

Regulatory Commission’s (NRC) Division of Spent Fuel Storage and 

Transportation and Division of High Level Waste Repository Safety, both 

within the Office of Nuclear Material Safety and Safeguards; and the 

Department of Justice’s Civil Division. We also reviewed documents and 

interviewed representatives from the National Academy of Sciences, the 

Nuclear Waste Technical Review Board, and other concerned groups. 

Once we developed our preliminary analysis of Yucca Mountain’s key 

attributes and challenges, we solicited input from nuclear waste 

management experts. (See app. II for our methodology for soliciting 

comments from nuclear waste management experts and app. III for a list 

of these experts.) 

To analyze the costs for the Yucca Mountain repository through to closure, 

we started with the cost information in DOE’s Yucca Mountain Total 

System Lifecycle Cost report, which used 122,100 metric tons of nuclear 

waste in its analysis.1

 We asked DOE officials to provide a breakdown of 

the component costs on a per-metric-ton basis that DOE used in the Total 

System Lifecycle Cost report. We used this information to calculate the 

costs of a repository at Yucca Mountain for 70,000 metric tons and 153,000 

metric tons, changing certain component costs based on the ratio between 

70,000 and 122,100 or 153,000 and 122,100. For example, we modified the 

cost of constructing the tunnels for emplacing the waste for the 70,000-

metric-ton scenario by 0.57, the ratio of 70,000 metric tons to 122,100 

metric tons. We applied this approach to component costs that would be 

 

1

DOE, Analysis of the Total System Lifecycle Cost of the Civilian Radioactive Waste 

Management Program, Fiscal Year 2007, DOE/RW-0591 (Washington, D.C., July 2008). The 

122,100 metric tons of nuclear waste included the spent nuclear fuel expected to be 

generated from all commercial nuclear reactors that had received NRC license extensions 

through January 2007. 

 Nuclear Waste Management 
Appendix I: Scope and Methodology 

impacted by the ratio difference, particularly for transporting and 

emplacing the waste and installing drip shields. We also incorporated 

DOE’s cost estimates for potential delays to licensing the Yucca Mountain 

repository into our analysis and made modifications to the analysis based 

on comments by cognizant DOE officials. Finally, we discounted DOE’s 

costs, which were in 2008 constant dollars, to 2009 present value using the 

methodology described in appendix IV. 

Examining and Identifying 

Nuclear Waste 

Management Alternatives 

To examine and identify alternatives, we started with a series of interviews 

among federal and state officials and industry representatives. We also 

gathered and reviewed numerous studies and reports on managing nuclear 

waste— along with interviewing the authors of many of these studies—

from federal agencies, the National Academy of Sciences, the Nuclear 

Waste Technical Review Board, the Massachusetts Institute of 

Technology, the American Physical Society, Harvard University, the 

Boston Consulting Group, and the Electric Power Research Institute. To 

better understand how commercial spent nuclear fuel is stored, we visited 

the Dresden Nuclear Power Plant in Illinois and the Hope Creek Nuclear 

Power Plant in New Jersey, which both store spent nuclear fuel in pools 

and in dry cask storage. We also visited DOE’s Savannah River Site in 

South Carolina and Fort St. Vrain site in Colorado to observe how DOEmanaged spent nuclear fuel and high-level waste are processed and stored. 

As we began to identify potential alternatives to analyze, we shared our 

initial approach and methodology with nuclear waste management 

experts—including members of the National Academy of Sciences and the 

Nuclear Waste Technical Review Board to obtain their feedback—and 

revised our approach accordingly. Many of these experts advised us to 

develop generic, hypothetical alternatives with clearly defined 

assumptions about technology and environmental conditions. Industry 

representatives and other experts advised us that trying to account for the 

thousands of variables relating to geography, the environment, regional 

regulatory differences, or differences in business models would result in 

infeasible and unmanageable models. They also advised us against trying 

to predict changes in the future for technologies or environmental 

conditions because they would purely conjectural and fall beyond the 

scope of this analysis. 

Based on this information, we identified two generic, hypothetical 

alternatives to use as the basis of our analysis: centralized storage and onsite storage. Within each of these alternatives, we identified different 

scenarios that examined the costs associated with the management of 

Page 44 GAO-10-48 Nuclear Waste Management
Appendix I: Scope and Methodology 

70,000 metric tons and 153,000 metric tons of nuclear waste and whether 

or not the waste is shipped to a repository for disposal after 100 years. 

Once we identified the alternatives, we again consulted with experts to 

establish assumptions regarding commercial spent nuclear fuel 

management and its associated components to define the scope and 

specific processes that would be included in each alternative. To identify a 

more complete, qualified list of nuclear waste management experts with 

relevant experience who could provide and critique this information, we 

used a technique known as snowballing. We started with experts in the 

field who were known to us, primarily from DOE, NRC, National Council 

of State Legislators, the State of Nevada Agency for Nuclear Projects, the 

Nuclear Energy Institute, and the National Association of Regulatory 

Utility Commissioners and asked them to refer us to other experts, 

focusing on U.S.-based experts. We then contacted these individuals and 

asked for additional referrals. We continued this iterative process until 

additional interviews did not lead us to any new names or we determined 

that the qualified experts in a given technical area had been exhausted. 

We conducted an initial interview with each of these experts by asking 

them questions about the nature and extent of their expertise and their 

views on the Yucca Mountain repository. Specifically, we asked each 

expert: 

• What is the nature of your expertise? How many years have you been 

doing work in this area? Does your expertise allow you to comment on 

planning assumptions and costs of waste management related to storage, 

disposal, or transport? 

• If you were to classify yourself in relation to the Yucca Mountain 

repository, would you classify yourself as a proponent, an opponent, an 

independent, an undecided or uncommitted, or some combination of 

these? 

We then narrowed our list down to those individuals who identified 

themselves or whom others identified as having current, nationally 

recognized expertise in areas of nuclear waste management that were 

relevant to our analysis. For balance, we ensured that we included experts 

who reflected (1) key technical areas of waste management; (2) a range of 

industry, government, academia, and concerned groups; and (3) a variety 

of viewpoints on the Yucca Mountain repository. (See app. III for 147 

experts we contacted.) 

Page 45 GAO-10-48 Nuclear Waste Management
Appendix I: Scope and Methodology 

Once we developed our list of experts, we classified them into three 

groups: 

• Those whose expertise would allow them to provide us with specific 

information and advice on the processes that should be included in each 

alternative and the best estimates of expected cost ranges for the 

components of each alternative, such as a typical or reasonable price for a 

dry cask storage. 

• Those who could weigh in on these estimates, as well as give us insight 

and comments on assumptions that we planned to use to define our 

alternatives. 

• Those whose expertise was not in areas of component costs, but who 

could nonetheless give us valuable information on other assumptions, 

such as transportation logistics. 

To define our alternatives and develop the assumptions and cost 

components we needed for our analysis, we started with the experts from 

the first group who had the most direct and reliable knowledge of the 

processes and costs associated with the alternatives we identified. This 

group consisted of seven experts and included federal government 

officials and representatives from industry. We worked closely with these 

experts to identify the key assumptions that would establish the scope of 

our alternatives, the more specific assumptions to identify the processes 

associated with each alternative, the components of these processes that 

we could quantify in terms of cost, and the level of uncertainty associated 

with each component cost. For example, two of the experts in this first 

group told us that for the on-site alternative, commercial reactor sites that 

did not already have independent spent nuclear fuel storage installations 

would have to build them during the next 10 years and that the cost for 

licensing, design, and construction of each installation would range from 

$24 million to $36 million. Once we had gathered our initial assumptions 

and cost components, we used a data collection instrument to solicit 

comments on them from all of our experts. We then used the experts’ 

comments to refine our assumptions and component costs. (See app. II for 

our methodology for consulting with this larger group of nuclear waste 

management experts.) 

DOE officials provided assumptions and cost data for managing DOE 

spent nuclear fuel and high-level waste, which we incorporated into our 

analysis of the centralized storage and on-site storage alternatives. These 

assumptions and cost information covered management of spent nuclear 

Page 46 GAO-10-48 Nuclear Waste Management
Appendix I: Scope and Methodology 

fuel and high-level waste at DOE’s Idaho National Laboratory, Hanford 

Reservation, Savannah River Site, and West Valley site. 

Developing Information on 

Key Attributes, Challenges, 

and Costs of the 

Centralized Storage and 

On-Site Storage 

Alternatives 

To gather information on the key attributes and challenges of our 

alternatives, we interviewed agency officials and nuclear waste 

management experts from industry, academic institutions, and concerned 

groups. We also reviewed the reports and studies and visited the locations 

that were mentioned in the previous section. To ensure that the attributes 

and challenges we developed were accurate, comprehensive, and 

balanced, we asked our snowballed list of experts to provide their 

comments on our work, using the data collection instrument that is 

described in appendix II. We used the comments that we received to 

expand the attributes or challenges on our list or, where necessary, to 

modify our characterization of individual attributes or challenges. 

To generate cost ranges for the centralized storage and on-site storage 

alternatives, we developed four large-scale cost models that analyzed the 

costs for each alternative of storing 70,000 metric tons and 153,000 metric 

tons of nuclear waste for 100 years followed by disposal in a geologic 

repository. (See app. IV.) We also generated cost ranges for each 

alternative of storing the waste for 100 years without including the cost of 

subsequent disposal in a geologic repository for storing 153,000 metric 

tons of waste on site for 500 years. For each model, which rely upon data 

and assumptions provided by nuclear waste management experts, the cost 

range was based on the annual volume of commercial spent nuclear fuel 

that became ready to be packaged and stored in each year. In general, 

each model started in 2009 by annually tracking costs of initial packaging 

and related costs for the first 100 years and for every 100 years thereafter 

if the waste was to remain on site and be repackaged. Since our models 

analyzed only the costs associated with storing commercial nuclear waste 

management, we augmented them with DOE’s cost data for (1) managing 

its spent nuclear fuel and high-level waste and (2) constructing and 

operating a permanent repository. Specifically, we used DOE’s estimated 

costs for the Yucca Mountain repository to represent cost for a 

hypothetical permanent repository.2

 

2

We excluded historical costs for the Yucca Mountain repository because these costs 

represent challenges unique to Yucca Mountain and may not be applicable to a future 

repository. However, the bulk of future cost for construction, operation, and closure may 

be representative of a new repository. 

Page 47 GAO-10-48 Nuclear Waste Management
Appendix I: Scope and Methodology 

We conducted this performance audit from April 2008 to October 2009 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. 

Page 48 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management Appendix II: Our Methodology for Obtaining Experts 

Comments from Nuclear Waste Management 

Experts 

As discussed in appendix I, we gathered the assumptions and associated 

component costs used to define our nuclear waste management 

alternatives by consulting with experts in an iterative process of 

identifying initial assumptions and component costs and revising them 

based on expert comments. This appendix (1) describes the data 

collection instrument we used to obtain comments on the initial 

assumptions and component costs, (2) describes how we analyzed the 

comments and revised our assumptions, and (3) provides a list of the 

assumptions and cost data that we derived through this process and used 

in our cost models. 

To obtain comments from a broad group of nuclear waste management 

experts, we compiled the initial assumptions and component costs that we 

gathered from a small group of experts into a data collection instrument 

that included 

• a description of the Yucca Mountain repository and our proposed nuclear 

waste management alternatives—on-site storage and centralized storage—

and attributes and challenges associated with them; 

• our initial assumptions that would identify and define the processes, time 

frames, and major components used to bound our hypothetical centralized 

and on-site storage alternatives; 

• the major component costs of each alternative, including definitions and 

initial cost data; and 

• components associated with each alternative with a high degree of 

uncertainty that we did not attempt to quantify in terms of costs. 

The data collection instrument asked the experts to answer specific 

questions about each piece of information that we provided (see table 6). 

Page 49 GAO-10-48 Nuclear Waste Management 
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

Table 6: Our Data Collection Instrument for Nuclear Waste Management Experts 

Section of the data collection 

instrument Questions asked of the experts 

Description of each alternative and its 

attributes and challenges 

What additional issues do you suggest we consider, or is there one listed that you would 

modify? 

List of initial assumptions for each 

alternative 

To what extent to you think this assumption is reasonable or unreasonable?a

If this assumption does not seem reasonable, please describe.a

Are there additional assumptions defining our scenario not mentioned above that you 

would recommend GAO consider? Please describe. 

List of component costs and initial cost 

data 

Is this estimate reasonable or unreasonable?a

If this estimate is not reasonable, please describe why (estimate too high, estimate too 

low, range too broad, range too narrow) and, if possible, provide specific alternative cost 

estimates.a

Please tell us anything about this cost item that might make it difficult (or not difficult) to 

estimate accurately?a

Are there additional cost categories not mentioned above that you would recommend 

GAO consider? Please provide a generic cost estimate or potential source of such an 

estimate, if possible. 

List of uncertain components In your opinion, do you think any of these items can be quantified? If so, please provide 

suggestions for how to quantify them, along with supporting data, if available. 

Source: GAO. 

a

This question was asked after each assumption or component. 

We pretested our instrument with several individual experts to ensure that 

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

we needed, and then refined the instrument accordingly. Next, we sent the 

instrument to 114 experts who were identified through our snowballing 

methodology (see apps. I and III). Each expert received the sections of our 

data collection instrument that included the attributes and challenges of 

the alternatives and the initial assumptions, but only those experts with 

the type and level of expertise to comment on costs received the cost 

component sections. 

We received 67 sets of comments from independent experts and experts 

representing industry, federal government, state governments, and other 

concerned groups.1

 These experts also represented a range of viewpoints 

on the Yucca Mountain repository. Each of their responses was compiled 

 

1

The 67 sets of comments do not reflect the total number of experts who responded 

because some groups of affiliated experts compiled their comments into a single response. 

For example, DOE’s Office of Civilian Radioactive Waste Management provided a 

consolidated set of comments for its nine experts. 

Page 50 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

into a database organized by each individual assumption or cost element 

for the on-site storage and centralized interim storage alternatives. 

To arrive at the final assumptions and cost component data for our 

models, we qualitatively analyzed the experts’ comments. The comments 

we received on the assumptions differed in nature from those we received 

on the component costs, so our analysis and disposition of comments 

differed slightly. For the assumptions, we took the comments on each 

assumption that were made when an expert did not believe it was entirely 

reasonable and grouped comments that were similar. We determined the 

relevance of a comment to our assumption based on whether the comment 

provided a basis upon which we could modify the assumption or was 

within the scope or capability of our models. For example, we received 

several comments about how an assumption may be affected by nuclear 

waste from new reactors, including potential liabilities if the Department 

of Energy (DOE) does not take custody of that waste, but in the key 

assumptions defining our alternatives, we explicitly excluded new reactors 

because we could not predict how many new reactors would be built, 

when they would operate, and the amount of waste that they would 

generate. For those comments that were relevant, we weighed the 

expertise of those making the comments and determined whether the 

balance of the comments warranted a modification to our preliminary 

assumption. In some instances, we conducted followup interviews with 

selected experts to clarify issues that the broad group of experts raised. 

For the component costs, we organized the comments on a particular 

component based on whether an expert thought the cost and uncertainty 

range was reasonable, too high, too low, the range was too broad, or the 

range was too narrow. We developed a ranking system to identify which 

experts had the greatest degree of direct experience or knowledge with 

the cost and weighed their comments accordingly to determine whether 

our preliminary cost should be modified. Also, we took into account the 

incidence of expert agreement or disagreement when deciding how much 

uncertainty to apply to a particular cost. 

Through this analysis, we determined that the preponderance of our 

preliminary assumptions and cost data were reasonable for use in our 

models either because the experts generally agreed it was reasonable, or 

the experts who thought it was reasonable had a greater degree of relevant 

expertise or knowledge than those who commented otherwise. However, 

some of the experts’ responses indicated that a modification to our model 

was needed. Table 7 presents a summary of the modifications we made to 

Page 51 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

our model assumptions and cost data based on the expert comments 

received. 

Table 7: Initial Assumptions and Component Cost Estimates for Our Centralized Storage and On-site Storage Alternatives and 

Modifications Made Based on Experts’ Responses to Our Data Collection Instrument 

Centralized storage 

Key aspect of the alternative Initial key assumption Modification based on expert 

comments 

Number of sites Two sites located in different geographic regions of 

the country. 

None 

Reactor operations Current reactors will receive, if they have not 

already, a 20-year license extension and will operate 

until the end of their licensed life. 

None 

When reactors cease operations, they will be 

decommissioned and only spent nuclear fuel dry 

storage will remain on site. 

None 

Transportation Transportation will be the similar to what is assumed 

for the Yucca Mountain repository—via rail, using 

dedicated trains. 

None 

Repackaging Waste will not be repackaged at the centralized 

facilities.a

None 

Final disposition Waste will be stored at the centralized sites until 100 

years from now and then be disposed of in a 

geologic repository.b

None 

Process Initial process assumption Modification based on expert 

comments 

Waste packaged into dry storage casks Reactor operators will only move the amount of 

waste from pools into dry storage that is necessary 

to preserve full-core offload capability—the capacity 

in their spent nuclear fuel pools to store all of the fuel 

in the reactor core. 

None 

The overall amount of fuel moved from the pools to 

dry storage will be equal to estimated annual rates at 

which fuel is discharged from the reactors. 

None 

Dual-purpose canister systems will be used until 

Transportation, Aging and Disposal systems become 

widely available. 

Only dual-purpose systems will be 

used. 

Transportation, Aging and Disposal systems will 

have a capacity of 8.5 metric tons plus or minus 5 

percent. 

None (although this assumption 

became obsolete when we no 

longer assumed transportation, 

aging, and disposal systems would 

be used). 

Page 52 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

Centralized storage 

Reactor site dry storage All reactor sites without dry storage facilities will 

construct them at the time they lose full-core offload 

capability—the capacity in their spent nuclear fuel 

pools to store all of the fuel in the reactor core. 

None 

Dry storage operations and maintenance costs vary 

by nature of the site, such as operating versus 

decommissioned. 

None 

On average, 1.5 decommissioned reactor sites will 

be cleared of their waste each year. 

None 

Transportation to centralized storage Once running at full capacity, transportation rates will 

be approximately 3,000 metric tons per year (what is 

assumed for Yucca Mountain). 

None 

Waste from decommissioned sites and GE Morris 

will be transported before waste from operating sites. 

This waste would not be converted to dry storage 

prior to transportation. 

None 

133 transportation casks will be required (what is 

assumed for Yucca Mountain) and will be acquired 

over a 7-year period. 

None 

 No new rail construction will be required. None 

Transportation system infrastructure, system 

support, and operations will be analogous to what 

DOE assumes for Yucca Mountain. 

None 

Centralized storage The two centralized facilities will begin accepting 

waste in 2028. 

None 

The sites will be built at existing federal facilities and 

be owned and operated by DOE. 

None 

Geologic disposal Waste will not be repackaged before being disposed 

of in a permanent repository. 

None 

Any spent nuclear fuel not originally packaged into a 

Transportation, Aging and Disposal canister will be 

repackaged at the geologic repository. 

This assumption became obsolete 

when we no longer assumed 

transportation, aging, and disposal 

canisters would be used. 

Process component Initial component cost estimate Modification based on expert 

comments 

Dry cask storage systems: 

• transportation, aging, and disposal 

• dual-purpose 

• $1.1 million plus or minus 10 percent 

• $900,000 plus or minus 5 percent 

• Obsolete 

• $900,000 plus or minus 25 

percent 

Loading operations: 

• cost per cask to load fuel into dry 

storage canisters 

• loading campaign consisting, on 

average, of five casks (including setup, clean up, training, and labor) 

• $150,000 plus or minus 5 percent 

• $750,000 plus or minus 5 percent 

• $275,000 plus or minus 45 

percent 

• None 

Page 53 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

Centralized storage 

Design, licensing, and construction of dry 

storage installations at reactor sites 

$30 million plus or minus 20 percent $30 million plus or minus 40 

percent 

Annual operations and maintenance: 

• operating reactor site dry storage 

• decommissioned reactor site dry 

storage 

• decommissioned reactor site wet 

storage 

• $100,000 plus or minus 20 percent 

• $3 million plus or minus 20 percent 

• $10 million plus or minus 20 percent 

• $100,000 plus or minus 50 

percent 

• $4.5 million plus or minus 40 

percent 

• None 

Transportation casks $4.5 million plus or minus 10 percent None 

Loading for transportation cost per 

canister 

$250,000 plus or minus 5 percent $150,000 plus or minus 40 percent 

Transportation infrastructure: 

• rolling stock and facilities 

• transportation system support 

• $400 million plus or minus 10 percent 

• $2.5 billion plus or minus 10 percent 

• None 

• None 

Transportation operations per-metric-ton $26,000 plus or minus 10 percent None 

Centralized facility licensing and 

construction: 

• 70,000 metric ton facility 

• 153,000 metric ton facility 

• $168 million plus or minus 10 percent 

• $232 million plus or minus 10 percent 

• $218 million plus or minus 20 

percent 

• $302 million plus or minus 20 

percent 

Centralized facility annual operations and 

maintenance 

$8.8 million plus or minus 10 percent None 

On-site storage 

Key aspect of the alternative Initial key assumption Modification based on expert 

comments 

Number of commercial sites Commercial spent nuclear fuel spent nuclear fuel will 

be stored at 75 reactor sites. 

None 

Number of DOE sites DOE high-level waste and spent nuclear fuel will 

remain at five current sites. 

None 

Reactor operations Current reactors will receive, if they have not 

already, a 20-year license extension and will operate 

until the end of their licensed life. 

None 

When reactors cease operations, they will be 

decommissioned and only spent nuclear fuel dry 

storage will remain on site. 

None 

Transportation There will be no transportation of waste between 

sites. 

None 

Repackaging Dry cask storage systems would require repackaging 

every 100 years. 

None 

Page 54 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

On-site storage 

Process Initial process assumption Modification based on expert 

comments 

Waste packaged into dry storage casks Reactor operators will use generic dual-purpose 

canisters for dry storage with a capacity of 13 metric 

tons plus or minus 5 percent. 

Range increased to plus or minus 

15 percent. 

Reactor operators will only move the amount of 

waste from pools into dry storage that is necessary 

to preserve full-core offload capability. 

None 

The overall amount of fuel moved from the pools to 

dry storage will be equal to estimated annual rates at 

which fuel is discharged from the reactors. 

None 

Reactor site dry storage All reactor sites without dry storage facilities will 

construct them at the time they lose full-core offload 

capability. 

None 

Dry storage operations and maintenance costs vary 

by nature of the site, such as operating versus 

decommissioned. 

None 

Repackaging Wet transfer facilities will need to be built at each site 

for every packaging interval (i.e. every 100 years). 

We will assume a generic transfer 

system that could be either wet or 

dry. 

All sites will need to replace their dry storage pad 

and infrastructure every 100 years when they 

repackage. 

None 

Process component Initial component cost estimate Modification based on expert 

comments 

Dry cask storage system $900,000 plus or minus 5 percent $900,000 plus or minus 25 percent 

Loading operations: 

• cost per cask to load fuel into dry 

storage canisters 

• loading campaign consisting, on 

average, of five casks (including setup, clean up, training, and labor) 

• $150,000 plus or minus 5 percent 

• $750,000 plus or minus 5 percent 

• $275,000 plus or minus 45 

percent 

• None 

Design, licensing, and construction of dry 

storage installations at reactor sites 

$30 million plus or minus 20 percent $30 million plus or minus 40 

percent 

Annual operations and maintenance: 

• operating reactor site dry storage 

• decommissioned reactor site dry 

storage 

• decommissioned reactor site wet 

storage 

• $100,000 plus or minus 20 percent 

• $3 million plus or minus 20 percent 

• $10 million plus or minus 20 percent 

• $200,000 plus or minus 50 

percent 

• $4.5 million plus or minus 40 

percent 

• None 

Construction of a transfer facility for 

repackaging 

$300 million plus or minus 50 percent (for a wet 

transfer facility) 

$300 million plus or minus 50 

percent (for either a wet or a dry 

transfer facility) 

Page 55 GAO-10-48 Nuclear Waste Management
Appendix II: Our Methodology for Obtaining 

Comments from Nuclear Waste Management 

Experts 

On-site Storage 

Repackaging operations: 

• repackaging costs per cask 

• repackaging campaign consisting, on 

average, of 5 casks (including set-up, 

clean up, training, and labor) 

• $1.2 million plus or minus 10 percent 

• $750,000 plus or minus 10 percent 

• $1.6 million plus or minus 10 

percent 

• None 

Storage pad replacement $30 million plus or minus 20 percent $30 million plus or minus 40 

percent 

Source: GAO analysis based on expert-provided data. 

Note: Unless specifically noted, all assumptions and costs apply specifically to commercial nuclear 

power sites. We used information provided by DOE for the assumptions and costs related to DOEmanaged spent nuclear fuel and high-level waste. 

a

We did not explicitly solicit comment on this assumption in the data collection instrument for the 

centralized storage alternative because we solicited comments on the repackaging requirements in 

the on-site alternative. 

b

This assumption applies only to the version of our centralized storage alternative that includes final 

disposal. 

Page 56 GAO-10-48 Nuclear Waste Management
Appendix III: Nuclear Waste Management 

Experts We Interviewed 

Name Affiliation 

1 Mark D. Abkowitz U.S. Nuclear Waste Technical Review Board (member) 

2 John Ahearne Sigma Xi 

3 Joonhong Ahn National Academy of Sciences/Nuclear and Radiation Studies Board 

4 David Applegate U.S. Geological Survey 

5 Wm. Howard Arnold U.S. Nuclear Waste Technical Review Board (member) 

6 Tom Baillieul The Chamberlain Group 

7 James David Ballard California State University, Northridge 

8 William D. Barnard U.S. Nuclear Waste Technical Review Board (retired) (staff) 

9 Lake Barrett DOE/Office of Civilian Radioactive Waste Management (retired) 

10 Barbara Beller DOE/Office of Environmental Management 

11 David W. Bland TriVis Incorporated 

12 Ted Borst CH2M-WG Idaho, LLC 

13 David C. Boyd Minnesota Public Utilities Commission 

14 Michele Boyd Physicians for Social Responsibility 

15 William Boyle DOE/Office of Civilian Radioactive Waste Management 

16 E. William Brach Nuclear Regulatory Commission (NRC)/Division of Spent Fuel Storage and Transportation 

17 Bruce Breslow State of Nevada Agency for Nuclear Projects 

18 Philip Brochman NRC/Office of Nuclear Security and Incident Response 

19 Tom Brookmire Dominion Resources, Inc. 

20 Robert J. Budnitz Lawrence Berkeley National Laboratory 

21 Susan Burke Idaho Department of Environmental Quality 

22 Barbara Byron Western Interstate Energy Board 

23 Robert Capstick The Yankee Nuclear Power Companies 

24 Thure E. Cerling U.S. Nuclear Waste Technical Review Board (member) 

25 Margaret Chu M.S. Chu & Associates 

26 Tom Clements Friends of the Earth 

27 Jean Cline University of Nevada Las Vegas 

28 Thomas Cochran Natural Resources Defense Council 

29 Marshall Cohen Nuclear Energy Institute 

30 Kevin Crowley Nuclear and Radiation Studies Board, National Research Council of the National Academies 

31 Jeanne Davidson U.S. Department of Justice/Civil Division 

32 Bradley Davis DOE/Office of Nuclear Energy 

33 Jack Davis NRC/Division of High Level Waste Repository Safety 

34 Jay C. Davis Lawrence Livermore National Laboratory (retired) 

Nuclear and Radiation Studies Board, National Research Council of the National Academies 

Appendix III: Nuclear Waste Management 

Experts We Interviewed 

Page 57 GAO-10-48 Nuclear Waste Management 
Appendix III: Nuclear Waste Management 

Experts We Interviewed 

 Name Affiliation 

35 Scott DeClue DOE/Office of Environmental Management 

36 Edgardo DeLeon DOE/Office of Environmental Management 

37 Fred Dilger Black Mountain Research 

38 David J. Duquette U.S. Nuclear Waste Technical Review Board (member) 

39 Doug Easterling Wake Forest University 

40 Steven Edwards Progress Energy 

41 Randy Elwood CH2M-WG Idaho, LLC 

42 Rod Ewing University of Michigan 

43 Steve Fetter University of Maryland 

44 James Flynn Pacific World History Institute 

45 Charles Forsberg Massachusetts Institute of Technology 

46 Derrick Freeman Nuclear Energy Institute 

47 Steve Frishman State of Nevada Nuclear Waste Project Office 

48 Robert Fronczak Association of American Railroads 

49 B. John Garrick U.S. Nuclear Waste Technical Review Board (chairman) 

50 Ron Gecan U.S. Congressional Budget Office 

51 Lynn Gelhar Massachusetts Institute of Technology 

52 Christine Gelles DOE/Office of Environmental Management 

53 Robert Gisch Department of Defense/Department of the Navy 

54 Aubrey Godwin Arizona Radiation Regulatory Agency 

55 Charles R. Goergen Washington Savannah River Companya

56 Stephen Goldberg Argonne National Laboratory 

57 Steven Grant Bechtel SAIC Company, LLCb

58 Paul Gunter Beyond Nuclear 

59 Brian Gustems PSEG Nuclear, LLC 

60 Brian Gutherman ACI Nuclear Energy Solutions 

61 Roger L. Hagengruber University of New Mexico 

Nuclear and Radiation Studies Board, National Research Council of the National Academies 

62 R. Scott Hajner Bechtel SAIC Company, LLCb

63 Robert Halstead Transportation Advisor, State of Nevada Agency for Nuclear Projects 

64 Paul Harrington DOE/Office of Civilian Radioactive Waste Management 

65 Ronald Helms Bechtel SAIC Company, LLCb

66 Damon Hindle Bechtel SAIC Company, LLCb

67 James Hollrith DOE/Office of Civilian Radioactive Waste Management 

68 Greg Holden Department of Defense/Department of the Navy 

69 Mark Holt U.S. Congressional Research Service 

70 George M. Hornberger U.S. Nuclear Waste Technical Review Board (member) 

Page 58 GAO-10-48 Nuclear Waste Management
Appendix III: Nuclear Waste Management 

Experts We Interviewed 

 Name Affiliation 

71 William Hurt Idaho National Laboratory 

72 Thomas H. Isaacs Stanford University 

Lawrence Livermore National Laboratory 

Nuclear and Radiation Studies Board, National Research Council of the National Academies 

73 Lisa R. Janairo Council of State Governments, Midwestern Office 

74 Andrew C. Kadak U.S. Nuclear Waste Technical Review Board (member) 

75 Kevin Kamps Beyond Nuclear 

76 Anthony Kluk DOE/Office of Environmental Management 

77 Lawrence Kokajko NRC/Division of High Level Waste Repository Safety 

78 Leonard Konikow U.S. Geological Survey 

79 Christopher Kouts DOE/Office of Civilian Radioactive Waste Management 

80 Steven Kraft Nuclear Energy Institute 

81 Darrell Lacy Nye County, State of Nevada 

82 Gary Lanthrum DOE/Office of Civilian Radioactive Waste Management 

83 Doug Larson Western Interstate Energy Board 

84 Ned Larson DOE/Office of Civilian Radioactive Waste Management 

85 Ronald M. Latanision U.S. Nuclear Waste Technical Review Board (member) 

86 Thomas Leschine University of Washington 

87 Adam H. Levin Exelon Corporation 

88 David Little Washington Savannah River Companyc

89 David Lochbaum Union of Concerned Scientists 

90 Bob Loux Consultant 

91 Edwin Lyman Union of Concerned Scientists 

92 Allison Macfarlane George Mason University 

93 Arjun Makhijani Institute for Energy and Environmental Research 

94 Zita Martin Tennessee Valley Authority 

95 Rodney McCullum Nuclear Energy Institute 

96 John McKenzie Department of Defense/Department of the Navy 

97 Richard A. Meserve Carnegie Institution for Science 

Nuclear and Radiation Studies Board, National Research Council of the National Academies 

98 Barry Miles Department of Defense/Department of the Navy 

99 Thomas Minvielle Department of Defense/Department of the Navy 

100 Bob Mitchell Yankee Rowe 

101 Ali Mosleh U.S. Nuclear Waste Technical Review Board (member) 

102 William M. Murphy U.S. Nuclear Waste Technical Review Board (member) 

103 Connie Nakahara Utah Department of Environmental Quality 

104 Irene Navis Clark County, Nevada 

105 Tara Neider Transnuclear, Inc. 

Page 59 GAO-10-48 Nuclear Waste Management
Appendix III: Nuclear Waste Management 

Experts We Interviewed 

 Name Affiliation 

106 Brian O’Connell National Association of Regulatory Utility Commissioners 

107 Mary Olson Nuclear Information and Resource Service 

108 Pierre Oneid Holtec International 

109 Ronald S. Osteen DOE/Office of Environmental Management 

110 Jean Ridley DOE/Office of Environmental Management 

111 John Parkyn Private Fuel Storage 

112 Stan Pedersen Bechtel SAIC Company, LLCb

113 Charles W. Pennington NAC International 

114 Mark Peters Argonne National Laboratory 

115 Per Peterson University of California at Berkeley 

116 Henry Petroski U.S. Nuclear Waste Technical Review Board (member) 

117 Max Power Oregon Hanford Cleanup Board 

118 Kenneth Powers DOE/Office of Civilian Radioactive Waste Management 

119 Jay Ray DOE/Office of Environmental Management 

120 Jeffrey Ray Washington Savannah River Companyc

121 Everett Redmond II Nuclear Energy Institute 

122 James Robert Tennessee Valley Authority 

123 Gene Rowe U.S. Nuclear Waste Technical Review Board (staff) 

124 Karyn Severson U.S. Nuclear Waste Technical Review Board (staff) 

125 David Shoesmith University of Western Ontario 

126 Linda Sikkema National Conference of State Legislators 

127 Kris Singh Holtec International 

128 Brian M. Smith Department of Defense/Department of the Navy 

129 Susan Smith DOE/Office of Civilian Radioactive Waste Management 

130 Joseph D. Sukaskas Maine Public Utilities Commission 

131 Jane Summerson DOE/Office of Civilian Radioactive Waste Management 

132 Eileen Supko Energy Resources International, Inc. 

133 Bill Swift Washington Savannah River Companyc

134 Peter Swift Sandia National Laboratories 

135 Raymond Termini Exelon Corporation 

136 Mike Thorne Mike Thorne and Associates Limited 

137 John Till Risk Assessment Corporation 

138 Richard Tosetti Bechtel SAIC Company, LLCb

139 Brian Wakeman Dominion Resources, Inc. 

140 John Weiss, Jr. Entergy Corporation 

141 Christopher U. Wells Southern States Energy Board 

142 Chris Whipple ENVIRON International Corporation 

Page 60 GAO-10-48 Nuclear Waste Management
Appendix III: Nuclear Waste Management 

Experts We Interviewed 

Page 61 GAO-10-48 Nuclear Waste Management 

 Name Affiliation 

143 James Williams Western Interstate Energy Board 

144 Wayne Worthington Progress Energy 

145 David Zabransky DOE/Civilian Radioactive Waste Management Board 

146 Paul L. Ziemer Purdue University (retired) 

Nuclear and Radiation Studies Board, National Research Council of the National Academies 

147 Louis Zeller Blue Ridge Environmental Defense League 

Source: GAO. 

a

On August 1, 2008, Savannah River Nuclear Solutions, LLC replaced Washington Savannah River 

Company as the primary contractor for DOE’s Savannah River site. Expert affiliation was with 

Washington Savannah River Company at the time of our interviews. 

b

On April 1, 2009, USA Repository Services, LLC, replaced Bechtel SAIC Company, LLC, as the 

primary contractor for the Yucca Mountain repository. Expert affiliation was with Bechtel SAIC 

Company, LLC at the time of our interviews. 

c

On July 1, 2009, Savannah River Remediation, LLC replaced Washington Savannah River Company 

as the liquid waste program contractor. Expert affiliation was with Washington Savannah River 

Company at the time of our interviews. 
Appendix IV: M

Assumptio

odeling Methodology, 

ns, and Results 

Page 62 GAO-10-48 

Appendix IV: Modeling Methodology, 

Assumptions, and Results 

The methodology and results of the models we developed to analyze the 

total costs of two alternatives for managing nuclear waste are based on 

cost data and assumptions we gathered from experts. Specifically, this 

appendix contains information on the following: 

• The modeling methodology we developed to generate a range of total 

costs for the two nuclear waste management alternatives with two 

different volumes of waste. 

• The Monte Carlo simulation process we used to address uncertainties in 

input data. 

• The discounting methodology we developed to derive the present value of 

total costs in 2009 dollars. 

• The individual models and scenarios within each model. 

• The results of our cost estimations for each scenario. 

• Caveats to our modeling work. 

Appendixes I and II describe our methodology for collecting cost data and 

assumptions and how we ensured their reliability. 

The general framework for our models was an Excel spreadsheet that 

annually tracked all costs associated with packaging, transportation, 

construction, operation, and maintenance of nuclear waste facilities as 

well as repackaging of nuclear waste every 100 years when applicable. The 

starting time period for all models was the year 2009, but the end dates 

vary depending on the specifics of the scenario. The cost inputs were 

collected in constant 2008 dollars, but the range of total costs for each 

scenario was converted to and reported in 2009 present value dollars. Our 

analysis began with an estimate of existing and future annual volume of 

nuclear waste ready to be packaged and stored. We chose to model two 

amounts of waste: 70,000 metric tons and 153,000 metric tons.1

 For ease of 

Modeling 

Methodology 

 

1

The 70,000 metric tons is the statutory limit placed on the amount of waste that can be 

disposed of at Yucca Mountain. The 153,000 metric tons is the estimated amount of current 

waste plus additional commercial spent nuclear fuel that would be generated by 2055 if all 

currently operating commercial reactors received license extensions. 

 Nuclear Waste Management 
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

calculation, we converted all input costs to cost per-metric-ton of waste, 

when applicable. 

The total cost range for each scenario was developed in four steps. First, 

we developed the total costs for commercial spent nuclear fuel volumes of 

about 63,000 metric tons and 140,000 metric tons, respectively. Second, we 

added DOE cost data for its managed waste.2

 Third, we discounted all 

annual costs to 2009 present value by a discounting methodology 

discussed later in this appendix. Finally, for scenarios where we assumed 

that the waste would be moved to a permanent repository after 100 years, 

we added DOE’s cost estimate for the Yucca Mountain repository to 

represent cost for a permanent repository.3

 To ensure compatibility of cost 

data that DOE provided with cost ranges generated by our models, we 

converted DOE cost data to 2009 present value. 

To address the uncertainties inherent in our analysis, we used a 

commercially available risk analysis software program called Crystal Ball 

to incorporate uncertainties associated with the data. This program 

allowed us to explore a wide range of possible values for all the input 

costs and assumptions we used to build our models. The Crystal Ball 

program uses a Monte Carlo simulation process, which repeatedly and 

randomly selects values for each input to the model from a distribution 

specified by the user. Using the selected values for cells in the 

spreadsheet, Crystal Ball then calculates the total cost of the scenario. By 

repeating the process in thousands of trials, Crystal Ball produces a range 

of estimated total costs for each scenario as well as the likelihood 

associated with any specific value in the range. 

Monte Carlo 

Simulation Process 

 

2

DOE management costs include spent nuclear fuel managed at the Hanford Reservation, 

Idaho National Laboratory, and Fort St. Vrain, in Colorado, and high-level waste at the 

Hanford Reservation, Savannah River Site, Idaho National Laboratory, and West Valley. 

3

We used DOE estimates for Yucca Mountain to represent the cost of a permanent 

repository. We, however, did not include historical costs for Yucca Mountain as we felt that 

these historical costs represent challenges unique to Yucca Mountain and may not be 

applicable to a future repository whereas the bulk of future cost for construction, 

operation, and closure would be replicated for a new repository. 

Page 63 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

One of the inherent difficulties in developing the cost for a nuclear waste 

disposal option is that costs are spread over thousands of years. The 

economic concept of discounting is central to such analyses as it allows 

costs incurred in the distant future to be converted to present equivalent 

worth. We selected discount rates primarily based on results of studies 

published in peer reviewed journals. That is, rather than subjectively 

selecting a single discount rate, we developed our discounting approach 

based on a methodology and values for discount rates that were 

recommended by a number of published studies. 

Discount Rates and 

Present Value 

Analysis 

We selected studies that addressed issues related to discounting activities 

whose costs and effects spread across the distant future or many 

generations, also known as “intergenerational discounting.” In general, we 

found that these studies were in near consensus on two points: (1) 

discounting is an appropriate methodology when analyzing projects and 

policies that span many generations and (2) rates for discounting the 

distant future should be lower than near term discount rates and/or should 

decline over time. However, we found no consensus among the studies as 

to any specific discount rate that should be used. Consequently, we 

developed a discounting methodology using the following steps: 

• We divided the entire time frame of our analysis into five different 

discounting intervals: immediate, near future, medium future, far future, 

and far-far future. 

• We assumed that within each interval the discount rates were distributed 

with a triangular distribution. 

• Based on all published rates, we developed the maximum, minimum, and 

mode values for each of the five specified intervals. 

• We discounted all costs, using Crystal Ball to randomly and repeatedly 

select a rate from the appropriate interval and discount cost values using a 

different rate for each trial. 

• Using these steps, we discounted all annual costs to 2009 present value. 

Our methodology builds on a wide range of published rates from a number 

of different sources in concert with the Crystal Ball program. This enabled 

us, to the extent possible, to address the general lack of consensus on any 

specific discount rate and, at the same time, address the uncertainties that 

were inherent in intergenerational discounting and long-term analyses of 

nuclear waste management alternatives. 

Page 64 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Individual Models We developed the following four models to estimate the cost of several 

hypothetical nuclear waste disposal alternatives, and we incorporated a 

number of scenarios within each model to address all uncertainties that 

we could not easily capture with Crystal Ball: 

• Model I: Centralized storage for 153,000 metric tons, which included the 

following scenarios: 

• Scenario 1: Centralized storage for 100 years. 

• Scenario 2: Centralized storage for 100 years plus a permanent 

repository after 100 years. 

• Model II: Centralized storage for 70,000 metric tons, which included one 

scenario: 

• Scenario 1: Centralized storage for 100 years. 

• Model III: On-site storage using total waste volume of 153,000 metric tons 

which included the following scenarios: 

• Scenario 1: On-site storage for 100 years. 

• Scenario 2: On-site storage for 100 years plus a permanent repository 

after 100 years. 

• Scenario 3: On-site storage for 500 years. 

• Model IV: On-site storage using total waste volume of 70,000 metric tons, 

which included one scenario: 

• Scenario 1: On-site storage for 100 years. 

Model I: Centralized 

Storage (153,000 metric 

tons) 

For this model we assumed that nuclear waste would remain on site until 

interim facilities are constructed and ready to receive the waste. Two 

centralized storage facilities would be constructed over 3 years—from 

2025 through 2027—and then start accepting waste. The first scenario for 

this model includes the costs to store waste at the centralized facilities 

through 2108. In the second scenario, these facilities would stay in 

Page 65 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

operation through 2155, or 47 years after a permanent repository for the 

waste would become available. The total analysis period for the cost of 

this alternative plus permanent repository continues until 2240, when a 

permanent repository would be expected to close. In general, the costs 

include the following: 

• Initial costs, which include costs of casks, costs for loading of casks, cost 

of loading campaigns, and operating and maintenance costs by three types 

of nuclear sites, i.e., operating sites with dry storage, decommissioned 

sites with dry storage, and decommissioned sites with wet storage. The 

uncertainty ranges for these costs were from plus or minus 5 percent to 

plus or minus 50 percent, depending on specific cost variable. 

• Costs associated with centralized facilities, including construction costs 

for centralized facilities, transportation cost for transfer of nuclear waste 

to centralized facilities, capital and operation and maintenance costs for 

transportation of waste to centralized facilities and operation and 

maintenance of centralized facilities. The uncertainty ranges for these 

costs are from plus or minus 10 percent to plus or minus 40 percent, 

depending on the cost category. 

Page 66 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Figure 6: Scenario and Cost Time Frames for the Centralized 153,000 Metric Ton Models 

Commercial waste (packaging and 

operations and maintenance [O&M])

Centralized facility and transportation

On-site DOE waste management

Centralized facility O&M 

Commercial waste (packaging and O&M) 

Commercial waste (on-site O&M)

Commercial waste (on-site O&M)

Centralized facility and transportation

Centralized facility O&M 

On-site DOE waste management

Permanent repository

100 years

2010 2030 2050 2070 2090 2110 2130 2150 2170 2190 2210 2230 2250

Centralized storage for 100 years

2009 2065

2025 2074

2065 2074

2075 2108

2009 2100

Centralized storage for 100 years

 with a permanent repository

2009 2065

2025 2074

2065 2074

2075 2155

2098 2240

2009 2100

232 years

Scenarios and Cost Time Frames for the Centralized 153,000 Metric Ton Models

Source: GAO analysis of expert and DOE-provided data.

Model II: Centralized 

Storage (70,000 metric 

tons) 

This model was developed under the assumption that total existing and 

newly generated waste from the private sector and DOE will be 70,000 

metric tons. The stream of new annual waste ready to be moved to dry 

storage will continue through 2030. The cost categories and uncertainty 

ranges assumed for this storage alternative are the same as those assumed 

in the centralized storage model for 153,000 metric tons. 

Page 67 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Figure 7: Scenario and Cost Time Frames for the Centralized 70,000 Metric Ton Model 

On-site commercial waste

Centralized facility

On-site DOE waste management

2010 2030 2050 2070 2090 2110 2130 2150 2170 2190 2210 2230 2250

Centralized storage for 100 years

2009 2050

2025 2108

2009 2100

100 years

Source: GAO analysis of expert and DOE-provided data.

Scenario and Cost Time Frames for the Centralized 70,000 Metric Ton Model

Model III: On-Site Storage 

(153,000 metric tons) 

We developed this model under the assumption that total existing and 

newly generated nuclear waste by the private sector and DOE would be 

153,000 metric tons. The stream of new waste ready to be moved to dry 

storage would continue through 2065. In general, the costs include the 

following: 

• Initial costs, which include costs of casks, costs for loading of casks, cost 

of loading campaigns, and operating and maintenance costs by three types 

of nuclear sites, i.e., operating sites with dry storage, decommissioned 

sites with dry storage, and decommissioned sites with wet storage. The 

uncertainty ranges for these costs were from plus or minus 5 percent to 

plus or minus 50 percent, depending on specific cost variable. 

• Repackaging costs, which include the costs for casks; construction of 

transfer facilities, site pools, and other needed infrastructure; and 

repackaging campaigns. Because these costs are first incurred after 100 

years and then every 100 years thereafter, they are included only in the 

model scenarios covering more than 100 years. The uncertainty for these 

costs range from plus or minus 10 percent to plus or minus 50 percent, 

depending on the specific cost variable. 

• Dry storage pad costs, including initial costs when dry storage is first 

established, as well as replacement costs. Because the replacement costs 

are first incurred after 100 years and then every 100 years thereafter, they 

are included only in the model scenarios covering more than 100 years. 

The cost of these pads, collectively referred to as independent spent fuel 

Page 68 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

storage installations, include costs related to licensing, design, and 

construction of dry storage. The independent spent nuclear fuel storage 

installation costs have an uncertainty range of plus or minus 40 percent. 

Figure 8: Scenarios and Cost Time Frames for the On-Site 153,000 Metric Ton Models 

2010 2030 2050 2070 2090 2110 2130 2150 2170 2190 2210 2230 2250

Commercial Waste (Packaging and 

operations and maintenance [O&M])

DOE waste management

2108

2009

2009

2108

Commercial waste (packaging and O&M)

DOE waste management

2009 2065

2009 2108

Commercial waste (O&M)

2066 2155

DOE waste (O&M) 

2109 2155

Permanent repository

2098 2240

Commercial waste (packaging and O&M)

DOE waste management

2009 2108

2009

Repackaging every 100 years

2109 2508 

2508

On-Site Storage for 100 Years

On-Site Storage for 500 Years

100 years

232 years

500 years

Scenarios and Cost Time Frames for the On-Site 153,000 Metric Ton Models

Source: GAO analysis of expert and DOE-provided data.

On-Site Storage for 100 Years

with a Permanent Repository

Model IV: On-Site Storage 

(70,000 metric tons) 

We developed this model under the assumption that total existing and 

newly generated nuclear waste by the private sector and DOE will be 

70,000 metric tons. The stream of new annual waste ready to be moved to 

dry storage will continue through 2030. The cost categories and 

uncertainty ranges assumed for this storage alternative are the same as 

those for the on-site model for storing 153,000 metric tons for 100 years. 

Page 69 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Page 70 GAO-10-48 Nuclear Waste Management 

Figure 9: Scenario and Cost Time Frames for the On-Site 70,000 Metric Ton Model 

For two scenarios, we assumed that at the end of 100 years the nuclear 

waste would be transferred to a permanent repository for disposal. To 

estimate the cost for a repository, we used DOE’s cost data for the Yucca 

Mountain repository and made three adjustments to ensure compatibility 

with costs generated by our models. First, we included only DOE’s future 

cost estimates for the Yucca Mountain repository. Second, because DOE 

provided costs in 2008 constant dollars, we converted all costs for the 

permanent repository to costs to 2009 present value using corresponding 

ranges of interest rates as previously described in this appendix. Finally, 

we assumed that repository construction and operating costs would be 

incurred from 2098 to 2240 when we added these cost ranges to our 

alternatives after 100 years. 

Table 8 shows the results of our analysis for all scenarios. 

Costs for a Permanent 

Repository 

Modeling Results 

2010 2030 2050 2070 2090 2110 2130 2150 2170 2190 2210 2230 2250

2009 2108

2009 2108

100 years

Commercial waste (packaging and 

operations and maintenance [O&M])

DOE waste management

On-site storage for 100 years

Scenario and Cost Time Frames for the On-Site 70,000 Metric Ton Model

Source: GAO analysis of expert and DOE-provided data.
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Table 8: Model Results for All Scenarios 

Dollars in billions 

Models and scenarios 

Range of 

total costsa Meana

Permanent repository 

(153,000 metric tons) 

Permanent repositoryb$41 to $67 $53

Permanent repository 

(70,000 metric tons) 

Permanent repositoryb$27 to $39 $32

Model I: centralized storage 

(153,000 metric tons) 

Centralized 100 years $15 to $29 $21

Centralized 100 years plus permanent repository $23 to $81 $47

Model II: centralized storage 

(70,000 metric tons) 

Centralized 100 years $12 to $20 $15

Model III: on-site storage 

(153,000 metric tons) 

On-site 100 years $13 to $34 $22

On-site 100 years plus permanent repository $20 to $97 $51

On-site for 500 years $34 to $225 $89

Model IV: on-site storage 

 (70,000 metric tons) 

On-site 100 years $10 to $26 $18

Source: GAO. 

Note: All costs are in 2009 present value and represent costs regardless of who will pay or is legally 

responsible to pay for them and as such do not address the issue of liabilities. Furthermore, these 

costs do not include other potential costs, such as decommissioning and environmental costs and the 

government’s penalties for delays in moving waste from the Idaho National Laboratory under the 

settlement agreement with Idaho. 

a

The cost estimates do not present exact values rather order-of-magnitude estimates as both the 

maximum and minimum as well as mean values will be somewhat different each time the simulation 

is repeated. This is because the Monte Carlo methodology will randomly select a different set of input 

data from one simulation run to the next. 

b

While our cost ranges for a permanent repository are based on DOE’s estimate for the Yucca 

Mountain repository, our cost ranges differ from DOE’s of $96 billion estimate for the following 

reasons: First, our cost ranges are in 2009 present value, while DOE uses 2007 constant dollars, 

which are not discounted. Our present value analysis reflects the time value of money—costs 

incurred in the future are worth less today—so that streams of future costs become smaller. Second, 

our cost ranges do not include about $14 billion in previously incurred costs. Third, our cost ranges 

are for 153,000 metric tons and 70, 000 metric tons of nuclear waste, while DOE’s estimated cost is 

for 122,100 metric tons. Finally, we use ranges while DOE provides a point estimate. 

Page 71 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Figures 10 and 11 show ranges of total costs, as well as the probabilities 

for two selected scenarios. In the figures, each bar indicates a range of 

values for total cost and the height of the each bar indicates the 

probability associated with those values. 

Figure 10: Total Cost Ranges for Centralized Storage for 100 Years with Final 

Disposition 

30

0

0.01

0.02

40 50 60 70 80

Billions of 2009 dollars

Source: GAO analysis of expert and DOE provided data.

Probability Mean = $47

Note: The values on the horizontal axis of the figure are to provide a scale and do not correspond 

exactly to the ranges for total costs which are provided in table 8. 

Page 72 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Figure 11: Total Cost Ranges for On-site Storage for 100 years with Final 

Disposition 

0

Probability

Source: GAO analysis of expert and DOE provided data.

0.01

0.02 Mean = $51

30 40 50 60 70 80 90 100

Billions of 2009 dollars

Note: The values on the horizontal axis of the figure are to provide a scale and do not correspond 

exactly to the ranges for total costs which are provided in table 8. 

Figure 12 shows the present value of the total cost ranges of storing the 

nuclear waste on site over 2,000 years. The shaded areas indicate the 

probability that the values fall within the indicated ranges and are the 

result of combinations of uncertainties from a large number of input data. 

Specifically, we estimate that these costs could range from $34 billion to 

$225 billion over 500 years, from $41 billion to $548 billion over 1,000 

years, and from $41 billion to $954 billion over 2,000 years, indicating and 

substantial level of uncertainty in making long-term cost projections. 

Page 73 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

Figure 12: Total Cost Ranges of On-Site Storage over 2,000 Years 

350

Source: GAO analysis of expert and DOE-provided data.

250

300

200

100

150

0

50

Certainty bands

50 percent

90 percent

100 

years

500 

years

1,000 

years

1,500 

years

2,000

years

Billions of 2009 dollars

Note: The values on the vertical axis of the figure are to provide a scale and do not correspond 

exactly to the total cost ranges presented in table 8. 

Our models are based on ranges of average costs for each major cost 

category that is applicable to the alternative under analysis. As a result, the 

costs do not reflect storage costs for any specific site. Since we did not 

attempt to capture specific characteristics of each site, our values for any 

cost factor, if applied to any specific site, are likely incorrect. 

Nevertheless, since we used ranges rather than single values for a wide 

range of cost inputs to the models, we expect that our cost range for each 

variable includes the true cost for any specific site. Moreover, we expect 

the total cost point estimate for any scenario is within the range of total 

costs we developed. 

Modeling Caveats 

Our models are designed to develop total cost ranges for each scenario 

within each alternative, regardless of who will pay or is legally responsible 

for the costs. Issues related to assignment of the costs and potentially 

responsible entities are discussed elsewhere in this report but are not 

incorporated into our ranges. Also, our cost ranges focus on actual 

expenditures that would be incurred over the period of analysis and do not 

Page 74 GAO-10-48 Nuclear Waste Management
Appendix IV: Modeling Methodology, 

Assumptions, and Results 

assume a particular funding source and do not necessarily represent costs 

to the federal government. Finally, because a number of cost categories 

are not included in our final estimated ranges, we cannot predict their 

impact on our final costs ranges. For example, we did not include (1) 

decontamination and decommissioning costs for existing facilities or 

facilities yet to be built within each scenario and (2) estimates for local 

and state taxes or fees, which would be required to establish new sites or 

for continued operation of on-site storage facilities after nuclear reactors 

are decommissioned. 

Table 8 and figures 10 and 11 present the results of our analysis by 

individual scenario. Because the purpose of our analysis was primarily to 

provide cost ranges for various nuclear waste management alternatives, 

we did not attempt to provide a comparison of results across scenarios. 

For a number of reasons, we believe such a comparison would have been 

misleading. The alternatives we have considered are inherently different in 

a large number of characteristics that could not be captured in our 

modeling work or they were not within the scope of our analysis. For 

example, differences in safety, health, and environmental effects, and ease 

of implementation characteristics of these alternatives should have an 

integral role in the policy debate on waste management decisions. 

However, because these effects cannot be readily quantified, they were 

outside the scope of our modeling work and are not reflected in the total 

cost ranges we generated. 

Page 75 GAO-10-48 Nuclear Waste Management
Appendix V: Comments from the Department 

of Energy 

Page 76 GAO-10-48 

Appendix V: Comments from the Department 

of Energy 

 Nuclear Waste Management 
Appendix VI: Comments from the Nuclear Appendix VI: Comments from the Nuclear Regulatory Commission 

Regulatory Commission 

Page 77 GAO-10-48 Nuclear Waste Management
Appendix VII: GAO Contact and Staff Appendix VII: GAO Contact and Staff Acknowledgments 

Acknowledgments 

Mark Gaffigan, (202) 512-3841 or gaffiganm@gao.gov

In addition to the individual named above, Richard Cheston, Assistant 

Director; Robert Sánchez; Ryan Gottschall; Carol Henn; Anne Hobson; 

Anne Rhodes-Kline; Mehrzad Nadji; Omari Norman; and Benjamin Shouse 

made key contributions to this report. Also contributing to this report 

were Nancy Kingsbury, Karen Keegan, and Timothy Persons. 

Page 78 GAO-10-48 Nuclear Waste Management

GAO Contact 

Staff 

Acknowledgments 

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