Nuclear Nonproliferation: DOE Action Needed to Ensure Continued  
Recovery of Unwanted Sealed Radioactive Sources (15-APR-03,	 
GAO-03-483).							 
                                                                 
Potentially dangerous sealed sources containing 		 
greater-than-Class-C radioactive material pose a threat to	 
national security because terrorists could use them to make	 
"dirty bombs." Public Law 99-240 requires the Department of	 
Energy (DOE) provide a facility for disposing of unwanted	 
sources. Because DOE has no disposal facility for these sources, 
its Off-Site Source Recovery Project is recovering and		 
temporarily storing them at Los Alamos, New Mexico. GAO was asked
to determine (1) the number of unwanted sealed sources that DOE  
plans to recover through 2010 and the estimated cost, (2) the	 
status of recovery efforts and any problems that DOE may face,	 
and (3) the status of DOE's efforts to provide a disposal	 
facility for these sealed sources				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-483 					        
    ACCNO:   A06662						        
  TITLE:     Nuclear Nonproliferation: DOE Action Needed to Ensure    
Continued Recovery of Unwanted Sealed Radioactive Sources	 
     DATE:   04/15/2003 
  SUBJECT:   Counterterrorism					 
	     Radioactive wastes 				 
	     Terrorism						 
	     Radioactive waste disposal 			 
	     Bombs						 
	     Hazardous substances				 
	     National preparedness				 
	     DOE Off-Site Source Recovery Project		 

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GAO-03-483

Report to the Ranking Minority Member, Subcommittee on Financial
Management, the Budget, and International Security, Committee on
Governmental Affairs, U. S. Senate

United States General Accounting Office

GAO

April 2003 NUCLEAR NONPROLIFERATION

DOE Action Needed to Ensure Continued Recovery of Unwanted Sealed
Radioactive Sources

GAO- 03- 483

The exact number of unwanted greater- than- Class- C sealed sources in the
United States is unknown, but DOE estimates it will recover about 14,300
such sources by the end of fiscal year 2010, at a total cost of about $69
million. DOE*s estimate of the number of sealed sources it will recover
was based on three assumptions* that a permanent disposal facility would
be available by fiscal year 2007; that the Off- Site Source Recovery
Project*s recovery operations would be phased out from fiscal years 2007
through 2010; and that, after fiscal year 2010, all sealed sources would
be sent directly to a disposal facility and the project would cease
operations.

Through February 2003, DOE*s Off- Site Source Recovery Project had
recovered more than 5,000 greater- than- Class- C sealed sources from
about 160 sites across the United States; however, the project faces three
problems that could hinder future recovery efforts. First, the project is
not a priority

with DOE*s Office of Environmental Management, because, according to
office officials, the project does not conform with the mission of the
office. The project did not receive full funding, even after September 11,
2001,

because of the Office of Environmental Management*s other higher priority
projects, and the office*s current budget specifies future annual funding
levels that, according to project officials, would be insufficient to
enable the project to recover additional sealed sources. Second, DOE
cannot recover any additional sealed sources containing plutonium- 239
because the project has already run out of space at the Los Alamos
National Laboratory that meets DOE*s higher security standards for storing
these sources. Third, DOE has not approved a means for storing sealed
sources containing strontium- 90 and cesium- 137 until a permanent
disposal facility is available.

As of February 2003, more than 17 years after the enactment of Public Law
99- 240, DOE had not made progress toward providing for the permanent
disposal of greater- than- Class- C radioactive sealed sources, as
required by the act. Specifically, DOE had not assigned responsibility to
an office within DOE to begin developing such a facility. Also, according
to DOE officials, DOE lacks a plan for ensuring the continued recovery of
sealed sources in the likely event that the disposal facility is delayed
beyond fiscal year 2007.

Example of a Radioactive Sealed Source That Contains Americium- 241

NUCLEAR NONPROLIFERATION

DOE Action Needed to Ensure Continued Recovery of Unwanted Sealed
Radioactive Sources

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 483. To view the full report,
including the scope and methodology, click on the link above. For more
information, contact Gene Aloise, 202- 512- 3841, aloisee@ gao. gov.
Highlights of GAO- 03- 483, a report to the Ranking Minority Member,
Subcommittee

on Financial Management, the Budget, and International Security, Committee
on Governmental Affairs, United States Senate

April 2003

Potentially dangerous sealed sources containing greater- thanClass- C
radioactive material pose a threat to national security because terrorists
could use them to make *dirty bombs.* Public Law 99- 240

requires the Department of Energy (DOE) provide a facility for disposing
of unwanted sources. Because DOE has no disposal facility for these
sources, its OffSite Source Recovery Project is recovering and temporarily
storing them at Los Alamos, New Mexico. GAO was asked to determine (1)

the number of unwanted sealed sources that DOE plans to recover through
2010 and the estimated cost, (2) the status of recovery efforts and any
problems that DOE may face, and (3) the status of DOE*s efforts to provide
a disposal

facility for these sealed sources. GAO recommends that the Secretary of
Energy (1) determine whether the priority given to the project is
commensurate with the

threat these sources pose; (2) ensure adequate resources are devoted to
the project; (3) take immediate action to provide space to store sealed
sources containing plutonium- 239, strontium- 90, and

cesium- 137; (4) initiate the process to develop a permanent disposal
facility for greater- than- Class- C radioactive waste; and (5) develop a
plan to ensure the continued

recovery of greater- than- Class- C waste until a disposal facility is
available. DOE did not comment on our recommendations.

Page i GAO- 03- 483 Nuclear Nonproliferation Letter 1 Results in Brief 3
Background 5 The Exact Number of Unwanted Greater- Than- Class- C Sealed
Sources Is Unknown, but DOE Plans to Recover About 14,000

Sealed Sources by the End of Fiscal Year 2010 at an Estimated Cost of
About $69 Million 9 DOE Has Recovered a Large Number of Sources, but
Unresolved

Problems Could Hinder Future Recovery Efforts 13 DOE Has Not Made Progress
toward Providing a Permanent Disposal Facility 25 Conclusions 28
Recommendations for Executive Action 29 Agency Comments 29 Scope and
Methodology 30 Appendix I Sections 1, 2, and 3 of the Low- Level
Radioactive

Waste Policy Amendments Act of 1985, Public Law 99- 240 33

Appendix II Comments from the Department of Energy 37

Tables

Table 1: Estimated Number of Greater- Than- Class- C Sealed Sources DOE
Plans to Recover Annually, Fiscal Years 1999 through 2010 11 Table 2:
Number of Each Type of Greater- Than- Class- C Sealed

Source that DOE Plans to Recover by the End of Fiscal Year 2010 12 Table
3: Estimated Annual Cost to Complete the Recovery of 14,309 Greater- Than-
Class- C Sealed Sources, Fiscal Years

2002 through 2011 12 Table 4: Estimated Total Cost to Complete Remaining
Recovery and Closeout Activities, as of Fiscal Year 2002 13 Table 5:
Number of Each Type of Greater- Than- Class- C Sealed Source Recovered and
Associated Grams and Curies of Radioactive Material, as of February 2003
14 Contents

Page ii GAO- 03- 483 Nuclear Nonproliferation

Table 6: Number of Each Type of Greater- Than- Class- C Sealed Source
Awaiting Recovery and Associated Number of Holders and Grams and Curies of
Radioactive Material, as of February 2003 17 Figures

Figure 1: The Off- Site Source Recovery Project*s Process for Recovering
Greater- Than- Class- C Sealed Sources 7 Figure 2: Photograph of a
Structure at the Los Alamos National

Laboratory in Which Greater- Than- Class- C Sealed Sources Recovered by
the Off- Site Source Recovery Project Are Stored as Waste 8 Figure 3:
Greater- Than- Class- C Sealed Sources Recovered by State,

as of February 2003 16 Figure 4: Greater- Than- Class- C Sealed Sources in
Need of Recovery by State, as of February 2003 19 Abbreviations

DOE Department of Energy NEPA National Environmental Policy Act of 1969
NRC Nuclear Regulatory Commission

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Page 1 GAO- 03- 483 Nuclear Nonproliferation April 15, 2003 The Honorable
Daniel K. Akaka Ranking Minority Member

Subcommittee on Financial Management, the Budget, and International
Security Committee on Governmental Affairs United States Senate

Dear Senator Akaka: Since the terrorist attacks of September 11, 2001,
there has been a great deal of concern about the control of sealed sources
containing radioactive material used in medicine, agriculture, research,
and industry throughout the United States. The radioactive material in
these sealed sources is encapsulated, or sealed, in metal* such as
stainless steel, titanium, or platinum* to prevent its dispersal. The
small size and portability of the sealed sources make them susceptible to
misuse, improper disposal, and theft. If these sealed sources fell into
the hands of terrorists, they could be used as simple and crude but
potentially dangerous radiological weapons,

commonly called dirty bombs. In general, a dirty bomb is produced by
packaging explosives, such as dynamite, with radioactive material, which
would be dispersed when the bomb went off. The radioactive material
dispersed* depending on the type, form (e. g., solid or powder), amount,
and concentration* could cause radiation sickness for people nearby as
well as the serious economic costs and social disruption associated with
the evacuation and subsequent cleanup of the contaminated area.

Certain sealed sources are considered particularly attractive for
potential use in producing dirty bombs because, among other things, they
contain more concentrated amounts of nuclear material known as *greater-
thanClass- C material** typically americium- 241, cesium- 137, plutonium-
238,

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 03- 483 Nuclear Nonproliferation plutonium- 239, and
strontium- 90. 1 Applications of greater- than- Class- C sealed sources
include portable and fixed gauges used in commercial

manufacturing processes, gauges used by the construction industry for
testing the moisture content of soil, medical pacemakers, medical
diagnostics and treatments, gauges used for petroleum exploration, and
government and private research and development.

The Low- Level Radioactive Waste Policy Amendments Act of 1985, Public Law
99- 240, requires the Department of Energy (DOE) to provide a facility for
disposing of all greater- than- Class- C radioactive waste, including
greater- than- Class- C sealed sources that are no longer wanted by their
owners, but DOE has not yet developed a disposal facility (see app. I).
Until a disposal facility is available, DOE created the Off- Site Source
Recovery Project, which, since fiscal year 1999, has been recovering
unwanted greater- than- Class- C sealed sources from their owners and
temporarily storing them at the Los Alamos National Laboratory in Los
Alamos, New Mexico. Currently, owners of unwanted greater- than- Class- C
sealed sources must continue to store and secure their sources on their
premises until either DOE recovers and temporarily stores them or a
disposal facility becomes available. Once a permanent disposal facility
becomes available, source holders will be able to send their sources
directly to the facility, and the sources that DOE is storing at Los
Alamos will be transferred to the facility for permanent disposal.

To assess DOE*s progress toward improving its control of greater-
thanClass- C sealed sources, you asked us to determine (1) the number of
greater- than- Class- C sealed sources that are unwanted, the number that
DOE plans to recover and dispose of through 2010, and the estimated cost
and schedule to recover and temporarily store these sources until a
permanent disposal facility is available; (2) the status of recovery
efforts to date and any problems that DOE may face in recovering and
temporarily storing greater- than- Class- C sealed sources; and (3) the
status of DOE*s

1 The Nuclear Regulatory Commission classifies low- level radioactive
waste (i. e., waste not specifically classified as high- level waste, such
as used fuel rods from nuclear power plants) as A, B, or C for the purpose
of disposal. Radioactive waste is classified by type of radionuclide (e.
g., americium- 241) and concentration of radioactivity (often measured in
curies per gram). Class A, B, and C radioactive wastes must meet
progressively more stringent requirements for disposal. Class A, B, and C
wastes (e. g., exit signs containing tritium and contaminated soil or lab
equipment) generally can be disposed of at existing commercial disposal
facilities. Wastes that exceed the Nuclear Regulatory Commission*s
criteria for Class C, known as greater- than- Class- C wastes, generally
cannot be disposed of at existing facilities.

Page 3 GAO- 03- 483 Nuclear Nonproliferation efforts to meet the
requirements of Public Law 99- 240 to provide long- term disposal for
greater- than- Class- C radioactive waste. To address these objectives,
we, among other things, visited the Off- Site Source Recovery

Project office at the Los Alamos National Laboratory to observe the
storage facilities and interview project officials, reviewed studies
estimating the number of greater- than- Class- C sealed sources and DOE*s
budget documents, and analyzed data on the progress of recovery efforts.
This report is the first of three we are preparing at your request to
examine efforts to control sealed radiological sources. Forthcoming
reports will

review domestic and international efforts to control these sources beyond
those of the Off- Site Source Recovery Project. The exact number of
unwanted greater- than- Class- C sealed sources is unknown but DOE*s Off-
Site Source Recovery Project officials estimate they will recover about
14,300 unwanted greater- than- Class- C sealed sources by the end of
fiscal year 2010, at an estimated total cost of about $69 million. These
officials told us that the number of unwanted greaterthan- Class- C sealed
sources that would be recovered is a rough estimate, which was derived by
reviewing, among other information, studies completed by the Nuclear
Regulatory Commission and DOE*s Idaho National Engineering Laboratory and
information provided by sealed source manufacturers. Although the Idaho
National Engineering Laboratory study estimated that there currently could
be about 250,000 to 500,000 greater- than- Class- C sealed sources in the
United States, the actual number of greater- than- Class- C sealed sources
that are no longer wanted is not known because no one kept track of this
information. The estimate

of the number of greater- than- Class- C sealed sources that DOE*s project
will recover is based on three assumptions* that a permanent disposal
facility for greater- than- Class- C sealed sources will be available by
fiscal year 2007; that the Off- Site Source Recovery Project will continue
to recover sources from certain holders of sources during a transition
period from fiscal year 2007 through fiscal year 2010; and that, after
fiscal year 2010, all greater- than- Class- C sealed sources will be sent
directly to the disposal facility and the Off- Site Source Recovery
Project will cease operations.

As of February 2003, DOE*s Off- Site Source Recovery Project had recovered
more than 5,000 greater- than- Class- C sealed sources from about 160
sites across the United States; however, the project faces three problems
that could hinder future recovery efforts. These problems include the
questionable long- term commitment of DOE*s Office of Environmental
Management to the project, inadequate storage capacity Results in Brief

Page 4 GAO- 03- 483 Nuclear Nonproliferation that meets the higher
security needs of sealed sources containing plutonium- 239, and the lack
of a means for temporarily storing sealed

sources containing strontium- 90 and cesium- 137. With regard to the first
problem, officials from DOE*s Office of Environmental Management, which is
responsible for the Off- Site Source Recovery Project, told us that they
would like the responsibility for the project to be placed in another DOE
office because the mission of the project is inconsistent with the mission
of the Office of Environmental Management. They also told us that the
project did not receive full funding, even after September 11, 2001,

because of other higher priority projects, and current Office of
Environmental Management budget documents specify future annual funding
levels that, according to project officials, would limit the project*s
ability to recover additional greater- than- Class- C sealed sources.
Without funding available to the Off- Site Source Recovery Project to
recover additional sources, owners of unwanted greater- than- Class- C
sealed sources will be forced to store and secure their sources on their
premises until a disposal facility is available.

Further, the Off- Site Source Recovery Project cannot recover any
additional greater- than- Class- C sealed sources containing plutonium-
239 because there is no more space at the Los Alamos National Laboratory
that meets DOE*s security standards for storing these sources. As a
result, about 150 holders of unwanted sources containing plutonium- 239,
most of which are universities, must retain them and keep them properly
secured until space becomes available. Although this nuclear material
requires

special security measures because of its potential for use in a crude
nuclear bomb, two holders of these sources have told us of instances in
which doors to the rooms containing unwanted greater- than- Class- C
sealed sources were left unlocked and open, and most holders expressed
their desire to dispose of the sources as quickly as possible. In
addition, DOE has not approved a means for temporarily storing strontium-
90 and cesium- 137 at a DOE facility until a permanent disposal facility
is developed as DOE has done for the other types of radioactive materials
contained in the sealed sources it needs to recover. According to DOE, it
recognizes these problems and is developing options to resolve them. Our
report recommends that DOE determine whether the priority that it is
giving the project is commensurate with the risks these sealed sources
pose, ensure adequate resources are devoted to the project, and provide,
as soon as possible, storage space for sealed sources containing
plutonium- 239, strontium- 90, and cesium- 137 with the appropriate level
of security.

Page 5 GAO- 03- 483 Nuclear Nonproliferation As of February 2003, DOE*s
Office of Environmental Management had not made progress toward providing
for the permanent disposal of greaterthan-

Class- C radioactive waste, and it is unlikely to provide such a facility
by fiscal year 2007, as previously assumed, because it is not a priority
with the office. Specifically, the office had not begun the first step in
developing a disposal facility* completing an appropriate analysis as
required by the National Environmental Policy Act of 1969 and implementing
regulations, which would likely be an Environmental Impact Statement.
Officials from DOE*s Office of Environmental Management told us that the
office had

provided funding for fiscal years 2002 and 2003 to develop such an
analysis, but that after the office reviewed the budget in February 2002,
it reallocated these funds to other priorities. These officials also told
us that DOE is considering moving the responsibility for developing the
analysis to another office within DOE, and they anticipate that this
decision will be made some time in fiscal year 2003. In an Environmental
Impact Statement, which Office of Environmental Management officials say
could take 2 years to develop, DOE could propose that either a new
disposal facility be built or an existing facility be used. If a new
facility were decided upon, developing it could take at least 7 years,
according to DOE*s estimates. If an existing facility were selected,
disposal services could be provided sooner, depending upon the
availability of the facility. For example, DOE has been exploring the
possibility of sending greater- thanClass- C sealed sources containing
plutonium- 239 to an existing facility, its Waste Isolation Pilot Plant
located in Carlsbad, New Mexico, but it remains uncertain when or if this
will be possible. Finally, according to Office of Environmental Management
officials, DOE does not have a plan for recovering greater- than- Class- C
sealed sources in the event that the

disposal facility is delayed. Our report recommends that DOE initiate the
process to provide a permanent disposal facility for greater- than- Class-
C waste, develop a plan to help manage this process, and develop a plan to
ensure the continued recovery and storage of greater- than- Class- C
sealed

sources in the likely event that availability of the disposal facility is
delayed beyond fiscal year 2007.

The Nuclear Regulatory Commission (NRC) regulates medical, industrial, and
research uses of radioactive materials through a combination of
activities, including regulatory requirements; licensing; and safety
oversight, including inspection and enforcement. NRC issues licenses for
the ownership of radioactive material and for the possession and use of
this material in certain items, such as sealed sources. NRC licensees
include medical, industrial, and academic organizations. In addition, NRC
has delegated its licensing authority to 32 states, called *agreement
states.* Background

Page 6 GAO- 03- 483 Nuclear Nonproliferation These agreement states
administer 76 percent of the licensees while NRC administers the remainder
of the licensees.

In the 1970s, DOE began to recover unwanted greater- than- Class- C sealed
sources containing plutonium- 239. Through 1998, DOE recovered more than
1,300 such sealed sources, mainly from universities, and destroyed them by
chemical processing. During this time, the Congress also enacted the Low-
Level Radioactive Waste Policy Amendments Act of 1985, Public Law 99- 240,
which requires the Department of Energy (DOE) to provide a

facility for disposing of all greater- than- Class- C radioactive waste,
including all greater- than- Class- C sealed sources that are no longer
wanted by their owners. However, DOE has not yet developed such a
facility.

Although DOE had no formal program to accept unwanted greater- thanClass-
C sealed sources from their owners, in 1992, the agency established a
working agreement with NRC to address greater- than- Class- C sealed
sources that might cause potential health and safety problems. Between
1993 and 1999, DOE recovered over 40 greater- than- Class- C sealed
sources at the request of NRC. By 1999, however, DOE determined that
chemically processing greater- than- Class- C sealed sources was
expensive, exposed laboratory workers involved in the chemical processing
to unacceptable doses of radioactivity, and created problematic waste that
needed

disposal. In addition, DOE lacked sufficient capacity to process the
growing numbers of greater- than- Class- C sealed sources that were being
reported as unwanted. As a result, DOE determined in 1999 that chemical
processing should be discontinued. That same year, DOE*s Office of

Environmental Management, whose main mission is to clean up DOE*s
contaminated weapons development facilities that DOE plans to close,
created the Off- Site Source Recovery Project to recover and temporarily
store unwanted greater- than- Class- C sealed sources until a disposal
facility was available. The Office of Environmental Management funds and
provides oversight and direction to the project; DOE*s National Nuclear
Security Administration Service Center in Albuquerque, New Mexico,
provides project oversight and direction for the Los Alamos National
Laboratory; and the University of California conducts planning and
recovery operations for DOE at Los Alamos.

The greater- than- Class- C sealed source recovery process begins when a
holder of a source notifies the project that it has no further use for its
source or when NRC or state regulators notify the project that a source
needs to be recovered because it might cause a potential health or safety
problem (see fig. 1).

Page 7 GAO- 03- 483 Nuclear Nonproliferation Figure 1: The Off- Site
Source Recovery Project*s Process for Recovering Greater- Than- Class- C
Sealed Sources

Source: DOE.

Project officials obtain extensive descriptive information about the
source, maintain the information in a database, and work with NRC to use
the information to prioritize recoveries. Once a decision has been made to
recover a greater- than- Class- C sealed source, the recovery effort can
occur in one of three ways: (1) the source holder packages and ships the
source to the Los Alamos National Laboratory; (2) project staff travel to
the source*s location to characterize, package, and ship the source to Los
Alamos; or (3) project subcontractors accomplish the required work for the
project. In any of these cases, the sources may be shipped directly to the
Los Alamos National Laboratory for receipt and storage, or they may

Page 8 GAO- 03- 483 Nuclear Nonproliferation first be shipped to a
subcontractor facility where they are consolidated and stored until a
larger shipment to Los Alamos is prepared. Greaterthan-

Class- C sealed sources sent to the Los Alamos National Laboratory are
either stored as nuclear material under appropriate security or, if
security requirements are waived, may be stored as waste in some of the
same structures as other radioactive waste stored by the laboratory (see
fig. 2).

Figure 2: Photograph of a Structure at the Los Alamos National Laboratory
in Which Greater- Than- Class- C Sealed Sources Recovered by the Off- Site
Source Recovery Project Are Stored as Waste

At the request of the Secretary of Energy and NRC Chairman in June 2002,
the DOE/ NRC Interagency Working Group on Radiological Dispersal Devices
was convened to identify any concerns with the nation*s ability to
adequately protect nuclear materials, including radiological sources, that

can be used in a radiological dispersal device, or dirty bomb. The working
group was tasked to provide a report to the Secretary of Energy and NRC
Chairman detailing recommendations for protecting radioactive materials of
concern. The objectives of the working group were to identify those
radioactive materials of concern for use as a radiological dispersal
device, examine the options for tracking these materials in a national
database

system, assess potential technologies for tagging these materials for
tracking purposes, and identify actions needed to ensure that sources are
secure and that storage and disposal is available for unsecured, excess,

Page 9 GAO- 03- 483 Nuclear Nonproliferation and unwanted sources. The
report provides recommendations that DOE and NRC can pursue to enhance
control of materials that could be used in radiological dispersal devices.
These include coordination with the

Department of Homeland Security and other federal agencies to establish
national policies for defining threats and radiological dispersal device
protection levels, implementing a national source tracking system, and
developing national strategies for recovering and disposing of unsecured
sources. As of February 2003, the report was still in draft.

Neither DOE nor any other government agency has kept track of the number
of greater- than- Class- C sealed sources that are no longer wanted;
therefore, this number is not known with certainty. Also, DOE created the
Off- Site Source Recovery Project to enable DOE to comply with Public Law
99- 240 until a disposal facility became available; hence, the project was
never envisioned as a permanent solution. As a result, before DOE could
estimate the number of greater- than- Class- C sealed sources that the
project would recover, it had to estimate how long the project would be in
operation. In fiscal year 2002, DOE estimated that the Off- Site Source

Recovery Project would operate from fiscal years 1999 through 2010 and,
during that time frame, the project would recover and temporarily store
14,309 unwanted greater- than- Class- C sealed sources. 2 DOE also
estimated the total cost to complete the planned recovery effort at $69.3
million.

To develop its estimate of the number of unwanted greater- than- Class- C
sealed sources it planned to recover, DOE first determined how long the
Off- Site Source Recovery Project would operate. Prior to 1999, DOE*s
activity was limited to recovering and destroying unwanted greater-
thanClass- C sealed sources. At the time, DOE was processing and
destroying up to 100 sealed sources per year. According to a project
official, the rate at which DOE estimated it could process and destroy
sealed sources

played a key role in determining the time frame for Off- Site Source
Recovery Project operations. According to this official, prior to 1999,
DOE planned to increase its processing capability to about 400 sealed
sources

2 As of February 2003, DOE had not modified these estimates. The Exact
Number of

Unwanted GreaterThan- Class- C Sealed Sources Is Unknown, but DOE Plans to
Recover About 14,000 Sealed Sources by the End of Fiscal Year 2010 at an
Estimated Cost of About $69 Million

DOE*s Estimate of How Long the Off- Site Source Recovery Project Will
Operate and How Many Sealed Sources DOE Plans to Recover

Page 10 GAO- 03- 483 Nuclear Nonproliferation annually, and in 1999, DOE
estimated that a backlog of about 4,000 to 5,000 unwanted greater- than-
Class- C sealed sources existed. As a result,

DOE set the time frame for the Off- Site Source Recovery Project at 12
years (fiscal year 1999 through fiscal year 2010), which was approximately
the amount of time DOE estimated it would take to manage the existing
backlog. Although DOE plans to store the sources it recovers instead of
destroying them, the time frame for the project has remained the same.

DOE then estimated the number of greater- than- Class- C sealed sources
that would become unwanted from fiscal year 1999 through fiscal year 2010.
To do this, DOE officials reviewed, among other information, its
preliminary database of about 3,000 unwanted greater- than- Class- C
sealed sources, discussions with representatives from the sealed source
industry, and past studies by NRC and DOE*s Idaho National Engineering

Laboratory, which included surveys of source holders and manufacturers
conducted by NRC and state regulatory agencies. 3 The study by the Idaho
National Engineering Laboratory, completed in 1994 at the request of DOE,
estimated that there could be about 250,000 to 500,000 greater- thanClass-
C sealed sources currently in the United States and as many as 24,000 new
greater- than- Class- C sealed sources are being produced each year.
According to a project official, the estimate of how many of these sealed
sources will become unwanted during the time period that the OffSite
Source Recovery Project is in operation represents a best guess based on
all of the information available.

As such, DOE officials estimated that about 18,000 greater- than- Class- C
sealed sources would become unwanted from fiscal years 1999 through 2010.
DOE initially developed a plan detailing how many of the 18,000 unwanted
greater- than- Class- C sealed sources it planned to recover each fiscal
year. However, DOE later modified the plan to recover 14,309

unwanted greater- than- Class- C sealed sources on the basis of three key
assumptions: (1) that a permanent disposal facility for the sources would
be available by fiscal year 2007; (2) that the Off- Site Source Recovery
Project would continue to recover sources from certain holders of sources

3 Nuclear Regulatory Commission, Above Class C Source/ Device Inventory
Survey

(Washington, D. C.: Nov. 1989) and Idaho National Engineering Laboratory,
Characterization of Greater- Than- Class- C Sealed Sources, Volumes 1, 2,
and 3,

DOE/ LLW- 163 (Idaho Falls, Idaho: Sept. 1994).

Page 11 GAO- 03- 483 Nuclear Nonproliferation during a transition period
from fiscal year 2007 through fiscal year 2010; 4 and (3) that after
fiscal year 2010, all greater- than- Class- C sealed sources would be
shipped by their owners to the disposal facility and the Off- Site

Source Recovery Project would cease operations. 5 Table 1 shows DOE*s plan
for recovering 14, 309 unwanted greater- than- Class- C sealed sources
through the end of fiscal year 2010.

Table 1: Estimated Number of Greater- Than- Class- C Sealed Sources DOE
Plans to Recover Annually, Fiscal Years 1999 through 2010

Fiscal years 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010
Total number of

sources

53 39 2,915 1,325 2,130 2,470 2,332 1,680 675 412 203 75 14,309

Source: DOE. Note: GAO*s presentation of DOE*s data.

According to DOE*s estimates, about 85 percent of the 14,309 greater-
thanClass- C sealed sources that the project plans to recover would
contain americium- 241, with the remainder containing plutonium- 238,
plutonium- 239, and various other radioactive materials (see table 2). DOE
did not specify the number of sealed sources containing cesium- 137 or
strontium- 90 that it planned to recover.

4 According to a project official, DOE assumed that, based on past
experience, owners of small numbers of unwanted greater- than- Class- C
sealed sources initially might have difficulty shipping their sources
directly to a disposal facility without the assistance of the Off- Source
Recovery Project. DOE assumed that by the end of the transition period
these difficulties would be resolved. 5 At 14,309, the number of greater-
than- Class- C sealed sources that DOE plans to recover appears more
precise than it is because DOE reduced the number of sealed sources it
initially planned to recover during the transition years, fiscal years
2007 through 2010, by a certain percentage each year.

Page 12 GAO- 03- 483 Nuclear Nonproliferation Table 2: Number of Each Type
of Greater- Than- Class- C Sealed Source that DOE Plans to Recover by the
End of Fiscal Year 2010

Type of greater- than- Class- C sealed source Number of sources

DOE plans to recover

Americium- 241 12,176 Plutonium- 238 1,722 Plutonium- 239 364 Other 47

Total 14,309

Source: DOE. Note: GAO*s analysis of DOE*s data.

In fiscal year 2002, DOE estimated that it would cost about $56.5 million
to complete the recovery of 14,309 greater- than- Class- C sealed sources
from fiscal years 2002 through 2011 (see table 3). 6 In addition, since
DOE had already spent about $12.7 million on recovery activities from
fiscal years 1999 through 2001, DOE estimated the total cost to recover
the 14,309 sealed sources at about $69.3 million. 7 Table 3: Estimated
Annual Cost to Complete the Recovery of 14,309 Greater- Than- Class- C
Sealed Sources, Fiscal Years 2002

through 2011

(Dollars in millions)

Fiscal years 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 a Total
cost to

complete activities

$5.1 $7.1 $6.7 $8.7 $8.0 $6.7 $4.9 $4.4 $4.5 $0.4 $56.5

Source: DOE. Note: GAO*s presentation of DOE*s data. a The $400,000 cost
estimated for fiscal year 2011 is for project closeout activities.

6 Although DOE planned to cease project operations by the end of fiscal
year 2010, DOE planned project closeout activities for fiscal year 2011.
As of February 2003, DOE had not changed its estimate of the cost to
complete the planned recovery activities. 7 DOE*s $56.5 million estimate
of the cost to complete the recovery of 14, 309 greater- thanClass- C
sealed sources and the $12.7 million that DOE had spent from fiscal years
1999 through 2001 do not add to $69.3 million because of rounding. DOE
Estimates the Total

Cost to Recover 14,309 Sealed Sources at $69.3 Million

Page 13 GAO- 03- 483 Nuclear Nonproliferation Table 4 shows how DOE plans
to spend the $56.5 million the agency estimates it will need to complete
remaining project activities. Table 4: Estimated Total Cost to Complete
Remaining Recovery and Closeout

Activities, as of Fiscal Year 2002

(Dollars in millions)

Activity Estimated cost

Recovering, inspecting, and storing greater- than- Class- C sealed
sources, including planning recoveries, maintaining contracts with
subcontractors, and preparing waste for future permanent disposal

$24.2 Upgrading equipment at Los Alamos and designing, testing, and
acquiring tools and containers for packaging, transporting, and storing
greater- than- Class- C sealed sources

9.0 Conducting other activities supporting project operations, including
overseeing and controlling the quality of project performance, complying
with applicable regulations and requirements, maintaining project data,
training staff, disseminating information, and paying the project*s share
of the costs associated with the Los Alamos National Laboratory*s
management and support staff

11.2 Conducting activities related to planning a disposal facility and
transitioning project operations to this facility, including facilitating
the recovery of nuclear material leased to federal agencies and
universities, characterizing and certifying greater- than- Class- C waste
stored at Los Alamos, transferring the waste to a disposal facility, and
closing out project operations

12.1

Total estimated cost to complete remaining recovery and closeout
activities $56.5

Source: DOE. Note: GAO*s analysis of DOE*s data.

As of February 2003, DOE*s Off- Site Source Recovery Project had recovered
5,294 unwanted greater- than- Class- C sealed sources, but the project
faces three problems that could hinder future recovery efforts. These
problems include the questionable long- term commitment of DOE*s Office of
Environmental Management to the project, the lack of storage capacity
needed to allow the recovery of sealed sources containing plutonium- 239,
and the lack of an approved means for temporarily storing sealed sources
containing strontium- 90 and cesium- 137. DOE Has Recovered a

Large Number of Sources, but Unresolved Problems Could Hinder Future
Recovery Efforts

Page 14 GAO- 03- 483 Nuclear Nonproliferation As of February 2003, the
Off- Site Source Recovery Project had identified and recovered 5,294
unwanted greater- than- Class- C sealed sources, and

owners of an additional 4,380 greater- than- Class- C sealed sources had
reported to DOE that they no longer wanted their sources, but DOE had not
yet recovered them. According to DOE*s estimates, these 4,380 sealed
sources and another 4,635 greater- than- Class- C sealed sources that DOE

estimates are either currently in use or not yet reported as unwanted will
need to be recovered by the end of fiscal year 2010.

About 65 percent of the 5,294 unwanted greater- than- Class- C sealed
sources that DOE had recovered contained the radioactive material
americium- 241, either alone or in combination with cesium- 137, and about
35 percent of the sources recovered contained plutonium- 238 (see table
5). As table 5 shows, DOE had recovered 15 of the 364 sealed sources
containing plutonium- 239 it planned to recover before running out of
storage capacity and had recovered no sealed sources containing strontium-
90. All together, the project has secured almost 2 kilograms of unwanted
radioactive material.

Table 5: Number of Each Type of Greater- Than- Class- C Sealed Source
Recovered and Associated Grams and Curies of Radioactive Material, as of
February 2003

Type of greaterthan- Class- C sealed source Number of

sources recovered

Number of grams of radioactive material

recovered Number of curies

of radioactive material recovered

Americium- 241 3,004 730 2,513 Americium- 241 and Cesium- 137 411 5 24
Curium- 244 2 Less than 1 Less than 1 Plutonium- 238 1,862 489 7,235
Plutonium- 239 15 696 44

Total 5,294 a 1,920 9,816

Source: DOE. Note: GAO*s analysis of DOE*s data. a Total includes 16
greater- than- Class- C sealed sources that DOE recovered before Off- Site
Source

Recovery Project operations began.

The Off- Site Source Recovery Project Has Recovered a Large Number of
Unwanted GreaterThan- Class- C Sealed Sources

Page 15 GAO- 03- 483 Nuclear Nonproliferation These greater- than- Class-
C sealed sources were recovered from 157 sites nationwide. Figure 3 shows
the number of unwanted greater- than- Class- C

sealed sources that DOE recovered from each state. These recoveries
include sealed sources contained in

 1,632 gauges that had been used by the construction industry for testing
the moisture content of soil from a manufacturer in North Carolina who is
consolidating these sources for shipment to Los Alamos and another 231
gauges from a manufacturer in California;

 1,500 gauges used for petroleum exploration from a DOE subcontractor
that is consolidating sources for shipment to Los Alamos and various
companies in Texas; and  588 medical pacemakers from a manufacturer in
Minnesota, 483 from a

manufacturer in Pennsylvania, 233 from a manufacturer in Florida, and 219
from DOE*s Oak Ridge research facility in Tennessee.

Page 16 GAO- 03- 483 Nuclear Nonproliferation Figure 3: Greater- Than-
Class- C Sealed Sources Recovered by State, as of February 2003

Note: GAO*s presentation of DOE*s data. In addition, the project recovered
one source from a site in Puerto Rico.

The 4,380 unwanted greater- than- Class- C sealed sources that awaited
recovery as of February 2003, were estimated to contain about 80.3
kilograms of radioactive material (see table 6). About 80 percent of these
unwanted greater- than- Class- C sealed sources (3,495 out of 4,380)
contained the radioactive material americium- 241, either alone or in
combination with cesium- 137. Table 6 also shows that the Off- Site Source
Recovery Project has identified 85 more sealed sources containing
plutonium- 239 that need to be recovered than it initially estimated

Page 17 GAO- 03- 483 Nuclear Nonproliferation (currently totaling 449 as
compared to the 364 initially estimated). In addition, the project has
identified 46 unwanted strontium- 90 sealed

sources that need to be recovered, which contain about 78 percent (about
62.8 kilograms) of the total amount of radioactive material that needs to
be recovered.

Table 6: Number of Each Type of Greater- Than- Class- C Sealed Source
Awaiting Recovery and Associated Number of Holders and Grams and Curies of
Radioactive Material, as of February 2003

Type of source Number of holders Number of

sources Curies Grams

Americium- 241 193 3,343 11,904 3,542 Americium- 241 and Cesium- 137 19
152 23 3 Californium- 252 a 3 15 22 Less than 1 Cesium- 137 b 9 21 3,435
57 Cobalt- 60 b 1 8 363 2 Curium- 244 6 59 Less than 1 Less than 1
Plutonium- 238 47 282 11,925 881 Plutonium- 239 149 449 812 13,034 Radium-
226 c 5 5 2 2 Strontium- 90 8 46 3,971,315 62,786

Total 440 d 4,380 3,999,801 80,308 e Source: DOE. Note: GAO*s analysis of
DOE*s data. a According to an Off- Site Source Recovery Project official,
because californium- 252 is expensive to

make, all greater- than- Class- C sealed sources containing californium-
252 are recycled. b According to an Off- Site Source Recovery Project
official, owners of 29 sealed sources containing

cesium- 137 or cobalt- 60 have reported to the project that their sources
are no longer wanted. Although most of these sources are not greater than
Class C and could be sent to an existing commercial disposal facility, the
owners for various reasons have been unable to dispose of them. c
According to an Off- Site Source Recovery Project official, because
radium- 226 is a naturally

occurring radioactive material, the Atomic Energy Act of 1954 places
naturally occurring radioactive material outside of federal jurisdiction.
However, this official told us that although such sources are the
responsibility of the states, few states currently have the ability to
recover these sources. d Some holders of sources have more than one type
of source.

e Total does not add to 80,308 because of rounding.

Page 18 GAO- 03- 483 Nuclear Nonproliferation The 4,380 unwanted greater-
than- Class- C sealed sources that awaited recovery were held by 328
different owners located across the United

States. 8 As figure 4 shows, about 59 percent of these unwanted sealed
sources are located in the state of Texas in gauges that had been used for
petroleum exploration. 8 The number of different holders of unwanted
greater- than- Class- C sealed sources that awaited recovery is lower than
the number in table 6 because some holders of sources have more than one
type of source.

Page 19 GAO- 03- 483 Nuclear Nonproliferation Figure 4: Greater- Than-
Class- C Sealed Sources in Need of Recovery by State, as of February 2003

Note: GAO*s presentation of DOE*s data.

Page 20 GAO- 03- 483 Nuclear Nonproliferation The Office of Environmental
Management*s most recent budget plan, which was completed in fiscal year
2001, showed DOE providing about

$3 million annually to the Off- Site Source Recovery Project from fiscal
year 2002 through fiscal year 2030. 9 Consequently, the amount of funding
that the Office of Environmental Management authorized for the Off- Site
Source Recovery Project in fiscal year 2002 was about $2.2 million less
than the $5.1 million that the project estimated it needed.

In February 2002, the Office of Environmental Management conducted a
review of its priorities with the goal of improving program performance.
The review recommended that the office realign its priorities in a manner
more consistent with its main mission to accelerate the cleanup and
closure of contaminated DOE weapons development facilities. Office of
Environmental Management officials told us that they questioned whether it
is appropriate that the Off- Site Source Recovery Project be assigned to
their office and they are looking into the possibility of moving
responsibility for managing the project to another office in DOE. These
officials told us that the Office of Environmental Management planned to
allocate more funding to cleaning up and closing contaminated DOE nuclear
weapons production facilities, which the office considered a higher
priority, and only provide the project funding to store sealed sources
that already had been recovered. Consequently, DOE*s Office of
Environmental Management reduced its request for funding for the project
for fiscal years 2003 and 2004 to $2.2 million and $2 million,
respectively. However, a DOE official told us that the office plans to
reduce future requests further to $1 million annually beginning in fiscal
year 2005, a funding level that, according to this official, would be
insufficient to keep current project staff assigned to the project.

In August 2002, the Congress appropriated an additional $10 million for
DOE*s Off- Site Source Recovery Project, as part of the 2002 Supplemental
Appropriations Act for Further Recovery from and Response to Terrorist
Attacks on the United States, Public Law 107- 206. According to a DOE
official, the Congress may have appropriated these funds, in part, as a
result of a January 2002 letter from the NRC Chairman to the Secretary of
Energy requesting an acceleration of efforts to recover greater- than-
Class- C sealed sources. In the letter, the NRC Chairman noted that NRC

9 The Office of Environmental Management*s budget plan was completed
before DOE finalized the time frame for the Off- Site Source Recovery
Project, which, as currently planned, will cease operations by the end of
fiscal year 2010. The Off- Site Source

Recovery Project Is Not a Priority of DOE*s Office of Environmental
Management

Page 21 GAO- 03- 483 Nuclear Nonproliferation had completed an evaluation
that concluded that* in light of the events of September 11, 2001* the
possession or storage of unwanted radioactive

sealed sources with no disposal outlet presents a potential vulnerability
to terrorist threats. The letter urged DOE to recover, within 18 months,
all greater- than- Class- C sealed sources currently known to be unwanted.

Rather than accelerating DOE*s recovery efforts, however, these funds will
be needed to keep DOE*s recovery efforts on track through fiscal year
2004. The Off- Site Source Recovery Project had planned recovery
activities for fiscal years 2003 and 2004 with a total cost of $13.8
million, but DOE*s Office of Environmental Management had requested from
the Congress a total of $4.2 million for these years, leaving a funding
shortfall of $9.6 million. Prior to fiscal year 2003, the Off- Site Source
Recovery Project was able to make up for funding shortfalls by carrying
over unspent funds from prior fiscal years. However, by the end of fiscal
year 2002, the size of the shortfall far exceeded the amount of funding
available to carry forward. Therefore, almost all of the supplemental
funding appropriated by the Congress will go toward helping the Off- Site
Source Recovery Project make up the funding shortfall and continue
recovering greater- than- Class- C sealed sources as planned through the
end of fiscal year 2004. Beyond fiscal year 2004, however, it remains
unclear whether the Off- Site Source Recovery Project will receive the
funding it needs to continue its planned recovery activities. The
Secretary of Energy publicly stated in November 2002 that securing and
reducing radiological materials that could be fabricated into dirty bombs
is DOE*s highest priority and an

urgent problem. However, without funding available to the Off- Site Source
Recovery Project to recover additional sources, owners of unwanted
greater- than- Class- C sealed sources will be forced to store and secure
their sources on their premises until a disposal facility is available.

The Off- Site Source Recovery Project has not been able to recover
additional greater- than- Class- C sealed sources containing plutonium-
239 since mid- 2002 because DOE lacks storage capacity at the Los Alamos
National Laboratory that meets the security requirements for this
material. Because plutonium- 239 can be used to make a crude nuclear bomb,
as well as a dirty bomb, DOE regulations require that any DOE facility
storing 6 kilograms or more of this material must meet DOE*s most
stringent security requirements. Meeting these requirements means that,
among other things, the sources containing plutonium- 239 must be stored
in a vault- like room in a facility protected by two layers of physical
barriers (e. g., an outer and an inner fence) providing access controls
and intrusion detection; armed guards who are capable of responding to an
intrusion; DOE Lacks Storage

Capacity Meeting the Security Requirements for Storing Additional Sealed
Sources Containing Plutonium- 239

Page 22 GAO- 03- 483 Nuclear Nonproliferation inspections of personnel,
vehicles, and hand- carried items entering and exiting the facility; and
exits that are alarmed or controlled at all times. As

of February 2003, the greater- than- Class- C sealed sources in storage at
the Los Alamos National Laboratory contain a total of less than 1 kilogram
of plutonium- 239. DOE*s security requirements for this smaller amount of
material are less stringent and have already been met in the locations at
the Los Alamos National Laboratory where it is being stored. However,
according to a DOE official, these storage locations have also been used
to store radioactive material associated with other programs operating at
Los

Alamos. As a result, by mid- 2002, the Off- Site Source Recovery Project
had reached the limits of its capacity to store additional plutonium- 239
at Los Alamos without needing to meet DOE*s most stringent security

requirements. As of February 2003, the project had identified an
additional 449 unwanted greater- than- Class- C sealed sources containing
about 13 kilograms of plutonium- 239 that it will not be able to recover
until storage space meeting DOE*s most stringent security requirements is
made available. 10 DOE is currently pursuing two parallel efforts to allow
the Off- Site Source

Recovery Project to recover and store additional greater- than- Class- C
sealed sources containing plutonium- 239. First, DOE is evaluating two
options for physically increasing the amount of storage space available
that meets the stringent security requirements for the additional
plutonium- 239 that the project plans to recover. These options include
packaging and placing the sources in a secure trailer at the Los Alamos
National Laboratory in such a way that they are stored at least as
securely as if they were in a vault and creating secured storage space at
the Nevada Test Site in Nye County, Nevada. DOE is developing these
options but is

not yet able to provide us with a time frame for how long it will take to
select and implement an alternative. An official from the Off- Site Source
Recovery Project told us that the project budgeted $1.5 million to cover
the initial cost of creating additional secure storage space for
plutonium- 239 but was unable to provide a plan for ensuring that the

project received the additional funding that would be needed to continue
to maintain this storage space for as long as it was needed.

10 The Off- Site Source Recovery Project also identified greater- than-
Class- C sealed sources containing another 15 kilograms of plutonium- 239
that are currently in use. According to an official from the Off- Site
Source Recovery Project, DOE will eventually need to recover these sources
as well. Consequently, DOE could need to provide the capacity to securely
store a total of an additional 28 kilograms of this material, if a
disposal facility were not made available beforehand.

Page 23 GAO- 03- 483 Nuclear Nonproliferation Concurrent with efforts to
increase physical storage capacity, DOE is also exploring whether all of
the sealed sources containing plutonium- 239 that

the Off- Site Source Recovery Project plans to recover meet the legal and
regulatory requirements for disposal at the Waste Isolation Pilot Plant.
Currently, by law, only radioactive waste resulting from the development
of nuclear weapons, referred to as defense waste, can be disposed of at
the Waste Isolation Pilot Plant. Any greater- than- Class- C sealed
sources containing plutonium- 239 that were used in this manner can be
disposed of at this facility; however, most of the plutonium- 239 sources
that the OffSite Recovery Project plans to recover were not directly used
for defense purposes. DOE is exploring whether a case can be made that,
although these sources were used for research and other purposes, the
plutonium- 239 that they contain was originally manufactured for use in
weapons development and thus can be disposed of at the Waste Isolation
Pilot Plant. In this way, DOE could potentially bypass the plutonium- 239
storage problem entirely by establishing a permanent disposal facility.
However, DOE regulations specify that no amount of plutonium- 239
requiring secured storage can be discarded, whether or not the material is
defense- related, without special approval to terminate the security

requirements. In March 2003, DOE approved the termination of the security
requirements for less than 2 kilograms of plutonium- 239 so that the Off-
Site Source Recovery Project can dispose of the defense- related
plutonium- 239 it is storing at the Los Alamos National Laboratory, but it
has not yet approved such a termination for non- defense- related
plutonium- 239 in storage at Los Alamos.

Until DOE is able to increase its capacity to store greater- than- Class-
C sealed sources containing plutonium- 239, 149 holders of unwanted
sources containing this radioactive material must continue to store and
secure their sources on their premises. About 77 percent of the holders of
unwanted plutonium- 239 sources are universities. Six of the universities
we contacted told us that they received the sources during the 1950s and
1960s as part of a national effort to promote research related to nuclear
physics and they have not used these sources for many years. As a result,
these universities each told us that they are storing and securing from 1
to 10 sealed sources of plutonium- 239 that they no longer want. In
general, the sources are stored in rooms or closets, typically without
windows, and access to the rooms can only be gained by passing through one
or more locked doors. Access to the keys to the doors is controlled, and
doors are checked periodically by campus safety personnel to ensure that
they are locked. In addition, NRC or state regulatory agencies review how
the universities are securing their sealed sources as part of the
agencies* reviews of the universities* nuclear safety programs. However,

Page 24 GAO- 03- 483 Nuclear Nonproliferation representatives from two
universities told us of instances in which the doors to the sources had
been found unlocked or open, and representatives from six of the
universities told us that they wanted the

Off- Site Source Recovery Project to recover their sources immediately. 11
We also talked to officials from a Department of Defense facility, a DOE
facility, and a decommissioned nuclear power plant about their plutonium-
239 sources, one of which had as many as 60 plutonium- 239 sealed sources
on- site. Officials at these facilities told us that their sources were
secure, and no instances of concern were mentioned. The official at the
nuclear power plant told us that the facility would like the Off- Site
Source Recovery Project to recover its sources as soon as possible because
it was in the process of shutting down operations.

The Off- Site Source Recovery Project cannot recover unwanted greaterthan-
Class- C sealed sources containing strontium- 90 and cesium- 137, because
DOE has not approved a means for temporarily storing these types of sealed
sources at a DOE facility until a permanent disposal facility is developed
as it has done for the other types of sealed sources it needs to recover.
12 In deciding how and where sealed sources containing strontium90

and cesium- 137 will be stored, DOE must do an appropriate analysis as
required by the National Environmental Policy Act of 1969 (NEPA) and
implementing regulations. Once DOE completes and approves the NEPA
analysis process for each type of source, it could begin to implement a
storage alternative. DOE prepared its NEPA analysis for strontium- 90 in
December 2001, which offered nine alternatives for storing sealed sources
containing this radioactive material until a disposal facility is
available. As of February 2003, the Office of Environmental Management had
not

approved its analysis for strontium- 90 and had not begun its analysis for
cesium- 137, and DOE was unable to provide us with an estimate of how long
it might take. According to Off- Site Source Recovery Project data, almost
all of the greater- than- Class- C sealed sources containing strontium90
that need to be recovered are currently being stored at facilities

11 Representatives from two universities told us that they wanted to keep
their sealed sources even though these sources were listed as unwanted on
the project*s database. 12 Strontium- 90 and cesium- 137 are nuclear
materials that remain radioactive for a long period of time, can
contaminate property, and require an extensive clean- up. These nuclear

materials can also be absorbed in the food chain and are potential cancer
causing risks. According to an Off- Site Recovery Project official, the
project is able to store the unwanted greater- than- Class- C sealed
sources that contain both americium- 241 and cesium- 137 because the
americium- 241 in the sources determines how the sources must be stored.
DOE Lacks an Approved

Means for Temporarily Storing Sealed Sources Containing Strontium- 90 and
Cesium- 137

Page 25 GAO- 03- 483 Nuclear Nonproliferation operated by the Department
of Defense and DOE. Also, while, according to a project official, most
unwanted sealed sources containing cesium- 137 that have been reported to
the project do not contain a greater- than-

Class- C amount of radioactive material, this official told us that there
are about 100 medical devices currently in use for treating blood that
contain cesium- 137 sealed sources and that some of these sources may
contain a

greater- than- Class- C amount of the radioactive material. The owners of
these medical devices have told project officials that they would like to
replace the devices with new technology.

As of February 2003, DOE had not made progress toward providing a
permanent disposal facility for greater- than- Class- C radioactive waste,
as required by Public Law 99- 240. Specifically, DOE had not decided which
office within the agency would begin the first step in developing such a
facility, completing the appropriate NEPA analysis, which would likely be
an Environmental Impact Statement. According to DOE officials, it is
unlikely that DOE will be able to provide a permanent disposal facility by
fiscal year 2007 unless the agency makes it a priority. Furthermore, the
agency lacks a plan for recovering and storing unwanted greater-
thanClass- C sealed sources in the event that the disposal facility is
delayed.

According to officials from the Off- Site Source Recovery Project, DOE is
unlikely to be able to provide a disposal facility by fiscal year 2007, as
it had assumed, unless the agency makes it a priority. As of February
2003, DOE had not decided which DOE office would be assigned the
responsibility for beginning the first step in providing a disposal
facility for greater- than- Class- C radioactive waste* completing the
appropriate NEPA analysis. Public Law 99- 240 gave DOE responsibility for
providing for the disposal of greater- than- Class- C radioactive waste.
In developing a disposal facility, DOE must determine, as required by NEPA
and implementing regulations, whether an Environmental Impact Statement is
necessary. If an Environmental Impact Statement is necessary, DOE would

have to propose a number of disposal alternatives, and the public would
have an opportunity to comment. Following completion of the Environmental
Impact Statement and a mandatory 30- day waiting period, DOE would
initiate a Record of Decision, in which the agency would select the
alternative to be implemented. After the Record of Decision is completed,
approved, and made public, DOE may begin to implement the decision.
Whether the alternative selected is to construct a new facility or modify
an existing facility, funding would need to be identified, and after the
facility was built, it would need to be licensed by NRC. All together, DOE
Has Not Made

Progress toward Providing a Permanent Disposal Facility

DOE Is Unlikely to Provide a Disposal Facility by Fiscal Year 2007

Page 26 GAO- 03- 483 Nuclear Nonproliferation developing a new disposal
facility could take at least 7 years, not including the time to physically
build the facility. Also, DOE had neither provided funding nor produced a
timeline for

completing the NEPA analysis. Officials in DOE*s Office of Environmental
Management told us that the office had identified funding for completing
the Environmental Impact Statement for fiscal years 2002 and 2003;
however, after office management reviewed the budget in February 2002, the
office redirected the funding to other higher priority projects. They also
told us that they anticipated that DOE would decide which DOE office would
be responsible for the NEPA analysis some time in fiscal year 2003, and
the Office of Environmental Management*s most recent budget plan for the
Off- Site Source Recovery Project mentioned the office*s intention to
defer the development of the facility.

DOE officials told us that it typically takes about 2 years to complete an
Environmental Impact Statement and as long as 3 years or more to complete
a Record of Decision. If the Record of Decision indicates that a new
facility is needed, funding would need to be secured, and construction
activities completed. The officials told us that there was not enough
information available at this time to estimate how long construction
activities would take. However, they told us that the NRC licensing
process that would follow could take at least 2 years. In a 1987 report to
the Congress, DOE estimated that providing a new facility, including
construction, could require at least 7 to 9 years to complete. 13 In the
1987 report, DOE also stated that if an existing facility could be used

for disposal of greater- than- Class- C sealed sources, disposal services
could be provided sooner, depending upon the availability of the facility.
However, it remains uncertain when or if this will be possible. DOE has
been exploring whether the acceptance criteria for the Waste Isolation
Pilot Plant in Carlsbad, New Mexico, can be broadened to include more of
the sealed sources that the project is recovering. Currently, the Waste
Isolation Pilot Plant can only accept certain types of radioactive waste
resulting from DOE*s defense- related activities, which would preclude it

13 Public Law 99- 240 also requires DOE to submit a report to the Congress
setting forth the agency*s recommendations for ensuring the safe disposal
of greater- than- Class- C radioactive waste, which the agency completed
in February 1987. See U. S. Department of Energy, Recommendations for
Management of Greater- Than- Class- C Low- Level Radioactive Waste, Report
to Congress in Response to Public Law 99- 240 (Washington, D. C.: Feb.
1987).

Page 27 GAO- 03- 483 Nuclear Nonproliferation from taking the majority of
the sources recovered by the project. Furthermore, although the
Environmental Protection Agency has certified

the Waste Isolation Pilot Plant, the facility did not require an NRC
license because the waste sent there did not result from NRC- licensed
activities. However, Public Law 99- 240 requires DOE to dispose of any
greater- thanClass- C radioactive waste that resulted from NRC- licensed
activities, which includes most of the sealed sources that the Off- Site
Source Recovery Project is recovering, at a facility licensed by NRC.
These legal matters would need to be resolved before the Waste Isolation
Pilot Plant could be considered a viable option. Another possibility being
explored is the potential for disposing of greaterthan-

Class- C sealed sources at DOE*s planned repository for waste resulting
from the nuclear power industry. For example, the Environmental Impact
Statement for building a disposal facility at Yucca Mountain discussed the
potential for disposing of greater- than- Class- C radioactive waste at
this facility. The purpose of such a repository is to enable DOE to meet
the requirements of the Nuclear Waste Policy Act, which establishes DOE*s
responsibility for providing for the permanent disposal of high- level
radioactive waste. However, the Nuclear Waste Policy Act limits the amount
of high- level waste that can be disposed of at a facility built to
satisfy the requirements of the Act and does not explicitly state whether
greater- than- Class- C waste could also be disposed of at the

same facility. As with the Waste Isolation Pilot Plant, these legal
matters would need to be resolved before sending unwanted greater- than-
Class- C sealed sources to DOE*s planned repository could be considered a
viable option.

As of February 2003, DOE*s Office of Environmental Management did not have
a plan for continuing the recovery of greater- than- Class- C sealed
sources in the event that the disposal facility is delayed. The Off- Site
Source Recovery Project was originally envisioned as providing DOE with
the means of recovering and temporarily storing unwanted greater-
thanClass- C sealed sources until a permanent disposal facility was
available. However, DOE still plans to begin phasing out the Off- Site
Source Recovery Project*s operations in fiscal year 2007 and cease
operations altogether in fiscal year 2010 as originally assumed. As a
result, under the current plan, any delays in providing a disposal
facility could begin to hinder DOE*s efforts to ensure unwanted greater-
than- Class- C sealed sources are properly secured as early as fiscal year
2007. DOE Lacks a Plan for

Recovering Sealed Sources if the Disposal Facility Is Delayed

Page 28 GAO- 03- 483 Nuclear Nonproliferation Since September 11, 2001,
recovering and disposing of greater- than- Class- C radioactive sealed
sources has taken on added significance

because doing so would secure nuclear materials that have the potential
for being misused and that pose a threat to national security. The
Secretary of Energy publicly stated in November 2002 that securing and
reducing radiological materials that could be fabricated into dirty bombs
is DOE*s highest priority and an urgent problem. We believe that
continuing the recovery efforts of the Off- Site Source Recovery Project
and providing a permanent disposal facility for greater- than- Class- C
radioactive sealed sources should be key elements in any DOE strategy to
address this problem. However, responsibility for these efforts is
currently located in an office within DOE where they are not a priority.
As a result, the Off- Site Source Recovery Project has not received
adequate funding; key decisions about how and where to temporarily store
and ultimately dispose of greater- than- Class- C sealed sources have not
been made; and future progress toward permanently securing unwanted sealed
sources is likely to be limited.

The Off- Site Source Recovery Project has made progress recovering
greater- than- Class- C sealed sources, but future progress will depend on
whether DOE gives the project the priority that is commensurate with the
risks that these sealed sources pose to the public; ensures adequate
resources are devoted to the project; and provides, as soon as possible,

sufficient space to store, at an appropriate level of security, any sealed
sources that it needs to recover. Ultimately, however, all unwanted
greater- than- Class- C sealed sources will need to be placed in a
permanent disposal facility. Since already more than 17 years have passed
since the

enactment of Public Law 99- 240, we believe it is time that DOE initiate
the process to provide such a facility. DOE will have difficulty ensuring
the success of this effort, however, without a plan that would, at a
minimum, assign responsibility for developing the facility; establish
milestones by which progress could be measured; evaluate potential
disposal options; estimate costs and schedules; and address legislative,
regulatory, and licensing considerations. Also, because it is unlikely
that such a facility will be operational by fiscal year 2007 when the Off-
Site Source Recovery Project is scheduled to begin phasing out operations,
a plan to ensure the continued recovery and storage of greater- than-
Class- C sealed sources until a disposal facility is available would help
DOE prevent any gaps in its ability to secure unwanted greater- than-
Class- C sealed sources.

As sealed sources currently in use wear out or become obsolete, the
proliferation of unwanted greater- than- Class- C sealed sources of all
types across the United States will continue to increase. Unless action is
taken, Conclusions

Page 29 GAO- 03- 483 Nuclear Nonproliferation DOE*s efforts to recover,
temporarily store, and ultimately dispose of unwanted greater- than-
Class- C sealed sources will be severely impeded,

ultimately forcing owners of these dangerous materials to continue storing
and securing them on their premises where they will remain susceptible to
misuse, improper disposal, and theft. Because of the risk that unwanted
greater- than- Class- C sealed sources

could be used as weapons of terror, we recommend that the Secretary of
Energy determine whether the priority given to the Off- Site Source
Recovery Project is commensurate with the threat posed by these sealed
sources. Once this determination has been made, the Secretary should

ensure that adequate resources are devoted to the project to cover the
costs of recovering and storing these sealed sources as quickly as
possible. To ensure that unwanted greater- than- Class- C sealed sources
containing plutonium- 239, strontium- 90, and cesium- 137 are properly
secured to

prevent their use in dirty bombs or, in the case of sources containing
plutonium- 239, nuclear weapons, we further recommend that the Secretary
of Energy take immediate action to provide storage space for these sources
at a secure DOE facility and establish milestones by which progress can be
measured to ensure that the storage space is provided as soon as possible.

In addition, we recommend that the Secretary of Energy initiate the
process to develop a permanent disposal facility for greater- than- Class-
C radioactive waste to carry out the requirements of Public Law 99- 240.
To help manage the process, the Secretary should develop a plan that
would,

at a minimum, assign responsibility for developing the facility; establish
milestones by which progress can be measured; evaluate potential disposal
options; estimate costs and schedules; and address legislative,
regulatory, and licensing considerations. Because it is unlikely that a
permanent disposal facility for such waste will be operational by fiscal
year 2007 when the Off- Site Source Recovery Project is scheduled to begin
phasing out operations, we recommend that the Secretary of Energy develop
a plan to ensure the continued recovery and storage of greaterthan- Class-
C sealed sources until a disposal facility is available.

During a discussion of our report with DOE officials, including the
Associate Deputy Assistant Secretary for Integration and Disposition,
agency officials expressed general agreement with our findings,
conclusions, and recommendations. In a subsequent March 31, 2003, letter,
which is reproduced in appendix II, DOE provided written comments on
Recommendations for Executive Action

Agency Comments

Page 30 GAO- 03- 483 Nuclear Nonproliferation our report and raised three
issues. Specifically, DOE asserted that (1) our report did not mention a
joint DOE and NRC working group that was

chartered to address the issue of unwanted sealed sources and their
potential use in radiological dispersal devices; (2) the project baseline
we reviewed had not been revised to incorporate the results of the working

group*s draft report and the need to change the recovery effort from a
general health- and- safety- driven program to a national- security-
andnuclear- nonproliferation- driven program; and (3) we did not interview
any policy executives within DOE in preparing our report.

Regarding the first issue, we have added to the report a discussion of the
purpose and objectives of this working group and its preliminary
recommendations to DOE and NRC. Although the efforts of this working group
are broader than the scope of the Off- Site Source Recovery Project, in
our view, the working group*s preliminary findings, conclusions, and

recommendations generally support the conclusions and recommendations in
our report. Regarding the second issue, our report states that the
greater- than- Class- C sealed sources that are being recovered by the
project are a national security concern because they are particularly
attractive for potential use in producing dirty bombs. In

addition, DOE has been required to provide a facility for disposing of
these sources for more than 17 years. Finally, regarding the third issue,
it is unclear to us why this point is being raised. During the course of
our review, we met with the Director and then the Acting Director for
Technical Program Integration, and on February 20, 2003, we met with the
Associate Deputy Assistant Secretary for Integration and Disposition to
obtain her comments on our written findings and discuss our preliminary
conclusions and potential recommendations. Furthermore, on March 26, 2003,
at her request, we met with the Assistant Secretary for Environmental
Management. During the meeting, we offered to accept any additional
information she wanted to provide and make appropriate

changes to the draft as needed. During this meeting, no changes were
suggested to our findings, conclusions, or recommendations.

We performed our review at the Off- Site Source Recovery Project office at
the Los Alamos National Laboratory in Los Alamos, New Mexico; DOE*s
Albuquerque Operations Office in Albuquerque, New Mexico; and DOE*s and
NRC*s headquarters in Washington, D. C. We reviewed statutes, regulations,
and appropriate guidance as well as interviewed agency officials to
determine the relevant statutory framework. We reviewed cost

and schedule estimates from DOE and interviewed appropriate officials to
determine how much DOE had spent to date recovering and storing Scope and

Methodology

Page 31 GAO- 03- 483 Nuclear Nonproliferation unwanted greater- than-
Class- C sealed sources and how DOE estimated the number of sealed sources
it planned to recover from fiscal years 1999

through 2010 and the cost to complete the remaining project activities. We
also obtained and reviewed the studies and other information on which DOE
based its estimates. We reviewed data from the Off- Site Source Recovery
Project on the number of greater- than- Class- C sealed sources recovered
to date and the number still awaiting recovery. In addition, we visited
the Los Alamos National Laboratory to see how sealed sources that the
project had recovered were being stored. We reviewed budget data and
interviewed headquarters officials from DOE*s Office of

Environmental Management to assess the level of the office*s commitment to
the Off- Site Source Recovery Project. We also interviewed appropriate
officials to determine what efforts DOE was undertaking to provide safe
and secure storage capacity for greater- than- Class- C sealed sources
containing plutonium- 239, strontium- 90, and cesium- 137. To understand
how owners of unwanted sources containing plutonium- 239 were managing
their sources until they were recovered, we spoke with representatives
from eight universities, a Department of Defense facility, a DOE facility,
and a decommissioned nuclear power plant, which were located throughout
the United States and listed on the project*s database as having unwanted
sources awaiting recovery. Finally, we interviewed

headquarters officials from DOE*s Office of Environmental Management to
determine the progress DOE had made toward providing a permanent disposal
facility.

We conducted our work from June 2002 through April 2003 in accordance with
generally accepted government auditing standards.

As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution of it until 30 days
from the date of this letter. We will then send copies to the Secretary of
Energy, the Acting Administrator, National Nuclear Security
Administration, the Director, Office of Management and Budget, and
interested congressional committees and other interested parties. We will
also make copies available to others who request them. In addition, the
report will be available at no charge at GAO*s web site at http: www. gao.
gov.

Page 32 GAO- 03- 483 Nuclear Nonproliferation If you or your staff have
any questions about this report, I can be reached at (202) 512- 3841.
Major contributors to this report include Gene Aloise,

Stephen Cleary, and Ilene Pollack. Sincerely yours,

Robert A. Robinson Managing Director, Natural

Resources and Environment

Appendix I: Sections 1, 2, and 3 of the LowLevel Radioactive Waste Policy
Amendments Act of 1985, Public Law 99- 240

Page 33 GAO- 03- 483 Nuclear Nonproliferation

Appendix I: Sections 1, 2, and 3 of the LowLevel Radioactive Waste Policy
Amendments Act of 1985, Public Law 99- 240

Appendix I: Sections 1, 2, and 3 of the LowLevel Radioactive Waste Policy
Amendments Act of 1985, Public Law 99- 240

Page 34 GAO- 03- 483 Nuclear Nonproliferation

Appendix I: Sections 1, 2, and 3 of the LowLevel Radioactive Waste Policy
Amendments Act of 1985, Public Law 99- 240

Page 35 GAO- 03- 483 Nuclear Nonproliferation

Appendix I: Sections 1, 2, and 3 of the LowLevel Radioactive Waste Policy
Amendments Act of 1985, Public Law 99- 240

Page 36 GAO- 03- 483 Nuclear Nonproliferation

Appendix II: Comments from the Department of Energy

Page 37 GAO- 03- 483 Nuclear Nonproliferation Appendix II: Comments from
the Department of Energy

Note: GAO comments supplementing those in the report text appear at the
end of this appendix.

See comment 2. See comment 1.

See comment 1.

Appendix II: Comments from the Department of Energy

Page 38 GAO- 03- 483 Nuclear Nonproliferation See comment 3.

Appendix II: Comments from the Department of Energy

Page 39 GAO- 03- 483 Nuclear Nonproliferation The following are GAO*s
comments on the Department of Energy*s (DOE) letter dated March 31, 2003.

1. DOE commented that our draft report does not adequately consider a
number of issues that DOE is addressing concerning nonproliferation of
sealed sources. Specifically, DOE mentions a joint DOE and Nuclear
Regulatory Commission (NRC) working group that was chartered to address
the issue of unwanted sealed sources and their potential use in
radiological dispersal devices. A discussion of the working group and its
draft report will be addressed in our forthcoming report on the control of
domestic radiological sources. However, we have added, in the background
section of this report, a discussion of the purpose of the working group,
the objectives it was addressing, and its preliminary recommendations to
DOE and NRC regarding the disposal of radiological sources. The efforts of
this working group are broader than the scope of the Off- Site Source
Recovery Project in that they include a discussion of all radiological
materials not just greater- than- Class- C sealed sources. In our view,
the working group*s preliminary findings, conclusions, and recommendations
generally support our conclusions and recommendations regarding the need
for DOE to (1) provide sufficient resources to ensure the continued
operations of the Off- Site Source Recovery Project; (2) provide secure
storage space for greater- thanClass- C sealed sources that DOE needs to
recover; (3) initiate the process to provide a permanent disposal facility
for greater- than- Class- C waste; and (4) develop a plan to ensure
continued recovery of these sources in the likely event that a permanent
facility is delayed.

DOE also makes the point that one major focus of this DOE and NRC working
group*s effort is to ensure DOE*s resources are spent wisely and to focus
recovery efforts on those sealed sources that pose the greatest concern.
However, greater- than- Class- C sealed sources have already been
identified as particularly attractive for potential use in

producing dirty bombs. Among other things, they contain concentrated
amounts of high- risk nuclear materials, such as americium- 241, cesium-
137, plutonium- 238, plutonium- 239, and strontium- 90. Furthermore,
Public Law 99- 240 specifically requires that DOE provide for the
permanent disposal of greater- than- Class- C sealed sources, a task even
more important now, following the events of September 11, 2001, than when
the law was enacted. GAO Comments

Appendix II: Comments from the Department of Energy

Page 40 GAO- 03- 483 Nuclear Nonproliferation 2. DOE commented that the
project*s baseline that we reviewed had not yet been revised to
incorporate the results of the working group*s draft

report and the need to change the recovery effort from a general health-
and- safety- driven program to a national- security- and-
nuclearnonproliferation- driven program. In addition, the project*s
baseline proposes a budget for fiscal year 2005 that will be considered,
along with the working group*s report, during DOE*s fiscal year 2005
request preparation, which is ongoing. Regarding DOE*s comment that the
project*s baseline will be revised to focus on national security and
nonproliferation, greater- than- Class- C sealed sources are a concern
because they are particularly attractive for potential use in producing
dirty bombs. Furthermore, for more than 17 years, DOE has been required by
Public Law 99- 240 to provide a facility for disposing of all greater-
than- Class- C waste, including greater- than- Class- C sealed sources
that are no longer wanted by their owners. To date, however, DOE has not
developed such a facility. Regarding DOE*s point about the budget, DOE*s
comments indicate that the project*s future estimated budget needs will be
considered along with the recommendations of the working group. However,
there is still no indication that the Off- Site Source Recovery Project
will get the funding it needs to recover greater- than- Class- C sealed
sources beyond fiscal year 2004. As stated in our report, DOE*s Office of
Environmental Management reduced its request for funding for the Off- Site
Source Recovery Project for fiscal years 2003 and 2004 to $2.2 million and
$2 million, respectively, to provide the funds necessary to store sealed
sources that had already been recovered. In addition, a DOE official told
us that the office plans to reduce future requests further to $1 million
annually beginning in fiscal year 2005, a funding level that, according to
this official, would be insufficient to keep current project staff
assigned to the project. 3. DOE commented that we failed to interview any
policy executives

within DOE in preparing this report and that the draft report reflects
this fact. It is unclear to us why this point is being raised. During the
course of our review, in addition to meeting with a variety of project
managers, we met with the Director and then the Acting Director for
Technical Program Integration. These officials are directly responsible
for the management of the Off- Site Source Recovery Project. On February
19, 2003, we provided DOE with our written findings, prior to sending the
draft to DOE for agency comment, to confirm that the critical facts and
key information used to formulate our analyses and findings were current,
correct, and complete. On February 20, 2003, we met with a variety of
program officials, including the Associate

Appendix II: Comments from the Department of Energy

Page 41 GAO- 03- 483 Nuclear Nonproliferation Deputy Assistant Secretary
for Integration and Disposition to discuss our findings, preliminary
conclusions, and potential recommendations

that flowed from the factual information we collected. These officials
agreed with our findings and preliminary conclusions and recommendations.
They did provide us technical changes, which we made to the draft report
as appropriate. In addition, on March 26, 2003, at her request, we met
with the Assistant Secretary for Environmental Management. At this
meeting, we said that we were willing to accept any information regarding
the findings, conclusions, and recommendations in our draft report that
the Assistant Secretary may have. In addition, we said that we were
willing to make appropriate changes to the draft. The Assistant Secretary
did not dispute the findings, conclusions, or recommendations in our draft
report but said that our draft did not mention the working group and its
resulting draft report dated February 2003. As stated above, we included a
discussion of the working group*s efforts in the background section of
this report.

(360234)

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