The transportation of large amounts of spent fuel to an interim storage or permanent disposal location is inherently complex and the planning and implementation may take decades to accomplish. The actual time it would take depends on a number of variables including distance, quantity of material, mode of transport, rate of shipment, level of security, and coordination with state and local authorities. For example, according to officials from a state regional organization we interviewed and the Blue Ribbon Commission report, transportation planning could take about 10 years, in part because routes have to be agreed upon, first responders have to be trained, and critical elements of infrastructure and equipment need to be designed and deployed. As we previously reported, DOE does not have clear legislative authority for either consolidated interim storage or for permanent disposal at a site other than Yucca Mountain and, as such, there is no facility to which DOE can transport commercial spent nuclear fuel. Without clear authority, DOE cannot make the transportation decisions necessary regarding commercial spent nuclear fuel. Specifically, as we reported in November 2009, August 2012, and October 2014, provisions in NWPA that authorize DOE to arrange for consolidated interim storage have either expired or are unusable because they are tied to milestones in the development of a repository at Yucca Mountain that have not been met. DOE officials and experts from industry we interviewed in October 2014 agreed with this assessment, and noted that the federal government's ability to site, license, construct, and operate a consolidated interim storage facility not tied to Yucca Mountain depends on new legislative authority. For permanent disposal, we reported in April 2011, that developing a permanent repository other than Yucca Mountain will restart the likely time-consuming and costly process of siting, licensing, and developing such a repository and it is uncertain what legislative changes might be needed, if any, to develop a new repository. In part, this is because NWPA, as amended, directs DOE to terminate all site specific activities at candidate sites other than Yucca Mountain. GAO-11-229. As we reported in October 2014, experts identified technical challenges that could affect the transportation of spent nuclear fuel and these challenges could be resolved with sufficient time. The three technical challenges the experts described were (1) uncertainties related to the safety of high burn-up fuel during transportation,nuclear fuel to be transported under current guidelines, and (3) sufficiency of the infrastructure to support transportation. (2) readiness of spent Before 2000, most fuel discharged from U.S. nuclear power reactors was considered low burn-up fuel and, consequently, the industry has had decades of experience in transporting it. As we reported in October 2014, various reports from DOE, NRC, the Electric Power Research Institute, and the Nuclear Waste Technical Review Board, as well as experts we interviewed, agreed that uncertainties exist on how long high burn-up fuel--used for about 10 years-- can be stored and then still be safely transported. Once sealed in a canister, the spent fuel cannot easily be inspected for degradation. We reported that as of August 2014, NRC officials told us that they had analyzed laboratory tests and models developed to predict the changes that occur during dry storage and that the results indicate that high burn-up fuel will maintain its integrity over very long periods of storage and can eventually be safely transported. However, NRC officials said they continued to seek additional evidence to confirm their position that long-term storage and transportation of high burn-up spent nuclear fuel is safe. We also reported that DOE and the Electric Power Research Institute have planned a joint development project to test high burn-up fuel for degradation, but those results will not be available for about a decade. As we reported in October 2014,storage of spent nuclear fuel allow higher temperatures and external radiation levels than guidelines for transporting the fuel, some of the spent nuclear fuel in dry storage may not be readily transportable. For example, according to the Nuclear Energy Institute, as of 2012, only about 30 percent of spent nuclear fuel currently in dry storage is cool because the guidelines governing dry enough to be directly transportable. For safety reasons, transportation guidelines do not allow the surface of the transportation cask to exceed 185 degrees Fahrenheit (85 degrees Celsius) because the spent nuclear fuel is traveling through public areas using the nation's public transportation infrastructure. NRC's guidelines on spent nuclear fuel dry storage limit spent nuclear fuel temperature to 752 degrees Fahrenheit (400 degrees Celsius). Scientists from the national laboratories and experts from industry we interviewed suggested three options for dealing with the stored spent nuclear fuel so it can be transported safely: (1) leave it to cool and decay at reactor sites, (2) repackage it into smaller canisters that reduce the heat and radiation, or (3) develop a special transportation "overpack" to safely transport the spent nuclear fuel in the current large canisters. However, as we reported in August 2012, spent nuclear fuel stored at reactor sites that had already shut down and dismantled their infrastructure may pose an even more difficult challenge because the ability to repackage the fuel or develop similar solutions may be limited without building additional infrastructure, such as a special transfer facility, or the spent fuel would need to be shipped to a site that had a transfer facility. See DOE, Office of Fuel Cycle and Research Development, A Project Concept for Nuclear Fuels Storage and Transportation, FCRD-NFST-2013-000132 Rev. 1 (June 15, 2013). 2013, DOE completed a preliminary technical evaluation of options available and needed infrastructure for DOE or a new waste management and disposal organization to transport spent nuclear fuel from shut-down sites to a consolidated interim storage facility. According to DOE officials, there was no need to make a decision regarding how best to move forward with the study results because there was, at that time, no site and no authorization to site, license, construct, and operate a consolidated interim storage facility. We also reported in October 2014 that procuring qualified railcars may be a time-consuming process, in part because of the design, testing, and approval for a railcar that meets specific Association of American Railroads standards for transporting spent nuclear fuel. As we found in October 2014, public acceptance is key to any aspect of a spent nuclear fuel management and disposition program, including transportation. Specifically, unless and until there is a broad understanding of the issues associated with management of spent nuclear fuel, specific stakeholders and the general public may be unlikely to support any spent nuclear fuel program. In particular, a program that has not yet been developed or for which a site has not been identified may have challenges in obtaining public acceptance. This finding is not new and, in April 2011 and in October 2014 we found reports spanning several decades that identified societal and political opposition as the key For example, in 1982, the obstacles to spent nuclear fuel management.congressional Office of Technology Assessment reported that public and political opposition were key factors to siting and building a repository. The National Research Council of the National Academies reiterated this conclusion in a 2001 report, stating that the most significant challenge to siting and commencing operations at a repository is societal. Our analysis of stakeholder and expert comments indicates the societal and political factors opposing a repository are the same for a consolidated interim storage facility. Moreover, we reported in April 2011 and October 2014 that any spent nuclear fuel management program is going to take decades to develop and to implement and that maintaining public acceptance over that length of time will face significant challenges. We also reported in November 2009, that the nation could not be certain that future generations would have the willingness or ability to maintain decades-long programs we put into place today.nuclear fuel more than once, which may be required if some spent nuclear fuel is moved to an interim storage facility prior to permanent disposal. Some stakeholders have voiced concerns that because of this opposition to multiple transport events, a consolidated interim storage site may become a de facto permanent storage site. Of particular concern is having to transport spent In October 2014, we reported that according to experts and stakeholders, social media has been used effectively to provide information to the public through coordinated outreach efforts by organizations with an interest in spent nuclear fuel policy. Some of these organizations oppose DOE's strategy and the information they distribute reflects their agendas. In contrast, we reported that DOE had no coordinated outreach strategy, including social media. We concluded that in the absence of a coordinated outreach strategy by DOE, specific stakeholders and the general public may not have complete or accurate information about the agency's activities, making it more difficult for the federal government to move forward with any policy to manage spent nuclear fuel. We recommended that DOE develop and implement a coordinate outreach strategy for providing information to specific stakeholders and the general public on federal activities related to managing spent nuclear fuel--which would include transportation planning. DOE generally agreed with our recommendation. Chairman Shimkus, Ranking Member Tonko, and Members of the Subcommittee, this concludes my prepared statement. I would be pleased to respond to any questions you may have at this time. If you or your staff members have any questions about this testimony, please contact me at (202) 512-3841 or ruscof@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this testimony. Karla Springer (Assistant Director), and Antoinette Capaccio, Robert Sanchez, and Kiki Theodoropoulos also made key contributions to this testimony. This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.

Summary:
Spent nuclear fuel--the used fuel removed from commercial nuclear power reactors--is an extremely harmful substance if not managed properly. The nation's inventory of spent nuclear fuel has grown to about 72,000 metric tons currently stored at 75 sites in 33 states, primarily where it was generated. Under the Nuclear Waste Policy Act of 1982, DOE was to investigate Yucca Mountain, a site about 100 miles northwest of Las Vegas, Nevada, for the disposal of spent nuclear fuel. DOE terminated its work at Yucca Mountain in 2010 and now plans to transport the spent nuclear fuel to interim storage sites beginning in 2021 and 2024, then to a permanent disposal site by 2048. Transportation of spent nuclear fuel is a major element of any policy adopted to manage and dispose of spent nuclear fuel. This testimony discusses three key challenges related to transporting spent nuclear fuel: legislative, technical, and societal. It is based on reports GAO issued from November 2009 to October 2014. Based on its prior work, GAO found three key challenges related to the transportation of spent nuclear fuel: legislative, technical, and societal. Societal challenges . As GAO reported in October 2014, public acceptance is key for any aspect of a spent nuclear fuel management and disposition program--including transporting it--and maintaining that acceptance over the decades needed to implement a spent fuel management program is challenging. In that regard, GAO reported that in order for stakeholders and the general public to support any spent nuclear fuel program--particularly one for which a site has not been identified--there must be a broad understanding of the issues associated with management of spent nuclear fuel. Also, GAO found that some organizations that oppose DOE have effectively used social media to promote their agendas to the public, but that DOE had no coordinated outreach strategy, including social media. GAO recommended that DOE develop and implement a coordinated outreach strategy for providing information to the public on their spent nuclear fuel program. DOE generally agreed with GAO's recommendation. GAO is making no new recommendations.