Radioactive Waste: Status of Commercial Low-Level Waste Facilities
(Chapter Report, 05/05/95, GAO/RCED-95-67).

Pursuant to a congressional request, GAO reviewed state efforts to
dispose of the low-level radioactive waste that is generated
commercially within their borders.

GAO found that: (1) 11 states plan to develop commercially generated
low-level waste disposal facilities and the state of Washington plans to
continue operating its existing disposal facility; (2) 4 states plan to
complete facilities between 1997 and 2002, but the remaining states have
yet to develop plans for their disposal facilities; (3) the slow
progress of development is due to the controversial nature of nuclear
waste disposal; (4) a smaller number of larger new facilities could
accommodate the current volume of waste at less cost than a greater
number of smaller facilities, but the volume of low-level waste could
increase in the near future; (5) although new facilities will be
necessary to store the waste in 33 states, the environmental effects of
having 11 new facilities are unclear; and (6) shifting disposal
responsibility from the states to the federal government could present
significant challenges, and could undermine state progress in
implementing the existing state approach.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-95-67
     TITLE:  Radioactive Waste: Status of Commercial Low-Level Waste 
             Facilities
      DATE:  05/05/95
   SUBJECT:  Hazardous substances
             Nuclear waste disposal
             Environmental monitoring
             Facility construction
             Site selection
             Federal/state relations
             Nuclear facilities
             Radioactive wastes
             State-administered programs
             Nuclear waste management
IDENTIFIER:  Beatty (NV)
             Richland (WA)
             Barnwell Nuclear Fuel Plant (SC)
             Illinois
             Connecticut
             Nebraska
             Wake County (NC)
             California
             Michigan
             Cortland County (NY)
             Allegany County (NY)
             Mojave Desert
             AIDS
             Texas
             Maine
             Vermont
             New Hampshire
             Puerto Rico
             Rhode Island
             Pennsylvania
             Massachusetts
             
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Cover
================================================================ COVER


Report to Congressional Requesters

May 1995

RADIOACTIVE WASTE - STATUS OF
COMMERCIAL LOW-LEVEL WASTE
FACILITIES

GAO/RCED-95-67

Low-Level Waste Disposal Facilities


Abbreviations
=============================================================== ABBREV

  DOE - Department of Energy
  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  NRC - Nuclear Regulatory Commission

Letter
=============================================================== LETTER


B-258743

May 5, 1995

The Honorable Christopher J.  Dodd
The Honorable Joseph I.  Lieberman
United States Senate

This report responds to your requests that we review certain aspects
of states' efforts to implement the Low-Level Radioactive Waste
Policy Act of 1980, as amended.  This act requires states to provide
for the disposal of the low-level radioactive waste that is generated
commercially within their borders. 

Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after the date of this
letter.  At that time, we will send copies to the appropriate
congressional committees; the Secretary of Energy; the Chairman,
Nuclear Regulatory Commission; the Director, Office of Management and
Budget; and state officials interested in the disposal of low-level
radioactive waste.  We will also make copies available to others upon
request. 

Please contact me at (202) 512-3841 if you or your staffs have any
questions.  Major contributors to this report are listed in appendix
III. 

Victor S.  Rezendes
Director, Energy and
 Science Issues


EXECUTIVE SUMMARY
============================================================ Chapter 0


   PURPOSE
---------------------------------------------------------- Chapter 0:1

Thousands of businesses, medical facilities, and universities and
over 100 nuclear power plants produce waste materials contaminated
with radioactivity.  These waste products, called commercially
generated low-level waste, have typically been disposed of by burial
in shallow trenches at a few locations around the country.  States
plan to develop 11 new disposal facilities.  These planned facilities
are the result of efforts by states to implement federal legislation
that makes them, either acting alone or in compacts, responsible for
developing new disposal facilities. 

Senators Christopher J.  Dodd and Joseph I.  Lieberman asked GAO to
assess states' progress in developing new disposal facilities,
potential economic and environmental effects of these facilities, and
alternatives to the current approach to developing new facilities. 


   BACKGROUND
---------------------------------------------------------- Chapter 0:2

In 1979, after states had closed three of six privately developed
disposal facilities because of environmental problems, congressional
committees considered making the federal government responsible for
siting new regional disposal facilities.  Later, the National
Governors' Association and others favored making the states
responsible for this activity because the siting of disposal
facilities involves primarily state and local issues.  The Low-Level
Radioactive Waste Policy Act of 1980 reflected the latter view.  This
act gave the states, either separately or in compacts, responsibility
for developing new disposal facilities.  Congressional consent was
required for a compact to become effective.  As an inducement to
states to form compacts and develop regional disposal facilities, the
act stated that compacts could, beginning January 1, 1986, restrict
the use of their disposal facilities to wastes generated within their
respective regions. 

Because of states' slow progress in forming compacts and developing
new disposal facilities, the Congress, in 1985, added milestones and
financial penalties to the act to stimulate progress.  For example,
each state's disposal facility was expected to be operational, and
disposal rights at the three existing disposal facilities would end
by, January 1, 1993.\1

Throughout the 1980s and the early 1990s, commercially generated
low-level waste was routinely disposed of in three facilities in
Nevada, South Carolina, and Washington.  However, Nevada closed its
facility on January 1, 1993.  The facility in Washington was closed
to generators in all but 11 states in two compacts on January 1,
1993, and on July 1, 1994, South Carolina closed its facility to all
waste generators outside an 8-state compact of southeastern states.\2


--------------------
\1 One additional milestone, the so-called take-title provision, was
held unconstitutional by the U.S.  Supreme Court in 1992 (New York v. 
United States, 112 S.Ct.2408). 

\2 On April 13, 1995, the governor of South Carolina proposed to the
state's General Assembly that operation of the state's disposal
facility be extended for up to 10 years.  Reopening this facility to
waste generators around the nation would require approval of both the
General Assembly and the compact of eight states.  On May 2 the
compact commission considered but did not pass a motion to extend
access to the facility. 


   RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:3

As of January 1995, 11 states had plans to develop disposal
facilities for commercially generated low-level waste, and the state
of Washington planned to continue operating its existing disposal
facility.  Altogether, these 12 facilities would serve waste
generators in 47 states.  The states that are developing these new
facilities estimate that they will complete the facilities between
1997 and 2002; however, only four candidate sites have been selected,
and no facility is being constructed.  Moreover, the remaining states
do not have plans to develop disposal facilities.  The slow progress
appears largely due to the controversial nature of nuclear waste
disposal. 

Studies performed between 1987 and 1993 by the Department of Energy
(DOE) and others concluded that a smaller number of larger new
facilities could accommodate the current volume of waste at less cost
than a greater number of smaller facilities.  These studies, however,
did not take into account uncertainties that could affect the volume
of low-level waste, such as when utilities might retire and then
dismantle nuclear power plants.  The environmental effects of having
11 new facilities are unclear.  On the other hand, because waste
generators in 33 states have lost access to existing disposal
facilities and must store their own waste, environmental risks at
their storage facilities may increase. 

Alternatives to the current program, such as shifting responsibility
from the states to the federal government or to the private sector,
appear to present significant challenges.  For example, the federal
government or a private company would likely have trouble getting a
state or locality to accept a disposal facility.  Also, supporters of
the current program say that considering other approaches could
undermine states' support for and progress in implementing the
state-compact approach.  For these reasons, caution is warranted in
considering changes to the existing state-compact approach. 


   GAO'S ANALYSIS
---------------------------------------------------------- Chapter 0:4


      SLOW PROGRESS BY STATES
-------------------------------------------------------- Chapter 0:4.1

In the 1980 act, the Congress expected states to have new disposal
facilities for low-level waste by January 1, 1986.  Since 1980, 42 of
52 states have established nine compacts.\3 Two compacts of 11
western states are using an existing disposal facility in Washington. 
Another compact of eight southeastern states is using a disposal
facility in South Carolina while North Carolina develops a new
facility for the compact.  The six remaining compacts plan to develop
seven disposal facilities.  In addition, Texas, Maine, and Vermont
have formed a 10th compact that is awaiting congressional approval. 
The three states intend to use a disposal facility that Texas plans
to develop.  Two states not affiliated with compacts intend to
develop their own disposal facilities, and the other five
unaffiliated states have not announced definitive plans for
implementing the 1980 act, as amended. 

Although 11 new disposal facilities are planned, only four candidate
sites have been selected, and no facility is being constructed. 
Currently, states responsible for establishing new facilities expect
to complete them between 1997 and 2002.  However, previous estimated
completion dates have been missed.  States' slow progress appears
largely due to the controversial nature of nuclear waste disposal. 
That is, the time and effort states have required to form compacts,
select states to develop new facilities, develop legislation and
regulations, and select sites for facilities appear to be symptomatic
of widespread concern about such facilities among the affected public
and political officials at various state and local levels. 


--------------------
\3 The act included the District of Columbia and Puerto Rico as
states. 


      POTENTIAL ECONOMIC AND
      ENVIRONMENTAL EFFECTS
-------------------------------------------------------- Chapter 0:4.2

There are no good, current data on the economic and environmental
effects of states' plans for disposal facilities nationwide.  Most
states have not estimated the total or unit disposal costs of their
planned facilities.  Studies by DOE and others concluded that a
smaller number of larger new disposal facilities could accommodate
the volume of waste that has been generated in recent years at less
cost than a greater number of smaller facilities.  In recent years,
the volume of waste has been about one-fourth as great as before
1980.  These studies, however, have limited usefulness in determining
a cost-effective number of sites.  For example, no studies had
up-to-date cost data that could be used to estimate costs for
disposal facilities in the range of sizes that might be required. 
Also, the studies did not account for uncertainties affecting the
future volume of low-level waste, such as when utilities will retire
and then dismantle their nuclear power plants.  Collectively, nuclear
power plants generate about half of the volume of low-level waste,
and dismantling retired plants is expected to generate sizable
quantities of waste.  Thus, utilities' decisions on when to shut down
plants and dismantle them will affect the volume of low-level waste
in the coming decades. 

Only California had completed its review of the environmental effects
of its proposed facility and site, but its conclusions have been
challenged and are under independent review.  Therefore, limited
information is available on the likely environmental effects of
disposal at the planned facilities.  However, environmental risks may
increase at the facilities of the waste generators in 33 states that
have lost access to disposal facilities because existing facilities
have closed to them, as provided by the act.  Until new facilities
are ready, these waste generators, which produce about 42 percent of
all commercially generated low-level waste, will have to store their
waste. 


      ALTERNATIVE APPROACHES
-------------------------------------------------------- Chapter 0:4.3

Questions have been raised about whether other approaches to managing
low-level waste might be more effective than the state-compact
approach.  Supporters of the current program, however, say that
exploring other approaches could undermine both the progress that
many states have made and the long-standing support of most states
for the current approach.  Moreover, other approaches to managing
this waste appear to have drawbacks.  For example, making the federal
government responsible for disposing of the waste would not solve the
problem of obtaining political and public acceptance of disposal
facilities. 


   RECOMMENDATIONS
---------------------------------------------------------- Chapter 0:5

GAO is making no recommendations. 


   AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:6

To ensure the accuracy, completeness, and objectivity of this report,
GAO provided copies of the entire draft or of sections to
knowledgeable federal officials, including the program manager for
DOE's National Low-Level Waste Management Office and Nuclear
Regulatory Commission (NRC) staff in four NRC offices--the Office of
State Programs, Division of Waste Management, Office of Nuclear
Materials Safety and Safeguards, and Office of the General Counsel. 
These officials generally agreed with the facts as presented in GAO's
report, and NRC officials noted that the report accurately
characterized the current situation in developing low-level waste
disposal facilities.  NRC and DOE officials also provided several
technical and editorial comments, which GAO incorporated as
appropriate to clarify and update the report. 


INTRODUCTION
============================================================ Chapter 1

Each year over 100 utility-owned nuclear power plants and thousands
of commercial enterprises, such as pharmaceutical manufacturers,
hospitals, universities, and industrial firms, generate various types
of radioactive contaminated waste.  While waste in the form of used
(spent) fuel from nuclear power plants is classified as "high-level"
because of the amount of radioactivity in the fuel, almost all other
commercial waste is designated as "low-level" because the levels of
radioactivity in these wastes are relatively lower.\1 Low-level
radioactive waste items include such things as rags, paper, liquid,
glass, protective clothing, as well as hardware, equipment, and
resins exposed to radioactivity or contaminated with radioactive
material at nuclear power plants. 

In 1993, operations at utilities' nuclear power plants accounted for
about 50 percent of the volume of commercially generated low-level
radioactive waste, but this volume contained about 95 percent of the
radioactivity in low-level waste.  Examples of other commercial uses
of radioactive materials that either directly or indirectly produce
low-level radioactive waste include the following: 

  Medical procedures involving radiation or radioactive material. 
     More than 100 million of these procedures are performed each
     year. 

  Testing and development of about 80 percent of new drugs. 

  Sterilization of consumer products, such as cosmetics, hair
     products, and contact lens solutions using radioactive
     materials. 

  Production of consumer products, such as smoke detectors, and
     industrial products, such as instruments to inspect for defects
     in highways, pipelines, and aircraft. 

The radioactivity in most commercially generated low-level waste
decays to safe levels within 100 years, but some waste remains
hazardous for longer than 500 years.  Because these wastes are
potentially harmful to workers, the general public, and the
environment, they must be stored and disposed of safely. 

Throughout the 1980s and the early 1990s, commercially generated
low-level waste was routinely disposed of in three facilities at or
near Beatty, Nevada; Barnwell, South Carolina; and Richland,
Washington.  However, Nevada closed its facility on January 1, 1993. 
The facility in Washington was closed to generators in all but 11
states on January 1, 1993, and on July 1, 1994, South Carolina closed
its facility to waste generators in all but 8 southeastern states. 


--------------------
\1 Low-level radioactive waste also does not include waste products
from processing uranium ore. 


   BACKGROUND ON DISPOSAL OF
   COMMERCIALLY GENERATED
   LOW-LEVEL RADIOACTIVE WASTE
---------------------------------------------------------- Chapter 1:1

The generation of significant amounts of nuclear wastes began during
World War II and because nuclear operations then and for years
afterward were controlled by the federal government, the government
assumed responsibility for the disposal of these wastes.  Eventually,
however, the federal Atomic Energy Commission began permitting
commercial entities to possess, own, and use radioactive materials
and to dispose of low-level waste.  With the increase in commercial
uses of radioactive materials, the Congress, in 1959, authorized the
Commission to transfer to states authority and responsibility for
regulating most commercial users other than nuclear power plants. 
States that desired to assume such authority and responsibility could
do so by establishing regulatory programs that were adequate to
protect the public health and safety and compatible with the
Commission's regulatory program.  Such states are referred to as
agreement states.\2

With increased commercial use of radioactive materials and an
expanding regulatory role for states, private companies, rather than
the federal government, began to provide disposal facilities for
commercially generated low-level waste.  By 1971 there were six
privately operated disposal facilities located in Illinois, Kentucky,
Nevada, New York, South Carolina, and the state of Washington.  All
of these disposal facilities except the facility in Illinois were
regulated by agreement states.  Only the facility in Washington was
developed on federal land; specifically, on the Hanford Reservation,
now managed by the Department of Energy (DOE).  (Figs.  1.1 and 1.2
show the disposal facility in Barnwell, South Carolina.)

   Figure 1.1:  Approach to One of
   the Disposal Trenches at the
   Barnwell Disposal Facility

   (See figure in printed
   edition.)

   Figure 1.2:  Almost 9 Months of
   Waste At the Barnwell Disposal
   Facility

   (See figure in printed
   edition.)

By March 1979 the disposal facilities in Illinois, Kentucky, and New
York had been closed for a variety of reasons, including leakage at
the sites.  Then, in July 1979, the governor of Nevada ordered the
Beatty facility shutdown after two incidents involving trucks
carrying radioactive waste into the facility.  Thereafter, the
governors of Nevada, South Carolina, and Washington wrote to the
Nuclear Regulatory Commission (NRC) for assurance that rules
governing shipments would be enforced.  The Beatty facility reopened
in late July 1979.  In October 1979, the governor of Washington
ordered that state's disposal facility to shut down after
deficiencies were found in waste shipments bound for the facility. 
Among other things, a truckload of radioactive cobalt was leaking. 
Also in 1979, the governor of South Carolina said that the state's
disposal facility was receiving up to 90 percent of all commercially
generated low-level waste and that decontamination of the disabled
Three Mile Island nuclear power plant would generate waste amounting
to almost 50 percent of the total volume the state had received in
1978.  For this reason, the governor said that South Carolina would
not accept waste from the disabled plant. 

Concerned about the potential loss of disposal capacity, several
congressional committees held hearings in 1979.  Initially, the
committees considered legislation that would make the federal
government responsible for the disposal of commercially generated
low-level waste.  The governors of the three states with operating
disposal facilities, however, opposed this approach because they
wanted states to have an opportunity to examine alternatives to
federal disposal.  By the end of the year, Washington and Nevada had
reopened their disposal facilities, and the Congress had deferred
consideration of legislation to the next year.  Subsequently, a task
force convened by the National Governors' Association recommended
that responsibility for the disposal of low-level waste be assumed by
the states.  Other state government organizations supported this
approach. 


--------------------
\2 In 1995 there were 29 agreement states. 


   LOW-LEVEL WASTE POLICY ACT AND
   AMENDMENTS
---------------------------------------------------------- Chapter 1:2

Late in 1980, the Congress established a new policy regarding the
disposal of commercially generated low-level waste by enacting the
Low-Level Radioactive Waste Policy Act of 1980 (P.L.  96-573).  The
act made each state responsible for making disposal capacity
available and stated that low-level radioactive waste can be most
safely and efficiently managed on a regional basis.  To implement
this policy, the Congress encouraged states to form compacts to meet
their collective disposal needs and to minimize the number of new
disposal sites.  Congressional consent was required for a compact to
become effective.  As an inducement to states to form compacts and
develop regional disposal facilities, the act stated that compacts
could, beginning January 1, 1986, restrict the use of their disposal
facilities to wastes generated within their respective regions.  The
Congress expected states to have new disposal facilities capable of
handling their own low-level waste by that date. 

Although nearly 40 states had formed seven regional compacts by the
end of 1983, it had become clear that no new disposal facilities
would be ready for at least another 5 years.  As a result, the
Congress passed and, on January 15, 1986, the President signed into
law, the Low-Level Radioactive Waste Policy Amendments Act of 1985
(P.L.  99-240).  At the same time, the Congress granted consent to
the seven regional compacts.  The amendments represented a compromise
for competing parties.  On one side, waste generators in states that
would be left without access to disposal facilities--generators that
were relying on the existing disposal facilities in Nevada, South
Carolina, and Washington--got a 7-year extension of the period during
which they could ship waste to existing disposal facilities.  On the
other hand, these three states, which wanted to close their
facilities to waste generators outside their respective compacts,
received additional assurances that other states or compacts of
states would develop their own disposal facilities. 

Among these additional assurances were six deadlines and milestones
by which states should make decisions and commit to certain actions
towards developing new disposal facilities.  The amendments
prescribed limited responsibilities for DOE and NRC.  The amendments
also established financial penalties, or surcharges, on the waste
disposed of in existing facilities if certain milestones were not
met.  In addition to basic disposal charges, waste generators were to
pay nonpenalty surcharges based on the volume of wastes disposed of
at the three operating disposal facilities.  The six deadlines and
milestones are described in figure 1.3. 

   Figure 1.3:  Deadlines and
   Milestones Contained in the
   1985 Amendments Act

   (See figure in printed
   edition.)

New York and two of its counties challenged several provisions of the
amendments, including the take-title provision contained in the last
milestone.  Nineteen other states supported this challenge.  Under
the take-title provision, states or compacts that failed to provide
for the disposal of all waste generated within their borders by
January 1, 1996, were required, upon request, to take title to and
possession of the waste and become liable for damages suffered by the
generators as a result of the state's failure to do so.  In 1992, the
U.S.  Supreme Court ruled in New York v.  United States, 112 S.Ct. 
2408 that this provision was unconstitutional.  The court concluded
that the Congress has power under the Constitution to preempt state
regulation or to encourage states to provide suggested regulatory
systems for disposal of the low-level waste generated within their
borders, but the Constitution does not confer upon the Congress the
ability to compel the states to do so in a particular way.  The court
held that the take-title provision was severable from the remainder
of the act. 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
---------------------------------------------------------- Chapter 1:3

Concerned about the environmental and economic effects of
implementing the Low-Level Radioactive Waste Policy Act of 1980, as
amended, Senators Christopher J.  Dodd and Joseph I.  Lieberman
requested that we review the status of the low-level waste program,
the economic and environmental effects of the planned disposal
facilities, and alternatives to the approach specified in the act, as
amended. 

To respond to the requesters, we interviewed

  state officials and members of the Low-Level Radioactive Waste
     Forum--an association of representatives of states and compacts
     established to help implement the act;

  waste generators and their associations, other professional
     associations, environmental groups, and members of academia;

  representatives from citizens' advisory groups and citizens groups
     that have opposed efforts by Connecticut, Nebraska, and
     Massachusetts to select sites for new disposal facilities;

  New York and North Carolina county officials in communities close
     to where sites have been considered; and

  officials in DOE, NRC, and the Environmental Protection Agency
     (EPA) who are responsible for issues in the commercially
     generated low-level waste area. 

In addition, we obtained and analyzed available documentation on the
subject area and attended various meetings sponsored by the Low-Level
Radioactive Waste Forum, EPA, NRC, and the National Institutes of
Standards and Technology. 

We also obtained and analyzed reports prepared by a presidential task
force, DOE, NRC, states, environmental organizations, and waste
generators and their associations.  We reviewed law review articles
and various articles and books from academic sources and professional
associations.  And, we hosted a meeting of representatives of
low-level waste generator organizations from six states and compacts. 

We visited several facilities to obtain information about waste
generation, storage, treatment, and disposal.  We visited waste
storage and processing facilities at the National Institutes of
Health in Bethesda, Maryland; a research hospital in Pennsylvania; a
research hospital, pharmaceutical manufacturer, and a nuclear power
plant in Illinois; and a biotechnology research firm in California. 
We also visited the operating disposal facility at Barnwell, South
Carolina, and a waste treatment facility in Tennessee. 

Finally, to assess pertinent economic issues, we examined reports
prepared by DOE contractors, NRC, and members of academia on the
economics of disposing of low-level waste.  Although these reports
did not address economic issues related to states' specific plans for
developing disposal facilities, they did provide general information
on topics such as the economic effects of developing varying numbers
and sizes of disposal facilities.  We did not independently verify
the cost data in these reports, and comparable economic studies were
not available from states. 

To ensure that our report is accurate, complete, and objective, we
provided copies of the draft report or portions of the draft report
to knowledgeable federal officials, including the program manager for
DOE's National Low-Level Waste Management Office and NRC staff in the
Office of State Programs, Division of Waste Management, Office of
Nuclear Materials Safety and Safeguards, and Office of the General
Counsel.  These officials generally agreed with the facts as
presented in our report, and NRC officials noted that our report
accurately characterized the current situation in developing
low-level waste disposal facilities.  NRC and DOE officials also
provided several technical and editorial comments which we
incorporated as appropriate to clarify and update the report. 

Our work was performed from January 1993 through April 1995 in
accordance with generally accepted government auditing standards. 


STATES ARE MAKING SLOW PROGRESS ON
DEVELOPING NEW DISPOSAL FACILITIES
============================================================ Chapter 2

As of January 1995, 11 states had plans to develop disposal
facilities for commercially generated low-level waste, and the state
of Washington planned to continue operating its existing disposal
facility.  Altogether, these 12 facilities would serve waste
generators in 47 states.  Five other states had no plans to meet the
needs of their waste generators.\1 Only 4 of the 11 states have
selected candidate sites for disposal facilities; and none of these
proposed facilities is under construction.  States' estimated dates
for opening the planned facilities range from 1997 to 2002, but these
dates may be optimistic. 

The length of time states are taking to establish new disposal
facilities is largely attributable to the controversial nature of
nuclear waste disposal.  Because existing facilities had closed to
most states and new facilities will not be built for some time, waste
generators in 33 states, which generate about 42 percent of the
waste, have not had access to disposal facilities since July 1, 1994. 
These waste generators will have to store their own wastes until new
disposal facilities are built. 


--------------------
\1 The law defined "state" to include the District of Columbia and
Puerto Rico. 


   NEW DISPOSAL FACILITIES ARE
   YEARS AWAY
---------------------------------------------------------- Chapter 2:1

Forty-two states have established nine compacts.  The Northwest and
Rocky Mountain Compacts, comprising 11 states, intend to use
Washington's existing disposal facility.  The Southeast Compact of
eight states plans to develop a disposal facility in North Carolina
and to close the Barnwell, South Carolina, disposal facility, which
is currently available for only those eight states.\2 And, six other
compacts plan to develop seven new disposal facilities.  (The two
states that comprise the Northeast Compact--Connecticut and New
Jersey--each plan to develop its own facility).  Three other states
have formed a tenth compact, the Texas Compact, that has not yet been
approved by the Congress.  This proposed compact also plans to
develop a disposal facility in Texas.  Finally, two states,
Massachusetts and New York, are not members of compacts, and they
intend to develop their own disposal facilities.  Thus, 11 new
disposal facilities are planned, and 1 existing facility would remain
open for a total of 12 disposal facilities.  Only four compacts,
however, have selected candidate sites for their respective
facilities, and no new disposal facility is yet under construction.\3
Figure 2.1 shows the volume of waste disposed of by waste generators
in each compact and unaffiliated state from 1991 through 1993 and the
membership of each compact. 

   Figure 2.1:  Waste Volume Among
   Compacts and Unaffiliated
   States from 1991 through 1993

   (See figure in printed
   edition.)

Note:The figures are based on the amounts of waste sent to existing
disposal facilities.  Michigan generators have not been allowed
access since 1990.  In that year, the state had about 36,000 cubic
feet of waste, or 3 percent of the nation's total. 

\a Texas, Maine, and Vermont formed a compact in 1992; however, the
Congress has not yet approved the compact. 

No state has developed a new facility for disposal of commercially
generated low-level radioactive waste since the 1980 act was passed. 
Current estimated dates for opening the 11 planned facilities range
from 1997 to 2002.  These dates, however, may be optimistic because
earlier dates have slipped over the years.  Also, some states that
once appeared to be making the most progress, such as Illinois, are
now further behind other states because of setbacks in their efforts
to select a site for a disposal facility.  Figure 2.2 shows how state
and compact estimates of completion dates changed between 1991 and
1995. 

   Figure 2.2:  Difference Between
   1991 and 1995 Estimates for
   Opening New Disposal Facilities

   (See figure in printed
   edition.)

Three compacts totaling 19 states continue to be served by the
existing disposal facilities in South Carolina and Washington.  (See
fig.  2.2.) Since July 1, 1994, when the South Carolina facility
closed to waste generators outside the Southeast Compact, generators
in the remaining 33 states have not had access to disposal
facilities.  (See fig.  2.3.) In fact, the states and compacts with
jurisdiction for the South Carolina and Washington facilities began
denying waste generators in some states, such as Michigan, New
Hampshire, Puerto Rico, and Rhode Island, access to the existing
disposal facilities prior to 1994.  The denials were made on the
basis that those states had not demonstrated sufficient progress in
either joining other compacts of states or developing their own
disposal facilities.  Waste generators that do not have access to
disposal facilities accounted for about 42 percent of all
commercially generated low-level waste in 1993, the last full year
that waste generators in most states had access to a disposal
facility.  The waste generators will have to treat and/or store their
low-level wastes until their respective states develop new disposal
facilities or obtain access to other facilities. 

   Figure 2.3:  States With and
   Without Access to Disposal
   Facilities

   (See figure in printed
   edition.)

California, Nebraska, North Carolina, and Texas are the host states
for new disposal facilities for three compacts and a proposed compact
made up of a total of 20 states.  Waste generators in these 20 states
account for about 43 percent of all commercially generated low-level
waste.  Developers of potential disposal facilities in the four host
states have submitted applications to state regulatory authorities to
construct and operate their facilities. 

The developer for a potential facility in California submitted a
license application in 1989, and the state has licensed the facility
pending sale of the land to the state by the U.S.  Department of the
Interior.  In 1990, the developer for the Nebraska facility submitted
a license application and then revised the application in 1993.  The
developers in North Carolina and Texas submitted final license
applications for state reviews in 1993.  None of the host states for
other compacts or Massachusetts and New York have identified
candidate sites for disposal facilities. 


--------------------
\2 On April 13, 1995, the governor of South Carolina called on the
state's General Assembly to extend the life of the Barnwell facility
for 10 years or until North Carolina has opened its planned disposal
facility.  The governor did not explicitly state whether he proposed
to once again open the facility to waste generators in all states or
to limit access to the facility to generators within the Southeast
Compact.  Under the current arrangement, the Barnwell facility could
not be reopened to waste generators outside the Southeast Compact
without the approval of the state legislature and the compact.  On
May 2 the compact commission considered but did not pass a motion to
extend access to the facility. 

\3 In 1988, Utah licensed a disposal facility for large shipments of
specific low concentrations of a limited number of radionuclides of
relatively less hazardous low-level waste.  However, the privately
developed facility is privately owned and operated.  The Northwest
Interstate Compact provided a resolution allowing the acceptance and
disposal of these wastes, and the facility operators have received
the necessary licenses and permits. 


   SLOW PROGRESS IS DUE TO
   CONTROVERSY OVER DISPOSAL
   FACILITIES
---------------------------------------------------------- Chapter 2:2

The limited progress states have made in developing new facilities
for disposing of commercially generated low-level waste appears to be
fundamentally due to the controversial nature of such facilities. 
Put another way, the length of time required to form compacts, select
states to host new facilities, develop necessary legislation and
regulations, and select candidate sites for facilities appears to
reflect the widespread concern about such facilities among the
affected public and various state and local government entities. 

Early in 1993, NRC's staff reviewed the experiences of 13 states in
addressing the needs of their waste generators for access to disposal
facilities.  NRC's staff identified seven factors that, in its
judgment, had affected the progress of these states, including

  criteria and procedures for selecting sites,

  funding and legislation,

  litigation,

  perceptions that federal and state regulations were inadequate,

  perceptions that long-term storage of waste is more desirable than
     disposal, and

  liability protection for citizens and property from potential
     releases of radioactivity from a disposal facility. 

The staff said that the seventh factor--public and political concern
over the development of new disposal facilities--appeared to be one
of the major factors linked to many of the other factors.  Public
concern and an absence of broad-based public and political acceptance
has had a significant effect on the development of new disposal
facilities.  Public concern, according to the staff, has been
demonstrated in a variety of ways, including

  lack of volunteer sites for disposal facilities,

  delays in enacting necessary legislation,

  changes in states' legislation affecting site-selection processes,

  strict site-selection regulations, and

  litigation. 

Moreover, according to the staff, public concern tends to increase
and change as the site-selection process advances. 

The process of developing compacts and selecting a state within a
compact to develop a disposal facility illustrates the difficulty at
the political level of moving forward with a program for developing a
disposal facility.  In the early 1980s, 11 northeastern states were
considering forming a regional compact.  However, the compact never
materialized because, according to observers, no state would agree to
host a disposal facility for the large amount of waste that would be
coming from the other states.  Subsequently, the states splintered
into smaller compacts, and several states decided to independently
pursue their own waste disposal solutions, but none has selected a
site for licensing. 

In an earlier report, we also pointed out that choosing sites for
disposal facilities could be controversial and time-consuming.\9 The
process of selecting sites became longer than states had originally
anticipated, in part, because of the extent of public involvement in
these proceedings. 

The following discussion of the experiences of several states
illustrates how the public and political concern over disposal
facilities has affected the states' abilities to develop new
facilities. 


--------------------
\9 Nuclear Waste:  Slow Progress In Developing Low-Level Radioactive
Waste Disposal Facilities (GAO/RCED-92-61, Jan.  10, 1992). 


      ILLINOIS
-------------------------------------------------------- Chapter 2:2.1

Because of questions about the process for selecting a new site for a
disposal facility and concerns about the suitability of a proposed
site, the governor of Illinois and the state's legislature created an
independent commission to examine the safety of the proposed site in
1989.  In 1992, the commission found the site unacceptable, rejecting
the conclusions of the state agency that had spent 8 years and about
$85 million finding and studying the site.  Since then, Illinois has
abandoned the site and has embarked on a new approach which involves
determining scientific requirements for the siting process followed
by statewide screening to find a site. 


      CONNECTICUT
-------------------------------------------------------- Chapter 2:2.2

In 1991, citizen groups in Connecticut challenged the results of a
statewide screening and selection process.  Afterwards, the state
enacted legislation that voided the site screening and selection
results and directed the state's siting authority to restart the
site-selection process.\10 The authority is now using a volunteer
process to find a site that has been approved by the local electorate
in a referendum. 


--------------------
\10 Nuclear Waste:  Connecticut's First Site Selection Process for a
Disposal Facility (GAO/RCED-93-81, Apr.  5, 1993). 


      NEBRASKA
-------------------------------------------------------- Chapter 2:2.3

In 1988, during the screening process to find a suitable site in
Nebraska, the developer received a formal expression of interest from
several counties.  The developer submitted a license application to
the state agencies in July 1990, and the state declared the
application complete and ready for technical review in December 1991. 
In January 1993, however, the state filed a lawsuit in the U.S. 
District Court for the District of Nebraska seeking a permanent
injunction to prevent the licensing or construction of a facility in
the state until community consent is demonstrated.  In October 1993,
the court granted summary judgment in favor of the defendants on
procedural grounds.  The court held that action on the community
consent issue was barred by the statute of limitations provision in
the compact.  In June 1994, the U.S.  Court of Appeals for the Eighth
Circuit affirmed the lower court's decision.  The state's petition to
the Supreme Court to hear an appeal was denied in November 1994. 

Also in January 1993, Nebraska's regulatory agency announced its
intent to deny a license for the proposed disposal facility on the
basis that the site contained wetlands.  In October 1993, after the
developer redesignated the boundaries of the site and eliminated the
disputed wetlands area, the regulatory agency notified the developer
that the agency would withdraw its intent to deny the license.  The
developer's license application is currently under state review. 


      NORTH CAROLINA
-------------------------------------------------------- Chapter 2:2.4

In 1990, two candidate sites were selected in the host state of North
Carolina.  Subsequently, officials in the affected counties opposed
the selection of the two candidate sites and filed two suits against
the state's siting authority.  One suit claimed that an environmental
impact statement was required before investigation of a site could
begin.  The other suit alleged that improper procedures were used in
the site-selection process.  In February 1993, the state court of
appeals ruled in favor of the siting authority.  The counties
appealed to the state supreme court in March 1993 and, in November
1993, that court agreed to let stand the decision of the appeals
court. 

Because of the pending lawsuits, the siting authority's contractor,
which was responsible for studying the sites, could do only
preliminary, off-site testing.  As a result, the siting authority did
not select one of the two sites for use as a disposal facility until
December 1993, or 3 years later than the siting authority had
planned.  Because the state called for further study of site features
in 1994, the siting authority's estimated date for licensing
construction of the planned disposal facility has slipped from March
1995 until August 1997. 


      CALIFORNIA
-------------------------------------------------------- Chapter 2:2.5

In 1993, California officials had expected that their proposed
disposal facility in the Mojave Desert for the Southwest Compact
would be operating by 1994, but the controversy surrounding the
siting effort has led to a later estimated opening.  Besides lawsuits
filed by opposition groups, a group of U.S.  Geological Survey
geologists, acting independently of their organization, prepared a
report raising technical concerns about the site and the siting
process.  On the basis of the geologists' report, a California
Senator asked the President for a full hearing and an examination of
alternatives for the site before the sale of federal land to the
state.  In 1994, the Secretary of the Interior asked the National
Academy of Sciences to review the concerns of the Geological Survey
geologists and to report back in May 1995.  Depending upon the
Academy's findings, the Secretary may also want an adjudicatory
hearing to examine opponents' concerns.  After the Academy has issued
its report and, perhaps, an adjudicatory hearing has been held, the
Secretary will determine whether the land will be transferred to the
state. 


      MICHIGAN
-------------------------------------------------------- Chapter 2:2.6

By October 1989, Michigan, the original host state for the Midwest
Compact, had identified three candidate sites for a disposal facility
but had then eliminated the three sites from further consideration
because the sites did not meet its siting criteria.  At a July 1991
meeting, Michigan presented several conditions for the compact to
meet if it expected the state to continue its siting efforts.  One
condition, for example, was that the state would be released from its
role as host state if, under Michigan law, the state could not find a
suitable site for a disposal facility. 

The compact decided that Michigan had unreasonable criteria that
essentially precluded the state from finding a suitable site.  The
compact then voted to expel Michigan for not acting in good faith to
honor a binding contractual obligation to find a waste disposal site
in Michigan.  Ohio has assumed the host-state responsibility and has
begun to develop a process for selecting a site for a disposal
facility. 


      NEW YORK
-------------------------------------------------------- Chapter 2:2.7

In 1989, a New York state commission selected five potential sites
for low-level waste in Cortland and Allegany counties.  The
commission had intended to conduct initial on-site technical
investigations of the five sites by late spring of 1990 and then
select at least two of the sites for a more intensive, 1-year
investigation.  However, public protests--including civil
disobedience during the commission's attempts to gain access to the
sites--and other objections from citizens and local governments
caused the governor to request the commission to defer on-site work
until a new approach could be developed.  The commission suspended
its field work in April 1990, and later in 1990, the state amended
its waste disposal act. 

In the meantime, Cortland County, where two of the five proposed
sites are located, had questioned the commission's credibility, in
part, because the county contended that the commission did not follow
its site-selection plan in selecting a volunteer site.  In February
1990, the state joined the two potential host counties in filing suit
against the federal government questioning the constitutionality of
the Low-Level Waste Policy Act, as amended.  These lawsuits led to
the Supreme Court's decision that the act's take-title provision was
unconstitutional.  The state is currently trying to determine the
best method for disposing of waste before deciding on a location for
a disposal facility. 


ECONOMIC EFFICIENCIES IN FEWER
DISPOSAL FACILITIES MAY DEPEND IN
PART ON FUTURE WASTE VOLUME
============================================================ Chapter 3

There are no reliable estimates of the cost to dispose of the
nation's commercially generated low-level radioactive waste.  In
1980, there were three operating disposal facilities serving almost
four times the current volume of commercially generated low-level
radioactive waste.  Currently, 11 new facilities are planned in
addition to the state of Washington's existing facility.  Most states
have not estimated the total costs of their planned facilities or the
unit disposal costs.  Studies by DOE and others that examine economic
aspects of low-level radioactive waste facilities have concluded that
fewer larger new facilities could accommodate current waste volumes
at less cost than a larger number of small facilities.  The studies,
however, have limited usefulness in determining the optimal number of
sites.  For example, no studies had up-to-date cost data, and the
models that were used had limited scope and were not capable of
estimating costs for the potential range of required disposal
facility sizes. 

In addition, there are uncertainties related to the volume of
commercially generated low-level waste that may be produced over the
lifetime of the planned disposal facilities that were not accounted
for in available studies of the economics of waste disposal.  Two
interrelated uncertainties are when utilities will retire their
nuclear power plants and, once plants have been shut down, when they
will be dismantled.  Also, waste generators might, depending on the
availability of disposal capacity and disposal fees, intensify past
efforts to minimize the volume of waste that they must manage and
eventually dispose of. 


   STATES HAVE NOT ESTIMATED TOTAL
   DISPOSAL COSTS
---------------------------------------------------------- Chapter 3:1

Most states and compacts have not estimated what the total costs will
be for their proposed facilities.  State officials said that they are
reluctant to provide such estimates because the different methods of
calculating cost estimates that the states would use would lead to
inaccurate comparisons of facility costs.  For example, in
determining the life-cycle cost--the full cost of the facility,
including siting, development, construction, operating, closing, and
post-closure monitoring--volume, and type of facility would play an
important part.  The unit cost of disposal at a small facility with
above-ground concrete vaults to hold the waste would be higher than
at a large facility that relied on shallow burial in earthen
trenches.  Also, each state and compact has different institutional
and regulatory requirements, including liability funds. 

In 1993, NRC surveyed states and compacts to obtain cost information. 
Of the 11 potential host states, 5 provided life- cycle cost
estimates--California, Massachusetts, Pennsylvania, Texas, and
Vermont.\1 The estimates ranged from $260 million in Texas to $920
million in Pennsylvania.  In an April 1993 letter to NRC, the
Low-Level Waste Radioactive Forum questioned the timing, methodology,
accuracy, and usefulness of NRC's study.  The Forum was concerned
that NRC's presentation of the data could erroneously imply that data
for the states were comparable and complete.  Forum officials told us
that the reasons for the wide variance in estimates may be based on
factors such as the type of facility, accounting methods, definition
of terms, and varying talents at estimating costs among the states. 


--------------------
\1 Massachusetts did not initiate a search for a disposal facility
site until about a year after providing the estimate to NRC.  Also,
Vermont subsequently decided to join a compact with Texas rather than
develop its own facility. 


   STUDIES SHOW THAT FEWER AND
   LARGER FACILITIES ARE MORE
   COST-EFFICIENT
---------------------------------------------------------- Chapter 3:2

We identified and reviewed seven conceptual studies that examined the
costs of disposing of commercially generated low-level radioactive
waste.\2 (See app.  I for information on these seven studies.) All of
these studies concluded that fewer, larger facilities would be more
economically efficient than several smaller ones.  The optimal number
of facilities was between two and five.  This finding was consistent
even though the studies were produced at different times, employed
different methodologies and cost estimates, and varied in their
estimates of the optimum number of facilities.  Moreover, the studies
were limited to assumptions that the volume of waste would continue
at the same rate for the life of the facilities.\3 The volume may
increase or decrease, depending, for example, on how and when nuclear
power plants are dismantled.  We were not able to develop a
comparative cost analysis to demonstrate the relative efficiency of a
wide range of plant sizes because we found no model with up-to-date
cost data that was capable of estimating costs for the entire range
of facility sizes required. 

Three of the studies prepared for DOE clearly demonstrate the
economic benefits of consolidating small-volume facilities.  The 1987
Conceptual Design Report, which examined large-scale facilities,
found that increasing annual disposal capacity from an annual rate of
235,000 cubic feet to 350,000 cubic feet would reduce unit disposal
costs by 25 to 50 percent.  A 1991 report on small volume facilities
concluded that unit costs rise radically as facility size decreases. 
The report estimated that costs were 143 percent higher for a
disposal facility capable of annually accepting 10,000 cubic feet of
waste than for a facility with three times this waste acceptance
capacity.  A 1993 study concluded that efforts to develop a
cost-effective waste disposal facility should seek to match facility
size as closely as possible to disposal waste demand and concentrate
waste disposal activities at a small number of large sites. 

Disposal facilities that can handle high volumes of commercially
generated low-level waste enjoy economies of scale because a
significant portion of facility costs are fixed and do not vary with
volume of disposal.  These fixed costs can be spread over the high
number of waste units received, thus lowering the per-unit cost of
disposal.  Because fixed costs are very significant in low-level
waste disposal, a facility's average costs decline markedly as
facility size increases.  (See table 3.1.) Also, a few large sites
can reduce the fixed costs of identifying and licensing many small
sites. 



                         Table 3.1
          
              Costs Compared to Facility Size

                       Annual disposal
Facility size         rate (cubic feet
(cubic feet)                 per year)  Unit disposal cost
------------------  ------------------  ------------------
300,000                         10,000             $643.27
900,000                         30,000             $223.99
1,500,000                       50,000             $140.14
----------------------------------------------------------
Source:  Economics of a Small Volume Low-Level Radioactive Waste
Disposal Facility, (Dames and Moore, Jan.  14, 1993). 

Although there is agreement among the studies on the efficiency of
fewer, larger facilities, only three of the seven studies we reviewed
estimated the optimal number of sites.  The estimates for the optimum
number of sites ranged from two to five.  In 1990, Bullard and Weger
found that facilities designed to handle annual volumes between
200,000 and 500,000 cubic feet were most economically efficient. 
Using DOE's projection of 933,000 cubic feet on average annually for
the period 2000 to 2030, the number of economically efficient sites
would be from two to five.  In 1992, Coates, Heid, and Munger
estimated the maximum number of economically viable sites to be five,
while stating that a more realistic estimate would be two or three
facilities. 

We were not able to develop a comparative cost analysis to
demonstrate the relative efficiency of a wide range of facility sizes
because all available cost studies contained either outdated data,
which do not reflect current marketplace conditions, or limited scope
for considering a narrow range of disposal facility sizes.  However,
all available cost information we collected point to a rapidly rising
trend in major cost categories and most notably in pre-operating and
siting costs. 

Cost information from North Carolina and Nebraska confirm that states
are facing escalating costs.  In 1989, North Carolina projected that
pre-licensing costs would be $17.7 million; by 1991 the estimate had
tripled to $51.1 million.\4 Nebraska's total cost estimates rose 231
percent from 1987 to 1992, from $36.9 million to $122.3 million. 
Also, NRC reported in its study that California's cost estimate had
increased by a factor of six.  Although we did not attempt to verify
specific cost data reported, we believe that the sources that were
used are the best available on the economic trends faced by states
and compacts under the program. 


--------------------
\2 Four of the studies were prepared for DOE.  A fifth study was
prepared for the Electric Power Research Institute.  Also, two
studies were prepared by university researchers.  None of the studies
relied on state information regarding all the specifically proposed
disposal facilities. 

\3 While the price of disposal has traditionally been based on
volume, several state officials and industry representatives said
that future pricing may be based more on the radioactivity of the
waste, which has shown an erratic trend in the last 15 years. 

\4 Unless otherwise noted, all costs have been adjusted to 1992
dollars. 


   UNCERTAINTIES THAT COULD AFFECT
   WASTE VOLUME AND ECONOMICS OF
   DISPOSAL FACILITIES
---------------------------------------------------------- Chapter 3:3

There are uncertainties related to the volume of commercially
generated low-level waste that may be produced over the lifetime of
the planned disposal facilities that were not accounted for in
available studies of the economics of waste disposal.  Two
uncertainties are when utilities will retire their nuclear power
plants and when they will decontaminate and dismantle retired plants. 
In addition, waste generators might, depending on factors such as the
availability of disposal capacity and fees charged for disposal
services, continue past efforts to minimize the volume of waste that
they must manage and eventually dispose of. 


      TIMING OF NUCLEAR POWER
      PLANT RETIREMENTS WILL
      AFFECT WASTE VOLUME
-------------------------------------------------------- Chapter 3:3.1

Today, there are more than 100 civilian nuclear power plants in
operation in about 30 states.  In 1993, the operating plants
collectively produced about 50 percent of the volume (and 95 percent
of the radioactivity) of commercially generated low-level waste. 
Typically, NRC licenses these nuclear power plants to operate for 40
years, but many utilities are interested in extending the authorized
operating lives of their plants by up to 20 years.  Although NRC's
regulations permit such life extensions, no civilian nuclear power
plant has yet operated for 40 years.  Sixteen plants have been
permanently shut down before operating that long. 

In the next 20 years, about 50 nuclear power plants will have to be
retired unless their licenses are extended.  No utility has yet
submitted an application to extend its operating license, and since
1979 utilities have retired seven nuclear plants earlier than had
originally been anticipated.\5 For example, owners of the Yankee Rowe
and the Monticello plants originally planned to submit applications
to NRC for license extensions as part of a cooperative program
between DOE and the nuclear power industry.  However, in 1992, the
utility that owns the Monticello plant indefinitely deferred its
application for a number of reasons, such as increases in estimated
costs of upgrading to new equipment standards, and DOE's inability to
accept spent fuel from the plant for storage or disposal.  Then, in
1992, the owner of the Yankee Rowe plant decided to retire that plant
for economic reasons. 

Thus, future decisions on when to retire civilian nuclear power
plants from service, including the possibility of extending the
operating lives of these plants, will affect the volumes of
commercially generated low-level waste that must be disposed of over
the next several decades.  The state of Pennsylvania, for example,
has estimated that extending, by 20 years, the operating lives of the
12 nuclear power plants located in states that make up the
Appalachian Compact could produce an additional 3.3 million cubic
feet of low-level waste through the first quarter of the next
century. 


--------------------
\5 Two of the seven plants are unusual cases.  First, one of two
plants at Three Mile Island experienced an accident after less than 2
years of operations.  Second, the Shoreham plant was tested
intermittently for 2 years but then permanently shut down.  The
average life of the remaining five plants was about 20 years, or half
the typical 40-year period of an operating license. 


      TIMING OF DECONTAMINATING
      AND DISMANTLING NUCLEAR
      POWER PLANTS WILL AFFECT
      WASTE VOLUME
-------------------------------------------------------- Chapter 3:3.2

In addition to the low-level waste that civilian nuclear power plants
produce during their operating periods, many components of the plants
become contaminated with radioactivity as a result of years of plant
operations.  For this reason, plants that have been retired from
service must be decommissioned.  Decommissioning refers to safely
removing a nuclear plant from service, reducing residual
radioactivity to a level that permits release of the plant property
for unrestricted use, and terminating the utility's license for the
plant. 

NRC requires a utility to submit a plan for decommissioning a nuclear
power plant within 2 years of the time that the utility retires the
plant from service.  Although specific decommissioning plans may vary
from plant to plant, NRC generally requires that a utility complete
decommissioning within 60 years of the plant's retirement.  To meet
the 60-year requirement, utilities may either dismantle and/or
decontaminate portions of a plant that contain radioactive
contaminants shortly after retirement or allow the radioactive
contaminants to decay over a period of years prior to decontamination
and/or dismantlement. 

Thus, decisions on when to decontaminate and dismantle retired plants
will affect the waste volume just as decisions on when to retire
nuclear power plants will affect the volume.  DOE estimates that
decommissioning and decontaminating the nuclear power plants that
utilities will shut down over the next 30 years will generate about
55 million cubic feet of low-level waste.  DOE assumed a 2-year
planning period after a plant has been permanently shut down followed
by a 4-year decontamination period.  Either more or less waste than
estimated, however, could be generated and disposed of at new
disposal facilities, depending on the timing of decommissioning and
decontamination of these plants.  If utilities decontaminate and
dismantle more nuclear plants over the next 30 years than projected,
they could generate even more low-level waste. 

Even if nuclear power plants are not decommissioned and
decontaminated immediately, there may be a sizable amount of waste
generated to keep them operating.  If all nuclear plants in the
Appalachian Compact received 20-year license renewals, for example,
Pennsylvania officials estimated that 3.3 million cubic feet of waste
would be generated for the same period. 


      TRENDS IN WASTE VOLUME
-------------------------------------------------------- Chapter 3:3.3

The future trend of waste volume depends on several uncertainties. 
Among other things, the trend may depend on the economics of storage
and disposal and waste minimization techniques. 

In the initial years (1963 to 1971) of commercially generated
low-level waste disposal, the volume of waste and the number of sites
increased.  As the number of disposal facilities declined, the volume
of disposed waste continued to increase, until the Low-Level Waste
Policy Act of 1980 was enacted.  (See fig.  3.1.) Since 1980, the
volume has decreased.  This reversal has been attributed, in large
part, to the 1980 act, as amended; decisions by states with existing
disposal facilities to charge higher disposal fees; and limits on the
volume of waste that could be disposed of in their facilities. 

   Figure 3.1:  Volume of
   Low-Level Waste Disposal

   (See figure in printed
   edition.)

Note:  There were five disposal facilities in 1977, four facilities
until April 1978, and three facilities from April 1978 through 1992. 
In 1993, two facilities were available to most states.  Also, the
Utah facility was available since 1988 for large shipments of
specific low concentrations of a limited number of radionuclides. 

Source:  DOE. 

Industry representatives and state and federal officials that we
talked with differed on whether further significant reductions will
occur in the volume of commercially generated low-level radioactive
waste that must be disposed of.  Some of the officials said that
uncertainties in the costs of storage and disposal could eventually
lead to reduced volume through new or additional treatment that would
not necessarily reduce radioactivity.  Others said that the
uncertainties could lead to reduced usage of radioactive materials,
particularly among smaller generators.  For larger generators, such
as utilities, storage and disposal costs are not expected to be as
important.\6 According to the Office of Technology Assessment, even
with higher anticipated disposal costs, low-level waste costs would
average about 1 percent of the utility's operational costs. 


--------------------
\6 A representative of a disposal facility developer estimated that
an increase in disposal cost from $50 to $250 would mean a $1 annual
increase for the average electricity user. 


SPECIFIC ENVIRONMENTAL EFFECTS OF
THE CURRENT PROGRAM ARE UNKNOWN
============================================================ Chapter 4

No studies have been conducted on the combined environmental effects
of the number of planned disposal facilities.  Also, because no new
disposal facilities have been built, little is known about the
specific environmental effects at most of the planned facilities. 
With waste generators in most states now storing their own wastes and
no new disposal facilities available, the environmental risks of
long-term storage may increase as the amount of waste increases and
reaches generators' current capacities. 


   LITTLE KNOWN ABOUT THE
   ENVIRONMENTAL EFFECTS OF THE
   PLANNED DISPOSAL FACILITIES
---------------------------------------------------------- Chapter 4:1

Currently, no studies have been conducted of the overall
environmental effects of the 1 existing and 11 planned disposal
facilities for commercially generated low-level waste.  Furthermore,
there are opposing views on whether having more disposal facilities
than in the past will increase the environmental risks. 

Because of past problems at disposal facilities, representatives of
national groups opposed to nuclear activities and some local
opponents of states' efforts to find sites for disposal facilities
question whether the waste can be safely disposed of.  Several former
disposal facilities experienced environmental problems, such as
radionuclides leaking into groundwater.  However, several state
officials and generators said that new disposal facilities would not
encounter such problems because the land disposal regulations
developed by NRC in 1982 include, among other things, stricter
requirements for investigating sites and building and operating
facilities.  In addition, NRC officials pointed out that each new
disposal facility would have to comply with these regulations,
including limits on the dose of radiation that a member of the public
could receive each year from operation of the facility.  (App.  II
provides a brief description of NRC's standard for allowable
radioactive risk to the public and EPA's current concern about NRC's
standard.) NRC officials also said that the environmental impact
statement that NRC prepared for the purpose of developing its
disposal regulations assessed, in general terms, potential
environmental effects, such as air quality, energy use, and social
impacts. 

Because of regulatory requirements for a buffer zone of land
surrounding a disposal facility for commercially generated low-level
waste, developing the 11 planned facilities may require more land
dedicated to disposal than would fewer larger facilities.  The
acreage dedicated to such facilities, including buffer zones, will
require monitoring and limited land-use applications for at least a
century.  Furthermore, unless the currently planned facilities can
expand their operating lives, there may be a need to establish more
sites in 20 to 30 years.  For example, the Southwest Compact
Agreement states that, if California decides to close its facility
after an operating life of 30 years, another state in the compact
will become the host of another disposal facility for another 30
years. 

According to some state officials and waste generators, however,
having several disposal sites could have positive effects on public
health and safety by reducing distances from generators to processors
and to disposal facilities and, therefore, reducing the chances of
transportation accidents.  Estimating potential transportation
benefits may be difficult, because of the many factors, such as road
conditions, weather, driver error, and type of vehicle, that
contribute to accidents.  In addition, many generators use various
waste brokers and processors in different parts of the nation for
temporary storage, packaging, and treatment of waste before sending
it to disposal facilities, which could also affect transportation
distances.  Proponents of new disposal facilities also point out that
the transportation of waste has never created a grave environmental
or safety risk.  According to DOE, 53 transportation accidents
involving low-level waste were reported in the 20-year period from
1971 to 1991.  Four involved the release of radioactive waste, but no
radiologically related death or injury occurred.  (See fig.  4.1 for
an example of how some types of low-level waste are transported.)

   Figure 4.1:  How Some Waste is
   Transported

   (See figure in printed
   edition.)

   Source:  Chem Nuclear Systems,
   Inc.

   (See figure in printed
   edition.)


   TOO EARLY TO ESTIMATE
   ENVIRONMENTAL EFFECTS OF
   SPECIFIC SITES
---------------------------------------------------------- Chapter 4:2

Very little information exists on the potential environmental effects
at most of the 11 planned disposal sites.  California has licensed a
facility, but environmental concerns remain unresolved.  Nebraska,
North Carolina, and Texas are currently reviewing license
applications, including environmental impact statements.  If the
states find significant environmental concerns based on their
reviews, the sites can be rejected. 

After 7 years of investigating the suitability of a site in Ward
Valley, in the Mojave Desert, California found that the site and
proposed facility met its regulatory requirements.  The state's
findings, however, have been challenged on the basis that the
developer's investigation of the site was not thorough and
independent.  Opponents of the site point out that three geologists
with the U.S.  Geological Survey have challenged the assumptions and
theoretical models used to analyze the safety of the proposed
facility.  For example, the geologists believe the potential exists
for the contamination of groundwater underlying the Ward Valley site
and subsequent transmittal of radioactive materials to the Colorado
River--a major source of water for Southern California, Arizona, and
part of Mexico.  A scientific consultant for the Metropolitan Water
District of Southern California said that the long-term potential for
contamination of the river is uncertain.  Because the Ward Valley
site is on federal land, the Secretary of the Interior has decided to
postpone further action on transferring the land to the state until
the National Academy of Sciences examines these issues and, if
necessary, the issues have been examined in an adjudicatory
hearing.\1

North Carolina has not completed its examination of the environmental
suitability of a proposed site for a disposal facility.  The North
Carolina developer submitted a report indicating that both of the
sites it had studied were suitable for disposal facilities.  In
October 1993, the developer submitted licensing documents for a site
in Wake County, noting that the site meets all applicable laws,
regulations, and requirements.  According to the developer, even
using very conservative estimates of the release of radioactive
particles to the environment, the public and the environment are
protected and estimated radiation doses are far below the regulatory
limits.  On December 8, 1993, North Carolina approved the 746-acre
Wake County site for further consideration, and the state regulatory
authority is reviewing the license application. 


--------------------
\1 The land would be transferred to the state because it is the
policy of Interior not to permit waste disposal sites on public
lands. 


   THERE ARE POTENTIAL ADVERSE
   ENVIRONMENTAL EFFECTS OF
   LONG-TERM STORAGE
---------------------------------------------------------- Chapter 4:3

Waste generators have stored waste temporarily to permit the waste to
decay or to consolidate waste for shipment for processing or
disposal.  With the recent closing of the Barnwell facility to waste
generators outside the Southeast Compact, however, waste generators
in the 33 states that are not members of the Northwest, Rocky
Mountain, and Southeast Compacts have no disposal facilities to
accept their wastes until their respective compacts or states have
developed new disposal facilities.  These generators, who accounted
for about 42 percent of all commercially generated low-level waste in
1993, will have to arrange storage for their waste until their
respective compacts or states develop new disposal facilities or
obtain access to other facilities. 

In the meantime, waste storage is increasing in numerous locations
around the nation, including in heavily populated areas and in
industrial parks.  For example, in 1993, after Washington, D.C., lost
access to a disposal facility, the radiation safety officer at a
university's medical research center in the District said that he
converted a portion of the institution's parking area to a storage
area.  Some biotechnology firms in an industrial park in San Diego,
California, store their waste drums and liquid waste containers in
cargo containers, as approved by the California Department of Health. 
Figures 4.2 and 4.3 show two other examples of storage areas.  Figure
4.4 shows the number of on-site storage areas in Ohio. 

   Figure 4.2:  Low-Level Waste
   Storage Area on a University
   Campus in Washington, D.C.

   (See figure in printed
   edition.)

   Figure 4.3:  Low-level Waste
   Stored at an Industrial Park
   Near Chicago

   (See figure in printed
   edition.)

   Note:  The photograph shows the
   amount of disposable waste
   accumulated during 1 year.

   (See figure in printed
   edition.)

   Figure 4.4:  Storage Areas for
   Low-Level Waste in Ohio

   (See figure in printed
   edition.)

   Note:  Some waste generators
   may ship wastes to brokers or
   processors for short-term
   storage.

   (See figure in printed
   edition.)

   Source:  The map is based on
   information from the Ohio
   Department of Health.

   (See figure in printed
   edition.)

The prospects of long-term storage of increasing quantities of
commercially generated low-level waste has raised several
environmental and health concerns, particularly for small waste
generators.  Generally, large generators, such as utilities that
operate nuclear power plants, have adequate storage space and
technical expertise.  Although some alternatives to supplement
long-term storage, such as legal disposal into sewage systems or
incineration, may be available to some waste generators, little is
known about the extent to which these alternatives might relieve the
storage burden on generators.  In this regard, there is limited
information currently available throughout the nation on quantities
of waste now in storage, waste generators' storage capabilities, and
the extent to which generators are using alternative waste management
techniques.  And, neither NRC nor DOE currently have plans to collect
such information. 


      LONG-TERM STORAGE RAISES
      ENVIRONMENTAL AND HEALTH
      CONCERNS
-------------------------------------------------------- Chapter 4:3.1

NRC has several primary concerns about the potential effects on
public health and the environment from waste generators significantly
increasing their storage of commercially generated low-level waste. 
One concern is the potential for releases of radioactive materials in
the event of an accident caused by an event such as a fire,
hurricane, or tornado.  According to an NRC official, no serious
accidents related to storage have occurred in the past.  Although NRC
has not conducted any analyses of the potential consequences of such
an event, it believes the risk of potential releases as a result of
an event or accident at one of numerous storage sites around the
country is higher than the risk of a release from a limited number of
disposal sites. 

Another NRC concern relates to potential degradation of the packages
that contain stored waste.  Depending on the waste storage
environment, degradation of waste packages could occur in several
ways, such as temperature fluctuations, corrosion, generation of
gases and corrosive substances, and radiation-induced embrittlement
of certain containers.  (Fig.  4.5 shows an example of corrosion of
low-level waste drums at a DOE facility.) Therefore, waste generators
need to maintain sufficient integrity of their stored waste packages
to prevent dispersal of the waste during storage, transport, and
handling.  According to NRC, if gone undetected, degradation of
packages could lead to spills or releases during handling for
disposal, which would create the potential for increased worker
exposures during handling, repackaging, and cleanup.  NRC officials
did not have any examples of such degradation, they said, because
extended on-site storage is a relatively new phenomenon. 

   Figure 4.5:  Degradation of
   Low-Level Waste Containers

   (See figure in printed
   edition.)

   Source:  DOE.

   (See figure in printed
   edition.)

Another of NRC's concerns is the possibility of increased radiation
exposure to workers from storage-related activities.  For example,
conducting routine radiation surveys and inspecting waste in storage
could add to workers' occupational doses of radiation.  Nuclear
utilities in Michigan, for example, indicated that technicians may
experience greater exposure levels due to the need to store larger
quantities of waste. 

In addition to NRC's concerns, some generators and state officials
said that there could be a greater risk of illegal dumping as the
amounts of waste in storage increase and storage capacity becomes
saturated.  For example, the officials said, NRC's regulations
permit, under certain conditions, users of radioactive materials to
dispose of wastes in sewage systems.  In the absence of access to
disposal facilities, these generators and officials said, waste
generators might dispose of waste in sewage systems in excess of the
limits that NRC permits.  In a 1980 report, we reported that the
abrupt closure of disposal facilities in 1979 might have led to some
illegal dumping.\2

Another concern among some generators is a possible reduction in
nuclear health care and medical research because of a lack of access
to disposal sites and storage capabilities.  For example,
Organizations United for Responsible Low-Level Radioactive Waste
Solutions\3 said that hospitals and clinics could be forced to stop
nuclear medicine procedures to diagnose heart disease, detect cancer,
or cure thyroid disease.  In some cases, the organization said that
physicians will choose other, less desirable, alternatives, such as
ultra-sound, rather than referring a patient to another hospital for
a nuclear medicine procedure.  The organization also said that
medical research on cancer, AIDS, Parkinson's disease, diabetes, and
other illnesses could suffer.  In 1993, the organization's chairman
expressed concern that small hospitals where research is conducted
could give up their nuclear departments and some therapy and research
suppliers could go out of business.\4


--------------------
\2 The Problem of Disposing of Nuclear Low-Level Waste:  Where Do We
Go From Here?  (EMD-80-68, Mar.  31, 1980). 

\3 A coalition of national organizations formed to achieve progress
in building new disposal facilities. 

\4 The chairman was also president of the American College of Nuclear
Physicians. 


      ALTERNATIVES MIGHT ALLEVIATE
      SOME OF THE STORAGE BURDEN
-------------------------------------------------------- Chapter 4:3.2

NRC's regulations permit alternatives to alleviate storage or
disposal for some commercially generated low-level waste.  Small
amounts of certain radioactive materials that are readily soluble or
dispersible in water, for example, can legally be disposed of in
sewer systems.  Some generators that had not been using this
alternative are now beginning to use it.  The radiation safety
officer at a hospital in California told us that the hospital began
the legal disposal of radionuclides in the sewage system for the
first time in 1993.  The radiation safety officer for a hospital in
Washington, D.C., told us that, when the District lost access to a
disposal facility in 1993, he encouraged a variety of efforts for
researchers at his institution, including legal sewage disposal. 
Furthermore, researchers at a medical college in New York have
designed a method to dissolve radioactive animal carcasses used in
medical research.  According to the researchers, using this chemical
process results in a solution that can then be disposed of into the
sewer within permissible levels of radiation. 

Others, however, have concerns about the increased disposal in sewage
systems.  Medical experts at some hospitals told us that they did not
believe that disposing of radioactive wastes in sewage systems within
legal limits is the best method of disposal.  They said that this
disposal method provides additional exposure to the public and,
although the amounts disposed of are within permissible levels, the
resulting exposure to the public is not as low as is reasonably
achievable by disposing of wastes in a land disposal facility. 
Furthermore, we recently reported that nine sewage treatment plants
were contaminated by radioactive materials appearing in the sewage
sludge, ash, and related by-products that are sometimes used for
agricultural and residential purposes, such as lawn and garden
fertilizer.\5 Officials at the affected plants said that they had
been unaware of the problem and had not tested for it.  The full
extent of the radioactive contamination at sewage treatment plants
across the country is unknown, in part, because NRC has inspected
only 15 of the approximately 1,110 NRC licensees that may discharge
radioactive material to treatment plants to determine if a
concentration problem exists.  Furthermore, NRC did not have
information on another approximately 2,000 licensees that discharge
radioactive materials into sewers because inspections of these
licensees are the responsibility of agreement states. 

Another alternative, treatment by on-site incineration, might be
attractive to waste generators for some waste if local opposition
were not an issue.  Local communities, however, may not always accept
incineration facilities, and some generators may be concerned about
taking possession of ash that contains radioactive elements from
other waste generators.  Some generators have used on-site
incinerators to reduce their waste, particularly biodegradable waste,
such as radioactive animal carcasses.  However, because of local
opposition, it may be difficult to build new incinerators or continue
using existing ones.  In 1984, for example, an engineering firm
canceled its plan to build a low-level waste incinerator in
Pennsylvania because of public opposition, and in 1994 the National
Institutes of Health closed an incinerator in Bethesda, Maryland,
because of public concern about emissions.  Officials of the
institutes said that the facility, which was used to burn medical
waste, including some radioactive waste, met all permitting
requirements, but they considered it more important to address the
public's concerns. 

The acting radiation safety officer for the institutes said that they
are considering using a waste processor's incinerator in Tennessee. 
Meanwhile radioactive animal carcasses are stored on-site in
freezers.  Although the Tennessee incinerator has been used by many
waste generators, few have used it for low-level biomedical waste. 
Some generators of biomedical waste have said that they are concerned
that their ash would be commingled inadvertently with that of others
and they would receive radionuclides not allowed in their licenses
when ash remaining from the burn is returned to them. 

Another alternative, decay in storage, is available to medical
licensees and others under certain conditions, including that
candidate radioactive wastes must have radioactive half-lives of less
than 65 days and that the waste generators must store the waste for a
period of time equal to 10 times the material's half-life.\6 Several
generators told us that this is a common practice; therefore, the
extent to which its use could increase is undetermined. 

Several waste processors said that new technologies for treating
waste may be developed if waste processors can find not only
technological solutions but also economic incentives to do so. 


--------------------
\5 Nuclear Regulation:  Action Needed to Control Radioactive
Contamination at Sewage Treatment Plants (GAO/RCED-94-133, May 18,
1994). 

\6 Half-life is the time required for a radioactive substance to lose
50 percent of its activity by decay.  In 10 half-lives, the waste has
lost enough radioactivity that it is no longer regulated. 


      LIMITED INFORMATION ON
      GENERATOR STORAGE CAPACITY
-------------------------------------------------------- Chapter 4:3.3

With disposal unavailable to most waste generators, storage of wastes
at generators' facilities is now increasing.  However, no information
is being collected on on-site storage of low-level waste on a
nationwide basis.  Although some individual state surveys have been
conducted on the storage capacity of the generators, the data are
inconsistent and therefore difficult to compare.  We identified and
reviewed surveys by five states on the storage of low-level
radioactive waste.  Because most of these surveys were completed
between 1992 and 1993, the information in them is somewhat dated. 
Overall, storage capacity varies significantly.  NRC and state
officials, as well as generators, agree that nuclear utilities would
generally have the most capability to store their waste and small
medical research facilities in urban areas would have the least
capability. 

Moreover, neither NRC nor DOE--the two federal agencies that could
provide a national perspective on low-level waste issues--currently
have plans to collect such data.  DOE officials said that the agency
lacks the necessary authority.  According to NRC officials, that
agency has considered both the cost to collect this data and the
potential usefulness of the data in its regulatory programs.  NRC has
concluded, the officials added, that collecting the data would be
costly and that the data would be of marginal value.  Without some
nationwide perspective on the status of on-site storage capacity and
the trends, it may be difficult to determine whether federal
agencies, like NRC and DOE which have some responsibilities in this
area, need to improve measures to protect the public health and
environment. 


CAUTION WARRANTED IN CONSIDERING
CHANGES TO THE EXISTING
STATE-COMPACT APPROACH
============================================================ Chapter 5

For reasons such as limited progress in developing new disposal
facilities and related economic and environmental concerns, questions
have been raised about the relative effectiveness of the current
approach and alternative approaches to managing commercially
generated low-level waste.  Alternatives include, among other things,
providing federal incentives or penalties to states, or making the
federal government or the private sector responsible for commercial
low-level waste disposal.  Alternative approaches, however, should be
viewed with caution.  Supporters of the current program believe that
exploring other approaches could undermine support for the
state-compact approach and the progress that many compacts and states
have made.  Furthermore, other approaches also appear to have similar
difficulties that states have encountered such as obtaining political
and public acceptance of disposal facilities. 


   STRONG SUPPORT FOR THE
   STATE-COMPACT APPROACH
---------------------------------------------------------- Chapter 5:1

States were instrumental in shifting responsibility for disposal of
commercially generated low-level waste from private industry to
compacts of states, because the states wanted control over the
selection of sites for disposal facilities.  After 14 years of
experience with the state-compact approach, states support continuing
the program and believe that they can be successful.  Other affected
parties, including some waste generators and developers/operators of
disposal facilities, agree and offer reasons to continue with this
approach. 

As discussed earlier, by 1978, three of the six disposal facilities
operated by private companies had been shut down.  That year,
President Carter established an interagency group to review the
entire U.S.  nuclear waste management program.  In its March 1979
report, the group recommended, among other things, that either
individual states or the federal government identify sites for
disposing of commercially generated low-level waste within the
framework of a national plan developed by, and agreeable to, federal
and state governments.\1 According to the group, states commenting on
a draft of its report generally supported development of a national
plan; however, some states took a strong position against the federal
government selecting sites for disposal facilities within their
jurisdictions.  Also, other states said that states should retain the
right, within the concept of a national plan, to veto the selection
of sites for disposal facilities within their jurisdictions. 

At about the time of the report, selecting sites for new disposal
facilities began to be seen as a state, rather than federal,
responsibility.  The governors of the three states with operating
disposal facilities--Nevada, South Carolina, and
Washington--testified to this effect before congressional committees. 
Also, officials in several states said that the political climate in
their states might prevent them from acting to solve the problem of
disposing of low-level waste; therefore, they said, developing new
disposal facilities might only be possible if responsibility for
selecting new sites is clearly fixed in law.  Other states, however,
wanted a federal solution because, in their view, public opinion
would probably impede states' unilateral efforts to establish
regional disposal facilities. 

In 1980, task forces formed by states and other organizations agreed
that a state-oriented solution was the best means of ensuring
development of new disposal capacity.  The task forces believed that
the states would be in a better position than the federal government
to protect their citizens' public health and safety.  For example,
the National Governors' Association task force on low-level
radioactive waste disposal issued a report in November 1980 that
stated, in part,

     "Since low-level waste is generated in every state, it is unfair
     to expect three states to shoulder the sole responsibility for
     the safe disposal of the entire nation's waste.  Unlike high
     level waste, the problem is not so technologically complex that
     it requires the leadership of the federal government to manage
     it effectively.  Because the states are primarily charged with
     protecting their citizens' health, safety, and environment, it
     is appropriate that they assume this responsibility.  In
     addition, the public is more likely to accept siting and other
     waste management decisions made by state government than by a
     more remote, less accessible federal agency."

In addition, task forces formed by the National Conference of State
Legislatures and the Conservation Foundation agreed with the National
Governors' Association position on state control over siting disposal
facilities for commercially generated low-level waste.  Finally, the
State Planning Council on Radioactive Waste Management, formed by the
President to review nuclear waste issues, recommended that every
state should be responsible for commercially generated low-level
waste and that states should be authorized to enter into interstate
compacts.  This broad support and the unanimous endorsement of the
National Governors' Association contributed significantly to
enactment of the Low-Level Radioactive Waste Policy Act of 1980. 

Despite what may be viewed as the slow pace of implementation of the
1980 act, as amended, state support for the disposal approach set out
in that legislation appears to continue.  For example, in October
1993, the Director, Natural Resources Group, National Governors'
Association, said that the majority of states prefer to keep the
current approach, because most states will not have to develop new
disposal facilities.  According to the director, alternatives to the
current approach would have to come from the states themselves.  The
director added that staffs of the National Governors' Association and
governors have raised the issue a few times in recent years; however,
they concluded that it would be unwise to reopen the act because they
are unsure of what would result.  Currently, the National Conference
of State Legislatures has a policy statement supporting the act, as
amended. 

Supporters of the state-compact approach maintain that most states
have pursued, either in compacts or on their own, development of
disposal facilities.  The supporters also believe the act is designed
to establish equity among states in handling the burden of waste
disposal, and they do not see other alternatives that would
accomplish this goal.  Moreover, the supporters question whether the
investments of states, developers, and waste generators would be
lost--more than $320 million in the last 14 years--and point out that
it would cost more time and effort to begin an alternative disposal
approach.  Furthermore, merely considering an alternative would,
according to the supporters, give reluctant states an opportunity for
further delay. 

Those who support the current approach to disposal of low-level waste
also said that more time is needed to show whether the approach can
be successful.  They point out that the strongest remaining incentive
for states to develop disposal facilities--loss of access to existing
facilities by waste generators--became effective only recently, after
existing disposal facilities closed to waste outside their regions. 
In addition, states have flexibility for further consolidation of
state-compacts, such as the Northwest Compact's arrangement to accept
waste generated within the Rocky Mountain Compact and the recent
formation of the proposed Texas-Maine-Vermont Compact. 


--------------------
\1 Report to the President by the Interagency Review Group on Nuclear
Waste Management, DOE (Mar.  1979.)


   OTHER APPROACHES TO MANAGING
   LOW-LEVEL WASTE HAVE DRAWBACKS
---------------------------------------------------------- Chapter 5:2

Representatives of some waste generators, states and state-compact
organizations, environmental groups, and state and federal regulatory
officials have expressed various degrees of dissatisfaction with
progress on the development of new facilities for disposing of
commercially generated low-level waste.  Some of these officials
suggested alternative approaches to managing or disposing of wastes;
however, none had provided extensive analysis to show that the
alternative could be more successful than the current approach.  On
the basis of our discussions with these parties and our collection
and analysis of data related to management and disposal of low-level
waste, we identified and analyzed the following general alternative
approaches to management and disposal of commercially generated
low-level waste: 

  Modifying the state-compact approach by adding penalties and/or
     incentives to encourage timely development of new disposal
     facilities. 

  Transferring responsibility for disposing of all or certain
     categories of low-level waste from states to the federal
     government. 

  Returning the responsibility for disposing of low-level waste to
     private industry. 

  Adopting alternatives to land disposal in the United States, such
     as storing waste; substituting shorter-lived radioactive
     materials or nonradioactive materials for radioactive materials,
     or banning the use of radioactive materials; and exporting
     low-level waste to other countries for disposal or disposing of
     waste in the oceans. 

Although some of these alternatives have precedents, each appears to
have drawbacks that could limit its effectiveness. 

Still other representatives and officials advocate studying the
management of commercially generated low-level waste and other types
of nuclear waste on a comprehensive basis as a first step to
determining if changes are needed in existing waste management
legislation.  In a bipartisan effort in 1994, 12 Senators, 27
Representatives, and numerous environmental groups separately asked
the President for an independent, comprehensive review of the
nation's nuclear waste programs, including commercially generated
low-level waste.  In their letters to the President, the proponents
of an independent review asserted that nuclear waste has historically
been addressed not on its hazardous nature or length of life, but by
other, nonscientific delineations, such as the sources of the waste. 
The proponents believe that the country's nuclear waste programs deal
with waste issues in a piecemeal fashion, and an integrated program
would presumably be safer and more cost-effective.  Such a review,
they suggest, should examine technical, managerial, and policy issues
that make the nuclear waste problem so complex. 


      ADDING INCENTIVES OR
      PENALTIES
-------------------------------------------------------- Chapter 5:2.1

One alternative approach to achieving the objectives in the low-level
waste act is for the federal government to provide states with
incentives, such as federal funding, to encourage progress, or to
penalize states' lack of progress by withholding federal funds. 
Those proponents who suggested federal funds to assist the states,
however, did not provide specifics on how such funds would improve
states' programs to develop disposal facilities or how the funds
would be made available. 

Other proponents have suggested financial penalties, such as
withholding funds to states that do not make measurable progress in
developing new disposal facilities.  The Low-Level Radioactive Waste
Policy Act, as amended, tried this approach to a limited degree.  The
act required states to meet a series of milestones that would lead to
the development of new disposal facilities by January 1, 1993.  If a
state did not meet a milestone, penalties included payment by waste
generators within the state of a non-refundable surcharge and/or loss
of rebates to states from an escrow account, managed by DOE and
accrued from waste generators.  From 1986 to 1992, DOE collected
about $37 million in the escrow account.  In 1993, DOE disbursed $26
million to states, including the final payment of $11 million to all
but the 5 states without plans for future access to disposal
facilities.  The remaining $11 million will be returned to waste
generators because the states and compacts did not provide any new
disposal facilities by the January 1, 1993, deadline. 

Assuming that states are in strict control of their siting efforts,
financial incentives or penalites might have some impact.  However,
the process of selecting a site and developing a disposal facility is
complex, controversial and, therefore, may be beyond a state's
ability to strictly control in all cases.  Since the surcharges have
ended, the possibility has also been suggested that the federal
government could withhold other federal funds, such as transportation
funds, if states do not meet predetermined deadlines.  Those
proponents who have suggested this approach, however, have not
addressed questions about equity and the effects that such an
approach would have on programs for which the funds are typically
provided. 


      TRANSFERRING RESPONSIBILITY
      TO THE FEDERAL GOVERNMENT
-------------------------------------------------------- Chapter 5:2.2

Some supporters have suggested making the federal government
(probably DOE) responsible for disposing of commercially generated
low-level waste.  First, there are precedents for the approach--DOE
has been given responsibility for disposing of spent fuel from
civilian nuclear power plants and the most radioactive class of
commercially generated low-level waste.  Second, this approach could
permit selection nationwide of sites for new disposal facilities
having superior geologic and technical qualifications rather than
relying on qualified, but not necessarily outstanding, sites within
many states.  Third, federal sites might create less public
opposition if all the waste is concentrated at remote locations. 
Last, the waste might be disposed of at one or more federal
reservations that are already too badly contaminated to restore to
unrestricted use.  For example, some supporters suggested
establishing regional collection and processing centers for low-level
waste with disposal of the waste on federal lands that are dedicated
to perpetual care, such as portions of DOE's Nevada Test Site,
because of radioactive contamination.  This alternative, according to
its advocates, would spare uncontaminated public lands. 

At first glance, federal responsibility for disposing of commercially
generated low-level waste may appear attractive because of the
existing precedents and the potential for disposing of this waste at
already contaminated federal facilities.\2 Indeed, the Nuclear Waste
Policy Act of 1982 assigned DOE responsibility for developing one or
more geologic repositories for permanent disposal of spent fuel from
civilian nuclear power plants and other highly radioactive waste. 
Moreover, amendments to that act in 1987 directed DOE to investigate
one site--Yucca Mountain, Nevada--as a candidate site for a
repository.  If, after investigating that site, DOE determines that
the site is suitable for a repository, it must recommend approval of
the site to the President.  Thus, in the Nuclear Waste Policy Act, as
amended, the Congress directed that the site at Yucca Mountain be
investigated for possible use as a site for a repository and
established procedures for making a political decision on selecting
the site following a technical determination on the suitability of
the site. 

However, establishing a similar method for federal disposal of
commercially generated low-level waste may be more difficult for
several reasons.  First, as recognized by the task force of the
National Governors' Association, disposal of commercially generated
low-level waste is not so technologically complex that it requires
federal management.  Second, states with substantial federal lands
have opposed efforts to place waste disposal facilities within their
borders.  In 1991, 21 western governors said that the west had
assumed a large part of the national waste management burden.  The
governors pointed out that a western state is the host to DOE's Waste
Isolation Pilot Plant, which is a proposed repository for disposal of
DOE's transuranic waste,\3 and the candidate repository site at Yucca
Mountain.  Also, at the time of the governors' statement, two of the
three existing facilities for disposing of commercially generated
low-level waste were located in the west.  According to the
governors, the west has been asked to shoulder a large part of the
national waste burden, because of the region's geology, rainfall, and
settlement patterns, while its environment and natural resources have
been the lifeblood of the region.  The governors said that the west
should not sacrifice its environment to subsidize inadequate waste
management practices in other parts of the country. 

Third, it is unclear that the federal government could be more
successful than states in obtaining public acceptance of new waste
disposal sites.  When states sought responsibility for developing
facilities for disposing of low-level waste, they argued that they
could meet the needs and concerns of their citizens better than the
federal government.  States said that federal control over the
selection of sites for disposal facilities would be more difficult
because of longstanding public distrust of federal nuclear waste
activities.  More recently, the Task Force on Radioactive Waste
Management established by the Secretary of Energy Advisory Board
concluded that, despite some progress, there continues to be
widespread lack of trust in DOE's radioactive waste management
activities.\4 On a pragmatic level, the task force said that public
trust and confidence is generally essential for agencies to
effectively carry out their missions. 

The 1985 amendments to the low-level waste act made DOE responsible
for disposing of the most hazardous class of commercially generated
low-level waste.  Thus, a modified method of placing disposal
responsibility in the federal government is to make DOE responsible
for disposing of still other, relatively hazardous, classes of
low-level waste.  The argument for this more modest federal
assumption of disposal responsibility is that states might then find
it easier to develop facilities for disposing of low-level waste that
is relatively less hazardous.  For example, the Illinois commission's
decision in 1993 to reject a site for a disposal facility was, in
part, based on the commission's uncertainty over whether the proposed
engineered facility would contain the long-lived waste that would
have been disposed of in the proposed facility for the period of
time--up to 500 years--that it would take for those radioactive
materials to decay.  On the other hand, federal assumption of
responsibility for disposing of more commercially generated low-level
waste would require the federal government to find a disposal
solution for this waste and would not relieve the states of the need
to develop facilities for disposing of the relatively large-volume
classes of low-level waste with less concentrated long-lived
materials. 

For several years, the possibility that DOE would treat and dispose
of mixed waste--low-level radioactive waste mixed with hazardous
materials--has been under consideration.  In November 1990, the
Low-Level Radioactive Waste Forum requested that DOE explore this
possibility.  Although DOE has not made a decision on this request,
in October 1994, DOE's Assistant Secretary for Environmental
Management said that the agency, in consultation with states, would
consider incorporating disposal of commercially generated mixed waste
into plans that DOE is preparing for managing mixed wastes located at
its nuclear facilities.\5


--------------------
\2 In 1992, for example, DOE disposed of its own low-level waste at
its facilities in an amount about equal to 84 percent of all
commercially generated low-level waste.  The amount of low-level
waste that DOE generates and disposes of may increase in the future
as a result of its ongoing efforts to clean up its nuclear
facilities. 

\3 Transuranic waste is discarded material (machinery, tools,
filters, rubber gloves, paper, rags, sheet metal, glassware, and
sludge from the reprocessing of nuclear fuels) contaminated with
man-made radioactive elements having atomic numbers greater than
uranium.  The waste by-products of defense activities, such as
plutonium, decay slowly and remain radioactive for thousands of
years. 

\4 Earning Public Trust and Confidence:  Requisites for Managing
Radioactive Wastes (Final Report of the Secretary of Energy Advisory
Board Task Force on Radioactive Waste Management, Nov.  1993). 

\5 Under the Federal Facility Compliance Act of 1992, by October 1995
DOE is required to submit plans for treating mixed waste at its
facilities to EPA or authorized host states, obtain the states' or
EPA's approval of the treatment plans, and enter into orders
requiring its compliance with the approved plans. 


      INCREASED PRIVATE SECTOR
      RESPONSIBILITY
-------------------------------------------------------- Chapter 5:2.3

Another alternative is increasing the private sector's responsibility
for developing and operating disposal facilities similar to the role
the private sector had previously.  Before the Low-Level Waste Policy
Act of 1980 was enacted, the private sector had developed, owned, and
operated disposal facilities regulated by the states or NRC. 
However, environmental problems occurred at some facilities, and
states in which some of these facilities were located opposed the use
of these facilities by waste generators nationwide.  For these and
other reasons, states concluded that they could best control their
own destinies by forming compacts and assuming responsibility for
developing disposal facilities. 

Private-sector responsibility for developing, owning, and operating
disposal facilities for commercially generated low-level waste would
be consistent with the role of the private sector in disposing of
other waste materials, such as solid and hazardous wastes.  Moreover,
states' previous environmental concerns may have been addressed, to
some extent, by NRC's issuance in 1982 of regulations governing
development of disposal facilities.  Finally, there is a recent
precedent for private sector development of a low-level waste
disposal facility.  In 1988, the state of Utah, which belongs to the
Northwest Compact, authorized a private company to develop and
operate a disposal facility for certain kinds of high-volume,
low-radioactivity low-level waste.  The facility has since received
licenses and permits required for the disposal of these wastes and
operates under a resolution passed by the Northwest Compact. 
According to NRC officials, this facility does not accept routine
operating waste from utilities.  Moreover, the officials said that
the bulk wastes that the facility does accept will not be accepted at
most of the disposal facilities that states are developing. 

For at least two reasons, however, having the private sector develop
and operate disposal facilities does not appear to be a favorable
alternative.  First, that approach would end states' ability,
provided by the compact approach of the 1980 act, as amended, to
restrict access to disposal facilities located within their borders
to waste generators within the compact in which the state is a
member.  Second, finding a site for and developing a disposal
facility appears to be at least as difficult as it was before the act
was passed. 


      OTHER ALTERNATIVES
-------------------------------------------------------- Chapter 5:2.4

Several other alternatives--from temporary storage to a ban on the
commercial uses of radioactive materials--have also been offered. 
Critics of states' selections of candidate sites for disposal
facilities, for example, have suggested that utilities store the
low-level waste generated by operation of nuclear power plants at
these plants and that all other low-level waste either be stored at
nuclear power plants or some other central storage facility.  Several
states, including Connecticut, Illinois, Massachusetts, and New York,
are considering such approaches, but none have adopted them. 

There are, however, several potential problems with the storage
approach: 

  If medical and academic waste generators must pay for a centralized
     facility solely for their waste, they may, when possible, opt
     for less costly treatment or storage alternatives. 

  Finding a central storage site could be as difficult as finding and
     developing a disposal site and facility if local residents do
     not perceive that a storage facility poses less risk to them
     than a disposal facility.  Earlier experience with the concept
     of a central facility for storing spent fuel illustrates this
     potential problem.  In that case, some state, local, and
     environmental groups opposed DOE's plans to construct a storage
     facility because of concerns that the facility could become a
     facility for permanent storage of the spent fuel. 

  A state with a centralized storage facility might not be able to
     prevent waste generators in other states from shipping their
     wastes to the central storage facility. 

  Because some of the stored low-level waste would probably be
     hazardous for more than 100 years, disposal, rather than
     temporary storage, would eventually be required. 

Because of the long half-lives of some radioactive materials that
become low-level waste, some critics of current state efforts to
develop disposal facilities have suggested that commercial firms
substitute shorter-lived materials that can be stored until they
decay to a harmless level and/or recycle the longer-lived materials. 
According to researchers in the medical and biotechnology community,
however, the use of shorter-lived materials are not always an option
in their research. 

Representatives of some environmental groups have also recommended a
moratorium on the generation of low-level waste until they are
assured that the waste will be permanently managed in an
environmentally sound manner.  Such an approach would require a
serious examination of the tradeoffs in reduced risk from nuclear
waste compared to the reduced benefits from nuclear materials in
society.  For example, a moratorium might diminish the ability to
conduct biomedical research.  Adopting a moratorium would, in effect,
require repealing the current policy--established in the Atomic
Energy Act of 1954, as amended--of encouraging peaceful uses of
atomic energy. 

Finally, two alternatives that would result in the disposal of
low-level waste outside the United States have been suggested.  One
such approach is shipping waste to another country.  NRC has
developed a proposed rule on licensing imports and exports of
low-level waste for disposal.  In commenting on the proposed rule,
some state officials said that they are concerned that the rule might
encourage waste exports at the expense of new domestic disposal
facilities, and others did not see the need for the proposed rule in
their states because waste could not move out of their compacts
without their approval.  Also, current international agreements
discourage or prohibit this practice.  All nations are required to do
their best to ensure that nuclear waste is not exported unless the
sending and receiving nation approves and the parties agree it is in
their best interests.  A return to the earlier practice of dumping
low-level waste in the Atlantic and/or Pacific Oceans is also an
alternative.  However, the Congress, in 1982, essentially banned
ocean disposal, except for research purposes and, in November 1993,
the United States was among the signatories to an international
agreement banning ocean disposal of radioactive waste for at least 25
years. 


STUDIES THAT EXAMINE ECONOMIC
ASPECTS OF LOW-LEVEL RADIOACTIVE
WASTE FACILITIES
=========================================================== Appendix I

1.  "Conceptual Design Report--Alternative Concepts for Low-Level
Radioactive Waste Disposal," prepared for EG&G Idaho, Inc., and the
Department of Energy (DOE) by Rogers and Associates Engineering
Corporation, (DOE/LAW-60T, June 1987). 

The report was provided by DOE's Nuclear Energy Low-Level Waste
Management Program to assist states and compact regions in developing
new low-level rad waste disposal facilities in accord with the
Low-Level Waste Policy Amendments Act of 1985.  The report provides
conceptual designs and evaluation of six widely considered concepts
for disposal.  Among other things, costs were estimated for the
preoperational, operational, closure, and institutional control
periods of each facility's life cycle. 

2.  "Projected Costs and User Fees for Small-Volume Low-Level
Radioactive Waste Disposal Facilities," by EG&G Idaho, Inc., for DOE,
(DOE/LAW-91, 1991). 

The report determines projected life-cycle costs and average user
fees for low-level radioactive waste disposal facilities ranging in
size between 10,000 and 60,000 cubic feet per year.  These projected
costs and fees are based on the life-cycle costs developed for a
235,000 cubic feet per-year facilities by the Conceptual Design
Report--Alternative Concepts for Low-Level Radioactive Waste
Disposal.  Two computer models were used to project the life-cycle
costs and user fees found in the report. 

3.  "Designs and Costs of Low-Level Waste Disposal Facilities" (EPRI,
Aug.  1987, Interim Report). 

The Electric Power Research Institute commissioned a project to
investigate important aspects of several generic low-level
radioactive waste disposal technologies.  Among other things,
disposal cost estimates for six generic disposal technologies are
presented. 

4.  Automated Pricing Schedule, "National Low-Level Waste Management
Program by EG&G Idaho, Inc.  (DOE/LLW-97, May 1993). 

The automated pricing schedule is an interactive computer model for
evaluating the economics of developing, operating, and closing a
low-level radioactive waste disposal site. 

5.  "Economics of a Small-Volume Low-Level Radioactive Waste Disposal
Facility" for DOE by Dames and Moore (Jan.  14, 1993). 

This report presents the results of a life-cycle cost analysis of a
low-level waste disposal facility, including all support facilities,
beginning in the pre-operational phase and continuing though
post-closure care.  The disposal technology selected for this report
is earth covered, concrete vaults, which use reinforced concrete
vault constructed above-grade and an earth cover constructed at the
end of the operational period for permanent closure. 

6.  "LLRW Disposal:  Economies of Scale and Waste-Type Segregation"
by Clark W.  Bullard and Hans T.  Weger in Energy Systems and Policy,
Vol.  14., pp.  227-236, (1990). 

The article examines the underlying cost structure of an advanced
low-level radioactive waste disposal technology that is typical of
those being designed for most states and compacts.  The article
includes concrete canisters placed in an above-ground, earth-mounded
concrete vault.  Among other things, the article discusses the issue
of consolidating sites by examining the relative magnitude of the
fixed and variable costs. 

7.  "The Failure of `Equity, Then Efficiency':  U.S.  Policy on
Low-Level Radioactive Waste Disposal," Dennis Coates, Victoria Heid,
and Michael Munger (June 1, 1992, revised Dec.  15, 1992). 

The paper was prepared by an assistant professor in the Department of
Economics, a graduate student in the MPA-Public Policy Analysis
program, and an associate professor in the Department of Political
Science at the University of North Carolina-Chapel Hill.  This paper
reviews the "equity" and "efficiency" issues related to low-level
radioactive waste disposal policies and presents preliminary
estimates of the "efficient" number of facilities for the disposal of
the nation's low-level radioactive waste. 


RADIATION RISK RELATED TO NRC'S
STANDARD FOR LOW-LEVEL WASTE
DISPOSAL AND EPA'S CONCERN ABOUT
THE STANDARD
========================================================== Appendix II

The Nuclear Regulatory Commission's (NRC) licensing requirements for
land disposal of low-level waste state that concentrations of
radioactive material that may be released to the general environment
must not result in an annual dose exceeding an equivalent of 25
millirems\1 to the whole body of any member of the public.  That
dose, we estimate, could result in an estimated lifetime risk of
premature cancer death of 1 in 1,000.\2 In comparing 26 federal
standards or guidelines on public radiation exposure, the low-level
waste standard was one of the lower ones.  The estimated lifetime
risk of premature cancer death ranged from 1 in 40 (the Environmental
Protection Agency's (EPA) Superfund cleanup standard) for EPA's
indoor radon guidance to a risk goal range of 1 in 15,000 to 1 in 1.5
million. 

The radiation standards that have been developed for various purposes
reflect a lack of overall interagency consensus on how much radiation
risk to the public is acceptable.  Because the standards have
different regulatory applications and are based on different
technical methodologies, the estimated risks to the public that are
associated with these standards and guidelines vary considerably.\3

Regarding low-level waste standards, NRC has established licensing
requirements for land disposal of low-level waste, but EPA is
responsible for establishing general criteria and numerical standards
applicable to nuclear waste management activities.  EPA has not
completed the standards for a number of reasons.\4 The standards are
being re-drafted, and EPA was seeking public comments through April
12, 1995, on a published, preproposal draft.  Afterwards, EPA will
follow its internal clearance process and seek review from other
federal agencies before publishing proposed standards in the Federal
Register for formal comment.  In an October 1994 letter, EPA's
Director, Office of Radiation and Indoor Air, told NRC's Director,
Office of Nuclear Material Safety and Safeguards, that there is a
significant gap in NRC's regulations for low-level waste disposal. 
The EPA official said that the issue must be addressed for EPA to
conclude that NRC regulations provide a sufficient level of
protection of public health and the environment.  The Director said
that NRC's regulation does not specifically address groundwater
protection and could allow a disposal facility to cause radioactive
contamination of groundwater to levels that would require treatment
before it could be used as drinking water.  Thus, EPA said that NRC's
regulation is inconsistent with EPA's groundwater protection policy
which says that maximum contaminant limits under the Safe Drinking
Water Act shall be used as reference points for water resource
protection efforts when the groundwater in question is a potential
source of drinking water. 


--------------------
\1 The standard also refers to annual limits of 75 millirems to the
thyroid and 25 millirems to any other organ of any member of the
public. 

\2 The estimated risk is derived from commonly used assumptions,
e.g., a cancer death risk of 5x10\-4 per rem to an individual
continuously exposed over a 70-year lifetime. 

\3 Nuclear Health and Safety:  Consensus on Acceptable Radiation Risk
to the Public is Lacking (GAO/RCED-94-190, Sept.  1994). 

\4 Radioactive Waste:  EPA Standards Delayed by Low Priority and
Coordination Problems, (GAO/RCED-93-126, June 1993)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Bernice Steinhardt, Associate Director
Dwayne E.  Weigel, Assistant Director
Mehrzad Nadji, Assistant Director
Daniel J.  Semick, Evaluator-in-Charge
Thomas H.  Black, Senior Evaluator
Cassandra D.  Joseph, Senior Evaluator

OFFICE OF GENERAL COUNSEL

Susan W.  Irwin, Staff Attorney





RELATED GAO PRODUCTS
============================================================ Chapter 1

Nuclear Waste:  Connecticut's First Site Selection Process for a
Disposal Facility (GAO/RCED-93-81, Apr.  5, 1993). 

Nuclear Waste:  New York's Adherence to Site Selection Procedures Is
Unclear (GAO/RCED-92-172, Aug.  11, 1992). 

Nuclear Waste:  Slow Progress Developing Low-Level Radioactive Waste
Disposal Facilities (GAO/RCED-92-61, Jan.  10, 1992). 

Nuclear Waste:  Extensive Process to Site Low-Level Waste Disposal
Facility in Nebraska (GAO/RCED-91-149, July 5, 1991). 

Energy Reports and Testimony:  1990 (GAO/RCED-91-84, Jan.  1991). 

Energy:  Bibliography of GAO Products January 1986-1990
(GAO/RCED-90-179, July 1990). 

Nuclear Regulation:  The Military Would Benefit From a Comprehensive
Waste Disposal Program (GAO/RCED-90-96, Mar.  23, 1990). 
