Nuclear Waste Management: Key Attributes, Challenges, and Costs for the Yucca Mountain Repository and Two Potential Alternatives
Published: 2009-11-04T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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 mid- 1940s 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.)
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 DOE- managed 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  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.  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  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.  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  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.
subsections: section_title: Background
paragraphs: 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. 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. 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  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.)
After the Congress approved Yucca Mountain as a suitable site for the  development of a permanent nuclear waste repository in 2002, DOE began  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. This amount  does not include any nuclear waste generated by new reactors or future  defense activities, or greater than class C nuclear waste. According to  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.
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 thate  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 tor  and that geologic disposal would be available in 50 to 60 years beyond a  NRC is currently considering whether to republish its  reactor’s life. 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 sites storing spent nuclear fuel is likely to continue to grow until an  alternative is implemented.  s of June 2009, and the number of reactor  Implementing a permanent, safe, and secure disposal solution for the  nuclear waste is of concern to the nation, particularly state governmentsand local communities, because many of the 80 sites where nuclear wast e  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  for  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 ions  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 review would include limitations on certain nuclear waste shipments to  Hanford until the process of immobilizing tank waste in glass begins,  tal  expected in 2019. 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  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. 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.
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.
section_title: The Yucca Mountain Repository Would Provide a Permanent Solution for Nuclear Waste, but Its Implementation Faces Challenges and Significant Upfront Costs
paragraphs: 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. 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.
subsections: section_title: As Designed, the Yucca Mountain Repository Would Be a Permanent Solution and Would Reduce the Uncertainty Associated with Future Nuclear Waste Safety
paragraphs: 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. 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  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. 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 thin- out 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 near- term, permanent disposal pathway for it. Moreover, DOE has agreed to  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. 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  substantially affect the ultimate total liability. 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.
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. 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. Some experts stated that the  current generation has a moral obligation to not pass on to future  generations the extensive technical and financial responsibilities for  managing nuclear waste in surface storage.
section_title: Yucca Mountain Faces Many Challenges, Including a Lack of Key Support and License Approval
paragraphs: 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. 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.
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  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  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.
section_title: 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
paragraphs: 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.
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.
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  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.
section_title: We Identified Two Nuclear Waste Management Alternatives and Developed Cost Models by Consulting with Experts
paragraphs: 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.
subsections: section_title: We Consulted with Experts to Identify and Develop Assumptions for Two Generic Alternatives to Analysis
paragraphs: 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  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.
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.
section_title: We Developed Cost Ranges for Each Alternative Using Models Large-scale Cost that Addressed Uncertainties and Discounted Future Costs
paragraphs: 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 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 metric  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 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.
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  uncertainties associated with a large number of cost inputs and  assumptions. Using a Monte Carlo simulation process, 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.)
section_title: Centralized Storage Would Provide a Near- Term Alternative, Allowing Other Options to Be Studied, but Faces Implementation Challenges
paragraphs: 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.
subsections: section_title: Centralized Storage Would Provide a Near-Term Alternative to Managing Nuclear Waste but Does Not Eliminate the Need for Final Disposal
paragraphs: 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 long- term 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  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  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.
section_title: Legal and Community Challenges Contribute to the Complexity of Implementing Centralized Storage
paragraphs: 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. 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  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.
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.” 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  repository. 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.
section_title: Cost Ranges for Centralized Storage Will Vary Depending on Waste Volume and Final Disposition
paragraphs: 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 dry- cask 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.)
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.
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. 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.  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.
section_title: On-Site Storage Would Provide an Intermediate Option with Minimal Effort but Poses Challenges that Could Increase Over Time
paragraphs: 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.
subsections: section_title: On-Site Storage Would Require Minimal Near- Term Logistics and Provide Time to Decide on Long- Term Waste Management Strategies
paragraphs: 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  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.
section_title: On-Site Storage Poses Legal, Community, and Technical Challenges that Are Likely to Intensify over Time
paragraphs: 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. 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  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 on- site 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  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.
section_title: Cost Ranges for On-Site Storage Will Vary Depending on Waste Volume, Final Disposition, and Duration of Storage
paragraphs: 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.)
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  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 location- specific 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 on- site 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.
section_title: Concluding Observations
paragraphs: 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  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.
section_title: Agency Comments
paragraphs: 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.
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.
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  are listed in appendix VII.
section_title: Appendix I: Scope and Methodology
paragraphs: 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.
subsections: section_title: Developing Information on Key Attributes, Challenges, and Costs of Yucca Mountain
paragraphs: 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. 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  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.
section_title: Examining and Identifying Nuclear Waste Management Alternatives
paragraphs: 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 DOE- managed 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 on- site storage. Within each of these alternatives, we identified different  scenarios that examined the costs associated with the management of  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.)
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  fuel and high-level waste at DOE’s Idaho National Laboratory, Hanford  Reservation, Savannah River Site, and West Valley site.
section_title: Developing Information on Key Attributes, Challenges, and Costs of the Centralized Storage and On-Site Storage Alternatives
paragraphs: 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.
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.
section_title: Appendix II: Our Methodology for Obtaining Comments from Nuclear Waste Management Experts
paragraphs: 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).
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. These experts also represented a range of viewpoints  on the Yucca Mountain repository. Each of their responses was compiled  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  our model assumptions and cost data based on the expert comments  received.
section_title: Appendix III: Nuclear Waste Management Experts We Interviewed
subsections: section_title: Affiliation
paragraphs: U.S. Nuclear Waste Technical Review Board (member)
National Academy of Sciences/Nuclear and Radiation Studies Board  U.S. Nuclear Waste Technical Review Board (member)
California State University, Northridge  U.S. Nuclear Waste Technical Review Board (retired) (staff)
DOE/Office of Civilian Radioactive Waste Management (retired)
DOE/Office of Civilian Radioactive Waste Management  Nuclear Regulatory Commission (NRC)/Division of Spent Fuel Storage and Transportation  State of Nevada Agency for Nuclear Projects  NRC/Office of Nuclear Security and Incident Response  Dominion Resources, Inc.
Idaho Department of Environmental Quality  The Yankee Nuclear Power Companies  U.S. Nuclear Waste Technical Review Board (member)
M.S. Chu & Associates  University of Nevada Las Vegas  Nuclear and Radiation Studies Board, National Research Council of the National Academies  U.S. Department of Justice/Civil Division  NRC/Division of High Level Waste Repository Safety  Lawrence Livermore National Laboratory (retired)
Nuclear and Radiation Studies Board, National Research Council of the National Academies  U.S. Nuclear Waste Technical Review Board (member)
State of Nevada Nuclear Waste Project Office  U.S. Nuclear Waste Technical Review Board (chairman)
Department of Defense/Department of the Navy  Bechtel SAIC Company, LLC  University of New Mexico  Nuclear and Radiation Studies Board, National Research Council of the National Academies  Bechtel SAIC Company, LLC  Transportation Advisor, State of Nevada Agency for Nuclear Projects  DOE/Office of Civilian Radioactive Waste Management  Bechtel SAIC Company, LLC  Bechtel SAIC Company, LLC  DOE/Office of Civilian Radioactive Waste Management  Department of Defense/Department of the Navy  U.S. Nuclear Waste Technical Review Board (member)
Stanford University  Lawrence Livermore National Laboratory  Nuclear and Radiation Studies Board, National Research Council of the National Academies  Council of State Governments, Midwestern Office  U.S. Nuclear Waste Technical Review Board (member)
NRC/Division of High Level Waste Repository Safety  DOE/Office of Civilian Radioactive Waste Management  Nye County, State of Nevada  DOE/Office of Civilian Radioactive Waste Management  DOE/Office of Civilian Radioactive Waste Management  U.S. Nuclear Waste Technical Review Board (member)
Institute for Energy and Environmental Research  Department of Defense/Department of the Navy  Carnegie Institution for Science  Nuclear and Radiation Studies Board, National Research Council of the National Academies  Department of Defense/Department of the Navy  Department of Defense/Department of the Navy  U.S. Nuclear Waste Technical Review Board (member)
U.S. Nuclear Waste Technical Review Board (member)
Utah Department of Environmental Quality  Transnuclear, Inc.
National Association of Regulatory Utility Commissioners  Nuclear Information and Resource Service  Bechtel SAIC Company, LLC  University of California at Berkeley  U.S. Nuclear Waste Technical Review Board (member)
DOE/Office of Civilian Radioactive Waste Management  U.S. Nuclear Waste Technical Review Board (staff)
U.S. Nuclear Waste Technical Review Board (staff)
National Conference of State Legislators  Department of Defense/Department of the Navy  DOE/Office of Civilian Radioactive Waste Management  DOE/Office of Civilian Radioactive Waste Management  Energy Resources International, Inc.
Mike Thorne and Associates Limited  Bechtel SAIC Company, LLC  Dominion Resources, Inc.
section_title: Appendix IV: Modeling Methodology, Assumptions, and Results
paragraphs: 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.
subsections: section_title: Modeling Methodology
paragraphs: 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. For ease of  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. 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. 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.
section_title: Monte Carlo Simulation Process
paragraphs: 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.
section_title: Discount Rates and Present Value Analysis
paragraphs: 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.
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.
section_title: Individual Models
paragraphs: 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    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 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.
subsections: section_title: Model I: Centralized Storage (153,000 metric tons)
paragraphs: 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  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.
section_title: Model II: Centralized Storage (70,000 metric tons)
paragraphs: 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.
section_title: Model III: On-Site Storage (153,000 metric tons)
paragraphs: 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  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.
section_title: Model IV: On-Site Storage (70,000 metric tons)
paragraphs: 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.
section_title: Costs for a Permanent Repository
paragraphs: 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.
section_title: Modeling Results
paragraphs: Table 8 shows the results of our analysis for all scenarios.
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 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.
section_title: Modeling Caveats
paragraphs: 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.
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  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.
section_title: Appendix V: Comments from the Department of Energy
section_title: Appendix VI: Comments from the Nuclear Regulatory Commission
section_title: Appendix VII: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.