Nuclear Security: DOE Needs Better Information to Guide Its	 
Expanded Recovery of Sealed Radiological Sources (22-SEP-05,	 
GAO-05-967).							 
                                                                 
Concerns remain over the control of sealed radiological sources, 
widely used in many industrial and medical devices and		 
applications. The Nuclear Regulatory Commission (NRC), the	 
Department of Energy (DOE), and states have responsibilities for 
ensuring the safe and secure use and eventual disposal of these  
sources as low-level radioactive wastes. DOE must ensure disposal
availability for greater-than-class C (GTCC) waste; states must  
do so for non-GTCC waste, that is, classes A, B, and C waste. NRC
and DOE also collaborate to identify and recover unwanted sources
that are not safe or secure. GAO examined DOE's (1) efforts to	 
recover unwanted sources and develop a GTCC waste disposal	 
option, (2) actions to recover and dispose of non-GTCC source	 
waste, and (3) ability to identify sources for recovery and	 
disposal.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-967 					        
    ACCNO:   A37797						        
  TITLE:     Nuclear Security: DOE Needs Better Information to Guide  
Its Expanded Recovery of Sealed Radiological Sources		 
     DATE:   09/22/2005 
  SUBJECT:   Independent regulatory commissions 		 
	     Policy evaluation					 
	     Radioactive waste disposal 			 
	     Radioactive wastes 				 
	     Strategic planning 				 
	     Waste management					 

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GAO-05-967

United States Government Accountability Office

  GAO	Report to the Chairman, Committee on Energy and Natural Resources, U.S.
                                     Senate

September 2005

NUCLEAR SECURITY

     DOE Needs Better Information to Guide Its Expanded Recovery of Sealed
                              Radiological Sources

                                       a

GAO-05-967

[IMG]

September 2005

NUCLEAR SECURITY

DOE Needs Better Information to Guide Its Expanded Recovery of Sealed
Radiological Sources

  What GAO Found

DOE has increased emphasis on its source recovery project and begun the
process of identifying disposal options for GTCC waste. DOE transferred
project responsibilities to another office that has given the project
higher priority and accelerated DOE's recovery efforts. DOE exceeded an
earlier goal for recovering sources and has now collected over 10,800 of
them. This recovery has been facilitated by additional project funding
support and DOE's resolving a shortage of storage space for certain
sources. In May 2005, DOE issued a notice of intent to prepare an
environmental impact statement to assess GTCC waste disposal options;
however, DOE has not yet determined when a disposal site might be made
available.

DOE has expanded the scope of its recovery effort to include non-GTCC
waste from sealed radiological sources, a change that could increase DOE
expenditures. DOE recovered and commercially disposed of 443 of these
sources from a bankrupt firm, at a cost to DOE of about $581,000. Given
that unwanted sources in storage present higher vulnerabilities, DOE might
need to recover more of them in the future if the commercial disposal site
that currently accepts this non-GTCC waste from most states ceases to do
so as planned in 2008. Lacking a commercial disposal option, DOE
anticipates storing this waste, rather than disposing of it at DOE sites,
because, among other reasons, it does not want to undermine the
responsibility the Congress gave the states to provide disposal
availability for non-GTCC waste.

DOE lacks information that would assist its efforts to identify and
recover unwanted sealed radiological sources that may pose a safety and
security risk. DOE has useful information on the sources in its
possession, including recovered sources. However, DOE does not know how
many sources might need recovery and how much disposal capacity is needed
for GTCC waste. NRC is developing a national source tracking system that
would not be useful for DOE's source recovery efforts because it is only
designed to track individual sources with high radioactivity. According to
DOE, nearly all of the sites where it has recovered sources contained
individual sources with lesser radioactivity than would be tracked by NRC,
but their combined radioactivity posed enough of a risk to warrant their
recovery by DOE.

DOE Personnel Packaging a Sealed Radiological Source in a Disposal Drum

Source: GAO.

Pictured left to right: A sealed source being removed (in pliers) from a
shielded storage container at a recovery site; the interior of a
multifunction container used for transport, storage, and disposal; and the
process of closing the steel pipe component after the source has been
loaded into the multifunction container.

United States Government Accountability Office

Contents

  Letter

Results in Brief
Background
DOE Has Increased Emphasis on Its Source Recovery Project and

Begun Assessing Options for Disposing of GTCC Waste

DOE Expanded the Scope of Its Source Recovery Project to Include Non-GTCC
Waste, Which Could Increase Project Expenditures

DOE Lacks Information to Better Identify Unwanted Sealed

Radiological Sources That May Need Recovery Conclusions Recommendations
for Executive Action Agency Comments and Our Evaluation

1 5 8

13

25

31 37 37 38

Appendixes                                                              
                Appendix I:             Scope and Methodology              43 
                             Selected Sealed Radiological Source Devices   
               Appendix II:                   and Their                    
                                       Potential Waste Classes             47 
              Appendix III:     Comments from the Department of Energy     50 
              Appendix IV:       Comments from the Nuclear Regulatory      53 
                                              Commission                   
                Appendix V:     GAO Contact and Staff Acknowledgments      56 

Tables     Table 1: IAEA High-risk Categories of Sealed Radiological    
                                       Sources                             10 
            Table 2: Summary of DOE-Recovered Sealed Radiological Sources, 
                         by Radionuclide, as of June 7, 2005               15 
              Table 3: DOE-Recovered Sealed Radiological Sources, by Their 
                      IAEA Source Category, as of June 7, 2005             35 
            Table 4: Selected Sealed Radiological Source Devices and Their 
                               Potential Waste Classes                     47 
Figures Figure 1: Loss of Control of Sealed Radiological Sources Figure  9 
                      2: Source Recovery Project Personnel Remove a Sealed 
                     Radiological Source and Repackage It into a           
                            WIPP-Acceptable Disposal Drum                  21 
               Figure 3: Relative Size of a Sealed Radiological Source and 
                                                                   Typical 
                                   Disposal Drums                          22 

Contents

Figure 4:	A Cross Section of a Nuclear Gauge, and Leveling Gauges Returned
to a Manufacturer 23

Figure 5:	Interior Views of Two 55-Gallon Disposal Drums, One with a Large
Opening for an Entire Disused Device and the Other with a Narrow Pipe
Opening for Only Sources 24

Abbreviations

CRCPD Conference of Radiation Control Program Directors
DOE Department of Energy
EIS environmental impact statement
GTCC greater-than-class C
IAEA International Atomic Energy Agency
NNSA National Nuclear Security Administration
NRC Nuclear Regulatory Commission
WIPP Waste Isolation Pilot Plant

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
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copyright holder may be necessary if you wish to reproduce this material
separately.

A

United States Government Accountability Office Washington, D.C. 20548

September 22, 2005

The Honorable Pete V. Domenici Chairman, Committee on Energy and Natural
Resources United States Senate

Dear Mr. Chairman:

The regulatory control and tracking of sealed radiological sources in the
possession of academic, government, industrial, medical, and utility
entities that are licensed to use them in devices and applications
continues to evolve. These sources contain radioactive material
encapsulated, or sealed, in metal to prevent its dispersal. The small size
and portability of sealed radiological sources, however, make them
susceptible to misuse, improper disposal, and theft. If some types of
sealed radiological sources fell into the hands of terrorists, they could
be used in fabricating 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 was activated.

There are an estimated 2 million devices containing sealed radiological
sources in use throughout the United States,1 and as many as one-quarter
of them, or up to 500 thousand, may no longer be needed. However, only
some of these sources are considered particularly attractive for producing
dirty bombs because, among other things, they contain more concentrated
amounts of certain nuclear material, such as americium-241, cesium-137,
plutonium-238, and strontium-90. Depending on the type, form (e.g., solid
or powder), amount, and concentration of the radioactive material
dispersed in a malevolent act, the released material could cause radiation
sickness for people nearby as well as significant economic costs and
serious social disruption associated with the evacuation and subsequent
cleanup of the contaminated area. Even without an intentional act, the
inadvertent loss of a sealed radiological source can also lead to
radiation exposure, high decontamination costs, and public panic. For
example, in a 1983 incident, a Texas company sold a cancer treatment
machine containing a sealed radioactive source to a clinic in Mexico. The
device was

1This estimate was first in J.O. Lubenau and J.G. Yusko, "Radioactive
materials in recycled metals-an update," Health Physics, Volume 74, No. 3
(March 1998) p. 297.

subsequently stolen, and the source was accidentally melted with other
metals to form steel reinforcing rods that were imported into the United
States and eventually used to build 37 homes and businesses. The steel
rods were encased in concrete and thus were naturally shielded, but the
incident caused public concern, costly decontamination, and increased
regulatory inspections.

The Nuclear Regulatory Commission (NRC) and the Agreement States2 are
responsible for regulating the use of sealed radiological sources and
other radioactive materials, from creation to disposal, in a way that
ensures the public health and safety. They do so through a combination of
regulatory requirements, licensing, inspection, and enforcement. Under the
Atomic Energy Act of 1954, NRC also is responsible for issuing rules,
regulations, or orders to promote the common defense and security. As we
reported in August 2003, NRC and the Agreement States disagreed about the
appropriate state role in the regulation of sealed radiological source
security.3 According to NRC, it and the Agreement States are currently
working together to implement increased regulatory requirements on
licensees that possess sealed radiological sources that are of security
concern.

After a licensee determines that a sealed radiological source is no longer
useful, the source can be returned to the manufacturer or supplier,
transferred to another licensee, stored to allow for a natural decrease in
radioactivity, or sent to a commercial waste disposal facility. Once the
source is packaged for disposal, the disposal container is put into a
waste class. NRC defines the four types of low-level radioactive waste
(i.e., waste not classified as high-level waste, such as spent fuel from
nuclear power plants) as classes A, B, C, and greater-than-class C
(GTCC).4 The type of radionuclide (e.g., americium-241) and the
concentration of radioactivity

2The Agreement States system was formed by section 274 of the Atomic
Energy Act of 1954, as amended (42 U.S.C. S: 2021). This section of the
act allows NRC to relinquish certain parts of its authority to Agreement
States, of which there are 33, to license and regulate certain radioactive
materials. NRC retains regulatory responsibility over licensees in the
other 17 states, and over other activities, such as regulation of all
nuclear power plants.

3GAO, Nuclear Security: Federal and State Action Needed to Improve
Security of Sealed Radiological Sources, GAO-03-804 (Washington, D.C.:
Aug. 6, 2003).

410 C.F.R. S: 61.55.

(often measured in curies per gram),5 are considered in determining the
waste class of the radioactive material, which carries progressively more
stringent requirements for disposal from class A to GTCC waste. Non-GTCC
waste, including classes A, B, and C waste (e.g., contaminated soil,
laboratory equipment, exit signs containing tritium, and some sealed
radiological sources) generally can be disposed of by shallow burial at
existing commercial low-level radioactive waste disposal sites. However,
GTCC waste (e.g., activated metals,6 sealed radiological sources, and
other highly radioactive waste) will generally require a different type of
disposal. Under the Low-Level Radioactive Waste Policy Act of 1980, as
amended,7 the states and federal government were given separate
responsibilities for providing disposal availability for these wastes.
States were made responsible for providing disposal availability for
non-GTCC waste, and the Department of Energy (DOE) was given the
responsibility of providing disposal for GTCC waste. Non-GTCC waste must
be disposed of in a facility licensed by either NRC or an Agreement State,
but only NRC can license a facility for GTCC waste. As an incentive for
states to manage waste on a regional basis, the Congress consented to the
formation of interstate agreements, known as compacts, and granted compact
member states the authority to exclude low-level radioactive waste from
other compacts and unaffiliated states.8

Even though states have not developed any new disposal sites for low-level
radioactive waste since passage of the act, we reported in June 2004,9
that disposal availability for non-GTCC waste was adequate in the short
term, but that federal oversight was needed to identify any future
shortfalls.

5A curie is a measure of the rate of radioactive decay; it is equivalent
to the radioactivity of 1 gram of radium or 37 billion disintegrations per
second.

6As a result of reactor operations, portions of the reactor barrel and
other stainless steel components near the fuel assembly become highly
radioactive. The majority of this waste is generated when nuclear power
plants are decommissioned, although some waste may result from maintenance
activities performed before decommissioning. There are presently 103
active and 24 decommissioned nuclear power plants in the United States.

7Pub. L. No. 96-573, as amended by Pub. L. No. 99-240, codified at 42
U.S.C. S:S: 2021b-2021j.

8There are 10 compacts comprised of 43 states and 7 unaffiliated states as
well as the District of Columbia and Puerto Rico.

9GAO, Low-Level Radioactive Waste: Disposal Availability Adequate in the
Short Term, but Oversight Needed to Identify Any Future Shortfalls,
GAO-04-604 (Washington, D.C.: June 9, 2004).

There are currently three commercial disposal sites that collectively
serve the nation's non-GTCC waste disposal needs.10 A shortfall in
disposal availability for the higher radioactive non-GTCC waste (classes B
and C waste), however, could occur by mid-2008, if South Carolina follows
through with plans to restrict access to its Barnwell disposal site to
only the 3 member states of the Atlantic Compact. This restriction would
mean that licensees in the 36 states that are currently allowed to use
this disposal site would be denied access to it, and under current
conditions, they would have no alternative option to dispose of their
higher radioactive non-GTCC waste. Regarding GTCC waste disposal, we
reported in April 200311 that DOE had not made progress toward providing
for the permanent disposal of GTCC waste because doing so was not a
priority at the time.

Given the lack of disposal options for GTCC waste and the public health,
safety, and national security concerns about unwanted sealed radiological
sources at licensee sites around the country, DOE, in collaboration with
NRC, has been recovering, taking title of, and storing sources-primarily
at its Los Alamos National Laboratory. DOE has been taking these actions
through its Off-Site Source Recovery Project, which has been operated by
Los Alamos National Laboratory personnel since the late-1990s. In June
1999, NRC and DOE entered into a memorandum of understanding describing
their respective roles and responsibilities for addressing the problem of
unwanted and uncontrolled sealed radiological sources, often referred to
as "orphan sources." This memorandum formalized agreements reached between
these agencies in 1992 to have DOE begin recovering and storing unwanted
sealed radiological sources because DOE had yet to develop a disposal site
for GTCC waste. Since then, DOE has routinely recovered, from licensees
that request such a collection, sealed radiological sources that when
packaged for disposal would be classified as GTCC waste. Many of these
unwanted sources, such as plutonium-239, were originally derived from
defense programs and loaned to colleges and universities that no longer
want them. DOE, at the request of NRC, also

10The commercial disposal site in Barnwell, South Carolina, is available
to the 3 member states of the Atlantic Compact and 36 other states that
are currently allowed to use this site for all non-GTCC waste. The
commercial disposal site in Richland, Washington, serves only the 8 member
states of the Northwest Compact and the 3 member states of the Rocky
Mountain Compact for all non-GTCC waste. A third commercial disposal site
in Utah is available to all states, except the Northwest Compact member
states, for the disposal of only class A waste.

11GAO, Nuclear Nonproliferation: DOE Action Needed to Ensure Continued
Recovery of Unwanted Sealed Radioactive Sources, GAO-03-438 (Washington,
D.C.: Apr. 15, 2003).

recovers sources that are in the possession of licensees that are no
longer able to ensure their safety and security. In our April 2003 report,
we found that while DOE's source recovery project had collected more than
5,000 sources, the project faced the following three problems that could
hinder future recovery efforts: questionable long-term commitment to the
program of DOE's Office of Environmental Management, inadequate storage
capacity that meets the higher security requirements for sealed
radiological sources containing plutonium-239, and DOE's inability to
store sealed radiological sources containing strontium-90 and cesium-137.

In this context, we examined (1) the status of DOE's efforts to recover
unwanted sealed radiological sources and to develop a disposal option for
GTCC waste, (2) DOE actions taken to recover and dispose of non-GTCC waste
from sealed radiological sources, and (3) the extent to which DOE can
identify unwanted sealed radiological sources for recovery and disposal.

To conduct our work, we reviewed pertinent information in existing
databases and published reports and interviewed officials from federal and
state agencies, professional organizations, and representatives from
entities that are licensed to possess sealed radiological sources. More
specifically, we examined DOE's efforts to recover unwanted sealed
radiological sources and the databases maintained by DOE and NRC to
inventory some of these materials. We assessed the reliability of these
data and determined that they were sufficiently reliable for the purposes
of this report. We also used structured interviews of licensees and
commercial waste brokers that possess unwanted sealed radiological sources
and reviewed their waste forms to obtain an understanding of how these
materials are classified, and what challenges might be faced if there is
no disposal option availability for them in the future. We excluded some
radioactive wastes from our review because the radioactive materials are
already under higher security, such as at nuclear power plants and DOE
facilities, or because they present a lower security risk, such as class A
waste. We conducted our review between June 2004 and September 2005 in
accordance with generally accepted government auditing standards. A more
detailed description of our methodology is provided in appendix I.

Results in Brief	DOE has increased emphasis on its source recovery project
and begun the process of identifying disposal options for GTCC waste.
Specifically, DOE transferred responsibilities for source recovery from
its Office of Environmental Management to its National Nuclear Security

Administration (NNSA) to better respond to both domestic and international
threats posed by unwanted sealed radiological sources. DOE was able to
recover 5,529 of these sources within 18 months, exceeding a recovery goal
established in October 2002 and more than doubling the number of sources
recovered since 1996. As of June 7, 2005, DOE had collected a total of
10,806 sealed radiological sources and plans to continue recovering
sources at least until there is a permanent disposal option for GTCC
waste. DOE's accelerated recovery efforts have been supported through
continued annual and supplemental appropriations. The recovery of these
unwanted sealed radiological sources was also facilitated by DOE's
resolution of some problems with storage availability for certain types of
sources. For example, DOE was able to recover and provide storage for over
260 plutonium-239 sources that licensees had registered for collection;
however, some new issues have arisen that are preventing DOE from
recovering the more than 100 of these sources that still remain at
licensee sites. Finally, DOE has begun identifying disposal options for
GTCC waste. In May 2005, DOE issued a notice of its intent to prepare an
environmental impact statement assessing various disposal options for GTCC
waste. In preparing this document, DOE plans to gather information on the
amount of GTCC waste that might be generated over the next 30 to 50 years;
however, making useful projections will be difficult because, among other
things, no national database tracks the volume of GTCC materials or waste.
Further, DOE has not yet determined when a permanent GTCC waste disposal
site might be available because of uncertainties surrounding what
alternatives will be available to DOE after it completes the assessment of
the various disposal options for this waste.

DOE has expanded the scope of its source recovery project to include
non-GTCC waste from unwanted sealed radiological sources-a change that
could increase recovery project expenditures if DOE needs to recover and
dispose of more of this waste in the future. DOE has already recovered and
commercially disposed of non-GTCC waste from some licensees that could no
longer ensure the safety and security of their unwanted sealed
radiological sources. For example, in fiscal year 2004, at the request of
NRC, DOE recovered from a bankrupt firm and commercially disposed of 443
mostly cesium-137, sealed radiological sources at a cost of approximately
$581,000. Moreover, DOE may need to begin recovering greater quantities of
non-GTCC waste from unwanted sealed radiological sources if licensees in
most states have no access to commercially dispose of it in the future.
Domestic and international experts contend that the lack of disposal
availability for unwanted sealed radiological sources makes them more
vulnerable to abandonment, misplacement, and theft that would

pose a safety and security risk. If DOE needs to recover more of these
types of sources, source recovery project expenditures may increase unless
DOE can recoup some of its costs from licensees that could otherwise pay
for disposal if a commercial disposal option were available. In the
absence of any commercial disposal option for the non-GTCC waste that DOE
collects, the department anticipates indefinitely storing this waste.
DOE's current policy is to not use its own sites for disposing of this
waste because, among other reasons, it does not want to undermine the
responsibility that the Congress gave to the states for providing disposal
availability for non-GTCC waste. We are recommending that DOE and NRC
collaborate in evaluating and reporting on the potential cost implications
of expanding DOE's recovery and disposal of non-GTCC waste from sealed
radiological sources, options to recoup DOE costs from licensees that may
have no disposal option, and the feasibility of disposing of this waste at
DOE sites.

DOE's ability to identify unwanted sealed radiological sources that may
pose a safety or security risk is limited by a lack of information needed
to guide its recovery and disposal efforts. DOE has useful inventory data
only on the sealed radiological sources in its possession, including those
recovered from licensees. This inventory captures, among other things,
information on the status of each source, including whether it is in
active use, is inaccessible, is in storage for potential future use, or is
packaged for disposal. However, DOE does not have comparable information
on the sealed radiological sources in the possession of licensees that
might need recovery in the future because NRC and the Agreement States do
not centrally collect this information from them. NRC has recently issued
a proposed rule that will allow it to establish a national system to track
the possession and movement of some individual sealed radiological sources
that present a potential risk to individuals, society, and the environment
because of their high levels of radioactivity. This proposed rule is
consistent with the recently enacted Energy Policy Act of 2005,12 which,
among other things, requires NRC to establish a tracking system and a task
force to evaluate and report on radiation source protection and security
concerns. However, as presently designed, this system would only track
individual sources with high radioactivity concentrations and would not
include essentially all of the sources of lesser radioactivity that DOE
has recovered. According to DOE, over 90 percent of the licensee sites
where sources were recovered contained individual sources of lesser
radioactivity than would be individually tracked by NRC, yet their
combined

12Pub. L. No. 109-58, 119 Stat. 594 (2005).

radioactivity concentration posed enough of a safety and security risk to
warrant their recovery by DOE. As a result, this proposed national source
tracking system would be of little use to DOE in its efforts to plan and
budget for the recovery and disposal of unwanted sealed radiological
sources. We are recommending that DOE and NRC collaborate on evaluating
and reporting on how a national source tracking system can be designed and
implemented to improve DOE's ability to identify unwanted sealed
radiological sources that may need DOE recovery and disposal.

DOE and NRC provided comments on a draft of this report. DOE stated that
it generally supports all of our recommendations. Moreover, DOE commented
that we had correctly reported the department's position with regard to
issues discussed in this report. In addition, DOE affirmed the need to
improve the national source tracking system to assist the department in
identifying and recovering unwanted sources from outside the department
that pose a potential safety and security risk. NRC stated that overall
our report was well written and balanced. NRC did not specifically agree
or disagree with our recommendations. However, NRC expressed concerns that
any changes to the design of its national source tracking system at this
time could be extremely burdensome on licensees and the agency and would
yield little, if any, practical benefit. Nevertheless, NRC stated that it
will continue to seek comments on the inclusion of sources of lower
radioactivity in its national source tracking system because licensees
possessing large quantities of these sources could present a security
concern.

Background	The loss of control of sealed radiological sources can arise
from their abandonment, misplacement, or theft. In such cases, there is a
risk of either the inadvertent or intentional malevolent human exposure to
radioactive materials in these sources. Figure 1 shows a graphic
representation of the ways in which the loss of control of sealed
radiological sources can occur.

Figure 1: Loss of Control of Sealed Radiological Sources

Inadvertent Damage Acquisition

(Sabotage)

Malevolent Motive Financial

Source: IAEA, Strengthening Control Over Radioactive Sources in Authorized
Use and Regaining Control Over Orphan Sources: National Strategies,
IAEA-TECDOC-1388 (Vienna, Austria: February 2004) p. 9.

Since September 11, 2001, international and U.S. agencies have taken
additional steps to increase the safety and security of radioactive
materials, particularly sealed radiological sources. Between 2002 and
2003, the International Atomic Energy Agency (IAEA)13 held various
meetings and conferences to discuss how the agency's Code of Conduct on
the Safety and Security of Radioactive Sources might be revised in light
of new security concerns. One result of these gatherings was the
development of a categorization scheme for sealed radiological sources in
terms of the

13IAEA was established within the United Nations in 1957. IAEA works with
its member states; 138 countries, including the United States; and
multiple other partners to promote safe, secure, and peaceful nuclear
technologies.

potential risks associated with their malevolent uses.14 The first three
of the five source categories identified by IAEA, which are considered to
pose the most significant risk to individuals, society, and the
environment, are listed in an annex to the Code of Conduct. The Code of
Conduct recommends that IAEA member states establish a national registry
that tracks, at a minimum, the first two source categories. Table 1
contains a listing of the radionuclides and their curie levels that are
presented in the IAEA Code of Conduct.

Table 1: IAEA High-risk Categories of Sealed Radiological Sources

                                       Category 1  Category 2      Category 3 
                       Radionuclide     (curies)a   (curies)a       (curies)a 
                      Americium-241         2,000            20 
            Americium-241/Beryllium         2,000            20 
                    Californium-252           500             5 
                         Cesium-137         3,000            30 
                          Cobalt-60           800             8 
                         Curium-244         1,000            10 
                     Gadolinium-153        30,000           300 
                        Iridium-192         2,000            20 
                      Plutonium-238         2,000            20 
            Plutonium-239/Beryllium         2,000            20 
                     Promethium-147     1,000,000        10,000         1,000 
                         Radium-226         1,000            10 
                        Scandium-75         5,000            50 
                        Selenium-75         5,000            50 
                       Strontium-90        30,000           300 
                        Thulium-170       500,000         5,000           500 

Ytterbium-169 8,000 80

Source: IAEA, Code of Conduct on the Safety and Security of Radioactive
Source (Vienna Austria: January 2004) Annex I, Table 1, p. 16.

aA curie is a measure of the rate of radioactive decay; it is equivalent
to the radioactivity of 1 gram of radium or 37 billion disintegrations per
second.

14IAEA, Categorization of Radioactive Sources, TECDOC-1344 (Vienna,
Austria: July 2003). IAEA defined five categories of radioactive sources
in this 2003 document. The agency based its categorization framework on
the health effects of exposure to the radioactive materials in the sources
and did not fully take into account the range of impacts that could result
from accidents or malicious acts involving radioactive sources.

In May 2003, a DOE/NRC interagency working group-which was formed to
address security concerns over the radioactive materials that could be
used in a radiological dispersal device-issued a report that, among other
things, recommended that actions be taken to develop a national threat
policy based on vulnerability assessments, a national source tracking
system, and an integrated national strategy for disposing of unsecured
sealed radiological sources.15 Following this DOE/NRC report, NRC adopted
the nonlegally binding IAEA Code of Conduct as a basis for (1) determining
which licensees may need additional protective measures for the sealed
radiological sources in their possession and (2) defining the scope of a
national source tracking system. NRC found that the curie thresholds for
radionuclides in the sources identified by the DOE/NRC interagency working
group were similar enough to the Code of Conduct categories to warrant
adoption of the IAEA source categorization scheme to better align domestic
and international efforts to increase the safety and security of sealed
radiological sources.

NRC and DOE have since engaged in separate efforts to (1) assess the
vulnerability of facilities that contain sealed radiological sources
within their jurisdictions, (2) promulgate new security measures, and (3)
begin systematically tracking some of these sources. According to NRC
officials, NRC has been working with the Agreement States since January
2002, and with licensees since September 2002, using a risk informed
approach to enhance the regulatory requirements applicable to high-risk
radioactive material. In June 2003 and January 2004, NRC issued its first
set of protective measures to large irradiators and device manufacturers
and distributors, respectively. In January 2004, NRC and the Agreement
States began to consider the need for additional protective measures for
other licensees. This process has involved several iterations of
vulnerability assessments of licensee sites that have devices or use
applications containing IAEA categories 1 and 2 sources, such as
teletherapy, gamma knife, well-logging devices, and self-shielded
irradiators. On September 6, 2005, NRC announced that over approximately
the next 90 days, affected licensees will receive orders from the agency
spelling out increased controls for certain radioactive materials. Over
the same period, individual Agreement States will issue their licensees
legally binding requirements essentially identical to NRC's orders.
Materials covered by these

15DOE/NRC Interagency Working Group on Radiological Dispersal Devices,
Radiological Dispersal Devices: An Initial Study to Identify Materials of
Greatest Concern and Approaches to Their Tracking, Tagging and Disposal
(May 2003).

requirements will be consistent with the IAEA Code of Conduct. Regarding
source tracking, in November 2003, NRC, with the assistance of the
Agreement States, identified and initially surveyed approximately 2,600
entities licensed to possess IAEA categories 1 and 2 sources. The
resulting interim inventory will supplement other information NRC intends
to use in developing a national source tracking system. Regarding DOE
efforts, DOE officials told us that various department offices have been
involved in developing, reviewing, and issuing domestic and international
guidance related to the security of sealed radiological sources. Moreover,
DOE has established its own source tracking system-that is, the
Radioactive Source Registry and Tracking System-which, among other things,
includes the unwanted sealed radiological sources that DOE has recovered
from licensees.

In addition to securing and tracking sealed radiological sources, IAEA and
NRC support the disposal of unwanted sources and other radioactive waste.
IAEA contends that although waste may be safely stored for decades, as
long as institutional controls are maintained, progress must be made
toward permanent disposal. According to the Director General for Energy
and Transport, European Commission, "the sources at greatest risk of being
lost from regulatory control are disused (unwanted) sources held in local
storage at the user's premises waiting for final disposal or return to
manufacturer."16 In response to an international joint convention
addressing spent nuclear fuel and radioactive waste management,17 IAEA set
forth the elements of an effective national legal and organizational
structure that would provide for the safe and secure management of
radioactive waste by appropriate national authorities. One of the key
indicators of such a structure is that "the amount of waste in storage
awaiting disposal should depend only upon operational considerations...and
should not include a backlog due to an inability (technical, financial,
organizational, etc.) to reduce the backlog."18 NRC also supports the
disposal of low-level radioactive waste but has placed no time limits on
storage, as long as the radioactive material is safe and

16IAEA, Proceedings of an international conference on security of
radioactive sources, held March 10-13, (Vienna, Austria: 2003).

17A Joint Convention on the Safety of Spent Fuel Management and on the
Safety of Radioactive Waste Management, signed by Member States of the
IAEA, entered into force on June 18, 2001.

18IAEA, Radioactive Waste Management: Status and Trends-Issue No. 2
(Vienna, Austria: September 2002) p. 16.

secure. NRC contends that it is acceptable to allow some licensees to
store a backlog of sources in instances where a disposal option for this
waste is not available to them.

In August 2005, the President signed into law the Energy Policy Act of
2005, which, among other things, addressed the safe disposal of GTCC waste
and nuclear facility and materials security. The act requires DOE to
prepare plans for the continued recovery of sealed radiological sources
and to report on its efforts to develop a GTCC waste disposal site. Other
provisions call for NRC to issue regulations establishing a mandatory
tracking system for radiation sources in the United States and to chair a
task force on radiation source protection and security. The task force,
comprised of NRC, DOE and other federal agencies, in consultation with
other groups, is to evaluate and provide recommendations relating to the
security of radiation sources in the United States from potential
terrorist threats, including acts of sabotage or theft or the use of
radiation sources in a radiological dispersal device.

  DOE Has Increased Emphasis on Its Source Recovery Project and Begun Assessing
  Options for Disposing of GTCC Waste

DOE has placed increased emphasis on its source recovery project and has
begun to assess disposal options for GTCC waste. DOE has realigned its
source recovery project within NNSA to more effectively respond to both
domestic and international threats posed by unwanted sealed radiological
sources. Further, DOE has accelerated its recovery efforts, surpassing an
earlier source recovery goal, and has made progress in resolving a storage
space shortage at its facilities that has slowed the recovery of certain
unwanted sealed radiological sources. Finally, DOE has begun preparing an
environmental impact statement to assess possible disposal options for
GTCC waste. However, difficulties in estimating current GTCC waste storage
and future waste volumes, especially from sealed radiological sources,
will complicate this effort. Further, DOE has not yet determined when a
permanent GTCC waste disposal facility will be available.

DOE Transferred To better respond to the security threats posed by
unwanted sealed Responsibility for the radiological sources both within
the United States and abroad, in October Source Recovery Project to 2003,
DOE realigned management responsibilities for its source recovery

    NNSA

project from the Office of Environmental Management to NNSA.19 This
realignment was, in part, a response to a recommendation to the Secretary
of Energy that we made in our April 2003 report that the priority given to
its Off-Site Source Recovery Project be commensurate with the threat posed
by some unwanted sealed radiological sources. Subsequently, NNSA
established the Nuclear and Radiological Threat Reduction Task Force,
under the Office of Defense Nuclear Nonproliferation, to unite all of the
department's radiological threat reduction efforts. One of the principal
missions of this task force is to identify; secure; and store, on an
interim basis, radioactive materials that could be used as a radiological
weapon. In May 2004, DOE announced the creation of the Global Threat
Reduction Initiative, which further elevated the importance of the task
force and DOE's recovery of sealed radiological sources. This initiative
was later institutionalized in the Office of Global Radiological Threat
Reduction, with a domestic component, the U.S. Radiological Threat
Reduction Program, and an international component, the International
Radiological Threat Reduction Program. The Off-Site Source Recovery
Project was subsumed under the U.S. Radiological Threat Reduction Program,
but the program retained Los Alamos National Laboratory personnel to
continue the source recovery effort.

    DOE Accelerated Its Efforts to Recover Unwanted Sealed Radiological Sources

DOE accelerated the recovery of unwanted sealed radiological sources
beginning in late 2002. As we reported in April 2003, DOE's ability to
meet planned recovery activities was largely facilitated by supplemental
congressional funding and by the urging of NRC to accelerate recovery
efforts in light of the events of September 11, 2001. In August 2002, the
Congress provided an additional $10 million to DOE's Off-Site Source
Recovery Project to recover 5,000 unwanted sealed radiological sources
over the following 18 months.20 Between October 1, 2002, and March 31,
2004, DOE recovered 5,529 of these sources, exceeding its recovery goal
and more than doubling the number of sources previously recovered since
1996. As of June 7, 2005, DOE had recovered 10,806 of these sources.
According to the source recovery project leader, the bulk of the remaining

19This realignment did not include transferring responsibilities for the
long-term storage and disposal of the recovered sources.

20H.R. Rep. No. 107-593, at 142 (2002), conference report accompanying
Pub. L. No. 107-206, Making Supplemental Appropriations for Further
Recovery From and Response to Terrorist Attacks on the United States for
the Fiscal Year Ending September 30, 2002, and for Other Purposes.

excess and unwanted sealed radiological sources in the United States
should be recovered in the next 2 years. Table 2 contains a summary of
DOE-recovered sealed radiological sources, by radionuclide, as of June 7,
2005.

Table 2: Summary of DOE-Recovered Sealed Radiological Sources, by
Radionuclide, as of June 7, 2005

                                              Percentage           Percentage 
                                    Number of   of total             of total 
                      Radionuclide    sources    sources   Curiesa    curiesa 
           Americium-241/Beryllium      5,222     48.33% 11,657.48      7.77% 
                     Plutonium-238      1,907      17.65 7,040.66        4.70 
                     Americium-241      1,900      17.58    464.07       0.31 
         Americium-241/Berylllium/                                 
                        Cesium-137        552       5.11     26.48       0.02 
                      Cesium-137Cs        363       3.36 1,621.65        1.08 
         Plutonium-239Pu/Beryllium        255       2.36    543.42       0.36 
                        Colbalt-60        197       1.82 42,602.21      28.41 
           Plutonium-238/Beryllium        169       1.56 2,186.87        1.46 
                     Plutonium-239         99       0.92      5.48       0.00 
                     Neptunium-237         25       0.23      0.01       0.00 
              Americium-241/Cerium         24       0.22     51.00       0.03 
             Americium-241/Lithium         22       0.20    437.00       0.29 
                        Curium-244         18       0.17      7.51       0.01 
                        Radium-226         17       0.16      0.05       0.00 
             Plutonium-238/Lithium         16       0.15    255.50       0.17 
                      Strontium-90         10       0.09 82,958.85      55.33 

      Plutonium-238/Lithium/                                     
            Cesium-137                 7       0.06        66.10      0.05 
            Uranium-235                2       0.02         0.00      0.00 
        Americium-241/Boron            1       0.01        15.00      0.01 
               Total              10,806    100.00%  149,939.34    100.00% 

Source: DOE source recovery project inventory database.

aA curie is a measure of the rate of radioactive decay; it is equivalent
to the radioactivity of 1 gram of radium or 37 billion disintegrations per
second.

DOE has maintained its source recovery project efforts through annual and
supplemental appropriations. In our April 2003 report, we recommended that
the Secretary of Energy ensure that adequate resources be devoted to

covering the costs of recovering and storing unwanted sealed radiological
sources as quickly as possible. In a September 2004 congressional hearing,
the director of DOE's Office of Global Radiological Threat Reduction
testified that the department had increased funding for the source
recovery project and had committed funds for continuing these efforts.21
The director stated that the fiscal year 2004 program budget was $1.96
million, not including about $3.49 million that was added to the budget to
respond in part to unexpected requests from NRC to recover sources of
security concern.22 In fiscal year 2005, the source recovery project
budget was increased to $5.6 million; for fiscal year 2006, DOE has
requested $12.8 million, in part, to better fund the expanded scope of the
U.S. Radiological Threat Reduction Program. The source recovery project
leader has estimated an average recovery cost of $3,000 per source, on the
basis of the initial 10,000 sources recovered, not including commercial
disposal costs for certain sources.

DOE plans to continue recovering unwanted sealed radiological sources, at
least until a GTCC waste disposal site is available. In our April 2003
report, we recommended that the Secretary of Energy develop a plan to
ensure the continued recovery and storage of unwanted sealed radiological
sources until a GTCC waste disposal site is available. We reported that
DOE used several sources of information and made three key assumptions
when projecting the anticipated need to recover 14,309 sources between
fiscal years 1999 and 2010. The assumptions were that (1) a permanent
disposal site for the sources would be available by fiscal year 2007; (2)
the Off-Site Source Recovery Project would continue to recover sources
from certain holders of sources during a transition period from fiscal
years 2007 through 2010; and (3) after fiscal year 2010, all unwanted
sealed radiological sources would be shipped by their owners to a disposal
site, and the Off-Site Source Recovery Project would cease operations.
However, according to the manager of DOE's U.S. Radiological Threat
Reduction Program, these assumptions are no longer used by the department
because the lack of a firm date for when a GTCC waste disposal site will
be available means that DOE cannot determine when it will cease recovering
unwanted sealed radiological sources from licensees. The Energy Policy Act
of 2005 requires

21Statement of Edward G. McGinnis, Director, Office of Global Radiological
Threat Reduction, National Nuclear Security Administration, Department of
Energy, before the United States Senate, Energy and Natural Resources
Committee, September 30, 2004.

22According to NRC, funding to support its request represented about
$500,000 of the additional $3.49 supplemental funding for the source
recovery project in fiscal year 2004.

DOE to submit a plan to the Congress that ensures the continued recovery
and storage of unwanted sealed radiological sources that pose a security
threat until a permanent GTCC waste disposal facility is available.
Further, this DOE manager told us that source recovery project personnel
may still be needed to help some licensees to meet the packaging
requirements of any future GTCC waste disposal facility.

    DOE Has Made Progress in Resolving a Storage Space Shortage That Has Slowed
    Recovery of Some Sealed Radiological Sources

DOE has taken actions to address the storage space shortage that has
prevented the recovery of certain types of unwanted sealed radiological
sources. We reported in April 2003 that DOE had inadequate storage
capacity to meet the higher security needs for recovered sealed
radiological sources containing plutonium-239, and lacked a means for
temporarily storing sources containing strontium-90 and cesium-137. We
recommended, among other things, that the Secretary of Energy take
immediate action to provide storage space for these sources at a secure
DOE facility. According to the director of DOE's Office of Global
Radiological Threat Reduction, as of September 2004, DOE had developed
sufficient storage space at the Los Alamos National Laboratory and the
Nevada Test Site to recover more than 260 plutonium-239 sealed
radiological sources registered by licensees for collection. According to
the source recovery project team leader, DOE's plan has been to recover
over 100 remaining plutonium-239 registered sources, representing
approximately 60 drums of waste;23 ship them to the Nevada Test Site; and
then incrementally transfer them to the Los Alamos National Laboratory as
space is made available from the shipment of the existing stored
plutonium-239 sources to the Waste Isolation Pilot Plant (WIPP) in New
Mexico.24 WIPP will only accept sources that are shipped from Los Alamos.
Implementation of this plan, however, has been delayed pending final
approvals to ship these sources between locations.

23As a comparison, according to the source recovery project team leader,
the Los Alamos National Laboratory is currently storing 21,000 55-gallon
drums of DOE- or defense-related nuclear waste destined for disposal at
WIPP.

24WIPP, operated by DOE and licensed by the Environmental Protection
Agency, is an underground repository for defense-generated transuranic
waste. Transuranic waste refers to man-made radioactive wastes that have
particles whose atoms are heavier than uranium; are alpha
particle-emitting, with a half-life longer than 20 years; and have a
concentration greater than 100 nano-curies per gram of waste. These wastes
include radionuclides, such as americium-241, plutonium-238, and
plutonium-239, that are generated by nuclear weapons production and the
reprocessing of spent nuclear fuels.

Additional progress has been made in addressing the storage issues that
relate to unwanted strontium-90, cesium-137, and some cobalt-60 sealed
radiological sources. According to the source recovery project team
leader, DOE has recovered a strontium-90 radioisotopic thermoelectric
generator that was owned by the department and used as a remote power
supply and disposed of the generator at the Nevada Test Site. DOE also has
recovered six of these devices that were commercially owned and is storing
them at the Los Alamos National Laboratory, pending approval for disposal
as waste. Regarding the cesium-137 sealed radiological sources, the source
recovery project has recycled 5 large cesium-137 irradiators to commercial
firms. DOE has also contracted to recover the remaining 14 registered
irradiators by the end of fiscal year 2005. Moreover, the team leader told
us that the source recovery project plans to collect 221 cobalt-60 sources
from a university this summer and to dispose of them at the Nevada Test
Site as DOE-owned nuclear material.

    DOE Is Preparing an Environmental Impact Statement for GTCC Waste Disposal
    Options, but Estimating Storage and Future Waste Volumes Will Be Difficult

DOE has begun to take action to identify a suitable location for the
disposal of GTCC waste, but producing useful estimates of the current
storage and future generation of this waste will be difficult. We reported
in April 2003 that DOE had not made progress toward providing for a
permanent disposal facility for the nation's GTCC waste, and that it was
unlikely to provide such a facility by fiscal year 2007 because developing
a disposal site for this waste was considered a low priority within the
department. We recommended that the Secretary of Energy initiate a process
to develop a permanent disposal facility for GTCC waste, including
empowering an office to take on this responsibility. In September 2004,
DOE took a first step in this direction by transferring responsibility for
assessing disposal options for GTCC waste from its Office of Environment,
Safety, and Health to its Office of Environmental Management. With this
authority and the heightened need to take action, on May 11, 2005, the
Office of Environmental Management published an advance notice in the
Federal Register of its intent to prepare an environmental impact
statement (EIS) for GTCC waste disposal.25 DOE now anticipates that the
actual notice of intent to prepare the EIS will be issued in the fall of
2005, followed by public meetings to further define the scope of the EIS
and to identify significant issues to be addressed. The DOE document
manager for the EIS told us that after the notice of intent is issued, the
process of preparing the

2570 Fed. Reg. 24775 (May 11, 2005).

EIS could take 2 years. The Energy Policy Act of 2005 requires that,
within 1 year, DOE report to the Congress on the estimated costs and a
proposed schedule to complete both the EIS and a record of decision for a
permanent disposal facility for GTCC waste. Moreover, before DOE makes a
final decision on the long-term disposal alternative or alternatives to be
implemented, this act requires DOE to prepare a report to the Congress
describing all alternatives under consideration, including recommendations
for ensuring the safe disposal of GTCC waste, and then to await action by
the Congress. Therefore, it is not possible for DOE to determine when a
permanent disposal facility will be available for GTCC waste.

In his September 2004 congressional testimony, the director of DOE's
Office of Global Radiological Threat Reduction, stated that the EIS for
GTCC waste disposal will include an analysis of waste inventories,
longterm disposition alternatives, and resource requirements-as well as an
assessment of legislative, regulatory, and licensing requirements.
According to the director, the broad scope of the EIS should enable DOE to
consider any new or existing site, facility, and disposal method for GTCC
waste. Possible locations and disposal options include commercial, DOE, or
other governmental facilities and private land. The disposal methods
examined will range from deep geologic disposal to enhanced near-surface
disposal, depending on the type of GTCC waste.

In completing the EIS, DOE plans to inventory the GTCC waste in storage at
licensee and DOE facilities as well as estimate the waste expected to be
generated in the future. According to the DOE document manager for the
EIS, the department will obtain information on nuclear utility and DOE
GTCC waste that is currently in storage and will estimate future volumes
over the next 30 to 50 years on the basis of a representative sample of
some nuclear power plants that are being decommissioned, and from existing
DOE databases. For nonutility licensees, the information on the storage
and projected generation of GTCC waste will be more speculative. This
official said that DOE has selected a contractor to update the estimates
made in a 1994 DOE report that the department now considers outdated.26
DOE asked the contractor to begin with the methodology used in the 1994
report to estimate current GTCC waste storage and to project future

26Idaho National Engineering Laboratory, Greater-Than-Class C Low Level
Radioactive Waste Characterization: Estimated Volumes, Radionuclides and
Other Characteristics,

DOE/LLW-114, Revision 1 (Idaho Falls, ID: September 1994).

generation of these wastes by nonutility licensees, rather than attempt to
survey all NRC and Agreement State licensees that might possess these
radioactive materials.

Attempting to obtain information on nonutility licensee storage of GTCC
waste that can be used to estimate future generation of GTCC waste from
sealed radiological sources will be especially difficult. Of the three
types of GTCC waste, the second largest volume behind activated metals is
from sealed radiological sources. Uncertainties surround producing these
estimates, such as (1) how to determine the quantities of unwanted sealed
radiological sources in storage and (2) how much waste and what class of
waste might be generated once these sources are packaged for disposal. One
estimating problem is that there is currently no standard process by which
licensees declare their sealed radiological sources as disused (unwanted).
According to an NRC official, sealed radiological sources would not be
considered waste, even if they are stored unused by a licensee, until the
licensee has determined that they are no longer useful. In addition,
sealed radiological sources that are no longer useful may be returned to
the source manufacturer or allowed to decrease in radioactivity
concentration while in storage so that they can be disposed as a lower
level waste class. Because licensees typically do not declare their
disused (unwanted) sources as waste until they are packaged and ready for
shipment to a waste broker or disposal site, it will be difficult for DOE
to project when this type of waste might need disposal in a GTCC waste
disposal facility.

Another uncertainty in estimating the future quantities of GTCC waste is
that the volume of waste generated by a small sealed radiological source
is determined by the size of its disposal container and not by the size of
the source or number of sources in the container. Disused sources are
typically placed in 30-gallon or 55-gallon disposal drums. The number of
sources put into one drum and the packing materials used are affected by
the acceptance criteria of the disposal site. Figure 2 shows a sequence of
photographs depicting source recovery project personnel removing a 5curie,
plutonium-239/beryllium source and repackaging it into a 55-gallon drum
especially designed to meet the acceptance criteria at WIPP. Source
recovery project personnel told us that these drums cost between $5,000
and $6,000 each. The sealed radiological source held in pliers in the
first photograph is clearly a fraction of the size of the 55-gallon
disposal drum.

Figure 2: Source Recovery Project Personnel Remove a Sealed Radiological
Source and Repackage It into a WIPP-Acceptable Disposal Drum

Source: GAO.

Pictured left to right: A sealed source being removed (in pliers) from a
shielded storage container at a recovery site; the interior of a
multifunction container used for transport, storage, and disposal; and the
process of closing the steel pipe component after the source has been
loaded into the multifunction container.

Figures 3 through 5 show photographs that illustrate the scale of sealed
radiological sources relative to their devices as well as how the sources
or their devices are packaged into more traditional disposal drums.

Figure 3: Relative Size of a Sealed Radiological Source and Typical
Disposal Drums

Source: GAO.

A display of sealed radiological source components: (A) radioisotopes in
powder or ceramic pellet form within glass vials, (B) solidified
radioactive material, (C) metal cells with lid to hold the radioactive
material, (D) completed sealed radiological sources, and (E) two types of
protective metal holders. Note the nickel (F) for scale.

Figure 4: A Cross Section of a Nuclear Gauge, and Leveling Gauges Returned
to a Manufacturer

Source: GAO. Source: GAO.

A cross section of a nuclear gauge for level or density measurement that
Leveling gauges returned to a manufacturer, each containing a sealed
relies on a cesium-137 sealed radiological source, as shown in the middle
radiological source. Most sealed source manufacturers state that these of
the gauge (A). types of devices have 15 years of working life.

Figure 5: Interior Views of Two 55-Gallon Disposal Drums, One with a Large
Opening for an Entire Disused Device and the Other with a Narrow Pipe
Opening for Only Sources

Source: GAO. Source: GAO.

Interior view of a 55-gallon disposal drum with a large opening, Interior
view of a 55-gallon disposal drum with a narrow pipe opening, surrounded
by concrete, that will hold a disused leveling gauge device surrounded by
concrete, in which sealed radiological sources will be from which the
sealed radiological source could not be safely removed. placed.

Yet another uncertainty in projecting the future volume of GTCC waste from
sealed radiological sources is that different types of radionuclides can
comprise the sources used in a device, and, depending on the radionuclide
used, the age of the source, and how the source is packaged for disposal,
the device can fall into different classes of waste. For example, as shown
in table 4 in appendix II, six different radionuclides can be used as the
source in an industrial radiography device. Further, the sources that can
be used in this industrial radiography device can produce non-GTCC and
GTCC waste, depending in part on how much radioactivity remains in the
source when it is disposed of and how the source is packaged. For example,
a 5curie, cesium-137 sealed radiological source that is used in a device
might fall into a GTCC waste class when packaged if little of the source
is depleted; but once it becomes unwanted and then packaged in a 55-gallon
disposal drum with nonradioactive filler material, it might fall into the
non-GTCC waste class because its radioactivity, as averaged over the
entire volume of the drum, would be lower.

  DOE Expanded the Scope of Its Source Recovery Project to Include Non-GTCC
  Waste, Which Could Increase Project Expenditures

DOE has expanded its source recovery efforts to include all sealed
radiological sources that could present a threat, a change that could
increase project expenditures. DOE's source recovery project now includes,
among other activities, the recovery and commercial disposal of non-GTCC
waste from unwanted sealed radiological sources that pose a health,
safety, security, or environmental threat. The recovery and commercial
disposal of more of these types of sealed radiological sources from
licensees that cannot afford to dispose of them today, in addition to the
recovery of higher radioactive sources, is likely to increase DOE project
expenditures. Further, DOE may need to recover even more non-GTCC waste
from unwanted sealed radiological sources in the future if licensees in
many states lose access to the only commercial low-level radioactive waste
disposal site where they can currently dispose of higher radioactive
non-GTCC waste (classes B and C waste). This increased recovery of
non-GTCC waste from sealed radiological sources will place greater demands
on source recovery project expenditures because of impediments to DOE's
recouping recovery costs from licensees that could otherwise cover their
source disposal costs if there were disposal availability. In the absence
of access to commercial disposal, DOE anticipates the need to indefinitely
store the recovered non-GTCC waste until a commercial disposal option
becomes available. DOE's current policy does not include using DOE sites
to permanently dispose of this waste because, among other reasons, it does
not want to undermine the authority the Congress gave to the states to
provide disposal availability for non-GTCC waste.

    DOE Has Recovered and Commercially Disposed of Some Non-GTCC Waste

The expanded scope of the source recovery project now includes, among
other activities, the collection and commercial disposal of non-GTCC waste
from unwanted sealed radiological sources that pose a health, safety,
security, or environmental threat.27 Responsibility for the safe
management and disposal of these radioactive materials is normally held by
those entities that NRC or the Agreement States license to possess and use
these materials. However, in some cases, licensees are unable to (1)
ensure the safe and secure use of these materials or (2) cover the
disposal costs of their unwanted sealed radiological sources. For example,
according to the

27The other activities of the source recovery project include recovering
from other countries sealed radiological sources that were previously
owned by the U.S. government, cooperating with IAEA, and working with the
Department of Homeland Security.

source recovery project leader, at the request of NRC, DOE commercially
disposed of its first significant quantities of non-GTCC waste during
fiscal year 2004. Source recovery project personnel collected 443 unwanted
sealed radiological sources (containing cesium-137, cobalt-60, or
radium226) from a bankrupt firm in Pennsylvania and commercially disposed
of most of them at the Barnwell, South Carolina, disposal site. In
commenting on a draft of this report, DOE provided examples of other
non-GTCC waste from sealed radiological sources that it had recovered.

Under the expanded scope of the source recovery project, DOE has developed
a priority scheme for deciding which sources to recover and when to do so.
According to the director of DOE's Office of Global Radiological Threat
Reduction, DOE has been working with the Department of Homeland Security
and other agencies, in addition to NRC, to determine the sources that
should receive the highest priority for recovery, including those that
when disposed of would not be considered GTCC waste. In addition, the
manager of DOE's U.S. Radiological Threat Reduction Program told us that
DOE and NRC are also in the process of revising the 1999 memorandum of
understanding that defined the responsibilities of each agency with
respect to the problem of unwanted and uncontrolled sealed radiological
sources to better reflect current DOE recovery practices. The source
recovery project leader provided us with an initial priority ranking
scheme for recovering sources that is used by DOE, as well as some other
factors that DOE considers. The initial ranking involves combining three
factors into an overall risk ranking for each licensee site that contains
sealed radiological sources. These factors include the level of security
over the source at a licensee site, the total quantity of radioactive
material present, and the quantity of radioactive material in any single
sealed radiological source to a licensee site. Other factors that DOE
considers when prioritizing sources at recover include the opportunity of
recovering additional unwanted sealed radiological sources that source
recovery personnel may discover during their visit at a licensee site. For
example, the source recovery project leader told us that if team members
come across vulnerable sealed radiological sources of lesser radioactivity
at a location where they are recovering higher radioactive sources, they
will collect them as well.

    Recovery of More Non-GTCC Waste from Sealed Radiological Sources Could
    Increase Project Expenditures Because DOE Cannot Recoup Recovery Costs

DOE has already incurred additional expenses to recover and commercially
dispose of non-GTCC waste from unwanted sealed radiological sources. It
cost DOE approximately $581,000 to recover hundreds of these sources that
had accumulated at a bankrupt firm in Pennsylvania and to commercially
dispose of them. The Barnwell disposal site received 15 of the 16,
55-gallon and 30-gallon drums of this non-GTCC waste and charged DOE a
$1,650 per-cubic-foot disposal fee. For example, the disposal fee and
container cost for just 1, 55-gallon disposal drum holding 130 of the
recovered cesium-137 sealed radiological sources cost DOE about $21,000,
not including labor, transport, and other costs. Additional DOE recovery
of non-GTCC waste from licensees that currently need to store their
sources and other waste because they do not want to or cannot pay these
high disposal fees may be necessary in the future. According to the deputy
director of DOE's Office of Global Radiological Threat Reduction, because
of the cost involved, encouraging those licensees that have sealed
radiological sources to dispose of them properly has proven difficult,
particularly with entities that only have a few sources. NRC can impose
fines as high as three times the cost of commercial disposal on a licensee
that fails to properly dispose of radioactive material.28 However, a
senior NRC official has publicly acknowledged the difficulty that
licensees with only a few unwanted sources have in finding a
cost-effective means for disposing of them.

DOE is currently impeded from recouping more of its recovery and storage
costs for GTCC waste as well as any non-GTCC wastes that it may need to
recover. Regarding GTCC waste, since DOE issued its 1987 report on how it
planned to address its responsibilities under the Low-Level Radioactive
Waste Policy Act of 1980, as amended, no specific action has been taken to
identify a different method of funding the source recovery project, other
than through the appropriations process. According to the manager of DOE's
U.S. Radiological Threat Reduction Program, DOE has been unable to
establish a standard fee for recovering unwanted sealed radiological
sources from licensees because existing cost recovery mechanisms require
the department to know both the number of years that these sources will be
stored and the cost of their disposal before setting a fee, which is not
currently possible. Regarding non-GTCC waste, the sources recovered to
date were primarily from a commercial firm that had gone bankrupt and

28NRC policy establishes base civil penalties for loss, abandonment, or
improper transfer or disposal of sealed radiological sources and devices
that, according to NRC, have been imposed on many occasions.

did not have the necessary funds to cover the cost of disposing of its
sources. DOE had to cover the recovery and commercial disposal costs
because there was no other source of funding. One of the reporting
requirements for the task force on radiation source protection and
security, required under the Energy Policy Act of 2005, is to provide
recommendations for appropriate regulatory and legislative changes for the
establishment of, or modification to, a national system (including user
fees and other methods) to provide for the proper disposal of sealed
radiological sources under the act.

    DOE May Need to Recover and Dispose of More Non-GTCC Waste If Licensees Have
    No Disposal Option, Further Increasing Demands on Project Expenditures

In the future, DOE may have to recover more non-GTCC waste from sealed
radiological sources if licensees that are forced to store their unwanted
sources because they have no access to a disposal site. As we reported in
June 2004, if South Carolina follows through with plans to restrict access
to the Barnwell disposal site to only the three member states of the
Atlantic Compact by mid-2008, and if no disposal alternative for the more
highly radioactive non-GTCC waste (classes B and C waste) is developed,
licensees in 36 states that are presently allowed to use this site will
need to store more of their unwanted radioactive materials. Although NRC
does not place time limits on the storage of radioactive materials as long
as they are safe and secure, greater quantities and longer periods of
storage, particularly of unwanted sealed radiological sources, will likely
increase safety and security risks. In January 2002, NRC sent a letter to
DOE requesting that the source recovery project take actions to recover
registered unwanted sealed radiological sources because the possession and
storage of these sources with no GTCC waste disposal outlet represented a
potential health and safety threat. Regarding non-GTCC waste from unwanted
sealed radiological sources, the manager of DOE's U.S. Radiological Threat
Reduction Program told us that DOE will likely need to increase the
recovery of these sources if licensees have no commercial disposal option
for this waste. Domestic and international experts contend that the lack
of disposal availability for unwanted sealed radiological sources can
increase their risk of abandonment, misplacement, and theft. For example,
the Health Physics Society29 stated

29The Health Physics Society is a nonprofit, scientific professional
organization whose mission is to promote the practice of radiation safety.
The society has approximately 6,000 scientists, physicians, engineers,
lawyers, and other professionals representing academia, industry,
government, national laboratories, the Department of Defense, and other
organizations.

that the lack of a GTCC and non-GTCC waste disposal option for unwanted
sealed radiological sources that pose security and public health concerns
will continue to increase the number of orphan sources. Further, IAEA has
reported that disused (unwanted) sources represent the largest pool of
vulnerable and potential orphan sources.30 If DOE were to begin recovering
more non-GTCC waste from unwanted sealed radiological sources, even
greater demands will be placed on DOE recovery project resources if DOE
cannot recoup some of its recovery costs from licensees. While DOE is
justified in covering the recovery and commercially disposal cost of the
non-GTCC waste it has collected from licensees that could not afford to
dispose of it themselves, the department may be able to recoup some of its
costs in the future from licensees that could afford the cost of disposal
if it were commercially available.

It is difficult to estimate the budgetary impact on DOE if there were a
need to increase the recovery of unwanted sealed radiological sources from
licensees that have no access to a commercial disposal site for their
higher radioactive non-GTCC waste. One reason for this situation is the
lack of information on the number of sources in storage that might need
DOE recovery. As we reported August 2003, there is no national database on
the quantities of sealed radiological sources in storage. Moreover, there
is no national database that tracks the storage of any low-level
radioactive waste. Given the lack of national data on how much waste is
generated annually, the disposal data from low-level radioactive waste
disposal operators can only provide an indication of the quantity of
disused or unwanted sealed radiological sources and other waste that might
need storage each year in the absence of disposal availability.
Nevertheless, we found that between 2001 and 2004, the Barnwell disposal
site disposed of, on average, 31,150 cubic feet of the higher radioactive
non-GTCC waste (classes B and C waste), of which about 588 cubic feet, or
about 2 percent of the total, was derived from disused sealed radiological
sources.31 Approximately one-half of the sealed radiological source waste
(about 56 percent) came from private industry, followed by government
agencies (about 25 percent), colleges and universities (about 11 percent),
and

30IAEA, Strengthening Control Over Radioactive Sources in Authorized Use
and Regaining Control Over Orphan Sources: National Strategies,
IAEA-TECDOC-1388 (Vienna, Austria: February 2004) p. 54.

31Between 2001 and 2004, the other low-level radioactive waste disposal
site in Washington only received an average of 155 cubic feet of classes B
and C waste comprised of sealed radiological sources.

medical waste (about 4 percent). If DOE recovered, took title of, and
commercially disposed of all non-GTCC waste from sealed radiological
sources that are sent to the Barnwell disposal site annually, it might
cost DOE approximately $1 million a year just to cover the disposal cost
at the current $1,700 cubic foot disposal fee rate. However, until DOE has
better information on the number of sources that may need to be recovered
and future disposal costs, including recovery, packaging, transport, and
other costs, it will be difficult to accurately estimate future costs of
recovering non-GTCC waste.

    Lack of Commercial Disposal Availability Could Heighten Interest in Using
    DOE Sites for Disposal

If licensees lose access to commercial disposal sites for their higher
radioactive non-GTCC waste in the future, DOE will likely have to recover
more of this waste from unwanted sealed radiological sources, which could
heighten interest in using DOE sites for disposal of these wastes. The
manager of DOE's U.S. Radiological Threat Reduction Program told us that
although DOE is not legally prohibited from permanently disposing of, at
DOE sites, the recovered non-GTCC waste for which it has taken title, it
would not want to do so. This DOE manager said that on the basis of
current policy, DOE would indefinitely store any recovered non-GTCC waste
from unwanted sealed radiological sources at its sites until commercial
disposal is available or DOE receives other congressional guidance. The
DOE manager provided three reasons to justify this current policy. First,
DOE does not want to undermine the responsibility given by the Congress to
the states to provide disposal availability for non-GTCC waste under the
Low-Level Radioactive Waste Policy Act of 1980, as amended. Second, DOE is
not allowed to compete with commercial waste companies for the disposal of
non-GTCC waste. Finally, DOE does not want to dispose of the relatively
small quantity of recovered non-GTCC waste at its sites because this might
set a precedent for disposing of all non-GTCC waste that does not have a
commercial disposal pathway. However, in lieu of storing this non-GTCC
waste, this DOE manager suggested that DOE could, under emergency access
provisions, approach the regulatory bodies that have jurisdiction over
commercial disposal sites to obtain disposal access. Despite DOE's current
policy regarding what it would do in the future with recovered non-GTCC
waste if there were no commercial disposal availability, there have been
calls to consider using DOE sites for the disposal of this waste. Our June
2004 report32 discussed some issues

32GAO-04-604.

that would need to be resolved to use DOE sites for this waste, including
the feasibility of DOE's accepting all non-GTCC waste, the responsibility
for paying for the disposal of this waste, and the licensing and
regulatory responsibilities covering its disposal.

  DOE Lacks Information to Better Identify Unwanted Sealed Radiological Sources
  That May Need Recovery

DOE lacks information that would assist in its efforts to identify and
recover unwanted sealed radiological sources that pose a safety or
security risk. Although DOE maintains an inventory of recovered sealed
radiological sources and sources registered for future recovery, neither
DOE nor any other government agency has centrally tracked the number of
sources in the United States or the number of unwanted sources in storage
at licensee sites across the country. Under the current regulatory
structure, NRC and Agreement states only know the authorized uses and
maximum quantities allowed for each licensee, not what they actually
possess. As a result, DOE has no means of determining the actual number of
sealed radiological sources that may require recovery in the future. NRC
is currently developing a national source tracking system to, among other
things, identify the possession and movement of some high-risk sealed
radiological sources. However, as presently designed, this tracking system
lacks information that DOE might find useful in planning and budgeting for
the recovery of unwanted sealed radiological sources and their eventual
disposal.

    DOE Has Information on Sealed Radiological Sources Already Recovered and
    Limited Information on Those to Be Recovered

The source recovery project maintains its own inventory of sealed
radiological sources that have been recovered and are in storage, and
those that licensees or NRC have asked DOE to recover. According to the
source recovery project team leader, the accuracy of the information on a
sealed radiological source in this inventory improves from when a licensee
initially registers the source; to when source recovery personnel have
follow-up conversations with the licensee to clarify the recovery request
for the source; to when the source recovery project team actually visits
the site to physically inspect the source, record its serial number, and
package it for disposal. The source recovery project team leader told us
that the information on sources initially registered is less accurate
because the licensee may not know anything about their source, or a
licensee might inadvertently provide incorrect information about the
source, such as its radionuclide and radioactivity concentration. Once
recovered, the information in the source recovery project inventory
includes the type of radionuclide, serial number, size, radioactivity
concentration, and method

of packaging for storage or disposal. The source recovery project team
leader told us that this inventory is designed to assist in administrative
planning, scheduling and prioritizing recoveries, tracking shipments, and
documenting storage or disposal locations.

Information on the recovered sealed radiological sources in DOE's
possession is then integrated into DOE's Radiological Source Registry and
Tracking System. This departmentwide inventory system was established in
November 2003, in response to a recommendation of the DOE/NRC Interagency
Working Group on Radiological Dispersal Devices. The tracking system is
managed by DOE's Office of Plutonium, Uranium, and Special Materials
Inventory and maintained at Sandia National Laboratories. DOE designed its
system to help (1) monitor the safety and security of all DOE-owned sealed
radiological sources that meet a certain threshold size and radioactivity
concentration and (2) provide information on the potential threat they
pose. In addition to descriptive information on the type of sealed
radioactive source and its location within the DOE complex, this tracking
system also records data on the source's status- such as whether the
source is in active use; is inaccessible and, thus, not being used; is in
storage for potential future use; or is packaged and awaiting final
disposal.

    DOE Cannot Determine How Many Unwanted Sealed Sources May Need Recovery

Because neither DOE nor any other government agency has centrally tracked
the number of sealed radiological sources in the United States at any
given time or the number of unwanted sources held by NRC and Agreement
States licensees, DOE has few available means of estimating the quantities
of sources that may need recovery in the future. Under the current
regulatory structure, NRC and the Agreement States only have information
on the authorized uses and maximum quantities of radioactive materials
licensees are allowed to possess, although each licensee is responsible
for maintaining inventories of its individual sources. Further, the source
recovery project inventory contains only information that licensees have
voluntarily provided to DOE on their unwanted sealed radiological sources
and more limited voluntary registration of sources that may require
recovery in the future. The information on sealed radiological sources
that NRC provides to DOE for scheduling recovery only captures those
sources that NRC or Agreement States are aware of that need recovery and
does not include sources that licensees may possess that are unwanted.
Consequently, neither of these methods for obtaining information provides
the kind of data that DOE can use to estimate future quantities of sealed
radiological sources that may need recovery. According

to the manager of DOE's U.S. Radiological Threat Reduction Program,
because the source recovery project has no information on the number of
sources in current use or in storage, DOE is limited in its ability to
provide useful estimates of the quantities of sealed radiological sources
that DOE might need to recover in the future.

    The Proposed National Source Tracking System Is Not Designed to Collect Some
    Information That Could Be Useful to DOE

NRC plans to develop a national source tracking system that will register
certain sealed radiological sources possessed by licensees and/or DOE. In
November 2003, NRC, in cooperation with the Agreement States, contacted
2,600 entities licensed to possess IAEA categories 1 and 2 sources in an
effort to capture for the first time national data on the actual type,
quantities, and current ownership of these sources. Over 99 percent of
these licensees voluntarily reported information back to NRC, but only
about one-half of them reported that they possessed these sources. NRC has
already conducted a follow-up survey of a portion of these licensees, and
other surveys are planned leading up to an implementation of the national
source tracking system in 2007. Although licensees are requested to
volunteer information for these interim surveys, NRC issued a proposed
rule in July 200533 that would, among other things, require licensees to
provide an inventory of their sealed radiological sources; annually verify
and reconcile their actual inventory with the information registered in
the system; and report certain transactions, such as the date of
manufacture, transfer, or disposal of their sealed radiological sources.
The Energy Policy Act of 2005 requires that NRC issue regulations, within
1 year, establishing this mandatory tracking system that shall be
coordinated with systems established by the Department of Transportation
to track the shipment of radiation sources. Such a tracking system must,
among other things, provide for the reporting of required information
through a secure Internet connection.

As presently designed, NRC's national source tracking system will
inventory and monitor primarily IAEA categories 1 and 2 sources-the
minimum required under the 2004 IAEA Code of Conduct-despite support from
IAEA and DOE for tracking additional source categories and other

3370 Fed. Reg. 43646 (July 28, 2005).

information.34 In its July 2003 technical document detailing the
methodology behind the IAEA source categorization scheme, IAEA suggested
that member states consider the combined radioactivity of aggregated
sealed radiological sources in one location for the purpose of
categorizing these sources on the basis of their potential to cause harm
to human health.35 Using this methodology, the accumulation of enough
individual IAEA category 3 sources in close proximity to one another would
yield concentrations of radioactive material equivalent to a single IAEA
category 2 source. For example, storing 15 well-logging devices in close
proximity (each well-logging device typically contains a 2-curie,
cesium-137 source, which is an IAEA category 3 source) would be equivalent
to having a 30-curie, cesium-137 source in this location, which is an IAEA
category 2 source.

Almost all of the unwanted sealed radiological sources recovered by DOE
would fall into categories below IAEA categories 1 and 2 and, therefore,
would not have been registered in the national source tracking system as
presently designed. According to the manager of DOE's U.S. Radiological
Threat Reduction Program, over 90 percent of the sites where DOE has
recovered sealed radiological sources had quantities of lesser radioactive
sources that when aggregated were equivalent to an individual IAEA
category 2 source and, thus, posed enough of a safety and security risk to
warrant their recovery. This recovery has been justified despite the fact
that the total curie level of all the recovered IAEA category 3 sources
was only about 15 percent of the curie level of the relatively few
recovered categories 1 and 2 sources, and without regard to whether the
sources might or might not have been located in close proximity at each of
the licensee sites. In a 2004 technical document, IAEA suggested that it
would be beneficial from both a safety and security viewpoint for all
disused or unwanted sealed radiological sources to be identified and to
undergo proper disposition.36 According to IAEA, the quality of a
country's national registry of radioactive sources will be a prime
indicator of the probability of there being vulnerable and orphan sources.
History has shown that many

34NRC has added seven radionuclides not recommended for tracking by the
IAEA Code of Conduct, including actinium-227, polonium-210, plutonium-236,
plutonium-239, plutonium240, thorium-228, and thorium-239. Although these
radionuclides are not prevalently used by licensees, they are used at DOE
facilities.

35IAEA, Categorization of Radioactive Sources, p. 9.

36IAEA, Strengthening Control Over Radioactive Sources, pp. 39, 54.

accidents involving orphan sources come about because sources that are no
longer in use are eventually forgotten, with subsequent loss of control
years later. Table 3 shows a breakdown of the sealed radiological sources
that DOE has recovered, by their IAEA source category, as of June 7, 2005.
As shown in the table, about 98.5 percent of these sources fall below
category 2 and, therefore, would not have been tracked in the proposed
national source tracking system.

Table 3: DOE-Recovered Sealed Radiological Sources, by Their IAEA Source
Category, as of June 7, 2005

IAEA source Number of Percentage of Percentage of category

                  sources total sources Curiesa total curiesa

                    Category 1         37      0.34%   78,984.07       52.68% 
                    Category 2    129           1.19   50,181.55        33.47 
                    Category 3   4,941         45.73   19,540.26        13.03 
            Categories 4 and 5   5,672         52.49   1,233.43          0.82 
                Uncategorizedb         27       0.25          0.01       0.00 
                         Total   10,806    100.00%    149,939.32      100.00% 

Source: DOE source recovery project inventory database.

aA curie is a measure of the rate of radioactive decay; it is equivalent
to the radioactivity of 1 gram of radium or 37 billion disintegrations per
second.

bUncategorized sources contain radionuclides that are not covered by an
IAEA source category.

In the proposed rule to implement a national source tracking system, NRC
states that it does not plan to include IAEA category 3 sources in the
registry at this time, but that it may consider doing so in the future
because licensees possessing a large quantity of IAEA category 3 sources
could present a security concern. Although NRC contends that reliable
tracking of the accumulation of IAEA category 3 sources will be difficult
and might pose a potential burden on licensees, NRC is seeking comments on
the inclusion of these sources in its tracking system. NRC stated in its
notice of intent that one way to address the accumulation of sources of
concern would be to lower the threshold for source tracking to include all
IAEA category 3 sources, since a source level tracking system cannot
include aggregation of sources because the sources may move in and out of
the tracking system with the change of ownership. However, in commenting
on a draft of this report, NRC stated that in lieu of the inclusion of
category 3 sources in the proposed national source tracking system at this
time, its new security orders for licensees possessing IAEA categories 1
and 2

sources do, where appropriate, address aggregation of any sources below
these two categories, such that the net result could reach the category 2
threshold in a given physical location. Nevertheless, it does not appear
that these new security orders would apply to licensees that do not
possess IAEA categories 1 and 2 sources but still have large accumulations
of IAEA category 3 or lesser source categories.

The national source tracking system, as designed, also would not collect
other information that DOE might find useful in budgeting and planning for
source recovery and future disposal needs for GTCC waste. Recent IAEA
technical guidance states that it is important to capture information on
the frequency of use of the source in a national registry of sealed
radiological sources-for example, whether the source is actually being
used or whether it is being stored securely.37 DOE already inventories
such information on sources in its possession in its Radioactive Source
Registry and Tracking System. DOE initially requested that NRC collect
information on licensees' disposal plans in its interim survey, including
whether the licensees were planning to have DOE recover their sources. NRC
included this question in its first survey of licensees but has decided to
drop it in subsequent surveys and in the design of the tracking system,
because of the low response rate to this question and because its security
regulations currently do not require licensees to report this information.
However, NRC is contemplating adding a feature to the design of its
anticipated national source tracking system that would capture information
on the long-term storage of some sealed radiological sources, although it
would be voluntary for licensees to provide this information.

The Energy Policy Act of 2005 requires NRC to chair an interagency task
force on radiation source protection and security. Within 1 year of its
creation, the task is to prepare a report to the Congress and the
President providing recommendations for a list of additional radiation
sources that should be required to be secured as well as any necessary
modifications to the national source tracking system. In addition, the
task force is also charged with making recommendations in this report
regarding the creation of, or modification to, procedures for improving,
among other things, the security of stored sources, including periodic
audits or investigations by NRC to ensure that these sources are properly
secured and can be fully accounted for.

37IAEA, Strengthening Control Over Radioactive Sources, p. 55.

Conclusions	DOE and NRC have important roles and responsibilities in
ensuring the safety and security of radiological sealed sources. The
recently enacted Energy Policy Act of 2005, among other things, adds new
requirements for both agencies, including the creation of a task force on
radiation source protection and security, chaired by NRC, and continued
recovery by DOE of unwanted sources until it provides a disposal site for
GTCC waste. The responsibilities for DOE may expand further if licensees
in most states lose access to the only disposal site for their higher
radioactive non-GTCC waste by mid-2008. Specifically:

o 	Loss of access would increase the quantities of non-GTCC waste in
storage that could necessitate more recovery of this waste by DOE. This,
in turn, might lead to increased costs for DOE's source recovery efforts.
However, how much additional funding will be necessary for this effort
would be difficult to ascertain for several reasons, including
uncertainties regarding the quantity of non-GTCC waste that might need
collection.

o 	These increased recovery and disposal costs will be incurred by DOE
unless other mechanisms are adopted to recoup these costs, especially from
those licensees that would be able to cover them if commercial disposal
were available.

o 	The increasing quantities of non-GTCC waste that will not have a
commercial disposal pathway could heighten interest in using DOE sites for
the disposal of this waste.

o 	The lack of information to track the number and status of sealed
radiological sources that may require recovery and disposal in the future,
limits DOE's ability to effectively plan and budget for its recovery and
disposal efforts and to monitor the performance of its source recovery
project.

Recommendations for 	We recommend that the Secretary of Energy and the
Chairman of the Nuclear Regulatory Commission, in collaboration with the
Task Force on

Executive Action Radiation Source Protection and Security, evaluate and
report on

o 	the cost implications of a potential expansion of DOE's recovery and
disposal of non-GTCC waste from sealed radiological sources,

o 	options for DOE to recoup these costs from licensees that may have no
commercial waste disposal options,

o  the feasibility of disposing of this waste at DOE sites, and

o 	how a national source tracking system can be designed and implemented
to improve DOE's ability to identify and track sealed radiological sources
that may need DOE recovery and disposal.

  Agency Comments and Our Evaluation

We provided a draft of this report to DOE and NRC for their review and
comment. DOE's written comments are reproduced in appendix III. DOE stated
that it generally supports the recommendations contained in this report.
More specifically, DOE commented that we had correctly reported the
department's position with respect to recouping recovery and disposal
costs; however, the department expressed some concern that charging fees
or recouping costs from licensees may inhibit them from registering
sources, leaving these excess sources at risk. We acknowledge in the
report that DOE should cover the recovery, storage, and disposal costs of
unwanted sealed radiological sources that were previously owned by DOE. We
also acknowledge the need for DOE to cover these costs in cases where
sources posing a health, safety, security, or environmental threat are
recovered from licensees that do not have the financial means to ensure
their proper disposal. Nevertheless, given the possibility that, in most
states, there may not be a commercial disposal option available to
licensees for their higher radioactive non-GTCC waste after mid-2008, we
continue to believe that DOE and NRC should evaluate approaches to recoup
recovery and disposal costs from licensees that could otherwise afford to
cover these costs if a commercial disposal option were available. DOE also
stated that, in addition to the non-GTCC sealed source waste that we
stated it recovered and disposed, it had also recovered other sources that
fall into this waste class. We added a reference to these other sources in
the report. Regarding using DOE sites for non-GTCC waste disposal, the
department commented that we appropriately noted its current policy and
statutory responsibilities that prohibit the use of department facilities
for this purpose. DOE stated that it would continue to identify potential
commercial treatments or disposal options for any additional non-GTCC
waste that is recovered. Finally, DOE concurred with our assessment that
the proposed national source tracking system should be improved to assist
the department in identifying and recovering unwanted sources from outside
the department that pose a potential safety and security risk. DOE stated
that its Office of Security is working with other elements of the

department and NRC in developing requirements to ensure that these
unwanted sources are adequately tracked.

NRC also provided written comments to a draft of this report, which are
reproduced in appendix IV. NRC stated that overall our report was well
written and balanced. While NRC did not specifically agree or disagree
with our four recommendations, its letter raised seven issues regarding
the proposed national source tracking system.

1.	NRC stated that its tracking system would provide some information
useful to DOE. We agree that the national source tracking system might
provide some information useful to DOE in its recovery of IAEA categories
1 and 2 sources. However, since we found that only 1.5 percent of the
sources recovered by DOE as of June 7, 2005, were in these two categories,
it appears that the national source tracking system would yield little, if
any, practical benefits to DOE.

2.	NRC stated that requiring the reporting of certain information that our
report asserts DOE would find useful, such as frequency of source use,
could be extremely burdensome on licensees and NRC and would yield little,
if any, practical benefits. NRC provided no support for this contention or
for why it cannot overcome these burdens as it has done in justifying the
reporting requirements proposed for licensees possessing IAEA categories 1
and 2 sources. In addition, NRC stated in its notice of proposed
rulemaking for the national source tracking system that most licensees
already have systems in which information on sources is maintained, and
that NRC's tracking system is designed to ease the reporting burden for
these licensees. As to the comment on the practical benefit of tracking
the use of high-risk radioactive materials, our report notes that the most
vulnerable sources to abandonment, misplacement, and theft are those that
are unwanted and in storage. Therefore, it seems reasonable to attempt to
collect some information on frequency of source use, particularly if the
storage of sources were to increase in the future in the absence of a
commercial disposal option for the higher radioactive non-GTCC waste.

3.	NRC commented that our report did not accurately characterize some
issues involving IAEA category 3 sources, mainly regarding our claim that
IAEA-TECDOC-1388 suggested that category 3 sources be tracked. NRC claimed
that the IAEA document did not make this suggestion and provided some
passages from the document to support its position. We believe that NRC's
comments in this regard reflect a narrow view of the

guidance provided by IAEA. For example, in IAEA's discussion of disused
(unwanted) sources in this technical document, it clearly suggests a need
to identify these sources and to gather information on their frequency of
use.

"Disused sources represent the largest pool of vulnerable and potential
orphan sources. History has shown that many accidents involving orphan
sources come about because sources that are no longer in use are
eventually forgotten, with subsequent loss of control years later. To this
end, it is beneficial from both a safety and security viewpoint for all
disused sources to be identified [emphasis added] and to undergo proper
disposition.... Licensees are discouraged from proper disposal of disused
sources by the cost involved, by the bureaucracy of doing so, or by the
lack of an available disposal option.... It is clear that information
needs to be gathered by those developing a national strategy regarding the
status of at least all [emphasis added] Category 1, 2 and 3 sources on the
licensee's inventory or national registry so that appropriate decisions
can be made regarding them. Generally, this will involve asking the
licensee or owner of the source about its frequency of use [emphasis
added]."

4.	In support of its decision not to track IAEA category 3 sources at this
time, NRC drew attention to its other regulatory efforts, especially its
new security orders for some licensees that possess IAEA categories 1 and
2 sources. NRC stated that, where appropriate, these security orders
address aggregation of any sources (IAEA category 3 sources and below)
such that the net result could reach the category 2 source threshold in a
given physical location. Despite these security orders, NRC's source
tracking system would not include IAEA category 3 sources and below.
However, NRC stated in its notice of proposed rulemaking for the national
source tracking system, that it is seeking comments on the inclusion of
IAEA category 3 sources in the registry because licensees possessing large
quantities of these sources could present a security concern.

5.	NRC pointed out that, as we reported, the actions it is taking to track
IAEA categories 1 and 2 sources are consistent with the IAEA Code of
Conduct and the Energy Policy Act of 2005. However, NRC failed to mention,
as we do in our report, that this legislation also directs NRC to chair an
interagency task force to provide a report, within 1 year, to the Congress
and the President with recommendations for, among other things, additional
radiation sources that should be required to be secured as well as any
modifications necessary to the national source tracking system. We believe
that our report provides ample support for areas where NRC, in
collaboration with DOE and other federal agencies, might consider
modifying the design of the national source

tracking system to better assist DOE in planning and budgeting for the
recovery and disposal of unwanted sealed radiological sources.

6.	NRC commented that it does not matter that almost all of the sources
that DOE has recovered are below IAEA categories 1 and 2 sources because,
according to NRC, the greatest risk from a source is its radioactivity
level. The radioactivity of an individual source is clearly one measure of
its potential safety and security risk. However, as our report notes,
DOE's recovery efforts, often at the request of NRC, are not solely
dictated by the radioactivity of an individual source, but more broadly
the health, safety, security, or environmental threat posed by the
aggregated radioactivity of many unwanted sources that are typically in
storage at licensee sites around the country. Our report also notes that
unwanted sources in storage tend to be the most vulnerable to abandonment,
misplacement, and theft despite requirements that licensees keep track of
the radioactive materials they possess. Some of the lesser radioactive
sources are frequently found by DOE to be kept in quantities where their
aggregated radioactivity would be equivalent to an IAEA category 2 source
that would present a security concern. These lesser radioactive sources
also may be more susceptible to inadvertent loss, which has already led in
some cases to radiation exposure, high decontamination costs, and public
panic. IAEA acknowledged in its Code of Conduct that its categorization of
high-risk radiological sources is based on health effects and does not
fully take into account the range of impacts that could result from
accidents or malicious acts involving radioactive sources.

7.	NRC stressed in its comments that DOE, through its representatives on
NRC working groups and committees developing the national source tracking
system, has had the opportunity to provide input on the design of the
system and the potential usefulness of the system to assist its source
recovery efforts. Regardless of DOE's opportunities to provide input to
NRC, DOE officials raised concerns to us during the course of our work
about the usefulness of NRC's source tracking system. Furthermore, in
commenting on our draft report, DOE stated that there is a need for a more
rigorous national-level tracking capability to assist the department in
identifying and recovering unwanted sources.

We incorporated technical changes in this report, where appropriate, on
the basis of detailed comments provided by both agencies.

We will send copies of this report to the appropriate congressional
committees. We will make copies available to others upon request. In
addition, the report will be available at no charge on the GAO Web site at
http://www.gao.gov.

If you or your staff have any questions about this report, please contact
me
at ((202) 512-3841 or at [email protected]. Contact points for our Offices
of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made major contributions to this report are
listed in appendix V.

Sincerely yours,

Gene Aloise, Director
Natural Resources and Environment

Appendix I

Scope and Methodology

In our review, we examined (1) the status of the Department of Energy's
(DOE) efforts to recover unwanted sealed radiological sources and develop
a disposal option for greater-than-class C (GTCC) waste, (2) DOE actions
taken to recover and dispose of unwanted non-GTCC waste from sealed
radiological sources, and (3) the extent to which DOE can identify and
track unwanted sealed radiological sources for recovery and disposal. To
better understand these issues, we met with officials at DOE, the National
Nuclear Security Administration, and the Nuclear Regulatory Commission
(NRC), and we visited the office of DOE's source recovery project at Los
Alamos National Laboratory and observed laboratory personnel recovering
unwanted sealed radiological sources from a university. We also
interviewed officials at nonfederal organizations, including the Health
Physics Society, the Organization of Agreement States, and the Conference
on Radiation Control Program Directors (CRCPD), as well as some recognized
experts in the field. We also met with representatives from commercial
entities that are licensed to possess high-risk radioactive sources and
state regulatory officials in California and Ohio.

More specifically, to examine the status of DOE efforts to recover
unwanted sealed radiological sources and develop a disposal option for
GTCC waste, we interviewed DOE officials from the U.S. Radiological Threat
Reduction Program, Office of Environmental Management, and Office of
Security. We reviewed applicable statutes, regulations, and agency
guidance as well as relevant DOE and NRC studies, reports, documents, and
agency plans. We obtained information from the source recovery project
inventory database to determine the number and type of sources recovered
as of June 7, 2005. To determine the reliability of these data, we first
asked officials a series of data reliability questions that addressed
areas such as data entry, data access, quality control procedures, and
data accuracy and completeness. We also inspected data records, reviewed
manuals and documents relating to DOE data collection and verification
methods, and interviewed DOE officials. We asked follow-up questions as
necessary. In consultation with a GAO expert in research methodology, we
analyzed the officials' responses for relevant weaknesses in data
reliability that would make their data unusable for our analysis and
reporting purposes. On the basis of these efforts, we determined that
these data were sufficiently reliable for summarizing volumes of recovered
sealed radiological sources.

We also sought a better understanding of how sealed radiological sources
are classified as waste. We developed a structured interview guide to
collect information from commercial waste brokers that possess GTCC and

Appendix I Scope and Methodology

non-GTCC waste from sealed radiological sources. This interview guide
asked questions on areas such as the wastes these brokers often collect
and the potential waste classes of common types of sealed radiological
source devices. Because the practical difficulties of developing and
administering a structured interview guide may introduce errors-resulting
from how a particular question is interpreted, for example, or from
differences in the sources of information available to respondents in
answering a question-we included steps in the development and
administration of the structured interview guide for the purpose of
minimizing such errors. We pretested the instrument with three commercial
waste brokers by telephone and modified it as appropriate to reflect
questions and comments received during the pretests.

To determine which commercial waste brokers to interview, we first used a
list of commercial waste brokers compiled by CRCPD's National Orphan
Radioactive Material Disposition Program. This list contained 18 waste
brokers that met the CRCPD criteria of being in good standing with CRCPD
and serving more than 1 million customers, serving non-DOE customers, or
serving more than one state. However, because this list is not
comprehensive and there is no single source listing of commercial waste
brokers, we also asked each broker we interviewed for the names of
additional brokers who could provide useful information or insights into
these issues. We continued this expert referral technique until the
references we received became repetitive. In all, we used our structured
interview guide to interview a nonprobablility sample of 12 commercial
waste brokers in various geographical locations.1 We then used the results
of these structured interviews to create a table summarizing common sealed
radiological sources devices and their potential waste class (see app.
II). We shared preliminary drafts of this table with experts at DOE and
NRC and with leading scientists in the field of sealed radiological source
security from nonfederal organizations, such as the Monterrey Institute of
International Studies and the Low-Level Waste Forum. We received and
incorporated their comments as appropriate on the structure and contents
of the table. On the basis of this process, we determined that these data
were sufficiently reliable for the purposes of this report.

1Results from nonprobability samples cannot be used to make inferences
about a population because in a nonprobability sample, some elements of
the population being studied have no chance or an unknown chance of being
selected as part of the sample.

Appendix I Scope and Methodology

To examine the actions DOE has taken to recover and dispose of unwanted
sealed radiological sources, we interviewed source recovery project
personnel and officials from the U.S. Radiological Threat Reduction
Program. We also conducted interviews with representatives from nonfederal
entities, including the Monterrey Institute of International Studies, the
Health Physics Society, CRCPD, the National Research Council, and the
Council on Foreign Relations. We discussed with these agency officials and
representatives the likelihood of DOE's needing to recover more non-GTCC
waste from unwanted sealed radiological sources in the future if the
Barnwell, South Carolina, disposal site restricts access for licensees in
36 states by mid-2008 as planned. To obtain a better understanding of how
much non-GTCC waste might be stored if licensees in these states are
denied disposal access for this waste, we gathered information on the
quantity of non-GTCC waste disposed at the two commercial disposal sites
that can accept classes B and C waste in Richland, Washington, and
Barnwell, South Carolina, between 2001 and 2004. To determine the
reliability of these data, we first asked disposal operators a series of
data reliability questions that addressed specific areas, such as data
entry, data access, quality control procedures, and data accuracy and
completeness. We added follow-up questions as necessary. In consultation
with a GAO expert in research methodology, we analyzed their responses for
relevant weaknesses in data reliability that would make their data
unusable for our analysis and reporting purposes. On the basis of these
efforts, we determined that these data were sufficiently reliable for
summarizing volumes of disposed waste at these disposal sites.

To determine the extent to which DOE can identify and track unwanted
sealed radiological sources for recovery and disposal, we interviewed DOE
and NRC officials regarding the scope, capabilities, and limitations of
their existing databases for tracking these sources. We reviewed past
estimates of the number of sealed radiological sources in the United
States, including the scope and methodologies used to create these
estimates. To examine NRC efforts to develop a national source tracking
system for certain sealed radiological sources, we interviewed NRC and DOE
officials who participated in the system's initial formulation. We
reviewed planning and management documents, including related NRC
submissions to the Office of Management and Budget, NRC's business case
analyses, and the proposed rule for implementing a national source
tracking system. We also reviewed the survey instrument NRC used to
populate the interim database. Finally, we interviewed state officials
from Illinois, New York, Ohio, and Oregon to determine whether any states
currently track sealed

Appendix I Scope and Methodology

radiological sources and gathered these officials' views on the need for a
national source tracking system.

We conducted our review between June 2004 and September 2005 in accordance
with generally accepted government auditing standards.

Appendix II

Selected Sealed Radiological Source Devices and Their Potential Waste Classes

Table 4 presents selected common devices that utilize sealed radioactive
sources and the NRC waste classes in which sources from these devices
might be disposed. This table shows the variability in the possible
sources used in devices, their relative risks according to the
International Atomic Energy Agency (IAEA) categorization scheme, and the
range of waste classes associated with the sources that could be used in
these devices. The radionuclides and the ranges of radioactivity listed
next to each device are presented for illustrative purposes-each device
might use one of these radionuclides in one or more sources. The IAEA
source category corresponds to each radionuclide and radioactivity range,
based on an IAEA technical document, as noted. The potential waste classes
are associated with each device and not with the specific radionuclides
that might be in these devices. In other words, not all radionuclides that
could be used in a source within a device produce the range of waste
classes associated with the device.

 Table 4: Selected Sealed Radiological Source Devices and Their Potential Waste
                                    Classes

                                                      Approximate initial     
                                                        curiea range of       
                                                   radioactivity per IAEA     
                                                   source Potential NRC waste 
                                                   device or application      
           Device               Radionuclide       categoryb classb when      
                                                   disposed                   
        Radioisotopic           Strontium-90        9,000 - 680,000 1,2 B/C,  
       thermoelectric                                         GTCC            
         generators             Plutonium-238              28 - 280 2         
Panoramic irradiatorsc         Cobalt-60         500,000 - 5,000,000 1 A,  
                                                              B/C             
        Self-shielded            Cesium-137         2,500 - 42,000 1,2 B/C,   
        irradiatorsc                                          GTCC            
                                  Cobalt-60             1,500 - 50,000 1      
        Blood-tissue             Cesium-137         1,000 - 12,000 1,2 B/C,   
        irradiatorsc                                          GTCC            
                                  Cobalt-60             1,500 - 3,000 1       
     Gamma knife (fixed,          Cobalt-60                                   
          multibeam                                   4,000 - 10,000 1 B/C
        teletherapy)c                              
         Teletherapy              Cobalt-60           1,000 - 15,000 1 B/C    
                                 Cesium-137              500 - 1,500 2        
     Calibration sources          Cobalt-60         .55 - 16,000 1,2,3,4 A,   
                                                           B/C, GTCC          
                                 Cesium-137           1.5 - 14,000 1,2,3,4    
                                Americium-241             1 - 25 2,3,4        
                           Plutonium-239/Beryllium         2 - 25 2,3         
                                Strontium-90               0.05 -2 4          
                                                       GAO-05-967 Security of 
                                                        Unwanted Radiological 
                                   Page 47                            Sources 

Appendix II
Selected Sealed Radiological Source Devices
and Their Potential Waste Classes

                         (Continued From Previous Page)

Approximate initial curiea range of radioactivity per IAEA source
Potential NRC waste Device Radionuclide device or application categoryb
classb when disposed

Industrial radiography Cobalt-60 11 - 330 2 A, B/C, GTCCd

Iridium-192 5 - 290 2,3

Cesium-137 5 - 12 3

Selenium-75 80 2

Ytterbium-169 2.5 - 20 3,4

Thulium-170 20 - 200 4

Fixed industrial gauges (level, Cesium-137 0.1 - 40 2,3,4 A, B/C, GTCC

dredger, conveyor, blast furnace, and Cobalt-60 0.1 - 20 2,3,4 spinning
pipe)

Californium-252 0.037 4

Well-logging sources Americium-241/Beryllium 0.5 - 70 2,3,4 A, B/C, GTCC

Radium-226 20 2

Cobalt-60 0.2 -10 2, 3

Plutonium-238/Beryllium 5 - 70 2, 3

Tritium 1 - 20 5

Cesium-137 0.5 - 20 3,4

Californium-252 0.027 -1.61 3,4

Brachytherapy (high/medium and low Cobalt-60 1 - 20 2,3 A, B/C, GTCC dose
rate) Cesium-137 0.01 -8 3,4,5

Iridium-192 0.02 - 15 3,4,5

Radium-226 0.005 -0.05 4,5
Iodine-125 0.005 -1.3 4,5
Gold-198 0.08 4
Californium-252 0.083 -0.54 3,4
Strontium-90 0.02 -0.12 4,5
Ruthenium/Rhodium-106 0.00022 - 0.0006 5
Palladium-103 0.03 - 0.056 5

Pacemakers Plutonium-238 2.9 - 8 3 B/C, GTCC Research reactor startup
source Americium-241/Beryllium 2 -5 3 B/C, GTCC

Portable gauges (moisture detectors,
density and moisture/density)c

Americium-241/Beryllium 0.01 - 3 3,4,5 A, B/C, GTCC
Cesium-137 0.008 - 0.011 5
Radium-226 0.002 - 0.005 5
Californium-252 0.00003 -0.00007 5

  Appendix II Selected Sealed Radiological Source Devices and Their Potential
                                 Waste Classes

                         (Continued From Previous Page)

                                             Approximate           
                                                 initial           
                                            curiea range           
                                                      of           
                                           radioactivity IAEA      Potential  
                                                     per source    NRC waste  
                                               device or               classb 
            Device           Radionuclide    application categoryb       when 
                                                                     disposed 
      Static eliminators    Americium-241    0.03 - 0.11         4  A, B/C,   
                                                                      GTCC    
                             Polonium-210     0.03 -0.11         4 
     Thickness/fill-level     Krypton-85        0.05 - 1         5  A, B/C,   
            gauges                                                    GTCC    
                             Strontium-90      0.01 -0.2         5 
                            Americium-241    0.012 - 0.6       4,5 
                              Cesium-137     0.05 -0.065         4 
                            Promethium-147          0.05         5 
                              Curium-244          0.2 -1         4 
      Bone densitometry      Cadmium-109            0.02         5 B/C, GTCC  
                            Gadolinium-153    0.02 - 1.5       4,5 
                              Iodine-125      0.04 - 0.8       4,5 
                            Americium-241    0.027 -0.27         4 
      X-ray fluorescence       Iron-55      0.003 - 0.14         5  A, B/C,   
          analyzers                                                   GTCC    
                            Americium-241    0.004 -0.20       4,5 
                             Cadmium-109     0.005 -0.15         5 
                              Cobalt-57      0.005 -0.04         5 

Electron capture detectors    Nickel-63        0.005 - 0.50 5    A, B/C    
                                  Tritium           0.05 - 1.0 5 
      Lightning preventers     Americium-241  0.0013 - 0.013   5 A, B/C, GTCC 
                                Radium-226   0.000007 -0.00008 5 
                                  Tritium                  0.2 5 
          PET checking         Germanium-68       0.001 - 0.01 5    A, B/C    
     Mossbauer spectrometry      Cobalt-57         0.005 - 0.1 5    A, B/C    

Sources: See the note below.

Note: The primary source for the first four columns is IAEA,
Categorization of Radioactive Sources, TECDOC-1344 (Vienna, Austria: July
2003). The primary sources for the waste classification column are
interviews we conducted with commercial low-level radioactive waste
brokers. We received comments and suggestions on drafts of this table from
nine scientists and regulators in the field and accepted revisions as
appropriate. These revisions affected roughly 30 percent of the fields in
the table, primarily those in the range of radioactivity and waste
classification columns.

aA curie is a measure of the rate of radioactive decay; it is equivalent
to the radioactivity of 1 gram of radium or 37 billion disintegrations per
second

bSee 10 C.F.R. part 61 for the NRC waste classification system.

cA device may utilize multiple sealed radiological sources. The range of
radioactivity per use for these devices reflects the aggregate activity.

dThere was unresolved disagreement between the waste brokers and some of
the regulators regarding whether industrial radiography sources could be
GTCC.

                                  Appendix III

                     Comments from the Department of Energy

Appendix III
Comments from the Department of Energy

Appendix III
Comments from the Department of Energy

Appendix IV

Comments from the Nuclear Regulatory Commission

Appendix IV
Comments from the Nuclear Regulatory
Commission

Appendix IV
Comments from the Nuclear Regulatory
Commission

Appendix V

                     GAO Contact and Staff Acknowledgments

                     GAO Contact Gene Aloise (202) 512-3841

Staff 	In addition to the person named above, Casey Brown, Ryan Coles,
John Delicath, Daniel Feehan, Doreen Feldman, Susan Iott, Thomas Laetz,

Acknowledgments	Cynthia Norris, Anthony Padilla, Judy Pagano, Leslie
Pollock, and Barbara Timmerman made key contributions to this report.

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